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

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

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

Guidance Documents  SECY , ‘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 Rev. 2 [SE pending]

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

Clean Plant Criteria Rx In-vessel  Credit for WCAP 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

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 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

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 quantities for latent debris  Credit for bypass testing to derive in-vessel load – Enercon strainer with bypass eliminators

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

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