ML24303A230
| ML24303A230 | |
| Person / Time | |
|---|---|
| Issue date: | 10/02/2024 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-0053 | |
| Download: ML24303A230 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards 719th Full Committee Meeting Docket Number:
(n/a)
Location:
teleconference Date:
Wednesday, October 2, 2024 Work Order No.:
NRC-0053 Pages 1-23 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
1 2
3 DISCLAIMER 4
5 6
UNITED STATES NUCLEAR REGULATORY COMMISSIONS 7
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8
9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23
1 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 719TH MEETING 4
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5
(ACRS) 6
+ + + + +
7 WEDNESDAY 8
OCTOBER 2, 2024 9
+ + + + +
10 The Advisory Committee met via 11 Videoconference, at 8:30 a.m. EDT, Walter Kirchner, 12 Chairman, presiding.
13 COMMITTEE MEMBERS:
14 WALTER L. KIRCHNER, Chairman 15 GREGORY H. HALNON, Vice Chairman 16 DAVID A. PETTI, Member-at-Large 17 RONALD G. BALLINGER, Member 18 VICKI M. BIER, Member 19 VESNA B. DIMITRIJEVIC, Member*
20 CRAIG D. HARRINGTON, Member 21 ROBERT P. MARTIN, Member 22 SCOTT P. PALMTAG, Member 23 THOMAS E. ROBERTS, Member 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
2 ACRS CONSULTANT:
1 DENNIS BLEY 2
4 DESIGNATED FEDERAL OFFICIAL:
7 ALSO PRESENT:
8 SCOTT MOORE, Executive Director 9
10
- Present via telephone 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
3 CONTENTS 1
Opening Remarks by the ACRS Chairman 2
1.1) Opening statement 4
3 1.2) Agenda and items of current interest.
6 4
5 Topical Report PWROG-18068, Use of Direct Fracture 6
Toughness for Evaluation of RPV [Reactor Pressure 7
Vessel] Integrity 8
2.1) Remarks from the Subcommittee Chair 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
4 P-R-O-C-E-E-D-I-N-G-S 1
8:30 a.m.
2 CHAIR KIRCHNER: Okay, the meeting will 3
now come to order.
4 This is the first day of the 719th meeting 5
of the Advisory Committee on Reactor Safeguards, ACRS.
6 I am Walt Kirchner, Chair of the ACRS. ACRS members 7
in attendance in person are Ron Ballinger, Vicki Bier, 8
Greg Halnon, Craig Harrington, Robert Martin, Scott 9
Palmtag, Dave Petti, and Thomas Roberts. ACRS members 10 in attendance virtually via Teams are -- is Vesna 11 Dimitrijevic. If I've missed anyone, either ACRS 12 members, please -- any ACRS members, please speak up 13 at this point. Looking to see if we have our -- if 14 any of our consultants online. I see Dennis Bley and 15 Steve Schultz are with us. Thank you.
16 The ACRS -- excuse me. Christopher Brown 17 of the ACRS staff is the Designated Federal Officer 18 for this mornings full committee meeting. No Member 19 conflicts of interest were identified for todays 20 meeting. And I note we have a quorum, as well.
21 The ACRS was established by statute and is 22 governed by the Federal Advisory Committee Act, FACA.
23 The NRC implements FACA in accordance with its 24 regulations.
Per these regulations and the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
5 Committees Bylaws, the ACRS speaks only through its 1
published letter reports.
2 Therefore, all Member comments should be 3
regarded as only the individual opinion of that 4
Member, and not a Committee position. All relevant 5
information related to ACRS activities, such as 6
- letters, rules for meeting participation and 7
transcripts are located on the NRC public website and 8
can be easily found by typing, about us ACRS, in the 9
search field on NRCs home page.
10 The ACRS, consistent with the Agencys 11 value of public transparency in regulation of nuclear 12 facilities, provides opportunity for public input and 13 comment during our proceedings. We have received no 14 written statements or requests to make an oral 15 statement from the public. Written statements may be 16 forwarded to todays Designated Federal Officer. We 17 have also set aside time at the end of this meeting 18 for public comments.
