ML18324A597

Minutes of ACRS Regulatory Policies and Practices Subcommittee Meeting - May 15, 2018

ML18324A597
Person / Time
Issue date:	11/20/2018
From:	Nguyen Q T Advisory Committee on Reactor Safeguards
To:	Advisory Committee on Reactor Safeguards
Nguyen Q
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Download: ML18324A597 (129)

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UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555

- 0001 November 20, 2018 MEMORANDUM TO:

ACRS Members FROM: Quynh Nguyen, Senior Staff Engineer

/RA/ Technical Support Branch, ACRS

SUBJECT:

CERTIFIED MINUTES OF THE ACRS REGULATORY POLICIES AND PRACTICES SUBCOMMITTEE MEETING ON MAY 15, 2018 The minutes of the subject meeting were certified on August 16 , 2018, as the official record of the proceedings of that meeting. Copies of the certification letter and minutes are attached.

Attachments: As stated c c w/ att. A. Veil M. Banks UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 - 0001 MEMORANDUM TO:

Quynh Nguyen, Senior Staff Engineer Technical Support Branch, ACRS FROM:

SUBJECT:

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

"An individual located at any point on the outer boundary of low population zone who is exposed to the radioactive cloud resulting from postulated fission product release during the entire period of its passage would not receive a radiation dose in (19) excess of 35 rem TEDE." The correct value from 10 CFR 50.34 (a)(1)(ii)(D)(2) is 25 rem TEDE.

Otherwise I find the minutes complete and technically accurate.

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

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

WALTER L. KIRCHNER, Chairman PETER RICCARDELLA, Member

-at-Large RONALD G. BALLINGER, Member HAROLD B. RAY, Member*

STEPHEN P. SCHULTZ, Consultant QUYNH NGUYEN, Designated Federal Official Other Participants: ANDY CAMPBELL, NRC ALLEN FETTER, NRC JENNIE RANKIN, NRC MARY RICHMOND, Bechtel RAY SCHIELE, Tennessee Valley Authority MALLECIA SUTTON, NRC RAO TAMMARA, NRC ROBERT TAYLOR, NRC ALEX YOUNG, Tennessee Valley Authority

• Present via telephone

SUMMARY

The purpose of this meeting is the review of selected sections (2.2, "Nearby Industrial Transportation and Military Facilities;" 3.5.16, "Aircraft Hazards;" and 15.1, "Accident Analysis")

of Tennessee Valley Authority's (TVA) Clinch River Early Site Permit (ESP) application. The meeting transcripts are attached and contain an accurate description of each matter discussed 2 during the meeting. The presentation slides and handouts used during the meeting are attached to these transcripts.

SIGNIFICANT ISSUES Issue Reference Pages in Transcript Aircraft Hazards: Qualitative arguments show why design basis accident of 10-6 (instead of 10

-7) is acceptable because these numbers are based on actual data.

24-26; 46; 54-56Chairman Kirchner makes a point that the source term is from a reactor module (and does not account for common cause failure). For their calculations, TVA used the most conservative (e.g., largest power) design of the proposed vendors in the plant parameter envelope.

Consultant Schultz had follow

-up questions.

30-34Chairman Kirchner inquired about the 25mrem threshold. 31; 63 Mr. Tammara begins hi s pr esentation.

The NRC s taff has ne ver l icensed a PZ of 1-m ile b ut has for 2 miles (43). There is a permit condition for a proposed airport in 2022 (46). There is a permit condition associated with potential tox ic chemicals (48). 37 Documents provided to the Subcommittee

REFERENCES:

1.Safety Evaluation: Geography & Demography (2.1); Nearby Industrial, Transportati on and MilitaryFacilities (2.2); ML18102B2032.Safety Evaluation: Aircraft Hazards (3.5.1.6) ML18102B149 3.Safety Evaluation: Accident Analysis (15.1) ML18102B150 Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSIONTitle:ACRS Regulatory Policies & Practices SubcommitteeDocket Number:N/A Location:Rockville, Maryland Date:May 15, 2018Work Order No.:NRC-3729Pages 1-75 NEAL R. GROSS AND CO., INC.

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

Washington, D.C. 20005 (202) 234-4433 1 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 2+ + + + +3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 (ACRS)5+ + + + +6 REGULATORY POLICIES & PRACTICES SUBCOMMITTEE 7+ + + + +8 TUESDAY 9 MAY 15, 2018 10+ + + + +11 ROCKVILLE, MARYLAND 12+ + + + +13 The Subcommittee met at the Nuclear 14 Regulatory Commission, Two White Flint North, Room 15 T2B2, 11545 Rockville Pike, at 8:30 a.m., Walter L.

16 Kirchner, Chairman, presiding.

17 COMMITTEE MEMBERS:

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

22 23 ACRS CONSULTANT:

24 STEPHEN P. SCHULTZ 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 2 DESIGNATED FEDERAL OFFICIAL:

1 QUYNH NGUYEN 2 3 ALSO PRESENT:

4 ANDY CAMPBELL, NRC 5 ALLEN FETTER, NRC 6 JENNIE RANKIN, NRC 7 MARY RICHMOND, Bechtel 8 RAY SCHIELE, Tennessee Valley Authority 9 MALLECIA SUTTON, NRC 10 RAO TAMMARA, NRC 11 ROBERT TAYLOR, NRC 12 ALEX YOUNG, Tennessee Valley Authority 13 14*Present via telephone 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 3 T-A-B-L-E O-F C-O-N-T-E-N-T-S 1 2 PAGE 3 Opening Remarks 4 by W. Kirchner..............4 5 Introductions and Overview 6 by R. Taylor...............7 7 Selected Safety Evaluation Sections 8 by R. Schiele...............9 9 Selected Safety Evaluation Sections, NRC 10 by A. Fetter and S. Tammara........35 11 Chapter 15, Accident Analysis 12 By S. Tammara...............62 13 Opportunity for Public Comments.........75 14 Adjourn.....................75 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 4 P R O C E E D I N G S 1 (8:29 a.m.)

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

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

11Quynh Nguyen of the ACRS staff is the 12 designated federal official for this meeting. And I 13 might point out if you're interested in thermal-14hydraulics this is the wrong meeting. It's next door 15 where we're doing a hearing for Brunswich MELLLA+, the 16 Thermal-hydraulics Subcommittee.

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

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

23Geography and Demography, 2.1. Nearby 24 Industrial Transportation and Military Facilities, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 52.2. Aircraft Hazards, 3.5.1.6 and Accident Analysis, 115.1. The Committee will gather information, analyze 2 relevant issues and facts and formulate proposed 3 positions and actions as appropriate for deliberation 4 by the full Committee.

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

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

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

20Written comments are also welcome. In 21 regard to early site permits, 10 CFR 52.23 provides 22 the Commission, provides that the Commission shall 23 refer a copy of the application to the ACRS and the 24 Committee shall report on those portions which concern 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 6 safety.1 The ACR section of the US NRC public 2 website provides our charter, bylaws, letter reports 3 and full transcripts of all full and subcommittee 4 meetings including slides presented at the meetings.

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

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

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

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

21 A transcript of the meeting is being kept and will be 22 made available as stated in the Federal Register 23 notice.24 Therefore, we request that participants in 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 7 this meeting use the microphones located throughout 1 the meeting room when addressing the Subcommittee.

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

5Make sure that the green light of the 6 microphone is on before speaking and off when not in 7use. We will now proceed with the meeting. And I 8 call upon Robert Taylor, senior management of NRO to 9 begin, Robert.

10 MR. TAYLOR: Good morning. Can you hear 11 me?12 CHAIRMAN KIRCHNER: Yes.

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

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

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

24 TVA also discussed the Clinch River 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 8 nuclear site features and their ESP application.

1 Today's presentation is the next step in our process 2 before the ACRS on the results and the status of this 3 review.4 The staff and TVA have made substantial 5 progress on the Clinch River ESP and today's 6 presentation is a reflection of that good work. The 7 chapters being presented today have developed safety 8 evaluations with no open items.

9 The fact that there are no open items is 10 a reflection on the thoroughness of the staff's review 11 and TVA's responsiveness to the staff inquiries as we 12have worked through the issues. This is the first ESP 13 for a small modular reactor plant design which has 14 presented unique and novel items for the Applicant and 15 the NRC.16 Despite this, we are pleased to report 17that the review is progressing on schedule. We 18 anticipate that we will back before the Subcommittee 19 for meetings on the other SEs under development in the 20 August and October time frame this year.

21 Our goal is to have ACRS full Committee 22 meetings in November or December of this year. With 23 that, the staff looks forward to a fruitful dialogue 24with the ACRS today. So thank you and we look forward 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 9 to the discussion.

1CHAIRMAN KIRCHNER: Okay, thank you.

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

4MR. SCHIELE: Good morning. (Off 5microphone comments). I'd like to introduce the team 6supporting us today. We've got Alex Young, TVA 7 Engineer; Rachel Turney-Work, supporting 2.1, 8Geography & Demography. We have Mary Richmond and 9 Becky Carr and Karene Riley supporting the remaining 10 sections.11 I've been in the industry for about four 12 years, submarines, Calvert Cliffs operations for 16, 13SRO shift manager. And for the last 20 I've been 14 managing large licensing projects and I've had the 15 pleasure since 2016 of supporting the Clinch River SMR 16 ESPA application.

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

22Just a quick visual of what this looks 23like. This is a map showing the gray area is the 24 watershed to show you where the current fleet nuclear 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 10 sites are right now, Browns Ferry, Watts Bar and 1 Sequoyah and where the Clinch River site is in 2 relation to that.

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

7We submitted the ESPA in May of 2016. NRC 8 accepted review in December of 2016. Last summer at 9this time we supported lots of audits. The Rev. 1 for 10 the ESPA was submitted in December of 2017 and we've 11 been supporting RAIs from early fall in 2017 to as 12 recently as early this spring in 2018 QA.

