ML111390571

Transcript of Briefing on the Status of NRC Response to Events in Japan and Briefing on Station Blackout

ML111390571
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Site:	Pilgrim
Issue date:	04/28/2011
From:	Apostolakis G, Jaczko G, Magwood W, Ostendorff W, Kristine Svinicki NRC/Chairman, NRC/OCM
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SECY RAS
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UNITED STATES OF AMERICA U.S. NUCLEAR REGULATORY COMMISSION BRIEFING ON THE STATUS OF NRC RESPONSE TO EVENTS IN JAPAN AND BRIEFING ON STATION BLACKOUT APRIL 28, 2011 9:30 A.M.

TRANSCRIPT OF PROCEEDINGS Public Meeting Before the U.S. Nuclear Regulatory Commission:

Gregory B. Jaczko, Chairman Kristine L. Svinicki, Commissioner George Apostolakis, Commissioner William D. Magwood, IV, Commissioner William C. Ostendorff, Commissioner

2 APPEARANCES NRC Staff Panel:

Bill Borchardt Executive Director for Operations Pat Hiland Director, Division of Engineering, NRR George Wilson Chief of Instrumentation and Control Branch, Division of Engineering, Office of Nuclear Reactor Regulation Eric Bowman Senior Project Manager, Division of Policy and Rulemaking, Office of Nuclear Reactor Regulation

3 1 PROCEEDINGS 2 CHAIRMAN JACZKO: Good morning, everyone. Before we begin 3 today's meeting, I wanted to recognize that this is National Administrative 4 Professionals Week and take this opportunity to acknowledge the dedicated 5 efforts and the high-quality performance of our agency's administrative 6 professionals. It's always, I think, a great opportunity during this week to make 7 sure we highlight the work that those people do every day to allow us to do our 8 jobs and to keep everything working and functioning. This is also a very special 9 day at the NRC. This is Bring Your Children to Work Day here at headquarters, 10 so there'll be lots of people, our future work force, running around, learning the 11 business, I think, at the agency.

12 With that, I'll turn to the agenda for today's briefing. The 13 Commission meets this morning to receive a brief update on the situation in 14 Japan and the NRC's ongoing efforts there to assist the Japanese government, 15 but then the remainder of todays meeting will focus on the NRC station blackout 16 rule, which is our regulatory approach for ensuring that licensees can effectively 17 cope with a loss of alternating current electrical power. And, I think, certainly this 18 is a situation that has relevance, as our task force looks at the situation in Japan, 19 but we also have seen that this is a rule that has relevance here for us in the 20 United States. Severe storms in the south last night provided a reminder of this.

21 One or more nuclear power plants experienced a loss of nearly all their off-site 22 power, leading to shutdowns of those plants. All of the safety systems performed 23 as they were designed and all available diesel generators started and loaded.

24 And, ultimately, the core cooling systems are operating normally. In addition, the 25 spent fuel cooling is currently in service. So, all these plants are stable and

4 1 they're being placed in a cooled-down condition.

2 Of course, these storms are also a reminder that these storms have 3 tremendous impact, and there have been many people who have lost their lives 4 as a result of this, so we always want to remember that as we talk about these 5 issues. But it was certainly a reminder of the importance of this particular rule 6 and dealing with the potential that not all of the alternating power capabilities 7 function.

8 So, today, the staff will give us a general background on the rules 9 development as well as more detailed information on the structure of our 10 regulatory approach for dealing with station blackout. And this is one of the 11 many significant issues that the agency's senior level task force is examining as 12 part of our comprehensive review of the safety of the U.S. nuclear facilities as a 13 result of the situation in Japan. And, certainly, from my perspective, I think the 14 purpose for us today is to get a good base line of information for the Commission 15 to get us all at the same level of knowledge about this rule, so that if we get 16 recommendations from the task force in this area, we'll be able to move 17 expeditiously and promptly to address those, and we'll have a good 18 understanding of the basis of the existing rule, and then, if there are changes to 19 be made, what those changes would be and how we would effectively and 20 expeditiously move forward with those recommendations. With that, I would offer 21 any colleagues, my colleagues to make any comments that they would like.

22 Commissioner Svinicki.

23 COMMISSIONER SVINICKI: Thank you, Mr. Chairman. First of 24 all, I appreciate your recognition of the hard-working administrative professionals 25 here at NRC who make possible all of the important work that we do here. And I

5 1 also would add, that, although, as you've indicated, we're still working to gain 2 knowledge of the events in Japan, station blackout certainly identifies itself as an 3 important issue that we need to be looking at, so thank you for today's meeting.

4 CHAIRMAN JACZKO: Okay, Bill. I'll turn it to you.

5 MR. BORCHARDT: Well thank you, good morning, what Ill do is 6 begin todays briefing with just a very brief overview of the situation in Japan.

7 Since March 21, when we held the last Commission meeting, on the Japan issue, 8 I would say that the situation has definitely improved but were still in the accident 9 mitigation phase. Off site and on-site AC power has been restored, however 10 theyre still using temporary pumps and hoses to inject water into the reactor 11 vessels and spent fuel pool, and into the containments. Theres still many 12 unanswered questions regarding the status of various pieces of equipment, the 13 reactor vessel integrity, the spent fuel pool.

14 Regarding the core, the reactor vessel, and the containment, as 15 well as the spent fuel conditions, I would describe the situation as not being quite 16 stable, but certainly not as highly dynamic as it was on March 21 when we last 17 met on this subject. The changes that are occurring within the plant are slower 18 and allowing more time for the Japanese operators and regulators to respond 19 and take corrective actions, as necessary.

20 There's still feed and bleed operations in progress. That is a 21 somewhat dynamic situation, as well as there's unfiltered and unmonitored 22 release paths that remain to be a concern at the Fukushima site. One of the 23 things that make this difficult for the Japanese in responding to this event and for 24 to us to understand the exact situation is that there's a number of suspect 25 accuracy and failed instrumentation at the site, affecting all of the units that really

6 1 hamper our ability to get a clear and consistent picture of the situation.

2 As you know, the site team in Japan continues. We're providing 3 technical support to the ambassador. We're interacting with the Japanese 4 officials of NISA, our regulatory counterpart, and the operator TEPCO. And the 5 team in Japan is also coordinating the efforts of the consortium of private 6 companies as well as non-government organizations as they work with the 7 government of Japan. Our operation center remains on a 24/7 response 8 capability. We're providing direct support to the site team as well as coordinating 9 all of the related headquarters activities by the technical staff.

10 One of the major developments over the last month has been the 11 creation and development of TEPCO's recovery plan, which is called a road map 12 towards restoration from the accident at Fukushima Power Station. There is a 13 number of elements in this road map, and it focuses on nitrogen injection that will 14 help minimize the potential for future hydrogen detonations, flooding of 15 containment to cool the core, working on process to provide reliable spent fuel 16 pool makeup to achieve long-term cooling. They'll also work on the Unit 4 17 structural integrity of the spent fuel pool, looking at ways of providing waste 18 storage and processing as well as controlling radioactive material on-site and off-19 site. And then, finally, to address the issue that I mentioned earlier, enhanced 20 monitoring of off-site conditions at the plant. So, our overall assessment is that 21 the Japanese are making progress on addressing the safety and the 22 environmental issues and that the road map that's been put into place is certainly 23 a good start towards long-term restoration.

24 Moving into today's Commission meeting. Obviously, the 25 earthquake and then the following tsunami resulted in a station blackout at the

7 1 site, which greatly complicated and contributed to the serious events in Japan.

2 Today's briefing's going to be a technical background about the conditions in the 3 U.S. plants, both the regulatory background and what processes and equipment 4 exists in the plants. As I mentioned, on March 21, we did, what I would say, was 5 an instant review of the situation and of the capabilities of U.S. facilities and 6 concluded that there was no need to make immediate changes or to impose 7 immediate orders on U.S. licensees. However, we have well underway the short-8 term, or 90 day review, that is looking at station blackout and a number of other 9 issues, out of which may result in some future regulatory action or some 10 requirement on licensees.

11 Following that 90 day review, there's going to be a longer-term 12 review that will continue to use all of the technical information available from 13 Japan in order to inform our regulatory approach moving forward. Very recently, 14 we've issued a temporary instruction to our inspections staff that has been 15 performed to evaluate the compliance with the existing regulations, and those 16 results are being provided to the headquarters staff for analysis now.

17 We'll be hearing from three speakers today. The first is going to be 18 Pat Hiland, who's going to provide an overview of the NRC station blackout rule, 19 as well as the advanced accident mitigation strategies implemented at U.S.

20 plants. George Wilson is going to discuss, in detail, the station blackout rule 21 requirements and guidance, and the preparedness of U.S. power plants to cope 22 and recover from a station blackout. And then, finally, Eric Bowman will discuss 23 the mitigating strategy requirements imposed following the terrorist attacks of 24 September 11, 2001. So I'll now turn the briefing over to Pat.

