ML120040451: Difference between revisions
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- 3. Inadvertent ECCS actuation at power | - 3. Inadvertent ECCS actuation at power | ||
- 4. Boron dilution in Modes 3, 4,and 5 | - 4. Boron dilution in Modes 3, 4,and 5 | ||
- 5. Main steam line brea k | - 5. Main steam line brea k | ||
: 1. Overpressure Protection | : 1. Overpressure Protection | ||
* SRP 5.2.2 specifies that adequate overpressure protection be demonstrated for the limiting event (loss | * SRP 5.2.2 specifies that adequate overpressure protection be demonstrated for the limiting event (loss | ||
Line 1,259: | Line 1,259: | ||
* Analysis was based upon reactor trip from 1 st trip signal | * Analysis was based upon reactor trip from 1 st trip signal | ||
* TVA re-analyzed the loss of load, assuming reactor trips on the 2 nd trip signal | * TVA re-analyzed the loss of load, assuming reactor trips on the 2 nd trip signal | ||
* Results of re-analysis show that RCS and MSS pressure safety limits are not exceeded 29 | * Results of re-analysis show that RCS and MSS pressure safety limits are not exceeded 29 | ||
: 2. CVCS malfunction event | : 2. CVCS malfunction event | ||
* CVCS malfunction event was not in the FSAR (i.e., it was omitted) | * CVCS malfunction event was not in the FSAR (i.e., it was omitted) | ||
Line 1,268: | Line 1,268: | ||
* Results indicate there is adequate time for manual | * Results indicate there is adequate time for manual | ||
mitigation 30 | mitigation 30 | ||
: 3. Inadvertent ECCS actuation | : 3. Inadvertent ECCS actuation | ||
* Analysis was unacceptable, as expl ained in RIS 2005-029 | * Analysis was unacceptable, as expl ained in RIS 2005-029 | ||
* TVA provided a re-analysis | * TVA provided a re-analysis | ||
* Results indicate there is adequate time for manual mitigation 31 | * Results indicate there is adequate time for manual mitigation 31 | ||
: 4. Boron Dilution in Modes 3, 4, and 5 | : 4. Boron Dilution in Modes 3, 4, and 5 | ||
* RG1.70, Revs 0 and 1, required explicit Boron Dilution calculations in Modes 1, 2 and 6. Subsequent revisions RG 1.70 added requirements to consider in all 6 modes | * RG1.70, Revs 0 and 1, required explicit Boron Dilution calculations in Modes 1, 2 and 6. Subsequent revisions RG 1.70 added requirements to consider in all 6 modes | ||
Line 1,278: | Line 1,278: | ||
* Analyses inconsistent with SRP since only Modes 1, 2, and 6 analyzed* Open Item for TVA to provide analyses of boron dilution event that meet the criteria of SRP Section 15.4.6, including | * Analyses inconsistent with SRP since only Modes 1, 2, and 6 analyzed* Open Item for TVA to provide analyses of boron dilution event that meet the criteria of SRP Section 15.4.6, including | ||
- Description of the methods and procedures used by the operators to identify the dilution path(s) and terminate the dilution in order to determine analyses comply with GDC 10 | - Description of the methods and procedures used by the operators to identify the dilution path(s) and terminate the dilution in order to determine analyses comply with GDC 10 | ||
- Time available for manual action begins at start of event 32 | - Time available for manual action begins at start of event 32 | ||
: 5. Main Steam Line Break | : 5. Main Steam Line Break | ||
* Results were too good (compared to similar plants) | * Results were too good (compared to similar plants) |
Revision as of 07:21, 30 April 2019
ML120040451 | |
Person / Time | |
---|---|
Site: | Watts Bar ![]() |
Issue date: | 12/15/2011 |
From: | Shukla G S Advisory Committee on Reactor Safeguards |
To: | |
References | |
NRC-1340 | |
Download: ML120040451 (281) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSIONTitle:Advisory Committee on Reactor Safeguards Plant Operations and Fire ProtectionDocket Number:(n/a)Location:Rockville, Maryland Date:Thursday, December 15, 2011Work Order No.:NRC-1340Pages 1-210 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 2+ + + + +3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 (ACRS)5+ + + + +6 PLANT OPERATIONS AND FIRE PROTECTION SUBCOMMITTEE 7+ + + + +8 THURSDAY 9 DECEMBER 15, 2011 10+ + + + +11 ROCKVILLE, MARYLAND 12+ + + + +13The Subcommittee met at the Nuclear 14Regulatory Commission, Two White Flint North, Room 15T2B3, 11545 Rockville Pike, at 8:30 a.m., Harold B.
16 Ray, Chairman, presiding.
17 MEMBERS PRESENT:
18 HAROLD B. RAY, Chairman 19 SAID ABDEL-KHALIK, Member 20 CHARLES H. BROWN, JR., Member 21 MICHAEL T. RYAN, Member 22 JOHN D. SIEBER, Member 23 GORDON R. SKILLMAN, Member 24 JOHN W. STETKAR, Member-at-Large 25 2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 NRC STAFF PRESENT:
1 GIRIJA S. SHUKLA, Designated Federal Official 2 LETA BROWN, NRR/DRA/AADB 3 ROBERT HAAG, Region II 4 PAT MILANO, NRR 5 SAMUEL MIRANDA, NRR/DSS/SRXB 6 JOHN PARILLO, NRR/DRA 7 ROGER PEDERSEN, NRR/DRA 8 JUSTIN POOLE, NRR/DORL 9 ED SMITH, NRR 10 11 ALSO PRESENT:
12 GORDON ARENT, TVA 13 ROBERT BRYAN, TVA 14 STEVE HILMES, TVA 15 FRANK KOONTZ, TVA 16 ALAN MACDONALD, Westinghouse 17 CHRIS McHUGH, Westinghouse 18 RYAN ROSSMAN, Westinghouse 19 DAVID STINSON, TVA 20 TOM WALLACE, TVA 21 22 23 24 25 3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 A G E N D A 1 Opening Statement . . . . . . . . . . . . . . . . .5 2 H. Ray (ACRS) 3 1. Introduction . . . . . . . . . . . . . . . . . 6 4 P. Milano & J. Poole (NRC) 5 2. WBN Unit 2 Design, Licensing and Construction 6 Activities . . . . . . . . . . . . . . . . . . . .12 7 D. Stinson (TVA) 8 3. Meteorology & Radiation Protection . . . . . .37 9 R. Bryan (TVA) 10 4. Radiological Consequences of Accidents . . . .64 11 R. Bryan (TVA) 12 5. Transient Analysis . . . . . . . . . . . . . .68 13 F. Koontz (TVA) 14 6. WBN Unit 2 Licensing Review - Introduction . .85 15 P. Milano & J. Poole (NRC) 16 7. WBN Unit 2 Licensing Review - Transient 17 Analysis . . . . . . . . . . . . . . . . . . . . 87 18 S. Miranda (NRC) 19 8. Region II Inspection Activities . . . . . . .128 20 R. Haag (NRC/Region II) 21 9. WBN Unit 2 Licensing Review - Status of Licensing 22 Activities . . . . . . . . . . . . . . . 158 23 J. Poole (NRC) 24 25 4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433
- 10. WBN Unit 2 Licensing Review - Radiation 1 Protection . . . . . . . . . . . . . . . . . . . 164 2 R. Pedersen & E. Smith (NRC) 311. WBN Unit 2 Licensing Review - Radiological 4 Consequences of Accidents . . . . . . . . . . . .187 5 J. Parillo & E. Smith (NRC) 6 12. WBN Unit 2 Licensing Review - Conclusion . . 198 7 P. Milano & J. Poole (NRC) 8 13. Subcommittee Deliberations on SSER 25 Appendix 9 HH Open Items . . . . . . . . . . . . . . .199 10 14. Public Comments . . . . . . . . . . . . . . 209 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 P R O C E E D I N G S 1 8:31 a.m.2 CHAIR RAY: The meeting will now come to 3 order. This is a meeting of the Advisory Committee on 4Reactor Safeguards Subcommittee on Plant Operations 5and Fire Protection. I'm Harold Ray, chairman of the 6 subcommittee. Subcommittee members in attendance are 7Said Abdel-Khalik, Gordon Skillman, John Stetkar, 8Charles Brown, Jack Sieber and Michael Ryan. Mr.
9 Girija Sukha of the ACRS staff is the Designated 10 Federal Official for this meeting.
11This meeting will be open to public 12 attendance. A telephone bridge line has also been 13established for this meeting to preclude interruption 14of the meeting. The phone will be placed in listen-in 15 mode during presentations and committee discussions.
16The subcommittee will hear presentations from the NRC 17 staff and the applicant, Tennessee Valley Authority, 18 regarding the status of construction, inspection and 19licensing activities related to Watts Bar Nuclear 20 Plant Unit 2.
21We've received no written comments or 22requests for time to make oral statements from members 23of the public regarding today's meeting. There is 24 time on the agenda for public comments at the end of 25 6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 the day.
1The subcommittee will gather information, 2analyze relevant issues and facts, and formulate 3proposed positions and actions as appropriate for 4deliberation by the full committee. The rules for 5 participation in today's meeting have been announced 6as part of the notice of this meeting published in the 7Federal Register on November 18th, 2011. A transcript 8of the meeting is being kept and will be made 9available as stated in the Federal Register notice.
10Therefore, we request that participants in this 11meeting use the microphones located throughout the 12meeting room when addressing the subcommittee. The 13participants should first identify themselves and 14speak with sufficient clarity and volume so that they 15 may be readily heard.
16Please silence your cell phones as the 17 chairman is now doing with his. We will now proceed 18with the meeting and I will call NRC staff to make 19 introductory remarks. Mr. Pat Milano.
20MR. MILANO: Good morning, Mr. Ray and 21members of the subcommittee. We're here today as Mr.
22Ray indicated to continue with our discussions on the 23 operating license application submitted by Tennessee 24 Valley Authority for ultimate operation of Watts Bar 25 7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433Unit 2. With me today and the individuals who will be 1speaking, to my left Justin Poole who's also with the 2Watts Bar Special Projects Branch, another one of the 3 licensing project managers, and from the staff in 4 Region II Mr. Bob Haag who is branch chief with the 5Division of Construction Projects and he'll be 6discussing the inspection status. There will be also 7members from the NRR technical staff who conducted, 8who were the primary leads for conducting the areas of 9 review that we will be discussing today.
10Before I actually get into the actual 11topics of discussion just so that you understand a 12little bit of change to the organization within the 13Watts Bar Special Projects Branch. Our branch handles 14both Watts Bar Unit 2 and TVA's Bellefonte 1 and 2, 15the Bellefonte 1 project in particular. So because of 16that and a shifting of our work assignments Mr. Poole 17 is, Justin is going to be doing more of the lead 18 review for Watts Bar, or coordination for Watts Bar.
19So, today he'll be doing the majority of the 20coordination for the NRC staff and in the future will 21 be handling everything himself.
22For today the agenda, we're going to be 23talking, TVA's going to be talking first. I'll be 24 introducing them shortly. They're going to give you 25 8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433a short discussion of the construction completion 1 status that currently exists and then we're going to 2 go into the areas of the FSAR review that we're here 3for today. Noting that some of these areas cover 4 multiple supplements to the Safety Evaluation Report 5because of the fact that we postponed discussions and 6in particular with the accident transient analysis in 7Chapter 15, we did that awhile back. We were going to 8 do that in one of the earlier meetings.
9 So today we're going to discuss Chapters 1011 and 12. Basically that entails the liquid and 11gaseous release and operational dose consequences.
12Then we're going to go into Chapter 15.4 discussing 13the accident dose consequences. And it seems like, a 14little bit out of sequence but this aligns with the 15way TVA is going to make their presentation. Then 16they're going to talk to the actual accident transient 17 analysis that's in Chapter 15.
18Also, when the NRC comes up late this 19morning and then this afternoon we're going to, Mr.
20 Haag will give you the status of the construction 21inspection and then we're going to go into a short 22status on open items. As you're aware, in Supplement 2325 currently there are 83 items that remain in an open 24 condition. Forty of those items are open and will 25 9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 require some amount of staff evaluation once either, 1once TVA provides something or we obtain something 2 from the region.
3 There are a couple items that are 4inspectional in nature like environmental 5qualification, inspection and audit. Of the other 43 6items out of that 83 are what the staff calls 7confirmatory items and those items, the areas that 8 those items exist in have to do with stuff where the 9staff has already made its reasonable assurance 10 determination but that was based on something, based 11on the staff's understanding. And what those will be 12 is as long as our inspection program or TVA provides 13us documentation which confirms the fact, the basis 14 for our conclusion then there will be no other staff 15evaluation that needs to take place. We'll just 16document the fact that TVA confirmed something or the 17region confirmed by inspection that item. So in 18reality out of those 83 only 40 of them really will 19 require some amount of staff evaluation and we'll be 20discussing those in future subcommittee meetings. And 21then lastly we'll discuss the few items that remain 22for staff review and presentation in the April 23 subcommittee meeting.
24CHAIR RAY: On the open items I think you 25 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433gave a good summary and certainly we all understand 1that confirmatory items are open because of the 2reasons that you said. In going through the 40 I'm 3 sure there are some that you won't want to have to 4 come back and talk to us about but there are some that 5 we will.6 MR. MILANO: Yes.
7CHAIR RAY: And if we have time, let's see 8 how time goes today but we may want to be more clear 9 about which those are so that people aren't surprised 10 or disappointed respectively on the subject.
11 And then I did want to say as I mentioned 12 to you before the meeting, I guess I thought we were 13going to have more discussion of the complex 14 relationship between Unit 2 and Unit 1 when it comes 15to flooding hazard and that assessment and the time 16lines associated with it and so on. There's a license 17 condition proposed that deals with that, but I think 18we still need to understand it better than we did last 19 time. I thought we were going to do that this time.
20It's not urgent but we do need to understand it 21because the full committee may wish to express an 22 opinion about it.
23MR. MILANO: Right. You are indeed 24correct, the staff's plans are to address that. There 25 11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433are some actions that are continuing to go on in 1 basically two areas. One is we -- this issue is not 2Unit 2-specific, it's site-specific. The same 3probable maximum flood level affects both units 4 equally. The compensatory actions that are taken are 5 for both units and so right now what the staff is 6doing, it's going to -- we believe it's going to take 7 a licensing basis change and a license amendment for 8Watts Bar Unit 1. That is, the staff is working with 9TVA to get that submitted and evaluated, and also the 10 staff is looking at doing some further evaluation of 11the results that were submitted in -- as an amendment 12to the Unit 2 FSAR that provided the new probable 13maximum flood level. We're going to be doing some 14amount of confirmatory analysis that's not yet 15completed and we'll present that also to you along 16 with the discussion.
17We were hoping to do that in April.
18 However, based on all these activities it's doubtful 19that TVA and the staff can get completed by April. So 20those will be one of the follow-on discussions that 21 we'll have at a later time.
22CHAIR RAY: Well all right, but I still 23 want to point out that this may not be as simple as oh 24well, we'll adopt what we did for Unit 1. It's 25 12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433possible that there's some comment that would be 1forthcoming as to Unit 2 on its own and so the sooner 2the better so that that can be discussed. Thank you.
3MEMBER STETKAR: Just out of curiosity, 4that all has to be integrated with Bellefonte also, 5 right?6MR. MILANO: Bellefonte, what TVA had done 7is as you're probably aware when TVA reassessed the 8complete Tennessee Valley watershed area and stuff, 9and it came up during the Bellefonte 3 and 4 review 10and you're correct, it will affect Bellefonte, there's 11some actions that TVA is contemplating completing for 12Bellefonte 1 and 2 to change the site characteristics 13over there. So you're correct, it affects all of 14 their stations.
15 MEMBER STETKAR: Okay, thanks.
16 MR. MILANO: With that I'm going to turn 17it over to TVA to begin their discussions. And Mr.
18 David Stinson, the vice president for Watts Bar Unit 19 2 and his staff will be making the presentation.
21 CHAIR RAY: Good morning.
22MR. STINSON: It's a pleasure to talk with 23you today. What we're going to do is I'm going to 24 give you a fairly quick update on Watts Bar status.
25 13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433We've had some changes since the last time we met that 1 you may be interested in. Bob Ryan to my right will 2talk about meteorology and radiation protection along 3with radiological consequences of accidents, and Frank 4Koontz will talk about transient analysis. Then we'll 5 open it up for questions.
6 As far as status goes let me just talk 7about four primary subjects to kind of give you an 8overview of the project. One is how we're doing with 9safety, quality, our safety-conscious work environment 10program, and then some reorganizations that we've done 11and new alignments on the project, and then Gordon 12 will talk about Appendix HH status.
13So last week we surpassed 13 million man-14hours without a lost work day. That's a major 15milestone for us. TVA's record there is 14.3 so we 16still have a little ways to go. If we can keep 17ourselves focused on safety through the next three 18months we'll actually have two years without a lost 19 work day so we're very proud of that. It's a good 20 accomplishment for the project.
21 Last year we worked almost 7.5 million 22 man-hours. We had a recordable injury rate of 0.49.
23 On projects like what we are doing this job today we 24look for companies that have an RIR around 1 to 1.5 as 25 14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433being a good record, so 0.49 is an exceptional safety 1 record. Our contractors in the OTV team have done a 2 good job here.
3There are over 28,000 supervisors' safety 4 interventions. This is something that we've done 5 contractually. We try to get more people involved.
6We know that about 83 percent of all injuries occur 7when the foreman's not in the area, some level of 8supervision, so we try to get as many folks out in the 9plant as we can. Also, our craft engaged in this. I 10know the program card, the intervention, the card 11program when they find someone that's not wearing the 12correct protective equipment or doing something in the 13wrong manner, they write those things up and submit 14them and we get better because of it. So we're proud 15of our safety program, we continue to focus on that 16and keeping people safe to come back to work the next 17 day.18Organizational structure. We had a 19 contract with the Bechtel Power Corporation that was 20based on an engineering procurement construction 21 contract. We've reached a time in the project where 22TVA needs to take more responsibility so we've 23actually converted that to more of a managed task 24 contract, and the roles you'd expect for Bechtel are 25 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 being --1CHAIR RAY: Excuse me, Dave. Say that 2 last sentence again, please? You converted it to?
3MR. STINSON: To more of a managed task 4approach or a contract as opposed to in an EPC 5basically we give them the keys to the plant, they do 6 the work and in the end they give the keys back.
7We're a little different in that TVA does have the 8startup responsibilities for the plant, we have an 9operating unit next door and the degree of interaction 10 that we need to have daily is a little smoother when 11 there's TVA people working directly with TVA people.
12So we modified the contract slightly. TVA, Bechtel 13has responsibility for engineering, for quality 14assurance, for supply chain and for ASME construction 15and other type construction work that we assign to 16 them. What's changed really is TVA has taken on a 17different role in that whereas before work priority 18came under the EPC, TVA takes responsibility for work 19 priority. We assign day-to-day direction. I think 20more importantly we're responsible singlehandedly for 21schedule and work performance. So this is, like I 22 said, a natural evolution on the project.
23We've staffed to fill these 24responsibilities on the TVA side. We have a few 25 16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433vacancies that we still need to fill, and I think 1what's important for us is that this is the model that 2we'll actually start Bellefonte out as and finish as.
3 It's TVA taking that leadership role day to day. So 4it clearly defines responsibility and it lines up our 5management model with our contract model so there are 6 no conflicts between the two.
7Organization is, I know you can't read 8 this slide that easily, but what's important is that 9 we've got bold blocks in there and then the non-bolded 10 blocks. The bold blocks are the Bechtel organization.
11Because of the end stamp and their requirement to 12maintain technical direction we place them in the 13 center of the organization and wrappered the TVA 14organization and other contractor organizations around 15that group. And like I said, it cleans up lines of 16 responsibility and it changes behavior in a way that 17 I think is very positive for us in that if we have 18 issues on the project they're not a company problem, 19they're a project issue that we need to resolve.
20We've actually gone to one color hard hat for all our 21Unit 2 people to kind of further, you know, build that 22team environment on the project. And we've seen some 23 success with that. Let's go to the next slide.
24 Quality. I just want to point out the 25 17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433quality program has not changed. TVA still maintains 1the oversight role in that area. What has changed is 2 that we modified our contract so that more companies 3 can work under that quality, under Bechtel's quality 4 program, gives us the ability to put different skill 5sets on the job and be more efficient. So no major 6changes there other than the fact that other companies 7are also working under Bechtel's quality assurance 8 program.9Safety-conscious work environment is an 10important program for us. It's one of the 11cornerstones of our nuclear quality program. I think 12we understand the foundation of any SCWE-type program, 13 communication. We spent a lot of time, I just 14finished 24 all-hands meetings to get all 2,800 folks 15through that process talking about the changes to the 16organization that we've had, our safety program, 17quality program, that sort of thing. So we try to 18 talk a lot. We also try to listen more effectively.
19As managers we tend to be very focused on -- not 20necessarily listening, so we're working on that 21 program.
22We have a lot of different monitoring 23 tools that we use to pulse the site, to make sure that 24 we don't have issues that are ongoing that we're not 25 18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433aware of. And like most utilities we have a lot of 1different ways for people to get safety issues on the 2table as you're aware. The supervisor is a principal 3 path for identifying safety issues and getting those 4 raised and resolved. And then we also have our 5Corrective Action Program, it's anonymous, and a kind 6of sign-your-name type program. Our employee concerns 7program, both the companies that we're working with 8 and TVA. Interesting to note that people tend to be 9more comfortable coming to TVA's ECP, so about 92 10percent of the people feel more comfortable working 11 with that. We have both avenues available. We also 12 have our inspector general who's actually onsite and 13 either walk into any of their office or they can also 14use the empower line, phone line that works very 15 effectively. I tell the folks that if they have an 16issue that they don't feel comfortable coming to their 17 supervisor they can use that. Every morning at 6:30 18 I get the previous day's comments that may have come 19in and I get 15 days to respond so it's a good program 20 there. And then finally, you know, the NRC and 21walking through the door there or hitting the hotline 22as well. This was an area that we were concerned 23 with. Let's go to the next slide.
24MEMBER SKILLMAN: Before you go, let me 25 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 ask this. I'm Dick Skillman. What events triggered 1 your taking back the keys and your focus on 2presentations on SCWE? You just said you had 24 3 meetings to meet 2,800 people.
5MEMBER SKILLMAN: That is a huge focus for 6you and your staff. Taking the keys back from Bechtel 7 Williams was also a very large step. What triggered 8 that?9MR. STINSON: Well, it was really was the 10conflict between the way that the project needed to be 11 managed and the level of involvement that TVA needed 12to exercise on the program and the integration between 13all the different organizations. So the Williams 14part, Williams is actually relatively new. We took 15the indirect work, scaffolding laborers, because we 16have local contractors now working on the project more 17than just Bechtel, that was the original intent, so we 18have Day & Zimmerman, we have Williams working a 19couple of different scopes. We wanted to have like a 20single integrated support organization that supported 21 all the contractors that TVA would integrate to make 22sure that everyone got supported equally. We found 23when we did that we actually had an overlap of 24responsibility, around 129 people. So we saw some 25 20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433efficiencies that could be gained by reorganizing our 1contract models and then also the site. And then, and 2 I would say it was time that we're in the stage where 3we're starting to start up systems in the plant, hand 4 over major areas of the plant and so we needed to 5 exercise more responsibility and our contract really 6didn't allow that easily. It was, we had to be given 7 that authority under the contract. We just 8renegotiated the contract so it was clear that TVA had 9 the lead role and that we would take responsibility 10 for those actions.
11MEMBER SKILLMAN: How about the SCWE part?
12MR. STINSON: Kind of two reasons. One is 13it's a requirement. We have a confirmatory order that 14says that we'll do a certain number of meetings a year 15and engage the site population on the importance of 16the program. So there's a mandatory requirement. But 17 also, and if we go to that next slide I'll show you, 18 last year when I, I've been here about 9 years but 19 when I first came onsite I asked how we were doing 20with NRC allegations and we had 26. And so in my view 21when you have a number like that, and the project that 22I came off of, the MOX project in Macon, South 23Carolina, another NRC reviewed site. And you know, we 24 had around three in the four years that I was in the 25 21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433same role there. So I saw that number as being very, 1 very high and in my mind it really boils down to a 2trust issue. Do you feel like as an employee that you 3can raise safety concerns and that people will listen 4 and they'll do something about it.
5 And so we have, you know, I talked about 6the past employee concerns resolutions, we have those 7 five paths, four of those are internal to either the 8 companies that work with us or TVA, and in fact both 9have those same paths. Usually if you're comfortable 10with the environment that you will use one of those 11four paths. And not always, but usually. So to me it 12looks like potential for a trust issue with the 13management team. And so I felt that it was important 14 to continue focusing on these areas so that we could 15 let people know, you know, our approach.
16 And it's really simple like trying to 17 focus like with managers what their responsibilities 18 are. We talked in terms of how we set work hours. I 19can tell you my work hours are set. I come in before 20the project starts and I leave you know well after the 21project is over for that shift, and the idea being 22 that we ought to make sure that people know they can 23come in and talk and raise safety concerns or any 24issue that they might have, that that's my 25 22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433responsibility that if no one else will listen to you 1I will. That was the message. Managers have that 2responsibility as well. So when you go from a 3situation where you have a lot of things that are 4going outside the internal paths to get resolution, 5that you've got to do things that are different. And 6so we're trying to take a different approach to folks 7and personalize the concerns process, trying to really 8emphasize to people you know like me. I grew up 9within five miles of the Valley, my family still lives 10you know right next to Browns Ferry. This is 11 personal. You know, we need to make sure that we do 12a good job. We're all interested in this being a safe 13 plant and that if no one else will listen to you that 14I will, and that's kind of the example that we're 15 trying to set through these meetings.
16 MEMBER SKILLMAN: Thank you.
17MR. STINSON: And you know, how are we 18doing, we're doing better. I wouldn't say we're good 19 yet. We've, through September we've had four 20allegations, a couple earlier in the year and then one 21 each in August and September. We have had an upturn 22 in allegations. We, through this reorganization and 23through our new budget that we established for 2011 we 24had a layoff. About 750 people were affected by that 25 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 layoff. We got 3 to 4 allegations in October and I 1think we had 2 in November so we're up in the 10 to 11 2 range for the year. Better, still not where we need 3to be. And so there was a belief that we needed to 4continue to reinforce that message of openness on the 5 project. So we're doing better, not quite where we 6need to be. I'd like to see that at zero or one, you 7 know, kind of number. Let's go to the next slide.
8I wanted to just follow up with some 9 pictures of the plant as we finish out the area. A 10lot of focus right now in two areas. One's the 11turbine building. We're trying to get out of that by 12springtime so we're really focusing on just completing 13the startup of the secondary side of the plant, and 14also upper containment. We're in the process of 15painting out upper containment right now. That's lube 16 oil system, the different panels that are there.
17 One of the things that this plant is a 18little unique in that we've had an operations and 19maintenance staff that have worked on a single unit 20 inside a 2-unit plant for the last 16 years, and had 21 been able to do pretty much what they wanted to do at 22the plant because it was all theirs. Now we're 23talking about bringing in a second unit and we want to 24make sure that it is very, very clear that they're on 25 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433Unit 2 and so we do that with color. So Unit 2 is the 1blue unit on the site. If you walk up to a panel the 2floor is actually will all be blue here in the near 3 future. You know that you're on Unit 2. If you walk 4 up to an MCC panel and the bucket is blue it's Unit 2; 5 if it's white, it's common systems; if it's red it's 6fire protection; if it's any other color it's Unit 1.
7 So we've been very directive on how we were going to 8 paint out the plant to make it easier for people to 9understand the difference between the two units 10visually and then all the other cues are there as 11well, but just to minimize mistakes because of the 12 many years that we've been running as a single unit.
13 Let's go to the next slide.
14Turbine deck itself. Like I said this is 15something that for us is a point of pride. You know, 16we have millions of man hours that go into this plant 17 and when we finish all people really see are the paint 18 and insulation, and so it needs to reflect the pride 19and the skills that we put into our work. So we're 20focusing very heavily in this area so we'll present 21the plant with a unit that they'll be very proud to 22 own and to operate. Let's go to the next slide.
23Talk quickly about our startup program on 24this slide. There's really nothing new. We have, you 25 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433know, a standard startup program, meeting all the 1Chapter 14 requirements. We're going through a 2component test and system test at this time. We've 3 used a focus on the turbine building site so that we 4could get all of our safety-related system procedures 5 and skills that are needed tested on the non-safety 6 side so that we would minimize any errors that might 7occur on the safety-related side. And that testing is 8 going well. Next slide.
9So we're currently about 23 percent 10 complete with component testing. We're doing system 11 flushing. Right now we're flushing out the feedwater 12lines on the secondary side. Pre-operational testing, 13 it's the 1.68 and FSAR guidance, we've got 43 out of 14119 procedures that are approved and we're about 71 15percent complete with overall procedure generation.
16We have 20 additional in our JTG. All the testing and 17 flushing that's done is under NGDC as opposed to the 18 operational group NPG. We've turned over 38 of 86 19systems to startup. We turned over four systems to 20 the operations organization. We have two more 21 scheduled by the end of the year.
22So where are we at? So we have our tanks 23are filled with pump suctions, refueling water storage 24 tank, RWST, and the primary water storage tank. We 25 26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433have condensate in operation, feedwater in service 1with two of the hotwell pumps running on 3 mrem.
2Booster pumps are running. We have tested through two 3 of the three and the third one should be tested this 4 week. The condenser circulating water is in service 5 so the cooling towers are in operation. Raw cooling 6water is in service. The oil systems are put in 7 place. We're turning over the turning gear, putting 8our turbine on turning gear weekly. Annunciator 9computer systems are in service. We're calibrating 10our solid state protection systems. The main 11feedwater pump oil systems are in service and the 12pumps are where we're flowing water through the 13feedwater system for flushing. And control air 14 flushing is in progress.
15 I will tell you that we felt like the 16plant was in a good cleanliness level overall but 17we've been very surprised with how well the plant's 18 cleaned up. We're very finding very little material 19in the strainers and we're going to come down in 20January and take condensate out of service. We'll go 21into the hotwell and we expect to find, you know, 22 debris there but as you would normally. So we'll go 23 and muck that out, clean that out and then we'll have 24a very clean, tight system in order to operate the 25 27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 plant. Next slide.
