ML19282A379
| ML19282A379 | |
| Person / Time | |
|---|---|
| Issue date: | 09/04/2019 |
| From: | Kent Howard Advisory Committee on Reactor Safeguards |
| To: | |
| Howard, K, ACRS | |
| References | |
| NRC-0552 | |
| Download: ML19282A379 (140) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Advisory Committee on Reactor Safeguards Docket Number: (n/a)
Location: Rockville, Maryland Date: Wednesday, September 4, 2019 Work Order No.: NRC-0552 Pages 1-112 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 666TH MEETING 5 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 6 (ACRS) 7 + + + + +
8 WEDNESDAY 9 SEPTEMBER 4, 2019 10 + + + + +
11 ROCKVILLE, MARYLAND 12 + + + + +
13 The Advisory Committee met at the Nuclear 14 Regulatory Commission, Two White Flint North, 15 Room T2B3, 11545 Rockville Pike, at 1:00 p.m., Peter 16 Riccardella, Chairman, presiding.
17 COMMITTEE MEMBERS:
18 PETER RICCARDELLA, Chairman 19 MATTHEW W. SUNSERI, Vice Chairman 20 JOY L. REMPE, Member-at-Large 21 RONALD G. BALLINGER, Member 22 DENNIS C. BLEY, Member 23 CHARLES H. BROWN, JR., Member 24 MICHAEL L. CORRADINI, Member 25 VESNA B. DIMITRIJEVIC, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 WALTER L. KIRCHNER, Member 2 JOSE MARCH-LEUBA, Member*
3 DAVID PETTI, Member 4 HAROLD B. RAY, Member 5
6 7 DESIGNATED FEDERAL OFFICIAL:
8 WEIDONG WANG 9 KENT HOWARD 10 11 *Present via telephone 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 CONTENTS 2 Opening Remarks by the ACRS Chairman . . . . . . 4 3 Advanced Reactor SECY Policy Paper on Siting . . 6 4 Turkey Point Subsequent License Renewal . . . . . 48 5 Adjourn . . . . . . . . . . . . . . . . . . . . 112 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 P R O C E E D I N G S 2 (1:00 p.m.)
3 CHAIRMAN RICCARDELLA: The meeting will 4 come to order. Today is the first day of the 666th 5 meeting of the Advisory Committee on Reactor 6 Safeguards.
7 I'm Pete Riccardella, ACRS Chairman.
8 The ACRS was established by the Atomic 9 Energy Act and is governed by the Federal Advisory 10 Committee Act, FACA.
11 The ACRS section of U.S. NRC public 12 website provides information about the history of the 13 ACRS and provides FACA-related documents, such as 14 chapter, bylaws, Federal Register Notices for 15 meetings, letter reports, and transcripts of all full 16 and subcommittee meetings, including all slides 17 presented at the meetings.
18 The committee provides its advice on 19 safety matters to the Commission through its publicly 20 available letter reports. The Federal Register Notice 21 announcing this meeting was published on August 6th 22 and provides an agenda and instructions for interested 23 parties to provide written documents or request 24 opportunities to address the committee, as required by 25 FACA.
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5 1 In accordance with FACA, there is a 2 Designated Federal Official for today's meeting. The 3 DFO for this meeting is Mr. Weidong Wang.
4 During today's meeting, the committee will 5 consider the following: Advanced Reactor SECY Policy 6 Paper on Siting, Turkey Point Subsequent License 7 Renewal, and Preparation of ACRS Reports.
8 There is a phone bridge line. To preclude 9 interruption of the meeting, the phone will be placed 10 in a listen-in mode during presentations and committee 11 discussion.
12 We have received no written comments or 13 requests to make oral statements from members of the 14 public regarding today's session. There will be an 15 opportunity for public comment, as we have set aside 16 10 minutes in the agenda for comments from members of 17 the public attending or listening to our meeting.
18 Written communications may be forwarded to 19 Mr. Weidong Wang, the Designated Federal Official.
20 A transcript of the open portions of the 21 meeting is being kept, and it is requested that 22 speakers use one of the microphones, identify 23 themselves, and speak with sufficient clarity and 24 volume, so that they can be readily heard.
25 I would like to request that everybody NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 silence their cell phones or other devices that might 2 make noise in the meeting.
3 And I also believe we have Member Jose 4 March-Leuba on a private line calling in. He is 5 hurricane-bound in Florida, but he will attend 6 remotely.
7 Jose, are you there?
8 MEMBER MARCH-LEUBA: Yes, I'm here. Thank 9 you.
10 CHAIRMAN RICCARDELLA: Okay. Very good.
11 So the first topic, as I mentioned, is 12 Advanced Reactor SECY Policy Paper on Siting, and I 13 would like to ask the Subcommittee Chairman, Dennis 14 Bley, to introduce the subject.
15 MEMBER BLEY: Thank you, Mr. Chairman.
16 And thanks to everyone for having the phones working 17 today. It's great.
18 We had a subcommittee meeting a few weeks 19 ago, and most of the members were there. Some issues 20 were raised, and I hope our presenters from the staff 21 will address some of those issues if they can.
22 At this point, I will turn the session 23 over to John Segala, NRO.
24 MR. SEGALA: Thank you, Dr. Bley, and 25 thank you, Chairman Riccardella, and the other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 committee members, for the opportunity to present 2 today on this important topic of population-related 3 siting considerations for advanced reactors.
4 As you know, this is a topic that has a 5 long history. And as Dr. Bley said, we briefed the 6 subcommittee meeting on August 23rd, and had a lot of 7 good discussions, and we're prepared today to answer 8 some of the committee/subcommittee's comments.
9 At the end of this meeting, we'll be 10 requesting a letter from the full committee on our 11 draft Commission paper.
12 And with that, I'll turn it over to Bill 13 Reckley, a senior project manager in my branch.
14 MR. RECKLEY: Thanks, John. As John 15 mentioned, this paper is related to population-related 16 siting consideration. I just kind of want to stress 17 that siting has a lot of different considerations, 18 both on the site as a potential hazard to the reactor, 19 and then of course the reactor as a potential hazard 20 to the environment. And this paper is limited to a 21 small slice of those issues, which is related to 22 population around a site.
23 So the purpose of the paper is to provide 24 the Commission with options and a recommendation on 25 possible change to the guidance documents. I will get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 into some of this in a little more detail, but right 2 from the beginning emphasize that we don't see at this 3 time a need to change regulations, but we think the 4 situation would benefit from revision to the guidance 5 documents; in particular, Regulatory Guide 4.7.
6 So the paper is laid out with that 7 purpose, some background in terms of regulations and 8 guidance, a discussion, which is largely a description 9 of the options, and then a specific recommendation 10 from the staff to the Commission.
11 I have tried to collapse all of that in 12 terms of regulations and guidance onto this one graph.
13 And you can see up this -- up the left side are the 14 regulations that most of us are most familiar with, 15 and that is 10 CFR 100.21, as it relates to defining 16 exclusion areas, low population zones, and population 17 center distances.
18 And just to summarize those circles, the 19 exclusionary boundary is defined actually within 20 Part 50 and Part 52 as that distance at which an 21 individual would receive less than 25 rem in two 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br />, the worst two hours of an accident.
23 MEMBER BLEY: Bill?
24 MR. RECKLEY: Yes.
25 MEMBER BLEY: You said this only focuses NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 on population, which is the outcome. But it's deeply 2 involved with all of the other aspects that affect 3 what the doses are going to be, which you can't 4 ignore. And I'm going to express a little surprise, 5 and you may have this covered later, one has to decide 6 for which accidents they are going to calculate the 7 doses, which really has to do with a lot more, 8 including risk.
9 And I'm a little curious why you folks 10 didn't have an option, maybe I'd call it 3A, that 11 really tried to be risk-informed about the criteria 12 that we use. And I don't know if you can plan to get 13 to that later. If you do, that's just fine.
14 MR. RECKLEY: Yeah. I think in about two 15 slides I'll try to address that. And if I don't 16 succeed, you can continue with the question.
17 So, again, the standard definitions down 18 the left side there, for the low population zone, 19 which is the distance at which 25 rem would -- less 20 than 25 rem to an individual for the duration of the 21 accident, and then a low -- a population center 22 distance, which is defined in the rules as being one-23 and-a-third times the radius of the low population 24 zone. And that is the minimum distance to which a 25 reactor could be in relation to a population center of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 about 25,000 people.
2 Over on the right side, you have 10 CFR 3 100.21H, which is a vaguely worded rule.
4 MEMBER CORRADINI: Can I --
5 MR. RECKLEY: Go ahead.
6 MEMBER CORRADINI: I want to repeat 7 something that I wrote down, but I could have it 8 wrong, from the subcommittee meeting. The definition 9 of a population center is a tad fuzzy.
10 MR. RECKLEY: Yes.
11 MEMBER CORRADINI: It's not precise, as I 12 remember you stating at the time.
13 MR. RECKLEY: Right.
14 MEMBER CORRADINI: True?
15 MR. RECKLEY: Yes.
16 MEMBER CORRADINI: Okay.
17 MR. RECKLEY: Well, it is about 25,000.
18 MEMBER CORRADINI: Well, I guess the 19 boundary of where I draw -- where I count 25,000 20 people --
21 MR. RECKLEY: It's a population boundary, 22 not a political boundary.
23 MEMBER CORRADINI: Okay.
24 MR. RECKLEY: So you look for where the 25 actual population is. You map that out, and that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 the distance to the population center, not necessarily 2 the political boundary of a -- you know, an 3 incorporated town or a city limit.
4 MEMBER CORRADINI: So the centroid of 5 where the population rises to or near 25,000.
6 MR. RECKLEY: Yes.
7 MEMBER CORRADINI: Okay.
8 MEMBER BLEY: I'm sorry. You said 9 "centroid," which implies the middle, and it's not.
10 MR. RECKLEY: The edge of the population 11 boundary.
12 MEMBER CORRADINI: But if it's not the 13 political boundary, then I could have a farm, a dairy, 14 since I'm that part of the country, a dairy entity.
15 And if I add up the 25,000, and the dairy farm is the 16 closest thing to 25,000, that's the boundary? I'm 17 still struggling as to how I get the 25,000 if it's 18 not the center of it.
19 MR. RECKLEY: Right. It did -- take a 20 case where you just draw where an actual population, 21 like a town where the residences start. So, in your 22 case, you would probably skip over the farm, right?
23 Skip over those couple hundred acres of the farm, even 24 if they're in the political boundary, and go to where 25 the actual residences, the suburban type, the actual NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 -- with some density of that population, draw a circle 2 around it. This is very inexact.
3 MEMBER CORRADINI: Okay. So that's all I 4 was trying to get at. It's inexact, and it's a matter 5 of judgment and conversation, not a clear -- it's not 6 like a -- it's not like, you know, normal distribution 7 I take the 595 of the population and it adds up to 25.
8 MR. RECKLEY: For that population center.
9 Now, when we get to the next one, which is under 121H, 10 where we're looking at population density, and that 11 rule is also vaguely worded, it says located away from 12 population centers in low population densities are 13 preferred.
14 The way we meet that rule is through the 15 guidance in Reg Guide 4.7 that looks at population 16 density of 500 persons per square mile and ever-17 increasing radius. So the first mile you couldn't 18 have more than 1,571 people; in the second mile, 19 6,000; and it keeps going with those constraints until 20 you get to the limit of 20 miles. We look at 21 population density out to 20 miles, and the population 22 within that 20-mile circle would have to be less than 23 628,000 people.
24 And so those things in combination are how 25 you basically address some of the issues and some of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 the vagueness that you're referring to.
2 MEMBER RAY: To respond to Mike again a 3 little bit, I just want to draw attention to the fact 4 we're talking about densely populated. And the farm 5 example you gave isn't an example of densely 6 populated.
7 MEMBER CORRADINI: But I could have -- I 8 could have -- I won't use a particular town that I am 9 aware of, but a town in the Midwest which has a 10 population of suburban -- or of houses, but then as I 11 move out I could have farms that are closely packed 12 but that are within the political boundary, but may 13 not be in the population center.
14 MEMBER RAY: They are not in -- in my 15 judgment, they are not in a densely populated center.
16 They are outside the densely populated center.
17 MR. RECKLEY: Right. Even though they 18 might be in the political boundary. Right.
19 MEMBER RAY: Or in between you and the 20 densely populated center.
21 MR. RECKLEY: Yes.
22 MEMBER RAY: For example.
23 MR. RECKLEY: Right.
24 CHAIRMAN RICCARDELLA: Bill, I'm sorry.
25 I wasn't able to attend the subcommittee meeting, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 these -- the 25 rem for the two other zones, that 2 assumes what some accident under some design -- under 3 the design basis accident or something.
4 MR. RECKLEY: In the traditional sense, it 5 includes the Reg Guide 1465, the alternate source 6 term, or before that the TID 14484. Source term, into 7 the containment, and then with the conditions of the 8 allowable leakage out of the containment, in a 9 traditional sense.
10 In a second, I will get to an alternative 11 to that for advanced reactors.
12 CHAIRMAN RICCARDELLA: Okay. Thank you.
13 MR. SEGALA: And I'd just like to add for 14 the Reg Guide, it has you project out the population 15 five years from the initial siting, and it also says, 16 you know, reactors should not be located at a site 17 where the population density is well in excess of the 18 500. So even -- it's a guidance document, so it's not 19 a strict acceptance criteria, 500.
20 MR. RECKLEY: Keeping in mind that the 21 rule that we're enforcing says population -- low 22 population density preferred. It's an unusual rule, 23 and it dates back to the fact that this siting 24 guidance and siting as a policy for the Commission 25 goes back to the beginning, really. This guidance was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 first written in 1962.
2 So as we looked at it and interfaced with 3 stakeholders, there were two issues that we identified 4 with the planned uses of advanced reactors, and in 5 particular small modular reactors, and the guidance as 6 it was written, and called on us to assess whether we 7 could change the guidance while maintaining 8 appropriate public safety and conformance to the 9 rules.
10 The first was the limitation of 500 11 persons per square mile out to 20 miles, and the 12 second one -- policy issue was actually the same 13 population density, but close in to a reactor site.
14 So if you go back to the previous slide, you can see 15 a potential use for small modular reactors or advanced 16 reactors in general would be for remote areas.
17 And so take a remote area, a small town in 18 Alaska, this would say -- the current guidance would 19 say that population within the first mile couldn't 20 exceed 1,500 people. The desire would be to have that 21 reactor most likely closer to the town than a mile 22 away, because the reason you want it there is that it 23 currently has no grid.
24 The other area of concern was within DOE 25 and other stakeholder interest was the possible use of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 reactors to replace retiring fossil units. And they 2 might be closer to population centers than the 20-mile 3 criteria or the 15-mile criteria would allow in terms 4 of populations within that circle being limited to 5 350,000 in the case of 15 miles.
6 And so if a reactor can safely be put 7 somewhere, would it make sense to revise the siting 8 guidance to allow it? And that was the matter that we 9 were looking at.
10 MEMBER BLEY: Bill, one thing that bothers 11 me about the right-hand side of this figure is when 12 you put total populations in there, assuming a 13 population density, and rings around the reactor, the 14 population is going to be off somewhere away from the 15 reactor. And in one direction, the population density 16 could go quite high, where if you average it in rings 17 by miles away from the reactor, you could make it look 18 very low.
