Closure Option 1

1. Closure Option 1 GSI-191 Workshop October 18-19,2012

2. Overview • Background • Available guidance documents • Template format and considerations • Beaver Valley Unit 2 Example • Summary

3. Option 1 Overview • This is the most straightforward of the three available options to close GSI-191 • Deterministic and NRC approved methods • Expect plants using this option are generally complete except for in-vessel effects • Fibrous debris is limited to 15 g/FA • Sump strainer and Invessel loading can be shown to be acceptable through meeting clean plant criteria or by supported testing • Fibrous debris either meets a 15 g/FA In-vessel limit or will meet the limit following modifications

4. Guidance Documents • SECY 12-0093, ‘Closure Options for GSI-191’ • May 2, 2012 letter from NRC to NEI, ‘Clean Plant Acceptance Criteria’ • December 22, 2011 letter from NEI to NRC, ‘GSI-191 Resolution Criteria for “Low Fiber” Plants’ • WCAP-16793 Rev. 2 [SE pending]

5. Clean Plant Criteria • theoretical thin bed is 1/16” or less, (using total fiber = generated + latent) and (100% transport,p= 2.4 lbs/ft3) • Sump Strainer Head loss testing is not required if, • No problematic insulation within ZOI • Measures taken to reduce debris source term (e.g. double banding) • Credit total area of all trains (provided that operating procedures direct prompt restoration for return to service or other justification) • Consideration of paint chips for strainers in pits • Sacrificial area accounted for (e.g. tags, labels) • Maintain cleanliness program (define if NEI guidance or plant specific) • Satisfactorily addressed NPSH, vortexing, upstream effects and structural integrity • Strainer Head loss = clean Hl + debris Hl (where Hl can be assumed to be 2 ft. unless other representative testing is cited / applicable) OR • Acceptable head loss test

6. Clean Plant Criteria Rx In-vessel • Credit for WCAP 16793 Rev. 2 • Demonstrate that the 15 g/FA is valid for the plant specific fuel design • Plants may apply relevant assumptions (strainer bypass fraction, debris transport fraction) provided they are adequately justified for their plant design (could be based upon information of similar design) • Can use 45% bypass assumption if it can be shown to be valid for plant conditions • For total containment fiber (in order to have less than 15 g/FA to the core); • Use 45% bypass, 75% transport provided the assumptions are valid for the plant • (simply stated): 15.7 lbs. total fiber = 157 fuel assemblies 20.0 lbs. total fiber = 200 fuel assemblies OR • Acceptable bypass test

7. Template Attributes • Resolution Status • Identify method of compliance with 15 g/FA criteria • Clean plant criteria or plant specific bypass testing • Modifications if currently not met • Licensing Basis Commitments • Resolution schedule • Meet SECY 12-0093 for open items (e.g. modifications) • 2 outages from 1/1/13 [no later than 1/1/17] • Licensing basis update following completion of open items and NRC acceptance

8. BV-2 Example • Resolution Status • No further questions except for in-vessel • Reference to previous submittals, including RAI responses • Emphasis on Modifications • Insulation (extensive change out to RMI) • Buffer replacement from NaOH to NaTb • Containment coating / cleaning program • use NEI 04-07 quantities for latent debris • Credit for bypass testing to derive in-vessel load • Enercon strainer with bypass eliminators

9. BV-2 Example • Rx invessel load • Existing commitment to resolve Rx in-vessel based upon WCAP-16793 Rev. 1 • Need to reconcile to Rev. 2 and any limitations associated with SE • New commitment to update licensing basis following NRC review / approval

10. Summary • For the BV2 example, closure is based upon low fiber loading and credit for bypass testing • For RMI plants, a strict containment cleanliness program or credit for plant specific bypass testing would be required • Expect that if plants need to make modifications or perform additional testing to meet 15 g/FA, they would defer to Option 2