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

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

22 Also the environmental review is going 23very well too. We're in the middle of the DEIS 24review. That review is scheduled to conclude the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 11 first week of June.

1 Chapter 2, Section 2.1, Geography &

2Demography. Clinch River site, the site is 935 acres.

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

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

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

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

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

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

23 The red outline is the Clinch River property line.

24 The Clinch River site is internal to that.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 12 The property is about 1,200 acres. The site is 935.

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

4MR. SCHULTZ: What are the facilities 5 within the five mile radius? Do you have --

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

7 MR. SCHULTZ: Thank you.

8MR. SCHIELE: Sure. Population 9 distribution, this is a slide illustrating the, so the 10 dark blue in the center is ten miles and the lighter 11 blue larger one is ten to 50.

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

18CHAIRMAN KIRCHNER: May I ask how many 19 people are within the darker blue ten mile sector?

20MR. SCHIELE: I have that number here 21somewhere. Rachel, do you have that number quickly 22 inside the ten mile?

23CHAIRMAN KIRCHNER: I see it there for the 24other sectors. I was just curious if it was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 13 comparable number.

1MR. SCHIELE: There was another slide like 2this with ten miles blown up that shows. I don't have 3 those numbers. I can get you that.

4 CHAIRMAN KIRCHNER: Please proceed.

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

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

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

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

20 Yes, go ahead, Rao.

21MR. TAMMARA: My name is Rao Tammara. The 22 SSAR table --

23CHAIRMAN KIRCHNER: And who you are with?

24MR. TAMMARA: I am with the NRO. I am 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 14also a technical reviewer for 2.1 on staff. Table 1 2.1-2 gives the summary of the total population for 2 2010 within zero to ten miles is 67,203.

3 CHAIRMAN KIRCHNER: Thank you.

4MR. SCHIELE: Thank you, Rao. Population 5 density, per Reg Guide 4.7 site suitability criteria 6 for nuclear power stations densities were calculated 7 for the 50 mile region for these three time periods, 8 the projected start of construction, the projected 9 commencement of operation and at the end of the 10 operation date, 2067.

11 The total projected population, the total 12 projected transient population were totaled to be able 13to come up with a population density. The 2021 and 14 2027 population density, as projected on these 15 numbers, is 247 for 2021, 261 people per square mile 16 for 2027.17 To note, this is less than the densities 18 that are recommended to be maintained for Reg Guide 19 4.7. That threshold is 500 people per square mile.

20 Go on to Section 2.2, Industrial, 21 Transportation and Military Facilities. The purpose 22 of this section is to establish whether the effects of 23 potential accidents in the vicinity of the site from 24 present and projected industrial, transportation, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 15military facilities should be used in design basis 1 events for plant design parameters for selected 2 accidents.

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

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

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

19The next circle is ten miles. And you'll 20 see one. That's the Kingston Fossil Plant. Outside 21 of ten miles, between ten and 20 you will see the Oak 22 Ridge Water Treatment Plant, the Bull Run Fossil Plant 23 and the Hallsdale Power Utility District Melton Hill 24 Water Treatment Plant.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 16 Transportation routes and natural gas 1pipelines. This slide illustrates location and you 2 will see a five mile radius there of the Clinch River 3 arm of the Watts Bar Reservoir.

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

7 Here's a 22 inch pipeline.

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

12 One other point on here is there's two 13railroads. At the top of the screen you'll see the 14Norfolk Southern Railroad. There's actually two arms 15 to that.16 One is outside this picture, it's at nine 17miles. This is, the closest is about at 6.5 miles.

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

20 The next slide is airports and airways.

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

24 Also as illustrated is, there's five 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 17 private airports within ten miles and there's two 1 private airports outside of ten miles. So this list 2 right here Big T, Wolf Creek, Cox, these are all these 3 little blue dots inside of ten miles.

4There's two outside of ten miles. You'll 5 see at the bottom of the screen Ferguson Flying Circus 6 and the other one, I apologize, when I put the white 7box here for the legend it covered up this other 8 private airport.

9The name of it is Oliver Springs and 10 they're about 180 degrees from other on the screen.

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

13CHAIRMAN KIRCHNER: Does Knoxville have a 14 major airport?

15MR. SCHIELE: Knoxville does have a major 16airport. It supplies, it's called the Metropolitan 17Knoxville Airport Authority. And I don't know how 18 many --19CHAIRMAN KIRCHNER: It's well outside the 20 ten mile.21 MR. SCHIELE: On this map it would be --

22 CHAIRMAN KIRCHNER: Far to the right.

23MR. SCHIELE: Yes, okay. Evaluation of 24potential accidents. Reg Guide 1.206 discusses 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 18 accidents that have a probability of occurrence of, or 1 in the order or magnitude 10

-7.2 The accident categories that were selected 3 to evaluate this threshold were chemical releases, 4 explosions, flammable vapor clouds, toxic chemicals 5 and fires, collisions with the intake structure, 6 aircraft hazards and liquid spills.

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

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

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

24 Main control room habitability analysis 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 19 will be reperformed at the time of COLA for anhydrous 1 ammonia and chlorine. Because this was a PPE and no 2 specific design was picked there is no specific 3location on site for the control room. So the control 4 room had the ability to be reevaluated during the 5 COLA.6 As far as chemical releases on site, once 7 again because it was a PPE there is not a specific 8 design. So the effects of a release on site will be 9 reevaluated with the COLA, okay.

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

12 MR. SCHULTZ: Just a question, Ray.

13 MR. SCHIELE: Go ahead.

14MR. SCHULTZ: On the highway 15 transportation routes and potential chemical releases, 16 TVA has done other evaluations for other sites I 17 presume.18 MR. SCHIELE: Correct.

19MR. SCHULTZ: Of a similar nature. Is 20 there any particular reason why the situation at this 21 site would be different from what you've analyzed 22 before for control room habitability?

23MR. SCHIELE: I imagine there would be 24some precedence. But the fact that this is such a 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 20remote location. I'll ask Mary Richmond if she wants 1 to add to this.

2MR. SCHULTZ: That's one reason I'm 3 asking.4MR. SCHIELE: Yes. And the I-40 is the 5major route for evaluation where we are. I don't know 6 if there's any precedent for like what was evaluated 7for Sequoyah or Watts Bar. Mary, can you add anything 8 to that?9MS. RICHMOND: One of the issues was that 10I-40 is the closest and it's a major route. So we 11 were being --

12CHAIRMAN KIRCHNER: May, sorry to 13 interrupt. Would you fully identify yourself?

14MS. RICHMOND: I'm sorry, Mary Richmond, 15Bechtel. Interstate 40 is the major route between.

16So we were very careful and we did it very 17 methodically taking the chemicals.

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

23 So that was identified and we analyzed it.

24And it's, for explosions and for flammable vapor 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 21 clouds it's canceled out except for the toxicity 1 analysis because both of those chemicals are very 2 highly volatile toxic chemicals.

3So they were removed for, at COLA stage 4 because the distance ideology is greater so we can 5 look at the control room habitability in greater 6 detail. That's not unusual.

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

10 CHAIRMAN KIRCHNER: Thank you.

11 MR. SCHIELE: Thank you, Mary. Aircraft 12 Hazards, NUREG-0800 standard review plan establishes 13 the criteria for evaluating hazards, 10

-7 is the 14 threshold that needs to be considered.

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

-7 by inspection.

20 Criterion 1, this was basically plant to 21 airport distance and number of operations. Based on 22 the five small privately owned airports between five 23 and ten miles and the two privately owned airports 24 between ten and 15 miles, the evaluation was 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 22 performed.

1 The projected number of operations is less 2 than the threshold for Criterion 1. Therefore, 3 Criterion 1 was determined to have been met for 4 aircraft operations and no further evaluation was 5 required.6 Criterion 2, this criterion is based on 7 the five statute mile distance to the nearest edge of 8 military training routes including low level routes 9and the location of military operating areas. The 10 site is about 19 miles from the center line of 11 training route IR2 and about 36 miles from the 12 Snowbird military operating area.

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

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

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

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 23 So based on the location of the site and 1these two airways we did not meet Criterion 3. So 2further evaluation was required. I'll get back to 3 that.4 So a detailed aircraft hazard analysis was 5performed. The results of the analysis showed that 6 based on the probabilities of a hazard and the 7 probabilities of the dose consequences associated with 8 that hazard that it was 10

-6 with a realistic 9probability that it was actually lower based on 10 qualitative arguments.

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

13 CHAIRMAN KIRCHNER: Would you elaborate, 14 Ray, for the record on what you mean by qualitative 15arguments? Normally the criterion is 10

-7. Isn't 16 that correct?

17 MR. SCHIELE: It's 10

-7 for the hazard.

18CHAIRMAN KIRCHNER: And you had a number, 19 I won't recite the number. But it was, I'm glad to 20 see you rounded it off.

21MR. SCHIELE: 10

-7 was for the hazard.

22 For the dose consequences associated with the hazard 23 it was 10-6. So the full eva luation, and I'll let 24 Mary Richmond from Bechtel elaborate on this, the full 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 24 evaluation showed that based on the qualitative 1 argument and meeting 10

-6 on the order of 10

-6 was met.

2 Mary, do you want to add to that?

3MS. RICHMOND: I'm Mary Richmond, Bechtel.

4 Basically the 10

-7 order of magnitude is for the 5 probability of occurrence with those consequences 6 exceeded.7 However, in the guide in NUREG-0800 and 8 also in the design specific standard review for the 9 SMRs there is an allowance because when you're talking 10 about probabilities that low and the data available, 11 and I'll talk a little bit more about the data 12 availability for aircraft crashes, 10

-6 per year is 13 acceptable if combined with reasonable qualitative 14 arguments you can show that the realistic probability 15 is lower.16 So the 10-7 number a little bit over the 17 order of magnitude that was calculated, was a very 18conservative number. So for example, some of the 19 qualitative arguments that we've presented in the SSAR 20 include we were doing a bounding building for a PPE 21 because at this time a design isn't selected.

