ML11298A225

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Transcript of the ACRS Power Uprates (Nine Mile Point) Subcommittee Meeting, October 5, 2011 (Open) Pages 1-213
ML11298A225
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Site: Nine Mile Point Constellation icon.png
Issue date: 10/05/2011
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Advisory Committee on Reactor Safeguards
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NRC-1179
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSIONTitle:Advisory Committee on Reactor Safeguards Power Uprates Subcommittee Open SessionDocket Number:(n/a)Location:Rockville, Maryland Date:Wednesday, October 5, 2011Work Order No.:NRC-1179Pages 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 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 2+ + + + +3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 (ACRS)5+ + + + +6 POWER UPRATES SUBCOMMITTEE 7+ + + + +8 OPEN SESSION 9+ + + + +10 WEDNESDAY, OCTOBER 5, 2011 11+ + + + +12 ROCKVILLE, MARYLAND 13+ + + + +14The Subcommittee met at the Nuclear 15Regulatory Commission, Two White Flint North, Room 16T2B1, 11545 Rockville Pike, at 8:30 a.m., J. Sam 17 Armijo, Chairman, presiding.

18 SUBCOMMITTEE MEMBERS:

19 J. SAM ARMIJO, Chairman 20 SAID ABDEL-KHALIK, Member 21 SANJOY BANERJEE, Member 22 JOY REMPE, Member 23 WILLIAM J. SHACK, Member 24 JOHN D. SIEBER, Member 25 2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 ACRS CONSULTANTS:

1 MARIO BONACA 2 GRAHAM WALLIS 3 4 DESIGNATED FEDERAL OFFICIAL:

5 PETER WEN 6 7 8

9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 AGENDA 1 Opening Remarks.................4 2 Staff Opening Remarks..............6 3 Introduction..................7 4 NMPNS EPU Overview...............11 5 Reactor Thermal-Hydraulic Design........25 6 Long-Term Stability Solution Option.......69 7 Nuclear Design: Interim Methods.........82 8 Material, Mechanical/

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

14 15 16 17 18 19 20 21 22 23 24 25 4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 P R O C E E D I N G S 1 8:28 a.m.2 CHAIRMAN ARMIJO: Good morning. This is 3a meeting of the Power Uprates Subcommittee. I'm Sam 4 Armijo, Chairman of this subcommittee. ACRS members 5in attendance are Said Abdel Khalik, Bill Shack, Jack 6Sieber and Joy Rempe. I saw Dick Skillman around, but 7perhaps he's attending the other meeting. Dr. Sanjoy 8Banerjee will not be able to attend the morning 9 session, but will attend this afternoon.

10ACRS consultants are Dr. Mario Bonaca and 11Professor Graham Wallis. Peter Wen is the Designated 12Federal Official for this meeting. The purpose of 13this meeting is to review the extended power uprate 14request for Nine Mile Unit 2, the staff's draft 15 safety evaluation and associated documents.

16You will hear presentations from the 17Office of Nuclear Reactor regulation and the licensee, 18Nine Mile Point Nuclear Station, LLC. As shown in the 19agenda, some presentations will be closed in order to 20discuss information that is proprietary to the 21licensees and its contractors, pursuant to 5 U.S.C.

22552(b), (c), (3) and (4). Attendance at this portion 23 of the meeting dealing with such information will be 24limited to the NRC staff, licensee representatives, 25 5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433and its consultants and those individuals and 1organizations who have entered into an appropriate 2 confidentiality agreement with them.

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

10The rules for participation in today's 11 meeting have been announced as part of the notice of 12the meeting, previously published in the Federal 13 Register. We have received no written comments or 14requests for time to make oral statements for members 15 of the public regarding today's meeting.

16The transcript of the meeting is being 17kept and will be made available, as stated, in the 18 Federal Register notice. Therefore, we request that 19participants in this meeting use the microphones 20located throughout the meeting room when addressing 21the subcommittee. The participants should first 22identify themselves and speak with sufficient clarity 23 and volume, so that they may be readily heard.

24We have several people on the phone bridge 25 6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433lines listening to the discussion. To preclude 1 interruption of the meeting, the phone lines are 2placed on listen in mode. We will now proceed with 3 the meeting, and I call on Ms. Louise Lunn of NRR to 4 introduce the presenters. Louise.

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

10In the interest of time, my opening remarks will be 11 brief.12At this meeting, the NRC staff present to 13you the results of our very thorough safety and 14 technical review of the licensee's application. The 15thoroughness of the review is supported by the fact 16that we had several pre-application meetings with the 17 licensee, starting as early as September of 2008, in 18 which the licensee scheduled an overall proposed EPU 19 implementation plans were discussed with the NRC.

20The NRC staff also performed an extensive 21acceptance review before initiating our detailed 22review of the application. We believe this helped 23 with the efficiency and effectiveness of our review.

24During the course of our review, the staff 25 7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433had frequent communications with the licensee, as well 1as two audits and numerous conference calls to discuss 2the EPU application and its supplemental responses to 3several rounds of requests for additional information, 4 covering multiple technical disciplines.

5Some of the more challenging review areas 6that you'll hear about today include steam dryer 7stress analysis, in which Nine Mile submitted its 8revised acoustic circuit model, thermal hydraulic 9stability analyses, interim methods, specifically the 10applicability of GE methods to expanded operating 11 demands.12As presented in the draft safety 13evaluation, which was provided to ACRS a month ago, 14there are currently no open technical issues in the 15 NRC staff's review of the licensee proposed extended 16power uprate application. We'd like to give our 17thanks to the ACRS staff, who assisted us with the 18preparations for this meeting, especially Peter 19 Yarsky. 20 At this point I'd like to turn over the 21discussion to our NRR project manager, Rich Guzman, 22 who will introduce the discussions. Rich.

23MR. GUZMAN: Good morning. My name is 24Rich Guzman. I am the senior project manager in NRR, 25 8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433assigned to Nine Mile Point Nuclear Station. First 1off, I'd like to apologize. I'm having some technical 2 difficulties in projecting the presentation onto the 3 screen. So at this time I'd ask that you use a hard 4 copy, the color copies that you have.

5The first presentation is from the NRC 6staff binder, which is titled "Opening Remarks." 7During today's Subcommittee meeting, you will hear 8presentations from the Nine Mile Point Nuclear Station 9and the NRC staff. The objective is to provide you 10with sufficient information related to the details of 11the EP application, as well as the evaluation 12supporting the staff's reasonable assurance 13 determination that public health and safety will not 14be endangered during the operation of this proposed 15 EPU. 16 Before I cover the agenda items, I would 17like to go over some background information really of 18the staff review of the Nine Mile Point 2 EPU. On May 19 27th, 2009 -- well there you have my script --

20 (Laughter.)

21 MR. GUZMAN: All right.

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

24MR. GUZMAN: All right. As you see there, 25 9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433on May 27th, 2009, the licensee submitted its license 1request for Nine Mile Point 2 EPU. The increase would 2be 34.67 megawatts thermal, their current license 3thermal power, to 39.88 megawatt thermal. This would 4represent a 15 percent increase from their current 5license, and a 20 percent increase from their original 6 license thermal power.

7The staff's method of review was based on 8 the RS 001, which is NRC's review plan for EPUs. As 9you know, it provides a safety evaluation template, as 10well as major C's that cover the multiple technical 11 areas that the staff is to review.

12There are no associated or linked 13licensing actions associated with this. Nine Mile 14previously submitted, and the staff approved two 15 license amendments, mainly the maximum extended load 16line limit analysis, and the AST amendment in 2007 and 172008, respectively. Finally, there were numerous 18supplements to the application, responding to multiple 19 staff RAIs. Overall, there were approximately 25 20supplemental responses, which supported our draft 21 safety evaluation.

22The staff projects December 2011 to 23 complete our review, and this would be in support of 24the licensee's scheduled implementation in the second 25 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 quarter of 2012.

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

9 10Finally, at the conclusion of the meeting, 11as needed, we can cover any open items in preparation 12for a full Committee meeting. And also to note, there 13will be closed sessions during the latter parts of 14 both the morning and afternoon sessions.

15So if there's any proprietary information 16that needs to be discussed, it can be deferred over to 17the designated closed session for the agenda. This 18 concludes my presentation. I would like to now turn 19the presentation over to the licensee, specifically 20Mr. Sam Belcher, who is the Senior Vice President for 21 Operations for the Constellation Fleets.

22And that said, I am going to eventually in 23 parallel, as you guys just need, talk to the slides 24that is in your binder, I'll eventually get this 25 11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 posted on the wall. I apologize.

1MR. BELCHER: Thank you. As mentioned, I 2am Sam Belcher. I'm the Senior Vice President of 3Operations for Constellation Energy Nuclear Group, and 4I'll be walking through a presentation. I don't know 5 if it will make it up not the slide or not, but it is 6 in your binder and it's titled "ACRS Subcommittee 7Presentation," and I'm on point 2, "Extended Power 8 Uprate, October 5th." 9I'll be walking us through a very high 10level overview, and then we'll get into more technical 11details as we move through the morning and into the 12 afternoon. We'll start with an overview, followed by 13a discussion on the plant modifications necessary for 14the extended power uprate, anticipated transient with 15scram and stability discussion, and then, as mentioned 16the closed sessions for fuel methods, material 17mechanical civil engineering topics, and then steam 18 dryer analysis also will be a closed session.

19 At a very high level, Nine Mile Point Unit 202 is a GE BWR 5, with a Mark II containment. Original 21license thermal power was 33.23 megawatts thermal. In 221995, a stretch uprate was done of 104.3 percent, 23which takes us to the existing license power limit of 24 34.67 megawatts thermal.

25 12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433This amendment would take us to 39.88 1megawatts thermal, with the intention to implement 2second quarter of next year. This is a constant 3pressure power uprate. Additionally, Nine Mile Point 4Unit 2 is not requesting any containment accident 5pressure credit to support ECCS positive suction head.

6 I see some smiles there.

7Also, no new fuel will be introduced as a 8part of this uprate. The current core and the EPU 9core will be GE 14 fuel consistently. Also, as 10mentioned previously, alternate source term has 11already been completed, and that was at the EPU power 12level as the base assumption. Also previously 13 discussed is the maximum extended load line limit 14 analysis, expanded operating domain as well.