19 And is this kind of setting up per mile 20 rings? Is that specified in the reg guide?
21 MR. RECKLEY: I think there is actually 22 some look by sector in addition to rings, to totally 23 avoid what you're saying.
24 MEMBER BLEY: Because you would really be 25 -- it would really be smooshing out the population NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 where it isn't and saying I have a low population 2 density when --
3 MR. RECKLEY: It is looked at in a little 4 more than just the consent agreements.
5 MEMBER BLEY: Okay.
6 MR. RECKLEY: So with that as background, 7 some of the additional background and history relating 8 to siting is in an Oak Ridge report, and I gives the 9 ADAMS accession number there.
10 They also developed a possible approach, 11 and I'll be talking about that in a second. That's 12 Option 2.
13 So the staff developed four options. As 14 you can kind of get out of this conversation, there 15 are many ways that one could approach this. So we 16 could have had many more four options, but we did 17 narrow it down to try to give the Commission an idea 18 of different ways that this might be addressed.
19 So one of the things that we did do is 20 look at the paper and some of the comments and some of 21 the discussion we had on August 23rd during the 22 subcommittee meeting. And we're -- in the background 23 there are some proposed changes that would summarize 24 what would we -- what we would put in the paper.
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18 1 took away anyway. One was to reinforce that this 2 guidance is related to unplanned releases and 3 accidents. There are rules in place for normal 4 effluents, normal operations. That is continued to be 5 controlled under those regulations such as 10 CFR Part 6 20.
7 Another question was on how Option 3 would 8 be implemented, and this goes to what Dr. Bley was 9 mentioning. What events do you look at? How are you 10 getting a source term in order to calculate the dose 11 for Option 3, which is the one that is based on an 12 assessment of the individual dose at a distance.
13 And there's two possible approaches that 14 we've talked about within the paper, and we tried to 15 clarify a little bit with the footnote in the backup 16 slides. The first is how we expect it to be pursued 17 for those that are using the methodology described in 18 draft Guide 1353 and NEI 18-04. That's the risk-19 informed approach that we brought before the committee 20 six months ago or more.
21 And in that -- if the reactor -- the 22 designer is using that methodology, they will develop 23 a mechanistic source term for the event sequences.
24 They will evaluate all of the event sequences in the 25 categories of design and beyond design basis events, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 and they will assess the offsite consequences.
2 And that would be the dose coming out of 3 those two event categories that they would compare to 4 the one rem in a month that we talk about under Option 5 3. And I'll get -- I know it's a little disjointed 6 here.
7 But another question that came up was the 8 -- how multi-unit events are handed. And so that same 9 footnote we were able -- a different footnote, we were 10 able to describe that 1353 or NEI 18-04 is done by 11 plant year. And so they are specifically looking at 12 multi-unit events or events that could affect more 13 than one radionuclide source in that event. So 14 whether it be reactors or off-gas systems or whatever 15 the source term might be.
16 MEMBER CORRADINI: So this is in the 17 current SECY that we saw?
18 MR. RECKLEY: It was hinted at in the 19 backup slide. The backup slide hopefully goes into a 20 little more detail now.
21 MEMBER CORRADINI: In the footnotes, right 22 under Option 3, it was discussed there; did I miss it?
23 MR. RECKLEY: Well, only vaguely, as 24 Dr. Bley mentioned. It says --
25 MEMBER CORRADINI: So let me now do -- my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 hand calculation is if I have five of these, I have 2 five plant-years for every real year. That's what you 3 just said to me. That if I have five of these 4 collocated and there's a multi-module site, I would --
5 for every year passing I would take five plant-years 6 as the frequency effect? That's what I thought you 7 used by the term "plant-year" in the assessment.
8 MR. RECKLEY: Really, the way that this 9 methodology works, you're looking at the probability 10 of an event at the plant. That could be a single-unit 11 event or a multi-unit event.
12 MEMBER CORRADINI: Okay. So, in other 13 words, as some licensees might come in and calculate 14 what is with many on a site, many on a plant site, it 15 would not be a module, but it would be a module times 16 some multiplier by some definable review procedure.
17 MR. RECKLEY: Yes.
18 MEMBER CORRADINI: Okay. Very good. I 19 misunderstood. Thank you.
20 MEMBER REMPE: Since he interrupted you, 21 I'm looking at page 21 of the backup slides. And I 22 get the -- that you have -- again, right now, you have 23 beyond -- design and beyond design basis events if 24 they use 1353. But if they use a different approach, 25 it looks like they don't have to consider beyond NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 design basis events. They only look at possible plant 2 transients and accidents.
3 MR. RECKLEY: And what we're trying to 4 define there, and we got into this trouble in the 5 subcommittee meeting, and part of the problem is after 6 50 years no one agrees on the terminology, they would 7 do it the way they do it now.
8 So if you consider NUREG-1465 source term 9 as a design basis accident source term, then call it 10 a design basis accident source term. If you consider 11 it to be a beyond design basis accident source term, 12 then consider it to be a beyond design basis accident 13 source term.
14 MEMBER CORRADINI: But it's a source term 15 with containment performance specified in -- or some 16 sort of performance measures that are considered to be 17 conservative.
18 MR. RECKLEY: Yes. And a source term that 19 was considered to be conservative.
20 MEMBER CORRADINI: Correct. So it's 21 essentially a non-light water equivalent of 1465 with 22 Reg Guide 1.183 attributes.
23 MR. RECKLEY: Yes.
24 MEMBER CORRADINI: Okay.
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22 1 reactor and I don't want to try and do a PRA, I just 2 want to do a maximum hypothetical release. Does that 3 mean -- can they argue and say that that's not within 4 our design basis? That's never going to happen. Do 5 they have to do a maximum hypothetical release? What 6 will they do?
7 MR. RECKLEY: We're looking at that now.
8 So it's a little clearer under the 1353 that they 9 would categorize it. If they want to propose an 10 alternative, and we mention this in a section of the 11 draft guide, that if somebody wanted to use a maximum 12 hypothetical, they could do that, but that's really a 13 deviation from the guidance in NEI 18-04 and 1353.
14 So they are going to be coming in on their 15 own to justify that they have in that case identified 16 the actual maximum hypothetical accident to use in the 17 proposal.
18 So these aren't -- anyway, so they would 19 have to come in and justify that.
20 MEMBER REMPE: It doesn't fall under 21 Option 3, then. It's something different. I've 22 forgotten -- it's been a while since I've read the 23 draft, so --
24 MR. RECKLEY: It could, if they could 25 convince us that it was a maximum hypothetical. That NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 would, in effect, bound the beyond design basis event 2 in DG-1353. And so they could -- they could use this 3 guidance if they can convince us that they actually 4 have identified the maximum hypothetical.
5 MEMBER CORRADINI: Can I reverse this? If 6 I have a particular design with a particular set of 7 analyses that say nothing rises above five times 10-7, 8 one might have to infer some maximum credible accident 9 to at least decide what the distances are.
10 What if I have Joe's reactor, and Joe's 11 reactor is so safe that they buy their analysis, show 12 that nothing rises on a frequency basis above five 13 times 10-7, with uncertainty, therefore, I have to --
14 I have to define some maximum credible accident to 15 decide what the boundary is.
16 We were only talking the reverse 17 direction. I'm thinking that this other direction is 18 -- with inherent features of the design and the 19 passive design, I'm still going to have to identify 20 something as to decide what the boundary is.
21 MR. RECKLEY: Let me just pass on the 22 hypothetical. Basically, you're saying if I can -- if 23 I can design a reactor that has basically no chance of 24 releasing the radioactive materials, or at least --
25 MEMBER CORRADINI: Frequency under 1353.
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24 1 MR. RECKLEY: -- of below five times 10-7.
2 MEMBER CORRADINI: Yeah. Because we have 3 some already that --
4 MR. RECKLEY: I would hope that if 5 somebody is able to do that, we would say, "Great 6 job."
7 MS. CUBBAGE: So, Bill, what if you looked 8 at your Example 3 -- this is Amy Cubbage -- your 9 slide, it's less than one. Not Slide 3, it's Slide 10 12. I'm sorry.
11 MR. RECKLEY: Yeah. We'll get there under 12 that proposal, as to what the siting limitations would 13 be.
14 MEMBER CORRADINI: But back to Joy's 15 question, I want to make sure that we're clear. So 16 now at least in words in the revised SECY, there is a 17 path where the individual applicants could say we're 18 going to follow 1353 and those estimates for 19 mechanistic source term and frequency, et cetera, but 20 I can also take another path and write my own approach 21 to a new 1465 that has the appropriate attributes and 22 is conservative and bounds it.
23 MR. RECKLEY: Yes. We said we would 24 review that. But, again, that is going to be a 25 deviation, and we'll review it as a specific proposal.
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25 1 MEMBER REMPE: And in that deviation, do 2 they get to stop at accidents, or do they need to go 3 to beyond design basis? Because the footnote to me 4 implies they don't have to go to beyond design basis.
5 They get to stop at accidents.
6 MR. RECKLEY: Well, keep in mind that the 7 light water methodology, with the stylized events and 8 the use of 1465, is light water reactor.
9 MEMBER CORRADINI: But what generated the 10 1465 source term are severe accidents that are beyond 11 the design basis.
12 MEMBER REMPE: Right.
13 MEMBER CORRADINI: So I would assume in 14 light way they would have to come up with a class of 15 potential accidents that are beyond their design base, 16 and then basically encapsulate with conservative 17 calculations to be the equivalent of a 13 --
18 MEMBER REMPE: Put Slide 21 up, if you 19 would, just for a minute. This is the revised --
20 MEMBER BLEY: I'd remind all of the 21 members we have only allotted an hour for this follow 22 up to the subcommittee.
23 MEMBER CORRADINI: Sorry.
24 MEMBER REMPE: That's what is kind of 25 bothering me, the mark-out of including design basis.
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26 1 MR. RECKLEY: And the reason I marked that 2 out -- I can put it back in, to be honest. The reason 3 I put it out -- struck it out was because it causes so 4 much confusion in what we do now, not in what we would 5 propose to do under 1353.
6 The source term that we use, whether you 7 calculate it under 1465 or the old TID, is called 8 different things by different people. And so that's 9 the concern.
10 So what I tried to do was to strike out 11 the confusion and say, "Do it by NUREG-800, the 12 standard review plan, and do it by Reg Guide 1.183,"
13 that defines how that is done, and try to avoid the 14 confusion of the terminology, because sometimes it's 15 called maximum credible, sometimes it's called maximum 16 hypothetical, sometimes it's called design basis.
17 MS. CUBBAGE: And if you look at the 18 sentence in question, striking the beyond design 19 basis, the words prior to that are talking about a 20 wide range of potential accidents.
21 MR. RECKLEY: Right.
22 MS. CUBBAGE: And that's not limited to 23 DBA.
24 MEMBER REMPE: Okay.
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27 1 there is the rationale for option three that was 2 discussed. We didn't change the paper.
3 We maintained the basis as the existing 4 criterion on population density, 500 people per square 5 mile, the compatibility with the methodology in DG-6 1353, and that's where we're getting the one rem over 7 a month for the analysis of the event sequences, and 8 engineering judgment for a multiplier that should take 9 that radius and multiply it by two. The --
10 MEMBER BLEY: Bill, right there, owing you 11 had the 30 days instead of --
12 MR. RECKLEY: Instead of 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
13 MEMBER BLEY: -- 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />, I get how 14 you're using 1353 to come up with the event sequences 15 to look at. What seems odd to me is, since we've 16 looked at 1353 and you guys have developed it, which 17 is looking for a risk informed --
18 MR. RECKLEY: Right.
19 MEMBER BLEY: -- approach, you could have 20 followed on with a risk informed approach to the 21 criteria, but you've put in what smelled like 22 arbitrary criteria once again, and why?
23 MR. RECKLEY: Again, as I said in the 24 beginning, we could have come up with a lot of 25 different alternatives.
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28 1 When we came up with option three, we were 2 trying to look at what, the limitations designers were 3 currently facing and whether we could come up with an 4 option that would maintain safety, but give them the 5 flexibility in siting, and after that, to stay as 6 simple as we could.
7 And really, as simple as we could was to 8 maintain the same criterion, 500 persons per square 9 mile, and then to introduce, as you mentioned, which 10 has got a risk informed element in it, the calculation 11 of the consequences, the one rem over a month.
12 And then the way we did the multiplier, to 13 be honest, I guess I can be honest, right, when we 14 first proposed this to stakeholders, our proposal was 15 two times the EPZ, and the reason it was two times the 16 EPZ is because that's roughly how it works out now.
17 The EPZ is 10 miles. We measure population density 18 out to 20 miles, so it's two times the EPZ.
19 As we interfaced with stakeholders, we 20 were convinced that linking it directly to the 21 emergency planning arena was probably not wise, and so 22 we withdrew the EPZ calculation and replaced it with 23 the LMP one rem over a month calculation.
24 I understand it's similar and they're not 25 unrelated, but it's a different parameter by a bit, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 but we kept the two. We kept the factor of two.
2 And footnote seven in the draft that you 3 have says the result of that will be that the area in 4 which we look at population density will be roughly 5 equivalent or slightly greater than two times the EPZ 6 and that's because the EPZ is two rem, I mean one rem 7 in the worst 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />. The LMP criterion is one rem 8 over the month.
9 MEMBER CORRADINI: And the times two is 10 just a factor of safety?
11 MR. RECKLEY: Yes, and again, in the 12 beginning, it was tied to the current practice --
13 MEMBER CORRADINI: Okay.
14 MR. RECKLEY: -- and we just maintained 15 that.
16 MEMBER CORRADINI: So just to repeat the 17 subcommittee, so is the staff planning to do any 18 calculations to understand the technical basis of all 19 of these choices?
20 MR. RECKLEY: The difficulty is -- the 21 short answer is no, and the reason is there's too many 22 variables in play, and that's because a large part of 23 what we're trying to do is to introduce a sense of a 24 societal measure without defining a societal measure, 25 and if you wanted a calculation that would push us in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 the direction of having to define some things in order 2 to back out what the appropriate number would be.
3 And so we thought about it and really 4 thought that it would be wiser just to pick a number.
5 If it comes across as engineering judgment, which, I 6 guess, in many parlances would also be synonymous with 7 arbitrary, that's where we are.
8 MEMBER CORRADINI: Okay.
9 MEMBER BLEY: Well, it's not always 10 arbitrary.
11 MR. RECKLEY: No.
12 MEMBER BLEY: To help you finish --
13 MR. RECKLEY: Yes, we're going to go 14 through it.
15 MEMBER BLEY: -- when you get to option 16 two, since you don't favor option two --
17 MR. RECKLEY: Yeah.
18 MEMBER BLEY: -- and nobody on the 19 Committee favors it, going through the details is very 20 plodding and slow.
21 MR. RECKLEY: Right, okay.
22 MEMBER BLEY: Just give the overview of 23 what it was trying to do.
24 MR. RECKLEY: Okay, I'll go quickly then 25 through the options. Option one is just the status NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 quo. So we've talked about that already under what 2 the current requirements are, so I'll skip through 3 that one.
