ML082980438
| ML082980438 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 10/15/2008 |
| From: | NRC/OCM |
| To: | |
| Tam P | |
| Shared Package | |
| ML082880712 | List: |
| References | |
| NRC-2464, TAC MD9305 | |
| Download: ML082980438 (71) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Meeting with Northern States Power Company RE Monticello Plant Docket Number: (n/a)
Location: Rockville, Maryland Date: Wednesday, October 15, 2008 Work Order No.: NRC-2464 Pages 1-68
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~ ... _. ~ __*.__...........JJ NEAL R GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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OFFICE OF NUCLEAR REACTOR REGULATION
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MEETING WITH NORTHERN STATES POWER COMPANY (NSPM) TO DISCUSS ISSUES RELATED TO A FUTURE APPLICATION FOR AMENDMENT REGARDING EXTENDED POWER UPRATE AT MONTICELLO NUCLEAR GENERATING PLANT, UNIT 1
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WEDNESDAY, OCTOBER 15, 2008
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The meeting convened at 9:00 a.m. in Room T-9 F5 at Two White Flint North, 11545 Rockville Pike, Rockville, Maryland, Peter S. Tam, Senior Project Manager, presiding.
NRC PARTICIPANTS:
PETER TAM, NRR/P1ant Licensing Branch 111-1 TOM ALEXION, NRR/Generic Communication & Power Uprate Branch CHAKRAPANI BASARAVAJU, NRR/Mechanica1 & Civil Engineering Branch JOHN BOZGA, Region III (via telephone)
KAMAL MANOLY, NRR/Mechanica1 & Civil Engineering Branch ROY MATHEW, NRR/E1ectrica1 Engineering Branch SUBINOY MAZUMDAR, NRR/ Instrumenta tion and Controls Branch NITIN PATEL, NRR/EEEB LICENSEE:
STEVEN HAMMER, NSPM SOO BEE KOK, SIA GABE SALAMON, NSPM ALLEN WILLIAMS, NSPM ALSO PRESENT:
KIRK JENKS, Constellation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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2 CONTENTS INTRODUCTION BY P. TAM 3 INSTRUMENT SETPOINT METHODOLOGY 5 STEAM DRYER STRUCTURAL INTEGRITy..... 10 EQUIPMENT QUALIFICATION 34 STATUS OF GRID STABILITy............. 47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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3 1 P-R-O-C-E-E-D-I-N-G-S 2 9:09 a.m.
3 MR. TAM: Good morning, I'm Peter Tam and 4 welcome to the Monticello Meeting talking about the 5 impending submittal of the EPU application. This is 6 a pre-application meeting. We do not have anything in 7 our possession to review.
8 But, in the meeting notice I did reference 9 a letter that I sent to Monticello when they withdrew 10 the previous submittal.
11 So, why don't we just go around and take 12 care of the administrative things that we cannot hold 13 the meeting yet because they are talking about 14 proprietary stuff.
15 Today's meeting will be fully transcribed 16 and this is our Court reporter. In order to -- for 17 those who are not used to this you need to each time 18 you speak no matter how short you speak -- you have to 19 give us your name so that he can look up and identify 20 you.
21 And the transcript will be part of the 22 meeting summary. We'll put in the public domain 23 except for the fact that it's proprietary, but I was 24 told that there was no proprietary information today.
25 Has everybody signed because I need to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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4 1 have the Court reporter look at it?
2 (No response.)
3 MR. TAM: Yes, I already have some of the 4 names. If you know a person not here please cross out 5 the persons name. All right, who from the licensee is 6 taking the lead?
7 MR. HAMMER: I will.
8 MR. TAM: Okay, do you want us to go 9 through the introduction of everybody first?
10 MR. WILLIAMS: I'd like that, yes.
11 MR. TAM: All right, let's go around. As 12 I said I'm Peter Tam.
13 MR. PATEL: Ni tin Patel from NRR 14 Electrical.
15 MR. ALEXION: Tom A1exion from NRR.
16 MR. MATHEW: Roy Mathew from the 17 Electrical Branch, NRR.
18 MR. WILLIAMS: I'm A1 Williams. I am the 19 Manager of the Extended Power Uprate Project at 20 Monticello.
21 MR. HAMMER: I'm Steve Hammer. I'm the 22 Proj ect Manager for the licensing aspects of the 23 extended Power Uprate Project at Monticello.
24 MR. SALAMON: Gabe Salamon, Licensing 25 Monticello.
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5 1 MR. BASARAVAJU: Pani Bsaravaju, 2 Mechanical and Civil Engineering Branch, NRR.
3 MR. MAZUMDAR: Subinoy Mazumdar, 4 Instrumentation and Controls, NRR.
5 MR. JENKS: I'm Kirk Jenks. I'm Nine Mile 6 Point EP Licensing Support.
7 MR. KOK: I'm Soo Bee Kok, I'm from 8 Structural Integrity Associates.
9 MR. TAM: Great.
10 MR. WILLIAMS: Great, are we ready to go.
11 Okay, again I'm Al Williams. I'm Manager of the 12 Extended Power Uprate Project. Good morning 13 everybody.
14 I would like to talk to you a little bit 15 today is what you are going to see from us at the 16 beginning of November for a license submi ttal for 17 extended power uprate at Monticello Point. So I'll be 18 going through some background of the Plant and of the 19 process to date.
20 We're going to talk about the three items 21 that were specifically listed in the letter that Mr.
22 Tam sent us concerning our initial submittal. We're 23 also going to talk about the grid stability study 24 which we performed and I'll go into the background 25 there.
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6 1 There are also some what I call minor 2 changes to our license amendment request since the 3 last time it was submitted. We'll go through those.
4 We'll talk about our overall schedule and then have a 5 summary.
6 So from a background from Monticello. As 7 some of you may remember we submi tted our initial 8 license amendment request to the NRC on March 31, 9 2008. It then entered the sufficiency review process 10 per the procedure LIC, I believe it's 109 which is an 11 internal NRC guidance for sufficiency review.
12 After discussion wi th the staff Monticello 13 chose to wi thdraw the license and memo request on June 14 25th and received a letter from the NRC to that 15 effect.
16 There were three of them specifically 17 listed in the withdrawal letter. First the steam 18 dryer evaluation was deemed not to have sufficient 19 information for the staff to do review. There were 20 also some questions on the equipment qualification in 21 terms of the analysis that was done at the Monticello 22 Plant.
23 And there were questions regarding the 24 instrument setpoint methodology or the reference is 25 TSTF 493. We will address all three of those in this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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7 1 meeting. It is not our intent to discuss proprietary 2 information in this meeting.
3 The Monticello Plant is performing 4 extended power uprate under these project principles 5 and they guide ever decision we make in the actual 6 proj ect and you'll see that as we go through our 7 presentation.
8 The first two bullets up there are major 9 principles for this project. First is we're going to 10 maintain or improve the safety and risk profile of the 11 Plant. What that means is is when we perform a 12 modification of the facility we go, we're going to go 13 to some length that either we're going to maintain our 14 margins or we're going to increase the margins of the 15 facility due to that modification.
16 So in other words, as we go through the 17 review process you're going to see that the Plant 18 that's going to operate at the extended power uprate 19 power level and a lot of areas do the modifications we 20 do we'll have more margins or more operating and 21 safety margins than what the Plant has now.
22 The second bullet is to improve our 23 enhanced equipment reliability. Monticello received 24 license extension to 2030 a few years ago and we'll go 25 through that.
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8 1 Part of the point of EPU is to replace 2 equipment that's going to be necessary for that 20 3 years of operations. So, EPU is actually part of a 4 bigger project we call life cycle management.
5 So again our intent is to make sure the 6 Plant can run safely and reliably for the extended 7 license period. There are five sub bullets.
8 Obviously we're going to follow the existing 9 regulatory processes.
10 We use industry operating experience 11 extensively in our project. We coordinate with other 12 Plant proj ects . A big point here is we try to 13 minimize the impact on day to day operation and what 14 that means is we're trying to give the operators in 15 the control room a Plant that substantially 1S 16 similarly operates as to what they operate 17 today.
18 Now there are a couple of adjustments to 19 that. We do have a couple of mods that have new 20 consoles in the control room that require training.
21 But we try to minimize those where we can.
22 So for the majority of the mods the only 23 difference the operator will see will see a procedure 24 change that will say instead of running on this point 25 on the dial it will be a little bit further over so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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9 1 the monitor it to a different setpoint.
2 But, in terms of the base operation of the 3 facility we're trying to keep that the same. And then 4 Monticello, as part of excel is also, also has another 5 nuclear Plant Prairie Island. So we try to extract 6 value from standardization or economies to scale.
