ML21309A057

Public Meeting Transcript Reactor Pressure Vessel Embrittlement Monitoring and Prediction in Long-Term Operation

ML21309A057
Person / Time
Issue date:	10/18/2021
From:	NRC/NMSS/DREFS/RRPB
To:
Schneider, Stewart
References
20211318, NRC-1694, NRC-2021-0174
Download: ML21309A057 (69)

Text

Official Transcript of Proceedings

NUCLEAR REGULATORY COMMISSION

Title:

Public Meeting on Reactor Pressure Vessel Embrittlement Monitoring and Prediction in Long-term Operation

Docket Number: (n/a)

Location: teleconference

Date: Monday, October 18, 2021

Work Order No.: NRC-1694 Pages 1-67

NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1716 14th Street, N.W., Suite 200 Washington, D.C. 20009 (202) 234 -4433 1

UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

+ + + + +

PUBLIC MEETING ON REACTOR PRESSURE VESSEL

EMBRITTLEMENT MONITORING AND

PREDICTION IN LONG-TERM OPERATION

+ + + + +

MONDAY,

OCTOBER 18, 2021

+ + + + +

The public meeting took place via Video

Teleconference, at 1:00 p.m. EST, Joan Olmstead, NRC

Facilitator, presiding.

PRESENT:

JOAN OLMSTEAD, NRC Facilitator

SCOTT BURNELL, NRC Public Affairs Officer

ALLEN HISER, NRR Senior Technical Lead

ELLIOT LONG, Principal Technical Lead, EPRI

DAVID RUDLAND, NRR Senior Technical Lead

STEWART SCHNEIDER, NMSS Senior Project Manager

ROBERT TAYLOR, NRR Deputy Officer Director

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P R O C E E D I N G S

1:08 p.m.

MS. OLMSTEAD: Good afternoon. My name is

Joan Olmstead, I am a member of NRC's Facilitator's

Corps, and it's my pleasure to facilitate this

afternoon'smeeting. Slide two, please.

This is an information meeting with a

question-and-answer session. And the purpose of this

meeting held by the Nuclear Regulatory Commission, or

NRC, staff is to meet directly with individuals to

discuss regulatory and technical issues.

Attendees will have an opportunity to ask

questions of NRC staff and provide feedback about the

issues during the discussion and question-and-answer

period. However, the NRC is not actively soliciting

comments towards regulatory decisions at this meeting.

The public announcement for this meeting

can be found in the Agencywide Documents Access and

Management System, ADAMS, in the -- the number is

ML21280A267. The NRC staff presentation slides can be

found in ADAMS under the accession number ML21270A002.

So, thank you for attending this meeting.

We are early in our review process, and this exchange

of information of NRC staff evaluation of reactors

pressure vessel embrittlement in long-term operation

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is important to the NRC's review.

The NRC staff discussion will include

information related to the embrittlement trend curve

in Regulatory Guide 1.99 Rev 2, Radiation

Embrittlement of Reactor Vessel Materials. And in 10

CFR 50.61, Fracture Toughness Requirements for

Protection against Pressurized Thermal Shock Events.

And the surveillance requirements in 10 CFR Part 50,

Appendix H, Reactor Vessel Material Surveillance

Program Requirements.

This is an information-gathering meeting.

And by the NRC's definition this means primarily the

purpose of this meeting is to exchange information

with members of the public and other stakeholders.

The NRC staff will also answer process-related

questions if time permits.

I'd like to note that the NRC has

continued to operate in a largely work-at-home status,

so most participants in this meeting are working

remotely and individually calling in. We recognize

this configuration presents unique challenges and

continue to welcome comments about what is and what

isn'tworking and with this meeting format.

Prior to the close of the meeting, I'll provide

information on how you can provide your feedback on

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today's meeting, and your inputs helps us improve

future NRC public meetings.

The agenda for our meeting is fairly

straightforward. After a presentation by NRC staff,

we'll have a presentation from the Electric Power

Research Institute, EPRI, and we will then give the

public an opportunity to provide feedback and ask

questions of the NRC staff.

This meeting is scheduled from one to four

p.m. Eastern Time. And we'll try to allow as much

public input as possible, but we will generally try to

adhere to the meeting schedule. Today's call is meant

to be an exchange of information, and as always for

NRC public meetings,no regulatory decisions will be

made. Slide 4, please.

This slide notes speakers for this

afternoon's meeting. Robert Taylor, Deputy Office

Director for the Office of Nuclear Reactor Regulation,

will be giving opening remarks, followed by David

Rudland,NRR Senior Technical Lead for this project.

Allen Hiser and Stewart Schneider are senior NRC staff

that also support this activity.

And with that, I'll turn this over to

Robert. Robert.

MR. TAYLOR: Thanks, Joan. Can everyone

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hear me?

MS. OLMSTEAD: Yes, we can hear you.

MR. TAYLOR: Great. So I wanted to take

the opportunity and open up this meeting and set a

tone for the discussion that we're going to have

today. And I'm excited to see the number panel -- or

number of attendees who've shown up for the meeting

and expressed interest in this. And we look forward

to hearing perspectives and feedback during the

meeting.

So for those of you who don't me, my name

is Rob Taylor. I'm the Deputy Office Director for New

Reactors in the Office of Nuclear Reactor Regulation,

and I have the materials issues for operating plants

under my responsibility as well. So I want to welcome

everyone to today's meeting. This is an important

topic as the NRC applies risk-informed approaches to

its safety mission.

Today we will hear from the NRC staff

about their efforts associated with monitoring and

prediction of reactor pressure vessel embrittlement

during longterm operation of nuclear power plants.

The NRC staff is continuing a discussion of these

issues that were first presented in a May 2020 public

meeting.

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During today's meeting, staff will

describe a holistic risk-informed analysis they've

performed on these issues and the potential impact on

reactor pressure vessel integrity. I want to assure

everyone that the NRC has high confidence that

operating plants remain safe and currently the NRC

regulations provide reasonable assurance of adequate

protection against brittle fracture of the reactor

pressure vessel.

Nothing in this meeting should be

construed as undermining our continued confidence in

the safe operation of these facilities. Instead, as

with any proactive and scientific regulatory program,

we should continue to assess new information and

identify places where our regulatory programs may need

enhancement in the future.

As such, today's meeting is intended to

gather insights and perspectives on this topic, and we

are not making any regulatory decisions.

The staff is proactively considering risk-

informed options to address the combined effects of

both issues of what we discuss today to ensure

continued reasonable assurance of adequate protection

against brittle fracture of the reactor pressure

vessels during longterm operation. The staff is very

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interested to receive feedback from external

stakeholders regarding the NRC staff's approach taken

in a holistic risk-informed analysis.

Other potential efforts impact to plant

operations that should be considered and if now is the

appropriate time to pursue these issues. The NRC

staff sincerely appreciates the external stakeholder

interest in these topics. We're expecting a very

interesting and productive meeting.

So with that, Joan, I will turn it back

over to you.

MS. OLMSTEAD: Thank you, Robert. Slide

5, please. This slide provides logistic information

on today's meeting. Please log into both the Webex

and call in to the toll-free phone line. The audio is

only through this bridge line. This arrangement

allows us to minimize our bandwidth to have a more

stable meeting platform and to help conduct the

meeting's discussion and question-and-answer session.

If you're not on Webex and you'd like to

view the presentation slides, they are in the NRC's

ADAMS document database. And the session number for

the package containing today's slides is ML21270A002.

The session slide's ML number is also included in the

public meeting announcement.

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Today's call is on an operator-moderated

phone line. Participants will have their lines muted

until we reach the portion of the meeting where they

can provide feedback and ask questions of the NRC

staff. You'll be given instructions on how to

participate before the discussion and question-and-

answer session portion of this meeting.

As indicated in the agenda, we have

allocated substantial portion of this meeting for this

process. However, if participants would like to email

questions to our public affairs officer during the

staff's presentation, please email Mr. Scott Burnell

at scott.burnell@nrc.gov.