15Finally, the New York state ISO has 16reviewed and approved the full EPU power uprate, with 17no grid modifications being necessary. The only 18modifications that I would note were revenue metering 19 type modifications for the increased output. But 20nothing for grid stability or anything along those 21 lines.22 The first two phases of the EPU 23 modification have been completed, and then the third 24and final phase of the modification will be completed 25 13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433in the second quarter of 2012, consistent with the 1refueling outage. At this point, unless there are 2some questions for me, I will turn it over to Dale 3 Goodney, who is our lead engineer, to talk in more 4detail around some of the plant modifications required 5 moving forward.

6MR. GOODNEY: Okay, good morning. As Sam 7 indicated, I'm Dale Goodney. I'm with Constellation 8Energy and the EPU lead, engineering lead for the EPU 9 project. I'll provide an overview of EPU plant 10 modifications. We'll cover the general approach, the 11review plant parameters and modification installation 12 time line.

13We'll summarize the major plant 14modifications and then we'll review other Nine Mile 2 15 plant improvements that are being implemented at the 16 station. 17In support of the license amendment 18request, a series of engineering studies were 19performed to determine the plant's ability to operate 20at EPU conditions, and to identify what modifications 21may be needed. These studies were developed by a team 22 of Constellation engineers, industry consultants, GE 23 Hitachi for the nuclear steam supply system, and 24 Sargent & Lundy for balance of plant systems.

25 14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433These studies analyzed the effects of the 1increase in steam flow, feedwater flow, electrical 2power output and reactor power on various plant 3systems and components. As Sam mentioned, this uprate 4is not increasing reactor pressure. Therefore, the 5evaluations were performed based on the methodologies 6 outlined in the past and pressure power uprate 7 licensing topical report.

8The analyses were all based on the target 9power level of 120 percent of the original license 10thermal power. Each study included a review of 11relevant operating experience, both internal and 12external, and were applicable to results were 13 incorporated into these evaluations.

14Another element of the engineering 15evaluations were the margin reviews. Design and 16operating margins were identified and evaluated for 17 both NSSS and balance of plant systems, to determine 18if there would be adequate margin under EPU 19 conditions.

20As a result of these reviews, over 20 21physical plant modifications, mostly in the balance of 22plant area were identified and described in the 23license amendment request. The primary purpose of 24these modifications are to (1) restore material 25 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433condition, (2) install instrumentation for data 1collection and analysis, or (3) upgrade or replace 2 equipment to restore design and operating margins at 3 EPU conditions.

4 This next slide shows the fundamental 5plant process parameters that would change due to the 6uprate, and compares the EPU conditions to the CLPP 7 conditions. These parameters are the primary starting 8 point for the evaluations that I just described, and 9 they also form the key design inputs for the 10modifications that were developed for the power 11 uprate.12 The next slide is the modification 13 installation time line, and as mentioned in our 14earlier slides, the Phase 1 and Phase 2 implementation 15is completed. Those are the modifications shown in 16the two left-hand columns. The remainder of the 17modifications will be installed prior to the end of 18 the 2012 refueling outage.

19On the next slide, or next few slides, 20 will summarize some of these modifications. It will 21cover basically four general categories. Feedwater 22and condensate, steam path, electrical I&C systems, 23 and auxiliary support systems.

24DR. WALLIS: Can I ask you about the steam 25 16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 dryer? This isn't the -- you know, GE has a new 1 design of steam dryer. That's not the one, right?

2It's the old steam dryer, modified because the 3analysis says you need to do so. So you're putting in 4strengthening at various places and perforated plates 5 and so on?

6 So just to clarify, that's the old steam 7dryer, strengthened because of the results of 8 analysis?9MR. GOODNEY: That's correct, and we'll be 10 covering those modifications --

11 (Simultaneous speaking.)

12MR. GOODNEY: Due to the higher feedwater 13flow requirements, the feedwater pumps will be 14modified with new rotating elements, new step-up gears 15and modified flow control valve trim. In addition, 16the heater drain pumps in motors were replaced in 172010, to increase the capacity of the pumps. These 18changes will provide the additional flow margin 19required for normal, off normal and transient 20 conditions.

21Reactor recirculation runback logic is 22being modified to maintain scram avoidance margin 23following a single feedwater pump trip. This will be 24accomplished by initiating the runback immediately on 25 17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433a feedwater pump trip, increasing the runback rate of 1the reactor recirc flow control valve, and -- the 2 higher feedwater pump runoff flow capacity.

3In terms of the steam path, the high 4 pressure turbine we replaced with a monoblock rotor, 5new diaphragms and buckets to increase the steam flow, 6six relief valves located on the reheat piping will be 7replaced with valves with a higher set pressures to 8 increase the steam relieving capacity.

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

16Two electrical modifications are needed to 17support the higher power output. The isophase bus 18duct will be upgraded by installing a higher capacity 19cooling system, and the coolers on the main 20transformers will be replaced with larger coolers, to 21 provide additional thermal margin.

22Instrumentation affected by the uprate 23include two tech spec instrument set points, the APRM 24 flow-biased scram, and the main steam high flow 25 18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 isolation. Those changes are included as part of the 1 license amendment request. The balance of plant 2 instrument loops are being rescaled, as required, to 3accommodate the higher flows, temperatures and 4 pressures under EPU conditions.

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

9The turbine building cooling, although it 10does have adequate margins for EPU conditions, it's 11going to be modified to isolate retired loads to 12provide additional margin, and the system will be 13 rebalanced to ensure that we get accurate cooling to 14all the power-dependent loads supplied by the system.

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

17 CHAIRMAN ARMIJO: I have a question, not 18 about modifications, but many years ago, a number of 19the BWRs had stress corrosion cracking problems in 20their recirc piping, core repiping, and a number of 21them did some replacements of the original type 304 22stainless steel with an improved material, 316 nuclear 23 grade.24I didn't, don't remember. What did you do 25 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433at Nine Mile 2? Are you still using the original 1 recirc piping?

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

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

7MR. INCH: The piping at Unit 2 was 8 originally considered as upgraded piping. I believe 9 it's 316. I'll have to verify that.

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

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

18CHAIRMAN ARMIJO: Okay, all right. Thank 19 you. 20MEMBER SHACK: But just on that point, you 21 do have a number of Class D welds left.

22 MR. INCH: Yes.

23MEMBER SHACK: At least there's a 24 discussion of that in the --

25 20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. INCH: The Class D welds are the 1similar metal welds, the safe end to nozzle welds. So 2 that is the --

3MEMBER SHACK: But they're what, ferritic 4 to a normal carbon steel safe end? Is that --

5 MR. INCH: It's the stainless steel safe 6 end to the low alloy steel nozzle. It's the similar 7 metal weld, and that's the -- those are the category, 8considered Category D welds, per 8801, Generic Letter 9 8801.10CHAIRMAN ARMIJO: And some of those you've 11done a weld overlay, repair, mechanical stress 12 improvement?

13MR. INCH: There was one indication on one 14of the high pressure core spray lines, that a 15mechanical stress improvement was done in the early 16 90's. We've been monitoring that since then, with no 17 growth.18It was an indication identified in one of 19the feedwater nozzles, approximately ten years ago.

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

22CHAIRMAN ARMIJO: So with the exception of 23 those two components, it's the as-built material?

24 MR. INCH: Yes.

25 21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433CHAIRMAN ARMIJO: Okay, thank you. And 1 when did you start the hydrogen water chemistry?

2MR. INCH: Hydrogen water chemistry was 3started in, it was either 2000 or 2001. We 4implemented hydrogen water chemistry in combination 5with noble metals. So it's always been a noble metals 6 hydrogen water chemistry application.

7MEMBER SIEBER: I may have I missed it, 8 but in my review of the material that was included, 9 that Nine Mile Point 2 has a Mark II containment, 10which is the upside down lightbulb or ice cream cone, 11similar to the Mark I containments in containment 12 volume, but the geometry was different.

13Did you analyze the containment 14capability, insofar as you now have approximately 20 15percent over the original design stored heat acumen 16 environment?

17 MR. INCH: Yes.

18MEMBER SIEBER: And if so, did that 19consider fuel failures, cladding oxidation and so 20 forth? How far did you go in that analysis?

21MR. INCH: The design bases analyses were 22 redone for the higher megawatt thermal.

23 MEMBER SIEBER: Right.

24MR. INCH: And decay heat levels, and 25 22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 those were performed by GE, using their design bases 1methods for the higher power levels, and mainly 2 because it's -- the peak pressure is governed by the 3short-term blowdown, and because it's a constant 4pressure power uprate, the peak pressure associated 5 with that blowdown has not changed.

6 MEMBER SIEBER: Right, that's true.

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

8 MEMBER SIEBER: Has to be increased.

9MR. INCH: Long-term response was 10mitigated by the suppression pool cooling systems.

11There's significant margin built into the original 12design on those systems, that the original design 13 analyses had not credited. So by actually crediting 14those systems capability, we were able to maintain the 15 suppression pool temperature effectively the same in 16 design bases space as current.

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

20 MEMBER SIEBER: Or change at all?

21 MR. INCH: Effectively, yes.

22MEMBER SIEBER: I have to think about 23 that.24MEMBER SHACK: While we're at it, is this 25 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 a vented Mark II? Is there a vent on this Mark II?

1 MR. GOODNEY: Phil.

2 MEMBER SIEBER: Has to be.

3MR. AMWAY: My name is Phil Amway, and I'm 4the extended power uprate operations lead, and I 5 maintain an active senior reactor operator's license 6 for the facility. Nine Mile Point 2 is able to vent 7the containment through a path that will divert the 8containment out directly to the stack, using a bypass 9 around the PTS train. We have that capability.

10CHAIRMAN ARMIJO: You know, this is a 11 little bit off the scope, but you can't help it, 12because of the Fukushima events. How do you test 13 those vents? Do you ever test them or that they --

14MR. AMWAY: We have performed, and again, 15my name is Phil Amway. We have performed walkdowns of 16those procedures. We have procedures in place that 17line up that vent path. All the materials are staged 18to do so. We cover it in training. We have not 19 actually physically made the alignments, to actually 20vent in that mode. But it is a fairly simple 21 mechanical arrangement that could be done.

22CHAIRMAN ARMIJO: Is there a rupture disc 23 in that design or not?

24MR. AMWAY: There is no rupture disc, no.