7 So if there's some modification or some 8 piece of equipment that we can use at both facilities 9 we try to do that. That's a goal we try to meet 10 obviously with Prairie Island being a BWR that can be 11 somewhat difficult at times.Monticello background. We 12 are a GE BWR 3. We were licensed in 1971. We began 13 operation at our original license thermal power limit 14 of 1,670 megawatts thermal.
15 Monticello was actually the first BWR to 16 receive an extended power uprate. In 1998 Monticello 17 increased licensed power to 1,775 megawatts thermal 18 which is where we operate today.
19 A note to that original EPU is that that 20 was mostly an analysis EPU. So when you hear Mr.
21 Hammer talk about the modifications we're doing that's 22 a far bigger scope EPU than what this original EPU 23 was.
24 Our application that we're going to submit 25 to you at the beginning of November is for 2004 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 megawatts thermal which is 120 percent of the original 2 license thermal power of 1,670 megawatts.
3 In terms of our schedule we do intend to 4 increase power in two stages. First, after we receive 5 EPU approval, which we are hoping it will be some time 6 in 2010, we will increase power to approximately 1,870 7 megawatts. And that number is based on our electrical 8 generator. The generator will be limited at that 9 point until the 2011 outage where we finish our EPU 10 mods.
11 After the 2011 outage our intent is to 12 increase to the full EPU power level of 2,004 13 megawatts. So, our implementation schedule, our 14 actual first implementation we intend to do online.
15 Our first set of modifications are going to be 16 installed in six months in March of 2009 with our 17 upcoming outage.
18 At this point I'd like to turn it over to 19 Steve Hammer to talk about the actual items in the 20 latter.
21 MR. HAMMER: My name is Steve Hammer. I'm 22 the Proj ect Manager for the licensing aspects of 23 extended power uprate at Monticello. The first thing 24 we want to talk about is some information on the 25 Monticello steam dryer.
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11 1 The Monticello steam dryer is a GE 1965 2 product line square hood dryer. This is the original 3 dryer that the Plant was originally started up with.
4 There have been no modifications done to the steam 5 dryer at this point in time.
6 The licensing basis accident for defining 7 the 1imi ted loads for the steam dryer at Monticello is 8 based on the main steam line break outside of 9 containment and that is consistent with what we will 10 be doing moving forward on that. That will remain the 11 limiting design basis of that for the steam dryer.
12 The steam dryer to this point in time has 13 been inspected per the BWR reactor vessel internal 14 project, BWRVIP-130. And we have very minimal 15 indications on the existing steam dryer from those 16 inspections.
17 EPRI and the BWRVIP have an initiative to 18 provide a consistent steam dryer methodology. To this 19 point in time a lot of the work has been done per 20 BWRVIP-182 which provides guidance for steam dryer 21 evaluation methodologies. This was submitted in 22 January of 2008.
23 There's addi tiona1 work going on right now 24 by a EPRI group to provide a licensing topical report 25 on a continuing dynamics of the CDI methodology.
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12 1 That's currently planned to be submitted in late 2008.
2 I think the goal at this point in time is 3 to actually have that submitted on or about November 41st. It is in final reviews at this point in time.
5 In addi tion, we have followed the guidance 6 provided in Reg Guide 1.20 Rev. 3 with the exception 7 of the '98 startup reporting.
8 Our steam dryer evaluation approach is per 9 BWRVIP 182 as I mentioned. That consists of a number 10 of different aspects. One aspect is to provide a 11 screening of the perceptibi1i ty of the existing system 12 to acoustic excitation and to consider validation of 13 that by scale model testing.
14 At Monticello we did both of those 15 aspects. We installed strain gages on the main steam 16 lines to provide measurement of main steam line 17 response both at -- originally that was done just to 18 current license thermal power. We'll talk a little 19 bit more about that testing of those signals as we 20 move through this.
21 We used the acoustic circuit model 22 developed by CDI to establish loads on the steam dryer 23 and that load definition is transferred from the main 24 steam lines onto the steam dryer by a load definition 25 of current license thermal power.
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13 1 In our case we are using scale model 2 testing to provide bump up factors that will allow us 3 to evaluate those loads at extended power uprate 4 conditions. We've done a finite element model of the 5 dryer at current license level power conditions to 6 define loads on the dryer. And we are also -- will be 7 using limit curves to define the limits on the dryer 8 during power ascension.
9 The main steam line strain gage data, as 10 I pointed out installed means, or stain gage is on our 11 main steam system. Based on the CDI methodology and 12 guidance. Those were installed in 2007.
13 The initial data taken in 2007 was 14 primarily based at me finding loads of current license 15 thermal power. Subsequent to that is as time has gone 16 on and I think everybody is aware we are now 17 everybody is considering me finding a low power data 18 to allow you to eliminate noise on the steam dryer 19 loads.
20 The initial data taken at Monticello did 21 not have the EIC data taken. So there was no 22 consideration of electrical induced currents. And in 23 addition the low power data that we took in 2007 was 24 more or less not taken intentionally to define low 25 power conditions. We were doing that more or less NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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14 1 just to test our the data acquisition system.
2 So, in our case we happened to take data 3 at 28 percent power and that's the low power data that 4 we have been using to this point in time.
5 Fil ters were applied to consider pipe 6 bending research pump electrical and vane passing 7 frequency noises and those have been filtered out. We 8 are planning at this point in time of doing sub-model 9 analysis similar to what TVA is doing to address hot 10 points of the high stress points on our dryer and at 11 this point in time we have about four locations that 12 have stress where it shows that will require sub-model 13 analysis or some further refinement of those loads to 14 ensure that we meet the acceptance criteria in the 15 dryer analysis.
16 We are applying bias and uncertainty 17 inconsistent with the CDr licensing topical report 18 approach and r think we are consistent with what TVA 19 Browns Ferry has done with those aspects.
20 The dryer evaluation results, as pointed 21 out previously, are in previous submittals. The SRV 22 sand pipe resident frequency is expected to occur upon 23 approximately 162 hertz at Monticello at current 24 license thermal power.
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15 1 verify that we will not see the onset of residents at 2 Monticello. That's been confirmed by two approaches.
3 One is an analytical approach that shows that the 4 calculated onset of residents requires a steam 5 velocity of 185 feet per second.
6 Our EPU steam velocity based on the heat 7 balance at Monticello is currently proj ected to be 179 8 feet per second. So we don't based on an 9 analytical approach we do not expect to see the onset 10 of residents.
11 In addition, we did a scale model test to 12 verify that when acoustic residence occurs a scale 13 model test predicted the onset of residence at about 14 201 feet per second.
15 Again, showing that we should add margin to the onset 16 of residence.
17 Our goal at this point in time is that we 18 will ensure that we have a stress ratio under EPA 19 condi tions of greater than 2.0 and we'll have a stress 20 ratio of greater than 2.0 at current license thermal 21 power.
22 MR. MANOLY: Steve, you said your 23 calculations steam velocity 179 which is lower than 24 186. How is the 185 related to that?
25 MR. HAMMER: Well, the 185 was just an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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16 1 analytical evaluation of where you would hit a 2 velocity that would again steam in Monticello. Based 3 on analysis 185 per second will create the 162 hertz.
4 So that's the length here.
5 MR. MANOLY: Well, the 201 1S the scale 6 model, huh?
7 MR. HAMMER: 201 is the scale model.
8 MR. MANOLY: So, how do you like expect 9 predictability between the scale model and the 10 calculated numbers?
11 MR. HAMMER: Well, our understanding is 12 tha t wi thin kind of expected accuracy ranges on scale 13 model testing. I mean both of these have a certain 14 amount of uncertainty associated with the analytical 15 approach and the scale model test.
16 You know my guess is that the actual 17 values are probably some place between those values.
18 MR. MANOLY: So, that uncertainty comes 19 before the calculations?
20 MR. HAMMER: I can't answer that right 21 now. I don't believe it is.
22 MR. MANOLY: But it's something to think 23 about.
24 MR. HAMMER: Yes. In addition, one of the 25 concerns that were identified by the NRC when we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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17 1 wi thdrew the license amendment is consideration of 2 existing steam dryer clause.
3 We have a fairly limited number of flaws 4 at Monticello or nearly like five. All of these are 5 relatively minor. There's one IGSCC flaws. The 6 others are in welds. The typical well flaws is on the 7 order of 1/8th inch or less.
8 And our goal, we will demonstrate based on 9 analysis that these flaws have no effect on component 10 stiffness and don't effect the FDA model from mobile 11 response due to cracking. In addition, we will 12 demonstrate that these cracks do not have a potential 13 for growth and we don't expect to see any repeated 14 formations.