4 The option two description is the best in 5 this slide in which a rough equivalent societal risk 6 measure is defined as the area times the source term 7 factor times the people per square mile. Slide nine 8 gives the same example I used during the Subcommittee.
9 If you assume a proportional reduction in 10 the area of contamination with the dose factor, which 11 would be roughly proportional to power level, you can 12 work through an example, as is given on this slide, 13 where instead of 1,200 square miles for a small 14 reactor, you would be facing a contamination area of 15 more like 63 square miles.
16 MEMBER BLEY: The bottom line is you're 17 scaling on power.
18 MR. RECKLEY: Yes, in the paper, we 19 proposed to take the source term factor and equate it 20 to power level. Again, the whole thing is a rough --
21 it generally holds, but it's not an exact correlation 22 if you try to back it out.
23 So some of the advantages, it's relatively 24 simply. It does allow designs, attributes to 25 considered somewhat, primarily in the area of power.
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32 1 Disadvantage listed there, will face some negative 2 perceptions no matter what changes to siting criteria 3 we pursue.
4 So going onto the recommended approach, 5 option three, again, the rules stay the same, so you 6 maintain the exclusionary boundary and low population 7 zone.
8 The guidance would be changed in Reg Guide 9 4.7 to call out that for plant designs that could show 10 that the event sequence doses for plants that have 11 event sequence doses that exceed one rem TEDE over a 12 month beyond the site boundary, we would look at 13 population density and we would look at it somewhat 14 similar to what we do now, the population density of 15 500 persons per square mile, and we would look, as we 16 just talked, over the radial distance equal twice the 17 radius at which one rem was estimated.
18 MEMBER BLEY: Can I correct my earlier 19 comment? I went back and looked at 42 and 47, 4.7.
20 They only do the averages over the rings. They don't 21 do any sector thing in there, at least in the table I 22 was looking at.
23 MR. RECKLEY: I'll look in mine actually.
24 Is that what you look at, just the rings, or do you 25 look at sectors, Rao or Michelle?
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33 1 MR. TAMMARA: My name is Rao Tammara. I 2 do the chapter two. Yeah, it is the rings.
3 MR. RECKLEY: Okay, I stand corrected.
4 I'm sorry.
5 MR. TAMMARA: The definition is you can go 6 to the total population divided by the area.
7 MEMBER BLEY: And that kind of says we're 8 averaging --
9 MR. RECKLEY: Yes.
10 MEMBER BLEY: -- over all of these people 11 --
12 MR. RECKLEY: Right.
13 MEMBER BLEY: -- too, so.
14 MEMBER PETTI: So, Bill, that last bullet 15 says "for event sequences greater than one rem." What 16 if the reactor has no event sequences greater than 17 one?
18 MR. RECKLEY: We'll get there in a second.
19 MEMBER PETTI: Okay, great.
20 MR. RECKLEY: Next slide. So you can look 21 at this option, and during the Subcommittee and on 22 this slide, I tried to boil it down to one slide, at 23 three cases.
24 One, you have event sequences with 25 significant doses approaching 25 rem offsite, in which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 case you'll have traditional exclusionary boundaries, 2 low population zones, population center distances 3 calculated per the rule.
4 In addition to that, whatever distance you 5 calculate one rem over the month, you would look at 6 500 people per square mile out to twice that radius.
7 So you have both the rule and the guidance affecting 8 the total population and also the population center 9 distance.
10 In the second, you have no event sequences 11 with offsite doses approaching 25 rem, but you do have 12 event sequences that are exceeding one rem over the 13 month following an event. So with no doses of 25 rem, 14 you have the low population zone collapse to the site 15 boundary, but with event sequences that have doses 16 over one rem, you're still going to look at population 17 density and keep it less than 500 people per square 18 mile out to twice the radius at which you calculate 19 one rem.
20 Then in the third case under this option, 21 you have no event sequences that exceed one rem at the 22 site boundary, so the only thing that remains in play 23 is the rule that says keep reactors away from densely 24 populated centers of about 25,000 people.
25 So what we tried to show in the graph is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 if you have a population center of 25,000, the reactor 2 would be outside that population center. If it's less 3 than 25,000, you could be within, and the reason we 4 were looking at it like this is going back to the 5 first problem statement.
6 We don't currently know of reactors who 7 are looking at remote siting, I mean remote areas, 8 isolated communities that would be serving a 9 population center of greater than 25,000, so this 10 would allow a reactor, if it could otherwise make the 11 safety case, to be within a small town in a remote 12 area.
13 MEMBER BLEY: You've dropped the 14 population density?
15 MR. RECKLEY: At that point, yes.
16 MEMBER BLEY: Because even though the 17 population center might be fewer than 25,000 people, 18 there could be a small area within it with really high 19 --
20 MR. RECKLEY: That's right.
21 MEMBER BLEY: -- population density?
22 MR. RECKLEY: Right, but again, this is 23 limited to those reactors that could show no event 24 sequences where you exceed one rem --
25 MEMBER BLEY: At the boundary.
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36 1 MR. RECKLEY: -- at the boundary.
2 MEMBER CORRADINI: So, can I -- so let's 3 go to NUREG 1537, non-power reactors. I can think of 4 some of the bigger ones of those that don't meet the 5 right-hand side of the lower one to the right, so am 6 I concerned?
7 In other words, the NIST reactor on the 8 Gaithersburg campus probably doesn't meet the bottom 9 one to the right unless I say that the campus itself 10 is a low population center. Is that what you said 11 over the phone? Did I --
12 MR. RECKLEY: Yes, that you could look at 13 the campus again, it's a huge campus, and look at it 14 in the context of how far are you actually away from 15 a population, a dense population?
16 MEMBER KIRCHNER: Bill, what Mike brought 17 up, it was in my mind and I didn't work through this 18 in advance. Would this be consistent with the rule 19 for non-power reactors, research reactors and such?
20 In other words, would they collapse to the same 21 answer?
22 MEMBER BLEY: I'm not sure. I mean, we 23 did the NIST reactor --
24 (Simultaneous speaking.)
25 MEMBER BLEY: We did the NIST reactor a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 few years ago and they really had almost a nil source 2 term. I don't remember the details. I doubt that --
3 MEMBER CORRADINI: But, except for the 4 Gaithersburg campus, they're in a population area that 5 would be greater than 25,000.
6 MEMBER BLEY: Yes.
7 MEMBER REMPE: But to meet it, Steve, 8 right --
9 MR. LYNCH: Yeah.
10 MEMBER REMPE: -- pointed out the very 11 restrictive criteria, but I have another question I 12 want to ask after that, but go ahead and repeat what 13 you said at the meeting.
14 MR. LYNCH: Sure, yeah, I can. Yeah, this 15 is Steve Lynch. I'm currently the Acting Chief of the 16 Advanced Reactor Licensing Branch and I'm also working 17 with the Research and Test Reactors Licensing Branch.
18 As far as the siting of a NIST reactor, 19 yes, it is in a population center that may be greater 20 than 25,000, but one of the differences, at least 21 under its current licensing basis, is the more 22 restrictive dose at the site boundary.
23 I believe that NIST is licensed such that 24 the maximum dose at the site boundary is limited to 25 100 millirem, so I think that is one of the different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 considerations with that facility to address 2 consistency with the NPUF rule.
3 MEMBER CORRADINI: But if it were one rem 4 instead of 100, if it was a factor of 10 larger, would 5 I really change anything? I understand what you're 6 saying, but it still doesn't change anything from a 7 health hazard standpoint.
8 MR. LYNCH: Could you clarify what you're 9 asking with the --
10 MEMBER CORRADINI: What I'm saying is if 11 the NIST reactor were to have done a calculation --
12 I'm using them as a government example. I have other 13 examples that I could bring up. But if it were, 14 instead of 0.1 rem, it was one rem at the boundary, it 15 still is not a health hazard, so it wouldn't require 16 evacuation, so --
17 MR. LYNCH: Correct.
18 MEMBER CORRADINI: -- it's equivalent.
19 It's an equivalent question.
20 MR. LYNCH: Correct, and I think that's 21 where the NPUF rule comes in. So the 100 millirem was 22 a conservative number that, in the absence of accident 23 dose criteria for non-power reactors in the 24 regulations, facilities such as NIST had voluntarily 25 used as their accident dose criteria.
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39 1 With the NPUF rule, accident dose criteria 2 for research reactors will be set at one rem. And as 3 we were saying, if, at the site boundary, it's 4 demonstrated that, for the duration of an accident, 5 dose is at less than one rem, there would be no 6 offsite emergency planning needed.
7 MEMBER REMPE: So this ties into the 8 question I've been wanting to ask. During the 9 Subcommittee meeting, I believe the question was 10 raised on how do you do this calculation? Is it a 11 conservative calculation? Is it best estimate? And 12 I thought that some changes would be made to the draft 13 SECY to clarify what you wanted.
14 MR. RECKLEY: And again, that was what we 15 were trying to do with the change to the footnote, so 16 it you look at --
17 MEMBER REMPE: But show me how that's --
18 on page 21's footnote or which footnote? Maybe I 19 missed it.
20 MR. RECKLEY: Yes, basically on slide 21 21 that lays out two approaches as we had currently 22 identified.
23 MEMBER REMPE: Put the slide up there and 24 show me that it tells me to do conservative or best 25 estimate. I get the first part for 1353, but for a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 different approach --
2 MR. RECKLEY: For 1353, you're going to be 3 doing the design basis event or beyond design basis 4 event best estimate calculations.
5 MEMBER REMPE: What about the applicant 6 using a licensing approach different from that in 7 1353? How do I know that guy has to do a conservative 8 calculation or a best estimate one?
9 MR. RECKLEY: For the other set that we 10 can know how they do it, right, but there's a 11 hypothetical that we don't know what they'll be 12 proposing, so it's hard to address, but for the other 13 ones that we know, which would be light water, small 14 modular reactors, the option that they have is to use 15 the existing guidance for light water reactors, which 16 would be to use the source term out of NUREG 1465.
17 That's considered to be a conservative 18 source term, but, so it's not taken, for example, like 19 the advanced reactor approach in DG-1353, but it would 20 be best estimate calculations, using best estimate 21 calculations.
22 It would be the more traditional approach 23 that you would find in the siting calculation in a 24 current FSAR for a currently operating reactor. Those 25 are the two that we know because we've seen them NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 before.
2 People can propose alternatives. A light 3 water SMR could propose something similar to, but 4 deviations from the guidance that's in 1465, and we've 5 seen some of that where the guidance is used in some 6 respects, but it's tweaked to reflect specific design 7 details, specific release paths and filtering that 8 might occur, that might not be in a traditional light 9 water reactor containment.
10 In your case of the maximum hypothetical, 11 they could propose that and we'd have to review it on 12 its merits. I don't really have any specific guidance 13 on how somebody would do a maximum hypothetical except 14 for almost by definition, it's not best estimate 15 because they're making up something that's 16 intentionally conservative.
17 MEMBER BLEY: But your expected response 18 to that question would have been the second insert you 19 put up there, is that right?
20 MR. RECKLEY: Yes, well, only in that we 21 didn't want to repeat a lot of the stuff from 1353 22 that describes how that's done and from that SECY 23 paper. What we were adding, because that's where I 24 thought the question was, was more what would a light 25 water reactor, what would somebody that's not using NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 1353 do?
2 And again, the easiest to describe is a 3 light water reactor approach, and then they always 4 have an option of proposing something on their own and 5 they would have to justify it on their own merits.
6 MEMBER REMPE: So I guess I was expecting 7 from the Subcommittee meeting that there would be 8 something about, that would say, "By the way, if you 9 have something that's not a light water reactor or not 10 the 1353 approach, we'd expect it to be darn 11 conservative," and I guess I don't see that here, but 12 maybe there's some other thing that gives them a clue.
13 MEMBER CORRADINI: What I'm hearing Bill 14 say is what's in blue is a conservative approach in 15 the light water world.
16 MR. RECKLEY: Right, they could propose 17 something.
18 MEMBER CORRADINI: And expecting an 19 equivalency in the non-light water world if something 20 comes up, and that's how they judge it.
21 MR. RECKLEY: Thank you, but it's going to 22 be a different source term than what's defined in 23 1465. You have different fuels, different --
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43 1 out to do the other part of siting, to figure out do 2 they meet the dose limits? Can they have a certain 3 EPZ? And then this is just going to leverage that 4 same number.
5 So the intent of this document wasn't to 6 define how every possible person is going to come up 7 with their source term, but given a certain source 8 term, how would we translate that into different 9 population density requirements?
10 I know that's not satisfying to you 11 because it's kind of like, well, but separately, we 12 have activities ongoing to look at source term and 13 other matters, and I think it's pretty clear from the 14 LMT guidance how you would do it. It's clear from the 15 light water world how you would do it. If someone 16 wants to come up with a different approach, we'll just 17 have to face that, and we'll need to figure that out 18 to give them a license regardless of this siting 19 issue.
20 MEMBER BLEY: As you folks described, this 21 is a high level SECY.
22 MR. RECKLEY: Yes.
23 MEMBER BLEY: There's a lot of details for 24 implementation.
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44 1 the Reg Guide.
2 MEMBER BLEY: That's what I wanted to get 3 to. Your intent is to do a Reg Guide to support this 4 to cover --
5 MR. RECKLEY: Yes.
6 MEMBER BLEY: -- these details.
7 MR. RECKLEY: This will be a change --
8 MEMBER BLEY: Because it's either going to 9 work well or not depending on that guidance.
10 MR. RECKLEY: Right, and so our plan and 11 what we call out in the paper is whatever option is 12 chosen, except for option one, which is status quo, it 13 would involve changing Regulatory Guide 4.7 to add 14 this as an alternative to the current approach of 500 15 persons per square mile out to 20 miles.
16 MEMBER BLEY: Okay.
17 MR. RECKLEY: Moving on then to the last 18 option, option four, I'll just briefly touch on it.
19 I don't believe there was a lot of support for this 20 one either. This was to develop broader societal risk 21 measures.
22 These are measures that would look at 23 potential doses to individuals and also population 24 doses. It would look at effects on economies, land 25 availability, displacement, decontamination costs, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 broader societal costs, and this kind of approach has 2 been talked about for decades, and usually avoided for 3 some of the disadvantages there. It talks a lot of 4 time to develop.
5 It would be a significant change from the 6 current siting, kind of treated as an independent 7 element because both the design and the site would be 8 looked at together, and so depending on how you did 9 it, you could have a design that would be acceptable 10 for one site and not acceptable at another site as a 11 result of the societal measures.
12 MEMBER BLEY: As a -- you know, you 13 introduced this in the SECY as this is a really good 14 idea if you could implement it.
15 MR. RECKLEY: Yes.
16 MEMBER BLEY: The trouble is in 17 implementation.
18 MR. RECKLEY: Right.
19 MEMBER BLEY: We heard comments from 20 others that kind of focused on land contamination. We 21 had a meeting a couple of years ago on this issue of 22 societal risk, and especially because that was the big 23 thing that went --
24 MR. RECKLEY: Right.
25 MEMBER BLEY: -- they had over in Japan.
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46 1 We calculate, or we used to calculate land 2 contamination as part of the risk assessments. We 3 don't always report them, but we could.