25 MR. HILAND: Thank you, Bill. Good morning Commissioners,

8 1 Chairman, and go to slide two, please, station blackout background. Looking 2 back over 35 years ago, the WASH-1400 document was issued. And that 3 document clearly stated that station blackout could be an important contributor to 4 the risk of nuclear power plant accidents. In particular, it concluded that if a 5 station blackout were to persist, it could lead to a core melt and containment 6 failure. In 1980, the Commission designated the issue of station blackout as an 7 unresolved safety issue, A-44. Additional regulatory requirements were imposed 8 in 1988, when 10 CFR 50.63 was issued. It's known as the SBO rule, that rule 9 requires each plant to be able to cope and recover from a station blackout event, 10 specifically to assure that the core is cooled and that the containment integrity is 11 maintained.

12 When the station blackout rule was issued, coincident with that was 13 a Regulatory Guide 1.55 that was released. That regulatory guide endorsed an 14 industry standard, 8700, providing guidance in how to implement the rule. All of 15 the operating fleet, all 104 plants today, met the station blackout rule at the time 16 based on a detailed review of each applicant's submittal of how they complied 17 with the rule, as well as, we conducted two on-site inspections in each of the 18 regions, for a total of eight, to provide us confidence that the rule was being 19 properly implemented.

20 After that time period, under the reactor oversight program, we 21 have our Component Design Basis Inspection, or CDBI inspection, that 22 continually looks at those components that may be involved in the station 23 blackout mitigation strategies, as well as there are other inspection modules for 24 our regional inspectors and our site resident inspectors, such as the corrective 25 action inspection program, a plant modification inspection module, as well as an

9 1 equipment alignment module. All of those items might touch on the station 2 blackout. Feedback from the regions and from the inspections to date indicates 3 that the component design basis inspections are pinpointing some of the SBO 4 activities that we see in the field.

5 Regarding license renewal activities, the evaluation for renewing 6 license has a specific requirement, and they're 10 CFR 54 for a review of the 7 station blackout aging and components required, the safety systems and 8 structures required for the SBO must be included in their aging management 9 process.

10 Regarding new reactors, now, all new standard, that's a word I 11 used in this slide, standard meaning that's not a passive new reactor, because 12 the second bullet would tell you that's not all plants, but all new standard reactors 13 are required to have an alternate AC power source. Its a diverse source, 14 meaning that it must be different than the installed emergency or standby diesel 15 generators. For new reactors with a passive design, that's an AP1000 has a 16 passive design, its design includes a battery-power coping strategy of up to 72 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.

18 As you're aware, we responded to the September 11, 2001 terrorist 19 attack through a number of initiatives. Initially, we issued interim compensatory 20 measures in an order in February of 2002. Within that order is section B.5.b, and 21 that's, we've heard the term B.5.b, and that's where it comes from. Those interim 22 compensatory measures were inspected at each site, evaluated, and eventually 23 became a license condition for all of our facilities. Just two years ago, in 2009, 24 10 CFR 50.54(hh) was issued to codify those requirements.

25 And the last slide is just a paraphrase of that paragraph in

10 1 50.54(hh). And these mitigation strategies are for beyond designed basis events 2 that could be beneficial in the context of the station blackout. With that, I'd like to 3 turn it over to Mr. George Wilson to go into more detail.

4 MR. WILSON: Thank you, Pat. Good morning, Chairman, 5 Commissioners. As Pat had stated, the 10 CFR 50.63 rule will also involve 6 alternating current power. It intended each site to have to cope, and the big key 7 here is to recover from the loss of off-site power, and we'll get both a little bit later 8 on in the procedures. Once this rule was issued, the NRC staff met with the 9 industry and several working groups, and they started developing the strategy 10 that the rule would be implemented. So we developed Regulatory Guide 1.155.

11 At the same time, the industry developed a NUMARC guide, it's 87-00, on how 12 they would implement and deal with the rule. The NRC endorsed the NUMARC 13 guidance as a way to implement and comply with the station blackout rule.

14 The real key with the station blackout rule was coping, and coping 15 is defined as the time that it takes to recover either on-site or off-site alternate 16 current power back into the plant. The rule specifically gave guidance on how 17 you would calculate and how you would go about doing the coping of the plant.

18 One of it was the on-site redundancy, the amount of diesel generators that you 19 would have at the site, the reliability of the diesel generators. Their reliability was 20 evaluated by different starting mechanisms; 10, 20, 50, to 100 start times, and 21 then that was evaluated. Also, the expected frequency of the loss of off-site 22 power, whether it would be hurricane-type winds, icing. That was also evaluated.

23 And the probable time needed to restore the off-site power that you would restore 24 based on your experience. All that criteria went into the coping analysis, and to 25 the plant. And that's how it was defined.

11 1 I want to point out here that we have had several, we have had 2 hurricanes here, and the diesel generator liability is a key here, both at Turkey 3 Point in Hurricane Andrew and at Waterford in Hurricane Katrina, the diesel 4 generators started and ran for multiple days. They never did go into a station 5 blackout based on the reliability of the emergency diesel generators that we have 6 at the American plants.

7 And the coping methods; there's two different coping mechanisms 8 that can be used in U.S. plants. Forty-four of the plants in the U.S. are battery-9 only, so they can have a maximum coping period of up to four hours. When it 10 was analyzed if the coping period went above four hours, then they had to either 11 do modifications to the plant to reduce the coping time, or they had to install an 12 alternate AC power that would come up. The AC, to be an alternate AC plant, 13 with to do no coping analysis at all, you had to be able to be able to bring the 14 power up within 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, excuse me, 10 minutes, and tie it on to the buses. If it 15 took longer than 10 minutes, then you had to do a combination of having an 16 alternate AC power and a coping analysis that was done for the time that you 17 would bring the plant up.

18 Sixty of the plants in the United States are alternate AC plants.

19 They cope from anywhere from coping analysis of two hours up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. The 20 coping -- the alternate AC power sources are either hydro-generators, 21 combustion turbines, gas turbines that they can use. It can be the alternate, it 22 can be an opposite unit's diesel generator, if they have excess capacity.

23 The staff reviewed the SBO rule implementation by writing a safety 24 evaluation for all 104 sites, and, in addition, as Pat had mentioned, we also went 25 out and performed eight inspections with a temporary instruction that was written.

12 1 We did two units, or two plants, in each region, and there was no major issues 2 identified during the temporary instruction. We did find some of the assumptions 3 in the coping analysis, and those were resolved. And so, based on that and the 4 safety evaluations, the staff had determined that the industry properly 5 implemented the station blackout rule, and they were in compliance with that.

6 Basically, the design overview of the plants with the station 7 blackout is that, as I stated, battery coping was a maximum of four hours. They 8 also evaluated and looked at how you could extend battery life, and I'll get on to 9 that in a little bit in the procedures by shedding loads. You had to evaluate the 10 effects of ventilation. You had to use ventilation, so heat up calculations were 11 done in each room to see what the impacts were. You looked at condensate any 12 way that you could do manual operator actions, bringing in compressed air, 13 minimize RCS inventory leakage. The leakage was based on, one of the key 14 components is that for the reactor coolant pump seals in a pressurized water 15 reactor, you could only assume 25 gallons per minute leakage for a total of 100 16 gallons.

17 And the big key here is, operator training was performed and 18 procedures were written. So not only did they have to write specific procedures 19 on how they were going to deal and cope with a station blackout, but they had to 20 be trained upon it.

21 For the specific SBO procedures, they did specific actions on the 22 restoration of AC power. We, in the United States, were a little bit different, 23 because there's a very close relationship between the grid operators and the 24 nuclear power plants. And one of the things, when we wrote a generic letter, in 25 Generic Letter 2006-02, that had to do with the grid interface with the nuclear

13 1 power plants, we verified that each one of the nuclear power plants would be the 2 first load that would be restored if the grid was lost. So we went back and made 3 sure that the primary reason is that for the safety of the power plants, but that is 4 the first load that's restored in a grid when it goes down in that area.

5 They also developed procedures to enhance emergency diesel 6 generator troubleshooting, and they looked at additional ways to bring power 7 back on, so you look at additional procedures where you bring an alternate AC 8 power on, and look at different ways you can tie it into the plant. They also 9 ensured that the support equipment would be functional without alternating 10 occurring power. That could be bringing in bottled air, putting in nitrogen air 11 stations in there, looking at what valves would have to be manually operated and 12 associated throttle position of those valves. Protection is done to any of the 13 steam-driven pumps, HPCI, RCIC because that is used to mitigate an action of a 14 station blackout, identify the RCS leakage packs, try to minimize the amount of 15 water, and conserve the inventory of water that you have in the primary.

