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Minutes of ACRS Regulatory Policies and Practices Subcommittee Meeting - May 15, 2018
	ML18324A597
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Issue date:	11/20/2018
From:	Quynh Nguyen; Advisory Committee on Reactor Safeguards
To:	; Advisory Committee on Reactor Safeguards
	Nguyen Q
References
	Download: ML18324A597 (129)
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UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 November 20, 2018 MEMORANDUM TO: ACRS Members FROM: Quynh Nguyen, Senior Staff Engineer /RA/

Technical Support Branch, ACRS

SUBJECT:

CERTIFIED MINUTES OF THE ACRS REGULATORY POLICIES AND PRACTICES SUBCOMMITTEE MEETING ON MAY15, 2018 The minutes of the subject meeting were certified on August 16, 2018, as the official record of the proceedings of that meeting. Copies of the certification letter and minutes are attached.

Attachments: As stated cc w/ att. A. Veil M. Banks

UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 MEMORANDUM TO: Quynh Nguyen, Senior Staff Engineer Technical Support Branch, ACRS FROM: Walter Kirchner, Chairman Regulatory Policies and Practices Subcommittee

SUBJECT:

CERTIFICATION OF THE MINUTES OF THE REGULATORY POLICIES AND PRACTICES SUBCOMMITTEE MEETING ON MAY15, 2018 I hereby "certify" the minutes of the May 15, 2018 ACRS Regulatory Policies and Practices Subcommittee meeting on the Clinch River Early Site Permit, noting that there is a factual error on p. 63, line19, of the transcript regarding allowable exposures at the LPZ boundary:

"An individual located at any point on the outer boundary of low population zone who is exposed to the radioactive cloud resulting from postulated fission product release during the entire period of its passage would not receive a radiation dose in (19) excess of 35 rem TEDE."

The correct value from 10 CFR 50.34 (a)(1)(ii)(D)(2) is 25 rem TEDE.

Otherwise I find the minutes complete and technically accurate.

I hereby certify, to the best of my knowledge and belief, that the minutes of the subject meeting are an accurate record of the proceedings for that meeting.

/RA/ August 16, 2018 Walter Kirchner, Chairman Dated Regulatory Policies and Practices Subcommittee

Certified on: August 16, 2018 Certified by: Walter Kirchner ADVISORY COMMITTEE ON REACTOR SAFEGUARDS MINUTES OF THE REGULATORY POLICIES & PRACTICES SUBCOMMITTEE MEETING May 15, 2018 The ACRS Plant Operations and Fire Protection Subcommittee held a meeting on May 15, 2018 in T2-B1, 11545 Rockville Pike, Rockville, Maryland. The meeting convened at 8:30 AM and adjourned at 10:39 AM.

The entire meeting was open to the public.

No written comments or requests for time to make oral statements were received from members of the public related to this meeting.

ATTENDEES ACRS Members/Consultants/Staff WALTER L. KIRCHNER, Chairman PETER RICCARDELLA, Member-at-Large RONALD G. BALLINGER, Member HAROLD B. RAY, Member*

STEPHEN P. SCHULTZ, Consultant QUYNH NGUYEN, Designated Federal Official Other

Participants:

ANDY CAMPBELL, NRC ALLEN FETTER, NRC JENNIE RANKIN, NRC MARY RICHMOND, Bechtel RAY SCHIELE, Tennessee Valley Authority MALLECIA SUTTON, NRC RAO TAMMARA, NRC ROBERT TAYLOR, NRC ALEX YOUNG, Tennessee Valley Authority

Present via telephone

SUMMARY

The purpose of this meeting is the review of selected sections (2.2, Nearby Industrial Transportation and Military Facilities; 3.5.16, Aircraft Hazards; and 15.1, Accident Analysis) of Tennessee Valley Authoritys (TVA) Clinch River Early Site Permit (ESP) application. The meeting transcripts are attached and contain an accurate description of each matter discussed 1

during the meeting. The presentation slides and handouts used during the meeting are attached to these transcripts.

SIGNIFICANT ISSUES Reference Pages Issue in Transcript Aircraft Hazards: Qualitative arguments show why design basis accident of 10-6 (instead of 10-7) is acceptable because these numbers are based 24-26; 46; 54-56 on actual data.

Chairman Kirchner makes a point that the source term is from a reactor module (and does not account for common cause failure). For their calculations, TVA used the most conservative (e.g., largest power) 30-34 design of the proposed vendors in the plant parameter envelope.

Consultant Schultz had follow-up questions.

Chairman Kirchner inquired about the 25mrem threshold. 31; 63 Mr. Tammara begins his presentation. The NRC staff has never licensed a LPZ of 1-mile but has for 2 miles (43). There is a permit 37 condition for a proposed airport in 2022 (46). There is a permit condition associated with potential toxic chemicals (48).

Documents provided to the Subcommittee

REFERENCES:

1. Safety Evaluation: Geography & Demography (2.1); Nearby Industrial, Transportation and Military Facilities (2.2); ML18102B203

2. Safety Evaluation: Aircraft Hazards (3.5.1.6) ML18102B149

3. Safety Evaluation: Accident Analysis (15.1) ML18102B150 2

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

ACRS Regulatory Policies & Practices Subcommittee Docket Number: N/A Location: Rockville, Maryland Date: May 15, 2018 Work Order No.: NRC-3729 Pages 1-75 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +

7 REGULATORY POLICIES & PRACTICES SUBCOMMITTEE 8 + + + + +

9 TUESDAY 10 MAY 15, 2018 11 + + + + +

12 ROCKVILLE, MARYLAND 13 + + + + +

14 The Subcommittee met at the Nuclear 15 Regulatory Commission, Two White Flint North, Room 16 T2B2, 11545 Rockville Pike, at 8:30 a.m., Walter L.

17 Kirchner, Chairman, presiding.

18 COMMITTEE MEMBERS:

19 WALTER L. KIRCHNER, Chairman 20 PETER RICCARDELLA, Member-at-Large 21 RONALD G. BALLINGER, Member 22 HAROLD B. RAY, Member*

23 24 ACRS CONSULTANT:

25 STEPHEN P. SCHULTZ NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 1 DESIGNATED FEDERAL OFFICIAL:

2 QUYNH NGUYEN 3

4 ALSO PRESENT:

5 ANDY CAMPBELL, NRC 6 ALLEN FETTER, NRC 7 JENNIE RANKIN, NRC 8 MARY RICHMOND, Bechtel 9 RAY SCHIELE, Tennessee Valley Authority 10 MALLECIA SUTTON, NRC 11 RAO TAMMARA, NRC 12 ROBERT TAYLOR, NRC 13 ALEX YOUNG, Tennessee Valley Authority 14 15 *Present via telephone 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 1 T-A-B-L-E O-F C-O-N-T-E-N-T-S 2

3 PAGE 4 Opening Remarks 5 by W. Kirchner . . . . . . . . . . . . . . 4 6 Introductions and Overview 7 by R. Taylor . . . . . . . . . . . . . . . 7 8 Selected Safety Evaluation Sections 9 by R. Schiele . . . . . . . . . . . . . . . 9 10 Selected Safety Evaluation Sections, NRC 11 by A. Fetter and S. Tammara . . . . . . . . 35 12 Chapter 15, Accident Analysis 13 By S. Tammara . . . . . . . . . . . . . . . 62 14 Opportunity for Public Comments . . . . . . . . . 75 15 Adjourn . . . . . . . . . . . . . . . . . . . . . 75 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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4 1 P R O C E E D I N G S 2 (8:29 a.m.)

3 CHAIRMAN KIRCHNER: The meeting will now 4 come to order. This is a meeting of the Regulatory 5 Policies and Practices Subcommittee of the Advisory 6 Committee on Reactor Safeguards.

7 I'm Walt Kirchner, Chairman of this 8 Subcommittee meeting. ACRS Members in attendance 9 today are Ronald Ballinger and myself. We are 10 expecting Margaret Chu and Harold Ray may join us on 11 the phone.

12 Quynh Nguyen of the ACRS staff is the 13 designated federal official for this meeting. And I 14 might point out if you're interested in thermal-15 hydraulics this is the wrong meeting. It's next door 16 where we're doing a hearing for Brunswich MELLLA+, the 17 Thermal-hydraulics Subcommittee.

18 On November 15, 2017, we heard and were 19 presented a general overview of this application.

20 Today the Subcommittee will hear from representatives 21 of TVA and the staff regarding selected sections of 22 TVA's Clinch River Early Site Permit application and 23 the corresponding safety evaluations as follows.

24 Geography and Demography, 2.1. Nearby 25 Industrial Transportation and Military Facilities, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 2.2. Aircraft Hazards, 3.5.1.6 and Accident Analysis, 2 15.1. The Committee will gather information, analyze 3 relevant issues and facts and formulate proposed 4 positions and actions as appropriate for deliberation 5 by the full Committee.

6 And I might point out we're joined by Pete 7 Riccardella. And a slight oversight, I failed to 8 mention that we also have Steve Shultz with us as a 9 consultant to the ACRS.

10 The ACRS was established by statute and is 11 governed by the Federal Advisory Committee Act. This 12 means that the Committee can only speak through its 13 published letter reports. We hold meetings to gather 14 information to support our deliberations.

15 Interested parties who wish to provide 16 comments can contact our offices requesting time after 17 the meeting announcement is published in the Federal 18 Register. That said, we also set aside some time for 19 spur of the moment comments from members of the public 20 attending or listening to our meetings.

21 Written comments are also welcome. In 22 regard to early site permits, 10 CFR 52.23 provides 23 the Commission, provides that the Commission shall 24 refer a copy of the application to the ACRS and the 25 Committee shall report on those portions which concern NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 safety.

2 The ACR section of the US NRC public 3 website provides our charter, bylaws, letter reports 4 and full transcripts of all full and subcommittee 5 meetings including slides presented at the meetings.

6 The rules for participation in today's meeting were 7 previously announced in the Federal Register.

8 We have received no written comments or 9 requests for time to make oral statements from members 10 of the public regarding today's meeting. We have a 11 bridge line established for interested members of the 12 public to listen in.

13 To preclude interruption in the meeting 14 the phone bridge will be placed in the listen-in mode 15 during the presentations and any discussions. We will 16 unmute the bridge line at a designated time to afford 17 the public an opportunity to make a statement or 18 provide comments.

19 At this time I request that the meeting 20 attendees and participants silence their cell phones 21 and any other electronic devices that may be audible.

22 A transcript of the meeting is being kept and will be 23 made available as stated in the Federal Register 24 notice.

25 Therefore, we request that participants in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 this meeting use the microphones located throughout 2 the meeting room when addressing the Subcommittee.

3 The participants should first identify themselves and 4 speak with sufficient clarity and volume so that they 5 may be readily heard.

6 Make sure that the green light of the 7 microphone is on before speaking and off when not in 8 use. We will now proceed with the meeting. And I 9 call upon Robert Taylor, senior management of NRO to 10 begin, Robert.

11 MR. TAYLOR: Good morning. Can you hear 12 me?

13 CHAIRMAN KIRCHNER: Yes.

14 MR. TAYLOR: Good morning and thank you, 15 Mr. Chairman. It is a pleasure for the staff to come 16 before the ACRS today to present the first chapters in 17 its review of the Clinch River Early Site Permit.

18 My name is Rob Taylor and I'm the acting 19 director of NRO's Division of New Reactor Licensing.

20 As you indicated, on November 15th last year the NRC 21 staff presented to the ACRS full Committee on the 22 early permit site review process, the plant parameter 23 envelope concept and the review status/schedule for 24 the Clinch River ESP review.

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8 1 nuclear site features and their ESP application.

2 Today's presentation is the next step in our process 3 before the ACRS on the results and the status of this 4 review.

5 The staff and TVA have made substantial 6 progress on the Clinch River ESP and today's 7 presentation is a reflection of that good work. The 8 chapters being presented today have developed safety 9 evaluations with no open items.

10 The fact that there are no open items is 11 a reflection on the thoroughness of the staff's review 12 and TVA's responsiveness to the staff inquiries as we 13 have worked through the issues. This is the first ESP 14 for a small modular reactor plant design which has 15 presented unique and novel items for the Applicant and 16 the NRC.

17 Despite this, we are pleased to report 18 that the review is progressing on schedule. We 19 anticipate that we will back before the Subcommittee 20 for meetings on the other SEs under development in the 21 August and October time frame this year.

22 Our goal is to have ACRS full Committee 23 meetings in November or December of this year. With 24 that, the staff looks forward to a fruitful dialogue 25 with the ACRS today. So thank you and we look forward NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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9 1 to the discussion.

2 CHAIRMAN KIRCHNER: Okay, thank you.

3 We'll turn now to the Applicant and Raymond Schiele 4 from TVA. Please proceed.

5 MR. SCHIELE: Good morning. (Off 6 microphone comments). I'd like to introduce the team 7 supporting us today. We've got Alex Young, TVA 8 Engineer; Rachel Turney-Work, supporting 2.1, 9 Geography & Demography. We have Mary Richmond and 10 Becky Carr and Karene Riley supporting the remaining 11 sections.

12 I've been in the industry for about four 13 years, submarines, Calvert Cliffs operations for 16, 14 SRO shift manager. And for the last 20 I've been 15 managing large licensing projects and I've had the 16 pleasure since 2016 of supporting the Clinch River SMR 17 ESPA application.

