ML11298A225

Transcript of the ACRS Power Uprates (Nine Mile Point) Subcommittee Meeting, October 5, 2011 (Open) Pages 1-213

ML11298A225
Person / Time
Site:	Nine Mile Point
Issue date:	10/05/2011
From:	Advisory Committee on Reactor Safeguards
To:
References
NRC-1179
Download: ML11298A225 (213)

Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Advisory Committee on Reactor Safeguards Power Uprates Subcommittee Open Session Docket Number: (n/a)

Location: Rockville, Maryland Date: Wednesday, October 5, 2011 Work Order No.: NRC-1179 Pages 1-132 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +

4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +

7 POWER UPRATES SUBCOMMITTEE 8 + + + + +

9 OPEN SESSION 10 + + + + +

11 WEDNESDAY, OCTOBER 5, 2011 12 + + + + +

13 ROCKVILLE, MARYLAND 14 + + + + +

15 The Subcommittee met at the Nuclear 16 Regulatory Commission, Two White Flint North, Room 17 T2B1, 11545 Rockville Pike, at 8:30 a.m., J. Sam 18 Armijo, Chairman, presiding.

19 SUBCOMMITTEE MEMBERS:

20 J. SAM ARMIJO, Chairman 21 SAID ABDEL-KHALIK, Member 22 SANJOY BANERJEE, Member 23 JOY REMPE, Member 24 WILLIAM J. SHACK, Member 25 JOHN D. SIEBER, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

2 1 ACRS CONSULTANTS:

2 MARIO BONACA 3 GRAHAM WALLIS 4

5 DESIGNATED FEDERAL OFFICIAL:

6 PETER WEN 7

8 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

3 1 AGENDA 2 Opening Remarks . . . . . . . . . . . . . . . . . 4 3 Staff Opening Remarks . . . . . . . . . . . . . . 6 4 Introduction . . . . . . . . . . . . . . . . . . 7 5 NMPNS EPU Overview . . . . . . . . . . . . . . . 11 6 Reactor Thermal-Hydraulic Design . . . . . . . . 25 7 Long-Term Stability Solution Option . . . . . . . 69 8 Nuclear Design: Interim Methods . . . . . . . . . 82 9 Material, Mechanical/

10 Civil Engineering Topics 11 NMPNS . . . . . . . . . . . . . . . . . . . 86 12 NRR . . . . . . . . . . . . . . . . . . . 112 13 Steam Dryier . . . . . . . . . . . . . . 126 14 Adjourn . . . . . . . . . . . . . . . . . . . . . .

15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

4 1 P R O C E E D I N G S 2 8:28 a.m.

3 CHAIRMAN ARMIJO: Good morning. This is 4 a meeting of the Power Uprates Subcommittee. I'm Sam 5 Armijo, Chairman of this subcommittee. ACRS members 6 in attendance are Said Abdel Khalik, Bill Shack, Jack 7 Sieber and Joy Rempe. I saw Dick Skillman around, but 8 perhaps he's attending the other meeting. Dr. Sanjoy 9 Banerjee will not be able to attend the morning 10 session, but will attend this afternoon.

11 ACRS consultants are Dr. Mario Bonaca and 12 Professor Graham Wallis. Peter Wen is the Designated 13 Federal Official for this meeting. The purpose of 14 this meeting is to review the extended power uprate 15 request for Nine Mile Unit 2, the staff's draft 16 safety evaluation and associated documents.

17 You will hear presentations from the 18 Office of Nuclear Reactor regulation and the licensee, 19 Nine Mile Point Nuclear Station, LLC. As shown in the 20 agenda, some presentations will be closed in order to 21 discuss information that is proprietary to the 22 licensees and its contractors, pursuant to 5 U.S.C.

23 552(b), (c), (3) and (4). Attendance at this portion 24 of the meeting dealing with such information will be 25 limited to the NRC staff, licensee representatives, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

5 1 and its consultants and those individuals and 2 organizations who have entered into an appropriate 3 confidentiality agreement with them.

4 Consequently, we need to confirm that we 5 have only eligible observers and participants in the 6 room, and the closure of the public phone line for the 7 closed portion. The subcommittee will gather 8 information, analyze relevant issues and facts, and 9 formulate proposed positions and actions as 10 appropriate for deliberation by the full Committee.

11 The rules for participation in today's 12 meeting have been announced as part of the notice of 13 the meeting, previously published in the Federal 14 Register. We have received no written comments or 15 requests for time to make oral statements for members 16 of the public regarding today's meeting.

17 The transcript of the meeting is being 18 kept and will be made available, as stated, in the 19 Federal Register notice. Therefore, we request that 20 participants in this meeting use the microphones 21 located throughout the meeting room when addressing 22 the subcommittee. The participants should first 23 identify themselves and speak with sufficient clarity 24 and volume, so that they may be readily heard.

25 We have several people on the phone bridge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

6 1 lines listening to the discussion. To preclude 2 interruption of the meeting, the phone lines are 3 placed on listen in mode. We will now proceed with 4 the meeting, and I call on Ms. Louise Lunn of NRR to 5 introduce the presenters. Louise.

6 MS. LUND: Thank you, good morning. I'm 7 Louise Lund, the Deputy Director of the Division of 8 Operator Reactor Licensing in the Office of Nuclear 9 Reactor Regulation. I appreciate the opportunity to 10 brief the ACRS Power Uprate Subcommittee this morning.

11 In the interest of time, my opening remarks will be 12 brief.

13 At this meeting, the NRC staff present to 14 you the results of our very thorough safety and 15 technical review of the licensee's application. The 16 thoroughness of the review is supported by the fact 17 that we had several pre-application meetings with the 18 licensee, starting as early as September of 2008, in 19 which the licensee scheduled an overall proposed EPU 20 implementation plans were discussed with the NRC.

21 The NRC staff also performed an extensive 22 acceptance review before initiating our detailed 23 review of the application. We believe this helped 24 with the efficiency and effectiveness of our review.

25 During the course of our review, the staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

7 1 had frequent communications with the licensee, as well 2 as two audits and numerous conference calls to discuss 3 the EPU application and its supplemental responses to 4 several rounds of requests for additional information, 5 covering multiple technical disciplines.

6 Some of the more challenging review areas 7 that you'll hear about today include steam dryer 8 stress analysis, in which Nine Mile submitted its 9 revised acoustic circuit model, thermal hydraulic 10 stability analyses, interim methods, specifically the 11 applicability of GE methods to expanded operating 12 demands.

13 As presented in the draft safety 14 evaluation, which was provided to ACRS a month ago, 15 there are currently no open technical issues in the 16 NRC staff's review of the licensee proposed extended 17 power uprate application. We'd like to give our 18 thanks to the ACRS staff, who assisted us with the 19 preparations for this meeting, especially Peter 20 Yarsky.

21 At this point I'd like to turn over the 22 discussion to our NRR project manager, Rich Guzman, 23 who will introduce the discussions. Rich.

24 MR. GUZMAN: Good morning. My name is 25 Rich Guzman. I am the senior project manager in NRR, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

8 1 assigned to Nine Mile Point Nuclear Station. First 2 off, I'd like to apologize. I'm having some technical 3 difficulties in projecting the presentation onto the 4 screen. So at this time I'd ask that you use a hard 5 copy, the color copies that you have.

6 The first presentation is from the NRC 7 staff binder, which is titled "Opening Remarks."

8 During today's Subcommittee meeting, you will hear 9 presentations from the Nine Mile Point Nuclear Station 10 and the NRC staff. The objective is to provide you 11 with sufficient information related to the details of 12 the EP application, as well as the evaluation 13 supporting the staff's reasonable assurance 14 determination that public health and safety will not 15 be endangered during the operation of this proposed 16 EPU.

17 Before I cover the agenda items, I would 18 like to go over some background information really of 19 the staff review of the Nine Mile Point 2 EPU. On May 20 27th, 2009 -- well there you have my script --

21 (Laughter.)

22 MR. GUZMAN: All right.

23 CHAIRMAN ARMIJO: Just go ahead. Don't 24 worry about it.

25 MR. GUZMAN: All right. As you see there, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

9 1 on May 27th, 2009, the licensee submitted its license 2 request for Nine Mile Point 2 EPU. The increase would 3 be 34.67 megawatts thermal, their current license 4 thermal power, to 39.88 megawatt thermal. This would 5 represent a 15 percent increase from their current 6 license, and a 20 percent increase from their original 7 license thermal power.

8 The staff's method of review was based on 9 the RS 001, which is NRC's review plan for EPUs. As 10 you know, it provides a safety evaluation template, as 11 well as major C's that cover the multiple technical 12 areas that the staff is to review.

13 There are no associated or linked 14 licensing actions associated with this. Nine Mile 15 previously submitted, and the staff approved two 16 license amendments, mainly the maximum extended load 17 line limit analysis, and the AST amendment in 2007 and 18 2008, respectively. Finally, there were numerous 19 supplements to the application, responding to multiple 20 staff RAIs. Overall, there were approximately 25 21 supplemental responses, which supported our draft 22 safety evaluation.

23 The staff projects December 2011 to 24 complete our review, and this would be in support of 25 the licensee's scheduled implementation in the second NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

10 1 quarter of 2012.

2 The next slide on your hard copy binder 3 there covers the agenda items for the Subcommittee 4 meeting. The morning will cover the fuel methods and 5 the thermohydraulic design review areas, mainly the 6 anticipated transient without scram, and the stability 7 review. Then the afternoon will go into materials and 8 the mechanical and civil engineering review, which 9 will also include the steam dryer analysis.

10 11 Finally, at the conclusion of the meeting, 12 as needed, we can cover any open items in preparation 13 for a full Committee meeting. And also to note, there 14 will be closed sessions during the latter parts of 15 both the morning and afternoon sessions.

16 So if there's any proprietary information 17 that needs to be discussed, it can be deferred over to 18 the designated closed session for the agenda. This 19 concludes my presentation. I would like to now turn 20 the presentation over to the licensee, specifically 21 Mr. Sam Belcher, who is the Senior Vice President for 22 Operations for the Constellation Fleets.

23 And that said, I am going to eventually in 24 parallel, as you guys just need, talk to the slides 25 that is in your binder, I'll eventually get this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

11 1 posted on the wall. I apologize.

2 MR. BELCHER: Thank you. As mentioned, I 3 am Sam Belcher. I'm the Senior Vice President of 4 Operations for Constellation Energy Nuclear Group, and 5 I'll be walking through a presentation. I don't know 6 if it will make it up not the slide or not, but it is 7 in your binder and it's titled "ACRS Subcommittee 8 Presentation," and I'm on point 2, "Extended Power 9 Uprate, October 5th."

10 I'll be walking us through a very high 11 level overview, and then we'll get into more technical 12 details as we move through the morning and into the 13 afternoon. We'll start with an overview, followed by 14 a discussion on the plant modifications necessary for 15 the extended power uprate, anticipated transient with 16 scram and stability discussion, and then, as mentioned 17 the closed sessions for fuel methods, material 18 mechanical civil engineering topics, and then steam 19 dryer analysis also will be a closed session.

20 At a very high level, Nine Mile Point Unit 21 2 is a GE BWR 5, with a Mark II containment. Original 22 license thermal power was 33.23 megawatts thermal. In 23 1995, a stretch uprate was done of 104.3 percent, 24 which takes us to the existing license power limit of 25 34.67 megawatts thermal.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

12 1 This amendment would take us to 39.88 2 megawatts thermal, with the intention to implement 3 second quarter of next year. This is a constant 4 pressure power uprate. Additionally, Nine Mile Point 5 Unit 2 is not requesting any containment accident 6 pressure credit to support ECCS positive suction head.

7 I see some smiles there.

8 Also, no new fuel will be introduced as a 9 part of this uprate. The current core and the EPU 10 core will be GE 14 fuel consistently. Also, as 11 mentioned previously, alternate source term has 12 already been completed, and that was at the EPU power 13 level as the base assumption. Also previously 14 discussed is the maximum extended load line limit 15 analysis, expanded operating domain as well.

16 Finally, the New York state ISO has 17 reviewed and approved the full EPU power uprate, with 18 no grid modifications being necessary. The only 19 modifications that I would note were revenue metering 20 type modifications for the increased output. But 21 nothing for grid stability or anything along those 22 lines.

23 The first two phases of the EPU 24 modification have been completed, and then the third 25 and final phase of the modification will be completed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

13 1 in the second quarter of 2012, consistent with the 2 refueling outage. At this point, unless there are 3 some questions for me, I will turn it over to Dale 4 Goodney, who is our lead engineer, to talk in more 5 detail around some of the plant modifications required 6 moving forward.

7 MR. GOODNEY: Okay, good morning. As Sam 8 indicated, I'm Dale Goodney. I'm with Constellation 9 Energy and the EPU lead, engineering lead for the EPU 10 project. I'll provide an overview of EPU plant 11 modifications. We'll cover the general approach, the 12 review plant parameters and modification installation 13 time line.

14 We'll summarize the major plant 15 modifications and then we'll review other Nine Mile 2 16 plant improvements that are being implemented at the 17 station.

18 In support of the license amendment 19 request, a series of engineering studies were 20 performed to determine the plant's ability to operate 21 at EPU conditions, and to identify what modifications 22 may be needed. These studies were developed by a team 23 of Constellation engineers, industry consultants, GE 24 Hitachi for the nuclear steam supply system, and 25 Sargent & Lundy for balance of plant systems.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

14 1 These studies analyzed the effects of the 2 increase in steam flow, feedwater flow, electrical 3 power output and reactor power on various plant 4 systems and components. As Sam mentioned, this uprate 5 is not increasing reactor pressure. Therefore, the 6 evaluations were performed based on the methodologies 7 outlined in the past and pressure power uprate 8 licensing topical report.

9 The analyses were all based on the target 10 power level of 120 percent of the original license 11 thermal power. Each study included a review of 12 relevant operating experience, both internal and 13 external, and were applicable to results were 14 incorporated into these evaluations.

15 Another element of the engineering 16 evaluations were the margin reviews. Design and 17 operating margins were identified and evaluated for 18 both NSSS and balance of plant systems, to determine 19 if there would be adequate margin under EPU 20 conditions.

21 As a result of these reviews, over 20 22 physical plant modifications, mostly in the balance of 23 plant area were identified and described in the 24 license amendment request. The primary purpose of 25 these modifications are to (1) restore material NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

15 1 condition, (2) install instrumentation for data 2 collection and analysis, or (3) upgrade or replace 3 equipment to restore design and operating margins at 4 EPU conditions.

5 This next slide shows the fundamental 6 plant process parameters that would change due to the 7 uprate, and compares the EPU conditions to the CLPP 8 conditions. These parameters are the primary starting 9 point for the evaluations that I just described, and 10 they also form the key design inputs for the 11 modifications that were developed for the power 12 uprate.

13 The next slide is the modification 14 installation time line, and as mentioned in our 15 earlier slides, the Phase 1 and Phase 2 implementation 16 is completed. Those are the modifications shown in 17 the two left-hand columns. The remainder of the 18 modifications will be installed prior to the end of 19 the 2012 refueling outage.

20 On the next slide, or next few slides, 21 will summarize some of these modifications. It will 22 cover basically four general categories. Feedwater 23 and condensate, steam path, electrical I&C systems, 24 and auxiliary support systems.

25 DR. WALLIS: Can I ask you about the steam NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

16 1 dryer? This isn't the -- you know, GE has a new 2 design of steam dryer. That's not the one, right?

3 It's the old steam dryer, modified because the 4 analysis says you need to do so. So you're putting in 5 strengthening at various places and perforated plates 6 and so on?

7 So just to clarify, that's the old steam 8 dryer, strengthened because of the results of 9 analysis?

10 MR. GOODNEY: That's correct, and we'll be 11 covering those modifications --

12 (Simultaneous speaking.)

13 MR. GOODNEY: Due to the higher feedwater 14 flow requirements, the feedwater pumps will be 15 modified with new rotating elements, new step-up gears 16 and modified flow control valve trim. In addition, 17 the heater drain pumps in motors were replaced in 18 2010, to increase the capacity of the pumps. These 19 changes will provide the additional flow margin 20 required for normal, off normal and transient 21 conditions.

22 Reactor recirculation runback logic is 23 being modified to maintain scram avoidance margin 24 following a single feedwater pump trip. This will be 25 accomplished by initiating the runback immediately on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

17 1 a feedwater pump trip, increasing the runback rate of 2 the reactor recirc flow control valve, and -- the 3 higher feedwater pump runoff flow capacity.

4 In terms of the steam path, the high 5 pressure turbine we replaced with a monoblock rotor, 6 new diaphragms and buckets to increase the steam flow, 7 six relief valves located on the reheat piping will be 8 replaced with valves with a higher set pressures to 9 increase the steam relieving capacity.

10 Moisture separate reheaters on the fifth 11 and sixth point feedwater heaters, will be rerated to 12 higher pressures, and as you mentioned earlier, the 13 steam dryer will be modified to provide the required 14 structural margin at the higher steam flows, and we'll 15 provide more details of those modifications in the 16 afternoon session.

17 Two electrical modifications are needed to 18 support the higher power output. The isophase bus 19 duct will be upgraded by installing a higher capacity 20 cooling system, and the coolers on the main 21 transformers will be replaced with larger coolers, to 22 provide additional thermal margin.

23 Instrumentation affected by the uprate 24 include two tech spec instrument set points, the APRM 25 flow-biased scram, and the main steam high flow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

18 1 isolation. Those changes are included as part of the 2 license amendment request. The balance of plant 3 instrument loops are being rescaled, as required, to 4 accommodate the higher flows, temperatures and 5 pressures under EPU conditions.

6 Due to the high heat load in the turbine 7 building, the turbine building HVAC system will be 8 modified to install four additional area coolers near 9 the condensate and condensate booster pumps.

10 The turbine building cooling, although it 11 does have adequate margins for EPU conditions, it's 12 going to be modified to isolate retired loads to 13 provide additional margin, and the system will be 14 rebalanced to ensure that we get accurate cooling to 15 all the power-dependent loads supplied by the system.

16 So that completes the preview of the EPU 17 modifications.

18 CHAIRMAN ARMIJO: I have a question, not 19 about modifications, but many years ago, a number of 20 the BWRs had stress corrosion cracking problems in 21 their recirc piping, core repiping, and a number of 22 them did some replacements of the original type 304 23 stainless steel with an improved material, 316 nuclear 24 grade.

25 I didn't, don't remember. What did you do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

19 1 at Nine Mile 2? Are you still using the original 2 recirc piping?

3 MR. INCH: Yes, the original Unit 2 was, 4 went into service in '87, and the piping was 5 originally, you know --

6 CHAIRMAN ARMIJO: You'll have to speak a 7 little bit louder, so that the microphone --

8 MR. INCH: The piping at Unit 2 was 9 originally considered as upgraded piping. I believe 10 it's 316. I'll have to verify that.

11 CHAIRMAN ARMIJO: Yes, if you could. So 12 it was built at a time. By that time, people knew 13 this was a better way to build it, and you just 14 happened to be at the right place at the right time.

15 MR. INCH: It was a safe end replacement 16 prior to service, where they replaced the safe ends 17 with IGSCC-resistant materials. That was all done 18 prior to service.

19 CHAIRMAN ARMIJO: Okay, all right. Thank 20 you.

21 MEMBER SHACK: But just on that point, you 22 do have a number of Class D welds left.

23 MR. INCH: Yes.

24 MEMBER SHACK: At least there's a 25 discussion of that in the --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

20 1 MR. INCH: The Class D welds are the 2 similar metal welds, the safe end to nozzle welds. So 3 that is the --

4 MEMBER SHACK: But they're what, ferritic 5 to a normal carbon steel safe end? Is that --

6 MR. INCH: It's the stainless steel safe 7 end to the low alloy steel nozzle. It's the similar 8 metal weld, and that's the -- those are the category, 9 considered Category D welds, per 8801, Generic Letter 10 8801.

11 CHAIRMAN ARMIJO: And some of those you've 12 done a weld overlay, repair, mechanical stress 13 improvement?

14 MR. INCH: There was one indication on one 15 of the high pressure core spray lines, that a 16 mechanical stress improvement was done in the early 17 90's. We've been monitoring that since then, with no 18 growth.

19 It was an indication identified in one of 20 the feedwater nozzles, approximately ten years ago.

21 There was an overlay done on that. Otherwise, we're 22 not tracking any --

23 CHAIRMAN ARMIJO: So with the exception of 24 those two components, it's the as-built material?

25 MR. INCH: Yes.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

21 1 CHAIRMAN ARMIJO: Okay, thank you. And 2 when did you start the hydrogen water chemistry?