15 But, the final element analysis is showing 16 right now that the stress is an alternated stress and 17 that these locations are very low so we don't expect 18 to see any significant change.
19 MR. MANOLY: How much come off from the 20 crack?
21 MR. HAMMER: It varies, the IGSCC cracks 22 are on a drain channel which has an inspection plate 23 on a drain channel. And those are -- that's a fairly 24 incrust section and those are probably through a wall.
25 But there's very li ttle moments there.
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18 1 The differential pressure in that drain channel is 2 open to the inside of the rafters. So we expect the 3 differential pressure to probably one PSI or less that 4 type of thing. So the loads are very small.
5 The other cracks are typically in fillet 6 welds. So they are not expected to be through the 7 wall. But they do -- some of them go part way through 8 a weld and there's one or two of them that go all the 9 way through a weld.
10 MR. BASARAVAJU: What kind of stress is 11 this that go through the well?
12 MR. HAMMER: Excuse me?
13 MR. BASARAVAJU: What kind of stress 14 levels?
15 MR. HAMMER: I'm not prepared to answer 16 that at this point in time. We've got the stress 17 analysis for the steam dryers still in validation at 18 this point in time and so you know all I'm prepared to 19 say is that they are very low. But I can't give you 20 an exact value.
21 What we expected from the previous 22 analysis which is you know we've redone that analysis, 23 but the previous analysis showed that they were less 24 than 2,000 PSI at all locations. So, you know at this 25 point in time I can't say what the exact number is for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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19 1 the new analysis.
2 Any other questions?
3 MR. WILLIAMS: Is it true though that the 4 cracks and or stress points from the previous analysis 5 are not in the same locations?
6 MR. HAMMER: Oh, the high stress?
7 MR. WILLIAMS: Yes.
8 MR. HAMMER: Yes, the high stress there is 9 some -- they are not in high stress locations. They 10 are all in low stress locations.
11 MR. MANOLY: So the restricted IGSCC 12 cracks here?
13 MR. HAMMER: Well no, there's one that 14 IGSCC. That's on the channel drain. The others are 15 believed to be due to fabrication type issues, 16 original weld stress type issues. And all of those 17 are in welds so I don't think are IGSCC.
18 MR. MANOLY: Well, IGC is usually 19 in the heating zone.
20 MR. HAMMER: Well but these are actually 21 in the weld itself.
22 MR. MANOLY: In the weld itself, okay.
23 MR. HAMMER: Yes, okay steam dryer 24 summary. The evaluation will be done per BWRVIP-182.
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20 1 licensing and topical report approach. We will impact 2 or evaluate the impact of plausible growth and we will 3 ensure, as I stated before that we are not impacted in 4 the resident response of the steam dryer.
5 So we're not impacting fini te resident 6 analysis and we will show that there is very limited 7 potential for crack growth. And our goal will be to 8 show that we have minimal alternating stress ratios 9 that are greater than 2.0 under EPU formations.
10 MR. MANOLY: How far along are you on the 11 evaluation?
12 MR. HAMMER: At this point in time it's in 13 validation and we're working through some of the final 14 details. Maybe I should point out that the analysis 15 as it stands at this point in time is largely based on 16 the 2007 data.
17 One issue that I should probably bring up 18 is that we also, similar to TVA had a scram in late 19 September which allowed us to get a new set of steam 20 dryer, main steam land loads in early October. And 21 right now we are -- we plan on using those new loads 22 to address EIC.
23 I mentioned that the original loads did 24 not have EIC in them. So we will both use EIC trying 25 to address those loads from that new data.
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21 1 MR. MANOLY: So you don't -- there is no 2 submittal not account for EIe?
3 MR. HA1'1MER: No.
4 MR. MANOLY: And it's a supposedly a 5 qualifying dryer event, right?
6 MR. HAMMER: Yes, well we ended up with 7 the original submittal. I don't remember the exact 8 date. But we have stress ratios less than 2.0.
9 MR. WILLIAMS: This is Al Williams. There 10 are about 1.8 or so was the EPU minimum alternating 11 stress ratio.
12 MR. MANOLY: So you're trying to bring 13 them up?
14 MR. HAMMER: Yes, we're trying to bring 15 them up.
16 MR. MANOLY: And we need to do some models 17 here.
18 MR. HA1'1MER: Well, that's going to be the 19 primary means of bringing them up. We'll have to do 20 some model testing. But right now our approach would 21 be similar to what the stress from TVA estimated.
22 MR. BASARAVAJU: So the validation would 23 require some models?
24 MR. HAMMER: Right, and we'll start 25 testing for that using the same type of approach.
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22 1 MR. MANOLY: I guess what I mentioned 2 completion you heard the same points. Steam is still 3 not in my view it is at a stage where we expected the 4 application would be complete.
5 The analysis should have been completed 6 before or two years into the application and still 7 debating the analysis. And I'm trying to really 8 hammer the point that we don't want to view the 9 progress. We want to complete the progress.
10 MR. HAMMER: Well, and we are entirely in 11 agreement with that. I think you are as aware as we 12 are for example, we submitted on March 31st and the 13 stress ratio acceptance criteria changed as TVA 14 pointed out in April. So that was one of the primary 15 reasons why we ended up withdrawing our submittals 16 because that criteria changed more or less after we 17 completed our analysis.
18 Now there's some risk, as we pointed out 19 yesterday, that there is you guys have some concerns 20 about whether the stress ratio of 2.0 is still 21 accurate. Again, it's the same type of thing. What 22 we're doing is we're doing this analysis wi th the goal 23 of being able to meet your -- the past stated criteria 24 of 2.0.
25 So, the risk that we've got is if we, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 know if we have a fuzzy target on what the stress 2 ratio is. You know it might require some additional 3 work.
4 We will submit based on the analysis. We 5 will demonstrate that we have created a stress ratio 6 greater than 2.0 and hopefully that can show that we 7 have some substantial margins that can be extracted 8 from both locations.
9 MR. WILLIAMS: And one of the other 10 things. One of the messages we've heard clearly from 11 NRC is that you want the industry to have a unified 12 approach on these steam dryer analysis.
13 And that's kind of the purpose of the CDI 14 topical report. To allow us and the other Plants to 15 come to the NRC with a unified approach. And that's 16 what we're attending to do. We intend to follow 17 obviously we have to take into account what TVA 1S 18 doing because they are with you for review right now.
19 But, we also communicate with the other 20 potential applicants for EPU's to make sure we all 21 understand both what the topical report says and what 22 each one of us is going to submi t so that we do 23 provide you a consistent approach so that one -- we 24 don't get into the same discussions that unfortunately 25 we've been in with another licensee.
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24 1 MR. MANOLY: Well, you know the CDI 2 approach has been progressing for some time. It was 3 evolving. It wasn't really set in concrete a year 4 ago, two years ago. It's growing and I would say 5 polishing, polishing the approach based on questions 6 we ask. I mean up to yesterday.
7 So, things are still kind of -- I'd like 8 to say finalized. But the reality is CDI has system 9 limitations you know.
10 Now maybe it's the size of the company, 11 you're trying to manage too many things at the same 12 time. But the bottom line 1S CDI's ability to 13 progress fast enough shouldn't be the reason that we 14 get applications that are in progress. And that's the 15 point that I was trying to 16 MR. WILLIAMS: And we will give you a 17 completed analysis. And our analysis will be complete 18 with the understanding that the basis for that 19 analysis is going to be a topical report that I know 20 you haven't seen yet because it's going to be 21 submitted about the same time -
22 MR. MANOLY: We already know what it's 23 going to say. I mean -
24 MR. WILLIAMS: And it's going to account 25 for any additional information that's come from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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25 1 previous reviews.
2 For example, we understand what had 3 happened In the Hope Creek submittal. We understand 4 what the understand was there was a meeting 5 yesterday of where TVA is. So we will account for 6 those items in our analysis and provide you a complete 7 analysis to the best of our ability based on the date 8 we're at.
9 Some of the problem we ran into the last 10 time is, as you said things continued to evolve in 11 these analysis and we can't predict the future. All 12 we can do is give you the completed analysis based on 13 the facts we know today.
14 MR. MANOLY: I guess the two issues that 15 were fundamental yesterday were the noise issue and 16 the sub-marvin. And those really was two factors 17 introduced to bring the load factor into it too.
18 So, I mean it's -- well we -- I thought it 19 was pretty much clear from the beginning that we were 20 looking for a load factor of two. Now, CDI could not 21 meet that so they had to come up with some ways to 22 polish the numbers to get the numbers higher.
23 I mean, tomorrow they may come up with 24 something new. I don't know, you know. The preferred 25 stamping, that was another factor. That was not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 included in the previous application. So, we deal 2 with the things as they come along.