Today's call is being recorded and will be

transcribed. The transcription will be made available

alongside with the published meeting summary. Given

the number of participants we expect on the call and

the format, I would ask that as a person speaks, they

introduce themselves each time they speak. I also ask

that the speakers limit their use of acronyms.

Your participation will be noticed in the

meeting summary if you provide your information

through Webex or the bridge line. Slide 6, please.

And now I'd like to introduce David

Rudland, NRR's Senior Technical Lead, to discuss the

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purpose of the meeting and provide NRC's presentation.

David.

MR. RUDLAND: Thanks. I'll do a sound

check to make that you can hear me okay.

MS. OLMSTEAD: Yes, I can hear you, David.

MR. RUDLAND: Okay, great. Yeah, as

introduced, my name is Dave Rudland, and I am a Senior

Technical Advisor for Materials in the Division of New

and Renewed Licenses in NRR. And I'm going to be

going through the slides today.

The purpose of our meeting this afternoon

is to continue the discussions we had, as Rob Taylor

pointed out in the May 2020 public meeting, on two RPV

embrittlement issues. The first being the

embrittlement trend curve in Regulatory Guide 1.99 Rev

2, which is also in 10 CFR 50.61. And it's, the

issues with that trend curve at high fluence where the

predictions appear to be in some circumstances under-

predictive of the measurements.

And the second issue is to talk about

Appendix H, the surveillance testing program. This is

10 CFR Part 50, Appendix H. And we'll be looking at

those issues and those circumstances where some

capsules have been delayed, leaving large gaps between

surveillance tests.

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We talked about the technical details at

that particular public meeting, so I'm not going to go

over those details again. I will talk about, briefly

talk about the issues but won't go into the details

that we did in that public meeting.

I will be discussing a holistic risk-

informed analysis that looks at both of these issues

together and its impact on vessel integrity. And

again, this is a risk-informed analysis that takes a

look at the complete issue.

As mentioned also this is going to be

mainly a technical discussion, and no regulatory

decisions will be made. We'll be talking about some

options that the staff is considering about how to

move forward, so of course we would like feedback not

only the analysis results that I'll be presenting, but

also on some of the options that we discuss later on

also. Next slide, please.

Before I get into the issues, I wanted to

kind of give a quick background on how the monitoring

prediction of embrittlement works. Within this

Regulatory Guide 1.99 and 10 CFR 50.61 there is an

embrittlement trend curve, and that trend curve

predicts changes in fracture toughness as a function

of fluence. The embrittlement is measured by a change

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in the transition temperature from a brittle fracture

to a ductile fracture.

As you can see in this -- in the left

illustration, there is a measure of embrittlement at

the beginning of life. The red curve demonstrates a

trend that is predicting an increase in embrittlement

with an increase in fluence.

In addition to that, surveillance capsule

testing provides monitoring to ensure the

embrittlement trend curve predicts the plant-specific

behavior properly. And the data left plot is

illustrating how the data would fall in the

embrittlement trend curve predicts the behavior

properly.

Within the regulations, a margin is added

to those predictions from the trend curve, producing

something called an adjusted reference temperature.

That adjusted reference temperature is then used in

the regulations such as 10 CFR 50 Appendix G to

predict the pressure temperature limits for normal

operation, which is shown in an illustration in the

right figure.

You can see illustrated pressure-

temperature curves for 40, 60, and 80 years and how

those curves move to the right as the vessel becomes

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more brittle. And what that does is that shortens the

window, it reduces the size of the operating window

for a plant to cool down. All right, next slide,

please.

So the idea scenario for these two working

together is that you have ETC that provides accurate

or conservative predictions of embrittlement and

surveillance data that covers all operating periods.

Because Appendix H lists that that is type of data

should be pulled periodically throughout the life of

reactor.

However, you can have certain

circumstances where you may end up with uncertainty in

those predictions. For instance, as illustrated on

the left figure again, you can have an embrittlement

trend curve that may under-predict the measurements.

As you can see, the orange and pink data illustrate

that the red curve under-predicts that behavior. That

could have a source of some uncertainty.

Or, as illustrated in the picture on the

right, you may have limited data or no data at high

fluence, in which the uncertainty is even larger in

how well the embrittlement trend curve predicts the

actual embrittlement state of that particular

material.

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And so each one of these conditions could

have uncertainty and could add to the issues with the

embrittlement trend curves. Next slide, please.

Illustrating that a different way, as you

can see at the top figures, if we have reasonably

periodic measurement of embrittlement and an accurate

embrittlement trend curve, then you have an expected

amount of uncertainty, which is illustrated in the

upperrighthand figure by the blue dashed lines.

And our margins and regulations are based

on the amount of expected uncertainty. However, like

I mentioned, if you have missing data or, and/or an

embrittlement trend curve that may under-predict the

behavior, you could have an increased amount of

uncertainty.

And with that increase amount of

uncertainty, we are not sure that we understand what

the impacts of that uncertainty are on future

predictions of embrittlement. And so this holistic

analysis was needed to really understand what the

impacts of that uncertainty -- impacts for that

uncertainty are on the behavior of the vessel. Next

slide, please.

So our current perspectives on this

potential issue. As Rob pointed out, we have high

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confidence that the current operating plants remain

safe and that all of our current and recent licensing

actions remain valid.

However, with some insufficient

embrittlement monitoring and under-predictions of the

embrittlement trend curve, we may have an impact on

the confidence in the integrity of the vessel in

longterm operations, in that safety margins and

performance monitoring may be impacted.

And what we feel right now is that we need

to do future work in order to determine which plants

are impacted by this potential issue. I'll go into

that a little bit more as we go through this

presentation. Next slide, please.

So I'm going to go into some details right

now about each of the issues, just briefly touching on

the issues before we go into the holistic analysis.

In May of 1988, the NRC published Regulatory Guide

1.99 Rev 2, which contained an improved embrittlement

trend curve that was fit on 177 surveillance data

points.

And then in June of '91, the NRC updated

10 CFR 50.61 to include that same embrittlement trend

curve that was in Regulatory Guide 1.99 Rev 2 to

address some issues that were being had with lower

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than measured predictions of the current -- of the

embrittlement trend curve that was in 10 CFR 50.61

prior to that update.

More recently, the embrittlement trend

curve was reevaluated for continued adequacy in 2014

and in more detail in 2019. Those evaluations are

public and the ADAMS accession numbers are shown on

this screen for more information. Next slide, please.

To go into some, a little detail about

what we're seeing with the embrittlement trend curve,

this plot illustrates that behavior. On the Y axis,

on the vertical axis, this is a measure of the

difference between the embrittlement predicted by

Regulatory Guide 1.99 Rev 2, the difference of that

value versus the measure value from surveillance data.

So a value of zero on this vertical axis

represents a perfect prediction of embrittlement from

that trend curve. The X axis is an increase in

fluence. And what you see is that you have a pretty

good prediction through most of the fluence history.

You have some scatter in the data. The

solid --I'm sorry, the dashed heavy lines represent

the standard deviation in the data, the scatter in the

data as expected by Regulatory Guide 1.99.

As you get higher and higher fluence, the

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scatter in the data becomes greater. And at 3E to the

19th fluence, the trends begin to deviate from that.

I should point out that the red points on this plot

are US data, US surveillance data, and the gray points

are from international data.

At about 6E to the 19th, the data becomes

statistically significant in that the deviation

becomes greater than that two standard deviation that

I mentioned. And by the time you get to about 1E to

the 20th neutrons per centimeter squared fluence, you

can have about up a minus 180 degrees Fahrenheit of

under-prediction of embrittlement.

And again, remember, in this case

embrittlement is being measured by a shift in the

transition temperature. I will go into some detail, a

little bit, of that temperature means and what the

significance of that temperature is in a few slides.

Next slide, please.

This is a plot for --the prior plot was

for base metals. This particular plot is for weld

metals. And you see a similar behavior. You have

good predictions at low fluence. However, as the

fluence gets larger, the scatter is getting -- the

scatter is getting bigger than what was predicted from

Reg Guide 1.99.

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However, at high fluence there's limited

data. And so you don't see the downward trend,

probably due to the lack of data at this particular

time. Okay, next slide, please.