1So transitioning operations. The 2operations group are engaging regularly, you know, 3with us. We have a Unit 1-Unit 2 interface team, that 4 32 individuals that are part of the plant staff that 5 work with us to make sure that the plant is ready to 6accept the systems and that the systems are in the 7right stage of completion for them to own. Our chief 8nuclear officer meets with us every other month in 9what we call a management review meeting. We've gone 10through and I think we've briefed on where we are with 11permanent staffing but we have a major turning program 12and new license classes for both licensed and non-13licensed operators and maintenance craft. And one of 14 the things that we're doing over this next year 15because our schedule is extending into next year is 16that we're actually using the Unit 2 maintenance staff 17as part of our startup organization and so we have 19 18I&C techs that are in today working. By the end of 19 February we expect to have about 30 mechanical 20maintenance people that are out of the class, 20 21electrical and 20 more I&C techs, so about, I think 22the number is going to be around 79 maintenance people 23will be there. So the advantage is normally we would 24do startup with a contract staff but we'll actually do 25 28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433it with our own maintenance people so they'll get the 1 opportunity to learn the plant as it comes up, how 2 they operate. Even though the plants are identical, 3you know, the pumps sound different, you know, than 4 the other so it gives them a chance to really learn 5the plants. We think, you know, that's going to be 6 very positive.
7Training is continuing on dual unit 8licenses and unit differences and we try very hard to 9minimize those differences. As we go through the next 10refueling outage in September for Unit 1 those 11differences become less and less as Unit 1 comes up to 12some of our modifications. And under the work 13management program, you know, we're fully flushing out 14 the process to get to a 26-week schedule basis prior 15to going into our surveillances for fuel load for the 16 plant. 17MEMBER STETKAR: You mentioned you're 18 going to license the operators dual unit.
20 MEMBER STETKAR: Are you going to have a 21 fully shared maintenance staff also or are they, are 22 they unitized?
23MR. STINSON: The maintenance staff is not 24 unitized.25 29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER SKILLMAN: In your preparations to 1head towards operations, what operating experience 2 have you incorporated?
3 MR. STINSON: So, and I'm going to speak 4to the operations folks and Tom Wallace is our 5operations manager on Unit 2 that's doing a lot of 6 that work for us. But there's been a lot of concern 7within TVA and the operational group that this has 8been a single unit for a long time. Now, we have a 9sister unit, Sequoyah, down the road. One of the 10things that they've stressed with operations and 11maintenance people is that they start taking care 12visits and going up to the Duke plants, going up to 13D.C. Cook, similar type plants, looking at their 14operation, but also looking at other utilities. So 15they've worked with INPO to set up these peer meetings 16and so that is one way that they're doing it. And 17then I think the other way is we, actually today we've 18 got an SRO that's sitting in the horseshoe on Unit 2 19 and so we had a license class, made folks available.
20 We have five AUOs that are on shift that are permanent 21AUOs for the plant and so they're coming into the 22testing process. You know, they're turning switches, 23operating equipment, they're doing rounds. We're 24working very hard to establish our standards, you 25 30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433know, for performance and cleanliness in the plant and 1working with them to make sure that our standards, you 2know, are equal to or better than the standards on the 3 operating plant.
4So it's really that whole process, peer 5visits, bringing both operations and maintenance 6personnel onto Unit 2 in the startup phase of the 7 operation where they start taking ownership of a 8 plant. To me that's the biggest barrier is when is it 9 yours. At what point in time do you take ownership.
10 And so our intent was to bring that date in as early 11as possible, start making the opportunities available 12 for the operating site to start owning that unit.
13 MEMBER SKILLMAN: Thank you.
14MR. STINSON: Next slide. So 15transitioning operations. We have a procedure called 16TI-437 which is how the operations staff goes through 17the turnover documents and accepts the system. And 18fairly involved as you would expect. It goes through 19all the documents that go with that system, drawings, 20calculations, procedures, maintenance instructions, 21that sort of thing. And wrapped around some very 22intensive lockdown to make sure that the plant is 23 exactly in the mode that operations staff expects.
24 To this point we've turned over four 25 31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 systems. The first system we turned over was building 1heat, obviously a very small system, about five 2breakers involved in that, but it was a little rough.
3And we're thinking gee, five breakers, that's, you 4know, shouldn't have been a little rough but it was 5because you know, there's always that kind of conflict 6 that you'll see between the organizations. What are 7you giving me, you know, how clean is that system.
8 Are you giving me work to do after I accept it. And 9 so part of this is that trust thing within 10organizations as well. And so that was a little 11 rough. We did system 37 gland seal water and that was 12 a system that does have ties into the operating unit 13directly on the secondary side. That was another 14level of complexity. As we went through we stopped at 15the end of each process and said okay, what worked, 16what didn't and we continued to revise these 17 procedures.
18 Last week we turned over two more systems.
19These are heating and ventilation type systems, again, 2030 Oscar November. We have two more systems that 21we're looking at this week and will actually go 22through plant health next week with the outside chance 23we might be able to do four. We've got a couple of 24electrical systems that will go over once the RCP 25 32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433board, and so we're continuing this process. So we're 1still on primarily non-safety systems. We're working 2through the processes to make sure that the system, 3the process that we use is smooth and then we'll 4finish the safety systems. We'll be more effective 5 that way. Gordon?
6MR. ARENT: Yes, this is Gordon Arent from 7 TVA. I just wanted to --
8 CHAIR RAY: Just a second. You're done, 9 David, are you?
11CHAIR RAY: Earlier in our review, I can't 12remember which meeting it was now for sure, but it was 13maybe the first or second meeting, the relationship 14 between the Unit 2 schedule and the Unit 1 operating 15schedule, outage schedule and so on was of some 16 concern because it was, Unit 2 appeared to be driven 17to a very tight schedule by the Unit 1 operating 18 availability. Nothing is discussed here although I 19recall that subsequently there was some change made to 20 relieve some of that pressure that existed. This is 21 perhaps before you had the engagement, I'm not sure, 22but in any event I guess I'd like to ask you to 23comment on to what extent Unit 2 is being driven by 24Unit 1 outage and other status schedule requirements.
25 33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. STINSON: Okay. I may get some help 1with this from the folks around the room. I would 2tell you that there was a lot of pressure at the last 3outage trying to get the RCW completed during the 4outage because of the potential for needing a mid-5 cycle outage if you didn't get it during that outage.
6We were able to do that work but I think we learned a 7lot, you know, from that. And I would tell you today 8the interaction with the site you know goes through a 9 process that does it slow us down from time to time?
10 It does. We may want to get out of the system. You 11know, we're working around train weeks, you know.
12We're pretty closely tied into those units, especially 13 around the electrical board so we, you know, we have 14to work around the train systems. The outage work, 15 for now, you know, if -- we have the next outage for 16the unit is in September. We view that as an 17 opportunity to do some work in an easier, that's the 18 simplest word I can --
19CHAIR RAY: Well, the issue at hand was 20whether or not Unit 2 was being driven beyond the 21headlights because of the need to meet those outage 22 windows in Unit 1.
23 MR. STINSON: I don't see that today. I 24 don't know, Frank, if you want to, or Tom, do you want 25 34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 to comment?
1MR. KOONTZ: Steve may be able to -- I 2 think the issue at the time when we were up here 3 earlier was the blackout testing on the diesels.
4CHAIR RAY: Well, there was some but then 5 there was this change --
6 MR. KOONTZ: I think we resolved that.
7 CHAIR RAY: -- that occurred.
8MR. KOONTZ: How to do that without an 9 outage.10CHAIR RAY: Maybe some overview of the 11schedule is yet to come and we'll understand that.
12We're not as concerned I don't believe with the 13turnover status, that's your business, but with 14whether or not you're having to do things on Unit 2 15prematurely or under too much pressure or whatever 16because of the outage windows on Unit 1 that are 17 available to you.
18MR. STINSON: No sir, I don't see that 19 today. I don't feel that pressure. Tom?
20 MR. WALLACE: No, sir. I don't think we 21have that pressure. We worked through earlier issues 22 with our blackout testing and our need for tech spec 23 changes that are ongoing in the process. We did put 24our hot pipe basically on our essential raw cooling 25 35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 water system to be able to get our flow numbers that 1we needed to be able to determine if we could do flow 2 balancing online or we'd have to do it in an outage.
3 We were able to complete that in the outage and have 4the numbers we need right now to make that decision 5 and not have an impact on the operating units.
6 CHAIR RAY: All right, well, that's fine 7 then. Take your time. We're not in any -- we're not 8 trying to push the schedule.
9 (Laughter) 10 CHAIR RAY: We want to make sure that if 11there is an interaction between the two that it's not 12leading you to do something on Unit 2 that you would, 13 that's sub-optimal.
14MR. STINSON: The one point I probably 15didn't mention and I should is that it's obvious we're 16not on our original schedule, that we're not going to 17finish in April of next year. And we're in the 18 process now of doing a complete estimate-to-complete 19 on the unit. This one is slightly different in that 20 TVA actually has taken ownership of the schedule and 21the databases that drive it. We're running samples to 22make sure that the numbers are accurate. Once we have 23 those estimates complete we'll go through actually a 24 seven kind of level governance review till we get to 25 36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433our board in February and at that point in time we 1will announce what our budget to complete will be, 2 what our schedule to complete will be and we'll be 3able to share that, you know, with you. It's somewhat 4frustrating I know for staff, you know, wanting to 5know and set their inspection times around our 6schedule but because of Sarbanes-Oxley we can't 7release that. But it's clear that we have a little 8 more time, it's given us a little more planning time 9 to work around these critical issues.
10CHAIR RAY: I think you're speaking to the 11 thing that was of concern to us, it just didn't seem 12 to me I could see how you were going to make what was 13 being laid out. We'll see what you're going to come 14 up with after you're ready -- when you're ready.
16 CHAIR RAY: Okay.
17MR. ARENT: Briefly, I just wanted to talk 18about the open items. Pat mentioned that at the 19outset meeting. There were 124 open items total to 20date from SSERs 22-25. On the right-hand side of the 21 picture you can see that 41 of those items have been 22in fact closed. We, TVA, have submitted 39 items for 23 review so 80 out of the 124 are in some stage of 24 closure or review for closure. The remaining 44, a 25 37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433number of those as Pat mentioned are confirmatory 1 items that will either be closed by the region or by 2 NRR.3We do owe probably about 10 direct 4responses into NRR for their final review. That's not 5actually a confirmatory item but additional 6information that's owed, and right now we're on track 7 over the next two submittals to have those completed 8 by the end of January. So, a number of these items 9 though from a confirmatory nature will go out as we 10 complete the plant because some of them are physical 11verifications of plants. So that's where we're at 12today on that. Again as Pat mentioned we can go into 13more detail offline if you like on some of those 14 specific items.
15CHAIR RAY: Well, yes. We're talking 16about the same thing. We want to make sure that 17particular open items, not the confirmatory items I 18don't believe but open items that need some further 19opportunity for review here that we know which ones 20 those are.
21MR. ARENT: Right. Okay. That's all I 22 have. I'm going to turn it over to Bob Bryan who's 23going to start our discussion on radiation protection.
24MR. BRYAN: Thank you, Gordon. Good 25 38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 morning. 1 CHAIR RAY: Good morning. As Dave 2mentioned we live in the Valley and we work at the 3 plant so ALARA is important to us, so we've tried to 4 build that into the plant. That said the basic 5shielding features for Watts Bar Unit 2 are identical 6to Watts Bar Unit 1. The buildings report at the same 7 time. The plants are mirror images, they're not 8slide-alone units so it's, so when you walk on the 9 Unit 2 side the things that are closest together are 10the common features and as you move out to the things 11that are closest to the outside wall on Unit 1 or 12closest to the other outside wall on Unit 2. The 13ventilation is designed so that you bring air into the 14upper floors that are clean and exhausted through the 15 dirtier rooms so that you don't spread contamination 16that way. Because of the layout of the plant a lot of 17the features that go into the radiation protection 18such as counting rooms, decontamination rooms and labs 19 were built as common areas that have feeds from both 20units and so they're shared between the units. The 21access to the auxiliary building into the radiation 22zone is common between the two units and so there's 23not a separate one for Unit 2, it's the same one 24 that's used for Unit 1 and the egress is the same.
25 39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER SKILLMAN: If I could, your point 1that the units are mirror images intrigues me and I'm 2 curious why you made that point.
3MR. BRYAN: A lot of units when they build 4 things the units are slide-along units. So when you 5 walk into one the -- ours is just a little different.
6CHAIR RAY: I can weigh in and say having 7 built a mirror image unit and look at 1 Diablo Canyon, 8 getting the reactor vessel back --
9 (Laughter) 10CHAIR RAY: -- can create problems when 11things are right-handed, they're right-handed in both 12units which causes the arrangement sometimes to be 13 awkward.14MEMBER SKILLMAN: Well, I wondered if that 15 meant the operators have to be dyslexic on Unit 2.
16 MR. BRYAN: They have to be really good, 17but the constructors are the ones that have to be 18 really good because at Sequoyah we did what they did 19 at Diablo Canyon.
20MEMBER SKILLMAN: I understand that there 21is a complication that comes because you can't go from 22Unit 1 to Unit 2 and expect the identical physical 23 configuration. Got it. Yes, sir, thanks.
24MR. BRYAN: Okay. On the NUREG/0737 items 25 40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433we have done mission dose calculations for Unit 2 that 1 we have updated in terms of some of the differences.
2 I'll be talking about them a little bit later but we 3 have done those and the vital areas of the plant were 4set up for Unit 1 operation for the single-unit 5 operation so we recast the documentation to reflect 6the two-unit operation and it'll be next year when we 7actually transition to the finished plant 8 configuration vital areas for the two units.
9Similarly on radiation monitors the 10coverage is really virtually identical to Unit 1 11 there. There are a total of 84 radiation monitors 12shared between the two units, 29 are Unit 1 monitors, 13 29 are Unit 2 monitors, 26 are common. Eight Unit 2 14monitors were put in service to support Unit 1 15operation at the time of license so we're adding 21 16new Unit 2 monitors. These are almost exclusively in 17the containment and along the secondary side paths.
18With the new monitors channel operability test 19extensions will be based on the operating experience.
20We have an adequate statistical base to support that.
21Unit 1 in the original plant, we had a number of local 22continuous air monitors. They have over time replaced 23those with portable continuous air monitors maintained 24by the rad protection people. Unit 2 is following the 25 41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433same arrangement and will generally use portable 1monitors for the local continuous air monitors. We're 2able to use the building-wide range gas monitors to 3provide the basic 10-deck hour protection requirements 4and then we have installed continuous air monitors in 5the fuel pool area. The rest of the plant monitors 6 are done with the portable monitors.
7MEMBER ABDEL-KHALIK: Is there an 8unfiltered in-leakage, control room in-leakage tech 9 spec?10 MR. BRYAN: Yes.
11MEMBER ABDEL-KHALIK: And will that be 12 changed?13 MR. BRYAN: No.
14MEMBER ABDEL-KHALIK: Or is it the same --
15MR. BRYAN: No, it's a common control 16 room. The control building isolation area is the same 17for both, it's the same room for Unit 1 and Unit 2.
18 You can look from the Unit 1 horseshoe to the Unit 2 19 horseshoe. So it shares the same ventilation.
20MEMBER ABDEL-KHALIK: So it will remain --
21 MR. BRYAN: Pardon?
22 MEMBER ABDEL-KHALIK: It will remain the 23 same as it's always been for Unit 1?
24MR. BRYAN: Yes. It shares ventilation 25 42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433system, it shares the same emergency ventilation 1 system, same filtration system.
2 MEMBER ABDEL-KHALIK: Okay.
3MR. BRYAN: Similarly the rad waste 4systems are, much of it is shared between the two 5 units. There's a fair amount of operational 6flexibility though built into the system so that we 7 can manage how much processing that we have to do on 8the releases. Typically the rad waste systems that 9 treat reactor coolant and its associated waste get a 10high level of processing but typically on the 11secondary side we've run very, very clear. And for 12 instance, we don't use the condensate demineralizers 13except generally in the startup mode and on Unit 1 14we've never had to put them in service to handle high 15source in the secondary side as an example. So 16generally that waste is just monitored and diluted and 17released as an untreated release. If we did get a 18 high source in there we are able to process it first 19 by the condensate demineralizers. Then we also have 20a mobile demineralizer skid that we would treat the 21 regeneration waste with.
22 MEMBER SIEBER: You said that you don't 23use condensate demineralizers during normal operation.
24 MR. BRYAN: That's right.
25 43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER SIEBER: And so you have a boiler 1 blowdown system that's a substitute for that?
2 MR. BRYAN: We do a steam generator 3 blowdown, yes.
4MEMBER SIEBER: Right. And is that a 5 continuous process?
6 MR. BRYAN: Yes, and it's just monitored 7 and generally released.
8MEMBER SIEBER: And what treatment do you 9 provide to the blowdown water?
10MR. BRYAN: Right now none other than 11 dilution.12 MEMBER SIEBER: Okay.
13MR. BRYAN: It's monitored. But if we got 14 a high-level release in there then we would treat it 15through the condensate demineralizer system. And then 16depending on how that came out probably would be 17treated also through the mobile demineralizer skid.
18 But in the 14 years of operation on Unit 1 we've had 19 no issues with just treating it.
20 MEMBER SIEBER: So let's pretend you get 21a small steam generator tube leak, you make a decision 22to continue to operate because it's so small. Your 23condensates and mineralizers will become radioactive.
24Your blowdown system if you used it would also be 25 44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 radioactive. Do you have treatment facilities and 1 procedures to deal with that kind of a situation?
2MR. BRYAN: Absolutely, and that's, I 3mean, that was the way the plant was designed from --
4 that was part of the initial design. There are 5radiation monitors in the demineralizer areas.
6They're set up to be high-radiation areas with the 7shielding and restrictions. So yes, that's built into 8 the --9MEMBER SIEBER: Right. Some licensees 10when they encounter that situation are surprised where 11 the activity goes.
12 MR. BRYAN: Understand.
13 MEMBER SIEBER: Okay.
14MEMBER ABDEL-KHALIK: Let's go back to the 15 control room handling please for a moment. First of 16 all, what is that tech spec limit?
17 MR. BRYAN: I'm sorry, I --
18MEMBER ABDEL-KHALIK: It must be very 19 small. Unfiltered control room in-leakage.
20 MR. BRYAN: I'll have to find out.
21 MEMBER ABDEL-KHALIK: I'm just wondering 22 how often do you have to test for that.
23 MR. BRYAN: Pardon?
24MEMBER ABDEL-KHALIK: How often do you 25 45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 test for that?
1 MR. BRYAN: Well, once -- Tom?
2MEMBER STETKAR: Make sure you identify 3 yourselves.
4MR. HILMES: Steve Hilmes, electrical and 5 I&C. Eighteen months surveillance.
6MEMBER ABDEL-KHALIK: Right. Has that 7been challenged, the tech spec limit for Unit 1 during 8 the construction activities for Unit 2?
9MR. HILMES: We did -- what do you mean by 10 challenged?
11MEMBER ABDEL-KHALIK: Meaning have you 12 exceeded tech spec limits?
13 MR. HILMES: No.
14MEMBER ABDEL-KHALIK: Did you have to 15 enter an LCO because of that?
16 MR. HILMES: Tom Wallace.
17 MR. WALLACE: Like the man said, we have 18a breaching program. If we have to breach a 19penetration into the control room it limits the amount 20of open space you can actually have. It's the same 21 space that you would have with the operating side if 22we weren't here. We can't see any limits. It's there 23 and it's within the design of the plant. As long as 24 we stay within the margin of those breaches and meet 25 46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the requirements that are set up with our engineering 1department to make that particular breach we do not 2 challenge our tech spec.
3MR. KOONTZ: Yes, this is Frank Koontz.
4 I can also mention that a lot of, as Tom mentioned a 5lot of these breaching permits come over to 6engineering and we evaluate them. For example, if 7they're doing cable pulls through the walls we'll look 8 at the flow area there, we'll look at whether that's 9an acceptable flow area you know as far as the in-10leakage into the control room or we look at how to 11seal it up in an emergency if they have to seal it for 12some reason. If we would have an event then we're 13 required to do that, what they need to do. All that 14 is evaluated under the breaching permit.
15MEMBER ABDEL-KHALIK: Usually that tech 16spec limit is pretty tight and I was just wondering if 17these construction activities would in any way 18 challenge that limit.
19 MR. BRYAN: No.
20MR. KOONTZ: So far we've not allowed it.
21MR. BRYAN: We haven't allowed it. That's 22what Tom was saying, that basically we are limited as 23to the maximum breach that we can have in there and --
24 MEMBER SIEBER: Time and size.
25 47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. BRYAN: -- and so, by size. And so 1when we do the construction activities we are not 2 allowed to --
3 MEMBER ABDEL-KHALIK: It's usually CFM.
4MR. BRYAN: Right, but that -- but you can 5 equate that to -- size hole. You know, the exact --
6 it's under 150 inches, cubic inches.
7MR. WALLACE: Oh, yes, that's the problem 8 is a much smaller --
9 MR. BRYAN: Much smaller than that.
10MR. WALLACE: That's for the auxiliary 11building where we have 117 inches we can work within.
12MEMBER ABDEL-KHALIK: For the control room 13 it's much smaller.
14 MR. BRYAN: Much smaller.
15MR. WALLACE: And much tighter 16requirements, that's correct. Yes, we have to do 17things like make sure the turbine building ventilation 18 is set up and the doors are properly set. We've got 19a high energy stimulating the turbine building that it 20 wouldn't factor into the equation.
21MEMBER STETKAR: Have you finished pulling 22 all the cables into the control room for Unit 2 yet?
23MR. HILMES: Steve Hilmes. No, I haven't 24 completed it all yet.
25 48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER STETKAR: Started?
1 MR. HILMES: Yes. Quite far along.
2MEMBER STETKAR: Okay. So you have --
3what I'm trying to -- you have some experience at 4least and you still haven't entered an LCO during any 5 of the other capables.
6MR. HILMES: We don't, yes, we don't enter 7the LCOs. We figure a way to limit the amount of in-8leakage you get when you're opening it up. And 9there's tricks to the technique to get the cables in.
10MEMBER ABDEL-KHALIK: So the tech spec is 11 based on a CFM limit, or based on a whole size limit?
12MR. BRYAN: The tech spec's based on a CFM 13 limit.14MEMBER SIEBER: Right. You can calculate 15 the whole thing.
16MR. BRYAN: But you can take that and you 17know what the pressure differentials you're 18maintaining are and so you can calculate back what an 19 allowable hole size would be with some conservatism.
20We'll have to get back to you on whether we have ever 21entered the LCO on control room leakage but to the 22best of my knowledge we haven't. It's something that 23 we certainly never do routinely.
24 MR. STINSON: So you're saying no, we've 25 49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 never --1 MR. WALLACE: I can never recall that 2we've entered the tech spec. We've always stayed 3 within the margin of the breaching program which the 4 system's tested and that's numbers established based 5 on the amount of leakage we had.
6MR. HILMES: Steve Hilmes. When they 7performed the testing you end up with the given margin 8 that you have left and that's what you can work with.
9MEMBER ABDEL-KHALIK: And has the last 10testing been done after you started cable pulling for 11 Unit 2?12MR. HILMES: Yes, it would have had to 13 have been.
14 MR. BRYAN: Yes.
15 MEMBER ABDEL-KHALIK: And you passed the 16--17 MR. HILMES: Yes.
18MEMBER ABDEL-KHALIK: -- the tech spec 19 during the test?
20MR. BRYAN: The other thing was a few 21years ago when the generic industry issue came out 22about control room leakage Watts Bar control room 23 design passed adequately. We didn't have to go back 24and do any of the special activities that some of the 25 50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 plants did. The tracer gas testing that was done.
1 MEMBER ABDEL-KHALIK: Okay, thank you.
2MEMBER RYAN: Just one follow-up question 3on the waste area. You've got common waste management 4 systems. Have you evaluated, could you describe a 5little bit if you have how you looked at stresses from 6 both units coming to that system at the same time, or 7a combination of different stresses coming to the rad 8 waste area at the same time?
9MR. BRYAN: Yes, we have. The systems 10 were designed coming in as to supply two units. You 11 know, it was built, they were sized for two-unit 12 operation. They're very, very similar to the systems 13that we have at Sequoyah. So we've got good 14operational history of two-unit operation on these 15 system designs.
16MEMBER RYAN: I appreciate that's a normal 17operating circumstance. What if things aren't normal 18 and you get more rad waste to deal with in both 19 places? What's the head room and your ability to 20 process I guess is one way to think about it?
21MR. BRYAN: Well, actually quite a bit.
22 And I was going to get to that here in a minute but --
23MEMBER RYAN: Okay, that's fine. Save it 24 for when you're going to get there, that's fine.
25 51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. BRYAN: Okay. One of the last things 1that's different in terms of the way we operate today 2than when Unit 1 was licensed, the original licensing, 3the plant assumed that we would do 22 containment 4 purges a year at -- Unit 1 has gone to 100 CFM, the 5continuous filtered vent. Unit 2 is going to operate 6the same way and so the routine releases were analyzed 7 with that set of assumptions.
8MEMBER SKILLMAN: What drives that 9 requirement, please?
10MR. BRYAN: Well, two things. We're an 11ice condenser containment which is a relatively small 12volume containment so it manages pneumatic leakage 13into the containment so that you keep your pressures, 14control containment pressure. And the other thing is 15it also helps you with keeping the containment 16 relatively clean for the weekly entries.
17 MEMBER SKILLMAN: Thank you.
18MR. BRYAN: We use the ANSI N18.1-1984 19search term for doing the routine releases. Things 20that were different from Unit 1, we updated the 21meteorology we were using to cover the period of time 22from 1986 to 2005. This is more or less consistent 23 with the dates that went in with the Supplemental 24 Final Environmental Impact Statement.
25 52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433The FSAR information was based on the 2007 1land use survey. When we do our annual releases we do 2an annual meteorology and an annual land survey so 3those are current for the year. The Watts Bar site is 4very similar to Unit 1. We use terrain adjustment 5factors for the local site area and then we did our 50 6mile population dose, was based on a revised 20-40 7 year estimate.
8MEMBER STETKAR: Bob, here's an off the 9wall question. You'll probably have to take it away, 10but maybe not. You have common meteorological towers 11for both of the units and I was reading about that.
12It has a data acquisition computer and something 13called the environmental data station which I'm 14assuming is at the tower, and it sends meteorological 15data to the plant, the central emergency control 16center (CECC) where there's a computer that then 17distributes it out to the technical support center and 18I guess eventually the EOP and any emergency planning 19 folks. What are the power supplies for those 20 facilities? Where do they get power to both the EDS 21 and the CECC?
22 MR. BRYAN: Well, the CECC has its power 23 supplies out of the, I mean, it's basically supplied 24by the Chattanooga Electric Power Board but it has, 25 53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the building has, and that part of it has backup power 1 supplies at the TVA offices. Steve, do you know?
2 MEMBER STETKAR: Where is the CECC?
3 MR. BRYAN: It's in Chattanooga.
4MEMBER STETKAR: Chattanooga? It's -- has 5 its own diesel? How about the onsite, the EDS?
6MR. BRYAN: Well, the onsite emergency 7 center is in the --
8MEMBER STETKAR: No, no, no, the data 9 acquisition system, the thing that actually collects 10 the meteorological data, processes it and sends it 11 out.12 MR. BRYAN: Steve, do you know the?
13MR. HILMES: Steve Hilmes. The tech 14 support center which is --
15MR. BRYAN: He's talking about the met 16 towers.17MEMBER STETKAR: The met tower itself. As 18 I understand it, maybe I misunderstood it. The data 19comes to a met tower, goes into a little data 20acquisition system. The computer does a bunch of 21processing, sends it out to the CECC. The CECC sends 22 it back to the tech support center and to, you know, 23 the CECC itself and, you know, whatever other places 24you use for emergency planning if there are any.
25 54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 That's at least reading through the brief summary in 1 the FSAR as I understood it.
2MR. WALLACE: This is Tom Wallace. The 3met tower, meteorological tower itself has plant power 4to it. There's a small interruptible power supply off 5there for some of the computers. There's also a small 6 gasoline. It's been years since I've been there but 7 there was a gas generator up there as well.
8MEMBER STETKAR: I was going to say since 9 it's been awhile since you've been there does anybody 10ever go out and check whether the gas generator 11 actually works?
12MR. WALLACE: Yes, sir. It's done by 13people up at Kingston plant that do that or one of the 14facilities that come out and service our 15meteorological tower up there. It alarms. But we 16 know if the met tower goes down you know it 17 immediately in the control room.
18MEMBER STETKAR: I'm obviously thinking 19about it against the, you know, prolonged loss of 20offsite power, whether or not you'd actually have 21real-time meteorological data available for any of 22 your emergency planning action limits.
23 MR. WALLACE: From our rev you'd have 24backup in that tower. It's out of -- that you get 25 55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 from other staples in other locations.
1MEMBER STETKAR: Well, but I mean there --
2that's okay but it's not Watts Bar-specific, you know, 3 as far as wind speeds and directions.
4MR. STINSON: So why don't we take that 5 back and get you a better answer.
6 MEMBER STETKAR: Okay, thanks.
7MEMBER SKILLMAN: Yes, I would like to add 8onto that if I could. It sounds like from the 9gentleman's response that the staff at the Kingston 10station keeps an eye on your met tower physical 11 facility. And I'd be curious whether or not your 12radiological controls people from your station or your 13maintenance people that are under the leadership of 14your station actually do hands-on on the met tower 15 because that is your eyes and ears for an accident.
16MR. STINSON: So, Tom Wallace runs 17 operations. Of course he was the operations man.
18 MR. WALLACE: The people that do the met 19tower maintenance and manage that stuff out of our 20environmental group do the -- it's the same equipment 21 for all the TVA sites. They're responsible for each 22and every one of those stations. But the system 23 itself is smart too and if it goes down it makes 24 notifications to people. There are requirements set 25 56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433up, frequency-type requirements set up for maintenance 1that has to be done and maintained, surveillance if 2you will I guess you'd call it for that maintenance 3 that's required to be done.