4 You could have kind of a three prime 5 that's the way it is, but adds a land contamination 6 factor as a surrogate for possible societal risk 7 measures. I don't know how easy it would be to reach 8 agreement on what a criteria ought to be for that.
9 MEMBER KIRCHNER: I think, again, you'd 10 have to first resolve the low dose issue, which has 11 proven intractable for years and years despite 12 evidence to the contrary.
13 MR. RECKLEY: And we do use, when we do 14 our regulatory analysis --
15 MEMBER KIRCHNER: But with a criterion, a 16 cutoff somewhere.
17 MEMBER BLEY: Right.
18 MR. RECKLEY: And we point out --
19 MEMBER KIRCHNER: And that would 20 difficult.
21 MR. RECKLEY: We point out in the paper 22 that in terms of regulatory analyses that we do for, 23 like, rule changes, you can identify a delta, but it's 24 an existing situation, a plant modification that we 25 may require or not require.
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47 1 You've got like a situation, then you can 2 assess, and we do consider these factors when we do 3 the regulatory analysis in the cost benefit 4 assessment. What gets difficult is when you don't 5 have a binary thing to compare.
6 Then as Walt was mentioning, you need to 7 come up with some other criteria and it's been very 8 elusive, and that is why we have not recommended this 9 option, although as Dr. Bley mentioned, if one could 10 do it, it would be the best measure of the actual 11 impact of a reactor on a particular community.
12 So it's just that we don't think it's 13 practical. So we recommend option three, and as John 14 mentioned, we would appreciate the insights of the 15 Committee on both the options and the recommendation.
16 MEMBER BLEY: Just as a matter of 17 discussion, a short one, I don't remember in the 18 environmental analysis that supports a license 19 application, they have at least an abbreviated form of 20 PRA. Do they do a land contamination calculation 21 there? Since nobody else knows either --
22 MR. RECKLEY: We would --
23 (Simultaneous speaking.)
24 MEMBER BLEY: -- we won't need to pursue 25 that one.
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48 1 MR. RECKLEY: Okay, I don't know. I'll 2 look at Marty. Is it included in the SAMA/SAMDA 3 evaluations? It's not? Okay, so, no.
4 MEMBER BLEY: Thank you, and that was your 5 last slide.
6 MR. RECKLEY: Yes.
7 MEMBER BLEY: Anything from members of the 8 Committee? Mr. Chairman, back to you on time.
9 CHAIRMAN RICCARDELLA: Thank you, very 10 good. We have a very busy agenda this week, and so 11 I'm happy that people are staying on schedule. I 12 think we should continue with the second item, which 13 is the Turkey Point subsequent license renewal, and I 14 will turn the floor over to our Vice Chairman Matt 15 Sunseri.
16 VICE CHAIRMAN SUNSERI: Thank you, Pete.
17 Maybe we'll just give it a second for the tables to 18 rearrange here.
19 CHAIRMAN RICCARDELLA: That's fine.
20 VICE CHAIRMAN SUNSERI: Okay. While you 21 all are getting your presentation up out, I'll go 22 ahead with some of the administrative stuff here.
23 All right. Thank you Mr. Chairman. This 24 is the -- the purpose of this part of the meeting 25 today is for Florida Power & Light Corporation, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 the NRC to brief the full Committee on subsequent 2 license renewal activities for the Turkey Point 3 Nuclear Generating Stations Three and Four.
4 A panel license review subcommittee 5 previously met on June 21, 2019 to discuss this 6 application. The subcommittee's objective was to 7 focus on the safety aspects of this application and to 8 formulate a proposed position and action for 9 deliberation by the full Committee, which we will do 10 following the presentations today.
11 Due to separate and independent external 12 relationships with structural integrity associates, 13 Peter Riccardella and I are recusing ourselves from 14 the deliberations on the topic of metal fatigue, class 15 one components, environmentally assisted fatigue, and 16 the leak before break analysis for Class One auxiliary 17 piping as these topics relate to the Turkey Point 18 subsequent license renewal application.
19 At this point I'd ask Meena Khanna of the 20 Division of Materials and License Renewal if you have 21 any remarks before we start?
22 MS. KHANNA: Okay, thank you. Thank you 23 Chairman Riccardella, Mr. Sunseri and members of the 24 ACRS. I am Meena Khanna, Acting Deputy Director of 25 the Division of Materials License Renewal.
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50 1 We sincerely appreciate the opportunity to 2 today to present to the ACRS full committee, the 3 results of the staff's safety review of the first 4 application for subsequent license renewal, also known 5 as Operation Beyond Sixty Years.
6 This application was submitted by Florida 7 Power & Light Company for the Turkey Point Nuclear 8 Generating Station, Units Three and Four, located near 9 Homestead, Florida.
10 I'd like to note that we did have the 11 opportunity to present the results of the staff's 12 safety review of the Turkey Point SLRA to the ACRS 13 subcommittee back on June 21.
14 Before I proceed any further, we would 15 like to acknowledge the very challenging circumstances 16 that the employees of Florida Power & Light and their 17 families, as well as the residents of Florida and the 18 Bahamas are experiencing as a result of Hurricane 19 Dorian.
20 We understand that FPL is implementing its 21 hurricane preparedness procedures to ensure the safety 22 of their nuclear power plants, their personnel, and 23 the public. As a result, some of the FPL members of 24 the Turkey Point team are unable to attend this 25 meeting in person today, but will be with us by phone.
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51 1 We really appreciate those that have 2 actually joined us under these circumstances. Our 3 thoughts and prayers are with those that have been 4 impacted by the storm.
5 By way of background, Turkey Point's Three 6 and Four received approval for their initial renewed 7 licenses from the NRC on June 6, 2002. The NRC review 8 at that time was performed using guidance developed 9 prior to the issuance of the Generic Aging Lessons 10 Learned Report, or the GALL Report.
11 The NRC guidance for license renewal over 12 the years has evolved through enhancements and 13 improvements based on lessons learned from NRC license 14 renewal reviews and from both domestic and 15 international industry operating experience.
16 The GALL Report went through two revisions 17 and additional interim staff guidance was issued 18 following revision two. The guidance for subsequent 19 license renewals contained in the GALL SLR Report 20 built upon the previous guidance, and included 21 additional focus and enhancements where necessary on 22 aging management and time limited aging analysis for 23 operation in the 60 to 80 year period.
24 In the staff's presentation today, you 25 will hear about some of these specific SLR issues as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 applied to the Turkey Point review.
2 The NRC Project Manager for Turkey Point 3 subsequent license renewal application safety review 4 is Ms. Lois James, here behind me. Mr. Billy Rogers, 5 also a Senior PM on the Turkey Point project, will 6 present an overview of the staff's safety review 7 today.
8 Part of the management team that are here 9 with me today include Mr. Eric Oesterle, Chief of the 10 License Renewal Project Branch seated next to me. And 11 in the audience are other DMLR and NRR technical 12 branch chiefs as well as our staff.
13 In addition, we have several staff on the 14 phone in case there are specific questions about the 15 technical review. We also have on the phone Paula 16 Cooper from Region II, who oversaw the facility 17 inspections associated with the effectiveness of the 18 Aging Management Programs implemented for initial 19 license renewal, as well as other NRR staff who 20 supported the review.
21 We look forward to a productive discussion 22 today with the ACRS. And as always, look forward to 23 addressing any questions that you may have.
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53 1 Licensing Director to introduce his team and commence 2 their presentation. Thank you.
3 MR. MAHER: My name is Bill Maher, I'm 4 Senior Licensing Director for Subsequent License 5 Renewal. Again, I'd like to echo the remarks of the 6 NRC as far as being able to accommodate us, and the 7 flexibility of the Committee to actually have people 8 on the phone who are not able to make it as a result 9 of Hurricane Dorian.
10 It was an interesting flight up this 11 morning. There were some bumps, but we got along.
12 And we actually made it. So, go to slide two.
13 So, what I'd like to do is to briefly 14 introduce, I already introduced myself. To my right 15 is Brian Stamp. He's the Site Director for Turkey 16 Point Three and Four.
17 And to my left I have Steve Hale from 18 ENERCON who is our technical lead on one of the 19 contractors that we have working on the project, 20 ENERCON. And Steve Franzone is on my staff, who is a 21 Licensing Manager associated with subsequent license 22 renewal.
23 I did want to at least preface this 24 particular presentation to show how we have satisfied 25 the NRC requirements for subsequent license renewal.
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54 1 How the aging affects associated for subsequent 2 license renewal are being effectively managed such 3 that the intended functions are being maintained.
4 And like Brian will point out, how our 5 gains are being -- how we're being able to maintain 6 those as we go through a period of subsequent, period 7 of observation. And I'll turn it over to Brian.
8 MR. STAMP: Hi, good afternoon. Like Bill 9 stated, my name is Brian Stamp. I am the site -- like 10 Bill said, I am Brian Stamp, Site Director at Turkey 11 Point. That means that I own the performance at 12 Turkey Point specifically, as well as a shared 13 oversight of the entire nuclear fleet.
14 Today on the slide we're looking at, I 15 want to talk briefly about our performance philosophy, 16 and specifically how it entails the sustainability.
17 The model that you're seeing is a model 18 that our C&O put together to really describe what that 19 sustainability looks like. And before this, all of 20 this comes from the philosophy that is governed by our 21 nuclear excellence model.
22 That nuclear excellence model has been 23 with us since 2008. And it has stayed the same for 24 all these years.
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55 1 core principals. The primary core value is around 2 deep respect for nuclear safety.
3 It also has a value of self improving 4 culture, learning organization, as well as a PDC. In 5 the PDC model, prevention, detection, and correction 6 which really describes how we want to spend 80 percent 7 of our time in that prevention and detection, and only 8 20 percent of our time in the actual correction.
9 That goes on down to a core principal that 10 really goes back to the sustainability and the 11 subsequent license renewal, which really is around the 12 effective long range planning of all the site 13 activities.
14 Now interestingly, the INPO organization 15 recently took our model with our C&O at the time, Mano 16 Nazar, and created their own document called the INPO 17 19-3. And it's staying on the COB.
18 While the words are a little different, 19 the output really is the same. It's really all about, 20 how do we make sure that we retain the gains that 21 we've already got at the performance level we're at, 22 plus rigorously and aggressively build additional 23 margin?
24 You know, one of the big criteria that we 25 use to make sure that we are doing both retaining and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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56 1 building a margin, it comes out at 10 CFR 50, Appendix 2 B, the quality assurance program.
3 You know, in that program there's two or 4 three key activities. One being the design control.
5 You know, that design control really ensures that we 6 make sure that the regulatory requirements as well as 7 our design basis requirements are rigorously reviewed.
8 They are tested and monitored.
9 And then all the reviews and the testing 10 then get in turn put into our control documents.
11 Whether that's a procedure or a document, that's used 12 in the field, like a drawing or a work order.
13 That's how that ensures that that design 14 basis is maintained. The regulatory basis is 15 maintained.
16 The other big part of that is the 17 corrective action program. That corrective action 18 program, the implementation of that ensures that any 19 adverse conditions in quality are quickly identified, 20 plus evaluated quickly, and/or the corrective actions 21 to prevent recurrence, put back into those same 22 documents, again, the procedures that we use or the 23 design documents that we use to improve those.
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57 1 process. That configuration control is what we use to 2 make sure that the site is always in the same 3 configuration as again, the design basis document as 4 well as the regulatory requirements say they should.
5 Now, all this goes back to, you know, this 6 retaining the gains, the aggressively building the 7 margin. That is really built into our core business 8 so that all of the, all of my direct reports have this 9 built into their daily work life, as well as all the 10 people below them.
11 And then taking this back to the 12 subsequent license renewal, it really goes back to the 13 way that we are implementing the aging management 14 process and program to ensure that again, we have that 15 sustainability long term.
16 With that, I'd like to turn it over to 17 Steve Franzone.
18 19 MR. FRANZONE: Thank you Brian. Good 20 afternoon. My name is Steve Franzone. I am the 21 Licensing Manager for the subsequent license renewal 22 project for Turkey Points Three and Four.
23 Slide four gives you an overview of the 24 location of Turkey Point Units Three and Four, which 25 is at the location -- which is at the very southern NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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58 1 tip of the Florida mainland.
2 The star in the center of the circle marks 3 the location of the site. It is located approximately 4 25 miles south of Miami.
5 The black dash circle represents the 50-6 mile radius of the plant. The closest cities are 7 Homestead and Florida City, which are approximately 8 nine miles west of the site.
9 The site is sandwiched between the 10 Everglades National Park and the Biscayne National 11 Park. The site has approximately 680 full time 12 employees. Go to slide five.
13 This slide provides a view of the entire 14 site looking north. Biscayne Bay is on the right-hand 15 side of the photo.
16 A little history about the site, site 17 construction started in 1965 by the Bechtel Power 18 Corporation with two 400 megawatt coil plants, which 19 are Units One and Two.
20 The construction permit for Turkey Point 21 was granted in 1967 for Units Three and Four. The 22 Nuclear Unit stated commercial operation in 1972 and 23 1973 respectively.
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59 1 plant's ultimate heat sink. The intake is on the 2 right and the discharge is on the left. And you'll 3 see a better view in a few slides.
4 The licensed thermal power is 2,644 5 megawatts thermal. At the top of the photo is Unit 6 Five, which is an 1150 megawatt electric combined 7 cycle gas fired plant which went into commercial 8 operation in 2007.
9 Unit One and Two have since -- have been 10 retired since this photo was taken. And the stacks of 11 the units have been dismantled.
12 This slide presents the major events that 13 have occurred at the Turkey Point site. You can see 14 the dates for the initial operating license.
15 In 1983 and 1984, the original steam 16 generators for both units were replaced. In fact, it 17 was only the U-tube section which was actually 18 replaced.
19 In 1991, the onsite electrical systems for 20 both units were upgraded. And this included going 21 from two emergency diesel generators to four emergency 22 diesel generators, adding a spare battery, new digital 23 sequencers, redistribution and separation of loads.
24 And upgrading the RCS RCDs.
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60 1 include surviving Hurricane Andrew in 1992, and the 5 2 percent uprate in 1995. We were not only a pre-GALL 3 plant, but we're also the first Westinghouse units to 4 receive a renewed license in 2002.
5 We replaced the reactor vessels in 2004 6 and '05. Finally, we received approval for an 7 extended power uprate, which included a 1.7 percent 8 measurement on certain recapture in 2012, and entered 9 into the period of extended operation for Unit Three, 10 and of course Unit Four was 2013. At that point, the 11 fuel enrichment was increased to 5 percent.
12 CHAIRMAN RICCARDELLA: Excuse me, just a 13 correction for the record. They replaced the reactor 14 vessel heads, not the reactor vessels.
15 MR. FRANZONE: Yes. Sorry. Good catch.
16 MEMBER BLEY: Not that it's -- well, it 17 might be relevant to this.
18 MR. FRANZONE: It would be real hard.
19 MEMBER BLEY: How did you do during 20 Andrew? Was there flooding there?
21 MR. FRANZONE: Do you want to take that 22 one?
23 MR. STAMP: No, actually there was no 24 flooding. I was actually onsite during Hurricane 25 Andrews. There was actually no flooding.