Each of this is being driven by the

fluence function within the embrittlement trend curve

in Regulatory Guide 1.99. The embrittlement is

predicted with that trend curve through a combination

of information from the material chemistry, as well as

the fluence. This equation that's at the top of the

chart shows that equation for predicting the

embrittlement.

CF is a chemistry factor that's a function

of nickel and copper. And then the fluence function

f is from the next part of the equation. And what's

plotted on this particular plot is that fluence

function as a function of fluence. And what you --

and what we see is about that about 3E to the 19, the

fluence function begins to -- the slope begins to

change and actually reaches a peak and begins to

decrease.

This point at which this inflection occurs

corresponds to the same fluence levels where the

under-prediction begins on Slide 12. It's unknown

right now whether or not the actual fluence function

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should follow that light blue line, or whether it

should increase slightly or decrease slightly. But we

know that following the dark blue line causes this,

some of this under-prediction to occur.

And the reason why this is there is

because at the time when this was developed, there was

a limited data. It was like I mentioned earlier, only

177 data points. And so when you extrapolate the

curve beyond the area in which we had data, that

behavior occurs. All right, next slide, please.

All right, so that's the main issues with

the embrittlement trend curve. I'm going to move now

to surveillance capsule. Appendix H from 10 CFR Part

50, as I mentioned earlier, requires periodic

monitoring of the changes in fracture toughness due to

neutron embrittlement. The regulation incorporates by

reference an ASTM standard, E185, that sets up the

testing surveillance schedule of details for a

program.

And these programs are typically about

three to five capsules. The capsules include material

property specimens that are placed inside the core,

closer to the core than the reactor vessel wall.

They're pulled at certain times and tested

to try to get a future behavior of embrittlement. The

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ASTM standard allows the last capsule, the final

capsule, to be pulled and tested at two times the

reactor pressure vessel design fluence.

Realizing that E185-82 was originally

really designed for 40- year lives, the last capsule --

I'm sorry, the second-to-last capsule was meant to be

tested at a fluence that was corresponding to about 40

years' life. And the last capsule therefore could be

tested at a much higher fluence.

And in fact, the ASTM standard allows for

holding and not testing that last capsule if you're

able to get the fluence, the correct fluence in the

first few capsules.

However, as we've moved to license renewal

and to subsequent license renewal, those particular

lives have changed from 40 years to 60 years and 80

years. And so that particular capsule continues to be

moved out.

In '97, the Commission made a finding

related to the Perry Plant that any time a staff

reviews a request to change a capsule withdrawal

schedule, it's limited to a verification or a

conformance kind of check to the ASTM standard. There

can't be a technical or safety check.

And because of the extended design lives,

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the change in the design fluence capsules and the

testing has been repeatedly delayed in some cases to

achieve to higher and higher fluence. Next slide,

please.

So as we went into license renewal, the

regulations --the staff decided the regulations did

not need to be changed, that the surveillance programs

could be addressed in the guidance. And the guidance

now provides flexibility to let the licensee

demonstrate adequate aging management.

Within the GALL reports, there are several

statements relating to these capsule programs. In

NUREG-1801 Rev 1, there's a statement that at least

one capsule with a projected neutron fluence equal to

or exceeding the 60- peak fluence needs to be tested --

needs to be tested.

In NUREG-2191, which is the GALL-SLR,

there's a similar statement that says withdrawal and

testing of at least one capsule with a neutron fluence

of the capsule between one and two times the peak

neutron fluence of interest at the end of the

subsequent period of operation need to be tested. And

it also specified that it's not acceptable to redirect

or postpone the withdrawal of testing to reach a

higher fluence level. Okay, next slide, please.

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What's happening in practice, however, is

that licensees are changing their capsule withdrawal

schedules prior to application. And this is only in

some cases. Prior to application for license renewal

or subsequent license renewal. And that change is

being evaluated under the current approach of

conformance, consistent with the Commission guidance

for earlier.

And then the current license basis

surveillance programs then are consistent with the

GALL program once they receive that conformance review

and approval. Next slide, please.

So this shows an example of one of those

cases. And in this particular figure, the Y axis

again is a measure of neutron fluence. The X axis is

the date at which a surveillance capsule was pulled

and tested. The black circled data points represent

one particular plant that has pulled four capsules.

And you can see theyears in which they were pulled.

Their last capsule was pulled around the

time of 2008 or so. Their fifth capsule was to be

tested at that first X, the orange X mark, which was

about 2009. And as you can see, it was moved a total

of four times, now to be tested somewhere around 2025.

There have been a lot of licensees that

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have delayed capsules. Some examples are shown on

this slide. But I do want to point out that not all

plants have delayed their withdrawal capsules. Many

have not,but some have.

And these changes have not been against

the guidance or the regulation. They have been moved

properly with the appropriate approvals. All right,

next slide, please. Hit one more time, please.

This is just another example to show of

the impact of this. This is this plot I showed

earlier of the difference between predicted and

measured embrittlement as a function of fluence. The

green lines on the plot show the four early

surveillance data points.

And what you can see is that all fourof

those fall within that range in which the

embrittlement trend curve does a good job at

predicting the embrittlement.

This particular plant's 60-year mark and

80-year mark are shown in blue. You can go one more

forward. And their fifth capsule is to be pulled in

2026, which is not until the 80- year mark, which is

about 1E to the 20th. Or they could have up to a

minus 180 degree under-prediction in their

embrittlement.

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And you can see here there's 25 years in

between when the last capsule was pulled and when the

next capsule is planned. Okay, next slide now. One

more time please.

This is a plot, again, a different way to

plot this. Embrittlement on the Y axis, on the

vertical axis, fluence on the horizontal axis. The

four data points I talked about earlier, you can see

how they are. One more time forward, please. If they

were to use Regulatory Guide 1.99 and only use the

material chemistry and the fluence, this was the

embrittlement trend that they would get, this orange

line.

The Regulatory Guide also allows them to

fit the data to adjust their embrittlement trend

curve. So if I take those four data points and I

adjust the embrittlement trend curve for those four

data points, I get the blue curve, which they can use.

So at 1E to the 20th, they have a embrittlement

measurement of about 230 degrees Fahrenheit.

If they were to test it and the tests were

to show the under-prediction that was suggested in the

previous slide, they could have about 150 degrees of

under-predicted fromtheir --from that blue line or

the adjusted embrittlement check.

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If I assume those two data points are

actual and I refit those using the procedures in

Regulatory Guide 1.99 Rev 2, I would get this yellow

line. Even with this yellow line, I still have under-

prediction of -- hit one more time please. I still

have an under-prediction of about 75 degrees, because

again, the fluence function does not properly predict

the behavior of the embrittlement.

Because of that flattening off and

decrease, the embrittlement trend -- or even when I

fit the data would not be an appropriate fit. In

actuality, the data would be a not credible because of

the differences between the data and embrittlement

trend curves, and the Regulatory Guide 1.99 would tell

them to go back and use the original curve, the orange

curve.

So there could be, even if we have the

data, there could still be issues with the

embrittlement trend predicting -- under-predicting the

actual behavior. Next slide, please.

So with those two issues that I talked

about, the under-prediction in embrittlement from

Regulatory Guide 1.99 and the same trend curve which

is in 50.61, and this issue with delaying the capsules

in Appendix H surveillance programs, the staff wanted

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to understand what the combined impacts were on

safety. And they used a risk-informed approach that

leveraged the five principles of risk-informed

decisionmaking.

And we wanted to make sure that not only

did we look at these five principles, but we kept in

mind the conditions in which this -- these issues were

of concern. And so we tried to choose a targeted

sample of plants to do this analysis on and use the

data that we had, but there was much plant-specific

information that was not available. And I'll talk a

little bit about that in terms of uncertainty here in

a couple of minutes. Next slide, please.

One of the main assumptions that we used

at the beginning was we wanted to compare the

embrittlement trend curve results from 1.99 to ASTM

E900-15 embrittlement trend curve. And we did that

because the staff found that this particular trend

curve provided the most accurate characterization of

the database of material.