4MEMBER SKILLMAN: Okay, thank you. Let me 5ask one more question. The terrain adjustment 6factors, those were identified in the SER on page 2-4 7that TVA was not using the terrain adjustment factors 8 and in this slide you're indicating --
9 MR. BRYAN: Well --
10 MEMBER SKILLMAN: Is that a change?
11MR. BRYAN: No. We applied terrain 12adjustment factors basically to the area within about 13five miles of the site. We did not apply the terrain 14adjustment factors at, either on Unit 1 or Unit 2 out 15to 50 miles. We did do some studies of the -- and to 16 understand how we did the terrain adjustment factors 17the doses are done with a straight line Gaussian 18program and so we ran a variable trajectory code to 19 get, and looked at the chi over Q's at the locations 20of interest. And basically if the, for the near site 21if the variable trajectory code gave us higher chi 22over Q's we used those. If our straight line 23 Gaussians gave us higher chi over Q's we used those.
24 So we basically picked the worst case in that.
25 57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433When you go out and you look out to 50 1miles we ran the variable trajectory code out all the 2way to 50 miles and if you apply those to all the 3receptor locations you end up with doses that are, oh, 4between about three and five times lower than you 5would get using the straight-line Gaussian alone. If 6you take the worst case from all of them you end up 7with about to the 50 mile total person-rem. You 8 change at about 0.3 rem over to 150 to 1.5 million 9 people. The requirements are that you don't, for 10terrain adjustment factors that you don't 11 substantially underestimate the dose. We don't feel 12 like we are. So, what it's talking about in the SER 13 is we didn't apply terrain adjustment factors to all 14the receptors on the 50 mile dose. We did apply them 15 to all within about five miles.
16 MEMBER SKILLMAN: Thank you.
17MEMBER RYAN: What case did you assume to 18say that you had the worst case? What meteorological 19condition did you assume to say you are now in the 20 worst case?
21MR. BRYAN: We looked at the 22meteorological, I mean we looked at the hourly 23 meteorology for 20 years and so --
24MEMBER RYAN: But you said it was the 25 58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433worst case so in 20 years the meteorology changes 1 quite a bit.
2 MR. BRYAN: Right.
3MEMBER RYAN: Fumigation is the worst 4 case.5MR. BRYAN: Well, what I meant was when 6you went in and you calculated the chi over Q's using 7our straight line trajectory code. So for each 8 receptor I get a chi over Q.
9 MEMBER RYAN: Yes.
10MR. BRYAN: I went and did that again with 11a variable trajectory code. All right, so now I've 12got two sets of chi over Q's. If the variable 13trajectory one was higher we'd pick that value for 14 this receptor.
15 MEMBER RYAN: Okay.
16MR. BRYAN: For this other receptor --
17 whichever one was higher was the one we used.
18MEMBER RYAN: That's not the worst case 19 analysis but that I accept.
20 MEMBER SIEBER: No, it's not.
21MEMBER RYAN: I understand what you did 22 now, but that's most assuredly not the worst case.
23 MR. BRYAN: I understand, not the worst, 24worst case. We took the, of those two values we took 25 59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 the more conservative one.
1MEMBER RYAN: You took the higher which is 2 conservative. Did you do uncertainty analyses on 3 those calculations?
4 MR. BRYAN: No.
5MEMBER RYAN: No, so you really don't have 6much insight into that uncertainty or precision. I'm 7not arguing what you did, I'm just trying to make sure 8 I understand the characterization of it.
9 MR. BRYAN: Okay.
10 MEMBER RYAN: All right, thanks.
11 MEMBER SKILLMAN: Thank you.
12 MR. BRYAN: For Unit 1 we used the RM 50 13addendum to Appendix I which allows you to set limits 14based on the site. With two-unit operation we went to 15 the basic Appendix I which puts the limits on a per-16unit basis. The one addition that you have to do for 17 Appendix I is you have to do a cost/benefit analysis 18which we did. It showed that there were no 19enhancements required. And then I think probably the 20 best thing of all is we've got 15 years of operational 21data on Unit 1 and it shows that we're a very small 22fraction of -- what we actually put out is actually a 23very small fraction of what even the FSAR releases 24 are.25 60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER RYAN: I appreciate what you said 1and reading through that it struck me that you really 2 have no insight into uncertainty. What you actually 3have are a range of values. You did bounding analysis 4kind of calculations and you were still under, you 5know, the limits that were set. So I'm trying to 6understand how you gain insight into variability or 7 margin in those kind of calculations.
8MR. BRYAN: Well, I think the most, you 9 know, if you want to go look where a conservatism is 10 and things you go and you look at the -- I mean, you 11start with the source term. And the source term would 12be equivalent to about 50 to 60 fuel pins leaking.
13That's a very, very large number. So, and I think 14 when you go in and you look at what your FSAR releases 15are compared to your actual releases that really is 16the basis for most of the differences in them. And so 17that, I think there's, I guess we feel like there's 18more than sufficient conservatism there to bound other 19 uncertainties.
20 I mean, we do, as I say we do look at all 21the meteorological data and we, for these releases we 22 basically look at averages of the things. When you 23 get over to the accident releases you're picking the 24things that are in the, you know, 5 percent, top 5 25 61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 percent area.
1MEMBER RYAN: Okay, I'll think about that.
2I guess what I'm struggling with is trying to 3 understand your insight into what things could go 4 wrong that could mean a bigger difference than other 5things that could go wrong in those releases. I mean, 6if they're all low, okay? But which one's more 7 important. They probably have relative importance in 8terms of if something did go wrong which one 9 contributed more.
10MR. BRYAN: I mean, activity in the 11reactor coolant's most important. Then what your 12 primary to secondary leakages is another key driver.
13Beyond that it's, I think everything else is at a 14 lower level.
15 MEMBER RYAN: Thanks.
16MEMBER SIEBER: What's the topography 17around the plant look like? Is it flat or hilly or 18 mountains?
19MR. BRYAN: It's a hilly river valley. I 20mean, the site, there's some local hills very close to 21the site. The Cumberland Plateau runs north, 22essentially north-south 5 to 10 miles to the west and 23 off to the east probably about 40 miles you have the 24 Appalachians.
25 62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER SIEBER: Okay. And so do you have 1 occasional or frequent inversions?
2MR. BRYAN: There are, at places in the 3 Valley you do have substantial inversions.
4 MEMBER SIEBER: Traps.
5MR. BRYAN: Chattanooga in particular was 6noteworthy for that. What I think we've seen, as you 7look at the, now about 40 years of meteorological data 8 for the site what we have tended to see is that 9overall wind speeds are lower now than they were maybe 10back in the '70s. We don't have quite as many periods 11 of calm now as we had maybe in the '70s.
12 MEMBER SIEBER: Have you ever considered 13using particle cell type codes for dispersion as 14 opposed to gaseous distribution?
15MR. BRYAN: There's a yes and no to that.
16Our meteorological people who do the basic studies for 17the valley do use the more advanced codes for their 18 studies. For us at the sites because we've got the 19 features built into this one that we need we haven't 20 made the decision.
21MEMBER SIEBER: Well, for emergency 22planning you need realtime data so whatever processing 23 system you use to connect to your met tower plus 24whatever other inputs you might have, it depends on 25 63 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433what the software does with that data to determine 1where the radiation levels are high, where they're low 2and so forth. Usually in hilly country where you have 3a lot of inversions, radiation doses in the valleys 4are higher than they are on the hilltops. That can be 5 quite pronounced.
6MR. BRYAN: And we, that's -- we also 7 have, we have field teams that go out and monitor.
8MEMBER SIEBER: Yes, yes. That takes time 9 to get them out there.
10 MR. BRYAN: It does.
11 MEMBER SIEBER: Yes. Thanks.
12MR. BRYAN: Last slide. There were, 13through SSER 24 we had seven open items. Six of those 14were basically items where we needed to incorporate 15 information into the FSAR that we had previously 16 submitted. The other one was to perform the 17cost/benefit study. Of these seven we have one that's 18 currently open.
19CHAIR RAY: Of the seven what did you say?
20 MR. BRYAN: We have, we've performed the 21cost/benefit study and we've updated the FSAR for six 22 of them so we have one that we still need to provide, 23 including with the FSAR.
24 CHAIR RAY: Okay.
25 64 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. BRYAN: That completes this part of 1 the presentation.
2 CHAIR RAY: All right. I believe you're 3 going to also do the next one.
4MR. KOONTZ: Well, I've got -- this is 5 Frank Koontz.
6 MR. BRYAN: We can move ahead and go to 7 dose consequences.
8CHAIR RAY: You want to go to dose and 9then come back? That's fine. What's on the agenda is 10 radiological consequences of accidents.
11MR. BRYAN: Okay. For the accident dose, 12for all of the accidents the dose consequences are of 13 course less than 10 CFR Part 100 and also for those 14where you're supposed to be substantially below the 15Part 100 limits we meet those. The next bullet shows 16basically the regulatory criteria that we were meeting 17for each of the different accidents that we evaluated 18 for dose. If you want to flip to the next slide.
19Things that were different from Unit 1.
20 For the accident analysis we updated the meteorology 21to get the chi over Q's based on a 20-year period from 22 1991 to 2010. Unit 2 has the original steam 23 generators in them which have a slightly smaller 24primary and secondary volume than the replacement 25 65 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433steam generators at Unit 1 so we've accounted for 1 that. We don't have tritium-producing rods in Unit 2.
2The dose equivalent iodine for these analyses was 3reduced to the tech spec limit and then we revised our 4fuel handling accident for the accident in the 5auxiliary building to use alternate source terms. The 6one for the containment, with the containment isolated 7still uses the Reg Guide 1.25 analysis. The fuel 8 handling accident for -- in the containment with the 9 equipment hatch open is bounded by the action in the 10spent fuel pool and so that analysis covers the 11 containment open case 2.
12CHAIR RAY: That's the containment open to 13 the auxiliary building, right?
14 MR. BRYAN: Yes.
15 CHAIR RAY: Not to the exterior. What's 16 the reason for that assumption? I couldn't find why 17you need to know more about how you operate I guess to 18 understand why you wouldn't assume open to the 19 outside, the door opened to the outside.
20MR. BRYAN: Because once you get the head 21 removed and you're flooded up you open the equipment 22hatch so you have ready access to the containment for 23 maintenance work and other outage activities.
24CHAIR RAY: Well, maybe I'm asking the 25 66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433question unclearly. Why is it not assumed that the 1door to the exterior rather than to the auxiliary 2 building is open?
3MR. BRYAN: It doesn't have a door to the 4 auxiliary building.
5CHAIR RAY: Well, or -- but the auxiliary 6 building is open to the outside. I'm just trying to 7 recall what I read in the analysis which is that the 8door is open to the auxiliary building, not to the 9 outside.10MR. BRYAN: That's true. The equipment 11hatch goes to the auxiliary building. It does not go 12to the outside and the auxiliary building is kept 13 closed from the outside.
14CHAIR RAY: I misunderstood the comment 15then I guess. It made it sound like to me that there 16was an assumption being made about there not being an 17 opening that could have existed but doesn't, and 18 you're just saying there isn't any such possibility.
19MR. BRYAN: There isn't such possibility, 20 no.21 CHAIR RAY: All right. I misunderstood.
22 MR. BRYAN: Okay. The other things that 23were slightly different from Unit 1, a lot of even the 24 emergency ventilation systems are shared between the 25 67 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433two units. So typically even for events in Unit 2 1releases could come off of the Unit 1 shield building 2 stack and that tends to be for, for LOCA as an example 3that's still the limiting event. For events that have 4releases off of the secondary side that go out through 5our valve vault, steam line rate, tube rupture and 6 loss of AC. The path from the Unit 2 valve vault to 7 one of the control building intakes tends to be the 8limiting path. So for Unit 2 they were analyzed on 9 the basis of that.
10MEMBER SKILLMAN: May I ask you to back up 11to slide 31, please? The bases for these analyses.
12 These reg guides have in their lifetime gone through 13various revisions and upgrades. May I ask you to 14 please comment on whether or not you have used a new 15or different version of a reg guide so that your 16analyses for Unit 2 are successful where they would 17not have been had you used the previous version of the 18reg guide? I'm just asking if you're cherry-picking.
19 MR. BRYAN: No. The only place that was 20for the fuel handling accident we changed some damper 21timing, damper closure timing and that would have 22applied to Unit 1 also. And using the alternate 23source term was advantageous for that but relative to 24 the older reg guide analysis.
25 68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER SKILLMAN: Because I read it, your 1 real conservatism for your fuel handling accident is 2 the 23 feet of water over the drop assembly. That's 3 what really gives you the lower amount that is 4 released because so much is removed by the column of 5 23 feet of water.
6MR. BRYAN: Right and that's what the 7 alternate source term lets you take advantage of.
8MEMBER SKILLMAN: Is that the same for 9 Unit 1? 10 MR. BRYAN: For Unit 1 they are running, 11 currently they were using that as an engineering 12evaluation of their damper condition. They are in the 13process of submitting the license amendment request to 14change their analysis basis to the alternate source 15 term for fuel handling accidents also.
16 MEMBER SKILLMAN: Thank you.
17MR. BRYAN: If there are no more questions 18 I'll turn it over to Frank Koontz.
19CHAIR RAY: Okay. We're a little ahead of 20 schedule so we can go ahead and I think do this next 21 piece and then we'll take a break.
22MR. KOONTZ: Okay. This is Frank Koontz.
23 I believe some of this information on Chapter 15 may 24have been covered at the last meeting. I wasn't at 25 69 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the meeting. I was actually in Hawaii so I was going 1 to say I missed the last meeting but I didn't.
2 (Laughter) 3 MEMBER STETKAR: You were absent.
4MR. KOONTZ: I was absent from the last 5 meeting. One of the things that we wanted to make a 6point of here is that the Unit 2 analyses that we did 7for Chapter 15 were generally similar to the ones that 8we had done for Unit 1 at the operating license for 9Unit 1. Some of the similarities is that we have the 10original steam generators in Unit 2, that's the model 11D-3 Westinghouse steam generators. Since the original 12license on Unit 1 they have upgraded the steam 13generators and they have gone to a new model 68AXP but 14 we still have the original ones.
15We do not have credit for a measurement 16uncertainty recapture. That's a leading edge flow 17 meter. We do have that hardware installed but we're 18not asking for that under our initial license. That's 19 similar to what Unit 1 had at their original license 20is they did not have LEFM installed at that time so 21our startup power is 3411 megawatts thermal NSSS, our 22 reactor power. So those two are very similar to the 23 original license.
24 Some of the things we did update and some 25 70 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433of the differences is what I'm going to talk about 1 next. The first thing we did is we re-baselined the 2large-break LOCA and the small-break LOCA. We decided 3 that we wanted to get away from the old BART/BASH 4methodology on large-break LOCA. We had gone to a 5best estimate analysis with Westinghouse on Unit 1.
6We wanted to do that best estimate analysis on Unit 2 7 and so we updated it with the ASTRUM methodology and 8that's what we've got for Unit 2. We did see a 9 difference in the peak clad temperatures. For 10example, the Unit 2 95th percentile peak clad 11temperature under ASTRUM is 1552 so that gives us a 12 large margin to the 2200 degrees.
13We understand there is an Information 14Notice the NRC sent out with respect to PAD, their 15fuel thermal performance model and how that might 16affect ASTRUM but we do have a large margin there.
17And I don't know if we mentioned PAD but we're working 18with both Westinghouse and the Owners Group to see 19 what we need to do to update that PAD code to put in 20the variable thermal conductivity as a function of 21 burn-up, but that'll take awhile.
22The benefit we've got there, the positive 23that we've got is that the thermal conductivity effect 24doesn't kick in for awhile as far as burn-up and so we 25 71 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 are in pretty good shape for at least the first cycle 1for Watts Bar Unit 2. But that would not be an impact 2to us and the NRC staff is looking at possibly a 3license condition on Watts Bar Unit 2 to resolve that 4 issue before we get in the first refueling.
5 For the small-break LOCA we re-baselined 6 that. We used the NOTRUMP code similar to what we use 7on Unit 1 and similarly there we've got a pretty large 8 margin. Unit 2 came out around 1184 degrees 9 Fahrenheit for the PCT for Unit 2.
10 Some of the other things we did in Chapter 1115 is we had several new analyses. The next slide 12 there, Gordon. One of the things the staff asked us 13 to look at was overpressure protection on the second 14 trip. Our Westinghouse analysis had looked at a 15 turbine trip event as causing a peak overpressure on 16the system and but it credited the first safety grade 17 trip. It was on the pressurizer. And the staff said 18well, the Standard Review Plan really says look at the 19failure of the first trip and model it as if it 20tripped on the second trip. So we went back and we 21re-analyzed that for the staff. We did get acceptable 22 results. It didn't make a large difference. For 23example, the limit is 2750 psia, that's 110 percent of 24the design pressure. The original trip came in at 25 72 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 2691 psia and when we went to the second trip it came 1in at 27, around 2715 psia. So we still have a 2 margin, that limit of 2750. So the staff accepted 3 that and they may talk about that this afternoon.
4 They also asked that we look at a CVCS 5malfunction event. We had not looked at that for Unit 6 1. What we did look at was an inadvertent SI and we 7 had made the case that that was bounding to the CVCS 8 malfunction. The difference in those two events is 9for an inadvertent SI you get an immediate reactor 10trip on the safety injection. For a CVCS malfunction 11it may be something like a charging pump control 12failure of some type, that the charging starts to 13over-charge and perhaps the letdown isolates and then 14 you're filling up the pressurizer. And the question 15on that event is whether it will fill the pressurizer 16and actually relieve water through the PORVs on the 17pressurizer and whether the PORVs are qualified for 18 water relief.
19So we had Westinghouse go back and analyze 20several cases on CVCS malfunction. We were able to 21 show that we did not get to a point where we had water 22relief through the PORVs, that the operators could 23 terminate that event in a timely fashion.
24 MEMBER ABDEL-KHALIK: In which mode?
25 73 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. KOONTZ: This is in power mode, mode 1 1.2MEMBER ABDEL-KHALIK: Have you analyzed 3 that during modes 4, 5 and 6?
4 MR. KOONTZ: No. We haven't looked. We 5 believe that the power mode is bounding. We do have 6the staff here from Westinghouse that did the 7 analysis. Ryan, would you like to comment? Would 8there be any differences in the lower modes? Or Alan, 9or Chris, either one of you three guys, that you 10 believe would be more limiting.
11MR. MCHUGH: This is Chris McHugh from 12 Westinghouse. Thermal remotes are not typically a 13problem because it's conservative less decay heat. If 14you turn decay heat off at mode 1 it takes forever to 15 fill. It's really a combination of the SI and the 16decay heat cause the thermal expansion. So there's a 17 lot more time in lower modes than there is in mode 1.
18MEMBER ABDEL-KHALIK: We heard a different 19story for another licensing action so you may want to 20 consider.21MR. KOONTZ: And that's for the CVCS 22 malfunction? Because I know we also get into the 23 lower modes in the boron dilution event also.
24 MEMBER ABDEL-KHALIK: Right.
25 74 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER STETKAR: Do you want, when you 1shut down on Unit 1 do you basically fill the 2pressurizer solid? How do you do gas on Unit 1? I 3 don't know how plants do it.
4MR. KOONTZ: The question is how do we go 5 through the shutdown process.
6MEMBER STETKAR: When you're coming down, 7 when you do degassing and you're coming down, do you 8 cycle pressurizer level essentially full?
9MR. WALLACE: Yes, sir. We will carry the 10pressurizer solid. We'll continue to run solid all 11 the way through de-gas and cleanup.
12MEMBER STETKAR: Decay heat is still 13pretty high at that time because that's typically the 14first day or two. Okay, thanks. There's a 15 vulnerability, for example.
16MR. KOONTZ: Yes. Well, we do have 17protection systems there for coms and you know, safety 18valves to protect the system if there was water solid.
19MEMBER STETKAR: Are your PORVs qualified 20 for water relief or not?
21MR. KOONTZ: Well, not through a 22regulatory process. I mean, the PORVs are the target 23rock models. They were successful in some of the EPRI 24valve testing as far as water relief so I think the 25 75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433case could be made that they would qualify. And we 1did look at the civil analysis on the tailpipes and 2the tailpipes will withstand the water relief load.
3 We haven't made that case at the NRC so I'd say in a 4 licensing space we're not qualified.
5MEMBER STETKAR: But they're the target 6 rock.7MR. KOONTZ: They're the target rocks, 8 yes. 9MEMBER SIEBER: Do you have loop seals on 10 the discharge side?
11MR. KOONTZ: Not on the PORVs. On the 12 safety valves we used to have the loop seals on the 13safety valves but we drained the loop seals and put in 14 the associated trim for the safety valves. We found 15that the slug loads from clearing the loop seals on 16 the safety valves were just too high.
17 MEMBER SIEBER: You have to do a lot.
18MR. KOONTZ: So even on Unit 1 a long time 19ago we learned that lesson and drained the loop seals 20 out. And that's one of the things we're trying to 21 show to the staff is that we didn't get water relief 22which would challenge either the PORVs or the 23 safety's. The safety's in the EPRI valve test had a 24little harder time passing water. They tend to 25 76 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 chatter and then gall and stick, and then you have a 1potential of moving to a more severe event like a 2small-break LOCA. So that was the goal of the 3analyses was to show that we wouldn't challenge the 4 PORVs or the safety's.
5 One of the other analyses that the staff 6was interested in was the core response to the main 7steam line break. And the principle problem was a 8 couple of things. They were a little bit concerned 9comparing Unit 2 to Unit 1 that we had a better return 10 to power, in other words a lower value. They didn't 11understand that, compared to both Unit 1 and other 12plants that they had seen. So one of the things we 13 did to --14MEMBER ABDEL-KHALIK: In terms of what, 15 your NTC?16MR. KOONTZ: In terms of the peak heat 17 flux, return to power.
18MEMBER ABDEL-KHALIK: Because you have 19 different core design?
20MR. KOONTZ: Well, it wasn't so much 21different core designs as it was different 22 conservatisms in the reactivity coefficients that we 23had used in the analyses. That was one thing. And we 24were able to deconstruct for them the results going 25 77 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 from Unit 2 all the way back to Unit 1 showing as we 1 changed each of the parameters back how it went from 2the Unit 2 results all the way back to the Unit 1 3results so they could see, you know, what the changes 4 did and how those affected the results. And what we 5ended up doing was re-running the main steam line 6break core response using consistent reactivity 7parameters, in other words, same amounts of 8conservatisms in both analyses and the staff was able 9 to see then that they had the right relationship 10between the loss of offsite power cases and the power 11available cases, and then also how that compared to 12Unit 1 including the shutdown margins that we had 13committed to on Unit 1 in the analysis versus the Unit 142 analysis. So they became satisfied that the main 15steam line break indeed was responding as they thought 16it should. And a lot of it was due to this 17conservatism that was held up in some of the 18 reactivity coefficients.
19MEMBER ABDEL-KHALIK: What is your tech 20 spec limit on the NTC at end of cycle?
21MR. KOONTZ: Well, we're -- Tom? I think 22 it's zero. We do not allow it to go positive.
23 MEMBER ABDEL-KHALIK: End of cycle.
24 MR. KOONTZ: Oh, the end of cycle.
25 78 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER ABDEL-KHALIK: Hopefully is a big 1 negative number.
2MR. KOONTZ: I don't know. Do you know 3 the tech spec, Pat? You, Chris, or Tom?
4MR. WALLACE: No, not off the top of my 5 head I don't.
6 MR. KOONTZ: We can find that out if you 7 want to know what it is.
8 MEMBER ABDEL-KHALIK: Okay.
9MR. KOONTZ: Some additional analyses that 10we did. We did re-look at the inadvertent ECCS 11 analysis. As I mentioned earlier we had looked at it 12on Unit 1 from the perspective of not challenging the 13 safety valves. We were worried about the Crosby 6M6 14safety valves. Like I mentioned they did perform 15 poorly in some of the EPRI tests as far as water 16 relief. So what we did in our original safety 17analysis is we assumed the PORVs were blocked and then 18 that would maximize the challenge to the safety. In 19 other words, we didn't credit any relief through the 20 PORVs. We made it look to see if it would challenge 21 the safety's, relieve water through the safety's.
22That's a good safety analysis. The staff 23didn't accept that though. They had issued a RIS 24 2005-29 and the RIS was actually oriented towards if 25 79 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 you did credit the PORVs then you need to show they're 1qualified and they can relieve water and whatnot to 2protect your safety's. Well, we hadn't done that but 3they asked the question what if the PORVs got 4 challenged. Then how would you handle that? So we 5 went back and we re-analyzed the event and were able 6to show that even if the PORVs were allowed to open 7that we didn't challenge the PORVs, that they would 8not pass water and that the peak reactor, or peak 9pressurizer level remained below the top of the 10 pressurizer. So we got acceptable results. They 11would not challenge the PORVs or the safety's.
12 Neither one would pass water.
13MEMBER STETKAR: That's based on a timing 14 analysis for operators?
15MR. KOONTZ: It's based on timing, it's 16 based on 10-minute operator action time and time for 17the operators to respond to the event. Any other 18 questions on that?
19 CHAIR RAY: Said, did you want to make a 20more definite request with regard to the CVCS and 21 other modes?
22MEMBER ABDEL-KHALIK: I would like to see 23 that.24 CHAIR RAY: Okay.
25 80 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. KOONTZ: Okay, so CVCS malfunction and 1 shutdown events.
2 MEMBER ABDEL-KHALIK: Right.
3 MR. KOONTZ: Shutdown modes. Okay.
4MEMBER STETKAR: Yes, I mean, you know, we 5worry primarily is going down when the system is still 6tight and the level is high. You know, and there are 7a couple of time windows in there that you're 8vulnerable to those types of malfunctions. You know, 9 pressurizer.
10 MR. KOONTZ: Pressurizer, yes.
11 MEMBER STETKAR: Overfill --
12MR. KOONTZ: Overfill in the pressurizer.
13 MEMBER STETKAR: -- malfunctions.
14MR. KOONTZ: One of the other analyses the 15 staff was interested in was boron precipitation. We 16have the same tech spec requirements for our boron 17that we have on Unit 1. Unit 1's are based 18principally on the fact that they have the tritium-19producing burnable absorber rod so they have to 20maintain a higher boron concentration in the 21accumulators in the RWST to offset lithium that's lost 22during a large-break LOCA. To lower operator 23 confusion we decided to keep the same tech specs for 24Unit 2 and what that does, it results in a time-to-25 81 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433hotleg recirc around three hours as what we use for 1both Unit 1 and Unit 2. So the staff wanted to 2reassure themselves that that was a conservative time.
3So we had performed calculations to show it was in the 4 order of five hours is when you'd really need to go to 5 hotleg recirc and we gave the staff enough data that 6they could independently do their own confirmatory 7 analysis. And they may talk about that this 8 afternoon. But they also came up with acceptable 9results so the three hours was considered a good time 10 frame.11 One of the open items that we have on the 12Chapter 15 transient analysis is the boron dilution 13and at the last meeting we indicated that we had just 14 started looking at that. This was boron dilution in 15modes 3, 4 and 5. We had the analysis in the FSAR for 16modes 1, 2 and then the refueling shutdown mode 6. So 17we went back to do explicit analysis on modes 3, 4 and 18 5, and one of the things we did first was that we went 19 over to the simulator and ran some tests. Bob and I 20both went over there and observed some of the 21indications that came in that would alert the 22 operators that they had a boron dilution going on in 23modes 3, 4 and 5. Then we went off and did the 24Westinghouse safety analysis because it's a more 25 82 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433conservative model to see what kind of timing would 1 result for operator action. And the goal in these 2studies is to show that the operators have at least 15 3minutes to respond from the time they get the alarm or 4indication that there's a dilution event going on 5 until they can go out and secure the system so that it 6 doesn't go re-critical.
7That analysis is just now getting to 8 completion. Chris McHugh has been working on that at 9 Westinghouse. We haven't submitted the results to the 10NRC yet so this is preliminary information but we did 11get acceptable results in mode 3 that the time from 12alarm to re-criticality ranged from, depending on 13which case we were running 36 to 97 minutes. So there 14was quite a bit of time for the operators. In mode 4 15 it ran from 36 to 58 and in mode 5 we had cases 16running from 22 to 29 minutes. Of course that's 17subject to staff review and they'll look at the 18conservatism we had in the models and see if they 19concur with us on those. And we'll probably submit 20those perhaps by the end of the year we can get it 21 through checking and review.
22 And that's really the most controversial 23things I guess out of the staff reviews on Chapter 15.
24 Most of the other analyses that they looked at were 25 83 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433pretty similar to Unit 1 and although we had a lot of 1 RAI questions on each event these were the ones that 2 they concentrated on. That's the only thing I have.
3MEMBER ABDEL-KHALIK: What is your peak 4 pressure for the loss of feedwater ATWS?
5 MR. KOONTZ: Ryan do you know, or Chris?
6We can look it up. I don't remember what it is off 7 the top of my head.
8CHAIR RAY: Okay. Because Said you're not 9 able -- we have two meetings running today and Said 10won't be with us this afternoon. Would you like us to 11try after the break to bring forward the staff 12discussion comparable to this Chapter 15 discussion 13 we've had here?
14MEMBER ABDEL-KHALIK: That would be good.
15 CHAIR RAY: Pat, can you do that?
16 MR. MILANO: Yes, our transient analysis 17reviewer, we've called him and he should be on his way 18 over here now.
19CHAIR RAY: All right, because we're 20supposed to hear from the region but because of Said's 21 having to attend two meetings today I think it would 22be helpful to the subcommittee if we could have the 23staff do their review comparable to what Frank has 24 done after the break. Okay? Anything else?
25 84 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER ABDEL-KHALIK: If that's okay with 1the person from the region. He may have travel 2 scheduled.
3 CHAIR RAY: Well, yes, I was hoping that 4I could assume that but I shouldn't. Thank you. All 5 right. So we'll try and do that. But before we 6 adjourn for the break let's see if there's any other 7 questions for TVA.
8MR. ARENT: We do have one follow-up item.
9This is Gordon Arent. To your earlier question 10 regarding the tech spec limit for in-leakage it's P1 11CFM 51, 51 CFM. And that is tested on an 18-month 12 period.13MEMBER ABDEL-KHALIK: No, the question 14really is whether, given all the work that you're 15doing in the control room, whether that testing 16 frequency is still okay.
17 MR. ARENT: And we'll confirm that. But 18again, it is looked at each time we perform a 19 penetration into that boundary so.
20MEMBER ABDEL-KHALIK: Right. It is a very 21 small number.
22 MR. ARENT: Yes, it is.
23 CHAIR RAY: Yes, I think the issue would 24be has experience shown that it's unlikely that you're 25 85 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433violating that unaware during the work that's ongoing.