3 MR. INCH: Hydrogen water chemistry was 4 started in, it was either 2000 or 2001. We 5 implemented hydrogen water chemistry in combination 6 with noble metals. So it's always been a noble metals 7 hydrogen water chemistry application.

8 MEMBER SIEBER: I may have I missed it, 9 but in my review of the material that was included, 10 that Nine Mile Point 2 has a Mark II containment, 11 which is the upside down lightbulb or ice cream cone, 12 similar to the Mark I containments in containment 13 volume, but the geometry was different.

14 Did you analyze the containment 15 capability, insofar as you now have approximately 20 16 percent over the original design stored heat acumen 17 environment?

18 MR. INCH: Yes.

19 MEMBER SIEBER: And if so, did that 20 consider fuel failures, cladding oxidation and so 21 forth? How far did you go in that analysis?

22 MR. INCH: The design bases analyses were 23 redone for the higher megawatt thermal.

24 MEMBER SIEBER: Right.

25 MR. INCH: And decay heat levels, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

22 1 those were performed by GE, using their design bases 2 methods for the higher power levels, and mainly 3 because it's -- the peak pressure is governed by the 4 short-term blowdown, and because it's a constant 5 pressure power uprate, the peak pressure associated 6 with that blowdown has not changed.

7 MEMBER SIEBER: Right, that's true.

8 MR. INCH: And the long-term response --

9 MEMBER SIEBER: Has to be increased.

10 MR. INCH: Long-term response was 11 mitigated by the suppression pool cooling systems.

12 There's significant margin built into the original 13 design on those systems, that the original design 14 analyses had not credited. So by actually crediting 15 those systems capability, we were able to maintain the 16 suppression pool temperature effectively the same in 17 design bases space as current.

18 So there really wasn't any significant 19 change in the long-term pressure temperature profile 20 for the --

21 MEMBER SIEBER: Or change at all?

22 MR. INCH: Effectively, yes.

23 MEMBER SIEBER: I have to think about 24 that.

25 MEMBER SHACK: While we're at it, is this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

23 1 a vented Mark II? Is there a vent on this Mark II?

2 MR. GOODNEY: Phil.

3 MEMBER SIEBER: Has to be.

4 MR. AMWAY: My name is Phil Amway, and I'm 5 the extended power uprate operations lead, and I 6 maintain an active senior reactor operator's license 7 for the facility. Nine Mile Point 2 is able to vent 8 the containment through a path that will divert the 9 containment out directly to the stack, using a bypass 10 around the PTS train. We have that capability.

11 CHAIRMAN ARMIJO: You know, this is a 12 little bit off the scope, but you can't help it, 13 because of the Fukushima events. How do you test 14 those vents? Do you ever test them or that they --

15 MR. AMWAY: We have performed, and again, 16 my name is Phil Amway. We have performed walkdowns of 17 those procedures. We have procedures in place that 18 line up that vent path. All the materials are staged 19 to do so. We cover it in training. We have not 20 actually physically made the alignments, to actually 21 vent in that mode. But it is a fairly simple 22 mechanical arrangement that could be done.

23 CHAIRMAN ARMIJO: Is there a rupture disc 24 in that design or not?

25 MR. AMWAY: There is no rupture disc, no.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

24 1 DR. BONACA: So it's a duct. Is it the 2 hard piping or --

3 MR. AMWAY: It's hard piping. We actually 4 bypass around any duct work that would be subject to 5 the high pressure condition.

6 MR. BELCHER: If I may add, I'm Sam 7 Belcher, the Senior Vice President for Operations for 8 Constellation Energy Group. While we have processes 9 and procedures and training in place, based on the 10 recent events, we are looking in detail at 11 improvements, not only at the Nine Mile Point site, 12 but at our other sites as well.

13 I think there are lessons learned that 14 will ultimately lead to us doing things differently.

15 But we are looking at that.

16 CHAIRMAN ARMIJO: Okay, continue on.

17 MR. GOODNEY: No problem. This final 18 slide covers other plant improvements that the station 19 has implemented or is planning to implement, to 20 restore material condition, improve margin, improve 21 equipment reliability. Some examples are replacement 22 of the third point feedwater heaters in 2010; the 23 standby flow control relief valve margin was improved.

24 Cleaning tower upgrades were implemented.

25 New feedwater pump seals will be installed, according NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

25 1 to the feedwater pump modifications I mentioned 2 earlier. One of the more significant improvements, 3 the station plans to replace all 20 jet pump inlet 4 mixers during the 2012 refueling outage. That will 5 restore the equipment back to the original design 6 performance, restore core flow margin, and address 7 operating experience relative to flow-induced 8 vibration.

9 Then finally, there have been several PRA-10 related risk reduction improvements, consisting of 11 procedure changes and other minor modifications. As 12 a result of these improvements, since 2008, the core 13 damage frequency at Nine Mile Point has been reduced 14 by 78 percent.

15 So that concludes my presentation on 16 modification overview. Pending any questions, I'll 17 turn this over to Phil Amway, to discuss power 18 ascension testing.

19 MR. AMWAY: Thank you, Dale. Again, to 20 reiterate, my name is Phil Amway. I'm the extended 21 power operations lead. I'll be giving two 22 presentations this morning. The first area is for the 23 power ascension testing program. Under this topical 24 area, we'll discuss the preparation of the program, 25 approach to uprated power --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

26 1 MEMBER ABDEL-KHALIK: I'm sorry. Can we 2 go back to the previous slide?

3 MR. AMWAY: Sure.

4 MEMBER ABDEL-KHALIK: You indicated that 5 you will replace the jet pump inlet mixers?

6 MR. GOODNEY: That's correct.

7 MEMBER ABDEL-KHALIK: Could you explain 8 more of the rationale for that?

9 MR. GOODNEY: I apologize. Excuse me.

10 You'd like to know the rationale behind replacing the 11 jet pump inlet mixers, and whether that will impact 12 the core flow measurement instrumentation.

13 MR. INCH: Oh, the jet pumps become fouled 14 over years of operation, from a mechanism that I don't 15 fully understand. But they call it a zeta potential, 16 where you get deposits that affect the efficiency of 17 the jet pumps. At Nine Mile, that's been occurring 18 for several years.

19 There's several options available. Ultra 20 high pressure cleaning is an option that was 21 considered, and but there's essentially the new mixers 22 we're putting in are identical to the original design.

23 So it restores the jet pumps to a new condition, and 24 so that's what is going on.

25 So therefore, the instrumentation is not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

27 1 affected. It just basically restores the performance 2 to the original performance.

3 MEMBER ABDEL-KHALIK: But the relation 4 between the driver flow, the jet pumps and the actual 5 core flow will change as a result of that 6 modification; is that correct?

7 MR. INCH: It will be restored to the 8 design bases, drive flow design basis and ratio, but 9 it's not a change to the design. So operational 10 procedures, every refuel outage, do a new baseline for 11 where those jet pumps are, to establish the 12 correlation between dry flow and core flow.

13 Then that's put into the instrumentation, 14 and it's all proceduralized, because it does change 15 over time. So the procedures account for that change.

16 MEMBER ABDEL-KHALIK: So that when the 17 operators, the current procedures for knowing where 18 they are on the power flow map, they use the driver 19 flow or they use the direct total core flow, as 20 measured from the 20 jet pumps?

21 MR. INCH: Operations has core flow.

22 Phil.

23 MR. AMWAY: We use total core flow direct 24 indication.

25 MR. INCH: When we plot our --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

28 1 MR. AMWAY: Yes.

2 MEMBER ABDEL-KHALIK: But in that process, 3 you use the relationship between the driver flow and 4 the core flow, which you say you empirically calibrate 5 every outage?

6 MR. INCH: Yes.

7 MR. AMWAY: Every outage, and it's part of 8 our start-up test program as well. We will do the 9 core flow calibration, which will calibrate the dry 10 flow to the jet pump flow.

11 MEMBER ABDEL-KHALIK: How much has that 12 calibration changed since the jet pump inlet mixers 13 were replaced? Oh, you have no idea.

14 (Simultaneous speaking.)

15 MEMBER ABDEL-KHALIK: How much has that 16 changed over the years, as a result of fouling?

17 MR. AMWAY: It has changed gradually over 18 the years. It's actually a reactor engineering 19 procedure. It's done at the conclusion of each 20 outage, once we get the full rated power. We'll do 21 that procedure and the trend has been, the acceptance 22 criteria of that procedure is as long as the 23 calibration is within two percent, no additional 24 action is required.

25 It's about every third outage we actually NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

29 1 have to go in and make a change, and adjust the gains 2 on the dry flow to match the core flow.

3 MEMBER ABDEL-KHALIK: So the allowable 4 deviation between the two flow indications is two 5 percent you said?

6 MR. AMWAY: Two percent.

7 MEMBER REMPE: Do you expect the new 8 plants that you're replacing to have similar fouling 9 characteristics?

10 MR. INCH: The new mixers, we hope to be 11 able to manage the fouling a little bit better. The 12 plan is to they'll have a coating on them, that will 13 resist fouling. It's not 100 percent, but it should 14 reduce the rate of fouling.

15 MEMBER SHACK: What is this magic coating?

16 MR. INCH: That's proprietary. I can't --

17 we can talk about that in closed session, I guess.

18 MEMBER SHACK: Yes.

19 CHAIRMAN ARMIJO: You may want to do that.

20 MEMBER SHACK: But otherwise its geometry 21 is identical, with the exception of a coating to 22 surface treatment of some sort, to minimize the 23 fouling rate.

24 MR. INCH: To try and minimize future 25 fouling, yes, right.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

30 1 MEMBER ABDEL-KHALIK: But generally th 2 trend is that the actual core flow will likely be less 3 than the indicated core flow. Is that the -- or is it 4 the other way around?

5 MR. INCH: Right now, the design M ration 6 for the jet pump mixers is -- at EPU, it will be about 7 2.28.

8 MEMBER ABDEL-KHALIK: No, no, no. I'm 9 asking about the effect of fouling, and you're 10 allowing a two percent deviation between or two 11 percent variation on the calibration, in the empirical 12 calibration between driver flow and actual core flow.

13 MR. INCH: I believe what Phil's referring 14 to is just the instrumentation tolerances --

15 MEMBER ABDEL-KHALIK: That's right.

16 MR. INCH: That are built into the design 17 bases. The fouling occurs over very long periods of 18 time, over many years in the cycle.

19 It's a very gradual process, and the 20 frequency for the calibrations will maintain and 21 ensure that the relationship between dry flow and core 22 flow is accurate to within the design tolerances at 23 all times. But it's not something that occurs 24 suddenly. I'm not sure if I'm --

25 MEMBER ABDEL-KHALIK: I'm just trying to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

31 1 understand the direction of the trend.

2 MR. INCH: Okay.

3 MEMBER ABDEL-KHALIK: Okay, and the time 4 line associated with that trend. You say that you 5 need to do that roughly every third outage?

6 MR. AMWAY: About every third cycle. We 7 actually have enough mismatch between the two 8 measurements that we actually adjust the gains of the 9 dry flow.

10 MEMBER ABDEL-KHALIK: So that sort of 11 gives you an indication of how quickly the core flow 12 is being impacted as a result of fouling? Or is it 13 just drift?

14 MR. AMWAY: It's just looking at the total 15 -- I mean some of that could be drift, some of that 16 could be fouling. I'm just looking at the total 17 measurements of drive to driven flow when we do that 18 procedure. It's not really looking at specific 19 factors that may input to that deviation of two 20 percent.

21 MR. INCH: I can give you a feel for some 22 of the numbers. The original, when we first started 23 the plant up in '87, the original calibration for dry 24 flow was approximately 41,000 GPM for a rated core 25 flow, which is 108-1/2, 108-1/2 million pounds per NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

32 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. That's the relationship. So M ratio, drive to 2 driven of approximately 2.4 or 2.5, I believe, at 3 OLTP.

4 Now, for to achieve 108, the rated core 5 flow, 108 million, we need 46,000 GPM drive flow, and 6 that's occurred over 22 years. That's the -- it's a 7 gradual change. It is affected by the stretch uprate 8 in effect. When we did the stretch uprate in 1995, 9 that was the original design, five percent uprate.

10 Then fuel type has some effect on it. C 11 Core DP has some effect on it. So as the, you get 12 some of the newer fuel design, you have a higher two 13 phase pressure drop. So that, the jet pumps have to 14 work a little bit harder. So that's in the mix with 15 some of those relationship changes.

16 CHAIRMAN ARMIJO: So do you expect the 17 fouling rate to be greater with the higher flows at 18 EPU?

19 MR. INCH: Again, our flows are really not 20 higher. They're the design flows. So the fouling 21 rates really shouldn't change from what it's been 22 historically. The change for power uprate, changes to 23 the core DP are slightly. So we need basically it's 24 a 1.9 percent effect on the dry flow relationship.

25 MEMBER ABDEL-KHALIK: But if the fouling NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

33 1 is some sort of a deposition of some, let's say an 2 iron oxide or some other material on those mixers, 3 you're putting a lot more water with all that same 4 material through, over a given period of time. So I 5 would expect the fouling to be faster.

6 MR. INCH: It's important that -- we're 7 really not putting any more -- the core flow stays the 8 same, and the dry flow really is the same. Now what 9 we're doing is put it back to the original core 10 relationship and efficiency of the jet pump. So the 11 rate of fouling should be equivalent.

12 MEMBER SHACK: And with your magic 13 coating, less.

14 MR. INCH: Well, hopefully yes.

15 CHAIRMAN ARMIJO: Okay.

16 DR. BONACA: Just one question I had 17 regarding the vent. Do you have that venting 18 procedures?

19 MR. AMWAY: Yes, we do have venting 20 procedures. It's part of our emergency operating 21 procedures, support procedures. But we do have those 22 in place.

23 DR. BONACA: All right, thank you.

24 MR. AMWAY: All right. If I may continue 25 on under power ascension testing, I'm on Slide 17.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

34 1 The topical areas that I want to address under power 2 sensitive testing are preparation, approach, schedule, 3 the test plan and the acceptance criteria and actions.

4 Under the preparations, our objective of 5 the start-up test program is to demonstrate 6 satisfactory equipment performance, ensure we have a 7 careful, monitored approach to EPU power level, and to 8 ensure that we meet established requirements.

9 We define the roles and responsibilities 10 in the master start-up test procedure. We have used 11 industry benchmarking to confirm that our test program 12 matches similarly uprated BWRs, and also that our test 13 plan and implementing test procedure development is 14 consistent with industry standards.

15 We will also perform operator training on 16 the power ascension test program, including the test 17 procedures that will be performed. The approach is 18 similar to that used for other BWRs that have 19 implemented extended power uprate, and that is 20 incremental testing approach. We collect baseline 21 data at 75, 90, 95 and 100 percent of current licensed 22 thermal power.

23 Once we rise above the 100 percent current 24 licensed thermal power, we will perform data 25 acquisition and incremental steps of one percent, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

35 1 an analysis of two and a half percent. Every five 2 percent plateau is a major testing window that 3 includes the active as well as the passive testing, 4 and there is an NRC data review with those five 5 percent incremental levels.

6 DR. WALLIS: And in doing this, you have 7 instrumented the steam lines? They go and look at the 8 fluctuations and that sort of thing.

9 MR. AMWAY: That is correct. That's part 10 of the ascension program. Power ascension testing 11 approach for Nine Mile 2 does not include large 12 transient testing. The basis for that is the 13 substantial industry operating experience from uprated 14 plants that have experienced large transient post-EPU 15 implementation, and also Nine Mile Point specific data 16 for large transients that have occurred at the station 17 at 104.3, which is the uprate, stretch uprate power 18 level.

19 We were able to use that data to 20 accurately project, using the analytical methods that 21 are available today, such that we fully understand how 22 the plant will respond post-uprate for large 23 transients.

24 MEMBER ABDEL-KHALIK: If you'll go back 25 again to the previous slide, please.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

36 1 MR. AMWAY: Sure.

2 MEMBER ABDEL-KHALIK: Have you had any 3 experience with the SRV leaks?

4 MR. AMWAY: With SRV leaks, and I may ask 5 George to provide additional information here, but 6 recently our SRV leakage has been very good.

7 We had problems, I'll say in the mid-90's, 8 with SRV leakage that was indicated by rising 9 suppression pool temperatures, and the frequency at 10 which we had to place suppression pool cooling in 11 service, to maintain pool temperatures just at normal 12 power.

13 That has not been the experience that I've 14 seen in the power plant for the last 10-12 years, and 15 I would say that we're not seeing it in tail pipe 16 temperatures, or the suppression pool temperatures.

17 George, do you have anything additional to add to 18 that?

19 MR. INCH: No. I might add that when we 20 stopped doing the steam flow surveillance tests, 21 actually opening the SRVs and closing them, which 22 challenges the receding, the SRV leakage has gone away 23 as a problem. So it's been very effective.

24 MEMBER ABDEL-KHALIK: And post-outage 25 testing of the SRVs, they meet the specs, as far as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

37 1 set point?

2 MR. INCH: Oh yes. I'm not prepared right 3 now to go into any of those details, but yes. They 4 change them out in accordance with a rotation plan.

5 They are tested at offsite. I believe they're sent 6 offsite and tested each outage. If you need more 7 details, I would have to come back.

8 MEMBER ABDEL-KHALIK: I'm just trying to 9 get just step by step here. So this emphasis on 10 instrumentation is in primarily during the power 11 upgrade, is in primarily concerns with regard to the 12 steam dryers.

13 MR. AMWAY: It's primarily with the steam 14 dryer, but it also includes balance of plant piping, 15 because of the increased steam flows and feed flows, 16 and we will be monitoring that vibration in those same 17 increments on the way out.

18 MEMBER ABDEL-KHALIK: Is there any concern 19 about increased leakage from the SRVs, as a result of 20 the increased steam flow, and the potential acoustic 21 coupling associated with the SRVs?

22 MR. INCH: No. We've looked at that 23 fairly significantly with our instrumenting. The main 24 steam lines with accelerometers in the vicinity of 25 SRVs, to make sure that there's no coupling.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

38 1 Analytically, we're not seeing any, haven't seen and 2 are not predicting to see any issues with this --

3 MEMBER ABDEL-KHALIK: How would your 4 instrumentation tell you whether or not you have 5 increased leakage out of the SRVs, as a result of the 6 --

7 MR. INCH: Well have, there's tailpipe 8 instrumentation to tell us if it's leaking. They 9 know.

10 MR. AMWAY: That's correct.

11 CHAIRMAN ARMIJO: And you have what kind 12 of measurement?

13 MR. AMWAY: It's a temperature 14 measurement, right on the tailpiping.

15 MEMBER ABDEL-KHALIK: Do you have a two-16 stage or a three-stage SRV?

17 MR. GOODNEY: Are you referring to Target 18 Rock?

19 MEMBER ABDEL-KHALIK: Right.

20 MR. GOODNEY: No, we don't have Target 21 Rock.

22 MEMBER ABDEL-KHALIK: You don't have 23 Target Rock. So what kind of SRVs do you have?

24 MR. INCH: They're Dikkers.

25 MR. GOODNEY: Dikkers.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

39 1 MEMBER ABDEL-KHALIK: And they're 2 instrumented only by measuring temperature in the 3 tailpipe?

4 MR. INCH: I believe so. I would have to 5 verify that.

6 MEMBER ABDEL-KHALIK: Okay.

7 MR. AMWAY: As far as what we see in the 8 control room, the temperature is our primary 9 indicator, the tailpipe temperature. You know, 10 they're also fitted with acoustic monitors that would 11 tell you to actually lift it.

12 MR. INCH: That's what I think, yes.

13 MR. AMWAY: But for the leaking, it's just 14 the thermocouples on the tailpipe.

15 MEMBER ABDEL-KHALIK: All right, thank 16 you.

17 MR. AMWAY: You're welcome. I'm up to 18 Slide 21 now, the power ascension testing schedule.

19 Data collection in one percent intervals, data 20 evaluation, two and a half percent intervals, and then 21 the major testing plateaus at five percent intervals.

22 That five percent test plateau includes 23 passive data collection, which includes the vibration 24 monitoring, radiation monitoring and plant parameter 25 monitoring. The active testing is associated with the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

40 1 stability of the various pressure control and 2 feedwater level control systems.