This database of material that I've shown

here was what ASTM used in making -- in developing

this particular embrittlement trend curve. And the

staff report where the staff did this evaluation is

shown below. The ML number for that is shown below.

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And what the data shows here is that -- is

that the predictions are good for most of the fluence

levels. Even the standard deviations seem relatively

reasonable if you don't see that dropoff in either the

base metals or the welds. So we wanted to use this as

a baseline. Next slide, please.

So the assumption that we used in the

analysis was we targeted a sample of 21 plants. We

focused on high fluence plants, because again, this

issue seems to be focused on fluences that were

greater than about 3E to the 19. But we included some

low copper plants or plants that weren't accessible to

embrittlement, and some BWRs to kind of round out the

sample of plants that we looked at.

And we -- from those samples and the data

we had, we determined the changes in this adjusted

reference temperature, or this transition temperature

shift from moving from (inaudible) --I'm sorry, can

everybody still hear me? I had a lot of static come

through the line.

MS. OLMSTEAD: Yes, I can hear you now.

MR. RUDLAND: Okay, all right, I'm sorry.

I don't know where that static came from.

And so we calculated what the switch in

adjusted reference temperature was from going from

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Regulatory Guide 1.99 Rev 2 to E900- 15. And we titled

that the embrittlement shift delta, and we used this

embrittlement shift delta to benchmark and to focus

our risk analyses. Can we go to the next slide,

please.

So what we found out from this is that

there is a tendency for the reference temperatures

that we're talking about to increase when switching

from Regulatory Guide 1.99 to ASTM E900-15. And we

say it's a tendency. It didn't happen in all cases,

but on average it seemed to -- the reference

temperature seemed to increase. And the base metals

were more likely to see that increase than the weld

metals.

Most of the cases only had a shift that

was about 50 degrees. There were some that had more

than 50 degrees, but not very many. And those that

did have a shift of more than 50 degrees tended to be

fluences that were around 6E to the 19. And I'll talk

about the impacts of that in one second.

But this range of ESDs, or the

embrittlement shift deltas, is what we assumed in the

risk study that I'll talk about here in a second.

Next slide.

So the staff did a variety of probablistic

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fracture mechanics analyses looking at these impacts.

They looked a variety of conditions, a variety of

transients. Looked at a variety of flaw sizes, both

1/4T flaws and small surface breaking flaws, to

determine if their -- determine what the impact was

going to be.

This particular plot is for a 103 per hour

cool down where the transient follows the PT curve.

If you could hit the next slide, please. So for this

particular plot, there is a -- there's two things.

There's the conditional probability of failure curves

and conditional probability of initiation.

And for the conditional probability of

failure, a 50-degree embrittlement shift delta gave

about two orders of magnitude, or two, or two and a

half orders of magnitude change in the conditional

probability of the failure.

At 150 degrees, if you hit the slide

again, please, there is about six order of magnitude

changes. So it's relatively a large change in

additional probabilities of failure for these

embrittlement shift deltas. But there's a lot of

uncertainties. The main one is the frequency of the

transient.

The frequency of following the PT curve

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during cool down is very low. And so what that is is

it's still a little bit uncertain. There's a lot of

plant fluence variations. We're unsure if these

analyses are bounding. There's a lot of plant-

specific considerations that need to be taken into

account.

And as always, we know that there are

administrative and operational controls in place

against violating PT limit curves and how much

protection do those --do those really give.

Details of this analysis, there's a

summary slide the next slide, but the details of this

analysis can be found in the reference that's shown at

the bottom of this slide. And the ML number is given

there.

So the summary of the results, if you go

to the next slide, illustrates that in most cases, the

conditional probability of failure was low or less

than 1E to the minus 6 from those conditions. And for

those conditions that were greater than 1E to the

minus6, there was some uncertainty.

But the staff felt that through-wall crack

frequency, which again is the conditional probability

of failure times the transient frequency, remains

below 1E to the minus 6. But we felt a bit

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uncomfortable because of these uncertainties.

There needed to be some additional

information that may be required to determine for at

high cool down rates it might be possible. And to

really understand what the event frequencies are, in

all cases, not just following the PT curve, will help

us to gain confidence that the risks are low. All

right, next slide, please.

We also looked at pressurized thermal

shock. That prior slide was for normal operations.

In pressurized thermal shock, again, 10 CFR 50.61 uses

the same embrittlement trend curve for as Reg Guide

1.99. And this RT-PTS that is calculated in that

regulation might be impacted.

There's a screening criteria which is

shown here of 270 degrees F for -- plates, forgings

and axial welds at 300 degrees F for circ welds might

be impacted. And actually if the embrittlement trend

curve was changed, some might actually pass this

screening environment.

However, for the sample that we took, for

the plant that we sampled, we calculated the through-

wall crack frequencies for pressurized thermal shock

with the corrected embrittlement, and it was less than

1E to minus 6 for all cases investigated. So the risk

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for pressurized thermal shock for these issues is

relatively low. All right, next slide.

So even though the risks are low, the

uncertainties are high, and the uncertainties are

increasing with time. And really taking care and

fixing these issues will help us maintain the --the

fundamental safety principles that went into

developing the regulations and the basis for plant

design and operation.

And really, safety margins that we need to

take a look at, as provided by the regulation, provide

reasonable assurance against brittle fracture. All

right, next slide.

I'm going to illustrate what I'm talking

about in this particular -- in this particular way.

This particular plot showed an illustration of a

pressure-temperature curve. The area to the right,

typical operating window, shows, excuse me, the area

in which typical plantscool down. So they'll start

at a high pressure, high temperature and decrease the

pressure and temperature to stay inside this window.

Next, please.

There is a structural limit, and that

structural limit is where if they -- if the particular

plant were to cool down too fast and not reduce

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pressure, they may pass that structural limit and have

a large chance of a brittle fracture. Hit, go again.

The orange curve demonstrates an accurate

PT curve, and that accurate PT curve provides

significant margin -- can you hit one more time,

please. Provides adequate margin between the

structural limit and the operating behavior. And you

notice there still is some gap between the PT curve

and the operating window, and that is usually due to

operational limits. Can you hit again, please.

And that adequate margin that we have

between the structural limit and the regulated PT

curve is directly proportional to each other. So that

the margin and the uncertainty are well aligned. One

more time, please.

However, if we use the current Reg Guide

1.99 and you have a condition where you are under-

predicted the behavior, you can have a PT curve that

shows -- that's shown like this. One more time,

please.

And while this line defines the operating

margin between the PT curve viewed in Reg Guide 1.99

and the operating window, you may actually have a

smaller operating window because the actual PT would

be the orange line. And the margin to structural

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failure -- hit one more time please. The margin is

actually reduced due to this under-prediction. And

that is going against typically how we develop

margins. You can hit more time please.

Typically as the margins -- as the

uncertainty increases, we like to have larger margins

since we -- since we're uncertain. But in this

particular case, the margin is decreasing while the

uncertainty is increasing.

And this increase in uncertainty and

reduction of margin is leading us to evaluate the

behaviors in these two --in both Appendix H and the

embrittlement trend curves in Reg Guide 1.99. Okay,

next slide, please.

And again, we also could talk about

performance monitoring. Appendix H, as I mentioned

earlier, allows for the periodic testing, which allows

us to make sure that an analysis remains valid and the

that the embrittlement trend curves properly predict

the plant-specific behavior, and to make sure that

there's no unexpected safety issues that may occur.

To delay capsule withdrawals or having an

extended period between capsule withdrawals represents

a lack of performance monitoring. Next slide, please.

So in summary, and the with the current

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state of knowledge, the generalized analysis suggests

that the overall risk of brittle fracture is low. The

uncertainty really is high, butit's increasing with

time, especially with the conditions that may be

occurring at high fluence with an under-prediction in

the Reg Guide trend curve and the delaying of

surveillance capsules.

In our particular analyses, though, the

plant-specific details really were not considered

because we didn't have a lot of information. We used

the information that we had. And so that adds to the

uncertainty that we had. And under certain

conditions, the safety margins may be impacted and are

probably decreasing as the uncertainty increases.