1 Okay. If there's nothing else we will take a break 2until 20 minutes to 11, 20 minutes to 11. And then 3 hopefully we can shuffle the agenda here so that the 4 item 11 on the list here which is the transient 5 analysis --
6 MEMBER ABDEL-KHALIK: He's here.
7CHAIR RAY: Okay, good. Then we will 8resume with the staff will come forward with that 9 discussion. And then we'll pick up with the agenda 10 with the region before lunch. We are in recess.
11 (Whereupon, the above-entitled matter went 12off the record at 10:20 a.m. and resumed at 10:41 13 a.m.)14CHAIR RAY: Back on the record. And 15before the staff makes the presentation that we asked 16for before the break TVA has asked to respond to some 17 questions that were left open.
18MR. KOONTZ: Yes, this is Frank Koontz 19 again. We were able to determine some of the 20responses for your questions that we had this morning 21during the break. One of the questions surrounded the 22met tower and its backup capabilities. And what we 23determined there is that the system is configured with 24a 30-minute uninterruptible power source and then 25 86 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433there's a propane-driven 30 kilowatt generator as a 1 backup to that. So that was the met tower.
2 There was a question on the end of cycle 3moderator temperature coefficient. And it's not in 4our technical specification but it's in our core 5operating limits report, and it's listed as -4.5 times 6 10-4 and that's delta-k/k degrees Fahrenheit.
7 And then there was a second question 8similar to that on the ATWS event. And what we do 9there is we follow the generic methodology in WCAP-10 8330. And for the loss of normal feedwater event 11which is the one you mentioned the peak pressure is 122725 psia and for the loss of load turbine trip event 13it's 2780 psia. And we still have the outstanding 14 question on this in modes 3, 4 and 5.
15 MEMBER ABDEL-KHALIK: Thank you.
16 MR. KOONTZ: That's all I have.
17CHAIR RAY: All right, thank you. Now to 18 the staff.
19MR. MILANO: I'll just do a quick 20 introduction. The lead reviewer for the accident 21transient analysis from the Reactor Systems Branch was 22Samuel Miranda and Mr. Miranda will be presenting the 23results of his, or the findings he obtained during the 24 course of his review of Chapter 15.
25 87 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. POOLE: I think, you know, Pat opened 1it up. Frankly, as part of the request we're jumping 2ahead to Sam's portion of the review which was Chapter 3 15, Transient Accident Analysis.
4MR. MIRANDA: Good morning. My name is 5Sam Miranda. We met yesterday. I ended up, the 6Reactor Systems Branch part of the review of the Watts 7Bar license application. And I'll give you a summary 8 of what the major issues were during this review.
9 I'll follow that structure there, review procedures, 10 results. We selected a few aspects of the review that 11presented some challenges to the staff and finally the 12 conclusions.
13We were instructed in this review to refer 14to the Watts Bar Unit 1 analyses. They had been 15 reviewed and approved and basically we were asked to 16 look for any differences that might have occurred 17between the time at Watts Bar Unit 1 and Unit 2. But 18as we got into the review we found that it was more 19 complicated than that and things had come up in that 20intervening time period. And some of our findings it 21turned out would also apply to Unit 1. And we'll see 22 that later on.
23 The analytic methods that were used were 24approved methods for both Units 1 and 2. And we also, 25 88 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433during our review we tried to keep a perspective on 1this plant. Since it is such a dated design we wanted 2to compare it to other plants of a similar design and 3power level. This did result in several rounds of 4RAIs and I have to admit some of the responses we got 5did not really answer our question so we had to do 6several rounds of RAIs and we had to do two audits.
7 The first audit, there were many questions that 8 remained. We had to settle them finally in June in 9 the second audit, two-day audit.
10We have the benefit of a Safety Evaluation 11 Report. We had 22 supplements of the Safety 12 Evaluation Report to look at, and it provided a long 13 history of analyses and reviews dating back to '84 I 14think, or actually earlier than that. And we found 15that the results we have received from Watts Bar Unit 162 were acceptable with sufficient margin. They met 17 the acceptance criteria that applied.
18 We did single out five accident analyses 19 that we had some issues with and we'll go through 20these individually. The first was the overpressure 21protection analysis. In that case the Standard Review 22Plan specifies that the reactor trip that is credited 23in the analysis should be the second safety-grade 24 trip. And the analysis that we received with the 25 89 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 application credited the first reactor trip. The 1 second issue with the CVCS malfunction event, it 2simply wasn't in the licensing basis. It wasn't in 3the FSAR and I pointed out to TVA that this should 4have been submitted way back when Watts Bar Unit 1 5 safety analyses were submitted. It was specified in 6the Reg Guide 1.70, the standard format for --
7standard format and content for the safety analyses 8 reports. It's listed as one of two mass emission 9events in Table 15-1. And eventually we received that 10 analysis. We had an issue with the inadvertent ECCS 11actuation of power and that's a long story which we'll 12 get into in further slides.
13We asked for a boron dilution analysis in 14modes 3, 4 and 5. TVA had submitted analyses in modes 151, 2 and 6. And the steam line break had a number of 16 issues that we'll describe later.
17So as I said we were looking for an 18 analysis in which the second reactor trip signal was 19 credited. We didn't get that. We got a copy of the 20overpressure report, certified overpressure report and 21in that report it said that the first reactor trip 22signal was credited. TVA was trying to argue that the 23first reactor trip signal was the trip signal that is 24received from the turbine hall and that was not 25 90 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433accepted by the staff. The trip coming from the 1turbine hall is not considered qualified since it's 2coming from a non-seismically qualified source. So 3we're looking for the second reactor trip signal from 4the reactor protection system. Usually the first 5 signal is the high-pressure followed by an over-6temperature delta t. When that signal occurs we 7assume the reactor is tripped and the peak reactor 8coolant system pressure that is attained during the 9 analysis which is a loss of load analysis is the 10limiting pressurization transient. And that is 11verified to be less than 110 percent of reactor 12coolant system design pressure. In TVA's case it went 13up from something like 2694 psi in the previous 14analysis to the 2714 psi, still below the 110 percent 15 of design pressure which is something like 2750 psi.
16 As I said before the CVCS malfunction is 17 missing. We asked for it. TVA had argued that this 18event was bounded by the inadvertent SI actuation 19event and our response, the staff's response was yes, 20the flow rate is lower for this case. It's usually 21less severe than the inadvertent SI actuation event 22but it's a different transient, different things 23happen and it's not exactly an apples to apples 24comparison that we would have to see an analysis. And 25 91 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the analysis results indicated that there was adequate 1time for manual mitigation. It was 10 minutes or more 2 available for shutting off the charging flow, and it 3was bounded by the SI actuation event although it's 4not necessarily true that the inadvertent SI actuation 5 event would always bound this case.
6MEMBER STETKAR: Sam, a couple of 7questions on that to look at. Is there a requirement 8for the applicant to perform a feasibility analysis 9 for that nominal 10-minute time window or is it just 10presumed that people are always 100.00000 percent 11successful because they have nominally 10.0000 minutes 12to mitigate this event regardless of its cost? For 13example, if local operator actions are required out of 14the plant to turn the pumps off. So, the basic 15question is is there a requirement to perform what, 16 you know, we typically call a feasibility assessment 17 that indeed those actions can be performed within 10 18 minutes.19 MR. MIRANDA: We have been, we have been 20presuming that 10 minutes is sufficient time for 21operator action. And the practice has been that if 10 22 minutes is shown by analysis to be available then we 23 accept that. If it's less than that then we ask for 24 a verification through simulator exercises.
25 92 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER STETKAR: So 9.9999 minutes you 1need an analysis, 10.0001 minutes the operators are 2 guaranteed success?
3 MR. MIRANDA: That's what it amounts to, 4 yes.5 MEMBER STETKAR: Okay.
6 MR. MIRANDA: Yes.
7MEMBER STETKAR: You weren't here when we 8 were discussing the CVCS malfunction event with TVA.
9The question arose about possible CVCS malfunctions 10during modes other than power operation 3, 4, 5, 6.
11The 10-minute time window here I assume was for a CVCS 12malfunction that is initiated at normal pressurizer 13 level. There are conditions when a plant is shutting 14down, in particular degassing operations where they 15actively fill the pressurizer almost water solid. The 16 CVCS malfunction that occurs during those conditions 17gives the operators, oh, essentially zero time before 18you actually challenge whatever relief capacity you 19have, depending on how they actually do the degassing 20 operations. Have you looked at all, asked TVA about 21those types of malfunction events? Because, you know, 22arguments are that, well, decay heat is much lower.
23It's actually not when you're coming down because they 24typically do the degassing within the first couple of 25 93 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433days of the outage. So decay heat levels still can 1be, you know, not as high as immediate post-scram but 2still interesting. Have you asked TVA about those 3 other malfunctions during non-power conditions?
4MR. MIRANDA: Well, the Reg Guide 1.70 5 specifies that the limiting case should be presented 6 in its safety analysis report, and the limiting case 7 usually is at full power. In this case --
8MEMBER STETKAR: Excuse me. The limiting 9case is usually at full power because nobody's ever 10thought of non-power conditions. That's why the 11limiting case in the regulations is at full power 12because nobody's ever thought of non-power conditions.
13 MR. MIRANDA: We've thought about it.
14MEMBER STETKAR: Okay. That's what I'm 15 challenging.
16MR. MIRANDA: We thought, for example, one 17of the questions we asked was we wanted analyses of 18the boron dilution in modes 3, 4 and 5. Those studies 19had been done in the past looking at different 20accident analyses in the lower modes and the 21 determination had been made that there's less margin 22 available at full power.
23 MEMBER STETKAR: Absolutely.
24MR. MIRANDA: In this case for the CVCS 25 94 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433malfunction we didn't ask for analyses in lower modes.
1Part of that is covered by LTOP and that's considered 2 elsewhere in the FSAR.
3MEMBER STETKAR: The only question though 4 is if there -- you said LTOP but if the valves aren't 5qualified for water relief or if there's a reasonable 6 chance that they might stick open you now have an 7 inventory control problem. So.
8 MR. MIRANDA: Yes.
9 MEMBER STETKAR: You know, LTOP is good, 10 they'll probably open the valves pretty quickly if 11it's in service under those conditions and it probably 12is, but that still doesn't solve the water relief 13 problem through the valves.
14MR. MIRANDA: Well, you can reasonably 15 argue that the valves are qualified for water relief 16 based on the fact that that you are at reduced 17temperature, that you're passing subcooled water 18through those valves. Okay. Because the valve tests, 19 the valve tests are conducted for various transients 20and for various water conditions up to saturation.
21And I think the results show that when you, as you go 22 away from saturation that the valves are --
23 MEMBER STETKAR: Is this for PORVs?
24 MR. MIRANDA: Yes.
25 95 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER STETKAR: I'm not talking about the 1 safety.2MR. MIRANDA: Right, the PORVs. Right.
3 Right. And there are some PORVs that, the ones I can 4think of offhand are target rock valves that are 5 qualified for water relief under any condition based 6 on the test results. So it depends on the plant and 7the conditions and part, some of those lower modes 8 which fall into the LTOP region where you have 9 analyses of relief through those valves, through the 10PORVs either due to mass addition from the charging 11 system or due to a heat addition of some kind.
12MEMBER STETKAR: Yes, most of them I've 13seen look at the heat addition part of it, or mass 14addition, you know, making the argument about the time 15available for somebody to stop the mass addition. But 16there are admittedly short, but there are time windows 17where that available time for operator intervention 18 can be pretty short where you do -- the only thing you 19have mitigating an overpressure transient is basically 20 LTOPs. And then qualification valves then comes into 21 question.22MR. MIRANDA: Right, and those valves for 23LTOP are set to a much lower pressure. And also, when 24you're in the lower mode you also consider what 25 96 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433systems are operating and available. So for example, 1if you're, say if you're in mode 3 or even mode 4 you 2wouldn't have the, wouldn't necessarily have 3pressurizer level control in the sense that, you know, 4you wouldn't have a failure there so what would be 5 your postulated failure would have to be an operator 6 error.7MEMBER STETKAR: Operator error or some 8 sort of electronic or control system malfunction.
9MR. MIRANDA: Yes, and a lot of those 10control systems would not be operational. There's no 11automatic control there, it's just, you know, whatever 12the operators are doing. And you can reasonably argue 13that, you know, an operator making an error would 14 realize it rather quickly and correct it. You know, 15 having his hand on the switch and he says oh, I 16shouldn't have turned that switch. I'll turn it back 17 again.18MEMBER ABDEL-KHALIK: Wouldn't that be the 19case with the boron dilution transient during these 20 modes that you ask them to do?
21MR. MIRANDA: Yes. The boron dilution is 22a plant operation and you start the boron dilution, so 23many gallons in so many minutes and so on. And that, 24the boron dilution is, I believe is usually an 25 97 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 operator error. Yes.
1MEMBER ABDEL-KHALIK: But there your 2 criterion is to give them 15 minutes.
3MR. MIRANDA: Yes, it's 15 minutes in 4 modes 1 through 5 and 30 minutes in mode 6. Yes.
5 MEMBER ABDEL-KHALIK: What I'm trying to 6 say is that your logic is inconsistent.
7MR. MIRANDA: It is. I didn't make it, I 8 just followed -- these are the safety analysis 9conventions that have been adopted over the past 40 10 years. It's 15 minutes for operator action in boron 11dilution, it's 30 minutes for operator action in most 12 events and for the mass addition events it's come to 13pass that 10 minutes is accepted. Anything less than 1410 minutes we demand simulator exercises. I can't 15 support it any further than that.
16CHAIR RAY: Well, we appreciate the candid 17 summary anyway. Thank you.
18MR. MIRANDA: The inadvertent ECCS 19 actuation. The analysis we received -- well, let me 20back up a little bit on this. The inadvertent ECCS 21actuation is an event that is classified as a 22 condition 2 event. It's an anticipated operational 23 occurrence. It happens, it has happened. It's 24happened at Millstone 3, it's happened at Salem. The 25 98 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433pressurizer does fill and the PORVs open. So far a 1 PORV has not failed to open although some PORVs when 2 they receded were leaking.
3The analysis we received from TVA 4consisted of an inadvertent ECCS actuation, the 5maximum safeguards flow, but the PORVs were not 6 assumed to be operational. And the logic there was 7without the PORVs they did an analysis showing that 8the maximum pressurizer pressure achieved during this 9event did not reach the safety valve opening setpoint.
10 And they said well, we've demonstrated that we won't 11open the safety valve. It's important not to open the 12safety valve because the safety valve once opened and 13failed open is not isolatable. The PORVs we don't 14need to worry about because the operator can always 15 close a block valve. That was their logic and --
16MEMBER ABDEL-KHALIK: What is the shutoff 17 head of these pumps?
18MR. MIRANDA: The shutoff head is usually, 19 it's very close to the opening setpoint of the.
20 MEMBER ABDEL-KHALIK: Let me just try to 21ask a specific question. What is the shutoff head of 22 these pumps and what is the flow rate that you would 23 get at the normal operating pressure?
24MR. MIRANDA: I don't know offhand what 25 99 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the flow rate is. The shutoff head of the charging 1pumps is usually around 2,600 psi. The opening 2 setpoint of the safety valves is 2,500 psi.
3MEMBER ABDEL-KHALIK: I understand all 4that, I'm just trying to get a feel for what is the 5flow rate when these pumps are actually actuated at 6 normal operating pressure.
7MR. MIRANDA: We've got that information.
8Let me see if I have it. I don't have the currents 9with me but that information is available. We can go 10 back and get that information.
11 MEMBER ABDEL-KHALIK: Thank you.
12MR. MIRANDA: In fact, it's a question 13that we sometimes ask, you know, give us the flow 14 delivery curve. We have received that.
15 MEMBER ABDEL-KHALIK: So just continue.
16MR. MIRANDA: Okay. So the results of the 17 analysis showed that the peak pressure that was 18achieved was just under the opening of the pressurizer 19 safety valve setpoint, just below that. And we said 20 well, there you are. If we have such an event we're 21not going to open the safety valve. Therefore, we're 22 okay.23MEMBER ABDEL-KHALIK: Now, let me ask you 24a question. If the shutoff head of these pumps is 25 100 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433above the setpoint of the safety valves what 1 terminates the transient?
2MR. MIRANDA: The transient is not 3 terminated.
4MEMBER ABDEL-KHALIK: What limits the peak 5 pressure?6MR. MIRANDA: The peak pressure is 7basically the run-out of the shutoff head of the 8 charging pumps and what you have here is --
9 MEMBER ABDEL-KHALIK: You just said that 10 the shutoff --
11 MR. MIRANDA: I know.
12MEMBER ABDEL-KHALIK: -- head is higher 13 than the --
14MR. MIRANDA: Right, I said that. What we 15have here is we have a pressurizer that's so many feet 16high, the safety valve is on top of the pressurizer 17 and the pressure, there's an elevation head involved 18 here. You have flow coming in from the charging 19 pumps. It's going to be a very small flow at the 20shutoff head, 2,600 psi or something below 2,600. And 21as it goes through the reactor coolant system there 22are pressure drops along the piping and then there is 23 the elevation head to get from the search line up to 24the top of the pressurizer where the safety valves are 25 101 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 located. And that elevation head, the difference in 1the pressurizer pressure compared to the reactor 2coolant system hotleg pressure is usually something 3 like 80 psi.
4MEMBER ABDEL-KHALIK: Are the reactor 5coolant pumps assumed to be tripped during this event?
6 MR. MIRANDA: No. No, they're not.
7Nothing happens during this event. It relies on 8operator action. The operator has to recognize what's 9 going on and following procedures of what -- let me 10revise that. The reactor is tripped at time zero 11 because the safety injection signal also trips the 12 reactor.13 MEMBER ABDEL-KHALIK: Right.
14MR. MIRANDA: And then the operator, then 15nothing else happens. The operator has to follow 16emergency operating procedures to diagnose what's 17happened here and determine that the proper course of 18action is to shut off the safety injection. And he 19 has basically 10 minutes to do that.
20MEMBER ABDEL-KHALIK: So the peak pressure 21 that's -- maybe if the licensee can answer this that 22 would be very helpful. The peak pressure is limited 23to a value below the setpoint of the safety's even 24 though the shutoff head of the pumps is greater than 25 102 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 the setpoint of the safety's because of what?
1MR. MACDONALD: This is Alan Macdonald 2from Westinghouse Transient Analysis. During that 3time period the operator -- credit is taken for 4operator action to terminate the SI. Usually what 5happens is that you terminate SI prior to the 6pressurizer going water solid. However, post you have 7a swell of decay heat which causes the pressurizer to 8 go water solid and that time is just a race to move to 9 decay heat fast enough to make it so that you offset 10 that swell.
11MEMBER ABDEL-KHALIK: But the event is 12 terminated by operator action.
13 MR. MACDONALD: Yes.
14 MEMBER ABDEL-KHALIK: Thank you.
15MR. MIRANDA: As I said, this analysis was 16not accepted by the staff and the reason is that 17 unless a plant is operating with block valves closed 18you wouldn't have a situation like this. And you will 19 open the PORVS, and there will be water passing 20 through the PORVs. And what we were looking for was 21some assurance that these PORVs if they open under 22 water relief they'll recede. We don't have that, we 23don't know that unless they're qualified for water 24 relief. And in most plants they're not. In TVA's 25 103 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 case they're not. So we asked for a new analysis.
1MEMBER STETKAR: I'm sorry, you said in 2 TVA's case they're not qualified for water relief?
3 MR. MIRANDA: Right. There are only six 4plants that have qualified PORVs. Watts Bar is not 5 one of them.
6 MEMBER STETKAR: So during LTOPs if they 7 have water relief they're not qualified?
8MR. MIRANDA: Well, during LTOPs as I said 9it's a different set of conditions. It's lower 10 pressure, lower temperatures.
11 MEMBER STETKAR: Not lower pressure.
12MR. KOONTZ: Maybe I can help on that.
13Frank Koontz. When I mentioned earlier that the PORVs 14were not qualified that's for full pressure power type 15operation conditions. We do credit PORVs. We 16 submitted information to the staff showing that they 17will work under LTOP conditions which is much lower 18 temperatures and pressures.
19MR. MIRANDA: So, we were getting analyses 20 like this, along these lines where the safety valves 21are demonstrated not to open and the PORVs are, the 22 PORVs are set aside as being valves that could be 23 isolated. And we found that to be unacceptable and 24 the reason was that if in the event that the PORV 25 104 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 should open under water relief and should stick open 1 that by itself constitutes a small-break LOCA at the 2top of the pressurizer and that violates the 3acceptance criteria that prohibits a condition 2 event 4 from developing into a condition 3 event. So if the 5operator is closing a block valve he's not mitigating 6an inadvertent SI actuation, a condition 2 event, he's 7mitigating a small-break LOCA, a condition 3 event 8which is evidence that the criterion has been 9 violated.
10 So we wrote a RIS on that in 2005 11basically saying don't send us analyses like this 12 anymore. Show us that you meet the condition 2 13acceptance criteria. And that was in 2005 and TVA 14 submitted an analysis like this in 2008. So we went 15 back to them and asked them for a new analysis. And 16after several rounds of RAIs we did get the new 17analysis and the results showed that there was at 18least 10 minutes available for operator action. So 19 they were acceptable.
20 Boron dilution. We got analyses only in 21modes 1, 2 and 6. We were looking for analyses in all 22 modes. And TVA at first tried to tell us about 23 Generic Letter 85-05. It's a letter written by the 24 staff in 1985 which basically said don't worry about 25 105 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433analyses in modes 3, 4 and 5. We don't consider it a 1 safety risk in the sense that we don't want to be 2backfitting anyone. If you don't have analyses in 3 modes 3, 4 and 5 you don't need to submit them because 4we don't think it's worth it. And that was addressed 5to operating plants. Except Watts Bar units were not 6operating in 1985 so we asked them to do the analyses 7and we haven't gotten them yet. This is an open 8 issue.9But the two things we're looking for in 10all modes, especially in modes 3, 4 and 5 which are 11 the shutdown modes, we want to see that the operator 12has sufficient time to terminate the dilution, 15 13minutes, and that 15-minute time span has to begin 14from some indication, some reliable indication to the 15operator that there is a boron dilution going on. And 16the Westinghouse methodology that we received from 17Watts Bar was a set of analyses in modes 1, 2 and 6 18 where this time span, this time period 15 minutes 19began at the initiation of the event, not at the time 20 of a reliable indication.
21MEMBER ABDEL-KHALIK: Wouldn't the 22assumption that the 15-minute period begins at the 23 initiation of the event be more conservative?
24MR. MIRANDA: The time -- let me see. No, 25 106 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433because if you don't get an indication that would 1alert the operator that something is going on that 2boron dilution could continue until you reach 3 criticality. And that could be anytime. If the 4operator doesn't know that he needs to do something he 5could reach criticality. The operator would never 6 know it until it's too late.
7 MR. MILANO: Is your question, you know, 8the difference between the start time of initiation 9and start time of initiation based on the alarm? And 10I think what Sam, what the difference is is that -- is 11the way the staff is reviewing it it takes into 12 account that there has been a certain period of time 13of dilution that's already occurred prior to the 14alarm, and then the operator has 10 minutes more, you 15know, where dilution could still be taking place until 16he terminates it. So you've got a longer time period 17 where dilution is occurring if you -- and by the way 18 the staff is reviewing it.
19MR. MIRANDA: I think, in other words when 20 the operator finally realizes there is a boron 21 dilution going on there may be no time left, or very 22 little time left.
23MEMBER STETKAR: Depending on where the 24 alarm is set.
25 107 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. MIRANDA: Yes.
1MEMBER ABDEL-KHALIK: And your assumption 2is that it will take the operator a minimum of 15 3minutes to do it because that would be the only way to 4logically say that, assuming that time counting starts 5 from the point of detection is the more conservative 6is if this 15 minutes is an assumption that this is 7the minimum time it would take the operator to do the 8 job.9MR. MIRANDA: That's the way it works out, 10 yes. That's the -- you call it an assumption, it's a 11ground rule. It's 15 minutes we have to have, yes.
12 Right.13MEMBER ABDEL-KHALIK: It is an assumption.
14 MR. MIRANDA: Yes.
15 MEMBER ABDEL-KHALIK: Okay, thank you.
16MR. MIRANDA: The steam line break. We 17 had a lot of discussions concerning this.
18MEMBER SKILLMAN: Would you please discuss 19 what "too good" means in that context, please?
20MR. MIRANDA: Yes, yes, I will do that.
21Steam line break is a condition 4 event and it's 22analyzed with and without offsite power. And the 23results in almost all cases for all plants, 24Westinghouse plants, is that the case with offsite 25 108 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 power will lead to a return to criticality. This is 1 a steam line break occurring on hot zero power. The 2core returns to critical and generates power. And the 3power, the peak power level in a case with offsite 4 power is always, always higher than the case without 5offsite power. And the reason is that without offsite 6power the reactor coolant pumps are tripped. The 7reactor coolant system flow is lower and therefore the 8primary to secondary side heat transfer rate is lower.
9 So the cooldown that is initiated from the secondary 10 side due to the steam break has less of an effect 11because the primary system flow rate is lower so that 12in the case without offsite power the return to 13 critical and the power generation that results would 14 go to a lower level. So for example, a 4-loop plant 15 of the Watts Bar design might return to critical and 16produce, say, I don't know, 15 or 18 percent power 17with offsite power and only about 5 percent without 18 offsite power.
19 The TVA results were reversed. The case 20 without offsite power produced a higher power level, 21 and that was not very high, it was only about 3 to 5 22 percent power. The case with offsite power produced 23 a much lower power levels, less than 2 percent, so I 24questioned that. And the response was that, the case 25 109 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433without offsite power, because the heat transfer rate 1 was not as high it caused a less severe 2depressurization in the reactor coolant system, and 3this depressurization did not extend to the 4accumulator setpoint. So there was no benefit of 5boron coming from the accumulators. Therefore, the 6core reached a higher power level. The case with 7 offsite power produced a great depressurization. It 8caused the accumulators to inject so the core got more 9 boron in that case.
10So the natural question after that was 11well, show me a smaller steam line break case with 12 offsite power, one that is too small to depressurize 13the reactor coolant system to the accumulator 14injection setpoint. I want to see a case without 15offsite power and without the accumulator boron. And 16the answer received was that all sizes will produce 17accumulator -- with power will produce accumulator 18injection which I couldn't believe. And Westinghouse 19 provided some analyses.
20MEMBER ABDEL-KHALIK: Excuse me. All 21sizes including inadvertent openings of secondary side 22 valve?23MR. MIRANDA: All sizes. Even zero. Even 24 zero, yes. So after several rounds of questions the 25 110 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 answer it turned out was that they were always getting 1accumulator injection for the with-power cases because 2of the auxiliary feedwater assumptions they were 3 using. They were using very, very conservative flow 4rates for auxiliary feedwater, very high rates of 5auxiliary feedwater addition so they were cooling down 6the plant just with auxiliary feedwater. So a zero 7 break size would cause accumulator injection.
8MEMBER STETKAR: Does that mean every 9 plant trip causes accumulator injection?
10MR. MIRANDA: Well, according to those 11 assumptions, yes. Yes, they were flooding the steam 12 generators with aux feed.
13MEMBER STETKAR: A lot of cold feedwater.
14MR. MIRANDA: Yes, yes. So, we got a new 15 analysis --
16MEMBER ABDEL-KHALIK: But if that's the 17case it wouldn't make any difference whether the 18 power, you have offsite power or you don't.
19MR. MIRANDA: Well, you have the 20offsetting effect of the degraded heat transfer due to 21the lower flow. So you could have more heat being 22 extracted from the secondary side but how that feeds 23 back to the core under reduced flow conditions, it's 24 not obvious. It just, there is -- you're increasing 25 111 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the secondary side heat extraction, but how it 1translates to the core temperatures is not, there's 2not as much of a direct link due to the reduced RCS 3 flow.4 So that was one question I had. Another 5question was they analyzed one state point. The 6procedure for steam line break is to select state 7 points from the transient and feed them through to a 8detailed core model, thermal hydraulic model to 9evaluate the DNB ratio. So they would take the power, 10 temperature, pressure, boron concentration and so on 11at any given point and they would do a transfer of 12state points. And this is basically hundreds of state 13 points but they select one, the one they think is 14 going to be the most severe and they take that, they 15carry that through to a natural DNBR calculation. And 16 that DNBR calculation should result in a DNBR that's 17 greater than the limit which would be 1.3.
18MEMBER ABDEL-KHALIK: So your primary 19 concern was DNB?
20MR. MIRANDA: DNB, yes. The steam line 21 break, it's a condition 4 event but it meets the 22 Westinghouse plants, it meets condition 2 criteria.
23MEMBER ABDEL-KHALIK: So what was the peak 24containment pressure for this ice condenser 25 112 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 containment during a steam line break?
1MR. MIRANDA: That's a different analysis.
2That is done at full power and it's designed to 3produce high temperature. It's a containment pressure 4response analysis where you try to dump as much steam 5into containment as possible. In this case you're 6 trying to maximize the cooldown.
7MEMBER ABDEL-KHALIK: What is the steam 8 generator pressure at hot zero power?
9MR. MIRANDA: At hot zero power the steam 10 generator pressure is at its highest.
11 MEMBER ABDEL-KHALIK: Correct.
12 MR. MIRANDA: And it's about 1,100 psi.
13MEMBER ABDEL-KHALIK: Correct. So if I 14had a steam line break inside containment at hot zero 15power at end of cycle wouldn't that produce the 16 highest containment pressure?
17MR. MIRANDA: No because if you have, you 18have the high pressure and you have the contents of 19 the steam generator which are also pretty high. But 20if you do a case at full power you're generating power 21 so that the steam --
22MEMBER ABDEL-KHALIK: The reactor trips 23very, very quickly. The reactor trips very quickly in 24 that --25 113 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER SIEBER: But you've got the decay 1 heat level circuit.
2MR. MIRANDA: Yes, you have decay heat.
3In the hot zero power case you assume there's no decay 4heat because you want to maximize the cooldown. So 5basically what you're doing for the containment 6 pressure response case, you have the plant initially 7 at full load, it trips, then you have the full decay 8 heat that you need to remove and you're generating 9 steam with that decay heat. And --
10 MEMBER ABDEL-KHALIK: So let me just ask 11the licensee the question. What is the peak 12containment pressure during a steam line break?
13 Whether it is at full power or at hot zero power and 14 in this case it would have to be end of cycle so that 15you can have the highest NTC and the highest decay 16 heat.17 MR. KOONTZ: This is Frank Koontz again.