22 So we chose a PP height, for example, of 23160 feet and that was red, like we put a box around 24the plan. So that's a very high height for a reactor.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 25 So if you were to like lower the height the "R" 1 probability would be lower to that order of magnitude.

2 Another example of making the 3 probabilistic value a little more realistic is we 4 conservatively included the rad waste building because 5at the time we're not, we don't know. But that was 6 included.7 If the rad waste building was not included 8in the boxed area we would also be down to the 10

-7 9order of magnitude. Probably one of the most 10 conservatisms when Rao talks this afternoon is the FAA 11data for the air traffic on the airway is not 12 available.

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

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

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 26I'm not giving credit for it. None of 1those were credited. So those were the qualitative 2arguments that were included. We were just over that 3 10-7 and we think with these qualitative arguments we 4 can show that it's below.

5CHAIRMAN KIRCHNER: Does the Knoxville 6 airport feed into this set of airways?

7MR. SCHIELE: By distance, no, because 8 this is --

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

13MR. SCHIELE: You're talking about the 14 two, V16 and J46?

15 CHAIRMAN KIRCHNER: Yes.

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

18MS. RICHMOND: Right. The number of 19 operations that we used, we did use the Knoxville-20 McGhee Tyson Airport because they do feed into that.

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

23MEMBER BALLINGER: On this map do you show 24 the holding patterns?

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 27 MR. SCHIELE: No.

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

3 MR. SCHIELE: So this --

4MEMBER BALLINGER: I've sat in the 5 Knoxville Airport with a tornado coming through in a 6 holding pattern and I can tell you that the 7 probability of an incident in that set of 8 circumstances has got to be higher than just landing 9 and taking off.

10MR. SCHIELE: This is a fairly small 11 circle here because this is five and ten miles. And 12 Knoxville is way off the map here.

13MEMBER BALLINGER: Okay, because these 14 holding patterns are generally like a 20 mile race 15 track, right. I'm just wondering if they overlap.

16MR. SCHIELE: I'm not sure, but I can find 17 out. Okay.

18MEMBER BALLINGER: Harold has sent me a 19couple of emails. He's been trying to talk and not 20being able to get through. He says that Ron is 21 working on it but apparently it's not working.

22CHAIRMAN KIRCHNER: Has he sent you 23 questions?

24 MEMBER BALLINGER: He hasn't sent me any 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 28 questions.

1 MEMBER RAY: Can you hear me okay now?

2CHAIRMAN KIRCHNER: Yes, Harold. Would 3 you like to ask any questions at this point?

4MEMBER RAY: That's all right. We're well 5 down the road. It's fine. I just want to make sure 6 if I tried to speak that you could hear me, but we're 7 good.8 CHAIRMAN KIRCHNER: We're working. Ray, 9 please proceed.

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

14 It gives guidance on the analysis model 15 for the time-dependent transport of radionuclides out 16 of the core through several pathways each with a 17 different time-dependent removal mechanism for 18 nuclides.19 For the purpose of evaluating off site, 20 post-accident doses the vendor analysis with the 21 highest dose was selected for use in the site-specific 22dose analysis. Each of the four SMR designs under 23 consideration was expected to provide advanced design 24 features that would further minimize accident 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 29 consequences.

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

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

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

21CHAIRMAN KIRCHNER: So at this point, Ray, 22 then you're using of the four potential designs that 23 you're considering the largest single unit which is 24 800 megawatts but your site envelope is 2,000 plus 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 30 megawatts thermal, right?

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

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

9MR. YOUNG: So I think for a questions 10 that's revolving around the site is being licensed in, 11excuse me, Alex Young, TVA. So I think your question 12 is revolving around the site as being licensed to 2420 13 megawatts but we're talking about the 800 megawatts 14 thermal gear.

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

19 We did not consider that multiple units 20for that vendor are in a simultaneous accident. So 21 that's why it's looking at 800 opposed to a total of 22 2420.23CHAIRMAN KIRCHNER: I understand that 24fully. I'm making a point that the assumption here is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 31 that you don't have common cause, common mode failure.

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

3 MR. SCHIELE: That's correct.

4CHAIRMAN KIRCHNER: So we'll take that up 5 with the staff.

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

11 Short term 95th percentile accident 12 atmospheric dispersion factors for the Clinch River 13site. Bounding vendor provided LOCA doses and X/Q 14 values associated with bounding vendor provided LOCA 15 doses.16 The resulting accident doses are expressed 17 as a total effective dose equivalent, TEDE, consistent 18with 10 CFR 52.17. All site LOCA doses meet the 25 19 room TEDE limit specified in 10 CFR 52.17.

20CHAIRMAN KIRCHNER: So, Ray, again for the 21 record, what was the highest dose that you estimated 22 versus the 25 rem limit because I understand the NRC 23 policy on this is that they are not looking for 25 24 rem.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 32 MR. SCHIELE: Correct.

1CHAIRMAN KIRCHNER: They're looking for a 2 considerable margin below that.

3MR. SCHIELE: Alex, do you want to take 4 that?5MR. YOUNG: Sure. So out of Chapter 15 6with the EAB the zero to two hour dose for the site 7 was estimated at or was calculated at 21.6 rem. And 8 then the 30 day dose for the LPZ was at a total of 9 2.97 rem.10 CHAIRMAN KIRCHNER: Thank you.

11MR. SCHIELE: That concludes TVA's 12 presentation on Sections 2.1, 2.2, 3.5.1.6 and Chapter 13 15. Are there any additional questions?

14MR. SCHULTZ: Ray, let me back up a bit on 15the source term. The 800 megawatt thermal that's 16 larger than some of the units that you're considering.

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

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

21MR. YOUNG: Sure. So the 800 megawatts is 22 the thermal power dose associated with the largest 23vendor that we considered out of four SMR vendors. So 24 basing on the principal core power resulting in core 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 33 inventory and amount of radioactive material that 1provided the most conservative source term for us. So 2 that was the basis for the 800.

3MR. SCHULTZ: And the evaluation of 4 release was done in what way? The evaluation of the 5 release of that source term.

6MR. YOUNG: So the releases are based off 7 or are mostly based off of standard Reg Guide 1183 8 methodology which is then, some of the vendors they 9 take into account some advanced SMR features that 10 reduce some of those source terms to a certain extent.

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

16MR. SCHULTZ: Okay, thank you. So you 17 went through a process that provided some element of 18 maximization to determine a, what you would consider 19 a maximum dose for a particular power level to 20 determine some level of a bounding source term?

21MR. YOUNG: Yes. All the vendors provided 22information to us. They all provided source terms and 23 doses to us and we picked the vendor that had the 24 highest doses.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 34MR. SCHULTZ: But did, if a unit was less 1 than 800 megawatts thermal, did you scale that up in 2 some fashion or did you go kind of on a design by 3 design basis?

4MR. YOUNG: No. We went on design by 5design basis. We did not do any type of composite or 6 scaling of the other values to look at a dose per 7 megawatt ratio kind of thing.

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

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

13 MR. YOUNG: That is correct.

14 MR. SCHULTZ: Thank you.

15CHAIRMAN KIRCHNER: Any additional 16questions? Ron, any further questions at this point?

17 Okay. Thank you, Ray.

18 MR. SCHIELE: Thank you.

19CHAIRMAN KIRCHNER: We're ahead of 20schedule. So I think rather than take a break at this 21 point let's proceed to the staff and your team, Bob.

22 Take a moment here to change out.

23 MR. FETTER: Is this on?

24CHAIRMAN KIRCHNER: Yes. Just push the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 35 button and you should see a green light.

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

2Good morning. I'm Allen Fetter, one of the two safety 3 projects for the Clinch River nuclear site, early site 4 permit review.

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

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

11 Ms. Sutton will be at the table for the 12 next ACRS Subcommittee meeting on emergency planning 13 scheduled for the latter half of August right now on 14emergency planning and exemption requests. And you 15 will hear about her credentials and experience at that 16 time.17 My qualifications include having a 18 doctoral degree in Geology which focused on isotope 19 geochemistry and tectonics. And I worked for, prior 20 to joining the NRC I worked for a number of years for 21 an environmental and geotechnical engineering firm.

22 I started working at NRC in 2004 and since 23 2009 I have been a project manager in the Office of 24New Reactors. Prior to taking over as safety project 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 36 manager for the Clinch River early site permit review, 1 I was the environmental project manager for the 2 Bellefonte COL and the PSEG early site permit reviews.

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

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

9 Between each presentation we will offer 10 ACRS Members the opportunity to ask questions or 11provide comments to each presentation. For the 12 sections discussed today in addition to the staff's 13 review of TVA's application, staff set up one public 14 meeting with the Applicant and issued one RAI to the 15 Applicant and the details are in the SE, in order to 16 obtain additional information to support NRC's 17 findings.18 Before I turn it over to Mr. Tammara, I 19 want to clarify some statements regarding our schedule 20 that TVA said the DEIS, the draft environmental impact 21 statement was scheduled for June 1st. It was issued 22 on April 27th and we were able to leverage some 23 administrative resources to do that.

24 We did not accelerate this. We followed 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 37 our normal process for a review. The public meeting 1 is on June 5th of this year and the final EIS is next 2June 2019. And that's all. With that I'll turn it 3 over to Mr. Tamarra.

4MR. TAMMARA: I'm Rao. Good morning, I am 5Rao Tammara. I'm with the NRO. I have three Master's 6 degrees, two in Chemical Engineering, one in 7 Environmental Engineering. I have 40 years of 8 experience, 32 working for a consulting company, NUS 9 Corporation and Tetra Tech NUS.

10I joined the NRC in 2006. Since them I am 11 with the NRC working on all COLs and ESPs so far. I 12 reviewed Chapter 2 Sections 2.1.1, 2.1.2, 2.1.3; 13 Aircraft Hazards, 3.5.1.6 and basically I acquired to 14 start the accident analysis Chapter 15.