3 We will perform data analysis of both the 4 active and passive testing, and then that data will be 5 reviewed by station management through the Plant 6 Operations Review Committee, and then submitted to the 7 NRC for review.

8 This next slide just shows an overview of 9 the various tests that are performed at the power 10 levels. Across the top of the slide, you'll see the 11 percent for current license thermal power, and the 12 intervals that we're doing the testing. Those power 13 levels in red, that are red highlighted, are those 14 associated with the five percent test plateaus at 15 which data will be transmitted to the NRC for review.

16 Then all the X's in the box along the left 17 column, you see the various tests that are performed, 18 and the X's designate how often they're performed, at 19 what power levels. Those indicated in the blue 20 shading are those that also have one percent data 21 collection requirements.

22 For power ascension testing acceptance 23 criteria, there's two major levels. The Level 1 24 acceptance criteria is associated with a limit 25 associated with plant safety.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

41 1 If we reach a Level 1 criteria, we abort 2 from the test. We reduce power level to a known safe 3 condition, and that would be the power level at which 4 the Level 1 criterion was verified met, and that we 5 will use our corrective action program to evaluate the 6 condition and determine required actions. Then we 7 will repeat the testing, to verify Level 1 criterion 8 is satisfied and document results.

9 Level 2 is the limit associated with plant 10 or equipment performance that does not meet design 11 expectations, but is not immediately adverse to plant 12 safety. We will perform similar actions, in the terms 13 of we will place the test on hold, and if needed, 14 lower power, and then again use the corrective action 15 program to determine the requirements.

16 In the Level 2, we may make a 17 determination that the data is satisfactory and that 18 we can continue testing. In either event, we will 19 have to also document the results as a test exception.

20 The final acceptance criterion that we may encounter 21 following the start-up program includes things such as 22 technical specification required surveillance tests.

23 They have their own acceptance criteria, 24 based on tech spec limits, and if we reach one of 25 those limits, we would follow the actions in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

42 1 procedures and the plant technical specifications.

2 MEMBER ABDEL-KHALIK: Can you give me an 3 example of a Level 2 acceptance criterion, and an 4 example of a Level 1 acceptance criterion that you can 5 immediately indicate with a test?

6 MR. AMWAY: Yes, I can. For a Level 1, 7 for the control systems which are tuned, we will 8 introduce step changes, for example, reactor pressure.

9 We would expect that the system will respond in a 10 quarter wave damping fashion, so that any oscillation 11 is quickly dampened, then maintain steady control of 12 the plant pressure.

13 If for some reason that we don't meet the 14 quarter wave damping, but the oscillations are 15 convergent, such that you reach a final steady value 16 and pressure, that would be an example of not meeting 17 Level 2. It doesn't meet the design expectation, that 18 we should be able to meet the quarter wave damping.

19 If we did that same step change, and we 20 got a divergent behavior in the oscillations, which 21 means they did not dampen out and in fact got worse, 22 then we would have actions in the procedure for how to 23 deal with that. That would be a Level 1 criterion, 24 and we would abort that test, to figure out why that 25 happened.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

43 1 MEMBER ABDEL-KHALIK: Okay.

2 DR. WALLIS: Are these limit curves 3 evaluated directly by computer, or does someone have 4 to look at this and look at that, and compare them?

5 MR. AMWAY: We will have both guidance in 6 the procedure for what the operators can look at 7 directly by plant instrumentation. But there will 8 also be backup confirmatory database reviews of the 9 parameters using computers.

10 DR. WALLIS: So there will be something 11 set in place, so that when something unusual happens, 12 it's right there on the computer or there's a warning 13 or something?

14 MR. AMWAY: That is correct.

15 DR. WALLIS: You don't have to wait for 16 someone to look at something?

17 MR. AMWAY: That's exactly right. If 18 there's no further questions on the power ascension 19 test program, I'd like to proceed on to the long-term 20 stability, Option 3.

21 In this topical area, I'll discuss an NRR 22 audit that was performed at Nine Mile 2 in support of 23 our uprate. We'll discuss long term stability, Option 24 3, and under that topical area, we'll discuss the 25 oscillation power range neutron monitor that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

44 1 installed at Nine Mile 2, the OPRM settings, the 2 backup stability protection.

3 We'll discuss the 2003 Nine Mile Point 4 stability event, and conclude with the effects of 5 extended power uprate on long-term stability solution.

6 Under the ATWS stability, we'll discuss the Unit 2-7 specific ATWS mitigation design features, preparation 8 for the simulator demonstration that was done in 9 support of the NRR audit.

10 We'll discuss the MSIV closure with 11 failure to scram and turbine trip with failure to 12 scram events, and then we'll address the conclusions 13 associated with ATWS stability.

14 NRR audit was performed at Nine Mile 2 in 15 October of 2009. The purpose of that audit was to 16 demonstrate procedure actions and operator response to 17 ATWS transience, that EPU conditions conform to 18 regulatory requirements.

19 The audit reviewed implementation of long-20 term stability, Option 3, and it also observed 21 operator performance in the plant reference simulator 22 for the two events I discussed, the MISV (ph) closure 23 and turbine trips with failure to scram.

24 The audit included a review of related 25 procedures and mitigation strategies, and that audit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

45 1 also concluded in 2009 the simulator was not ready yet 2 to show comparison data for EPU versus current license 3 thermal power data. That has since been completed and 4 provided to the NRC.

5 In terms of a time line for the 6 oscillation power range monitor, in 1998, Nine Mile 2 7 received Amendment No. 80, which allowed the 8 installation of the system, and it ran in the unarmed 9 condition while we evaluated the performance of the 10 simulator and performed tuning, to make sure that it 11 was set up for the Nine Mile 2-specific application.

12 In 2000, we received Amendment 92, which 13 armed the system, to make the OPRM trips active. In 14 2002, we implemented a plant-specific DIVOM curve, as 15 a result of GE Safety Communication 01-01. In 2003, 16 we implemented further changes to filter frequency and 17 period tolerance setting for GE Safety Communication 18 03-20, and that was as it related to the Nine Mile 19 Point 2003 event.

20 For the OPRM settings, we have cycle-21 specific DIVOM analysis performed using a TRACG 22 methodology. The cycle-specific amplitude set points 23 are defined in the core operating limits report, and 24 for extended power uprate, we have reduced the enabled 25 region from 30 percent of rated thermal power to 26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

46 1 percent of rated thermal power, and that's to maintain 2 the level of protection the same for extended power 3 uprate, as it is for current license thermal power.

4 For backup stability protection, the 5 backup stability protection regions are determined 6 using cycle-specific ODYSY decay ratio calculations, 7 and the regions are defined on the plant's power to 8 flow operating maps. The backup stability protection 9 actions are defined in plant procedures, with routine 10 reinforcement in the operator training program, and 11 the BSP exit regions --

12 MEMBER ABDEL-KHALIK: So if you'll back to 13 the pervious slide, please.

14 MR. AMWAY: Sure.

15 MEMBER ABDEL-KHALIK: The set point for 16 recirculation dry flow less than 60 percent. This two 17 percent uncertainty between the dry flow, in the 18 calibration between dry flow and actual core flow.

19 Which direction does that normally go? Does it push 20 you inside the exclusion zone, or outside the 21 exclusion zone?

22 MR. AMWAY: The way we actually have our 23 procedures set up is we implement the enabled region 24 at 62 percent. So it's active up to 62 percent core 25 flow, which gives us margin to the 60 percent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

47 1 requirement.

2 MEMBER ABDEL-KHALIK: So even if there was 3 --

4 MR. AMWAY: So even if it was in a non-5 conservative direction, we're still bounded the way we 6 set the system parameters.

7 MEMBER ABDEL-KHALIK: By the way you set 8 it up?

9 MR. AMWAY: That's correct.

10 MEMBER ABDEL-KHALIK: Okay, thank you.

11 MR. AMWAY: On Slide 32, I discuss the 12 2003 stability event. That event was initiated by a 13 component failure that resulted in a high to low speed 14 transfer of both reactor recirculation pumps. In that 15 event, the period-based detection algorithm initiated 16 an automatic scram, because of core-wide oscillations.

17 The reactor in the post-trip event review, 18 we determined that the reactor was properly tripped by 19 the period-based detection algorithm. However, we did 20 see some unexpected confirmation count resets prior to 21 the scram.

22 The post-review analysis determined that 23 two parameter settings needed to be changed, to 24 address the confirmation count resets, and those 25 parameters changes had been implemented for a BWR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

48 1 owner's group recommendation.

2 MEMBER ABDEL-KHALIK: So the net effect of 3 these resets was a delay in reactor trip?

4 MR. AMWAY: That's correct.

5 MEMBER ABDEL-KHALIK: And how much of a 6 delay was that, time-wise?

7 MR. AMWAY: I would have to take that as 8 an action to take a look. It was, I mean I was on the 9 event review team that looked at that data.

10 I can tell you that the backup stability 11 protection actions that the operators would normally 12 take and look for in that event were to the point that 13 the operators even saw any oscillatory behavior, when 14 the period-based detection algorithms scrammed the 15 reactor.

16 CHAIRMAN ARMIJO: But we're talking 17 seconds, minutes, hours?

18 MR. AMWAY: Seconds.

19 CHAIRMAN ARMIJO: Seconds, okay.

20 MEMBER ABDEL-KHALIK: So you'll follow up 21 on this, and let us know?

22 MR. AMWAY: I will follow up on the actual 23 time delay between when we think the reactor should 24 have --

25 MEMBER ABDEL-KHALIK: Should have tripped, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

49 1 and the time when it actually tripped.

2 MR. AMWAY: Correct, and when it actually 3 did, but that is a period of seconds.

4 MEMBER ABDEL-KHALIK: Okay, thank you.

5 MR. AMWAY: You're welcome. Effects of 6 extended power uprate on the long-term stability 7 solution. There are no methods changes for extended 8 power uprate. The maximum rod line remains the same, 9 and that is the maximum extended load line limit 10 analysis boundary.

11 The OPRM armed region maintains the same 12 level of stability protection. Cycle-specific set 13 point analysis captures core design variations.

14 Option 3 long-term stability solution remains 15 unchanged, and the Option 3 OPRM set points will be 16 developed based on plant-specific DIVOM curves for the 17 extended power uprate cycle-specific reload analysis.

18 That concludes the overview of the Option 19 3. We'll move on to the next topic area, the ATWS 20 mitigation for Nine Mile 2. We'll start off with a 21 review of the mitigation system design features at 22 Nine Mile 2. We have a redundant reactivity control 23 system that is there to protect against ATWS events 24 and provide mitigation actions.

25 That system is initiated on RPV high NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

50 1 pressure of 1,065 psig. At time zero, once that 2 system actuates, we get a backup scram method, which 3 is the alternate rod insertion. At the same time, 4 time zero, we get an automatic reactor recirc pump 5 trip, to slow speed. Normally, the plant would be at 6 high speed operation of the recirc pumps.

7 At 60 hertz operation, that would transfer 8 to low speed at 15 hertz. At 25 seconds into the 9 transient, which the IRCSS is initiated if reactor 10 power remains above four percent, which means the ARI 11 was ineffective at completing the scram, then we get 12 an automatic feedwater runback.

13 That's going to drop reactor water level 14 down to where we want it for ATWS mitigation. It's 15 very effective at mitigating any instabilities that 16 may occur during the ATWS transient. We also at 25 17 seconds receive an automatic reactor recirc trip to 18 off, which would be zero speed.

19 If reactor power remains above four 20 percent, at 98 seconds, we get automatic boron 21 injection, and that's with both trains of standby 22 liquid control.

23 MEMBER ABDEL-KHALIK: And where does the 24 98 come from?

25 MR. AMWAY: The 98 seconds is a timer NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

51 1 that's built into the redundant reactivity control 2 system. In our accident analysis, we assume 120 3 seconds. So the 98 seconds bounds the 120 second 4 analysis.

5 When we prepared for the simulator 6 demonstration, that demonstration was performed in 7 2009. So it was before any operator-specific EPU 8 training on EPU conditions. The crews were provided 9 with a 10 or 15 minute brief, just to say this is what 10 EPU is in terms of power levels, steam flow, feedwater 11 flows, and I used an SRO for the demonstration that is 12 not part of the extended power uprate team, to avoid 13 biasing the operator response.

14 The purpose of the setup was to confirm 15 the expectation that the current procedures that exist 16 today, and the actions and action times, are 17 sufficient to address the ATWS event at EPU 18 conditions, post-EPU compared to current license 19 thermal power.

20 The initial conditions that we set up 21 prior to the demonstration. We establish a reactor 22 power, a full EPU power level of 39.88 megawatts 23 thermal and 99 percent core flow, which is consistent 24 with the upper end of the MELLLA boundary. We 25 establish a pressure pool temperature at 90 degree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

52 1 Fahrenheit, and a suppression pool level at 199.5 2 feet. Service water temperature, 84 degrees 3 Fahrenheit, and no control rod motion occurred during 4 the scram.

5 These initial conditions are consistent 6 with worse case conditions that could occur prior to 7 the ATWS initiation, and it's also consistent with the 8 design analysis inputs.

9 As a result of that demonstration, we 10 confirmed that the operators are able to place both 11 loops of suppression pool cooling in service in 404 12 seconds, which is well within the assumed action time 13 of 1,080 seconds. We were able to achieve hot 14 shutdown in 406 seconds, and we maintained peak 15 suppression pool temperature below the heat capacity 16 temperature limit, with a five degree margin.

17 It's also important to note that five 18 degree margin is based on a pressure band of 800 to 19 1,000 pounds, which is the normal pressure that we 20 would maintain post-ATWS, until we confirmed that we 21 were in hot shutdown. There is alternate strategies 22 available, that if the approach the heat capacity 23 temperature limit, we would take manual action to 24 reduce reactor pressure, to gain margin for the heat 25 capacity temperature limit, and avoid the blowdown.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

53 1 MEMBER ABDEL-KHALIK: Do you have a 2 schematic of how your power flow map will change after 3 this power uprate? I'm particularly interested in the 4 upper right corner of the power flow map.

5 MR. AMWAY: I do have that. If it's okay, 6 if you let me get through here, before I conclude this 7 presentation I can bring up my backup slides and show 8 you the power to flow map.

9 MEMBER ABDEL-KHALIK: Thank you.

10 MR. GUZMAN: This is Rich Guzman. After 11 the break, we can actually get this laptop working, 12 and we do have backup slides available. Particularly 13 if it's something we need to go in closed session, we 14 can also cover it during the closed session.

15 CHAIRMAN ARMIJO: Yes. Probably we'll 16 finish this part of the presentation, then take a 17 break, and so --

18 MR. AMWAY: I can review the two loop 19 power flow map right at the end of this presentation, 20 I've got a few more pages, and Joel, that's going to 21 be my backup Slide No. 10, if you want to get that 22 ready.

23 So continuing on with Slide No. 37, for 24 the MISV closure with failure to scram, as I stated, 25 the containment parameters remain well within design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

54 1 analysis, and when we evaluated the simulator response 2 to compare critical parameter response, they closely 3 matched the design analysis for that event.

4 For turbine trip with failure to scram, we 5 set up the same initial conditions, which again 6 conform for the worse case conditions expected, and 7 are consistent with the Design analysis inputs for 8 that event. The results of the turbine trip with 9 failure to scram, we again demonstrated the operators 10 can place both loops of suppression pool cooling in 11 service at rated flow, in 425 seconds.

12 Again, that's well within the assumed 13 action time of 1,080 seconds. We achieved hot 14 shutdown at 465 seconds. We maintained a suppression 15 pool temperature margin to heat capacity temperature 16 limit of 19 degrees Fahrenheit. Containment 17 parameters remained well within design limits, and 18 again the plant reference simulator behavior, in terms 19 of critical parameter response, closely matched the 20 analysis.

21 MEMBER ABDEL-KHALIK: Well, what are you 22 trying to prove by the fourth bullet?

23 MR. AMWAY: The fourth bullet being the 24 containment parameters --

25 MEMBER ABDEL-KHALIK: Right, indicated by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

55 1 the simulator.

2 MR. AMWAY: Oh. It would be the fourth or 3 the fifth bullet then?

4 MEMBER ABDEL-KHALIK: Either this slide or 5 Slide 37. It's the same kind of information.

6 MR. AMWAY: Okay. The containment 7 parameters, I'm speaking there in terms of the 8 suppression pool, peak temperature, the containment 9 pressures in both the dry well and the supp chamber, 10 those are the parameters I'm discussing.

11 The design analysis assumes approximately 12 six to seven psig for these events. That's largely 13 driven by the expected suppression pool temperature 14 response.

15 MEMBER ABDEL-KHALIK: But I was just 16 trying to get to the point of what are you trying to 17 -- let's go back to Slide 37, please. So if we look 18 at the fourth bullet here, okay, what are you trying 19 to prove with this statement?

20 MR. AMWAY: What I'm trying to prove is 21 that the operator -- that we can meet the operator 22 response times, and maintain the containment parameter 23 within design assumptions, or design analysis for 24 these events.

25 MEMBER ABDEL-KHALIK: Is this a reflection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

56 1 on the simulator model, or a reflection on the design 2 analysis, or a reflection on the operator ability to 3 respond to the event?

4 MR. AMWAY: It's based on the operator's 5 ability to respond to the event.

6 MEMBER ABDEL-KHALIK: So this is not a 7 statement regarding the fidelity of the simulator?

8 MR. AMWAY: No.

9 MR. INCH: The simulator's not an 10 engineered model. We don't use it for design. We use 11 it for operator training. It's been benchmarked to 12 plant data, and transient data in accordance with the 13 guidance. I think there's, you know, for simulator 14 fidelity.

15 MEMBER ABDEL-KHALIK: And that's why I'm 16 asking the questions, right. The simulator is not an 17 engineering model. It's simply an empirical model 18 that's fit to analysis and plant data. So what does 19 this statement tell you, other than --

20 MR. AMWAY: What I was trying to 21 demonstrate was the simulator was providing an 22 accurate training tool to the operators in this event.

23 So what I did was I looked at critical parameters. So 24 I'll give you an example. For the boron initiation 25 temperature, 110 degrees.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

57 1 The analysis assumption assumes that we 2 would reach that temperature limit of 110 degrees in 3 59 seconds. When I reviewed the simulator data, it 4 achieved 110 degrees in 60 seconds.

5 MEMBER ABDEL-KHALIK: Sure, because --

6 MR. AMWAY: In other words, it's just a 7 qualitative analysis to say the simulator's performing 8 similarly to how we expect the plant to behave, based 9 on our design analysis.

10 MEMBER ABDEL-KHALIK: But isn't that a 11 circular argument? If the simulator is based on the 12 analysis, wouldn't you expect it to perform according 13 to what the analysis said it should do?

14 MR. AMWAY: I would, and I'm not trying to 15 qualify the simulator by that, but just to make sure 16 that we have the simulator modeled to match what the 17 design analysis says.

18 CHAIRMAN ARMIJO: But basically, the 19 operators didn't have to do anything different for 20 this event at EPU than they would have done at current 21 licensed thermal power?

22 MR. AMWAY: That is correct.

23 CHAIRMAN ARMIJO: And you demonstrated 24 that.

25 MR. AMWAY: That's right.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

58 1 CHAIRMAN ARMIJO: That's what I get out of 2 this.

3 MR. AMWAY: And that's really what we were 4 trying to demonstrate with this, that we can use the 5 same EOPs, same EOP actions, same action times and 6 mitigate the event.

7 CHAIRMAN ARMIJO: But if, just for this 8 slide, the only thing that you might expect to have 9 changed was the margin on the suppression pool 10 temperature.

11 MEMBER SHACK: Well, if he actually, if 12 the operators took 1,500 seconds rather than 404 13 seconds, then the other bullets wouldn't have 14 followed.

15 CHAIRMAN ARMIJO: Sure.

16 MR. AMWAY: That's correct.

17 MEMBER ABDEL-KHALIK: Oh, I see.

18 MEMBER SHACK: I mean that's -- so it 19 really is a test of the operator action, assuming that 20 in fact the design analysis --

21 MEMBER ABDEL-KHALIK: Is valid.

22 MEMBER SHACK: Is valid. But you know, 23 what else can you expect?

24 MEMBER ABDEL-KHALIK: In a sense, you 25 know, if the response on the procedure matches the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

59 1 assumptions in the analysis, and since the --

2 MEMBER SHACK: Because you expect it to.

3 (Simultaneous speaking.)