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61 1 Andrew didn't have a lot of heavy rains 2 like the storm that just went through, Dorian.
3 MEMBER BLEY: Um-hum.
4 MR. STAMP: The -- I was in the control 5 room, and it was actually just like a simulator 6 scenario. The plant actually operated exactly like it 7 was designed.
8 Probably the best ever.
9 MEMBER BLEY: Interesting. And it didn't 10 -- I mean, it looks like it would have pumped water 11 into your intake area and flooded that.
12 But it didn't?
13 MR. STAMP: No. No, Andrew --
14 MR. FRANZONE: I think it was closed.
15 MR. STAMP: I was just going to say, 16 Andrew was moving at a pretty good clip. If I 17 remember right, it was 10 or 12 miles an hour. So, 18 and it was a very small, condensed storm.
19 So, it actually passed over the site in 20 roughly three to four hours, the main part of that 21 storm.
22 MEMBER DIMITRIJEVIC: And did you lose 23 power?
24 MR. STAMP: Yeah. We lost all offsite 25 power. But again --
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62 1 MEMBER DIMITRIJEVIC: For how long?
2 MR. STAMP: Well, you're now you're --
3 MR. HALE: About a week.
4 MR. STAMP: You're testing me.
5 MR. HALE: Yeah. We lost all the -- oh, 6 I'm sorry. Steve Hale, ENERCON. We lost all the 7 transmission lines going into the site.
8 They were restored within about a week.
9 MEMBER DIMITRIJEVIC: So, did you operate 10 on the diesel generator for a week?
11 MR. HALE: Yes. Yes, we did.
12 MEMBER DIMITRIJEVIC: That's what I know.
13 MR. HALE: It also highlighted some 14 challenges with regard to communications. Because a 15 lot of the communications were relying on cell towers 16 and things of this sort.
17 So, actually working with the NRC in the 18 region, we addressed some of the issues that fell out 19 of Hurricane Andrew with regards to communications.
20 You know, satellite phones, things like that, to 21 improve that response in case something like that 22 happened again.
23 MEMBER DIMITRIJEVIC: Well, interesting 24 that you just added to do the generator the year 25 before that happened.
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63 1 MR. HALE: Yes. Very convenient. Yes.
2 (Laughter) 3 MR. FRANZONE: Yes. And the flood level 4 for the site is 20 foot minimum protection. And it 5 goes higher. And the surges were not that high.
6 And in fact they were very much in line 7 with what they had predicted back in the '70s, so.
8 All right. Are we ready to go on? Okay.
9 MEMBER KIRCHNER: Do you --
10 MR. FRANZONE: Yes, sir?
11 MEMBER KIRCHNER: What's the current 12 operating status of the plant today?
13 MR. FRANZONE: Both units are at 100 14 percent power.
15 MEMBER KIRCHNER: They're still at 100 16 percent, okay.
17 MR. FRANZONE: Yes. We did not shut down 18 for this storm.
19 MEMBER KIRCHNER: Okay. Thank you.
20 MR. FRANZONE: As you can see, the main 21 features here are the closed loop cooling canals.
22 This feature is unique to Turkey Point, and is 23 approximately 168 miles of cooling canal.
24 It is basically a giant radiator that you 25 can actually see from space. It not only provides the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 normal cooling flow, so acts as the ultimate heat 2 sink.
3 The red solid line is the site boundary.
4 Where the bright yellow solid line is, the exclusion 5 area boundary.
6 To maintain the efficiency of this giant 7 radiator, the measures that we take include selective 8 dredging and clearing of the vegetation from the 9 berms.
10 This insert, the insert provides location 11 of the major structures. And we'll discuss it on the 12 next slide in more detail.
13 As you can see here, it's an expanded view 14 of the insert from slide eight. To orient you, north 15 is at the top of the slide. And just out of view is 16 the Unit Five, the combined site for natural gas unit.
17 We'll start from the left and go to the 18 right and just point out the major structures. Then 19 if you have more questions.
20 So first you'll see the switch yard. Next 21 will be the discharge structure. And then the turbine 22 building.
23 And then we have the containments, which 24 are post-tension containments. Sandwiched in between 25 the containments is the control building. It's the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 comm and control building for both Units.
2 And then next again, is the OX building.
3 Again, it's common for both Units. Then next we'll 4 have the intake structure.
5 And finally, on the very right-hand side 6 of the photo, you can see the independent spent fuel 7 storage facility. Any questions? I'll just go on.
8 Okay. Slide nine.
9 FPL's made -- has made and continues to 10 make significant investments in the plant. This slide 11 provides a listing of recent major modifications and 12 upgrades for the plant.
13 The timing of the submittal is important, 14 because when you take into account the ten-year window 15 for the pre-SPEO inspections, we are in the five-year 16 planning window for major projects.
17 Also, the submittal is important in 18 achieving our goals of retaining gain and building 19 margin for Turkey Point, as we discussed on slide 20 three.
21 Turkey Point has been an integral part of 22 the south Florida community for over 45 years.
23 Operation at Turkey Point, there are estimated to 24 generate nearly 1.7 billion dollars of total economic 25 output annually.
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66 1 The plant staff has a long history of safe 2 operation, and are valued members of the community, 3 having volunteered over six thousand hours in support 4 of charitable organizations.
5 The continued operation of Turkey Point 6 into a subsequent period of extended operation will 7 allow the plant workers and FPL to continue supporting 8 the local community.
9 MEMBER BLEY: Before you go.
10 MR. FRANZONE: Yes?
11 MEMBER BLEY: Can you tell me about two of 12 those items? The obsolescence projects and what 13 happened to your containment spray piping? How come 14 you had to replace that?
15 MR. FRANZONE: You want to start with the 16 containment spray piping?
17 MR. STAMP: Yeah. The containment spray 18 piping, we actually have --
19 MR. FRANZONE: There we go, Brian.
20 MR. STAMP: So, the containment spray 21 piping, we've actually started to replace some of that 22 piping. We started the last outage on one Unit where 23 we replaced the piping on the penetration into the 24 area that was susceptible to the corrosion.
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67 1 the spring, and to do the similar on the second Unit.
2 And then the following fall, we're going to come back 3 and replace all the piping on the first Unit that we 4 did.
5 MEMBER BLEY: You did have extensive 6 corrosion then?
7 MR. STAMP: No. We did -- we did evaluate 8 the internals of the piping. The corrosion, I 9 wouldn't say it was extensive, but it was corrosion 10 there.
11 But, you know, preemptively we did replace 12 the piping. There was a, you know, it did have the 13 corrosion on it. And we're going to do it.
14 We're assuming that the same condition 15 belongs on the other Unit. So we're going to replace 16 the same piping on that.
17 MEMBER BLEY: Okay.
18 MR. HALE: We just need to explain the 19 piping is carbon steel. Okay.
20 MEMBER BLEY: Yes. Okay.
21 MR. HALE: And by design, I don't think it 22 was originally thought that it would be exposed to the 23 boric acid on a regular basis. But, so the corrosion 24 was really had to do with carbon steel and boric acid 25 really.
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68 1 MR. FRANZONE: Okay. And that second, 2 your first question you had was on the obsolescence 3 project?
4 MEMBER BLEY: Um-hum.
5 MR. FRANZONE: Right. So, as you know, 6 Turkey Point, and a lot of nuclear plants get older, 7 and so some of the components that we originally had 8 become obsolete.
9 So, what we've done is, is there's 10 basically a structured program. And we went through 11 a whole laundry list of items that we ended up 12 replacing.
13 I'll give you an example, would be the OX 14 transformers were replaced as part of that. Control 15 Board, enunciation system was replaced. We replaced 16 the instrument air system.
17 We've replaced the vital MCC buckets.
18 Because they needed that. ERDADS was replaced. Let 19 me see, some of the other ones. A significant portion 20 of the fire protection system.
21 We replaced ICW, which are intake cooling 22 water and component cooling water, which is our 23 service water strainers. And we recoded simple, 24 recoded some of the internals of the tanks.
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69 1 system was also upgraded. And so, it's just an 2 ongoing effort that we have to make because these 3 plants are just getting older, and the parts are not 4 available.
5 MEMBER REMPE: So, on this slide, I don't 6 see anything about the steam generator replacements.
7 And they were done thoroughly --
8 MR. FRANZONE: In 1983 and 1984. So, this 9 slide mainly is after the renewed license was issued 10 in 2002.
11 MEMBER REMPE: Okay.
12 MR. FRANZONE: Just trying to capture the 13 major ones.
14 MEMBER REMPE: How are the tubes behaving 15 with the replacement steam generators?
16 MR. FRANZONE: Very good. Unit Three is 17 only 2 percent plugged. And Unit Four is three-18 quarters of a percent plugged.
19 So they're doing really good. We've taken 20 the lessons we had in the early '70s to heart. And 21 after that when we did replace the generators, we had 22 very tight chemistry controls, so.
23 MR. HALE: In fact, for extended power 24 uprate, the Committee here asked some questions about 25 the steam generators and performance after the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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70 1 extended power uprate.
2 And they performed very well. We haven't 3 seen any degradation associated specifically for the 4 increase in power level.
5 MEMBER REMPE: Okay. Thank you.
6 CHAIRMAN RICCARDELLA: What about your 7 instrument and control system? Did you do any 8 upgrades with that?
9 MR. FRANZONE: Instrument air?
10 CHAIRMAN RICCARDELLA: No. I&C? Just 11 have you gone with a digital system more recently?
12 MR. STAMP: Yeah. For a lot of things.
13 For example, on all the feedwater controls, they have 14 all been transferred over to digital.
15 All of the modules that were originally in 16 place for all of the control systems, you know, that 17 inputted into the direct protection system, safeguard 18 system, have all been upgraded to newer models.
19 In fact, we're getting ready to go to a 20 third round of that, and to further upgrade those 21 again.
22 MR. HALE: And for the extended power 23 uprate for the turbine controls, we actually moved the 24 DEH system and digital controls on the turbine.
25 CHAIRMAN RICCARDELLA: Thank you.
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71 1 MR. FRANZONE: Okay. If we go to slide 2 ten. And as I've mentioned before, both Units are at 3 100 percent power. Average station capacity factor 4 for the last two years was 91.9 percent.
5 And unless there's no other questions, 6 we'll go to the next slide. Okay. The project team 7 -- we're on slide 11.
8 The project team has many years of both 9 Turkey Point experience and license renewal 10 experience. The multi-disciplined team consists of 11 ENERCON as the lead preparer for the schedule, as well 12 as Westinghouse, Framatone, and Structural Integrity 13 Associates in supporting roles.
14 Also, the project team was supported by 15 the next era FPL fleet and site program owners as well 16 as various subject matter experts such as Chuck 17 Ramdeen, who is civil, and he's here today. And Scott 18 Boggs who is on the phone with us. And Maribel 19 Valdez, who is also here today.
20 Every aging management program for SLR was 21 actually assigned a program owner to support a portion 22 of the application preparation and the NRC review.
23 The project team generated over 130 reports, which 24 supported the application in its review.
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72 1 that knowledge will be passed onto the personnel who 2 need it in the future.
3 The technical leads for our project 4 partner, ENERCON are both former FPL employees with 5 almost 80 years of combined experience with FPL. Both 6 developed the original license renewal application for 7 Turkey Point.
8 We have established an SLR/LR liaison 9 position now in order that we will be successful in 10 the transition to the subsequent period of extended 11 operation.
12 Mr. Bob Tomonto, who could not be here 13 with us today, but he has almost 30 years of licensing 14 and engineering experience at Turkey Point.
15 Specifically, his last two jobs have been as the 16 Turkey Point licensing manager, and as one of the 17 onsite design engineering managers.
18 I will now turn the presentation over to 19 Steve Hale who is one of the ENERCON technical leads 20 I just talked about. Again, thanks for giving us the 21 opportunity to present today.
22 MR. HALE: Thanks Steve. Good afternoon.
23 Sorry about that. Thanks Steve. Good afternoon, my 24 name is Steve Hale. And I work for ENERCON as one of 25 the technical leads for the Turkey Point subsequent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 license renewal project.
2 Previous to that, I worked for Florida 3 Power & Light for over 46 years. And held many 4 positions, including the engineering director at the 5 site.
6 I was directly involved with original 7 license development for Turkey Point and St. Lucie, as 8 well as the extended power uprates for Point Beach, 9 St. Lucie, and Turkey Point. In fact, I actually made 10 all the ACRS presentations for all those major 11 licensing actions.
12 Just as a point of interest for original 13 licenses for Turkey Point, the ACRS subcommittee was 14 actually conducted at the site of Turkey Point. And 15 we walked the committee, primarily because it was the 16 first Westinghouse unit to go through license renewal.
17 For the subsequent license renewal 18 application, we followed the guidance of NEI 17-01, 19 which was developed specifically for subsequent 20 license renewal. To ensure a quality application, we 21 also reviewed REIs, REI responses for the last eight 22 applications that went through, and incorporated those 23 lessons learned.
24 We also conducted peer reviews with other 25 SLRA participants, and as well NEI, and other industry NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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74 1 folks. One of the other activities we implemented was 2 to have pre-meetings with the NRC on -- discussing 3 various technical topics.
4 And we also had a punchlist from the staff 5 on specific technical issues we needed to address in 6 the application. Which we did.
7 Our approach going in was to comply with 8 NUREGS 2191 and 2192 to the greatest extent practical.
9 And I think we've been able to accomplish that.
10 We alone with the NRC have worked 11 diligently to hold to the 18-month review schedule.
12 And with issue of the SER, with no open items or 13 confirmatory items in July, we were able to beat the 14 target schedule of 18 months.
15 MEMBER BLEY: Steve?
16 MR. HALE: Yes?
17 MEMBER BLEY: I'm not sure if I've heard 18 other people say they've reviewed other REIs from 19 other applications. Did that help you very much?
20 MR. HALE: Yes, very much so. Especially 21 the later ones. You know, some of the older ones, but 22 since River Bend and Waterford were fresh, --
23 MEMBER BLEY: Um-hum.
24 MR. HALE: To say the least. And actually 25 River Bend, they were trying to test the overall NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 process for subsequent licensing, --
2 MEMBER BLEY: Yeah.
3 MR. HALE: As well as part of the River 4 Bend review. We thought it was important to look at 5 those.
6 MEMBER BLEY: So you think you avoided 7 some --
8 MR. HALE: Yes. We did.
9 MEMBER BLEY: Okay.
10 MR. HALE: Next slide, Steve. Having been 11 involved with both original license renewal and 12 subsequent license renewal, I have an excellent 13 perspective as to what was involved in the integrated 14 plan assessment for both efforts.
15 And since the ACRS has reviewed every 16 license renewal application that has proceeded us, and 17 Turkey Point is the first application for subsequent 18 license renewal, we thought the best way to present 19 the methodology was talk about the differences between 20 what we saw for license renewal and subsequent license 21 renewal.
22 For scoping and screening, there were 23 minimal changes, because the criteria really hasn't 24 changed. You have to address modes that have been 25 implemented or current licensing basis changes which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 may have occurred.
2 And we did have to update our evaluation 3 for (a)(2), which is the scoping criteria of non-4 safety, which can affect safety. And that's primarily 5 due to the fact that guidance documents have been 6 developed since we submitted originally. And we had 7 to address that specific guidance.