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

20Next slide please. This main section has 21 three subsections which include 2.1.1, consisting of 22 site location and description; 2.1.2 which is 23exclusion area control, authority and control. The 24 third subsection is 2.1.3, population distribution.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 38 The site location and description 1 addresses the description of the site which includes 2 coordinates, site boundaries, orientation of principal 3 plant, location of highways, railroads, waterways in 4 the vicinity of the site and exclusion area.

5The unique feature of this site is the 6 exclusion area. The exclusion area is delineated by 7 the site boundary, site boundary.

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

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

19MR. SCHULTZ: Rao, could you provide some 20 background as to why that approach was taken in 21 determining an analytical EAB?

22MR. TAMMARA: Because that really, the 23 actual EAB is much farther away and the EAB is in 24different directions. If you analyze the X/Q it is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 39 much less, potentially much less than what they have 1 taken conservative.

2 They have taken uniformly throughout all 3 16 directions, same small distance so that they can 4 consider if we meet this dose criteria we will meet at 5the site boundary. That was the conservatism the 6 object.7 And staff has no objection from that point 8 because they have used that one. The dose they have 9 being much, you know, would be lower than whatever 10 they use.11 Therefore, they have conservatively taken 12 a more limiting dose conformance therefore we have no 13objections to what they have chosen. We have no 14 reason. That's the reason we have accepted that.

15MR. SCHULTZ: Are there any site 16 characterization X/Q evaluations that have been done?

17 Is there a tower site evaluations for X/Q at this 18 point?19 MR. TAMMARA: That probably I am not the 20 right person to answer that question because --

21MR. SCHULTZ:

I might have asked the 22 Applicant but --

23MR. TAMMARA: Not Applicant on the 24 meteorological section which they evaluated in more 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 40detail in Chapter Section 2.3. They looked at the on 1site data. They have the assumptions. They have 2 evaluated --

3MR. SCHULTZ: So that's been done 4 separately?

5MR. TAMMARA: Right. This is, we are the 6users but they are the reviewers. Therefore, I cannot 7 probably answer very freely.

8 MR. SCHULTZ: I understand. Thank you.

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

12MR. SCHULTZ: But this analytical approach 13 was to basically allow an evaluation to be done --

14 MR. TAMMARA: Right.

15MR. SCHULTZ: -- without all of the 16 detailed information assembled which will happen later 17 on.18 MR. TAMMARA: That's correct. The value 19 of X/Q is more conservative compared to the other 20 ones. That's what we have taken into account.

21 MR. SCHULTZ: Certainly.

22 MR. TAMMARA: That is all.

23 MR. SCHULTZ: Thank you.

24MR. TAMMARA: The second is exclusion area 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 41control. And that's addresses the legal authority, 1 control of the activities and, that are unrelated to 2 the plant operation and whatever the arrangements they 3 have made with respect to the state local governments 4 in case of emergency.

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

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

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

21 But however, if you take a look at the 22 second paragraph of the same regulation the regulation 23says political boundaries are not limiting. You have 24 to look at the population where the majority 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 42 population is residing, how far away from the 1 boundary, political limits.

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

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

12CHAIRMAN KIRCHNER: And that doesn't 13 include the transient population on the Oak Ridge 14 Reservation, right?

15MR. TAMMARA: No, but still it is, yes, 16right. So that, but however the Applicant analysis 17 used Census Bureau for different designation when 18 you're in the urban area designation.

19 But ultimately the conclusion is similar.

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

24 Just I wanted to present the uniqueness of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 43 the site so that how it has been accepted if they have 1 any questions I want to clarify that.

2CHAIRMAN KIRCHNER: So I'm looking at Reg 3 Guide 4.7, yes, and I see that the boundary for the 4 LPZ should be based on population distribution not 5political boundaries that you said. Have you, has the 6 Commission, have we ever licensed a plant with only 7 one mile LPZ?

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

13CHAIRMAN KIRCHNER: Okay. And we are 14 going to hear about emergency planning later in the 15 summary, okay. Thank you.

16MR. TAMMARA: Next slide please. Staff 17 reviewed the information provided by the Applicant 18 pertaining to the site location and description and 19 also checked independently the information available 20 from the public domain.

21 Staff found it acceptable and they 22 satisfied the guidance provided in NUREG-0800, Section 23 2.1.1. Staff also reviewed the information provided 24 by the Applicant pertaining the exclusion area 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 44 authority and control.

1 Based on the information provided staff 2 finds it acceptable as it satisfies the guidance 3provided in NUREG-0800 Section 2.1.2. Next slide 4 please.5 Staff also reviewed the information 6 provided by the Applicant pertaining to population 7 distribution including population projections during 8 the life of the plant, operation center distance as I 9 described before and also population density.

10 Based on the information provided by the 11 Applicant and staff's independent confirmatory 12 analysis, the staff found the information to be 13 acceptable as it meets the requirements of 10 CFR 14 100.20.15Next slide please. The second subsection 16 is 2.2, which pertains to nearby industrial, 17transportation and military facilities. This section 18has first portion identification of all of these 19 facilities.

20 Those are sources within the five miles of 21 the site. And the second portion is the description 22of the materials, products and other materials or 23 chemicals which are processed, stored by these 24 sources.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 45 So they include maps of the site, nearby 1 facilities and transportation routes, description of 2 the facilities products and materials and the number 3 of people they employ, description of pipelines, 4 highways, waterways, airways and airports.

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

7 Staff reviewed the Applicant provided specific, I'm 8 sorry.9 Information provided by the Applicant 10 pertaining to the location and description of nearby 11 industrial, transportation and military facilities for 12the evaluation of potential hazards for their safe 13 operation of the proposed plant.

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

20 Another important thing for this site is 21 that there is a proposed airport which is planned to 22be built in the year 2022. If this airport comes into 23 being at the COLA stage the impact evaluation of the 24 hazards of this airport has to be evaluated and 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 46 included in the application.

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

4Next slide please. The third section, 5 subsection of this main 2.2 is the evaluation of 6potential accidents. In this evaluation the basic 7 evaluation is to determine whether there is any 8 accident which is designated to be a design basis 9 accident.10 A design basis accident is defined as an 11 accident that has a probability of occurrence in the 12 order of magnitude of 10

-7 or greater and resulting in 13 a potential consequence exceeding 10 CFR 100 dose 14 guidelines.

15 So the design basis accident has to occur 16 in connection with those exceeding the 10 CFR Part 100 17 guideline and that's probably the total probability 18 should be greater than 10

-7. So in order to find out 19 whether there is any design basis accident the 20 evaluations are determined to, evaluated to determine 21 whether any accident is design basis accident.

22 In doing so the impacts considered 23 explosions, flammable vapor cloud explosions from 24 industrial facilities, truck traffic, pipelines, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 47 waterways, release of hazardous chemicals from 1 transportation accidents, major depots, storage areas, 2 on site storage tanks.

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

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

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

17Next slide please. Based on the review 18 the Applicant provided information, analysis and 19 staff's independent confirmatory calculations, the 20 staff found Applicant's conclusions to be acceptable, 21 as the evaluations are in accordance with the guidance 22 provided in NUREG-0800, Section 2.2.3 with an 23 exception of potential impacts from toxic chemical 24 release of anhydrous ammonia, chlorine and nitric acid 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 48 from a truck transport on the roadway.

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

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

12CHAIRMAN KIRCHNER: Okay. Just for 13 qualitative comparison purposes, since I-40 is 14 approximate to this site versus for example TVA's 15 other sites, I think it's I-75 that goes down --

16 MR. TAMMARA: Yes.

17CHAIRMAN KIRCHNER: -- to Chattanooga.

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

24MR. TAMMARA: Not necessarily. The 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 49problem here is this is a ESP. So the roadway is 1 about 5,800 feet away from the closest boundary. So 2 presently we do not know exactly where the control 3 room is.4 So what is the intake structure is whether 5it is a limited or, we don't know the design. And we 6 don't know the evaluation factors of the control room 7 because it is a, first of all it is a new design.

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

10 Second, we don't know the design parameters of the 11 intakes.12 And we don't know the design parameters of 13the evaluation grades. Therefore, it is difficult to 14 calculate what would be the concentration in the 15 control room.

16 So the present analysis what has been done 17 is if there is an accident we calculated the 18 concentration very closest to the boundary and see 19 whether the limited concentration would be higher or 20 lower.21 If our analysis has shown, our data 22 analysis had shown the concentration is lower than 23 alleged potentially control room would not have any 24 problem because the site won't, concentration is lower 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 50 and it is meeting the limiting concentration.

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

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

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

10CHAIRMAN KIRCHNER: My point here was that 11 compared to, for example, TVA's other sites their 12 location is sufficiently distant from major arteries 13 like an interstate highway such that they will fall 14below the toxicity limit just by dispersion and 15 distance.16 MR. TAMMARA: Yes, I do not --

17CHAIRMAN KIRCHNER: But here we have a 18 relatively small site, relatively approximate to I-40.

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

23 So the location of the intakes is not 24going to be an issue. So first order in doing that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 51 analysis is, it appears that they're going to have a 1 higher toxic protection.

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

7MR. TAMMARA: Possibly. I cannot answer.

8MR. FETTER: So it sounds like you're 9 saying the amount of recirculation that a control 10 versus fresh air intake and that's something that's 11 not a specialty that Rao has.

12MR. TAMMARA: And also it is like, that's 13 why we are putting a condition they have to 14demonstrate the actual data that it is not going to 15 impact the operators. That is the intent.

16CHAIRMAN KIRCHNER: So noted, okay. Thank 17 you.18 MR. TAMMARA: Any other questions?

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

21MR. FETTER: That's fine. Are you guys 22 okay continuing on?

23MR. TAMMARA: Yes, sure. I have no 24 problem.25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 52MR. FETTER: We just need a little 1 technical assistance for this slide show.