3 MR. HAMMER: I would expect our data -
4 you guys saw the TVA uniform data yesterday. I would 5 expect our data to be very similar to that in nature 6 once it's submitted.
7 MR. MANOLY: And you expect that there are 8 to be no modifications, right?
9 MR. HAMMER: At this point ln time there's 10 no modifications.
11 MR. MANOLY: Before you submit you should 12 really -
13 MR. WILLIAMS: I want to address that. We 14 have a dryer that's 37 years old. A dryer has minimal 15 flaws, four or five. It is a fairly, call it benwall 16 dryer. In other words, it has some flexibility to it 17 and the modifications associated with providing a 18 higher structure ratio are to stiffen it.
19 As we've looked at that on site, as we've 20 evaluated that the risk to doing the mod are higher 21 than the risks that it's going to solve. Or higher 22 than the results that we're going to have.
23 For example, as we looked at it it appears 24 that the actual welding that we'd have to do to the 25 steam dryer could put us at more risk. In other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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27 1 words, we could burn through a plate and we could end 2 up with a dryer that's in worse shape than we have 3 now.
4 So, as a company we've looked at that and 5 said that's not a risk that we want to pursue. So our 6 approach all along with our current dryer has been to 7 try and license it with no modifications. So that's 8 the process we're taking.
9 MR. MANOLY: Do you have a square dryer or 10 a slanted dryer?
11 MR. WILLIAMS: Square hood dryer.
12 MR. MANOLY: Square hood dryer. The 13 process original dryer?
14 MR. WILLIAMS: It's a smaller version of 15 the Quad Cities dryer, that's correct.
16 MR. BASARAVAJU: They have no corrugated 17 plates?
18 MR. WILLIAMS: No, that modification is no 19 longer available for steam dryers. It's been found 20 to have limited effectiveness.
21 So, let's get back to margins. When we 22 look at risks and margins for the facility what I 23 worry about and what my management worries about is 24 that by doing this modification we could actually 25 reduce our margins. This is a difficult modification NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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28 1 to make.
2 This piece of equipment has been in the 3 reactor for 37 years. It's contaminated, it's got 4 high dose rates. We'll have to do the work under 5 water. It's the kind of modification we're trying to 6 not do.
7 As a matter of fact, of all the options 8 we're looking at for EPU the modification of the dryer 9 is the one that we are not pursuing at all. If we 10 can't license this dryer we have to step back and 11 decide what other paths we want to take.
12 MR. MANOLY: So hopefully you're not in 13 the same boat as Susquehanna because they qualified 14 they tried to qualify the dryer and then finally they 15 realized after so many mods that it's not practical to 16 do it and they had to replace the dryer.
17 MR. WILLIAMS: We are looking at 18 contingencies if we get to the point where we feel we 19 can't license the dryer. Those contingencies are 20 being considered by senior management and we'll make 21 those decisions based on our discussions wi th the 22 staff.
23 (Whereupon, off the record from 9:42 a.m.
24 until 9:45 a.m.)
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29 1 our -- we will be doing the steam dryer analysis using 2 the BWRVrp-182 criteria. The CDr license and report 3 methodology. That methodology will be very similar to 4 what TVA is doing. We expect our data to be fairly 5 similar to the TVA Unit 1.
6 We're going to have very clear data with 7 reasonable noise signals on it. Fairly typical of 8 what you see. Right now the approach is very 9 consistent wi th what's been done by these uni ts in the 10 past.
11 The number of high stress locations right 12 now that exceed or don' t meet the 2.0 criteria is very 13 limited. Right now we expect to have to do the 14 substructure modeling we believe on about three 15 points.
16 What we are currently doing is based on 17 the new data that we got in start up from our October 18 outage is we are considering evaluating those high 19 stress locations with this new data and we believe the 20 new data might also result in us being able to improve 21 our stress margins so that all of that is still in 22 progress and it's still in validation at this point in 23 time. So 24 MR. MANOLY: You expect -- you're done 25 wi th all of the evaluations before you submit the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 application?
2 MR. HAMMER: Absolutely, we will not be 3 submitting until the final analysis is complete. And 4 as you are aware there's a lot going on with CDr right 5 now. TVA and Monticello and all, but right now we 6 still believe that that hopefully will all come 7 together on or about November 1st. So that's a 8 potentially doable target.
9 MR. MANOLY: Okay, is the structural 10 authori ty integrity doing poor or just on select 11 products?
12 MR. HAMMER: Structural integrity is doing 13 portions of the steam dryer analysis. They are doing 14 the sub-model evaluation. They are doing the flaw 15 evaluation for us, those types of things.
16 MR. MANOLY: We'll be included in that 17 report, right?
18 MR. HAMMER: Yes.
19 MR. BASARAVAJU: This October 2008 data, 20 is it going to be CLTP data or non-flow data?
21 MR. HAMMER: Both, what we did is we took 22 data at seven different power levels on start up from 23 the outage. And what we did there was we took Erc 24 data at every location also. So now we have a 25 complete set of data.
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31 1 MR. BASARAVAJU: So that can be used if 2 you need -
3 MR. HAMMER: That will be used to support 4 the final evaluation.
5 MR. MANOLY: So you shouldn't be really 6 thinking about replacing the dryer then.
7 MR. WILLIAMS: From a structural 8 standpoint, we believe the dryer we have will perform 9 to the limits that have been set.
10 Like every other piece of equipment in our 11 Plant we have to evaluate it's performance at the 12 higher power levels. Depending on what models are 13 used there may be some question about the new dryers 14 or the dryers ability to perform at 120 percent power.
15 MR. BASARAVAJU: Is it moisture carryover?
16 MR. WILLIAMS: Yes, moisture carryover is 17 the biggest issue. It is not a safety issue.
18 However, obviously we do not want to run a high 19 moisture carryover because it can impact the turbine.
20 It will impact dose rates in the long term to the 21 unit. And that's not something we want to do in the 22 long term.
23 So, we don't have the facts we need to 24 evaluate the performance. So all we can do is either 25 base it on a model which has again really no bench NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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32 1 marking basis or receive approval for the dryer and 2 then as you step up use actual performance data on the 3 dryer and then make our decision as to how well we're 4 going to do in the future.
5 What we do know is that there is no 6 modification that's available to eliminate this 7 moisture carryover problem.
8 MR. MANOLY: What's your current moisture 9 carryover?
10 MR. WILLIAMS: About .04 percent coming 11 out of the dryer.
12 MR. MANOLY: That's CLTP, right?
13 MR. WILLIAMS: Yes.
14 MR. MANOLY: And the set limit is .1?
15 MR. WILLIAMS: Our limit 1S .1.
16 MR. MANOLY: .1?
17 MR. WILLIAMS: Yes.
18 MR. HAMMER: That's the design value.
19 MR. MANOLY: So if you exceed that you're 20 going to have to do something?
21 MR. WILLIAMS: We're going to have to 22 either evaluate the limit or evaluate the performance 23 of the dryer and decide what other actions we need to 24 take and those decisions are not a project decision, 25 their a Plant and a Plant Manager safety decision.
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33 1 So, obviously there will be a few 2 different people involved in those discussions.
3 MR. HAMMER: And what you'll see in our 4 license amendment, for example from a dose 5 consequences standpoint, we used the bonding 6 assumption here. We assumed the carryover of up to .5 7 for the dosing analysis. So that's a pretty 8 conservative approach.
9 MR. BASARAVAJU: If you decide to replace, 10 what kind of dryer will you be using. Will it be the 11 cylinder type or a metal design?
12 MR. WILLIAMS: No, we are looking 13 obviously that's part of our contingency for the 14 project is to decide if we need to replace the dryer 15 what we're going to do. We're evaluating a number of 16 different dryer designs.
17 What we won't do is replace it with the 18 same design we have now because it doesn't get rid of 19 the problem. So, we have to have a newer design.
20 There are a number of manufacturers that can make a 21 steam dryer that will both meet the structural 22 requirements and the performance requirements.
23 So, we're evaluating all of those and 24 should we decide from a performance standpoint that 25 the dryer needs to be replaced we'll pick one of them NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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34 1 and go through Reg Guide 1.20 which would require 2 certain activities, not the least of which would be 3 instrumentation of the dryer.
4 MR. HAMMER: Any other questions?
5 MR. MANOLY: No, thank you.
6 MR. HAMMER: Okay, the next issue that we 7 want to discuss today is equipment qualification.
8 During the process where we withdrew the application 9 it was one of the issues that was discussed in those 10 letters.
11 Monticello has completed the environmental 12 qualification analysis required to support the Plant 13 operation and extended operation power uprate 14 conditions.