As I mentioned, delaying capsules

represents a lack of sufficient performance

monitoring. But most of these issues are focused on

plants or conditions where the fluences are excess of

6E to the 19 neutrons per centimeter squared. All

right, next slide, please.

So who is impacted? Using some data from

the MRP, we can estimate that at about 60 years, about

nine percent of the PWRs surpass the fluence level of

6E to the 19 neutrons per centimeter squared at the ID

surface. Andby 80 years it's about 34%.

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The differences between the columns to the

left and the columns to the right are the BWRs, which

really are not impacted by this because they are --

they operate and will operate through at least 80

years at a much lower fluence.

For those percentages of the -- of the

plants that I'm talking about, plant-specific details,

such as remaining material and other things, really

may contribute to which plants are impacted. And

again, more work is needed to determine how or if any

of those plants are truly impacted.

In terms of surveillance data, any plant

that has renewed its license that chooses to delay the

last capsule will be impacted. Those plants that are

in an integrated surveillance program will not, will

not be impacted. All right, next slide, please.

So what are our goals? Again, like I

mentioned early on, the staff feel that the

regulations are sufficient for a reasonable assurance

of adequate protection against brittle fracture. But

we want to make sure that as we move on into the

future -- as we move on into the future we continue to

have reasonable assurance.

So we want to provide remedies to the

identified solution --to the identified issues with

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the RPV surveillance requirements and the under-

predictions of embrittlement. We want to do that on a

risk-informed performance basis.

And we want to make sure that we don't

impact those plants that are not adversely affected.

The plants that have surveillance data that covers the

end of their license fluence level, and/or those that

may have a fluence that's less than 3E to the 19th --

3E to the 19th neutrons per centimeter squared. Next

slide, please.

So the staff is considering options, and

those options can range from a plant-specific action,

maybe a focused regulatory action, generic

communication, or possibly no action. So within this

discussion, we'd like to talk about these kinds of

things. If we can go to the next slide please.

Some of the things that we would like to

talk about are the options that I just mentioned of

whether or not the staff's approach that we took.

Looking at this thing holistically is appropriate,

seems to be appropriate. Are there other options that

we have not considered, or that we should consider?

Are there any other potential impacts to the plant

that need to be considered that we didn't consider

already? Unnecessary updates to PT limits is just one

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of those.

And is this the right time to pursue these

-- to purse these issues and to make a change on these

issues. I need to say again that the NRC is right now

is not actively soliciting any comments towards a

regulatory decision at this meeting. This is more of

a information-gathering session to understand people's

point of view. Okay, next slide, please.

Okay, so in summary, as I mentioned

earlier, the staff has high confidence that the

operating plants remain safe and that recent licensing

actions remain valid. The issues that I described

here may impact the staff's confidence in about ten

years that the integrity of the vessel for longterm

operation because of safety margins and performance

monitoring may be impacted.

We need to do further work, especially

plant-specific work, to determine which plants are

impacted, but we want to be proactive, and we want to

be able to assure continued reasonable assurance and

do that through a risk-informed, performance-based

solution.

We are considering options. Our desire

has been and will always be to try to focus that

solution on only those conditions that are impacted by

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this issue.

I think that's my last slide. There's no

next slide. Okay, so that's the end of my

presentation. I need to now turn the presentation

over to Elliot Long from EPRI. Elliot Long is a

Principal Technical Leader at EPRI. He will be making

a presentation on behalf of EPRI.

MS. OLMSTEAD: Thank you, David.

Operator, can you please unmute Elliot Long's line,

please.

OPERATOR: Elliot Long, your line is now

open.

MR. LONG: Hello, everyone, can you hear

me clearly?

MS. OLMSTEAD: Yes, we can.

MR. LONG: Excellent.

MS. OLMSTEAD: Elliot, I cannot hear you

now, though.

MR. LONG: (Simultaneous speaking.)

PARTICIPANT: Elliot's slides.

MR. LONG: On the --

MS. OLMSTEAD: Yes. All right, we see the

slides now. And can you put them on the slide view.

Okay. All right, that should work, Elliot. Thank

you.

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MR. LONG: Thank you all very much. As

was noted, I am Elliot Long. I am a Principal

Technical Leader with the Electric Power Research

Institute, and I'm going to make a presentation today

discussing some of the industry initiatives to help

generate highfluence data. So next slide, please.

As I noted, we have two ongoing industry

and EPRI MRP initiatives to generate additional

sources of high fluence capsule data. The first of

these is the Coordinated Reactor Vessel Surveillance

Program. And then the second is the PWR Supplemental

Surveillance Program, or PSSP.

I also want to revisit the conclusion made

by our colleague, my colleague Kim Hardin back in

November of 2019 at the ACRS meeting, and then talk

briefly about the potential impact of PT limit curve

as it regards to this current issue.

Before I move forward, you'll see the red

star. I don't have much about BWR units in this, it's

mostly a PWR discussion. However, the BWR units do

have an NRC-approved ISP, Integrated Surveillance

Program, through60 years of operation. In addition

to that, there is an implementation plan for

subsequent license renewal that has also been accepted

by NRC. I see the report title there.

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The second report does note that the

highest BWR units will not exceed the threshold for

fluence of 6 times 10 to the 19th during (inaudible)

an SLR time period. I just wanted to point that out

that we'll mostly be focusing on PWRs here. And I do

have some additional information on slide 12 in regard

to that fluencetopic. Next slide, please.

So we'll first talk about the CRVSP,

Coordinated Reactor Vessel Surveillance Program, as

documented in MRP-326, now Revision 1. Next slide.

The original intention of this program was

to optimize the remaining and existing US PWR

surveillance capsule withdrawal schedule to increase

the amount of high fluence data that can be generated

by the remaining capsule. This new data can then be

used to inform embrittlement trend correlations and

generate data from 60-plus years of operation.

The original revision from 2011 did just

that, wherein we reviewed every US plan, PWR plan,

surveillance capsule schedule and recommended changes

to maximize and optimize the high fluence data that

can be achieved by the current capsules that remain

through 2025. This year, the EPRI MRP did a revision

to this report, basically to review how we did, what

has happened, what's changed, what's left to do, and

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see if anything needs to be updated to continue moving

forward with plan.

The updates include checking the evaluated

capsule since 2011, revisiting future capsule pull

schedules, documenting updated capsule fluence values,

and then assessing the impact of closed or to-be

closed plants on the overall plan. Next slide.

As you can see, we have now tested 16 out

of the 30 CRVSP capsules. They're either already

tested or planned to be tested. The remaining 14,

there are 14 left of these, about half will not be

tested for a variety of reasons. Some due to plant

shutdown, some have been delayed beyond 2025.

In summary, as of this summer, we have 48

capsules in the US that have a tested fluence greater

than 3 times 10 to the 19th. Four of these are over

8. By 2025, those remaining seven CVRSP capsules will

also be tested at fluences greater than 3E 19, and two

of those will be over 8 times 10 to the 19th.

This report also did a first update to the

schedule for when the PSSP PWR Supplemental

Surveillance Program capsules will be withdrawn. The

first one will be Farley One, Capsule P, in the spring

of 2027. And then in the following fall of 2028,

Shearon Harris Capsule P will be ready.

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And that leads me into the next slide,

where we discuss the PSSP. So next slide again. This

program was developed to generate additional again

high fluence data that has a very similar objective to

the prior program, inform future ETC development

applicable to the RPVs at higher fluence.

This one was a targeted approach designed

to fill in the gaps of materials in the capsule

database.It also was designed to irradiate these

materials in commercial reactors since we were

generating data from commercial reactors and not from

test reactors.

The end game really says it all, we

fabricated two supplemental capsules and irradiated

them for ten years. That's the current status before

we withdrawal test and evaluate those materials.

These two capsules contain 288 Charpy Specimens from

27 unique plates, forgings, and welds.

The data will ultimately yield 24 new

transition temperature shift results, and then three

of the materials will shift just generate an upper

shelf energy.

You can see the fluence ranges at the

bottom. I will stress that all of the materials in

these capsules were from previously irradiated and

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tested surveillance capsules. So they were already

irradiated at a plant.