16 Additionally, you look at past, the procedures actually look at past -- the first 17 primary water source, which would be the Condensate Storage Tank, and 18 looking past that, look how you could get additional water sources into the 19 Condensate Storage Tank to further provide inventory water. Also look at 20 stripping non-essential loads off on the DC, which is looking at taking off DC-21 powered pumps, or removing the starting-flash circuitry for a diesel generator, 22 because that takes down the battery.

23 Also, you would look at, during the heat-up calculations that you 24 would do in the room, that can cause some actuations to happen. So some of

14 1 the actions, the procedures would direct, would have operators go out and 2 bypass the isolation for HPCI or RCIC to ensure the steam valves would stay 3 open, you still have the steam supply for the steam-driven pumps. Also, look at 4 the equipment that you would actually use to cool down and shut down the plant, 5 and evaluate what that usage would be. This is -- the procedures got very 6 specific, and they were site specific on exactly how they could cope and deal with 7 a station blackout.

8 Also, in the United States, the grid interface, as I explained earlier --

9 there are agreements between each one of the nuclear power plants and the 10 local grid operators, based on voltage and frequency and the restoration of the 11 plant. In addition, the NRC staff here locally, on Monday through Friday, do a 12 grid report, and we look at what potentials for the grid is. And based on the fact 13 that if the grid is stressed or strained, then sometimes maintenance at the power 14 plants would minimize, to ensure that theres no trips, or minimize the chance 15 that there would be a trip of the plant to maintain the grid reliability. We also 16 have grid-reliability standards in the United States now, that are in full force by 17 the Federal Energy Regulatory Commission, and those grid-reliability standards 18 were written after the Northeast blackout, and they ensured additional reliability 19 and stability in the grid, and additional studies are done on that to ensure that 20 that is one of the reasons that, to try to maintain the stability of the off-site power.

21 In addition, theres a specific grid-reliability standard for the nuclear power plants 22 only, which is Nuclear 001, which specifically goes into voltage and frequency 23 requirements at a nuclear power plant, because those are a lot tighter than 24 normal loads that are on the grid.

15 1 In summary, in the United States, there has only been one 2 identified case of a station blackout. That was at the Vogtle plant in 1990, and 3 that event lasted for approximately 55 minutes. The plant was in a shutdown 4 during the time, and it was because a truck had backed into one of the other 5 transformers that was being used, caused a ground, and ended up being in a 6 station blackout. The plant was able to restore one of the diesel generators and 7 get power restored, and come out of the blackout. As Pat had stated earlier, we 8 do still evaluate for station blackout compliance, and in the license renewal, we 9 make sure that the recovery paths have an aging-management plan. And once 10 again, that is recovery paths. And power uprates, if a licensee changes 11 something, the staff goes back and ensures that the battery-loading capacity 12 didnt change, which could potentially change your coping. We also look at 13 license amendment requests. As stated earlier, one of the plants is a 16-hour 14 coping plant, and originally it was a four-hour coping plant, but there was some 15 operating experience that had happened at the particular plant out west, and 16 based on that operating experience the staff was aware of, the licensee re-17 performed a coping analysis, and went from four hours to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />. Which 18 included -- that includes some modifications to ensure that the amount of fuel oil 19 that they would need would be there.

20 And we also interface with FERC and NERC. We meet quarterly 21 with FERC and NERC. If theres any issue at all that happens on the grid, 22 theres a memorandum of agreement and a memorandum of understanding to 23 sign with both agencies, which, if there is issues with the grid up to a certain 24 level, if it does get severe, then our headquarters operations officer is called by

16 1 NERC, and the electrical branch is contacted to look at it. We also get anything 2 that would cause local problems in the grid, so were very in tune with the grid in 3 looking at issues, and we would get those back out to the plants as they would 4 get stuff back into us. Now Im going to pass this on to Eric.

5 MR. BOWMAN: Thank you George. Good morning Chairman, 6 Commissioners. Im Eric Bowman. Im the staff lead for the mitigating-strategies 7 requirements that were imposed following the terrorist events of 9/11. As Pat 8 had mentioned, we imposed these requirements through a series of regulatory 9 actions, but for convenience sake, Ill refer to them generically as the B.5.b 10 requirements. By their terms, the B.5.b requirements are broadly applicable to 11 any events that are related to explosions or fire. Due to the context in which the 12 strategies to meet those requirements were developed, most of the details of the 13 strategies on a site basis are designated for official use only, as security-related 14 information. Although they were developed to address impacts to the plant due 15 to explosions or fire, the result was a set of flexible, deployable strategies to 16 accomplish the key safety functions for the reactor sites that could be useful in a 17 wide variety of circumstances.

18 Throughout the development process for the B.5.b requirements, 19 we met periodically with our international partners to share information on 20 approaches to the problem and improve our response. The B.5.b development 21 process was a deliberate, phased approach. Initially, we started out looking at 22 what could be done with readily available materials or personnel. Then we 23 moved on to see what can be done further to aid in the cooling of the spent fuel 24 in the spent fuel pools, and the final phase of the development process was

17 1 looking at the core cooling and maintenance of containment. The efforts started 2 out under the lead of the Office of Nuclear Security and Incident Response, 3 ultimately transitioning to the NRR in the lead for operating reactors. We had 4 great support from the regional offices, and analyses that came up from the 5 Office of Research during the effort.

6 As I had mentioned, Phase 1 looked at what could be done with 7 readily available materials and personnel. In large part, the reason for that was 8 because we wanted to see what could be put in place rapidly to address the 9 need, and also the terms of the order itself referred to the use of readily available 10 materials and personnel. Phase 1comprised a series of inspections, 11 assessments, and analyses, drawing on existing equipment and procedures, 12 best practices the licensees had for their initial responses, and lessons learned 13 that came about from the research analyses. That phase culminated in the 14 Phase 1 guidance document that was produced in February of 2005, describing 15 what our expectations were for the characteristics of the strategies that would 16 meet the requirements of the Interim Compensatory Measures Order. That 17 guidance document is designated safeguards information.

18 High-level overview of what we can speak of publicly about the 19 Phase 1 strategies; they involved coordination of response with off-site 20 responders, improvements to the firefighting capabilities on-site, and what I 21 would term as passive measures, such as configuration of fuel within the spent 22 fuel pools in order to enhance coolability.

23 In Phase 2, we looked further at what could be done to promote 24 spent fuel cooling using measures that didnt rely on readily available materials or

18 1 personnel. The results of this phase were a set of mitigating strategies that are 2 required for the licensees to be able to provide makeup water, or cooling spray to 3 the fuel, using means that are diverse from the normal methods for makeup 4 water or cooling of the pools. The diversity includes a diversity from the power 5 supplies within the spent fuel pool building, or the building containing the spent 6 fuel pool -- whatever its called on the site. And a number of the strategies within 7 this group are use of motor forces diverse entirely from on-site power distribution.

8 The Phase 3 looked at what else could be done for core cooling 9 and containment. In that effort, we worked with the industry to identify just what 10 are the key safety functions that would need to be satisfied, based on the design 11 characteristics of the plants. The results here were two sets of mitigating 12 strategies; one that is required of pressurized water reactors, and one that is 13 required of boiling water reactors. For the majority of these strategies, the entry 14 conditions assume a loss of all internal power distribution, both alternating 15 current and direct current, and minimum staffing on-site, so its slightly more 16 conservative than a station blackout condition.

17 Because of the passive nature of the initial strategies, as well as 18 the entry conditions being more conservative, assuming a loss of all internal 19 power distribution, the B.5.b strategies, if they were used in the event of an 20 extended station blackout, would have the potential to extend the period for 21 which a licensee could supply the key safety functions without on-site power 22 available. Subject to your questions, that concludes my briefing.

23 MR. BORCHARDT: That completes the staffs presentation.

24 CHAIRMAN JACZKO: Thanks, appreciate the insights. Well start

19 1 with Commissioner Magwood with questions.

2 COMMISSIONER MAGWOOD: Thank you. Thank you for your 3 presentations today. Very informative. Let me ask sort of a basic question on 4 station blackout, something that Ive been looking at in the last several weeks, 5 and I just wanted to sort of hear your thoughts about this. The -- youve talked 6 about the maximum life of the batteries and the coping strategy being four hours.

7 And I wonder if you could describe how the agency dealt with this, came up with 8 a four-hour coping duration, while at the same time, the procedures clearly 9 indicate that this is supposed to be a site-specific analysis where you look at site-10 specific characteristics of the plant, off-site power resources, and one would think 11 you would have a variety of conclusions after going through that analysis. But 12 yet most of the plants, a vast majority of the plants, have this four-hour coping 13 strategy. Can you reconcile those for me?

14 MR. WILSON: Yeah, the four-hour coping analysis was arrived 15 when the staff worked with the industry, and they looked at how long, roughly, it 16 would take to restore off-site power in various places. The estimate was .9 to 17 two hours, so based on that, the staff doubled the time and said you will cope 18 with a station blackout for four hours. So the industry came up with, it would be 19 .9 to two hours, like I said, and we doubled it to have a safety margin there, to --

20 youd cope with four hours. We chose four hours based on the size and the 21 capacity of the batteries, so anything longer than that, modifications were made 22 or you brought an additional source on, but thats where the original four hours 23 came from.