15 The resul ts show that two transmi t tal 16 applications are required for EPU implementation.
17 What we plan on doing as those transmitters with some 18 further work could be qualified to support EPU 19 operations. But in order to improve margins we are 20 going to improve, replace these and a number of other 21 older obsolete components to support the project.
22 MR. WILLIAMS: This is -- let me jump in.
23 As we talked about the beginning the project 24 principles, one of the big project principles is to 25 increase the margins of the facility.
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35 1 These two transmitters that we are saying 2 are "required by EPU" we feel pretty strongly that we 3 could do more detailed analysis and say they are okay.
4 But that doesn't meet our principle.
5 We can replace these transmitters which 6 are pretty old transmitters with new models which have 7 more margin and are more accurate. They meet their 8 project goal.
9 So rather than perform a bunch of analysis 10 just to say we don't have any. In the submi t tal 11 you're going to see we're going to say we have these 12 two transmitters but we're doing that to meet our 13 project principles. So you will see the completed 14 modification paperwork which is the discussion we had 15 during our EPU process.
16 But, I wanted to make sure you understood 17 the background as to why those two are going to be 18 listed in the submittal.
19 MR. HAMMER: The last bullet here 20 discusses the 10 CFR 50.49 qualification files. As 21 discussed in the call where we agreed to withdraw the 22 license amendment, the plans for completion of those 23 files will be prior to EPU implementation.
24 So, when we make the submittal those files 25 will still be outstanding. But they will be completed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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36 1 prior to implementing the EPU.
2 MR. PATEL: I have a question. This is 3 Nitin Patel. Do you know the model numbers of the 4 transmitters that you are replacing or -
5 MR. HAMMER: They're Rosemont 6 MR. PATEL: 153?
7 MR. HAMMER: I want to say they are 8 1139's. But I don't remember. They are fairly old.
9 They are really old.
10 MR. PATEL: Okay, now so do you have any 11 idea right now what are the temperatures variations 12 inside and outside the building?
13 MR. HAMMER: Yes, we have those and you'll 14 see that as part of the amendment. I guess we 15 submitted that as one of the questions that we came 16 about with the last acceptance review process.
17 Now one of the questions, we're going to 18 have to revise that letter a little bit based on the 19 results of ongoing work. We'll refine that analysis 20 based on some additional testing that was done in the 21 Plant.
22 We believe that that original question 23 from the NRC was aimed primarily at radiation. So 24 right now we were -- our current proposal is that we'd 25 just like to respond to the radiation aspects.
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37 1 But if you guys aren' t interested in 2 seeing the additional changes let me know, so.
3 MR. PATEL: You are to use the RAIs ln 4 future submittals. Let me clarify some aspects on the 5 EPI so it doesn't you know it might be able to 6 minimize generalities.
7 In the submittal we would like to know the 8 changes in the three EPU and of course -
9 MR. HAMMER: For all aspects?
10 MR. PATEL: for all aspects inside 11 company and outside company. We don't need all of the 12 calculations. I think you have been doing that. One 13 of the programs you're using marketing and temperature 14 curves.
15 But we'd like to have a comparison of the 16 curves, you know to reinforce the EPU the temperature 17 curves.
18 MR. HAMMER: You want to see the curves?
19 MR. PATEL: I want to see the curves.
20 MR. HAMMER: Not just the peak parameters?
21 MR. PATEL: Neither values for the peak 22 parameters, the peaks in the parameters and also the 23 curves, comparison of the curves, and your EQ 24 qualification cards. All the qualification cards to 25 demonstrate that most EPU parameters are still handled NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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38 1 by existing EPU programs and most of the equipment are 2 handled by existing EPU codes because we are 3 identifying the two transmitters that you want to 4 modify. And then also you can separate events and not 5 do any modifications.
6 MR. HAMMER: Well some of that, you know 7 might be of limited utility. For example, the 8 qualification curve the qualification curves in the 9 EQ files are in the past history, the new history and 10 what will end up happening is the 54 files might do 11 erroneous evaluations to be able to show that we still 12 meet qualification requirements.
13 And you know we can provide all of those 14 curves, but we can't provide that erroneous 15 qualification for example at this point in time.
16 We've got a basis for what we consider to be 17 acceptable.
18 Well, let me we'll consider that.
19 We'll see what we can find.
20 MR. PATEL: Well, the other thing is you 21 know since you demonstrate you know the forced EPU is 22 still handled by the EQ program.
23 If it falls out of the EQ profile then you 24 have to go for justification in the -
25 MR. BOZGA: Excuse me, this is NRC.
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39 1 MR. TAM: Hi, this is Peter Tam.
2 MR. BOZGA: Yes, Peter the line is 3 breaking up. Is there a reason why. I can't hear the 4 conversation. I apologize.
5 MR. TAM: Can you hear me. Can you hear 6 me?
7 MR. BOZGA: I can hear you clearly.
8 MR. TAM: Okay, I think our speakers were 9 not facing you.
10 MR. BOZGA: Okay.
11 MR. TAM: All right, we'll change that.
12 MR. BOZGA: rrhank you.
13 MR. TAM: Is this John Bozga?
14 MR. BOZGA: Yes, John Bozga, NRC Region 15 III power operate.
16 MR. TAM: Okay, who else?
17 MR. BOZGA: Just myself.
18 MR. TAM: All right, thank you John.
19 MR. BOZGA: Thank you Peter.
20 MR. PATEL: This is Nitin Patel from NRE 21 Electrical.
22 MR. BOZGA: Thank you.
23 MR. PATEL: The subject we are discussing 24 right now are equipment qualification.
25 MR. BOZGA: Okay.
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40 1 MR. PATEL: And I'm having a discussion 2 wi th licensee right now what we expect in their 3 submittal ln the AEP equipment qualification.
4 MR. BOZGA: Okay.
5 MR. PATEL: What we expect in the 6 submi ttal is the changes in the parameters. The 7 parameters itself, the change in the parameters.
8 For example, like temperature radiation 9 outside and inside containment and also the comparison 10 of the curves of the temperatures outside and inside 11 containment.
12 Second thing we expect in the submi ttal is 13 the -- any modifications of the equipment that they 14 are expecting or they are going to provide and also 15 the replacement if they are going to do any 16 replacement also equipment we need to know about it.
17 Like you have identified two transmi tter modifications 18 over here.
19 And if they are falling out of the 20 existing EQ program then also we would like to have 21 the explanation and justifications for those equipment 22 that are falling out of the existing EQ program and 23 how they are qualified for, you know their 40 years of 24 qualified life.
25 I f you're al so adding any equipment to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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41 1 existing EQ program then we would like l you know have 2 it identified in the submittal that these are the 3 equipment you/re adding and how you are planning to 4 qualify those equipment.
5 Sometimes what happens is you know some of 6 the areas are now becoming harsh because of the EPI.
7 And you might saYI well okay this transmitter l say for 8 example 854 is already in the EQ program and now we 9 are bringing this transmitter now it/s falling into 10 the EQ program and that transmitter is going to 11 qualify. We would like to have you upgrade the 12 transmitter for the EQ program.
13 For example I like if you are doing any 14 modifications on 845 Rosemont transmitter you are 15 changing that origin because it is EQ equipment every 16 ten years.
17 For here you haven t changed that but from I
18 the maintenance. So you might want to perform the 19 maintenance on that to being it to the EQ category.
20 MR. HAMMER: What we/ve got -- we have -
21 we/ve done that review. There are five cable types 22 that are being added to the EQ program. But they are 23 all cable types that already in the EQ program.
24 MR. PATEL: Okay.
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42 1 there are actually three cable types. So, we don't 2 expect to -- we need to revise our files or recognize 3 that these new cables are part of the EQ program. But 4 it doesn't constitute any new qualification reports or 5 anything like that.
6 MR. PATEL: Well the cables it might be 7 true. But what I'm saying is for example like 8 MR. HAMMER: And we reviewed, there is no 9 equipment. So in our case that's just these five 10 cables.
11 MR. PATEL: Okay, other thing if sometimes 12 you know, during the EPU you might -- the situation 13 might happen where you might be dropping some 14 equipment from the EQ list because they were there to 15 begin with not EQ equipment.
16 So, if you are going to drop some 17 equipment like that we would like to know, have the 18 fillet weld effect analysis on those equipment.
19 MR. HAMMER: We're not going to do that at 20 this point in time. That would be a great thing to do 21 and we'd love to do that. We just haven't had time to 22 do that.
23 MR. PATEL: And you know some of the 24 licenses done that and you know we would like to have 25 the fillet welds effect analysis on that.
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43 1 MR. HAMMER: Yes, we're not going to 2 we're don't plan to do that.
3 MR. PATEL: And at the time of the 4 submi t tal we would expect you to have a complete 5 analysis and your plan of replacement or re-qualifying 6 any equipment that's needed to be done.
