TMI Update: Jan 14, 2024


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Good Day:

I had a lengthy phone chat with a colleague who has performed many, many risk assessments for nuclear power reactor risk issues. I contacted him to see if it was possible to use existing computer models to evaluate the risk implications of deferring inspections of components, relaxing the limits on work hours, etc.

As I suspected, he explained how easy it was to do. The challenge is in defining the performance and/or reliability reduction from a deferred task or relaxed limit. I posed several examples to him and asked how the potential risk implications could be modeled. For the 17 motor-operated valves on Limerick Unit 1 that Exelon sought to defer in-service inspections, the failure of the MOVs to perform their safety function (to open in some cases and to close in other cases) could be doubled. The model will then calculate the chance of core meltdown, which can be compared to the baseline (i.e., no impairments) case to see how the deferrals impacted safety margins.

For the case of relaxing work hour limits, the chances of worker mistakes in the model can be increased by multiples of 2, 5, and 10 (meaning the chance of an operator failing to start a safety system when needed is twice, five-times, or ten-times higher) to gauge the sensitivity of safety to human performance.

And the models can easily consider multiple impairments -- all 17 MOVs not being inspected this refueling, work hour limits being relaxed, torus coating remediation being deferred, etc.).

The colleague also apprised me of something I'd not realized (except in hindsight). The operating reactors vary in design and age. The risk value of a 2-inch valve at Plant X can be vastly different from that 2-inch valve's risk value at Plant Y. Similarly, some plants rely more on operators performing safety tasks than others; thus, the safety implications of relaxing work hour limits affect reactor safety differently. The NRC issued blanket relaxations of work hour limits despite knowing that the impact at some reactors would be quite higher than at other reactors.

But to the colleague's awareness, neither the NRC nor any plant owner has evaluated the risk implications from any of the assorted deferrals, reliefs, and relaxations. When I pushed back on this assertion, the colleague pointed out that if assessments had been performed, either the request or the approval would have cited the results.

The risk models are routinely used by plant owners for things like monitoring safety margins during refueling as the equipment is removed from service for maintenance and later returned to service. The NRC routinely uses the models to determine which crayon to pull from the set to color violations and kill time until lunch.

In any case, I prepared the attached slideshow to reflect my understanding of the risk assessment models and how one can account for deferrals, reliefs, and relaxations -- that it, if one were actually a risk-informed regulator and not a risk-deformed pretender.

Feel free to pass along the slideshow.

Thanks,
Dave

Mr. Bryan C. Hanson
Senior Vice President
Exelon Generation Company, LLC
President and Chief Nuclear Officer
Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555

SUBJECT: LIMERICK GENERATING STATION, UNITS 1 AND 2 – EXEMPTION FROM SELECT REQUIREMENTS OF 10 CFR PART 26 (EPID L-2020-LLR-0014 [COVID-19])

Dear Mr. Hanson: The U.S. Nuclear Regulatory Commission (NRC) has approved the requested exemption from specific requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 26, “Fitness for Duty Programs,” Section 26.205, “Work hours.” This action is in response to your application dated April 2, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20093M206), which cited the March 28, 2020 (ADAMS Accession No. ML20087P237) letter from Mr. Ho Nieh describing a process to request expedited review of certain exemptions from 10 CFR Part 26 during the COVID-19 Public Health Emergency (PHE).
Nuclear Regulatory Commission - Press Release
No: II-20-007 April 6, 2020
Contact: Roger Hannah, 404-997-4417
 
NRC Schedules Virtual Meeting to Discuss Performance of Honeywell Facility
The Nuclear Regulatory Commission staff will discuss the results of a performance review of the Honeywell uranium conversion facility in Metropolis, Ill., during a virtual meeting scheduled for April 14.
 
The session will be held from 1-3 p.m., Eastern Time (12-2 p.m., Central Time) with NRC officials from the Region II office in Atlanta and the agency’s headquarters in Rockville, Md., as well as Honeywell officials at the facility in Metropolis. The meeting can be accessed by the public and media via Skype and NRC officials will be available following the formal portion of the meeting to answer questions. For individuals without access to Skype, a telephone conference call number will also be available.
 