They were refabricated into new specimens

and are going back in to generate the higher fluence

levels shown there, 4.5 on 10 the 19th upward to 1.2

to the 20. So each individual component will have its

own unique fluence value. Next slide, please.

So as I said, the program fabricated two

supplemental capsules containing previously irradiated

and reconstituted PWR materials. The EPRI MRP

sponsored the fabrication and the host plans are shown

there.

Farley One went in in October of 2016. So

it'll have about 11 years, ten and a half of

irradiation. And then Shearon Harris has the second

one. It'll also have about a little under ten years

of irradiation in that vessel. The published report

was shown there in 2016. Please go to the next slide.

2027, the Farley Capsule P will be

withdrawn and Shearon Harris in 2028. You can see at

the right we took broken Charpy Specimens, the top

right image, machined one half of one side down to an

insert, so that middle piece is actually the material

of interest. We then welded end tabs of standard

material on either side both into the middle picture.

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Machined them flush and cut them to standard Charpy

size.

These are the materials, the 288 of the

bottom image there on the first caption, the first

figure, are in the capsule. They're going to be

evaluated starting into '27, 2027 and 2028. It'll

take a couple of years to get all that analysis done.

Hope to have the two capsule reports ready

towards the middle within 18 months of the withdrawal.

And then we'll spend the early part of the 2030s

evaluating the data and the impact on any future ETCs

for the existing ones or the need to develop new ones.

And then I showed just a picture on the

bottom right of what the capsule looks like seated in

its holder in the vessel. Go on to the next slide,

please.

Now I want to revisit what was discussed

at the November 2019 ACRS meeting that EPRI

participated in with my colleague Tim Hardin. I

summarized the conclusions and recommendations from

the final slide of that meeting on the right.

These conclusions have not changed from

EPRI's perspective. If a future revision to the Reg

Guide is implemented, E900-15 remains the preferred

ETC model as of today. That's consistent with the

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NRC's views as well.

It is understood that this, the target

fluence is 6 times 10 to the 19th. Below that, the

Reg Guide remains adequate for predicting

embrittlement.

And I do went to focus then if 6 times 10

to the 19th is the level and we're worried again about

PT limit curves, 10 CFR 50 Appendix G, the appropriate

metric is the 1/4T fluence. So I felt it appropriate

to determine when certain plant designs will see that

fluence level at the 1/4T. So go on to the next

slide, please.

This chart at the right shows the surface

fluence value needed to generate a 1/4T and 3/4T

fluence of 6 times 10 to the 19th using the

attenuations formulas in the current Reg Guide.

As you can see, the various designs of PWR

reactors in the US, the 2 and 3 loop WEC, B&W, the

various 4 loops, and some of CEs all have different

vessel thicknesses, ranging from a 62 inch thick

vessel up to an 11.2. The 1/4T fluence of 6 times 10

to 19th necessary and the surface fluence necessary to

hit that is listed under the 1/4T column.

So for instance, a WEC-4loop with a B&W

fabricated vessel needs a surface fluence of 9.99 E19

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to hit a 1/4T fluence of 6 times 10 to the 19th. So I

then looked at which plants have submitted for SLR and

what their SLR fluence would be. And thus far, only

one of the six PWRs would ever hit the necessary

surface fluence to achieve a 1/4T fluence of 6 times

10 to the 19th.

And even that one plant, plant A, is going

to take upwards of 65 EFPY (inaudible) are well into

the SLR operating period, well into the future before

that would occur.

You can also see from this chart a 3/4T,

which is governing for the heat-up limitations, it

seems like there would never be an issue. And in

things that will never be an issue as well, in the

bottom, BWR plants will never reach these fluence

levels as well in any reasonable timeframe. The BWR

SLR plant fluence is less than 5 times 10 to the 18th

neutrons per centimeters squared at the surface.

So I just wanted to summarize when this

could become an issue when you look at the 1/4T

fluence and the surface fluence necessary to hit that

value.

And that's all that I had for today.

Thank you.

MS. OLMSTEAD: Thank you, Mr. Long. Now

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Satira Labib from Duke Energy will make some

presentation. And I'll ask the Operator to unmute Mr.

Labib's line.

OPERATOR: Your line is now open.

MS. LABIB: Can you hear me?

MS. OLMSTEAD: Yes, we can.

MS. LABIB: Yes. I'm Satira Labib from

Duke Energy, Reactor Vessel Integrity Engineer. And

this is in regards to Slide 18 that mentioned Robinson

Nuclear Plant. So in 2011, Robinson made a commitment

to the NRC with withdraw their Capsule U when the

capsule reached the 80 year peak fluence value which

is 8E to the 19th. This commitment was made based on

recommendations listed in what Elliot just discussed,

MRP 326 to help the industry collect higher fluence

data.

RNP still intends to abide by this

commitment and withdraw Capsule U in 2024 when we

reach the aforementioned fluence value. This will

ensure that Robinson will have surveillance test data

available to cover the predicted level of vessel

fluence during the 80-year period and it should also

be noted that the projected 60-year fluence is below

the 6E to the 19th which is mentioned in this

presentation. And the value above which the under

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prediction of embrittlement is considered to be found

significant. That's my only comment.

Thank you.

MS. OLMSTEAD: Thank you very much, Ms.

Labib. And now I understand Mr. Paul Gunter from

Beyond Nuclear would like to make a presentation and I

will ask the operator to unmute his line.

OPERATOR: Paul, your line is now open.

MR. GUNTER: Hello, can you hear me?

MS. OLMSTEAD: Yes, we can.

MR. GUNTER: Thank you. I don't really

have a presentation per se, but you know, this is

quite a complex subject here. And I'm participating

mostly for my education and coming a little bit

farther up on the issue.

I understand that per usual I can ask

questions of the Nuclear Regulatory Commission, but I

wanted to start to see if I could ask a question of

EPRI. Is that permitted? If not, I could perhaps --

if EPRI can't answer, perhaps NRC could.

But on Slide 4 of EPRI's presentation,

there's a bullet point there update to the evaluation

includes, and I'm looking at the fourth point, their

analysis of closed or to be closed plants. And I'm

wondering with I could get a comment from either EPRI

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or from the Nuclear Regulatory Commission what

analysis we're talking about there or if, in fact,

there's another reference where I could go to get a

better understanding of this update. Because I didn't

hear the update in the presentation. So that's a

question.

MR. RUDLAND: Paul, this is Dave Rudland.

At this type of meeting, I believe we can ask

questions to EPRI, but they don't need to respond.

The questions should be directed towards the NRC.

And in fact, we have a section in a moment

to do a question and answer session. So if you wanted

to wait just a few seconds, we could do that. I

wanted to make sure you were finished with any

comments that you had or statements that you wanted to

make before we moved into the question and answer

section.

MR. GUNTER: Well, let me just say then to

cut to the chase here to get to that question. You

know, our main concern as an interested public

advocate for public safety and environment protection,

the subsequent license renewal proceedings are going

ahead right now and I understand that you're saying

that you're projecting loss of margin and offering

reasonable assurance. But the fact that clearly, you

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have a performance inadequacy that has been identified

and the -- but the public only has this shot at the

subsequent license renewal window which is closing.

And so while there is a concern that was

voiced in this meeting that the Agency has defined a

performance issue by delaying these capsules and

you're saying they've been delayed already 25 years,

but we don't really know -- you're still working on

your formula, so we don't really know how much longer

this delay is going to be, but at the same time, the

windows for the public due process are closing on age

management programs which include reactor pressure

vessel embrittlement and how your age management

programs are falling behind at present.

So I'm raising that as a concern that

you're providing yourself the luxury for the licensees

to proceed through the review process. It's a little

like paving the road as you travel, as you move right

through the public process. So I'm raising that as a

concern and that will conclude my comment.

MS. OLMSTEAD: Thank you very much, Mr.

Gunter. We appreciate your statement.

And this brings us to the discussion and

question and answer portion of this meeting. I'll ask

Glenna to show Slide 37 again from the NRC slide deck.

