ML23264A864
| ML23264A864 | |
| Person / Time | |
|---|---|
| Issue date: | 09/06/2023 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2526 | |
| Download: ML23264A864 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Docket Number: (n/a)
Location: teleconference Date: Wednesday, September 6, 2023 Work Order No.: NRC-2526 Pages 1-178 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 708TH MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 WEDNESDAY 9 SEPTEMBER 6, 2023 10 + + + + +
11 The Advisory Committee met via 12 teleconference at 8:30 a.m., Joy L. Rempe, Chairman, 13 presiding.
14 15 COMMITTEE MEMBERS:
16 JOY L. REMPE, Chairman 17 WALTER L. KIRCHNER, Vice Chairman 18 DAVID A. PETTI, Member-at-Large 19 RONALD G. BALLINGER, Member 20 VICKI M. BIER, Member 21 CHARLES H. BROWN, JR., Member 22 VESNA B. DIMITRIJEVIC, Member 23 GREGORY H. HALNON, Member 24 JOSE A. MARCH-LEUBA, Member 25 ROBERT MARTIN, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
2 1 THOMAS ROBERTS, Member 2 MATTHEW W. SUNSERI, Member 3
4 5 ACRS CONSULTANTS:
6 DENNIS BLEY 7 STEPHEN SCHULTZ 8
9 DESIGNATED FEDERAL OFFICIAL:
10 WEIDONG WANG 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 1 C-O-N-T-E-N-T-S 2 Opening Remarks by the ACRS Chairman . . . . . . 4 3 Revision of Regulatory Guide (RG) 1.183, 4 "Alternative Radiological Source Terms for 5 Evaluating Design Basis Accidents at Nuclear 6 Power Reactors" . . . . . . . . . . . . . . . . . 4 7 Saint Lucie Subsequent License Renewal 8 Application Review . . . . . . . . . . . . . . 109 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 1 P-R-O-C-E-E-D-I-N-G-S 2 8:30 a.m.
3 CHAIRMAN REMPE: This is the first day of 4 the 708th meeting of the Advisory Committee on Reactor 5 Safeguards.
6 I'm Joy Rempe, Chairman of the ACRS.
7 Other members in attendance are Ron Ballinger, Vicki 8 Bier, Charles Brown, Vesna Dimitrijevic, Greg Halnon, 9 Walt Kirchner, Jose March-Leuba, Robert Martin, Dave 10 Petti, Thomas Roberts, and Matt Sunseri.
11 I note we do have a quorum. Today, the 12 Committee is meeting in-person and virtually.
13 The ACRS was established by the Atomic 14 Energy Act and is governed by the Federal Advisory 15 Committee Act. The ACRS section of the U.S. NRC 16 public website provides information about the history 17 of this Committee and documents, such as our charter, 18 bylaws, Federal Register Notices for meetings, letter 19 reports, and transcripts of all full and subcommittee 20 meetings, including all slides presented at the 21 meetings.
22 The Committee provides it advice on safety 23 matters to the Commission through its publically 24 available letter reports.
25 The Federal Register Notice announcing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 1 this meeting was published on August 17, 2023. This 2 announce provided a meeting agenda as well as 3 instructions for interested parties to submit written 4 documents or request opportunities to address the 5 Committee.
6 The Designated Federal Officer for today's 7 meeting is Mr. Weidong Wang.
8 A communications channel has been opened 9 to allow members of the public to monitor the open 10 portions of the meeting. The ACRS invites members of 11 the public to use the MS Teams link to view slides and 12 other discussion materials during these open sessions.
13 The MS Teams link information was placed in the 14 Federal Register Notice and agenda on the ACRS public 15 website.
16 We've been notified that representatives 17 of Integrated Nuclear Solutions, LLC, and NEI have 18 requested to make oral statements during one of 19 today's sessions.
20 Periodically, the meeting will also be 21 opened to accepted comments from participants 22 listening to our meetings. Written comments may be 23 forwarded to Mr. Weidong Wang, today's CFO, or 24 Designated Federal Official -- Officer.
25 During today's meeting, the Committee will NEAL 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 1 consider the following topics. Revision of Reg Guide 2 1.183, Alternative Radiological Source Terms for 3 Evaluating Design Basis Accidents. St. Lucie 4 Subsequent License Renewal Application.
5 Although the agenda states that the topic, 6 Pressurized Water Reactors Owners Group Topical Report 7 on Hydrogen-Based Transient Clad Strain Limit will be 8 discussed at 4:00 p.m., ACRS will continue with report 9 writing at this time.
10 At the end of the August 24th Subcommittee 11 on the PW Owners Group Topical Report, it was 12 recommended that the Committee should consider whether 13 a letter is needed.
14 Stakeholders interested in hearing a 15 discussing regarding this topic may listen to the 16 planning procedures portion of our meeting on Friday 17 morning when this topic will be addressed.
18 Note the portions of the sessions for the 19 ACRS meeting was on the agenda, there is a transcript 20 of the open portions of the meetings is being kept and 21 is requested that speakers identify themselves and 22 speak with sufficient clarity and volume so they can 23 be readily heard.
24 Additionally, participants should mute 25 themselves when not speaking.
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7 1 So, at this time, I'd like to ask other 2 members if they have any opening remarks.
3 Not seeing anyone, I'd then like to ask 4 Dave Petti to lead us in our first topic for today's 5 meeting.
6 MEMBER PETTI: Okay -- yes, I've unmuted 7 myself so hopefully everybody can hear.
8 Today, we're going to talk about Reg Guide 9 1.183 which, if you recall, we met on this quite a 10 while ago, back in 2022, I think, and maybe even in 11 2021. It's getting kind of long to remember the 12 history. But, given everything we have, the tight 13 schedule, and our audio difficulties, let's just get 14 into it and start with Mike Franovich to provide some 15 opening remarks.
16 Mike?
17 MR. FRANOVICH: Good morning, I see you 18 all have the same lights and tones as we have in the 19 main office over on 100 White Flint. Hopefully, 20 people online can hear me.
21 I do want to thank Chairman Petti and the 22 Committee and Chairman Rempe to make the time for us 23 today.
24 I do have some good news for you. We will 25 not be presenting on Part 53. So, you do get a break NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 1 from us. But I'd also like to say on behalf of the 2 NRR executive leadership, I want to acknowledge the 3 tremendous flexibility the ACRS has shown to 4 accommodate shifting priorities among NRC rule makings 5 and licensing activities.
6 Specifically, many of these activities 7 center on rapidly enabling the use of advanced 8 technologies. Strong congressional bipartisan 9 interest, industry, and may other stakeholders have 10 made it abundantly clear that the NRC must meet this 11 challenge. And such circumstances pose signification 12 enterprise risk for our Agency while maintaining 13 safety.
14 An important step forward to meet the 15 moment is finalizing an important revision to the 16 Agency's regulatory guidance pertinent to advanced 17 fuels, what we'll say in short is Revision 1 or Reg 18 Guide 1.183 today.
19 The guide and public comment disposition 20 document were made publically available on the 31st of 21 August in support of today's meeting.
22 As a reminder, the staff had planned on a 23 phased approach to update guidance with a second 24 revision in the works.
25 The staff has been actively working on a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 1 future, quote, Revision 2 to address fuel burn up 2 levels up to 80 gigawatt tons -- gigawatt days per ton 3 in support of the Commission's high priority increased 4 enrichment rule making and other matters such as 5 guidance on BWR suppression pool scrubbing credit.
6 Today's discussions will center around the 7 content of the Reg Guide and changes since issuance of 8 Rev 0 in the year 2000.
9 A nearly quarter-century journey has been 10 enriched by licensing experiences, technical 11 advancements, and modeling severe accident 12 progression, development of updated containment source 13 terms, and use of modern consequence analysis and 14 techniques.
15 It is a history ripe with strong opinions 16 and strong views on how to best achieve reasonable 17 assurance of safety without creating unnecessary 18 conservatism. I am grateful and very proud of our 19 multidisciplinary team delivering -- diligently 20 delivering a guide that is of very high quality.
21 It is important to note that this guide 22 provides regulatory certainty to licensees of methods 23 the NRC staff considers acceptable for design basis 24 accident dose consequence analysis using what's called 25 the alternative source term.
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10 1 During the development and revision alone, 2 we have embraced a regulatory transformation.
3 Transformation is an unending process, not a once in 4 a lifetime experience, although sometimes it may feel 5 that way.
6 As such, we are a learning organization, 7 adaptively and creatively improving our efficiency and 8 reliability as regulators.
9 The key theme under riding our work is 10 applying the Commission's direction and use integrated 11 decision making principles.
12 Those principles include defense in depth 13 safety margins, risk insights, and use of engineering 14 insights as well. But also, have a disciplined 15 adherence to the back fit and forward fit requirements 16 of the Agency.
17 Rev 1 and the guide which was termed DC-18 1389 was issued for public comment in August -- in 19 April of 2022. So, it's been a little over a year.
20 Today, we will go over the comment 21 disposition from the public comments we received, 22 which is approximately 168 public comments.
23 We'll focus on the more substantive 24 comments.
25 I'd also like to mention that you will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 1 hearing from two staff members who have differing 2 views on the potential implications of the decision on 3 a plant-specific licensing action associated with MSIV 4 leakage.
5 This is a complex subject and it is not 6 unexpected to have differing views.
7 The EDO, Executive Director for 8 Operations, rendered a decision on the differing 9 professional opinion, the DPO, appeal on August 25th 10 of 2023.
11 This discussion will occur after the main 12 discussion regarding Reg Guide 1.183 Revision 1.
13 Of note, the ACRS members with a need to 14 know where provided with a copy of the DPO case file 15 last week following established Agency processes.
16 The staff are currently conducting 17 appropriate redactions of the case file and expect to 18 make the case file publically available in the near 19 term.
20 That said, I will turn the presentation 21 over to Mark Blumberg, Senior Reactor Engineer and 22 Irradiation Protection and Consequence Branch in my 23 division, the Division of Risk Assessment in the 24 Office of Nuclear Reactor Regulations.
25 Mark, I turn it over to you.
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12 1 MR. BLUMBERG: Thank you very much for 2 that introduction, Mike.
3 I'd like to tell you the Reg Guide Working 4 Group is pleased to present to you a summary of our 5 work on Reg Guide 1.183 today.
6 We are grateful for the time we have today 7 to provide additional information for the ACRS review 8 of the draft final Reg Guide.
9 Joseph Messina and I will lead this 10 presentation and we will call upon other working group 11 members as the need may arise do discuss specific 12 issues.
13 I'd like to start with the discussion of 14 our agenda. So, please go to slide two.
15 We'll start the presentation with some key 16 messages for our presentation.
17 Then, review the purpose of Reg Guide 18 1.183 and the associated regulatory requirements.
19 Next, we will discuss the changes to the 20 guidance since the last time the ACRS was asked to 21 review it.
22 Lastly, we will conclude by providing a 23 summary of our presentation.
24 We will also provide a look forward 25 regarding our intentions for further revisions to Reg NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 1 Guide 1.183.
2 Please go to slide three.
3 Before we get into the heart of our 4 presentation, we'd like to acknowledge the 17 working 5 group and steering committee members.
6 We coordinated the proposed changes across 7 the management and the staff of multiple organizations 8 within the NRC.
9 Our steering committee is comprised of 10 four division directors from the Office of Nuclear 11 Reactor Regulation and the Office of Nuclear Reactor 12 Research.
13 Similarly, the working group is comprised 14 of staff from within these two offices and the Office 15 of General Counsel.
16 This steering committee and the working 17 group provided diversity, coordination, and checks and 18 balances of the regulatory guide revision among 19 subject matter experts within the NRC.
20 Please go to slide four that introduces 21 our key messages.
22 Slide four please? And then, to slide 23 five?
24 We have four key messages for this 25 presentation.
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14 1 First, DG-1389 was issued as a draft for 2 public comment in April of 2022.
3 Second, the ACRS and stakeholder 4 involvement on the revision to Reg Guide 1.138 began 5 prior to 2009, when an initial draft was issued for 6 public comments.
7 Recent development of the guidance 8 involved numerous public workshops and a meeting with 9 the ACRS Subcommittee prior to issuing DG -1389.
10 The third key message is that the working 11 group, in coordination with the steering committee, 12 had prepared responses to the public comments and 13 updated the Reg Guide based upon these comments.
14 We obtained internal concurrences, and the 15 OGC, no legal objection of these -- on these documents 16 and is providing the ACRS an opportunity to review the 17 draft final version of the guidance before we publish 18 it.
19 Lastly, although the disposition of 163 20 public comments required significant and detailed 21 responses, the changes to DG-1389 in response to these 22 comments were minimal because the DG-1389 guidance 23 continues to be appropriate and defensible.
24 Please go to slide six. That introduces 25 our discussion on Reg Guide 1.183's purpose and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 1 associated regulatory requirements.
2 And then, go to slide five.
3 I'm sorry, this is slide seven.
4 Reg Guide 1.183 Revision 0 was issued --
5 MEMBER SUNSERI: Mark, this is ACRS, can 6 we interrupt for a second?
7 MR. BLUMBERG: Yes, sir.
8 MEMBER SUNSERI: I have a question.
9 CHAIRMAN REMPE: Okay, can you hear me, 10 Mark, or do I need to get closer to --
11 MR. BLUMBERG: Yes, Joy, I can hear you.
12 CHAIRMAN REMPE: Okay.
13 I had a question about how the 14 interactions with some of the stakeholders went.
15 When I looked at some of the PWR Owners 16 Group questions and the responses back about 17 implementation, and in particular, partial 18 implementation when Rev 0 and Rev 1 were coexisting.
19 I thought when I read the question, and I 20 saw the response back, it wouldn't have answered my 21 question.
22 Did the staff interact with some of these 23 public meetings saying, hey, this is how I plan to --
24 or the staff plans to address this question?
25 And was there a response back from the PWR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 1 Owners Group that says, yes, that takes care of it and 2 we know how to move forward?
3 MR. BLUMBERG: No, there were no meetings 4 with the public after the public comments were 5 resolved or during the comment resolution.
6 The meetings that occurred were all before 7 it was issued for public comment.
8 I will say that during those meetings, 9 this came up several times as well as during the last 10 ACRS meeting. I think Steve Schultz had brought up 11 this issue as well.
12 And the thing that is difficult for the 13 staff is that this method provides that -- this 14 regulatory guidance provides a method that we find 15 acceptable. It's not the only method.
16 But we can't -- the difficult thing is 17 that, everyone's licensing basis is different. And as 18 such, it's very difficult for the staff to come up 19 with all the if, then, else situations that might 20 arise.
21 So, our plain response to this is that 22 each of these methods current provide acceptable 23 methods to the staff.
24 Deviations from those methods are 25 acceptable, but they need to provide justification as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 1 to why they would be acceptable.
2 CHAIRMAN REMPE: Okay.
3 So, we get to implementation and the 4 request for examples, I'll have more questions.
5 Because it just seems like some general guidance or 6 some examples that give people an idea of what to do 7 when one starts to load in a partial core of high burn 8 up or -- excuse me, higher enriched fuel might be 9 useful.
10 Okay?
11 Thank you, thank you.
12 MR. BLUMBERG: Understood. Thank you, 13 Joy.
14 Okay, are there any more questions before 15 I move on?
16 Okay, hearing none, I'll go on to slide 17 seven. Reg Guide 1.183 Revision 0 was issued over 20 18 years ago to support a landmark change that uses a 19 more realistic source term.
20 This source term was developed from 21 decades of severe accident research and stimulated by 22 the accident at Three Mile Island.
23 The Reg Guide was created to support the 24 implementation of 10 CFR 50.67, known as the 25 Alternative Source Term Rule.
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18 1 This rule established design basis dose 2 limits for the control room, exclusion area boundary 3 and low population zone for the purposes of 4 determining the design requirements for mitigating 5 safety systems.
6 Reg Guide 1.183 provides an acceptable 7 method for modeling the design basis accidents used to 8 demonstrate compliance with 10 CFR 50.67.
9 At the time it was developed, it was 10 recognized that the source term derived from NUREG-11 1465 might need to evolve. So, the source term was 12 not specified in 10 CFR 50.67, but put into Regulatory 13 Guide 1.183.
14 One of the main reasons we are proposing 15 this revision to Reg Guide 1.183 is to support the 16 inclusion of a revised source term needed for 17 increased enrichments, burn ups, and near-term 18 accident tolerant fuel designs.
19 Please go to slide eight.
20 Slide eight provides a table summarizing 21 the source terms used in various versions of the 22 regulatory guidance. It is provided to give you an 23 overall view of the various ranges of applicability 24 for the various versions of the regulatory guidance.
25 Basically, as the guidance evolved, it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 1 evolved to provide guidance for expected burn ups and 2 enrichment ranges.
3 Please go to slide nine.
4 Slide nine lists the regulations directly 5 tied to Reg Guide 1.183. They are grouped based on 6 the safety assessments or systems that they relate to.
7 These include site safety assessments, 8 control room, and technical support habitability.
9 Although Reg Guide 1.183 was originally 10 created to support compliance with 10 CFR 50.67, and 11 General Design Criteria 19, the proposed regulatory 12 guidance expands its possible use to provide methods 13 that could be used to demonstrate compliance with dose 14 criteria in Part 52.
15 Please go to slide ten to introduce the 16 next topic, then slide 11.
17 Slide 11 provides a representative bar 18 graph that breaks down the comments into categories of 19 interest.
20 These categories are listed with the 21 category with the greatest number of comments first, 22 and those with the least last.
23 As an example, general and editorial 24 comments were provided in approximately 17 percent of 25 the comments received.
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20 1 Comments about equipment qualification 2 were about 1 percent of the comments.
3 This graph is provided to give you an idea 4 where the greatest interest exists based upon public 5 comments received.
6 Please go to slide 12 to introduce the 7 highlighted changes, then slide 13.
8 Slide 13 lists the categories of 9 significant changes due to public comments.
10 We will be going over each of these in 11 more details in the slides that follow.
12 The categories will be discussed in an 13 order that highlights key areas of interest first and 14 issues of less significance last.
15 The slides that follow are rather 16 detailed, so we will not have time to go through every 17 detail. Rather, I will summarize them rather than 18 going into those details on each slide.
19 Please go to slide 14.
20 In DG-1389, staff did not propose any 21 changes to regulatory positions on suppression pool 22 scrubbing.
23 The two comments provided were to re-24 evaluate BWR release fractions based upon new accident 25 sequences including suppression pool scrubbing.
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21 1 And to allow for this scrubbing based upon 2 a contractor's NUREG report.
3 And the state of the ARC reactor 4 consequences analysis.
5 Our responses point out that suppression 6 pool scrubbing guidance is already provided in the 7 guidance and a revision of the LOCA release fractions 8 is beyond the scope of the regulatory guidance 9 revision.
10 Changes were made to DG-1389 guidance so 11 that it does not discourage credit for suppression 12 pool scrubbing.
13 We were requested to include an example of 14 when we credited suppression pool scrubbing for the 15 economic simplified boiling water reactor. So, we 16 added a footnote that provides information on this 17 example.
18 Please go to slide 15.
19 In DG-1389, staff introduced the term 20 transit dose. It was added to demonstrate compliance 21 with the General Design Criteria 19 requirements.
22 GDC-19 requires adequate protection to 23 permit operators access and occupancy of the control 24 room under accident conditions.
25 The footnote was also added providing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 1 guidance for calculating the impact of SHINE dose.
2 Previously, guidance was silent on the 3 issue of control room access transit dose, except for 4 providing an end leakage value for ingress and egress 5 through the control room operating doors.
6 Eleven public comments on the control room 7 were received. These comments requested that the 8 added guidance on transit dose and footnote be 9 removed, acknowledgment that a correction factor is 10 already included in the dose codes like RADTRAD, 11 requested allowances for the alternative geometry 12 correction factors, and questioned whether sufficient 13 safety margin exists for the control room dose 14 calculations.
15 The staff agreed with the request to 16 remove the guidance on transit dose, removed footnote 17 15, acknowledged the finite geometry correction 18 factor, and addressed the concern regarding safety 19 margin.
20 Regulator Position 4.2 which provides 21 guidance on calculating control room dose was revised 22 to clarify the guidance.
23 Please go to slide 16.
24 DG-1389 revised the alternative source 25 terms and methods for demonstrating compliance with 10 NEAL 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 1 CFR 50.67 which stated that Revision 0 continue to be 2 available for use by licensees and applicants.
3 Eleven comments requested clarifying 4 statements, examples of selective implementation, and 5 stated that Revision 1 should supersede Revision 0 6 because of errors.
7 There was also request for the NRC to 8 evaluate the impact of Rev 1 on a sampling of plants.
9 We agreed with adding clarifying 10 statements and an example of selective implementation.
11 The background section and Regulatory Position 1.1.1 12 and 1.1.5 were revised in response to these public 13 comments.
14 Please go to slide 17.
15 CHAIRMAN REMPE: Mark, this is Joy again, 16 can you hear me, Mark?
17 MR. BLUMBERG: Yes, I hear you, Joy.
18 CHAIRMAN REMPE: Sorry, we were -- this is 19 an unusual situation today with our audio.
20 But anyway, I -- when I looked at those 21 sections, what I saw as the clarification or example 22 that really go to Rev 1 if you go above a certain 23 enrichment or burn up.
24 Is that -- am I correctly reading what the 25 clarifying statements an example for?
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24 1 MR. BLUMBERG: Yes.
2 My recollection of the statements that 3 were made revolved around the fact that each 4 particular sets of guidance have applicabilities and 5 scope for which they are -- they can be used.
6 If you're --
7 CHAIRMAN REMPE: So, then --
8 MR. BLUMBERG: If you're trying to use one 9 outside of the scope of the other -- I mean, combining 10 the two, it potentially caused problems if you're 11 going outside the scope of one and then you're 12 applying to something that is higher burn up and 13 enrichment for which it was developed.
14 CHAIRMAN REMPE: So, I had a question. If 15 I wanted to load and mix and half of its core, then 16 would I need to go and use Rev 1 for the source term 17 for the entire core or would I use Rev 1 for the 18 higher enriched fuel and Rev 0 for the lower?
19 And is that just obvious to everybody?
20 And then, I was curious why we were doing 21 that in light of the Sandia 2023 report which showed 22 that source term really wasn't that highly affected by 23 enrichment and burn up?
24 And so, I just was puzzled why that was 25 the only example or clarification made?
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25 1 Because that didn't seem to answer what I 2 thought the BWR Owners Group was asking.
3 MR. BLUMBERG: I can give you my response, 4 maybe some others in the group can chime up.
5 But that was the clearest example in our 6 minds to provide them and probably the most likely 7 example that, you know, in this situation, it might be 8 encountered.
9 At least from the standpoint that many 10 people want to use this for higher burn up and 11 enrichment, we focused on that example.
12 Is there anyone else --
13 CHAIRMAN REMPE: Designed --
14 MR. BLUMBERG: -- from the working --
15 CHAIRMAN REMPE: I just want to 16 understand.
17 Is that -- does everybody in industry know 18 then you should divide the core up and you should have 19 a source term based on where the fuel is with respect 20 to enrichment and burn up, despite the fact that the 21 Sandia report showed that that wasn't a big factor?
22 I just was curious, but again, the PWR 23 Owners Group says, you know, this is costly. Do we 24 have to do the whole licensing basis over? What 25 exactly are we supposed to do?
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26 1 And the staff believes that answers the 2 PWR Owners Group question ? And if that's what the 3 staff believes, is my first question, and then, I 4 really hope NEI answers that, too, today.
5 But anyway, it's clear to the licensees 6 with that clarification what they need to do? And 7 just tell me what they should do?
8 MR. BLUMBERG: So, it provides a method 9 for meeting the regulations. It doesn't mean that 10 it's the only method.
11 So, if licensees think that there's some 12 other way of doing this, then they can propose that 13 and provide justification for doing such.
14 The guidance doesn't prevent -- prohibit 15 alternatives, it just provides a method.
16 CHAIRMAN REMPE: Anyone else?
17 (No response.)
18 CHAIRMAN REMPE: Okay, go ahead. Thank 19 you.
20 MR. BLUMBERG: Okay, thank you.
21 Slide 17, please?
22 MEMBER MARCH-LEUBA: If you're using the 23 microphone and the speakers, did you get that?
24 MR. BLUMBERG: I'm sorry, I didn't catch 25 that.
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27 1 MEMBER SUNSERI: You're okay.
2 MR. BLUMBERG: Okay, thank you.
3 staff proposed minor wording changes in 4 DG-1389 and added that the reduction of airborne 5 radioactivity by both sprays and gravitational setting 6 that are competing processes should be evaluated on an 7 individual case basis.
8 Four public comments questioned whether 9 applying the gravitational settling model in NUREG-14 10 -- or CR 61.89 continues to be applicable when 11 considering the added main steam line deposition 12 models and with an MHA source term?
13 Our response was that the main steam line 14 models did not consider removal by both sprays and 15 natural deposition simultaneously.
16 And in NUREG CR 61.89 can be used if 17 adjusted to incorporate the revised MHA source term.
18 Regulatory Position A-5 was clarified to 19 state the main steam line models are not valid when 20 crediting other aerosol removal mechanisms.
21 It revised Regulatory Position A-2.2 to 22 state that reductions in NUREG CR 61.89 are not 23 accepted, but that methods, when adjusted for the MHA 24 source term, could be credited on a case by case 25 basis.
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28 1 Please go to slide 18.
2 DG-1389 introduced the modifier maximum 3 hypothetical accident, or MHA, to the loss of cooling 4 accident.
5 This was done to differentiate the 6 accident described in regulations and its associated 7 dose acceptance criteria from the mechanistic 8 evaluation that's used to demonstrate compliance with 9 10 CFR 50.46 on the ECCS.
10 We received seven public comments on the 11 MHA.
12 We were questioned whether the terminology 13 and reduce in new accident asserted that the source 14 term did not represent the worst case accident.
15 And asked whether specific pipe breaks are 16 assumed in the MHA LOCA evaluation.
17 We disagreed with these comments and 18 responded to the questions regarding the MHA.
19 Our overall responses are based upon the 20 fact that the MHA is not a new accident and it's 21 described in regulations.
22 We also stated that no specific pipe break 23 is assumed for the MHA LOCA evaluation.
24 No changes were made to the DG-1389 25 language on the MHA due to these comments.
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29 1 Please go to slide 19.
2 In DG-1389, we added three main steam line 3 deposition models and new guidance for crediting 4 alternative drain pathways to the condenser.
5 We also clarified what parts of the 6 release path can be credited.
7 Thirteen public comments were received on 8 the MSIV leakage pathway.
9 These comments are on the use of non-10 safety related equipment, source term scaling factors, 11 in board deposition credit, clarifying the 12 acceptability of proposed deposition models, the 13 assumed sizes of containment aerosols, and the removal 14 mechanisms for the re-evaluated steam line deposition 15 models.
16 We agreed with most of the public 17 comments, but disagreed with revising containment 18 aerosol sizes and to limiting credit to only safety 19 related components in alternative leakage pathway.
20 We added clarifications to Reg Position A-21 5 regarding scaling factors and removed the need for 22 case by case evaluations when using the revised steam 23 line deposition models.
24 Please go to slide 20.
25 In DG-1389, staff expanded Reg Guide NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
30 1 1.183's scope to use new light water reactor -- to 2 include new light water reactor applications.
3 Five public comments related to the 4 meaning of advanced LWRs and the applicability of the 5 guidance to new LWR applications were received.
6 The staff responded to public comments by 7 clarifying that the guidance is applicable to any new 8 LWR application under Parts 50 or 52.
9 And by listing all relevant regulatory 10 requirements.
11 Changes were made to the reasons for the 12 revision, background, and regulatory position sections 13 of the guidance.
14 Now, I'll turn the presentation over to 15 Joseph Messina for the next few slides.
16 MR. MESSINA: Thank you, Mark.
17 MEMBER MARCH-LEUBA: Wait, wait, let's 18 check the microphone.
19 MR. MESSINA: Hello? Okay, good morning, 20 my name is --
21 (Audio interference.)
22 MEMBER MARCH-LEUBA: Pull the speakers 23 while he's speaking.
24 MR. MESSINA: How about now?
25 Good morning, my name is Joe Messina. I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
31 1 a Reactor Systems Engineer in the Methods and Fuel 2 Analysis Branch of the Division of Safety Systems.
3 When Paul Clifford left the Agency, he transferred the 4 lead of the non-LOCA gap fractions portion of this Reg 5 Guide to me.
6 So, I'll be going over a couple of slides.
7 In Tables 3 and 4 of the Reg Guide, we provide non-8 LOCA gap release fractions for BWRs and PWRs 9 respectively to go along -- and to go along with these 10 tables, we provided Figure 1 which specifies a power 11 history applicability envelope that should be met in 12 order to use the gap fractions in the tables.
13 So, operation, in terms of LHGR versus 14 burn up should remain below that envelope which I'll 15 show in the slide.
16 I'll note that the non-LOCA gap fractions 17 are highly sensitive to fuel design and power history.
18 Now, we understand that these power 19 envelopes may not work for maybe a 100 percent of the 20 fleet, so we provided a detailed analytical procedure 21 on how gap fractions can be calculated independently 22 by industry with different power histories or 23 different fuel designs.