18 We'd have to check on the peak containment pressure.
19What I can say is that for the containment design what 20we worried about for pressure is the large-break LOCA 21because that's the one that generates the most mass 22energy release to the containment, generates the peak 23 pressure.24MEMBER ABDEL-KHALIK: I understand, but 25 114 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 sometimes they are comparable.
1MR. KOONTZ: Right. For the steam line 2 break it turns out that what that generates is the 3highest temperatures in containment. They're much 4higher temperatures than for the large-break LOCA and 5they peak around 325 degrees to 327 degrees 6 Fahrenheit. And for the steam line break although you 7get a lot of steam out there's not a lot of mass 8associated with that compared to the LOCA where you've 9generated all the primary side leak into containment.
10 The ice does not fully melt out in a steam line break 11as it does in a large-break LOCA. So from the 12perspective of the containment design we don't melt as 13 much ice for the steam line break but we do generate 14higher temperatures in the lower compartment. And for 15 the LOCA we melt all the ice but we don't generate 16quite as high of temperatures in the lower 17 compartment. And what Sam's concerned about is the 18 event he was looking at is the quarter response, the 19 return to power and all those effects that you get 20from over-cooling the water from the steam line break.
21 MEMBER ABDEL-KHALIK: Right.
22 MR. KOONTZ: We can look it up. I mean, 23 I don't remember exactly what the --
24MR. BRYAN: This is Bob Bryan. In the 25 115 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433design your first pressure peak, whether it's a steam 1 line break or a LOCA is pretty much caused by the 2shoving all of the air from the lower compartment into 3the upper compartment. And that gives you about a 4 psi. And so that's just basically a gas law equation.
5So even for moderately small steam line breaks you 6will essentially blow all of the air out of the lower 7 compartment. So basically for all of these breaks 8 except for very, very small ones you're going to see 9 pressures in or about the 8 psi range. And as Frank 10said, since you've got total energy release is so much 11lower in a steam line break compared to LOCA you never 12 melt the ice so that represents the peak pressure.
13MEMBER ABDEL-KHALIK: Could you please 14give us definitive numbers to the peak containment 15 pressure during the event?
16MR. BRYAN: To contrast that the peak 17 pressure for LOCA is around 12.5.
18MEMBER ABDEL-KHALIK: Okay, thank you.
19 Thanks. Now, are these calculations done at the 20 moderator temperature coefficient that they give for 21 a tech spec limit of, I guess I translate your units 22 to -45 PCM per degree?
23MR. MIRANDA: The core response steam 24 break analyses which we were reviewing are conducted 25 116 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433at hot zero power, end of life conditions with the 1most negative NTC. And that's in order to generate 2 the greatest reactivity excursion.
3 MEMBER ABDEL-KHALIK: Okay.
4MR. MIRANDA: So, my first impressions in 5 looking at the steam break analyses were that, first 6of all that this relationship between a steam break 7 with offsite power versus a steam break without 8offsite power seemed to be reversed and that was 9attributed to the effect of the accumulator. And then 10also the magnitude of the return to power seemed to be 11rather low. And Westinghouse explained that that was 12because of their reactivity coefficients they were 13 using. And they had been improving shall we say, 14improving since the time we first saw the Watts Bar 15results back in the '80s until today. So that the --
16in similar plants they're also getting rather low 17 returns to power.
18 And so what we did was during the second 19 audit Westinghouse conducted a series of analyses in 20which they changed one reactivity coefficient at a 21time starting with the Doppler feedback and then going 22to the moderator temperature coefficient and so on 23 until they reproduced the results I had seen earlier 24from the '80s. So that explains the effect of each 25 117 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 coefficient that was in use. And these coefficients 1 that Westinghouse was using were documented and used 2 in other plants of similar design.
3 MEMBER ABDEL-KHALIK: Now, you indicated 4earlier that, you know, you did sort of due diligence 5and found out that they are running the aux feedwater 6 flow at fairly high value and that's the reason 7perhaps for this discrepancy in the result. What was 8the assumed aux feedwater flow and is that within the 9 capability of the aux feedwater pumps?
10MR. MIRANDA: They were, it's 11 conservative. You'd have the cooldown, the maximum 12cooldown so what they were doing was using the maximum 13aux feed flow available, all pumps running and I 14believe they were all going to the faulted steam 15 generator. So it's kind of an unrealistic situation.
16MEMBER ABDEL-KHALIK: So they were 17 assuming runout capacity for all aux feedwater pumps 18 and all of that going to the faulted generator?
19 MR. MIRANDA: That's what I --
20 MEMBER ABDEL-KHALIK: Is that correct?
21 PARTICIPANT: That's correct. It's 2,842.
22 MEMBER ABDEL-KHALIK: Okay.
23MR. MIRANDA: So in effect they were 24creating another accident in aux feed flow-induced 25 118 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 cooldown.1During the course of this review we --
2there was a lot of reliance on the WCAP-9226 which was 3written in 1978 which was written in order to show 4that limiting cases were identified for Reg Guide 1.70 5 which requires limiting cases. So the WCAP-9226 did 6a series of -- reported a series of sensitivity 7studies, steam line breaks of different sizes and 8different assumptions including cases with and without 9offsite power. And they concluded from that WCAP that 10 the largest steam break was also the limiting case.
11But a lot of things have changed since 12 1978 and just to mention a few. In 1978 the flow 13measuring Venturi was located in the steam line and 14therefore it was possible to have a break upstream 15with a steam line which amounted to a 4.5 square foot 16 break. And that was analyzed in WCAP-9226. Today 17Westinghouse plants don't have a flow Venturi steam 18 line. It's located in the steam generator outlet 19 nozzle so it's not possible to have a break upstream 20of that Venturi. And the maximum break that could 21occur in a Westinghouse plant is 1.4 square feet which 22is the area, the 16 inch flow area through the nozzles 23where the flow chokes. So, more than half of the 24 cases analyzed 9226 were no longer applicable, they 25 119 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 were the large-break that doesn't exist anymore.
1MEMBER ABDEL-KHALIK: No, let's go back to 2the sort of unreasonable assumption of too much aux 3feedwater flow. Regardless of whether you have the 4 reactor coolant pumps running or not this assumption 5leads to a much more severe cooldown transient, is 6 that correct?
7MR. MIRANDA: Much more than I would 8 expect under normal conditions, yes.
9MEMBER ABDEL-KHALIK: Correct. So 10regardless of whether one is more severe than the 11other per your expectations you would expect that 12because the assumed transient is more severe in terms 13of the cooldown that if they were to do this correctly 14either, number one, the reactor would not return to 15power or the peak power would actually be less than 16 what they calculated.
17MR. MIRANDA: You mean if they were to 18 reduce the aux feed flow to --
19MEMBER ABDEL-KHALIK: Correct. To make it 20 a less severe cooldown transient.
21 MR. MIRANDA: Yes. Right. They do that 22to produce a conservative analysis. Right. So if 23they were to use a smaller aux feed flow rate I would 24expect a, either a no return to criticality or a 25 120 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 smaller peak power level.
1MEMBER ABDEL-KHALIK: So if that's the 2 case why are you concerned and asking them to repeat 3 the analysis?
4 MR. MIRANDA: I asked them to repeat the 5 analysis to understand how they got the results they 6got because the other side, the other side of that 7question was why is the flow rate, why is the peak 8power level reached so small. It should have been 9much higher, especially with the higher aux feed flow.
10It should have been, I was expecting a peak power 11level in excess of 20 percent and they were showing 12only, I don't know, about 5 percent. So that part of 13it, the analyses they repeated to examine that part 14was due to the reactivity coefficients they were 15 using. They were much improved coefficients compared 16 to the ones they were using in the '80s.
17MEMBER ABDEL-KHALIK: But nevertheless 18 they have agreed to redo the analysis.
19MR. MIRANDA: They did that. They did it 20 during the audit, yes. And because, actually it was 21a series of analyses where they separated out each 22 coefficient to see the effect of it.
23 MEMBER ABDEL-KHALIK: Okay.
24MR. MIRANDA: So I was able to get from 25 121 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 the '80s results to the 2008 results.
1 MEMBER ABDEL-KHALIK: Thank you.
2 CHAIR RAY: You have this all written up 3 somewhere I trust for historical purposes if we wind 4 up having to re-resurrect this from five years?
5MR. MIRANDA: Well, we do have an audit 6 report.7 CHAIR RAY: Yes, okay.
8MR. MIRANDA: Another thing that changed, 9this is historical. Another thing that changed since 10WCAP-9226 was written was the boron injection tank.
11Plants in those days had a boron injection tank in the 12safety injection system containing 20,000 ppm boron 13which was injected into the core and then had a 14 dramatic effect on the reactivity. That's been 15removed and now the concentration of boron in the 16 safety injection water is only about 2,500 ppm.
17So, it doesn't, the reactivity curves 18don't show, you can't tell by looking at the 19reactivity curves exactly when the safety injection 20water enters the core. It used to be that there would 21 be a big drop-off. Now it just levels off.
22 And the end of the steam line break is not 23so much the time at which high concentration boron 24enters the core, it's more related toward when the 25 122 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433steam generator dries out, when the -- basically when 1the cooldown has proceeded to its logical end. And 2then the temperatures begin to level off and the 3reactivity excursion is ended and the core returns to 4 sub-critical.
5So the staff as a result of this 6 particular review, it was the only review by the way 7that I've seen where these results were reversed. And 8it's traced back to the methods used that date to 9 1978. And we are, the staff is reviewing WCAP-9226 10and chances are that it's not going to be accepted any 11longer for referencing in licensing applications 12because it's outdated. And the staff retains the 13right to do that when they approve a method or topical 14 report. When things change the staff can withdraw its 15 approval.16 So as a result of all this all of the 17analyses we've seen with the exception of the boron 18dilution where we're still waiting for results, we've 19 seen -- we're convinced that --
20 MEMBER ABDEL-KHALIK: Sorry, back to the 21 comment you made about withdrawing approval of a 22 licensing topical report. What code was used to do 23 this analysis?
24MR. MIRANDA: The code that was used to do 25 123 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 the Watts Bar analyses was the RETRAN code.
1 MEMBER ABDEL-KHALIK: The RETRAN.
2 MR. MIRANDA: RETRAN.
3 MEMBER ABDEL-KHALIK: LOFTRAN.
4 MR. MIRANDA: Was it LOFTRAN?
5MEMBER ABDEL-KHALIK: LOFTRAN, that's 6 almost 30 years old.
7MR. MIRANDA: That's right, okay. You're 8using LOFTRAN. You usually use RETRAN. For this case 9 you're using LOFTRAN and for the sensitivity studies 10at the audit it was also LOFTRAN. WCAP-9226, the 11studies that were done for that report in 1978 they 12 used the MARVEL code.
13 MEMBER ABDEL-KHALIK: MARVEL.
14 MR. MIRANDA: And that code is no longer 15used, except by Mitsubishi. And you'll find MARVEL 16 studies --
17MEMBER ABDEL-KHALIK: So your withdrawing 18 approval of that particular licensing topical report 19 does not impact the staff's approval of LOFTRAN.
20 MR. MIRANDA: No, no, LOFTRAN is a valid 21code, so is RETRAN. So is MARVEL. It's just the way 22in which they were used for the steam line break 23 analysis.24 MEMBER ABDEL-KHALIK: Okay.
25 124 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. MIRANDA: We found that some of the 1things that came up during the Unit 2 reviews would 2 extend to Unit 1. So that's something that needs to 3be addressed, how Unit 1 is going to deal with the 4effects that were found in Unit 2. And as I said 5before, the steam break analysis methods have to be 6 updated. The methods that Westinghouse is using today 7are not the same methods that were described in WCAP-8 9226. There are some things they no longer do and 9there are other things that they've added that they 10 haven't reported.
11MEMBER SKILLMAN: Does your second bullet 12point to deficiencies in the present analyzed 13 condition of Unit 1?
14MR. MIRANDA: Well, for example, the 15inadvertent SI actuation, both Units 1 and 2 have 16that, well, before the review started they had that 17 analysis that looked at depressurizing safety valves 18 and showing they wouldn't open. Well, the licensing 19 basis as a result of this review for Unit 2 has a new 20analysis and so now we have two different licensing 21bases with two different analyses. And we would 22expect to see a similar change made to Unit 1 and that 23would be also in line with the RIS that was written in 24 2005. That RIS indicated that kind of analysis was 25 125 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433not acceptable and that applications by licensees even 1on unrelated topics would be reviewed with respect to 2the inadvertent SI actuation event and if necessary 3there would have to be a change. That's what the RIS 4 said that would be reviewed.
5 MEMBER SKILLMAN: How is that handled in 6 enforcement space for Unit 1?
7MR. MIRANDA: Well, I don't know. I don't 8consider this to be a safety issue, I think it's a 9 licensing issue. I don't think you're going to have 10 a small-break LOCA tomorrow at one of these plants.
11MEMBER SKILLMAN: Our business here, it 12poses a very interesting question when you take a 13newer unit and apply it to the licensing basis of the 14older unit. And then the analytical activities on the 15newer unit discover what could be a shortfall or an 16 efficiency on the licensing basis of the old unit.
17 MR. MIRANDA: Yes.
18MEMBER SKILLMAN: That seems like even 19though that's not ACRS's purview for Unit 2 that 20certainly raises a flag about what is going to be done 21 on Unit 1.
22MR. MIRANDA: Yes. Another example is 23that Unit 1 does not have the CVCS malfunction in its 24 license. It's not in their FSAR, it needs to be added 25 126 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 to comply with Reg Guide 1.70.
1CHAIR RAY: Well, let's not get into 2what's required to comply with the reg guide. Go 3 ahead.4MR. MIRANDA: Well, that's it. Unless 5 there are any further questions.
6MEMBER STETKAR: Can I ask TVA a question?
7What is your, you refer to it as LTOPs. It's referred 8 to as COMS, the low pressure setpoint on the PORVs.
9I've been searching for it here, I can't find it in 10 the FSAR.11 MR. KOONTZ: You mean where do they arm, 12 the pressure that they harness?
13MEMBER STETKAR: What is the arming 14 pressure, do you know?
15MR. KOONTZ: For Unit 1 it's 350. I think 16 for Unit 2 it can be armed as low as I'm thinking it 17 was 250.18MEMBER STETKAR: Well no, not the arming.
19 What is the actual pressure, the opening pressure 20 setpoint.21MR. KOONTZ: Oh, it's a variable. We'd 22 have to look into it.
23MEMBER STETKAR: Oh, it's variable as 24 opposed to the temperature.
25 127 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. KOONTZ: Yes.
1 MEMBER STETKAR: Okay.
2MR. KOONTZ: It's in the pressure 3 temperature limits report is where it's at.
4 MEMBER STETKAR: Okay.
5 MR. KOONTZ: PTLR they call them.
6MEMBER STETKAR: Yes. We obviously don't 7have that. I was just trying to get a feel for where 8 it's at.9MR. KOONTZ: I was trying to think, it may 10 be in the --
11MEMBER STETKAR: I can't find it in the 12 FSAR. I've been sitting here trying to find it so I 13 don't think it is. Okay, thanks.
14CHAIR RAY: Okay. Well, any other 15comments or questions on the transient analysis 16presentation now that we've heard both from the TVA 17 and the staff? Thank you, Sam. Okay, now --
18MEMBER ABDEL-KHALIK: Thank you for 19 accommodating us.
20CHAIR RAY: Yes, appreciate that. Pat, we 21 can either break for lunch now or we can take the 22 region. I think we would prefer to break unless the 23region needs to go forward in which case we can 24 accommodate that.
25 128 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. MILANO: Bob has already indicated to 1us that he doesn't have a travel restriction that 2 wouldn't prevent us from doing it this afternoon.
3CHAIR RAY: All right. Then we will take 4 a break for lunch and we'll resume at, in accordance 5 with the schedule we'll resume at 1 o'clock.
6 (Whereupon, the above-entitled matter went 7off the record at 11:48 a.m. and resumed at 1:03 p.m.)
8CHAIR RAY: We'll resume session and we'll 9begin with our scheduled report before the lunch break 10 from Region II.
11MR. POOLE: Okay. So the next portion of 12the presentation we'll go turn it over to Bob Haag to 13 go over the status of the Region II construction 14 inspection activities.
15 MR. HAAG: Good afternoon. As mentioned 16before my name is Bob Haag. I'm the branch chief from 17Region II with oversight for Watts Bar 2 construction 18 activities. What I wanted to do was kind of give you 19 the results of some of our recent inspection efforts 20and assessment efforts, then go over kind of the 21 status of where we're at with implementing the 22inspection program. Our level of effort is the amount 23of inspection that we've been performing, kind of 24 where the staff is as far as how many people have been 25 129 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 assigned to the project and inspecting at Watts Bar.
1 And I was also going to spend a bit of time at the end 2of the presentation going over pre-op testing 3 inspections and where we're at in our preparation 4 phase.5 So the first slide deals with the results 6of our inspection program. In previous presentations 7I had described how we were assessing performance for 8Watts Bar 2 construction project, and it's similar to 9the way we're looking at performance and assessing 10performance under the ROP. It's very structured, you 11 know, at each quarter we'll look at performance at a 12 mid-cycle. We look at it in a more formal manner at 13the end of cycle. We also look at it -- we've adopted 14 that policy and that process.
15So our last formal performance assessment 16was the 2011 mid-cycle review. And the overall 17results from that review was that we felt performance 18was at an acceptable level and that TVA's programs, 19processes and implementation were adequate for the 20given level of activities involving safety-related 21 work. 22I wanted to highlight three areas that we 23both discussed during our performance review which is 24an internal NRC review and that we highlighted to TVA 25 130 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433in our assessment results letter. The first area I 1wanted to highlight was a problem that we'd seen with 2implementing, their implementation of corrective 3 action for some historical problems. And these were 4issues that had been identified back in the '80s time 5 frame. Most of them were identified through TVA's 6rating of a condition, a construction deficiency 7report (CDR) and we were following up on those actions 8to make sure that they were properly implemented. And 9what we found were four examples of where TVA thought 10the corrective actions were complete. When we looked 11 and pursued it we identified that corrective actions 12had not been adequate. They resulted in a severity 13level IV violation that we issued. And our concern 14there was based on the number of historical issues 15 that TVA has to fix, again that have been identified 16 during regional construction and some of the more 17 recent construction activities is the fact that they 18need to be diligent in making sure those corrective 19actions are complete. So we've iterated that to them, 20we've discussed that in some public meetings and 21clearly we're following up during our review of other 22 historical --
23MEMBER ABDEL-KHALIK: Can you give us 24examples of significant historical issues that fall in 25 131 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 that category?
1MR. HAAG: Not significant, none of these 2were significant as far as the typical, you know, mind 3 frame of what a significant issue is. The ones that 4 come to mind as far as these four examples, a couple 5of them dealt with welds, inadequate welds that either 6 they needed to go back and assess as far as were the 7welds adequate or they had already identified they 8needed to do some repairs and hadn't done the repairs.
9 None of them, though, I would characterize as far as 10 significant.
11 MEMBER ABDEL-KHALIK: Okay, thank you.
12MR. HAAG: The second area I wanted to 13 highlight was the ongoing saga with the Heinemann 14circuit breakers and the seismic qualification for 15 those breakers. These are the molded case, 120 volt 16 circuit breakers and during a previous inspection we 17had identified a problem with the seismic 18 qualification. These are new breakers, replacement 19breakers that they're using. And what we highlighted 20in our letter was just the length of resolution for 21this and the fact that it hadn't been resolved. It's 22 been going on for almost two years as far as once we 23identified it TVA's initial resolution or initial 24 response to us, the back and forth. Where it stands 25 132 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 right now is we wrote, the region wrote a TIA request 1for information for the technical branch and NRR to 2look into it and they've had a series of public 3meetings where the TVA staff presented to the NRR 4staff their position and where they're at with the 5qualification effort. It's still yet to be resolved.
6The third item I wanted to mention was the 7fact that during this review, the mid-cycle review we 8went and looked at crosscutting aspects. We follow a 9very similar process for our construction inspections 10as we do in the ROP. If we have a finding we'll look 11to see if there are crosscutting aspects and if the 12numbers reach a certain threshold we're questioning 13 whether there is a substantive crosscutting issue.
14During an earlier assessment back in I 15 think this was the end of cycle review for 2010 they 16 had satisfied the criteria in our manual chapter for 17number of similar crosscutting aspects that would give 18you a substantive crosscutting issue. But at that 19time we recognized that two of the four issues were 20 very recent and we had yet to be able to really assess 21 TVA's corrective action. So we delayed deliberation 22to say whether there was a substantive crosscutting 23 issue. We went back and we reviewed that in our 2011 24 mid-cycle review and determined there was not a 25 133 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433substantive crosscutting issue. So that kind of blows 1 the book on that issue.
2MEMBER ABDEL-KHALIK: Because of 3 corrective actions?
4MR. HAAG: Because of the corrective 5actions and the fact that when we had an additional 6six months of review time the numbers actually went 7 down to less than what the threshold would have been 8in manual chapter as far as reaching a certain 9 threshold.
10 The other points I discuss from our mid-11 cycle review is that when we looked over at the period 12of time, and typically you always look back for a 12-13 month period of time, there have been 12 severity 14 level 4 violations identified during that period and 15they had a variety of subjects, design control, 16 corrective action, I mentioned one of the corrective 17action issues, procurement and procedural compliance.
18 I would highlight, you know, there were no escalated 19enforcement or severity level penalties, civil 20penalties and that's one of the criteria in the manual 21chapter as part of our assessment process where if 22there were escalated enforcement or civil penalties we 23 would look at increasing our inspection effort.
24CHAIR RAY: Bob, does this matter of who's 25 134 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 got the keys that you heard discussed earlier today, 1 I think you were here for it.
2 MR. HAAG: Yes.
3CHAIR RAY: Just tell us how that affects 4 you if at all.
5 MR. HAAG: As far as the change recently 6 and how TVA is interacting with their contractor?
7CHAIR RAY: Well, you could express it 8 that way but basically we're looking at a period of 9 time here which has included both modes of operating 10 going way back. I don't know if you were there or 11 not. We talked about how because of the legacy of 12responsibility having shifted to a portion of it at 13 Bechtel and some that is still there that used to be 14with TVA and now part of it, and I'm not trying to 15differentiate here between quality affecting 16activities and management responsibilities. I 17understand the difference between them, but I'm really 18 asking the question how if at all, and a comment was 19 made about everybody wears the same color hat now so 20 implying that it's a single integrated team, no 21 differentiation between TVA and Bechtel is the way I 22took that. The question really is are you affected by 23 that at all one way or the other.
24 MR. HAAG: No.
25 135 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433CHAIR RAY: Does it make any difference at 1 all?2MR. HAAG: The answer is no. I mean, when 3I look at how we were conducting our inspections, 4interfacing with either TVA or the workers, it has 5changed very little over the past, well, since the 6 project has taken place. I mean, TVA has always had 7an active role, contractually things may have changed 8 but they've always had an active role in the project 9from my perspective. And they continue to maintain 10 that.11CHAIR RAY: Okay. Well, I noticed design 12control is an issue up there and of course design 13control moved from TVA to Bechtel and I guess it's 14 still with Bechtel even under this modified.
15MR. HAAG: Clearly engineering efforts are 16 being done by Bechtel engineers.
17 CHAIR RAY: Okay.
18MEMBER SKILLMAN: Bob, my question is with 19this inadequate corrective action for several items 20that are legacy, years old, what confidence do you 21have in TVA's present QA program and particularly 22their energy around criterion 16 to identify items and 23 to pursue them until they are fixed.
24MR. HAAG: The way I'd respond to that is 25 136 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the current corrective action program while clearly 1has to envelop these legacy issues they're somewhat 2 separate. And we look at the current corrective 3action program under the same tools that we do the 4 ROP. We do PI&R inspections, we typically look at, 5you know, when problems are identified do they 6correctly identify it, do they capture all aspects of 7them and then we'll look at the corrective action.
8 And we do, we've been doing annual PI&R inspections 9and we've seen some problems there and we've seen some 10improvements and the typical corrective action program 11 and what's implemented right now at the station.
12These historical issues, the 13identification was not a problem. You know, the 14identification had been done years ago. It really was 15the follow-up to the issue and ensuring that, you 16know, if you had some belief that corrective action 17 was done back in the '80s and now you needed to 18confirm that, well you need to have some clear 19evidence that those actions were done, not relying on 20somewhat anecdotal information. So it was more of 21that where they, the level of pursuit of the 22corrective actions, that's where we saw some 23 breakdowns at least in these four examples.
24 Our confidence going forward? It really 25 137 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433has to be built. I mean, we're going to, we've 1identified those historical issues that we have on our 2inspection plate and we're going to look at those 3 things so clearly we're not just sampling those.
4 There's, you know, a set number of historical issues 5we're going to inspect. So we'll be verifying the 6 corrective action for those. And again, through the 7discussions we've had, management discussions and you 8know, in emphasizing to TVA, the importance that they 9understand what the corrective actions are and that 10 they do due diligence, making sure it gets done.
11MEMBER SKILLMAN: Have you heard with the 12 same energy that TVA leadership speaks of building a 13 safe work environment, the same energy around having 14quality workmanship and a quality product for what 15 they are doing at Watts Bar 2?
16 MR. HAAG: I mean, I would say that was 17never a problem. It was these examples where we found 18 shortcomings. And you know, we've looked at TVA's 19corrective actions for the severity level 16 violation 20in that, you know. Obviously the individual items had 21to go back and be corrected but they also needed to 22step back and look at and ask themselves why didn't we 23pick up on this. Why did we think the problem was 24resolved when it really wasn't. And we've pursued 25 138 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433that and we're looking at that. Yes, we have some 1 confidence that they have made some changes and have 2improved their process but again, until we get, you 3know, additional examples where we've looked at their 4closure packages, where we've looked at their 5corrective actions and have some confidence, you know, 6 it's still an open issue.
7 MEMBER SKILLMAN: Thank you.
8MEMBER ABDEL-KHALIK: I had a question 9about design control. Are there any concerns about 10 updating design drawings in a timely fashion to 11 correctly reflect the as-built condition?
12MR. HAAG: I'm not aware of specific 13examples or concerns related to that, you know, 14 updating their drawings, making sure that the design 15you know didn't fit what they thought it did, that 16 when they make a change that they clearly update all 17the design documents. I don't think we've seen 18problems there. The design control, it's typically 19been, you know, classic criterion 3 violation where 20 they didn't properly translate the design maybe into 21a working document, or you know, the product that they 22had in the plant, that was more the examples that 23 we've seen as far as design control.
24 MEMBER ABDEL-KHALIK: Could you say that 25 139 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 again, please?
1MR. HAAG: The criterion 3 where you have, 2 the plant is designed. You have the design basis, 3whether it's a calculation or an analysis, and then 4transcribing that to your field instructions, your 5work packages for actually building the plant. That's 6where we've seen some of the disconnects. Again, 7 these would have been at a severity level 4 level so 8they weren't necessarily that significant themselves.
9MEMBER ABDEL-KHALIK: Okay, all right.
10 Thank you.
11 MR. HAAG: So the next slide I wanted to 12 use was to kind of give you a sense of the level of 13effort that we're expending for the construction 14 inspections. For 2011 we spent over 17,000 of related 15hours involving inspection. Now those are all not 16direct inspection effort. Those are some of the hours 17that the inspectors and the folks who work in the 18region, who work for me, you know, managing the 19 project. But a large number of that is inspection 20effort, inspectors actually out at the plant, out 21there looking at construction, looking at records.
22That was an increase from the previous year of almost 234,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. And when we look at our scheduled 24 inspections and what's left to be done we think it's 25 140 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 going to pretty much stay at that level of 17,000 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> which is a huge effort. When you convert that 2 to FTE I mean it's a significant effort.
3We're planning to continue the four 4resident inspectors, staffing at four inspectors 5 onsite. We've had success in being able to look at 6areas that we wanted to, especially on those things 7where the schedule isn't as firm as you might 8necessarily would like as far as predictability and 9being able to send the regional inspector. So having 10someone out there on a full-time basis clearly 11alleviates that problem. They're there always and you 12know, if there's a change in schedule they can look at 13something else and be ready to look at the particular 14 area that you're interested in.
15As far as effort besides the four resident 16inspectors, when I went back and I counted up over the 17past year as far as how many inspectors you can see 18the number, 41 inspectors. I think that's pretty 19impressive as far as folks we either had from the 20region, some of those are contractors. We had a 21couple of inspections where we had contractor 22inspectors but 41 other individuals, you know, have 23 actually been, you know, having eyes on construction 24 activities and doing inspections.
25 141 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433As far as the regional complement and this 1is still within my branch we've increased the numbers.
2 We have four people who work for me on a full-time 3basis on the project and that's an increase from we 4 had two before back in 2010. And this previous year 5we added a team leader and a senior project manager to 6 my branch.
7Another initiative I wanted to talk about 8was our periodic public meetings. Our regional 9 administrator has an interest in maintaining ongoing 10dialogue and allowance for the public to understand 11where the project is so he's asked us to conduct 12periodic meetings as necessary to set the time frame.
13 He just wants us to ensure the local public has the 14ability to understand where the project is from an 15inspection standpoint, understand any of the issues 16that may be going on between NRC and TVA, ask 17 questions and comments. So we're initiating those.
18 And we're taking credit for several 19different initiatives. We have an end of cycle 20meeting as part of the process and I'm including that 21as the ability to get out and tell the public what 22we're doing, let them ask questions, provide comments.
23So in total we had four public meetings out at the 24 site in the local area at different venues in which 25 142 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the public had an opportunity to, again, hear our 1 inspection effort, what we're doing, any issues that 2are going on between TVA and the NRC and then ask 3 comments and questions.
4MEMBER SKILLMAN: Bob, please tell us what 5 the mood is when you meet with the public.
6MR. HAAG: It's varied. You know, none of 7the meetings have had a huge turnout. I'd say 8typically we may get, you know, between 20, 25, 30 9members of the public and it's varied. We have, there 10are several individuals who are opposed to the project 11 and they're routine attendance. We also get quite a 12bit of turnout from local officials who are supporting 13the project and they want to just voice their 14 continued support for the project.