4 MEMBER ABDEL-KHALIK: The simulator is 5 sort of fit into what the analysis says, you would 6 expect it --

7 MEMBER SHACK: But you want to make sure 8 that in fact that operators can do what the analysis 9 assumes they do, and they seem to have -- they do it 10 with some margin.

11 MEMBER ABDEL-KHALIK: I think I 12 understand.

13 MR. AMWAY: That brings me to Slide No.

14 40, the conclusions. The conclusion of the 15 demonstration showed that the existing procedures, 16 operator reaction times and strategies are effective 17 in mitigating ATWS and ATWS instability events.

18 Nine Mile 2 features an ATWS recirc trip 19 function, and as a result, the transient power levels 20 are primarily based on the maximum control rod line, 21 which is unchanged for extended power uprate, and that 22 operators can perform actions in a timely manner, to 23 bring the plant to safe shutdown.

24 CHAIRMAN ARMIJO: If you could bring up 25 that backup slide and take a look at it before we take NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

60 1 a break.

2 MR. INCH: We want to take a break first, 3 to look at it.

4 CHAIRMAN ARMIJO: Well, you know, I'd like 5 to wrap it up with this, because this is --

6 (Simultaneous speaking.)

7 MR. AMWAY: I have a hard copy here.

8 CHAIRMAN ARMIJO: Can't get it up on the 9 screen conveniently?

10 MR. AMWAY: Well the staff presumably is 11 going to address the same issue after the break, so we 12 can do it either way.

13 CHAIRMAN ARMIJO: Let's get it done now.

14 We're a little bit ahead of schedule. Just take a 15 minute, to kind of freshen your mind.

16 (Off record discussion between panel 17 members.)

18 CHAIRMAN ARMIJO: Yeah, why don't we do 19 that? We'll reconvene at 10:00, give us a 15 minute 20 break.

21 (Whereupon, a short recess was taken.)

22 CHAIRMAN ARMIJO: Okay, let's come back 23 into session. I think now we'll address the question 24 before the break on the power flow map.

25 MEMBER ABDEL-KHALIK: I think you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

61 1 indicated that you will stay on MELLLA.

2 MR. AMWAY: That's correct.

3 MEMBER ABDEL-KHALIK: Could you show us 4 where the boundary is before the power uprate, and 5 where it's going to be after the power uprate?

6 MR. AMWAY: I can. This is our two loop 7 power flow operating map, and you can see on here 8 these are the backup stability protection regions that 9 are defined on our map that I spoke of, in that 10 section on stability. This line right here is the 11 MELLLA boundary, okay.

12 So right now, the operating point, this is 13 shown for extended power uprate, but our current 14 licensed thermal power is at roughly 85 percent, which 15 would be about right across in here, okay.

16 So the expanded domain is really above 17 this line, up to in this triangular area right here is 18 the EPU power level. Where we're permitted to operate 19 is anywhere within the white regions or the green 20 regions, okay.

21 So the difference between current license 22 thermal power and extended power uprate is this domain 23 that used to be our MELLLA domain. It's considerably 24 shrunk by, there's actually two lines shown here. The 25 Gulf 1 line that's indicated by this marker right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

62 1 here, is the 100 percent rod line.

2 So the 100 percent rod line is defined as 3 the rod line at which if you get to 100 percent core 4 flow, you should be at 100 percent of rated power.

5 There is actually a thin boundary domain within those 6 two lines. It's very small. It's on the order of one 7 percent.

8 So we have used most of that MELLLA 9 operating room to achieve the uprate power level, such 10 that when we're at 100 percent of EPU power level, 11 we're in this corner.

12 MEMBER ABDEL-KHALIK: So you don't have 13 much --

14 MR. AMWAY: We don't have much operating 15 room, which underscores the reasons why we're trying 16 to restore the original design margin in the reactor 17 recirc system, which will enable us to go into the 18 green region here, which will give us the operational 19 flexibility we need at 100 percent of rated power 20 for, you know, to account for small pattern 21 adjustments of the control rod system, and for, you 22 know, depletion of the fuel cycle.

23 MEMBER ABDEL-KHALIK: But you can go the 24 other way?

25 MR. AMWAY: I cannot go into this yellow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

63 1 region.

2 MEMBER ABDEL-KHALIK: Right.

3 MR. AMWAY: I can only go, this is my 4 boundary to the left, and I can go all the way to the 5 green boundary on the right.

6 MEMBER ABDEL-KHALIK: Five percent.

7 MR. AMWAY: It's roughly about five 8 percent.

9 MEMBER ABDEL-KHALIK: How much will you 10 gain by this improvement in the jet pumps?

11 MR. AMWAY: Right now, and I'll ask George 12 to back me up a little bit on it, but we were going to 13 -- we would not be able to achieve EPU power level 14 with the existing condition of the jet pumps.

15 We would maximize our core flow, and we 16 would not be at an operating point consistent with 17 100 percent EPU power level. George, did you want to 18 add anything else?

19 MR. INCH: No, that's correct.

20 MEMBER ABDEL-KHALIK: So currently on this 21 map, where is your maximum core flow, given the fouled 22 condition of the jet pumps?

23 MR. INCH: Approximately 97 percent core 24 flow.

25 MR. AMWAY: So that would be --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

64 1 MR. INCH: At our current power level.

2 MR. AMWAY: --about right in this region.

3 The flow is across the bottom, so you'd be measuring 4 flow vertically, and they're in five percent 5 increments. So this is 100 percent core flow here.

6 This would be 95 percent core flow at this point.

7 MEMBER ABDEL-KHALIK: So is there a 8 condition being proposed, that the power uprate be 9 limited pending demonstrated performance of the 10 refurbished jet pumps?

11 MR. GUZMAN: This is Rich Guzman. We do 12 not have a proposed license condition on that at this 13 time. But certainly we'll take that in development of 14 our final safety evaluation. But I will certainly 15 talk to the staff regarding that matter, and update 16 our safety evaluation as needed, to address that 17 matter.

18 MR. INCH: But we definitely don't believe 19 there is any need for any license condition. I mean 20 that's a limitation of --

21 MEMBER ABDEL-KHALIK: But you're assuming 22 that when you do that, you'll get the right flow, to 23 allow you to go to, you know, 120 percent of the 24 original license thermal power.

25 MR. INCH: If, for example, if the jet NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

65 1 pumps don't perform as designed, then we'll have a 2 shortfall in core flow, and we may not be able to 3 complete the test program up to 120. But more than 4 likely what will happen is that we won't be able to 5 use the full increase core flow domain. But we'll be 6 able to get to 120 percent.

7 Along the MELLLA line, 120 percent power 8 is at 99 percent core flow. So and if we go to 9 maximize dry flow on the system, we'll be able to get 10 there. So we'll be able to achieve 120 percent, 11 especially with the clean jet pumps.

12 MEMBER ABDEL-KHALIK: Okay. The point is 13 currently, the way the plant is, you can't get the 14 core flow required to allow you to remain within the 15 power flow map at 120 percent power.

16 MR. INCH: I'd state it a little bit 17 differently.

18 MEMBER ABDEL-KHALIK: Okay.

19 MR. INCH: We'll be within the power flow 20 map.

21 MEMBER ABDEL-KHALIK: Okay.

22 MR. INCH: We may not be able to --

23 MEMBER ABDEL-KHALIK: To reach 120 24 percent.

25 (Simultaneous speaking.)

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

66 1 MR. INCH: --full power. But at all 2 times, we're within the licensing envelope.

3 MEMBER ABDEL-KHALIK: Sorry, okay. That's 4 fine.

5 MR. INCH: So that's why I was saying --

6 MEMBER ABDEL-KHALIK: Well, wouldn't it be 7 reasonable then? I mean in other words, achievement 8 of 120 percent power and remaining within the power 9 flow map is contingent upon your ability to improve 10 the jet pump performance?

11 MR. INCH: Well, it's really an 12 operational flexibility issue, and Phil --

13 MR. AMWAY: You can operate with a small 14 core flow window.

15 MEMBER ABDEL-KHALIK: But you can't even 16 get there now.

17 MR. INCH: Well, you can get there without 18 a flow window. Even with fouled jet pumps. You know 19 with clean jet pumps, we're going to be able to get to 20 99 percent core flow. We'll be able to get to the 21 full 105 percent core flow window.

22 There's no reason to anticipate any reason 23 why we wouldn't, because the design analysis and all 24 the original start-up testing supports that with a 25 clean jet pump, we'll get there, you know.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

67 1 Even with the higher DPs associated with 2 EPU, all the numbers say we'll be able to get to 104 3 percent rated core flow. So we'll be within the power 4 flow map the whole time.

5 MEMBER ABDEL-KHALIK: I guess this is 6 really not the place to argue it, but you know, my 7 feeling is that without demonstrated performance of 8 the new jet pumps, it's --

9 MEMBER SHACK: That's sort of his problem.

10 He has to stay within the power flow map.

11 MR. INCH: Right.

12 MR. AMWAY: I'm going to stay within the 13 power flow map.

14 MEMBER ABDEL-KHALIK: Regardless.

15 MR. AMWAY: I've got nothing that tells me 16 I can deviate. The way I see it, I mean we're taking 17 out the existing inlet mixers, replacing them with the 18 same type of inlet mixer that I have today. The 19 reason why I'm doing that is to restore the original 20 design margin of what the system was designed to do 21 from day one when the plant was built.

22 It's not really a change, in terms of a 23 different type of jet pump that would have different 24 flow characteristics. It has all the same flow 25 characteristics of the jet pumps today.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

68 1 CHAIRMAN ARMIJO: And you'll demonstrate 2 that in your power ascension test program.

3 MR. AMWAY: Right.

4 CHAIRMAN ARMIJO: So it's a flexibility 5 issue, really.

6 MR. AMWAY: Yes.

7 MEMBER ABDEL-KHALIK: We'll just argue 8 this point. We'll think about it. Thank you.

9 MR. AMWAY: Are there any other questions 10 on the power flow map?

11 CHAIRMAN ARMIJO: Just keep it around.

12 (Laughter.)

13 CHAIRMAN ARMIJO: All right. I think 14 we're going to go now to Peter.

15 MR. INCH: Oh, I do have an answer to the 16 materials question, the 316 stainless.

17 CHAIRMAN ARMIJO: Oh yes.

18 MR. INCH: It's not the nuclear grade, but 19 it is low carbon.

20 CHAIRMAN ARMIJO: Right.

21 MR. INCH: The carbon level is .02.

22 CHAIRMAN ARMIJO: Probably .03, isn't it?

23 MR. INCH: .023, I believe. It's a low 24 carbon.

25 CHAIRMAN ARMIJO: It's a low carbon, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

69 1 right. Okay. It is --

2 MEMBER SHACK: The spec on low carbon is 3 .03, so he's well within that.

4 CHAIRMAN ARMIJO: 03, yeah. Okay, thank 5 you.

6 MEMBER REMPE: Maybe it's a closed session 7 question, but are there other plants that have used 8 these new jet pumps with this new coating and had 9 great experience? Or would you rather talk about it 10 later?

11 MR. INCH: I think we need to discuss it 12 later on that.

13 MEMBER REMPE: Okay.

14 MR. AMWAY: Thank you.

15 MR. GUZMAN: Good morning. At this time, 16 the NRC staff will be presenting the Nine Mile Point 17 2 EPU ATWS instability review, specifically covering 18 the audited areas that they covered, which the 19 licensee did mention earlier. This presentation will 20 be followed with an open session version of the fuel 21 methods discussion by Dr. Yarsky, and then at that 22 point, we'll go to closed session.

23 All right. So with that, I'm going to 24 turn it over to Dr. Huang, to introduce his team, and 25 go with the first slide.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

70 1 DR. HUANG: Yes. I'm Tai Huang, from 2 Reactor System Branch, along with Dr. Jose March-3 Leuba, who will present the subcommittee member on the 4 staff evaluation on the Nine Mile Point 2 EPU.

5 There are two portion of the review. One 6 is, you know, the submittal of available documents on 7 their Option 3, long-term stability solution 8 implementation, and second one would be the staff 9 audit on their simulator, to verify whether their 10 operating reactor, operating procedural to the 11 training of their operator are adequate.

12 So that current long-term stability 13 implementation, according to the staff evaluation, 14 it's adequate for EPU. They satisfy the 10 CFR Part 15 50 design criteria 10 reactor design, and 12, 16 suppression of the reactor power oscillation.

17 So level of protection in EPU is similar 18 to the current licensed thermal power, and as well as 19 the staff audit goes, we conclude that the Nine Mile 20 Point 2 operator show good understanding of stability 21 in ATWS issue for EPU, in staff observations of 22 operators' action in the simulator support customary, 23 assume a 120 second delay, assume for calculation.

24 You know, in their run, I mean the license 25 run, you see they're using less than 120 seconds NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

71 1 there. Nine Mile Point 2 EOP adequate for EPU, as the 2 staff evaluation in SER shows. As we go on for that 3 generic, you know, on that power flow map here, what 4 the different from the curling (ph) thermal power to 5 the EPU, you can see, you know, that in the power flow 6 diagram here, you know, curling thermal power is 7 right, corner is right here.

8 MEMBER SHACK: You need to do it on the 9 mouse, I think.

10 DR. HUANG: Yeah, okay, on the mouse.

11 CHAIRMAN ARMIJO: Use the mouse.

12 DR. HUANG: Yeah, okay, and then EPU be 13 extended out on that same narrow line to the EPU 14 corner. You see the power flow map just is shorter.

15 You see that EPU corner over there, all right. Then 16 that there's no like end point are the same, is the 17 same, after, you know, that reactor trip.

18 The end point would be the end point, 19 following the pump trip, right here on the corner. So 20 EPU and curling thermal power condition and not that 21 would be the same point there. So that try to make 22 EPU does not change the end point after the 23 recirculation pump trip. So that diagram show this.

24 Next slide. Now there are two parts. One 25 is Option 3, long-term stability implementation on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

72 1 stability issue. You know the story on that, in the 2 licensee's presentation. This is just summarized.

3 They install since 1998 an arm since 2000, and plant 4 has a very good experience on this Option 3.

5 According to that information, 2003 Nine 6 Mile Point 2 event was detected and the scram 7 activated. So that mean that OPRM on the Option 3 8 system is working. But the lesson learned from that, 9 that the owners group, they come out with adjustment 10 of parameter setting, so that that's already done for 11 this plant.

12 So there's no impact expected for EPU.

13 Option 3 and DIVOM methodology are applicable to this 14 plant. Now ATWS, the second part on the ATWS 15 instability, that the Nine Mile Point 2 has 16 implemented latest EPZ and SAGs. So early level 17 reduction in boron injection are accomplished through 18 automated ATWS action. If high pressure is detected 19 with power grid at four percent, then there's 20 automatic flow runback, automatic boron injection.

21 At Nine Mile Point, we had excellent ATWS 22 response, because they have a select system injections 23 through high pressure core spray system on the top.

24 So they don't need to worry about at the bottom up 25 there. So they don't have that problem.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

73 1 So 100 percent water driving feedwater, 2 yeah, for this Nine Mile Point 2. So EOPs are 3 reviewed every cycle, but are not affected 4 significantly by EPU, because boron is injected in a 5 high pressure core spray system, and there is no need 6 to define a hot shutdown boron weight, you know, 7 because from the top down.

8 So EPU does not affect heat capacity 9 thermal limits slightly. It's by one degree, 10 according to the analysis. So that's the only 11 difference right there, right.

12 Now staff, second part. The staff has 13 audited, and the purpose of that when staff review the 14 performance, OPRM, there are two parts. OPRM Solution 15 3 system in the simulator, and staff reviewed the ATWS 16 performance in the simulator as three events.

17 One is turbine trip ATWS from the MELLLA 18 corner. MELLLA corner was simulated on stable 19 observation in the slides. MELLLA corner will be the, 20 you know, it's back in the slides, the MELLLA corner.

21 CHAIRMAN ARMIJO: The upper right-hand 22 corner.

23 DR. HUANG: I understand that, okay.

24 Mainstream oscillation valve, oscillation case ATWS 25 from the MELLLA corner, and also from EPU conditions.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

74 1 So we compare to that, and we can show on later slide 2 what the difference between EPU and curling thermal 3 power condition.

4 Nine Mile Point 2, you know, submit 5 additional information, because at the time the staff 6 audit at the plant, simulator not up to the EPU 7 conditions for the ATWS. So they ran the results and 8 show additional information to the staff. So we show 9 that, you know, in a later presentation on the 10 simulator. Now turn over this to Jose, Dr. March-11 Leuba on the simulator portion.

12 DR. MARCH-LEUBA: I'm Jose March-Leuba 13 from Oak Ridge National Laboratory, an NRR consultant, 14 and the recent discussion this morning about what is 15 the purpose of doing simulator calculations of ATWS.

16 Let me reemphasize your conclusion, that it is to 17 review the operator actions.

18 You can ask Dr. Yarsky, who has 19 presentation 20 minutes from now, how long it takes to 20 run an ATWS calculation with engineering code, and 21 he'll tell you several days, if not weeks, of CPU 22 time.

23 This is with multiple restarts and 24 multiple stops and backtracks, when the computer 25 didn't do what it was supposed to, and five engineers NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

75 1 looking at the results, to see what feedwater strategy 2 you should have been using.

3 So we have two types of scenarios. I mean 4 one is a very accurate code trace, for example, of 5 Type G, that very accurately models the conservation 6 of energy, mass and momentum and does everything well.

7 On the other side, we have a pretty good simulator 8 model, but it has a human in the loop, as the real 9 operator doing the real control system on real time.

10 The first 120 seconds go in that time real 11 fast. So it is not abundantly clear to anybody 12 looking at it that with the 120 seconds, operator will 13 be able to do anything. So the purpose of this audit 14 that we performed was to go and in the real simulator 15 with real operator, to see what they're supposed to 16 do. My goal, just to give you a visual, is do we need 17 Superman in the control room to do everything that 18 we're asking these operators to do?

19 The conclusions after watching this is 20 indeed, we don't need Superman in there. The 21 operators are really well-trained, they're very 22 professional, and if I were to show you a video of the 23 operators handling an ATWS, and operators handling a 24 control room in motion, you will not see the 25 difference if you didn't have audio with it.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

76 1 The operators just walked to the panel.

2 They're not running from panel to panel. There's one 3 operator in charge of level control; there's another 4 operator in charge of the control rows, and they're 5 doing their job. Indeed, the timing turned out to be 6 -- the 120 seconds turned out to be very realistic.

7 So that was the purpose of --

8 MEMBER ABDEL-KHALIK: During these 9 observations, the operators knew in advance what event 10 they're going to be responding to?

11 DR. MARCH-LEUBA: Not always. They knew 12 they were going to be doing an ATWS, and I was going 13 to point out that you do all these runs in sequence.

14 So by the time you do the third simulation, they 15 already know the procedures by heart, okay. So there 16 is a variability from time to time, but not always.

17 We do go there and we kind of moved 18 operators into oh, why don't you run this case now for 19 us, and they didn't know it in advance. We really, we 20 didn't do it on purpose, but we have extra time. We 21 said well, let's run now assumption that the control 22 room's not going at all, or let's run an assumption 23 that there's a leak doesn't come in at all.

24 So they, we do change. We put some 25 variability in the system. But even if they were to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

77 1 know it in advance, they have the procedures in big 2 panels and there's a flow chart, and the first thing 3 there the senior operator does is go get the right 4 flow chart, put it on top of the table, and he's just 5 following it.

6 He gets his marker, that's done. We enter 7 in this branch, that's done. So they're well-trained.

8 They're well-trained in advance. It's maybe knowing 9 what training scene they're going to get reduces their 10 anxiety a little bit, but I don't think it changes the 11 results.

12 So the real difference was probably 13 adrenalin. I realize the adrenalin will be flowing a 14 little differently, and they might be doing things a 15 little faster. But that's where training comes on.

16 You do faster the right procedure, and they do follow 17 procedure.

18 No operator goes and touches any panel 19 unless the senior operator from behind says "it's time 20 to do EOP 3G," and gives the order. So here we have 21 very small description, because I don't want to show 22 the details. Two MSRV closures, a cooling seal, 23 cooling licensing thermal power at EPU. The very 24 first thing that happens, you have this kickout here, 25 which this is the MSRV closure.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

78 1 You have a big pressure transient, and 2 they have this on both. Right after that, you trip 3 the pumps, and the moment you trip the pumps, both 4 CLTP and EPU become the same condition. Then you see 5 approximately the same thing happens.