24 This is especially important as we get to 25 more of these ATF designs which are proprietary and we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
32 1 can't really provide generic gap fractions for those.
2 We received a few comments on the non-LOCA 3 gap fraction portions and Figure 1.
4 Most of the comments, we simply added 5 clarification to the Reg Guide such as that, 6 uncertainty should be calculated -- accounted for when 7 comparing to the curve.
8 But the biggest change, which I would 9 still say is not too significant, was the treatment of 10 partial length rods.
11 We were asked about the applicability of 12 the figure to partial length rods. Since we gave the 13 figure in terms of rod average power, partial length 14 rods at the bottom of a BWR likely would not be able 15 to meet the curve, even if at the same peak power 16 since they won't have the regions of lower power that 17 a full length rod would have.
18 So, we added the peak power curve to the 19 Figure 1. And that peak power curve can be met for 20 the partial length rods, then the gap fractions in the 21 tables can be used.
22 And I will note that we still state that, 23 for partial length rods, they should use the -- assume 24 that it's a full length rod for inventory purposes 25 since the design changes would not necessarily be a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
33 1 100 percent accounted for.
2 But that -- assuming it's a full rod 3 should be conservative.
4 And then, we also received a few comments 5 about non-LOCA and non-control rod drop and control 6 rod ejection accident, fragmentation induced transit 7 fission gas release.
8 But ultimately, we maintained our 9 position, just expanding on it, adding clarification.
10 I won't talk much about that for the sake 11 of time, but if there are questions on that paragraph 12 of the Reg Guide, I can speak more to that.
13 Next slide, please?
14 So, here's the slide depicting the 15 applicability limits for non-LOCA gap fractions for 16 Rev 0, which is the gray box in -- on the left side, 17 on the left curve.
18 And DG-1389 and then, the new curves in 19 Rev 1.
20 Now, I will say that the curves in Rev 1 21 are the same and the peak power curves were applied 22 based on the statement boxed in red at the top of the 23 curve. But we added that for clarify for the partial 24 length rods.
25 And you'll see that the Rev 0 limits, they NEAL 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 1 only had -- Rev only had limits from 54 to 62 gigawatt 2 days, which is not really justifiable because anyone 3 can operate at any LHGR before that and, as long as 4 they're inside that gray box, they can use the gap 5 fractions.
6 And we know that gap fractions would not 7 be equal with different -- drastically different power 8 histories.
9 MEMBER PETTI: So, Joe, I have a question.
10 MR. MESSINA: Yes?
11 MEMBER PETTI: This shows --
12 MEMBER MARCH-LEUBA: Wait, wait. We only 13 need one microphone.
14 (Off-microphone comments.)
15 MEMBER PETTI: But the Sandia 2023 report 16 shows no benefit.
17 I interpreted that, the Sandia report of 18 2023 LOCA but in the non-LOCA because of they were not 19 --
20 MR. MESSINA: Correct, yes.
21 So, the Sandia report only deals with MHA 22 LOCA. Non-LOCA should be dealt with -- seen as 23 separate.
24 MEMBER PETTI: Okay, thanks.
25 MR. MESSINA: Okay. Any more questions?
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35 1 And if not, I'll hand it back over to Mark.
2 MR. BLUMBERG: Thank you.
3 MR. MESSINA: Next slide, please.
4 MR. BLUMBERG: Thank you, Joey. In DG-5 1389, staff removed the environmental qualification 6 guidance contained in Reg Guide 1.183 Revision 0.
7 This guidance was --
8 MEMBER SUNSERI: Hold on a second, we've 9 got -- we need to get Joe on the audio here, just 10 stand by.
11 (Pause.)
12 MR. BLUMBERG: Are we ready?
13 MEMBER SUNSERI: Yes, we're good now.
14 Thank you.
15 MR. BLUMBERG: Okay. Would you like me to 16 start over?
17 MEMBER SUNSERI: Yes, please.
18 MR. BLUMBERG: Yes, sure, great.
19 In DG-1389, staff removed the 20 environmental qualification guidance contained in Reg 21 Guide 1.183 Revision 0.
22 This guidance was provided in Appendix I 23 of DG-1389 entitled, Assumptions for Evaluating 24 Radiation Doses for Equipment Qualification.
25 This change was intended to put the EQ NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
36 1 guidance where it belonged, back into Reg Guide 1.89 2 on equipment qualification.
3 staff received two public comments related 4 to the continued use of EQ guidance in Reg Guide 1.183 5 Revision 0, including questions regarding the 6 continued use of the TID-14833 source term for EQ, as 7 was specified in Revision 0 of Reg Guide 1.183.
8 In our response, we stated that EQ 9 guidance in Revision 0, including the use of TID-14833 10 guidance can continue to be used, provided that the 11 plant design and licensing basis is in accordance with 12 the applicability and limitations of Reg Guide 1.183 13 Revision 0.
14 We've provided language on the 15 applicability and limitations of Rev 0, the Rev 0 16 source term, and stated That if it was continued to be 17 used, that it needed to be technically justified.
18 The background section was updated to 19 clarify the continued applicability of Rev 0, for Reg 20 Guide 1.183 consistent with our response to the public 21 comments.
22 And please go to slide 24.
23 In DG-1389, staff provided a revised fuel 24 handling accident model, allowing for the modeling of 25 retention and re-evolution of iodine from the spent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
37 1 fuel pool.
2 This model replaced the non-mechanistic 3 releases previously assumed for the fuel handling 4 accident and allowed for hold up of radioactivity 5 within the spent fuel pool.
6 Twelve public comments were received by 7 the working group.
8 They included requesting clarifications of 9 the iodine species assumed, revisions to the water 10 depths in the model, a method for calculating doses to 11 workers around the spent fuel pool, and requests for 12 information to confirm the applicability of the 13 release fractions in Tables 3 and 4 to the fuel 14 handling accident.
15 The requested clarifications were provided 16 and information on the limitations of data.
17 We also clarified that the method for 18 calculating control room dose and off site doses and 19 not for those working near the spent fuel pool.
20 Please go to slide 25. DG-1389 added 21 guidance that states that a modified version of the 22 control room methodology in Reg Guide 1.194 may be 23 used to estimate the off site atmospheric dispersion 24 factors out to distances of 1,200 meters and to align 25 the most unfavorable dispersion coincident with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
38 1 most adverse releases.
2 Three public comments on meteorology were 3 provided.
4 These comments requested the basis for the 5 modified control room methodology and requested us to 6 state the codes to be used for atmospheric dispersion, 7 acceptability of the prior guidance, and questioned 8 the need to align the most unfavorable dispersion 9 coincident with the most adverse release.
10 We stated that we agreed that a basis 11 needed to be provided but when we transmitted DG-1389 12 to the ACRS, the responses to public comments -- and 13 the responses to public comments to the ACRS, Reg 14 Guide 1.249 had not been issued.
15 It was recently issued so we plan on 16 revising the Regulatory Position 5.3 to include Reg 17 Guide 1.249 and update our responses to public 18 comments to reflect that update.
19 We also pointed out that codes for 20 atmospheric dispersion --
21 MEMBER PETTI: Just a question.
22 MR. BLUMBERG: Yes?
23 MEMBER PETTI: So, before you go with Rev 24 1, you'll make those changes?
25 MR. BLUMBERG: That's correct.
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39 1 It's a very simple change. It's just 2 putting that reference in that statement.
3 MEMBER PETTI: Thank you.
4 MR. BLUMBERG: You're welcome.
5 We also pointed out that codes for 6 atmospheric dispersion are contained in references for 7 Reg Guide 1.183 and met the new guidance on aligning 8 -- excuse me for a second, let me get a drink of 9 water.
10 We also pointed out that the codes for 11 atmospheric dispersion are contained in references for 12 Reg Guide 1.183 and that the new guidance on aligning 13 atmospheric dispersion factors with releases was to 14 align the guidance with that currently in Reg Guide 15 1.194.
16 Please go to slide 26 to introduce our 17 conclusions and a look forward on future changes to 18 Reg Guide 1.183. And then, go to slide 27.
19 Now, we will discuss our conclusions for 20 this presentation.
21 The NRC has developed updated design basis 22 dose analysis guidance based upon experience since 23 issuing Reg Guide 1.183, Rev 0, research data, new 24 analyses, and significant stakeholder involvement.
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40 1 advances for modeling accident tolerant fuel, high 2 burn up, and increased enrichment source terms.
3 They also include advancements from 4 modeling BWR MSIV leakage, including guidance for 5 crediting hold up and deposition of MSIV leakage 6 within the main steam lines and the condenser for 7 BWRs, non-LOCA source terms, and revised transport and 8 decontamination models for the fuel handling accident 9 design basis analyses.
10 Lastly, we want to make you aware that we 11 are currently investigating further improvements to 12 accommodate even higher enrichments and burn ups.
13 This work seeks to create guidance for up 14 to ten weight percent enriched uranium U-235, and burn 15 ups up to 80 gigawatt days for metric ton uranium.
16 We are looking to expand the scope of the 17 guidance for the near-term accident tolerant fuel 18 designs and potential for future rule making that 19 might affect the dose analyses.
20 So, we are planning on re-engaging the 21 industry on these potential changes and expect to be 22 back before the ACRS to discuss these issues when we 23 revise Reg Guide 1.183 to Rev 2.
24 DR. BLEY: Mark?
25 MR. BLUMBERG: Yes?
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41 1 DR. BLEY: It's Dennis Bley.
2 Could you go back to slide 27? There was 3 one thing -- I'm sorry, 25?
4 MR. BLUMBERG: Twenty-five?
5 DR. BLEY: Yes, up in your first bullet 6 you talk about the issue raised is aligning the most 7 unfavorable dispersion coincident with the most 8 adverse releases.
9 The extent to which that assumption is 10 conservative is really site specific and depends on 11 kind of how often a particular site's in an 12 unfavorable dispersion condition.
13 You didn't -- I don't believe you said how 14 you dealt with that comment down in your responses 15 below.
16 Can you refresh that one?
17 MR. BLUMBERG: So, one of the things I 18 believe -- and I don't have that response in front of 19 me, so I'm going by memory.
20 My recollection was that when we responded 21 to it, we just pointed out that this was to align it 22 with guidance -- other guidance for other dose points 23 that's contained in the Reg Guide 1.194.
24 And also, it seems to me that in the 25 response to the public comment, there were some NEAL 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 1 concerns about how to go about doing this.
2 And I think we responded with a method for 3 doing so. I'd have to double check on that, though.
4 DR. BLEY: Okay, thank you. And, clearly, 5 it is a conservative step and I'm just -- I was 6 wondering what they were pushing on and I guess I 7 still think it's really dependent on the site, how 8 conservative that assumption is.
9 But thanks, that's enough for me.
10 MR. BLUMBERG: You're welcome, thank you.
11 So, that concludes our presentation.
12 We're now open for questions from the ACRS.
13 MEMBER PETTI: Yes, I have a couple that 14 I want to make sure I understand.
15 I heard other members raise some issues 16 related to mixed core guidance, which I'll let Joy, 17 you know, talk about. But the red zone Rev 1 18 coexistence, it struck me as odd because it's not 19 something that's commonly done. I know it's been done 20 in the past.
21 Does it allow them, on a case by case 22 basis, to mix and match, if you will, something from 23 Rev 0 and something from Rev 1? Or are there some 24 guardrails that, you know, prevent that? How does 25 that actually work from an implementation perspective?
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43 1 MR. BLUMBERG: So, each method by 2 themselves provides a method acceptable for meeting 3 the regulation. Combining those methods creates a new 4 method. And when combining, the licensee or applicant 5 would need to provide additional justification for 6 doing so.
7 MEMBER PETTI: Okay, that helps.
8 The second is this understanding of this 9 new report Sandia 2023 that has LOCA source terms that 10 show, apparently, higher releases but no explicit burn 11 up of enrichment dependence.
12 So, I'm sitting here trying to understand 13 that there's information on the street that says there 14 are higher source terms, potentially, than what are in 15 Table 1 and 2 in Rev 1.
16 And how do I justify that in my head that 17 we know that the data from the Tables 1 and 2 may not 18 be conservative because we know these new results from 19 Sandia?
20 And I worry about how long it'll take to 21 get that into Rev 2 -- gets into Rev 2 because all 22 these uncertainties out there in the future. And I'm 23 struggling.
24 I'm sure there's us on this committee, 25 this is information we need when we get to our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
44 1 discussions.
2 So, any perspective on that, Mark?
3 MR. BLUMBERG: So, I think the perspective 4 that I have is based upon timing and the development 5 of the regulatory guidance and the issuance of this 6 revised source term and its findings.
7 When we started development of DG-1389, 8 the source term that we had that was vetted was the 9 2011 source term.
10 The 2023 source term, let's see, I'm 11 sorry, let me make sure I've got the right number on 12 this, one second, yes, the 2023-01313 source term was 13 under development at that time.
14 And we're currently in 2023. I'm trying 15 to recall about whether or not it has gone through the 16 vetting process. It seems like it has.
17 Could I have Office of Research to provide 18 some perspective on that?
19 CHAIRMAN REMPE: So, this is Joy. They 20 did a peer review and the peer review has been 21 completed in a transmittal letter that Kim Webber sent 22 to Mike Franovich. Right?
23 And so, I don't know NRR Research wants to 24 answer it, but what else is required besides a peer 25 review for vetting?
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45 1 MR. BLUMBERG: So, what we had done in the 2 past, not necessarily with 2011, but with NUREG-1465, 3 we did issue that for public comment in NUREG-1465.
4 And the public was involved in commenting on that.
5 We had talked about doing that. Those 6 discussions, we haven't gotten that far with it.
7 So, as of today, what we have in this is 8 the 2011 source term. That's just the status of where 9 we're at.
10 MEMBER PETTI: I understand all that, I 11 just, I guess I'm surprised that the train's still 12 moving on the track when there's potentially a body on 13 the track up ahead.
14 Terrible analogy, sorry. But there's 15 something that could derail Rev 1 and you know it's 16 out there, but it hasn't gone through and got all the 17 I's dotted and the T's crossed, yet, here we keep 18 going.
19 Help me here, I'm just struggling. I can 20 see Mike has his hand up.
21 MR. FRANOVICH: I don't know if you can 22 hear me now?
23 MEMBER MARCH-LEUBA: Okay, yes we can.
24 MR. FRANOVICH: I'm on the phone version.
25 Can you hear me?
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46 1 MEMBER MARCH-LEUBA: Yes, now we can.
2 MR. BLUMBERG: Yes, I can.
3 MR. FRANOVICH: Okay.
4 MEMBER MARCH-LEUBA: If you can get close 5 to this microphone. Yes, that's clear.
6 MR. FRANOVICH: Okay. I think the short 7 answer is here the state of balance keeps shifting.
8 We've been seeing this for the last 25 years.
9 Some of the severe accident modeling, I 10 don't want to overstate what our colleagues have done 11 in research, but it is a better knowledge of what the 12 timing of certain releases and pressures and the 13 systems, whether they're PWRs or BWRs.
14 And that is more of the driver of these 15 changes in terms of a containment source code.
16 This report that came over from research 17 from Ken Roberts and myself was done in a manner to 18 expedite visibility on the work. But we haven't done 19 the piece -- the protocol piece to engage all 20 stakeholders on that. That was envisioned to be done 21 in Revision 2. We don't have a broader viewpoint.
22 Yes, there was a peer review done, but we 23 don't have broader views on it. And so, that's really 24 the short answer of it. And it's kind of a moving 25 target. I recognize that. But for 25 years, things NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
47 1 have been a moving target in this area.
2 So, at what point do you make a decision 3 and say, we move forward knowing there are analytical 4 margins available and physical margins in these plants 5 and dealing with it with a more fulsome set of issues 6 in Revision 2?
7 And I'll talk about that more a little bit 8 later. But that's the short perspective on it.
9 MEMBER MARCH-LEUBA: Let's test -- say 10 something.
11 MEMBER BIER: Can people hear me?
12 MEMBER MARCH-LEUBA: Yes.
13 MEMBER BIER: Okay, I talk pretty loud.
14 I have a question similar in the way of Dennis's 15 questions. I mean, clearly, it's possible 16 mathematically to get a bad source term in combination 17 with bad dispersion conditions.
18 And so, as a PRA person, I would think, 19 well, how likely is that combination and how much 20 worse is it than other combinations?
21 And so, the question that I have is if 22 people want to get away from the level of conservatism 23 of assuming both at their worst, could they do a 24 probabilistic analysis with it and do a more risk 25 informed kind of process, how would that be taken into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
48 1 account?
2 MR. BLUMBERG: So, I'll just point out 3 that the source term that was developed was developed 4 using a risk informed process. 1465 looked at the 5 most important sequences to inform that.
6 So, the process that we do have, does 7 incorporate the use of risk in its development.
8 MEMBER BIER: It's okay, we can move on.
9 I'm not sure I fully understand the answer, but I'll 10 think about it.
11 MR. BLUMBERG: Thank you.
12 MEMBER PETTI: Members, other questions?
13 MEMBER ROBERTS: Yes. It's Tom Roberts.
14 You probably need to mute the speaker.
15 MEMBER MARCH-LEUBA: You can use this one.
16 It really affects --
17 MEMBER ROBERTS: Yeah, we're -- yeah, the 18 mic is on.
19 MEMBER MARCH-LEUBA: No, no, no. You have 20 to mute yours.
21 MEMBER ROBERTS: Mute mine? Can you hear 22 me now?
23 MEMBER MARCH-LEUBA: Yes.
24 MEMBER ROBERTS: Yeah, Mark, can you hear 25 me now?
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49 1 MR. BLUMBERG: Yes, Mr. Roberts.
2 MEMBER ROBERTS: We can't hear him. I 3 can't hear him.
4 MR. BLUMBERG: Yes, sir. I can.
5 MEMBER ROBERTS: Yeah. It's Tom Roberts, 6 following up on what Vicki just said. I think one of 7 the areas that I know confuses me, and I think from 8 the public comment the fact is it confuses a lot of 9 people.
10 Is the role of the Reg Guide 1.183 11 analysis to show compliance with regulations in 10 CFR 12 50.67 in a risk informed context that it really is a 13 deterministic analysis that makes some, you know, 14 stylized assumptions to get you through to a result to 15 show you meet regulation.
16 And it -- the stylized substances aren't 17 necessarily, maybe the word rational is too strong of 18 a word. But, not necessarily, you know, mechanistic.
19 You combine things like a somewhat 20 arbitrary assumption that really stops at the really 21 end vessel, release phase.
22 And so, there's just this somewhat, you 23 know, arbitrary stop to the transient that says, okay, 24 that's good enough, that's enough, you know, source 25 term release to containment.
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50 1 And then, it also has deterministic 2 assumption that containment, well containment will 3 meet its leak rate assumptions regardless of what the 4 reaction and phenomena might show.
5 And so, you've got what's a mix of very 6 conservative assumptions with some conservative --
7 some assumptions that may or may not be conservative 8 depending on the sequence you look at.
9 So, defining the role of this analysis, 10 how it fits into the overall regulatory structure, 11 seems like something that's of value. I noted in the 12 DPR I think you're going to talk about next, there was 13 a recommendation to step back and write down what the 14 purpose of this analysis is.
15 And then, you know, presumably then, 16 determine what would change in the prescription and 17 what would change in its use depending on what that 18 written down view of what this analysis intended to 19 show would lead to.
20 And I would like to get your comment on 21 that. And maybe one specific question, is one of the 22 changes in this revision is to lump in the technical 23 and support center dose, the habitability of the TSC 24 into the Reg Guide.
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51 1 tell, that was standard practice. But, it wasn't in 2 the Reg Guide before. That's now added.
3 And so, it would seem like the technical 4 support center, its role is emergency management. And 5 so, why a prescription that uses all the deterministic 6 stylized assumptions going in for a technical support 7 center that may or may not, you know, need to function 8 or be designed to function in that environment is an 9 example of where it maybe the, you know, when you 10 write down the reason why the assumptions are made, 11 maybe you start to see maybe some different set of 12 assumptions are needed.
13 So, for example, maybe there's analysis 14 somewhere, which I couldn't find, that said that a Reg 15 Guide 1.183 analysis would be conservative for a 16 severe accident at the TSC. I don't know, there may 17 be analysis like that.
18 But, maybe there's some PRA analysis that 19 says the TSC, it doesn't need to be credited in any 20 event more significant in more likely sequences. I 21 don't know. I'd have to guess why it's reasonable to 22 use the Reg Guide 1.183 for the TSC capability.
23 So, maybe you can comment on the overall 24 need to write down the rationale for this 25 prescription. And then specifically on the TSC.
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52 1 Thanks.
2 MR. BLUMBERG: Okay. There's a lot there 3 to unpack, Mr. Roberts. So, I'll try to do my best.
4 So, first of all, I agree with you that 5 especially in the current environment of risk 6 informing that we need to be clear about the purposes 7 of this guidance.
8 The -- and, I'm not sure that that's done 9 in this guidance. The two, of course the 10 deterministic analysis came first before we had PRA.
11 And now that we've got PRA, how these things are 12 combined is a topic of many, many discussions.
13 And, as we'll see later when I put my 14 other hat on in the DPO, there were some concerns with 15 how that was done with some license amendments.
16 So, I agree with you. I think that in the 17 guidance we need too clearly, as best we can, define 18 that.
19 With respect to the TSC, I came from a 20 facility that basically because of the 0737 actions, 21 had done analysis consistent with GDC 19 for their 22 TSCs. And not all plants had those particular 23 requirements or analysis in place.
24 Some plants did. Some plant's don't. It 25 is my understanding if we go to, let's see here, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
53 1 slide was it? I think it is the slide on regulatory 2 requirements. One moment, please. It's slide nine, 3 if you could go to that.
4 Within -- the basis for including it in 5 this guidance, is provided in 10 CFR Part 50, Appendix 6 E. And if Ed Stutzcage is on the line, if you would 7 like to talk about that, please speak up, Ed.
8 MR. STUTZCAGE: I'm not sure that I'm 9 following you on this one.
10 MR. BLUMBERG: That's not good.
11 MR. DICKSON: Hey Mark, this is Elijah 12 Dickson. Do you mind?
13 MR. BLUMBERG: Sure. Thank you, Elijah.
14 MR. DICKSON: Yeah. I'll help supplement.
15 You're spot on the problem.
16 MR. BLUMBERG: Yeah, I can't hear you.
17 MR. DICKSON: Yeah. This is Elijah 18 Dickson with the staff, a Senior Reliability Risk 19 Analyst with the Division of Risk Assessment.
20 Mark, you are spot on those TSC 21 requirements. They were a spinoff of Three Mile 22 Island actions, right.
23 MR. BLUMBERG: Um-hum.
24 MR. DICKSON: And so, if you go back and 25 you look at NUREG 03-0737, there's a variety of items NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
54 1 there, of course, just like a list of them. But, one 2 of those is to go assess TSC.
3 And that was put into guidance eventually 4 with I think Rev 0, there was at least a point or two 5 with this NUREG. And then, we got at, you know, a 6 little bit further into this update.
7 MEMBER ROBERTS: Sure. I looked at that.
8 And 0737 uses the term accident conditions.
9 MR. DICKSON: Um-hum.
10 MEMBER ROBERTS: Which is somewhat vague, 11 because you could interpret that to be design basis, 12 or MHA conditions.
13 MR. DICKSON: Right.
14 MEMBER ROBERTS: Or, you can interpret it 15 at least severe accident conditions, depending on how 16 you choose to read it.
17 MR. DICKSON: Um-hum.
18 MEMBER ROBERTS: So, the, I guess, the 19 case law is that's been largely interpreted to be the 20 design basis or MHA accident where the containment 21 bypass scenarios are basically, you know, rolled out.
22 MR. DICKSON: Right. The source term 23 itself is this design basis source term that doesn't 24 affect kind of a severe accident type of source term 25 for the purposes of assessing, you know, the safety-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
55 1 related SSCs for containment, you know, contain the 2 leakage and mitigation, and then, of course, release 3 out to the environment.
4 And then, like when it comes to like boots 5 on the ground, you go and you assess, you know, where 6 the TSC is and your chi over q meteorological data.
7 And make sure that it's below those criteria, those 8 dose related criteria in 0737.
9 MEMBER ROBERTS: Yeah. And I would think 10 a severe accident assessment or a level three, level 11 two, PRA would look at the TSC and if it's credited in 12 one of the sequences, then the height ability would be 13 assessed for that scenario not just for the, you know, 14 the stylized assessment per the Reg Guide.
15 MR. DICKSON: Right. Yeah.
16 MEMBER ROBERTS: And I would think that, 17 you know, it would be interesting, does designing it 18 through the regulatory guide get it robust enough to 19 be a unique facility for their atmosphere accidents?
20 And that's the major question, I think.
21 MR. DICKSON: Right. It's a hard 22 question. Because when you're doing the PRA work, 23 right, you're looking at core damage frequency and 24 LERF-type events, right. Those are the figures of 25 merit that you're assessing for PRAs too.
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56 1 And that's kind of two steps behind when 2 you're actually assessing these figures of merit of 3 dose to these operators.
4 MEMBER ROBERTS: Um-hum.
5 MR. DICKSON: It's -- especially when 6 you're using this deterministic source term as well 7 that already includes core damage, right. You assume 8 that the core melts.
9 Per the regulation there's a footnote in 10 the regulation that said that you need to assume that 11 there's a melt to assess these safety-related systems.
12 I don't think there's very many operator actions and 13 design basis space from the TSC that would help 14 conditions for a melted core, right, in these design 15 basis accidents in the PRAs, right.
16 So, you're not supposed to credit operator 17 actions in these design basis analyses. But, in the 18 PRAs you could.
19 I'm not sure if I've answered your 20 question or not.
21 MEMBER ROBERTS: Yeah. I think it's --
22 well, that method is an example of where the, probably 23 good exercise to write down what the purpose analysis 24 using the stylized mix of assumptions are. And then, 25 see if here are gaps.
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57 1 MR. DICKSON: Understood.
2 MEMBER ROBERTS: I don't know if there's 3 a gap here, because as you point out, you know, 4 operator action is clearly not credited for these 5 kinds of things. Or, there may be scenarios where it 6 is.
7 MR. DICKSON: Um-hum.
8 MEMBER ROBERTS: In which case, presumably 9 the PRA would have looked at that.
10 MR. DICKSON: Right. Okay. Thank you.
11 MEMBER ROBERTS: No, it's just, you know, 12 trying to be clear.
13 MR. DICKSON: Got it.
14 MEMBER ROBERTS: Okay. Thank you.
15 MEMBER PETTI: Other questions, Members?
16 MEMBER MARCH-LEUBA: If you speak loudly, 17 I think I can hear you.
18 (Off-microphone comments.)
19 MR. FRANOVICH: There's a whole set of 20 questions here on the role of PRA. I understand the 21 welcome to the world of very deterministic regs.
22 But, it is risk informed in the terms of 23 part of the source term in the original 1465. It was 24 an outgrowth of NUREG 1150 and the five plants that 25 were studied in the late '80s, early '90s.
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58 1 We have made measures to try to bring in 2 more engineering insights with risk perspectives.
3 And, one of those issues, really this is probably a 4 good time to talk about it. And we'll talk about it 5 more in the next session.
6 But, in terms of actual physical features 7 of the plant and their robustness, we're dealing with 8 seismic events and other sources or pathways where 9 those could actually be reduced.
10 As you recall, we did have a development 11 of a draft interim staff guidance document. It was 12 focused at the time really on matters when licensees 13 were not crediting pathways like the condenser.
14 Since that time, we have learned a lot 15 more. We were attempting to update those really 16 antiquated experiences from methods in the 1990s to 17 use more of the risk insights in engineering, insights 18 that look at the robustness of these pathways.
19 And what we've done, is in this particular 20 Reg Guide, there are elements when licensees would 21 like to try to credit such pathways.
22 There is elements that we lifted out of a 23 reference document. It was a draft document, a 24 technical basis document. We have some of the experts 25 in the room today that could speak to that for cases NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
59 1 where licensees wish to credit it.
2 For cases where we want to apply insights 3 with a greater level of effort, we will not pursue 4 this ISG. I know the Committee had a question about 5 that.
6 We will find a more durable place to place 7 such guidance if we use it, in terms of our internal 8 reviews and leveled effort for cases when licensees 9 are not crediting such pathways. Which is a subject 10 that will come up in the next session.
11 So, I would say we're incrementally moving 12 toward a more risk informed approach. We're not quite 13 there fully.
14 Revision Two, does provide us 15 opportunities of one key rulemaking, the increased 16 enrichment rulemaking, is affording some optionality 17 in there, depending on how the Commission goes with 18 the rulemaking itself, to re-look at 5067 and what 19 under currents that rule which was created at the time 20 from the 1990s.
21 So, I'm going to share that perspective 22 with the Committee that it is lightly risk informed 23 right now in terms of guidance. But, we'd like to 24 more -- move more in that direction if possible.
25 CHAIRMAN REMPE: Mike, while you're up, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
60 1 could I ask you a question?
2 MR. FRANOVICH: Absolutely.
3 CHAIRMAN REMPE: When do you anticipate 4 Rev 2 will be issued, the first draft?
5 And, secondly, in your opinion, will you 6 have then Rev 0, Rev 1, and Rev 2 available? Or, will 7 you combine those?
8 MR. FRANOVICH: We have a recommendation 9 out of a DPO panel, I don't want to get too far ahead, 10 to look at potentially sunsetting Rev 0.