The NRC staff assessed performance of the Honeywell facility during the period beginning Jan. 1, 2018 and ending Dec. 31, 2019, in safety operations, safeguards, radiological controls, facility support and other areas. Although the safeguards area was assessed, that information is not publicly available due to its sensitive nature. The NRC staff review determined that Honeywell continued to conduct its activities safely and securely, protecting public health and the environment.
 
The NRC does not have resident inspectors at the Metropolis facility, but fuel facility inspectors from its Atlanta regional office conduct periodic inspections of various aspects of the operation.
 
Because the review found that none of the program areas needed improvement and the facility is currently in a “ready-idle” status with a reduced amount of material on site, the NRC has adjusted its inspection program accordingly. That reduction in overall inspections will remain in effect for the next two years if the facility remains in “ready-idle” status.
 
A copy of the NRC letter to the company regarding the performance review is publicly available on the NRC website.
 
For virtual meeting access or telephone call-in information, please contact either Tom Vukovinsky at 404-997-4622 (email: Thomas.vukovinsky@nrc.gov) or Paul Startz at 404-997-4709 (email: Paul.startz@nrc.gov).
 
Document Title:
Limerick Generating Station, Units 1 and 2 - Exemption from Select Requirements of 10 CFR Part 26 (EPID L-2020-LLR-0014 [COVID-19]).
Document Type:
Code Relief or Alternative
Letter
Document Date:
04/03/2020

Document Title:
Email re: Beaver Valley Power Station, Unit 2 - Verbal Relief for Snubbers - Delivered 4/4/2020 at 4:00 p.m. (EPID L-2020-LLR-0050)
Document Type:
Code Relief or Alternative
E-Mail
Document Date:
04/04/2020
Document Title:
Email re: Beaver Valley Power Station, Unit 2 - Verbal Relief for MOVs - Delivered 4/4/2020 at 4:00 pm (EPID L-2020-LLR-0049)
Document Type:
Code Relief or Alternative
E-Mail
Document Date:
04/04/2020
Document Title:
Beaver Valley Station, Units 1 & 2; Davis-Besse Nuclear Power Station, Unit 1; and Perry Nuclear Power Plant, Unit 1 - Annual Notification of Property Insurance Coverage
Document Type:
Legal-Insurance/Indemnity Document
Letter
Document Date:
03/27/2020

Capitolwire: Text of Senator Muth’s April 1 press release.
 
Limerick Township, Pa. -- Senator Katie Muth (D-Berks, Chester, Montgomery) today renewed her call on Exelon to improve its commitment to worker and community safety during the refueling at the Limerick Generating Station in Montgomery County, and made a short list of requests of the corporate energy giant in a letter to senior executives.
 
“Thus far, Exelon has provided an inadequate pandemic response plan, withheld information from county and state officials, and failed to prioritize the safety of its employees, contract workers, community first responders, as well as all residents of the 44th senatorial district and entire region,” Senator Muth wrote. “This is grossly irresponsible as Exelon has brought at least 1,400 workers to the epicenter of Pennsylvania’s Covid-19 pandemic.”
 
In an effort to contain the spread of Covid-19 through Montgomery County and beyond, Senator Muth is asking Exelon to do the following:
• Provide a complete list of worker accommodations. A previously provided list is incomplete. This list will ensure that first responders are geographically aware of potential risk of exposure to Covid-19 and better inform hospitality employees of the need to take precautions in the cleaning and service of lodgings.
 
* Work with federal, state, and county officials to create and implement a 14-day, controlled quarantine protocol for all contracted workers. Exelon should continue to fully compensate workers during this time and cover all costs incurred by workers during the quarantine.
 
* Continue to work with federal, state, county, and local officials throughout the refueling process, particularly improving transparency with regard to care of employees displaying symptoms of Covid-19, as requested by Congresswoman Dean and Commissioners Arkoosh and Moscowitz.
 
“These requests are simply a call for corporate responsibility to ensure maximum preventative measures to ensure safety and reduce harm of both workers, their families, essential workers across the tri-county area,” wrote Senator Muth. “It is my understanding that the plan is for many of these workers to move onto additional refueling projects, such as the scheduled Beaver Valley refueling project in western PA, as well as at other nuclear facilities across the country, and without proper safety and quarantine measures, we are risking a massive spread of Covid-19 across this state and nation.”
 