24 COMMISSIONER MAGWOOD: Whats our actual experience with

20 1 loss of off-site power, in terms of how long it takes to restore off-site power?

2 MR. WILSON: There is some data that was -- we used a NUREG, 3 6890, that has some data in it, and it would go anywhere from .5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to three 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. Were also in, one of the statements that I made is we have constant 5 communications with NERC and FERC, and they have done some studies and 6 done some projections across the country on certain circumstances. How long it 7 would take to restore an off-site power, and were presently looking at that, and 8 we have that to the quick-look team.

9 COMMISSIONER MAGWOOD: When youre thinking about the 10 restoration of off-site power, its interesting that having an alternative source of 11 off-site power is one of the options that you look at in mitigating a station 12 blackout. However, when you think about the sorts of events that lead to the loss 13 of off-site power, what is the thinking in terms of, if you lose one source of 14 transmission from one off-site source, why do you think you have a second?

15 What sorts of scenarios would it be useful to have the second, redundant off-site 16 power source if you lost the first one? If you have a hurricane that takes out the 17 transmission lines for one source of off-site power, why would you think thered 18 be a second?

19 MR. WILSON: I would go ahead and say youre not asking a 20 question with alternate AC source, or are you asking a question about the 21 redundancy of off-site power?

22 COMMISSIONER MAGWOOD: Yes.

23 MR. WILSON: Well, the more off-site power lines that you have, 24 unless you would have a common cause failure that would wipe out a switchyard,

21 1 the more lines that would come in and you have a more redundant off-site power, 2 then that would give you more capability to mitigate an accident. You would want 3 an alternate AC source, the staff would like to have an alternate AC source, 4 because the capacity of an alternate AC source is above that of the battery, so 5 theres more margin if I have an alternate AC source. Theres no requirement, as 6 you had mentioned, to protect that alternate AC source from events. I mean, 7 from environmental effects. Theres no requirement. We have, Appendix A, 8 GDC-2, that affects safety-related stuff from environmental effects, but those 9 requirements are not for the alternate AC source, so it is not a safety-related 10 source as robust as the emergency diesel generators, but it does have a longer 11 capacity and capability. Thats the reason wed want it, but theres no 12 requirement as such to have an underground cable which would protect it from, 13 like, high winds. Theres no requirement that we have for that.

14 COMMISSIONER MAGWOOD: But you mentioned that the 15 procedures that have been developed for station blackouts -- how much work 16 has been done to reconcile, or I guess to merge the station blackout procedures 17 with the severe-accident management guidelines? How much coordination is 18 there between those two?

19 MR. WILSON: Well, the station blackout is an abnormal operating 20 procedure. The SAMGs are above anything that you would have, so theyre way 21 beyond what a station blackout. The basis of the SAMGs, when you go through 22 them, is you would have power to do certain things, to get water back or to 23 minimize the release path. So as far as I know, theyre not in tune, they dont go 24 from one to the other. The station blackout specifically tries to restore power, but

22 1 as far as I know, and -- Donny, can you add anything?

2 MR. HARRISON: You got it.

3 MR. WILSON: But theyre not in tune where one feeds into the 4 other. Theyre used for a different purpose.

5 COMMISIONER MAGWOOD: So you never assumed that in the 6 case of a severe accident, that you lost offside power? Is that what youre 7 saying?

8 CHAIRMAN JACZKO: Donny, do you want to maybe go up to the 9 mic?

10 MR. HARRISON: Im Donny Harrison from NRR. The answer to 11 your question would be no. If youre into the SAMGs, youre into an event thats 12 gone beyond your normal emergency procedures and your abnormal 13 procedures, but what you might be in is going through the SAMG guidelines 14 looking for water sources, for containment flooding, and that type of thing. But at 15 the same time, you may have your station-blackout procedures open also, and 16 youre trying to recover AC power. You might be doing the coping strategies of 17 taking loads off your batteries so you can prolong their life. So you may be 18 actually in both at the same time. Thats kind of what would probably happen.

19 COMMISSIONER MAGWOOD: I mean, Ive looked at some of the 20 SAMGs. I havent looked at all of them. Ive looked at some examples of 21 SAMGs for specific plants. You might want to stick around for this. And Im just 22 curious as to what -- most of the SAMGs, as I read them, seem to anticipate that 23 you do have power 24 MR. HARRISON: Well for most things, you need water and you

23 1 need to pump it, so implicit in that, youre going to need some type of power 2 supply or steam, if you can run a RCIC pump off the steam and have DC power 3 for the control of the pump. So the SAMGs basically are geared towards a list of 4 water supplies for containment flooding. Some of them need AC power, some of 5 them probably need DC power for control. Again, then you get into the strategy 6 of, Can I prolong the battery life so I can control the RCIC pump? if thats what 7 youre using to provide water to the core. So its a mix, and the SAMGs are 8 guidelines. Theyre not procedural for specific events. So what it is is a list, 9 oftentimes, and so youll get into that and youll start going through the list saying, 10 What is available? What isnt available? and youll get down to what youve got.

11 COMMISSIONER MAGWOOD: All right, I think Ill leave it at that 12 for now. Let me ask just sort of a broad question. This is something that 13 actually, Eric, Leeds and I have talked about a little bit already. Which is, what 14 are the options if one were to have the desire to have a longer coping time? A 15 longer coping duration? What technical options immediately present themselves 16 in your mind to increase the duration?

17 MR. WILSON: Well, the way you would have to -- right now, we 18 dont know about the batteries. You could potentially have a higher-capacity 19 battery would be one way, but even with an alternate AC source, you have to 20 have everything on-site. Like the one plant that has a 16-hour coping analysis.

21 That means their alternate AC source has enough fuel capacity. Its already 22 there that it will run for 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />, and they need to get off-site power back within 23 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> because that is all the capacity thats there unless theyre going to 24 mitigate and bring additional fuel oil and stuff on for the source. So to go beyond

24 1 a four-hour capacity, I think you would have to have an alternate AC source and 2 you would have to have the capability of those -- well youd have to have 3 everything there for it to run if you wanted to cope with something for longer than 4 four hours, or change the battery out to a higher-capacity battery that could 5 handle a larger discharge.

6 Another option would be to potentially bring in a battery charger 7 that you could bring in, with a power supply to recharge the batteries and 8 maintain that capacity. That would be something that would -- you wouldnt have 9 to change your batteries. That would be, just bring another battery charger, 10 charge the batteries, and you could extend the capacity of those batteries that 11 you have on-site now.

12 COMMISSIONER MAGWOOD: And I understand there are a small 13 number of licensees that are doing something along those lines now, is that 14 correct?

15 MR. WILSON: Yes, there is one licensee that Im aware of that has 16 brought a temporary battery charger in, they have it in their procedures that they 17 would charge, and increase the capacity of that battery. And that is one of the 18 coastal plants in the United States that a hurricane could actually affect.

19 COMMISSIONER MAGWOOD: Thank you very much. Thank you, 20 Chairman.

21 CHAIRMAN JACZKO: Commissioner Ostendorff?

22 COMMISSIONER OSTENDORFF: Thank you Mr. Chairman.

23 Thank you all for being here today. I wanted to maybe start out with Pat, I guess 24 its a question for you and perhaps George. Just a big picture, looking at what

25 1 the NRC does via regions, resident-inspector programs, to assess the readiness 2 of a specific plant to deal with a station blackout. I understand there was a one-3 time inspection done back in the 80s that is part of, also, license-renewal 4 application process. Are there any other looks that the NRC takes via its resident 5 inspectors or by other mechanisms, to provide an NRC perspective on the 6 licensees readiness to deal with the station blackout conditions?

7 MR. WILSON: Pat, Ill take this one if you dont mind. Actually, 8 after Generic Letter 2006-02, we have written some procedures. We used to go 9 out and do a temporary instruction that looked at the worst grid conditions, so 10 whether that would be -- mostly in the summer, where the grid would be 11 stressed. So we used to have a temporary instruction that would go out and look 12 at summer readiness, to make sure that the plant was ready for the extreme grid 13 conditions that could happen in the summer. We changed -- actually went in and 14 changed one of the procedures. The adverse weather procedure actually looks 15 at summer readiness for the plant, on a grid-type basis. Not specifically for 16 station blackout, but it looks at -- are the diesels ready, or are they monitoring the 17 grid? So specifically looks at that -- not looking at incompliance with station 18 blackout, but looks at because the grids stressed during those conditions. And 19 thats something the resident inspectors do.