25 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433DR. BONACA: So it's a duct. Is it the 1 hard piping or --

2MR. AMWAY: It's hard piping. We actually 3 bypass around any duct work that would be subject to 4 the high pressure condition.

5MR. BELCHER: If I may add, I'm Sam 6Belcher, the Senior Vice President for Operations for 7 Constellation Energy Group. While we have processes 8and procedures and training in place, based on the 9recent events, we are looking in detail at 10improvements, not only at the Nine Mile Point site, 11 but at our other sites as well.

12I think there are lessons learned that 13 will ultimately lead to us doing things differently.

14 But we are looking at that.

15 CHAIRMAN ARMIJO: Okay, continue on.

16MR. GOODNEY: No problem. This final 17slide covers other plant improvements that the station 18has implemented or is planning to implement, to 19restore material condition, improve margin, improve 20equipment reliability. Some examples are replacement 21of the third point feedwater heaters in 2010; the 22standby flow control relief valve margin was improved.

23Cleaning tower upgrades were implemented.

24New feedwater pump seals will be installed, according 25 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433to the feedwater pump modifications I mentioned 1 earlier. One of the more significant improvements, 2 the station plans to replace all 20 jet pump inlet 3mixers during the 2012 refueling outage. That will 4restore the equipment back to the original design 5performance, restore core flow margin, and address 6operating experience relative to flow-induced 7 vibration.

8Then finally, there have been several PRA-9related risk reduction improvements, consisting of 10 procedure changes and other minor modifications. As 11 a result of these improvements, since 2008, the core 12 damage frequency at Nine Mile Point has been reduced 13 by 78 percent.

14So that concludes my presentation on 15modification overview. Pending any questions, I'll 16turn this over to Phil Amway, to discuss power 17 ascension testing.

18MR. AMWAY: Thank you, Dale. Again, to 19reiterate, my name is Phil Amway. I'm the extended 20power operations lead. I'll be giving two 21presentations this morning. The first area is for the 22 power ascension testing program. Under this topical 23area, we'll discuss the preparation of the program, 24 approach to uprated power --

25 26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER ABDEL-KHALIK: I'm sorry. Can we 1 go back to the previous slide?

2 MR. AMWAY: Sure.

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

5 MR. GOODNEY: That's correct.

6MEMBER ABDEL-KHALIK: Could you explain 7 more of the rationale for that?

8MR. GOODNEY: I apologize. Excuse me.

9You'd like to know the rationale behind replacing the 10jet pump inlet mixers, and whether that will impact 11 the core flow measurement instrumentation.

12MR. INCH: Oh, the jet pumps become fouled 13over years of operation, from a mechanism that I don't 14fully understand. But they call it a zeta potential, 15 where you get deposits that affect the efficiency of 16the jet pumps. At Nine Mile, that's been occurring 17 for several years.

18There's several options available. Ultra 19high pressure cleaning is an option that was 20considered, and but there's essentially the new mixers 21we're putting in are identical to the original design.

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

24 So therefore, the instrumentation is not 25 27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 affected. It just basically restores the performance 1 to the original performance.

2MEMBER ABDEL-KHALIK: But the relation 3between the driver flow, the jet pumps and the actual 4 core flow will change as a result of that 5 modification; is that correct?

6MR. INCH: It will be restored to the 7 design bases, drive flow design basis and ratio, but 8it's not a change to the design. So operational 9procedures, every refuel outage, do a new baseline for 10where those jet pumps are, to establish the 11 correlation between dry flow and core flow.

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

15MEMBER ABDEL-KHALIK: So that when the 16operators, the current procedures for knowing where 17 they are on the power flow map, they use the driver 18flow or they use the direct total core flow, as 19 measured from the 20 jet pumps?

20MR. INCH: Operations has core flow.

21 Phil.22MR. AMWAY: We use total core flow direct 23 indication.

24 MR. INCH: When we plot our --

25 28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. AMWAY: Yes.

1MEMBER ABDEL-KHALIK: But in that process, 2 you use the relationship between the driver flow and 3the core flow, which you say you empirically calibrate 4 every outage?

5 MR. INCH: Yes.

6MR. AMWAY: Every outage, and it's part of 7our start-up test program as well. We will do the 8core flow calibration, which will calibrate the dry 9 flow to the jet pump flow.

10MEMBER ABDEL-KHALIK: How much has that 11calibration changed since the jet pump inlet mixers 12 were replaced? Oh, you have no idea.

13 (Simultaneous speaking.)

14MEMBER ABDEL-KHALIK: How much has that 15 changed over the years, as a result of fouling?

16MR. AMWAY: It has changed gradually over 17 the years. It's actually a reactor engineering 18 procedure. It's done at the conclusion of each 19outage, once we get the full rated power. We'll do 20that procedure and the trend has been, the acceptance 21criteria of that procedure is as long as the 22calibration is within two percent, no additional 23 action is required.

24 It's about every third outage we actually 25 29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433have to go in and make a change, and adjust the gains 1 on the dry flow to match the core flow.

2MEMBER ABDEL-KHALIK: So the allowable 3 deviation between the two flow indications is two 4 percent you said?

5 MR. AMWAY: Two percent.

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

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

14MEMBER SHACK: What is this magic coating?

15MR. INCH: That's proprietary. I can't --

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

17 MEMBER SHACK: Yes.

18CHAIRMAN ARMIJO: You may want to do that.

19MEMBER SHACK: But otherwise its geometry 20is identical, with the exception of a coating to 21surface treatment of some sort, to minimize the 22 fouling rate.

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

25 30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER ABDEL-KHALIK: But generally th 1 trend is that the actual core flow will likely be less 2than the indicated core flow. Is that the -- or is it 3 the other way around?

4MR. INCH: Right now, the design M ration 5 for the jet pump mixers is -- at EPU, it will be about 6 2.28.7MEMBER ABDEL-KHALIK: No, no, no. I'm 8 asking about the effect of fouling, and you're 9allowing a two percent deviation between or two 10percent variation on the calibration, in the empirical 11calibration between driver flow and actual core flow.

12MR. INCH: I believe what Phil's referring 13 to is just the instrumentation tolerances --

14 MEMBER ABDEL-KHALIK: That's right.

15MR. INCH: That are built into the design 16 bases. The fouling occurs over very long periods of 17 time, over many years in the cycle.

18It's a very gradual process, and the 19frequency for the calibrations will maintain and 20ensure that the relationship between dry flow and core 21flow is accurate to within the design tolerances at 22all times. But it's not something that occurs 23 suddenly. I'm not sure if I'm --

24 MEMBER ABDEL-KHALIK: I'm just trying to 25 31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 understand the direction of the trend.

1 MR. INCH: Okay.

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

5 MR. AMWAY: About every third cycle. We 6actually have enough mismatch between the two 7measurements that we actually adjust the gains of the 8 dry flow.9MEMBER ABDEL-KHALIK: So that sort of 10 gives you an indication of how quickly the core flow 11 is being impacted as a result of fouling? Or is it 12 just drift?

13MR. AMWAY: It's just looking at the total 14-- I mean some of that could be drift, some of that 15could be fouling. I'm just looking at the total 16 measurements of drive to driven flow when we do that 17 procedure. It's not really looking at specific 18factors that may input to that deviation of two 19 percent.20MR. INCH: I can give you a feel for some 21 of the numbers. The original, when we first started 22the plant up in '87, the original calibration for dry 23flow was approximately 41,000 GPM for a rated core 24flow, which is 108-1/2, 108-1/2 million pounds per 25 32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 hour. That's the relationship. So M ratio, drive to 1driven of approximately 2.4 or 2.5, I believe, at 2 OLTP.3Now, for to achieve 108, the rated core 4flow, 108 million, we need 46,000 GPM drive flow, and 5 that's occurred over 22 years. That's the -- it's a 6gradual change. It is affected by the stretch uprate 7in effect. When we did the stretch uprate in 1995, 8 that was the original design, five percent uprate.

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

15 CHAIRMAN ARMIJO: So do you expect the 16fouling rate to be greater with the higher flows at 17 EPU?18MR. INCH: Again, our flows are really not 19 higher. They're the design flows. So the fouling 20rates really shouldn't change from what it's been 21 historically. The change for power uprate, changes to 22 the core DP are slightly. So we need basically it's 23 a 1.9 percent effect on the dry flow relationship.

24 MEMBER ABDEL-KHALIK: But if the fouling 25 33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433is some sort of a deposition of some, let's say an 1iron oxide or some other material on those mixers, 2 you're putting a lot more water with all that same 3 material through, over a given period of time. So I 4 would expect the fouling to be faster.

5MR. INCH: It's important that -- we're 6really not putting any more -- the core flow stays the 7 same, and the dry flow really is the same. Now what 8we're doing is put it back to the original core 9 relationship and efficiency of the jet pump. So the 10 rate of fouling should be equivalent.

11MEMBER SHACK: And with your magic 12 coating, less.

13 MR. INCH: Well, hopefully yes.

14 CHAIRMAN ARMIJO: Okay.

15DR. BONACA: Just one question I had 16regarding the vent. Do you have that venting 17 procedures?

18MR. AMWAY: Yes, we do have venting 19 procedures. It's part of our emergency operating 20procedures, support procedures. But we do have those 21 in place.22 DR. BONACA: All right, thank you.

23MR. AMWAY: All right. If I may continue 24on under power ascension testing, I'm on Slide 17.

25 34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 The topical areas that I want to address under power 1sensitive testing are preparation, approach, schedule, 2the test plan and the acceptance criteria and actions.

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

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

14We will also perform operator training on 15 the power ascension test program, including the test 16procedures that will be performed. The approach is 17similar to that used for other BWRs that have 18implemented extended power uprate, and that is 19incremental testing approach. We collect baseline 20data at 75, 90, 95 and 100 percent of current licensed 21 thermal power.

22Once we rise above the 100 percent current 23licensed thermal power, we will perform data 24acquisition and incremental steps of one percent, and 25 35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433an analysis of two and a half percent. Every five 1percent plateau is a major testing window that 2includes the active as well as the passive testing, 3and there is an NRC data review with those five 4 percent incremental levels.