18 First, a little bit about TVA, TVA's 19 mission. TVA is a partner with 154 local power 20 companies serving over nine million people, 700,000 21 businesses in parts of seven states directly serving 22 56 large industries and federal installations.

23 Just a quick visual of what this looks 24 like. This is a map showing the gray area is the 25 watershed to show you where the current fleet nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 sites are right now, Browns Ferry, Watts Bar and 2 Sequoyah and where the Clinch River site is in 3 relation to that.

4 A brief overview of application 5 development. In 2014, TVA decided to pursue an early 6 site permit application. In 2010 to 2015, they did 7 site characterization.

8 We submitted the ESPA in May of 2016. NRC 9 accepted review in December of 2016. Last summer at 10 this time we supported lots of audits. The Rev. 1 for 11 the ESPA was submitted in December of 2017 and we've 12 been supporting RAIs from early fall in 2017 to as 13 recently as early this spring in 2018 QA.

14 This is a high level picture of the status 15 of the original schedule for both the NRC safety 16 review and the NRC environmental review. You can see 17 the original schedule had us possibly dealing in late 18 2018 with no open items.

19 We have, as Rob said, the schedule, we're 20 on schedule maybe a little ahead of that. We're 21 having the first ACRS meeting in middle of 2018. So 22 the safety review is going well.

23 Also the environmental review is going 24 very well too. We're in the middle of the DEIS 25 review. That review is scheduled to conclude the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 first week of June.

2 Chapter 2, Section 2.1, Geography &

3 Demography. Clinch River site, the site is 935 acres.

4 It's adjacent to the Clinch River arm of the Watts Bar 5 Reservoir and on the north it's bordered by the Oak 6 Ridge Laboratory property.

7 It's in the City of Oak Ridge in Roane 8 County, Tennessee. These geography distances are 9 approximate to the City of Kingston, Harriman, Lenoir 10 City and Knoxville.

11 The land is owned by the US government and 12 managed by TVA as an agent of the federal government.

13 Here is an illustration of the property where the one 14 mile LPZ is and a five mile radius.

15 As you can see, it's, you can see the 16 illustration of the river around three sides, east, 17 west and south with the Oak Ridge property to the 18 north. Within that one mile there are no hospitals, 19 prisons, jails in the LPZ and no transient population 20 events or attractions in that area.

21 This is an illustration of the EAB. The 22 EAB is the site boundary. And this is a radius that 23 shows zero to two miles. That's the big blue circle.

24 The red outline is the Clinch River property line.

25 The Clinch River site is internal to that.

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12 1 The property is about 1,200 acres. The site is 935.

2 So this section right here if you sort of cut it off 3 a little bit right here, that would be the difference 4 between the site and the property boundaries.

5 MR. SCHULTZ: What are the facilities 6 within the five mile radius? Do you have --

7 MR. SCHIELE: That's a slide coming up.

8 MR. SCHULTZ: Thank you.

9 MR. SCHIELE: Sure. Population 10 distribution, this is a slide illustrating the, so the 11 dark blue in the center is ten miles and the lighter 12 blue larger one is ten to 50.

13 So we did an evaluation of the population 14 projected out to the 50 mile radius. The years for 15 the selection for the census was 2010. The 16 calculation development year was 2013. And the two 17 dates of interest is the 2021 start of construction 18 and 2027 start of operation.

19 CHAIRMAN KIRCHNER: May I ask how many 20 people are within the darker blue ten mile sector?

21 MR. SCHIELE: I have that number here 22 somewhere. Rachel, do you have that number quickly 23 inside the ten mile?

24 CHAIRMAN KIRCHNER: I see it there for the 25 other sectors. I was just curious if it was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 comparable number.

2 MR. SCHIELE: There was another slide like 3 this with ten miles blown up that shows. I don't have 4 those numbers. I can get you that.

5 CHAIRMAN KIRCHNER: Please proceed.

6 MR. SCHIELE: This is an illustration of 7 population center boundaries. Population centers, as 8 defined by 10 CFR 100.3, are densely populated 9 clusters with more than 25,000 people.

10 There are two centers that were of 11 significance, the Knoxville area and the Cleveland 12 area. The Knoxville is about 4.8 miles from the site 13 and the Cleveland area is about 45 miles.

14 So on this picture you'll see Knoxville 15 right there and Cleveland is right at the corner of 16 the picture down here. And yellow star is the site.

17 (Off microphone comment) 18 MR. SCHIELE: This is the urban areas 19 right which is a large vicinity. It's 4.8 miles 20 southeast at the very edge of the urban area, correct.

21 Yes, go ahead, Rao.

22 MR. TAMMARA: My name is Rao Tammara. The 23 SSAR table --

24 CHAIRMAN KIRCHNER: And who you are with?

25 MR. TAMMARA: I am with the NRO. I am NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 also a technical reviewer for 2.1 on staff. Table 2 2.1-2 gives the summary of the total population for 3 2010 within zero to ten miles is 67,203.

4 CHAIRMAN KIRCHNER: Thank you.

5 MR. SCHIELE: Thank you, Rao. Population 6 density, per Reg Guide 4.7 site suitability criteria 7 for nuclear power stations densities were calculated 8 for the 50 mile region for these three time periods, 9 the projected start of construction, the projected 10 commencement of operation and at the end of the 11 operation date, 2067.

12 The total projected population, the total 13 projected transient population were totaled to be able 14 to come up with a population density. The 2021 and 15 2027 population density, as projected on these 16 numbers, is 247 for 2021, 261 people per square mile 17 for 2027.

18 To note, this is less than the densities 19 that are recommended to be maintained for Reg Guide 20 4.7. That threshold is 500 people per square mile.

21 Go on to Section 2.2, Industrial, 22 Transportation and Military Facilities. The purpose 23 of this section is to establish whether the effects of 24 potential accidents in the vicinity of the site from 25 present and projected industrial, transportation, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 military facilities should be used in design basis 2 events for plant design parameters for selected 3 accidents.

4 Within this area of five miles there is 5 one navigable waterway, one major highway, four major 6 roads, a minor rail line, two natural gas pipelines 7 all within five miles. Additional facilities were 8 evaluated beyond ten miles that were significant 9 enough to be considered for further review.

10 No identified roads, railways or navigable 11 waterways at distances greater than ten miles posed 12 significant potential hazards. In addition, the 13 products and materials associated with these 14 industrial facilities or transportation routes were 15 evaluated.

16 Here's an illustration of the industrial 17 facilities that were evaluated. The inner circle here 18 is five miles. Inside that circle is the Oak Ridge 19 Laboratory.

20 The next circle is ten miles. And you'll 21 see one. That's the Kingston Fossil Plant. Outside 22 of ten miles, between ten and 20 you will see the Oak 23 Ridge Water Treatment Plant, the Bull Run Fossil Plant 24 and the Hallsdale Power Utility District Melton Hill 25 Water Treatment Plant.

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16 1 Transportation routes and natural gas 2 pipelines. This slide illustrates location and you 3 will see a five mile radius there of the Clinch River 4 arm of the Watts Bar Reservoir.

5 So the actual waterway, that's a boundary 6 and it's also a transportation route. You'll see two 7 gas pipelines. Here's a six inch pipeline right here.

8 Here's a 22 inch pipeline.

9 Major transportation routes, Tennessee 10 Interstate 40 on this illustration if you look right 11 here this would be going to Knoxville. And on the 12 other side this would be going to Nashville.

13 One other point on here is there's two 14 railroads. At the top of the screen you'll see the 15 Norfolk Southern Railroad. There's actually two arms 16 to that.

17 One is outside this picture, it's at nine 18 miles. This is, the closest is about at 6.5 miles.

19 There's also a minor railroad, the Heritage Railroad 20 right here.

21 The next slide is airports and airways.

22 On this slide you'll see two federal airways, V16 and 23 J46. That's this green line here and the dark blue 24 line there.

25 Also as illustrated is, there's five NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 private airports within ten miles and there's two 2 private airports outside of ten miles. So this list 3 right here Big T, Wolf Creek, Cox, these are all these 4 little blue dots inside of ten miles.

5 There's two outside of ten miles. You'll 6 see at the bottom of the screen Ferguson Flying Circus 7 and the other one, I apologize, when I put the white 8 box here for the legend it covered up this other 9 private airport.

10 The name of it is Oliver Springs and 11 they're about 180 degrees from other on the screen.

12 So the two outside of ten are Oliver Springs and 13 Ferguson Flying Circus.

14 CHAIRMAN KIRCHNER: Does Knoxville have a 15 major airport?

16 MR. SCHIELE: Knoxville does have a major 17 airport. It supplies, it's called the Metropolitan 18 Knoxville Airport Authority. And I don't know how 19 many --

20 CHAIRMAN KIRCHNER: It's well outside the 21 ten mile.

22 MR. SCHIELE: On this map it would be --

23 CHAIRMAN KIRCHNER: Far to the right.

24 MR. SCHIELE: Yes, okay. Evaluation of 25 potential accidents. Reg Guide 1.206 discusses NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 accidents that have a probability of occurrence of, or 2 in the order or magnitude 10-7.

3 The accident categories that were selected 4 to evaluate this threshold were chemical releases, 5 explosions, flammable vapor clouds, toxic chemicals 6 and fires, collisions with the intake structure, 7 aircraft hazards and liquid spills.

8 As we saw in the earlier slide, five 9 facilities were selected as storage facilities for 10 this evaluation. And, oops, the transportation routes 11 that were evaluated were both pipelines, Interstate 40 12 and the two federal airways.

13 The effects of the design basis events 14 were as follows. The evaluations that were performed 15 for hazards nearby the Clinch River site, it included 16 accidents involving explosions, flammable vapor 17 clouds, collisions with the intake and liquid spills 18 do not pose a threat to the Clinch River site.

19 However, evaluation of the potential 20 effect of toxic chemical releases from both industrial 21 facilities and transportation routes concluded that 22 with the exception of anhydrous ammonia and chlorine 23 the distance to the toxic in points are less than the 24 distance to the power block area. So we're okay.

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19 1 will be reperformed at the time of COLA for anhydrous 2 ammonia and chlorine. Because this was a PPE and no 3 specific design was picked there is no specific 4 location on site for the control room. So the control 5 room had the ability to be reevaluated during the 6 COLA.

7 As far as chemical releases on site, once 8 again because it was a PPE there is not a specific 9 design. So the effects of a release on site will be 10 reevaluated with the COLA, okay.

11 Chapter 3, Section 3.5.1.6, Aircraft 12 Hazards. NUREG-0800 standard review plan --

13 MR. SCHULTZ: Just a question, Ray.

14 MR. SCHIELE: Go ahead.

15 MR. SCHULTZ: On the highway 16 transportation routes and potential chemical releases, 17 TVA has done other evaluations for other sites I 18 presume.

19 MR. SCHIELE: Correct.

20 MR. SCHULTZ: Of a similar nature. Is 21 there any particular reason why the situation at this 22 site would be different from what you've analyzed 23 before for control room habitability?

24 MR. SCHIELE: I imagine there would be 25 some precedence. But the fact that this is such a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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20 1 remote location. I'll ask Mary Richmond if she wants 2 to add to this.

3 MR. SCHULTZ: That's one reason I'm 4 asking.

5 MR. SCHIELE: Yes. And the I-40 is the 6 major route for evaluation where we are. I don't know 7 if there's any precedent for like what was evaluated 8 for Sequoyah or Watts Bar. Mary, can you add anything 9 to that?

10 MS. RICHMOND: One of the issues was that 11 I-40 is the closest and it's a major route. So we 12 were being --

13 CHAIRMAN KIRCHNER: May, sorry to 14 interrupt. Would you fully identify yourself?

15 MS. RICHMOND: I'm sorry, Mary Richmond, 16 Bechtel. Interstate 40 is the major route between.

17 So we were very careful and we did it very 18 methodically taking the chemicals.

19 As you saw, there are some water treatment 20 plants in the area that store chlorine. And there's 21 also fossil fuel plants that use anhydrous ammonia for 22 part of their selective catalytic reduction system to 23 remove the NOX.

24 So that was identified and we analyzed it.

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21 1 clouds it's canceled out except for the toxicity 2 analysis because both of those chemicals are very 3 highly volatile toxic chemicals.

4 So they were removed for, at COLA stage 5 because the distance ideology is greater so we can 6 look at the control room habitability in greater 7 detail. That's not unusual.

8 There are some other plants that control 9 room habitability analysis was done for those 10 chemicals.

11 CHAIRMAN KIRCHNER: Thank you.

12 MR. SCHIELE: Thank you, Mary. Aircraft 13 Hazards, NUREG-0800 standard review plan establishes 14 the criteria for evaluating hazards, 10-7 is the 15 threshold that needs to be considered.

16 Using proximity criteria TVA performed a 17 screening analysis to establish whether the 18 probability of aircraft hazards, accidents rather, for 19 the proposed site would be less than the order of 20 magnitude of 10-7 by inspection.

21 Criterion 1, this was basically plant to 22 airport distance and number of operations. Based on 23 the five small privately owned airports between five 24 and ten miles and the two privately owned airports 25 between ten and 15 miles, the evaluation was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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22 1 performed.