6 There are some difference out here, and 7 this is not due to the initial condition. It's what 8 the operator did differently in these two runs. This 9 run was done before, and this has to do with 10 maintaining level once you reach the fuel, and he did 11 it better on the second run. But there is no 12 significant difference between the two.

13 We'll go to the next slide here. Again, 14 this is not the engineering simulator, but it's pretty 15 good. It does concern mass and energy and momentum, 16 and we see it in Nine Mile Point, the peak capacity 17 temperature limit, which is 140 degrees F, or 139, is 18 not even reached for an MSRV closure. The maximum 19 temperature in the suppression pool is 130 degrees F.

20 This is in part because Nine Mile Point 2 21 is a really great ATWS plant. I mean if God forbid we 22 don't have an ATWS, but we're allowed to have an ATWS.

23 (Laughter.)

24 DR. MARCH-LEUBA: Because everything, 25 everything is right in that plant. I mean everything NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

79 1 is done automatically. The boron is injected in the 2 top of the core, so it is no issue with remixing, and 3 there's plenty of margin to everything.

4 CHAIRMAN ARMIJO: A slight reduction in 5 margin is just the result of having more heat to get 6 rid of, or is that an artifact of the --

7 DR. MARCH-LEUBA: It's an artifact. In 8 principle, there should be no difference in the HCTL, 9 heat capacity temperature limit, between the two.

10 CHAIRMAN ARMIJO: The actual.

11 DR. MARCH-LEUBA: Oh, you're talking about 12 the --

13 CHAIRMAN ARMIJO: The actual could be 14 higher, wouldn't it? You're getting rid of more.

15 DR. MARCH-LEUBA: You're not getting rid 16 of more heat. That's the point. After you trip the 17 pumps, you are at the same power than you were before, 18 or an approximation. Now you do have a different 19 core, you have a different coefficient. So you end up 20 having the slightly different numbers, one, two, three 21 percent difference.

22 CHAIRMAN ARMIJO: Yes, okay.

23 DR. MARCH-LEUBA: The difference between 24 EPU and OLTP is in decay heat. There, you have 20 25 percent more decay heat. But as long as you don't go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

80 1 into a one week extended outage, decay heat is 2 removed. It's before your scram and you are still 3 putting 50, 60 percent power into your containment.

4 That's what you have in ATWS.

5 So in summary, the staff found the EPU 6 operation acceptable from a stability point of view, 7 because the long-term solution, which is Solution 3, 8 provides exactly the same level of protection under 9 EPU than under the coolant power. Therefore, the OPRM 10 scram and the OPRM procedures satisfy the GDC, general 11 design criteria 10 and 12, which is the criteria that 12 we have to satisfy.

13 On the ATWS scenarios, really the ATWS 14 stability is not affected significantly by EPU event, 15 and it's because after you trip the pumps, you are in 16 exactly the same condition. I mean that satisfy all 17 our acceptance criteria, which are three criteria, if 18 you remember.

19 They are the core coolability, meaning you 20 don't destroy your fuel and put it in the bottom of 21 the vessel; you maintain vessel integrity; and you 22 maintain containment integrity, and the containment 23 integrity has to do with the suppression pool 24 temperature we were talking about before.

25 Just to emphasize that Nine Mile Point 2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

81 1 has an excellent ATWS pro forma design, and I wish all 2 the plants were like it. I mean it has automatic 3 trips, so we really don't even have to worry about the 4 operator doing the right thing. The control system 5 will do it for them. They inject the boron on the top 6 of the core, so there's no mixing problems, and the 7 feedwater pumps are 100 percent motor-driven, meaning 8 that there is no issue with how much availability of 9 inventory to maintain level in the vessel during ATWS, 10 and that's the end of our presentation.

11 CHAIRMAN ARMIJO: Any questions? I 12 suspect one. Thank you.

13 MEMBER ABDEL-KHALIK: What is the last 14 bullet?

15 DR. MARCH-LEUBA: If you do not have 16 motor-driven feedwater pumps, which many plants don't; 17 they use steam-driven, the moment you close the MSRV, 18 then you don't have steam for those pumps and you 19 don't have feedwater, and you rely on other ACCS 20 systems, which are not as large.

21 If you were to increase, in some of these 22 plants, if you were to increase the power 23 significantly, you will not have enough. HPCI will 24 not be sufficient to maintain level. Here, you have 25 100 percent feedwater available. You don't have any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

82 1 problems.

2 MEMBER ABDEL-KHALIK: Okay, thank you.

3 CHAIRMAN ARMIJO: Thank you. Let's keep 4 going. I guess we're getting into Peter Yarsky's 5 presentation.

6 DR. YARSKY: Hello. I'm Dr. Peter Yarsky 7 from the staff. I'm a member of the Office of 8 Research, and I'm going to be talking about the 9 applicability of the interim methods to the Nine Mile 10 Point 2 extended power uprate LER. The basis for our 11 methods review was the safety evaluation for the 12 interim methods license and topical report, NEDC-13 33173P.

14 In the course of our review, we have 15 confirmed that the EPU LER is fully consistent with 16 all of the conditions and limitations in the staff's 17 SE for the IMLTR. The IMLTR specifies 24 different 18 conditions and limitations. In the Nine Mile Point 2 19 EPU application, no supplements to the IMLTR are 20 referenced.

21 The Appendix A to the power uprate safety 22 analysis report provides the disposition of each of 23 the conditions limitations, and in the course of our 24 review, we found that all 24 conditions limitations 25 were acceptably met. In the course of our review, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

83 1 conducted one regulatory audit pertaining to the 2 IMLTR.

3 Then the audit had to do with initially 4 guiding LPRM calibration interval. The frequency with 5 which the LPRMs are calibrated, that's sometimes 6 referred to as the LPRM update, affects core monitor 7 accuracy to predict core power distribution. In the 8 Nine Mile Point 2 technical specifications, the LPRM 9 calibration interval is specified in units of 10 effective full power hours. So at EPU conditions, the 11 equivalent exposure interval between LPRM calibration 12 intervals would increase along with the thermal power 13 by approximately 15 percent.

14 We asked RAI SMPB-1, which was the only 15 RAI coming from the methods review, to address LPRM 16 calibration interval, and the outcome of that RAI was 17 that the staff conducted an audit at GEH, to confirm 18 that the power distribution uncertainties were 19 acceptable for this longer exposure interval.

20 MEMBER ABDEL-KHALIK: Was this issue 21 raised at the original stretch uprate?

22 DR. YARSKY: I'm not familiar with the 23 stretch power uprate review.

24 MEMBER ABDEL-KHALIK: But it would have 25 been equally applicable, wouldn't it?

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

84 1 DR. YARSKY: The extension of the 2 interval, yes, would have been applicable, but not 3 equally applicable --

4 (Simultaneous speaking.)

5 MEMBER ABDEL-KHALIK: Well, I mean 6 essentially the same issue.

7 DR. YARSKY: Yes. I personally became 8 first familiar with this topic during the review of 9 the Monticello EPU, and the conclusion and resolution 10 of that issue was different in Monticello than for 11 Nine Mile Point 2.

12 MEMBER ABDEL-KHALIK: Okay.

13 DR. YARSKY: Yes. The Subcommittee was 14 briefed on this issue during a generic review related 15 to interim methods, I believe, in August.

16 CHAIRMAN ARMIJO: This summer.

17 DR. YARSKY: It is June, in June. So it's 18 the same topic, just applied on a plant-specific 19 basis.

20 CHAIRMAN ARMIJO: Peter, if the 21 uncertainties hadn't been acceptable, wouldn't the 22 solution be pretty straightforward? You just 23 recalibrate?

24 DR. YARSKY: The solution would have been 25 straightforward. It could easily have been an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

85 1 adjustment to the LPRM calibration level. That has 2 been done by other licensees seeking power uprate.

3 CHAIRMAN ARMIJO: Okay.

4 DR. YARSKY: That's all I have. So --

5 CHAIRMAN ARMIJO: That's it. Okay. Well 6 then I think we're ready to go into closed session, 7 and first I'd like the staff and the applicant to 8 confirm that the right people are here, and that 9 nobody's on the bridge line that shouldn't be on the 10 bridge line.

11 (Whereupon, at 10:29 a.m., the meeting was 12 adjourned to closed session.)

13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

86 1 O P E N S E S S I O N 2 10:59 a.m.

3 CHAIRMAN ARMIJO: Ready to go.

4 MR. AMWAY: Okay. Before we begin the 5 material mechanical civil discussion, I wanted to 6 respond to the open question on the quantifying the 7 scram delay back in the Stability section, where I 8 presented the 2003 stability event for Nine Mile Point 9 2, and the question of that was what kind of time 10 delay do we have from the onset of oscillation to 11 where we should have scrammed to when we actually 12 scrammed the reactor.

13 The answer to that question is 15 to 20 14 seconds.

15 CHAIRMAN ARMIJO: That's the delta between 16 the ideal and the somewhat delayed because of the 17 resets?

18 MR. AMWAY: The time delay from when the 19 OPRM should have scrammed the reactor, based on 20 confirmation counts, and when it actually did, that 21 total delta is 15 to 20 seconds.

22 CHAIRMAN ARMIJO: Okay, and with the 23 corrections and the updates, that has disappeared 24 where you expected?

25 MR. AMWAY: That's correct. That would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

87 1 eliminate that 15 to 20 second delay.

2 MEMBER SHACK: And you're not going to run 3 an experiment to verify that?

4 MR. AMWAY: That is also correct.

5 CHAIRMAN ARMIJO: And we don't expect you 6 to.

7 MR. INCH: My name is George Inch. I'm 8 the physical engineer for mechanical structural for 9 the power uprate of Unit 2. I'm going to be going 10 through the reactor pressure vessel internal materials 11 issues, and related flow-induced vibration 12 evaluations.

13 So for the internals, the EPU evaluations 14 included the effect effluence, the effect of flow-15 induced vibration, structural effects that are non 16 flow-induced vibration-related, and the impact of EPU 17 on the current material condition with regard to 18 intergranular stress corrosion cracking, and 19 irradiation-assisted stress corrosion cracking.

20 The accepted threshold for effluence, 21 where irradiation-assisted stress corrosion becomes a 22 significant factor in the growth rate of an existing 23 IGSCC flaw and potential IASCC that's accepted in the 24 BWR vessel internals program is 5E to the 20 neutrons 25 per centimeter squared.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

88 1 The existing components that are expected 2 to exceed that threshold in the current license term, 3 and that's expected, anticipated in the vessel 4 internal program scope are the top guide, the shroud 5 and the core plate.

6 CHAIRMAN ARMIJO: George, you know, that 7 threshold is a pretty fuzzy threshold. It's not a 8 hard line.

9 MR. INCH: Right.

10 CHAIRMAN ARMIJO: So what other components 11 are close to that 5 times 10 to the 20th? You know, 12 these were, this is the same list as pre-EPU.

13 MR. INCH: Yes.

14 CHAIRMAN ARMIJO: So as you go up 20 15 percent more in flux, I would expect more components 16 come into this population, and others get closer.

17 MR. INCH: Additional components really 18 don't come into the mix. I mean the effluence level 19 goes up, but the threshold, that threshold really 20 isn't exceeded by any additional components.

21 CHAIRMAN ARMIJO: So okay.

22 MR. INCH: So that the --

23 MEMBER ABDEL-KHALIK: What's the next --

24 I mean the question --

25 (Simultaneous speaking.)

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

89 1 MR. INCH: It would be some jet pump 2 components that are in the core region. Everything 3 that's going to --

4 (Simultaneous speaking.)

5 MR. INCH: And, you know, these are the 6 core region components and then, you know, what's 7 outside of the reactor, I mean the core shroud would 8 be the jet pump components. But because of the size 9 of the annular region, you get significant 10 attenuation. So those components are, you know, don't 11 approach --

12 CHAIRMAN ARMIJO: None of the guide tubes, 13 whether it's drives or instrumentation.

14 MR. INCH: All the instrumentation in the 15 core is above this, just as a matter of course. So 16 and the guide tubes are all below the core plate, and 17 so you get significant attenuation as you go down.

18 CHAIRMAN ARMIJO: Okay. So these are 19 still the same components you worried about pre-EPU?

20 MR. INCH: Yes.

21 MEMBER ABDEL-KHALIK: What's the condition 22 of your shroud now?

23 MR. INCH: The Nine Mile Point 2 core 24 shroud has IGSCC cracking associated with the belt 25 line welds. The H-4 weld and H-5 weld have OD IGSCC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

90 1 cracking. Cracks are approximately 70 percent of the 2 circumference. They're relatively shallow, as it's a 3 two inch shroud, and the cracks are less than half of 4 an inch in depth.

5 They were first identified in the baseline 6 inspections performed in the 90's. I believe it was 7 in '97 where they were identified. We've 8 ultrasonically inspected those multiple times, at 9 least four times.

10 Since we implemented hydrogen water 11 chemistry and noble metals, we haven't seen measurable 12 growth that we consider to be real growth. With UT, 13 there's always variation. So you never match it up 14 within the uncertainty of the deployment tools and the 15 UT devices. But the condition has been stable for at 16 least ten years.

17 CHAIRMAN ARMIJO: Are these shrouds 18 clamped? Have you put any of these --

19 MR. INCH: There's no tie rods.

20 CHAIRMAN ARMIJO: There's no tie rods, so 21 it's just as-built, and you're monitoring and testing 22 the cracks?

23 MR. INCH: Yes. The flaw evaluation for 24 the core shroud has been updated for the power uprate 25 higher loads for differential pressures. It's, that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

91 1 flaw evaluation still shows that the normal upset 2 event is the controlling event for the core shroud.

3 It's not the faulted event.

4 The vertical welds, all the vertical welds 5 are clean. There's no cracking on the vertical welds.

6 Very minor cracking on other locations, less than ten 7 percent, very typical. So the location of the 8 indications on the core shroud are consistent with the 9 understanding in the fabrication process. So it was 10 the final weld built --

11 CHAIRMAN ARMIJO: After you, on the 12 shroud, since you've inspected it a lot, after you 13 implemented the hydrogen water chemistry and the noble 14 metals, have you found any new cracks that hadn't been 15 there pre-hydrogen?

16 MR. INCH: Not that we consider -- we 17 don't consider them new. The UTs have evolved over 18 the past ten years. I'm always seeing, you know, I 19 get a scan and the percent cracking is essentially the 20 same. But we get a little additional coverage at a 21 location. There's a lot of starts and stops, but 22 there's been no significant change in with the new 23 cracking.

24 CHAIRMAN ARMIJO: Okay, just a couple of 25 other things. On the top guide and the core plate, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

92 1 have you, do you have any -- can you inspect them 2 well, and do you have cracks, IGSCC, in those 3 components?

4 MR. INCH: The top guide, we have the 5 inspection can be performed of the top guide grid 6 beams. That was inspections that were recently added 7 to the VIP program, approximately --

8 MEMBER SHACK: These are enhanced VT1?

9 MR. INCH: These are enhanced VT1, where 10 we clear the cell and they have a cleaning process, to 11 get the enhanced visual capability. We've done, 12 completed an initial deployment of this new tool in 13 2010, and that worked quite well. So we haven't 14 established that Unit 2A baseline yet on the top 15 guide, but we --

16 CHAIRMAN ARMIJO: Have you seen anything 17 that looks like a crack?

18 MR. INCH: No, no. We've looked at two 19 cells. We've done standard refueling inspections.

20 We've looked at two cells with the enhanced VT1, and 21 we've done the standard VT inspections that would 22 normally detect any significant structural issues.

23 But we haven't completed the five percent baseline 24 that is recommended as planned for implementation over 25 the next --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

93 1 MEMBER SHACK: Now these are one of these 2 milled top guides, right? Solid, or do you have the 3 interlocking beam kind of thing?

4 MR. INCH: This is a BWR-5, so it's not 5 the BWR-6 top guide.

6 MEMBER SHACK: The 6 is the one that's 7 milled out?

8 MR. INCH: I believe so.

9 CHAIRMAN ARMIJO: So these are 10 interlocking, welded?

11 MR. INCH: I'll verify that, but I'm 12 pretty sure these are interlocking designs.

13 MEMBER SHACK: So there's lots of corners 14 to look at.

15 CHAIRMAN ARMIJO: Okay so -- yeah, that's 16 the problem. Now the shroud is UT inspectible, but 17 what about the core plate?

18 MR. INCH: Core plate at Unit 2, the only 19 inspection requirements for core plate are for the 20 bolting, and it's part of the program. The evaluation 21 that we have right now is a generic evaluation for the 22 inspectability of the bolting, and so we have in 23 place, as pretty much all the, most of the BWRs do, an 24 interim analyses that shows that the bolting will 25 retain its integrity through the 40-year term.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

94 1 The VIP is working on alternatives to the 2 inspection recommendations, so --

3 CHAIRMAN ARMIJO: But basically, they're 4 not inspectible?

5 MR. INCH: Not currently, that's correct.

6 CHAIRMAN ARMIJO: Okay. So you're really 7 relying on the analysis and the mitigation afforded 8 by the water chemistry?

9 MR. INCH: That's correct.

10 CHAIRMAN ARMIJO: Okay.

11 MR. INCH: So the effect of effluence is 12 not insignificant on the core shroud. It's a 40 to 60 13 percent increase at peak locations in the core barrel 14 there, and you know, that's because we're loading 15 higher batch fractions and the higher power bundles 16 are getting closer. So there is a, it does increase 17 effluence.

18 We have taken that fluence out through the 19 60-year term, looked at the peak fluence. We stay 20 within the currently accepted range, where hydrogen 21 water chemistry will remain effective.

22 MEMBER SHACK: What is that end of life 23 fluence?

24 MR. INCH: Let me get back to you. It's 25 less than 10 to the 22, I know that.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

95 1 MEMBER SHACK: It's cold comfort, but --

2 MR. INCH: It's above the threshold by 3 which radiation-assisted crack growth rate 4 acceleration is expected to occur. We also have 5 reduced ductibility of the materials.

6 CHAIRMAN ARMIJO: Sure.

7 MR. INCH: So we're within, we're applying 8 the VIP guidance.

9 MEMBER SHACK: The normal guide for 10 effectiveness of hydrogen water chemistry, somewhere 11 around three times ten to the 21, and it's sounds like 12 you're probably pushing that.

13 MR. INCH: Towards the end of the 60 14 years. Yes, we'll be pushing that number. But let me 15 verify, get you a good number on that. But so that 16 covers the slide, I think.

17 CHAIRMAN ARMIJO: Not really. Your last 18 bullet, I just, I think it's -- I have to argue with 19 that statement, because your actions are much better 20 than the words on this chart.

21 The fluence does everything. It does 22 nothing good for you except make power. Your 23 radiolysis rate goes up in proportion to the power 24 uprates. So that means the water chemistry gets more 25 aggressive.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

96 1 But you're compensating that by increasing 2 your hydrogen input rate by the same ratio.

3 MR. INCH: Yes.

4 CHAIRMAN ARMIJO: So you are addressing 5 that. Radiation hardening is going to push things in 6 the wrong direction. So I looked at your various 7 documents, and you're doing everything that I think 8 can be done, that addresses the mechanism of this 9 stress corrosion cracking, either IASCC or IGSCC.

10 But I just take exception to that 11 statement, that it doesn't represent a significant 12 increase in potential, because I think it really does, 13 and your actions indicate that you kind of think so 14 too. So I don't know where that statement came from.

15 But maybe you want to get rid of it in the full 16 Committee.

17 MR. INCH: We don't need to debate that, 18 except -- the flow-induced vibration of the internal, 19 Nine Mile's well in the pack of the GE operating 20 experience for the flow rates that were taken in the 21 Unit 2. The components that are really impacted are 22 the shroud head separator assembly, because you've got 23 the higher steam flows coming up through it.

24 The jet pumps to a lesser extent. As I 25 said, it's a 1.9 percent effect there versus an 18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

97 1 percent on a steam flow.

2 DR. WALLIS: So the effect is really a V-3 squared effect? Is that what it does?

4 MR. INCH: It's a turbulent -- that's how 5 it's evaluated, yes. For those internals, it's a 6 velocity squared due to turbulent loading.