19 A transcript of the meeting is being kept 20 and will be posted on our website. When addressing 21 the Committee, the participants should first identify 22 themselves and speak with sufficient clarity and 23 volume so that they may be readily heard. If you are 24 not speaking, please mute your computer on Teams. If 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
6 you are participating by phone, press star-six to mute 1
your phone and star-five to raise your hand on Teams.
2 The Teams chat feature will not be 3
available for use during this meeting. For everyone 4
in the room, please put your -- all your electronic 5
devices in silent mode, and mute your laptop 6
microphone and speakers. In addition, please keep 7
sidebar discussions in the room to a minimum since the 8
ceiling microphones are live.
9 For presenters, the table microphones are 10 uni-directional, and youll need to speak into the 11 front of the microphone to be heard online. Finally, 12 if you have any feedback for the ACRS about todays 13 meeting, we encourage you to fill out the public 14 meeting feedback form on the NRCs website.
15 During todays meeting, the Committee will 16 consider two topics. In the morning session we will 17 discuss the Topical Report PWROG-18068, Use of Direct 18 Fracture Toughness for Evaluation of Reactor Pressure 19 Vessel Integrity. And in the afternoon session, which 20 will begin at 1:00 p.m., we will have our Planning and 21 Procedures Session.
22 Tomorrow morning the Committee will 23 receive an information briefing on the Palisades 24 Nuclear Plant restart, and further information in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
7 tomorrow morning's introductory comments.
1 And with that, I will now turn to the --
2 the Committees deliberations over to the Fuels, 3
Materials and Structures Subcommittee Chair, Ron 4
Ballinger. Ron?
5 MEMBER BALLINGER: Thank you --
6 VICE CHAIR HALNON: Before we get started, 7
the court reporter may not be familiar with the 8
Members here in the room. So, at least for a few 9
times, make your name clear when you talk, and then I 10 think they'll get, eventually, familiar with who's in 11 the room. James is not on -- not as familiar with us 12 as James is.
13 CHAIR KIRCHNER: Yeah, so again, just to 14 reiterate Greg's comment, just introduce yourself when 15 you first speak, so --
16 VICE CHAIR HALNON: Which I failed to do 17 when I spoke.
18 CHAIR KIRCHNER: That was Vice Chairman 19 Greg Halnon.
20 (Laughter.)
21 MR. MOORE: Chair Kirchner --
22 (Simultaneous speaking.)
23 CHAIR KIRCHNER: Thank you Greg, though, 24 for the reminder. And I'm remiss, Members, any 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
8 opening comments or other -- our Executive Director 1
Scott Moore has a comment. Go ahead, Scott.
2 MR. MOORE: Thank you, Chair Kirchner.
3 So, one of the things that the Committee will have to 4
decide is when they want the court reporter to stop 5
recording, because you're going into deliberation.
6 CHAIR KIRCHNER: Okay, thank you. And 7
with that, now we turn to Member Ballinger. Ron?
8 MEMBER BALLINGER:
Thank
- you, Mr.
9 Chairman. I guess, during the previous Subcommittee 10 meeting we had a presentation related to the PWROG 11 Topical Report. And at that Subcommittee meeting we 12 decided that we would not invite the applicant or the 13 staff to come and give any further presentation on the 14 topic, but that we would produce what amounts to a 15 draft letter on the topical report. And that's what 16 I've done.
17 And I think I've incorporated comments or 18 suggestions from Members that provided them. And so, 19 what we have today is a draft letter which I would 20 propose that we just read in and then go from there.
21 I'm not sure what the best path forward is with 22 respect to reading in, waiting for comments, line-by-23 line. I'm not sure what the best way is to go 24 CHAIR KIRCHNER: I think your proposal is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
9 good. When I -- Sandra is ready, let's go ahead and 1
put the letter up, and I'll ask you to read the letter 2
into the record. And then, with the advice of our 3
Executive Director, we can make a decision on when we 4
do not need further services of the court reporter --
5 (Simultaneous speaking.)