“By fulfilling these requests for increased mitigation, Exelon has an opportunity to right its wrongs and previous negligence, and demonstrate a commitment to protecting the health and safety of workers, their families and the community at large,” she concluded.
NRC Schedules Virtual Meeting to Discuss Performance of Framatome Facility
The Nuclear Regulatory Commission staff will discuss the results of a performance review for the Framatome nuclear fuel fabrication facility in Richland, Wash., during a virtual meeting scheduled for April 7.
 
The session will be held from 4-5:30 p.m. Eastern Time (1-2:30 p.m. Pacific Time) with NRC officials from the Region II office in Atlanta and the agency’s headquarters in Rockville, Md., as well as Framatome officials at the facility in Richland. The meeting will be accessible to the public and media via Skype and NRC officials will be available following the formal portion of the meeting to answer questions. For individuals without access to Skype, a telephone conference number will be available.
 
The NRC staff assessed performance of the Framatome facility in Richland during the period beginning Jan. 1, 2018, and ending Dec. 31, 2019, in safety operations, safeguards, radiological controls, facility support and other areas. Although the safeguards area was assessed, that information is not publicly available due to its sensitive nature. The NRC staff review determined that Framatome continued to conduct its activities safely and securely, protecting public health and the environment.
 
The review found that no program area needed improvement, which means the NRC will continue its normal inspection program for such facilities. The NRC does not have resident inspectors at the Richland facility. Facility inspectors from the agency’s Atlanta regional office conduct periodic inspections of various aspects of the operation.
 
A copy of the NRC letter to the company regarding the performance review is publicly available on the NRC website.
 
For virtual meeting access or telephone call-in information, please contact either Richard Gibson Jr., at 404-997-4718 (email: Richard.gibson@nrc.gov) or Gregory Goff at 404-997-4744 (email: Gregory.goff@nrc.gov).
 
Nuclear Regulatory Commission - News Release
No: 20-021 April 1, 2020
CONTACT: David McIntyre, 301-415-8200
 
NRC Approves License Transfer of Crystal River 3 Nuclear Power Plant
The Nuclear Regulatory Commission has approved the license transfer for the Crystal River 3 nuclear power plant from Duke Energy Florida to ADP CR3, enabling active decommissioning of the former nuclear power plant.
 
ADP CR3 is a subsidiary of Accelerated Decommissioning Partners LLC, a joint venture of NorthStar Group Services, Inc. and Orano Decommissioning Holdings. NorthStar will also be contracted to demolish the permanently shut down coal-fired Crystal River units 1 and 2.
 
Duke permanently ceased operations at Crystal River 3 in 2013. The company applied for the license transfer in June 2019. Under its agreement with ADP CR3, Duke will remain the owner of the nuclear power plant, property and equipment, and will retain ownership and control of the trust fund that pays for the decommissioning. ADP CR3 will become the NRC licensee responsible for decommissioning the plant in compliance with all state and federal regulations.
 
ADP CR3 plans to complete decommissioning by 2027.
 
Planned Nuclear Refueling Outages in 2020
In 2020, 56 of the nation’s 58 nuclear reactors in 21 states—including several that have issued lockdown measures—planned to undergo refueling outages. At least 31 of the 58 plants had scheduled outages between mid-February and early May. The remaining 25 planned refueling outages between late August and late October. 

The average U.S. refueling outage times have shortened in recent years—decreasing from an average of 46 days in 2012 to 32 days in 2019—owing in part to improved and planning and execution practices for refueling outages over the years, NEI told POWER. Of significant note is that the 2020 season is poised to be especially busy in part because planned nuclear generation outages are generally timed to coincide with a plant’s refueling cycle, it said. 
 