7 DR. WALLIS: Resonance or anything?

8 MR. INCH: No. They do a separation 9 evaluation to any vortex setting, and that's the 10 standard procedure that GE's used. The peak stresses 11 for that shroud head remain less than 5,000. GE uses 12 a 10,000 psi criteria. So the internals really are 13 robustly made. There's significant margin to any FIV 14 issues.

15 The top head region where you have the 16 higher steam flow, those velocities remain very low, 17 where you have the spray nozzles and the head or the 18 head vent lines. So those stay below two feet per 19 second, and the cross-flow configuration has been 20 taken into account, and there's large margins there.

21 So the conclusion is, you know, pretty 22 clear that there's no impact or detrimental effects on 23 any of the internals due to potential for the FIV.

24 Structural effects. You know, the higher 25 power levels, you do have higher internal pressure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

98 1 differences, and there's some small temperature 2 changes. All the analyses are done consistent with 3 the original design bases. For Unit 2, there's really 4 no structural change has been made to the internals 5 that need to be considered. As I said, the 6 thermohydraulic changes are fairly straightforward.

7 With the pressure differences and the 8 temperature changes, there's a little bit change in 9 the carry-under fractions. The way GE does these 10 analyses is with scaling factors to the original 11 design, and with that, you know, for example the core 12 plate and core shroud goes from 11,000 to about 13 14,000, and that's with primary membrane bending is 14 limiting, with an allowable of 21,450 psi.

15 So the shroud head bolt. The limiting 16 component there is the T bolt and bearing stress, and 17 that goes from 8,000 to 13,500, with an allowable of 18 18,000. Now that shroud head bolt analyses is taking 19 credit for the reduced number of shroud head bolts 20 than we actually currently have installed. So it's a 21 conservative evaluation.

22 So all the usage factors really didn't 23 have for the internals, they didn't have a significant 24 change. The only one of note was really the shroud 25 went from .43 to .507. That's primarily due to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

99 1 slightly larger temperature variation on heat up and 2 cool-downs. That's not a high cycle fatigue.

3 So all the internal components are fully 4 qualified, and as I mentioned previously, the core 5 shroud flaw evaluations that we work have been updated 6 to reflect the higher pressure differences, the higher 7 fluences, reflective of the power uprate condition.

8 We covered pretty well in the questions 9 the, you know, what's been done for IGSCC and IASCC.

10 It's procedurally controlled. The program that's been 11 implemented has always considered, you know, aging 12 effects and the higher fluence level. So the 13 selection of the components and the intervals that are 14 selected aren't impacted by the higher fluence levels.

15 They're still fairly conservative intervals for all 16 the components.

17 Like for the shroud, it's a maximum of ten 18 years, even with hydrogen water chemistry and 19 ultrasonic inspections. We talked about the hydrogen 20 water chemistry and noble metals. There is an 21 increase in the hydrogen, just to keep, maintain the 22 three to one molar ratio in the downcomer.

23 CHAIRMAN ARMIJO: How do you monitor the 24 molar ratio water chemistry program?

25 MR. INCH: At Unit 2, the implementation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

100 1 of the hydrogen water chemistry currently uses molar 2 ratio. We are evaluation the recently-issued staff 3 approved BWRVIP-62-Alpha guidance, where the staff has 4 allowed, on an interim basis, to use molar ratio. But 5 they want to see electrochemical potential monitoring 6 being performed, to credit the hydrogen water 7 chemistry. We haven't implemented that at Unit 2 at 8 this time.

9 CHAIRMAN ARMIJO: Yeah. Instrumentation 10 is tough. It's not necessarily survivable.

11 MR. INCH: Yes. That's a very challenging 12 request from the staff right now.

13 CHAIRMAN ARMIJO: Yes, yes. But molar 14 ratio gives you good indication that it's working.

15 MR. INCH: Yes.

16 CHAIRMAN ARMIJO: You have, also you have 17 online noble metal capability, so you don't have to do 18 this during an outage.

19 MR. INCH: Yes. We implemented, we were 20 one of the first plants to implement online. We did 21 it in 2008, and it's done on a yearly basis, and it 22 works. It's about two, two and a half weeks every 23 year done, at least 90 days after the new fuel is 24 installed, and it's working well for us.

25 It's much easier to do and less of a plant transient NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

101 1 than the offline process.

2 MEMBER SHACK: Thank you, and you don't 3 have to -- I mean this goes on forever. You don't 4 ever have to do an offline noble metal injection 5 again?

6 MR. INCH: Yes. That's --

7 MEMBER SHACK: That's the goal.

8 MR. INCH: That's the qualification of the 9 process, yes, that you don't have to ever do an 10 offline application. Yes, the details of the process 11 are, you know, I don't think we probably need to get 12 into. But it's a different particle size, much finer.

13 It's engineered to penetrate deeper into cracks, and 14 so --

15 CHAIRMAN ARMIJO: So this is platinum that 16 you're added or not palladium?

17 MR. INCH: Yes. I believe with online, 18 they eliminated the, I think it was rhodium that they 19 had in there. But it's only platinum. So it's a 20 different cocktail that they're using. But it's 21 fundamentally the same.

22 CHAIRMAN ARMIJO: Okay.

23 MR. INCH: I think we already talked about 24 the control blade cracking. One of the impacts of 25 power uprate is scaling of the reactor pressure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

102 1 vessel, you know, nozzles, and one of the -- so the 2 scale factors were applied to the design bases fatigue 3 usage, accounting for both 40 and 60 years in design 4 bases.

5 When we get our license renewal for 60 6 years at Unit 2, it was identified that the feedwater 7 nozzle and another location in feedwater had the 8 potential to exceed one in the license renewal term.

9 At that time, we took a hard look at, you know, what's 10 the best way to approach this, and you know, design 11 bases fatigue usage calculations are usually very 12 conservative, and they take up a design cycle, and a 13 number of design cycles.

14 So when we looked at it, it was clear to 15 us that we could optimize, you know, get a more 16 realistic usage factor by actually more accurately 17 trending. So we committed for the locations that were 18 predicted to be above one, to implement a fatigue 19 monitoring program, such that long before we would 20 approach one, we would be predicting it and could plan 21 any appropriate actions.

22 Those remain the case for the power uprate 23 conditions. The scaling of the -- well, before I go 24 to that, the one location that we did select for 25 fatigue monitoring using stress-based monitoring was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

103 1 the feedwater nozzle location. That's not unusual for 2 the BWRs. Where that location is part of power 3 uprate, we did a fatigue, a refined fatigue usage 4 calc.

5 MEMBER SHACK: Oh yeah. I guess what 6 caught my eye was computing usage with FatiguePro, 7 which has generally not been received well, unless 8 there's a new version of FatiguePro that eliminates 9 the one stress factor kind of approach.

10 MR. INCH: The numbers I'm showing here, 11 this is an important clarification; I'm on Slide 62, 12 these are based on design, not FatiguePro. So the 13 numbers we're quoting here for the EPU 40-year CUF are 14 a refined design basis usage for the 40 year term, not 15 keyed to FatiguePro.

16 But as you can see, the standard 17 multiplication factor for license renewal is a 1.5 18 factor on, you know, for the additional 20 years.

19 Even with the refined usage, we would still predict 20 the stainless steel clad portion of the feedwater 21 nozzle safe end to be above one.

22 So we're using FatiguePro right now. It 23 was first, the software was first installed in 2008, 24 as a simplified way and a more accurate way to count 25 cycle. We are doing the stress-based monitoring of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

104 1 this location, and the current FatiguePro software 2 does use the simplified greens (ph) function. So the 3 RIS is applicable.

4 The EPU scaling is relatively small. It's 5 a six percent to 15 percent change, and --

6 MEMBER SHACK: Now does that include an 7 environmental factor?

8 MR. INCH: No.

9 MEMBER SHACK: What would happen if I put 10 in an environmental factor?

11 MR. INCH: This usage factor is a design 12 bases usage factor. The power, the license renewal 13 provisions have evaluations for environmental effects 14 in the license renewal term. So the FatiguePro 15 monitoring does include environmental usage, and I 16 believe there was an environmental usage evaluation 17 done.

18 I would have to get back to you on this 19 particular nozzle, on how environmental fatigue 20 affects these numbers.

21 MEMBER SHACK: If you could go back to the 22 next bullet, it says there's still a discussion going 23 on, I guess.

24 MR. INCH: Well, yes. You know, the whole 25 industry is working to address the RIS. There is a --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

105 1 Structural Integrity is working on a FatiguePro update 2 that would address the full NB-32 fatigue methodology, 3 and to include environmental fatigue usage in the 4 rules. You know, right now, we're not required in 5 using this to manage below one in the 40 year term.

6 So we enter the license renewal term in 7 2026 at Unit 2, so there's quite a bit of time to get 8 this right. We are committed to implementing, you 9 know, fatigue monitoring, and as part of that, the RIS 10 requires us to evaluate that, you know, before we're 11 actually crediting it for usage below one. So that is 12 what our current status us.

13 CHAIRMAN ARMIJO: George, could you go 14 back to Slide 62?

15 MR. INCH: Yes.

16 CHAIRMAN ARMIJO: I don't understand how 17 the cumulative usage factor at current license thermal 18 power is higher than that at EPU. Am I reading this 19 thing wrong, or --

20 MR. INCH: Well, that's the refined 21 calculation.

22 CHAIRMAN ARMIJO: But they're two 23 different calculations?

24 MR. INCH: Yes. The original calc had a, 25 for multiple events, had --

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

106 1 CHAIRMAN ARMIJO: Well, you would say that 2 was a crude calculation?

3 MR. INCH: It was conservative, and you 4 know, there's a way --

5 MEMBER SHACK: Unconcerned. It was less 6 than one. That was all you needed.

7 MR. INCH: It's the way they did the 8 calcs. If you were less than one, you were done.

9 Everybody knew they were conservative, so --

10 CHAIRMAN ARMIJO: Okay. So now this is a 11 refined?

12 MR. INCH: Yes.

13 CHAIRMAN ARMIJO: The EPU is a refined?

14 Okay.

15 MR. INCH: Now when I say "refined," what 16 they did is they went back and looked at each 17 particular event, and then for each event, there was 18 a thermal FEA, where they looked at what the actual 19 cycling on the stress --

20 CHAIRMAN ARMIJO: It was detailed.

21 MR. INCH: It was a detailed accumulation 22 for each event.

23 MEMBER SHACK: Now it's got four 24 significant figures rather than three?

25 CHAIRMAN ARMIJO: Yeah, right. It's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

107 1 really good.

2 (Simultaneous speaking.)

3 CHAIRMAN ARMIJO: So it's an analysis of 4 -- so you did cycle by cycle you did?

5 MR. INCH: Yes. There's, to get these 6 numbers, they started from a natural baseline, and 7 then they refined each event, and then refined each 8 cycle and what the usage for each cycle is.

9 10 CHAIRMAN ARMIJO: And then they added them 11 up?

12 MR. INCH: And then added them up.

13 CHAIRMAN ARMIJO: Okay, got it.

14 DR. WALLIS: What is this EPU scaling 15 factor small mean? What's that?

16 MR. INCH: You know, relative to what does 17 EPU do to the usage factor?

18 DR. WALLIS: But does it mean that without 19 the refined calculation, it would actually increase 20 the CUF above one?

21 MR. INCH: I'm not sure I understand here.

22 DR. WALLIS: Well, to me, it implies that 23 the EPU increases things by 6 percent to 15 percent.

24 MEMBER SHACK: Right.

25 DR. WALLIS: So if you use the old CUF NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

108 1 calculation, you get something closer to one?

2 MR. INCH: That's right.

3 DR. WALLIS: Okay. So you need to refine 4 the calculation?

5 MR. INCH: Yes sir.

6 DR. WALLIS: Thank you.

7 CHAIRMAN ARMIJO: This scaling, it's a 8 stress, scaling on stress?

9 MR. INCH: Yes.

10 CHAIRMAN ARMIJO: Certainly not cycles.

11 MR. INCH: Right. It's a scaling on 12 stress.

13 CHAIRMAN ARMIJO: Okay, okay.

14 MR. INCH: That's all I have.

15 CHAIRMAN ARMIJO: Well, we have a dilemma 16 here. We could take a quick look here. The staff, 17 let me ask the staff. Could they get their 18 presentation done in half an hour?

19 MR. GUZMAN: Actually, the assigned 20 presenter is not here.

21 CHAIRMAN ARMIJO: Well, that answered my 22 question. I think we'll take an early lunch, and 23 we'll be back at 11:30, unless somebody's got an 24 objection to that. At 12:30, I'm sorry.

25 (Simultaneous speaking.)

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

109 1 CHAIRMAN ARMIJO: Okay. We're going to 2 take a lunch. Be back at 12:30. Thank you, Bill.

3 (Whereupon, at 11:31 a.m., a luncheon 4 recess was taken.)

5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

110 1 A F T E R N O O N S E S S I O N 2 12:57 p.m.

3 CHAIRMAN ARMIJO: Okay, gentlemen. We're 4 going to reconvene. For those who don't know, that 5 jackhammer is actually outside. It's not in the 6 building, so structurally the building is sound, I 7 think.

8 MEMBER SHACK: Of course, there's 9 resonance.

10 CHAIRMAN ARMIJO: Right. So we'll go 11 ahead. Rich, you put your group is up.

12 MR. GUZMAN: Good afternoon again. My 13 name is Rich Guzman. Before we transition over to the 14 staff giving their presentations on the materials and 15 mechanicals and civil engineering reviews, the 16 licensee requested to give some clarifications from 17 the morning meeting. I thought this would be a good 18 time to provide that, before we start delving into the 19 materials and steam dryer discussions.

20 MR. WENGLOSKI: Good afternoon. Phil 21 Wengloski, Constellation Energy Nuclear Group. I just 22 wanted to clarify my response. It was brought to my 23 attention on the control blade cracking issue, that my 24 answer could have been taken one of two different 25 ways.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

111 1 The response I intended to give, which was 2 consistent with George's Slide 60, is that we do not 3 have the control blade models, marathon models as 4 susceptible to the cracking. We may have other 5 marathon models present in the core, but not the 6 models that are susceptible to cracking.

7 CHAIRMAN ARMIJO: Is yours a C lattice 8 plant?

9 MR. WENGLOSKI: That's correct.

10 CHAIRMAN ARMIJO: Yes, but I saw the 11 comment about C lattice plants having susceptibility 12 to this problem, and I think that's very -- I don't 13 want to (papers shuffling). Anyway, it doesn't make 14 any sense to me. But you do have marathon blades in 15 a C lattice plant?

16 MR. WENGLOSKI: Correct.

17 CHAIRMAN ARMIJO: And GE has told you 18 that's not susceptible?

19 MR. WENGLOSKI: Right. The models that 20 we're using are not susceptible to cracking.

21 CHAIRMAN ARMIJO: Time well tell, but 22 okay. But you do have marathon blades?

23 MR. WENGLOSKI: Correct.

24 CHAIRMAN ARMIJO: Okay.

25 MR. WENGLOSKI: Any further questions?

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

112 1 CHAIRMAN ARMIJO: No.

2 MR. WENGLOSKI: Thank you for that.

3 MR. INCH: Yes, George Inch. The peak 4 effluence were approaching 22 EFPY (ph), probably out 5 two years. So it's approximately 2E to 21 each 6 location on the H4 well, projected out at EPU 7 effluences until the end of 40 years would be 2E to 8 the 21. Then it goes to 4E to the 21 at that H4 9 location.

10 CHAIRMAN ARMIJO: That's at 60 year or 54 11 --

12 MR. INCH: The 54 EFPY in 60 years, yes.

13 So it looks like we're just below at the 60 year mark 14 --

15 MEMBER SHACK: Well, people have various 16 opinions.

17 CHAIRMAN ARMIJO: About how long it will 18 last, how long it will work.

19 MR. INCH: The top guide clearly is above 20 that at these locations.

21 MR. GUZMAN: Okay. With that, we'll go 22 ahead and start our presentation. Pat Purtscher will 23 be giving his brief on the materials engineering 24 review. Pat, you want to get started?

25 MR. PURTSCHER: Okay. We looked for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

113 1 reactor vessel embrittlement, and there are several 2 factors that we always consider. The EPU is going to 3 increase the total fluence in the vessel, so we're 4 going to check initially the material surveillance 5 program.

6 That's the fundamental program we use to 7 monitor. We build with the limiting materials in the 8 plants. At Nine Mile, they are enrolled in the BWR 9 VIP integrated surveillance program.

10 As part of that program, they're not a 11 host plant. They're limiting materials are 12 characterized by capsules that are in other plants, 13 BWR plants. So the change in effluence for Nine Mile 14 doesn't directly affect the capsules that will be used 15 to characterize the limiting beltline materials.

16 They do still have two capsules in their 17 reactor vessel that are being irradiated, but there's 18 no current plans to use those at this point. They're 19 backup capsules. Some of the other factors that we 20 look at are all related to Appendix G requirements.

21 The PT limits, the upper shelf energy projections for 22 all the materials in the beltline, and then there's an 23 inspection exemption that's been granted for the circ 24 weld on the vessel.

25 So we examine that to see if that, how NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

114 1 that changes with the increased fluence. In all 2 cases, they have passed, they still meet these 3 requirements from Appendix G, with significant margins 4 remaining. So there really is no concern from the 5 staff, based on this increased fluence due to the EPU.

6 Next slide. We're now going to look at 7 the internals and the core support materials. Again, 8 due to the -- now that the fluences are higher on the 9 internals than they're on the reactor vessel itself, 10 and as they mentioned in their presentation, now the 11 top guide, the shroud and the core plate are all 12 exceeding what we take to be the threshold for 13 radiation-assisted stress corrosion cracking.

14 So now we consider them to be susceptible 15 materials once they get above that threshold. To 16 address that, they have instituted, you know, using 17 BWRVIP-62, that's been characterized as a Category 3 18 plant, they're using noble metal additions to mitigate 19 the possibility of stress corrosion cracking. This is 20 following all the EPRI guidelines.

21 So they are following all the industry 22 standards, and the staff sees no issues related to the 23 increased fluence.

24 MEMBER SHACK: Well, there was sort of a 25 discussion this morning that as a Category 3B plant, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

115 1 where they're only looking at molar ratio, you guys 2 take a somewhat skeptical view of that, and you're 3 asking them to do ECP measurements.

4 MR. PURTSCHER: Well, but they did do one 5 time measurement of EPC when they instituted noble 6 metal online additions. So they did it once, and kind 7 of validated the secondary parameters that they're 8 monitoring.

9 So as long as they monitored, as long as 10 they checked that once, and there have been no major 11 changes to the noding and the environment, we feel 12 that's enough justification. So with that one time 13 measurement, to validate it.

14 So really that's, to the vessels and the 15 internals, that's really the summary. Just to say it 16 again, the EPU has a minimal effect on the 17 embrittlement issues, the upper shelf values, the PT 18 limits and the surveillance program. These three 19 internal components we've talked about, that exceeded 20 the threshold for IASCC, are being managed by BWRVIP 21 documents that have been accepted the staff.

22 So this, since there should be no problem 23 associated with the increased fluence related to the 24 EPU. So we're satisfied with their submittal. Okay.

25 Any questions?

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

116 1 MR. TSIRIGOTIS: My name is Alexander 2 Tsirigotis. I work in the Mechanical and Civil 3 Engineering Branch, which reviews the EPU impact on 4 the structural integrity of the system structural 5 components.

6 Mainly, the pressure retaining components 7 and the supports, the reactor pressure vessels and 8 supports, the control mechanisms, reactor situation 9 pumps and supports, reactor pressure vessel internals 10 and core support --, and the seismic and dynamic 11 qualifications of the mechanical and electrical 12 equipment.

13 The approach to evaluate the Nine Mile 14 Point 2 EPU impact on the structural integrity of the 15 -- follows the guidance which is provided in the 16 staff-approved Z topical report entitled "Constant 17 Pressure Power Uprate," and it's licensing report 18 NEDC-33004P-A.

19 This is commonly referred to at the BWR 20 EPU as the CLTR. The CLTR also refers into two other 21 Z topical reports, the ELTR-1 and ELTR-2, which 22 provide more detail on the generic guidelines and 23 generic evaluations.

24 These two topical reports, together with 25 associated NRC staff position paper on safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

117 1 evaluation, incorporated in the topical reports, have 2 been applied for all BWR extended power uprate 3 submittals, since the NRC review and acceptance or 4 endorsement for --.

5 The staff approved the CLTR is for 6 constant pressure power uprates, commonly referred to 7 as CPPUs. With a power increase up to 20 percent from 8 the plant's 100 percent original thermal power, and 9 with a minimum and maximum steam and feedwater flow 10 increases up to about 24 percent.