6 MEMBER BALLINGER: I might also add that 7
we haven't actually decided to write a letter, we've 8
asked the Committee's -- well, it's the Committee's 9
choice. So, I guess it's after we read in, we see 10 what happens.
11 Okay.
Dear Chair Hanson,
during the 719th 12 meeting of the Advisory Committee on Reactor 13 Safeguards October 2-through-4, 2024, we completed our 14 review of Topical Report PWROG-18068-NP Revision One, 15 Use of Direct Fracture Toughness for Evaluation of 16 Reactor Pressure Vessel Integrity and the Associated 17 Safety Evaluation, SE.
18 Our
- Fuels, Materials and Structure 19 Subcommittee reviewed this matter on September 20, 20 2024. During these meetings, we've had the benefit of 21 discussions with the NRC -- with NRC staff and 22 representatives from the Pressurized Water Reactor 23 Owners Group -- whoops, PWROG. We also had the 24 benefit of reference documents.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
10 Inclusions and recommendations. The use 1
of direct fracture toughness data proposed in PWROG-2 18068-NP represents a significant advancement in the 3
methods for estimating reactor pressure vessel, RPV, 4
embrittlement.
5 The methodology proposed -- Two, the 6
methodology proposed in PWROG, I'll just abbreviate it 7
from now on, provides for more consistency of 8
prediction as well as reduced uncertainty, especially 9
at subsequent license renewal fluences.
10 Three, the methodology proposed in PWROG 11 will allow more accurate pressurized thermal shock, 12 PTS, and pressure-temperature, P-T, limit curve 13 determination. The SE should be issued.
14 Background. The fracture toughness of the 15 RPV steel provides a key input to calculations that 16 commercial licensees perform to demonstrate the 17 integrity of the vessel during both normal operation 18 and postulated accident conditions, e.g. PTS.
19 Currently the American Society of 20 Mechanical Engineers K1C and K1R curves indexed to the 21 reference temperature for nil-ductility transition, 22 RTNDT, of the unirradiated material describe the 23 toughness of the RPV materials and their variance with 24 temperature. These curves were adopted in 1972 as a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
11 lower bound representation to a set of 173 toughness 1
values derived from Charpy data. These data have been 2
incorporated into the Regulatory Guide, RG 1.99 3
Revision Two.
RPV irradiation embrittlement 4
prediction methodology -- a bunch in parenthesis.
5 The use of RTNDT to normalize temperature 6
was designed to account for heat-to-heat differences 7
in the ductile-brittle transition temperature thereby 8
collapsing the fractured toughness data onto a single 9
curve. However, this Charpy-based fracture toughness 10 correlation approach is broadly conservative which 11 propagates forward in the development of PTS limits, 12 10 CFR 50.61, as well as the development of P-T limit 13 curves, 10 CFR 50 Appendix G, for operation.
14 Since the development of the correlation 15 in Reg Guide 1.99, database for RPV embrittlement has 16 been greatly expanded with 1,878 data points added to 17 the database. This data has been employed in the 18 development of an updated embrittlement correlation 19 codified in American Society for Testing and 20 Materials,
- ASTM, E900-15, Standard Guide for 21 Predicting Radiation-Induced Transition Temperature 22 Shift in Reactor Vessel Materials.
23 Analysis of this more extensive data set 24 has shown that the current approach, RTNDT plus 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
12 embrittlement shift prediction plus margin, is not the 1
best fracture metric. Data analysis has shown that 2
the actual margin for any given material is generally 3
unknown and inconsistent but is substantial, and the 4
RG 1.99 prediction contains considerable uncertainty.
5 The staff has proposed a path forward to 6
update the PV embrittlement process in SECY-22-0019 7
rulemaking plan for a
revision of operation 8
embrittlement and surveillance requirements for high-9 fluence plants in long term. Options two and three in 10 SECY-22-0019 would allow the use of E900-15 to 11 estimate the degree of PV embrittlement.
12 The Committee has endorsed the use of 13 option two in an April 28, 2022 letter rulemaking plan 14 for the revision of embrittlement and surveillance 15 requirements for high-fluence nuclear power plants and 16 long-term operation.