8 As we moved into aging management reviews 9 and aging management programs, you start to see the 10 differences between subsequent license renewal and 11 original license renewal.
12 Turkey Point, as has been mentioned 13 previously, was a pre-GALL plant. And as a result our 14 aging management reviews were based on available 15 industry tools at the time.
16 With the issue of GALL Rev. 00, Rev. 01, 17 Rev. 02, and the interim staff guidance documents as 18 well as GALL SLR, the number of aging affects we had 19 to address has expanded somewhat.
20 The most significant differences we saw in 21 going to subsequent license renewal, was in the number 22 of aging management programs.
23 Turkey Point currently has 28 aging 24 management programs for original license renewal. And 25 moving into SLR, we're going to have 50 aging NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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77 1 management programs.
2 I'd like to give you some specifics on 3 those AMPs. So of the 50 AMPs, 14 are new, and 36 are 4 existing. And when I say existing, that's just lining 5 up what we do at the site with the GALL requirements.
6 For the 14 new AMPs, it's not as if we're 7 not doing things under those aging management 8 programs, they're just not under the umbrella of 9 license renewal or specifically identifying that this 10 is credited for our renewed license.
11 As noted, there were 11 aging management 12 programs with exceptions to GALL. All of which had 13 been reviewed by the NRC and accepted. Most have to 14 do with specific design features or characteristics at 15 Turkey Point that require taking the exception.
16 For plant specific AMPs, the new AMP has 17 to do with the polymer high voltage insulators 18 associated with the recovery path for the switch yard 19 to station blackout.
20 It's plant specific because there 21 currently is no GALL program for polymer insulators, 22 high voltage insulators.
23 The other plant specific AMP is an 24 existing AMP, which has been approved by the NRC, 25 having to do with management of fatigue of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 pressurizer surge lines. Next slide.
2 With regard to commitments, there are 57 3 mostly on an AMP by AMP basis. And include the 4 required pre-SPEO inspections.
5 These will be maintained separately for 6 clarity and to avoid confusion with commitments for 7 current license renewal.
8 There are three license conditions as 9 noted here. One of which is replace the carbon steel 10 piping inside containment, which we've already talked 11 about.
12 There will be a new chapter of the USFAR 13 specifically dedicated to subsequent license renewal.
14 This chapter will include a complete list of the 15 subsequent license renewal commitments.
16 Both Next Era, FPL, and ENERCON have 17 extensive experience with license renewal commitment 18 management and implementation. And this will ensure 19 all actions will be completed per the schedule.
20 Additionally as Steve mentioned, a new 21 SLRA liaison position has been created at Turkey 22 Point, which will be filled by a senior level, highly 23 qualified and experienced person.
24 Finally, moving onto time limited aging 25 analysis. The effort for SLR involved the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 detailed search of current licensing basis documents.
2 When compared to original license renewal, 3 some of the dispositions have changed from disposition 4 I and double II to triple III. And that's because 5 there are now GALL AMPs for certain TLAs like fatigue 6 that didn't exist previously.
7 We also updated the environmentally 8 assisted fatigue calculations because of some changes 9 to the guidance documents like NUREG 6909.
10 We did identify two new TLAs for 11 subsequent license renewal. One is for adopting leak 12 before break for non-primary loop RCS piping. And the 13 other involved the update of the reactor coolant pump 14 integrity analysis supporting Code Case N-481.
15 And that's really all I had to say. Any 16 questions?
17 MEMBER BLEY: Yeah, the new Chapter 17 SAR 18 is -- is that required? Or you just decided it was a 19 good idea?
20 MR. HALE: You're required to have an FS 21 -- UFSAR updated as part of the regulations with your 22 submittal.
23 MEMBER BLEY: Right. But the idea of 24 having a separate chapter on this was --
25 MR. HALE: We thought it would be best.
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80 1 You know, certainly when you think about the future 2 and the overall transition between the two, you know, 3 you can -- we're already making those plans.
4 But initially we felt it best to maintain 5 a separate UFSAR chapter.
6 MEMBER BLEY: You have any hints of others 7 in the industry that are likely to do that?
8 MR. HALE: We did have some dialog with 9 Exelon and Dominion. And I think they're pretty much 10 following a similar path.
11 MEMBER BLEY: Similar to you. Okay.
12 CHAIRMAN RICCARDELLA: And what's the 13 status of your reactor vessel with regard to radiation 14 embrittlement? Anything interesting?
15 MR. HALE: The reactor vessel, we redid 16 all of the calculations for subsequent license 17 renewal. TTS is at about 264. Something like that.
18 We did have some components that fell 19 below the 50 foot pounds for upper shelf energy. That 20 actually occurred for Turkey Point in the '90s.
21 And so we had to have a specific EMA 22 analysis --
23 CHAIRMAN RICCARDELLA: Okay.
24 MR. HALE: Addressing upper shelf energy.
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81 1 renewal. We updated it for extended power uprate.
2 And now we've updated it again for, when 3 I say we, it was Framatome actually did the analysis 4 for the -- the EMA analysis.
5 CHAIRMAN RICCARDELLA: And what is your 6 total end of life fluence at the end of the -- of 7 renewal fee? The section renewal fee again?
8 MR. HALE: I will have to pull that value 9 up. I can get it to you.
10 CHAIRMAN RICCARDELLA: Okay. I'd like 11 that.
12 MR. HALE: We -- it's in the application 13 in Chapter 4.2. But, we can give you that.
14 MR. BOGGS: This is Scott Boggs. I'd be 15 happy to answer that for you.
16 CHAIRMAN RICCARDELLA: Okay. Yeah.
17 MR. BOGGS: The end of life fluence on the 18 vessel is 1.08 D to the 20th. And on the limiting 19 weld it's 9.86 D to the 19th.
20 CHAIRMAN RICCARDELLA: Thank you.
21 MR. BOGGS: And that includes significant 22 margins that we've included for fuel loading.
23 CHAIRMAN RICCARDELLA: Okay. Thank you.
24 MR. HALE: And that was also based on 72 25 EFPY.
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82 1 CHAIRMAN RICCARDELLA: Um-hum.
2 MR. HALE: Which basically assumes the 3 plant runs at like 100 percent capacity factor from 4 here until the end of the plant life.
5 CHAIRMAN RICCARDELLA: Okay.
6 MR. HALE: So, there's margins inherently 7 built into the EFPY that was assumed for the fluence 8 calculations.
9 CHAIRMAN RICCARDELLA: Thank you.
10 VICE CHAIRMAN SUNSERI: So any other --
11 this isn't the end of your presentation is it?
12 MR. MAHER: No. It's not. So, we're on 13 slide 17. So, again, I would like to thank the 14 Committee.
15 Even though Turkey Point is a predone 16 plant for the first round of license renewal, we've 17 adopted the SLR goal with minimal exceptions as Steve 18 was talking about.
19 In keeping with the sustainability that 20 Brian talked about earlier, the goal now is to focus 21 on building and maintaining margin to be able to get 22 to 80 years worth of operation.
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83 1 that's taking place now, and the transition through 2 the subsequent period of operation.
3 Again, I'd like to thank the ACRS 4 Committee for the opportunity to present to you. And 5 we'd like to thank the NRC staff associated with our 6 work in getting -- working through the areas that 7 needed to be reviewed so that we could be in this 8 position right now.
9 And I'll turn it over to Brian for any 10 closing remarks.
11 MR. STAMP: Yes. So on behalf of Florida 12 Power & Light and Turkey Point, I would like to thank 13 the NRC for the thorough review our subsequent license 14 renewal application.
15 The many hours spent in this review will 16 give the public confidence in the continued operation 17 at Turkey Point.
18 The process was very thoughtful. It was 19 predictable. Which gave us, as well as the rest of 20 the industry, a clear path forward.
21 And again, we appreciate and recognize the 22 importance of this first of a kind licensing effort, 23 both for the industry as well as for ourselves, as it 24 establishes, you know, lessons learned and processes 25 going forward.
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84 1 Thank you very much.
2 VICE CHAIRMAN SUNSERI: Thank you.
3 MEMBER KIRCHNER: May I ask a question?
4 VICE CHAIRMAN SUNSERI: Sure. I was just 5 going to ask if there were any other questions.
6 MEMBER KIRCHNER: So, often margin is used 7 for increasing power. Is there a plan to do another 8 EPU for this plant? For Three or Four?
9 MR. MAHER: No. Not currently there is 10 not.
11 MEMBER KIRCHNER: Okay. Thank you.
12 VICE CHAIRMAN SUNSERI: Members, any other 13 questions? And Jose, are you still out there? Do you 14 have a question for the group?
15 MEMBER MARCH-LEUBA: I'm here. The 16 weather is improving a lot. But I don't have any 17 questions.
18 (Laughter) 19 VICE CHAIRMAN SUNSERI: Okay. Well, 20 that's good to hear. Thank you.
21 All right. Well, I'll just close this 22 part and say I think this team did a fair 23 representation of what we heard during the 24 subcommittee week.
25 There was a little slightly different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 group of people I would characterize as closer to the 2 day to day operations, which really inspired us that 3 the programs are being implemented in the way that Mr.
4 Stamp indicated here.
5 So, we appreciate your -- enduring the 6 hardship to be here during the week. And I know it's 7 a big commitment to be here when your plant is, you 8 know, just being missed by a hurricane. So, we thank 9 you for that.
10 We will now transition to the staff for 11 the staff presentation. So, Meena, if you could get 12 your team ready.
13 (Off mic comments) 14 VICE CHAIRMAN SUNSERI: Whenever you're 15 ready, yes.
16 MR. ROGERS: Good morning Chairman 17 Riccardella, Mr. Sunseri and Members of the ACRS. My 18 name is 19 VICE CHAIRMAN SUNSERI: Hold on. Can you 20 -- is your mic on?
21 MR. ROBERTS: Thank you. I'll start 22 again. Good morning Chairman Riccardella, Mr. Sunseri 23 and Members of the ACRS.
24 My name is Bill Rogers. I'm one of the 25 Project Managers for the safety review of the Turkey NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 Point Nuclear Generating Units Numbers Three and Four, 2 or Turkey Point subsequent license renewal application 3 or SLR for short, or SLRA.
4 As previously stated, we are here today to 5 discuss the NRC staff's safety review of the Turkey 6 Point SLRA that is documented in the safety evaluation 7 report or SER, which was issued on July 19, 2019.
8 And joining me here at the table today is 9 Angela Wu, a Safety Project Manager in the Division of 10 Materials and License Renewal, or DMLR, who will be 11 assisting with the slides.
12 And the Turkey Point Lead Safety Project 13 Manager, Lois James. And she's a Senior Project 14 Manager also in DMLR.
15 We have some in the audience, and joining 16 by phone are additional members of the technical staff 17 who participated in the review of the SLRA and 18 conducted the audits. Next slide please.
19 We will begin the presentation with a 20 general overview of the time line of the staff's 21 review.
22 The presentation will provide information 23 on the closure of the open items related to the buried 24 and underground piping and tanks program, which was 25 previously discussed in the meeting with the plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 license renewal subcommittee.
2 We will also discuss the disposition of 3 the aging management programs, AMPs, relative to the 4 guidance contained in the generic aging lessons 5 learned subsequent license renewal report, the GALL 6 SLR report.
7 And the staff's review of the SLRA and 8 audit activities. We will also highlight several of 9 the technical areas reviewed, which were unique to the 10 subsequent license renewal review relative to the 11 initial license renewal reviews.
12 And discuss the site specific license 13 condition. And then I will close with the staff's 14 safety conclusion. Okay. Next slide.
15 Turkey Point Units Three and Four were 16 granted the original licenses in 1972 and 1973, which 17 were set to expire in 2012 and 2013 respectively.
18 Prior to the license expirations, the licensee, 19 Florida Power & Light Company, or FPL, submitted the 20 initial license renewal application for 40 to 60 years 21 on September 11, 2000.
22 The staff met with the ACRS subcommittee 23 on plant license renewal and full committee on both 24 the safety evaluation report or SER with open items, 25 and the safety evaluation report and issued the Units NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 Three and Four initial renewed licenses in 2002 with 2 expiration dates of 2032 and 2033 respectively.
3 In January 2018, FPL submitted an SLRA for 4 Turkey Point Units Three and Four. The staff 5 performed its review of the SLRA, issued the SER of 6 open items, and presented the results of our review to 7 the ACRS subcommittee on plant license renewal on June 8 21, 2019.
9 Subsequently, the staff closed the open 10 item associated with the buried piping and issued the 11 SER on July 19, 2019. Next slide, please.
12 As I mentioned, the staff previously 13 identified one open item in the SER of open items 14 associated with the buried and underground piping and 15 tanks, an aging management program.
16 Specifically, the staff determined the 17 need for additional information regarding why 18 additional inspections beyond those recommended in the 19 GALL SLR report were not included in for buried steel 20 piping during the ten-year period prior to the 21 subsequent period of extended operation.
22 FPL provided additional information to 23 address the staff's concerns. Including one, FPL 24 committed to install cathodic protection at least nine 25 years prior to the subsequent period of extended NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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89 1 operation consistent with the GALL SLR report.
2 FPL clarified that there was only one pipe 3 break. And it was due to excavation activities and 4 not age related degradation.
5 And third, FPL committed to perform the 6 additional inspections beyond those recommended in the 7 GALL SLR report during the ten years period prior to 8 the subsequent period of extended operation.
9 So prior to the ARCS subcommittee meeting 10 on plant life renewal, the meeting was on July 21, FPL 11 provided additional information to address the staff's 12 concerns. And that was documented in the SER of open 13 items.
14 On the basis of this information, the 15 staff determined that its concerns related to the open 16 items were resolved. And as a result, the staff was 17 able to present the open items as a resolved issued 18 during the ACRS subcommittee meeting. Okay. Next 19 slide, please.
20 The SLR described a total of 49 AMPs. The 21 SLRA described a total of 49 AMPs. Twelve new and 37 22 existing.
23 This slide identifies the Applicant's 24 original SLRA disposition. You have the AMPs in the 25 left column. And the final disposition documented in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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90 1 the SER in the right column.
2 All of the AMPs were evaluated by the 3 staff for consistency of the GALL SLR report, and to 4 ensure compliance with 10 CFR, Part 54.
5 As a result of the staff's review, the 6 Applicant made several changes to the AMPs. One new 7 plant specific AMP was addressed to -- was added to 8 address polymer high voltage insulators.
9 As an example of another change the SME 10 Section 11, Subsection IWL AMP was changed from 11 existing with enhancements to existing with 12 enhancements and exceptions. Next slide, please.
13 Okay. On this slide I'd just like to 14 discuss a little of the staff's review and audit 15 activities which occurred to support the staff's 16 evaluation.
17 The Turkey Point review is the first 18 safety review performed by the staff using the GALL 19 SRP, or excuse me, GALL SLR, I mean, SRP/SLR guidance 20 issued in 2017.
21 In developing the process for reviewing 22 and SLRA, the staff identified several process 23 efficiencies as compared to the safety review of 24 initial license renewal applications.