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

8MR. AMWAY: That is correct. That's part 9of the ascension program. Power ascension testing 10approach for Nine Mile 2 does not include large 11transient testing. The basis for that is the 12substantial industry operating experience from uprated 13plants that have experienced large transient post-EPU 14implementation, and also Nine Mile Point specific data 15for large transients that have occurred at the station 16at 104.3, which is the uprate, stretch uprate power 17 level.18 We were able to use that data to 19accurately project, using the analytical methods that 20are available today, such that we fully understand how 21the plant will respond post-uprate for large 22 transients.

23MEMBER ABDEL-KHALIK: If you'll go back 24 again to the previous slide, please.

25 36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. AMWAY: Sure.

1MEMBER ABDEL-KHALIK: Have you had any 2 experience with the SRV leaks?

3MR. AMWAY: With SRV leaks, and I may ask 4George to provide additional information here, but 5 recently our SRV leakage has been very good.

6We had problems, I'll say in the mid-90's, 7with SRV leakage that was indicated by rising 8suppression pool temperatures, and the frequency at 9which we had to place suppression pool cooling in 10service, to maintain pool temperatures just at normal 11 power.12That has not been the experience that I've 13 seen in the power plant for the last 10-12 years, and 14 I would say that we're not seeing it in tail pipe 15temperatures, or the suppression pool temperatures.

16George, do you have anything additional to add to 17 that?18 MR. INCH: No. I might add that when we 19stopped doing the steam flow surveillance tests, 20actually opening the SRVs and closing them, which 21challenges the receding, the SRV leakage has gone away 22 as a problem. So it's been very effective.

23MEMBER ABDEL-KHALIK: And post-outage 24testing of the SRVs, they meet the specs, as far as 25 37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 set point?

1MR. INCH: Oh yes. I'm not prepared right 2now to go into any of those details, but yes. They 3change them out in accordance with a rotation plan.

4They are tested at offsite. I believe they're sent 5offsite and tested each outage. If you need more 6 details, I would have to come back.

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

12MR. AMWAY: It's primarily with the steam 13 dryer, but it also includes balance of plant piping, 14 because of the increased steam flows and feed flows, 15and we will be monitoring that vibration in those same 16 increments on the way out.

17MEMBER ABDEL-KHALIK: Is there any concern 18about increased leakage from the SRVs, as a result of 19 the increased steam flow, and the potential acoustic 20 coupling associated with the SRVs?

21MR. INCH: No. We've looked at that 22fairly significantly with our instrumenting. The main 23steam lines with accelerometers in the vicinity of 24SRVs, to make sure that there's no coupling.

25 38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 Analytically, we're not seeing any, haven't seen and 1 are not predicting to see any issues with this --

2MEMBER ABDEL-KHALIK: How would your 3 instrumentation tell you whether or not you have 4increased leakage out of the SRVs, as a result of the 5--6MR. INCH: Well have, there's tailpipe 7instrumentation to tell us if it's leaking. They 8 know.9 MR. AMWAY: That's correct.

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

12MR. AMWAY: It's a temperature 13 measurement, right on the tailpiping.

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

16MR. GOODNEY: Are you referring to Target 17 Rock?18 MEMBER ABDEL-KHALIK: Right.

19MR. GOODNEY: No, we don't have Target 20 Rock.21MEMBER ABDEL-KHALIK: You don't have 22 Target Rock. So what kind of SRVs do you have?

23 MR. INCH: They're Dikkers.

24 MR. GOODNEY: Dikkers.

25 39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER ABDEL-KHALIK: And they're 1instrumented only by measuring temperature in the 2 tailpipe?3MR. INCH: I believe so. I would have to 4 verify that.

5 MEMBER ABDEL-KHALIK: Okay.

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

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

12MR. AMWAY: But for the leaking, it's just 13 the thermocouples on the tailpipe.

14MEMBER ABDEL-KHALIK: All right, thank 15 you.16MR. AMWAY: You're welcome. I'm up to 17Slide 21 now, the power ascension testing schedule.

18Data collection in one percent intervals, data 19evaluation, two and a half percent intervals, and then 20the major testing plateaus at five percent intervals.

21That five percent test plateau includes 22passive data collection, which includes the vibration 23 monitoring, radiation monitoring and plant parameter 24 monitoring. The active testing is associated with the 25 40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433stability of the various pressure control and 1 feedwater level control systems.

2We will perform data analysis of both the 3active and passive testing, and then that data will be 4reviewed by station management through the Plant 5Operations Review Committee, and then submitted to the 6 NRC for review.

7This next slide just shows an overview of 8the various tests that are performed at the power 9 levels. Across the top of the slide, you'll see the 10 percent for current license thermal power, and the 11 intervals that we're doing the testing. Those power 12levels in red, that are red highlighted, are those 13 associated with the five percent test plateaus at 14which data will be transmitted to the NRC for review.

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

21For power ascension testing acceptance 22criteria, there's two major levels. The Level 1 23acceptance criteria is associated with a limit 24 associated with plant safety.

25 41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 If we reach a Level 1 criteria, we abort 1from the test. We reduce power level to a known safe 2condition, and that would be the power level at which 3the Level 1 criterion was verified met, and that we 4will use our corrective action program to evaluate the 5condition and determine required actions. Then we 6 will repeat the testing, to verify Level 1 criterion 7 is satisfied and document results.

8Level 2 is the limit associated with plant 9or equipment performance that does not meet design 10expectations, but is not immediately adverse to plant 11 safety. We will perform similar actions, in the terms 12 of we will place the test on hold, and if needed, 13lower power, and then again use the corrective action 14 program to determine the requirements.

15In the Level 2, we may make a 16 determination that the data is satisfactory and that 17we can continue testing. In either event, we will 18have to also document the results as a test exception.

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

22 They have their own acceptance criteria, 23based on tech spec limits, and if we reach one of 24those limits, we would follow the actions in the 25 42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 procedures and the plant technical specifications.

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

5MR. AMWAY: Yes, I can. For a Level 1, 6for the control systems which are tuned, we will 7introduce step changes, for example, reactor pressure.

8We would expect that the system will respond in a 9quarter wave damping fashion, so that any oscillation 10 is quickly dampened, then maintain steady control of 11 the plant pressure.

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

18If we did that same step change, and we 19got a divergent behavior in the oscillations, which 20 means they did not dampen out and in fact got worse, 21then we would have actions in the procedure for how to 22deal with that. That would be a Level 1 criterion, 23 and we would abort that test, to figure out why that 24 happened.25 43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER ABDEL-KHALIK: Okay.

1DR. WALLIS: Are these limit curves 2 evaluated directly by computer, or does someone have 3 to look at this and look at that, and compare them?

4MR. AMWAY: We will have both guidance in 5the procedure for what the operators can look at 6directly by plant instrumentation. But there will 7also be backup confirmatory database reviews of the 8 parameters using computers.

9DR. WALLIS: So there will be something 10set in place, so that when something unusual happens, 11it's right there on the computer or there's a warning 12 or something?

13 MR. AMWAY: That is correct.

14DR. WALLIS: You don't have to wait for 15 someone to look at something?

16MR. AMWAY: That's exactly right. If 17there's no further questions on the power ascension 18test program, I'd like to proceed on to the long-term 19 stability, Option 3.

20In this topical area, I'll discuss an NRR 21audit that was performed at Nine Mile 2 in support of 22our uprate. We'll discuss long term stability, Option 233, and under that topical area, we'll discuss the 24oscillation power range neutron monitor that's 25 44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433installed at Nine Mile 2, the OPRM settings, the 1 backup stability protection.

2We'll discuss the 2003 Nine Mile Point 3 stability event, and conclude with the effects of 4extended power uprate on long-term stability solution.

5Under the ATWS stability, we'll discuss the Unit 2-6specific ATWS mitigation design features, preparation 7for the simulator demonstration that was done in 8 support of the NRR audit.

9We'll discuss the MSIV closure with 10failure to scram and turbine trip with failure to 11 scram events, and then we'll address the conclusions 12 associated with ATWS stability.

13NRR audit was performed at Nine Mile 2 in 14October of 2009. The purpose of that audit was to 15demonstrate procedure actions and operator response to 16ATWS transience, that EPU conditions conform to 17 regulatory requirements.

18The audit reviewed implementation of long-19 term stability, Option 3, and it also observed 20operator performance in the plant reference simulator 21for the two events I discussed, the MISV (ph) closure 22 and turbine trips with failure to scram.

23The audit included a review of related 24 procedures and mitigation strategies, and that audit 25 45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433also concluded in 2009 the simulator was not ready yet 1to show comparison data for EPU versus current license 2thermal power data. That has since been completed and 3 provided to the NRC.

4In terms of a time line for the 5oscillation power range monitor, in 1998, Nine Mile 2 6received Amendment No. 80, which allowed the 7installation of the system, and it ran in the unarmed 8condition while we evaluated the performance of the 9 simulator and performed tuning, to make sure that it 10 was set up for the Nine Mile 2-specific application.

11 In 2000, we received Amendment 92, which 12 armed the system, to make the OPRM trips active. In 132002, we implemented a plant-specific DIVOM curve, as 14 a result of GE Safety Communication 01-01. In 2003, 15we implemented further changes to filter frequency and 16 period tolerance setting for GE Safety Communication 1703-20, and that was as it related to the Nine Mile 18 Point 2003 event.

19For the OPRM settings, we have cycle-20specific DIVOM analysis performed using a TRACG 21 methodology. The cycle-specific amplitude set points 22 are defined in the core operating limits report, and 23for extended power uprate, we have reduced the enabled 24 region from 30 percent of rated thermal power to 26 25 46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433percent of rated thermal power, and that's to maintain 1the level of protection the same for extended power 2 uprate, as it is for current license thermal power.

3For backup stability protection, the 4backup stability protection regions are determined 5 using cycle-specific ODYSY decay ratio calculations, 6and the regions are defined on the plant's power to 7flow operating maps. The backup stability protection 8actions are defined in plant procedures, with routine 9reinforcement in the operator training program, and 10 the BSP exit regions --

11MEMBER ABDEL-KHALIK: So if you'll back to 12 the pervious slide, please.

13 MR. AMWAY: Sure.

14MEMBER ABDEL-KHALIK: The set point for 15recirculation dry flow less than 60 percent. This two 16percent uncertainty between the dry flow, in the 17calibration between dry flow and actual core flow.

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

21 MR. AMWAY: The way we actually have our 22 procedures set up is we implement the enabled region 23 at 62 percent. So it's active up to 62 percent core 24 flow, which gives us margin to the 60 percent 25 47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 requirement.