17 In addition to the above issues, the 18 current PWR fleet license life of 40 years is now 19 being exceeded, or will be exceeded, for most plants, 20 with some units now approved for life extension to 80 21 years.
22 It has been shown that the deviation in 23 the predicted versus measured temperature shift, when 24 applying the correlation in Reg Guide 1.99 become 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
13 significantly negative, implying reduced margin at 1
fluences greater than approximately 3E times 10 to the 2
- 19. Several current PWRs are predicted to exceed this 3
value during SLR.
4 The methodology proposed in PWROG will 5
provide a method to address the limitations described 6
above. The methodology also makes use of the vastly 7
increased RPV embrittlement database. Note I used the 8
word vastly.
9 Discussion. PWROG proposes a methodology 10 that justifies the use of direct fracture toughness 11 data to evaluate RPV integrity as an alternative to 12 the requirements of PTS and P-T limit curves.
13 Specifically, the Topical Report presents a
14 methodology to generate a ductile-brittle transition 15 reference temperature, T0, adjust the data for 16 differences between tested material and RPV component 17 of interest master curve approach, account for at 18 least result -- for test result uncertainty and 19 material variability in the respective RPV component 20 and to apply the data using the ASME Section XI Code.
21 The approach represents a departure from 22 the approach used in the current methods required for 23 the PTS rule and the development of the P-T limit 24 curve. Current approaches make use of an -- of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
14 empirical embrittlement correlations, Reg Guide 1.99, 1
that are based on Charpy data correlated with material 2
toughness from the PWROG.
3 And then there's now a transition.
4 Transitioning from the current -- this is from their 5
report. Transition from the current unirradiated 6
reference temperature for nil-ductility transition and 7
the predicted embrittlement shift approach for RPV 8
integrity evaluations, to a direct fracture toughness 9
approach, is expected to benefit RPV operation for 10 license renewal and subsequent license renewal by 11 reducing uncertainties.
12 The available irradiated master curve data 13 show, in many cases, that substantial conservatism 14 exists due to uncertainties in the current approach.
15 Thus, application of irradiated master curve data as 16 an alternative to 10 CFR 50.61 and 10 CFR 50 Appendix 17 G RPV evaluations is expected to show a margin -- to 18 show margin in these analyses. Establishing a robust 19 fracture toughness basis will ensure public health and 20 safety by reducing uncertainty and enabling a 21 statistical understanding of the actual irradiated RPV 22 fracture toughness.
23 The approach taken in the proposed 24 methodology uses NRC-approved methodologies in ASME 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
15 Section XI Appendix G Subsection G-2010 RTT0 and the 1
NRC-endorsed Code Case N-830-1. Direct use of 2
fractured toughness for flaw evaluations of pressure 3
bounded materials in class one ferritic steel 4
components.
5 The methodology used is the industry 6
consensus ASTM E1921 standard test method for 7
determination of reference temperature, T0, for 8
ferritic steels in the transition range and the ASTM 9
E900-15 standard guide for predicting embrittlement, 10 and ensures uncertainties are properly addressed and 11 appropriately bounding.
12 The proposed approach in PWROG represents 13 a significant improvement in estimation of the extent 14 of embrittlement since it makes use of actual 15 toughness data as opposed to empirical correlations, 16 and thus will allow for both a reduction in, and 17 better characterization of, uncertainties.
18 Benefits will likely include improved PTS 19 evaluations for license renewal, power uprates and 20 other operational
- changes, and extend the 21 applicability or improve the operating margin for 22 heat-up/cool-down P-T limit curves in 10 CFR 50 23 Appendix G.
24 Summary. Use of direct fracture toughness 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
16 proposed in PWROG-18068-NP represents a significant 1
advancement in the method for estimating PV 2
embrittlement. Methodology proposed in PWROG provides 3
for more consistency in prediction as well as reduced 4
uncertainty, especially at SLR fluences. The 5
methodology proposed in PWROG will allow more accurate 6
PTS and P-T limit curve determination.
7 The SE should be issued. We are not 8
requesting a formal response from the staff to this 9
letter. Sincerely, Walt Kirchner.