15 MEMBER SKILLMAN: Thank you.
16 MR. HAAG: So it does vary.
17 MEMBER SKILLMAN: Thank you.
18MR. HAAG: So the status of where we're at 19 in implementing the inspection program. During a 20previous briefing I had described kind of how we 21developed the inspection program for Watts Bar Unit 2 22and it is unique because the history and the time 23 frame from when they did the initial construction to 24where they're at right now, we had a -- we're doing 25 143 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433more than just typically what was done in earlier 1 plants. Clearly the NRC has a program for inspecting 2 construction. It's managed at 25.12, pre-op is 25.13, 3start is 25.14 but we're doing more than that, you 4 know. So we went back, and again I don't want to go 5 over all that, but we've looked in these different 6 areas. And we ended up with over 500 unique 7 inspection items that we're doing for Watts Bar Unit 8 2 and we've got those loaded into an access database 9where we're tracking. Whenever we do an inspection 10we'll track it and we'll close it out. So in the end 11we're going to be able to say we've completed the 12inspection program. To date we've closed a little 13over 150 of the items so there's still quite a few 14 left to be done.
15A large majority of the remaining items we 16have looked at one way or another and we've documented 17that inspection in a report. There's just either a 18few things we want to continue to follow up on and 19close out. Some of them we haven't even looked at at 20all but a large majority of the remaining items we 21have spent some inspection on. And you know again, 22there's just a piece that we need to look at to be 23 able to say we're finally complete.
24We've completed inspection of seven of the 25 144 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 corrective action programs, special programs. Those 1were the get well programs that TVA initiated to deal 2with the problems from the early construction that was 3done back in the 1980s. A couple of those programs 4are broken out into sub-issues and we've closed eight 5of those sub-issues. So there's still quite a bit of 6 work left to do there, but again I would say the large 7majority of the CAPs and SPs we have inspected to some 8 degree and you know, we understand what's left to be 9done and we're just either waiting on the construction 10to be finished or our ability to get up there and look 11 at these issues.
12 MEMBER STETKAR: Bob, are you, you know, 13 you mentioned your resource estimates for FY 2012 on 14the order of about 17,000 person hours. Given the 15fact that at least according to this slide, now 16 recognizing that you're in progress on several of 17those, but this is, what, 30 percent complete roughly?
18 MR. HAAG: Just based on --
19MEMBER STETKAR: I have no idea what TVA's 20new schedule will look like but are you quickly going 21to become resource-constrained or do you think that 22 you're okay?
23MR. HAAG: We think we're okay and it's 24more than just, you know, just a hunch. You know, 25 145 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433what we've done for all of the IPS items, we've 1 estimated the level of inspection by number of hours 2and we routinely track that as far as where are we at, 3percentage complete, what's left to be done, when are 4you going to inspect it. We've had a recent 5initiative where we want to get the remaining 6inspections loaded into our Primavera construction 7inspection schedule. We're pretty successful on that.
8What's the uncertainty part, and that's the last 9 bullet right here, is the corresponding construction 10 activities. What we're trying to do, and it's similar 11to the effort that they're doing for the Part 52 12plants is to take your construction inspection effort, 13whatever you want to look at, whether it's a weld, the 14installation of a hanger, whatever, tie that to the 15construction schedule from the utility, align the line 16 time. And when they update their schedule our 17 inspection schedule is also updated. We've had 18moderate success in doing that. It's a work in 19 progress. I mean, it sounds like an easy process but 20it's not because, you know, the way they code items in 21 their construction schedule sometimes it's difficult 22for us to be able to link our inspections to that.
23 But again, you know, we're working on that. As part 24 of the fact that we're also, CCI is also doing the 25 146 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433Part 52 construction and they're much more 1sophisticated in that effort. You know, we're taking 2advantage of the people who have that expertise to be 3able to help us out in the Watts Bar 2 project. Next 4 slide.5 So the last thing I wanted to do was kind 6of give you an idea of where we're at with the pre-7operational testing inspections. I mentioned earlier 8we added a position to my branch. It's a team leader 9 and his focus and his charge really has been looking 10at the 25.13 inspection program, kind of defining 11 that, what do we want to do, coming up with the 12resource estimates, interfacing with TVA, what does 13their schedule show for system turnover, when the 14testing is going to be done and make sure we're ready 15for that. And we're having success in at least the 16 initial scoping effort.
17Manual Chapter 25.13 has mandatory tests, 18tests that have to be witnessed. These are the larger 19tests, the containment integrated leak rate test, hot 20 functional test, RPS. Then it also has the primal 21 system tests. Those are, you know, it lists over 20 22different systems and you can pick and choose which 23systems you want to spend your inspection effort on to 24be able to look at both the test procedure, test 25 147 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433witnessing and records reviews. So we've gone through 1 and we've selected the systems that we want to focus 2on and we've assigned inspectors, lead inspectors for 3all the mandatory and the primal tests. Our challenge 4now is to define the remaining inspection support 5group that's going to be needed because one person 6certainly can't look at many of these tests. They're 7involved and you may need, you know, three or four 8people, you know, back shift coverage and things like 9 that. So what we're looking at right now is coming up 10 with the resources that are needed, figuring out who 11 in the region or even outside the region can provide 12those inspections. We're also looking at possibly 13 having contract inspectors to assist us in that.
14 The other part of 25.13 is the operational 15preparedness inspections. Those are the areas, the 16traditional support areas. Management controls the 17procedures and I gave you some examples up there, 18radiation protection, chemistry, security, fire 19 protection. We're taking a little different approach 20 there. If you spend any time looking at those 21inspections and the way the program is defined the 22procedures have not been updated since they were 23 issued and used back in the '70s and '80s, maybe early 24'90s. So you know, we've questioned is there a need 25 148 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433to do all those inspections as currently written. We 1think the answer is no so we're going through and 2 doing a review to understand what's required for the 3inspection, factor in related inspections that may 4have been done recently under the ROP or other related 5inspection areas and come up with a clear 6understanding of what's needed for Watts Bar Unit 2 7given its, you know, situation, the fact that many of 8these programs have been established and have been in 9use for Watts Bar Unit 1. We've been inspecting them 10 over a number of years so what do we need to look at.
11Do we need to look at program inspections or do we 12need to look at, you know, implementation and has TVA 13captured, you know, what needs to be added to the 14program to cover Unit 2. We think that's the answer, 15 but again we need to go back, define those, come up 16with some recommendations, make sure the program 17 office, the NRR branches who have responsibility for 18 those areas are in agreement with that and then kind 19of lay out our inspections there. So that was what I 20wanted to present to you as far as the inspection 21 program.22 MEMBER BROWN: Can I ask a question?
23 MR. HAAG: Sure.
24 MEMBER BROWN: You talked about, and you 25 149 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433have a list of access, I guess it's a database for 1 stuff and there are, I don't know, there's a hundred 2and something, 120, 130 open items that are covered in 3the SSER where Region II is identified as the lead 4person or lead organization for resolving those, 5 confirmatory and otherwise. Are those in your --
6 MR. HAAG: Yes, they are.
7 MEMBER BROWN: -- database also?
8 MR. HAAG: Yes.
9 MEMBER BROWN: The other thing I noticed 10 in here was that there's a number of combinations of 11Region II NSIR items all dealing with emergency 12facilities, accident control, whatever, for the site.
13Nothing in there relative to the cybersecurity issues 14relative to the new rule 73.54. How is that being 15 addressed in terms of your long-term confirmation of 16that the integrating of that particular issue? I seem 17to remember we had a previous full meeting on 18cybersecurity stuff and they explained what they were 19 doing. All I'm trying to do is figure out how, I 20don't see anything being set up to go cover that. Or 21 at least it's not listed.
22 MR. HAAG: And it's not included in that 23access database mainly because the temporary 24 instruction that is going to be written to cover the 25 150 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433inspection effort has not been finalized. It's still 1 in draft.2MEMBER BROWN: Who's doing that, 3 headquarters or you?
4MR. HAAG: NSIR is doing that. The region 5has been involved, there is a point of contact in the 6region, not in our division but the Division of 7Reactor Safety who will be doing the inspections at 8the operating site. He's also been involved in it as 9far as planning for Watts Bar Unit 2 because that will 10 be one of the first plants that actually gets this 11 inspection. So that's a point of contact, you know, 12from a continuous standpoint, you know. They've been 13involved in it, they will be involved in it, not just 14for construction activities but also for the operating 15 plants. We will put, once that temporary instruction 16comes out it will get added to the IP&S database so we 17make sure we track that and we've completed it before 18 we say all our construction inspections are done.
19MEMBER BROWN: I don't know, I'm just, I'm 20 winging it right now, okay? I'd really like to hear 21at a later date when that's, I think we should hear at 22a later date how that's being executed. You know, 23 what does it look like, what do you all intend to do.
24 MR. HAAG: Yes.
25 151 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER BROWN: In other words, how is that 1getting passed down, what's the temporary instruction 2say, how will you all execute that and what are the 3key critical areas which you intend to go pull the 4string on to ensure that we've isolated the plant and 5the items of interest from external hacking to put it 6 bluntly. So I'd like to have that on the -- Harold, 7if you don't mind I'd like to have that discussion at 8some point from an inspection standpoint when it's 9 available.
10CHAIR RAY: Well, yes. As far as this 11process that we're engaged in here now of course it's 12leading up to a full recommendation and a full 13 committee letter or perhaps more than one letter and 14 we can discuss at that time whether to put something 15 in the letter pertaining to what you're --
16 MEMBER BROWN: No, I just wanted to have 17some detail instead of waiting until the eleventh 18 hour2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br />. I'd just like to have some idea of where 19they're going and how you intend to do that before we 20 get to that point.
21CHAIR RAY: Oh, I thought you wanted 22something more than just some additional information.
23 MEMBER BROWN: At one of the other 24 meetings I'd like to have --
25 152 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 CHAIR RAY: Let me ask Justin here. We 1need to have some tracking of this between yourself 2and Girija so that Charlie or I can ask when are we 3going to get any more information about this 4 inspection procedure.
5 MR. POOLE: Sure.
6 CHAIR RAY: And we're not going to, like 7I say, if nothing is available by the time we need to 8wrap this process up we can make a note of it at that 9 time. 10MR. MILANO: I'd like to make one comment.
11 CHAIR RAY: Sure, Pat.
12MR. MILANO: One of the other things that 13we're going to do in this process is working with NSIR 14they are going to do a pilot audit at Watts Bar and 15that's not an audit type of inspection out there.
16What they're going to do is after the temporary 17 instruction is prepare. They're going to take it to 18 Watts Bar and look at its ability to be implemented.
19And it'll be sort of like a tabletop review. They'll 20go through it and say, you know, can this step 21actually be accomplished or do they need to adjust the 22focus or the direction in it to accomplish the 23objective that they want. So that audit right now 24we're looking at sometime late spring but it's still, 25 153 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433it's not fixed. It's all predicated as we've 1indicated on the initial development of the temporary 2 instruction.
3MEMBER BROWN: I'm just not sure what the 4instruction is going to say. I'd like to have some 5 idea what's in it, what it's intended to accomplish.
6What an instruction does, is it just to make sure that 7 the plant comes out like you want it to be or is it 8something that somebody's going to do every three 9months for the next 30 or 40 years, or what is it? I 10 mean, I just, I don't even know what this instruction 11is supposed to accomplish. That would be a nice thing 12 to know also.
13MR. MILANO: The reason why I was bringing 14 that up was it's probably, timing-wise it's probably 15best to, if you do want to hear something about it is 16after the audit is done and it's adjusted accordingly 17--18MEMBER BROWN: That's fine, I'm not 19pointing at any, tomorrow, or something. I'd just 20 like to have, before we close out and we're ready to, 21 you know, make a full understanding of what we think 22 we've got we ought to have some idea what's going on 23 there, that's all.
24 MR. SHUKLA: Mr. Chairman, there is only 25 154 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433one subcommittee meeting between and the full 1 committee meeting remaining, so.
2 CHAIR RAY: Well, that may or may not be 3the case, we'll see. But in any event as Charlie said 4I'm not trying to change whatever the present schedule 5is, I just don't want to lose track of this item. If 6we can get the information before we're done and 7resolve it so that it goes away I think that's in 8 everybody's interest. If not.
9MEMBER BROWN: I have one other once we're 10 finished with this.
11 CHAIR RAY: That's fine.
12MEMBER BROWN: A couple of the action 13 items also still have to deal with the communications 14between the Eagle 21 and the integrated computer 15system, the site, this large site integrated computer 16 system. And they have a nice explanation of what this 17 is supposed to be, you know, a configuration and how 18it was supposed to be hard-wired and all this other 19 kind of stuff. You guys are down as the responsible 20action party to resolve this and make sure it comes 21out looking like that. And I guess I'd like, I 22presume you're going to be recommending that it be 23closed or not closed. Two of the items, let's see, 24one of the items associated with this is a 25 155 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 confirmatory item, the other one is an open item but 1 you were still down as the action party for both of 2 those. I guess I'd like to, because of the delicate 3nature of that whole one-way communication, you know, 4 does it get configured the way it's supposed to, how 5are you going to check it, what are the resources you 6 have to do that and how is it made such that it can't 7 be, you can, the configuration control for that area 8 which is kind of open.
9MR. HAAG: So you'd like to have a 10presentation once we finish that inspection, give you 11 the results?
12MEMBER BROWN: Yes, that sounds like a 13short item, 5 or 6 minutes, 10 minutes, whatever it 14 is. It's not rocket science, it's a matter of what's 15 it look like in reality as opposed to the PowerPoint 16slide and explanation. That's something a little bit 17more to amplify again what's in the SSER to make it 18 clear.19MR. HAAG: As I mentioned earlier we have 20included all those Appendix HH items that have Region 21II inspection portion, we have those included in IP&S 22and we've got an individual inspector assigned to all 23of that appendix items. So there is someone who is 24assigned to it. I can't tell you right now how far in 25 156 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433this case it's a female, how far she is in looking at 1 it but we've got --
2MEMBER BROWN: I'm not asking for that 3 right now. Just, it's item 63 and 93 I believe. So 4 thanks to Harold reminding me.
5 CHAIR RAY: Appendix HH.
6MEMBER BROWN: Yes, Appendix HH in the 7 latest SSER. The details are in SSER 23.
8 MR. HAAG: Sure. Okay.
9 MEMBER BROWN: Okay?
10MEMBER SKILLMAN: Bob, I'd like to ask 11another question, please. What's interesting about 12Watts Bar 1 and 2 is the number of years between Unit 13 1 having come online and when Unit 2 will come online.
14 And you've identified a number of programs here that 15are essential for the health of the unit rad pro, 16chemistry, security, fire protection, but there are 17 more, configuration control, configuration management, 18 design control. And my presumption is that by and 19 large Unit 2, Watts Bar 2 will either adopt or be 20 adopted by the Unit 1 procedures. And that leads me 21to wonder are there weaknesses in the Unit 1 22procedures that need to be resolved before the 23integration of Watts Bar 2 is pulled into 24 applicability for those procedures. In other words, 25 157 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 are there existing weaknesses today that really need 1attention so that when Watts Bar 2 is adopted that the 2program is healthy for both? Have you given any 3 consideration to that, please?
4 MR. HAAG: I'd answer that by saying the 5people who will be doing that portion of the 25.13 6 inspections are the same organizations within Region 7 II who have been doing the inspections on the Unit 1 8 programs. For example, the radiation protection. You 9know, the ROP clearly has baseline inspections that 10you do on an annual and a biannual, you know, period.
11We'll be having that same branch perform the 12inspections on Unit 2 that once we define what 13inspections need to be done they'll be doing those 14 inspections. So they would have the best insight from 15a regulatory standpoint as far as where are some of 16 the problem areas that have been identified with the 17Unit 1 programs if they exist and how are those, if 18it's a shortcoming or, you know, a marginal program 19how is that being addressed now because there's two 20units that that program has to support. So I mean, I 21 think that's the best answer I'm going to be able to 22 give you in that, you know, we have that consistency 23 both from an understanding of where the problems are 24 and also, you know, history on, you know, where do I 25 158 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433need to look, where should I be spending my time 1 because of insights from previous inspections.
2MEMBER SKILLMAN: Harold, do you consider 3 that something worth talking about at a later point?
4I'm thinking about a lot of the work that I've done 5where I've found that the organization knew it had 6problems but didn't do anything and a year or two 7passed and now two units were in trouble. Here's a 8case where there's really a time constant that is 9 introduced.
10 CHAIR RAY: Well, let's talk about it at 11the end, Dick. I'm not inclined to think that it's 12 something we should create an action item about.
13 MEMBER SKILLMAN: Okay, thank you. Bob, 14 thank you.
15MR. POOLE: Okay. Thanks. The next part 16of the presentation is to go over the status of the 17 licensing activities.
18 Okay, this slide shows based on the 19 staff's review over the past two years or so and 20asking RAI questions and writing up their SE 21 evaluations. TVA has had to make numerous amendments 22 to their FSAR. The current version of the Watts Bar 232 FSAR is at Amendment 107. The next bullet there is 24 to show that over the --
25 159 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER STETKAR: Is that -- that's been 1 amended?2 MR. POOLE: Yes. Yes, it was. The next 3bullet there is to show that over the past five 4supplements to the safety report a large chunk of the 5 review, the safety review has been completed and 6 having gone before you guys today most of them have at 7 least been discussed in front of the committee. The 8major areas that we have remaining is fire protection 9 which we intend to talk in April and then the closure 10of the open items in the SER. And then I'll also 11point out, it probably should have been a bullet on 12here too, was the discussion we had last time on 13 hydrology and the maximum flood level.
14 MEMBER STETKAR: For sure.
15MR. POOLE: Okay. So as has been pointed 16 out a few times already both in the introduction and 17TVA had a slide in their presentation and we've heard 18from some of the members here there's been a number of 19 questions on how do we handle the open items. So we 20provided a slide here today just to go over some of 21the numbers, how we break them down and then Chairman 22as you mentioned we would love to hear at some point, 23 you know, which ones, go over at some point which ones 24 you guys are most interested in.
25 160 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433CHAIR RAY: Yes, I've gone over them 1 myself. We have hard copies for those who want to use 2 same but it looks to me like we'll have time that we 3 can refer to that today and just go over the open 4items to see if any numbers have particular ones that 5are open at this time that we think warrant further 6 discussion with the subcommittee or potentially full 7 committee. But you tell me when you would like us to 8 do that.9MR. POOLE: Sure. Let me run through this 10slide and then we can talk about that. So as the 11 first bullet says there was 124 open items that were 12 written into the different supplements of the Safety 13Evaluation Report. Just to avoid confusion there was, 14you know, looking at Table HH I believe the final 15 number on there is actually 139. The reason for the 16discrepancy is that in preparing the different 17supplemental SERs there were drafts, open items 18originally created and then for whatever reason never 19ended up getting published. They were either resolved 20prior to publishing or were delayed until a further 21 publication. So there were some numbers that were 22 never used.
23 As TVA pointed out before, to date as of 24 SER 25 we've closed 41 of those 24 which means that 25 161 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433there's a total of 83 that remain open. We show in 1 this slide that we break those down into essentially 2 two categories, the items requiring NRC confirmation 3of which there are 43, and then items which require 4 additional NRC evaluation which there are 40. Items 5that require confirmation essentially were created 6when the staff was provided sufficient information in 7order for them to make a finding of reasonable 8 assurance. We needed confirmation, needed some sort 9of confirmation from the applicant to complete a 10follow-up action. This action could have been 11satisfactory testing, installation of equipment, or it 12could be a submittal of a report or a safety FSAR 13 update. So given that, the closure of these 14confirmatory items can be accomplished either by 15regional inspection or a submittal to the headquarters 16 staff. 17For items requiring a submittal to 18headquarters staff the staff will verify that the 19information submitted is what was expected in order 20for the item to be closed. A very typical example of 21 this is when during the review the staff required 22additional information and requested via an RAI. TVA 23 provided the response and in reviewing the response 24staff felt that the information provided was important 25 162 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 enough to require an update to the FSAR. In many of 1these RAI responses TVA actually provided draft 2versions or pages of what they intended to update the 3FSAR to look like which allowed the staff to review at 4the same time as they're reviewing the technical 5 information. So these truly are just a check of 6getting the same information that was already sent in, 7and then the staff just wanting to verify that it gets 8 put into their FSAR to remain as part --
9CHAIR RAY: We understand, I think.
10 That's fine.
11MR. POOLE: Okay. And then the other part 12of that is -- so because it's just a check, a 13confirmation there's no evaluation done in the 14Supplemental Safety Evaluation Report. It's marked 15off in Appendix HH and the submitted document is 16referenced in the table. This is also done similarly 17for inspection items, confirmatory items that are 18closed via inspection. There's no evaluation written 19in the SER and its update of the table pointing to the 20 evaluation done by the region and their inspection 21 report. 22And then the items that require additional 23evaluation which are essentially the true open items, 24these were written because the staff required further 25 163 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433information from the applicant in order to complete 1its review. Upon receipt of the information the staff 2can finish its evaluation and document it 3appropriately in the next, in a further supplement to 4the Safety Evaluation Report. Our goal is to close as 5 many if not all of these by the April subcommittee.
6CHAIR RAY: Okay, well, tell you what, 7 Justin. You probably have staff people standing by 8here that are intending to participate in these 9 scheduled items of staff presentation. Why don't we 10 stop the review of open items here now. I think we 11 understand the difference between confirmatory items 12 and other open items.
13 MR. POOLE: Okay.
14 CHAIR RAY: And so that we can let these 15people get back to productive work. Let's do the 16staff presentations that are on the schedule now. We 17will have a break perhaps after the first one given 18 what time it is now. But finish them up and then at 19the end we'll be able to go through the open items 20table and give an indication to you and the applicant 21which items warrant consideration for the next, or if 22 there are other subcommittee meetings in addition to 23 the next one, future subcommittee meetings.
24 MR. POOLE: Okay.
25 164 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 CHAIR RAY: Can we do it that way?
1 MR. POOLE: Yes, that's fine.
2CHAIR RAY: That way it lets the staff get 3 back to their business. So, with that you take over 4 and let's go through the items where there are staff 5 presentations yet to do.
6 MR. POOLE: Okay. While they're making 7 their way up to the table here I'll just point out, 8 the next slide was just to say that before the --
9their presentations are based on previous to 10Supplement 24 and 25. These were the dates. Okay.
11 The next part of the presentation that we'll go over 12 is the status of radiation protection. The reviewer 13for this portion was Mr. Roger Pedersen. I'll now 14 turn it over to him.
15 CHAIR RAY: All right, Roger.
16 MR. PEDERSEN: Good afternoon.
17 CHAIR RAY: Good afternoon.
18MR. PEDERSEN: I'm a senior health 19physicist in the Office of Nuclear Reactor Regulation.
20 I reviewed Amendments 92 through 104 in terms of how 21those changes related to radiation protection both the 22occupational radiation protection in Chapter 12 of the 23 FSAR as well as public radiation protection in terms 24of radiological effluents, both liquid and gaseous 25 165 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433effluents that's contained in Chapter 11 of the FSAR.
1TVA made several changes to Chapter 12 in 2terms of occupational radiation protection design 3 features. The list that I have here are some of the 4more notable. I didn't provide an exhaustive list of 5all the changes that were made. And of these six 6changes only the third bullet there in that last 7bullet resulted in a situation in which the initial 8change was unacceptable to the staff and we had to go 9back through the RAI process and resolve those issues.
10 But let me run through them real quickly here.
11There were a number of changes to the 12source terms that were identified in the FSAR. The 13most notable is the containment airborne estimates.
14TVA had identified an error in their previous 15calculation so they corrected that. It did not result 16in a significant change. It did not change the, even 17though the airborne estimate in the upper containment 18and lower containment changed it did not change 19whether they were considered an airborne area 20requiring controlled access or not. So it had no 21 impact on our previous analysis.
22There were a number of changes in plant 23radiation monitoring. Again, the most notable of 24those were the area airborne radiation monitors in the 25 166 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 aux building. Previously the FSAR described a fixed 1system of airborne monitoring. TVA had revised the 2FSAR consistent with how Unit 1 is being operated and 3 that in the aux building which is pretty much common 4 to both plants they have four portable monitors that 5provide four channels of airborne monitoring that are 6comparable to the fixed monitors that were previously 7 described there. They alarm locally, they alarm --
8CHAIR RAY: Was this a 50.59 change for 9 Unit 1 or what?
10 MR. PEDERSEN: I would imagine so.
11MR. BRYAN: This is Bob Bryan. Yes, it 12 was.13 CHAIR RAY: Okay.
14 MR. PEDERSEN: In addition to that there 15was a change in the description of the calibration 16 frequencies and the channel operability tests. I'll 17get back to the position that we negotiated. There 18was a significant change in the description of the HP 19 support facilities. The original FSAR had layout 20drawings depicting things like whole body counters and 21dosimetry and respiratory protection issues. Those 22 layout drawings were removed from the FSAR. In lieu 23of replacing those drawings I accepted a detailed 24 description of the facilities and the commitment out 25 167 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433of the applicant that they're adequately sized for 1 two-unit operation which of course will be a subject 2 of follow-up inspection activities.
3The applicant also changed, made some 4 changes to their dose assessment both the collective 5 dose assessment, the annual dose that they expect to 6operate the plant and the dose assessment for vital 7 area access. That's the dose to operators that have 8to access the plant during accident conditions to 9operate vital equipment to mitigate the course of the 10 accident. It's TMI Lessons Learned item 0737-2B2.
11And that last item is actually one of the open items.
12 Most of the RAIs that I had with these issues and the 13other issues were clarification issues asking for the 14applicant to clarify the basis for the change. And so 15they have clarified the basis for the change with the 16 vital area access, they just haven't documented that 17in the FSAR yet. That's I believe the only open item 18 left in the open item list.
19 And then the last item, again that was one 20of the ones that ended up as not acceptable to the 21staff, was an issue about RPM qualifications. The 22previous FSAR had a fairly clear commitment to the 23regulatory guidance in our Reg Guide 1.8 1978 in terms 24of what the qualifications are for the radiation 25 168 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 protection manager. That was removed. The response 1that I got to my RAI was not clear. It actually 2precipitated a review of the current procedure on 3 qualifications. And one of the two issues besides the 4number of years of operating experience, one of the 5 other issues that I brought up was whether there was 6 a clear criteria as to how long someone who does not 7meet the qualifications could act as the RPM. It 8turned out that their procedure wasn't adequate to 9 cover that to ensure the way they did things would be 10consistent with the Reg Guide 1.8. So I believe that 11generated a corrective action. That's what I was 12told, I haven't verified that. So they're going to 13change their procedure based on that. But now there's 14 a clear commitment to Reg Guide 1.8 in their FSAR.
15 Let me back up to the other item before we 16change slides. The area of radiation monitoring, the 17 channel operability test. The previous FSAR and the 18way Unit 1 was originally licensed, there was a 19commitment to do quarterly channel operability tests.
20That's to take each channel of the area radiation 21monitors, test the alarm capability, make sure they 22alarm at the appropriate point, make sure that they 23have full range of reading, et cetera. They had made 24a change, a 50.59 change from that commitment to a 25 169 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433periodic test per their procedures and that's what the 1original change to the FSAR stated. They went from a 2 quarterly commitment to a periodic commitment. When 3 I asked what "periodic" meant I got the 50.59 change 4package and some problems with the bases there. So 5 the long and the short of the review is that the TVA 6 has committed to quarterly changes or a frequency 7 that's established by the performance of the same or 8similar monitors. So that it's a performance-based 9criteria now. The statistical acceptance criteria is 10 that 95-95 acceptance. It's a 95 percent confidence 11that the individual monitor will pass the next test 95 12percent of the time is what that means. And although 13I'm not an I&C guy I understand that's a standard I&C 14 acceptance criteria for performance-based frequencies.
15 Next slide.
16In terms of the plant effluents, the 17liquid effluents there were a number of changes to the 18source term associated with the liquid effluents from 19the plant. Most of them had very minor changes to the 20overall dose. In fact, there were only very minor 21changes to the overall dose calculations. However, 22 there was a significant change to the description of 23the source terms. TVA had changed the source term 24table that's there, Table 11.2-5 which gives the 25 170 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433normal operating source term which is actually the 1bottom slash there. I apologize for having these a 2 little bit backwards. But the normal operating mode 3would be as was discussed earlier that the steam 4generator blowdown would be released from site 5unprocessed as long as it was below the trip setpoint 6on the monitor for the blowdown line, and that the 7condensate demineralizer, the effluent from the 8regeneration of the condensate demineralizer would 9 also be released from the site unprocessed. If in 10fact there was operation with steam generator leakage 11in excess of that trip point the blowdown would be 12directed to the inlet of the condensate demineralizer 13and processed through the condensate demineralizer.
14 Then there were two sets of source terms given in this 15change that would address either releasing the 16effluent from the condensate demineralizer 17regeneration directly to the environment without 18processing or to go ahead and process that effluent 19 with the mobile demineralizer that's part of their 20 normal rad waste processing.
21The purpose of that Table 11.2-5 was to 22demonstrate that these modes of operation actually 23meet the 5 curie total release limit that's in RM 50-2 24and those tables do in fact demonstrate that.
25 171 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433However, in response to a question that I had they 1also provided some tables that adjusted these total 2curies to an effluent concentration limit for those 3three modes of operation and compared them with the 4concentration limits in 10 CFR 20 Appendix B. The 5result of that analysis is that the -- for the normal 6operating mode they meet 10 CFR 20. For the operating 7mode in which they would process the blowdown through 8the condensate demineralizer and then process the 9condensate demineralizer through the mobile 10demineralizer that in fact meets Part 20 as well.
11 However, without that additional processing with the 12mobile demineralizer it clearly does not meet Part 20.
13 So they will have to control how long --
14now, the Part 20 concentration limits are annual 15average so it's the average concentration over the 16entire operating year. So obviously extended 17operation in that mode would not be acceptable. So 18they will have to administratively limit how long they 19 can operate in that mode. And that would be covered 20by the technical specifications, the effluent 21technical specifications that'll be put into place in 22the offsite dose calculation manuals that are 23associated with that that control and limit the 24 effluents. Although we haven't received the ODCM as 25 172 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433yet so we haven't reviewed that yet but that is going 1 to be a part of it.
2CHAIR RAY: When you talk about all these 3 things is there, this is just a new review independent 4 of Unit 1 the way it is today? Or do you link these 5 things in some way saying this is different, this is 6the same, that sort of thing? I look at that, I 7listen to what you're saying, I can understand it but 8 I'm just asking myself I wonder how they do it at Unit 9 1.10MR. PEDERSEN: The FSAR, Watts Bar was 11originally submitted as a two-unit site with a common 12 FSAR. We reviewed that up to a certain point as a 13common two-unit site. We actually wrote a safety 14evaluation, Supplemental Safety Evaluation 16 that 15addressed both units operating. What I'm reviewing 16are the changes that have happened since then. The 17Unit 1 design basis when it was licensed per the 18Supplement 16, we only assumed that last bullet there.