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And that gives us some suggestions of discussion

topics for this session. And you can also ask other

questions of course.

Our operator will now give you information

on how to get into the queue for providing feedback

and asking questions for today's topics and we will

not be using the Webex chat or Q&A features, so please

enter the queue if you'd like to speak during this

meeting.

Operator?

OPERATOR: Thank you. We will now begin

the question and answer session. If you would like to

ask a question please press *1. Record your name

clearly when prompted. To withdraw your request,

please press *2.

MS. OLMSTEAD: And thank you very much.

And in an effort to ensure that we hear from as many

people as possible, we ask that participants limit

their feedback and questions to about three to five

minutes. After that, you can always reenter the queue

and speak again as time permits.

And first, I'd like to turn to Mr. Scott

for now to see if he received any questions from the

public by email during today's presentation.

MR. BURNELL: Thank you, Joan. To this

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point, I have not received any emails.

MS. OLMSTEAD: All right, well, thank you.

And now I'd like to ask the operator to see if

there's anyone in the phone queue that would liketo

ask a question.

Operator, first question, please.

OPERATOR: Thank you. Your first question

comes from Paul Gunter. You're line is open and you

may ask your question.

MR. GUNTER: Thank you. I'm just going to

repeat the question that in EPRI's presentation they

talk about how they're going to update their process

for this and they outline an analysis of closed or to

be closed plants and I'm wondering if EPRI could

eliminate that or if the NRC might provide some

comments. Thanks.

MR. HISER: Paul, this is Allen Hiser with

NRC. I'm not quite certain what the bullet on that

slide meant. I know that in many cases with plants

that are shutting down, both we and the industry have

looked at the surveillance capsules that are still

available for the plant to see if there would be value

in retrieving and testing those capsules. At this

point, NRC has not found too much value in those

capsules. I'm not sure if that's the full extent of

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the EPRI activity in this area or not.

MR. GUNTER: Well, I do know that -- can I

comment and follow up?

MR. HISER: Sure.

MR. GUNTER: I do know that -- EPRI

participated in a March 7th and 8th, 2017 workshop

with the Nuclear Regulatory Commission and other

industry and regulatory stakeholders that was looking

at harvesting of decommissioning nuclear power

stations with high priority on reactor pressure

vessels. And I'm wondering where that subject has

gone to, and if in fact, this is a reference to

harvesting.

MR. HISER: I don't know if it is or not.

I know that is one area that if there happened to be

a plant that was decommissioning that we would be

interested in obtaining specimens from the reactor

pressure vessel. The problem is that the fluences on

plants that would be decommissioning are not in the

range that we have identified potential issues at

present. If we had a vessel that had a fluence of 6

times 10 to the 19th, then we would probably be very

interested in it. But there are no opportunities for

that at this point.

MR. GUNTER: Would it also be able to

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provide some insights on how neutron embrittlement is

-- you know, the EMDA report referenced how neutron

bombardment can actually penetrate a vessel wall and

then bounce off the concrete on the other side and

cause embrittlement to be working from the outer wall

of the pressure vessel or welds, so that you could --

it just seems to me that there has been interest in

harvesting samples for a whole host of insights to do

with neutron embrittlement.

Would you not see any value for being able

to capture actual data on how neutron embrittlement

could be working its way by bouncing off the concrete

and then embrittling from the outer side of the vessel

inward?

MR. HISER: I know there were studies that

had been done looking at through-wall embrittlement

effects, and I would expect that some mechanism like

you mentioned would provide evidence, would have

provided evidence in those studies. I'm familiar with

one from the 1980s because I was one of the lead

reviewers or one of the lead technical staff on it.

So I'm not sure that there would be much additional

fruit that would be gained from pulling samples from

decommissioned reactors to assess that at this point.

It may be that at some point in the future

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as plants that are decommissioning have high fluences

on them, then at that point it may become more

interesting for us. But I think at this point, those

are some of the limitations.

MR. RUDLAND: This is Dave Rudland. In

terms of what we're trying to do in this effort,

especially with looking at the way the trend curves

predict, I also have to agree with Allen, I don't see

that it would add much to this particular study.

MS. OLMSTEAD: Well, thank you very much,

everyone, for that discussion. And I'd like to go on

next to our next person in the queue, please,

operator?

OPERATOR: Thank you. And that's from

Thomas Basso. Your line is open. You may ask your

question.

MR. BASSO: Thank you. This is Thomas

Basso. I'm with the Nuclear Energy Institute. I'm

the Senior Director of Engineering and Risk. And it's

kind of a comment and a question. So we do appreciate

and support the overall approach from the holistic

risk-informed analysis approach.

So my question probably to Dave Rudland is

do you have enough information for doing this from an

risk-informed approach or what else is needed to

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ensure from a risk-informed approach that we've come

up with the appropriate way of looking at this?

Is there more --you know, is there more

work that needs to be done from the risk community or

any outstanding concerns with the overall approach?

MR. RUDLAND: Thanks, Tom. Again, this is

Dave Rudland. I don't think there's anything that's

needed --anything additional that's needed from the

risk people. I think right now our biggest concern is

plant-specific details. I think a lot of our -- some

of our uncertainty, at least in analyses that we've

done so far has been generically based and plant-

specific information I think is the best way to try to

focus that.

As I mentioned in the presentation, we

don't really know how the plants are impacted at this

point because we haven't done enough work to determine

the individual plants are meeting the conditions that

we're talking about. So I think that's where we need

to focus our efforts, but I'm not -- I don't think

getting more information from the risk folks would

help us in this particular case.

MR. BASSO: In some of my earlier

experience at a plant that I used to work at, I know

that there's significant margin built into the

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operating procedures that address having adequate

margin. But obviously, the more data we get, the more

we can refine that margin, so appreciate the efforts,

sir. Thank you.

MS. OLMSTEAD: All right, thank you very

much. And operator, could we go to the next person in

the queue?

OPERATOR: Thank you. And that's from

Christopher Koehler. Your line is open. You may ask

your question.

MR. KOEHLER: Hi, can you hear me?

MS. OLMSTEAD: Yes, we can.

MR. KOEHLER: My question is specifically

related to -- I think it was the NRC's Slide 20 or so

where you showed the Reg Guide embrittlement trend

versus a best fit embrittlement trend and how a

licensee might react to --yes, that's the one.

And you stated that if the best fit was

based on non-credible surveillance capsule data, that

the Reg Guide directs the licensee to go back to the

Reg Guide generic embrittlement trend which I think is

inconsistent with how it's actually done in practice

in which case, and this is based on the work shop

slides that -- from post-Generic Letter 92- 01 was it,

where it indicated that if you have non-credible

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surveillance data, you should use the best fit

chemistry factor from that data and then also use the

full margin term on top of that. So I just wanted to

confirm what I heard and what you intended when you

said that.

MR. RUDLAND: This is Dave Rudland.

Thanks for your comment. I do appreciate that. If

you read the words of the Reg Guide, it doesn't make

you use the non-credible chemistry factor. It says to

go back to use the chemistry factor from --that you

derived from the chemistry. However, in many cases,

the chemistry factor for the non-credible fit, I

suppose, has been used. But the Reg Guide itself does

not -- does not make -- does not force you or does not

recommend that you use the non-credible chemistry

factor.

MR. HISER: Chris, this is Allen Hiser.

Just to amplify that, obviously the goal of the

embrittlement or the surveillance program and use of

embrittlement trend curve is to get the most accurate

prediction that you have. So if you have non-credible

data that are indicating a higher embrittlement than

use of the chemistry factor from the tables in the Reg

Guide, then we would hope that plants woulduse some

more accurate representation.

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So like Dave says, the Reg Guide doesn't

say that you shall use it, but I think that clearly is

within the engineering realm of wanting to provide the

most accurate prediction.

So the workshop slides I think are still -

- provide reasonable guidance on circumstances like

that.

MR. KOEHLER: Thank you.

MS. OLMSTEAD: Thank you, too. And now

I'll ask the operator for the next person in the

queue.

OPERATOR: Certainly. And again just

press *1 to ask a question. Our next question comes

from Steven Richter. Your line is open. You may ask

your question.

