ESP / COL Applications

Meteorological Data Requirements and

Regulatory Conformance Issues

Ping Wan Bechtel Power Corporation

The Eleventh Nuclear Utility Meteorological Data Users Group MeetingOctober 2006

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U.S. Nuclear Energy

Quick facts

- 103 nuclear plants

- 20% of the nation’s electricity

- 90.7% capacity factor

- No new contracts since 1975

- No new plants since 1995

- >23,000 MWe of new capacity since 1990

3

U.S. Energy Demand

1980 19901970 2015 2025

Commercial Use

Residential Use

Source: U.S. Department of Energy

3,839BkWh

2003

2003

Industrial Use

5,787BkWh

2005

50 Percent More Electricity Needed by 2025

4

U.S./DOE - Nuclear Power 2010

Call for building new nuclear power plants by 2010.

Support engineering of advanced designs.

Validate regulatory process.

Develop concepts to mitigate financing risks.

Cost share industry/government.

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Proven Technology

Approved- ABWR

- AP 600

- AP 1000

- System 80+

Certification Process- ESBWR

- ACR 1000

- EPR

6

Part 52 Licensing Process

Early Site Permit

Application

Staff Review

ACRS Review

Mandatory Hearing

Early SitePermit

Decision

EquivalentEnvironmental

Information

OR

Application for Design

Certification

Staff Review

ACRS Review

CertificationRulemaking/

Hearing

Decision on Design

Certification

EquivalentDesign

Information

OR

Applicationfor CombinedLicense (COL)

Staff Review

ACRSReview

Mandatory Hearing

Decision on COL

Constructionand ITAACCompletion

Finding onITAAC

Design

Siting

COL

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Demonstrating the Process

Government and Industry

NuStart

COL E S P

Energy Bill NP-2010

Certification

Preparing ESP and/or COL Applications

Meteorological Data Requirements

9

Used Of Meteorological Data

Use of Data

Application

Development

Regulatory

Review

Plant Operation

Atmospheric dispersion estimates for both postulated accidental and routine airborne releases of effluents X X X

Comparison with offsite sources to determine the appropriateness of climatological data use for design considerations X X

Evaluation of environmental risks from radiological consequences of a spectrum of accidents X X

Evaluation of non-radiological environmental impacts X

X

Development of emergency response plans

XX

X

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Regulatory Requirements and Guidance

NRC Regulations

NRC Regulatory Guidance

NRC Review Guidance

Industry Standards / Guidelines

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Regulatory Requirements and Guidance (conti-)

Sample List

R.G. 1.23 (Proposed Rev. 1)

RS-002 (2003)

NUREG-0800,Draft Rev. 3 (1996)

NUREG-1555 (1999)

Draft DG 1145 (2006)

NUREG-0654, 0696, 0737

ANS / ANSI 3.11 (2005)

NEI 01-02 (ESP) & 04-01 (COL)

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Meteorological Tower and Instrument Siting

The objective of the onsite meteorological program is to provide measurements which represent the general site area as well as the overall site meteorology without structure influence.

Essential siting Criteria (R.G. 1.23, Proposed Rev. 1)

Base of the tower at approximately the same elevation as the finished plant grade of the new units

Location of tower upwind of the existing and new plant cooling system

Upper measurement level of the tower within the TIBL for coastal or lakeshore sites

Sensor location at least 10 obstruction heights away from such obstructions

Wind sensors located on mast away from tower structure influence

Ambient temperature and humidity sensors located away from existing and proposed moisture sources

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Meteorological Parameters Measured

On the primary tower Wind speed and wind direction at 2 levels (at 10 meters and 60

meters, which generally coincides with the routine release level for LWRs), and at the stack release height (if applicable)

Delta-T between 10 meters and 60 meters, and 10 meters and the stack release height

Ambient temperature at 10 meters Atmospheric moisture at 10 meters, and at the top of the cooling

tower (if applicable) Precipitation at or near the tower

At the backup tower Wind speed , wind direction, and horizontal wind direction

fluctuation at 10 meters

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Length & Currentness of Records

For an ESP Application At least one annual cycle of onsite meteorological data Meteorological data in the form of joint frequency

distribution of wind speed, wind direction by atmospheric stability class as described in R.G. 1.23

An electronic listing of all hourly averaged data

For a COL Application At least 2 consecutive annual cycles (preferably 3 or more

whole years), including the most recent 1-year period Meteorological data format and electronic listing same as

for the ESP Application

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Other Regulatory Requirements

Data Acquisition and Data Reduction

System Accuracy

Instrument Surveillance, and

Quality Assurance and Documentation

Regulatory Requirements on these areas can be found in various Regulatory Guides (e.g., R.G. 1.23, Proposed Rev. 1 & Draft DG 1145) and Review Guidance Documents (e.g., RS-002, NUREG-0800, Draft Rev. 3 and NUREG-1555)

Preparing ESP and/or COL Applications

Regulatory Conformance Issues

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Use of Existing Meteorological Data

Conformance Issues Confirm Representativeness of the Data

Met tower and instrument siting Meteorological parameters measured

Determine Data Quality Data acquisition (data recording/transmission) Data reduction (data processing/substitution) Instrument surveillance (calibration, maintenance, QA/QC)

Assess Completeness of the Data Set Annual data recovery rates Length of records

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Confirm Representativeness of Data

Met tower and sensor siting

Influence/Interference factors (including existing & proposed units) to be considered:

Surrounding terrain (e.g., hills, rivers & valley) Nearby natural- & man-made obstructions (e.g., trees & plant

structures Plant heat dissipation system (e.g., lakes & cooling towers) Related construction activities (e.g., earthmoving, heavy

equipment hauling & concrete batch plant operation)

Met tower & the new units have similar meteorological exposure.