25 For example, one efficiency dealt with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 conduct of audits. Instead of one large and lengthy 2 onsite audit, the staff conducts two standard audits, 3 an operator experience audit, and an in-office audit.
4 This allows us to streamline the number of 5 staff traveling to the site. The majority of the 6 audit activities and breakout discussions were 7 conducted in our office through the use of portals and 8 telecommunications.
9 Also, onsite activities are performed on 10 an as needed basis. The necessity for an onsite audit 11 might be identified in the following manner:
12 During the performance of the operating 13 experience audit and the in-office audit, when it's 14 determined that onsite observations of material 15 conditions related to aging or -- excuse me, related 16 to aging, or component locations and configurations 17 are required to complete the staff's review.
18 Or, when a complex technical issue is 19 identified such that communications and information 20 gathering would be more efficiently performed by an 21 onsite audit.
22 For Turkey Point, during the two-week 23 experiencing audit, the staff performed an independent 24 review of plant specific operating experience to 25 identify pertinent examples of age related NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 degradation.
2 And it was documented in the Applicant's 3 corrective action program database. And to provide 4 insight into AMP effectiveness.
5 During the four-week in-office audit, the 6 audit team focused on two areas, the scope and the 7 screen review, and the review of AMPs, aging 8 management review items or AMRs, and time limited 9 aging analysis, or TLAAs and those reviews.
10 Based on the operating experience audit 11 and the in-office audit, the staff determined that it 12 was necessary to perform an onsite audit and also a 13 separate complex and technical issue audit.
14 The onsite audit reviewed documentation of 15 aging management programs and directly observed 16 material conditions of various structures and 17 equipment.
18 The onsite complex technical issue audit 19 reviewed appli -- the Applicant's proposed methods to 20 manage the effects of aging of concrete and steel 21 structural supports to irradiation, as well as the 22 analysis results. The issue will -- this issue will 23 be discussed further with the next slide.
24 Another efficiency that the staff 25 implemented as part of its review of the SLRAs was to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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93 1 no longer require the performance of inspection 2 procedure IP 71002, the license renewal inspection.
3 This inspection primarily focused on the adequacy of 4 pre-implementation activities for AMPs.
5 However, for subsequent license renewal, 6 the majority of aging management programs have already 7 been implemented and in effect since the beginning of 8 the 40 to 60 year period of extended operation. And 9 therefore, are no longer in a pre-implementation 10 phase.
11 Additionally, the 71002 include a scoping 12 and screening evaluation that focused on the 13 Applicant's activities relative to initially 14 identifying non-safety related SOCs with a potential 15 to affect safety-related SOCs, for inclusion of these 16 non-safety related SOCs within scope.
17 For SLR required observations of non-18 safety related components with a potential to affect 19 safety-related components, are performed by the 20 technical review staff as part of the SLRA review, or 21 during an onsite audit.
22 For Turkey Point, the staff's review was 23 also informed by the results of the Region II initial 24 license renewal inspection, IP 71003, phase four, 25 which coincided with the SLRA review time line.
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94 1 It should be noted that the phase four 2 inspection is related to the issuance of the initial 3 renewed license. And is independent of the SLRA 4 review.
5 MEMBER BLEY: Bill, can I interrupt you a 6 second?
7 MR. ROGERS: Yes, sure.
8 MEMBER BLEY: I was not at the 9 Subcommittee meeting and haven't discussed with you.
10 The -- on first license renewal, many of us always 11 found those inspection reports extremely informative.
12 And, I haven't thought about this before 13 right now. Your argument why you didn't need them 14 now, you know, makes sense on the one hand. On the 15 other hand, things would show up in those reports that 16 you didn't really see any other way.
17 I assume there are continuing inspections 18 and on the AMPs and you had access to those reports, 19 is that right?
20 MR. ROGERS: Yes, that's correct. And, I 21 was going to discuss this, I'll just go off the script 22 here for a second and just explain what occurred 23 during our review process.
24 So, as you mentioned, the next inspection 25 procedures, IP71-003, that has one to four phases.
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95 1 And, the first two are post-licensing prior to PEO, to 2 initial PEO. And, the fourth one would occur during 3 the period of extended operation.
4 So, the Turkey Point IP71-003 Phase 4 5 coincided with our review. It was during the time 6 line.
7 MEMBER BLEY: Okay.
8 MR. ROGERS: So, the -- actually, the 9 inspector that performed the -- led the inspection, 10 Paula Cooper, Region II is on the telephone today.
11 But what we found is there are ongoing sets of 12 inspections that, for a period of time overlap the 13 initial review and the subsequent renewal.
14 So, while we found while the Phase 4 15 inspection is not -- does not have like a regulatory 16 tie to this licensing action, the information's still 17 very useful to us. And, we had discussions during 18 both our audit of our onsite audit that we were 19 reviewing plant conditions, which are open issues 20 figurations. We discussed that with the Regional 21 Inspector, Paula Cooper, during that time.
22 And, there has been some, you know, 23 there's been back and forth on that.
24 I will say that when our auditors were 25 onsite, well, actually, both. When they were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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96 1 reviewing operating experience from the plant 2 database, and when they were onsite, we had similar 3 observations.
4 Now, the actions taken by the two parties 5 are somewhat different. Paula issued an inspection 6 procedure that had some findings associated with it.
7 MEMBER BLEY: Okay.
8 MR. ROGERS: We're in a licensing action, 9 and what we did is we used that information to 10 determine whether the aging management programs need 11 to be augmented or enhanced in some fashion.
12 So, we both reacted to the same set of 13 information that was shared back and forth.
14 Relative to the firs points you made about 15 the 71-002 inspection --
16 MEMBER BLEY: Yes?
17 MR. ROGERS: -- in pre-implementation, 18 that inspection is more of a paper review for when you 19 review the AMPs. They're not implemented; there's not 20 as much material to review.
21 So, for example, for this review, the new 22 programs reviewed by Headquarters staff, and 23 essentially, it's the same manner that the inspectors 24 would have done it during the pre-implementation 25 review.
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97 1 The one difference that I think is also 2 notable, is when the inspectors were doing the (a)(2) 3 review, that (a)(2) portion of that 71-002 inspection 4 back in the first renewal, so there were three bodies 5 that looked at that. The inspectors would do an 6 inspection. We had one division in NRR that would do 7 a review of that. And then, we had the License 8 Renewal Division look at it. So, all three parties 9 looked at it.
10 And, as the Applicant indicated, there's 11 not been an extensive change in the results or 12 approach to then identify items in scope for non-13 safety effective safety.
14 However, I will note that when we did our 15 onsite audit, one of the things that was looked at 16 during the onsite audit was (a)(2) related questions.
17 And, they were done by the Headquarters staff at that 18 time. So, we did take someone onsite to look at that.
19 MEMBER BLEY: Matt, did the Subcommittee 20 have an opportunity to review with the Inspector any 21 of the things? The only reason I'm bringing it up is, 22 if not, we might want to go -- push on that for the 23 next one.
24 VICE CHAIRMAN SUNSERI: Yes, no, Paula was 25 here --
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98 1 MEMBER BLEY: Oh, okay.
2 VICE CHAIRMAN SUNSERI: -- in person and 3 --
4 MEMBER BLEY: Very good.
5 VICE CHAIRMAN SUNSERI: -- made a 6 presentation.
7 MEMBER BLEY: I don't want to get her to 8 repeat what she said to the Subcommittee. I just 9 wanted to make sure we were involved in that. That's 10 great. Thank you.
11 And, thank you for that.
12 MR. ROGERS: Certainly.
13 MEMBER BLEY: Wonderful explanation.
14 MR. ROGERS: I will note, she's on the 15 telephone right now if you'd like to follow up with 16 any additional questions. She's on standby for that 17 purpose.
18 MEMBER BLEY: I haven't been through that 19 in the detail that would make that make sense to me 20 right now, so thank you.
21 MR. ROGERS: Okay, fine.
22 MEMBER BLEY: And, thanks to Paula.
23 MR. OESTERLE: So, this is Eric Oesterle.
24 I was just going to add that one of the 25 things that the staff committed to the ACRS was that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 1 for the Subcommittee meetings and the Full Committee 2 meetings, that we would always bring a site 3 representative or a Regional Inspector to the meeting 4 to share their observations on the inspections they've 5 done for license renewal including observations on 6 material conditions of the plant.
7 And so, like Mr. Sunseri identified Paula 8 who did the inspection down at Turkey Point, she was 9 at the Subcommittee meeting and is available today.
10 And so, we will continue to do that for future ACRS 11 meetings on SLR.
12 MEMBER BLEY: Thanks, Eric. I think 13 that's really important.
14 MR. ROGERS: Sure, and thank you. Next 15 slide, please?
16 So, this slide just addresses two examples 17 of plant specific issues unique to subsequent license 18 renewal.
19 The staff performed a first of a kind 20 review of irradiated structural concrete and steel 21 located in containment. In this case, it was the 22 reactor pressure vessel support system.
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100 1 of subsequent license renewal reviews.
2 Currently, there is no generic resolution 3 for addressing high fluence level impacts on 4 structural systems and components.
5 The staff guidance developed for 6 subsequent license renewal indicates all SLR 7 applicants should perform a plant-specific review of 8 fluence levels within containment, identify any 9 potential impacts on structural components, and 10 develop aging management program activities as 11 necessary.
12 In this case, the Applicant's evaluation 13 of the impact of high fluence levels on the concrete 14 portion of the RPV structural support system conclude 15 that the effects of radiation would not impact the 16 ability of the support system to perform its intended 17 function.
18 In addition, the concrete components would 19 continue to be periodically inspected during the 20 performance of the structure's monitoring program.
21 The Applicant's evaluation of the steel 22 portions of the RPV structural support system 23 determined that the enhancements to the ASME Section 24 11 in service inspection of nuclear power plant 25 components Subsection IWF AMP would be required.
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101 1 The Applicant enhanced the Section 11 IWF 2 AMP to require the inspection of all of the accessible 3 surfaces of all six reactor vessel supports of each 4 unit on a frequency of once every five years.
5 The Applicant had determined that these 6 inspections would demonstrate to the effects of aging 7 and the steel supports will be adequately managed so 8 that the intended functions will be maintained during 9 the subsequent period of extended operation.
10 The staff audited the Applicant's analyses 11 and evaluations over a period of several weeks both at 12 Turkey Point site and the additional facilities. The 13 staff's review was a multi disciplined effort that 14 included a team with expertise in fluence, materials, 15 and structures.
16 The staff concluded with reasonable 17 assurance that the Applicant had identified the 18 potential aging effects and developed aging management 19 programs that monitor the components conditions to 20 identify the effects of aging prior to the loss of 21 intended function.
22 Next, I'll discuss the staff's review of 23 the newly identified material component combination, 24 the polymer high voltage insulators, and as previously 25 mentioned, this was not addressed in the GAL SLR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1 report and the material component combination had been 2 first identified during the River Bend initial license 3 renewal application reviewed in 2018.
4 MEMBER BLEY: Are you planning that this 5 will make it into the GAL report in the next revision 6 or how do we track this?
7 MR. ROGERS: So, what we're -- yes, what 8 we're doing at the moment in the part of our process 9 is we gather this type of information in the package 10 and internally to the division in addition with 11 lessons learned. And, then, there is an ongoing 12 discussion of whether or not revisions are necessary.
13 And, they either will take the form of Interim Staff 14 Guidance or revisions to the document.
15 MEMBER BLEY: Okay. I didn't ask the 16 Applicant the same question but I'll just ask you.
17 How did you and the Applicant, together, come up with 18 what the right process is for inspecting these or 19 foreseeing them in the future?
20 MR. ROGERS: Sure. The -- well, the 21 Applicant determined what the process was. They took 22 their operating experience, they did an analysis and 23 evaluated these polymers. And, let me go back to my 24 notes for one moment.
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103 1 high voltage insulators and the evaluation considered 2 a loss of material, reduced insulation resistance to 3 the many mechanisms including wear, surface buildup of 4 contamination, and polymer degradation. Those were 5 the three primary things.
6 They put that into an aging management 7 program, had an evaluation of how they would address 8 these aging mechanisms. At that point, the staff 9 evaluates that and concluded that it met the 10 requirements of managing the effects of aging.
11 MEMBER BLEY: Okay, thanks. And, is there 12 Interim Staff Guidance now on this for the next time 13 it comes up?
14 MR. ROGERS: Not at this point. I might 15 ask Eric to address that thought.
16 MR. OESTERLE: Thanks, Bill. This is Eric 17 Oesterle.
18 So, back in March we did have a -- we 19 conducted a public meeting on SLR lessons learned 20 based on where we were with the NRC staff's review of 21 the three SLR application at that time.
22 And, one of the major focuses of that 23 meeting was looking at technical issues that were 24 identified as a result of these reviews that maybe 25 ripe for development of new guidance.
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104 1 And so, those both remain on the table.
2 We committed to periodic engagements with industry on 3 these technical issues and others that come up. But 4 we haven't determined yet what's the right format, if 5 it's going to be an ISG on one or more issues combined 6 or are we going to do a revision to the GAL SLR report 7 and the SRP SLR documents wholesale.
8 But there is a commitment to have these 9 ongoing discussions on lessons learned and technical 10 issues that would rise to that level.
11 MEMBER BLEY: I'm not personally familiar 12 with these insulators. Is there enough experience 13 with them so far that we really have a good idea of 14 what kind of problems they might incur with aging?
15 And, that the proposed AMP, well, the accepted AMP is 16 the right thing to do?
17 MR. HALE: Hi, this is Steve Hale.
18 In development of the aging management 19 program of the polymers, we did have some historical 20 information regarding how these have performed.
21 Although they're relatively new.
22 We spent quite a bit of time with our 23 information and distribution department which is the 24 ones that are primarily involved with this.
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105 1 is they're very resistant to, you know, collecting 2 salt spray and things like that.
3 MEMBER BLEY: That was a good thing.
4 MR. HALE: Yes, yes, exactly. So, you 5 know, in our discussions with D&B, you know, they were 6 able to give us the feedback on the types of aging 7 management we needed to perform on those insulators.
8 But they do find that they perform much better from 9 the, you know, collection of debris and things of that 10 sort.
11 MEMBER BLEY: thank you.
12 MR. HALE: Yes.
13 MR. ROGERS: There is one site specific 14 safety license condition that addresses FPL's one time 15 inspection AMP. The staff determined that the one 16 time inspection AMP did not address carbon steel 17 containment spray system piping as would be expected.
18 The Applicant indicated it plans to 19 replace the carbon steel piping in the containment 20 spray system inside containment with stainless steel 21 piping.
22 In addition, the Applicant had already 23 included this pipe replacement in site approved plant 24 improvement plan and has begun replacement.
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106 1 them, but how did they get boric acid in there? Did 2 they actually start the spray accidently some time or 3 --
4 MR. OESTERLE: Leaky valves.
5 MEMBER BLEY: They -- okay.
6 MR. ROGERS: So, rather than requiring the 7 Applicant to address the material environment and 8 aging effect, it wouldn't remain in the subsequent 9 period of extended operations.