1MEMBER ABDEL-KHALIK: So even if there was 2--3MR. AMWAY: So even if it was in a non-4conservative direction, we're still bounded the way we 5 set the system parameters.

6 MEMBER ABDEL-KHALIK: By the way you set 7 it up?8 MR. AMWAY: That's correct.

9 MEMBER ABDEL-KHALIK: Okay, thank you.

10MR. AMWAY: On Slide 32, I discuss the 11 2003 stability event. That event was initiated by a 12component failure that resulted in a high to low speed 13transfer of both reactor recirculation pumps. In that 14event, the period-based detection algorithm initiated 15an automatic scram, because of core-wide oscillations.

16The reactor in the post-trip event review, 17we determined that the reactor was properly tripped by 18the period-based detection algorithm. However, we did 19see some unexpected confirmation count resets prior to 20 the scram.

21 The post-review analysis determined that 22two parameter settings needed to be changed, to 23address the confirmation count resets, and those 24parameters changes had been implemented for a BWR 25 48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 owner's group recommendation.

1MEMBER ABDEL-KHALIK: So the net effect of 2 these resets was a delay in reactor trip?

3 MR. AMWAY: That's correct.

4MEMBER ABDEL-KHALIK: And how much of a 5 delay was that, time-wise?

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

9 I can tell you that the backup stability 10 protection actions that the operators would normally 11 take and look for in that event were to the point that 12the operators even saw any oscillatory behavior, when 13the period-based detection algorithms scrammed the 14 reactor.15CHAIRMAN ARMIJO: But we're talking 16 seconds, minutes, hours?

17 MR. AMWAY: Seconds.

18 CHAIRMAN ARMIJO: Seconds, okay.

19MEMBER ABDEL-KHALIK: So you'll follow up 20 on this, and let us know?

21MR. AMWAY: I will follow up on the actual 22time delay between when we think the reactor should 23 have --24MEMBER ABDEL-KHALIK: Should have tripped, 25 49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 and the time when it actually tripped.

1MR. AMWAY: Correct, and when it actually 2 did, but that is a period of seconds.

3 MEMBER ABDEL-KHALIK: Okay, thank you.

4MR. AMWAY: You're welcome. Effects of 5extended power uprate on the long-term stability 6 solution. There are no methods changes for extended 7power uprate. The maximum rod line remains the same, 8and that is the maximum extended load line limit 9 analysis boundary.

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

13Option 3 long-term stability solution remains 14unchanged, and the Option 3 OPRM set points will be 15developed based on plant-specific DIVOM curves for the 16extended power uprate cycle-specific reload analysis.

17That concludes the overview of the Option 18 3. We'll move on to the next topic area, the ATWS 19mitigation for Nine Mile 2. We'll start off with a 20review of the mitigation system design features at 21 Nine Mile 2. We have a redundant reactivity control 22system that is there to protect against ATWS events 23 and provide mitigation actions.

24That system is initiated on RPV high 25 50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433pressure of 1,065 psig. At time zero, once that 1 system actuates, we get a backup scram method, which 2 is the alternate rod insertion. At the same time, 3time zero, we get an automatic reactor recirc pump 4trip, to slow speed. Normally, the plant would be at 5 high speed operation of the recirc pumps.

6At 60 hertz operation, that would transfer 7to low speed at 15 hertz. At 25 seconds into the 8transient, which the IRCSS is initiated if reactor 9power remains above four percent, which means the ARI 10 was ineffective at completing the scram, then we get 11 an automatic feedwater runback.

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

18If reactor power remains above four 19 percent, at 98 seconds, we get automatic boron 20injection, and that's with both trains of standby 21 liquid control.

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

24MR. AMWAY: The 98 seconds is a timer 25 51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433that's built into the redundant reactivity control 1 system. In our accident analysis, we assume 120 2 seconds. So the 98 seconds bounds the 120 second 3 analysis.4When we prepared for the simulator 5demonstration, that demonstration was performed in 6 2009. So it was before any operator-specific EPU 7 training on EPU conditions. The crews were provided 8 with a 10 or 15 minute brief, just to say this is what 9EPU is in terms of power levels, steam flow, feedwater 10flows, and I used an SRO for the demonstration that is 11 not part of the extended power uprate team, to avoid 12 biasing the operator response.

13The purpose of the setup was to confirm 14the expectation that the current procedures that exist 15today, and the actions and action times, are 16sufficient to address the ATWS event at EPU 17conditions, post-EPU compared to current license 18 thermal power.

19The initial conditions that we set up 20prior to the demonstration. We establish a reactor 21 power, a full EPU power level of 39.88 megawatts 22thermal and 99 percent core flow, which is consistent 23with the upper end of the MELLLA boundary. We 24establish a pressure pool temperature at 90 degree 25 52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 Fahrenheit, and a suppression pool level at 199.5 1 feet. Service water temperature, 84 degrees 2Fahrenheit, and no control rod motion occurred during 3 the scram.

4These initial conditions are consistent 5 with worse case conditions that could occur prior to 6the ATWS initiation, and it's also consistent with the 7 design analysis inputs.

8As a result of that demonstration, we 9confirmed that the operators are able to place both 10loops of suppression pool cooling in service in 404 11seconds, which is well within the assumed action time 12of 1,080 seconds. We were able to achieve hot 13shutdown in 406 seconds, and we maintained peak 14 suppression pool temperature below the heat capacity 15 temperature limit, with a five degree margin.

16It's also important to note that five 17degree margin is based on a pressure band of 800 to 181,000 pounds, which is the normal pressure that we 19 would maintain post-ATWS, until we confirmed that we 20 were in hot shutdown. There is alternate strategies 21available, that if the approach the heat capacity 22temperature limit, we would take manual action to 23 reduce reactor pressure, to gain margin for the heat 24 capacity temperature limit, and avoid the blowdown.

25 53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER ABDEL-KHALIK: Do you have a 1schematic of how your power flow map will change after 2this power uprate? I'm particularly interested in the 3 upper right corner of the power flow map.

4MR. AMWAY: I do have that. If it's okay, 5if you let me get through here, before I conclude this 6presentation I can bring up my backup slides and show 7 you the power to flow map.

8 MEMBER ABDEL-KHALIK: Thank you.

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

14CHAIRMAN ARMIJO: Yes. Probably we'll 15finish this part of the presentation, then take a 16 break, and so --

17MR. AMWAY: I can review the two loop 18 power flow map right at the end of this presentation, 19 I've got a few more pages, and Joel, that's going to 20be my backup Slide No. 10, if you want to get that 21 ready.22 So continuing on with Slide No. 37, for 23 the MISV closure with failure to scram, as I stated, 24 the containment parameters remain well within design 25 54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433analysis, and when we evaluated the simulator response 1 to compare critical parameter response, they closely 2 matched the design analysis for that event.

3For turbine trip with failure to scram, we 4 set up the same initial conditions, which again 5conform for the worse case conditions expected, and 6are consistent with the Design analysis inputs for 7that event. The results of the turbine trip with 8failure to scram, we again demonstrated the operators 9can place both loops of suppression pool cooling in 10 service at rated flow, in 425 seconds.

11 Again, that's well within the assumed 12action time of 1,080 seconds. We achieved hot 13shutdown at 465 seconds. We maintained a suppression 14 pool temperature margin to heat capacity temperature 15limit of 19 degrees Fahrenheit. Containment 16parameters remained well within design limits, and 17again the plant reference simulator behavior, in terms 18of critical parameter response, closely matched the 19 analysis.20 MEMBER ABDEL-KHALIK: Well, what are you 21 trying to prove by the fourth bullet?

22MR. AMWAY: The fourth bullet being the 23 containment parameters --

24MEMBER ABDEL-KHALIK: Right, indicated by 25 55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 the simulator.

1MR. AMWAY: Oh. It would be the fourth or 2 the fifth bullet then?

3MEMBER ABDEL-KHALIK: Either this slide or 4 Slide 37. It's the same kind of information.

5MR. AMWAY: Okay. The containment 6 parameters, I'm speaking there in terms of the 7suppression pool, peak temperature, the containment 8 pressures in both the dry well and the supp chamber, 9 those are the parameters I'm discussing.

10The design analysis assumes approximately 11six to seven psig for these events. That's largely 12driven by the expected suppression pool temperature 13 response.14MEMBER ABDEL-KHALIK: But I was just 15 trying to get to the point of what are you trying to 16-- let's go back to Slide 37, please. So if we look 17 at the fourth bullet here, okay, what are you trying 18 to prove with this statement?

19MR. AMWAY: What I'm trying to prove is 20that the operator -- that we can meet the operator 21response times, and maintain the containment parameter 22within design assumptions, or design analysis for 23 these events.

24MEMBER ABDEL-KHALIK: Is this a reflection 25 56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433on the simulator model, or a reflection on the design 1 analysis, or a reflection on the operator ability to 2 respond to the event?

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

5MEMBER ABDEL-KHALIK: So this is not a 6 statement regarding the fidelity of the simulator?

7 MR. AMWAY: No.

8MR. INCH: The simulator's not an 9engineered model. We don't use it for design. We use 10it for operator training. It's been benchmarked to 11plant data, and transient data in accordance with the 12 guidance. I think there's, you know, for simulator 13 fidelity.14 MEMBER ABDEL-KHALIK: And that's why I'm 15asking the questions, right. The simulator is not an 16engineering model. It's simply an empirical model 17 that's fit to analysis and plant data. So what does 18 this statement tell you, other than --

19MR. AMWAY: What I was trying to 20demonstrate was the simulator was providing an 21accurate training tool to the operators in this event.

22So what I did was I looked at critical parameters. So 23I'll give you an example. For the boron initiation 24 temperature, 110 degrees.

25 57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433The analysis assumption assumes that we 1 would reach that temperature limit of 110 degrees in 259 seconds. When I reviewed the simulator data, it 3 achieved 110 degrees in 60 seconds.

4 MEMBER ABDEL-KHALIK: Sure, because --

5MR. AMWAY: In other words, it's just a 6qualitative analysis to say the simulator's performing 7similarly to how we expect the plant to behave, based 8 on our design analysis.

9MEMBER ABDEL-KHALIK: But isn't that a 10 circular argument? If the simulator is based on the 11analysis, wouldn't you expect it to perform according 12 to what the analysis said it should do?