Sensor elevations & measurements (wind speed, wind direction, delta-T, dew point & precipitation) on the met tower meet regulatory requirements for the new units

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Upper Level Wind and Temperature Measurement Heights

R.G. 1.23 Requirements

at least 2 levels (e.g., approximately 10 and 60 meters) of wind measurements

Implicitly indicated that the 60 meters, upper measurement level as the level of the routine releases

Conformance Issues

Some of the new reactor designs (e.g., AP1000, EPR & ABWR) could have radiological release point higher or lower than 60 meters

Ensure that separation between the Delta-T levels (i.e., 10 meters and the upper level) is no less than 30 meters.

Ensure that the proposed data collection system (existing or new) is capable of capturing representative data.

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Dew Point Measurement Height

R.G. 1.23 Requirements

Monitor atmospheric moisture at approx. 10 meters and at a height where the measurements represent the resultant atmospheric moisture content, if cooling towers are used

Conformance Issues

Majority of U.S. nuclear plants measured Dew Point at 10 meters only (i.e., once-through cooling system)

Additional Dew Point measurements at higher level may be required for new plants, if cooling tower are used.

Ensure that the Dew Point data are adequate and reliable, when use existing data. (Dew Point sensors are know to be difficult to maintain.)

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Thermal Internal Boundary Layer Effects

R.G 1.23 Requirements For sites near a large body of water, the upper

measurement level should be within the TIBL during sea or lake breeze conditions.

Conformance Issues Depending on the relative location of the met tower to the

TIBL, and to the proposed units, X/Q estimates for the new units could be under-predicted, unaffected or over-predicted.

The impacts from under-predictions need to be accurately quantified and factored in making the site-specific X/Q estimate.

The Potential implications on facility design due to over-predictions need to be evaluated.

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Typical TIBL Event

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Data Substitution

Regulatory Requirements

There are many methods of acquiring data from meteorological measurement systems which are acceptable to the NRC Staff.

Conformance Issues

Valid measurements from a redundant sensor at the same level or at a different level (with adjustment) can be used.

Replacement of a large amount of missing primary tower Delta-T data with back-up tower sigma-theta data from a nearby should be avoided.

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Use of Nearby Existing or Regional Data

Regulatory Requirements

No clear regulatory guidance on the subject available

Draft DG-1145 indirectly suggested: Wind rose comparisons (both seasonal and yearly) X/Q estimates based on XOQDOQ, PAVAN and/or ARCON96

Conformance Issues

Using reactor specific DCD limit values in lieu of making direct X/Q calculations can be considered. However, one could lose the design margin that is potentially afforded by using onsite met data.

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Climatic Representative

Regulatory Requirements

Evidence should be provided to show how well the existing met data represent long-term conditions at the proposed site.

Conformance Issues

The climatic representativeness of the onsite met data can be checked by comparison with nearby stations with similar geographical locations and topographical settings that have reliable long-term met data.

Alternatively, a demonstration of representativeness can be made using data collected by the same system, if a long-term valid and reliable data base is readily available.

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Issuance of R.G. 1.23, Third Proposed Rev. 1

Status

NRC plans to issue a Draft Revision 1 of R.G. 1.23 by October 2006

Conformance Issue

Issuance of Draft R.G. 1.23, Rev. 1 may be late coming for those applicants with submittals planned for 2007 or 2008.

NRC indicated no major changes expected in the Draft Rev. 1. However, the applicants must be prepared to address any changes in the revision.

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Dispersion Modeling Guidance & Tools

Sample List

Types of X/Q Estimates NRC Guidance Tools

Routine & Accidental Radiological Releases

R.G. 1.111

R.G. 1.145

XOQDOQ

PAVAN

Control Room Habitability Evaluation (for both chemical and radiological releases)

R.G. 1.194

NUREG/CR-6210

R.G. 1.78

NUREG-0570

NUREG/CR-1152

ARCON96

HABIT

Emergency Planning (Near Real-time Predictions)

(* Modifications required – adding plume tracking capability)

R.G. 1.23

NUREG-0654

NUREG-0696, 0737

No NRC-sponsored codes

MESODIF-II*

CALPUFF*

Environmental Impacts of Cooling Tower Plume

No specific guidance EPRI Model - SACTI

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Hypothetical Deployment Schedule and Financial Commitment for New Nuclear Generation

1 2 3 5 6 7 8 9 10 11 12

ESP

COL

100%

0%

4

~~

~~

Start

ApplicationSubmit

Application SER Issued

EIS Issued

LWA-1 ESP Issued

Year

Start

ApplicationSubmit

ApplicationSER Issued

LWA-2 Issued

COL Issued

Site EngineeringFOAK Engineering

Procurement PlanningSite Specific Engineering

COL Preparation COL Review

HearingsESP Prepare ESP Review

Hearings

SitePreparation

First Safety-Related Concrete

ConstructionITAAC

Fuel LoadIn Service

Plant DeploymentCumulative

COLEngineering

ESP6665-4/04-1

Expenditures

PlantDeployment

Engineering

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Conclusions

Criteria for a successful ESP or COL Application To have a valid, accurate, adequate and representative

meteorological data base is vitally important;

Planning or selecting a data collection system, and conducting a thorough examination of the data by a professional meteorologist are highly recommended; and

Close coordination and cooperation between the regulatory agency and permit applicants is highly desirable for the following reasons:

Relevant guidance from both the NRC and industry is not comprehensive and precise;

Issuance of R.G. 1.23, Rev. 1, DG-1145 and NUREG-0800, Rev. 3 is expected to be in the near future; and

Applicants should be prepared to address the new and/or the revised regulatory guides.