11 The CPPU approach assumes that the maximum 12 reactor pressure dome remains unchanged from the 13 licensed power level, and the dome temperature is also 14 unchanged. The Nine Mile Point 2 proposed EPU does 15 not change the current plant maximum normal operating 16 reactor dome pressure, and it increases the original 17 thermal power by 20 percent, with a maximum steam and 18 feedwater flow increases of nearly 24 percent.

19 Therefore, we found that it meets the limitations of 20 the topical reports.

21 In addition to the main steam and 22 feedwater piping, which are the main systems that are 23 affected by the EPU due to its increase in the flows, 24 other piping systems that are mostly affected by the 25 EPU due to increased system temperatures and pressures NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

118 1 within those systems are the extraction steam, the 2 feedwater heater vents and drains, the moisture 3 separator heater vents and drains, and the auxiliary 4 condensate.

5 The licensee's evaluation of flow-induced 6 vibration levels for piping follows the vibration 7 acceptance criteria found in ASME OM-S/G Part 3, which 8 provides requirements for pre-operational and initial 9 start-up vibration testing of nuclear power plant pipe 10 and systems.

11 The OM-S/G Part 3 provides monitoring 12 requirements, acceptance criteria, and it includes 13 equations for calculating the vibratory alternating 14 stress for Class 1 and Class 2 and 3 piping, and for 15 thickness for Class 1 piping. It also contains 16 guidance and visual inspection methods, displacement 17 methods and vibrational deflectional values for 18 various pipe sizes and spans.

19 The structural evaluations for the system 20 structures and components under EPU conditions employ 21 the current plant design base methodology and 22 acceptance criteria. The structural evaluations also 23 met design basis code and record allowable values.

24 That's why we found there is reasonable assurance 25 that the plant SSAs (ph) important to safety as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

119 1 structurally adequate to perform the internal design 2 functions under the EPU conditions.

3 MEMBER SHACK: But you can't really be 4 sure they're not going to need any modifications to 5 the pipe supports until you run that FIV test, right?

6 I mean they could well need to do something.

7 MR. TSIRIGOTIS: The SIV test?

8 MEMBER SHACK: The FIV test.

9 MR. TSIRIGOTIS: Oh yes. You are right 10 about that. During the -- so far, the evaluations 11 that they have done, they have found out that they 12 don't need any piping modifications or any support 13 modifications or additions. During the start-up 14 testing, they had a plan in place which they will 15 monitor the vibration levels, and if there is a need 16 for any modifications through the corrective code, 17 they will provide corrective actions to do that work.

18 CHAIRMAN ARMIJO: But that will indicate 19 that their analysis wasn't really that good --

20 (Simultaneous speaking.)

21 MR. TSIRIGOTIS: They have already done --

22 I understand what you're saying. They have already 23 done walk-downs to establish the baseline. From those 24 walk-downs, they have identified whether there is an 25 issue with the vibration levels that the pipe's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

120 1 supposed to see.

2 CHAIRMAN ARMIJO: That's where they'll put 3 instrumentation.

4 MR. TSIRIGOTIS: Right, right. They have 5 instrumentation. They have -- there are locations 6 which have been gauged, strain gauges, and --

7 CHAIRMAN ARMIJO: Accelerometers.

8 MR. TSIRIGOTIS: Accelerometers where 9 needed. The OM-S/G Part 3 is being applied in just 10 about every power uprate, and it's during the initial 11 start-up also for the plants.

12 MEMBER SHACK: What's been the experience?

13 I mean if they found they need to add supports, or the 14 analysis have been generally satisfactory?

15 MR. TSIRIGOTIS: So far from what we've 16 seen in the power uprates from the walk-downs, they 17 haven't identified, from what I know at least, they 18 haven't identified an issue where they needed to add 19 something, mainly because when they established the 20 baseline, they project that baseline to the EPU flows, 21 with velocity square, which is customary to do so. If 22 they find an issue, then they take a corrective 23 action.

24 DR. BONACA: I have a question regarding 25 environmental qualification.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

121 1 MR. TSIRIGOTIS: Uh-huh.

2 DR. BONACA: There is a statement in the 3 SER that says that, you know, for inside containment, 4 licensee noted that post local conditions, radiation 5 levels will increase above the levels using the 6 current EQ program. Then it says the NRC staff 7 reviewed the increase EQ evaluation and confirmed that 8 the increase should not affect the qualification of 9 the equipment. What would be the basis for that?

10 MR. TSIRIGOTIS: I'm sorry. I can't hear 11 you very well. Are you reading from the SER, from the 12 staff SER?

13 DR. BONACA: Yes, yes, page 57.

14 MR. TSIRIGOTIS: 57. That's not my page.

15 (Simultaneous speaking.)

16 DR. BONACA: Yeah, inside containment.

17 MR. TSIRIGOTIS: Is that Section 2.2.5, 18 seismic and dynamic qualifications of mechanical and 19 electrical equipment?

20 DR. BONACA: It must be, yes. Do you have 21 the page?

22 (Off record discussion.)

23 MR. TSIRIGOTIS: I don't see that. That's 24 not in my evaluation. That's the same part. I think 25 it might be in the electrical part. Anyway, it's in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

122 1 the SER.

2 (Simultaneous speaking.)

3 DR. BONACA: -- stand by. Clearly, the 4 radiation field must be higher. Why is --

5 (Simultaneous speaking.)

6 MR. TSIRIGOTIS: (reading to self) 7 MR. GUZMAN: What we can do is we'll take 8 that -- I just need to get back to the safety 9 evaluation, and find out the technical staff --

10 DR. BONACA: What's the basis for it, yes.

11 MR. TSIRIGOTIS: This is not my writing.

12 I will find out whose review this falls under, and 13 we'll get back to you.

14 DR. BONACA: Okay, I appreciate it.

15 Thanks.

16 CHAIRMAN ARMIJO: Okay. Any other 17 questions from the committee?

18 (No response.)

19 CHAIRMAN ARMIJO: All right. I think 20 we're ready to move on to the next topic.

21 MR. GUZMAN: The next topic is intended to 22 be in closed session.

23 CHAIRMAN ARMIJO: So we're going to go 24 into closed session. Again, remind everyone here, it 25 should only be folks from Nine Mile and their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

123 1 consultants, and make sure the bridge line is closed.

2 (Whereupon, at 1:15 p.m., the meeting 3 adjourned to closed session.)

4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

124 1 O P E N S E S S I O N 2 4:35 p.m.

3 CHAIRMAN ARMIJO: If not, we're going to 4 come out of closed session and do a public session, 5 and at this point, I'll ask if there are any comments 6 for members of the public, either on the bridge line 7 or open the door so they can come in to this room. Is 8 there anyone on the bridge line who would like to make 9 a comment? If so, please identify yourself.

10 (No response.)

11 CHAIRMAN ARMIJO: Maybe the bridge line 12 isn't open yet. Peter will -- is it open now?

13 DR. YARSKY: The bridge line is open.

14 CHAIRMAN ARMIJO: Okay. The bridge line's 15 open. Is there anyone, a member of the public, who 16 would like to make a comment concerning this review?

17 If so, please identify yourself.

18 (No response.)

19 CHAIRMAN ARMIJO: Okay. How about someone 20 in here, n this meeting room?

21 (No response.)

22 CHAIRMAN ARMIJO: Okay. I'm going to take 23 that as there's no comment from the public. At this 24 point, I'd like to turn it over, just as far as 25 Subcommittee discussion. I'd just like to go around NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

125 1 the table, and see if there's any added points that 2 the members would like to make, and then after that, 3 maybe try and give the staff and licensee some 4 guidance on the full Committee meeting, because this 5 obviously all has to get done in two hours. So that's 6 the challenge. Joy?

7 MEMBER REMPE: Some education. During the 8 discussion, this last topic, there was a mention of an 9 upcoming audit. Could you provide a little more 10 background? I think Stephen was the one who mentioned 11 it and was talking to people in the crowd. What 12 exactly is going to happen here? Is there going to be 13 an end to end audit or what exactly is it?

14 DR. SHAH: This is Vik Shah. I think we 15 have to plan it out before we finalize what kind of 16 audit we'll be doing. I think we are going to review 17 the (breaking up) 194, and during that review, we will 18 be having an audit. I think we will have a (breaking 19 up).

20 MEMBER REMPE: I'm having trouble 21 understanding you.

22 CHAIRMAN ARMIJO: It's breaking up.

23 DR. BASAVARAJU: We have already submitted 24 a topical report.

25 MEMBER REMPE: Who submitted it? Say it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

126 1 again. Who submitted the topical?

2 DR. BASAVARAJU: BWR Vessel Internals 3 program. They submitted a topical report, BWR 194.

4 MEMBER REMPE: Okay.

5 DR. BASAVARAJU: And it just came in for 6 review, and that is the one which will summarize and 7 give all the steam dryer evaluation, the ACM and the 8 structural evaluation. So during that review, we were 9 planning to have an audit, but we have not still 10 identified the times or extent. So that's --

11 MEMBER REMPE: Thank you.

12 MEMBER BANERJEE: What is the time scale?

13 I don't want to go out of turn, because this is new 14 information. What is the time scale for review of the 15 topical and I assume it will come to us as well?

16 DR. BASAVARAJU: Yes.

17 DR. SHAH: It's about two years, right 18 Pani?

19 DR. BASAVARAJU: Yes. It's a topical 20 report. Because this is an important topical report, 21 we may accelerate it. But the typical topical report 22 reviews, NRC's time is for two years.

23 CHAIRMAN ARMIJO: Okay. So it won't help 24 us for Nine Mile. Bill, nothing. Said? No, any 25 comments.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

127 1 DR. BONACA: No. Well, a little input.

2 I thought in general that this was a good application.

3 I felt it was thorough and the steam dryer issue, 4 there are a number of questions which were raised 5 today. I think that I feel pretty comfortable with 6 what I saw.

7 CHAIRMAN ARMIJO: Thank you.

8 DR. BONACA: Anyway, I will make comments 9 to you.

10 CHAIRMAN ARMIJO: Yes, okay, in your 11 report. Mr. Wallis?

12 DR. WALLIS: Well, I thought on most 13 issues, Nine Mile Point people did a very good job.

14 I'm still working on the steam dryer. I'm still 15 puzzled, because I'm told that this small scale test 16 was only used to establish resonance, and yet I read 17 the report, the objective was to develop a bump-up 18 factor relating (coughing) to those anticipated at 19 EPU, to use in the acoustic circuit model.

20 I mean the whole thing says, the whole 21 purpose of the report is to develop numbers to put 22 into a model. I'm really puzzled by this assertion 23 that none of that was the case. I don't understand 24 that, and I'm still working on the numbers. I have 25 learned some things which have been very helpful about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

128 1 some of the issues I raise, and I thank the 2 participants for doing that for me.

3 CHAIRMAN ARMIJO: Sanjoy.

4 MEMBER BANERJEE: Nothing more than I said 5 already.

6 CHAIRMAN ARMIJO: Nothing more. Jack?

7 MEMBER SIEBER: I have no comments or 8 questions at this time.

9 CHAIRMAN ARMIJO: Okay, all right. Well, 10 my view is I think the Nine Mile people and staff are 11 very well prepared for this. I think we can beat the 12 steam dryer to death, but and we obviously can't, 13 won't be able to spend that much time at the full 14 committee meeting.

15 So that between the staff and the Nine 16 Mile, I think we really need one good presentation, 17 without any repetition at all. So you're going to 18 have to sort that out. I think the plant's in -- the 19 impression I got from the presentation, the plant's in 20 very good shape for EPU.

21 I think the work you've done on the 22 materials, and on the various upgrades and 23 modifications, that goes a long way to making me feel 24 pretty comfortable --

25 MEMBER SHACK: And they use that good NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

129 1 barrier clad --

2 CHAIRMAN ARMIJO: And they use my 3 cladding, so that's great.

4 (Laughter.)

5 CHAIRMAN ARMIJO: But I'm still surprised 6 at how conservative the fuel design is. It's got more 7 capability, but that's okay. But overall, I think 8 you're well-prepared. I think our problem will be to 9 manage the time, so that you get, the full Committee 10 gets a good feel for the entire plant, and that we 11 don't let the steam dryer dominate everything.

12 So that's going to be hard to do, but I 13 think since so many of us have heard this 14 presentation, and as soon as we get Mr. Wallis' report 15 and Mario's reports, we probably can sort out our 16 questions and focus down. But overall, I think you're 17 well-prepared. We'll work with Rich.

18 MR. GUZMAN: I was hoping I could close 19 out one quick action item, and I wanted to make sure 20 I responded to Dr. Bonaca's question and concern on 21 part of the safety evaluation, and I'll just restate 22 it. The section is part of the Electroengineering 23 review, under Environmental Qualifications for 24 Electrical Equipment.

25 The statement said that "The NRC staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

130 1 reviewed the licensee's environmental qualification 2 evaluation, and confirmed that the increase should not 3 affect the qualification of the EQ equipment located 4 inside containment." The question is why? Because 5 they should not. Does it or does it not?

6 The staff recognizes the obscurity in that 7 wording, and so it was in error, and we should or we 8 will correct that, and --

9 MEMBER SHACK: No, I think the question 10 was that the statement was made that it exceeded the 11 environmental qualification, and then the statement 12 followed that --

13 MR. GUZMAN: Okay.

14 MEMBER SHACK: It's still all right.

15 MR. GUZMAN: Still all right, okay.

16 MEMBER SHACK: It was that first line that 17 was the killer.

18 MR. GUZMAN: Okay, yes. So right. So the 19 preceding statement says the licensee noted that the 20 radiation levels would increase above the levels used 21 in the current EQ program.

22 MEMBER SHACK: Right.

23 MR. GUZMAN: And NRC staff review 24 confirmed that these increases should not affect the 25 qualifications. So I guess the question is why, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

131 1 if you go further in the safety evaluation, I mean 2 recognizing that the "should not" was not the 3 appropriate words. It should have said, for lack of 4 a better word, "would not" or "will not."

5 But further down in the safety evaluation, 6 it does go into the, you know, that the staff reviewed 7 the licensee's assessment of the effects of the 8 proposed EPU on EQ equipment, and ultimately we 9 reviewed it against 10 C.F.R. 5049, which is the 10 electrical equipment qualification.

11 MEMBER SHACK: Maybe you should give 12 something like "Despite this step."

13 MR. GUZMAN: Right. So we recognize that 14 the wording needed to be tightened up. It certainly 15 should have been more definitive and explain it. So 16 we will make sure on the final --

17 DR. BONACA: This is an example of the way 18 that the information is provided. There were two 19 other, three other in the SER, I believe goes to the 20 outside containment portion. There is a statement 21 that simply says that's okay, and the question is why 22 is it okay?

23 I mean it's counterintuitive that if you 24 have a higher radiation field, it doesn't make any 25 difference. There has to be some reason why, and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

132 1 mean the qualification exceeded the value. Therefore, 2 there was margin. But something should be said.

3 MR. GUZMAN: And as you know, I mean the 4 intent is to give you the best product that we can for 5 the draft safety evaluation. But in parallel, what we 6 tried to is we actually send the draft safety 7 evaluation to the licensee. They provide some 8 comments to us and we will incorporate those comments, 9 as well as another round of quality check by the 10 staff, to strengthen the product, which would be the 11 final safety evaluation.

12 So there will be some changes, and we will 13 note that one, as well as the other ones that you did 14 note.

15 DR. BONACA: Okay, thank you.

16 CHAIRMAN ARMIJO: Okay. Well with that, 17 I think I'd again like to thank Nine Mile Point and 18 the staff. Good presentations. Good discussion, and 19 with that we're going to adjourn the meeting. Thank 20 you.

21 (Whereupon, at 4:46 p.m., the meeting was 22 adjourned.)

23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

CRS Subcommittee on Power Uprates NRC Staff Review Nine Mile Point, Unit 2 Extended Power Uprate October 5, 2011

Opening Remarks Louise Lund Deputy Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 2

Opening Remarks NRC staff effort

• Pre-application review and public meetings

• Acceptance Review

• Requests for additional information Challenging review areas included:

• Steam dryer stress analysis

• Thermal Hydraulic Design: Stability / ATWS-Stability

• Interim Methods: Applicability of GE Methods to Expanded Operating Domains Draft SE - no open technical issues 3

Introduction Rich Guzman Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 4

Introduction Objective

Background

• NMPNS EPU Application - May 27, 2009

• 3467 to 3988 MWt, 15 % increase (521 MWt)

• 20 % increase above original licensed thermal power EPU Review Schedule

• Followed RS-001

• No linked licensing actions under review

• Supplemental responses to NRC staff RAIs EPU Implementation 5

Topics for Subcommittee NMPNS EPU Overview Anticipated Transient without Scram and Stability Fuel Methods - IMLTR Materials and Mechanical & Civil Engineering Steam Dryer Analysis Review of open items / Conclusions 6

Nine Mile Point, Unit 2 Extended Power Uprate ACRS Subcommittee Meeting Materials Engineering Patrick Purtscher Vessel & Internals Integrity Branch October 5, 2011 1

Reactor Vessel Embrittlement

• EPU increases total fluence on RV

• RV Material Surveillance Program, Uses BWRVIP ISP, but not a host plant, still has 2 capsules in RV

• Meets Appendix G requirements for P-T limits, USE projections, circ weld inspection exemption, significant margins remain 2

Internals and Core Support Materials

• EPU increases total fluence on RV Internals

• Top guide, shroud, and core plate all exceed IASCC threshold for susceptibility

• BWRVIP-62, Category 3b plant - uses NMCA for mitigation of SCC, follows EPRI guidelines for effectiveness 3

Conclusion EPU has minimal impact on RV embrittlement issues Three RVI components exceed threshold for IASCC, but adequately managed; Core plate - BWRVIP-25-A Top guide - BWRVIP-26-A Shroud - BWRVIP-76-A 4

QUESTIONS 5

Nine Mile Point, Unit 2 Extended Power Uprate ACRS Subcommittee Meeting Mechanical & Civil Engineering Review Alexander Tsirigotis Mechanical & Civil Engineering Branch October 5, 2011 6

Review Scope EPU impact on structural integrity of systems, structures, and components (SSCs):

• Pressure-retaining components and their supports

• RPV and supports

• Control rod drive mechanisms

• Reactor recirculation pumps and supports

• RPV internals and core supports

• Seismic and dynamic qualification of mechanical and electrical equipment.

7

Review Results Piping systems that are mainly affected from the EPU:

- Main steam, condensate, feedwater, extraction steam and heater vents and drains.

- Evaluation for FIV levels of piping in accordance with the ASME OM -S/G Part 3.

- There are no modifications to piping and pipe supports that are required due to EPU.

Structural evaluations of SSCs at EPU conditions employed current plant design basis methodology and acceptance criteria.

Structural evaluations met design basis code allowable values. 8

Conclusion Reasonable assurance that plant SSCs important to safety are structurally adequate to perform intended design functions under EPU conditions.