13MR. AMWAY: I would, and I'm not trying to 14 qualify the simulator by that, but just to make sure 15 that we have the simulator modeled to match what the 16 design analysis says.

17CHAIRMAN ARMIJO: But basically, the 18operators didn't have to do anything different for 19 this event at EPU than they would have done at current 20 licensed thermal power?

21 MR. AMWAY: That is correct.

22CHAIRMAN ARMIJO: And you demonstrated 23 that.24 MR. AMWAY: That's right.

25 58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433CHAIRMAN ARMIJO: That's what I get out of 1 this.2MR. AMWAY: And that's really what we were 3 trying to demonstrate with this, that we can use the 4same EOPs, same EOP actions, same action times and 5 mitigate the event.

6CHAIRMAN ARMIJO: But if, just for this 7 slide, the only thing that you might expect to have 8 changed was the margin on the suppression pool 9 temperature.

10MEMBER SHACK: Well, if he actually, if 11the operators took 1,500 seconds rather than 404 12seconds, then the other bullets wouldn't have 13 followed.14 CHAIRMAN ARMIJO: Sure.

15 MR. AMWAY: That's correct.

16 MEMBER ABDEL-KHALIK: Oh, I see.

17MEMBER SHACK: I mean that's -- so it 18really is a test of the operator action, assuming that 19 in fact the design analysis --

20 MEMBER ABDEL-KHALIK: Is valid.

21MEMBER SHACK: Is valid. But you know, 22 what else can you expect?

23MEMBER ABDEL-KHALIK: In a sense, you 24know, if the response on the procedure matches the 25 59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 assumptions in the analysis, and since the --

1 MEMBER SHACK: Because you expect it to.

2 (Simultaneous speaking.)

3MEMBER ABDEL-KHALIK: The simulator is 4sort of fit into what the analysis says, you would 5 expect it --

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

10MEMBER ABDEL-KHALIK: I think I 11 understand.

12MR. AMWAY: That brings me to Slide No.

1340, the conclusions. The conclusion of the 14demonstration showed that the existing procedures, 15 operator reaction times and strategies are effective 16 in mitigating ATWS and ATWS instability events.

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

23CHAIRMAN ARMIJO: If you could bring up 24 that backup slide and take a look at it before we take 25 60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 a break.1MR. INCH: We want to take a break first, 2 to look at it.

3CHAIRMAN ARMIJO: Well, you know, I'd like 4 to wrap it up with this, because this is --

5 (Simultaneous speaking.)

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

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

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

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

13We're a little bit ahead of schedule. Just take a 14 minute, to kind of freshen your mind.

15(Off record discussion between panel 16 members.)17CHAIRMAN ARMIJO: Yeah, why don't we do 18 that? We'll reconvene at 10:00, give us a 15 minute 19 break.20 (Whereupon, a short recess was taken.)

21CHAIRMAN ARMIJO: Okay, let's come back 22into session. I think now we'll address the question 23 before the break on the power flow map.

24MEMBER ABDEL-KHALIK: I think you 25 61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 indicated that you will stay on MELLLA.

1 MR. AMWAY: That's correct.

2MEMBER ABDEL-KHALIK: Could you show us 3where the boundary is before the power uprate, and 4 where it's going to be after the power uprate?

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

11So right now, the operating point, this is 12shown for extended power uprate, but our current 13licensed thermal power is at roughly 85 percent, which 14 would be about right across in here, okay.

15So the expanded domain is really above 16this line, up to in this triangular area right here is 17the EPU power level. Where we're permitted to operate 18is anywhere within the white regions or the green 19 regions, okay.

20So the difference between current license 21thermal power and extended power uprate is this domain 22that used to be our MELLLA domain. It's considerably 23shrunk by, there's actually two lines shown here. The 24Gulf 1 line that's indicated by this marker right 25 62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 here, is the 100 percent rod line.

1So the 100 percent rod line is defined as 2 the rod line at which if you get to 100 percent core 3flow, you should be at 100 percent of rated power.

4There is actually a thin boundary domain within those 5two lines. It's very small. It's on the order of one 6 percent.7 So we have used most of that MELLLA 8operating room to achieve the uprate power level, such 9 that when we're at 100 percent of EPU power level, 10 we're in this corner.

11MEMBER ABDEL-KHALIK: So you don't have 12 much --13 MR. AMWAY: We don't have much operating 14 room, which underscores the reasons why we're trying 15 to restore the original design margin in the reactor 16recirc system, which will enable us to go into the 17 green region here, which will give us the operational 18 flexibility we need at 100 percent of rated power 19for, you know, to account for small pattern 20adjustments of the control rod system, and for, you 21 know, depletion of the fuel cycle.

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

24 MR. AMWAY: I cannot go into this yellow 25 63 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 region.1 MEMBER ABDEL-KHALIK: Right.

2MR. AMWAY: I can only go, this is my 3boundary to the left, and I can go all the way to the 4 green boundary on the right.

5 MEMBER ABDEL-KHALIK: Five percent.

6MR. AMWAY: It's roughly about five 7 percent.8MEMBER ABDEL-KHALIK: How much will you 9 gain by this improvement in the jet pumps?

10MR. AMWAY: Right now, and I'll ask George 11 to back me up a little bit on it, but we were going to 12-- we would not be able to achieve EPU power level 13 with the existing condition of the jet pumps.

14We would maximize our core flow, and we 15would not be at an operating point consistent with 16100 percent EPU power level. George, did you want to 17 add anything else?

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

19MEMBER ABDEL-KHALIK: So currently on this 20map, where is your maximum core flow, given the fouled 21 condition of the jet pumps?

22 MR. INCH: Approximately 97 percent core 23 flow.24 MR. AMWAY: So that would be --

25 64 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. INCH: At our current power level.

1MR. AMWAY: --about right in this region.

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

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

6MEMBER ABDEL-KHALIK: So is there a 7condition being proposed, that the power uprate be 8limited pending demonstrated performance of the 9 refurbished jet pumps?

10 MR. GUZMAN: This is Rich Guzman. We do 11not have a proposed license condition on that at this 12 time. But certainly we'll take that in development of 13our final safety evaluation. But I will certainly 14talk to the staff regarding that matter, and update 15our safety evaluation as needed, to address that 16 matter.17MR. INCH: But we definitely don't believe 18 there is any need for any license condition. I mean 19 that's a limitation of --

20MEMBER ABDEL-KHALIK: But you're assuming 21 that when you do that, you'll get the right flow, to 22allow you to go to, you know, 120 percent of the 23 original license thermal power.

24MR. INCH: If, for example, if the jet 25 65 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433pumps don't perform as designed, then we'll have a 1shortfall in core flow, and we may not be able to 2complete the test program up to 120. But more than 3 likely what will happen is that we won't be able to 4use the full increase core flow domain. But we'll be 5 able to get to 120 percent.

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

11MEMBER ABDEL-KHALIK: Okay. The point is 12currently, the way the plant is, you can't get the 13 core flow required to allow you to remain within the 14 power flow map at 120 percent power.

15MR. INCH: I'd state it a little bit 16 differently.

17 MEMBER ABDEL-KHALIK: Okay.

18MR. INCH: We'll be within the power flow 19 map.20 MEMBER ABDEL-KHALIK: Okay.

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

22MEMBER ABDEL-KHALIK: To reach 120 23 percent.24 (Simultaneous speaking.)

25 66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. INCH: --full power. But at all 1 times, we're within the licensing envelope.

2MEMBER ABDEL-KHALIK: Sorry, okay. That's 3 fine.4 MR. INCH: So that's why I was saying --

5MEMBER ABDEL-KHALIK: Well, wouldn't it be 6 reasonable then? I mean in other words, achievement 7of 120 percent power and remaining within the power 8flow map is contingent upon your ability to improve 9 the jet pump performance?

10MR. INCH: Well, it's really an 11 operational flexibility issue, and Phil --

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

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

16MR. INCH: Well, you can get there without 17a flow window. Even with fouled jet pumps. You know 18 with clean jet pumps, we're going to be able to get to 1999 percent core flow. We'll be able to get to the 20 full 105 percent core flow window.

21There's no reason to anticipate any reason 22 why we wouldn't, because the design analysis and all 23the original start-up testing supports that with a 24 clean jet pump, we'll get there, you know.

25 67 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 Even with the higher DPs associated with 1 EPU, all the numbers say we'll be able to get to 104 2percent rated core flow. So we'll be within the power 3 flow map the whole time.

4MEMBER ABDEL-KHALIK: I guess this is 5 really not the place to argue it, but you know, my 6feeling is that without demonstrated performance of 7 the new jet pumps, it's --

8MEMBER SHACK: That's sort of his problem.

9 He has to stay within the power flow map.

10 MR. INCH: Right.

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

13 MEMBER ABDEL-KHALIK: Regardless.

14MR. AMWAY: I've got nothing that tells me 15I can deviate. The way I see it, I mean we're taking 16out the existing inlet mixers, replacing them with the 17same type of inlet mixer that I have today. The 18 reason why I'm doing that is to restore the original 19design margin of what the system was designed to do 20 from day one when the plant was built.

21It's not really a change, in terms of a 22 different type of jet pump that would have different 23flow characteristics. It has all the same flow 24 characteristics of the jet pumps today.

25 68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 CHAIRMAN ARMIJO: And you'll demonstrate 1 that in your power ascension test program.

2 MR. AMWAY: Right.

3CHAIRMAN ARMIJO: So it's a flexibility 4 issue, really.

5 MR. AMWAY: Yes.

6MEMBER ABDEL-KHALIK: We'll just argue 7 this point. We'll think about it. Thank you.

8MR. AMWAY: Are there any other questions 9 on the power flow map?

10 CHAIRMAN ARMIJO: Just keep it around.

11 (Laughter.)

12CHAIRMAN ARMIJO: All right. I think 13 we're going to go now to Peter.

14MR. INCH: Oh, I do have an answer to the 15 materials question, the 316 stainless.

16 CHAIRMAN ARMIJO: Oh yes.

17MR. INCH: It's not the nuclear grade, but 18 it is low carbon.

19 CHAIRMAN ARMIJO: Right.

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

21CHAIRMAN ARMIJO: Probably .03, isn't it?