2 The projected number of operations is less 3 than the threshold for Criterion 1. Therefore, 4 Criterion 1 was determined to have been met for 5 aircraft operations and no further evaluation was 6 required.

7 Criterion 2, this criterion is based on 8 the five statute mile distance to the nearest edge of 9 military training routes including low level routes 10 and the location of military operating areas. The 11 site is about 19 miles from the center line of 12 training route IR2 and about 36 miles from the 13 Snowbird military operating area.

14 Based on this separation it was determined 15 that Criterion 2 was met and no further evaluation was 16 required. Criterion 3, Criterion 3 is based on at 17 least two statute miles beyond the edge of the nearest 18 federal airway.

19 I will go back to the airway slide real 20 quick because we're going to talk about this. So you 21 can see the two federal airways within, that's the 22 five mile radius, that's the smaller radius.

23 The criterion is two statute miles. The 24 federal airway is from center line, four on either 25 side of center line. That's an eight mile path.

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23 1 So based on the location of the site and 2 these two airways we did not meet Criterion 3. So 3 further evaluation was required. I'll get back to 4 that.

5 So a detailed aircraft hazard analysis was 6 performed. The results of the analysis showed that 7 based on the probabilities of a hazard and the 8 probabilities of the dose consequences associated with 9 that hazard that it was 10-6 with a realistic 10 probability that it was actually lower based on 11 qualitative arguments.

12 Therefore, the effect of aircraft hazards 13 for this section is met.

14 CHAIRMAN KIRCHNER: Would you elaborate, 15 Ray, for the record on what you mean by qualitative 16 arguments? Normally the criterion is 10-7. Isn't 17 that correct?

18 MR. SCHIELE: It's 10-7 for the hazard.

19 CHAIRMAN KIRCHNER: And you had a number, 20 I won't recite the number. But it was, I'm glad to 21 see you rounded it off.

22 MR. SCHIELE: 10-7 was for the hazard.

23 For the dose consequences associated with the hazard 24 it was 10-6. So the full evaluation, and I'll let 25 Mary Richmond from Bechtel elaborate on this, the full NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 evaluation showed that based on the qualitative 2 argument and meeting 10-6 on the order of 10-6 was met.

3 Mary, do you want to add to that?

4 MS. RICHMOND: I'm Mary Richmond, Bechtel.

5 Basically the 10-7 order of magnitude is for the 6 probability of occurrence with those consequences 7 exceeded.

8 However, in the guide in NUREG-0800 and 9 also in the design specific standard review for the 10 SMRs there is an allowance because when you're talking 11 about probabilities that low and the data available, 12 and I'll talk a little bit more about the data 13 availability for aircraft crashes, 10-6 per year is 14 acceptable if combined with reasonable qualitative 15 arguments you can show that the realistic probability 16 is lower.

17 So the 10-7 number a little bit over the 18 order of magnitude that was calculated, was a very 19 conservative number. So for example, some of the 20 qualitative arguments that we've presented in the SSAR 21 include we were doing a bounding building for a PPE 22 because at this time a design isn't selected.

23 So we chose a PP height, for example, of 24 160 feet and that was red, like we put a box around 25 the plan. So that's a very high height for a reactor.

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25 1 So if you were to like lower the height the "R" 2 probability would be lower to that order of magnitude.

3 Another example of making the 4 probabilistic value a little more realistic is we 5 conservatively included the rad waste building because 6 at the time we're not, we don't know. But that was 7 included.

8 If the rad waste building was not included 9 in the boxed area we would also be down to the 10-7 10 order of magnitude. Probably one of the most 11 conservatisms when Rao talks this afternoon is the FAA 12 data for the air traffic on the airway is not 13 available.

14 So we looked at the major airports serving 15 those airways and we put 50 percent of that, those 16 operations on the airway because that's what was 17 available. If you lower that, those numbers you're 18 going to see a much reduced result of the probability 19 of an aircraft crash.

20 Also at the time again because we just 21 have a box, there was no credit taken for skid 22 distances because that's one of the effective areas 23 about the skid. And the design, so there's probably 24 going to be at least an obstruction to one side that's 25 protected in the safety related structures.

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26 1 I'm not giving credit for it. None of 2 those were credited. So those were the qualitative 3 arguments that were included. We were just over that 4 10-7 and we think with these qualitative arguments we 5 can show that it's below.

6 CHAIRMAN KIRCHNER: Does the Knoxville 7 airport feed into this set of airways?

8 MR. SCHIELE: By distance, no, because 9 this is --

10 CHAIRMAN KIRCHNER: No, I didn't express 11 that well. Do, with their landing and take off 12 patterns, do they then feed into these air routes or 13 are these the 30,000 and above air routes?

14 MR. SCHIELE: You're talking about the 15 two, V16 and J46?

16 CHAIRMAN KIRCHNER: Yes.

17 MR. SCHIELE: Yes. I would have to look 18 that up. I'm not sure. Mary, do you know that?

19 MS. RICHMOND: Right. The number of 20 operations that we used, we did use the Knoxville-21 McGhee Tyson Airport because they do feed into that.

22 So that's one reason why our numbers are high is 23 because those number of operations are very high.

24 MEMBER BALLINGER: On this map do you show 25 the holding patterns?

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27 1 MR. SCHIELE: No.

2 MEMBER BALLINGER: So if you superimpose 3 the holding patterns on this, where are they?

4 MR. SCHIELE: So this --

5 MEMBER BALLINGER: I've sat in the 6 Knoxville Airport with a tornado coming through in a 7 holding pattern and I can tell you that the 8 probability of an incident in that set of 9 circumstances has got to be higher than just landing 10 and taking off.

11 MR. SCHIELE: This is a fairly small 12 circle here because this is five and ten miles. And 13 Knoxville is way off the map here.

14 MEMBER BALLINGER: Okay, because these 15 holding patterns are generally like a 20 mile race 16 track, right. I'm just wondering if they overlap.

17 MR. SCHIELE: I'm not sure, but I can find 18 out. Okay.

19 MEMBER BALLINGER: Harold has sent me a 20 couple of emails. He's been trying to talk and not 21 being able to get through. He says that Ron is 22 working on it but apparently it's not working.

23 CHAIRMAN KIRCHNER: Has he sent you 24 questions?

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28 1 questions.

2 MEMBER RAY: Can you hear me okay now?

3 CHAIRMAN KIRCHNER: Yes, Harold. Would 4 you like to ask any questions at this point?

5 MEMBER RAY: That's all right. We're well 6 down the road. It's fine. I just want to make sure 7 if I tried to speak that you could hear me, but we're 8 good.

9 CHAIRMAN KIRCHNER: We're working. Ray, 10 please proceed.

11 MR. SCHIELE: Thank you. Moving on to 12 Chapter 15, Transient and Accident Analysis. NEI 10-13 01 provides industry guidance for developing the plant 14 parameter envelope in support of an early site permit.

15 It gives guidance on the analysis model 16 for the time-dependent transport of radionuclides out 17 of the core through several pathways each with a 18 different time-dependent removal mechanism for 19 nuclides.

20 For the purpose of evaluating off site, 21 post-accident doses the vendor analysis with the 22 highest dose was selected for use in the site-specific 23 dose analysis. Each of the four SMR designs under 24 consideration was expected to provide advanced design 25 features that would further minimize accident NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 consequences.

2 TVA anticipates by calculation that these 3 consequences of a LOCA would be less than those for 4 the large PWR designs and that no events of greater 5 consequences will be identified. The COLA will verify 6 that the accident doses provided in the ESPA are 7 bounding or will provide an evaluation of accident 8 radiological consequences.

9 Source term, the LOCA source term selected 10 for the inclusion for the PPE was based upon vendor 11 input and represents the design with the highest 12 resulting doses. To assess the reasonableness of this 13 evaluation a comparison of the PPE LOCA source term to 14 that of the AP1000 was performed.

15 The result was the activity release 16 associated with the worst two hour time period of a 17 scaled down AP1000 is approximately 25 percent greater 18 than that of the surrogate plant. The activity 19 release for the 30 day duration of the LOCA for the 20 AP1000 is approximately equivalent to that of the 21 surrogate plant and is also considered reasonable.

22 CHAIRMAN KIRCHNER: So at this point, Ray, 23 then you're using of the four potential designs that 24 you're considering the largest single unit which is 25 800 megawatts but your site envelope is 2,000 plus NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 megawatts thermal, right?

2 CHAIRMAN KIRCHNER: So the assumed value 3 was the worst case dose, not necessarily the source 4 term. But the worst case dose from that source term 5 from all four designs.

6 So if a design had one reactor or two or 7 12, whether it would be released was using that 8 language. I can have Alex elaborate on that a little 9 more. Alex Young from TVA.

10 MR. YOUNG: So I think for a questions 11 that's revolving around the site is being licensed in, 12 excuse me, Alex Young, TVA. So I think your question 13 is revolving around the site as being licensed to 2420 14 megawatts but we're talking about the 800 megawatts 15 thermal gear.

16 So when we looked at the accident 17 scenarios we just looked at the vendor with the 18 highest dose and we just considered one unit for that 19 vendor as an accident.

20 We did not consider that multiple units 21 for that vendor are in a simultaneous accident. So 22 that's why it's looking at 800 opposed to a total of 23 2420.

24 CHAIRMAN KIRCHNER: I understand that 25 fully. I'm making a point that the assumption here is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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31 1 that you don't have common cause, common mode failure.

2 You're looking at the larger single, one single module 3 being the source of the accident.

4 MR. SCHIELE: That's correct.

5 CHAIRMAN KIRCHNER: So we'll take that up 6 with the staff.

7 MR. SCHIELE: Evaluation methodology and 8 conclusion. SMR doses for a LOCA are evaluated at 9 both the EAB and LPZ boundary. Doses are calculated 10 using a ratio of X/Q methodology which includes the 11 following parameters.

12 Short term 95th percentile accident 13 atmospheric dispersion factors for the Clinch River 14 site. Bounding vendor provided LOCA doses and X/Q 15 values associated with bounding vendor provided LOCA 16 doses.

17 The resulting accident doses are expressed 18 as a total effective dose equivalent, TEDE, consistent 19 with 10 CFR 52.17. All site LOCA doses meet the 25 20 room TEDE limit specified in 10 CFR 52.17.

21 CHAIRMAN KIRCHNER: So, Ray, again for the 22 record, what was the highest dose that you estimated 23 versus the 25 rem limit because I understand the NRC 24 policy on this is that they are not looking for 25 25 rem.

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32 1 MR. SCHIELE: Correct.

2 CHAIRMAN KIRCHNER: They're looking for a 3 considerable margin below that.

4 MR. SCHIELE: Alex, do you want to take 5 that?

6 MR. YOUNG: Sure. So out of Chapter 15 7 with the EAB the zero to two hour dose for the site 8 was estimated at or was calculated at 21.6 rem. And 9 then the 30 day dose for the LPZ was at a total of 10 2.97 rem.

11 CHAIRMAN KIRCHNER: Thank you.

12 MR. SCHIELE: That concludes TVA's 13 presentation on Sections 2.1, 2.2, 3.5.1.6 and Chapter 14 15. Are there any additional questions?

15 MR. SCHULTZ: Ray, let me back up a bit on 16 the source term. The 800 megawatt thermal that's 17 larger than some of the units that you're considering.

18 So that was just an evaluation metric that was used to 19 determine a generic source term associated with the 20 SMR, a generic SMR concept?

21 MR. SCHIELE: I'll go to Alex.

22 MR. YOUNG: Sure. So the 800 megawatts is 23 the thermal power dose associated with the largest 24 vendor that we considered out of four SMR vendors. So 25 basing on the principal core power resulting in core NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 inventory and amount of radioactive material that 2 provided the most conservative source term for us. So 3 that was the basis for the 800.

4 MR. SCHULTZ: And the evaluation of 5 release was done in what way? The evaluation of the 6 release of that source term.

7 MR. YOUNG: So the releases are based off 8 or are mostly based off of standard Reg Guide 1183 9 methodology which is then, some of the vendors they 10 take into account some advanced SMR features that 11 reduce some of those source terms to a certain extent.

12 Vendors provided that information to us 13 that is supposed to be their atmospheric release 14 source term and if by the associated doses when we do 15 the ratio the X/Q's methodology to take that dose and 16 convert to a site dose.

17 MR. SCHULTZ: Okay, thank you. So you 18 went through a process that provided some element of 19 maximization to determine a, what you would consider 20 a maximum dose for a particular power level to 21 determine some level of a bounding source term?

22 MR. YOUNG: Yes. All the vendors provided 23 information to us. They all provided source terms and 24 doses to us and we picked the vendor that had the 25 highest doses.

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34 1 MR. SCHULTZ: But did, if a unit was less 2 than 800 megawatts thermal, did you scale that up in 3 some fashion or did you go kind of on a design by 4 design basis?

5 MR. YOUNG: No. We went on design by 6 design basis. We did not do any type of composite or 7 scaling of the other values to look at a dose per 8 megawatt ratio kind of thing.

9 We just looked at the largest vendor and 10 their largest dose because if we, the designs aren't 11 scaling in that manner right now.