7 MR. HAMMER: Yes.
8 MR. PATEL: So, do you have any questions 9 regarding EQ?
10 MR. WILLIAMS: That was completely 11 understood. Your last statement was completely 12 understood from our previous discussions.
13 MR. PATEL: Okay.
14 MR. WILLIAMS: And that's the point with 15 these two transmitters. The analysis obviously is 16 complete and the modification paperwork will be 17 complete. We'll implement those changes likely in the 18 2009 audit.
19 MR. HAMMER: The one difference here what 20 you're asking for compared to the previous amendment 21 acceptance review questions is you're asking for the 22 time history profiles. Those weren't provided 23 previously. We can do that.
24 MR. PATEL: Okay.
25 MR. HAMMER: But-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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44 1 MR. PATEL: I mean I don't need your 2 erroneous calculation on each and every equipment.
3 MR. HAMMER: Yes.
4 MR. PATEL: That's not the point I'm 5 making.
6 MR. HAMMER: You just want to see how 7 those compare -
8 MR. PATEL: To the existing EQ -
9 MR. HAMMER: -- to the EQ files, right.
10 MR. PATEL: And if they are falling out of 11 the EQ -- you know your EQ bonding profile then we'd 12 like to know some explanation and justification for 13 that.
14 MR. HAMMER: Sure, that's a fairly 15 substantial quantity of information and we'll have to 16 consider how to do that. That's a lot more 17 information than what we provided the last time 18 around.
19 We didn't provide all those timing 20 histories and all the EQ program profiles for example 21 the last time we were here, but we could do that. We 22 just provided the peaks. All we did was provide the 23 peaks.
24 MR. PATEL: Peaks and descents from the 25 numerical values?
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45 1 MR. HAMMER: Yes, we provided numerical 2 values for the peaks for all parameters in all areas.
3 MR. PATEL: That might be only half of the 4 curves probably in the areas that you might be have to 5 provide.
6 MR. HAMMER: I'll have to look at that.
7 Monticello typically did not qualify things to a 8 volume curve to cover the entire building for example.
9 MR. PATEL: Okay.
10 MR. HAMMER: We have -- my guess 1S we're 11 going to have a number of curves that are not -- I'll 12 have to look and determine exactly how much that is.
13 We'll have to figure that out and we'll see what we 14 can do to satisfy you.
15 MR. PATEL: We can have another conference 16 call if you guys need to discuss about that after you 17 come back.
18 MR. HAMMER: One of the other things we're 19 doing going forward on this proj ect now is we're going 20 to try and qualify many more things to involve a 21 profile that covers the reactor building.
22 MR. PATEL: Okay.
23 MR. HAMMER: But right now what's in there 24 is they've done a lot of work for what they call a 25 qualified each and every area. And they've got 85 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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46 1 areas. I'm a little concerned I might have to give 2 the 85 curves which I don't know if you want to see 3 that. But we'll run that kind of thing.
4 But we'll see what we can pull together 5 and if we need some more conversation we'll come and 6 talk to you.
7 MR. PATEL: Okay, that's about. Do you 8 have any questions regarding that EQ area?
9 MR. MANOLY: I just have -- going back to 10 -- I have one question. Are you going to submit the 11 power ascension test program and the limit curves and 12 application?
13 MR. HAMMER: We have the power ascension 14 test program. It's one of the enclosures of the limit 15 curves off the top of my head I don't remember exactly 16 if they are in the data at this point. I would have 17 to verify that.
18 MR. MANOLY: You should be able to.
19 MR. HAMMER: Yes, you should be able to do 20 that. All right -
21 MR. MATHEW: This is Roy Mathew. So 22 you're clear on what you have to do in the EQ area?
23 MR. HAMMER: Yes, I believe so.
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47 1 founded by what you're looking for is the basis.
2 I will make sure that what you're stating 3 in the license amendment we have verified it. So, the 4 curve the EPU condition and the EPU condition what are 5 one of the profiles you had to show us to demonstrate.
6 That's the bottom line.
7 MR. HAMMER: Some of the background to 8 grid stability. The first license amendment we were 9 unable to get the Midwest Independent System Operator 10 to allow us to have a grid stability analysis that was 11 complete through 2004 and megawatts thermal within the 12 time frames of the original submittal.
13 So at that point in time we were -- we had 14 a license condition that covered that eventuality.
15 MR. WILLIAMS: We actually submitted that 16 1,870 -
17 MR. HAMMER: Yes.
18 MR. WILLIAMS: wi th the intent of 19 resubmitting the 2004 once MISO was complete.
20 MR. HAMMER: And, we would not -- the 21 license amendment was based on not exceeding that 22 1,870 megawatt thermal power level until that final 23 MISO approval study had been completed.
24 At this point in time MISO has completed 25 the study for both stage one, which was the original NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 value ln 1,870 and they've also completed stage two 2 which is the full power uprate.
3 They have the stability analysis at this 4 point in time shows that there is no impact upon grid 5 stability at either power level. There are actually 6 no grid modifications or site modifications that are 7 required in order to support stability and MISO 8 performed that stability analysis with and without 9 capacitor banks.
10 So, the last bullet that we're talking 11 about here notes that in order to meet our 12 interconnection requirements wi th MISO we are required 13 to have a capability of providing a 0.95 lead and 14 lagging power factor.
15 And in order to satisfy that requirement 16 we will have to install capacitor banks in order to 17 meet that MISO requirement.
18 But, as noted the capacitor banks aren't 19 really required to verify or ensure grid stability.
20 So, at this point in time we are in process of 21 negotiating with MISO the final design on those 22 capaci tor banks and the final schedule for those 23 capacitor banks.
24 MR. WILLIAMS: And the location.
25 MR. HAMMER: And the location.
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49 1 MR. MATHEW: And so the grid analysis 2 isn't done then, the grid analysis. Okay, in the past 3 the thing that occurred you needed to change some of 4 the breakers. You don't need that anymore?
5 MR. HAMMER: What the previous analysis 6 that we -- we had a independent contractor that did a 7 grid stability analysis that was representative of 8 what we expected MISO to be able to do. And that 9 independent contractor was proj ecting that there might 10 be some modifications that were required.
11 But the final MISO analysis that we have 12 at this point in time does not identify any grid 13 modifications. So there are no grid changes.
14 MR. MATHEW: So there are no electrical 15 equipment that needs to be 16 MR. HAMMER: What you'll see in the 17 license amendment for offsite power. There's no 18 required modifications for grid stability. We will 19 note this capacitor bank to meet our leading leg and 20 power factor requirements with MISO.
21 The other thing that's happening as you go 22 through the license amendment you'll note that we are 23 replacing some of our 4.16, 4 kV buses in the site 138 24 kV switchgear and that factors into this type of 25 analysis because you know when we have to replace the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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50 1 1R transform and the 2R transform which are normal 2 offsite power sources and some of the switch gears.
3 So, the modifications that we've got are 4 aimed at providing the capability to provide a 5 reliable source of in house power for the new reactor 6 feed pumps primarily because we're increasing the 7 house load quite a bit.
8 So, it's really an improving margins, as 9 Al pointed out on the existing 4 kV switchgear. You 10 can't show adequate margins, wi th the new motors, wi th 11 the existing 4 kV switchgear. So we have to replace 12 those. So that's the only modifications we've done.
13 MR. PATEL: And that will be identified in 14 the submittal?
15 MR. HAMMER: They are identified in the 16 submittal, yes.
17 MR. PATEL: Okay.
18 MR. MATHEW: This switchgear analysis will 19 be provided to us or -
20 MR. HAMMER: Yes, we will provide an 21 enclosure 14 covers grid stabili ty and we will 22 provide essentially a new enclosure 14 that provides 23 this and I think we also will provide these.
24 MR. TAM: I'm curious, because in the 25 previous submittal we have problems. You were put on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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51 1 a cue saying that it would take so many years to 2 improve stage two. What happened because now you say 3 it's completed?
4 MR. HAMMER: I would -- I would say that 5 MISO stepped outside of the process for us.
6 MR. WILLIAMS: Well, let's go further.
7 MISO recognized that the process they had had a lot of 8 what they would call speculative empowering increasing 9 on the grid. There were a number of wind producers 10 that had gotten in the cue between the time we put in 11 our phase request and our phase two.
12 What MISO recognized is that most of those 13 were again speculative. So they applied to FERC to 14 make a change to their process which effectively 15 allowed them to do as Steve mentioned. It allowed 16 them to do our analysis out of their cue order because 17 they had verification if you will that we were going 18 to install the new capacity.
