PWR Sump Performance GSI191 Industry Workshop Hyatt Regency

PWR Sump Performance (GSI-191) Industry Workshop Hyatt Regency, Baltimore, Maryland October 18 -19, 2012 Mark Richter Senior Project Manager Nuclear Energy Institute

GSI-191 Industry Workshop § Workshop Objectives – Provide guidance and information to PWR licensees to assist in the resolution and closure of this long-standing issue. – Provide the range of closure path options and applicability relative to SECY 12 -0093. – Provide an opportunity for open discussion with peers and NRC staff to resolve questions and identify remaining issues.

GSI-191 Industry Workshop § Workshop Focus – Industry and Regulatory Perspectives – PWROG Closure Plan, STP Risk-Informed Project, and other coupled deterministic and riskinformed closure options – Bypass Testing, Defense-in Depth and Mitigation Strategies, and Operability Determination – Closure Option Templates based on options in SECY 12 -0093 for Year-End Submittals

GSI-191 Closure Options Option 1: Compliance with 10 CFR 50. 46 Based on Approved Models § Attributes and Requirements – Ideal for low/no fiber plants that meet “Clean Plant Criteria” or plants that can meet the 15 grams per fuel assembly fiber limit associated with WCAP 16793 r. 2 – Must demonstrate compliance with 10 CFR 50. 46 – Must comply with any additional conditions imposed through the anticipated SE for WCAP-16793 r. 2 – Additional margin may be achieved later based on current PWROG testing results – Required plant actions must be completed within two refueling outages after January 1, 2013

GSI-191 Closure Options Option 2: Deterministic or Risk-Informed § Graded approach with actions based on amount of fibrous insulation § Plants must implement defense-in-depth and mitigation measures to offset residual risk while testing and/or modifications are completed (Plants may reference the NEI March 5, 2012 letter to NRC summarizing these measures) § Option 2 offers a deterministic or risk-informed path for resolution and closure

GSI-191 Closure Options Option 2 a: Deterministic Resolution Path § Attributes and Requirements – Actions taken based on amount of fibrous insulation – Apply results of new PWROG test program to provide basis for new in-vessel criteria – Anticipate new in-vessel criteria will minimize or eliminate the need for additional plant modifications – Testing and plant modifications are to be completed within three refueling outages after January 1, 2013

GSI-191 Closure Options Option 2 b: Full Risk-Informed Resolution Path § Attributes and Requirements – Utilize risk-informed methods piloted by STPNOC-Risk assessment models and plant-specific testing support assumptions – Plant-specific resolution schedule established with NRC – Anticipate license amendment request submitted by December, 2015. – All testing and analysis to support assumptions complete within two RFOs after January 1, 2013 – If risk-informed approach is determined to not be feasible, deterministic resolution will be completed by third RFO after January 1, 2013

GSI-191 Closure Options Option 3 Different Regulatory Treatment for Suction Strainer and In-Vessel Effects § Attributes and Requirements – Separate resolution paths for strainers and in-vessel effects – Strainer resolved deterministically, in-vessel resolved by risk -informed or yet to be defined methods – Requires identification of defense-in-depth measures to mitigate risk while testing, and modifications are completed – Deterministic scope to be complete within two RFOs after January 1, 2013 and the risk-informed scope consistent with the schedule defined by Option 2 b. – The NRC is interested in identifying a plant(s) to pilot this conceptually defined option

GSI-191 Industry Workshop Topical Agenda § Thursday October 18 th § Introductions and Opening Remarks § PWROG Closure Plan Panel Discussion w/Q&A § Risk-Informed Approach § NRC Perspectives on Closure § Risk-Informed Approach Panel Discussion w/Q&A § PWROG Closure Plan – PWROG Perspective on Closure – GSI-191 Downstream Effects Resolution Path – GSI-191 Downstream Effects – Alternate Flow Paths § Closing Comments

GSI-191 Industry Workshop Topical Agenda § Friday October 19 th § Opening Remarks: Agenda Review and Re-focus § Option 3 (Reg. Guide 1. 174 and Other Approaches) – Risk-Informing In-Vessel Effects – Risk-Informed Approach for GSI-191 Resolution § Defense-in –Depth, Mitigation Measures § Bypass Testing Attributes and Recent Bypass Testing Results – Bypass Testing – STP Testing with NEI Debris Preparation – Bypass Testing NRC Perspective

GSI-191 Industry Workshop Topical Agenda § Template Overview for All Closure Options § Panel Discussion on Closure Strategies w/Q&A – Option 1 – Beaver Valley – Option 2 a – Farley – Option 2 b – Vogtle – Option 3 – Point Beach § Operability Determination Approaches – Assuring Regulatory Certainty Through Technical Specifications – Operability Determination Template § Closing Comments