20 COMMISSIONER OSTENDORFF: Anything there, Pat?

21 MR. HILAND: Id like to add something, just a minor comment. My 22 first 10 years in the Commission, I was a resident inspector at three different 23 power plants. PWR and two boiling-water reactors. And the job of the resident 24 inspector is to be aware of the plant conditions every day. He goes into the

26 1 plant, he hears what the plant modifications are, what the design changes are, he 2 understands the need for the alternate AC sources on-site, both the standard 3 diesel or in Oconees case, the hydro plant, as well as whats there for the station 4 blackout. And so you rely on that daily presence, five days a week or actually 5 seven days a week, of the resident inspector. So I would add that only, just 6 emphasize.

7 COMMISSIONER OSTENDORFF: Let me just kind of maybe add 8 another question on to that, that is related to this precise query. And that is --

9 and Commissioner Magwood was asking questions about the four-hour battery 10 time and so forth, as one component of the coping strategies for a specific plant.

11 Can you talk a little bit -- I guess George, about -- is the coping strategy a 12 dynamic, evolving, living piece? Or is it static? Can you talk a little bit about how 13 that might be updated as conditions at the plant, or in that particular part of the 14 grid, may change?

15 MR. WILSON: The coping analysis that was done was a one-time 16 snapshot that the licensees had to look at their coping analysis. We do evaluate, 17 as I stated, in some of the license amendments like power uprate, if the battery 18 capacity would be affected if they were changing and adding DC loads, and wed 19 go back and look at that. And as in the case of the one unit, due to operating 20 experience, we challenged them and they went back and redid their calculation, 21 ended up being a 16-hour coping plant. There has been several findings on 22 station blackout. They look at the assumptions. So it is -- there are issues that 23 are identified in different inspection procedures, but we do not go back and 24 reevaluate the full-blown assumptions and calculations that a licensee does.

27 1 MR. BORCHARDT: I think thats -- the key is that the regional 2 inspections that are done, as well as the resident inspectors, will look at every 3 design change thats made at the plant, or nearly every, and then theyll look at 4 50.59 evaluations to make sure that all the proper considerations were taken into 5 account. One of those would be loading on diesels, and if you change the load 6 of the diesel, or you change the load on a battery, those would all be evaluated 7 and would likely lead to an issue, perhaps, with station blackout. We dont do 8 station blackout reviews per se, but theres many, many ways that you would get 9 to a station-blackout issue just in the normal course of our oversight activities.

10 COMMISSIONER OSTENDORFF: Okay, thank you. Let me go 11 back to a comment that George had mentioned in his briefing, and that was, we 12 do have experience with hurricanes, and the Chairman mentioned the tornadoes 13 weve had just in the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and certainly we had a tornado here in the 14 last couple weeks down in southern Virginia that impacted a switchyard at a 15 nuclear power plant. From the hurricane experience, or tornadoes, is there any 16 big area of query that you think the NRC needs to look at, or feel pretty 17 comfortable that our exiting processes adequately assess the impact of these 18 weather-related events on off-site power availability?

19 MR. WILSON: Well, I know one of the things that the staff has 20 done, to give you an example to add defense and depth, when industry and 21 utilities have come in and asked for an extension, an AOT extension, a lot of 22 outage time on some sort of power source, either being a diesel generator or 23 transformer or one of the lines, one of the things that the staff requires is the 24 replacement of that power source with some sort of other power source. Not

28 1 safety related, but they bring in temporary diesel generators, and with that, the 2 temporary diesel generators, what we have seen is that there are temporary 3 diesel generators, so if something would happen, you could easily get one of the 4 temporary diesel generators, and they got them at Waterford during Hurricane 5 Katrina, they had the temporary diesel generators brought on-site. They had 6 them in case they did lose off-site power, or they had a problem with the other 7 diesels, and they had that temporary diesel there. So that we know that they do 8 have that capability to do it, and they also line up fuel sources, I think, based on 9 some discussions -- and one of my staff members, actually out in Waterford 10 during Katrina, the roads were blocked, they had no other way, so they were 11 starting to bring fuel oil through with a barge. So we have had lessons learned 12 from the hurricanes that not only do they have extra power sources that they can 13 get, but also, you have to think outside the box, to look to see how youre going 14 to get the fuel oil there if the roads were blocked. So that is stuff that weve got 15 lessons learned, and it has seemed to work. At Turkey Point, they ran the 16 diesels for a couple weeks, so it seems to work.

17 MR. HILAND: Yeah, let me just add -- and Turkey Points a good 18 example, where hurricanes are something that you see on the weather map, 19 approaching you. And there are procedures at the site, and they initiated it at 20 Turkey Point. They shut the plant down before the hurricane got there. They 21 started up the diesels, and essentially, they were well prepared for that event.

22 So there is a process, versus a tornado is unknown. That tornado, you get 23 about, at luck, 15, 30 minutes of warning, for a tornado warning, to react. But for 24 hurricanes, we have procedures in place. Our regional office goes into a standby

29 1 mode in the response center. The resident inspectors for Hurricane Andrew 2 were on-site throughout the entire event, and so there are some preparatory 3 work that you can do for a hurricane.

4 COMMISSIONER OSTENDORFF: Thank you. Eric, Id like to turn 5 to you for a minute here on B.5.b. And again, thank you for your presentation, 6 and I recognize that there are limitations as to what you might be able to address 7 in this session, but let me just ask this question. Can you talk in general terms as 8 to what the NRC does to inspect the ability of the licensee to carry out B.5.b-type 9 actions, as far as equipment reliability, testing that equipment, operator training, 10 et cetera?

11 MR. BOWMAN: Thats examined on a triennial basis, as part of the 12 triennial fire protection inspection. We added the B.5.b requirements and the 13 strategies that meet them as an inspectable area there, January 1 of 2010. So 14 they look at -- so they look at the capabilities of the equipment to be used to meet 15 the strategies, the maintenance on the equipment, and the training of the 16 personnel.

17 COMMISSIONER OSTENDORFF: So we have a little bit over a 18 year experience with that. Is that what we -- you said January 1, 2010? Any big 19 ah-ha kind of lessons learned from that level one year experience so far?

20 MR. BOWMAN: If I could defer that to the closed session, Id 21 prefer.

22 COMMISSIONER OSTENDORFF: Thank you. Thank you, Mr.

23 Chairman.

24 MR. BORCHARDT: Commissioner, I would also just acknowledge

30 1 that the industry has done a review of that equipment, of their own. Theyve 2 identified some issues that are being resolved. Some of them are being informed 3 by the uniqueness of what happened in Japan, as to where equipment is stored, 4 for example. It was looked at differently now, given the tsunami kind of flooding 5 issues, than we might have looked at it previously.

6 COMMISSIONER OSTENDORFF: Thank you.

7 CHAIRMAN JACZKO: If I could just clarify, the tri-annual is not the 8 first inspections we've done at B.5.b. We did, following implementation of B.5.b 9 we did a temporary instruction, as I recall, to inspect all the B.5.b implementation.

10 MR. BOWMAN: That's correct, sir. There were, I believe, four or 11 five temporary inspections that were conducted along the development process.

12 In 2008, we did a final verification that everything was in place. Then we 13 transitioned to monitoring it through the reactor oversight process and the tri-14 annual fire protection inspection, and --

15 CHAIRMAN JACZKO: Okay. So that, I just wanted to clarify.

16 MR. BOWMAN: That's correct.

17 COMMISSIONER OSTENDORFF: Thanks for the clarification.

18 MR. BOWMAN: Sure.

19 COMMISSIONER OSTENDORFF: Thanks, Chairman.

20 CHAIRMAN JACZKO: Commissioner Svinicki?

21 COMMISSIONER SVINICKI: Thank you all for your presentations.

22 My colleagues have touched on some topics I might have addressed. They 23 might not have posed the questions in the exact same way, so I apologize if I'm 24 covering any of the same ground a little bit.

31 1 At a very high level, Bill, you talked about the fact, you gave a 2 status report on what's happening in Japan, and you talked a little bit about our 3 90 day and our longer term review. As long as our colleagues in Japan are 4 focused, as they are now, very immediately and deeply still on mitigation, dealing 5 with the circumstances on the ground there, they're obviously appropriately 6 focused on that and not focused, right now, in being able to look at detailed 7 chronologies of events, or lessons learned, or things like that. And yet, we have 8 underway this near term review.

9 And so, my thought turns on station blackout to a question that I still 10 want to ask you, because we do know quite a bit, and we have a presence in 11 Japan, and we've been learning a lot about the events. I would ask any of you if 12 you want to respond: based on what you know today, is there anything about the 13 events that occurred in Japan, with relation to station blackout, that cause you to 14 immediately identify areas in our regulations that you would assess today are 15 potentially inadequate, based on what you know right now?

16 MR. BORCHARDT: Right after the event, and every day since, we 17 ask ourselves whether or not there's some regulatory action we need to take to 18 assure the protection for the 104 plants in this country. And to date, we have not 19 identified anything that requires immediate action. That doesn't mean we won't 20 identify some things that we want to raise to the Commission for future 21 consideration. Station blackout rule oversight might be one of those.