19 Obviously we need approval from the state 20 and from the NRC. But, we had a -- it wasn't a 21 speculative venture on our part. So they were allowed 22 to go outside. So that's what they did for us, is did 23 that, did our analysis outside of their normal cue 24 process.
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52 1 they stayed with the original cue process they were 2 potentially challenging grid reliability and 3 Monticello because they could not do reviews fast 4 enough in order to support the needed power generation 5 requirements that Monticello has.
6 MR. PATEL: Any bet on diesel generators?
7 MR. HAMMER: No, the diesel generator 8 loads are not changing. We're staying with the exact 9 same loads in the diesel genera tors. It's let's 10 assume at this point in time.
11 MR. PATEL: Any impact other than what you 12 have identified on any DC or AC systems?
13 MR. HAMMER: Well, we got in some problems 14 last time when we were all talking about DC systems 15 for example. The only impact on DC systems is really 16 the control logic for the 4 kV changes.
17 You know we've got DC power that feeds the 18 control logic switch operations and really operations 19 on the existing 4 kV buses. That will change when we 20 go to new 13 kV buses.
21 Our judgement is those loads should 22 decrease. They should drop wi th EPUs. So the DC 23 impacts are very, very minimal and probably bounded by 24 the current analysis.
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53 1 pointed out the existing 4 kV buses don't have enough 2 margins. So what we'll do is we'll have breakers and 3 we'll have much more significant volt interrupt 4 readings. We're very low on margins in that also.
5 And we're also talking about moving some 6 selected motor patrol centers around in the plant and 7 the goal of all of those changes is to improve the 8 margin of the in house distribution system so that we 9 have more margin on the existing in house distribution 10 system. Right now there is fairly tight margins in a 11 number of locations.
12 MR. PATEL: Okay.
13 MR. MATHEW: Okay so, number four 14 submittal, you will be submitting all of them in the 15 morning. One submittal, not like the two state -
16 MR. HAMMER: Yes, right we'll have one 17 submittal that covers total operations. There will be 18 no limits on that submittal at this point.
19 MR. PATEL: This is Nitin Patel. Regions, 20 are there any questions?
21 MR. BOZGA: No.
23 MR. BOZGA: No.
24 MR. PATEL: Okay.
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54 1 have -- another area that -
2 MR. PATEL: Thank you very much.
3 MR. HAMMER: that was part of the 4 acceptance review issues was the instrument setpoint 5 calculation methodology. Monticello employees and NRC 6 approved GE setpoint methodology.
7 Setpoints are calculated from the 8 analytical limit and margins are calculated between 9 the analytical limit and the allowable value, and 10 between the allowable value and the nominal setpoint.
11 MR. MAZUMDAR: Question, I am Subinoy 12 Mazumdar from Instrumentation and Controls. Now, you 13 have used the term margin. Margin normally means 14 added tolerance. We normally use the term tolerance.
15 So you mean here tolerance or accuracy?
16 (No response.)
17 MR. MAZUMDAR: Margin normally means extra 18 fat in the system. Not the current one.
19 MR. HAMMER: Maybe the easiest way to 20 respond to that is we did make a lot of these issues 21 were addressed at the same set of questions were 22 addressed for our PRM submittals. So, there is a 23 September 16, 2008 which RAI responds on the PRM 24 submittal and that provided a sample calculation that 25 showed our typical approach.
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55 1 MR. MAZUMDAR: We don't call it margin 2 there. We call it accuracies or tolerances.
3 MR. HAMMER: That's probably a more 4 correct -
5 MR. MAZUMDAR: Yes.
6 MR. WILLIAMS: From a project principle 7 statement I agree. If we're talking this instrument 8 setpoint calculation the margins we're referring to 9 are a little bit broader than what we're discussing 10 here.
11 MR. MAZUMDAR: Right, right.
12 MR. HAMMER: The AL/AV margin or 13 tolerance, probably I should point out that's probably 14 more of an appropriate term, includes measuring 15 accuracy, primary element to accuracy, instrument look 16 back or see the calibration errors.
17 The allowable value and nominal trip 18 setpoint tolerances include loop accuracy under 19 calibrated conditions, calibration errors and drift 20 errors.
21 MR. MAZUMDAR: In this case also some of 22 the tolerances you are repeating them in both the 23 cases. And I think from allowable value to nominal 24 trip setpoint the loop accuracy should not be there.
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56 1 got at this point in time -- I'm not necessarily an 2 expert in setpoint methodology, but this as I pointed 3 out as we are consistent with a GE setpoint 4 methodology program.
5 MR. MAZUMDAR: No, all right.
6 MR. HAMMER: Okay, next. In our extended 7 power uprate transmittal there's two setpoints that 8 are calculated that are associated wi th this response.
9 The analytical limit to nominal trip 10 setpoint one contains all errors and is equivalent to 11 the limited trip setpoint in RIS 2006-17. The nominal 12 trip setpoint two is calculated at 98 percent 13 confidence that the allowable value is not exceeded 14 during testing. And this is consistent with what was 15 provided with -
16 MR. MAZUMDAR: On that 90 percent we 17 normally insist on 95 percent.
18 MR. HAMMER: Okay, the final setpoint is 19 selected to satisfy both nominal trip setpoints one 20 and nominal trip setpoint two and is equivalent to the 21 nominal setpoint in RIS 2006-17.
22 Continuing on with the methodology.
23 Examples of as found and as left tolerances are 24 included in set calculations. As I mentioned one 25 example of the sample calculation was provided in our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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57 1 PRNM response from September 16th of this year.
2 And our intention right now is to use that 3 same example for most of the EPU -
4 MR. MAZUMDAR: Do you have that 5 calculation?
6 MR. HAMMER: We have that, yes we have 7 that.
8 MR. MAZUMDAR: I have not - - because Hukam 9 Garg was working on it before. I have not seen that 10 calculation.
11 MR. HAMMER: The MNG procedures require 12 shift manager determination of immediate applicabili ty 13 if an instrument is found to be out of tolerance. The 14 condition is entered into corrective action process.
15 MR. MAZUMDAR: When you say out of 16 tolerance which one you are talking about because 17 there are three numbers. As found tolerance, as left 18 tolerance, and the nominal values?
19 MR. HAMMER: We are not within as found 20 tolerance. The requirements of our program include 21 notification of management to consider the impacts of 22 that. And the shift manager will get involved with 23 that.
24 MR. MAZUMDAR: What about if you cannot 25 set it within there as left tolerance?
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58 1 MR. HAMMER: If you can't set it within 2 the as left tolerance some will set it. The 3 conditions entered into the corrective action process 4 of the as found tolerances exceeded and all setpoints 5 are reset to the nominal trip setpoint within the as 6 left tolerance calibration. The deviations with that 7 would be covered by the corrective action process with 8 the full operations.
9 MR. MAZUMDAR: You will go by writing out 10 this 493 is not approved. So we will not review 11 anything against that.
12 MR. HAMMER: Right.
13 MR. MAZUMDAR: But once that is approved 14 you will abide by that?
15 MR. HAMMER: Yes.
16 MR. WILLIAMS: And I can answer that. In 17 the past submittals, not just EPU, but in the past 18 submittals from Monticello we've said exactly that.
19 We recognized that the TSTF 493 is still under 20 negotiations.
21 We've added in the past a commitment that 22 says when it's approved we'll meet the conditions 23 associated with it.
24 MR. HAMMER: One thing that might actually 25 be helpful to us is you said you weren't aware of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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59 1 September 16, 2008 PRNM submittal.
2 The response to the questions from the 3 acceptance review from EPU are very largely to be 4 based on that submittal. We're going to point to that 5 submittal for essentially all of our responses.
6 What we will do is the evaluation of LSSS.
7 We'll be covered for EPU by itself. But all of the 8 other aspects and how we control within our process 9 and the sample cut we're going to point to that 10 previous submittal.
11 So it might be helpful to us if you would 12 take a look at that and then see if that meets your 13 requirement.
14 MR. MAZUMDAR: Hukam would look into.
15 Peter, Hukam has that one, right?
16 MR. TAM: Pardon me?
17 MR. MAZUMDAR: The September 16th 18 submittal.
19 MR. TAM: Yes, we have it.
20 MR. MAZUMDAR: Hukam has that?
21 MR. TAM: Huh?
22 MR. MAZUMDAR: Hukam has that. Hukam is 23 out, but you have it right. You don't know. Any way, 24 it has come and somebody in our branch will review it.
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60 1 reviewing it.
2 MR. MAZUMDAR: Okay.
3 MR. TAM: I just don't remember the name 4 of that person.
5 MR. H.AMlYIER: And you know, if you have any 6 issues with that type of stuff if you'll let us know 7 we'd appreciate it.