10 I might add that the staff has not asked 11 for a letter. In their presentation, they explicitly 12 said that --
13 CHAIR KIRCHNER: So, for anyone listening, 14 we had this letter evolved from a Subcommittee meeting 15 held on September 20. One can go to that and see the 16 presentations that were made, and also there's a 17 transcript at that meeting which had a majority of the 18 Committee in attendance. We decided that we would 19 write a letter and -- so, thank you for the letter, 20 Ron.
21 And at this point, high level comments 22 from any of the Members?
23 MEMBER BIER: With comments. First of all, 24 Ron, that was very clear. I understand it better than 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
17 I did before, so that's good.
1 MEMBER BALLINGER: Thank you for the input 2
from the other Members, by the way. They're the ones 3
that made it clearer --
4 (Simultaneous speaking.)
5 CHAIR KIRCHNER: By clearer --
6 MEMBER BALLINGER: Other Members made it 7
-- were the ones that made it clearer.
8 (Simultaneous speaking.)
9 MEMBER BIER: Oh, okay. Anyway, I thought 10 it was a good letter. And I'm somewhat leaning to, 11 that yes, we should go ahead and write the letter just 12 because of the importance of the issue and, again, to 13 kind of, you know, make it clear to the public that 14 yes, we think this is okay. But I don't feel strongly 15 about that.
16 CHAIR KIRCHNER: Any other comments? Go 17 ahead, Tom.
18 MEMBER ROBERTS: When we come off the 19 transcript now? When should we come off the 20 transcript, just now or should we have a high level 21 comment?
22 CHAIR KIRCHNER: Why don't we have our 23 discussion, and then we will go off the transcript 24 when we actually do line-by-line.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
18 MEMBER ROBERTS: Okay, high level. I 1
agree with what Vicki just said, I think this is a 2
very well-written letter and it, you know, clarified 3
the issues for me. Where it leaves me, the first time 4
I read the letter and then hearing it read now, I'm 5
still a little bit confused as to what we're 6
communicating beyond what we communicated in 2022.
7 In 2022 we communicated that we agree with 8
option two of the rulemaking, which essentially uses 9
the fracture toughness methods at more of a high 10 level, you know, go use that method instead of the 11 existing Reg Guide. And then this is the, I think, 12 the next step in saying okay, this is how you would do 13 it.
14 And so, if that's really what we're 15 saying, maybe there's some, you know, clean-up in the 16 language a little bit to kind of connect those dots a 17 little better. But if this is basically us saying 18 that, yeah, we've now convinced ourselves that there 19 is a method and the details are now filled in, so it's 20 even more support for option two of the rulemaking, 21 that might be a good way to paint this. I mean, 22 because -- make sure, if I understood that.
23 MEMBER BALLINGER: A couple of comments on 24 that. That white paper that was -- the SECY that was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
19 sent to the Commission, which we reviewed, has not 1
been acted on by the Commission. And Reg Guide 1.99, 2
which would be basically revised as a result of that 3
SECY, has not been done, and we would see that. And 4
so, that's why that stuff is in there.
5 The importance, for me, is the use of 6
direct fracture toughness data, which is a departure, 7
a significant departure and a welcomed one, at least 8
in my personal opinion. And, it being the first time 9
it's being used in a formal sense, we're going to see 10 the words fracture toughness going forward with ALS 11 and everything else continually from now on. So I 12 think that that's, you know.
13 And also, there are a few plants -- I 14 still have not been able to find that table. Gosh.
15 Anyway, there was a table that was produced by one of 16 the staff members, I think it was Mark Kirk, who 17 identified which plants would likely be an issue at 18 SLR. And this helps them out a lot. Not the least of 19 which is probably Palisades.
20 VICE CHAIR HALNON: I have a comment too, 21 Walt. This is Greg. Kind of building what Ron -- I 22 was thinking the same thing. We're sort of building 23 a mosaic of high fluence operations in SLR, and this 24 is a piece of that mosaic that I think that it would 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
20 be important to have on the record as a letter so 1
that, as we walk through this, we can say here's the 2
five, four, whatever amount of reports that we've made 3
on high fluence operations, and this is a piece of 4
that. So I think it's a good thing to document, to 5
make sure it's clear, and to go forward with building 6
that picture that we're building in the future.