22 But the short term task force is looking at station blackout. I believe 23 they'll address it to some degree. I think it'll, if I were to guess, would guess that 24 will also be an element of the longer term review, as we gain more and more 25 information about the existence or the conditions of switch gear inside of the

32 1 plants in Japan, which we really have no idea of the condition of that equipment.

2 COMMISSIONER SVINICKI: And I think, somewhat, my question 3 is rooted in a comment, that I believe you made representing the U.S., and you 4 were also, I think, Vice President, the Convention on Nuclear Safety, a really 5 important international meeting on national nuclear safety cooperation 6 internationally. But I think you indicated in your remarks there that we may be 7 learning about this event even a decade from now.

8 So is it accurate to say that, for our 90 day review and also the 9 longer term, that we will, by, perhaps, the end of the year, we'll be looking at 10 issuing some further recommendations if appropriate? It will still be challenging 11 to have good fidelity and solid knowledge of all of the events that occurred over 12 in Japan. Is it true that the team that's doing the 90 day review and our longer 13 term review, they're going to struggle with that issue?

14 MR. BORCHARDT: Clearly. I mean, and their charter 15 acknowledged that they're to use whatever information they have available today.

16 Because we didn't want to wait until we had all of the information; who knows 17 how long that would be? So we didn't want to delay in doing what was 18 appropriate and prudent to do now, or in the near term. And so they will identify 19 many holes in our knowledge that, hopefully, many of those will be filled during 20 the time period of the longer term review. But it's not outside the realm of 21 possibility that it'll be years before we know the full condition of, you know, the 22 inside of the core, and various pieces of equipment that are currently in very high 23 radiation areas.

24 COMMISSIONER SVINICKI: And this may sound simple, but 25 sometimes things are more complicated than we think. Do we have a good

33 1 ability right now to do a comparison between our requirements on station 2 blackout and Japan's requirements on station blackout? That sounds very 3 simple, like, as long as we can translate it, why don't we have the ability to just 4 lay those side by side? Is that more complicated than we think?

5 MR. BORCHARDT: I don't know, you know, and I don't know how 6 much of the short term task force, they've looked into that. But you're right, it 7 sounds like it'd be pretty simple, it's something you could do through a web 8 search even. But I don't really know, if Artie or -- where's Artie?

9 CHAIRMAN JACZKO: Right behind you.

10 MR. BORCHARDT: Yeah. We'll have to get back to you.

11 COMMISSIONER SVINICKI: Okay, but that is something that it 12 would be your understanding that, for the 90 day review, they'll at least try to 13 access whatever they can in terms of comparability, and that would inform 14 whatever it is the 90 day review would put forward?

15 MR. BORCHARDT: I think that sounds reasonable.

16 COMMISSIONER SVINICKI: Okay.

17 MR. BORCHARDT: they're not doing it now, they will be later 18 today.

19 [laughter]

20 CHAIRMAN JACZKO: Let's make sure that they have their, you 21 know, that that's a task, that they can complete in the appropriate way, then 22 they'll do that.

23 COMMISSIONER SVINICKI: And then I would characterize some 24 of my colleagues' questions, based on the presentations you gave, they have to 25 do with something I think the NRC has been questioned about since this event

34 1 occurred, and it is: how frequently do we challenge and reassess underlying 2 assumptions that we've made in developing the regulations we have in place?

3 So, George, you talked quite a bit today about looking at any time a licensee 4 might propose a change on-site, we will look at the evaluation they did to comply 5 with station blackout. We'll see if there's any effect there, and we would 6 challenge that.

7 But I think that some of the questions that I think NRC has been 8 asked have to do with: do we look at our assumptions about broader external 9 conditions? And George, you've mentioned working with the Federal Energy 10 Regulatory Commission on grid reliability, grid status, the North American 11 Electric Reliability Corporation. We have important relationships there where we 12 reassess that. But, of course, that's very dynamic, as the nation looks at maybe 13 having more renewable energy, the grid may look different in the future.

14 Can you characterize our overall engagement on really having access to the best 15 information about external things like grid reliability, so that we can constantly be 16 informing whether our regulatory assumptions that we've made in the past are 17 adequate?

18 MR. WILSON: We -- as I had stated, we meet quarterly with both 19 NERC and FERC. And if anything comes up, we're aware of it. We actually are 20 noticed and given information if they're going to change any of their reliability 21 standards. We have commented on the reliability standards to ensure that the 22 safety of the nuclear power plants are maintained. I feel very confident about the 23 status of the grids.

24 When they do new reports, we know that they are doing new 25 research reports, such as there's three reports out right now that we're looking at,

35 1 based on the frequency response of the grid and the interconnection. We do 2 have, joint Commission meetings with the Federal Energy Regulatory 3 Commission and we also invite NERC. We have contacts with the Department of 4 Energy on their grid sector, their energy sector, to evaluate that.

5 So, as things do change, we do re-look at that. And to see if we do have to 6 evaluate the grid assumptions and the staff has been looking very hard at this for 7 the last three years, specifically with stuff that changes in the grid, and to see 8 how the renewable sources such as, specifically, wind, and how that's taken, 9 because it potentially affects the reliability. And there has been an incident 10 where the wind just stopped blowing and there was 1100 megawatts that was 11 lost in ERCOT, which is the Texas grid. So I feel very confident, we know the 12 status of it and are evaluating that.

13 COMMISSIONER SVINICKI: And you mentioned, in response to a 14 question from Commissioner Ostendorff, that our site-by-site evaluation of the 15 compliance with station blackout was a bit of a one-time snapshot. Based on the 16 answer you just gave me, do you have all of the authorities that you need, if you 17 did need to change an underlying assumption that was external to the plant 18 conditions itself, having to do with a grid or something else? Do you feel 19 confident that you have the authority to compel that licensees have to take that 20 changed circumstance into account?

21 MR. WILSON: Yeah, I think that we have the process that we do 22 look at it potentially as plant-specific backfit, or if we thought there was a broad 23 look at potential rulemaking, and route that through the process. So I would think 24 that process is in place to do that.

25 COMMISSIONER SVINICKI: Okay. And my last question is -- I'll

36 1 rope in Pat, because I think this is a little bit of a put you on the spot question, but 2 for George and Pat: we've talked a lot about four hour batteries. We talked a 3 little bit about eight hour batteries. But, you know, you're probably, like many of 4 us, since this event occurs, there's been a lot of discussion about four hour 5 battery life.

6 And I don't know if, perhaps, at a family event, or a barbeque, or 7 anything, maybe some member of your family might come up to you and say, 8 Well, you know, we have natural events that can occur, like hurricanes: those 9 can be multi-day events. What is the basis for having four hours? Just to a lay 10 person, when they come to you and say, Is it really only four hours that nuclear 11 power plants have to cope with some sort of event of a long duration? What do 12 you say to -- if you were talking to a family member, what would you say to that?

13 MR. HILAND: Yeah, I'll start. First of all, the, I would talk to the 14 family member and say, That's the maximum that we allow reliance on a 15 battery. We have a high expectation that you restore either off-site power or one 16 of your emergency diesels, or an alternate AC power source. It doesn't mean 17 that the battery -- as you heard, we have an example of a plant that has a small 18 generator; maybe they bought it at Home Depot. And they bring it in, they 19 charge the battery, or recharge the battery.

20 That means you can extend the life of the battery, but the four hour 21 coping time is the maximum we allow. That's not to say the batteries can't last 22 longer than that. I don't have the details of all the batteries at the plants, but 23 they're tested periodically to assure that they're in a high state of readiness.

24 That's how I would answer that question.

25 Our experience is the reliability of our emergency diesels is very

37 1 high. Very high reliability, and it's very -- demonstrated very promptly to restore 2 emergency diesel that either didn't start the first time, there's a problem with it, 3 the mechanics are on-site, the operators know how to operate the controls of the 4 diesel. So we have some high level of confidence that, within four hours, they'll 5 get either off-site power back, of course that doesn't happen if you have a 6 hurricane, or they'll get the emergency diesels back on line. That's my answer.

7 George?

8 MR. WILSON: Yeah. What I would add is, because I've been 9 asked this question. I commute two hours each way and I get asked this 10 question a lot, recently. And how I've answered is that we've only had one 11 station blackout in the United States. Our diesels are very reliable, and they 12 restored that power within 55 minutes. I also explain that we have redundant 13 power supplies. So you have to have something to take out multiple sources of 14 power. And once I explain that, I've, usually they stop, or I run overboard --

15 [laughter]

16 COMMISSIONER SVINICKI: All right, thank you. Thank you all 17 very much. Thank you.

18 CHAIRMAN JACZKO: Commissioner Apostolakis.

19 COMMISSIONER APOSTOLAKIS: Thank you, Mr. Chairman. I 20 guess most of my questions have been asked, but I, we've been talking about 21 assumptions and so on. It seems to me, two of the assumptions that we have 22 been making regarding station blackout now have to be questioned in light of 23 what has happened in Japan.