12 MR. SCHULTZ: So what you found was that 13 the limiting values were for the 800 megawatt thermal?

14 MR. YOUNG: That is correct.

15 MR. SCHULTZ: Thank you.

16 CHAIRMAN KIRCHNER: Any additional 17 questions? Ron, any further questions at this point?

18 Okay. Thank you, Ray.

19 MR. SCHIELE: Thank you.

20 CHAIRMAN KIRCHNER: We're ahead of 21 schedule. So I think rather than take a break at this 22 point let's proceed to the staff and your team, Bob.

23 Take a moment here to change out.

24 MR. FETTER: Is this on?

25 CHAIRMAN KIRCHNER: Yes. Just push the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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35 1 button and you should see a green light.

2 MR. FETTER: Yes, it's much greener now.

3 Good morning. I'm Allen Fetter, one of the two safety 4 projects for the Clinch River nuclear site, early site 5 permit review.

6 Ms. Mallecia Sutton is one of the other 7 safety project managers who is seated at the table 8 with Rob Taylor and our current branch chief, Ms.

9 Jennie Rankin who will be with us through the end of 10 the fiscal year through the other ACRS meetings and 11 possibly longer.

12 Ms. Sutton will be at the table for the 13 next ACRS Subcommittee meeting on emergency planning 14 scheduled for the latter half of August right now on 15 emergency planning and exemption requests. And you 16 will hear about her credentials and experience at that 17 time.

18 My qualifications include having a 19 doctoral degree in Geology which focused on isotope 20 geochemistry and tectonics. And I worked for, prior 21 to joining the NRC I worked for a number of years for 22 an environmental and geotechnical engineering firm.

23 I started working at NRC in 2004 and since 24 2009 I have been a project manager in the Office of 25 New Reactors. Prior to taking over as safety project NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 manager for the Clinch River early site permit review, 2 I was the environmental project manager for the 3 Bellefonte COL and the PSEG early site permit reviews.

4 Today's ACRS meeting, Subcommittee meeting 5 is the first of four Subcommittee meetings that are 6 planned for the Clinch River ESP review. Today Mr.

7 Rao Tammara, the NRC reviewer for safety evaluations 8 for 2.1, 2.2, 3.5.1.6 and 15.03 will present three 9 separate slide presentations on his evaluations.

10 Between each presentation we will offer 11 ACRS Members the opportunity to ask questions or 12 provide comments to each presentation. For the 13 sections discussed today in addition to the staff's 14 review of TVA's application, staff set up one public 15 meeting with the Applicant and issued one RAI to the 16 Applicant and the details are in the SE, in order to 17 obtain additional information to support NRC's 18 findings.

19 Before I turn it over to Mr. Tammara, I 20 want to clarify some statements regarding our schedule 21 that TVA said the DEIS, the draft environmental impact 22 statement was scheduled for June 1st. It was issued 23 on April 27th and we were able to leverage some 24 administrative resources to do that.

25 We did not accelerate this. We followed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 our normal process for a review. The public meeting 2 is on June 5th of this year and the final EIS is next 3 June 2019. And that's all. With that I'll turn it 4 over to Mr. Tamarra.

5 MR. TAMMARA: I'm Rao. Good morning, I am 6 Rao Tammara. I'm with the NRO. I have three Master's 7 degrees, two in Chemical Engineering, one in 8 Environmental Engineering. I have 40 years of 9 experience, 32 working for a consulting company, NUS 10 Corporation and Tetra Tech NUS.

11 I joined the NRC in 2006. Since them I am 12 with the NRC working on all COLs and ESPs so far. I 13 reviewed Chapter 2 Sections 2.1.1, 2.1.2, 2.1.3; 14 Aircraft Hazards, 3.5.1.6 and basically I acquired to 15 start the accident analysis Chapter 15.

16 For Clinch River these are the five 17 subsections I have reviewed and I will present these 18 three subsections one after the other. The first one 19 is 2.1 and 2.2 which addresses the demography and 20 geography.

21 Next slide please. This main section has 22 three subsections which include 2.1.1, consisting of 23 site location and description; 2.1.2 which is 24 exclusion area control, authority and control. The 25 third subsection is 2.1.3, population distribution.

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38 1 The site location and description 2 addresses the description of the site which includes 3 coordinates, site boundaries, orientation of principal 4 plant, location of highways, railroads, waterways in 5 the vicinity of the site and exclusion area.

6 The unique feature of this site is the 7 exclusion area. The exclusion area is delineated by 8 the site boundary, site boundary.

9 However, for the Applicant has designated 10 an analytical EAB where they have conservatively 11 considered the dose evaluations very close to the 12 plant taking conservatively 1,100 feet and evaluating 13 the dispersion parameters, accident dispersion 14 parameters.

15 And corresponding using the dose 16 evaluations using the analytical EAB the dispersion 17 parameters are being addressed or evaluated in the 18 subsection of SSAR 2.3. But those are being utilized 19 in Chapter 15 for the dose evaluations.

20 MR. SCHULTZ: Rao, could you provide some 21 background as to why that approach was taken in 22 determining an analytical EAB?

23 MR. TAMMARA: Because that really, the 24 actual EAB is much farther away and the EAB is in 25 different directions. If you analyze the X/Q it is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 much less, potentially much less than what they have 2 taken conservative.

3 They have taken uniformly throughout all 4 16 directions, same small distance so that they can 5 consider if we meet this dose criteria we will meet at 6 the site boundary. That was the conservatism the 7 object.

8 And staff has no objection from that point 9 because they have used that one. The dose they have 10 being much, you know, would be lower than whatever 11 they use.

12 Therefore, they have conservatively taken 13 a more limiting dose conformance therefore we have no 14 objections to what they have chosen. We have no 15 reason. That's the reason we have accepted that.

16 MR. SCHULTZ: Are there any site 17 characterization X/Q evaluations that have been done?

18 Is there a tower site evaluations for X/Q at this 19 point?

20 MR. TAMMARA: That probably I am not the 21 right person to answer that question because --

22 MR. SCHULTZ: I might have asked the 23 Applicant but --

24 MR. TAMMARA: Not Applicant on the 25 meteorological section which they evaluated in more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 1 detail in Chapter Section 2.3. They looked at the on 2 site data. They have the assumptions. They have 3 evaluated --

4 MR. SCHULTZ: So that's been done 5 separately?

6 MR. TAMMARA: Right. This is, we are the 7 users but they are the reviewers. Therefore, I cannot 8 probably answer very freely.

9 MR. SCHULTZ: I understand. Thank you.

10 MR. TAMMARA: Whoever is presenting that 11 section will be glad to really given insight how they 12 evaluate it.

13 MR. SCHULTZ: But this analytical approach 14 was to basically allow an evaluation to be done --

15 MR. TAMMARA: Right.

16 MR. SCHULTZ: -- without all of the 17 detailed information assembled which will happen later 18 on.

19 MR. TAMMARA: That's correct. The value 20 of X/Q is more conservative compared to the other 21 ones. That's what we have taken into account.

22 MR. SCHULTZ: Certainly.

23 MR. TAMMARA: That is all.

24 MR. SCHULTZ: Thank you.

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41 1 control. And that's addresses the legal authority, 2 control of the activities and, that are unrelated to 3 the plant operation and whatever the arrangements they 4 have made with respect to the state local governments 5 in case of emergency.

6 The third subsection deals with the 7 current population and the population projections in 8 future for the life of the plant within the 50 miles 9 of the plant. Characteristics of the low population 10 zone, whether there are any residences in the 11 description of the low population zone area and 12 population center distance and population density.

13 One more unique situation for this site is 14 the 10 CFR 100.3 defines that the population center 15 having a population greater than 25,000 people should 16 be one and one third times the distance between the 17 plant reactor to the outer boundary of LPZ.

18 But in this case the plant is located in 19 the city limits of Oak Ridge itself. So it is an 20 interesting point to, because if you literally look at 21 the city it is very difficult to meet that one.

22 But however, if you take a look at the 23 second paragraph of the same regulation the regulation 24 says political boundaries are not limiting. You have 25 to look at the population where the majority NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 population is residing, how far away from the 2 boundary, political limits.

3 So if you, based upon that one by 4 observing where the population of Oak Ridge is located 5 if you take a look at the north to east northeast 6 sectors even though the boundary is within the city 7 limit, meaning within the reactor but the population 8 starts beyond five miles.

9 Up to five miles it is zero. Therefore, 10 interpreting that requirement to have considers they 11 are meeting the one and one third distance from the 12 reactor to the LPZ because LPZ is only one mile.

13 CHAIRMAN KIRCHNER: And that doesn't 14 include the transient population on the Oak Ridge 15 Reservation, right?

16 MR. TAMMARA: No, but still it is, yes, 17 right. So that, but however the Applicant analysis 18 used Census Bureau for different designation when 19 you're in the urban area designation.

20 But ultimately the conclusion is similar.

21 But we insisted, staff looked at that they should 22 adhere to the regulative requirement and the Applicant 23 should both conclusions have said they meet the 24 requirement.

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43 1 the site so that how it has been accepted if they have 2 any questions I want to clarify that.

3 CHAIRMAN KIRCHNER: So I'm looking at Reg 4 Guide 4.7, yes, and I see that the boundary for the 5 LPZ should be based on population distribution not 6 political boundaries that you said. Have you, has the 7 Commission, have we ever licensed a plant with only 8 one mile LPZ?

9 MR. TAMMARA: Not really. But two miles 10 we have. But one mile we haven't. And also we 11 haven't seen this situation for the last. That's why 12 I brought up it's a unique situation in this 13 application.

14 CHAIRMAN KIRCHNER: Okay. And we are 15 going to hear about emergency planning later in the 16 summary, okay. Thank you.

17 MR. TAMMARA: Next slide please. Staff 18 reviewed the information provided by the Applicant 19 pertaining to the site location and description and 20 also checked independently the information available 21 from the public domain.

22 Staff found it acceptable and they 23 satisfied the guidance provided in NUREG-0800, Section 24 2.1.1. Staff also reviewed the information provided 25 by the Applicant pertaining the exclusion area NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 authority and control.

2 Based on the information provided staff 3 finds it acceptable as it satisfies the guidance 4 provided in NUREG-0800 Section 2.1.2. Next slide 5 please.

6 Staff also reviewed the information 7 provided by the Applicant pertaining to population 8 distribution including population projections during 9 the life of the plant, operation center distance as I 10 described before and also population density.

11 Based on the information provided by the 12 Applicant and staff's independent confirmatory 13 analysis, the staff found the information to be 14 acceptable as it meets the requirements of 10 CFR 15 100.20.

16 Next slide please. The second subsection 17 is 2.2, which pertains to nearby industrial, 18 transportation and military facilities. This section 19 has first portion identification of all of these 20 facilities.

21 Those are sources within the five miles of 22 the site. And the second portion is the description 23 of the materials, products and other materials or 24 chemicals which are processed, stored by these 25 sources.

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45 1 So they include maps of the site, nearby 2 facilities and transportation routes, description of 3 the facilities products and materials and the number 4 of people they employ, description of pipelines, 5 highways, waterways, airways and airports.

6 And they also include the projections for 7 the future industrial growth. Next slide please.

8 Staff reviewed the Applicant provided specific, I'm 9 sorry.

10 Information provided by the Applicant 11 pertaining to the location and description of nearby 12 industrial, transportation and military facilities for 13 the evaluation of potential hazards for their safe 14 operation of the proposed plant.

15 Based on the review of the information 16 provided by the Applicant and also staff's independent 17 checking of the information from the available data 18 from public domain, staff found it to be acceptable as 19 the information used the guidance provided in NUREG-20 0800, Section 2.2.1-2.2.2.

21 Another important thing for this site is 22 that there is a proposed airport which is planned to 23 be built in the year 2022. If this airport comes into 24 being at the COLA stage the impact evaluation of the 25 hazards of this airport has to be evaluated and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 1 included in the application.

2 Yes, 2022. It should be included in this 3 COLA application. Therefore, a permit condition 2.2-1 4 is included in this SE to evaluate at that time.

5 Next slide please. The third section, 6 subsection of this main 2.2 is the evaluation of 7 potential accidents. In this evaluation the basic 8 evaluation is to determine whether there is any 9 accident which is designated to be a design basis 10 accident.

11 A design basis accident is defined as an 12 accident that has a probability of occurrence in the 13 order of magnitude of 10-7 or greater and resulting in 14 a potential consequence exceeding 10 CFR 100 dose 15 guidelines.

16 So the design basis accident has to occur 17 in connection with those exceeding the 10 CFR Part 100 18 guideline and that's probably the total probability 19 should be greater than 10-7. So in order to find out 20 whether there is any design basis accident the 21 evaluations are determined to, evaluated to determine 22 whether any accident is design basis accident.

23 In doing so the impacts considered 24 explosions, flammable vapor cloud explosions from 25 industrial facilities, truck traffic, pipelines, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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47 1 waterways, release of hazardous chemicals from 2 transportation accidents, major depots, storage areas, 3 on site storage tanks.

4 And potential from transportation 5 accidents, industrial storage facilities, on site 6 storage and potentially forest fires. Next one.

7 Staff reviewed the Applicant provided site 8 specific evaluations of potential accidents. The 9 Applicant performed evaluations of potential hazards 10 due to nearby facilities in the CRN site vicinity.