11 State of practices have moved along. We 12 have been dealing with some older methods and looking 13 at some offsets as you know, which has been 14 challenging for both licensees and regulators.
15 What is the proper way to sunset Revision 16 Zero and also look at, there's a regulatory 17 information summary that establishes positions, it's 18 called 2006-1, I forget the number exactly, but, it's 19 2006.
20 That too also needs to be looked at from 21 our regulatory process on how to -- how to either 22 withdraw that risk or modify it.
23 In regards to the schedule on increased 24 enrichment rulemaking, that is a high priority 25 rulemaking for the Commission. I believe the draft of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
61 1 the rule is due the end of next year.
2 There is a Reg basis that should be 3 released here within about a week or two. And so, in 4 tandem with rulemaking, one needs to provide guidance 5 for stakeholders.
6 And so, that is why we feel a lot of these 7 matters that are being raised and that rulemaking is 8 sort of the central point enforcing function for us to 9 get on with Revision Two. Which is kind of a good 10 thing.
11 CHAIRMAN REMPE: So, Zero will be 12 eliminated and Rev 1 will also be eliminated. And 13 we'll just have Rev 2 then?
14 MR. FRANOVICH: Well, I can't say that 15 definitively until we go through a corporate 16 evaluation.
17 CHAIRMAN REMPE: Okay.
18 MR. FRANOVICH: There are regulatory 19 processes we must follow to see are we backfitting, 20 are we forward fitting? The reason we're living with 21 the two stages of coexistence of Rev 0 and Rev 1 right 22 now when it goes final, is, it's a forward fit 23 consideration and backfit consideration.
24 But, I know it's very sophisticated and 25 detailed. And I don't want to spend the Committee's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
62 1 time on that.
2 But, there are control measures that we 3 have to go through and evaluate for these processes.
4 CHAIRMAN REMPE: Thank you.
5 MR. FRANOVICH: Sure.
6 DR. SCHULTZ: Mark, this is Steve Schultz.
7 MR. BLUMBERG: Hi, Steve.
8 DR. SCHULTZ: Good morning.
9 MR. BLUMBERG: Good morning.
10 DR. SCHULTZ: I still have a concern 11 related to your comment that not only could Rev 0 be 12 used for those licensees that currently have 13 implemented it, but then one could move to Revision 14 One.
15 But, there's the opportunity to mix and 16 match it seems, that could be presented to the staff.
17 And I guess I'm most concerned because I think the 18 staff has enough on their plate with what will become 19 submittals associated with Revision One as well as the 20 development of Revision Two.
21 So, are you really just providing that 22 middle approach as an option that you don't expect and 23 don't want licensees to choose, and you're going to 24 hold to the implementation of Revision One?
25 That's the first question. And then, NEAL 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 1 secondly, with regard to Revision Two, what's the plan 2 for the public interaction associated with the 3 developments in Revision Two?
4 Have you got a program planned for public 5 meetings associated with that that's ongoing? And if 6 not, when will it start?
7 MR. BLUMBERG: Okay. Today I'm wearing 8 two hats. I'm going to be talking about these issues 9 and wearing my second hat with respect to the DPO.
10 So, the decisions that were made with 11 respect too not withdrawing Rev 0, as well as the 12 second question on Rev 2, could I please defer to my 13 management to respond to, please?
14 DR. SCHULTZ: Okay.
15 MEMBER MARCH-LEUBA: No, say your name.
16 They can't hear you.
17 MR. HSUEH: Hi, this is Kevin Hsueh.
18 MEMBER PETTI: Please use the microphone 19 if too, if you can.
20 MR. HSUEH: Okay.
21 MEMBER MARCH-LEUBA: And speak loudly and 22 clearly.
23 MR. HSUEH: Okay. This is Kevin Hsueh in 24 the Office of (audio interference.)
25 DR. SCHULTZ: Somebody has their mic open.
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64 1 MEMBER MARCH-LEUBA: Can you mute him?
2 He's muted now. Okay, yeah.
3 MR. HSUEH: Yeah. We speak to the second 4 question about on the proper interactions about Rev 2.
5 I think what we plan to do is to add current. Right 6 now, our plan is to add current to Rev 1 on this 7 issue.
8 Then, we will use the same approaches that 9 we have done in the Rev 1. We have -- for the Rev 1, 10 we have three or four public comment meetings and to 11 interact with the external stakeholders.
12 And then, also including those, there 13 probably meet and greet, and kind of shore up proposed 14 changes and then to receive feedback from the public, 15 from the external stakeholders.
16 And so, what we envisioned to do is for 17 the Rev 2, we kind of envision using the same process.
18 And that we'd like to have a lot of this early 19 interactions.
20 Basically, I know that there's a lot of 21 high interest. There's a great force for spotting 22 issues. So, that's one of the areas where we don't 23 like to kind of engage with the most stakeholders and 24 before we proceed further.
25 That is kind of our current plan.
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65 1 DR. SCHULTZ: Thank you, Kevin. Do you 2 have comments on the implementations of licensees that 3 pick and choose between Rev 0 and Rev 1 elements that 4 they might want to promote or propose?
5 MR. HSUEH: I think that Mark mentioned 6 earlier and clearly, is that basically we understand 7 the situation that the licensee could pick some 8 elements in Rev 0 and some elements in Rev 1.
9 And I think that the -- Mark mentioned 10 earlier, when it is a combination, it becomes a new 11 measure. And then, work with NRC staff, we need to 12 evaluate those proposals on a case by case basis.
13 And so, it's just one measure that the Rev 14 Guide just kind of proposes, one measure when there's 15 a combination of those, we anticipate. That's why we 16 plan to do this kind of measure depends on the case 17 specific.
18 DR. SCHULTZ: It just seems that that's 19 very generous for the applicants that it would be much 20 easier for the staff to implement a review of Rev 1.
21 And stick to the advanced guidance that's provided 22 there.
23 But, I appreciate your comment. Thank 24 you.
25 MR. HSUEH: You're welcome.
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66 1 MEMBER PETTI: Okay. Seeing nobody else 2 wanting to make a comment, let's move onto the 3 differing views.
4 We're just a few minutes behind schedule.
5 We're doing actually pretty well, I think.
6 MEMBER MARCH-LEUBA: This is Jose. May I 7 suggest a short going off the record, so I can tell 8 you what's going on with the sound for everybody in 9 the room?
10 MEMBER PETTI: Okay.
11 MEMBER MARCH-LEUBA: Yeah. We're off the 12 record.
13 (Whereupon, the above-entitled matter went 14 off the record at 9:52 a.m. and resumed at 9:53 a.m.)
15 MEMBER PETTI: Okay. Mark, continue.
16 MR. BLUMBERG: Okay. So, we've concluded 17 our presentation on the Regulatory Guidance from the 18 staff. And we're now moving onto the Differing 19 Professional Opinion presentation.
20 So, Mike and I would like to thank you for 21 this opportunity to provide our differing views on 22 this Regulatory Guide.
23 (Off-microphone comment.)
24 MR. BLUMBERG: I'm sorry, is there a 25 problem?
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67 1 MR. MARKLEY: Nope. I'm getting seated.
2 Thanks.
3 MR. BLUMBERG: Great.
4 MEMBER MARCH-LEUBA: You have to talk when 5 you are seated here.
6 MR. MARKLEY: Yeah. I am seated now.
7 Thank you.
8 MR. BLUMBERG: Great. Once again, we 9 appreciate this opportunity to provide this, these 10 views to you. The remarks we are about to make 11 represent our views and do not represent the positions 12 of the NRC staff or our management.
13 As we mentioned before in this previous 14 discussion, your first introduction to our DPO was, 15 which is called DPO 2021-001, was provided in our 16 presentation to the ACRS during the staff's 17 presentation on an interim staff guidance document 18 that was referred to as DRA ISG 2021-01.
19 During that presentation, because the DPO 20 results were not finalized and because the DPO process 21 procedure at that time limited what information could 22 be discussed, we were unable to provide you details 23 regarding that DPO.
24 Today, the DPO case file has been provided 25 to you for your review. However, we understand that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
68 1 it's unlike that you, like us, have had much time to 2 digest the information in this extensive case file.
3 Today, Mike and I will try to provide a 4 short view of our concerns that we had with the 5 publishing of Reg Guide 1.183, Rev 1 in its current 6 form.
7 We will discuss a summary of the report, 8 the DPO report and its recommendations, examples of 9 specific issues, observations and conclusions 10 identified in the EDO's Appeal Panel Report, and as 11 these issues pertain to impacting nuclear safety.
12 We will provide key points for revising 13 Reg Guide 1.183. And, lastly, we will provide a 14 pertinent lessons learned from this DPO that we feel 15 impact safety. Could you please go to slide two?
16 This slide summarizes the directed actions 17 from the Executive Director for Operations, some 18 selected recommendations from the DPO Panel Analysis 19 Report, and where we stand with those recommendations 20 and actions.
21 On August 25, 2023, the EDO issued a memo 22 and a DPO Panel Report. The memo directed actions 23 were to one, take actions to ensure compliance with 10 24 CFR 56(c)(7) for the subject plan and resolve the 25 licensing basis clarity issues for the license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
69 1 amendment, including the impact of MSIV packing 2 leakage, the basis for the limiting break location, 3 and the aerosol deposition credit for the main 4 condenser.
5 And secondly, and as it pertains to this 6 Reg Guide, develop an implementation plan for 7 recommendations in the DPO Appeal Panel Analysis 8 Report. Recommendations in that report stated in 9 part, in light of the issues identified in this 10 report, in the near term, revise and consolidate the 11 staff's updated guidance, and it pointed to the 12 guidance, which was DG-1389 and the ISG.
13 The DPO Panel Report believes any update 14 to Reg Guide 1.183 should be consolidated into a 15 single revision of the regulatory guidance and not 16 include a companion interim staff guidance.
17 And lastly, this is the subject we brought 18 up in the previous presentation, enhance focus on the 19 overall intent of regulations related to DBA analysis.
20 For example, focus on assessing the acceptability of 21 engineering safety features rather than over reliance 22 on non-safety related features such as deposition in 23 the power conversation systems.
24 The report also provides specific issues, 25 observations and conclusions that should be addressed.
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70 1 The NRC staff is evaluating the Report recommendations 2 and possible revisions to Rev 1.
3 But, despite the above direction and 4 recommendations, no changes have been made to the 5 version of Reg Guide 1.183 that you have for your 6 review. Please go to slide three.
7 Slide three provides a very limited set of 8 examples of specific issues, observations, and 9 conclusions that impact nuclear safety. And are 10 directly tied to the guidance that needs to be in Reg 11 Guide 1.183 to ensure safety is maintained.
12 The Appeal Panel Report states that the 13 staff should revise language in the Guidance relative 14 to the MSIV leakage pathway so that the limiting 15 pathway to the environment would be considered.
16 Guidance in Reg Guide 1.183, Rev 1, does not specify 17 this pathway.
18 Regulatory Position A-5.5 would allow 19 licensees who have prior staff approval for crediting 20 deposition and steam lines that could be bypassed by 21 stem leakage. To continue, it allows these licensees 22 to continue to credit that piping.
23 Ignoring this pathway significantly 24 underestimates the doses calculated and does not 25 perform an adequate test of the needed safety systems NEAL 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 1 to protect the operators who are needed to protect the 2 health and safety of the public.
3 The second issue has to do with staff 4 assuming conservativisms that are not reflected in the 5 licensing basis.
6 The guidance needs to be more 7 comprehensive to prevent this from happening in the 8 future and to align with the guidance in 10 CFR --
9 with the rule in 10 CFR 5067 that requires the staff 10 to issue the amendment only if the applicant's 11 analysis demonstrate compliance with the dose limits 12 in the regulations.
13 From a safety perspective, this is 14 important, since conservativisms not credited in the 15 licensing basis can be modified without the 16 recognition that they are important to safety.
17 The third issue is that the removal 18 coefficients for aerosol settling are non-19 conservative. While the staff attempted to resolve 20 this issue in the guidance, the perspective was that 21 what was done for the license amendments, that is the 22 subject of this DPO, is appropriate.
23 The model in the Reg Guidance states 24 specifically that they are only applicable when sprays 25 are not credited. It needs to be more specific and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
72 1 state that both should not be credited at the same 2 time.
3 Updating this guidance would resolve the 4 DPO Panel Report finding that stated that the NRC had 5 not acknowledged these non-conservatisms and revised 6 guidance.
7 Revision 1 should state that Rev 0 8 guidance that was previously issued and enabled the 9 use of this non-conservative removal coefficient 10 should be withdrawn.
11 The fourth bullet pertains to the limited 12 location for the break. It points out that the 13 recirculation line break does not represent a bounding 14 condition.
15 The working group removed language to 16 address this issue in a previous draft revision that 17 should be restored.
18 Lastly, the DPO Panel identified issues 19 with the method for determining what non-safety 20 related pathways to the condenser should be credited.
21 The DPO Panel stated that they disagreed 22 with the inherent seismic robustness of the pathway.
23 That it provides high confidence that a pathway to the 24 condenser will be available in and of itself.
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73 1 type of application for some licensees have identified 2 the need for physical modifications to ensure the 3 pathway is not failed by seismic related failure 4 mechanisms such as system piping interactions and 5 anchor issues. This finding needs to be added to the 6 guidance to reflect this operating experience.
7 And now, I'd like to turn the presentation 8 over to Mike Markley.
9 MR. MARKLEY: So, the key points as far as 10 revising Reg Guide 1.183, these issues are 11 sufficiently technical that it could have warranted a 12 subcommittee meeting. It's very complex, the details 13 and the issues, the mappings, source term tables just 14 like they're talking about here today.
15 And it would have been, I think, much 16 better had we gone that route. But, they're proposing 17 a final now. And they're -- you know, Revision 1 to 18 Reg Guide 1.183 should incorporate the issues in the 19 DPO Appeal Panel and other things that need to be 20 fixed.
21 I mean, fix things that need fixing now.
22 Because what's going to happen is, is you're going to 23 have a whole population of plants propagating these 24 same errors again, or errors that weren't fixed.
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74 1 where these DPOs spawn from was essentially that 2 plants use that ISV or the context of that ISV and 3 submit its submittals that basically they don't meet 4 the systems six and seven.
5 And, you know, the canned rating of 6 conservatism that's not docketed, or it's not part of 7 the licensee's case is not really where we want to be 8 fundamentally.
9 So, you know, for that, I think, you know, 10 the DPO needs to be in this revision. Plus, once you 11 have a population of plants that have adopted a 12 particular revision, they're under no obligation to 13 adopt the next revision just because you issue it.
14 That's their correct licensing basis.
15 We have a lot of plants right now that are 16 using Reg Guide 1.174, Rev 2 rather than Rev 3, 17 because that's their licensing basis they had. That 18 tested five of five approved that way. They have the 19 NOP-05 that way. They haven't figured the PRAs 20 sufficiently to want to take a next step.
21 And so, that's where we would end up, with 22 a large population of plants replicating some of the 23 same errors. And any future revision could be years 24 away.
25 And, I mean, look how long it took to get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
75 1 to Rev 1. These things don't happen quickly. And so, 2 I expect it would be a long, long time before, you 3 know, Rev 2 would become available.
4 And what you heard today was a normal 5 process. And, once you have an expedited process, the 6 DPO lessons learned and implementation plan won't be 7 incorporated if it goes that route. As will your 8 concern about the Sandia questions that you asked 9 today.
10 So, you know, to me you should fix what 11 you fix today. I don't think we should put enterprise 12 risk over radiological risk. This is about dose of 13 the control operators.
14 To the point of one of your questions 15 earlier today, although it's not part of this 16 presentation, we're reviewing licensees' proposals 17 right now to move the TSC away from the control room 18 to other parts of the plant.
19 They have the same dose criteria for the 20 TSC. They have to have the same filtration systems 21 and so forth. So, this is a separate regulation, it's 22 the emergency planning regulations.
23 But, we have other plants that are doing 24 that now. And they've got mitigating pathways of 25 getting into the plant and so forth to do what they NEAL 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 1 need.
2 But, we prefer to see a Reg Guide 1.183 3 right now include the DPO. And that's basically it.
4 Is if you wait until Rev 2, it will be beyond my 5 working career at the NRC.
6 That's all I have. Mark, back to you.
7 MR. BLUMBERG: All right. Thank you, 8 Mike. Could you just go to slide five, please?
9 The EDO report included recommendations on 10 revising and consolidating the staff's updated 11 guidance in DG-1389 in the ISG. It also provided 12 specific issues that should be addressed and 13 recommendations and authorizations regarding the 14 methods to use in the DBA analysis.
15 Of note, DG-1199, which is a previous 16 draft revision to Reg Guide 1.183, was not issued in 17 part because the NRC wanted to inform Reg Guide 1.183, 18 Rev 1, with experience gained by four license 19 amendments.
20 The subject of the DPO is one of those 21 four amendments. So, DG-1389 which superseded 1199, 22 and even the draft final Reg Guide 1.183, Rev 1, were 23 written to propagate the methods that the NRC found 24 acceptable in those amendments.
25 However, the DPO shows that the methods NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
77 1 used in the amendments did not demonstrate compliance 2 with 10 CFR 5067, which is used to ensure nuclear 3 safety. These methods erroneously allowed a safety 4 system to be removed and containment isolation valve 5 leakage to be relaxed.
6 Approving the current version without 7 incorporating the lessons learned and recommendations, 8 will continue to propagate these methods that do not 9 ensure nuclear safety.
10 So, in conclusion, we believe that it is 11 clear that issuing Reg Guide 1.183, Rev 1, without 12 incorporating the lessons learned from our DPO would 13 be a mistake. The DPO provides a real life example of 14 how methods in the proposed revision do not provide 15 adequate guidance to ensure nuclear safety.
16 That concludes the presentation that we 17 have on the DPO.
18 MEMBER PETTI: Questions? Thank you.
19 Members, questions or comments again on anything 20 before we go to public comment?
21 MEMBER BROWN: This is Charlie Brown.
22 MEMBER MARCH-LEUBA: Loudly, Charlie.
23 MEMBER BROWN: Okay. I'll speak louder.
24 Can you hear me?
25 MEMBER MARCH-LEUBA: Yes, thanks.
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78 1 MEMBER BROWN: As one that's not steeped 2 in the language of this Reg Guide and the DPO, and, if 3 I take the spin from it, I'm trying to understand from 4 somebody that's knowledgeable, it's plain it's not me.
5 Main steam valve leakage from piping and 6 other places that's obvious you shouldn't have that.
7 What I get is that leakage that is a mess and plant 8 experience will, this creates a problem with a source, 9 to come up with a source term type determination.
10 Did you hear me okay?
11 MR. BLUMBERG: So, from my perspective, it 12 causes a problem because it bypasses the pathways that 13 we're crediting for removal of that radioactivity.
14 And that's exactly what was done in this 15 example. Was that particular pathway was not 16 considered and the downstream piping was credited.
17 MEMBER BROWN: But, is the volume of that, 18 is the volume of that extension to create a problem?
19 Or, is that just because we removed the downstream 20 pathway?
21 In other words, is that a major 22 contributor to overall source term usability or 23 viability?
24 That was my question. I mean, it seems to 25 me you can't operate because steam is pouring out of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
79 1 all the packing breaks. So, how does -- whether you 2 have this capturing system or not, it seems to me to 3 be just another -- it maybe that -- it may not be that 4 bad. I don't know how to say that any other way.
5 MR. BLUMBERG: So, there are several 6 examples in the DPO Panel Report. I don't know if we 7 have a DPO Appeal Panel member on this call. So, I 8 don't want to speak for them.
9 But, there are several examples if you 10 look at the report as to how that can occur. And why 11 they felt that it was something that needed to be 12 considered.
13 MEMBER BROWN: Okay.
14 MEMBER MARCH-LEUBA: The staff wants to 15 make some comments?
16 MEMBER PETTI: Do you want to call it?
17 MEMBER MARCH-LEUBA: It's up to you.
18 MEMBER PETTI: We've got to be careful 19 here, because this is a unique situation. So, I just 20 want to make sure that the Members have adequately 21 asked enough questions of the folks that have issued 22 the DPO.
23 We can then move when that's done to what 24 the staff feels. I just don't want to get into a back 25 and forth on this.
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80 1 MEMBER BROWN: That's fine. I just 2 happened -- I tried to, when I read what this -- a lot 3 of this was all I had.
4 MEMBER PETTI: Absolutely.
5 MEMBER BROWN: And I saw the issue and I'm 6 just relating it to past experience. And how big of 7 a source -- how big of a conflict is that?
8 And that's why I couldn't find an answer.
9 I -- there was no way I was going to find it in the 10 voluminous number of pages.
11 So, I figured I'd try to listen to the 12 presentation and then see what the facts the operating 13 plants have to say. But, I'm done. That was it for 14 me.
15 MEMBER PETTI: Okay.
16 CHAIRMAN REMPE: So, the question really 17 is a staff question rather than a question for the DPO 18 presenters.
19 MEMBER BROWN: Well, I guess, I don't 20 know. I don't know if maybe it's a mix. I don't 21 know. I'll ask the staff about those.
22 CHAIRMAN REMPE: So, that's finished with 23 the DPO presenters. And I suppose it's allowed to go 24 back to a staff question before we go to public 25 comment?
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81 1 MR. BURKHART: It's up to you all. This 2 is Larry Burkhart. I just want to make clear that 3 this is the DPO presentation. And they are available 4 for your questions.
5 Of course, whenever you want to talk to 6 the staff, they'll answer your questions with that.
7 MEMBER BROWN: I'm just -- I'm just 8 looking for somebody to tell me what the answer to 9 that question is. That's all.
10 But, the staff sounds like the right place 11 then.
12 MR. MARKLEY: The staff can explain it to 13 you. But, I mean, the simple answer is, is this is 14 how you don't meet 5067 for controlling dose.
15 MEMBER BROWN: So, it's about controlling 16 dose. Not about dose levels.
17 MR. MARKLEY: This is Mike Markley. I 18 apologize.
19 MEMBER BROWN: Okay. So, there is not a 20 contributor to the general population. This is 21 strictly a local issue relative to the dose.
22 MR. BLUMBERG: So, it would contribute to 23 both offsite dose as well as in the control room. The 24 source room contributes to both.
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82 1 challenge -- right, the public dose limits, it 2 challenges the control room, dose limits imposed by 3 the control room.
4 MR. BLUMBERG: So, in the example in the 5 DPO, it did not challenge the offsite dose limits.
6 MEMBER BROWN: Okay. I understand that 7 now. Okay.
8 MEMBER PETTI: Yeah. But, obviously it's 9 higher, but yeah. Okay.
10 MEMBER BROWN: All right. I'm done and 11 I'll let you all finish this off. That was my 12 question.
13 MEMBER PETTI: Okay. How about the staff?
14 Are you happy with the staff? Do you want -- are you 15 happy with that?
16 MEMBER BROWN: I'm done. Yes. Thank you 17 for that.
18 MEMBER PETTI: Okay.
19 MEMBER ROBERTS: I have one quick 20 question. What is the downside of holding off on Rev 21 1? That means Rev 0 would be in effect for some time 22 while you resolve the Rev 1 issues.
23 Is there some mitigation plan to get rid 24 of Rev 0, or is Rev 0 just fine for the near-term?
25 MR. MARKLEY: This is Mike Markley.
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83 1 Certainly the DPO panel report describes what the 2 EDO's office would like to see done with it. To say, 3 I don't know if you want to call it sunsetting it or 4 retiring it or however they characterize it, but the 5 challenge you have, and it was described earlier, is 6 that a plant that has that as their licensing basis is 7 kind of an, the regulator is in a hard place to try to 8 encourage them to want to adopt a new version. They 9 are capable of maintaining it at version, it's just it 10 wouldn't be available for future adoption as a Rev 0.
11 MEMBER ROBERTS: Okay. Maybe I wasn't 12 clear on the question. If you go to Slide 4 your last 13 bullet says you prefer to resolve Reg Guide 1.183 Rev 14 1 now. It would presumably take, I don't know, I'm 15 guess, it's not going to happen tomorrow, it takes 16 time to work through those issues. Is there any 17 consequence to delaying the existing version of Rev 1 18 and continue to rely on Rev 0 for however long it 19 takes to resolve these issues?
20 MR. MARKLEY: I think Mark's Slide 3 spoke 21 to some of the deficiencies. And I'll let Mark answer 22 some of that. But I think the challenge from my 23 perspective, this is Mike Markley again, that it's not 24 going to solve the errors, you're going to still 25 propagate more errors in the outcomes. I mean, it is NEAL 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 1 an improvement over Rev 0, no doubt.
2 MR. BLUMBERG: So I think the answer, this 3 is Mark Blumberg again. I think the answer to your 4 question relies with management. Maybe they can 5 answer that. But my understanding is that it imposes 6 an enterprise risk. And I'll let them expand upon 7 that.
8 CHAIRMAN REMPE: We're going to have a 9 problem --
10 PARTICIPANT: Yes.
11 CHAIRMAN REMPE: -- here again --
12 PARTICIPANT: Yes.
13 CHAIRMAN REMPE: -- with, this is the DPO 14 Q&A part.
15 PARTICIPANT: Correct.
16 CHAIRMAN REMPE: And we have some 17 questions to the staff after we get through this.
18 MEMBER ROBERTS: I understand that. And 19 of course my question was, there is some downside to 20 the recommendation.
21 (Simultaneous speaking.)
22 MEMBER ROBERTS: -- professional 23 representation to delay to Rev 1. I'm trying to 24 understand what that risk is.
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85 1 again. And I apologize, but the last slide we have 2 on, I mean, the last bullet on Slide 4, really 3 characterizes the problem it puts us in. We feel 4 like, as the DPO submitters, we'll never get out of 5 the submittal of different views. We may end up 6 having to submit a different view on the Reg Guide, as 7 well as the first one (audio interference) precedence 8 to come in the door because it's not being fixed.
9 MEMBER ROBERTS: Okay, so you're saying 10 that it is, you think it's more of a risk proceeding 11 with Rev 1 then delaying Rev 1?
12 MR. BLUMBERG: I would fully agree with 13 that. You know, I'd just like to be given the 14 opportunity to fix these issues.
15 MEMBER BROWN: Tom, could you repeat that, 16 what you said again?
17 MEMBER ROBERTS: Yes. I think what Mark 18 just agreed with is there is more of a risk with 19 proceeding with Rev 1 than delaying it. But there is 20 some risk either way. Right? There is some risk with 21 continuing to proceed with Revision 0 for another, I 22 don't want to say a time, a year or two years. I 23 don't know what it will be to cut through all these 24 DPO issues and come up with a revised Rev 1.
25 They said it will continue Rev 0 for some NEAL 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 1 time. I was trying to understand what risk that 2 presents. That's the question I meant.
3 CHAIRMAN REMPE: So I guess I have a 4 question. And I wasn't going to nitpick it, but I 5 will I guess.
6 On Slide 2, the last bullet, you have the 7 slide is evaluating the DPO appeals panel report 8 recommendations and possible revisions to Rev 1 of Reg 9 Guide 1.183. My understanding is that at some point 10 the staff must evaluate and implement something to 11 address those recommendations. It's a question of 12 when, which is sort of what Tom is going into to. And 13 so Tom hit the bottom line.
14 But I think if I were going to nitpick I 15 would say that they less, and it's more of a, a win to 16 implement the recommendations. Is how I look through 17 to that last bullet --
18 MR. MARKLEY: Right.
19 CHAIRMAN REMPE: -- because they know they 20 have to.
21 MR. MARKLEY: Yes. But what we have been 22 told is it's going to kick down to Rev 2.
23 CHAIRMAN REMPE: Okay.
24 MR. MARKLEY: Yes.
25 MEMBER PETTI: At this point, given where NEAL 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 1 we are on time, I think we should give public a couple 2 comments and then we'll come back to our discussion.
3 PARTICIPANT: Hold on.
4 MEMBER PETTI: Okay. Okay. Okay. So 5 before we close it -- yes. Mike, I'd figured we'd 6 address this after public comments, but where are you 7 in the appeal process?
8 Tell us what the lay of the land is. And 9 really, with your best guess of schedules really I 10 think (audio interference) in this whole discussion.
11 MR. BLUMBERG: So the question is where we 12 are in the appeal process?
13 MEMBER PETTI: Yes. It's not --
14 CHAIRMAN REMPE: This --
15 MEMBER PETTI: It's not for you; this is 16 for the staff.
17 MR. BLUMBERG: Thank you.
18 MR. FRANOVICH: I don't want to take too 19 much time, and we didn't come here to debate point-20 for-point, respecting the Committee's time.
21 There is probably one or two technical 22 matters that I, like you chose just to address, that's 23 already captured in the guidance. We also have some 24 guidance already in this current rev regarding seismic 25 lock downs. But I'd like Steve to address one or two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
88 1 things, and then I have an overall perspective I'll 2 share with you on time, and time frames and other 3 matters that have been over relayed to you.
4 MR. JONES: So Steve Jones. Currently 5 with Division of Advanced Reactors, but previously 6 with the Division of Safety Systems.