2MR. TAMMARA: The next section is Aircraft 3Hazards, Section 3.5.1.6. Next slide please. For the 4 site suitability the plant design should consider that 5 any of the aircraft accidents is not a design basis 6 event.7 I have already explained what the design 8 basis accident is, that an event having a probability 9 of 10-7 or greater having the consequences greater 10 than dose limits exceeding the dose limits 10 CFR Part 11 100 that includes 10 CFR 50.34(a)(1) with a 12 probability of occurrence greater than 10

-7 per year.

13 Doing the aircraft analysis there are, 14 some of the screening criteria are applied and they 15 have to be considered and also screened out based upon 16 the guidance. Federal airways, holding patterns and 17 approach patterns should be at least two statute miles 18 away.19 Military installations or any air space 20usage should be at least 20 miles from the site. All 21 airports should be at least five miles from the site.

22Next slide please. The airports which are 23 within the five to ten miles the flights that are 24 having, can be screened out if they are 500 d

2. D, is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 53 the distance from the plant to the airport.

1 If you calculate that number of flights 2 and if it is within the, the actual number of flights 3 are within the limit that no further evaluation of 4 that airport is required. So also if it is, airport 5 is beyond ten miles the limiting value of the number 6 of flights is 1,000 d 2.7 The airports identified by the Applicant 8 and checked by the staff do not meet, meet this 9 criterion therefore no additional evaluation has been 10 performed or required to be performed for the area of 11 the airports.

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

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

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

21Next slide. Staff performed an 22 independent confirmatory analysis using the actual FAA 23data. Staff collected and looked in five year recent 24 data from the FAA that covers 2011 to 2015 all flights 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 54 flying within the five miles or in the ten miles of 1 this sight irrespective of where the, type of the 2 aircraft is.

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

7 The potential aircraft crash probability 8we calculated, staff calculated is 1.5 times 10

-8 9 based upon all the flights within ten miles following 10those two airways.

So that is a most conservative 11 calculation using the real FAA data.

12 And based upon that one staff accepts the 13Applicant's value as reasonable. Therefore, staff 14 agrees with the Applicant's conclusion that the 15aircraft crash probabilities is in the order or 16 magnitude 10

-7 per year or less and meets the provided 17 NRC guidance.

18CHAIRMAN KIRCHNER: Rao, just for 19 clarification purposes, the preceding slide shows an 20 estimate of 7.53 times 10

-7 using the DOE standard.

21 So that feels a lot like one times 10

-6 to me, right.

22 As an engineer when I round this up.

23 MR. TAMMARA: That's correct.

24CHAIRMAN KIRCHNER: So I guess the only 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 55thing I would say is that the Applicant provided us 1 with some qualifying arguments that would reduce their 2number. It just, since we're dealing with numbers 3 here at least in the material that's been presented, 4 it just doesn't follow ipso facto that you agree with 5 their estimate.

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

11MR. TAMMARA: The way the guidance is 12 written if you take a look at the guidance, first 13thing is if you make the assumptions and show that 14 comfortably the probability calculated is 10

-7 or 15 less, okay, generalize options than it is easy to 16 accent.17 But if you read the second sentence of the 18 guidance it says if you, if the assumptions are 19 realistic and more appropriate are any statistical 20 evidence if you can use, you can go and you can accept 21 as high as 10

-6 per year. So the language written is 22 you can make a general, if you don't have anything you 23 mix general reasonable engineering and scientific 24 assumptions and prove your less than 10

-7 it is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 56 acceptable because everything would be less than that.

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

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

11So what else could we? It is most 12conservatively showing a distance. But they might 13 have it, the Applicant might have used some because 14they are not available with this data. But they have 15 made some assumptions to use more realistically what 16 they have.

17 So therefore, when staff's judgment is 18used and it is acceptable. That is the situation 19 here.20CHAIRMAN KIRCHNER: Thank you. Our former 21 member, John, no, John is still a member, Stetkar 22 would appreciate your more realistic calculation.

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

24 MR. TAMMARA: Thank you.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 57MR. SCHULTZ: Rao, a related question.

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

4MR. TAMMARA: No, it is under 5 construction.

6MR. SCHULTZ: It is and it's nearby the 7site. Does that, is there enough information for you 8 to have included that here?

9MR. TAMMARA: No, we haven't. It is, not 10 enough information is available.

11MR. SCHULTZ: But it's under construction?

12MR. TAMMARA: I think so. It will be, the 13notion is it comes into being in 2022. So at what 14 stage it is in I'm not sure.

15MR. SCHULTZ: Is there any expectation 16that the results of the evaluation would change 17 because of the location and the size of that airport?

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

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

24MR. TAMMARA: No, that will, usually that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 58 kind of facility they have to go to the federal and 1 state permitting procedures because there is another 2nuclear plant is there. They have to evaluate what 3 would be the impact of the airport to nearby 4 facilities just like we are doing here.

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

12They helped evaluate. And also as an 13 operating plant Calvert Cliff has to evaluate what 14 would be the potential impact of the proposed 15 facility.16 MR. SCHULTZ: Understood.

17MR. TAMMARA: So therefore, we haven't 18 done for the ESP therefore we have put it but a 19 condition that at the COL stage they have to evaluate 20 that.21MR. SCHULTZ: All right. Is there not 22 enough information to determine that --

23 MR. TAMMARA: That's correct.

24MR. SCHULTZ: Wait, let me ask my 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 59question. Is there not enough information to 1 determine that it won't be a difficult situation where 2 something has got to give between the airport 3construction and design or the plant design before 4 2022?5 MR. TAMMARA: That's correct.

6MR. SCHULTZ: It seems like enough 7 information might be available to at least determine 8 that the construction project can continue and this 9 site evaluation can continue.

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

11MR. SCHULTZ: Or in reverse, this is going 12 to be a problem in 2022 and something will have to be 13 worked out. That doesn't seem to be a proper way to 14 proceed.15 If it's going to be a problem if we can 16 determine that now obviously it would be a better time 17 than six years from now or so after the construction 18is more complete. I mean that's how facilities get 19 into difficulty is when you get things close to done 20 and then find out, we didn't consider it properly and 21 there might be a problem here.

22MR. TAMMARA: That's why we are 23 identifying the Applicant, hey, you need to realize, 24 be aware of it.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 60CHAIRMAN KIRCHNER: But I think where 1 Steve is going is just to do a little projected 2 calculation. You've got a general aviation airport, 3 x, I forget the exact distance.

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

13MR. SCHULTZ: That's what I was looking 14for. Clearly the evaluation needs to be done in 15detail once the parameters are known. But is there a 16 determination at this time that this is not going to 17 create an issue for the airport or for the site 18 application by 2022?

19MEMBER BALLINGER: In the justification 20 for the airport itself an analysis had to be done.

21Why put the airport there? It must be some assumption 22 of the number of flights in and out and all that to 23 justify constructing the airport in the first place.

24 And so you would think that justification would be 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 61 easy to get access to.

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

3MR. CAMPBELL: Is this on? Okay, I'm Andy 4Campbell. I'm the deputy director of DSEA. The part 5 of the problem with doing just that is it's very 6 speculative.

7 Without knowing the specifics of what the 8 airport is going to be and whether or not it's even 9 going to be for the ESP stage that would be highly 10speculative.

On the other hand, you could do some 11 sort of screening.

12 But it would be again, very speculative.

13There's not a lot of data and it's certainly not 14required at the ESP stage. It would be required at 15 the COL stage.

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

20CHAIRMAN KIRCHNER: Well I would, because 21 there's, I know our charter is restricted to safety.

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

24And it would seem to me prudent rather 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 62 than speculative to make such an estimate of the 1 potential impact of that proposed airport and I'll let 2 it go at that.

3MR. CAMPBELL: Certainly the Applicant 4 could do that if they so desired.

5CHAIRMAN KIRCHNER: Okay. Does that 6 conclude this section?

7 MR. TAMMARA: Yes.

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

12 (Whereupon, the above-entitled matter went 13 off the record at 10:02 a.m. and resumed at 10:14 14 a.m.)15CHAIRMAN KIRCHNER: Let's begin the 16 meeting and proceed to Chapter 15 please.

17MR. TAMMARA: Yes. The next section is 18Chapter 15, Accident Analysis. Evaluation of 19 radiological consequences, consequences of postulated 20 designed basis accidents for the proposed CRN site.

21 Dose analysis include plant parameter 22 envelope accident source terms consisting of assumed 23 DBA, isotopic releases to the environment in lieu of 24specific plant design information. Site 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 63 characteristic short term accident atmospheric 1 dispersion factors that they have developed site 2 specific information in Chapter 2, Section 2.3.

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

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

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

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

24 The Applicant considered the loss of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 64 coolant accident LOCA is expected to be more closely 1approached. 10 CFR 52.17 limits then other design 2 basis accidents that may have greater probability of 3 occurrence but lesser magnitude of activity release.

4 The selected PPE LOCA accident source term 5 is based on standard, light water reactor fuel which 6 is representative of SMR design assuming core power 7 level of a single unit at 800 megawatt thermal. For 8 reasonableness the PPE source term is compared with 9the AP1000 design with a scaling factor by ratio of 10.235 that is the ratio of 800 megawatt thermal to 11 2,400 megawatt thermal and assessed to be not 12 unreasonable.

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

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

23Next slide please. The dose to the 24 individual located at the EAB or on the outer boundary 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 65 of LPZ is calculated based on the amount of activity 1 released to the environment at dispersion using the 2 transport from the release point to the dose point, 3 breathing rate of an individual at the dose point 4location and the activity to the dose conversion 5 factor.6 So these are the parameters which will 7determine the dose. Since the dose and the vendor 8 dose is determined based upon the vendor X/Q that is 9 more representative of many of the sites the only 10 change for the site is the site specific X/Q.

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

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

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

24 Analysis meets the dose criteria specified 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 66 in 10 CFR 50.34(a)(1) and also 10 CFR 52.17 and the 1 PPE includes the bounding accident releases for the 2 determination. Next slide please.