19We didn't address extended operation with steam 20generator leakage. This was added to the Unit 1 FSAR 21and then the Unit 2 FSAR was changed to come into 22 conformance with that. The actual dose calculations 23 are based on that normal operating mode with minimal 24or steam generator leakage less than the trip 25 173 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 setpoint.1 So the TVA recalculated the doses and we 2did an independent dose calculation as well which I'll 3get to. Other things that changed in that dose 4calculation were the population distribution around 5the site from the latest Census, I believe it was the 62000 Census, and then the annual land use survey that 7they do. They also incorporated the changes to that.
8And they were minimal changes. They calculated the 9dose, we calculated the dose. There were slight 10changes to the actual numerical values but the maximum 11individual, exposure to individual didn't change. The 12maximum exposed organ which is in the child did not 13 change. And those doses will be presented in the 14table in a slide here that I have in a few minutes.
15 Next slide.
16The changes made to the FSAR didn't impact 17the liquid effluents very much but there was a 18significant impact to the gaseous effluents. In 19addition to some minor changes to the source term the 20dilution of the boron recycle system had a minimal 21 impact. The change from 22 purges per year to a 22continuous filtered vent had more of an impact on the 23source term and we incorporated that into our re-24analysis as well as TVA incorporated that in their 25 174 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 calculation as well.
1The major changes though, however, were 2associated with the land use survey and the Census, 3the population distribution. Things have changed 4 quite a bit around the plant since Unit 1 was licensed 515 years ago. In particular, the critical milk 6animal, the cow and dairy farm that was previously the 7limiting pathway no longer was in existence so that 8 changed. There are still dairies around. I believe 9two out the -- three out of the previous five, six 10 dairies are still in existence but. And then a 11garden, a local garden has actually been moved up 12 closer to the site so it turns out that that local 13garden becomes more of a critical dose pathway than 14 the iodine milk child pathway.
15In addition to that the meteorology was 16changed as you heard earlier. TVA recalculated their 17dispersion and deposition factors. And of course 18since the location has changed the turbine correction 19factors that would be associated with that dose 20 calculation changed since they're location-specific.
21The last bullet there, I mentioned that 22we, the staff, did an independent assessment.
23Supplement 16 to the FSAR was our original independent 24assessment and our original safety conclusion was 25 175 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433documented in Supplement 16. We revised that, that 1initial staff independent assessment with our standard 2 assumptions methods. We did use for the source term 3 our own GALE code which is a slightly different code 4than what TVA used. We used, we calculated our own 5chi over Q's and D over Q's with a standard code 6called XOQ/DOQ which has been consistently used in 7 licensing. And then we did our own dose calculations 8that are based on the GASPAR and LADTAP codes that 9have been around and been used in licensing since the 10'70s which are in fact different than the codes that 11 Watts Bar used.
12 So this is the result. The first column 13 there is the design objectives that are listed in 10 14 CFR -- excuse me, Appendix I. The second column are 15the TVA-calculated doses and the third column there is 16 the NRC-calculated doses for those various criteria, 17 liquids, total body, any organ, noble gasses and the 18airborne effluents, and then the last one is the 19radioiodine and particulate. There's a 15 millirem 20 criteria for any organ, all pathways.
21There's general agreement between the TVA 22and NRC assessments within about 10 percent of each 23 other. Both of them indicate that they're well within 24 the design criteria, their respective criteria. And 25 176 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 so there's not much of a problem there until you get 1to the last one. The 15 millirem for the airborne 2 radionuclides and particulate, previously during the 3Unit 1 licensing was calculated out as 7.5 millirem 4 per unit so there was a significant increase.
5The significance is that TVA had committed 6to meeting RM 50-2. Go ahead and change the slide.
7RM 50-2 was actually the forerunner to 10 CFR 50 8Appendix I. It has very similar design objectives as 9Appendix I with the notable exception that in some of 10 those design objectives they were given, even though 11the numeric value was the same they were given on a 12per-site as opposed to a per-unit basis. And when 13that change was made and Appendix I was finalized the 14requirement for the licensee to do a cost/benefit 15analysis in addition to meeting the specific design 16criteria that are listed there, licensees are also 17required to do cost/benefit analysis to see that if 18 modifications to the rad waste system could actually 19 attain what's called a beneficial cost/benefit ratio 20at $1,000 per man-rem. However, there's an exception 21 to that requirement that's built into Appendix I and 22that's for plants that received a construction permit 23between 1974 and '76 which TVA was. So Unit 1 was 24 built to that exception.
25 177 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433They did not provide a cost/benefit 1 analysis. They demonstrated that they met RM 50-2.
2That can no longer be concluded from the dose 3calculations, either the staff's or the licensee's 4dose calculations. A maximum organ dose of 9.15 5 implies a site dose of over 18 millirem which of 6 course doesn't meet the 15 millirem requirement. So 7 TVA was required to do the cost/benefit analysis.
8We provide actually a very proceduralized 9 analysis method in Regulatory Guide 1.110. It gives 10a list of what is considered technically feasible 11 modifications, enhancements --
12CHAIR RAY: 1975 dollars, are you kidding 13 me?14 MR. PEDERSEN: Yes. No, I'm not.
15 CHAIR RAY: Jiminy Christmas.
16MEMBER STETKAR: When was Reg Guide 1.110 17 last updated?
18 MR. PEDERSEN: 1976.
19CHAIR RAY: I don't know if anybody can 20 calculate 30 years ago.
21MR. PEDERSEN: Actually, the document 22itself gives a list of enhancements, technically 23feasible enhancements and gives the cost, the capital 24 cost in 1975 dollars of what that would be. It goes 25 178 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433through an extensive procedure of taking the direct 1 and indirect costs, adjusting them for capital --
2CHAIR RAY: I know how to do it, I just --
3 it's --4 MR. PEDERSEN: -- and adding the --
5 CHAIR RAY: You're getting almost a half 6a century of discounting here and that's a big number.
7 MR. PEDERSEN: Yes, but --
8 CHAIR RAY: The inflation of the '80s.
9 MR. PEDERSEN: That's actually addressed 10in the document. The rationale was if you're doing 11 the cost/benefit ratio, if you assume that inflation 12adjustment would impact both the costs and the 13benefits the same it doesn't make any difference, they 14cancel each other out. That's the rationale built 15into the document. That's why $1,000 per man-rem 16 hasn't been adjusted.
17CHAIR RAY: All right, I see the point.
18 Yes.19MEMBER RYAN: It makes it very hard to 20communicate what exactly it is you're doing, however.
21 MR. PEDERSEN: I agree, I agree.
22MEMBER RYAN: I mean it's very arcane and 23 I've got to tell you, I think about updating it.
24MR. PEDERSEN: If it were me I would 25 179 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 probably recommend that as well.
1CHAIR RAY: Yes, because the $1,000 would 2 now be I don't know what but some big number.
3 MEMBER RYAN: A whole lot more.
4MR. PEDERSEN: Well, NRR is actually in 5the process of trying to update that. The $1,000 per 6man-rem standard assumption that was built into a lot 7 of our cost/benefit analysis not just for plant 8 licensing, but for --
9MEMBER RYAN: At some point it's simply a 10 metric. It means nothing whatsoever to do with 11regular money. It's just some metric number that 12 you're using to assess this versus that.
13 MR. PEDERSEN: That's true.
14 MEMBER RYAN: So yes, one approach would 15 be to drop the dollars.
16 CHAIR RAY: That's right.
17MEMBER RYAN: And just call it the metric, 18you know, the figure of merit calculation, whatever 19you want to call it. It does not represent real 20dollars and it's very hard to explain that to anybody 21 that's not familiar with the history and use of it.
22MR. PEDERSEN: Actually, the reg guide 23itself, you're right. It leads you into putting both 24the cost and the benefit in terms of dollars. The way 25 180 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433that TVA actually did the analysis and the way the 1analysis is being done these days in NRO I believe is 2 consistent, in which instead of --
3MEMBER RYAN: I challenge anybody to go 4 try and teach a class of young engineers what it all 5 means. You'd get done with it in a day.
6MR. PEDERSEN: It took me more than a day 7 to try to figure it out. I've never, I've licensed, 8I've done reviews in the past when we were doing quite 9a bit of reviews, in fact, I did the Chapter 12 review 10 for Unit 1 15 years ago and this is the first time 11I've ever had to go through this, the cost/benefit.
12I understand NRO with the new reactors have in fact 13 done a number of these assessments.
14 The way TVA did this assessment, instead 15of putting things in terms of dollars they put things 16in terms of person-rem, in terms of the collective 17 dose. The calculating out a cost for an enhancement, 18if you've got $20,000 that would imply that you'd have 19to have at least a 20 person-rem savings to come up 20with that beneficial cost/benefit ratio and so it was 21 done in terms of dose saved and how much dose would 22have to be saved to benefit that. So that's how they 23 did their analyses.
24And they went through, it's $1,000 per 25 181 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433person-rem, that's both total body and person thyroid 1 rem. So it's collective thyroid rem as well. The 2 person-rem was fairly easy to demonstrate that the 3lease expensive modification listed in the guidance 4 document would require more dose savings, total body 5 dose savings than the operation of the unit actually 6 results in.
7MEMBER RYAN: So that raises another issue 8 that having a separate individual organ dose when we 9have effective committed dose is another longstanding 10 rule.11MR. PEDERSEN: Yes, you're right. We did 12not do this review in terms of effective committed 13 dose. It's to demonstrate compliance with Appendix I 14which is based on ICRP 2. We did not make a 15 conforming change.
16MEMBER RYAN: For those that don't know 17 ICRP 2 was written in 1959.
18MR. PEDERSEN: Yes, yes. And it's one of 19 the issues that we have right now that we have an 20ongoing process of trying to adopt the latest ICRP 21recommendations and making conforming changes, 22 particularly to Appendix I is one of the main bullet 23 items on the list.
24So, as I said, TVA provided that 25 182 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 assessment. I've reviewed it. My review is 1 documented in Supplement 25 there. The staff did an 2independent assessment. We, as I said we had our own 3chi over Q's, our own offsite dose calculations based 4on our own set of standard assumptions. Our doses 5were slightly higher than TVA's in most cases and our, 6the costs were slightly lower and that's because 7within the document that capital recovery cost, 8there's a range of factors that are given in the 9 guidance. TVA used a factor that's in the middle of 10the range. I used the low end of the range to 11minimize what the cost would be. And even by 12 minimizing the cost and having slightly higher doses 13I did not come to a beneficial cost/benefit ratio. So 14I, you know, verified TVA's conclusion that no 15enhancements to the rad waste systems would be 16 warranted.
17MEMBER ABDEL-KHALIK: Doesn't this 18approach sort of constrain licensees and prevents them 19 from taking advantage of advances in technology?
20MR. PEDERSEN: I don't see the point --
21 no, I don't see how it could constrain them.
22MEMBER ABDEL-KHALIK: I mean, you know, if 23you can't do the cost translation correctly, if you're 24using obsolete numbers and something comes up that it 25 183 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433an advance in technology, if you can't do the 1cost/benefit on apples to apples comparison you're 2 sort of not allowing them to make that comparison.
3 MR. PEDERSEN: The licensees are free to 4add, to go way beyond what we require. It actually 5 constrains the staff as to what we can.
6CHAIR RAY: I think the way to think about 7it is it would be interesting to know what the heck is 8$1,000 in 1975 dollars today. What is it?
9 MR. PEDERSEN: There was extensive bases 10 for coming up with that at the time.
11MEMBER RYAN: But it's out of date 12 dramatically.
13 MR. PEDERSEN: I agree.
14MEMBER RYAN: I mean, the dosimetry is 60 15years out of date and the financial basis is 40 years 16 out of date.
17CHAIR RAY: When you escalate the dollars 18from '75 to today using whatever the, there are 19 different inflation factors you could pick, but when 20 you do that what number do you come up with?
21MR. PEDERSEN: As I said, NRR is going 22through that process right now. They haven't come up 23with a number. They are in the process of updating 24 that $1,000 per man-rem. Not for Appendix I because 25 184 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433this guidance requires this process but the staff 1itself through the backfit rule if we have to backfit 2 a licensee or backfit a requirement on a licensee or 3do rulemaking we have to do a cost/benefit analysis to 4 justify that backfit.
5CHAIR RAY: So one would think that you 6 would know what the number is.
7MR. PEDERSEN: So that updated value will 8 be applied to our own analysis.
9CHAIR RAY: I mean somebody here you would 10think would know what $1,000 in '75 dollars is today.
11 You guys know.
12MR. BRYAN: This is Bob Bryan. TVA has as 13part of their design process a cost/benefit for 14 looking at ALARA changes and we use $25,000.
15CHAIR RAY: Twenty-five? Okay. Well, 16that's a number that I wouldn't quibble with. It's 17 just, you know, hard to -- if as Mike was saying, if 18you're talking to members of the public $1,000 just 19doesn't make any sense, but $25,000 which is the real 20number I presume that one gets when you escalate 1975 21 dollars to --
22 MEMBER SIEBER: That's pushing it.
23 MR. PEDERSEN: There's a range of values 24 that are used.
25 185 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER SIEBER: It's a factor of 10 maybe, 1 but not 25.
2MEMBER RYAN: It clearly costs a whole lot 3 more to save a person-rem than $1,000. Whether it's 4 25 or 50 or some number in that range for various 5kinds of 1 rem savings I'm sure there's a range of 6 numbers. It's not one number.
7CHAIR RAY: Well, $1,000 will translate 8into one single number depending on what escalation 9 factors you want to use.
10 MEMBER RYAN: I understand that.
11 CHAIR RAY: I'm just asking the question 12 what is the number.
13MEMBER ABDEL-KHALIK: A lot less than 14$25,000.15 CHAIR RAY: Okay.
16 MEMBER SIEBER: Maybe 10.
17 CHAIR RAY: I'm not sure. That's a long 18 time and if you compound the --
19MEMBER ABDEL-KHALIK: Still a lot less 20 than $25,000.
21 CHAIR RAY: All right.
22MEMBER STETKAR: The last 20 years 23 inflation hasn't been --
24CHAIR RAY: I just remember when it was 25 186 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433running 18-19 percent. Anyway, but that was 1 construction.
2 MEMBER ABDEL-KHALIK: So would you still 3use that $25,000 per man-rem for things like 4 evaluating zinc addition?
5MR. BRYAN: If we follow our procedure 6 yes, we would.
7CHAIR RAY: Okay. I'm sorry to divert 8 things.9 MR. PEDERSEN: That's my last slide.
10CHAIR RAY: All right. Now, you've got 11two colleagues here but it's now 2:30 and I assume you 12 each have your presentations to make, John first and 13 then Leta.
14MR. POOLE: Well, actually John has his 15 presentation on the accident dose.
16 CHAIR RAY: Right.
17MR. POOLE: Leta is actually here just to 18 support his review, so.
19CHAIR RAY: All right. Well, I thought I 20 saw her name here listed on the meteorology.
21MR. POOLE: Correct, but in preparing the 22 slides we just kind of lumped them all to one.
23CHAIR RAY: All right, that's fine. Well, 24I hate to ask you to do this but if we go through your 25 187 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433presentation we'll wind up running I'm afraid later 1than we should to take a break so I need to give 2 people a break here and we'll do that for -- until 20 3 minutes to the hour, and then we'll resume. For the 4 balance of the day.
5 (Whereupon, the above-entitled matter went 6off the record at 2:27 p.m. and resumed at 2:41 p.m.)
7 CHAIR RAY: So let's do that and we have 8one more two-part presentation I guess from the staff.
9 So let's proceed with that, Justin.
10 MR. POOLE: Okay. Yes, the next part of 11the presentation is to go over the status of the 12design basis accident dose consequence evaluations.
13With me I have John Parillo and Leta Brown who are 14 both from the Accident Dose Branch. John?
15MR. PARILLO: Okay. My review focused on 16identifying the difference between Watts Bar Unit 1 17and any changes that were made for Watts Bar 2. So 18 basically I asked the applicant to identify for each 19 accident all the major inputs and show, you know, in 20 table form what that value is for Unit 1 and what it 21is for the Unit 2 and explain any differences. So 22that, they did that and kind of condensed the major 23differences on this slide. We've already talked about 24 the updated atmospheric dispersion coefficients, chi 25 188 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 over Q's, and of course the differences in the steam 1 generators which affect mainly the releases from the 2secondary side. And of course this Unit 2 at least 3 right now is not intended to be licensed for tritium 4production so that affects source term for the 5 accidents. And the updated dose conversion factors 6which resulted in a lower dose equivalent iodine, that 7 should say tech spec limitations on the primary 8 coolant. And the other difference was that for Watts 9Bar Unit 2 they added some release scenarios, 10additional release scenarios for the fuel handling 11accident, and in those additional release scenarios 12they incorporated the insights from the alternative 13 source term using Reg Guide 1.183.
14MEMBER RYAN: John, can we just clarify 15the iodine point you made? The lower dose equivalent 16iodine coolant values means the concentration allowed 17 in coolant is low.
18 MR. PARILLO: Is low.
19MEMBER RYAN: Because the dose conversion 20 factor went up.
21MR. PARILLO: Because, yes, when -- if you 22have a given mixture -- and for dose equivalent iodine 23they restrict it to iodine-131 through -135, so you 24look at those five isotopes. And for a given mixture 25 189 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 if you use the DCFs from ICRP 2 which is also what's 1in the old Technical Information Document 1844 you 2will come out with a higher dose equivalent iodine-3 131.4 MEMBER RYAN: Per unit activity.
5 MR. PARILLO: Yes, for that same, and if 6you look at that same concentration and you use 7updated dose conversion factors you'll come up with an 8 actually fairly significantly lower --
9 MEMBER RYAN: Lower dose.
10MR. PARILLO: So when that translates you 11end up with a more restrictive tech spec. And they 12have actually which I was going to get to a little 13 later is they have very restrictive coolant activity 14tech spec limits, both for the long-term operation and 15for the iodine spike, the short-term relative to many 16 other plants.
17MEMBER RYAN: Thanks for clarifying. I 18think it's very important for folks to get right 19 what's getting bigger and what's getting smaller and 20 all of that.
21 MR. PARILLO: Right. And of course that 22has -- as a reviewer to me I thought it was worthy to 23mention that the offsite dose, and this slide says 24 just offsite but it's actually true for control room 25 190 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 as well, that all of the dose consequences for Watts 1Bar 2 are low relative to the acceptance criteria.
2And there's a couple of reasons that I listed here in 3my notes for that. One of them is that they have a 4very effective dual containment design so that all of 5the containment leakage is captured and processed 6 prior to release. And also the ice condenser system 7does have beyond the pressure-reducing characteristics 8there is also an iodine absorption that's used and 9 some credit is taken for that as well.
10 CHAIR RAY: John, let me interrupt you a 11 second. Let me ask the applicant, you still refer to 12this as the shield building though, rather than a 13 secondary containment, don't you?
14 MR. BRYAN: Yes. This is Bob Bryan. We 15have a shield building that's the typical annulus 16secondary containment that is typical of many plants, 17but when you get out to the auxiliary building there's 18a large portion of the auxiliary building that is also 19 maintained as a part of the secondary containment 20 boundary. It's kept at a negative pressure relative 21to the outside and it has HEPA and charcoal filters on 22 it. And so the leakage from the containment is 23apportioned 75 percent to the annulus and its 24filtration system, and the other 25 percent is treated 25 191 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 by the auxiliary building gas treatment systems, and 1 that's --2CHAIR RAY: Do you refer to that as the 3 secondary containment?
4MR. BRYAN: The whole thing we call the 5 secondary containment boundary.
6CHAIR RAY: You do? Both the shield 7 building and the portion of the auxiliary building?
8 MR. BRYAN: Yes. And the design was set 9 up so that we had no, at the time no unfiltered out-10 leakage from the plant.
11 CHAIR RAY: All right, thanks.
12MR. PARILLO: Thank you, Bob, you just 13covered my next point which I was going to mention 14 that not only is all of the things that Bob mentioned, 15but those filtration units are also very robust. They 16 have two carbon beds in a series and per our 17regulatory guides are allowed to assume 99 percent 18 removal. It's probably higher than that but we cap it 19at 99 percent. So, not only is all of the leakage 20processed but it's processed very effectively. And 21there's probably other reasons but those are the main 22 reasons that I focused on.
23So that, in this particular slide we're 24talking about a loss of coolant accident and the doses 25 192 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433being well within 10 CFR 100.11. Now, when you use 1the term "well within" in the design basis accident 2 dose nomenclature that actually is a defined number.
3 It refers to less than 25 percent and that's usually 4applied to, or not usually, it is applied in a 5 regulatory sense to, for instance, the fuel handling 6accident and also the rod ejection accident and that.
7So the key here is that for the LOCA that in some 8cases was -- used to be referred to as the maximum 9hypothetical accident. That's the accident that 10 actually we're talking about in the regulation where 11the numbers are delineated, you know, a substantial 12 core damage accident. So in the case of Watts Bar 2 13their maximum hypothetical accident, their LOCA 14analysis for dose consequences, their doses are 15 actually less than 25 percent of the 10 CFR Part 100 16 values. That becomes important for the next bullet 17 down. 18 Incidentally then, getting back to their 19very restrictive coolant, tech spec coolant values 20 helps them in terms of the main steam line break and 21 the steam generator tube rupture. Their doses there 22are well below the applicable regulatory requirements.
23So, and that's directly related to the restrictive 24 tech specs that they have on the coolant.
25 193 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 Now, in terms of this next bullet on the 1rod ejection accident the applicant's statement was 2that the rod ejection accident was bounded by the 3 LOCA. And of course in terms of the source term 4release that's an obvious, you know, obvious statement 5that you're going to have a much more, you know, 6energetic release in a LOCA. But the complication 7 becomes in terms of in regulatory space, at least in 8the regulatory guide space is that the accepted 9criteria for the accident is different. For the LOCA 10 we accept the full 100 value, but for the rod ejection 11 accident we say it has to be well within. So that's 12 why the first bullet is important, that the LOCA for 13 Watts Bar 2 actually has doses that are well within.
14 So if you go through the logic then their conclusion 15that the rod ejection accident would be bounded by the 16LOCA then makes sense both from the release of fission 17products and also the, you know, how that affects 18where you are in relation to the regulatory limit for 19 the accident. So I hope I didn't confuse anybody on 20 that.21 CHAIR RAY: No.
22MR. PARILLO: Okay. And the other 23difference had to do with the way Watts Bar 2 has 24looked at the fuel handling accident. And I was a 25 194 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 little sloppy when I made this slide, so. The first 1bullet should read, the first scenario, release 2 scenario should read, "The containment closed to the 3auxiliary building with credit for the reactor 4building purge ventilation system filtration" which is 5another filter system. They use very conservative, 6 took credit but not much credit for that system 7because of concerns with humidity. So that, but that 8 was using, when I say traditional assumptions I mean 9 non-alternative source term assumptions and used the 10whole body and thyroid dose criteria. So that was the 11 first release scenario and that was pretty much more 12akin to what's in the licensing basis for Watts Bar 13 Unit 1. 14 Then the next two were additional 15scenarios that they evaluated. And for release in the 16spent fuel pool in the auxiliary building with no 17credit for filtration using the alternative source 18term assumptions and with the dose acceptance 19expressed in terms of total effective dose equivalent 20instead of the whole body and thyroid. And the third 21release, again this was -- should read "The 22containment open to the auxiliary building with no 23credit for filtration." And that was also done using 24the alternative source term and of course the TEDE 25 195 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433acceptance criteria. And all of these scenarios meet, 1again, this is -- for fuel handling accidents we also 2 use this well within, so less than 25 percent of the 310 CFR 100.11 limits. And so that's, you can go to 4the next. So the conclusion is that design basis 5 accidents predict doses within applicable regulatory 6 acceptance criteria and that we didn't have any open 7 items for this portion.
8CHAIR RAY: All right. Any questions?
9 Okay. Was there anything more to be said on the 10 meteorology?
11 MS. BROWN: No.
12 CHAIR RAY: Okay.
13 (Laughter) 14MS. BROWN: There were no questions as far 15 as I understand it.
16MR. PARILLO: She already asked him all 17 the questions.
18 CHAIR RAY: Okay.
19 MR. PARILLO: Thank you.
20CHAIR RAY: Thank you. Justin, do you 21 have anything more before we turn to open items?
22 MR. POOLE: Not really. Take one minute 23 here. Just the summary of what we have remaining, and 24we've kind of already gone over this for the most 25 196 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 part. The staff review is nearing completion. Some 1of the future milestones are listed here on this 2 slide, doing the SER and issuance of a license. I'm 3sorry, issuance of the final environmental supplement 4 for the license. Completing our ACRS review. Going 5through ASLB and then some regional items regarding 6 operational rate assessment and the certification of 7 as-built.
8For the next meeting, as we said before we 9have the next subcommittee meeting scheduled for April 10 of 2012. The main focus will be fire protection and 11 closure of open items. So I think at this time is 12 probably a good spot that we.
13CHAIR RAY: Yes, I want to review the open 14items and if there are any public comments open the 15phone line, and with that we'll probably be done. So 16if I could ask members to, and anybody else turn to HH 17in the SSER 25 appendix where the open items are 18 listed. As Justin explained earlier the confirmatory 19 items reflect staff agreement where some action is 20still required to be taken and the vast majority of 21 items open simply to ensure that it is in fact done as 22agreed upon. So it's not my intention to focus on the 23confirmatory items but if anybody has anything they 24want to comment on about a confirmatory item please 25 197 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 speak up. But all I want to do is go over the other 1open items and see in a little more pedantic way if 2 there's anything here that needs to be on the agenda 3 for the next and potentially final, but that'll have 4 to be seen, subcommittee meeting.
5 So the first one I see that's not a 6confirmatory item is listed here, is 12 on page 2, and 7refers to an audit to verify implementation of some 8 requirements. Thirteen, IST program before OL 9 issuance. Normally we would not review that. Sixteen 10 has to do with the environmental qualification and 11again presumably we are not concerned with any review 12 there. Seventeen, similarly. Twenty-three is a 13confirmatory item. Twenty-five has to do with 14insurance, not a matter of concern to us. Twenty-six 15has to do with an accident in one unit, concurrent 16shutdown of the second unit without offsite power.
17Unit 2 pre-op testing will validate diesel response 18sequencing loads on Unit 2 emergency diesel generators 19and the staff will evaluate the status of this issue.
20Again, it appears the requirements are clear enough 21 and this is really in the form of test performance.
22Thirty has to do with degraded voltage 23 relay setpoint dropout settings and the confirmation 24 the tech specs are properly derived from those. Not 25 198 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433something we would review I don't believe. Thirty-1two, emergency diesel generator voltage and speed 2 range and so on having to do with tech spec 3surveillance requirements. Nothing there I don't 4 think. Next one is confirmatory item then there's 35, 5information concerning feedwater purity requirements.
6I don't have any interest in seeing that come here 7unless somebody else does. Then we've got a series of 8confirmatory items till you get over to 47 which is a, 9let's see. It's a water-sealed valve leakage test 10results and a discrepancy that existed needs to be 11 resolved there. That doesn't appear to require ACRS 12 further review.
13Confirmatory items till you get to 59.
14ESF system materials with containment sprays and core 15 cooling in the event of a LOCA is incomplete pending 16resolution of GSI-191 which raises a question I've 17 been intending to find a place to ask and that is to 18direct to Justin. What's the outlook on 191 as far as 19 Watts Bar 2? Why all this concern? Is it treated 20 like an operating plant from the standpoint of 191?
21 MR. MILANO: Yes.
22 CHAIR RAY: Yes, Pat.
23MR. MILANO: Yes, we are doing the review 24 of GSI-191. Actually, the staff has already drafted 25 199 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 a relatively complete safety evaluation for GSI-191.
1However, there is one outstanding issue as it relates 2to all the plants and that's the treatment of in-3vessel effects. And that's what's been holding us up 4from issuing a safety evaluation to resolve that.
5 What we, we have been in dialogue with TVA and we've 6been, not to say that this is going to be the staff 7approach but one of the things we're thinking about is 8as you've heard in the past TVA did a lot with the 9Unit 2 containment to remove all the fibrous material 10and basically we consider it to be a zero fiber plant.
11 So the --12 CHAIR RAY: Call it a low-fiber plant.
13MR. MILANO: A low-fiber plant. And so 14one of the things that we have been conversing with 15 TVA on is for them to come in with some type, barring 16the staff's ability to generically resolve the in-17vessel effects issue and the methodology that TVA 18 would come in and make an argument, you know, with 19regard to the minimal fiber and the fact that what its 20 impact is on, you know, in-vessel effects. And that 21 it's, that we could make some type of reasonable 22assurance decision in advance of, you know, of a more 23generic review of it. And that's one of the things 24we're thinking about doing but I can't say at this 25 200 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 time for sure.
1CHAIR RAY: All right. Let's identify 61 2 as one that we'd like a status on at the next 3 subcommittee meeting.
4MR. SHUKLA: But I would note that Unit 2 5 is different than Unit 1.
6CHAIR RAY: Of course. Am I confusing 7 them somehow?
8 MR. SHUKLA: No.
9MR. POOLE: Just to clarify, you're 10 actually talking about number 59.
11 MR. MILANO: Fifty-nine.
12CHAIR RAY: Oh, was I? Okay. I've got my 13finger on the wrong thing here. I'm sorry. I was 14 going to ask Said about 61, that's why.
15MEMBER ABDEL-KHALIK: Well, we have a very 16 large margin as far as the peak clad temperature for 17a large-break LOCA but I think it would still be 18interesting to find out what the result of that 19 discrepancy will be.
20CHAIR RAY: All right, so you'd like to 21 treat it similar to 59 --
22 MEMBER ABDEL-KHALIK: Correct.
23CHAIR RAY: -- which I meant to refer to.
24 All right. Okay, that confirmatory item still 65.
25 201 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER BROWN: Sixty-three, even though 1it's a confirmatory item, it's -- I don't know how to 2differentiate between that and 93. They are both 3 addressing the same issue so they kind of go hand in 4 hand.5CHAIR RAY: Okay. Would you like 6 discussion of that?
7 MEMBER BROWN: Well, yes.
8 CHAIR RAY: For a status?
9MEMBER BROWN: Yes, it's hand in hand with 10 93. I think if you do one you've got the other one.