7 With respect to packing leakage I'd just 8 like to briefly indicate why it's considered. As it's 9 been discussed in this meeting it's a style, you know, 10 a generalized stylized assumptions of regarding how to 11 calculate the dose on operators. It's a potential 12 unfiltered release path.
13 When most of the leakage paths are 14 contained within the secondary containment and there's 15 a standby gas treatment system that would gather that 16 leakage and filter it and release it through a stack 17 which, you know, removes it from the control room.
18 In the case of a, the way the leakage is 19 assessed on the MSIVs, there is two valves. One is 20 inside primary containment, the other is outside 21 primary containment and secondary containment in the 22 stream tunnel. And their pressurized in-between and 23 measure the overall leakage.
24 They cannot really detect what leakage 25 goes where, but there is generally an assumption in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
89 1 the calculations. But the inboard valve fails open 2 and the outboard valve thus sees full containment 3 pressure. And if you look at what's the most adverse 4 lead path it would be when crediting potentially 5 downstream, that position and other factors.
6 The leakage out the packing would be then 7 released into the steam tunnel, which is a seismic 8 structure. But it doesn't have a sealed confinement.
9 And it's assumed to release directly to the atmosphere 10 at that point. Generally as a very conservative 11 assumption.
12 So there is a lot of conservatism stacked 13 out there with the leakage, you know, the inboard 14 valve being open, all the measured leakage being 15 assumed to go out one path, and then that path being 16 an unfiltered direct release to the atmosphere, where 17 that location is, with respect to the control room 18 intake. Or in the case of the offsite dose 19 consequences, the dose boundary.
20 MEMBER MARCH-LEUBA: So you're -- this is 21 Jose.
22 MR. JONES: Yes.
23 MEMBER MARCH-LEUBA: In summary what 24 you're saying is the calculated dose from the leakage 25 of the MSIV includes a large number of conservatisms?
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90 1 MR. JONES: That's correct. Right.
2 MEMBER MARCH-LEUBA: Thank you.
3 MR. JONES: And then with respect to the 4 Rev 0 versus Rev 1 of the Reg Guide, Rev 0 has in 5 place endorse, or essentially endorsement of a BWR 6 owner's group topical report that allows credit for 7 the main condenser to collect leakage. And in that 8 approach, there generally the packing leakage is not 9 necessarily assessed. It's assumed all the leakage 10 goes to the main condenser.
11 And we're essentially maintaining that 12 same approach. We've both, in Rev 1 we've relaxed the 13 detail requirements for low seismic hazard plants in 14 assessing how robust the steamed piping is and the 15 condenser is for that function.
16 MEMBER MARCH-LEUBA: For my back of the 17 envelope thinking type calculations, what's the 18 fraction of the source term that gets described by the 19 condenser, is it 98 percent or is it 50 percent? Do 20 you know?
21 MR. JONES: That's really outside my area 22 of expertise. What I would say is that I guess the 23 reason we're looking here is, this is a small fraction 24 of overall primary containment leakage. What makes it 25 significant is that it's unfiltered. And the filters NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
91 1 give you a, you know, 95 percent. So 20, a factor of 2 20 in reduction in dose. Plus it's released at a 3 point far away.
4 In this case it's unfiltered --
5 MEMBER MARCH-LEUBA: Right.
6 MR. JONES: -- so you get 20 times the 7 value. And it's near the, near the point that you're 8 measuring, so you care about it more.
9 MEMBER MARCH-LEUBA: So again, in your 10 mind it's conservatism that you can calculate the 11 number simply because you know what the real answer 12 is, but you know it's too large by design?
13 MR. JONES: Right.
14 MEMBER MARCH-LEUBA: Thank you.
15 MR. BLUMBERG: Could I as a staff Member, 16 not a DPO presenter answer the technical question 17 that's at hand?
18 MEMBER PETTI: Go ahead.
19 MR. BLUMBERG: So the amount of scrubbing 20 that is performed in the condenser is highly dependent 21 upon the aerosol deposition upstream. In general 22 there is very little scrubbing in the condenser, but 23 the condenser provides a hold up volume that is quite 24 large that reduces the dose substantially. And it can 25 be anywhere from, you know, ten to 100. Factor of ten NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
92 1 to 100.
2 It really is very site dependent in how 3 much leakage is coming in and going out of that hold 4 up volume. Does that help?
5 MEMBER MARCH-LEUBA: Yes. Thank you. So 6 it could be as high as a hundred, a factor of a 7 hundred, which would make it significant. But there 8 are many assumptions like failure of the MSIV inside 9 containment, which I think is the main number if you 10 were going to PRA. Okay, thank you very much.
11 MR. MARKLEY: Mike please? Thank you.
12 I'll be respectful of your time. I really do 13 appreciate the views that Mark and Mike have shared 14 with their colleagues and with the ACRS. I think 15 we're better off organizationally to have those 16 conversations. They're not easy conversations, but 17 they are necessary.
18 We are a learning organization. We have 19 lessons learned from our experience of the four LARs.
20 In particular, the one plant right now where we have 21 to clarify the licensing basis, working with the 22 licensee.
23 And so, I want to note that this is part 24 of our journey here in trying to advance our 25 practices. Remind you of many of the specifics that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
93 1 were raised today have been directly or indirectly 2 considered in the DPO appeal process. Which 3 essentially is now a settled matter.
4 Some of the raised concerns were supported 5 and some were not. It's kind of an unprecedented 6 situation. You know, I don't think we've seen that 7 historically before.
8 A lot of the issues were very plant-9 specific also. So, we need to recognize that the 10 discussion points were focused on a particular 11 licensing action while there are some extended 12 condition issues we have to deal.
13 The recommendations to the guide are 14 opportunities to increase clarity in the future. But 15 in our opinion, they didn't rise to the level of 16 nuclear safety concerns.
17 Further, the DPO decision will be 18 available to all NRC staff so the decision and 19 expectations will be made clear for licensing actions 20 that are reviewed in the interim period between 21 Revision 1 and 2. So it will be widely known. It's 22 already widely know that we have some lessons learned 23 here.
24 Any new issues that were presented today 25 are due appropriate consideration during the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
94 1 development of Revision 2 and thus athwart all 2 stakeholders opportunities for review and comment.
3 Once publicly released, external stakeholders will 4 also have the benefit of the EDO's decision to better 5 inform their perspectives.
6 The concerns raised today need to be 7 properly weighed against other changes that may 8 obviate or support new positions. Along with any 9 potential changes based on the EDO's direction from 10 the appeal.
11 We have noted today that there are many 12 future updates that need to be done. I won't repeat 13 all those for sake of time. They are urgent matters.
14 They do present enterprise risk.
15 If you haven't watched some of the 16 hearings that our Commission has been faced with on 17 Capitol Hill, you can watch those certainly on 18 YouTube. I think there is a very high stakeholder 19 interest in advancing technologies. And this is one 20 small link, but an important link, in that overall 21 mosaic of activities in our country.
22 The management team and staff have taken 23 time to look at the EDO's decision on the appeal.
24 Based on those reviews we have not identified any 25 safety significant concerns on the impact of Rev 1.
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95 1 We further believe that the issues raised or concerns 2 raised are those that we can address, add clarity if 3 needed in Rev 2. They are significant enhancements 4 identified for in Rev 1 that we see an importance of 5 issuing this guide now in the near-term.
6 In short, a balanced, integrated and 7 timely effort is necessary to meet the Commissions 8 expectations for the high priority increased 9 enrichment rulemaking. We discussed that earlier.
10 And regulatory guide 1.183 is an important 11 link in the effort. Regarding the appeal, the staff 12 will develop an implementation plan, we're required 13 to, we were directed by the EDO, and execute that plan 14 in accordance with requirements, policies and other 15 processes of the Commission.
16 In furtherance of the way forward I want 17 to note the following. The EDO concluded there is no 18 immediate safety concern. And as noted in the appeal 19 panel's report, the issues did not warrant assessment 20 under NRR's process for emergent safety issues, better 21 known as the LIC-504 process.
22 I'm the executive sponsor for that 23 process. I'm probably one of the few people left in 24 the agency who actually worked on it. Not having to 25 invoke this process does give you a perspective on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
96 1 level of safety concerns.
2 Shaping this outcome is the recognition of 3 U.S. plants and performance and having greatly 4 strengthened over the 25 years since 50.67 was 5 actually issued. That was a long list of 6 accomplishments, but here is a few of key moments.
7 Post-9/11 mitigation measures, post-8 Fukushima flex mitigation strategies, BWR reactor 9 accident and capable events, reevaluation of both 10 seismic and flood hazards, and other physical plant 11 modifications ought to reduce plant risks.
12 That said I'd like to convey on behalf my 13 comprehensive review of the EDO's decision of the 14 appeal. My position, and that of the NRR executive 15 team, is to issue the Reg Guide Revision 1 without 16 undue delay. It's time to take the first step in 17 advance regulatory positions and methods reflected in 18 the state of the practice, and accident consequence 19 dose assessments.
20 This step forward enables development and 21 employment of the myriad of advance fuel technologies.
22 The staff is requesting a letter report from the 23 Committee for issuance of Revision 1. Thank you very 24 much. And I'll take any questions if you have any 25 (audio interference).
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97 1 MEMBER PETTI: Okay.
2 MR. MARKLEY: Very good. Thank you.
3 MEMBER PETTI: Thank you. Let's now turn 4 to public comment, and then we'll come back to our 5 next steps to go over. So, let's see. First on the 6 agenda is Paul Clifford from Integrated Nuclear 7 Solutions.
8 MR. CLIFFORD: Okay, good morning. And 9 thanks for the opportunity to speak. My name is Paul 10 Clifford, and I am here representing myself. I am not 11 here representing the NRC staff, like I did for 20 12 years. And I'm not here representing the Nuclear 13 Industry.
14 Today my focus is on the MHA LOCA releases 15 that are in Tables 1 and 2 of the proposed revision to 16 the Reg Guide. I provided a set of slides, which I 17 believe will be put in the transcripts. That was sent 18 last week to each of the members. It might help to 19 walk through those slides with me. And there is a lot 20 of good background material there that may be useful 21 to you during future deliberations on this topic.
22 Let me start with some conclusions and 23 recommendations, and then I'll walk back through some 24 of the examples that really illustrate the regulatory 25 uncertainty that's introduced by the issuance of Rev NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
98 1 1.
2 First of all, the first main conclusion is 3 that the Sandia reports document that, both the 2011 4 and the 2023 reports, that there is no burn-up 5 dependents of the released fractions and that the 6 dramatic differences are due solely to the 7 improvements and enhancements to the MELCOR model that 8 then have downstream effects on the accident 9 progression, the timing and the magnitude of releases.
10 So therefore these release fractions are applicable to 11 the current operating fleet because they're not just 12 increased as you go up higher and burn-up, they're 13 applicable today.
14 That being said, these represent 15 significant research findings. And they suggest that 16 the plant's licensing basis, which is based on the Rev 17 0 regulatory basis, may be challenging. The NRC's 18 response to these research findings is inconsistent 19 past, present and regulatory policy.
20 The second major point is that the risk 21 attributes and safety significance associated with 22 these dramatic changes need to be evaluated to 23 determine what, to determine if immediate actions are 24 needed to ensure adequate protection of public health 25 and safety.
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99 1 I don't believe this has been done. The 2 very first thing that's usually done in response to 3 new research findings is to assess individual plant 4 safety.
5 Moving on to Point Number 3. As I will 6 show by these examples, issuing Rev 1 in its current 7 form does not provide regulatory stability or 8 predictability. A good example is that the 2011, if 9 you recognize that there is no burn-up dependents, 10 that means the 2011 release fractions are no longer 11 relevant and they've been superseded by the 2023 12 release fractions. So therefore issuing Rev 1, by the 13 time it's published, it will already be outdated.
14 The only way to provide regulatory 15 stability and predictability is for the staff to 16 follow regulatory requirements with respect to back 17 fit and to follow their own management directives. A 18 back fit determination to document a reasoned 19 justified risk-informed decision on how, or if, these 20 changes should be implemented on the exited fleet 21 needs to be completed.
22 Second, after a revision to the guidance 23 is made, a forward fit determination needs to document 24 a reasoned justified risk-informed decision on when, 25 or if, any future guidance will be applied to future NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
100 1 licensing actions.
2 As I mentioned, there is no burn-up 3 dependence. But if you look at the revisions, Rev 0 4 is clearly listed, the range of applicability up to 5 62. Rev 1, range of applicability to 68. And the 6 future proposed Revision 2, which will be based on the 7 Sandia 2023, would be applicable up to 80 gigawatt 8 days.
9 But the existing pathway that the staff 10 has chosen is that all three Reg Guides are going to 11 coexist. So if you recognize that there is 12 overlapping applicability, you can understand the 13 introduction of regulatory uncertainty with having 14 three sets of guidance that are applicable to all 15 plants.
16 So in my slides I provided some 17 interesting text extracted directly from the Sandia 18 reports. Which backs up these claims of no burn-up 19 dependence.
20 Now, with respect to Commission policy, 21 all of the Sandia reports are applicable to the 22 existing fleet. Implementing new release fractions is 23 a change to a regulatory position and must be 24 evaluated in accordance with 10 CFR 51.09, back fit, 25 and in accordance with Commission policy as dictated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
101 1 by management directive 8.4.
2 Now let me just read just an excerpt of 3 what the Commission policy is as stated in management 4 directive 8.4. Now back fit and forward fit 5 evaluation and analysis requirements provide the 6 benefits of, A, regulatory stability, by ensuring that 7 the changes the plant makes are necessary or provide 8 a substantial safety enhancement. B, provide reasoned 9 and informed NRC decision making by requiring the 10 proposed actions be properly justified. And C, 11 provide transparency of NRC decision making by 12 requiring that the NRC document and make publicly 13 available its analysis and its evaluations. To date 14 I don't believe this has been done.
15 Now, my proposed pathway --
16 MEMBER PETTI: Paul how much longer?
17 MR. CLIFFORD: I believe one minute.
18 MEMBER PETTI: Okay.
19 MR. CLIFFORD: My proposed path forward 20 would be to just recognize that the 2023 report 21 supersedes the 2011 and therefore 2011 is irrelevant.
22 And so the staff should evaluate the safety 23 implications of 2023 using risk and safety 24 significance in accordance with procedure, identify 25 whether immediate actions are necessary and then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
102 1 document a back fit determination on how to proceed 2 with this new information. At that point Rev 1 should 3 be issued based upon the 2023 report, and a forward 4 fit determination should be documented.
5 An alternative, to avoid further delays, 6 would be to issue Rev 1 without any changes to Tables 7 1 and 2 with just the other improvements that we heard 8 about today. Get that on the street and then provide 9 the staff an opportunity and time, schedule, to do a 10 back fit, forward fit determination.
11 Now the three examples I'm providing here 12 are, so Plant Y requests approval for a power uprate.
13 No change to burn-up, so they're going to maintain 14 their existing 62 meter watt days. All three 15 revisions would be applicable to that current plant 16 because it's staying at 62. And even if you follow 17 the advertised range of applicability they're all 18 applicable to 62.
19 So, is the licensee able to maintain Rev 20 0? I don't know. Will the staff expect that the 21 latest revision be followed? Maybe. We don't know.
22 That's the regulatory uncertainty. We 23 don't want licensees to spend a lot of time updating 24 dose counts, submit them, then all of a sudden they're 25 not accepted. So maintaining the three active NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
103 1 versions is a problem.
2 The second example would be Plant C, which 3 would request a high burn-up time management reload 4 cause up to 75. Well, if you just read the range of 5 applicability, only Rev 2, the future Rev 2 would be 6 applicable.
7 However, the Sandia reports would clearly 8 demonstrate that the releases are not sensitive to 9 high burn-up, so therefore would the plant be able to 10 maintain Rev 0 which is in its current license basis, 11 along with the argument that there is no burn-up 12 dependents. I don't know if that would be accepted.
13 And I'm not sure how the staff would response. That's 14 regulatory uncertainty.
15 The final example would be, if we continue 16 down this path and say six months from now a new plant 17 requests a modest increase of burn-up, say 68 gigawatt 18 days, they follow Rev 1, which has the 2011 release 19 fractions, and they update all their dose 20 calculations. Well during the LAR review, a 21 individual staff reviewer may insist that I've got new 22 information here with the Sandia 2023, and based upon 23 adequate protection I require you to implement the 24 latest review. The latest release fractions.
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104 1 equate to regulatory stability and predictability 2 because we don't know how individual staff reviewers 3 are going to address the fact that there is this known 4 information out on the street left over.
5 MEMBER PETTI: Thank you. Next we will 6 hear from Al Csontos representing NEI. Come on up.
7 MR. CSONTOS: Okay.
8 PARTICIPANT: Speak loudly.
9 MR. CSONTOS: Okay. Thank you. My name 10 is Aladar Csontos from Nuclear Energy Institute 11 presenting on the Industry's feedback and perspectives 12 on the Reg Guide.
13 So we have a position paper that we will 14 provide for the record. And we'll email it to Larry 15 after this meeting is over. I will not go over the 16 three pages, I will give you the highlights.
17 The highlight is, is that the Industry 18 supports the publication of Rev 1, okay? We know it's 19 not perfect, okay?
20 We have multiple utilities with multiple 21 PWRs, and also BWRs, who are interested in exercising 22 Rev 1 to support going to 68 burn off, but also put 23 into your cycles. And I understand some of the 24 concerns we have here but we need to walk before we 25 run, okay?
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105 1 And in this case we're walking, okay? And 2 moving forward to a place where we can go to ATF 3 higher burn-up. First and foremost going to the 4 smaller portion here where we're going to multiple 5 utilities and multiple sites that are going to need 6 this to go to two year cycles. Okay?
7 I have one person from Southern Nuclear.
8 Let me give some background. We have been waiting for 9 this Reg Guide for a while. Okay? It was supposed to 10 be out last September, I believe was the initial date 11 that this given when this was first created. We have 12 had many of meeting. Okay?
13 And the last RIC, NRC RIC meeting that was 14 out there, we had Southern Nuclear provide an update 15 and a request to have this done by no later than June 16 of this year to support their business decisions.
17 Okay. And that's just one utility.
18 So I'd like to have Tom Kindred from 19 Southern Nuclear. I don't want you to just hear from 20 me, I want you to hear from one of the utilities. I 21 didn't want to get all five or six of the utilities to 22 come in and tell you this, so I just got one for right 23 now. So, Tom, can you go ahead and speak to your 24 interests?
25 MR. KINDRED: Sure thing, Al. Can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
106 1 everyone hear me?
2 MEMBER KIRCHNER: Yes.
3 MR. KINDRED: Hey, this --
4 MEMBER PETTI: Yes.
5 MR. KINDRED: All right, thank you. This 6 is Tom Kindred. I'm a consulting engineer in the 7 nuclear of fuel and analysis department at Southern 8 Nuclear. I'd like to thank the Committee for hearing 9 Southern Nuclear's position on this important topic.
10 In regards to Regulatory Guide 1.183 11 Revision 1, Southern Nuclear would like to affirm our 12 support and alignment with the remarks delivered by 13 the Nuclear Engineer Institute. Our fleet, the 14 Southern Nuclear fleet, has a pressing need this year 15 to see final publication of this Reg Guide as it would 16 enable, whereas approval of the Reg Guide would enable 17 streamline alternative source term methodologies and 18 mid-increased burn-ups in the broader adoption of 19 accident tolerant fuel load pellets and pressurized 20 water applications.
21 We believe at Southern Nuclear that 22 Revision 1 provides a stable and predictable licensing 23 approach that is prudent to support our initial 24 investments to move forward with ATF features that 25 improve safety and lower the cost of electricity for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
107 1 our customers. Thank you.
2 MR. CSONTOS: Thank you. And so that's 3 the key point here is that, you know, we need Rev 2 as 4 well. And we need Rev 2 as expeditiously as possible.
5 We want to have engagements with the staff early, 6 often and frequent, to address many of the issues that 7 we're hearing articulated here.
8 We've identified a lot of the technical 9 issues that we've identified in the Rev 1. We placed 10 them into here. And also the discussion topics for 11 Rev 2. Okay?
12 I don't want to go into, I don't want to 13 belabor the point, but ultimately we do need durable, 14 predictable guidance in this area for the future.
15 Especially when it comes to going to two year cycles 16 and up to 75 gigawatt days ran to you. And the ATF 17 features. Okay?
18 That's a tall order in a short period of 19 time, but we need it as soon as possible, but no later 20 than 2026. Okay? That's really a hard, yes. We 21 need, that's a hard goal date. So that's going to be 22 tough, but I think that we can get there if we have 23 these engagements, workshops.
24 And we have our counts and we can share 25 these information back and forth. In an open forum.
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108 1 And that's ultimately all I wanted to say. If there 2 is anything else?
3 MEMBER PETTI: Thank you. Members, let's 4 hope we can finish by the top of the hour here with 5 where we want to go. Not that we'll have it all 6 locked in. We are --
7 MEMBER MARCH-LEUBA: No, no. The court 8 reporter --
9 (Simultaneously speaking.)
10 CHAIRMAN REMPE: The court reporter is to 11 be on for the rest of this or is it time to take a 12 break, release the court reporter --
13 (Simultaneous speaking.)
14 MEMBER PETTI: Oh, yes, true. Okay. Yes, 15 are there any other public comments? Not hearing any, 16 then, yes, I think we should release the court 17 reporter.
18 CHAIRMAN REMPE: Okay. So at this time, 19 Jim, we'd like you to go off -- we would like to go 20 off the record, and we'd like you to come back at 1:00 21 p.m. today.
22 (Whereupon, the above-entitled matter went 23 off the record at 10:46 a.m. and resumed at 12:59 24 p.m.)
25 CHAIRMAN REMPE: It is 1:00 p.m. on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
109 1 East Coast. And I'd like to ask our Member, Matt 2 Sunseri, to lead us through the next topic for today.
3 MEMBER SUNSERI: Thank you, Chair Rempe.
4 Good afternoon, everyone. My name is Matt Sunseri and 5 I chair the Subcommittee that reviews plant license 6 renewals.
7 This afternoon we are reviewing a 8 subsequent license renewal applicant for plant St.
9 Lucie. We will hear from the applicant, Florida Power 10 & Light, and staff on the technical and safety aspects 11 of the application.
12 The Subcommittee received the SLR 13 application, relevant inspection reports and staff 14 review around the 1st of August. We know that leading 15 into our review there were no open or unresolved 16 issues, and no confirmatory items. This status, by 17 our process, allows the Subcommittee to perform our 18 review virtually and to bring the results directly to 19 the full Committee.
20 We have prepared a draft report based on 21 our preliminary review, and we will be ready to 22 finalize our report following the applicant and staff 23 presentations and the full Committee deliberations.
24 Due to the work that I do outside of the 25 ACRS, I am recusing myself from portions of this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
110 1 review related to the metal and environmental fatigue 2 or radiation embrittlement of the reactor pressure 3 vessel. At this time I now turn the presentation over 4 to Bernie Thomson, deputy director, new and renewed 5 reactor licensing. Or NRC opening remarks. Bernie.
6 MS. THOMSON: No --
7 MEMBER SUNSERI: That's not going to work.
8 You're going to have to speak louder.
9 MS. THOMSON: Thank you.
10 MEMBER SUNSERI: Yes.
11 MS. THOMSON: We are experiencing IT 12 issues throughout all of the following results not 13 just you, it's everyone. But thank you for the 14 introduction. And thank you, Chair Rempe, and Members 15 of the ACRS. My name is Bernie Thomson and I'm the 16 Deputy Director or (audio interference) --
17 MEMBER SUNSERI: Okay. All right.
18 MS. THOMSON: Thank you again. Can you 19 hear me now?
20 MEMBER MARCH-LEUBA: Yes.
21 MS. THOMSON: Okay. So, thank you again.
22 And good afternoon. My name is Bernie Thomson. I'm 23 the Deputy Director of the Division of New and Renewed 24 Licenses in the Office of Nuclear Reactor Regulation.
25 We appreciate the opportunity today to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
111 1 present to the ACRS the results of the staff's review 2 of the seventh application for subsequent license 3 renewal. This application was submitted by Florida 4 Power & Light for the St. Lucie Plant Units 1 and 2 5 located in Jensen Beach, Florida.
6 For background, St. Lucie Units 1 and 2 7 received approval for their initial license renewal on 8 October 2nd, 2003. The NRC review, at that time, was 9 performed using guidance developed prior to the 10 issuance of the Generic Aging Lessons Learned Report, 11 or the GALL report.
12 The initial GALL Report was issued in 13 2001. The NRC guidance for license renewal has 14 evolved over the years through enhancements and 15 improvements based on the lessons learned from the NRC 16 application reviews. And from consideration of both 17 domestic and international industry operating 18 experience.
19 The initial GALL Report for license 20 renewal went through two revisions with additional 21 interim staff guidance following Revision 2. GALL 22 report Revision 2, along with these ISGs, were used to 23 develop the guidance for subsequent license renewal 24 that's contained in the GALL SLR report.
25 In addition to the previous license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
112 1 renewal guidance, the GALL SLR Report included 2 additional focus on the aging management and (audio 3 interference) time-limited aging analysis focused on 4 the operations in the 60- to 80-year time period.
5 NRC project managers, the project manager 6 for the St. Lucie subsequent license renewal 7 application review is Vaughn Thomas. Vaughn will 8 introduce the staff who will be presenting and 9 addressing questions regarding the safety review.
10 Part of the management team here with me 11 today is Lauren Gibson, chief of the license renewal 12 projects branch. As well as branch chiefs of the 13 staff involved in the technical review.
14 Our senior technical advisory for aging 15 management, Dr. John Wise, will also be available to 16 answer questions from the Committee.
17 Paula Cooper, Region II, senior reactor 18 inspector, will discuss the regional inspection 19 activities.
20 John Hickman, senior resident inspector at 21 St. Lucie, is also attending virtually and will 22 support today's presentations.
23 I'd like to note that the staff completed 24 its review with no confirmatory or open items in the 25 safety evaluation. Finally, we will address any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
113 1 questions you may have on the staff's presentation.
2 And we look forward to a productive discussion today 3 with the ACRS.
4 At this time I will turn the presentation 5 over to Mr. Michael Davis, lead licensing project 6 manager at Florida Power & Light to introduce his team 7 and commence the presentation. Thank you.
8 MEMBER MARCH-LEUBA: Speak loud. I want 9 to make sure I can hear you.
10 MR. DAVIS: All right. Good afternoon.
11 And hopefully you can hear. Great.
12 Thank you for the opportunity for us to 13 speak with you all today. We look forward to 14 presenting the overview of the St. Lucie subsequent 15 license renewal application.
16 And you can go ahead and go to Slide 2.
17 R is introduction. On, before I say that, please feel 18 free to stop us at any time if you do have a question 19 as we go through the presentations.
20 My name is Mike Davis, licensing projects 21 director for NextEra Energy and FPL. Presenting with 22 me today will be Rob Craven, the St. Lucie site Vice 23 President who's joining us virtually. And Steve Hale 24 from ENERCON, our partner in developing the subsequent 25 license renewal application.
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114 1 Steve is one of the technical leads for 2 the St. Lucie SLR project. And had the same role for 3 the Point Beach and Turkey Point SLR efforts.
4 Previous to that he worked for NextEra Energy for over 5 46 years. And held many positions throughout this 6 career, including engineering director at Turkey 7 Point. He was directly involved with the original 8 license renewal for the Turkey Point and St. Lucie 9 sites, as well as extended power uprates for Point 10 Beach, Turkey Point and St. Lucie.
11 I would like now to turn the presentation 12 over to the St. Lucie Vice President, Rob Craven, who 13 has some opening remarks. And you can go to Slide 3.
14 And hopefully Rob is able to join us. Rob, can you 15 hear us?
16 PARTICIPANT: He's still showing muted.
17 MEMBER MARCH-LEUBA: He needs to unmute 18 himself.
19 MR. DAVIS: Oh.
20 MEMBER SUNSERI: Rob, unmute yourself if 21 you're trying to talk.
22 MR. CRAVEN: Okay, good. So, well, first 23 of all, thanks for having us today. There is a couple 24 of things I just want to touch on.
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115 1 there, just one thing about our mission. And that's 2 we produce energy in a safe, reliable and cost 3 effective way while caring for employees, communities 4 and the environment.
5 And the way we do this is really through 6 some of our core values. And I want to touch on 7 committee to excellence. And what that really refers 8 to is we have good programs processes in place.
9 One of the things we are focusing on 10 specifically is around aging management. And also our 11 summer capital improvements we're doing at the site.
12 We're spending tens of million dollars a year on 13 improving the site overall. And then focusing on our 14 aging management programs.
15 At the bottom you see some of our focused 16 areas. One of the things we'll touch on is generation 17 reliability. And those things don't happen without a 18 very well run plant. Which is a focus for us.
19 The next slide for overview, not going to 20 do our capacities, but just highlight that we are ROP 21 Column 1. And all of our indicators are currently 22 green. If there are no questions I'll turn it back 23 over to Mike.
24 MR. DAVIS: Thank you, Rob. We can go to 25 Slide, the next slide. All right, this slide, as well NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
116 1 as the next few slides will cover, contain some facts, 2 figures and photos, which will provide a brief 3 overview of the site itself.