9

QUESTIONS 10

ower / Flow Operating Map 1

ACRS Subcommittee Presentation Nine Mile Point 2 Extended Power Uprate October 5, 2011

Nine Mile Point 2 Extended Power Uprate NMP2 EPU Overview Sam Belcher SVPSite Operations

MP2 EPU Agenda Overview Sam Belcher Plant Modifications Dale Goodney Power Ascension Testing Phil Amway Anticipated Transient Without Scram (ATWS) Phil Amway and Stability CLOSED SESSION Fuel Methods (IMLTR) Phil Wengloski Material, Mechanical/Civil Engineering Topics George Inch CLOSED SESSION Steam Dryer Analysis George Inch 3

MP2 EPU Overview GE BWR 5 Mark II Containment Thermal Power

- Original License Thermal Power (OLTP) 3323 MWth

- Current License Thermal Power (CLTP) 3467 MWth Stretch Uprate 104.3% (1995)

- EPU Thermal Power (120% OLTP) 3988 MWth Implement 2nd Quarter 2012 4

MP2 EPU Overview (contd)

Attributes of the NMP2 constant pressure power uprate:

- NMP2 is not requesting any Containment Accident Pressure (CAP) credit to support ECCS NPSH

- No new fuel introduction; the current core and the EPU core are composed entirely of GE 14 fuel

- The Alternative Source Term for accident radiological consequences was previously implemented using the EPU power level as a base assumption NMP2 has implemented Maximum Extended Load Line Limit Analysis (MELLLA) expanded operating domain 5

MP2 EPU Overview (contd)

The NYISO has reviewed and approved the EPU full power output no grid modifications are necessary The first two phases of EPU modifications have been installed The third and final phase of modifications needed to support EPU operation will be complete by 2nd Quarter of 2012 6

Nine Mile Point 2 Extended Power Uprate Plant Modifications Dale Goodney EPU Lead Project Engineer

ant Modifications General Approach Plant Parameters Installation Timeline Major Modifications NMP2 Plant Improvements 8

ant Modifications General Approach Engineering studies were performed to evaluate structures, systems and components to determine the plants ability to operate at EPU conditions

- Analyzed effects of increase in steam flow, feedwater flow, reactor power and electrical output

- Evaluations were based on NEDC33004PA, Licensing Topical Report Constant Pressure Power Uprate, Revision 4 (CLTR)

- Analyses are based on the target power level of 120% OLTP

- Operating Experience was evaluated and applied 9

ontd)

Design and operating margins were identified and evaluated for both NSSS and BOP systems Over 20 physical plant modifications were described in the License Amendment Request

- Restore Material Condition

- Instrumentation for data collection and analysis

- Upgrades to restore design and operating margin at EPU conditions Installation began in 2007 and will continue through 2012 Refueling Outage 10

ant Modifications Plant Parameter Changes Parameter CLTP EPU (104.3% OLTP) (120% OLTP)

Thermal Power (MWth) 3467 3988 Reactor Pressure (psia) 1035 1035 Rated Steam Flow (Mlb/hr) 15.002 17.636 Rated Feedwater Flow (Mlb/hr) 14.970 17.604 Generator Output (Mwe) 1211 1369 eedwater Temperature (°F) 425.1 440.5 11

ant Modifications Installation Timeline 2007 and 2008 2010 and 2011 2011 through 2012 Refueling Main Steam (MS) Line

• Replace 3rd Point Feedwater

• Upgrade Feedwater Pumps and Gear Sets Vibration Monitoring Heater

• Replace Feedwater Pump Motor Cables Strain Gages

• Recirculation Runback Initiation and Runback Rate

• Replace Feedwater Heater

• Replace High Pressure Turbine Partial Bypass Around the Drain Pumps and Motors

• Replace Low Pressure Turbine Cross Around Relief Condensate Valves Demineralizers

• Install Piping Vibration

• Replace Low Pressure Turbine Atmospheric Relief Monitoring Diaphragms

• Steam Dryer Modifications

• Install Shielding for

• Feedwater Heater Rerate Equipment Qualification

• Generator Isolated Phase Bus Duct Cooling Improvements

• Improve Main Transformer Cooling

• Instrument Replacement and Scaling

• Improve Turbine Building HVAC

• Turbine Building Closed Loop Cooling Enhancements

• Extraction Steam Expansion Joint Replacement

• Main Steam/Feedwater Pipe Supports 12

ajor Plant Modifications Condensate and Feedwater

- Feedwater Pump Upgrades

- Heater Drain Pumps and Motors

- Reactor Recirculation Runback Steam Path

- High Pressure Turbine

- CrossAround Relief Valves

- Moisture Separator Reheater and 5th/6th Point Feedwater Heater Requalification

- Steam Dryer 13

ajor Plant Modifications (contd)

Electrical/I&C

- Isophase Bus Duct Cooling

- Main Transformer Cooling

- Technical Specification Instrument Setpoints

- BOP Instrument Rescaling and Setpoints Auxiliary Support Systems

- Turbine Building HVAC

- Turbine Building Closed Loop Cooling 14

MP2 Plant Improvements NMP2 has implemented, or is planning to implement prior to EPU, a number of upgrades to restore margin, improve equipment reliability and reduce risk. Examples are:

- Replaced Third Point Feedwater Heaters in 2010

- Increased Standby Liquid Control Relief Valve Margin in 2010

- Performed Cooling Tower Upgrades in 2008 and 2010

- New Feedwater Pump Seals in 2012

- Replace Jet Pump Inlet Mixers in 2012

- Several PRArelated risk reduction improvements. Since 2008, Core Damage Frequency (CDF) has been reduced by 78%

15

Nine Mile Point 2 Extended Power Uprate Power Ascension Testing Phil Amway EPU Operations Lead SRO

ower Ascension Testing Preparation Approach Schedule Test Plan Acceptance Criteria and Actions 17

ower Ascension Testing Preparation Test Objective Development

- Satisfactory Equipment Performance

- Careful, Monitored Approach to EPU Power

- Meet Established Requirements Roles & Responsibility Development Industry Benchmarking Test Plan and Implementing Test Procedure Development Power Ascension Test Training 18

ower Ascension Testing - Approach Similar to approach used in other EPUs - Incremental Testing Baseline data at 75%, 90%, 95% and 100% CLTP Greater than 100% CLTP

- Data acquisition performed in incremental steps of 1% and 2.5%

- Active Testing and NRC Data Review at incremental steps of 5%

19

ower Ascension Testing - Approach (contd)

No Large Transient Testing

- Industry OE indicates that plants will continue to respond to transients as designed following EPU implementation

- Plant specific OE at 104.3% OLTP (Generator Load Reject and MSIV Closure)

- NMP2 has previously performed Large Transient Testing and documented results

- Plant operators will be trained on large transient events in the simulator

- Analytical methods and training facilities adequately simulate large transient events 20

ower Ascension Testing - Schedule Data collection - 1% intervals Data evaluation - 2.5% intervals EPU Major Testing Plateau - 5% intervals

- Passive data collection (e.g. vibration, radiation monitoring, plant parameter monitoring)

- Active control system stability dynamic testing Pressure regulator step test Feedwater level control step test

- Data Analysis

- Plant Management (PORC) Review

- NRC Review 21

ajor Testing 22

d Actions Level 1 Acceptance Criteria: A limit associated with plant safety If Level 1 criterion is not met:

- Abort the test

- Reduce power to last known safe condition

- Use the Corrective Action Program to evaluate the condition and to determine and implement required actions

- Repeat testing to verify that the Level 1 criterion is satisfied

- Document problem resolution 23

d Actions (contd)

Level 2 Acceptance Criteria: A limit associated with plant or equipment performance that does not meet design expectations but is not immediately adverse to plant safety If Level 2 criterion is not met:

- Place the test on hold and confirm the plant is in a safe condition

- Use the Corrective Action Program to evaluate the condition and to determine and implement required actions

- Repeat testing to verify the Level 2 criterion is satisfied unless the asfound condition is determined satisfactory

- Document problem resolution 24

d Actions (contd)

Other Acceptance Criteria: A limit associated with plant surveillance requirements, plant operating procedures, rounds or alarm responses When this criteria is not met, plant procedures will be followed 25

Nine Mile Point 2 Extended Power Uprate Long Term Stability Solution Option III and ATWS - Stability Events Phil Amway EPU Operations Lead SRO

ng Term Stability Solution - Option III/ATWS NRR Audit at Nine Mile Point 2 Long Term Stability Solution - Option III

- Oscillation Power Range Neutron Monitor (OPRM)

- OPRM Settings

- Backup Stability Protection (BSP)

- 2003 NMP2 Stability Event

- Effects of EPU on the Long Term Stability Solution Impact of EPU on ATWS - Stability Events

- NMP2 ATWS Mitigation Design Features

- Preparation for Simulator Demonstration

- MSIV Closure with Failure to Scram

- Turbine Trip with Failure to Scram

- Conclusions 27

RR Audit at NMP2 Performed October 28, 2009 to demonstrate procedure actions and operator response to ATWS transients at EPU conditions conform to regulatory requirements Reviewed implementation of Long Term Stability Solution -

Option III Observed operator performance in plant reference simulator

- MSIV Closure with Failure to Scram

- Turbine Trip with Failure to Scram Included review of related procedures and mitigation strategies Requested follow up information when plant reference simulator was modified to provide ATWS Stability transient response data 28

scillation Power Range Monitor (OPRM) 1998 - NUMAC Power Range Neutron Monitor OPRM hardware installed (Amendment 80) system tuning performed for plant specific settings 2000 - Reactor Protection System (RPS) OPRM trips armed (Amendment 92) 2002 - Implemented Plant Specific Delta CPR Over Initial CPR Versus Oscillation Magnitude (DIVOM) curve per GE Safety Communication 0101, Stability Setpoint Calculation using Generic DIVOM Curve 2003 - Implemented filter frequency and period tolerance settings per GE Safety Communication 0320, Stability Option III Period Based Detection Algorithm Allowable Settings 29

PRM Settings Cycle specific DIVOM analysis is performed using TRACG methodology Cycle specific amplitude setpoint is defined in the Core Operating Limits Report OPRM trips will be enabled >26% RTP and <60%

recirculation drive flow to maintain the same enabled region in terms of MWth power 30

ackup Stability Protection (BSP)

BSP regions are determined using cycle specific ODYSY decay ratio calculations BSP regions are defined on plant power/flow operating maps Operator actions are defined in plant procedures with routine training reinforcement BSP exit region procedures are enforced at all times 31

03 NMP2 Stability Event Component failure resulted in high to low speed transfer of both Reactor Recirculation pumps OPRM Period Based Detection Algorithm (PBDA) initiated an automatic reactor scram because of core wide oscillations The reactor was properly tripped by the PBDA Unexpected Confirmation Count (CC) resets occurred prior to the scram Post scram analysis determined that two parameter settings needed to be changed to address CC resets Parameter setting changes have been implemented per BWROG recommendations 32

fects of EPU on Long Term Stability Solution No methods changes for EPU Maximum rod line remains the same (MELLLA boundary)

OPRM armed region maintains the same level of stability protection Cycle specific setpoint analysis will capture core design variations Option III long term solution remains unchanged Option III OPRM setpoints will be developed based on plant specific DIVOM curves for the EPU cycle specific reload analysis 33

MP2 ATWS Mitigation Design Features High RPV pressure initiates ATWS systems T=0 seconds

- Automatic Alternate Rod Insertion (ARI)

- Automatic Reactor Recirculation Pump Trip (RPT) to slow speed T=25 seconds and power >4%

- Automatic Feedwater Runback

- Automatic Reactor RPT to off T=98 seconds and power >4%

- Automatic Boron Injection 34

eparation for Simulator Demonstration Simulator demonstration performed prior to operator training for EPU conditions Operating crew was provided with a briefing on EPU power level, steam and feedwater flows An SRO other than the EPU Operations Lead participated in the demonstration to avoid biasing operator response Simulator demonstration confirmed that current procedures and strategies successfully mitigate ATWS events 35

SIV Closure with Failure to Scram 3988 MWth at 99% core flow (MELLLA boundary)

Maximum Suppression Pool temperature 90°F Minimum Suppression Pool level 199.5 feet Maximum Service Water temperature 84°F No Control Rod Motion The above worst case conditions are consistent with design analysis inputs 36

SIV Closure with Failure to Scram (contd)

Both loops of Suppression Pool cooling in service at rated flow in 404 seconds vs action time of 1080 seconds Hot shutdown (<0.1% power) achieved in 406 seconds Peak Suppression Pool temperature remains below Heat Capacity Temperature Limit with 5°F margin Containment parameters remain well within design analysis Plant reference simulator critical parameter response closely matched the design analysis for this event 37

urbine Trip with Failure to Scram 3988 MWth at 99% core flow (MELLLA boundary)

Maximum Suppression Pool temperature 90°F Minimum Suppression Pool level 199.5 feet Maximum Service Water temperature 84°F No Control Rod Motion The above worst case conditions are consistent with design analysis inputs 38

urbine Trip with Failure to Scram (contd)

Both loops of Suppression Pool cooling in service at rated flow in 425 seconds vs. action time of 1080 seconds Hot shutdown (<0.1% power) achieved in 465 seconds Peak Suppression Pool temperature remains below Heat Capacity Temperature Limit with 19°F margin Containment parameters remain within design analysis Plant reference simulator critical parameter response closely matched the design analysis for this event 39

onclusions Existing procedures, operator action times and strategies are effective in mitigating ATWS and ATWS instability transients NMP2 features an ATWS RPT function. As a result, transient power levels are primarily based on the maximum control rod line which is unchanged for EPU Operators can perform actions in a timely manner to bring the plant to safe shutdown 40

Nine Mile Point 2 Extended Power Uprate Material, Mechanical/Civil Engineering Topics George Inch Principal Engineer Mechanical/Structural Lead

PV Internals Fluence Flow Induced Vibration (FIV)

Structural Effects (NonFIV)

Intergranular Stress Corrosion Cracking (IGSCC) and Irradiation Assisted Stress Corrosion Cracking (IASCC) 42

PV Internals - Fluence Irradiation assisted stress corrosion cracking (IASCC) fluence threshold is 5 E20 n/cm2 The following components exceeded the IASCC fluence threshold:

- Top Guide (BWRVIP26A)

- Shroud (BWRVIP76A)

- Core Plate (BWRVIP25A)

Continued implementation of the current program in accordance with the BWRVIP recommendations assures the prompt identification of any degradation of reactor vessel internal components NMP2 Utilizes Hydrogen Water Chemistry and Noble Metals Reactor vessel water chemistry conditions maintained consistent with the EPRI and established industry guidelines Peak fluence increase does not represent a significant increase in the potential for IASCC 43

PV Internals - Flow Induced Vibration Vibration levels for EPU were estimated by extrapolating vibration data from prototype plant or similar plants and on GEH BWR operating experience The following components were evaluated: a) shroud head and separator assembly; b) jet pumps; c) core delta P line; d) guide rods; e) incore guide tubes and control rod guide tubes; f) jet pump sensing lines; g) feedwater sparger; h) fuel assembly, top guide, and core plate; i) RPV top head spare instrument nozzle; j) RPV top head vent nozzle; k) RPV head spray pipe and head spray nozzle; l) core spray piping Results show that continuous operation at EPU conditions does not result in any detrimental effects on the safetyrelated reactor internal components 44

PV Internals - Structural Effects (NonFIV)

Evaluations/stress reconciliation was performed consistent with the Design Basis Analysis Original configurations of the internal components utilized, unless a component had undergone permanent structural modification Effects of thermalhydraulic changes due to EPU were evaluated EPU loads compared to those in the existing design basis analysis For increases in load, linearly scaled the critical/governing stresses based on increase in loads - compare resulting stresses against the allowable stress limits All stresses and fatigue usage factors are within the design basis ASME code allowable values RPV internal components demonstrated to be structurally qualified for operation at EPU conditions 45

PV Internals - IGSCC and IASCC Procedurally controlled program consistent with BWRVIP issued documents Components inspected include: core spray piping and spargers; core shroud and core shroud support; jet pumps and associated components; top guide; lower plenum; vessel inner diameter attachment welds; instrumentation penetrations; steam dryer drain channel welds; and feedwater spargers Program assures prompt identifications of any degradation Hydrogen water chemistry and noble metal applications to mitigate the potential for IGSCC and IASCC Recent Control Blade Cracking OE

- Not applicable to GEH Marathon C lattice models

- GEH concluded no lifetime reduction for C lattice 46

tigue Monitoring Program NMP2 implemented FatiguePro for fatigue monitoring in 2008 independent of EPU

- Automated event tracking and usage based on cycle counting for most event Assumed design basis event severity, records actual event severity

- Stress based monitoring of FW nozzle location to improve the accuracy of usage 47

tigue Monitoring Program (contd)

The EPU evaluation performed refined fatigue usage calculations for the FW nozzle

- Reduced usage from original design basis FW nozzle high usage defined by offnormal rapid cycling events occurring during partial loss of feedwater heating and hot standby operation

- EPU scaling factor small (between 6% and 15%)

- Stress based fatigue monitoring anticipated to demonstrate usage less than 1.0 for 60 years CLTP 40 year CUF EPU 40 year CUF Carbon Steel Safe End 0.965 0.6537 Stainless Steel Clad 0.916 0.8299 48

tigue Monitoring Program (contd)

FatiguePro implemented at NMP2 uses a single stress term for stress based monitoring

- Simplified Greens function

- RIS200830 is applicable to NMP2 NMP2 is following industry developments to reconcile RIS200830 issue

- FatiguePro 4 ASME Code Sub article NB3200 fatigue analysis methodology Environmental Fatigue rules (NUREG/CR5704/6583/6909)

- NMP2 is considering alternative confirmatory analyses as proposed by RIS200830 49

NMP2 EPU ATWS & Stability Dr. Tai L. Huang (NRR/ADES/DSS/SRXB)

Dr. Jose March-Leuba (ORNL)

ACRS Subcommittee Meeting October 5, 2011

Staff SER Staff has completed an SER with positive findings based on the review of available documents and a staff audit

- Current LTS implementation (Sol III) is adequate for EPU

• Satisfies GDC 10 & 12

• Level of protection in EPU is similar to CLTP

- Staff audit concluded that

• NMP2 operators show good understanding of stability and ATWS issues for EPU.

• Staff observations of operators action in the simulator support the customary 120 s delay assumed for safety calculations

• NMP2 EOPs are adequate for EPU 2

EPU Does Not Change the End Point After The Recirculation Pump Trip

• End Point is the same for CLTP and EPU because it is defined by

- Natural Circulation

- Subcooling (lower pressure of FW heating-steam)

• Stability characteristics of end point are similar 3

Stability LTS Option III installed since 1998, and armed since 2000 Plant has good experience with Option III

- 2003 NMP2 event was detected and scram actuated

• very low amplitude oscillations, which kept on resetting the OPRM confirmation counts

- Lessons learned (parameter settings) implemented at NMP2 per BWROG recommendations No impact expected for EPU

- Option III and DIVOM methodology are applicable 4

ATWS-Instability NMP2 has implemented latest EPG/SAGs

- Early level reduction & boron injection are accomplished through automated ATWS actions if high pressure is detected with power >4%:

• Automatic flow runback

• Automatic boron injection NMP2 has excellent ATWS response:

- SLC injection through HPCS (early shutdown)

- 100% motor driven FW (sufficient HP inject capacity)

• EOPs are reviewed every cycle, but are not affected significantly by EPU because boron is injected in HPCS and there is no need to define a HSBW.

- EPU does affect HCTL slightly (from 140°F to 139°F) 5

Staff Audit

• Staff reviewed the performance of the OPRM Solution III system in the simulator

• Staff reviewed ATWS performance in the simulator (3 different scenarios)

- Turbine Trip ATWS From The MELLLA Corner with simulated unstable oscillations

- MSIV Isolation ATWS from MELLLA corner

- MSIV Isolation ATWS from EPU conditions

• NMPNS submitted additional information with the simulator ATWS results 6

Simulator shows similar response at EPU and CLTP CLTP EPU 7

Simulator shows margin to emergency depressurization CLTP EPU 8

Summary

• EPU operation is acceptable from stability point of view

- Installed LTS (Sol III) provides similar level of protection under EPU and CLTP

- OPRM scram satisfies GDC 10 and 12

• ATWS and ATWS-Stability not affected significantly by EPU

- Satisfies ATWS Acceptance Criteria (10CFR 50.62)

- NMP2 has excellent ATWS performance design

• Automatic trips

• Upper plenum boron injection

• 100% motor-driven FW pumps 9

Nine Mile Point Unit No. 2 Extended Power Uprate ACRS Subcommittee Meeting Interim Methods Applicability of GE Methods to Expanded Operating Domains Dr. Peter Yarsky RES/DSA/RSAB 2-1

Methods Review Basis

• Review based on approved LTR NEDC-33173P Applicability of GE Methods to Expanded Operating Domains, (the IMLTR)

• Staff confirmed that the EPU LAR is fully consistent with the conditions and limitations specified in the staffs SE for the IMLTR 2-2

Staff Review Items

• IMLTR: 24 Conditions and Limitations

- No Supplements to the IMLTR referenced in the NMP2 EPU LAR

- PUSAR Appendix A dispositions each condition and limitation

- All 24 conditions and limitations acceptably met

- Staff conducted one regulatory audit pertaining to the IMLTR 2-3

Staff Review Items

• LPRM Calibration Interval

- LPRM update affects core monitor accuracy to predict power distribution

- Interval is 1,000 EFPH

- Post EPU, exposure interval between calibrations would increase 15 percent

- Staff audited GEH data to confirm that power distribution uncertainties were acceptable for longer exposure interval 2-4

Conclusions

• Methods application acceptable because all staff SE conditions and limitations on the IMLTR are met 2-5