11 The effects of chemical releases from on 12 site chemical storage will be evaluated at the COLA 13 referencing this ESP because the locations of the on 14 site storage, control room and other safety related 15 structures designs and the locations will be 16 determined at the COLA stage, they are not available 17 at the ESP stage.

18 Next slide please. Based on the review 19 the Applicant provided information, analysis and 20 staff's independent confirmatory calculations, the 21 staff found Applicant's conclusions to be acceptable, 22 as the evaluations are in accordance with the guidance 23 provided in NUREG-0800, Section 2.2.3 with an 24 exception of potential impacts from toxic chemical 25 release of anhydrous ammonia, chlorine and nitric acid NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 from a truck transport on the roadway.

2 Since the Applicant determined the minimum 3 safe distance due to the potential toxic chemical 4 concentration of anhydrous ammonia, chlorine and 5 nitric acid, from the potential release from the truck 6 transport is greater than the actual distance the 7 Applicant is, communicate and shall reanalyze the 8 impacts of the delivery tank using the guidance 9 provided in Reg Guide 1.78 and NUREG-0800 to 10 demonstrate the compliance with 10 CFR Part 100.

11 Therefore, a permit condition to 2.2 that 12 two is included in the SE.

13 CHAIRMAN KIRCHNER: Okay. Just for 14 qualitative comparison purposes, since I-40 is 15 approximate to this site versus for example TVA's 16 other sites, I think it's I-75 that goes down --

17 MR. TAMMARA: Yes.

18 CHAIRMAN KIRCHNER: -- to Chattanooga.

19 But that's a considerable distance from Sequoyah and 20 Watts Bar. Is this unusual? Would this require a 21 COLA to provide a, what do I want to say, an HVAC 22 system for the control room that's different, 23 superior, more difficult to implement than is 24 typically done for most power plants?

25 MR. TAMMARA: Not necessarily. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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49 1 problem here is this is a ESP. So the roadway is 2 about 5,800 feet away from the closest boundary. So 3 presently we do not know exactly where the control 4 room is.

5 So what is the intake structure is whether 6 it is a limited or, we don't know the design. And we 7 don't know the evaluation factors of the control room 8 because it is a, first of all it is a new design.

9 And it is not a light water, to make some 10 assumptions. So first we don't know the location.

11 Second, we don't know the design parameters of the 12 intakes.

13 And we don't know the design parameters of 14 the evaluation grades. Therefore, it is difficult to 15 calculate what would be the concentration in the 16 control room.

17 So the present analysis what has been done 18 is if there is an accident we calculated the 19 concentration very closest to the boundary and see 20 whether the limited concentration would be higher or 21 lower.

22 If our analysis has shown, our data 23 analysis had shown the concentration is lower than 24 alleged potentially control room would not have any 25 problem because the site won't, concentration is lower NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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50 1 and it is meeting the limiting concentration.

2 There is no way to exceed in the control 3 room. But however, it is not the case. The 4 concentration is much higher at the site boundary, 5 therefore it is ambiguous to assume the control room 6 has a potential to increase.

7 I mean, it may exceed the limiting 8 concentration. Therefore, that has to demonstrated.

9 That is the intent over here. They have to evaluate 10 it at the COL stage.

11 CHAIRMAN KIRCHNER: My point here was that 12 compared to, for example, TVA's other sites their 13 location is sufficiently distant from major arteries 14 like an interstate highway such that they will fall 15 below the toxicity limit just by dispersion and 16 distance.

17 MR. TAMMARA: Yes, I do not --

18 CHAIRMAN KIRCHNER: But here we have a 19 relatively small site, relatively approximate to I-40.

20 And I would submit that the, and if you look at the 21 exclusion area boundary in particular the bulk of the 22 areas to the north away from the lower site boundary 23 that's closest to I-40.

24 So the location of the intakes is not 25 going to be an issue. So first order in doing that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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51 1 analysis is, it appears that they're going to have a 2 higher toxic protection.

3 They're going to have, I'm trying to think 4 of the right way to say this. That the toxicity that 5 the HVAC system for the control room is going to deal 6 with is going to be higher than they would see at 7 their other sites.

8 MR. TAMMARA: Possibly. I cannot answer.

9 MR. FETTER: So it sounds like you're 10 saying the amount of recirculation that a control 11 versus fresh air intake and that's something that's 12 not a specialty that Rao has.

13 MR. TAMMARA: And also it is like, that's 14 why we are putting a condition they have to 15 demonstrate the actual data that it is not going to 16 impact the operators. That is the intent.

17 CHAIRMAN KIRCHNER: So noted, okay. Thank 18 you.

19 MR. TAMMARA: Any other questions?

20 CHAIRMAN KIRCHNER: Why don't we proceed 21 on, Allen?

22 MR. FETTER: That's fine. Are you guys 23 okay continuing on?

24 MR. TAMMARA: Yes, sure. I have no 25 problem.

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52 1 MR. FETTER: We just need a little 2 technical assistance for this slide show.

3 MR. TAMMARA: The next section is Aircraft 4 Hazards, Section 3.5.1.6. Next slide please. For the 5 site suitability the plant design should consider that 6 any of the aircraft accidents is not a design basis 7 event.

8 I have already explained what the design 9 basis accident is, that an event having a probability 10 of 10-7 or greater having the consequences greater 11 than dose limits exceeding the dose limits 10 CFR Part 12 100 that includes 10 CFR 50.34(a)(1) with a 13 probability of occurrence greater than 10-7 per year.

14 Doing the aircraft analysis there are, 15 some of the screening criteria are applied and they 16 have to be considered and also screened out based upon 17 the guidance. Federal airways, holding patterns and 18 approach patterns should be at least two statute miles 19 away.

20 Military installations or any air space 21 usage should be at least 20 miles from the site. All 22 airports should be at least five miles from the site.

23 Next slide please. The airports which are 24 within the five to ten miles the flights that are 25 having, can be screened out if they are 500 d2. D, is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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53 1 the distance from the plant to the airport.

2 If you calculate that number of flights 3 and if it is within the, the actual number of flights 4 are within the limit that no further evaluation of 5 that airport is required. So also if it is, airport 6 is beyond ten miles the limiting value of the number 7 of flights is 1,000 d2.

8 The airports identified by the Applicant 9 and checked by the staff do not meet, meet this 10 criterion therefore no additional evaluation has been 11 performed or required to be performed for the area of 12 the airports.

13 Staff reviewed the Applicants information 14 pertaining to the site specific aircraft analysis.

15 The Applicant identified only two airways that are 16 within two miles of the site that include V16 and J46 17 which they have evaluated the probability of accident.

18 The Applicant determined the aircraft 19 crash probability of 7.53 to the -7 per year using non 20 airport operations referenced in DOE guidance accident 21 analysis for aircraft crash and hazardous facilities.

22 Next slide. Staff performed an 23 independent confirmatory analysis using the actual FAA 24 data. Staff collected and looked in five year recent 25 data from the FAA that covers 2011 to 2015 all flights NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1 flying within the five miles or in the ten miles of 2 this sight irrespective of where the, type of the 3 aircraft is.

4 And we used that data to calculate 5 conservatively applying all the flights within the ten 6 miles following those two airways. And we calculated 7 what would be the probability conservatively.

8 The potential aircraft crash probability 9 we calculated, staff calculated is 1.5 times 10-8 10 based upon all the flights within ten miles following 11 those two airways. So that is a most conservative 12 calculation using the real FAA data.

13 And based upon that one staff accepts the 14 Applicant's value as reasonable. Therefore, staff 15 agrees with the Applicant's conclusion that the 16 aircraft crash probabilities is in the order or 17 magnitude 10-7 per year or less and meets the provided 18 NRC guidance.

19 CHAIRMAN KIRCHNER: Rao, just for 20 clarification purposes, the preceding slide shows an 21 estimate of 7.53 times 10-7 using the DOE standard.

22 So that feels a lot like one times 10-6 to me, right.

23 As an engineer when I round this up.

24 MR. TAMMARA: That's correct.

25 CHAIRMAN KIRCHNER: So I guess the only NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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55 1 thing I would say is that the Applicant provided us 2 with some qualifying arguments that would reduce their 3 number. It just, since we're dealing with numbers 4 here at least in the material that's been presented, 5 it just doesn't follow ipso facto that you agree with 6 their estimate.

7 You calculate a number with real data or 8 "real" data from FAA that's significantly lower than 9 their number and therefore you can feel confident that 10 your determination is fine. I'm just having a problem 11 that you agree with the Applicant.

12 MR. TAMMARA: The way the guidance is 13 written if you take a look at the guidance, first 14 thing is if you make the assumptions and show that 15 comfortably the probability calculated is 10-7 or 16 less, okay, generalize options than it is easy to 17 accent.

18 But if you read the second sentence of the 19 guidance it says if you, if the assumptions are 20 realistic and more appropriate are any statistical 21 evidence if you can use, you can go and you can accept 22 as high as 10-6 per year. So the language written is 23 you can make a general, if you don't have anything you 24 mix general reasonable engineering and scientific 25 assumptions and prove your less than 10-7 it is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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56 1 acceptable because everything would be less than that.

2 But if you haven't really statistics 3 available or you have a real data which is measured or 4 documented then you can take and show you can go as 5 far as 10-6 still it is acceptable. So if you read in 6 those things the staff is using the second portion.

7 I'm using the FAA realistic data and when 8 taking really conservative and not taking military 9 only, light plane only, only commercial and using 10 total number of flights and I'm assuming they're all 11 going in that and still am using and calculating.

12 So what else could we? It is most 13 conservatively showing a distance. But they might 14 have it, the Applicant might have used some because 15 they are not available with this data. But they have 16 made some assumptions to use more realistically what 17 they have.

18 So therefore, when staff's judgment is 19 used and it is acceptable. That is the situation 20 here.

21 CHAIRMAN KIRCHNER: Thank you. Our former 22 member, John, no, John is still a member, Stetkar 23 would appreciate your more realistic calculation.

24 I'll let it go at that. Thank you.

25 MR. TAMMARA: Thank you.

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57 1 MR. SCHULTZ: Rao, a related question.

2 The permit condition 2.2-1 references or relates to 3 that potential new airport that you mentioned earlier 4 might be constructed.

5 MR. TAMMARA: No, it is under 6 construction.

7 MR. SCHULTZ: It is and it's nearby the 8 site. Does that, is there enough information for you 9 to have included that here?

10 MR. TAMMARA: No, we haven't. It is, not 11 enough information is available.

12 MR. SCHULTZ: But it's under construction?

13 MR. TAMMARA: I think so. It will be, the 14 notion is it comes into being in 2022. So at what 15 stage it is in I'm not sure.

16 MR. SCHULTZ: Is there any expectation 17 that the results of the evaluation would change 18 because of the location and the size of that airport?

19 Do you think it would change the evaluation that 20 you're doing now?

21 You've done quite a detailed evaluation as 22 has the Applicant related to this airport. To have 23 something sitting out there that's going to be 24 evaluated later.

25 MR. TAMMARA: No, that will, usually that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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58 1 kind of facility they have to go to the federal and 2 state permitting procedures because there is another 3 nuclear plant is there. They have to evaluate what 4 would be the impact of the airport to nearby 5 facilities just like we are doing here.

6 Just to give an example when we are doing 7 the Calvert Cliffs COL there was next door the natural 8 gas staging facility storage and also the, they would 9 bring store and distribution facility, Cove Point. So 10 when the State of Maryland gave a permit they had to 11 evaluate what would be the accident safety point of, 12 evaluation of the Calvert Cliffs.

13 They helped evaluate. And also as an 14 operating plant Calvert Cliff has to evaluate what 15 would be the potential impact of the proposed 16 facility.

17 MR. SCHULTZ: Understood.

18 MR. TAMMARA: So therefore, we haven't 19 done for the ESP therefore we have put it but a 20 condition that at the COL stage they have to evaluate 21 that.

22 MR. SCHULTZ: All right. Is there not 23 enough information to determine that --

24 MR. TAMMARA: That's correct.

25 MR. SCHULTZ: Wait, let me ask my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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59 1 question. Is there not enough information to 2 determine that it won't be a difficult situation where 3 something has got to give between the airport 4 construction and design or the plant design before 5 2022?

6 MR. TAMMARA: That's correct.

7 MR. SCHULTZ: It seems like enough 8 information might be available to at least determine 9 that the construction project can continue and this 10 site evaluation can continue.

11 MR. TAMMARA: But we need to know --

12 MR. SCHULTZ: Or in reverse, this is going 13 to be a problem in 2022 and something will have to be 14 worked out. That doesn't seem to be a proper way to 15 proceed.

16 If it's going to be a problem if we can 17 determine that now obviously it would be a better time 18 than six years from now or so after the construction 19 is more complete. I mean that's how facilities get 20 into difficulty is when you get things close to done 21 and then find out, we didn't consider it properly and 22 there might be a problem here.

23 MR. TAMMARA: That's why we are 24 identifying the Applicant, hey, you need to realize, 25 be aware of it.

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60 1 CHAIRMAN KIRCHNER: But I think where 2 Steve is going is just to do a little projected 3 calculation. You've got a general aviation airport, 4 x, I forget the exact distance.

5 If you put a nominal general aviation 6 airport load into the mix along with the distance that 7 the airport is, would it substantially change your 8 conclusions or would you still have adequate margin in 9 terms of this crash probability or conversely if you 10 don't have adequate margin and you fall below then 11 that's something that would factor into the plant 12 design and layout obviously or any mitigating 13 measures, right, by the Applicant, right?