4 St. Lucie Units 1 and 2 are four loop 5 combustion engineering PWRs that are located on the 6 Hutchinson Island just north of Jensen Beach, Florida.
7 Cooling water for the units is pulled from, and 8 discharged to, the Atlantic Ocean.
9 Both units initial licensed core power was 10 2560 megawatt thermal. And as a result of a power 11 uprate in the 1980s, and an extended power uprate in 12 2012, both units are now licensed for 3020 megawatts 13 thermal.
14 CHAIRMAN REMPE: Excuse me?
15 MEMBER MARCH-LEUBA: You're good.
16 CHAIRMAN REMPE: Okay. Could you talk a 17 little bit about, if there are any differences in 18 Units 1 and Units 2 because it's been a lot of years 19 you've been operating, and are they still identical or 20 have changes made as you go --
21 MR. DAVIS: Oh. Well there are 22 differences between the units because of the time they 23 were constructed. You know, around seven or eight 24 years difference. And --
25 MR. HALE: Mike, let me. You know, Unit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
117 1 1 was before Browns Ferry modeling. Unit 2 was after.
2 So when you walk around the sites you will see some 3 differences.
4 But basically NSSS is the same and a lot 5 of the auxiliary systems are the same. But what you 6 see more is some of the licensing criteria. Like 7 missile detection for example. You'll see a part side 8 wall on (audio interference) Unit 1, whereas you see 9 a total enclosure on Unit 2. So the missile criteria 10 changed.
11 And St. Lucie 2 is a cool shutdown plant, 12 St. Lucie was a hot shutdown plant in terms of the 13 design basis addition. So you see some differences 14 like that, but overall the plants are very close to 15 each other in terms of a secondary plant (audio 16 interference).
17 CHAIRMAN REMPE: I can remember that your 18 steam generators are made from a different vendor --
19 MR. HALE: Yes.
20 CHAIRMAN REMPE: So that's going to affect 21 some of the subsequent discussion you had.
22 MR. HALE: Yes.
23 CHAIRMAN REMPE: And that's another --
24 MR. HALE: Yes. Unit 1 was B&W Canada.
25 And Unit 2 was (audio interference) --
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118 1 MEMBER SUNSERI: You just have to talk 2 louder.
3 MR. HALE: Okay.
4 MEMBER SUNSERI: And maybe direct your 5 voice this direction.
6 (Simultaneous speaking.)
7 CHAIRMAN REMPE: I just was curious, 8 knowing the differences with the steam generators, and 9 actually your response about the licensing criteria 10 being different is interesting too because I don't 11 remember that from before when we talked about St.
12 Lucie.
13 MR. HALE: Well we did original license 14 from (audio interference). We had to go, you know, 15 the scoping and screening the first time we went 16 through that. We spent a lot of time with the staff 17 walking through the differences between the units on 18 the licensing side.
19 CHAIRMAN REMPE: Okay. Thank you.
20 MR. DAVIS: Okay, we can go to the next 21 slide.
22 MEMBER HALNON: Yes, before we get off 23 that line of questioning, this is Greg Halnon, can you 24 just briefly discuss the difference in the station 25 blackout?
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119 1 I noticed there is some scoping 2 differences based on station blackout. Like the Unit 3 1 air compressors and whatnot. Is there a licensing 4 difference or is there a physical interconnection to 5 that?
6 MR. HALE: Yes.
7 MEMBER HALNON: Or --
8 MR. HALE: Yes. No, there is a licensing 9 difference. Unit 1 has an alternate power supply. So 10 Unit 1 relies on the interconnections with the Unit 2 11 diesel generators for station blackout. They call it 12 alternate power supply.
13 Unit 2 is a DC coping plant. So its 14 station blackout is based on DC power and restoration 15 to the diesels after a certain time period.
16 MEMBER HALNON: Okay. That answers a lot 17 of my questions. Appreciate it. Thank you.
18 MR. HALE: Yes, no problem.
19 MR. DAVIS: All right. So the current 20 slide you see is a map of the site and its location.
21 St. Lucie's Unit 1 and 2 are located on the Florida 22 Atlantic Coast on Hutchinson Island, as I mentioned 23 before. Just north of Jensen Beach.
24 On the map, the blue star in the center of 25 the circle marks the location of the site. And then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
120 1 the black dashed circle is a six mile radius, just to 2 give perspective of the distances at the site in 3 relation to the mainland there.
4 We can go to the next slide. Our current 5 license expiration dates are March 2036 for Unit 1, 6 and April of 2043 for Unit 2. The original license 7 renewal application was approved in October of 2003.
8 It was based on the draft Rev 0 of NUREG-1801. As 9 part of that renewal ten programs were updated to the 10 NUREG-1801.
11 Inspector procedure 71003, Phase 2 12 inspections were completed for Unit 1 in 2015. And 13 for Unit 2 in 2017. Unit 1 entered the period of 14 extended operation in 2016. And Unit 2 entered the 15 period of extended operation this year in April.
16 And NEI 14-12 aging management plan 17 effectiveness review was completed in January of 2021.
18 And our subsequent license renewal application was 19 submitted in October of 2021.
20 Go to the next slide. So this is an 21 aerial view of the St. Lucie site. As I mentioned 22 earlier, the site pulls it cooling water from the 23 Atlantic Ocean. The intake canal is at the bottom of 24 the picture, or the south, south of the plant. And 25 continues around to the west side of the plant for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
121 1 cooling water. The discharge canal is the, returns 2 water to the Atlantic Ocean. And it's the northern 3 canal. The one at the top of the picture.
4 Looking at the inset picture you can see 5 the Unit 1 containment building is to the north. And 6 Unit 2 containment building to the south. The turbine 7 buildings are on the west side of the containment 8 buildings. And each auxiliary building is to the 9 south of its containment building. Hopefully you can 10 see that.
11 We can go to the next slide. So the next 12 two slides are a listing of modifications and upgrades 13 that the plant has completed since the first license 14 renewal. Although not a comprehensive list, we have 15 included some of the major modifications to the units.
16 These modifications include those associated with the 17 extended power uprate I mentioned that occurred in 18 2012.
19 The second bullet lists replacement of the 20 Unit 2 steam generators. And we know that there is 21 interest in discussing that. We have a slide coming 22 up to talk about that in more detail.
23 And we can go ahead and go to the next 24 slide.
25 MEMBER SUNSERI: Just a quick question.
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122 1 When you have like, replace heater drain pumps, does 2 that include the motors or just the pumps?
3 MR. HALE: This is Steve Hale again. Yes, 4 the heater drain pumps, we did replace the motors as 5 well with the pumps themselves.
6 MEMBER SUNSERI: Okay, thank you.
7 MR. HALE: In some cases you may be able 8 to use the existing motor, but --
9 MEMBER SUNSERI: Right. Right.
10 MR. HALE: -- in those cases we had them 11 replaced. Both.
12 MEMBER SUNSERI: And the feedwater pumps 13 I presume are turbine driven or --
14 MR. HALE: No. They're --
15 MEMBER SUNSERI: Oh --
16 MR. HALE: -- motor driven.
17 MEMBER SUNSERI: And did you do the motors 18 on them as well?
19 MR. HALE: -- FPL motor drive feed pumps.
20 Yes.
21 MEMBER SUNSERI: Okay.
22 MEMBER MARCH-LEUBA: You're too far aware.
23 MEMBER SUNSERI: Yes. You'll just have to 24 talk louder or get closer.
25 MR. HALE: Okay, I'm going to --
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123 1 MEMBER SUNSERI: Okay. Thank you.
2 DR. SCHULTZ: Okay, this is, excuse me.
3 This is Steve Schultz. I have a question related to 4 the previous slide, as well as this one.
5 You mentioned that some of the 6 modifications were done in support of the 2012 uprate.
7 Could you just go through these pieces and let us know 8 what the timing was for the, when these refurbishments 9 were done so we get an idea of what was done in 2012?
10 And you mentioned how much you're doing on 11 a annual basis, but give us an appreciation for what 12 you've done recently and what was associated with the 13 2012 upgrade.
14 MR. DAVIS: Steve, do you want to come 15 over?
16 MR. HALE: Let me get a little closer.
17 MR. DAVIS: Yes.
18 MEMBER MARCH-LEUBA: Steve, why don't you 19 sit in my place.
20 MR. HALE: Most of the modifications we 21 have listed here were implemented in the 2011 to 2012 22 time frame in order to prepare for the extended power 23 uprates. Some that weren't necessarily were the 24 reactor vessel heads. I don't have the specific 25 dates, but they were replaced kind of the mid-2000s I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
124 1 believe. In that general time frame.
2 Unit 1 steam generators, which aren't 3 listed here, were replaced prior to our original 4 license renewal. And that's why they're not listed 5 here.
6 And the Unit 2 steam generators were 7 replaced probably, you know, we had the one cycle of 8 operation prior to going to EPU conditions. So they 9 were towards the 2012 time frame as well.
10 But of course the high and low pressure 11 kick steam pass, replacement of the MSRs, MSIVs and 12 pre-steam bypass control capacity, feed pumps, feeder 13 drain pumps, you know, all of those are all related to 14 the extended power uprate. We did replace the main 15 transformers. Those were replaced in advance of the 16 EPU due to aging.
17 But generally most, to answer your 18 question, generally most of these modifications were 19 implemented to support the extended power uprate.
20 DR. SCHULTZ: That helps. Thank you very 21 much.
22 MR. DAVIS: Okay.
23 MR. HALE: Okay.
24 MEMBER SUNSERI: You can stay there if you 25 want.
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125 1 (Laughter.)
2 MR. DAVIS: You can go probably, yes, to 3 the next slide now. Oh, I'm sorry, yes, it's still 4 me. We are on the next slide. Catching up.
5 Here we go. So as you can see, NextEra 6 Energy has made significant investments in various 7 systems and components. Steve Hale, who was just 8 talking, one of our ENERCON technical leads here with 9 us today, was directly involved with the St. Lucie 10 extended power uprate project. And as you can tell by 11 his discussion, he is very familiar with that.
12 And any other questions about any of these 13 upgrades or modifications? All right, we can proceed 14 to the next slide.
15 I want to talk a little bit about the SLR 16 project team we assembled. They have many years of 17 experience, both in Florida Power Light, and St.
18 Lucie, specifically in license renewal. It is a 19 multiple-discipline team that consists of ENERCON as 20 the lead preparer for the submittal. And as well as 21 Westinghouse, Framatome and Structural Integrity 22 Associates in supporting those. Of course the project 23 team was also supported by NextEra and FPL personnel, 24 both at the fleet level and at the site itself.
25 Every aging management program, or SLR, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
126 1 was assigned a program owner to support a portion of 2 the application preparation and NRC review. The few 3 technical leads for our project partner, ENERCON, one 4 of them being Steve here today, and Jack Hoffman, who 5 is with us virtually, have combined of almost 80 years 6 of experience in FPL. Both developed the original 7 license renewal application for both Turkey Point and 8 St. Lucie.
9 This project team generated over 100 10 reports, which supported the application. These 11 reports not only provided the next level of detail for 12 the various aging management programs, and other parts 13 of the application, but going forward they will also 14 provide a way to ensure that the knowledge for SLR 15 will be passed on to the personnel who will be 16 implementing SLR.
17 In addition, as part of our implementation 18 process, these reports will be incorporated into the 19 plant control document system. As part of our 20 implementation plan, we have also established an SLR 21 coordinator position in order to ensure we have a 22 successful transition to subsequent, I'm sorry, 23 subsequent period of extended operation.
24 So now I am going to turn the presentation 25 over to Steve Hale, who has already had a good part of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
127 1 it, from ENERCON.
2 MR. HALE: Okay, thanks, Mike. For the 3 subsequent license renewal application we follow the 4 guidance of NEI 17-01, which was developed 5 specifically for subsequent license renewal.
6 We also reviewed RAIs and responses 7 associated with the first three application that went 8 through SLR review. Which was Turkey Point Surry and 9 Peach Bottom.
10 And when you address the results of those 11 resolutions in our technical documents, and in the 12 application. Other activities we implemented to 13 ensure quality SLRA, included extensive interviews 14 with the AMP owners, both at the site and the fleet 15 level, as well as an AMP effectiveness review that 16 Mike mentioned, which was done in January of 2021.
17 We also had several pre-application 18 meetings with the NRC staff to ensure that we address 19 everything we needed to in the application itself.
20 Our approach going in was to comply with NUREG-21-91, 21 our generic aging lessons learned SLR, and 21-92, the 22 standard review plan SLR, to the greatest extent 23 possible. And we feel that we have been able to 24 accomplish that.
25 We, along with the NRC, work diligently to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
128 1 ensure we met the SLR review schedule. Which 2 culminated in the issue of the SER in July this year.
3 Go to Slide 13. Having been involved with 4 both original, and now subsequent license renewal, I 5 have somewhat of a unique perspective as to what was 6 involved in the integrative plant assessment for both 7 efforts. We thought the best way to describe our 8 integrated plant assessment methodology was discuss 9 the differences we found as we went through the 10 process.
11 For scoping and screening there were 12 really minimal differences because the scoping 13 criteria really hasn't changed. There has been some 14 evolution in the guidance documents associated with 15 what's called the (a)(2) scoping criteria, which has 16 to do with non-safety, which can affect safety. And 17 that's because through various revisions to NEI 95-10 18 and other reviews that were performed on the license, 19 original license applications, we had to address some 20 additional criteria there.
21 Once you start moving into aging 22 management reviews you start seeing the differences.
23 When we did the original license renewal we addressed 24 aging effects that were identified in industry 25 documents at the time. And once you move into the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
129 1 changes associated with GALL, you know, NUREG-1801, 2 Revs 1 and 2, as well as the ISGs, and then with issue 3 of GALL SLR, there were a number of aging effects we 4 had to address expanded somewhat.
5 But the real differences you see are in 6 the aging management programs. If you'll see, for 7 initial license renewal, St. Lucie had 27 aging 8 management programs whereas for subsequent license 9 renewal they'll be 47 AMPs.
10 If you go to the next slide I'll provide 11 a little more detail. The, you know, our commitment 12 to try and comply with GALL SLR to the greatest extent 13 possible, I think is confirmed by looking at the 14 consistency. If you notice in the license renewal 15 application there is just pages and pages of tables 16 where you have to address the individual aging effects 17 associated with all the various systems, structures 18 and electrical systems. And we had over a 98 percent 19 consistency with those AMR line items which originally 20 goes to our goals when we establish the project.
21 If you look at the aging management 22 programs, we had 47. As I mentioned previously, 11 of 23 those are new, 36 are existing. And all of these were 24 evaluated against the GALL AMP guidance documents.
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130 1 enhancements to those aging management programs, or 2 exceptions where necessary.
3 There was one plant-specific program, 4 which was a carry-on from original license renewal, 5 which was management of fatigue, the pressurizer surge 6 line.
7 As I mentioned previously, we did address 8 RAIs, but in the individual AMPs we actually had a 9 section in the technical documents that talked about 10 the RAIs, the resolutions and how we addressed them in 11 the aging management programs. In addition to that, 12 to facilitate the NRC review we provided them a matrix 13 of the Turkey Point, Surry and Peach Bottom RAIs and 14 where they were addressed, both in the technical 15 documents as well as the application. And they were 16 able to use that on the ePortal.
17 Next slide.
18 MEMBER KIRCHNER: I got a question.
19 MR. HALE: Yes.
20 MEMBER KIRCHNER: Walt Kirchner speaking.
21 When you went from the experience at, previous 22 experience to this SLR application, did you find any 23 new areas that you didn't previously cover in those 24 prior programs?
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131 1 where we had established new programs. I think 2 certainly in the electrical area. Not that we weren't 3 doing the activities. I'd like to distinguish between 4 --
5 MEMBER KIRCHNER: Yes.
6 MR. HALE: -- performing activities and 7 then something under the blessing of a license renewal 8 AMP.
9 You know, we have some examples of that.
10 Like a compressed air program. We don't have a, you 11 know, we didn't have a license renewal compressed air 12 program but we were committed to the regulatory 13 guidance documents and things of that sort. And so we 14 just basically took that, compared it to what was in 15 GALL and identified enhancements if we needed to.
16 MEMBER KIRCHNER: Right. Any new areas or 17 any surprises?
18 MR. HALE: No, I don't believe so. You 19 know, when you operate the plant, as we've operated 20 these for as long as we have --
21 MEMBER KIRCHNER: Yes.
22 MR. HALE: -- you know, there is very 23 little that's going to surprise you. The staff is 24 going to cover one item, which was the selective 25 leeching they identified on the diesel generator NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
132 1 radiators. And they'll speak to that.
2 MEMBER KIRCHNER: Okay. Thank you.
3 MR. HALE: Yes. These are a list of the 4 programs we had exceptions to. I don't have to go 5 into these in detail, but if you have a specific 6 question we can. These exceptions were reviewed and 7 evaluated by the staff and accepted.
8 Most have to do with specific design 9 features at the site that made it difficult or 10 impossible to comply with the GALL requirements. And 11 we took exceptions to that. Any questions there?
12 MEMBER KIRCHNER: Just, if I could 13 continue?
14 MR. HALE: Sure.
15 MEMBER KIRCHNER: Given that you're an 16 ocean front site, do you have any saltwater issues, 17 like exterior tanks and such? Do those present 18 special challenges for you?
19 MR. HALE: Yes, I think being on a 20 saltwater site and salt latent atmosphere you will 21 have more corrosion to manage. But typically, you 22 know, those are already picked up by the programs 23 identified with nothing really unique associated with 24 it. Okay.
25 MEMBER KIRCHNER: Thank you.
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133 1 MR. HALE: Yes. So any other questions 2 here? Well now I want to move on to, I guess, Joy, 3 you mentioned replacement steam generators at St.
4 Lucie.
5 Next slide. I'm sorry. Having been 6 involved with those discussions with ACRS originally, 7 I remember the challenges we had at time. It was kind 8 of like the perfect storm. We saw indications on the 9 Unit 2 steam generators after one cycle, and then 10 SONGS was going on at the same time. So we had quite 11 a bit of dialogue considering we were increasing the 12 power level by 12 percent on these steam generators.
13 Well, it's a good news story. We've done 14 five inspections since EPU was implemented. We've 15 seen a steady decrease in the wear rates on the steam 16 generator tubes. And we've seen no evidence of tube-17 to-tube wear, which was the primary failure mechanism 18 at SONGS. And the inspection technic we utilize 19 specifically looks for that when we do our 20 inspections.
21 The, I'm sorry, I got ahead of myself.
22 The increase in tube wear rate after implementation of 23 EPU was less than the conservative forecast that we 24 had made. So it really shows that we had made the 25 right calls in terms of what we assumed the wear rates NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
134 1 would be. And it actually turned out to be less with 2 the first inspection after EPU. The inspections that 3 we have performed have demonstrated acceptable margin 4 against tube structural integrity with no tube-to-tube 5 wear observed.
6 Comparing the pre and post-EPU values, 7 overall benchmark steam generator tube wear rates at 8 the anti-vibration bars had fallen significantly. So 9 we've really seen what we anticipated to happen, 10 happen.
11 CHAIRMAN REMPE: I have a question.
12 MR. HALE: Sure.
13 CHAIRMAN REMPE: Okay. So I actually got 14 curious enough I went back and looked at some --
15 MR. HALE: Yes.
16 CHAIRMAN REMPE: -- of my old notes --
17 MR. HALE: Yes.
18 CHAIRMAN REMPE: -- and it was around 19 9,000 tubes I believe in each --
20 MR. HALE: Yes.
21 CHAIRMAN REMPE: -- of those generators.
22 MR. DAVIS: Yes.
23 CHAIRMAN REMPE: And at the time there 24 were like, it seemed like there were like 2,000 25 indicators and around --
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135 1 MR. HALE: Yes.
2 CHAIRMAN REMPE: -- a 1,000 tubes.
3 MR. HALE: Yes.
4 CHAIRMAN REMPE: What kind of indicators 5 are you getting now?
6 MR. HALE: The specific numbers, I think 7 we have Kester Thompson, you can respond to the 8 specific numbers of indications.
9 CHAIRMAN REMPE: Okay. So, I mean --
10 MR. HALE: Yes.
11 CHAIRMAN REMPE: -- you've said 12 significantly down.
13 MR. HALE: Yes.
14 CHAIRMAN REMPE: I like numbers, so could 15 you --
16 MR. HALE: All right.
17 CHAIRMAN REMPE: -- tell me kind of what 18 you're seeing nowadays, and what happened right after 19 the EPU too?
20 MR. HALE: We did see in an increase in 21 the wear rate, but was not as much as we anticipated.
22 CHAIRMAN REMPE: Yes. Okay.
23 MR. HALE: Okay. And, Kester, are you on?
24 MR. THOMPSON: Yes, I am.
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136 1 and your affiliation. And then, I don't know if you 2 heard the question?
3 MR. THOMPSON: Yes, I've heard the 4 question.
5 MR. HALE: Okay.
6 MR. THOMPSON: Yes. This is Kester 7 Thompson. I'm the steam generator program owner for 8 the plant.
9 Yes, so like said before, right after EPU, 10 yes, we did see a slight uptick in the wear rate.
11 However, we've seen a dramatic drop in the wear rate 12 since then. Very, very significant.
13 And right now the number of tubes that 14 we're seeing exhibiting wear at the AVB locations, are 15 about 2,600 tubes. 2,631 from the last inspection in 16 the Alpha generator and 2,105 in the Bravo generator.
17 Overall, there are more indications in the generator, 18 but the area of concern in the U-band, where the anti-19 vibration bars are located, those are the numbers.
20 CHAIRMAN REMPE: So it's in the 2,000's 21 for the indicators. We used to quote two different 22 numbers, how many tubes as well as indicators. Is it 23 -- I assume it's a fewer number of tubes with multiple 24 indicators per tube. Do you have those numbers?
25 MR. THOMPSON: What I have is the total NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
137 1 number. Total number, not just for anti-vibration 2 bars, would be the -- and the alpha generator would be 3 8,618, and the bravo generator is 6,267. The number 4 of tubes I don't have immediately, but I can pull that 5 by the time we get to the end of the presentation.
6 CHAIRMAN REMPE: Okay. So I'm a little 7 confused. I thought you gave something that was in 8 the 2,000s for the number of indicators that you're 9 seeing, and it varied. It was like 2,300 and 2,105 10 for A and B. And then I was asking how many tubes 11 give those indicators, and I would have expected you 12 to come back with 1,000. But you came back with 13 something like 8,000 or something, and I'm a little 14 puzzled.
15 But if you could kind of fine-tune those 16 numbers and let me know. And then I guess it doesn't 17 matter as long as we can see, hey, it went down. But 18 I am curious how much it went up right after the EPU.
19 But anyway, it would be good to see actual numbers.
20 It's nice to see the words. I'm not sure any of this 21 goes in the letter, but I just would like to confirm, 22 yeah, it is going down with actual numbers.
23 MR. THOMPSON: Okay. I understand the 24 question, and we'll get an answer to you.
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138 1 clarification, let me add when you have an indication, 2 it never goes away. It's always there. So they just 3 accumulate.
4 CHAIRMAN REMPE: Oh. So that would be 5 reasonable to have --
6 (Simultaneous speaking.)
7 MEMBER SUNSERI: And they grow, if you 8 will, until they reach a tube plugging limit, which 9 then the tube gets plugged and taken out of service.
10 Now, a tube can have multiple indications on it, as 11 you pointed out. Your tube plugging criteria is 12 something around 40 percent, something like that?
13 Yeah.
14 So you could have an indication that's 10 15 percent, and they just keep running. And then they 16 monitor how much it wears, if it grows any. And so, 17 when they're tracking that, they say their growth 18 rates or their wear rates are declining; that's 19 because they're not growing as fast as they had 20 predicted.
21 MR. HALE: To give you an example, the 22 number of tubes plugged in the 2A steam generator is 23 436, and the 2 Bravo steam generator, which doesn't 24 seem to have quite the same number as the 2 Alpha, is 25 52.
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139 1 MEMBER BALLINGER: This is Ron Ballinger.
2 How much margin do you have?
3 MR. HALE: Well, the steam generators were 4 originally built with 20 percent margin based on LOCA 5 analysis. When we went through the extended power-up 6 rate because I don't know if you all recall the 7 thermal conductivity degradation issue with --
8 (Simultaneous speaking.)
9 MR. HALE: Yeah, with the best-estimate 10 LOCA analysis, we had to restrict that as EEQ to 10 11 percent. But if needed, you know, there are 12 evaluations that can be accomplished to expand that.
13 CHAIRMAN REMPE: So (audio interference.)
14 about 27 percent or 16 tubes were plugged in 2A, and 15 12 percent or five were plugged in 2B. But that was 16 back in 2011, and you said 426 --
17 MR. HALE: In 2 Alpha. Yeah.
18 CHAIRMAN REMPE: In 2 Alpha. So that's 19 cumulative over all of the years.
20 MR. HALE: Cumulative. Yes.
21 CHAIRMAN REMPE: I guess if we don't want 22 to talk about indicators, because it's a cumulative 23 number and you're just getting more all the time, how 24 many are plugged and --
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140 1 line, is the tube's plugged, because that's where 2 you've reached the limit that needs to be taken care 3 of. And secondly, that can have a direct impact, 4 depending on how many are plugged in your safety 5 analysis.
6 (Simultaneous speaking.)
7 CHAIRMAN REMPE: -- give us some numbers 8 on the last couple of inspections, how many you're 9 seeing that now need to be plugged to get that 426, 10 whatever the number is for each of them.
11 MR. HALE: Do you have that handy, Kester?
12 MR. THOMPSON: Yes. During the last 13 inspection, we plugged 65 tubes. That was -- yes.
14 Yeah. We plugged 65 tubes, and that was 59 in Alpha 15 and six in Bravo. That was in the fall of 2021. For 16 the previous outage -- get you the one here for the 17 previous outage. These are in our reports that we 18 submitted on the docket here.
19 MEMBER SUNSERI: But -- so let me ask 20 this. I mean, from an overall safety and aging 21 management program perspective, you're following every 22 guideline. You're --
23 MR. HALE: Yes, sir.
24 MEMBER SUNSERI: -- doing the material 25 management program. You're monitoring the performance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
141 1 of the tubes using the latest inspection technology.
2 You have plug-in criteria. You have thermal limits 3 on, you know, the plant. And it just becomes an asset 4 management --
5 (Simultaneous speaking.)
6 MR. HALE: Exactly. Yeah. And that's why 7 you --
8 MEMBER BALLINGER: And there's no 9 imbalance between steam generators. From the way I 10 read it, it's pretty much uniform. You don't have X 11 percent in one steam generator and 4X percent in the 12 other steam generator. They're consistent throughout.
13 CHAIRMAN REMPE: They said 59 and --
14 MEMBER BALLINGER: And 60.
15 CHAIRMAN REMPE: I thought 65 total, 59 16 and six.
17 MR. HALE: That is correct.
18 (Simultaneous speaking.)
19 MEMBER BALLINGER: Well, I mean looking at 20 the total. So you'd only have a mismatch in the 21 margin.
22 CHAIRMAN REMPE: The total of --
23 MEMBER SUNSERI: Of 8,000, 9,000 tubes.
24 CHAIRMAN REMPE: Yeah. So there's 400-25 and-something-or-other total, and I'm not sure, I can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
142 1 take another look.
2 MR. THOMPSON: On the previous outage, I 3 do have those numbers. On the previous outage, it was 4 a total of 85 tubes plugged, and 79 of the 85 were in 5 the Alpha generator.
6 MEMBER BALLINGER: Oh.
7 CHAIRMAN REMPE: So it is -- you are aware 8 of it, and you're tracking it. And eventually, again, 9 you're at 400 and -- what was the number out of 8,000?
10 MR. THOMPSON: Four hundred and thirty-11 six.
12 CHAIRMAN REMPE: That's in one steam 13 generator?
14 MR. THOMPSON: Yeah. That's in 2 Alpha.
15 CHAIRMAN REMPE: Out of 9,000 --
16 MR. THOMPSON: Right.
17 CHAIRMAN REMPE: -- which is good to know.
18 As I recall -- and help me if I misremember -- the 19 problem wasn't really the design. It was how they 20 installed this --
21 MR. THOMPSON: It was how they were 22 fabricated.
23 CHAIRMAN REMPE: Oh. I thought that was 24 that they weren't supported --
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143 1 fabricated.
2 CHAIRMAN REMPE: Okay.
3 MR. THOMPSON: They were actually 4 fabricated horizontally, and it had to do with the way 5 they were fabricated where they had tubes actually 6 resting on the AVBs and causing some deformation 7 there. But I think from our perspective, bottom line, 8 we wanted to ensure that we weren't seeing what 9 happened at SONGS. And while we would prefer not to 10 have that many indications in the new steam generator, 11 I think it has been banished by the steam generator 12 program. And that's the bottom line.
13 CHAIRMAN REMPE: Thank you. I just was 14 curious --
15 (Simultaneous speaking.)
16 CHAIRMAN REMPE: -- appreciate the 17 additional information.
18 MR. THOMPSON: I do have that additional 19 information you asked earlier about the number of 20 tubes, also. And can I respond?