8 Okay, the last issue is changes to the 9 LAR. As we noted here we have three general issues 10 wi th the non-acceptance items. That was a steam 11 dryer, EQ, and insulation issues. Those are being 12 addressed in the revision of the LAR.
13 The acceptance of the review questions are 14 being docked. So the questions that we had during the 15 acceptance review process the last time around we are 16 capturing those in enclosure 16 we're pointing to 17 those as a means of addressing some of those issues at 18 this point in time.
19 The acceptance review questions that were 20 not docketed, which is the three open issues in EQ, 21 steam dryer, and the pi tista stuff, those are in 22 enclosure 17 and we'll provide a separate response for 23 those in enclosure 17.
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61 1 that in the acceptance review process is your standard 2 is that you'd like to see that all industry RAIs from 3 recent sites have been evaluated.
4 So, what we did is we didn't review Hope 5 Creek assessment RAI until we looked at actually four 6 si tes with the goal of trying to verify that the 7 submittal had enough detail ln it to be able to 8 respond to the questions that we raised at those 9 sites.
10 That resulted in US identifying 25 areas 11 that were enhanced to varying extents to address those 12 recent RAIs. So that is also one of the changes that 13 we're making.
14 The steam dryer submittal is being 15 enhanced. There was an enclosure in the previous 16 submittal that covered the steam dryer. That will be 17 updated to show the new steam dryer results and as we 18 pointed out in the grid stability summary there was 19 enclosure that discusses grid stability issues in the 20 last panel. That will be revised to reflect the 21 completion of the entire grid stabili ty study for this 22 license amendment.
23 So, that's the changes that we expect to 24 provide in the license amendment at this point. And 25 wi th that now I'd like to turn it back over to Al NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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62 1 Williams to discuss schedule.
2 MR. WILLIAMS: Okay, the NRC has seen a 3 revision of this schedule before. Listed up top are 4 the viewing outages that Monticello has. We're on a 5 two year cycle. The next outage is in March of 2009 6 followed by 2011.
7 As we discussed we'll be doing some set of 8 mods in the 2009 outage so that we can do a partial 9 implementation or partial power uprate during that 10 cycle. And we'll complete the modifications in 2011.
11 There is an independent submittal in with 12 the NRC. We've made reference to it. The power-range 13 nuclear monitoring submittal has been with the NRC 14 since February for review. We've asked for that for 15 implementation in 2009 to allow us to install that 16 during the outage.
17 It also shows the schedule that we've gone 18 through. In March we submitted a EPU at 1870 and then 19 withdrew. You see our proposed schedule for the EPU 20 evaluation of 2004. We are projecting approval of 21 that in early 2010 at which point we will -- once we 22 gain approval we will implement partially the extended 23 power uprate.
24 There is an additional submittal that will 25 likely be provided to the NRC after EPU approval.
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63 1 That's MELLA+, MELLA+ and DSS-CD. It is our intent to 2 submit that after EPU has been approved.
3 I would characterize that submittal as not 4 required for EPU, but rather to again provide us some 5 operating margins at the 120 percent power levels.
6 So, we do intend to submit power plus some time at the 7 end of the first quarter or the second quarter of 2010 8 and when that's -- we recognize that we will be the 9 first plant to show about a year review. We're hoping 10 that we can work with the staff to achieve that.
11 MR. ALEXION: A question on that slide.
12 The DSS-CD stability solution what good is that?
13 MR. WILLIAMS: I'm going to let Steve do 14 that.
15 MR. HAMMER: DSS-CD has it's a 16 different stability solution than the old PRN 17 solution. And what it is the way I would 18 understand is it's something of a enhancement to the 19 stabili ty solution three, the GE provisions. And they 20 haven't licensed that to this point in time.
21 But, right now GE's proposed if you're 22 going to implement MELLA+ then do that with DSS-CD.
23 MR. ALEXION: Does that like pick up where 24 option three resolved?
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64 1 replacement of option three. So it's -- and it's GE, 2 it's their direction for the future. It's the same 3 basic knowledge that their using wi th the PRNM system.
4 But it's kind of an enhancement to that module.
5 MR. ALEXION: Is that possibly a meeting 6 for the EPU?
7 MR. HAMMER: What we are doing right now, 8 we are replacing the PRNM system. If you go with the 9 PRNM system option three is the desired implementation 10 solution for having PRNM system installed.
11 Right now we are at option 1B print and 12 you know what since we're going and installing the 13 PRNM system GE's standard with PRNM is option three.
14 We could have stayed wi th the existing 15 PRNM as an option 1B but that would have required a 16 different set of modifications to the whole PRNM 17 system. So since our plan was to have that installed 18 in 2009 we're reflecting that system.
19 MR. ALEXION: That's currently under 20 review with the staff.
21 MR. HAMMER: That's currently under 22 review.
23 MR. ALEXION: If that was to happen -- if 24 that review was to be delayed would that effect the 25 EPU?
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65 1 MR. WILLIAMS: No, that's where we could 2 go to the other set of modifications. PRNM is not 3 required for EPU's, it's preferred.
4 We could implement a different set of 5 modifications to our existing components which would 6 allow us to join the committee. We do not want to go 7 that way for the simple reason that the PRNM system is 8 in reality a better system. So, that's our intent.
9 MR. HAMMER: Plus there are some major 10 issues with the PRNM system. This is a good change.
11 MR. MAZUMDAR: Could I ask one more. You 12 have any set limit except points?
13 MR. HAMMER: Do we have -- no, for EPU, no 14 our screen shows that we will not have safety limit.
15 MR. WILLIAMS: Any other questions on 16 that?
17 (No response. )
18 MR. WILLIAMS: The final slide in summary 19 we do intend to submit our license amendment request 20 early in November 2008. Our submittal target is 21 November 1st.
22 However, soon after setting November 1st 23 as the target I notice that it was a Saturday. So, 24 November 3rd will likely be the date that you see our 25 submittal.
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66 1 It does address specifically the prior 2 items that have been discussed between the industry 3 and the staff and you'll see that in a separate 4 enclosure in the LER. And also considers any response 5 to where they are applicable RAIs from previous EPU 6 submittals.
7 So, we believe we've addressed in 8 summary, we believe we've addressed the items in the 9 letter. We have addressed the RAIs.
10 There was a fairly small subset of items 11 that didn't get specifically addressed from previous 12 points and we've corrected the independent system 13 operator issue which was a significant discussion 14 topic between the staff and Monticello.
15 So, we believe you are going to see a 16 submittal that meets and responses to all the issues 17 we had in the previous one. So we're hopeful we can 18 work with the staff to get this approved and the time 19 frame has never been set by the processes. with that 20 I'll open it up to any questions.
21 MR. TAM: Let me ask the NRC staff, 22 whoever is in the meeting. Do any of you have a 23 caucus?
24 MR. MAZUMDAR: I don't have any.
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67 1 don't have too many of us left here. I think we have 2 communicated our messages.
3 As I said before we have a full transcript 4 and if you want us to clarify anything after the 5 meeting, after you look at the transcript you can call 6 us and we can hold some phone calls.
7 Understand we are very close to the 8 submi ttal date. But still if you can address anything 9 before you submit I think it will still be best.
10 MR. SALAMON: Did we miss anything in the 11 presentation. Any areas of concern?
12 MR. TAM: Hearing none we -- are you a 13 visitor or are you with -
14 MR. KOK: I'm from Structural Integrity, 15 I'm a contractor. I'm working for 16 MR. TAM: Oh, so you're working for them.
17 So you're with them, all right. So we don't really 18 have any observers of the meeting.
19 Before we adjourn the meeting I have the 20 usual NRC public meeting feedback form. So for those 21 who are interested please fill out the form and mail 22 it back.
23 For some reason the address, NRC address 24 is not complete. But you can see the NRC return 25 address and try to complete it at the bottom. All NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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68 1 right, or you can just give it to me.
2 Any seconds or any other things to say.
3 Region III, do you have anything to say?
4 MR. BOZGA: No, thank you Peter.
5 MR. TAM: All right.
6 MR. HAMMER: Thank you for all of your 7 time and consideration. We appreciate your feedback 8 and -
9 MR. TAM: I apologize for our physical 10 facility giving us all kinds of problems today. But, 11 we overcame it.
12 MR. WILLIAMS: Thank you all again.
13 MR. TAM: All right, so this meeting 1S 14 adjourned.
15 MR. BOZGA: Thank you.
16 (Whereupon, the meeting was adjourned at 17 10:35 a.m.)
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CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: Monticello Plant Name of Proceeding: Meeting with Northern States Power Company Docket Number: (n/a)
Location: Rockville, Maryland were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
=
Official Reporter Neal R. Gross & Co., Inc.
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