14 MR. SCHULTZ: That's what I was looking 15 for. Clearly the evaluation needs to be done in 16 detail once the parameters are known. But is there a 17 determination at this time that this is not going to 18 create an issue for the airport or for the site 19 application by 2022?

20 MEMBER BALLINGER: In the justification 21 for the airport itself an analysis had to be done.

22 Why put the airport there? It must be some assumption 23 of the number of flights in and out and all that to 24 justify constructing the airport in the first place.

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61 1 easy to get access to.

2 It might be a little artificial. But at 3 least you have a number.

4 MR. CAMPBELL: Is this on? Okay, I'm Andy 5 Campbell. I'm the deputy director of DSEA. The part 6 of the problem with doing just that is it's very 7 speculative.

8 Without knowing the specifics of what the 9 airport is going to be and whether or not it's even 10 going to be for the ESP stage that would be highly 11 speculative. On the other hand, you could do some 12 sort of screening.

13 But it would be again, very speculative.

14 There's not a lot of data and it's certainly not 15 required at the ESP stage. It would be required at 16 the COL stage.

17 So in terms of the analysis I'm not sure 18 what the regulatory basis for said analysis would be 19 without definitive plans and definitive information 20 for an airport.

21 CHAIRMAN KIRCHNER: Well I would, because 22 there's, I know our charter is restricted to safety.

23 But obviously the Applicant has financial interests at 24 risk as well.

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62 1 than speculative to make such an estimate of the 2 potential impact of that proposed airport and I'll let 3 it go at that.

4 MR. CAMPBELL: Certainly the Applicant 5 could do that if they so desired.

6 CHAIRMAN KIRCHNER: Okay. Does that 7 conclude this section?

8 MR. TAMMARA: Yes.

9 CHAIRMAN KIRCHNER: At this point, let's 10 see we have one more section to go. And why don't we 11 take a short break and come back at 10:15 on the clock 12 there on that wall. And so we are recessed.

13 (Whereupon, the above-entitled matter went 14 off the record at 10:02 a.m. and resumed at 10:14 15 a.m.)

16 CHAIRMAN KIRCHNER: Let's begin the 17 meeting and proceed to Chapter 15 please.

18 MR. TAMMARA: Yes. The next section is 19 Chapter 15, Accident Analysis. Evaluation of 20 radiological consequences, consequences of postulated 21 designed basis accidents for the proposed CRN site.

22 Dose analysis include plant parameter 23 envelope accident source terms consisting of assumed 24 DBA, isotopic releases to the environment in lieu of 25 specific plant design information. Site NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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63 1 characteristic short term accident atmospheric 2 dispersion factors that they have developed site 3 specific information in Chapter 2, Section 2.3.

4 So those dispersion parameters have been 5 used for the, this Chapter 15. 10 CFR 52.17 and also 6 citing 10 CFR 50.34(a)(1) postulated accident dose 7 analysis requirements have the same dose criteria.

8 The evaluation must determine that an 9 individual located at any point on the boundary of the 10 exclusion area for any two hour period following the 11 onset of postulated fission product, release would not 12 receive a radiation dose in excess of 25 rem total 13 effective dose equivalent, TEDE.

14 An individual located at any point on the 15 outer boundary of low population zone who is exposed 16 to the radioactive cloud resulting from postulated 17 fission product release during the entire period of 18 its passage would not receive a radiation dose in 19 excess of 35 rem TEDE.

20 SRP 15.03 provides a new guidance 21 including evaluation of PPE accident releases. Next 22 slide please. The fission product released to the 23 environment is reviewed based on industry accepted 24 approaches, assumptions and methodologies.

25 The Applicant considered the loss of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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64 1 coolant accident LOCA is expected to be more closely 2 approached. 10 CFR 52.17 limits then other design 3 basis accidents that may have greater probability of 4 occurrence but lesser magnitude of activity release.

5 The selected PPE LOCA accident source term 6 is based on standard, light water reactor fuel which 7 is representative of SMR design assuming core power 8 level of a single unit at 800 megawatt thermal. For 9 reasonableness the PPE source term is compared with 10 the AP1000 design with a scaling factor by ratio of 11 .235 that is the ratio of 800 megawatt thermal to 12 2,400 megawatt thermal and assessed to be not 13 unreasonable.

14 The radionuclide released to the 15 environment for the loss of accident LOCA is 16 documented and is considered by the Applicant in the 17 ESP application as a part of plant parameter envelope 18 in the SSAR Table 2.0.3.

19 Staff found the PPE LOCA release source 20 term to be not unreasonable for the purpose of site 21 analysis postulated for the consequences of a possible 22 accident event. So it is, the reasonableness is based 23 upon that ratio.

24 Next slide please. The dose to the 25 individual located at the EAB or on the outer boundary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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65 1 of LPZ is calculated based on the amount of activity 2 released to the environment at dispersion using the 3 transport from the release point to the dose point, 4 breathing rate of an individual at the dose point 5 location and the activity to the dose conversion 6 factor.

7 So these are the parameters which will 8 determine the dose. Since the dose and the vendor 9 dose is determined based upon the vendor X/Q that is 10 more representative of many of the sites the only 11 change for the site is the site specific X/Q.

12 So dose can be determined by the ratio of 13 when the X/Q, site specific characteristic evaluation.

14 So the dose can be ratioed off. That is the way the 15 dose is evaluated for the ESP site.

16 The actual doses of the exclusion area 17 boundary and the outer boundary of the LOCA operation 18 zone at the CRN site are obtained by multiplying the 19 vendor supplied dose associated bounding PPE LOCA 20 source term with the ratio of the site specific, site 21 characteristic and the vendor supplied site parameter 22 X/Q's by the equation. Dose at the site is equal to 23 dose specified by the vendor by the ratio of site 24 characteristic X/Q versus vendor supplied X/Q.

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66 1 in 10 CFR 50.34(a)(1) and also 10 CFR 52.17 and the 2 PPE includes the bounding accident releases for the 3 determination. Next slide please.

4 MR. SCHULTZ: Just on that slide a 5 question. What are the boundary distances that are 6 being used here?

7 The exclusionary boundary you mentioned, 8 it was mentioned earlier that there was an analytical 9 boundary that was associated with that. Is that what 10 this is or --

11 MR. TAMMARA: Yes, that's correct, 1,100.

12 MR. SCHULTZ: 1,100 and the LPZ --

13 MR. TAMMARA: Is one mile.

14 MR. SCHULTZ: -- boundary is?

15 MR. TAMMARA: One mile.

16 MR. SCHULTZ: One mile, okay. Thank you.

17 MR. TAMMARA: 1,100 feet.

18 CHAIRMAN KIRCHNER: I have a slightly 19 different question but related. It is an irregular, 20 the actual exclusionary boundary is irregular. Is 21 1,100 the smallest distance to, of the exclusion area 22 this doesn't go on the transcript very well. Is it 23 irregular for --

24 MR. TAMMARA: The site boundary and also 25 --

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67 1 CHAIRMAN KIRCHNER: The 1,000 or 1,100 is 2 the minimum distance from the center point of the site 3 --

4 MR. TAMMARA: That's correct.

5 CHAIRMAN KIRCHNER: -- to the smallest 6 lineal distance.

7 MR. TAMMARA: The closest point.

8 CHAIRMAN KIRCHNER: Okay, fine.

9 MR. TAMMARA: That's correct.

10 CHAIRMAN KIRCHNER: Thank you. Second, 11 have you audited the site characteristics, the X/Q 12 numbers that are used? I would note that in your 13 table you point out that the vendor designs for that 14 ratio or that parameter more correctly are engineering 15 numbers like 1 times 10-3, 5, 5 times 10-4, et cetera.

16 And then we have some rather precise site 17 characteristic numbers for the same parameter. Have 18 you audited that? Does that allow for, does it allow 19 for thermal inversions?

20 I've been through that area before when 21 the fog sets in and the cloud cover is very low and 22 the coal doesn't go anywhere, the coal dust and such 23 That's an area of the country that's subject to 24 morning fog and such.

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68 1 characteristic parameter, particularly for the EAB 2 given that when you use that multiplier you get fairly 3 close to 25 rem, 21.6 as was pointed out.

4 MR. TAMMARA: That's correct. The site 5 characteristic X/Q are evaluated based upon the site 6 meteorology and other parameters using the code that 7 has been evaluated by our meteorology subsection under 8 2.3.

9 It has documented what are the models they 10 have used, what criteria they have audited in the 11 parameters how they came up with. A detailed analysis 12 have been used and analyzed and addressed in Section 13 2.3.

14 So when they present that section probably 15 they will give you more insight and more thorough 16 explanation of how they determined, how they accepted 17 the numbers.

18 We are, they actually reviewed, accepted 19 the X/Q and they independently generated and compared 20 the Applicant's and theirs and concluded and based 21 upon their evaluation we used the numbers because we 22 are the end users to get the ratio. But I do not know 23 specifically to answer.

24 CHAIRMAN KIRCHNER: Well I understand 25 that. You've got three significant figures in that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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69 1 parameter. I put my glasses on and I can't even read 2 this.

3 MR. TAMMARA: 4.96.

4 CHAIRMAN KIRCHNER: 4.96, so you know what 5 occurs to me is that what you have from the vendors 6 are, as I mentioned, engineering like numbers, 1.0 7 times 10-3, et cetera. Then we have rather precise 8 numbers for the site characteristic.

9 And I understand they probably were 10 generated using the guidance and the Reg Guide. But 11 it begs the question what uncertainty that number 12 might have with bounds and how comfortable then one is 13 that estimating a dose of 21.6, which is getting close 14 in engineering terms to 25, and the expectation is to, 15 right, that is not a limit that is to be attained.

16 It's, if I remember, 10 CFR 50.34 there is 17 some wording there that suggests that there should be 18 a comfortable margin. So how comfortable are you with 19 this analysis?

20 MR. TAMMARA: You find this out. The case 21 for COL they have to make sure the actual source terms 22 they have selected end up on. They have to compare 23 against the source term and make sure the PPE is 24 bounding.

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70 1 PPE source term is bounding then it is okay.

2 Otherwise they have to take a variance. This ESP 3 stage it is showing taking the boundary PPE value you 4 are meeting the 25.

5 CHAIRMAN KIRCHNER: Well we, of course 6 there is uncertainty in several assumptions that 7 result in that final number in terms of dose. There's 8 the uncertainty as to whether scaling AP1000 is an 9 accurate assumption.

10 It's, in a gross sense I would expect 11 that's a good assumption. From what we know from some 12 of the designs they probably wouldn't see the burn up 13 that AP1000 will attain at this point, et cetera.

14 But it does, I just want to put a marker 15 down that when we here from the meteorology people we 16 would like to test those numbers.

17 MR. TAMMARA: Right.

18 CHAIRMAN KIRCHNER: And then we'll come 19 back and look at how close this is to 25 rem.

20 MR. TAMMARA: That's true. But in our 21 judgment at the COL stage if there is a variation in 22 the source term, so in the actual design probably that 23 answer will be much closer to 25 they might have to do 24 some mitigating measure.

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71 1 deviating from the source term. So but because the 2 X/Q is already evaluated for the site specific there 3 is nothing they can do probably.

4 So the only thing they can do is they 5 might have to have additional controls to lower the 6 release and mitigate it. I do not know.

7 CHAIRMAN KIRCHNER: Or they could do what 8 you did with aircraft. They could go back and 9 reevaluate the meteorology.

10 MR. TAMMARA: Right, that's true. They 11 have to. That's what I'm saying. They have to 12 reevaluate taking the variance and show, demonstrate 13 that their dose calculation, recalculated dose 14 calculation with the actual source term is within the 15 25 margin, whatever they have demonstrated that.

16 MS. SUTTON: This is Mallecia Sutton. So 17 the staff is currently writing the SE and will present 18 the findings on the X/Q which I know they currently 19 have an article on now related to X/Q with the 20 Applicant and will be happy to present your, the 21 findings on October, November.

22 So I know that some of that the staff is 23 analyzing and is reviewing at this time.

24 CHAIRMAN KIRCHNER: Now the other thing 25 again for the record that I should note is you are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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72 1 assuming the limit is based on a single module 2 failure.

3 MR. TAMMARA: That's correct.

4 CHAIRMAN KIRCHNER: Not the bounding plant 5 parameter element that would obtain if it were looking 6 at a larger --

7 MR. TAMMARA: That's correct because the 8 limits are based upon the unit.

9 CHAIRMAN KIRCHNER: Yes. Okay, Ron, any 10 nuclear questions?

11 MEMBER BALLINGER: No.

12 CHAIRMAN KIRCHNER: Pete?

13 MEMBER RICCARDELLA: No.

14 CHAIRMAN KIRCHNER: Steve.

15 MR. SCHULTZ: (Off microphone comments.)

16 No, I think my comments will just pick up where you 17 that is the, we understand what is being done at this 18 stage is the evaluation. There are also going to be 19 some near term discussions related to dose evaluations 20 that are going to be performed related to the EAB, LPZ 21 and for emergency planning purposes.