21 CHAIRMAN REMPE: Mm-hmm.
22 MR. THOMPSON: So, right now, for wear and 23 anti-vibration bars, the number of indications, 8,618 24 in Alpha and 6,267 in Bravo. The corresponding number 25 of tubes that were affected were, in the Alpha NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
144 1 generator, 2,631, and in the Bravo generator, 2,105.
2 CHAIRMAN REMPE: Sounds (audio 3 interference). Thank you.
4 MR. THOMPSON: Okay.
5 MR. HALE: Any other questions?
6 DR. SCHULTZ: Steve, this is Steve Schultz 7 calling. Do you have any particular rationale 8 associated with the consistent attenuation as we go 9 forward in time? Is it just the wear rates perhaps 10 were -- are different as you go forward, or any 11 operational rationale associated with it?
12 (Simultaneous speaking.)
13 MR. HALE: Go ahead, Kester.
14 MR. THOMPSON: Oh, no. I was just about 15 to say that the thing that you expect is to see 16 something that's well behaved. You expect to see that 17 attenuation and that our reduction in the wearing 18 taking place -- so the fact that it came down tells 19 you that you don't have an unstable environment taking 20 place there, which is good. So attenuation is what we 21 expect to see there.
22 So that's something that we're tracking, 23 and as we manage the program and we conduct ready-24 current testing, we're at the same time looking to 25 see, do we have any tube-to-tube we're developing? So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
145 1 we have special techniques that we're using for that.
2 So we're doing a lot on the preventive 3 front and just trying to stay ahead of things as we 4 manage the aging of the equipment.
5 DR. SCHULTZ: The inspection technique 6 sounds very well done. I really appreciate that 7 you're able to do more than just look inside the tubes 8 and see what's happening. Thank you.
9 MR. HALE: Okay. If we could move to --
10 (Simultaneous speaking.)
11 MR. HALE: -- other questions. Okay, sir.
12 If we move to slide 18, with regard to 13 commitments, there are 52 for St. Lucie 1 and 51 for 14 St. Lucie 2. And these are mostly on an AMP-by-AMP 15 basis. And they also include all the pre-SPO 16 inspections. These will be maintained separately for 17 clarity and to avoid confusion with commitments for 18 current license renewal.
19 There will be a new Chapter 19 in each of 20 the St. Lucie UFSARs specifically dedicated to 21 subsequent license renewal. The new chapter will 22 include a complete table of the SLR commitments in 23 each UFSAR. Both NextEra, FPL, and ENERCON -- we have 24 extensive experience with license renewal and 25 subsequent license renewal commitment management and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
146 1 implementation. And this will ensure all actions will 2 be completed per the schedule.
3 And as Mike mentioned, we've also 4 established a lead position on the site, a highly 5 qualified and experienced person to be the primary 6 lead for subsequent license renewal.
7 If we move to slide 19, this just provides 8 a summary of a time-limited aging analysis for St.
9 Lucie. We perform the same level of effort and 10 looking at all the CLB documents to identify TLAAs.
11 With comparison to original license 12 renewal, we saw some of the dispositions change from 13 the analytical resolutions, which are I and double I, 14 to the aging management resolutions, or triple I. And 15 that's primarily due to the fact that there are TLAA 16 aging management programs at GALL now, which didn't 17 exist when we went through this originally at St.
18 Lucie.
19 We've also updated all of the 20 environmentally assisted fatigue calculations. And 21 this is because there were new guidance documents, 22 like NUREG-6909, that provided, I would say, more 23 evolved and developed guidance for performing those 24 calculations.
25 If there are no more questions, I can turn NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
147 1 it back over to Mike.
2 MR. DAVIS: Okay. Thank you, Steve.
3 So, in summary, even though St. Lucie is 4 a draft GALL Rev 0 plant for the first round of 5 license renewal, we have adopted the GALL for 6 subsequent license renewal with minimal exceptions, as 7 Steve pointed out. In keeping with our sustainability 8 focus, the goal now is to build and maintain margin to 9 achieve 80 years of operation.
10 And you were asking about the upgrades 11 that we have done, and we gave you a list of completed 12 upgrades. But there is another upgrade, a significant 13 one that's ongoing now, and that is the intake cooling 14 water piping replacement. And that is an example of 15 something currently in progress to maintain and build 16 that margin for long-term operation.
17 Again, we would like to thank all the 18 members of ACRS for the opportunity to present today.
19 And if Rob Craven is still able to join us or to come 20 off mute, I think he has some closing remarks.
21 Rob?
22 MR. CRAVEN: Thanks. Yeah, I just want to 23 thank the team and the cooperation from the NRC and 24 working together on this project for us.
25 MR. DAVIS: Thank you.
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148 1 MEMBER SUNSERI: Okay. Thanks, Rob.
2 Thanks, team members.
3 Any other questions or comments for this 4 group before we switch chairs here?
5 MEMBER KIRCHNER: I have one.
6 MEMBER SUNSERI: Yeah, Walt?
7 MEMBER KIRCHNER: Just on a lighter note, 8 the dates are pretty far out. You talked about having 9 the senior person to oversee the SLR activities. Is 10 that person going to make it to the --
11 (Simultaneous speaking.)
12 MEMBER KIRCHNER: -- program to get that 13 person's --
14 MR. DAVIS: It's Greg. I think Greg is on 15 the call. Greg Summers is that person. If he is 16 willing to divulge his age --
17 MEMBER SUNSERI: He doesn't have to do 18 that, but yeah, people need to be able to change their 19 jobs and all that stuff like that. The fact that 20 you're doing this thoughtfully is the important part.
21 MR. BRUNSON: This is Matt Brunson. So 22 Mike alluded to it in one of the slides. We've --
23 (Simultaneous speaking.)
24 MEMBER SUNSERI: Just hold on. Stand by.
25 MR. BRUNSON: My apologies. This is Matt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
149 1 Brunson. I'm the ENERCON project management at SLR.
2 Just to answer that continuity concern, it's a fair 3 one. I'm sure Greg will outlive us all, but he is a 4 senior person, Greg Summers, the SLR site coordinator.
5 Those aging management programs are, of 6 course, procedural documents. Underneath those live 7 the procedures that execute those aging management 8 programs. All of the bases reports that we developed 9 the SLR from, 100 or so reports, have been updated 10 through all of the NRC audit process. So they are 11 living documents, those aging management programs.
12 And the procedures and the preventative 13 maintenance requirements, sampling plans and work 14 orders -- that's all written down. So that ensures the 15 ability of continuity for the engineers that will be 16 implementing this, especially for Unit 2, which is 17 quite similar. Yeah. So does that answer your 18 question okay, sir?
19 MEMBER KIRCHNER: Yes. Thank you.
20 MEMBER SUNSERI: Any others?
21 DR. SCHULTZ: Steve Schultz. Just one 22 question. You mentioned early on that when you did 23 the interviews of the site program SLR leads or owners 24 -- and I was curious to know what were the one or two 25 major things that you learned from that interview NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
150 1 process. Is that an extensive -- you follow the EPRI 2 guidelines in doing the interviews? What was the 3 takeaways, the major ones?
4 MR. HALE: Well, having participated in 5 performing those interviews, my first take was the 6 aging management program owners were very 7 knowledgeable of their systems and some of the issues 8 that may be involved with them. And nothing really --
9 I'll call it significant -- came out of it. But I was 10 impressed with the level of knowledge and the 11 commitment the aging management program owners had to 12 their programs.
13 DR. SCHULTZ: Good. Thank you.
14 Appreciate that.
15 MR. HALE: You're welcome.
16 MEMBER SUNSERI: All right. With that, 17 we'll wrap up this part of the session, and we'll move 18 into the next. So, if we could transition -- and is 19 it Vaughn, or Vaughn Thomas, and Paula Cooper coming 20 up? How's your outside voice? Is it strong? Does 21 someone need to sit here?
22 SPEAKER: Let's do a sound check. Say 23 your name.
24 MR. THOMAS: My name is Vaughn Thomas.
25 SPEAKER: You're good.
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151 1 MS. COOPER: My name is Paula Cooper.
2 SPEAKER: Say again.
3 MS. COOPER: Paula Cooper.
4 SPEAKER: Yeah.
5 MR. WISE: My name is John Wise.
6 (Simultaneous speaking.)
7 SPEAKER: Okay. Let's make Vaughn talk 8 more.
9 MR. THOMAS: Yeah. Yeah. No problem.
10 Let me know when you're ready to start.
11 MEMBER SUNSERI: We're ready when you are.
12 MR. THOMAS: All right. Great. Thank 13 you, Mike.
14 And good afternoon, Chairman and members 15 of the ACRS. My name is Vaughn Thomas, and I'm the 16 Licensing Renewal Project Manager for the safety 17 review of the St. Lucie Units 1 and 2 subsequent 18 licensing renewal application, or the SLRA.
19 As you heard from Bernie earlier today, 20 we're here to discuss the staff's safety review of the 21 St. Lucie SLRA as documented in the safety evaluation 22 report, or the SER, which was issued on July 21st, 23 2023. Joining me today at the table is Lauren Gibson, 24 Branch Chief for the Licensing Renewal Branch; Dr.
25 John Wise, senior technical advisor for aging NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
152 1 management; and Paula Cooper, Region II senior reactor 2 inspector.
3 Also joining us today, both in the 4 audience and virtually, are some of the original 5 staff, along with members of the ENERCON staff who 6 participate in the video of the SLRA and conducted the 7 audits.
8 Next slide, please.
9 We'll begin today's presentation with an 10 overview of the St. Lucie licensing history before we 11 move on to the St. Lucie aging management programs.
12 We'll then discuss selected technical areas that we 13 believe are of interest to the ACRS and hear from 14 Region II inspections and plant material conditions 15 before sharing the conclusion of the staff's safety 16 review.
17 Next slide, please.
18 St. Lucie Units 1 and 2 were initially 19 licensed on March 1st, 1976, and April 6th, 1983, 20 respectively. In November 2001, the applicant 21 submitted the initial license renewal application.
22 Initial renewed license were issued October 2003, 23 extending the expiration dates by 20 years to the max 24 2036, and for Unit 1 and April 2043 for Unit 2.
25 On August 3rd, 2021, Florida Power & Light NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
153 1 submitted an SLRA for St. Lucie Units 1 and 2, which 2 was accepted for review on September 29th, 2021. And 3 the safety evaluation was issued on July 21st, 2023, 4 we have no open items or other items.
5 Next slide, please.
6 The St. Lucie SLRA described a total of 47 7 aging management programs, or AMPs, consisting of 36 8 existing programs and 11 new programs. This slide 9 identifies applicant's original disposition of this as 10 initially submitted in the application in the left 11 column, and the final disposition as documented in the 12 SE in the right column.
13 Other AMPs, except one, were evaluated for 14 consistency with their own SLR report. And 15 ultimately, all the AMPs were found to be consistent 16 with suitable enhancements exceptions. applicant 17 included one plant-specific (audio interference) 18 program, which is reviewed in accordance with our 19 standard plan, and a subsequent license renewal was 20 found to be acceptable.
21 PARTICIPANT: Keep your voice high.
22 MR. THOMAS: Oh. Thank you. I would like 23 to talk a little bit about what we did to review aging 24 management activities and other technical information 25 in the application. As part of our review, the staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
154 1 are conducting an aging management audit to review 2 operating experience, or AMPs, and (audio 3 interference) TLAAs.
4 This audit spanned 21 weeks from October 5 2021 to February 2022 and included both on-site and 6 virtual activities and leveraged the portal and 7 breakout sessions between the staff and the applicant.
8 We were able to issue approximately 53 RAIs and two 9 wrong RAIs, secondary RAIs, from this review.
10 The applicant submitted six SLRA 11 supplements. Several clarification calls were 12 conducted to discuss a variety of responses to RAIs 13 that were issued by the NRC staff, including (audio 14 interference) to the external surface of the emergency 15 diesel generator radiator tubes, which I will discuss 16 on the next slide.
17 Based on the review of the SLRA that 18 resolves the audits and additional information 19 provided by the applicant. The staff included that 20 the applicant's aging management program activities 21 were consistent with the criteria of the standard 22 review plan, or SLRA, and of the requirements of 10 23 CFR Part 54.
24 Next slide, please. This slide represents 25 a sample of several target areas of the SLRA review.
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155 1 The first area relates to (audio interference) 2 operating experience at St. Lucie (audio interference) 3 generator radiator tube leak that occurred in June 4 2022.
5 Because of the leak -- was selective 6 leaching on the external surfaces of the Unit 1 EVG 7 radiator tubes that were exposed to an aggressive 8 indoor air environment into salt-laden air. St.
9 Lucie's failure analysis noted that inaccessibility of 10 the radiator tube surface made visual and mechanical 11 detection methods ineffective to detect selective 12 leaching on the external surfaces of the radiator 13 tubes.
14 A subsequent review of the historical 15 operating experience by the NRC staff identified EVG 16 radiator tube links from May and June 2021 -- June 17 2001, sorry -- and November of 2007. The discovery of 18 these previous radiator tube failures and the ongoing 19 periodic replacements of the Unit 1 EVG reactor 20 radiators prompted the staff to request additional 21 information.
22 In the applicant's response to staff RAI, 23 St. Lucie proposed additional one-time inspection to 24 confirm that the aggressive air environment was 25 limited to energy radiators and to ensure selective NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
156 1 leaching of other (audio interference) components 2 similar to the EVG radiator tube (audio interference) 3 was not occurring.
4 St. Lucie also proposed to perform one-5 time volumetric inspections of the Unit 2 EVG radiator 6 tubes to confirm that the selective leaching on the 7 radiator tubes was unique in the Unit 1 EVG radiator 8 tubes. St. Lucie also clarified that because of the 9 Unit 1 EVG radiator tubes currently being replaced, 10 they are not considered long-term components and do 11 not require (audio interference).
12 The staff found St. Lucie's proposed 13 changes acceptable to manage detected leaching (audio 14 interference) components exposed to the aggressive air 15 environment. The staff review of buried and 16 underground piping and tanks program focused on 17 external puttings, used for the subject components.
18 (Audio interference) the need for 19 additional information with respect to (audio 20 interference) and unlevel packing and tanks are 21 externally quoted in accordance with the SLR report 22 recommendations. The staff reviewed the applicant's 23 response from the applicant demonstrates that the 24 buried metallic piping is either concrete encased or 25 externally (audio interference) and that underground NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
157 1 steel piping and portions of the buried fire 2 protection system pipings are externally coated.
3 In addition, the applicant provided a 4 (audio interference) exception related to their steel 5 piping, which has not been confirmed as externally 6 reported. The staff reviewed this exception a found 7 it acceptable based on its review of solid proximity 8 testing there -- which demonstrated a nonaggressive 9 environment. And the fact that the staff did not 10 identify instances of age-related degradation (audio 11 interference) during its audit.
12 If there are any other questions or 13 further information related to those areas, we have 14 (audio interference) and are prepared to respond.
15 MEMBER KIRCHNER: Yes, I'll ask a 16 question.
17 MR. THOMAS: Go right ahead.
18 MEMBER KIRCHNER: This is Walt Kirchner.
19 So this is directed more to Paula, your team. How 20 would you summarize the condition of the plant, 21 particularly with respect to salt corrosion (audio 22 interference) issue that's likely to (audio 23 interference) 24 MS. COOPER: Yeah. As you can expect, St.
25 Lucie's fall on both sides. Having the Indian River NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
158 1 on one side and having the Atlantic Ocean on the 2 other, it's a very salty environment, for a lack of 3 better word.
4 I would say last year -- I believe it was 5 last year -- I was deployed from the region to do 6 problem identification and resolution samples at the 7 plant because there was concerns about the corrosion 8 associated with the supports within the intake 9 structure.
10 So it's -- I will say that the great thing 11 about saltwater corrosion is it's very predictable.
12 It's not a hidden mechanism. It's very easy to see, 13 St. Lucie recognizes the condition, they're actively 14 now, I guess, upgrading their intake cooling water 15 piping to a more corrosion-resistant carbon-sealed 16 pipes with stainless steel supports within the 17 structure.
18 But it is a known mechanism. Is a managed 19 mechanism. They do preemptively try to coat --
20 they're even doing some advanced needling techniques 21 on the coating of some of these external surfaces. So 22 they're definitely doing what they can in order to 23 mitigate the corrosion and replace it when necessary.
24 But it does exist. They are managing 25 that. And at this point, there's no safety concerns NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
159 1 with how they're managing plant. It's just (audio 2 interference) 3 MEMBER KIRCHNER: How would you describe 4 the overall condition of the external parts of the 5 plant? How would you -- this is Walt Kirchner asking 6 the staff. How would you describe to the public the 7 general condition of the external exposed parts of the 8 plant?
9 We heard earlier about differences between 10 Unit 1 and Unit 2 in terms of missile protections 11 (audio interference) water storage tanks. I would 12 also ask about diesel storage tanks and such. What's 13 the general condition? What's your assessment?
14 MS. COOPER: I'll also leverage -- John, 15 if you'd like to also chime in on this question.
16 Overall, from a public standpoint, we can't really 17 just say it meets all regulatory requirements; it's 18 meeting its design basis. Those words don't 19 necessarily make the public feel good, right? They 20 want to know more --
21 (Simultaneous speaking.)
22 MEMBER KIRCHNER: Condition assessment.
23 MS. COOPER: Yeah. So I would say that, 24 I mean, especially given the environment, they're 25 doing exceptionally well keeping up with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
160 1 degradation that they know, that they see the 2 containment. You can see where they have the pulled 3 forms. They've got a little bit of corrosion kind of 4 coming through those old form concrete layers.
5 But they're aware of it. They're 6 following all the ASME codes. I would say, at the end 7 of the day, the conditions, especially given the 8 environment, are being exceptionally maintained.
9 They really are keeping up with it, and they do --
10 it's very apparent that they are doing what they can 11 in order to get as long of a life as they can for this 12 plant.
13 MR. HICKMAN: And if I could add to that 14 -- this is John Hickman, the senior resident inspector 15 here at St. Lucie. Can you hear me?
16 MEMBER KIRCHNER: Yes.
17 MR. HICKMAN: Just adding to what Paula 18 just said, you know, I concur with that. And part of 19 our baseline inspection program, which I manage here 20 at St. Lucie, addresses and looks for those age 21 management issues that might arise.
22 And one thing I can say with the 23 relationship of the NRC with the licensee, they're 24 very receptive to our observations and very equipped 25 to correct these deficiencies that we bring up to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
161 1 them. So, once again, they are meeting all regulatory 2 requirements and maintaining the health and safety of 3 the public.
4 MEMBER KIRCHNER: Thank you.
5 MR. THOMAS: Are there any other 6 questions?
7 If there are no other questions, I'll turn 8 it over to Paula Cooper, senior reactor inspector in 9 Region II, who's going to discuss the inspections and 10 the plant material conditions.
11 Paula?
12 MS. COOPER: Thanks, Vaughn.
13 Good afternoon, everyone. I'm Paula 14 Cooper, senior reactor inspector from the Region II.
15 Also joining me virtually, whom you've just heard, is 16 John Hickman, senior resident inspector at the St.
17 Lucie plant.
18 My role here today is to present the 19 inspectors' perspective on the material condition of 20 the plant and the adequacy of the site's performance 21 on managing the effects of aging. These insights are 22 gained from both region-based inspections and those 23 performed by the residents.
24 This table represents the inspections that 25 were performed through the license renewal inspection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
162 1 program, specifically by the 71003 inspection 2 procedure, which is a series of inspections that are 3 performed after the initial license was renewed.
4 Each of the two units received a Phase 1 5 inspection. This phase occurs prior to the period of 6 extended operation during an outage where the 7 inspectors can walk down normally inaccessible areas, 8 such as containment, to observe the implementation of 9 aging management programs.
10 For the Unit 1 Phase 1 inspection, the 11 inspector observed the phased array ultrasonic exam on 12 safety injection lines for the indications of thermal 13 embrittlement, traditional ultrasonic on the main feed 14 water line for float-accelerated corrosion, and 15 conducted walk-downs of safety-related structures, 16 including containment.
17 The Phase 2 was a five-week inspection 18 with two weeks on-site performed by a team of five 19 inspectors prior to entering the PEO to verify the 20 license renewal activities were completed. The 21 inspectors reviewed 21 commitments and four aging 22 management programs.
23 The inspectors determined that based on 24 the samples selected, that the licensee completed or 25 was on track to complete the necessary tasks to meet NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
163 1 the license renewal commitments, license conditions, 2 and regulatory requirements associated with the 3 issuance of the renewed operating license for Unit 1.
4 Unit 2, however, had several activities 5 pending where it was decided to perform a Phase 2 for 6 Unit 2. Prior to the Phase 2, a Phase 1 for Unit 2 7 was performed. During this inspection, the inspector 8 observed ultrasonic exams on small-bore piping on the 9 safety injection lines, phased array on the steam 10 generator cold legs, and conducted walk-downs of 11 safety-related structures, including containment.
12 The Phase 2 for Unit 2 was intended to be 13 a five-week inspection with two weeks on-site.
14 However, the second on-site week was canceled due to 15 Hurricane Irma. I was able to travel back to the site 16 a month later to complete the walk-downs and scoping 17 reviews.
18 Despite the sudden change in the 19 inspection schedule, the six inspectors on the team 20 were still able to complete the review of 18 aging 21 management programs and four TLAs and reached the same 22 conclusion we reached for Unit 1.
23 The Phase 4 is the last remaining phase 24 associated with the initial renewed license, and it's 25 scheduled to be performed in 2027. Additionally, if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
164 1 the license is renewed for the subsequent license 2 renewal period, the inspection program has been 3 recently revised to include two additional phases.
4 These phases are equivalents of a Phase 2 and a Phase 5 4, shown on the slide as Phase 5 and 6, but for the 6 SLR application.
7 In addition to the inspections mandated by 8 the license renewal inspection program, inspectors 9 used several ROP baseline inspections procedures to 10 evaluate the implementation of the aging management 11 activities. I'd also like to point out that this is 12 not an exhaustive list. Most of the programs within 13 the ROP have been updated to include aging management 14 programs that are not represented on this slide.
15 The first example is a baseline inspection 16 of the in-service inspection program. This inspection 17 is performed each refueling outage and provides the 18 inspectors the opportunity to review and assess 19 inspections credited for aging management. This also 20 includes the steam generate Eddy current inspection if 21 you're interested in that particular one.
22 The second example is the heat sink 23 inspection. That has now been incorporated under the 24 comprehensive engineering team inspection. But this 25 provides the inspectors an opportunity to review the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
165 1 service water system as well as the ultimate heat 2 sink.
3 Lastly, the problem identification and 4 resolution inspection provides the opportunity as 5 needed to address age-related degradation identified 6 in the plant. One of the elements we focus on when 7 reviewing the aging management programs under the 8 license renewal inspection program is the ability for 9 the site to react or adjust to newly identified aging 10 mechanisms.
11 Last year, as Vaughn described earlier, 12 the emergency diesel generator radiator tubes 13 experienced a leak which in turn activated the 14 licensee's corrective action program. The licensee 15 performed additional examinations and testing which 16 later concluded that the mechanism that led to the 17 leak was selective leaching.
18 The material environment, in this case, 19 air indoor uncontrolled, in the GALL did not identify 20 selective leaching as an aging mechanism requiring 21 management. Through the problem identification and 22 resolution inspection, the residents, with 23 consultation from regional and headquarters staff, 24 were able to review and verify that the licensee was 25 able to adequately address and implement appropriate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
166 1 corrective actions to address this new aging 2 mechanism.
3 I will now speak to the material condition 4 of the St. Lucie plant from a regional inspector 5 viewpoint. As a senior reactor inspector, I am tasked 6 with performing several region-based inspections at 7 sites generally located in the Southeast.
8 As it relates to St. Lucie, historically, 9 I've performed a heat sink inspection, license renewal 10 inspection, in-service inspections, ISFSI inspections, 11 and multiple samples in the area of problem 12 identification and resolution. As a result, there are 13 few areas of the St. Lucie plant that I haven't seen.
14 Overall, I have no concern with the 15 overall material condition of the plant that needs to 16 be addressed outside of the baseline reactor oversight 17 process, and the licensee has been successful at 18 completing large capital improvement projects that 19 maintain or improve the material condition of its 20 structure, systems, and components. And the inspector 21 will continue to inspect and assess the licensee's 22 ability to manage the effects of aging through those 23 baseline inspections.
24 At this time, I'll turn it back over to 25 Vaughn Thomas, provided there are no questions.
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167 1 MEMBER SUNSERI: Well, I would just pause 2 here for a second, Vaughn, if that's okay. This 3 Committee has over the years truly appreciated the 4 eyes-on-site perspectives that the resident inspectors 5 provide. So I would just want to pause here and make 6 sure that this Committee has ample time to question 7 Lauren and -- or Paula and --
8 MS. COOPER: John.
9 MEMBER SUNSERI: -- John about anything 10 that we can't see but they can.
11 MEMBER KIRCHNER: So, Paula, this is Walt 12 Kirchner again. How would you describe the 13 containment condition? You mentioned that as a 14 specific object of some of your inspections.
15 MS. COOPER: Yes. So, when I go into 16 containment, it's during an outage. So, as you would 17 expect, the one thing that you will routinely see in 18 containment are booties and gloves. And that's the 19 kind of, quote unquote, garbage that you could see 20 inside a containment, and that's very common in every 21 site across plant.
22 But what John will speak to and what he 23 can follow up on it up before they even start, they 24 have to do a full scrub of containment to get every 25 little bit of material out of there (audio NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
168 1 interference) design basis accidents.
2 So John, as part of his role as a 3 resident, is to do a containment close-down inspection 4 and to make sure it is clean because there are some 5 conditions that you would expect -- you get a lot of 6 trays in, and you go in with double booties because a 7 containment, one, easily breaks or cracks or --
8 they're not exactly very robust materials that you're 9 using when you go into containment.
10 So that's very common. Outside of that, 11 the plant is always maintained very clean. You don't 12 have combustibles. You don't have garbage or Big Gulp 13 cups or anything along those lines anywhere along the 14 plant. It is very exceptionally well maintained.
15 MEMBER KIRCHNER: Well, that's good to 16 hear. That's housekeeping. I should have been more 17 specific. How about the actual containment structure?
18 How (audio interference) the reactor vessel and other 19 places where the Agency has targeted their 20 inspections?
21 MS. COOPER: Sure. Yeah. In terms of 22 your containment liner, your floor, your moisture 23 barriers, they have an exceptional record with keeping 24 up. They did have, as a fleet, a concern with a 25 containment liner, but it was at a different plant.
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169 1 So, as in response to that corrective 2 action, they do have a more focused view on making 3 sure that things like your moisture barriers are 4 intact so you don't get moisture going into your 5 inaccessible portions of your liner.
6 In terms of primary piping, it's generally 7 stainless steel, so you don't see a lot of any kind of 8 corrosion on a lot of that level of piping. So that's 9 generally really well maintained. Their numbers are 10 in good condition in terms of -- like they follow the 11 IST program.
12 So, in terms of a lot of the internal 13 components, especially when we're dealing with safety-14 related, they're all in exceptional condition. They 15 are very well maintained, or they're in a material 16 that is in need of maintenance, so it's just by 17 default.
18 (Simultaneous speaking.)
19 MEMBER SUNSERI: Hold on a second. Jose 20 first, and then whoever's on the line next.
21 (Simultaneous speaking.)
22 MR. HICKMAN: This is John Hickman.
23 MEMBER MARCH-LEUBA: Yeah. John, can you 24 hold on a minute?
25 MR. HICKMAN: Sure.
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170 1 MEMBER MARCH-LEUBA: (audio interference) 2 age, there is some settlement on the foundation, and 3 you will go down two inches in a corner. Any issues 4 with -- I mean, obviously this plant is built over 5 sand, right? So any issues with settlement?
6 MS. COOPER: Not that I'm aware of. There 7 are sites in Region II that do have settlements, and 8 they carry a license condition to monitor for 9 settlement. So they're required to survey and verify 10 that the differential settlement won't adversely 11 impact the structure.
12 For St. Lucie, they do not have any of 13 those concerns. Why their licensing base for their 14 lost heat sink is the assumption that their bridge 15 will fail due to liquefaction. But in terms of 16 safety-related structures, those soils have been 17 mitigated to eliminate those mechanisms. So you just 18 don't see that concern.
19 MEMBER MARCH-LEUBA: Okay. Thank you.
20 MEMBER SUNSERI: Okay, John. Your turn.
21 MR. HICKMAN: Yeah, just to add to what 22 Paula said and aspects of the responsibilities of the 23 resident inspectors when containment is open of our 24 pre-inspections at the beginning of outages and post 25 inspections at the end of outage -- the things that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
171 1 you guys just discussed is the conditions that we look 2 for and address. And the licensee has to answer those 3 questions prior to closing out those containments.
4 Another thing that we do and the aspect 5 that really tests containment's ability to contain is 6 the local leak rate test that we observe and we look 7 at to ensure that if you have a radiological accident, 8 that is maintained inside the containment, which is 9 another way to assess the containment's performance 10 for its design performing duties.
11 MEMBER SUNSERI: All right. Thank you.
12 Yeah, I don't want to go by without 13 acknowledging the housekeeping comments, though, 14 because my experience has been that's a good leading 15 indicator of the attitudes of the staff. I mean, 16 people are willing to pick up the trash and put it in 17 the bins, or not put it on the ground, anyway.