3MR. SCHULTZ: Just on that slide a 4question. What are the boundary distances that are 5 being used here?

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

10MR. TAMMARA: Yes, that's correct, 1,100.

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

12 MR. TAMMARA: Is one mile.

13 MR. SCHULTZ: -- boundary is?

14 MR. TAMMARA: One mile.

15MR. SCHULTZ: One mile, okay. Thank you.

16 MR. TAMMARA: 1,100 feet.

17CHAIRMAN KIRCHNER: I have a slightly 18 different question but related. It is an irregular, 19the actual exclusionary boundary is irregular. Is 20 1,100 the smallest distance to, of the exclusion area 21this doesn't go on the transcript very well. Is it 22 irregular for --

23 MR. TAMMARA: The site boundary and also 24--25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 67CHAIRMAN KIRCHNER: The 1,000 or 1,100 is 1 the minimum distance from the center point of the site 2--3 MR. TAMMARA: That's correct.

4CHAIRMAN KIRCHNER: -- to the smallest 5 lineal distance.

6 MR. TAMMARA: The closest point.

7 CHAIRMAN KIRCHNER: Okay, fine.

8 MR. TAMMARA: That's correct.

9CHAIRMAN KIRCHNER: Thank you. Second, 10have you audited the site characteristics, the X/Q 11numbers that are used? I would note that in your 12 table you point out that the vendor designs for that 13 ratio or that parameter more correctly are engineering 14 numbers like 1 times 10

-3, 5 , 5 times 10

-4 , et cetera.

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

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

24So how confident are you in that site 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 68 characteristic parameter, particularly for the EAB 1 given that when you use that multiplier you get fairly 2 close to 25 rem, 21.6 as was pointed out.

3MR. TAMMARA: That's correct. The site 4 characteristic X/Q are evaluated based upon the site 5 meteorology and other parameters using the code that 6 has been evaluated by our meteorology subsection under 7 2.3.8 It has documented what are the models they 9 have used, what criteria they have audited in the 10parameters how they came up with. A detailed analysis 11 have been used and analyzed and addressed in Section 12 2.3.13 So when they present that section probably 14 they will give you more insight and more thorough 15 explanation of how they determined, how they accepted 16 the numbers.

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

23CHAIRMAN KIRCHNER: Well I understand 24that. You've got three significant figures in that 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 69parameter. I put my glasses on and I can't even read 1 this.2 MR. TAMMARA: 4.96.

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

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

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

19MR. TAMMARA: You find this out. The case 20 for COL they have to make sure the actual source terms 21they have selected end up on. They have to compare 22against the source term and make sure the PPE is 23 bounding.24 It is so strong they have selected in the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 70 PPE source term is bounding then it is okay.

1Otherwise they have to take a variance. This ESP 2 stage it is showing taking the boundary PPE value you 3 are meeting the 25.

4CHAIRMAN KIRCHNER: Well we, of course 5 there is uncertainty in several assumptions that 6result in that final number in terms of dose. There's 7 the uncertainty as to whether scaling AP1000 is an 8 accurate assumption.

9It's, in a gross sense I would expect 10that's a good assumption. From what we know from some 11 of the designs they probably wouldn't see the burn up 12 that AP1000 will attain at this point, et cetera.

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

16 MR. TAMMARA: Right.

17CHAIRMAN KIRCHNER: And then we'll come 18 back and look at how close this is to 25 rem.

19MR. TAMMARA: That's true. But in our 20 judgment at the COL stage if there is a variation in 21 the source term, so in the actual design probably that 22 answer will be much closer to 25 they might have to do 23 some mitigating measure.

24 But variance such as that they are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 71deviating from the source term. So but because the 1 X/Q is already evaluated for the site specific there 2 is nothing they can do probably.

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

6CHAIRMAN KIRCHNER: Or they could do what 7you did with aircraft. They could go back and 8 reevaluate the meteorology.

9MR. TAMMARA: Right, that's true. They 10have to. That's what I'm saying. They have to 11 reevaluate taking the variance and show, demonstrate 12 that their dose calculation, recalculated dose 13 calculation with the actual source term is within the 14 25 margin, whatever they have demonstrated that.

15MS. SUTTON: This is Mallecia Sutton. So 16 the staff is currently writing the SE and will present 17the findings on the X/Q which I know they currently 18 have an article on now related to X/Q with the 19 Applicant and will be happy to present your, the 20 findings on October, November.

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

23CHAIRMAN KIRCHNER: Now the other thing 24 again for the record that I should note is you are 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 72 assuming the limit is based on a single module 1 failure.2 MR. TAMMARA: That's correct.

3CHAIRMAN KIRCHNER: Not the bounding plant 4 parameter element that would obtain if it were looking 5 at a larger --

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

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

10 MEMBER BALLINGER: No.

11 CHAIRMAN KIRCHNER: Pete?

12 MEMBER RICCARDELLA: No.

13 CHAIRMAN KIRCHNER: Steve.

14 MR. SCHULTZ: (Off microphone comments.)

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

21 In order to have good discussion related 22 to those parameters the determination of boundaries is 23 going to be important to understand the uncertainties 24 associated with these assumptions for the variety of 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 73 different designs that might be considered and also 1 the sensitivities that one might determine.

2 As was stated, we do have limits that have 3been established in the regulation. At this stage in 4 terms of new reactor licensing we are looking for 5 margin and when one considers its evaluation which 6might pertain to a different approach to emergency 7 planning.8 One would expect that margins and limits 9would be very important. Just a general comment at 10 this time to consider at the next stage, near term 11 stage and licensing proceedings. Thank you for your 12 presentation.

13 MR. TAMMARA: Thank you.

14CHAIRMAN KIRCHNER: Okay. Let me turn and 15 see if anyone from the public is in audience and 16wishes to make a comment. Seeing none, we'll open up 17 the bridge line and see if we have any members of the 18 public who have been listening in and wish to make a 19 comment.20MEMBER RAY: Walt, before you do that, did 21 you take member comments? I couldn't hear.

22CHAIRMAN KIRCHNER: I was going to take 23 final comments, Harold, in just a moment.

24MEMBER RAY: That's fine. It was, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 74 whatever was going on the last minute or so I couldn't 1 hear so please go ahead.

2CHAIRMAN KIRCHNER: Okay. We have two 3 meetings going on simultaneously and while we are 4 waiting for some technical assistance, Harold, if you 5 have any comments this would be a good opportunity 6 while we have the staff in front of us.

7MEMBER RAY: Yes, I would be glad to. I'm 8 sorry I'm not there. I will try and provide 9 equivalent input.

10 But in any event, on the discussion of the 11 perspective possibility of an airport and its 12 implications for the site I think that will warrant 13 some more discussion as to whether in an ESP 14 proceeding if it's gotten to some point and whether 15 it's an airport or any other thing, it's not specific 16 to airports, but whether proposed additions to the 17 environment should be considered and if so on what 18 basis.19 The discussion that I could hear which was 20 we don't know the details about it yet and therefore 21 it hasn't been considered but might have to be in the 22future. I think in an ESP proceeding, it's my opinion 23 anyway that perhaps we ought to consider things when 24 they've gotten at least to some point of specificity.

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 75 I certainly did that on a liquefied 1 natural gas facility on one occasion. So that's the 2 only comment that I have.

3 CHAIRMAN KIRCHNER: Okay, thank you. So 4 if any member of the public is out there and wishes to 5 make a comment please state your name and provide your 6 comment.7 Not hearing anyone I think we can close 8 the bridge line and proceed around the table. Any 9 final comments, Ron?

10 MEMBER BALLINGER: No further comments.

11 CHAIRMAN KIRCHNER: Pete?

12 MEMBER RICCARDELLA: No comments.

13 CHAIRMAN KIRCHNER: Steve?

14MR. SCHULTZ: No further comments. I 15thank the staff. I think the presentations by both 16 the staff and the Applicant have been well done this 17 morning and I appreciate the current status 18 information and look forward to the future meetings.

19 Thank you.

20CHAIRMAN KIRCHNER: So let me echo Steve's 21 thanks and to both the staff and the Applicant. And 22 with that we are adjourned.

23 (Whereupon, the abo ve-entitled matter went 24 off the record at 10:37 a.m.)

25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 Clinch River Early Site PermitSSAR Sections 2.1, 2.2, 3.5.1.6, & Ch.15May 15, 2018Advisory Committee on Reactor SafeguardsSubcommittee MeetingPresented by Ray Schiele, Licensing Manager TVA's MissionEnergyEconomic DevelopmentEnvironmentServing the people of the Tennessee Valley to make life better.Partner with 154local power companies, to serve 9 million people and700,000 businesses in parts of seven states. Directly serve 56 large industries and federal installations.

l 2Advisory Committee on Reactor Safeguards TVA's Nuclear FleetAdvisory Committee on Reactor Safeguards 3Browns FerrySequoyahWatts BarCRN Site Early Site Permit Application Development 4TVA decides to pursue ESPA 20 14Site Characterization 2010 -2015ESPA Submitted to NRC May 2016NRC accepts ESPA for reviewDecember 2016NRC performs Audits March-May 2017ESPA Rev. 1 Submitted December 2017RAIs 2017-2018Advisory Committee on Reactor Safeguards NRC Environmental ReviewNRC Safety ReviewAudit RAI ResponsesComment ResolutionComment PeriodDEISto EPA, USACEFEISScopingMeetingPSERAudits (Hydrology, Seismic)ACRSACRSFSERSER w/ no OIsSERw/ OIsER AuditDocketingDecisionNRC ReviewScheduleRAI ResponsesOI ResponsesScoping PeriodNotice of IntentAudit RAI Responses20162017201820192020ESPA Submitted 5-12-16RAI ResponsesTVA Business Sensitive ES P AProjectUpdat e-LicensingProcess Advisory Committee on Reactor Safeguards l 6Chapter 2

-Section 2.1Geography & Demography Advisory Committee on Reactor Safeguards l 7The proposed CRN site location encompasses 935 acres of land adjacent to the Clinch River arm of the Watts Bar Reservoir, within the City of Oak Ridge, Roane County, Tennessee. Borders DOE Oak Ridge Reservation6.8 miles East of Kingston, TN9.2 miles East-Southeast of Harriman, TN8.8 miles Northwest of Lenoir City, TN25.6 miles West-Southwest of Knoxville, TNThe land is owned by the United States of America and managed by TVA as the agent of the federal government.Section 2.1

-Geography & Demography Section 2.1

-Geography & DemographyAdvisory Committee on Reactor Safeguards l 8Population DistributionThe low-population zone (LPZ) is defined as a 1 mi radius from the site center point.There are no hospitals, prisons, or jails within the LPZThere are no transient population events or attractions within this area.