Table. Expected U.S. Nuclear Plant Refueling Outages in 2020. Courtesy: NEI
 
Plant
City
State
Company
Approx. Start
1
Browns Ferry
Athens
AL
Tennessee Valley Authority
Mid February
2
Grand Gulf
Port Gibson
MS
Entergy
Mid February
3
Brunswick
Southport
NC
Duke Energy Progress
late February
4
Davis Besse
Oak Harbor
OH
First Energy
Late February
5
Byron
Byron
IL
Exelon
Early March
6
Nine Mile
Oswego
NY
Exelon
Early March
7
Vogtle
Augusta
GA
Southern Nuclear Operating Co.
Early March
8
South Texas Project
Wadsworth
TX
STP Nuclear Operating Co.
Early March
9
Arkansas Nuclear One
Russellville
AR
Entergy
Early March
10
Point Beach
Two Rivers
WI
NextEra (FPL)
Early March
11
Salem
Hancocks Bridge
NJ
PSEG
Early March
12
Fermi
Frenchtown Charter Twp.
MI
DTE Energy
Mid March
13
McGuire
Huntersville
NC
Duke Energy
Mid March
14
Susquehanna
Berwick
PA
Talen Energy
Mid March
15
Sequoyah
Soddy Daisy
TN
Tennessee Valley Authority
Late March
16
Beaver Valley
Shippingport
PA
FirstEnergy
Late March
17
Limerick
Pottstown
PA
Exelon
Late March
18
Quad Cities
Cordova
IL
Exelon
Late March
19
Turkey Point
Florida City
FL
Florida Power & Light
Late March
20
Seabrook
Seabrook
NH
NextEra Energy
Early April
21
Salem
Hancocks Bridge
NJ
PSEG
Early April
22
Palo Verde
Tonopah
AZ
Arizona Public Service Company
Early April
23
Comanche Peak
Glen Rose
TX
Luminant
Early April
24
Ginna
Ontario
NY
Exelon
Early April
25
Oconee
Seneca
SC
Duke Energy
Early April
26
VC Summer
Jenkinsville
SC
Dominion Energy
Early April
27
Millstone
Waterford
CT
Dominion Energy
Early April
28
Braidwood
Braceville
IL
Exelon
Mid April
29
Watts Bar
Spring City
TN
Tennessee Valley Authority
Mid April
30
Catawba
York
SC
Duke Energy
Early May
31
Surry
Surry
VA
Dominion Energy
Early May
32
Indian Point
Buchanan
NY
Entergy
Early May
33
Palisades
Covert
MI
Entergy
Late August
34
North Anna
Mineral
VA
Dominion Energy
Early September
35
Robinson
Hartsville
SC
Duke Energy Progress
Early September
36
Vogtle
Augusta
GA
Southern Nuclear Operating Co.
Early September
37
Fitzpatrick
Oswego
NY
Exelon
Early September
38
Prairie Island
Welch
MN
Northern States Power
Early September
39
DC Cook
Bridgman
MI
AEP
Mid September
40
McGuire
Huntersville
NC
Duke Energy
Mid September
41
Cooper
Brownville
NE
Nebraska Public Power District
Mid September
42
Waterford
Killona
LA
Entergy
Mid September
43
Point Beach
Two Rivers
WI
NextEra (FPL)
Early October
44
Salem
Hancocks Bridge
NJ
PSEG
Early October
45
Palo Verde
Tonopah
AZ
Arizona Public Service Company
Early October
46
Browns Ferry
Athens
AL
Tennessee Valley Authority
Early October
47
Diablo Canyon
Avila Beach
CA
Pacific Gas & Electric
Early October
48
Callaway
Fulton
MO
Ameren
Early October
49
Byron
Byron
IL
Exelon
Early October
50
Turkey Point
Florida City
FL
Florida Power & Light
Early October
51
Farley
Dothan
AL
Southern Nuclear Operating Co.
Early October
52
Comanche Peak
Glen Rose
TX
Luminant
Early October
53
Peach Bottom
Delta
PA
Exelon
Mid October
54
Millstone
Waterford
CT
Dominion Energy
Mid October
55
Watts Bar
Spring City
TN
Tennessee Valley Authority
Mid October
56
Duane Arnold
Palo
IA
NextEra Energy
Late October
 
As of March 25, according to the Nuclear Regulatory Commission (NRC), 13 of the U.S.’s 96 commercial nuclear reactors were offline for refueling outages: Indian Point 3, Nine Mile Point 1, Susquehanna 2, Browns Ferry 2, Brunswick 2, McGuire 1, North Anna 2, Turkey Point 4, Vogtle 2, D.C. Cook 1, Perry 1, Point Beach 1, and Quad Cities 1. At least five others were coasting down in preparation for refueling outages: Limerick 2, Salem 1, Byron 2, Monticello, and Comanche Peak 1. 
The Energy Information Administration (EIA), which compiles data from the NRC into a useful interactive map that shows the status of U.S. nuclear outages, noted that 16.9% of total U.S. nuclear capacity—about 17 GW of the total 100 GW—was offline as of March 25.

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