24 One is the time that we consider when we try to manage station 25 blackout. I mean, we talk about four hours, eight hours, some PRAs go to 24

38 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. But as far as I know, there are no studies that go to weeks. And that's the 2 first assumption. The second assumption is that there may be major 3 infrastructure damage. So when you, Mr. Wilson, talk about diesel reliability, I 4 assume you are talking about under conditions that are not as severe as what we 5 have seen in Japan. So are these the two assumptions that we have to revisit 6 now, in light of Japan? The time and the state of the infrastructure?

7 MR. BORCHARDT: Well, in my view, clearly the state of the 8 infrastructure is very important. I mean, it's for station blackout, it's for 9 emergency preparedness, it really cuts across the entire spectrum of plant 10 response to an event. We practice emergency response activities assuming that 11 there is the infrastructure surrounding the plant. So there's clearly a good lesson 12 learned.

13 Regarding the duration of the time, I think there is something, we 14 certainly need to evaluate. But I do believe that our regulatory processes and 15 requirements, even though they might, you know, they talk about four hours for 16 the batteries. We, as Pat and George mentioned, have requirements for 17 reliability of the diesel generators, for tech specs, times for how long they can be 18 out of service, and all of those requirements, and fuel storage tanks 19 requirements, that assume that it's going to be a longer duration event than just 20 four hours, certainly.

21 COMMISSIONER APOSTOLAKIS: But certainly not weeks, 22 though. I don't know of any study that went out that far.

23 MR. BORCHARDT: No, but I think that there are, there are plant 24 procedures and protocols in place to get the tanks refilled for diesel generators. I 25 mean, diesel generators are an incredibly important system for plant response.

39 1 And there are -- every plant that I'm aware of has arrangements to have their 2 facilities, their tanks refilled, in the event that they need to go on long term 3 operation of the diesel generators. When we had the northeast blackout a 4 number of years ago, there were some plants that had, off-site power was out, 5 for a time period, and all those preparations were put into play in order to go, 6 assume that we would have long term loss of transmission capability.

7 COMMISSIONER APOSTOLAKIS: Now, I have a question 8 regarding the temporary instruction. I'm trying to understand what exactly the 9 inspectors did that led you to the conclusion that there are no issues. Did they 10 go in there and look at whether our regulations and the commitments of the 11 licensee are met? Or did they go beyond that and they looked at, you know, 12 what if we have a major external event, natural phenomenon, what's going to 13 happen? Are you prepared to cope with it? Is that something that the task force 14 will look into and the inspectors just looked at the current commitments and 15 made sure that they are, in fact, satisfied? And then, of course, the conclusion 16 that there are no issues probably makes sense.

17 MR. BORCHARDT: In general, we want to give our inspectors 18 guidance to go out and inspect against existing requirements. They may identify 19 topics and ideas that go beyond the design basis or beyond the regulatory 20 requirements. We were certainly becoming aware of some of those ideas, but as 21 a general rule, we inspect against existing requirements. The task force would 22 be the proper vehicle to say, okay, that's fine, but do we need to revisit what the 23 regulatory requirement is? Does it need to go further than the current construct 24 does?

25 COMMISSIONER APOSTOLAKIS: The B.5.b equipment. I don't

40 1 know if it's appropriate to ask the question now, but did you consider major 2 catastrophe and what it could do to the B.5.b equipment?

3 MR. BOWMAN: The B.5.b was the response to an event that 4 involved explosions and fire, so that was generally the focus of what was looked 5 at in developing the mitigating strategies that would meet the requirements. We 6 can discuss it further in the closed session. I think that would probably be 7 appropriate.

8 COMMISSIONER APOSTOLAKIS: Commissioner Magwood 9 mentioned earlier that what will happen at a particular site is, of course, site-10 specific. And I'm wondering whether we have site-specific accident sequences 11 and somebody, the licensee, or us, or both, are looking at these sequences and 12 make sure that the regulatory requirements we have, or the commitment of the 13 licensee, since it's beyond design basis, are actually consistent with the site-14 specific nature of these events.

15 And one example, for example, we -- one example, for example, 16 okay. When we assume that the operators will actually do something, are we 17 considering the possibility they won't do it? Or that they would do the right thing, 18 or the wrong thing? You know where I'm going with this. Are you using PRA at 19 all, when you're doing these evaluations?

20 MR. HARRISON: I think, in a general sense, if you go back to the 21 IPEs and IPEEEs, there was considerations that would be PRA-oriented analysis 22 to address some of this. The IPE and IPEEE were used to close out a number of 23 the safety issues that were, in the mid-80s, related to various capabilities. So 24 those were reviewed in that context. Now, we also have SPAR models, and 25 licensees have internal event PRA models that they have. And again, that

41 1 should inform their SAMG's as to, like, if you need a diesel generator or fire pump 2 capability, if you have that capability, you can put that in your plant-specific PRA 3 and show that you could mitigate some severe accidents using that.

4 COMMISSIONER APOSTOLAKIS: So some of it is done.

5 MR. HARRISON: Some of it is there.

6 COMMISSIONER APOSTOLAKIS: Okay. Thank you, Mr.

7 Chairman.

8 CHAIRMAN JACZKO: Okay, I'll go back to Commissioner 9 Svinicki's question about the family picnic, or whatever, wherever it was. One of 10 the things I'm having trouble reconciling, I think Commissioner Magwood raised 11 this point too, is the four hour, the four hour time, the coping time, and I think, 12 Pat, you did a nice job explaining that's the maximum time that we would allow 13 before we would expect off-site power to be restored. Where I'm having a hard 14 time reconciling that is we have lots of examples where it takes longer than four 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br /> to restore off-site power. So there seems to be an inconsistency with that 16 assumption, and I think, George, you said the same thing: that our data says that 17 restoration takes about three hours. So I'm not sure if that, if that includes some 18 run time for the diesels and then four hours, or if that is four hours with, say, an 19 immediate loss of off-site power and an immediate inability of the diesels to 20 operate. How do you reconcile those two issues?

21 MR. WILSON: Well, the four hours is based on losing all alternate 22 current power. So that's the losing the diesels and losing off-site power. As to 23 diesels are running and you have your power supply --

24 CHAIRMAN JACZKO: Right.

25 MR. WILSON: -- and that's what we've seen here, in the U.S., the

42 1 diesels have ran. We've only had that one event. But the four hours, like I said, 2 is, that's just based on having no power and just doing, only coping on the 3 batteries by itself. If you have -- if you can do a combination, then you do an 4 analysis. You do a coping period that, if you think your batteries, you're going to 5 need your batteries for two hours, you would do a coping analysis that says, I 6 can handle just on the batteries for two hours, then I have my alternate AC power 7 come on, and then I do an analysis on how long I would think that alternate AC 8 power needs to run before I would restore the power. That's how they're all 9 combined. So the four hours is the, what I would consider to be the worst-case 10 scenario, where I have nothing, I'm just on my batteries. And, like I said, there 11 are processes that --

12 CHAIRMAN JACZKO: And I appreciate that. The point, though, is 13 that, clearly, if we get into a situation which is the situation we have in Japan, 14 which is, where you lose the diesels, it takes more than four hours, in some 15 cases, to get off-site power restored. In the hurricane situation, you know, 16 Turkey Point, you said the diesels were running for days? I'm interpreting that to 17 mean that it was days before off-site power was restored. I mean, I think, from 18 Browns Ferry last night, they still have not restored, maybe they have one line, 19 not fully restored, but they have one line, so that they seem to be okay, there. So 20 --

21 MR. HILAND: [inaudible] emergency diesels there.

22 CHAIRMAN JACZKO: And, again, and in that case, the diesels are 23 running. But, of course, the station blackout is the rule for when the diesels 24 aren't running, is not the rule for when the diesels are running. It's intended to be 25 that situation in which they don't, they don't run, for whatever reason. So, again,

43 1 that's why I think, from a risk perspective, we don't believe it's a significant event.

2 But four hours doesn't seem to be a reasonable time to restore off-site power if 3 you've, if you've lost the diesels immediately. So I'm not sure where we have the 4 data that supports that right now. I mean, unless I'm, I mean, tell me if I'm wrong, 5 I guess it's what I'm trying to ask. Am I wrong about hurricanes? Did it only take 6 four hours to restore site power and they just didn't --

7 MR. HILAND: No, you're correct. You're correct. But the four 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, as George described, came from an analysis that what was the ability to 9 restore off-site power, and what was the ability to restore, how reliable were the 10 emergency diesels. Now, they came up with two hours. And we said, okay, two 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br /> is the average at the time. We're not going to allow anyone to give an 12 analysis greater than four hours, with that expectation.