11 CHAIR RAY: All right.
12MEMBER BROWN: If I understand 93 13 correctly. I don't know that 93 is, that's an NRR 14 resolve. This one is a region. They're both -- 93 is 15also Region II. Yes, they ought to be lumped 16 together.
17CHAIR RAY: Okay. Now do you want to say 18 anything more about what your interest is so that we 19 get the right information?
20 MEMBER BROWN: Am I supposed to remember 21 what I said earlier?
22 CHAIR RAY: Only if you want to.
23MEMBER STETKAR: The answer is no, you 24 don't want to say anything more.
25 202 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER BROWN: The answer is whatever I 1said in the transcript is what I'd like to hear about.
2 I thought I was fairly complete.
3 CHAIR RAY: All right.
4MEMBER BROWN: Some of that involves 5staff, I mean Region II and some of it involves staff.
6 CHAIR RAY: Enough.
7 MEMBER BROWN: Yes, enough.
8CHAIR RAY: All right, 65 is the next 9 item. I'm not sure what the heck it's about.
10MEMBER BROWN: I was going to ask. I 11 don't know what WCAP-13869 is, so.
12MR. POOLE: All it was was there was a 13difference between -- I don't recall what the WCAP is 14 either.15 MEMBER BROWN: It's a check --
16MR. POOLE: It's an I&C. Right. But 17there was just a difference between, and the Unit 1 18 was using one revision and Unit 2 was using another.
19 CHAIR RAY: All right.
20MR. POOLE: Staff has actually -- already 21 has one closed for 36.
22MR. SHUKLA: Gentlemen, I think Mr. Brown 23 was interested in number 64 also.
24 MEMBER BROWN: That's a -- no. I looked 25 203 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433at that. That's a test item. Somebody should read 1the results and they'll know whether it's okay or not.
2 We don't need to see that.
3 CHAIR RAY: All right, thank you. Okay, 4 moving on. Seventy --
5 MEMBER STETKAR: Sixty-seven, but that's 6kind of similar. That's the whole probable maximum 7flood thing. I mean this is, once you figure out what 8 it is.9 CHAIR RAY: I saw that and --
10 MEMBER STETKAR: That's -- I mean, I can 11 go measure heights.
12 CHAIR RAY: I would think so, yes.
13 MEMBER STETKAR: I would think so.
14CHAIR RAY: All right. Seventy, that 15doesn't appear to be anything requiring ACRS attention 16or review. Seventy-one I thought was kind of 17 interesting but I don't want to ask for review here.
18 Seventy-seven --
19MEMBER BROWN: What's HRCAR? HRCAR 20 monitors. Are those atmospheric? Are they radiation 21 monitors?22MR. MILANO: High-radiation containment 23 atmospheric monitors.
24 MEMBER BROWN: Okay.
25 204 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER SIEBER: High-radiation containment 1 area monitors.
2 MEMBER BROWN: All right.
3 CHAIR RAY: Okay. Pass on that?
4 MEMBER BROWN: Yes, I'll pass on that.
5 CHAIR RAY: Seventy-nine.
6MEMBER BROWN: Unless Mike wants me to do 7 something.
8 MEMBER RYAN: They're okay, Charlie.
9 MEMBER BROWN: You happy?
10 MEMBER RYAN: I'm happy.
11 MEMBER BROWN: Thank you.
12 CHAIR RAY: Okay, 79 deals with the same 13 monitors. Any different comment there? I take it 14 not.15 MEMBER BROWN: No.
16 CHAIR RAY: And then there's a how do we 17meet this reg guide in number 80. Pass on that.
18Eighty-one, compliance with EPRI document here for 19staff review again wouldn't normally come to us I 20don't believe. Moving down to 91. This is one that's 21a little more interesting and do you want to say 22 something, John, about it?
23MEMBER STETKAR: No, I don't because I 24 don't remember what it's all about.
25 205 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 CHAIR RAY: All right. Let's add it to 1 the list.2 MEMBER STETKAR: We probably should hear 3 about it.4CHAIR RAY: Yes. So 91 is something we 5want to hear about. Ninety-three we've covered, thank 6 you. Ninety-four, you're satisfied with that?
7MEMBER BROWN: Yes. These are roughly, 8we're going to go through the IEEE standards and 9confirm that they meet the specific requirements of 10 the IEEE spec.
11 CHAIR RAY: Same on 98 and 101?
12 MEMBER BROWN: Because 93, 94, 95.
13 CHAIR RAY: There isn't any 95.
14MEMBER BROWN: I'm sorry, 98, 101, 105, 15 108. I went through these, I didn't see any reason to 16--17 CHAIR RAY: Okay.
18MEMBER BROWN: -- to pull harder on those.
19MEMBER RYAN: That includes 110 and 111 20 too.21 MEMBER BROWN: Including 110 and 111.
22CHAIR RAY: Yes, all right. Then we have 23confirmatory items down to 118. I don't know, it's --
24Said, do you have any interest in that? I'm not sure 25 206 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 what the heck.
1MR. MILANO: That's the wind size fixed in 2 core probes.
3 CHAIR RAY: Yes. Would be operable 4following failure of SPMD. Care about that? All 5 right. One twenty, John?
6 MEMBER STETKAR: No.
7CHAIR RAY: All right. One twenty-one, 8 no. One twenty-three, no. One twenty-five, no. EQ 9testing, yes. One twenty-six? Yes, that's right. It 10 just didn't say -- it says environmental 11 qualifications.
12MEMBER STETKAR: They decided to spell it 13 out.14CHAIR RAY: All right. One twenty-seven.
15 MEMBER STETKAR: No.
16 CHAIR RAY: Okay. One twenty-nine?
17MEMBER BROWN: That's for minimally 18insulated cable on 127, right? Is that right? Is 19 that what you're talking about, MI cable?
20 MR. MILANO: Yes.
21 MEMBER BROWN: Okay.
22 CHAIR RAY: One twenty-nine seems pretty 23far down in the weeds. One thirty-one. While I'm 24trying to ponder that one do you have some thought 25 207 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 about it, 131?
1MEMBER STETKAR: No, that's just making 2 sure that --
3 CHAIR RAY: Yes. Got the right numbers.
4MEMBER STETKAR: They've got the right 5 numbers in the EOPs to take action.
6 CHAIR RAY: One thirty-two.
7 MEMBER STETKAR: Yes.
8 CHAIR RAY: Okay, add that to the list.
9MEMBER STETKAR: That's the boron 10 dilution, basically timing analysis.
11CHAIR RAY: Okay, 132 is on. One thirty-12 three?13MEMBER STETKAR: I'd say 133 and 134 14 together. They're part of the flood stuff.
15 CHAIR RAY: Yes, and again, there's both 16an interest in -- we've got the right action being 17taken but more profoundly why are we doing it the way 18 we're doing it. And I think, I mean I could provide 19 an answer but because we're putting in the Unit 2 OL 20 stuff that the basis of which isn't there, it's 21elsewhere, we want to understand clearly are we doing 22 the right thing here in adopting this time sequenced 23 license condition that says at certain points in the 24future we're going to provide, basically change the 25 208 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 licensing basis over time. And I think I understand 1 all that I need to on that, I just want to make sure 2 that I understand what the staff's thinking about it 3is, and for sure we're going to want to recognize this 4in the letter that we write and I want to get it 5 right. Okay.
6MEMBER ABDEL-KHALIK: Mr. Chairman, there 7is something I'm interested in. I don't know if 8 you've had the opportunity to review it in the past 9since I haven't been attending these subcommittee 10 meetings and that pertains to the turbine-driven aux 11 feedwater pump room heat-up during station blackout.
12CHAIR RAY: Certainly not. And the reason 13I said it the way I did was you said during station 14 blackout. And you were thinking about the station 15 blackout that is the existing licensing basis?
16 MEMBER ABDEL-KHALIK: Correct, correct.
17 CHAIR RAY: Okay.
18MEMBER ABDEL-KHALIK: We just want to see 19whether that is actually limiting as far as station 20 blackout coding time.
21CHAIR RAY: So it's the heat up of the --
22 MEMBER ABDEL-KHALIK: Turbine-driven aux 23 feedwater pump room.
24CHAIR RAY: Interesting, okay. So make a 25 209 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433note of that, Girija. All right, I think the last one 1 here is 134 or did we cover that as part of the -- we 2 did. Okay. So that's all the non-CI items in the --
3MR. SHUKLA: Can I just go over quickly on 4 the exact numbers?
5 CHAIR RAY: No.
6 (Laughter) 7 CHAIR RAY: Use the transcript. I'm not 8going to go through it again. I mean, you know, we do 9it once. I'm not going to do it again. So with that 10 I think we're to the point where we'll ask whether 11 staff or applicant have anything more, and we'll ask 12for any public comments before I quit. You guys have 13 anything else?
14 MR. POOLE: We have nothing else.
15 CHAIR RAY: Applicant?
16 MR. KOONTZ: Mr. Chairman, this is Frank 17 Koontz again. We do have one open question and that 18was the main steam line break pressure inside 19 containment and it's 9.29 psig.
20 MEMBER ABDEL-KHALIK: Thank you.
21CHAIR RAY: Okay. Girija, can we get the 22 telephone line open in case there's somebody that's 23been sitting there wanting to speak to us. It's open, 24is it? Is there anyone on the phone line who would 25 210 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 wish to make a comment to us?
1MR. SHUKLA: There is only one staff 2 person was online and he's not needed anymore.
3 CHAIR RAY: Okay. But you never know.
4 MR. SHUKLA: Yes.
5CHAIR RAY: Somebody may call in. All 6 right, and there's no one here in the audience who's 7asked for an opportunity to speak to the subcommittee?
8 Okay, with that then let's go around the table here 9and see if we've captured everything that everybody 10 wants to talk about and we'll adjourn. Charlie?
11 MEMBER BROWN: No.
12 CHAIR RAY: Mike?
13MEMBER RYAN: Nothing further, Mr.
14 Chairman.15 CHAIR RAY: Okay. John?
16 MEMBER STETKAR: Nothing.
17 CHAIR RAY: Said?
18 MEMBER ABDEL-KHALIK: Nothing.
19 CHAIR RAY: Dick? Jack?
20 MEMBER SIEBER: Nothing to add.
21CHAIR RAY: All right. I have nothing to 22 add. With that we will adjourn.
23 (Whereupon, the above-entitled matter went 24 off the record at 3:15 p.m.)
25 1ACRS Subcommittee Meeting Regarding Watts Bar Nuclear Plant Unit 2 Status of Licensing and Inspection Docket No. 50-391 December 15, 2011 2 Agenda Topics
- TVA- Construction Completion Status
- Meteorology and Radiation Protection (FSAR 11 & 12)
- Radiological Consequences of Accidents (FSAR 15.4)
- Accident and Transient Analyses (FSAR Chapter 15)
- NRC- Status of Licensing and Construction Inspection
- Status of Open Items
- Supplements 24 and 25 to SER
- Remaining Safety Review Activities 3 Region II Presentation of Status of Construction Inspection Activities 4 Results of Inspection Program
- Completed 2011 Mid-Cycle review. Overall acceptable performance noted. Three areas highlighted:
- Inadequate corrective action for historical items (violation with four examples)
- Resolution of Heinemann circuit breakers
- No substantive cross-cutting issues
- Twelve (12) severity level IV violations identified in 12-month period. Violations included design control, corrective action, procurement, and procedural
compliance issues.
- No escalated enforcement or civil penalties.
5 Inspection Program Updates
- RII expended 17,279 staff hours on the project in FY11, an increase from 13,119 hours0.00138 days <br />0.0331 hours <br />1.967593e-4 weeks <br />4.52795e-5 months <br /> in FY10. Expect 2012
hours will be similar to 2011.
- Continuing with four (4) WB2 construction resident
inspectors
- In addition to the resident inspectors, 41 inspectors
performed inspections in 2011
- Four (4) positions in RII (team leader, project
inspectors, and project manager) assigned to the WB2
inspection project
- Conducting periodic public meetings with TVA near the site (four meetings held in 2011) 6* Approximately 532 construction inspection items in the Inspection Planning and Scheduling (IP&S)
- Closed 154 IP&S items
- Most of the remaining IP&S items have been inspected, but require additional effort to close
- Closed eight (7) Corrective Action Programs and
Special Programs, many (8) sub-issues also closed
- TVA's scheduling uncertainties have challenged our inspection planning and staffing allocations Status of Inspection Activities 7* Team leader focusing on planning for pre-operational testing inspections
- Two major sections: Testing and Operational
Preparedness Inspections
- Lead inspectors assigned to mandatory tests (six) and primal test (nine) inspections
- Operational Preparedness inspections assess management controls and procedures. Examples:
radiation protection; chemistry; security; fire protection, etc.Pre-Operational Testing Inspections 8 NRR Presentation of Status of Licensing Activities 9 Status of Operating License Application
- Supplements to original Safety Evaluation Report
- SSER 21 - identifies regulatory framework
- SSER 22 - FSAR Chapters 2, 3, 5, 6, 8, 9, 10, 13, 14, 17
- SSER 23 - FSAR Chapters 4, 7
- SSER 24 - FSAR Chapters 2.4, 11, 12, 13.6.6, 15
- SSER 25 - FSAR Chapters 15.4
- Major Review Areas Remaining
- Fire Protection Report
- Closure of open items from SER review Status of Open Items
- Total Open Items - 124 (some numbers never used)
- Open Items closed as of SSER 25 - 41
- Of the 83 that remain open
- Items requiring NRC confirmation (e.g., updating FSAR): 43
- Items requiring additional NRC evaluation (e.g., additional information required from TVA to complete staff review): 40 10 Safety Evaluation Report Supplements (SSERs)
- SSER 24 Published September 2011
- SSER 25 Published November 2011 11 12 Status of Radiation Protection Radiation Protection (CH 12)
- Containment Airborne Estimates
- Area Airborne Monitoring in Aux. Bld.
- Four portable monitoring channels vice fixed
- Area Monitor Operability Test frequency
- 95% / 95% acceptance criterion
- Descriptions of HP Support Facilities
- Annual Dose Assessment & Vital Area access
- RPM Qualifications
- Committed to RG 1.8 - 1987 13 Plant Effluents (Ch 11.1, 11.2, & 11.3)
Liquid* S/G tube leakage added to liquid source term to meet concentration limits in 10 CFR 20 and RM 50-2.
- Above 3.65E-5 uCi/cc :
Blowdown processed (CD)
- Above 3.65E-5 uCi/cc : processed (CD + MD)
- Less than 3.65E-5 uCi/cc : unprocessed
- Updated calculations of doses from liquid effluents
- Latest Census and Land-Use Survey
- Minimal change to 10 CFR 50 App. I doses 14 Plant Effluents (Ch 11.1, 11.2, & 11.3)
Gaseous* Update Plant Configuration
- Continuous Containment Filtered Venting not 22 Purges per year (Airborne Source Term)
- Delete Boron Recycle System
- Updated calculations of doses from gaseous effluents
- Latest Census and Land-Use Survey
- Critical milk animal & garden locations
- Meteorology (X/Q, D/Q values), terrain correction
- Staff independent assessment 15 Annual Dose per Reactor UnitApp. I TVA NRC Liquid Effluents Total Body (mrem) 3 0.72 0.64 Any Organ (mrem) 10 1.00 1.49 Noble-gas effluents Gamma Dose in Air (mrad) 10 0.80 0.90Beta Dose in Air (mrad) 20 2.71 3.59 Total Body (mrem) 5 0.57 0.51Skin of an Individual (mrem) 15 1.54 2.60 Airborne Radioiodines /
Particulates Any Organ 15 9.15 9.75 16 RM 50-2 Vs. ALARA Cost/Benefit
- 10 CFR 50 App. I , II.D effluent treatment augmentation cost/benefit analysis
- Exception for plants with 1974-1976 CPs
- RM 50-2 design criteria fore-runner to App. I
- Ex.: Maximum Organ Dose - 15 mrem per site (RM
50-2) Vs. 15 mrem per unit (App. I)
- WBN organ dose is 9.15 mrem per unit (18.3 per site)
- Meets App. I, not RM 50-2 17 Reg Guide 1.110 Cost/Benefit Analysis
- Provides a list of radwaste system enhancements
- Annualized costs (capital, labor, operating, &
maintenance)- Constant 1975 $$
- $1,000 per person-rem saved - population within 50 miles of site
- Staff independent analysis- Slightly higher doses, slightly lower costs- Verified TVA conclusion; no augments warranted 18 19 Status of Design Basis Accident Dose Consequence Evaluations 20 Major Differences from WBN Unit 1 Licensing Basis
- Updated Atmospheric Dispersion Coefficients
- Original vs. Replacement Steam Generators
- No Tritium-Producing Burnable Absorber Rods (TPBARs) since Unit 2 will not be licensed for tritium
production
- Updated Dose Conversion Fa ctors resulted in lower Dose Equivalent Iodine coolant values
- Fuel Handling Accident analyzed for different release
scenarios using the Alternative Source Term (AST) 21 Off-site dose consequences are low relative to acceptance criteria
- Loss of Coolant Accident (LOCA) doses are "well within" 10 CFR 100.11 values (<25%)
- Main Steam Line Break (MSLB) & Steam Generator Tube Rupture (SGTR) doses are a "small fraction" of 10 CFR
100.11 (< 10% ) for both pre-existing and accident
generated iodine spike cases
- Control Rod Ejection Accident (CREA) bounded by
LOCA; LOCA dose meets the acceptance criteria for CREA, "well within" 10CFR100.11 values (<25%)
Fuel Handling Accident (FHA) analyzed for three release scenarios
- Closed Containment with credit for filtration using traditional assumptions with whole body and thyroid
dose acceptance criteria
- Auxiliary building with no credit for filtration using AST
assumptions with Total Effective Dose Equivalent (TEDE) acceptance criteria
- Open containment with no credit for filtration using AST
assumptions with TEDE acceptance criteria
- All FHA scenarios meet "well within" (25%) for either 10 CFR 100.11 or 10 CFR 50.67 dose acceptance criteria 22 Conclusions
- Design basis dose consequence analyses predict doses within applicable regulatory acceptance criteria
- No open items in the area of design basis dose
consequence analyses 23 24 Section 15: Transient and Accident Analyses Section 15, Transient and Accident Analyses
- Agenda Topics
- Review Procedures
- General Results
- Challenging Review Areas
- Conclusions 25 Review Procedures
- Reference the licensing basis of Watts Bar Unit 1
- Ensure that analytic methods are used within the limits of the staff's approval
- Compare results to similar plants
- Additional information was requested to aid in the review of challenging areas:
- Several rounds of RAIs were issued
- Additional analyses were requested
- Two audits were conducted
- First audit - March 15 th in Rockville, MD
- Second audit - June 28 through 30 in Cranberry, PA 26 27 General Results
- Most results were acceptable w/o further information
- Analyses performed using NRC-approved methodology
- Analyses were continually reviewed since the Unit 1 application
- Results acceptable with margin to acceptance criterion or
regulatory limit
- Results for five accident analyses presented some review challenges 28 Challenging Review Areas
- 1. Overpressure protection analysis
- 2. CVCS malfunction event
- 3. Inadvertent ECCS actuation at power
- 4. Boron dilution in Modes 3, 4,and 5
- 5. Main steam line brea k
- 1. Overpressure Protection
- SRP 5.2.2 specifies that adequate overpressure protection be demonstrated for the limiting event (loss
of load)
- Analysis should be based upon a reactor trip from the
2 nd trip signal
- Analysis was based upon reactor trip from 1 st trip signal
- TVA re-analyzed the loss of load, assuming reactor trips on the 2 nd trip signal
- Results of re-analysis show that RCS and MSS pressure safety limits are not exceeded 29
- 2. CVCS malfunction event
- The event is listed in RG 1.70, Rev 2
- The event is not bounded by the inadvertent ECCS
event* TVA provided an analysis
- Results indicate there is adequate time for manual
mitigation 30
- 3. Inadvertent ECCS actuation
- Analysis was unacceptable, as expl ained in RIS 2005-029
- TVA provided a re-analysis
- Results indicate there is adequate time for manual mitigation 31
- 4. Boron Dilution in Modes 3, 4, and 5
- RG1.70, Revs 0 and 1, required explicit Boron Dilution calculations in Modes 1, 2 and 6. Subsequent revisions RG 1.70 added requirements to consider in all 6 modes
- SRP 15.4.6 calls for analysis of event in all modes
- Analyses inconsistent with SRP since only Modes 1, 2, and 6 analyzed* Open Item for TVA to provide analyses of boron dilution event that meet the criteria of SRP Section 15.4.6, including
- Description of the methods and procedures used by the operators to identify the dilution path(s) and terminate the dilution in order to determine analyses comply with GDC 10
- Time available for manual action begins at start of event 32
- 5. Main Steam Line Break
- Results were too good (compared to similar plants)
- Results were inconsistent with the conclusions of WCAP-9226* Results were deconstructed, at the 2 nd audit, to explain the contribution of each key assumption and parameter
- A new limiting-case analysis was provided 33 Staff Review Conclusions
- Staff draws a reasonable assurance conclusion with the same, or higher confidence, as compared to the Unit 1
review* Some changes in the Unit 2 licensing basis must also
apply to the Unit 1 licensing basis
- Westinghouse's steam line break analysis methods should be updated 34 35 Project Summary of Watts Bar Unit 2 Remaining Activities Project Status
- Staff review nearing completion
- Future Milestones
- Complete SER and SFES-OL
- Complete ACRS Review
- Conduct hearing and ASLB provide decision
- Operational readiness assessment
- Certification of as-built construction 36 Expectations for Next Meeting
- Scheduled for April 2012
- Fire Protection
- Closure of Open Items 37 1 WBN Unit 2 ACRS Presentation December 15, 2011 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT UNIT 2
2 Agenda Watts Bar Status Update
- Dave Stinson Meteorology and Radiation Protection
- Robert Bryan Radiological Consequences of Accidents (Chapter 15.4)
- Robert Bryan Transient Analysis (FSAR Chapter 15)
- Frank Koontz Questions Watts Bar Unit 2 Status 3
WBN2 Completion Status Project Status Update
-Safety -Quality -Safety Conscious Work Environment Organizational Structure / Alignment Appendix HH Status 4
SAFETY - Highlights Highlights
-Over thirteen million safe work hours since the last lost time accident (3/10/2010)
-Fiscal Year 2011 Worked 7,409,301 hours0.00348 days <br />0.0836 hours <br />4.976852e-4 weeks <br />1.145305e-4 months <br /> with a total of eighteen recordable injuries (0.49 injury rate)
Over 28,426 Supervisor's Safety Observation performed The craft turned in 1,718 intervention cards 5
Organizational Structure / Alignment The Bechtel and Williams Services contract facilitated a change to a new organization structure.
Organization revised to reflect TVA's leadership role with responsibility for -Assigning work priority
-Day-to-day direction
-Schedule performance Key vacancies have been identified.
Several highly experienced people recruited and on board Plan for remaining key vacancies has been developed and is in work in conjunction with Human Resources Next steps include Bellefonte Nuclear site transition plan 6
Organizational Structure / Alignment 7
QUALITY The Bechtel Quality Assurance Program and Manual remain in place for construction completion Program includes all quality control inspections, quality assurance audits and surveillances Inspection results are monitored by activity and craft for recognition of trends and required corrective actions Document review results are monitored and fed back to originating organization Line organizations develop corrective actions for recognized trends and common issues TVA Quality Assurance manager provides oversight for the program 8
SAFETY CONSCIOUS WORK ENVIRONMENT (SCWE) 9 Maintain improvements in the overall work environment
-Communication
- from management to all employees
-Allowing time to listen
- keeping the door, and the ears, open
-Casual monitoring of the environment by Employee Concerns Program (ECP)
- monitoring by walking around and engaging people -High visibility of ECP
- be seen in the plant and in meetings to develop familiarity that leads to trust Ensure the SCWE message is rolled into the daily business focus with the same importance and acceptance as safety and quality
- weekly SCWE focus message for the project Timely resolution of issues brought to the ECP
SAFETY CONSCIOUS WORK ENVIRONMENT (SCWE)
Highlights
-Improved Allegation Performance 2011 over 2010 Calendar Year 2010
- twenty-six onsite Calendar Year 2011
- four onsite, as of 9/30/11
-January - one -February - one -August - one -September
- one 10 TURBINE BUILDING PHOTOS 11 TURBINE BUILDING PHOTOS 12 TURBINE BUILDING PHOTOS 13 TURBINE BUILDING PHOTOS 14 STARTUP & TESTING
- Goals Developed a comprehensive testing program to demonstrate plant and system performance meet design requirements.
The program ensures:
Regulatory requirements are met Final Safety Analysis Report (FSAR) Chapter 14 requirements are met Individual components are tested in accordance with industry standards and show readiness for pre
-operational testing Thorough demonstration of systems' performance against design requirements Test conduct does not impact the operation of U1 15 Component level testing (circuit checks, valve strokes, motor runs, calibration)
-Current count is 8316, currently 23% complete
-Challenged by unit interface program restoration and support systems (control air)
System flushing Preoperational test and Acceptance test performance
-PTI governed by RG 1.68 and FSAR
-43 of 119 procedures approved, two test procedure performances completed
-Overall procedure generation is 71% complete (20 in Joint Test Group (JTG) review cycle) All testing/flushing performed by Startup under New Generation Development and Construction (NGDC)
Thirty-eight of eighty
-six systems turned over to startup Four system turnovers completed to Nuclear Power Group, two more scheduled by end of year STARTUP & TESTING
- Overview 16 START-UP & TESTING
- Current Status Current Status
-Refueling Water Storage Tank (RWST) and Primary Water Storage tank filled to pump suctions
-Condensate and feed water in service via condensate hotwell pump, booster pump runs in progress
-Condenser circulating water in service
-Raw cooling water in service
-Generator and Main Turbine oil systems placed in service weekly for turning gear operation
-Annunciator and computer systems in service
-Solid state protection / Eagle racks and Foxboro I/A ready for calibrations
-Main feed water pump (MFWP) oil systems filled to support feedwater flushing -Control air flushing in progress and being placed in service to loads 17 Transition to Operations Management Review Meetings (Oversight by Chief Nuclear Officer (CNO), VP of Operations, Nuclear Safety Review Board (NSRB)
Permanent Staffing Additions -Licensed and Non
-Licensed Operators
-Maintenance Craft Training
-Dual Unit Licenses
-Unit Differences Training Work Management
-Preventive Maintenance
-Surveillance Scheduling
-Functional Equipment Groups (FEG's)
-Schedule Convergence
-Refueling Outage Infrastructure after Hot Functional Testing 18 Transition to Operations Procedure Development/Revision System Turnover
-System 30O (Turbine PMP and Space coolers)
-System 30N (Turbine Bldg Exhaust Fans)
-System 37 (Gland Seal Water) Complete
-System 44 (Building Heat) Complete
-TI-437 Lessons Learned Operations Owns the Turnover Process System Turnover Weekly Meeting for Near Term Systems Turnover of In
-Service Systems 19 SSER (22-25) Open Items Examples FSAR Updates Non-proprietary Documents 20 17/14% 14/11% 93/75% SSER Open Items (Appendix HH)
Inspections NRR/RII NRR Examples Verification of installed cable lengths Verify Installation of GL 2008
-01 Vents 41/33% 39/31% 44/36% SSER Open Item Status 12/9/11 Closed Submitted Open Radiation Protection and Radiation Waste Management (FSAR Chapter 11 & 12) 21 Radiation Protection WBN committed to ALARA principles Shielding features are the same as Unit 1 Many features are shared between units
-Labs, Counting Rooms, Access
-Designed for two unit operation NUREG 0737 II.B.2
-Post accident access and occupancy
-Updated vital areas to include Unit 2 22 Radiation Protection Radiation Monitors
-Coverage similar to Unit 1
-Many Unit 2 monitors are used for Unit 1 Ops
-21 new Unit 2 monitors
-Channel Op Tests extensions to be supported by experience
-Local CAM previously replaced with portable monitors 23 Radioactive Waste Management Radwaste Systems are shared
-Operational flexibility to manage releases
-Condensate demineralizers usually bypassed
-100 CFM continuous filtered containment vent ANSI N18.1
-1984 source term Updated Site Specific Parameters
-1986 - 2005 meteorology data
-2007 land use survey
- Applied terrain adjustment factors
-50 Mile population dose based on 2040 estimate 24 Radioactive Waste Management (cont)
Liquid and gaseous releases
-Well within regulatory limits
-Unit 1 used RM 50 Appendix I for 2 unit operation
-Cost benefit performed Unit 1 operating history
-Actual releases small fraction of FSAR releases 25 Chapter 11 and 12 SSER Open Items Item 112, 113, 114, 115, 116
-Update FSAR
-Completed by FSAR Amendment 105 Item 135 - Perform Radwaste System Cost
-Benefit Study
-Complete - Cost Benefit submitted Item 117 - update FSAR
-Information previously provided
-Open 26 Transient Analysis (FSAR Chapter 15) 27 Chapter 15 Transient Analysis Unit 2 Analyses Generally Similar to Unit 1 at OL
-Original Steam Generators
-No Measurement Uncertainty Recapture LBLOCA & SBLOCA have large margins to PCT Limit of 2200 o F -ASTRUM vs. Appendix K Model 28 Chapter 15 Transient Analysis New Analysis
-Overpressure Protection on Second Trip
-CVCS Malfunction that Increases Reactor Coolant System Inventory
-MSLB Analysis and Parameter Sensitivity Study Additional Analyses
-Inadvertent ECCS
- no Liquid Release from PORVs
-Boron Precipitation Open - Boron Dilution Modes 3, 4, 5
-Same as Unit 1
-Providing additional information 29 Radiological Consequences of Accidents (FSAR Chapter 15) 30 Accident Dose Dose Consequences less than 10 CFR Part 100 and Guidance Document Limits Analyses Based on
-LOCA - Reg. Guide 1.4
-Waste Gas Decay Tank
-Fuel Handling Accident
- Reg. Guide 1.25 and Reg. Guide 1.183
-MSLB & SGTR
- SRP 15.1.5
-Loss of AC Power
- Conservative Assumptions
-Rod Ejection
- Bounded by LOCA 31 Accident Dose (Cont.)
Differences from Unit 1 Licensing Basis
-Dispersion Coefficients based on 1991
- 2010 Meteorology Data
-Original Steam Generators
-No Tritium Rods
-Dose Equivalent Iodine reduced (T/S value)
-Fuel Handling Accident based on Alternate Source Term 32 Questions?
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