MR. RICHTER: Hello, this is Steve

Richter, Energy Northwest. This question is for David

Rudland. Going through your presentation, I didn't

notice, perhaps I missed it, any discussion on heat

affected zone material. Was there a reason it was

omitted? Were you considering it bounded or just not

for the purposes of this presentation? I saw the weld

material, the base material, but not heat affected

zone. Is that a concern?

MR. RUDLAND: I think the data that we

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showed was the data that was given as part of the

development of the ASTM E900 standard. Heat affected

zone data I believe is not required through Appendix H

any more.

MR. RICHTER: Okay. So that was the

reason you left it out. That's fine. Thank you.

MR. RUDLAND: Yes.

OPERATOR: At this time, I'm showing no

further questions.

MS. OLMSTEAD: All right, I'm going to

give a couple minutes. Please press *1 if you'd like

to get in the queue again, ask further questions, or

make any other statements or provide input for us.

I do notice somebody has just joined the

queue. Operator, can you introduce them, please?

OPERATOR: Jan, your line is open. You

may ask your question.

MS. BOUDART: Thank you. I am Jan Boudart

from Nuclear Energy Information Service. And I am

looking at a paper and I was going to have it ready

exactly when it was created, but it was kind of a long

time ago. And it was also a Japanese paper. So --

oh, I don't have a date on this paper. I apologize.

But it is created by Ino Hiromitsu and it is about a

plant in Japan that there was never any consideration

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of it being reopened after the Fukushima accident.

And the reason the Japanese did not consider

restarting this plant was embrittlement or one of the

reasons. And there is a graph in this paper showing

the computer predictions of embrittlement and the

actual capsules that were taken out of this plant.

The name of the plant is Genkai 1.

And the last capsule that was taken out

was so far above the predicted embrittlement that this

is one of the things that influenced TEPCO in deciding

not to reopen Genkai.

And so I just have a couple of comments

about this that I would like to clear up. Number one,

the Genkai graph is based on years, not on fluence.

And I think that there has to be a justification for

using fluence instead of years. And I wanted to point

out that the 19th power is 10 times greater than the

18th power so that a huge amount of time will elapse

from the time the fluence reaches the 18th power to

the time it reaches the 19th power.

And I'm questioning whether that enormous

increase in fluence would even occur in human history.

I mean I don't know how long it takes for the fluence

to reach these levels. And I was wondering if you

could give us some examples of fluences that have been

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reached in real time, I mean like when did such and

such a plant reach the 18th power? And when did such

and such a plant reach the 17th power? And how long

was the interval between reaching the 17th and the

18th? And how long does it take to get from one

exponent to the next higher exponent especially when

you're going from 18 to 19? Can someone estimate the

amount of time it would take to go from the 18th to

the 19th power? That's my question.

MR. HISER: This is Allen Hiser. I'll take

the first crack at it. The fluences depend on the

design of the reactor, how large the reactor vessel

is, how much water is between the core and the vessel.

So many BWR plants, which I'm assuming Genkai reactor

may be, would be on the order of 10 to the 18th at 40

years or 60 years of operation. BWRs also have a

variety of fluence levels. For example, just one that

I'm familiar with, the Turkey Point plants, at about

60 years, the fluence is about 6 times 10 to the 19th.

To go from 10 to the 18th to 10 to the 19th, there is

no set number of years. It's just a factor of ten in

the operation of the plant. So if a plant reached 10

to the 18th in 40 years, it would take them 400 years

to get to get to 10 to the 19th.

MS. BOUDART: Say that last part again,

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please, Mr. Hiser?

MR. HISER: It would be 10 times the

operating period to go from 10 times 10 to the 18th to

10 times 10 to the 19th.

MS. BOUDART: And has Turkey Point been

going for 60 years?

MR. HISER: They are about 50 years at

this point.

MS. BOUDART: And do you have a fluence

measure for them at 50 years?

MR. HISER: My guess is somewhere around 5

times 10 to the 19th.

MS. BOUDART: Five times 10 to the 19th?

Oh, yes, because the coefficient is something --

what's the coefficient? I didn't remember that. Nine

point something?

MR. HISER: Five times 10 to the 19th.

MS. BOUDART: Okay. Well, okay. So --

okay. And then I'm asking you to repeat again. You

said Turkey Point is 5 times 10 to the 19th for a long

time. How long -- I'm sorry to repeat this question.

Maybe you answered it and I didn't pick it up.

How long does it take a reactor like at

Turkey Point to go from 10 to the 18th to 10 to the

19th? I'm sorry, I know you said this, but I missed

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it.

MR. HISER: It would be -- let's see. It

probably was about year one that they were about 10

times 10 to the 18th, approximately.Then about year

10 when they would have been about 1 times 10 to the

19th. And these are guesstimates from recollection.

MS. BOUDART: Certainly, there were

capsules that were taken out -- oh, that would be a

different measurement though, the measurement of

brittleness, but not a measurement of fluence.

Okay, and then can you explain why you

have decided to go with fluence instead of time?

MR. HISER: Fluence is a measure of the

number of neutrons that have hit the reactor vessel

and so that correlates with the damage. If the

reactor is shut down for outages, it accumulates no

additional fluence. So it doesn't --

MS. BOUDART: Right.

MR. HISER: There's no real strong

correlation with time. It's really how much time the

plant operators.

MS. BOUDART: Okay. I appreciate your

answer. Thank you so much.

MR. HISER: Okay.

MS. OLMSTEAD: And thank you very much for

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your statement, Ms. Boudart.

And now I don't see anyone else in the

queue. I'll give people a few more minutes. Please

press *1 if you'd like to get in the queue and make a

statement or ask any questions.

Operator, do we have someone else in the

queue?

OPERATOR: We do. Michael Guthrie, your

line is open. You may ask your question.

MR. GUTHRIE: Hello. This is Michael

Guthrie with Dominion Energy. I have a question

regarding the value of 6 times 10 to the 19th that's

in the NRC presentation. Are you referring to inside

surface fluence or are you talking about 1/4 T fluence

as Elliot Long was referring to?

MR. RUDLAND: This is Dave Rudland. The

number that we were referring to was just the fluence

level in which the under prediction of the

embrittlement trend curve becomes statistically

significant, whether it occurs --no matter where it

occurs it's throughout the wall. We were just looking

at the point at which the prediction becomes non-

conservative. So if you're looking at PT curves, it

1/4 T. If you're looking at PTS, it's ID surface.

MR. GUTHRIE: Thank you. That clears it

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up.

MS. OLMSTEAD: And thank you. Operator,

is there anyone else in the queue?

OPERATOR: At this time, I'm showing no

further questions.

MS. OLMSTEAD: I'll give a couple more

minutes. Please press *1 if you'd like to get in the

queue to ask a question or make a statement. And if

we don't have anyone else showing up, I'll probably

start closing the meeting.

Operator, do we have anyone else in the

queue?

OPERATOR: At this time, I'm showing no

further questions.

MS. OLMSTEAD: All right, I'm just

checking on something and -- all right, it looks like

we don't have anyone else in the queue.

So please, Glenna, can you put up NRC

Slide 39?

All right, and as you can see on this

slide, to find more information about this meeting,

you can go to this website, regulations.gov and look

at the docket number, NRC-2021- 0174. Now the NRC will

post today's meeting summary and transcript within 30

days from today on the regulations.gov site.

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And please note that while the

regulations.gov's standard template mentions comments,

we will not be taking comments for this project at

this website.

Slide 40, please. I'd like to remind

everyone to fill out your meeting feedback forms

located at the NRC's recently held public meetings

webpage for this meeting's announcements. Your input

helps us improve future NRC public meetings.

Next slide, please. And these are some

contacts if you want to contact these people for more

information about this topic.

And thank you all for your attendance at

today's meeting. We very much appreciate your time

and feedback and we will carefully consider today's

discussion and look forward to engaging more with you

in the coming months. Thank you.

And that will end our meeting for today.

(Whereupon, the above-entitled matter went

off the record at 2:48 p.m.)

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NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com