7 MEMBER BALLINGER: And I say this with a 8
bit -- a bit tongue-in-cheek, the white paper that 9
went to the Commission identified this issue as, of 10 high priority, and that was two-and-a-half years ago.
11 So I wonder what happens if something is not 12 identified as high priority. And so this letter would 13 probably reinforce the importance of getting this 14 done.
15 VICE CHAIR HALNON: Do you --
16 MEMBER BALLINGER: I mean, I'll bet you --
17 VICE CHAIR HALNON: Should we say that in 18 the letter?
19 MEMBER BALLINGER: Probably shouldn't.
20 (Laughter.)
21 MEMBER BALLINGER: I probably shouldn't.
22 But, you know, what we'll -- the tripwire for applying 23 this will be the first plant that exceeds the 24 screening criteria at SLR. And that's -- those guys, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
21 for those Members that don't know what that is, the 1
welds and plates, there have to -- the licensees have 2
to do a projection to end-of-life on whether they will 3
exceed the transition temperature limits, which is 300 4
degrees for plate and I think 270 for welds, I don't 5
know for sure. And if that happens, they have to back 6
adjust their plant so that they don't exceed those 7
criteria at the end-of-life.
8 So I'm guessing that we'll have a few 9
plants that will exceed that -- will exceed the 10 screening criteria. Although they won't -- they 11 technically haven't yet.
12 And there's also the issue of the Reg 13 Guide 1.99, that white paper, where applicants have 14 been adjusting their removal of capsules to do 15 toughness measurements because, when the plant was 16 built, they had X capsules in place with a 40-year 17 licensed life and now they're out to 60 or 80 years, 18 and so they're having to do gymnastics, if you will, 19 to get capsules that allow them to do the prediction 20 to the end-of-life, so.
21 That's not part of this but it's part of 22 that white paper, and that's why pushing this a little 23 bit would be helpful, I think.
24 PARTICIPANT: So, adding to what Ron said, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
22 direct fracture toughness is not what the subject of 1
the '22 SECY was?
2 MEMBER BALLINGER: No.
3 PARTICIPANT: Okay, so E900, the ASTM 4
standard, that has nothing to do with direct fracture 5
toughness? Okay, thank you.
6 (Simultaneous speaking.)
7 MEMBER BALLINGER: That's -- I tried -- I 8
took your comment and I tried to change the words a 9
little bit, hopefully I've done a little bit better 10 job at addressing what you said.
11 PARTICIPANT: Okay, thanks. So it's --
12 basically it's putting quite a bit more meat on the 13 bones of the '22 SECY approach.
14 MEMBER BALLINGER: Yeah.
15 PARTICIPANT: That seems to make sense.
16 CHAIR KIRCHNER: Okay, further comment?
17 Then I believe at this juncture we can 18 release the court reporter -- or, hold on one minute 19 20 MR. MOORE: So Chairman, you may want to 21
-- we're in a full Committee meeting, you may want to 22 take public comments before --
23 (Simultaneous speaking.)
24 CHAIR KIRCHNER: Okay, thank you for the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234-4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com
23 reminder. Yes, okay. So if we have any participants 1
from the public who wish to make a comment, please 2
raise your hands so we can see you.
3 Not seeing any hands raised right now on 4
our screens. If anyone would like to make a comment, 5
just unmute your mic, identify yourself, affiliation 6
as appropriate, and state your comment.
7 Hearing none. So now, at this juncture we 8
can release the court reporter. Thank you for your 9
service this morning.
10 (Whereupon, the above-entitled matter went 11 off the record at 8:57 a.m.)
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
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www.nealrgross.com C E R T I F I C A T E This is to certify that the foregoing transcript In the matter of:
Before:
Date:
Place:
was duly recorded and accurately transcribed under my direction; further, that said transcript is a true and accurate DPNQMFUFrecord of the proceedings.
Court Reporter 25 Advisory Committee on Reactor Safeguards NRC 10-02-24 teleconference