Section 2.1

-Geography & DemographyAdvisory Committee on Reactor Safeguards l 9There are no residences or commercial activities within the EAB

.No public highways or active railroads traverse the exclusion area.Barge traffic occurs adjacent to the EAB along the Clinch River arm of the Watts Bar Reservoir.Exclusion Area Boundary Section 2.1

-Geography & DemographyAdvisory Committee on Reactor Safeguards l 10Population DistributionThe population distribution surrounding the site, up to a 50

-mi radius , estimated based upon the most recent 2010 USCB decennial census data

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

Section 2.1

-Geography & DemographyAdvisory Committee on Reactor Safeguards l 11Population CenterDistance to population center boundary (greater than 25,000 people) complies with 10 CFR 100.3 guidance.USCB census

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

Section 2.1

-Geography & DemographyAdvisory Committee on Reactor Safeguards l 12Population DensityPopulation densities, per Regulatory Guide 4.7, General Site Suitability Criteria for Nuclear Power Stations , were calculated for the 50-mi region for the projected start of construction date (2021), the projected commencement of operation date for the last unit (2027), and the end of operation date (2067).The total projected permanent population for 2021 and 2027 is approximately 1,305,000 and 1,377,000, respectively.The total projected transient population for 2021 and 2027 is approximately 638,000 and 674,000, respectively. The 2021 and 2027 total projected population for the 50-mi region is approximately 1.94 million and 2.05 million, respectively. The 2021and 2027 total population density is 247 people per mi 2 and 261 people per mi 2 , respectively. These projected population densities are less than the 500 people per mi 2 recommended by Regulatory Guide 4.7.

Advisory Committee on Reactor Safeguards l 13Chapter 2

-Section 2.2Nearby Industrial, Transportation, and Military Facilities Section 2.2

-Nearby Industrial, Transportation, and Military Facilities l 14Locations and RoutesPotential hazard facilities and routes within the 5-mile vicinity of the CRN Site identified in accordance with RG 1.206, RG 1.91, RG 4.7, and RG 1.78

.-Identified all facilities and activities within 5 miles

-Identified potentially significant facilities and activities beyond 5 miles.1 navigable waterway, 1 major highway, 4 major roads, 1 minor rail line, and 2 natural gas pipelines identified within 5 miles.Additional industrial facilities were identified beyond 10 miles that were significant enough to be considered for further review.No identified roads, railways or navigable waterways at distances greater than 10 miles that are significant potential hazards.Description of Products and MaterialsIdentified chemicals used, produced, or transported by each facility/activity.Advisory Committee on Reactor Safeguards Section 2.2

-Nearby Industrial, Transportation, and Military FacilitiesAdvisory Committee on Reactor Safeguards l 15ORNL (Battelle and URS)TVA Kingston Fossil PlantOak Ridge WTPTVA Bull Run Fossil PlantHallsdalePowell Utility District Melton Hill WTPIndustrial Facilities Advisory Committee on Reactor Safeguards l 16Section 2.2

-Nearby Industrial, Transportation, and Military FacilitiesClinch River arm of Watts Bar ReservoirI-40TN 1/US11-70, and TN 58, TN 95, and TN 327Heritage Railroad Corporation RailwayEast Tennessee Natural Gas Pipeline 1 (6 inch) and Pipeline 2 (22 inch)Transport Routes/Natural Gas Pipelines Advisory Committee on Reactor Safeguards l 17Section 2.2

-Nearby Industrial, Transportation, and Military FacilitiesBig TWolf CreekCox FarmWill A HildrethFarmRiley CreekFederal Airways V16 and J46Airports and Airways Section 2.2

-Evaluation of Potential AccidentsAdvisory Committee on Reactor Safeguards l 18Determination of Potential AccidentsRG 1.206 states that design

-basis events, internal and external to the CRN Site, are defined as those accidents that have a probability of occurrence on the order of magnitude of 10

-7 per year or greater with potential consequences serious enough to affect the safety of the plant to the extent that the guidelines in 10 CFR 100 could be exceeded.The following accident categories are considered in selecting design

-basis events:

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

-Collisions with the intake structure.

-Aircraft hazards.

-Liquid spills.

Advisory Committee on Reactor Safeguards l 19Section 2.2

-Evaluation of Potential AccidentsThe following locations were analyzed for postulated accidents within the accident categories considered in selecting design

-basis events:Nearby Storage Facilities

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

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

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

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

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

)Nearby Transportation Routes

-East Tennessee Natural Gas Pipelines 1 and 2

-I-40-Federal Airways V16 and J46 Advisory Committee on Reactor Safeguards l 20Section 2.2

-Evaluation of Potential AccidentsEffects of Design Basis EventsEvaluations were performed of the potential hazards nearby to the CRN Site. These evaluations concluded that potential accidents involving explosions, flammable vapor clouds, collisions with intake structures, and liquid spills do not pose a threat to the CRN Site. Evaluation of the potential effect of toxic chemical releases from nearby industrial and transportation routes concluded that, except for anhydrous ammonia and chlorine potentially transported along I

-40, the distance to the toxic endpoints are less than the distance to the CRN Site power block area. A main control room habitability analysis will be performed at the time of COLA for the transport of anhydrous ammonia and chlorine on I

-40.The effects of chemical releases from onsite chemical storage will be evaluated in the COLA because plant features such as the control room habitability system design and location of safety-related structures must be considered to determine there is no adverse effect from these hazards

.

Advisory Committee on Reactor Safeguards l 21Chapter 3

-Section 3.5.1.6Aircraft Hazards Advisory Committee on Reactor Safeguards l 22Section 3.5.1.6

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

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

-7 per year by inspection.

Advisory Committee on Reactor Safeguards l 23Section 3.5.1.6

-Aircraft HazardsFive small privately

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

-owned airports are within 10 to15 statute mi of the CRN Site

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

.The results of this evaluation, summarized in SSAR Table 2.2-7 of the ESPA, indicate that the proximity screening criterion 1 is met for each evaluated airport; therefore, no nearby airports need further evaluation.Criterion 1: The plant-to-airport distance, D, is between 5 and 10 statute miles, and the projected annual number of operations is less than 500 D2, or the plant

-to-airport distance, D, is greater than 10 statute miles, and the projected annual number of operations is less than 1000 D2.

Advisory Committee on Reactor Safeguards l 24Section 3.5.1.6

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

.The closest military operation area (MOA) is the Snowbird MOA located approximately 36 mi from the CRN SiteGiven this separation distance between the CRN Site and the nearest military training route (greater than 5 mi from the nearest edge of a military training route), along with the distance to the nearest MOA, criterion 2 is met.Criterion 2: The plant is at least 5 statute miles from the nearest edge of military training routes, including low

-level training routes, except for those associated with usage greater than 1000 flights per year, or where activities (such as practice bombing) may create an unusual stress situation.

Advisory Committee on Reactor Safeguards l 25Section 3.5.1.6

-Aircraft HazardsThere are two Federal airways, one victor (V) and one jet (J) route (V16 and J46, respectively) whose nearest edge lies within 2 statute mi of the CRN Site. Thus, due to the proximity of Federal airways V16 and J46, the proposed CRN Site does not meet proximity screening criterion 3

.A detailed aircraft hazards analysis was performed and the expected rate of occurrence of potential exposures resulting in radiological dose has been shown to be on the order of magnitude of 10

-6 per year and the realistic probability has been shown to be lower, based on qualitative arguments. Criterion 3: The plant is at least 2 statute miles beyond the nearest edge of a Federal airway, holding pattern, or approach pattern.

Advisory Committee on Reactor Safeguards l 26Chapter 15 Transient and Accident Analysis Advisory Committee on Reactor Safeguards l 27Accident SelectionNEI 10-01, Industry Guidance for Developing a Plant Parameter Envelope in Support of an Early Site Permit recommends that accident analyses model the time

-dependent transport of radionuclides out of the reactor core through several pathways, each with different time

-dependent removal mechanisms for radionuclides.

-For the purposes of evaluating offsite post

-accident doses, the vendor analysis with the highest resultant post

-accident dose was selected for use in the CRN Site

-specific dose analysis.Each of the four small modular PWR designs under consideration for the CRN Site is expected to include advanced design features that would further minimize accident consequences.TVA anticipates that the consequences of a LOCA will be less than those for large PWR designs and that no events of greater consequence will be identified

.The COLA will verify that the accident doses provided in this ESPA are bounding or provides an evaluation of accident radiological consequences.Chapter 15

-Transient and Accident Analysis Advisory Committee on Reactor Safeguards l 28Chapter 15

-Transient and Accident AnalysisSource TermsThe PPE LOCA source term is based on a design that uses standard light

-water reactor fuel, which is representative of the SMR designs under consideration, and assumes a core power level for a single unit at 800 MW thermal.To assess reasonableness, a comparison of the PPE LOCA source term to that of the AP1000 design was performed.

-The activity release associated with the worst 2

-hour time period of the scaled

-down AP1000 is approximately 25 percent greater than that for the surrogate plant (as provided in the PPE).