10 The staff developed this license condition 11 to ensure that the pipe would be replaced prior to 12 SPEL.
13 In conclusion, the staff finds that the 14 requirements of 10 CFR 54.29(a) have been met for the 15 subsequent license renewal of Turkey Point Units 3 and 16 4, that there is reasonable assurance of safe 17 operation of Turkey Point Units 3 and 4 during the 18 subsequent period of extended operation.
19 That ends our presentation and we're 20 available for additional questions.
21 VICE CHAIRMAN SUNSERI: Well, once, again, 22 I think I would add that you did a good job of 23 representing what went on the Subcommittee meeting.
24 I know it's hard to replicate, you know, a five hour 25 meeting in a short period of time like this. But we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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107 1 do appreciate the high level review.
2 I do want to offer the opportunity for 3 your Region II representative to provide any remarks 4 if she cares to. I think she was very impressive 5 during the Subcommittee meetings, so I'd just offer 6 that comment if Paula's out there.
7 MS. JAMES: Paula? Paula? Paula Cooper?
8 MEMBER REMPE: Is the line open so she can 9 --
10 MS. JAMES: We have a separate line.
11 MEMBER BLEY: It still might not be open.
12 He's checking on it now.
13 MS. JAMES: This is Lois James. I'm -- I 14 will go give her a quick call.
15 VICE CHAIRMAN SUNSERI: Well, that's okay.
16 It was just a courtesy.
17 MS. JAMES: I'll see which line she's on.
18 VICE CHAIRMAN SUNSERI: Yes, if there was 19 something, it's not -- I think we have all our 20 questions answered.
21 MS. JAMES: Okay.
22 VICE CHAIRMAN SUNSERI: All right. So, at 23 that point, we are done. Are there any other 24 questions from the members?
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108 1 forgotten something on the buried piping. I'll look 2 back at the old slides from the Subcommittee meeting.
3 In this one, your slide four identified 4 the second item was there had been breaks in the 5 piping that was a result, there was only, and that was 6 due to an evacuation construction excavation activity.
7 But then, you noted several leaks, leaks 8 I take are not breaks, I presume there's a difference.
9 I mean, I think there's a difference. Okay.
10 MS. JAMES: Yes, sir. This is Lois James.
11 MEMBER BROWN: And then, in the 12 Subcommittee meeting, you indicated that there was a 13 set of inspections, of the methodic protection systems 14 be installed within nine years prior to the additional 15 twenty-year extended operation.
16 And, but then, you were going to monitor 17 the -- with inspections during that ten-year period 18 prior to the end period also.
19 But then, you had two caveats in there.
20 If the CP system looks like it's effective you do one 21 thing, if it's not, you do something else. That -- I 22 don't -- that was in the Subcommittee you. You didn't 23 bring that out so there's really a kind of a two sets 24 of operations that you're going to be doing inspection 25 wise, that's the way I read the Subcommittee.
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109 1 I presume that's still in place? That 2 didn't disappear between the Subcommittee and Full 3 Committee meeting?
4 MS. JAMES: This is Lois James.
5 No, sir, that did not disappear. We were 6 trying to give a high level overview of it, not get 7 into that level of detail. But we do have Brian Allik 8 on the phone.
9 MEMBER BROWN: I just wanted to make sure 10 there --
11 MS. JAMES: Yes.
12 MEMBER BROWN: -- no -- that we didn't 13 lose some --
14 MS. JAMES: That has not changed.
15 MEMBER BROWN: -- consistency. That's all 16 I was --
17 MS. JAMES: That has not changed.
18 MEMBER BROWN: -- trying to make sure 19 something hadn't changed.
20 MS. JAMES: No, sir.
21 MEMBER BROWN: Okay, that's all I had.
22 Thank you.
23 VICE CHAIRMAN SUNSERI: Was there a 24 question over here?
25 MEMBER BROWN: No, nothing.
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110 1 VICE CHAIRMAN SUNSERI: Anybody else?
2 Jose, you have any comments you want to 3 add or questions you want to ask?
4 MEMBER MARCH-LEUBA: Nothing here.
5 VICE CHAIRMAN SUNSERI: All right. So, 6 now we will open the phone line for any public 7 comments. And, while we're getting the phone lines 8 open, we'll turn to the audience here. Is there 9 anybody in the audience who would like to make a 10 public comment, come to the microphone, state your 11 name, and provide your comment.
12 (NO RESPONSE) 13 VICE CHAIRMAN SUNSERI: Okay. So, there 14 is no comments from the room. I'll turn to the phone 15 line. If there's any members of the public listening 16 in that would like to make a comment, now is the 17 opportunity. State your name and provide your 18 comment, please.
19 MS. COOPER: This is Paula Cooper at 20 Region II. Can anybody hear me?
21 VICE CHAIRMAN SUNSERI: Yes, Paula, we can 22 hear you now.
23 MS. COOPER: Awesome, because the staff 24 line was busy and I couldn't get on, so I'm on the 25 public line.
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111 1 VICE CHAIRMAN SUNSERI: Oh, okay, all 2 right.
3 MS. COOPER: However, I don't have any 4 comments to add other than if you have any questions 5 for me, I am here. But I will say that Turkey Point 6 staff, and I don't want to make it seem like I am pro-7 licensee, but they were very receptive to every 8 comment and observation that we gave them on the 9 inspection. And, I'm pretty confident that they're 10 going to implement them appropriately.
11 VICE CHAIRMAN SUNSERI: All right, well, 12 thank you for that comment.
13 Are there any other members of the public 14 that would like to make a comment?
15 (NO RESPONSE) 16 VICE CHAIRMAN SUNSERI: All right. So, we 17 know the line is open because Paula used it. So, if 18 there's no other comments, we'll close the public 19 line. And, Mr. Chairman, we turn the floor back to 20 you.
21 CHAIRMAN RICCARDELLA: Okay.
22 VICE CHAIRMAN SUNSERI: Well, let me --
23 I'm sorry, just one other point.
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112 1 will review in deliberation at your choice. Thank 2 you. CHAIRMAN RICCARDELLA: Yes, I think we'll 3 -- we have a lot to cover. And so, we'll take about 4 a 15 minute break, reconvene at 3:30 by that clock.
5 And, we have, by my count, five letters. There's one 6 I'd like to cover fairly rapidly. It's a revision to 7 a letter that we approved last meeting on a NuScale 8 report, on a NuScale topical report that I had some --
9 we had some comments while we were at NuScale and we 10 concluded that those were substantive, not editorial.
11 And so, we're going to reconsider that.
12 And then, we have the two letters that 13 were from the topics that were today. And, I'd like 14 to at least go through -- at least have a read through 15 of both of those before we conclude today.
16 So, with that, we will adjourn and I guess 17 for the day or -- recess.
18 (Whereupon, the above-entitled matter went 19 off the record at 3:17 p.m.)
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Turkey Point Units 3 and 4 Subsequent License Renewal ACRS Full Committee Meeting September 04, 2019
Agenda
- Introductions (Bill Maher - FPL Senior Licensing Director)
- Performance Philosophy and Sustainability - (Brian Stamp
- FPL Turkey Point Site Director)
- Turkey Point Site Information (Steve Franzone - FPL Licensing Manager)
- Subsequent License Renewal (SLR) Project (Steve Hale -
ENERCON Technical Lead)
- Closing Remarks - (Bill Maher - FPL Senior Licensing Director) 2
Performance Philosophy and Sustainability 3
Turkey Point Site Information 4
Turkey Point Site Information 5
Turkey Point Site Information Plant History
- Initial operating licenses issued Unit 3 - July 19, 1972 Unit 4 - April 10, 1973
- 1983-1984, replaced original steam generators
- 1991, upgraded on-site electrical system going from two emergency diesel generators (EDGs) to four EDGs
- 1992, Hurricane Andrew
- 1995, 5% power uprate, 2200 MWt to 2300 MWt
- June 6, 2002, received renewed operating licenses (first Westinghouse units)
- 2004-2005, replaced reactor vessel heads
- 2010, implemented alternate source term (AST) methodology
- 2012, 2013 implemented ~ 15% extended power uprate (EPU +
MUR) 2300 MWt to 2644 MWt
- 2012, 2013, Unit 3 and 4 entered the period of extended operation (PEO) 6
Turkey Point Site Information 7
Turkey Point Site Information 8
Turkey Point Site Information Significant Plant Modifications Since Initial License Renewal
- Replaced reactor vessel heads
- Replaced main and auxiliary transformers
- Cooling canals rehabilitation
- Replaced cask crane structure and crane
- Obsolescence Projects
- Extended Power Uprate (EPU) related modifications
- In progress Low pressure turbine rotor replacements U3 & U4 Containment Spray piping replacement Modifications and improvements to structures 9
Turkey Point Site Information Current Plant Status
- Plant Status
- 18 month fuel cycle
- Reactor oversight process (ROP) action matrix Column 1
- Last refueling outage Unit 3, Fall 2018 Unit 4, Spring 2019
- Next refueling outage Unit 3, Spring 2020 Unit 4, Fall 2020 10
SLR Project Multi-year effort starting in 2015
- Completed Feasibility study in early 2016
- Application submitted and accepted in early 2018 FPL/ENERCON Team
- Multi-discipline team with significant nuclear experience, both on site and corporate
- Extensive license renewal experience, both licensing and implementation, including original License Renewal (LR) effort for Turkey Point (PTN)
- Extensive PTN specific engineering and licensing experience
- SLRA Liaison position staffed at site by senior, experienced person 11
SLR Project Regulatory and Industry Guidance
- Used NEI 17-01 guidance
- Incorporated lessons learned from previous LRAs
- Conducted industry peer reviews
- Followed NUREG-2191 (GALL-SLR) and NUREG-2192 (SRP-SLR) to the greatest extent possible
- 18 month NRC review schedule (from April 2018)
Current Status
- Final SER issued July 22nd, 2019, no open or confirmatory items 12
SLR Project Integrated Plant Assessment - Overall approach similar to that of original LR
- Differences between LR and SLR
- Scoping and screening Minimal differences Some updates required to address 10 CFR 54.4(a)(2)
- Aging management reviews PTN initial LR pre-GALL, additional aging effects required disposition based on NUREG-2191 (GALL-SLR)
- Aging management programs (AMPs)
Significant differences PTN initial LR pre-GALL, 28 AMPs PTN SLR, 50 AMPs 13
- 14 new AMPs 12 consistent without exception 1 consistent with enhancement 1 plant-specific
- 36 existing AMPs (35 based on GALL) 1 consistent with exception 24 consistent with enhancements 10 consistent with exceptions and enhancements 1 plant-specific 14
SLR Project Commitments
- 57 total
- Will be maintained separate from commitments for current LR
- 3 license conditions in SER:
Incorporate supplement into the UFSAR Implement programs and complete activities described in the supplement prior to the subsequent period of extended operation (SPEO)
Replace containment spray piping inside containment UFSAR
- New Chapter 17, maintained separate from current LR
- SLR commitments included in table in Chapter 17 Project Team has extensive experience with LR commitment management and implementation 15
SLR Project Time-Limited Aging Analyses (TLAAs)
- Based on GALL AMPs for TLAAs, some TLAA dispositions shifted from (i) or (ii) to (iii)
- Updates required to environmentally assisted fatigue calculations due to changes in guidance documents
- Two new TLAAs for SLR Leak-Before-Break analysis for non-primary loop reactor coolant piping
- Pressurizer surge, residual heat removal and accumulator lines Reactor coolant pump integrity analysis used to address Code Case N-481 16
Closing Remarks
- Manage aging effects to ensure intended functions are maintained
- Evaluated TLAAs with acceptable results
- Satisfied requirements for subsequent license renewal
- Retain gains and build margin for the future 17
Advisory Committee on Reactor Safeguards Full Committee Meeting Turkey Point Nuclear Generating Unit Nos. 3 & 4 Subsequent License Renewal Safety Evaluation Report (SER)
September 4, 2019 Bill Rogers, Senior Reactor Engineer Office of Nuclear Reactor Regulation
Presentation Outline
- Overview of Safety Review of Turkey Point SLRA
- Closure of Open Item 3.0.3.1.7-1, Buried and Underground Piping and Tanks Program
- Aging Management Programs (AMPs)
- Staff Review and Audit Activities
- Examples of Plant-Specific Issues Unique to Subsequent License Renewal
- Site-Specific Safety License Condition
- Conclusion 2
Overview of Safety Review of Turkey Point SLRA Unit Initial Initial License Renewed Expiration Subsequent License License Renewal License Date Renewal Application Application 3 07/19/1972 09/11/2000 06/06/2002 07/19/2032 01/31/2018 4 04/10/1973 09/11/2000 06/06/2002 04/10/2033 01/31/2018
- Application Submitted - January 31, 2018
- Acceptance Determination - April 26, 2018
- Safety Evaluation Report with Open Items - May 21, 2019
- ACRS Subcommitee Meeting - June 21, 2019
- Safety Evaluation Report - July 19, 2019 3
Open Item 3.0.3.1.7-1, Buried and Underground Piping and Tanks Program
- Issue: Basis for why additional inspections, beyond those recommended in GALL-SLR AMP XI.M41, are appropriate for buried steel piping during the 10-year period prior to the subsequent period of extended operation (SPEO).
Issue Resolution 1 Cathodic protection (CP) not CP will be installed at least 9 years prior operational during the 10-year to the SPEO.
period prior to the SPEO.
AMP XI.M41: CP is installed at least 5 years prior to the SPEO.
2 FPL stated in the SLRA that Only one pipe break - due to construction there have been breaks in excavation activities; not age-related.
buried piping at Turkey Point.
3 Staff noted that several leaks FPL will conduct additional inspections in have occurred in buried steel the 10-year period prior to the SPEO.
piping.
4
Aging Management Programs (AMPs)
Applicants Original Disposition of Final Disposition of AMPs in SER AMPs
- 14 new programs
- 12 new programs 12 consistent 12 consistent 1 consistent with enhancement
- 37 existing programs 1 plant specific
- 3 consistent
- 36 existing programs
- 27 consistent with - 24 consistent with enhancements enhancements
- 6 consistent with - 1 consistent with exceptions enhancements and exceptions - 10 consistent with
- 1 plant specific enhancements and exceptions
- 1 plant specific 5
Staff Review and Audit Activities Audit / Inspection Dates Location Operating Experience May 7 - 18, 2018 Rockville, MD Audit ML18183A445 June 18 - July 23, 2018 In-office Audit Rockville, MD ML18230B482 On-site Audits July 17 - October 17, 2018 Homestead, FL /
- Complex Technical Rockville, MD ML19032A536 August 27 - 31, 2018
- On-Site Homestead, FL ML18341A024 6
Examples of Plant Specific Issues Unique to Subsequent License Renewal
- Staff performed a first-of-a-kind review of irradiated structural concrete and steel located in containment
- Staff performed a review of polymers used in high voltage insulators not discussed in GALL-SLR Report 7
SER Section 3.0.3.1.4, One-Time Inspection
- Site-Specific Safety License Condition
- Replace the portions of the carbon steel containment spray system piping inside containment that are exposed to treated borated water with stainless steel piping, which is not susceptible to loss of material in a treated borated water environment 8
Conclusion
- On the basis of its review of the SLRA, the staff finds that the requirements of 10 CFR 54.29(a) have been met for the subsequent license renewal of Turkey Point Nuclear Generating Unit Nos. 3 and 4.
9