13 And you're right. In the hurricane situation, the reason the plants 14 have, you know, preemptive procedures, when they see a hurricane approach, 15 they shut the plant, they turn on their emergency diesels, and that's, they 16 anticipate the loss of the off-site power. You know, the four hours is, you want to 17 restore either off-site or an emergency diesel. And we, we may confuse 18 emergency diesel with alternate AC power. And alternate AC means your 19 emergency diesels are out of service, as some, some mechanical problem or 20 common mode, and you have this alternate AC. And there's a number of plants 21 that chose that path. The alternate AC, and the reason for the time frames, is 22 how much fuel do you have on-site for this alternate AC, whatever the gas 23 turbine, how much gas do you have available to run it? And you know, typically -

24 -

25 CHAIRMAN JACZKO: Those alternate ACs are not seismically

44 1 qualified.

2 MR. WILSON: That's correct, they're not.

3 MR. HILAND: Right, that's correct.

4 CHAIRMAN JACZKO: So they're not intended to necessarily 5 survive --

6 MR. HILAND: That's correct.

7 CHAIRMAN JACZKO: -- some of those type of events.

8 MR. HILAND: Right.

9 CHAIRMAN JACZKO: Well, I appreciate that and as I said, I'm just 10 trying to understand the, you know, kind of the basis. And, again, just to 11 reiterate, it's not, the diesel reliability is very high, and I was just looking back at 12 the statement's consideration for the original ruling, even, I think, in the time from 13 the 80s to the time in which the rule was ultimately implemented, there were 14 improvements in diesel generator reliability. I assume that those improvements 15 have only enhanced over time, to today. So the likelihood of a station blackout is 16 very low, but in the event that there is a station blackout, that's externally driven, 17 I'm not convinced that, in that situation, four hours is a reasonable time to restore 18 off-site power. And that may be something that we want to look up a little bit 19 more.

20 There's been, I think, a lot of good questions about the coping 21 analysis and the living nature of that coping analysis. I understand that the staff 22 has looked at this issue in the past, and one of the, I think one of the options that 23 was considered, given that the rule doesn't appear to allow, directly, the agency 24 to require an update, that coping analysis, one of the issues that was presented 25 was the possibility of a generic letter. I don't know if you have any information on

45 1 the status of that. Is that something the staff is pursuing, or are they no longer 2 pursuing a generic letter to update coping analyses?

3 MR. WILSON: Actually, we were, we have evaluated looking, 4 looking into going to the rulemaking as what we have looked at. So that is 5 something that the staff is still looking, and we'll pass the data that we have on to 6 the 30 day look team --

7 CHAIRMAN JACZKO: Okay.

8 MR. WILSON: We do have, we do have some data that we've 9 done and that data will be passed on to the, to the look team. And I was not 10 aware of a generic letter. We were looking at a lot of data that we had received, 11 both from FERC and NERC, and some of the NUREG studies, and looking to 12 see whether or not we had to go after rulemaking and --

13 CHAIRMAN JACZKO: Okay.

14 MR. WILSON: -- enhance the station blackout rule itself.

15 CHAIRMAN JACZKO: So that is, that is effectively ongoing at this 16 point, although not at a, maybe not gotten to a --

17 MR. WILSON: Yes, we're still, we're still accumulating data.

18 CHAIRMAN JACZKO: Okay. Good. Thanks. To what, and we've 19 talked a little bit about, kind of from the external perspective, what the station 20 blackout does, but I wanted to explore just an issue of, obviously, a significant 21 consideration that we've seen from Japan is the impact on spent fuel pools. And 22 to what extent are the spent fuel pools and the limited power needs that they may 23 have included in the station blackout considerations. Is that a piece of it, or is it 24 just the core?

25 MR. WILSON: No, the station blackout rule did not evaluate the

46 1 spent fuel pool cooling, so that was not part of the rule itself. That was one of the 2 reasons that we had added the other portion, and had Eric go over some of the 3 B.5.b strategy, because that specifically evaluated the spent fuel pool.

4 CHAIRMAN JACZKO: They, maybe under severe -- I mean, are 5 there procedures, maybe under severe accident, or under, I guess it would be 6 more under the B.5.b, to provide power to, to whatever systems are necessary 7 for circulation in the pools? Do those procedures exist more on a kind of a 8 severe accident perspective, or?

9 MR. WILSON: Well, I have some rough data that, we have 10 conducted a survey of the spent fuel pools. It was done in the mid-90s, and 11 about a third of the plants, the spent fuel pools themselves are actually on a --

12 the back-up power is the diesel generator, so they're actually on the safety 13 buses. They're manually loaded, so they are on a safety-related power supply.

14 A large number of the other ones actually have RHR as a back-up to provide 15 spent fuel pool cooling or make-up, so RHR is a safety-related system, then that 16 would be the back-up of the diesel.

17 And then there's several others that they can put a spool piece in to 18 cross-connect systems, to provide additional cooling and make-up mechanisms.

19 So we did look at that in the 90s and evaluate that. So there are ways that they 20 could transfer power, since they could get the battery backup, or a system that is 21 powered by the 1E safety-related system, to provide that. So that has been 22 looked at.

23 CHAIRMAN JACZKO: All right. And then, just turn to the last 24 question. And maybe it, almost may be the opposite of, the flip side of what 25 Commissioner Apostolakis raised, which is: to what extent are we, and how are

47 1 we modeling station blackout in some of the risk assessments that we do? Do 2 we have a good way to model these kinds of events as we look at our severe 3 accident and the, I mean, particular in the PRA? How exactly do we model these 4 kind of events? And I think, hinting from Commissioner Apostolakis, we don't 5 necessarily look beyond 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for this kind of situation, into the longer, longer 6 time frame. And is that a non-conservatism or a conservatism in the PRA 7 analysis that we have.

8 MR. HARRISON: The way that the point-specific PRA's are 9 developed, the key becomes the probability of recovery of off-site power, 10 ultimately. I know back in the '80s, it was, like, 50 percent of all events were 11 recovered in the first half-hour, and it kind of works down from there. So, and 12 most of the data says that at least prior from my past, we had no events that 13 went beyond like 10 or 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, or something like that. So that gives you a tail 14 of the curve on the recovery curve.

15 So most PRAs run for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mission times, if there's some critical 16 issue that occurs after that, they may run to 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />, or something like that. But 17 what they're looking for is reaching a safe, stable condition at the plant, so if I can 18 -- I got power back or I've got some capability where I can maintain that, then 19 they'll stop the analysis and declare it successful. What that will mean is if you're 20 into an extended outage after an earthquake or whatever, you're going to have to 21 provide fuel to the diesels, and in that situation it's determined that, within a day, 22 you can get those supplies there. Or, within eight hours, you'll be able to get that 23 fuel supply to the plant and be able to provide it. So, that's an inherent 24 assumption, I would say, that's underneath the PRA: that those capabilities will 25 be there.

48 1 CHAIRMAN JACZKO: As we go forward, I mean, and again, as we 2 get more information and the task force is looking at this kind of things, I mean, 3 that obviously would probably be relevant data inputs to see if some of those 4 assumptions are no longer unnecessarily valid as we go forward. So, again, we 5 appreciate your information. I don't know if anyone has any other questions.

6 Commissioner Magwood?

7 COMMISSIONER MAGWOOD: Just a quick question about Japan.

8 One of the things about the early portions of the events in Japan that was a bit 9 frustrating was recognizing that the Japanese were unable to provide emergency 10 power to the plant and weren't able to connect the -- they brought generators in 11 but couldn't get them connected. Do we have any more insight or understanding 12 as to what the problem was in the early days of the event?

13 MR. BORCHARDT: I don't have a definitive answer. It's another 14 one of those areas where we don't have clear information, but we do have good 15 indication that the switch gear on the lower elevations of the building were 16 severely affected by the tsunami, and that probably, and this is just my opinion, 17 probably caused serious degradation to the electrical distribution within the plant.

18 So even if you had an electrical supply, the temporary generator, there's no place 19 to make an easy connection.

20 CHAIRMAN JACZKO: Any other questions?

21 COMMISSIONER APOSTOLAKIS: I'd like to make one brief 22 comment. The key in developing the accident sequence in a station blackout is 23 the recovery of off-site power, as Donnie mentioned. The 0.9 to two hours range 24 that you mentioned referred to routine failures of the grid. People now have two 25 separate curves, which goes back to your question, Mr. Chairman. There is one

49 1 curve for recovery from these routine events, and another one from major 2 external events. And that time goes much longer than two hours. So the four 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> which was conservative I guess applies only to the routine events and not 4 to the longer.

5 CHAIRMAN JACZKO: Well, again, I thank you all for your insightful 6 information, and its given us lots of things to think about. And we'll adjourn now 7 and have just a brief closed portion to discuss some of the B.5.b. issues. Thank 8 you.

9 [Whereupon, the proceedings were concluded]