-The activity release for the 30

-day duration of the LOCA is approximately equivalent to that of the surrogate plant and is also considered reasonable.

Advisory Committee on Reactor Safeguards l 29Chapter 15

-Transient and Accident AnalysisEvaluation Methodology and ConclusionsSMR Doses for a LOCA are evaluated at the EAB and LPZ boundary.Doses are calculated using the ratio of the Q methodology.The evaluation uses the following parameters:

-Short-term 95 thpercentile accident atmospheric dispersion factors (X/Qs) for the CRN Site.-Bounding vendor

-provided LOCA doses.

-X/Q values associated with the bounding vendor

-provided LOCA doses.The resulting accident doses are expressed as total effective dose equivalent (TEDE), consistent with 10 CFR 52.17. All site LOCA doses meet the 25 rem TEDE limit specified in 10 CFR 52.17 AC R S Subcommi tt e e Me etingl Novembe r 15 , 2 01 7 l 30 1Presentation to the ACRS SubcommitteeSafety Review of the Clinch River Nuclear Site, Early Site Permit ApplicationDemography/Geography/Site Hazards:

(SSAR Sections 2.1 and 2.2)Presented by Seshagiri Rao Tammara, Technical ReviewerNRO/DSEA/RPACMay 15, 2018 2.Key Review Areas2.1 Geography and DemographySite Location and DescriptionCoordinates, site boundaries, orientation of principal plant structures, location of highways, railroads, and waterways that traverse in the vicinity of the site and exclusion areaExclusion Area Authority and ControlLegal authority, control of activities unrelated to plant operation, and arrangements for traffic controlPopulation DistributionCurrent population and future projections, characteristics of the low population zone (LPZ), population center distance, and population density 3Key Review Areas2.1 Geography and DemographyStaff reviewed the information provided by the applicant pertaining to Site Location and Description, and also checked independently the information available from the public domain. Staff found it to be acceptable as they satisfy the guidance provided in NUREG-0800 Section 2.1.1.Staff reviewed the information provided by the applicant pertaining to Exclusion Area Authority and Control. Based on the information provided, the staff finds it to be acceptable as it satisfies the guidance provided in NUREG -0800 Section 2.1.2.

4.Key Review Areas2.1 Geography and Demography (cont'd)Staff reviewed the information provided by the applicant pertaining to Population Distribution including population projections covering the life of the plant, Population Center Distance and Population Density.Based on the information provided by the applicant and staff's independent confirmatory evaluation, the staff found the information to be acceptable as it meets the requirements of 10 CFR 100.20.

5.Key Review Areas2.2 Nearby Industrial, Transportation, and Military FacilitiesIdentification of Potential Hazards in Site VicinityMaps of site, nearby significant facilities and transportation routesDescription of facilities, products, materials, and number of people employedDescription of pipelines, highways, waterways, airways and airportsProjections of industrial growth 6.Key Review Areas2.2 Nearby Industrial, Transportation, and Military Facilities (Cont'd)Staff reviewed the information provided by the applicant pertaining to the location and description of Nearby industrial, Transportation and Military Facilities for the evaluation of potential hazards for the safe operation of the proposed plant.Based on the review of information provided by the applicant and the staff's independent checking of information from the available data from the public domain, the staff found it to be acceptable as the information meets the guidance provided in NUREG-0800 Section 2.2.1

-2.2.2.The current site plans indicate future construction of an airport nearby the site by 2022. If this is in operation by COLA stage, its impact evaluation is required to be addressed in COLA. Permit condition 2.2

-1 concerns this requirement.

7.Key Review AreasEvaluation of Potential Accidents:Design-Basis Events: Accidents having a probability of occurrence on the order of magnitude of 10

-7per year or greater and resulting in a potential consequences exceeding 10 CFR 100 dose guidelinesExplosions and Flammable Vapor Clouds

-Industrial Facilities, Truck Traffic, Pipelines, Waterway TrafficRelease of Hazardous Chemicals

-Transportation Accidents, Major Depots, Storage Areas, Onsite Storage TanksFires -Transportation Accidents, Industrial Storage Facilities, Onsite Storage, Forest 8.Key Review AreasEvaluation of Potential Accidents (Cont'd):Staff reviewed the applicant-provided site specific evaluations of potential accidents. The applicant performed evaluations of potential hazards due to nearby facilities in the CRN Site vicinity. The effects of chemical releases from onsite chemical storage will be evaluated in the COLA referencing this ESP, because the locations of storage, control room and other safety-related structures designs and locations will be determined at COLA stage.

9Key Review AreasEvaluation of Potential Accidents (Cont'd):Based on the review of the applicant

-provided information, analyses and the staff's independent confirmatory calculations, the staff found the applicant's conclusions to be acceptable, as the evaluations are in accordance with the guidance provided in NUREG

-0800 Section 2.2.3, with the exception of potential impacts from toxic chemical release of anhydrous ammonia, chlorine and nitric acid from a truck transport on nearby roadway. Since the applicant determined the minimum safe distance due to potential toxic chemical concentration of anhydrous ammonia, chlorine and nitric acid from the potential release from a truck transport is greater than the actual distance, the applicant is committed and shall reanalyze the impacts of the delivery tanker truck using guidance provided in RG 1.78 and NUREG-0800, to demonstrate the compliance with 10 CFR100.20. Therefore, Permit Condition 2.2

-2 is included.

1Presentation to the ACRS SubcommitteeSafety Review of the Clinch River Nuclear Site, Early Site Permit ApplicationAircraft Hazards:

(SSAR Section 3.5.1.6)Presented by Seshagiri Rao Tammara, Technical ReviewerNRO/DSEA/RPACMay 15, 2018 2.Key Review Areas3.5.1.6 Aircraft HazardsFor the site suitability, the plant design should consider that any of the aircraft accidents is not a design basis event (where the aircraft accident could lead to radiological consequences in excess of the exposure guidelines of 10 CFR 50.34(a)(1) with a probability of occurrence greater than an order of magnitude of 10-7per year)Federal airways, holding patterns, or approach patterns should be at least 2 statute miles awayMilitary installation or any airspace usage (e.g., bombing ranges) should be at least 20 miles from siteAll airports should be at least 5 miles from site 3.Key Review Areas3.5.1.6 Aircraft Hazards (Cont'd) All airports should have projected operations less than:

1.500d 2for airports within a distance (d) of 5 to 10 miles 2.1000d 2for airports outside of 10 miles distance (d) Staff reviewed the applicant's information pertaining to site-specific aircraft analysis (aircraft hazards

).The applicant calculated the aircraft crash probability for the identified two airways (V16 and J46) which are within 3.2 km (2 mi) of the CRN Site.The applicant determined the aircraft crash probability of 7.53 x 10-7 per year using non

-airport operations referenced in DOE-STD-3014-96, "Accident Analysis for Aircraft Crash into Hazardous Facilities."

4.Key Review Areas3.5.1.6 Aircraft Hazards (Cont'd)The staff performed independent confirmatory aircraft crash probability calculations using the highest recent 5-year (2011

-2015) Federal Aviation Administration (FAA) supplied flight operations data within 8 km and 16.1 km (5 mi and 10 mi) of site.The potential aircraft crash probability of 1.5 x 10

-8 per year is conservatively estimated by the staff, assuming that all the flights within 16.1 km (10mi) of CRN Site from FAA data follow these two airways. Therefore, staff agrees with applicant's conclusion that the aircraft crash probability is about an order of magnitude of 10-7per year or less and meets the provided NRC guidelines.

1Presentation to the ACRS SubcommitteeSafety Review of the Clinch River Nuclear Site, Early Site Permit ApplicationAccident Analysis, (SSAR Chapter 15

)Presented by Seshagiri Rao Tammara, Technical ReviewerNRO/DSEA/RPACMay 15, 2018 2Accident AnalysisSSAR Chapter 15 "Accident Analysis"Evaluation of the radiological consequences of postulated Design Basis Accidents (DBAs) for the proposed CRN SiteDose analysis used

1.PPE accident source term consisting of assumed DBA isotopic releases to environment in lieu of specific plant design information 2.Site characteristic short term (accident) atmospheric dispersion factors (See review of SSAR Chapter 2) 3Regulations and GuidanceSSAR (10 CFR 52.17(a)(1)) and siting (§50.34(a)(1)) postulated accident dose analysis requirements have the same dose criteria:The evaluation must determine that:

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

2.An individual located at any point on the outer boundary of the low population zone, who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage) would not receive a radiation dose in excess of 25 rem TEDE.SRP 15.0.3 provides review guidance, including evaluation of PPE accident releases.

4PPE Accident Source TermChapter 15 "Accident Analysis" (cont'd)The radionuclide release to the environment for a loss of coolant accident (LOCA) is documented and is considered by the applicant in the ESP application as a part of the PPE in SSAR Table 2.0-3.Staff found the PPE LOCA release source term to be not unreasonable for the purposes of site analysis or postulated from considerations of possible accident event

.The PPE source term is compared with that of AP1000 design (provided in Vogtle3 and 4 ESPA) with scaling ratio of 0.235 (800 MWt/3,400 MWt) and ascertained to be not unreasonable.

5DBA Dose AnalysisChapter 15 "Accident Analysis" (cont'd)The accident doses at the exclusion area boundary (EAB) and the outer boundary of the low population zone (LPZ) at the CRN Site are obtained by multiplying the vendor supplied dose associated with bounding PPE LOCA source term, by the ratio of the site-specific(site

-characteristic) and vendor supplied site

-parameter X/Qs.Dosesite= Dosevendor[(X/Q)site/ (X/Q)vendor ]Analysis meets the dose criteria specified in 10 CFR 50.34(a)(1) and 10 CFR 52.17(a)(1) and the PPE includes the bounding accident releases for the determination.

6DBA Dose AnalysisChapter 15 "Accident Analysis" (cont'd)The calculated radiological consequences at CRN Site are within regulatory dose criteria of 25 rem TEDE for the maximum 2

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