22MR. INCH: .023, I believe. It's a low 23 carbon.24CHAIRMAN ARMIJO: It's a low carbon, 25 69 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 right. Okay. It is --

1 MEMBER SHACK: The spec on low carbon is 2.03, so he's well within that.

3 CHAIRMAN ARMIJO: 03, yeah. Okay, thank 4 you.5MEMBER REMPE: Maybe it's a closed session 6question, but are there other plants that have used 7these new jet pumps with this new coating and had 8 great experience? Or would you rather talk about it 9 later?10 MR. INCH: I think we need to discuss it 11 later on that.

12 MEMBER REMPE: Okay.

13 MR. AMWAY: Thank you.

14MR. GUZMAN: Good morning. At this time, 15 the NRC staff will be presenting the Nine Mile Point 16 2 EPU ATWS instability review, specifically covering 17the audited areas that they covered, which the 18licensee did mention earlier. This presentation will 19 be followed with an open session version of the fuel 20methods discussion by Dr. Yarsky, and then at that 21 point, we'll go to closed session.

22All right. So with that, I'm going to 23turn it over to Dr. Huang, to introduce his team, and 24 go with the first slide.

25 70 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433DR. HUANG: Yes. I'm Tai Huang, from 1Reactor System Branch, along with Dr. Jose March-2Leuba, who will present the subcommittee member on the 3 staff evaluation on the Nine Mile Point 2 EPU.

4There are two portion of the review. One 5is, you know, the submittal of available documents on 6their Option 3, long-term stability solution 7implementation, and second one would be the staff 8audit on their simulator, to verify whether their 9operating reactor, operating procedural to the 10 training of their operator are adequate.

11So that current long-term stability 12implementation, according to the staff evaluation, 13 it's adequate for EPU. They satisfy the 10 CFR Part 1450 design criteria 10 reactor design, and 12, 15 suppression of the reactor power oscillation.

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

23 You know, in their run, I mean the license 24run, you see they're using less than 120 seconds 25 71 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 there. Nine Mile Point 2 EOP adequate for EPU, as the 1 staff evaluation in SER shows. As we go on for that 2 generic, you know, on that power flow map here, what 3 the different from the curling (ph) thermal power to 4 the EPU, you can see, you know, that in the power flow 5 diagram here, you know, curling thermal power is 6 right, corner is right here.

7MEMBER SHACK: You need to do it on the 8 mouse, I think.

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

10 CHAIRMAN ARMIJO: Use the mouse.

11DR. HUANG: Yeah, okay, and then EPU be 12extended out on that same narrow line to the EPU 13 corner. You see the power flow map just is shorter.

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

17The end point would be the end point, 18following the pump trip, right here on the corner. So 19 EPU and curling thermal power condition and not that 20would be the same point there. So that try to make 21 EPU does not change the end point after the 22 recirculation pump trip. So that diagram show this.

23Next slide. Now there are two parts. One 24is Option 3, long-term stability implementation on the 25 72 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 stability issue. You know the story on that, in the 1licensee's presentation. This is just summarized.

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

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

11So there's no impact expected for EPU.

12Option 3 and DIVOM methodology are applicable to this 13 plant. Now ATWS, the second part on the ATWS 14instability, that the Nine Mile Point 2 has 15implemented latest EPZ and SAGs. So early level 16reduction in boron injection are accomplished through 17 automated ATWS action. If high pressure is detected 18with power grid at four percent, then there's 19 automatic flow runback, automatic boron injection.

20At Nine Mile Point, we had excellent ATWS 21response, because they have a select system injections 22through high pressure core spray system on the top.

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

25 73 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433So 100 percent water driving feedwater, 1yeah, for this Nine Mile Point 2. So EOPs are 2reviewed every cycle, but are not affected 3 significantly by EPU, because boron is injected in a 4high pressure core spray system, and there is no need 5to define a hot shutdown boron weight, you know, 6 because from the top down.

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

11Now staff, second part. The staff has 12audited, and the purpose of that when staff review the 13performance, OPRM, there are two parts. OPRM Solution 143 system in the simulator, and staff reviewed the ATWS 15 performance in the simulator as three events.

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

20CHAIRMAN ARMIJO: The upper right-hand 21 corner.22DR. HUANG: I understand that, okay.

23Mainstream oscillation valve, oscillation case ATWS 24from the MELLLA corner, and also from EPU conditions.

25 74 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433So we compare to that, and we can show on later slide 1what the difference between EPU and curling thermal 2 power condition.

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

11DR. MARCH-LEUBA: I'm Jose March-Leuba 12from Oak Ridge National Laboratory, an NRR consultant, 13 and the recent discussion this morning about what is 14 the purpose of doing simulator calculations of ATWS.

15Let me reemphasize your conclusion, that it is to 16 review the operator actions.

17You can ask Dr. Yarsky, who has 18presentation 20 minutes from now, how long it takes to 19run an ATWS calculation with engineering code, and 20he'll tell you several days, if not weeks, of CPU 21 time.22This is with multiple restarts and 23multiple stops and backtracks, when the computer 24didn't do what it was supposed to, and five engineers 25 75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433looking at the results, to see what feedwater strategy 1 you should have been using.

2So we have two types of scenarios. I mean 3one is a very accurate code trace, for example, of 4 Type G, that very accurately models the conservation 5of energy, mass and momentum and does everything well.

6On the other side, we have a pretty good simulator 7model, but it has a human in the loop, as the real 8 operator doing the real control system on real time.

9The first 120 seconds go in that time real 10 fast. So it is not abundantly clear to anybody 11looking at it that with the 120 seconds, operator will 12be able to do anything. So the purpose of this audit 13that we performed was to go and in the real simulator 14with real operator, to see what they're supposed to 15 do. My goal, just to give you a visual, is do we need 16Superman in the control room to do everything that 17 we're asking these operators to do?

18The conclusions after watching this is 19indeed, we don't need Superman in there. The 20operators are really well-trained, they're very 21professional, and if I were to show you a video of the 22 operators handling an ATWS, and operators handling a 23control room in motion, you will not see the 24 difference if you didn't have audio with it.

25 76 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433The operators just walked to the panel.

1They're not running from panel to panel. There's one 2 operator in charge of level control; there's another 3operator in charge of the control rows, and they're 4doing their job. Indeed, the timing turned out to be 5-- the 120 seconds turned out to be very realistic.

6 So that was the purpose of --

7MEMBER ABDEL-KHALIK: During these 8observations, the operators knew in advance what event 9 they're going to be responding to?

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

13So by the time you do the third simulation, they 14already know the procedures by heart, okay. So there 15 is a variability from time to time, but not always.

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

23So they, we do change. We put some 24 variability in the system. But even if they were to 25 77 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433know it in advance, they have the procedures in big 1 panels and there's a flow chart, and the first thing 2 there the senior operator does is go get the right 3 flow chart, put it on top of the table, and he's just 4 following it.

5He gets his marker, that's done. We enter 6in this branch, that's done. So they're well-trained.

7 They're well-trained in advance. It's maybe knowing 8what training scene they're going to get reduces their 9anxiety a little bit, but I don't think it changes the 10 results.11So the real difference was probably 12 adrenalin. I realize the adrenalin will be flowing a 13 little differently, and they might be doing things a 14little faster. But that's where training comes on.

15You do faster the right procedure, and they do follow 16 procedure.

17No operator goes and touches any panel 18unless the senior operator from behind says "it's time 19 to do EOP 3G," and gives the order. So here we have 20 very small description, because I don't want to show 21the details. Two MSRV closures, a cooling seal, 22cooling licensing thermal power at EPU. The very 23first thing that happens, you have this kickout here, 24 which this is the MSRV closure.

25 78 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433You have a big pressure transient, and 1they have this on both. Right after that, you trip 2 the pumps, and the moment you trip the pumps, both 3CLTP and EPU become the same condition. Then you see 4 approximately the same thing happens.

5There are some difference out here, and 6 this is not due to the initial condition. It's what 7the operator did differently in these two runs. This 8 run was done before, and this has to do with 9maintaining level once you reach the fuel, and he did 10it better on the second run. But there is no 11 significant difference between the two.

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

19This is in part because Nine Mile Point 2 20is a really great ATWS plant. I mean if God forbid we 21don't have an ATWS, but we're allowed to have an ATWS.

22 (Laughter.)

23DR. MARCH-LEUBA: Because everything, 24everything is right in that plant. I mean everything 25 79 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 is done automatically. The boron is injected in the 1top of the core, so it is no issue with remixing, and 2 there's plenty of margin to everything.

3CHAIRMAN ARMIJO: A slight reduction in 4 margin is just the result of having more heat to get 5 rid of, or is that an artifact of the --

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

9 CHAIRMAN ARMIJO: The actual.

10DR. MARCH-LEUBA: Oh, you're talking about 11 the --12CHAIRMAN ARMIJO: The actual could be 13 higher, wouldn't it? You're getting rid of more.

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

21 CHAIRMAN ARMIJO: Yes, okay.

22 DR. MARCH-LEUBA: The difference between 23EPU and OLTP is in decay heat. There, you have 20 24percent more decay heat. But as long as you don't go 25 80 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433into a one week extended outage, decay heat is 1 removed. It's before your scram and you are still 2putting 50, 60 percent power into your containment.

3 That's what you have in ATWS.

4So in summary, the staff found the EPU 5 operation acceptable from a stability point of view, 6 because the long-term solution, which is Solution 3, 7provides exactly the same level of protection under 8EPU than under the coolant power. Therefore, the OPRM 9scram and the OPRM procedures satisfy the GDC, general 10design criteria 10 and 12, which is the criteria that 11 we have to satisfy.

12On the ATWS scenarios, really the ATWS 13stability is not affected significantly by EPU event, 14and it's because after you trip the pumps, you are in 15 exactly the same condition. I mean that satisfy all 16our acceptance criteria, which are three criteria, if 17 you remember.

18They are the core coolability, meaning you 19don't destroy your fuel and put it in the bottom of 20the vessel; you maintain vessel integrity; and you 21maintain containment integrity, and the containment 22integrity has to do with the suppression pool 23 temperature we were talking about before.

24 Just to emphasize that Nine Mile Point 2 25 81 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433has an excellent ATWS pro forma design, and I wish all 1the plants were like it. I mean it has automatic 2 trips, so we really don't even have to worry about the 3operator doing the right thing. The control system 4will do it for them. They inject the boron on the top 5of the core, so there's no mixing problems, and the 6feedwater pumps are 100 percent motor-driven, meaning 7 that there is no issue with how much availability of 8inventory to maintain level in the vessel during ATWS, 9 and that's the end of our presentation.