22 In order to have good discussion related 23 to those parameters the determination of boundaries is 24 going to be important to understand the uncertainties 25 associated with these assumptions for the variety of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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73 1 different designs that might be considered and also 2 the sensitivities that one might determine.

3 As was stated, we do have limits that have 4 been established in the regulation. At this stage in 5 terms of new reactor licensing we are looking for 6 margin and when one considers its evaluation which 7 might pertain to a different approach to emergency 8 planning.

9 One would expect that margins and limits 10 would be very important. Just a general comment at 11 this time to consider at the next stage, near term 12 stage and licensing proceedings. Thank you for your 13 presentation.

14 MR. TAMMARA: Thank you.

15 CHAIRMAN KIRCHNER: Okay. Let me turn and 16 see if anyone from the public is in audience and 17 wishes to make a comment. Seeing none, we'll open up 18 the bridge line and see if we have any members of the 19 public who have been listening in and wish to make a 20 comment.

21 MEMBER RAY: Walt, before you do that, did 22 you take member comments? I couldn't hear.

23 CHAIRMAN KIRCHNER: I was going to take 24 final comments, Harold, in just a moment.

25 MEMBER RAY: That's fine. It was, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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74 1 whatever was going on the last minute or so I couldn't 2 hear so please go ahead.

3 CHAIRMAN KIRCHNER: Okay. We have two 4 meetings going on simultaneously and while we are 5 waiting for some technical assistance, Harold, if you 6 have any comments this would be a good opportunity 7 while we have the staff in front of us.

8 MEMBER RAY: Yes, I would be glad to. I'm 9 sorry I'm not there. I will try and provide 10 equivalent input.

11 But in any event, on the discussion of the 12 perspective possibility of an airport and its 13 implications for the site I think that will warrant 14 some more discussion as to whether in an ESP 15 proceeding if it's gotten to some point and whether 16 it's an airport or any other thing, it's not specific 17 to airports, but whether proposed additions to the 18 environment should be considered and if so on what 19 basis.

20 The discussion that I could hear which was 21 we don't know the details about it yet and therefore 22 it hasn't been considered but might have to be in the 23 future. I think in an ESP proceeding, it's my opinion 24 anyway that perhaps we ought to consider things when 25 they've gotten at least to some point of specificity.

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75 1 I certainly did that on a liquefied 2 natural gas facility on one occasion. So that's the 3 only comment that I have.

4 CHAIRMAN KIRCHNER: Okay, thank you. So 5 if any member of the public is out there and wishes to 6 make a comment please state your name and provide your 7 comment.

8 Not hearing anyone I think we can close 9 the bridge line and proceed around the table. Any 10 final comments, Ron?

11 MEMBER BALLINGER: No further comments.

12 CHAIRMAN KIRCHNER: Pete?

13 MEMBER RICCARDELLA: No comments.

14 CHAIRMAN KIRCHNER: Steve?

15 MR. SCHULTZ: No further comments. I 16 thank the staff. I think the presentations by both 17 the staff and the Applicant have been well done this 18 morning and I appreciate the current status 19 information and look forward to the future meetings.

20 Thank you.

21 CHAIRMAN KIRCHNER: So let me echo Steve's 22 thanks and to both the staff and the Applicant. And 23 with that we are adjourned.

24 (Whereupon, the above-entitled matter went 25 off the record at 10:37 a.m.)

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Clinch River Early Site Permit SSAR Sections 2.1, 2.2, 3.5.1.6, & Ch.15 Advisory Committee on Reactor Safeguards Subcommittee Meeting Presented by Ray Schiele, Licensing Manager May 15, 2018

TVAs Mission Serving the people of the Tennessee Valley to make life better.

Energy Environment Economic Development Partner with 154 local power companies, to serve 9 million people and 700,000 businesses in parts of seven states. Directly serve 56 large industries and federal installations.

Advisory Committee on Reactor Safeguards l 2

TVAs Nuclear Fleet CRN Site Watts Bar Sequoyah Browns Ferry Advisory Committee on Reactor Safeguards 3

Early Site Permit Application Development TVA decides to pursue ESPA 2014 Site Characterization 2010 - 2015 ESPA Submitted to NRC May 2016 NRC accepts ESPA for review December 2016 NRC performs Audits March-May 2017 ESPA Rev. 1 Submitted December 2017 RAIs 2017-2018 Advisory Committee on Reactor Safeguards 4

ESPA Project Update - Licensing Process 2016 2017 2018 2019 2020 ESPA Docketing Submitted Decision NRC Review 5-12-16 Schedule NRC Safety Review Audits SER (Hydrology, Seismic) PSER w/ OIs ACRS SER w/ no OIs ACRS FSER Audit RAI RAI OI Responses Responses Responses Scoping Period NRC Environmental Review Comment Period ER Audit FEIS Notice Comment Resolution DEIS of Scoping Audit RAI RAI to EPA, Intent Meeting Responses Responses USACE TVA Business Sensitive

Chapter 2 - Section 2.1 Geography & Demography Advisory Committee on Reactor Safeguards l 6

Section 2.1 - Geography & Demography The proposed CRN site location encompasses 935 acres of land adjacent to the Clinch River arm of the Watts Bar Reservoir, within the City of Oak Ridge, Roane County, Tennessee.

Borders DOE Oak Ridge Reservation 6.8 miles East of Kingston, TN 9.2 miles East-Southeast of Harriman, TN 8.8 miles Northwest of Lenoir City, TN 25.6 miles West-Southwest of Knoxville, TN The land is owned by the United States of America and managed by TVA as the agent of the federal government.

Advisory Committee on Reactor Safeguards l 7

Section 2.1 - Geography & Demography Population Distribution The low-population zone (LPZ) is defined as a 1 mi radius from the site center point.

There are no hospitals, prisons, or jails within the LPZ There are no transient population events or attractions within this area.

Advisory Committee on Reactor Safeguards l 8

Section 2.1 - Geography & Demography Exclusion Area Boundary There are no residences or commercial activities within the EAB.

No public highways or active railroads traverse the exclusion area.

Barge traffic occurs adjacent to the EAB along the Clinch River arm of the Watts Bar Reservoir.

Advisory Committee on Reactor Safeguards l 9

Section 2.1 - Geography & Demography Population Distribution The population distribution surrounding the site, up to a 50-mi radius, estimated based upon the most recent 2010 USCB decennial census data.

Transient population is projected to 40 years beyond the 2027 commencement of operation date for the last unit.

Advisory Committee on Reactor Safeguards l 10

Section 2.1 - Geography & Demography Population Center Distance to population center boundary (greater than 25,000 people) complies with 10 CFR 100.3 guidance.

USCB census-delineated urban areas are used to identify population centers and are based largely on population density.

Advisory Committee on Reactor Safeguards l 11

Section 2.1 - Geography & Demography Population Density Population densities, per Regulatory Guide 4.7, General Site Suitability Criteria for Nuclear Power Stations, were calculated for the 50-mi region for the projected start of construction date (2021), the projected commencement of operation date for the last unit (2027), and the end of operation date (2067).

The total projected permanent population for 2021 and 2027 is approximately 1,305,000 and 1,377,000, respectively.

The total projected transient population for 2021 and 2027 is approximately 638,000 and 674,000, respectively.

The 2021 and 2027 total projected population for the 50-mi region is approximately 1.94 million and 2.05 million, respectively.

The 2021and 2027 total population density is 247 people per mi2 and 261 people per mi2, respectively. These projected population densities are less than the 500 people per mi2 recommended by Regulatory Guide 4.7.

Advisory Committee on Reactor Safeguards l 12

Chapter 2 - Section 2.2 Nearby Industrial, Transportation, and Military Facilities Advisory Committee on Reactor Safeguards l 13

Section 2.2 - Nearby Industrial, Transportation, and Military Facilities Locations and Routes Potential hazard facilities and routes within the 5-mile vicinity of the CRN Site identified in accordance with RG 1.206, RG 1.91, RG 4.7, and RG 1.78.

- Identified all facilities and activities within 5 miles

- Identified potentially significant facilities and activities beyond 5 miles.

1 navigable waterway, 1 major highway, 4 major roads, 1 minor rail line, and 2 natural gas pipelines identified within 5 miles.

Additional industrial facilities were identified beyond 10 miles that were significant enough to be considered for further review.

No identified roads, railways or navigable waterways at distances greater than 10 miles that are significant potential hazards.

Description of Products and Materials Identified chemicals used, produced, or transported by each facility/activity.

Advisory Committee on Reactor Safeguards l 14

Section 2.2 - Nearby Industrial, Transportation, and Military Facilities Industrial Facilities ORNL (Battelle and URS)

TVA Kingston Fossil Plant Oak Ridge WTP TVA Bull Run Fossil Plant Hallsdale Powell Utility District Melton Hill WTP Advisory Committee on Reactor Safeguards l 15

Section 2.2 - Nearby Industrial, Transportation, and Military Facilities Transport Routes/Natural Gas Pipelines Clinch River arm of Watts Bar Reservoir I-40 TN 1/US11-70, and TN 58, TN 95, and TN 327 Heritage Railroad Corporation Railway East Tennessee Natural Gas Pipeline 1 (6 inch) and Pipeline 2 (22 inch)

Advisory Committee on Reactor Safeguards l 16

Section 2.2 - Nearby Industrial, Transportation, and Military Facilities Airports and Airways Big T Wolf Creek Cox Farm Will A Hildreth Farm Riley Creek Federal Airways V16 and J46 Advisory Committee on Reactor Safeguards l 17

Section 2.2 - Evaluation of Potential Accidents Determination of Potential Accidents RG 1.206 states that design-basis events, internal and external to the CRN Site, are defined as those accidents that have a probability of occurrence on the order of magnitude of 10-7 per year or greater with potential consequences serious enough to affect the safety of the plant to the extent that the guidelines in 10 CFR 100 could be exceeded.

The following accident categories are considered in selecting design-basis events:

- Chemical Releases: Explosions, flammable vapor clouds (delayed ignition), toxic chemicals, or fires.

- Collisions with the intake structure.

- Aircraft hazards.

- Liquid spills.

Advisory Committee on Reactor Safeguards l 18

Section 2.2 - Evaluation of Potential Accidents The following locations were analyzed for postulated accidents within the accident categories considered in selecting design-basis events:

Nearby Storage Facilities

- ORNL (Batelle and URS) (located 3.8 mi from the CRN Site power block area)

- TVA Kingston Fossil Plant (located 7.6 mi from the CRN Site power block area)

- Oak Ridge WTP (located 10.3 mi from the CRN Site power block area)

- TVA Bull Run Fossil Plant (located 15 mi from the CRN Site power block area)

- Hallsdale Powell Utility District Melton Hill WTP (located 18.2 mi from the CRN Site power block area)

Nearby Transportation Routes

- East Tennessee Natural Gas Pipelines 1 and 2

- I-40

- Federal Airways V16 and J46 Advisory Committee on Reactor Safeguards l 19

Section 2.2 - Evaluation of Potential Accidents Effects of Design Basis Events Evaluations were performed of the potential hazards nearby to the CRN Site. These evaluations concluded that potential accidents involving explosions, flammable vapor clouds, collisions with intake structures, and liquid spills do not pose a threat to the CRN Site.

Evaluation of the potential effect of toxic chemical releases from nearby industrial and transportation routes concluded that, except for anhydrous ammonia and chlorine potentially transported along I-40, the distance to the toxic endpoints are less than the distance to the CRN Site power block area. A main control room habitability analysis will be performed at the time of COLA for the transport of anhydrous ammonia and chlorine on I-40.

The effects of chemical releases from onsite chemical storage will be evaluated in the COLA because plant features such as the control room habitability system design and location of safety-related structures must be considered to determine there is no adverse effect from these hazards.

Advisory Committee on Reactor Safeguards l 20

Chapter 3 - Section 3.5.1.6 Aircraft Hazards Advisory Committee on Reactor Safeguards l 21

Section 3.5.1.6 - Aircraft Hazards NUREG-0800 establishes that the risks as the result of aircraft hazards should be sufficiently low, in that each requires that aircraft accidents that could lead to radiological consequences in excess of the exposure guidelines of 10 CFR 50.34(a)(1) with a probability of occurrence greater than an order of magnitude of 10-7 per year should be considered in the design of the plant.

Utilizing proximity criteria, TVA performed a screening analysis to establish whether the probability of aircraft accidents for the proposed CRN Site is considered to be less than an order of magnitude of 10-7 per year by inspection.

Advisory Committee on Reactor Safeguards l 22

Section 3.5.1.6 - Aircraft Hazards Criterion 1:

The plant-to-airport distance, D, is between 5 and 10 statute miles, and the projected annual number of operations is less than 500 D2, or the plant-to-airport distance, D, is greater than 10 statute miles, and the projected annual number of operations is less than 1000 D2.

Five small privately-owned airports are located between 5 and 10 statute mi of the CRN Site and two small privately-owned airports are within 10 to15 statute mi of the CRN Site.

The airport projected number of operations, based on available data, is less than the significance factor (i.e., the allowable annual number of operations) called for by criterion 1.

The results of this evaluation, summarized in SSAR Table 2.2-7 of the ESPA, indicate that the proximity screening criterion 1 is met for each evaluated airport; therefore, no nearby airports need further evaluation.