18 They're interested in taking care of the facility.
19 And that attitude permeates through the 20 organization. So hearing the housekeeping results and 21 then hearing the technical results, I'm not surprised 22 that they're maintaining it well.
23 Any other questions?
24 MEMBER HALNON: Matt, this is Greg. I had 25 a question about what Walt was talking about on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
172 1 containment.
2 A lot of the containments rooms -- I say 3 a lot; I mean a couple of containments that had been 4 on saltwater have had some cosmetic problems with 5 spalling and other things. And plus your brother to 6 the north, of course, are dealing with ASR. But is 7 the containment outside structure from the standpoint 8 of -- I realize it's probably sound from a structural 9 perspective, but is the saltwater environment causing 10 any unique problems or issues that the plant's dealing 11 with from a -- presently is cosmetic, but maybe 20 12 years down the road may not be?
13 MS. COOPER: Yeah, at this point, I would 14 say that their cold forms in between the layers of 15 containment are getting saltwater intrusion where you 16 can see some level of corrosion kind of on the edge 17 surrounding containment. They don't have spalling, at 18 least nothing that I would consider significant.
19 But in terms of corrosion at this point, 20 it's qualitatively managed because it's not at a level 21 that anyone would really consider long term would be 22 a concern. But you can see it. It is occurring.
23 Same thing with a lot of feed mechanisms on-site.
24 It's a predictable mechanism. So they can see the 25 level of corrosion just clearly from that leaching or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
173 1 that kind of staining aspect on those layers.
2 But that's managed by ASME on their IWE 3 and IWF. So, in terms of the level of inspection, 4 it's a high-level inspection considering the safety 5 significance of that structure. But I can't say other 6 than that that I'm aware of any other structural 7 deficiencies on their containment structure.
8 MEMBER HALNON: Okay.
9 MEMBER SUNSERI: John, do you want to add 10 anything to -- you're good?
11 MR. HICKMAN: No. I'm good with what 12 Paula said. And as she said, there's some staining, 13 but nothing that rises to the level of concern.
14 MEMBER SUNSERI: All right. Okay. Good.
15 MEMBER HALNON: Trying to get back to the 16 steam generator replace -- was that -- did they have 17 to cut a bigger hole in containment to get the steam 18 generators in or out, or could they use the equipment 19 hatch as it was?
20 MS. COOPER: I don't know if it was for 21 the reactor vessel --
22 (Simultaneous speaking.)
23 MR. HALE: Yeah. Yeah. Fortunately for 24 St. Lucie, we did create a hatch that was big enough 25 to pull the steam generators in and out.
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174 1 MEMBER HALNON: Okay. So you don't know 2 the condition, necessarily, of the outer layer or 3 rebar, then, inside containment?
4 MR. HALE: Well, you've got to -- the St.
5 Lucie containment is a free-standing steel containment 6 with a three-foot annulus and a rebar containment, 7 what they call a shield building.
8 MEMBER HALNON: Okay. So --
9 (Simultaneous speaking.)
10 MEMBER HALNON: Okay. I got it.
11 MR. HALE: Yeah. Okay?
12 MEMBER HALNON: Well, and -- so that's 13 similar to the Davis-Besse shield building issue, and 14 of course, they have the cold weather event that 15 causes their problems. But it's still got to be part 16 of the licensing basis for the area to be 17 freestanding, and they went through a tremendous 18 amount of calculations to determine that it wasn't 19 going to fall down.
20 And I realize that's kind of far out 21 there, but I just wanted to make sure that you don't 22 have any question about the condition of the rebar 23 inside the shield building.
24 MR. HALE: Yeah. No, we didn't see that 25 when we did the steam generator replacement.
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175 1 MEMBER HALNON: Okay. Thank you. That's 2 all I got.
3 MEMBER SUNSERI: That was Steve Hale 4 speaking.
5 MR. HALE: Oh, I'm sorry. Steve Hale.
6 MEMBER SUNSERI: No, I got a question.
7 Vesna, are you -- have your hand up, 8 Vesna?
9 MEMBER DEIMITRIJEVIC: Yes. Sorry. I 10 could not unmute myself.
11 MEMBER SUNSERI: No, you're good.
12 MEMBER DEIMITRIJEVIC: Short question.
13 Does plant have a risk-informed ISI program for the 14 section 11 piping?
15 MS. COOPER: I'm not sure. I don't know 16 if John Hickman can respond. But that's something 17 that's only been recently transitioning in the last 18 five or so years. I don't know if (audio 19 interference) are transitioned yet.
20 MR. HICKMAN: Yeah, I'm not sure if I can 21 answer that. I've only been at St. Lucie for about 22 two months, so --
23 MR. HALE: Yeah. They are certainly 24 considering a risk-based ISI program. But based on my 25 knowledge, I don't think they've implemented that yet.
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176 1 MEMBER DEIMITRIJEVIC: Yeah. I have a lot 2 of information, but I'm not at home all my regular 3 computer, so I cannot access it. But my question was 4 related because these risk-informed programs are based 5 on the degradation mechanism, and I was wondering if 6 -- I think if St. Lucie hasn't, it will probably be 7 done ten years ago or something. I'm not sure.
8 And they may need upgrade after these 9 degradation mechanism studies you have done. So that 10 was what my question was related to. So okay.
11 Thanks.
12 MR. HALE: All right. Thank you.
13 MEMBER SUNSERI: All right. So let's go 14 back Vaughn now.
15 You have some closing remarks, I think.
16 MR. THOMAS: Yes.
17 Next slide.
18 Okay. Thank you, Paula. In conclusion, 19 for the SLRA safety review, the staff finds the 20 requirements of 10 CFR 54.29(a) have been met (audio 21 interference).
22 This concludes our presentation, and the 23 (audio interference) will answer any questions you 24 actually have.
25 MEMBER SUNSERI: All right. Members, any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
177 1 final questions for the staff?
2 Okay. We're going to open up the phone 3 lines now for any comments from the members of the 4 public. So, if you're a member of the public 5 listening in, you can unmute your phone line by star-6 six. Or if you're on the Teams, just unmute and state 7 your name and your statement.
8 All right. So we will transition away 9 from the public comments, and one last chance for ACS 10 members.
11 All right. I do want to think Florida 12 Power & Light, your team. Obviously, you put a lot of 13 effort into this application, good showing of support 14 or to answer our questions, and likewise the staff.
15 And in particular, we always love that the resident 16 inspectors -- they especially make an effort to come 17 here and visit with us in person. It makes it so much 18 more meaningful.
19 Chair Rempe, at this point in time, that 20 concludes this part of the presentation. I would 21 recommend that if you're willing to entertain this, 22 that we take a ten-minute break, put the draft report 23 up, and I can at least read it into the record, and 24 then see where you want to go from there.
25 CHAIRMAN REMPE: So, at this time, I'd NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
178 1 like to have us go off the record.
2 (Whereupon, the above-entitled matter went 3 off the record at 2:27 p.m.)
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St. Lucie Units 1 and 2 Subsequent License Renewal Application ACRS Committee Meeting September 6, 2023
Agenda
- Introductions (Mike Davis, Licensing Projects Director)
- Performance Philosophy (Rob Craven, PSL Site Vice-President)
- St. Lucie Site Overview (Mike Davis)
- Subsequent License Renewal (SLR) Project (Steve Hale, ENERCON)
- Project Team
- Regulatory Guidance
- Integrated Plant Assessment
- Aging Management Programs (AMPs)
- Time-Limited Aging Analyses (TLAAs)
- Closing Remarks (Mike Davis) 2
3 St. Lucie Site Overview Plant Performance
- Plant Capability Factor1:
- Jun 2023: U1 - 93.35% U2 - 94.49%
- Dec 2022: U1 - 93.02% U2 - 91.07%
- Dec 2021: U1 - 92.35% U2 - 92.95%
- Dec 2020: U1 - 90.22% U2 - 94.08%
- Regulatory status
- ROP Actions Matrix Column 1
- All ROP Indicators are Green
- 1) cumulative mean for previous 18 months 4
St. Lucie Site Overview
- Plant Description
- Four-Loop Combustion Engineering (now Westinghouse) PWR
- Cooling Water pulled from the Atlantic Ocean
- Located on Hutchinson Island just North of Jensen Beach, Florida
- Licensed core power history, Units 1 and 2
- 2560 MWt, initial license
- 2700 MWt, Stretch Power uprate (U1-1981 and U2-1985)
- 3020 MWt, 11% Extended Power Uprate (EPU) (2012) 5
St. Lucie Site Overview 6
St. Lucie Site Overview
- Current license expiration dates, 3/1/2036 (Unit 1), 4/6/2043 (Unit 2)
- Original license renewal application (LRA) approved on October 2, 2003
- Based on draft Rev. 0 of NUREG-1801, Generic Aging Lessons Learned (GALL)
- 10 programs were updated to NUREG-1801, GALL Rev. 0, as part of the application review process
- Unit 1 Inspection Procedure (IP) 71003 inspection completed 11/20/2015 and for Unit 2 on 10/20/2017
- Submitted Subsequent License Renewal Application (SLRA) on 10/12/2021 7
St. Lucie Site Overview 8
St. Lucie Site Overview Significant Plant Modifications Since Initial License Renewal
- Replaced reactor vessel heads
- Replaced Unit 2 Steam Generators
- Replaced High and Low Pressure Turbine Steam Paths
- Replaced Moisture Separator/Reheaters
- Upgraded Main Steam Isolation Valves
- Increased Main Steam Bypass Control System Capacity
- Replaced Main Feedwater Pumps and Modified Steam Generator Flow Control Valves
- Replaced Heater Drain Pumps 9
St. Lucie Site Overview Significant Plant Modifications Since Initial License Renewal
- Replaced No. 5 Feedwater Heaters
- Replaced Main Generator Rotor and Rewind Stator
- Replaced Main Generator Hydrogen Coolers
- Replaced Turbine Plant Cooling Water Heat Exchangers
- Replaced Main Transformers 10
SLR Project St. Lucie/ENERCON Team
- Multi-discipline team with significant nuclear experience, both on site and corporate
- Extensive license renewal experience, both licensing and implementation, including original LR efforts for Turkey Point and St. Lucie
- Extensive St. Lucie (PSL) specific engineering and licensing experience including the extended power uprate effort
- SLR Coordinator position staffed at site by senior, experienced person 11
SLR Project Regulatory and Industry Guidance
- Used NEI 17-01 guidance
- Incorporated lessons learned from previous LRA/SLRAs and RAIs from the SLRA review of Turkey Point, Peach Bottom and Surry
- Conducted interviews with aging management program (AMP) owners on site November 2020 following the guidance of EPRI TR-110089, Experience-based Interview Process for Power Plant Management
- Followed NUREG-2191 (GALL-SLR) and NUREG-2192 (SRP-SLR) to the greatest extent possible
- Safety Evaluation Report (SER) issued July 2023 12
SLR Project Integrated Plant Assessment - Overall approach similar to that of original LR
- Differences between LR and SLR
- Scoping and screening Minimal differences Some updates required to address 10 CFR 54.4(a)(2)
- Aging management reviews (AMRs)
PSL initial LR per Draft GALL - additional aging effects required disposition based on GALL-SLR
- Aging management programs (AMPs)
Significant differences PSL initial LR, 27 AMPs PSL SLR, 47 AMPs 13
SLR Project - AMPs Consistency with NUREG-2191
- Very consistent, >98% A through E notes (~2500-line items)
- AMPs (Appendix B)
- Goal is to maximize consistency
- Includes aging management effectiveness review of current LR AMPs AMPs AMPs AMPs AMPs Plant AMP Consistent Consistent with Exception with Exception Specific Category with GALL with Enhancement and Enhancement AMPs Existing 36 6 23 1 5 1 New 11 11 0 0 0 0 Total AMPs 47 Turkey Point, Surry, Peach Bottom RAIs addressed
- Separate section in each AMP basis document summarizes how the RAIs were addressed
- RAI matrix provided in ePortal 14
SLR Project - AMPs AMPs with exceptions to GALL
- XI.M3, Reactor Head Closure Stud Bolting
- Current bolting is high strength
- XI.M29, Outdoor and Large Atmospheric Metallic Storage Tanks Unit 1 Refueling Water Tank bottoms inspection
- XI.M30, Fuel Oil Chemistry
- Some fuel oil tanks do not allow for internal inspection, complete draining and/or cleaning
- XI.M31, Reactor Vessel Material Surveillance
- Incremental adjustment to the current capsule removal schedule required
- XI.S3, ASME Section XI, Subsection IWF
- High strength bolting is utilized in some applications
- XI.S6, Structures Monitoring
- Ground water/Soil sampling 15
SLR Project - AMPs PSL AMP effectiveness review, evaluated all AMPs - Completed
- Performed in accordance with NEI 14-12, Aging Management Program Effectiveness, in January 2021
- Review concluded that all AMPs continue to be effective with no failed elements 16
Steam Generator AMP St. Lucie 2 Steam Generator performance after EPU
- Five RSG tube eddy current testing (ECT) completed post EPU - includes specific technique to identify tube-to-tube wear (TTW)
- Inspections of the St. Lucie 2 RSGs have confirmed that the primary tube degradation mode reported at San Onofre - RSG TTW has not been observed at St. Lucie 2 Wear at AVBs observed at St. Lucie 2 has consistently attenuated after EPU.
TTW is not a credible degradation mode for the St. Lucie 2 RSGs.
17
SLR Project - AMPs Commitments
- 52 for Unit 1, 51 for Unit 2
- Will be maintained separate from commitments for current LR PSL Units 1 and 2 UFSARs
- New Chapter 19 in each UFSAR, maintained separate from current LR
- SLR commitments included in table in Chapter 19 in each UFSAR Project Team has extensive experience with LR commitment management and implementation 18
- PSL TLAAs RV Embrittlement Metal Fatigue Environmental Qualification Metal Containment and Penetration Fatigue Plant Specific TLAAs
- Updates required to environmentally assisted fatigue calculations due to changes in guidance documents 19
Closing Remarks
- Manage aging effects to ensure intended functions are maintained
- Evaluated TLAAs with acceptable results
- Satisfied requirements for subsequent license renewal
- Retain gains and build margin for the future
- Site VP Closing Comments 20
Advisory Committee on Reactor Safeguards St. Lucie Plant, Units 1 and 2 Subsequent License Renewal Application (SLRA)
Safety Evaluation (SE)
September 6, 2023 Vaughn Thomas, Project Manager Paula Cooper, Region II Senior Reactor Inspector
Presentation Outline
- St. Lucie Plant (St. Lucie) Licensing History
- St. Lucie Aging Management Programs
- Specific Technical Areas of Review
- Inspections and Plant Material Conditions
- Conclusion on St. Lucie SLRA Review 2
St. Lucie, Units 1 and 2:
Licensing History Initial License Renewal Initial Initial License Renewed Expiration Unit License Renewal Application License Date 1 3/1/1976 11/30/2001 10/2/2003 3/1/2036 2 4/6/1983 11/30/2001 10/2/2003 4/6/2043 Subsequent License Renewal Application Submitted 8/3/2021 Acceptance Determination 9/29/2021 Safety Evaluation 7/21/2023 3
St. Lucie Units 1 and 2 Aging Management Programs SLRA - Original Disposition of AMPs SE - Final Disposition of AMPs o 47 AMPs in total o 47 AMPs in total o 35 existing programs o 36 existing programs
- 4 consistent with GALL-SLR
- 7 consistent with GALL-SLR
- 30 consistent with
- 28 consistent with enhancements and/or enhancements and/or exceptions exceptions
- 1 plant-specific
- 1 plant-specific o 12 new programs o 11 new programs
- All consistent
- All consistent 4
Specific Areas of SLRA Review
- Selective Leaching & External Surface Monitoring
- Selective Leaching in Air Environment
- Aggressive Air Environment from Salt Laden Air
- Inability to Externally Inspect Radiator Tube Surfaces
- Prior Failures Discovered by the NRC Staff
- Buried and Underground Piping and Tanks 5
Region II: AMP Inspections License Renewal Inspection Program for Initial Period of Extended Operations Inspection Dates Results U1 IP 71003 May 22, 2015 No Findings Phase 1 ML15142A614 U1 &2 IP 71003 January 4, 2016 No Findings Phase 2 ML16004A248 U2 IP 71003 April 12, 2017 No Findings Phase 1 ML17102B262 U2 IP 71003 November 30, 2017 No Findings Phase 2 ML17334A308 U1 & U2 IP 71003 TBD: 2027 ------
Phase 4 License Renewal Inspection Program for Subsequent License Renewal Inspection Dates Results U1 & U2 IP 71003 TBD: 2035 ------
Phase 5 U1 & U2 71003 TBD: 2046 ------
Phase 6 6
Region II: AMP Inspections ROP Baseline Inspections Inspection Date Aging Management Program IP71111.08 ISI 18-month RFO Augmented Inspection Activities 2022 U1 Boric Acid Corrosion Surveillance 2023 U2 ISI Program - Component and Component Support Inspections ISI Program - Containment Inspections ISI Program - Reactor Vessel Reactor Vessel Internals Inspection Steam Generator Inspections IP71111.21M Comprehensive Triennial Service Water System and Inspection of Water Control Engineering Team Inspection TBD: 2025 Structures (IP71111.07T Heat Sink) (2022 U1&U2)
IP71152 PI&R Annual & Ensure activities in the licensees aging management Biennial program are adequate to identify the aging effect prior 2023 to loss of SSC intended function, and whether the licensees corrective actions address the adequacy of the aging management program.
IP71111.21N.04 Age Related TBD: 2024 ALL Degradation 7
Region II: Plant Material Condition and Conclusion
- Plant material condition meets regulatory requirements for systems, structures, and components.
- The inspectors found that the AMPs were being implemented in accordance with the license condition.
- The NRC will continue to monitor AMPs using the baseline Reactor Oversight Process and License Renewal Inspection Program.
8
SLRA Review Conclusion On the basis of its review of the SLRA, the staff determined that the requirements of 10 CFR 54.29(a) have been met for the subsequent license renewal of St. Lucie Plant, Units 1 and 2.
9
Revision of Regulatory Guide 1.183 Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors Mark Blumberg, Senior Reactor Engineer (Technical Lead)
NRR/DRA/ARCB mark.blumberg@nrc.gov Joseph Messina, General Engineer (Technical Contact)
NRR/DSS/SFNB joseph.messina@nrc.gov September 6, 2023 - ACRS Full Committee Meeting
Agenda
- 1. Key Messages
- 2. Purpose and Regulatory Requirements
- 3. Revised Guidance
- a. Summary of Public Comments
- b. Highlighted Changes to Draft Rev. 1 in Response to Public Comments
- 4. Conclusions and Looking Forward (Rev. 2) 2
NRC Management and Staff Coordination Steering Committee NRR/DSS:
Mike Franovich, NRR/DRA Joseph Messina (Technical Lead)
Joseph Donoghue, NRR/DSS Steve Jones Mohamed Shams, NRR/DANU Michele Sampson, RES/DE NRR/DANU:
Michelle Hart Working Group NRR/DRA: RES:
Mark Blumberg (Technical Lead) Michael Eudy John Parillo Jerry Dozier OGC:
Shilp Vasavada Mary Frances Woods Elijah Dickson Sean Meighan (Project Lead)
Ed Stutzcage (Acting Project Lead) 3
Agenda
- 1. Key Messages
- 2. Purpose and Regulatory Requirements
- 3. Revised Guidance
- a. Summary of Public Comments
- b. Highlighted Changes to Draft Rev. 1 in Response to Public Comments
- 4. Conclusions and Looking Forward (Rev. 2) 4
Key Messages
- The NRC staff issued draft Regulatory Guide (RG) 1.183 Rev. 1 (DG-1389),
Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors in April 2022 for public comment.
- ACRS and stakeholder involvement on the revision to RG 1.183 began prior to 2009 when an initial draft was issued for public comments. Recent development of the guidance involved numerous public workshops (4) and a meeting with the ACRS subcommittee prior to issuing DG-1389.
- The NRC staff prepared responses to the public comments on DG-1389, obtained internal concurrence, an Office of General Counsel no legal objection and provided the draft final version of the guidance for the ACRS review.
- Although the disposition of the 163 public comments required significant and detailed responses, the changes to DG-1389 in response to these comments were minimal because the DG-1389 guidance continues to be appropriate and defensible.
5
Agenda
- 1. Key Messages
- 2. Purpose and Regulatory Requirements
- 3. Revised Guidance
- a. Summary of Public Comments
- b. Highlighted Changes to Draft Rev. 1 in Response to Public Comments
- 4. Conclusions and Looking Forward (Rev. 2) 6
Purpose and Regulatory Requirements
- NRC staff developed RG 1.183 Rev. 0 (July 2000) to support implementation of 10 CFR 50.67, Accident source term
- 10 CFR 50.67 establishes design basis dose limits for the control room, exclusion area boundary and low population zone for the purposes of determining the design requirements for mitigating safety systems
- RG 1.183 provides an acceptable method for modeling the design basis accidents used to demonstrate compliance with 10 CFR 50.67
- 10 CFR 50.67 allows for the use of alternative source terms other than the source term derived from NUREG-1465, Accident Source Terms for Light-Water Nuclear Power Plants used in RG 1.183, Rev. 0.
7
Purpose and Regulatory Requirements (cont.)
Regulatory Max. Rod Average Enrichment Source Term Guide Burnup w/o U-235 GWd/MTU 1.3, 1.4, 1.195 18-25 3-3.5 TID-14844 1.183, Rev. 0 Up to 60, 5 NUREG-1465 With NUREG/CR-5009 up to 62 1.183, Rev. 1 Up to 68 8 SAND-2011-0128 1.183, Rev. 2 Up to 80 10 SAND-2023-01313 (proposed) 8
Purpose and Regulatory Requirements (cont.)
- Site Safety Assessment
- 10 CFR 50.67, 10 CFR 50.34, 10 CFR 52.17, 10 CFR 52.47, 10 CFR 52.79, 10 CFR 52.137, 10 CFR 52.157
- Control Room Habitability
- 10 CFR 50.67, 10 CFR 50, Appendix A, General Design Criteria (GDC) 19, 10 CFR 50.34
- Technical Support Center Habitability
Agenda
- 1. Key Messages
- 2. Purpose and Regulatory Requirements
- 3. Revised Guidance
- a. Summary of Public Comments
- b. Highlighted Changes to Draft Rev. 1 in Response to Public Comments
- 4. Conclusions and Looking Forward (Rev. 2) 10
Summary of Public Comments Percentage of Comments by Categories General or Editorial 17%
LOCA 16%
Range of Applicability 12%
Source or Release Fraction 11%
MSIV Leakage Pathway 8%
Fuel Handling Accident 8%
Control Room 7%
Implementation 7%
Acceptance Criteria 3%
Pre-accident Spike 3%
Meteorology 2%
Equipment Qualification 1%
Transient Fission Gass Release 1%
11
Agenda
- 1. Key Messages
- 2. Purpose and Regulatory Requirements
- 3. Revised Guidance
- a. Summary of Public Comments
- b. Highlighted Changes to Draft Rev. 1 in Response to Public Comments
- 4. Conclusions and Looking Forward (Rev. 2) 12
Highlighted Changes to Draft Rev. 1 in Response to Public Comments
- Suppression Pool Scrubbing
- Control Room
- Implementation
- Natural Deposition in Containment
- Maximum Hypothetical Accident (MHA) loss of coolant accident (LOCA) Source Term
- Main steam isolation valve (MSIV) Leakage Pathway
- New Reactor Applications and Regulations
- Non-LOCA Gap Fractions, Figure 1
- Equipment Qualification
- Fuel Handling Accident
- Meteorology and Atmospheric Dispersion 13
Suppression Pool Scrubbing 2 Public Comments
- Overview: In DG-1389, staff did not propose any changes to the regulatory positions (RPs) on suppression pool scrubbing
- Public Comments: 1) re-evaluate boiling-water-reactor (BWR) release fractions based upon new accident sequences including suppression pool scrubbing, 2) allow for suppression pool scrubbing based upon a contractors report on suppression pool decontamination (NUREG/CR-6153) and the State-of-the-Art-Reactor Consequence Analyses
- Response to Public Comments: 1) staff position on suppression pool scrubbing is already contained in RP A-2.5, and a revision to the LOCA source term release fractions is beyond scope of the RG revision, 2) revised RP A-2.5 to state that scrubbing has historically not been credited, rather than stating it should not generally be credited.
Added an example where scrubbing has been credited in the primary containment cooling system for the Economic Simplified BWR
- Changes made to DG-1389: As described above and added the following footnote 1 to Appendix A.
For an example of the modeling of radionuclide transport in containment with scrubbing credit in the primary containment cooling system (PCCS) of a new BWR reactor application, see Section 15.4.5 of NUREG-1966, Final Safety Evaluation Report, Related to the Certification of the Economic Simplified Boiling-Water Reactor Standard Design, (ADAMS Accession No. ML14100A304 (package)) (Ref. A-7).
14
Control Room 11 Public Comments
- Overview: DG-1389 introduced 1) the term transit dose to address the issue of control room access as stated in the GDC 19: Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions Previously guidance was silent on the issue of control room access transit dose with the exception of ingress/egress, and 2) footnote 15 for radiation shine calculations
- Public Comments: 1) Requested the proposed guidance regarding transit dose be eliminated or a regulatory basis provide since most licensees have not included this evaluation in their licensing basis and that the GDC could be interpreted to apply only to the control room structure itself,
- 2) Footnote 15 be clarified or removed, 3) acknowledge that the finite geometry factor is incorporated computer codes such as RADTRAD, 4) add allowances for alternative conversion factors, and 5) whether sufficient safety margins exist for control room doses
- Response to Public Comments: Agreed with the need to revise transit dose, remove footnote 15, acknowledge the finite geometry factor and address the concern regarding safety margins.
- Changes made to DG-1389: The staff has removed the language associated with transit dose in RP 4.2, restored the RG 1.183, Revision 0 language and removed footnote 15. Staff is evaluating this issue and will determine whether to address this issue in a future revision to this RG.
