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 risk-informed 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 2a: 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 2b: 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 2b. The NRC is interested in identifying a plant(s) to pilot this conceptually defined option

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

GSI-191 Industry Workshop Topical Agenda 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 Friday October 19th 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

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