Advisory Committee on Reactor Safeguards l 23

Section 3.5.1.6 - Aircraft Hazards Criterion 2:

The plant is at least 5 statute miles from the nearest edge of military training routes, including low-level training routes, except for those associated with usage greater than 1000 flights per year, or where activities (such as practice bombing) may create an unusual stress situation.

The CRN Site is located about 19.2 statute mi from the centerline of military training route IR2 this training route or approximately 13.4 statute mi from the edge of the training route.

The closest military operation area (MOA) is the Snowbird MOA located approximately 36 mi from the CRN Site Given this separation distance between the CRN Site and the nearest military training route (greater than 5 mi from the nearest edge of a military training route), along with the distance to the nearest MOA, criterion 2 is met.

Advisory Committee on Reactor Safeguards l 24

Section 3.5.1.6 - Aircraft Hazards Criterion 3:

The plant is at least 2 statute miles beyond the nearest edge of a Federal airway, holding pattern, or approach pattern.

There are two Federal airways, one victor (V) and one jet (J) route (V16 and J46, respectively) whose nearest edge lies within 2 statute mi of the CRN Site.

Thus, due to the proximity of Federal airways V16 and J46, the proposed CRN Site does not meet proximity screening criterion 3.

A detailed aircraft hazards analysis was performed and the expected rate of occurrence of potential exposures resulting in radiological dose has been shown to be on the order of magnitude of 10-6 per year and the realistic probability has been shown to be lower, based on qualitative arguments.

Advisory Committee on Reactor Safeguards l 25

Chapter 15 Transient and Accident Analysis Advisory Committee on Reactor Safeguards l 26

Chapter 15 - Transient and Accident Analysis Accident Selection NEI 10-01, Industry Guidance for Developing a Plant Parameter Envelope in Support of an Early Site Permit recommends that accident analyses model the time-dependent transport of radionuclides out of the reactor core through several pathways, each with different time-dependent removal mechanisms for radionuclides.

- For the purposes of evaluating offsite post-accident doses, the vendor analysis with the highest resultant post-accident dose was selected for use in the CRN Site-specific dose analysis.

Each of the four small modular PWR designs under consideration for the CRN Site is expected to include advanced design features that would further minimize accident consequences.

TVA anticipates that the consequences of a LOCA will be less than those for large PWR designs and that no events of greater consequence will be identified.

The COLA will verify that the accident doses provided in this ESPA are bounding or provides an evaluation of accident radiological consequences. Advisory Committee on Reactor Safeguards l 27

Chapter 15 - Transient and Accident Analysis Source Terms The PPE LOCA source term is based on a design that uses standard light-water reactor fuel, which is representative of the SMR designs under consideration, and assumes a core power level for a single unit at 800 MW thermal.

To assess reasonableness, a comparison of the PPE LOCA source term to that of the AP1000 design was performed.

- The activity release associated with the worst 2-hour time period of the scaled-down AP1000 is approximately 25 percent greater than that for the surrogate plant (as provided in the PPE).

- The activity release for the 30-day duration of the LOCA is approximately equivalent to that of the surrogate plant and is also considered reasonable.

Advisory Committee on Reactor Safeguards l 28

Chapter 15 - Transient and Accident Analysis Evaluation Methodology and Conclusions SMR Doses for a LOCA are evaluated at the EAB and LPZ boundary.

Doses are calculated using the ratio of the /Q methodology.

The evaluation uses the following parameters:

- Short-term 95th percentile accident atmospheric dispersion factors (X/Qs) for the CRN Site.

- Bounding vendor-provided LOCA doses.

- X/Q values associated with the bounding vendor-provided LOCA doses.

The resulting accident doses are expressed as total effective dose equivalent (TEDE),

consistent with 10 CFR 52.17. All site LOCA doses meet the 25 rem TEDE limit specified in 10 CFR 52.17 Advisory Committee on Reactor Safeguards l 29

ACRS Subcommittee Meeting l November 15, 2017 l 30 Presentation to the ACRS Subcommittee Safety Review of the Clinch River Nuclear Site, Early Site Permit Application Demography/Geography/Site Hazards:

(SSAR Sections 2.1 and 2.2)

Presented by Seshagiri Rao Tammara, Technical Reviewer NRO/DSEA/RPAC May 15, 2018 1

Key Review Areas 2.1 Geography and Demography Site Location and Description Coordinates, site boundaries, orientation of principal plant structures, location of highways, railroads, and waterways that traverse in the vicinity of the site and exclusion area Exclusion Area Authority and Control Legal authority, control of activities unrelated to plant operation, and arrangements for traffic control Population Distribution Current population and future projections, characteristics of the low population zone (LPZ), population center distance, and population density 2 .

Key Review Areas 2.1 Geography and Demography Staff reviewed the information provided by the applicant pertaining to Site Location and Description, and also checked independently the information available from the public domain. Staff found it to be acceptable as they satisfy the guidance provided in NUREG-0800 Section 2.1.1.

Staff reviewed the information provided by the applicant pertaining to Exclusion Area Authority and Control.

Based on the information provided, the staff finds it to be acceptable as it satisfies the guidance provided in NUREG -0800 Section 2.1.2.

3

Key Review Areas 2.1 Geography and Demography (contd)

Staff reviewed the information provided by the applicant pertaining to Population Distribution including population projections covering the life of the plant, Population Center Distance and Population Density.

Based on the information provided by the applicant and staff's independent confirmatory evaluation, the staff found the information to be acceptable as it meets the requirements of 10 CFR 100.20.

4 .

Key Review Areas 2.2 Nearby Industrial, Transportation, and Military Facilities Identification of Potential Hazards in Site Vicinity Maps of site, nearby significant facilities and transportation routes Description of facilities, products, materials, and number of people employed Description of pipelines, highways, waterways, airways and airports Projections of industrial growth 5 .

Key Review Areas 2.2 Nearby Industrial, Transportation, and Military Facilities (Contd)

Staff reviewed the information provided by the applicant pertaining to the location and description of Nearby industrial, Transportation and Military Facilities for the evaluation of potential hazards for the safe operation of the proposed plant.

Based on the review of information provided by the applicant and the staffs independent checking of information from the available data from the public domain, the staff found it to be acceptable as the information meets the guidance provided in NUREG-0800 Section 2.2.1-2.2.2.

The current site plans indicate future construction of an airport nearby the site by 2022. If this is in operation by COLA stage, its impact evaluation is required to be addressed in COLA. Permit condition 2.2-1 concerns this requirement.

6 .

Key Review Areas Evaluation of Potential Accidents:

Design-Basis Events: Accidents having a probability of occurrence on the order of magnitude of 10-7 per year or greater and resulting in a potential consequences exceeding 10 CFR 100 dose guidelines Explosions and Flammable Vapor Clouds - Industrial Facilities, Truck Traffic, Pipelines, Waterway Traffic Release of Hazardous Chemicals - Transportation Accidents, Major Depots, Storage Areas, Onsite Storage Tanks Fires - Transportation Accidents, Industrial Storage Facilities, Onsite Storage, Forest 7 .

Key Review Areas Evaluation of Potential Accidents (Contd):

Staff reviewed the applicant-provided site specific evaluations of potential accidents. The applicant performed evaluations of potential hazards due to nearby facilities in the CRN Site vicinity.

The effects of chemical releases from onsite chemical storage will be evaluated in the COLA referencing this ESP, because the locations of storage, control room and other safety-related structures designs and locations will be determined at COLA stage.

8 .

Key Review Areas Evaluation of Potential Accidents (Contd):

Based on the review of the applicant-provided information, analyses and the staffs independent confirmatory calculations, the staff found the applicants conclusions to be acceptable, as the evaluations are in accordance with the guidance provided in NUREG-0800 Section 2.2.3, with the exception of potential impacts from toxic chemical release of anhydrous ammonia, chlorine and nitric acid from a truck transport on nearby roadway.

Since the applicant determined the minimum safe distance due to potential toxic chemical concentration of anhydrous ammonia, chlorine and nitric acid from the potential release from a truck transport is greater than the actual distance, the applicant is committed and shall reanalyze the impacts of the delivery tanker truck using guidance provided in RG 1.78 and NUREG-0800, to demonstrate the compliance with 10 CFR100.20. Therefore, Permit Condition 2.2-2 is included.

9

Presentation to the ACRS Subcommittee Safety Review of the Clinch River Nuclear Site, Early Site Permit Application Aircraft Hazards: (SSAR Section 3.5.1.6)

Presented by Seshagiri Rao Tammara, Technical Reviewer NRO/DSEA/RPAC May 15, 2018 1

Key Review Areas 3.5.1.6 Aircraft Hazards For the site suitability, the plant design should consider that any of the aircraft accidents is not a design basis event (where the aircraft accident could lead to radiological consequences in excess of the exposure guidelines of 10 CFR 50.34(a)(1) with a probability of occurrence greater than an order of magnitude of 10-7 per year)

Federal airways, holding patterns, or approach patterns should be at least 2 statute miles away Military installation or any airspace usage (e.g., bombing ranges) should be at least 20 miles from site All airports should be at least 5 miles from site 2 .

Key Review Areas 3.5.1.6 Aircraft Hazards (Contd)

All airports should have projected operations less than:

1. 500d2 for airports within a distance (d) of 5 to 10 miles

2. 1000d2 for airports outside of 10 miles distance (d)

Staff reviewed the applicants information pertaining to site-specific aircraft analysis (aircraft hazards).

The applicant calculated the aircraft crash probability for the identified two airways (V16 and J46) which are within 3.2 km (2 mi) of the CRN Site.

The applicant determined the aircraft crash probability of 7.53 x 10-7 per year using non-airport operations referenced in DOE-STD-3014-96, Accident Analysis for Aircraft Crash into Hazardous Facilities.

3 .

Key Review Areas 3.5.1.6 Aircraft Hazards (Contd)

The staff performed independent confirmatory aircraft crash probability calculations using the highest recent 5-year (2011-2015) Federal Aviation Administration (FAA) supplied flight operations data within 8 km and 16.1 km (5 mi and 10 mi) of site.

The potential aircraft crash probability of 1.5 x 10-8 per year is conservatively estimated by the staff, assuming that all the flights within 16.1 km (10mi) of CRN Site from FAA data follow these two airways.

Therefore, staff agrees with applicants conclusion that the aircraft crash probability is about an order of magnitude of 10-7 per year or less and meets the provided NRC guidelines.

4 .

Presentation to the ACRS Subcommittee Safety Review of the Clinch River Nuclear Site, Early Site Permit Application Accident Analysis, (SSAR Chapter 15)

Presented by Seshagiri Rao Tammara, Technical Reviewer NRO/DSEA/RPAC May 15, 2018 1

Accident Analysis SSAR Chapter 15 Accident Analysis Evaluation of the radiological consequences of postulated Design Basis Accidents (DBAs) for the proposed CRN Site Dose analysis used:

1. PPE accident source term consisting of assumed DBA isotopic releases to environment in lieu of specific plant design information

2. Site characteristic short term (accident) atmospheric dispersion factors (See review of SSAR Chapter 2) 2

Regulations and Guidance SSAR (10 CFR 52.17(a)(1)) and siting (§50.34(a)(1)) postulated accident dose analysis requirements have the same dose criteria:

The evaluation must determine that:

1. An individual located at any point on the boundary of the exclusion area for any 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> period following the onset of the postulated fission product release would not receive a radiation dose in excess of 25 rem total effective dose equivalent (TEDE).

2. An individual located at any point on the outer boundary of the low population zone, who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage) would not receive a radiation dose in excess of 25 rem TEDE.

SRP 15.0.3 provides review guidance, including evaluation of PPE accident releases.

3

PPE Accident Source Term Chapter 15 Accident Analysis (contd)

The radionuclide release to the environment for a loss of coolant accident (LOCA) is documented and is considered by the applicant in the ESP application as a part of the PPE in SSAR Table 2.0-3.

Staff found the PPE LOCA release source term to be not unreasonable for the purposes of site analysis or postulated from considerations of possible accident event.

The PPE source term is compared with that of AP1000 design (provided in Vogtle 3 and 4 ESPA) with scaling ratio of 0.235 (800 MWt/3,400 MWt) and ascertained to be not unreasonable.

4

DBA Dose Analysis Chapter 15 Accident Analysis (contd)

The accident doses at the exclusion area boundary (EAB) and the outer boundary of the low population zone (LPZ) at the CRN Site are obtained by multiplying the vendor supplied dose associated with bounding PPE LOCA source term, by the ratio of the site-specific(site-characteristic) and vendor supplied site-parameter X/Qs.

Dosesite = Dosevendor [(X/Q)site / (X/Q)vendor ]

Analysis meets the dose criteria specified in 10 CFR 50.34(a)(1) and 10 CFR 52.17(a)(1) and the PPE includes the bounding accident releases for the determination.

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DBA Dose Analysis Chapter 15 Accident Analysis (contd)

The calculated radiological consequences at CRN Site are within regulatory dose criteria of 25 rem TEDE for the maximum 2-hour period at the EAB and 25 rem TEDE at the outer boundary of the LPZ for the duration of the accident release. The analyses used and PPE source term are not unreasonable. Therefore, staff considers the applicant approach adequate and acceptable in meeting the regulatory requirements of 10 CFR 50.34(a)(1) and 10 CFR 52.17(a)(1).

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