15
Implementation 11 Public Comments
- Overview: DG-1389 revised the alternative source terms and methods for demonstrating compliance with 10 CFR 50.67, but stated that Revision 0 will continue to be available for use by licensees and applicants
- Public Comments: Requested clarifying statements, evaluations of implementation of Revision 1 for sample plants, examples of selective implementation and stated that Revision 1 should supersede Revision 0 because of errors in Revision 0
- Response to Public Comments: Agreed that clarifying statements and an example of selective implementation should be added
- Changes made to DG-1389: Clarifying statements regarding implementation were made to the Background, RP 1.1.1, Safety Margins, and RP 1.1.5, Applicability to Light-Water Reactor Applications, Including, Advanced Evolutionary and Passive Designs 16
Natural Deposition in Containment 4 Public Comments
- Overview: Staff proposed minor wording changes in DG-1389 and added that the reduction of airborne radioactivity by both sprays and gravitational settling (competing processes) should be evaluated on an individual case basis
- Public Comments: Questioned whether applying the gravitational settling model in NUREG/CR-6189 continues to be applicable when considering the added main steam line deposition models and the continued applicability of NUREG/CR-6189 with the MHA source term
- Response to Public Comments: Main steam line models did not consider removal by sprays and natural deposition in containment and NUREG/CR-6189 can be used if adjusted to incorporate the revised MHA source term
- Changes made to DG-1389: RP A-5 clarified to state the main steam line models are not valid when crediting other aerosols removal mechanisms, revised RP A-2.2 to state that reductions in NUREG/CR-6189 are not accepted, but the methods, when adjusted for the MHA source term, could be credited on a case-by-case basis 17
MHA LOCA Source Term 9 Public Comments
- Overview: Staff included text in DG1389 to clarify many aspects of the ranges of applicability of the source term and its use
- Public Comments: applicability of/to 1) accident sequences and reactor designs, 2) chromium coated cladding and chromium-doped fuel, 3) impact of burnup/use of earlier source term,
- 4) Impact of burnup/use of earlier source term, 5) applicability to mixed oxide fuel (MOX),
- 6) applicability to accident tolerant fuel (ATF), 7) crediting of multiple removal mechanisms,
- 8) applicability of physical models to other designs, and 9) proposed restrictions to applicability in burnup, fuel type (including MOX), and clad type
- Response to Public Comments: 1) clarified ranges of applicability in text, 2) revised the applicability range of chromium limits for chromia-doped and chromia-coated fuel, 3) no change, 4) added text to Background of the draft final regulatory guidance regarding applicability of Rev 0, 5) clarified that the source term is not endorsed for MOX, 6) revised to state that the source term is not applicable to iron-chromium-aluminum (FeCrAl) and other long-term ATF concepts, 7) clarified text to address the use of different removal mechanisms,
- 8) revised text to state that the models would be considered for other designs on a case-by-case basis, and 9) defined applicability of source term before first RP (Section C) of RG
- 4) Modified Background section, 5) Modified Introduction to clarify the RG is not endorsed for MOX fuels 6) Revised footnote 10, 7) Modified R.P. A-5, 8) Modified R.P. A-5.6, 9)
Modified beginning of Section C 18
MSIV Leakage Pathway 13 Public Comments
- Overview: In DG-1389 three main steam line deposition models and revised alternative drain path seismic guidance were added and the parts of the release pathway that can be credited were clarified
- Public Comments: On the use of non-safety related equipment, source term scaling factors, inboard deposition credit, clarifying the acceptability of proposed deposition models, assumed sizes of containment aerosols, and removal mechanisms for re-evaluated the Office of Nuclear Regulatory Research, Accident Evaluation Branch (AEB) 98-03 models
- Response to Public Comments: Agreed with most public comments, but disagreed with revising containment aerosol sizes and limiting credit to safety related components in the alternative leakage pathway
- Changes made to DG-1389: Added clarifications to RP A-5 regarding: scaling factors, removed the need for case-by-case evaluations when using the revised AEB 98-03 method in RP A-5.6.2, and added the technical basis for the crediting the condenser and main steam line piping 19
New Reactor Applications and Regulations 5 Public Comments
- Overview: In DG-1389, staff expanded the scope of use of RG 1.183, Revision 0 for use with new reactor applications
- Public Comments: Related to the meaning of advanced LWR [light-water reactor] and applicability of the guidance to new LWR applications
- Response to Public Comments: The staff responded to the public comments by clarifying that the guidance is applicable to any new LWR application under Parts 50 or 52 and listing all relevant regulatory requirements
- Changes made to DG-1389: Staff provided the following changes to RG
- Section A, Applicable Regulations, Section B, Reason for Revision and Background, Section C, Subsection 1.1.5, Applicability to New Light-Water Reactor Applications, Including Advanced Evolutionary and Passive Designs by clarifying RG applicable to new LWR applications, including advanced evolutionary and passive LWR designs, and
- Section A, Applicable Regulations, Section C, Subsection 1.3.1 Design Basis Radiological Analyses by providing the applicable regulations for design basis radiological analyses for new reactor applications (i.e., safety analysis report requirements, include all subparts of Part 52, and include 10 CFR 100.21 for siting) 20
Non-LOCA: Gap Fractions, Fig. 1 4 Public Comments
- Overview: In DG-1389, staff added a power history curve (LHGR (Linear heat generation rate) vs burn-up - see Figure 1) that must bound operation in order for the added non-LOCA gap fractions in Tables 3 (BWR) and 4 (pressurized-water reactor (PWR)) to be applicable and replaced the Rev. 0 Footnote 11 LHGR and burn-up limits
- Public Comments: Staff received public comments related to Figure 1 regarding the treatment of power uncertainties, the peak LHGR, and the applicability of Figure 1 to part-length rods (PLRs)
- Response to public comments:
- Staff specified that power uncertainties should be accounted for when demonstrating adherence to the Fig. 1 power envelope, as stated in the Clifford tech.
bases document referenced in DG-1389
- Staff stated that the peak LHGR is not meant to be exceeded. If it cannot be met, the licensee can follow the procedure outlined in Appendix I
- Staff stated that the non-LOCA gap fractions can be applied to PLRs if they meet the peak LHGR curve that was added to Fig. 1
- Changes made to DG-1389: staff updated Figure 1 to include peak LHGR power envelopes and added clarification on treatment of PLRs and power uncertainties to RP 3.2 21
Non-LOCA Gap Fractions, Fig. 1 (Contd)
RG 1.183 Rev. 0 DG-1389 Figure 1 New RG 1.183 Rev. 1 Figure 1 22
Environmental Qualification 2 Public Comments
- Overview: In DG-1389 staff removed the Environmental Qualification (EQ) guidance from RG 1.183, Revision 0 (Appendix I, Assumptions for Evaluating Radiation Doses for Equipment Qualification), since updated EQ guidance is being incorporated into RG 1.89, Revision 2 (DG-1361)
- Public Comments: Staff received public comments related to the continued use of EQ guidance in RG 1.183, Revision 0, including the continued use of TID-14844 for EQ, as specified in RG 1.183, Revision 0
- Response to Public Comments: EQ guidance in RG 1.183, Revision 0 can continue to be used (including the use of the TID-14844 source term), provided that the plant design and licensing basis is in accordance with the applicability and limitations of RG 1.183, Revision 0
- Other facilities, such as those that increase enrichment above 62 gigawatt-days per metric ton uranium (GWd/MTU) of 5 weight percentage Uranium-235 enrichment (bounds specified in RG 1.183, Revision 0), need to ensure that the guidance used is technically justified
- Changes made to DG-1389: Staff updated the Background, to clarify the continued applicability of RG 1.183, Revision 0, consistent with the public comment response, removed the reference to RG 1.183, Revision 0, Appendix I, and referenced RG 1.89, Revision 2 for EQ guidance. Also, since the revised RG 1.89 (Rev. 2) guidance on EQ was issued, it is now referenced in RG 1.183.
23
Fuel Handling Accident 12 Public Comments
- Overview: In DG-1389 staff provided a revised Fuel Handling Accident model allowing for modeling of retention and re-evolution of iodine from the spent fuel pool
- Public Comments: Requested: 1) clarification on the acceptable iodine species assumptions and a constant from a reference document, 2) revision of the method for water depths outside the applicability specified, 3) a method that calculated doses for fuel handlers and spent fuel pool workers, and 4) confirmation regarding the applicability of the release fractions labeled other halogens from Tables 3 and 4.
- Response to Public Comments: 1) The requested clarifications were provided,
- 2) revisions to the method are outside the applicability of the experiments used as the basis for the method, 3) the guidance is not intended for calculating doses to fuel handlers and workers near the spent fuel pool, and 4) the requested confirmation was provided
- Changes made to DG-1389: Modifications were made to include the requested clarifications into RPs B-1.3 and B-2 24
Meteorology and Atmospheric Dispersion 3 Public Comments
- Overview: DG-1389, added guidance that: 1) states that a modified version of the control room methodology in RG 1.194 may be used to estimate the offsite atmospheric dispersion factors out to distances of 1,200 meters,
- 2) align most unfavorable dispersion coincident with most adverse releases
- Public Comments: 1) Stated that the basis for the added guidance appears to be DG4030, however, the associated Reg Guide 1.249 had not been issued,
- 2) clarify codes for dispersion and acceptability of prior guidance,
- 3) questioned need to include above Overview item 2
- Response to Public Comments: 1) The NRC staff agrees with the comment that a basis needs to be provided so a reference to RG 1.249 will be added,
- 2) codes are contained in referenced guidance, 3) aligned guidance with RG 1.194
- Changes made to DG-1389: The staff will revise RP 5.3 to add the reference to RG 1.249 (for estimating the offsite atmospheric dispersion factors using a modified version of the control room methodology in RG 1.194), and the staff clarified guidance to ensure a conservative dose is calculated 25
Agenda
- 1. Key Messages
- 2. Purpose and Regulatory Requirements
- 3. Revised Guidance
- a. Summary of Public Comments
- b. Highlighted Changes to Draft Rev. 1 in Response to Public Comments
- 4. Conclusions and Looking Forward (Rev. 2) 26
Conclusions and Looking Forward
- The NRC staff has developed updated design basis dose analysis guidance, based upon experience since issuing RG 1.183, Rev. 0, research data, new analyses, and significant stakeholder involvement
- These changes represent significant advancements in guidance for:
- ATF, high-burnup fuel, and increased enrichment source term analyses (68 GWd/MTU rod average and enrichments up to 8 weight percent Uranium-235 for certain near-term ATF designs (chromium-coated cladding and chromia-doped fuel)
- modeling BWR MSIV leakage including guidance for crediting holdup and deposition of MSIV leakage within the main steam lines and condenser for BWRs
- non-LOCA source terms
- revised transport and decontamination models for the fuel-handling design-basis accidents
- Looking Forward (Rev. 2)
- Increased Enrichment (10 weight percent Uranium-235) and burnup (80 GWd/MTU)
- Expanded scope for near-term ATFs (chromium-coated, FeCrAl -iron-chromium-aluminum)
- Additional items under consideration - e.g., Increased Enrichment rulemaking, suppression pool scrubbing 27
Questions/Comments?
Mark Blumberg, Senior Reactor Engineer (Technical Lead)
NRR/DRA/ARCB mark.blumberg@nrc.gov Joseph Messina, General Engineer (Technical Contact)
NRR/DSS/SFNB joseph.messina@nrc.gov 28
SELECTED ACRONYMS AEB Accident Evaluation Branch ATF accident tolerant fuel BWR boiling-water reactor DPO differing profession opinion EQ equipment qualification GDC general design criteria GWd Gigawatt-days LHGR linear heat generation rate LOCA loss-of-coolant accident LWR light-water reactor MHA maximum hypothetical accident MOX mixed-oxide fuel MSIV main steam isolation valve MTU metric ton of uranium PCCS primary containment cooling system PLR part-length rods PWR pressurized-water reactor RADTRAD RADionuclide Transport, Removal, and Dose Estimation RG regulatory guide RP regulatory position 29
Backup Slides 30
LWR Source Term Timeline 1999 1975 1990 10CFR50.67 WASH-1400 NUREG- 2000 2009 NRC 1150 RG 1.183 DG-1199 1930 1940 1950 1960 1970 1980 1990 2000 2010 2020 2030 1961 1995 2022 SL1 NUREG- DG-1389 1962 1465 TID-14844 1954 10CFR100 1942 Atomic Critical Energy 1957 1979 1986 2011 Pile-1 Act Windscale TMI-2 Chernobyl Fukushima 31
Differing Professional Opinion (DPO-2021-001)
Executive Director for Operations Appeal Panel Report Recommendations and Observations Impacting Draft Final Regulatory Guide (RG) 1.183, Revision 1 Mark Blumberg, NRR/ARCB Michael Markley, NRR/LPL2-1 September 6, 2023 DIFFERING VIEWS OF NRC EMPLOYEES:DO NOT REPRESENT POSITIONS OF NRC MANAGEMENT
Differing Professional Opinion (DPO-2021-001) Panel Report1
- EDO issued the DPO Appeal Panel Analysis Report on August 25, 2023, and a memo that includes the following staff directed actions:
- Take appropriate actions to ensure compliance with 10 CFR 50.67 for the subject plant and resolve the licensing basis clarity issues for the license amendment including the impact of MSIV packing leakage, the basis for limiting break location, and the aerosol deposition credit for the main condenser.
- Develop an implementation plan for recommendations in the DPO Appeal Panel Analysis Report.
- Report recommendations stated, in part, that:
- In light of the issues identified in this report, in the near term, revise and consolidate the staffs updated guidance (DG-1389 and DRA-ISG-2021-01).
- The DPO Appeal Panel believes any update to RG 1.183 should be consolidated into a single revision to the regulatory guide and not include companion interim staff guidance.
- Enhanced focus on the overall intent of regulations related to the DBA analysis (e.g., focus on assessing the acceptability of engineered safety features rather than overreliance on non-safety-related features (e.g., deposition in power conversion systems)).
- The report also provided specific issues, observations and conclusions that should be addressed.
- The NRC staff is evaluating Report recommendations and possible revision to Revision 1 of RG 1.183.
1 DPO Case File for DPO-2021-001 (ADAMS No. ML23240A717, not yet publicly available).
2
Examples of Specific Issues, Observations and Conclusions Impacting Nuclear Safety
- Revise language relative to MSIV packing leakage, to better reflect actual operating experience (i.e., events indicate that packing leaks may not be a small contributor to overall main steam line leak rate) and consider these limiting pathways to the environment.
- Compliance with 10 CFR 50.67 must be based upon the licensees submittal that becomes part of the licensing basis. The DPO Appeal Panel notes that care must be used when determining what assumptions constitute actual conservatisms vice basic assumptions underpinning a deterministic and somewhat stylized evaluation such as the DBA analysis.
are nonconservative and do not appear to reflect the state of knowledge that has been developed since issuance of AEB-98-03. non conservatisms in AEB 98-03 and other issues such as crediting spray[s] simultaneously with main steam line deposition the NRC has not issued timely updates, revised guidance or generic communication to address these issues.
- The selection of the recirculation line break does not represent a bounding condition.
- The DPO Panel disagreed that the inherent seismic robustness of the pathway provides high confidence that a pathway to the condense[r] will be available in and of itself. Past seismic walkdowns related to this type of application for some licensees have identified the need for physical modifications to ensure the pathway is not failed by seismic-related failure mechanisms, such as system piping interactions and anchor issues.
3
Key Points for Revising Regulatory Guide 1.183
- The technical issues are sufficiently complex to have warranted an ACRS Subcommittee meeting,
- If not incorporated, plant-specific precedents using Revision 1 would be broadly replicated,
- Any future Revision 2 may be years in development and never be adopted,
- Prefer to resolve RG 1.183, Revision 1, now, including the DPO issues, and not submit differing views on RG 1.183, Revision 1, or plant-specific licensing actions.
4
DPO Lessons Learned
- The subject of this DPO provides a real-life example of why safety is not assured with the current draft revision of RG 1.183, Revision 1
- The AST license amendment, subject to the DPO, was one of four license amendments used to inform the development of RG 1.183, Revision 1 whose issuance was delayed so that it could be informed by the methods used.
- The DPO results show that these methods, used to remove and relax safety systems, were in error or need clarity.
- This version of the RG will continue to propagate methods that do not ensure nuclear safety.
5
Integrated Nuclear Solutions LLC Regulatory Uncertainty Associated With RG 1.183 708th ACRS Meeting September 6, 2023 Presenter: Paul Clifford Regulatory Uncertainty Associated with RG 1.183 1 Integrated Nuclear Solutions LLC
Conclusions and Recommendations
- SANDIA 2011 and 2023 MHA release fractions are not burnup dependent and are applicable to the current fleet
- These release fractions are significant research findings which suggest that existing plant licensing bases may be challenged
- NRC staffs response to these research findings are inconsistent with past precedent and regulatory policy
- Risk attributes and safety significance associated with these changes needs to be evaluated to determine if immediate actions are needed to ensure reasonable assurance of adequate protection of public health and safety Regulatory Uncertainty Associated with RG 1.183 2 Integrated Nuclear Solutions LLC
Conclusions and Recommendations (cont.)
- As shown in the examples, issuing RG 1.183 Rev.01 in its current form does not provide regulatory stability or predictability
- SANDIA 2011 is no longer relevant, being superseded by 2023
- To provide regulatory stability and predictability, the following actions should be completed:
- Backfit Determination to document a reasoned, justified, risk-informed decision for how, or if, these changes should be implemented on existing fleet
- Forward Fit Determination to document a reasoned, justified, risk-informed decision for when, or if, these changes should be implemented going forward Regulatory Uncertainty Associated with RG 1.183 3 Integrated Nuclear Solutions LLC
Proposed Path Forward - Range of Applicability RG 1.183 Rev.00
- Up to 62 GWd/MTU, 5.0 w/o enrichment
- Up to 68 GWd/MTU, 8.0 w/o enrichment RG 1.183 Rev.01
- Up to 80 GWd/MTU, 8.0 w/o enrichment RG 1.183 Rev.02 All versions of RG 1.183 will coexist Regulatory Uncertainty Associated with RG 1.183 4 Integrated Nuclear Solutions LLC
Misleading Range of Applicability SAND2011-0128 In terms of fractional releases, source terms developed for high burnup fuel and for MOX do not differ markedly from source terms developed by similar means for lower burnup fuel or for low-enrichment uranium dioxide fuel. The source terms do differ from those described in NUREG-1465. These differences can be attributed to improved understanding of reactor accident phenomenology and modeling since publication of NUREG-1465.
SAND2023-01313 Finally, this analysis demonstrates that in-containment source terms are essentially unchanged by increased burnup or elevated enrichment and that the most significant variation in source term continues to arise from differences between accident scenarios.
No Burnup Dependence Regulatory Uncertainty Associated with RG 1.183 5 Integrated Nuclear Solutions LLC
Commission Policy
- Both SANDIA reports are applicable to existing fleet (although 2023 supersedes 2011)
- Implementing new release fractions is a change to a regulatory position and should be evaluated in accordance with Commission Policy MD 8.4 Section I, Policy Regulatory Uncertainty Associated with RG 1.183 6 Integrated Nuclear Solutions LLC
Path Forward - Recommended Staff Actions: Maintaining multiple versions of MHA
- Risk and Safety Significance releases promotes regulatory uncertainty
- Forward Fit Determination RG 1.183 RG 1.183 Rev.0 Rev.1 (2000) (TBD)
SANDIA SANDIA Report Retire Rev.0 Report (2011) (2023)
Staff Actions:
Alternatively, issue Rev.01 without changes to - Risk and Safety Significance MHA releases to avoid further delays and - Need for immediate action?
provide time for Backfit and Forward Fit - Backfit Determination documentation Regulatory Uncertainty Associated with RG 1.183 7 Integrated Nuclear Solutions LLC
Regulatory Uncertainty - Examples Regulatory Uncertainty Associated with RG 1.183 8 Integrated Nuclear Solutions LLC
Regulatory Uncertainty - Example 1 RG 1.183 Rev.00 Plant Y requests approval for a power uprate, but will maintain their existing 62 62 GWd/MTU burnup and 5.0 w/o enrichment limits RG 1.183 Rev.01 68
- Licensee able to maintain Rev.00?
80
- Staff expects latest revision?
- Maintaining 3 active versions of the same guidance creates regulatory uncertainty Regulatory Uncertainty Associated with RG 1.183 9 Integrated Nuclear Solutions LLC
Regulatory Uncertainty - Example 2 RG 1.183 Plant Z requests approval for HBU/IE Rev.00 reload cores, up to 75 GWd/MTU burnup 62 and 7.0 w/o enrichment limits RG 1.183 Rev.01
- Based upon stated range of applicability, only Rev.02 is applicable at HBU 68
- However, SANDIA reports demonstrate RG 1.183 that releases are not sensitive to HBU or Rev.02 enrichment 80
- Does plants license basis Rev.00 remains applicable?
- Maintaining 3 active versions of the same guidance creates regulatory uncertainty Regulatory Uncertainty Associated with RG 1.183 10 Integrated Nuclear Solutions LLC
Regulatory Uncertainty - Example 3
- Six months from now, Plant Z requests approval for a modest increase in allowable fuel burnup
- Licensee applies Rev.1 (2011) release fractions within updated dose calculations
- During LAR review, staff insist that the latest MHA releases (SANDIA 2023) need be incorporated due to adequate protection
- Following guidance does not equate to regulatory stability and predictability Regulatory Uncertainty Associated with RG 1.183 11 Integrated Nuclear Solutions LLC
Backup Slides Regulatory Uncertainty Associated with RG 1.183 12 Integrated Nuclear Solutions LLC
Voluntary Guidance - Implementation Regulatory Uncertainty Associated with RG 1.183 13 Integrated Nuclear Solutions LLC
One Acceptable Means to Demonstrate Compliance Regulatory Uncertainty Associated with RG 1.183 14 Integrated Nuclear Solutions LLC
Alternative Non-LOCA Releases
- RG 1.183 provides generic, bounding radionuclide release fractions for Non-LOCA radiological consequence assessments
- Unlike MHA core average releases, Non-LOCA release fractions range of applicability limited due to sensitivity to burnup, enrichment, fuel design, and operating history
- RG 1.183 also provides an acceptable analytical procedure for calculating alternative Non-LOCA radionuclide release fractions
- In the past, many licensees have successfully licensed alternative gap fractions to accommodate more economical fuel utilization Minimal hurdle to develop and license alternative releases Regulatory Uncertainty Associated with RG 1.183 15 Integrated Nuclear Solutions LLC
MHA Releases
- MHA releases derived using nonparametric order statistics to develop distributions for the timing of radionuclide release during four accident phases and for release fractions of nine chemical classes of radionuclides as calculated with the MELCOR accident analysis computer code.
- Numerous MELCOR simulations involving multiple severe accident scenarios using several NSSS designs
- Extensive validation and peer review Regulatory Uncertainty Associated with RG 1.183 16 Integrated Nuclear Solutions LLC
Alternative MHA Releases
The NRC, its contractors, various national laboratories, peer reviewers, and others expended substantial effort in performing severe accident research and in developing the source terms in Sandia National Laboratories technical reports.The NRC staff will consider applications for an AST different from that identified in this guide, although the staff does not expect to approve any MHA LOCA source term that is not of the same quality as the source terms in NUREG-1465 and SAND-2011-0128.
- Significant hurdle to develop and license alternative releases Effectively, RG 1.183 is not one acceptable means, but the only acceptable means to satisfy regulatory requirements Regulatory Uncertainty Associated with RG 1.183 17 Integrated Nuclear Solutions LLC
NRC Staff Response to SANDIA Research Findings Regulatory Uncertainty Associated with RG 1.183 18 Integrated Nuclear Solutions LLC
NRCs Response to New MELCOR Predictions
- At the time of their publication, the SANDIA reports represent the state-of-the-art
- Most accurate representation of severe accident progression and releases
- Significant differences from plants license bases
- NRCs response to these research findings should have mirrored their response to other safety-significant research findings (e.g., RIL 0401 (RIA) and RIL 0801 (LOCA))
Regulatory Uncertainty Associated with RG 1.183 19 Integrated Nuclear Solutions LLC
Logical and Systematic Response DISCOVERY The NRC staffs response to RIL 0801 followed a logical progression:
Discovery EVALUATION Evaluation Action The staff should follow the same approach, combined with MD 8.4 Backfit and Forward Fit requirements, in response to the ACTION SANDIA findings Regulatory Uncertainty Associated with RG 1.183 20 Integrated Nuclear Solutions LLC
Backfit and Forward Fit Policy
- 10 CFR 50.109, Backfitting, provides a codified process for evaluating the imposition of new or modified regulations, interpretations, or staff positions
- Management Directive (MD) 8.4, Management of Backfitting, Forward Fitting, Issue Finality, and Information Requests, provides direction and expectations for staff
- Detailed staff guidance provided in NUREG-1409 Regulatory Uncertainty Associated with RG 1.183 21 Integrated Nuclear Solutions LLC
Change accident sequences Where is risk and based on modern risk-insights?
safety significance assessment?
Is action needed today to ensure adequate protection?
Where is Backfit Determination?
Compliance or adequate protection exception from Cost justified substantial Backfit Analysis? increase in protection?
Regulatory Uncertainty Associated with RG 1.183 22 Integrated Nuclear Solutions LLC
No change to regulatory requirements Decision to update RG 1.183 Where is risk and safety significance assessment? Where is Forward Fit Determination?
Adequate protection? Cost justification?
Regulatory Uncertainty Associated with RG 1.183 23 Integrated Nuclear Solutions LLC
Why Maintain Multiple Versions of Same Guidance?
Regulatory Uncertainty Associated with RG 1.183 24 Integrated Nuclear Solutions LLC
Retiring Inactive or Revising Regulatory Guides Withdrawal of a Regulatory Guide Withdrawal of a Regulatory Guide should be thought of as the final revision of the guide. Guides are revised for a variety of reasons including changes in
- As described on NRC website, technology and methodology. Although a RG is withdrawn, current licensees may continue to use it, and withdrawal does not affect any existing licensees withdrawal is part of the RG or agreements. process https://www.nrc.gov/reading-rm/doc-collections/reg-guides/index.html
- Same is true for RG revisions
- Not uncommon to retire legacy RGs
- In 2020, RG 1.77 was retired when RG 1.236 was issued Regulatory Uncertainty Associated with RG 1.183 25 Integrated Nuclear Solutions LLC
Path Forward - Status Quo RG 1.183 RG 1.183 RG 1.183 Rev.0 Rev.1 Rev.2 (2000) (TBD) (TBD)
SANDIA SANDIA Report Report (2011) (2023)
All versions of RG 1.183 will coexist Regulatory Uncertainty Associated with RG 1.183 26 Integrated Nuclear Solutions LLC
Path Forward - Required by MD 8.4 Staff Actions: Staff Actions:
- Risk and Safety Significance - Risk and Safety Significance
- Forward Fit Determination - Forward Fit Determination RG 1.183 RG 1.183 RG 1.183 Rev.0 Rev.1 Rev.2 (2000) (TBD) (TBD)
SANDIA SANDIA Report Report (2011) (2023)
Staff Actions: Staff Actions:
- Risk and Safety Significance - Risk and Safety Significance
- Backfit Determination - Backfit Determination Regulatory Uncertainty Associated with RG 1.183 27 Integrated Nuclear Solutions LLC
Path Forward - Recommended Staff Actions: Maintaining multiple versions of MHA
- Risk and Safety Significance releases promotes regulatory uncertainty
- Forward Fit Determination RG 1.183 RG 1.183 Rev.0 Rev.1 (2000) (TBD)
SANDIA SANDIA Report Retire Rev.0 Report (2011) (2023)
Staff Actions:
Alternatively, issue Rev.01 without changes to - Risk and Safety Significance MHA releases to avoid further delays and - Need for immediate action?
provide time for Backfit and Forward Fit - Backfit Determination documentation Regulatory Uncertainty Associated with RG 1.183 28 Integrated Nuclear Solutions LLC
NEI Position for RG 1 .183 FC ACRS meeting:
Regulatory uncertainty surrounding the radiological source terms in RG 1.183 is a major hurdle for early adoption of ATF features. This issue needs the regulatory stability and predictability offered through RGs. Issuing RG 1.183 R1/2 is CRITICAL path to the widespread adoption of ATF/LEU+/HBU fuels in a cost-effective manner.
We recognize that this revision has been in development for over 15 years; and the NRC will soon issue RG 1.183 Rev. 1 based on SAND2011-0128. The industry supports many aspects of the proposed revision which provide updates in the understanding of accident modeling and/or relaxing constraints on inputs. These include 1) the updated model for the fuel handling accident which demonstrates that this accident actually results in much lower doses and can allow for earlier fuel movement during outages, 2) non-LOCA gap fractions which are not constrained to the burnup and linear power limits which were defined in Revision 0, and 3) a more realistic consideration of the post-accident integrity of the BWR steam line and condenser which provides a simpler approach to this credit for those BWRs that have not yet adopted it.
Other changes in RG 1.183 Revision 1 are more problematic for the industry such as the large increase in halogen releases for BWRs. These higher release fractions may require plant modifications, offsetting the benefits of ATF designs in BWRs. While many plants may struggle to meet these release fractions, the latest research in SAND2023-01313 (ML23097A087), performed for even higher burnups and increased enrichments, indicates that release fractions are only going higher in RG 1.183 Revision 2.
Further, the SANDIA reports show that burnup and enrichment do not significantly influence the release fractions and therefore do not increase the safety consequences of transitioning to higher burnups.
Increases in release fractions are based on changes to the MELCOR code.
Therefore, while industry supports the near-term issuance of RG 1.183 Revision 1, we want to be sure the need for an expeditious Revision 2 is also acknowledged. It is imperative that Revision 2 addresses some key issues identified in the latest SANDIA report to support BWR implementation. Results of the updated in-containment source term analysis documented in SAND2023-01313 (ML23097A087),
indicate that suppression pool scrubbing is prevalent in the BWR severe accident progression and that it significantly decreases the non-noble gas airborne activity because the vast majority of the activity would be released into the suppression pool. This phenomenon, inherent to the BWR severe accident progression, needs to be incorporated in the RG 1.183 guidance either by the release fractions directly or by including an acceptable method to account for it downstream from the release fractions. Also, where appropriate, multiple layers of conservatism in assumptions need to be removed from the guidance. For example, acceptable methods for calculating aerosol deposition introduced in the proposed Revision 1 do not allow credit for main steam line deposition along with credit for calculating aerosol removal from drywell sprays. Multiple BWRs currently have credit for aerosol removal from drywell sprays as well as aerosol deposition within the main steam lines in their licensing basis. In addition, credit for aerosol impaction in the BWR MSIV leakage path should be generically approved as currently applied in some BWRs. Considering the number of BWRs currently modeling these removal mechanisms, RG 1.183 R2 should include guidance for crediting these important, mitigative features.
Without additional changes to RG 1.183, many BWR and PWR plants may not be able to implement HBU and IE due to higher source terms resulting from the updated in-containment source term analysis for High Burnup/High-Assay Low Enriched Uranium fuel (HBU/HALEU) documented in SAND2023-01313
(ML23097A087). The sequence of events considered in SAND2023-01313 have not changed since the Individual Plant Examinations (IPEs) documented in NUREG-1560 (1996) and ignore improvements in plant safety, such as B5B and FLEX implementations and updated risk insights over the last 30 years because of Fukushima learnings and risk-informed applications. The disconnect between reality and the regulation, and the disconnect between different regulatory requirements within the applicable guidance documents, lead to the incorrect determination of significant risk contributors that overly estimate conservative source terms. As a result, industrys effectiveness is severely challenged when trying to enable changes such as HBU and IE.
We also want to acknowledge the significant amount of time industry spent to provide detailed comments on this DG and that we were not provided the staff responses to our comments with enough time prior to this committee meeting for our review and understanding (provided only three days prior to this ACRS meeting). Also, attempts at collaboration during the revision process proved ineffective, resulting in no significant changes or effective engagement to resolve issues identified by the industry.
Going forward, the industry remains ready and willing to collaborate more closely with the NRC in the development of future revisions to this regulatory guide, such that it is useful and can be readily implemented to reach anticipated future operating goals. Durable guidance is needed today to facilitate the widespread implementation of ATF/LEU+/HBU and we expect early and frequent engagement with the NRC to accomplish this.