10CHAIRMAN ARMIJO: Any questions? I 11 suspect one. Thank you.

12MEMBER ABDEL-KHALIK: What is the last 13 bullet?14DR. MARCH-LEUBA: If you do not have 15motor-driven feedwater pumps, which many plants don't; 16they use steam-driven, the moment you close the MSRV, 17 then you don't have steam for those pumps and you 18don't have feedwater, and you rely on other ACCS 19 systems, which are not as large.

20If you were to increase, in some of these 21plants, if you were to increase the power 22significantly, you will not have enough. HPCI will 23 not be sufficient to maintain level. Here, you have 24 100 percent feedwater available. You don't have any 25 82 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 problems.1 MEMBER ABDEL-KHALIK: Okay, thank you.

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

5DR. YARSKY: Hello. I'm Dr. Peter Yarsky 6from the staff. I'm a member of the Office of 7Research, and I'm going to be talking about the 8applicability of the interim methods to the Nine Mile 9Point 2 extended power uprate LER. The basis for our 10methods review was the safety evaluation for the 11interim methods license and topical report, NEDC-12 33173P.13In the course of our review, we have 14confirmed that the EPU LER is fully consistent with 15 all of the conditions and limitations in the staff's 16SE for the IMLTR. The IMLTR specifies 24 different 17conditions and limitations. In the Nine Mile Point 2 18EPU application, no supplements to the IMLTR are 19 referenced.

20The Appendix A to the power uprate safety 21analysis report provides the disposition of each of 22 the conditions limitations, and in the course of our 23review, we found that all 24 conditions limitations 24were acceptably met. In the course of our review, we 25 83 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433conducted one regulatory audit pertaining to the 1 IMLTR.2Then the audit had to do with initially 3guiding LPRM calibration interval. The frequency with 4which the LPRMs are calibrated, that's sometimes 5 referred to as the LPRM update, affects core monitor 6 accuracy to predict core power distribution. In the 7 Nine Mile Point 2 technical specifications, the LPRM 8calibration interval is specified in units of 9effective full power hours. So at EPU conditions, the 10equivalent exposure interval between LPRM calibration 11intervals would increase along with the thermal power 12 by approximately 15 percent.

13We asked RAI SMPB-1, which was the only 14RAI coming from the methods review, to address LPRM 15calibration interval, and the outcome of that RAI was 16 that the staff conducted an audit at GEH, to confirm 17that the power distribution uncertainties were 18 acceptable for this longer exposure interval.

19MEMBER ABDEL-KHALIK: Was this issue 20 raised at the original stretch uprate?

21DR. YARSKY: I'm not familiar with the 22 stretch power uprate review.

23MEMBER ABDEL-KHALIK: But it would have 24 been equally applicable, wouldn't it?

25 84 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433DR. YARSKY: The extension of the 1interval, yes, would have been applicable, but not 2 equally applicable --

3 (Simultaneous speaking.)

4MEMBER ABDEL-KHALIK: Well, I mean 5 essentially the same issue.

6DR. YARSKY: Yes. I personally became 7first familiar with this topic during the review of 8the Monticello EPU, and the conclusion and resolution 9of that issue was different in Monticello than for 10 Nine Mile Point 2.

11 MEMBER ABDEL-KHALIK: Okay.

12DR. YARSKY: Yes. The Subcommittee was 13briefed on this issue during a generic review related 14 to interim methods, I believe, in August.

15 CHAIRMAN ARMIJO: This summer.

16DR. YARSKY: It is June, in June. So it's 17the same topic, just applied on a plant-specific 18 basis. 19CHAIRMAN ARMIJO: Peter, if the 20uncertainties hadn't been acceptable, wouldn't the 21solution be pretty straightforward? You just 22 recalibrate?

23DR. YARSKY: The solution would have been 24 straightforward. It could easily have been an 25 85 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433adjustment to the LPRM calibration level. That has 1 been done by other licensees seeking power uprate.

2 CHAIRMAN ARMIJO: Okay.

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

4CHAIRMAN ARMIJO: That's it. Okay. Well 5then I think we're ready to go into closed session, 6 and first I'd like the staff and the applicant to 7confirm that the right people are here, and that 8 nobody's on the bridge line that shouldn't be on the 9 bridge line.

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

12 13 86 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 O P E N S E S S I O N 1 10:59 a.m.

2 CHAIRMAN ARMIJO: Ready to go.

3MR. AMWAY: Okay. Before we begin the 4material mechanical civil discussion, I wanted to 5respond to the open question on the quantifying the 6scram delay back in the Stability section, where I 7presented the 2003 stability event for Nine Mile Point 82, and the question of that was what kind of time 9delay do we have from the onset of oscillation to 10where we should have scrammed to when we actually 11 scrammed the reactor.

12The answer to that question is 15 to 20 13 seconds.14CHAIRMAN ARMIJO: That's the delta between 15the ideal and the somewhat delayed because of the 16 resets?17 MR. AMWAY: The time delay from when the 18OPRM should have scrammed the reactor, based on 19confirmation counts, and when it actually did, that 20 total delta is 15 to 20 seconds.

21CHAIRMAN ARMIJO: Okay, and with the 22corrections and the updates, that has disappeared 23 where you expected?

24MR. AMWAY: That's correct. That would 25 87 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 eliminate that 15 to 20 second delay.

1MEMBER SHACK: And you're not going to run 2 an experiment to verify that?

3 MR. AMWAY: That is also correct.

4CHAIRMAN ARMIJO: And we don't expect you 5 to.6 MR. INCH: My name is George Inch. I'm 7the physical engineer for mechanical structural for 8the power uprate of Unit 2. I'm going to be going 9through the reactor pressure vessel internal materials 10issues, and related flow-induced vibration 11 evaluations.

12So for the internals, the EPU evaluations 13included the effect effluence, the effect of flow-14induced vibration, structural effects that are non 15flow-induced vibration-related, and the impact of EPU 16on the current material condition with regard to 17intergranular stress corrosion cracking, and 18 irradiation-assisted stress corrosion cracking.

19The accepted threshold for effluence, 20where irradiation-assisted stress corrosion becomes a 21 significant factor in the growth rate of an existing 22IGSCC flaw and potential IASCC that's accepted in the 23BWR vessel internals program is 5E to the 20 neutrons 24 per centimeter squared.

25 88 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433The existing components that are expected 1to exceed that threshold in the current license term, 2and that's expected, anticipated in the vessel 3 internal program scope are the top guide, the shroud 4 and the core plate.

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

8 MR. INCH: Right.

9CHAIRMAN ARMIJO: So what other components 10 are close to that 5 times 10 to the 20th? You know, 11 these were, this is the same list as pre-EPU.

12 MR. INCH: Yes.

13CHAIRMAN ARMIJO: So as you go up 20 14 percent more in flux, I would expect more components 15 come into this population, and others get closer.

16MR. INCH: Additional components really 17 don't come into the mix. I mean the effluence level 18goes up, but the threshold, that threshold really 19 isn't exceeded by any additional components.

20 CHAIRMAN ARMIJO: So okay.

21 MR. INCH: So that the --

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

23 I mean the question --

24 (Simultaneous speaking.)

25 89 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. INCH: It would be some jet pump 1components that are in the core region. Everything 2 that's going to --

3 (Simultaneous speaking.)

4MR. INCH: And, you know, these are the 5core region components and then, you know, what's 6 outside of the reactor, I mean the core shroud would 7 be the jet pump components. But because of the size 8of the annular region, you get significant 9 attenuation. So those components are, you know, don't 10 approach --

11CHAIRMAN ARMIJO: None of the guide tubes, 12 whether it's drives or instrumentation.

13MR. INCH: All the instrumentation in the 14core is above this, just as a matter of course. So 15 and the guide tubes are all below the core plate, and 16 so you get significant attenuation as you go down.

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

19 MR. INCH: Yes.

20MEMBER ABDEL-KHALIK: What's the condition 21 of your shroud now?

22MR. INCH: The Nine Mile Point 2 core 23shroud has IGSCC cracking associated with the belt 24 line welds. The H-4 weld and H-5 weld have OD IGSCC 25 90 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 cracking. Cracks are approximately 70 percent of the 1 circumference. They're relatively shallow, as it's a 2two inch shroud, and the cracks are less than half of 3 an inch in depth.

4They were first identified in the baseline 5 inspections performed in the 90's. I believe it was 6in '97 where they were identified. We've 7ultrasonically inspected those multiple times, at 8 least four times.

9Since we implemented hydrogen water 10chemistry and noble metals, we haven't seen measurable 11 growth that we consider to be real growth. With UT, 12there's always variation. So you never match it up 13within the uncertainty of the deployment tools and the 14UT devices. But the condition has been stable for at 15 least ten years.

16CHAIRMAN ARMIJO: Are these shrouds 17 clamped? Have you put any of these --

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

19CHAIRMAN ARMIJO: There's no tie rods, so 20it's just as-built, and you're monitoring and testing 21 the cracks?

22 MR. INCH: Yes. The flaw evaluation for 23the core shroud has been updated for the power uprate 24 higher loads for differential pressures. It's, that 25 91 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433flaw evaluation still shows that the normal upset 1event is the controlling event for the core shroud.

2 It's not the faulted event.

3The vertical welds, all the vertical welds 4are clean. There's no cracking on the vertical welds.

5Very minor cracking on other locations, less than ten 6percent, very typical. So the location of the 7indications on the core shroud are consistent with the 8 understanding in the fabrication process. So it was 9 the final weld built --

10CHAIRMAN ARMIJO: After you, on the 11shroud, since you've inspected it a lot, after you 12implemented the hydrogen water chemistry and the noble 13metals, have you found any new cracks that hadn't been 14 there pre-hydrogen?

15MR. INCH: Not that we consider -- we 16don't consider them new. The UTs have evolved over 17the past ten years. I'm always seeing, you know, I 18get a scan and the percent cracking is essentially the 19 same. But we get a little additional coverage at a 20 location. There's a lot of starts and stops, but 21there's been no significant change in with the new 22 cracking.23 CHAIRMAN ARMIJO: Okay, just a couple of 24other things. On the top guide and the core plate, 25 92 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433have you, do you have any -- can you inspect them 1well, and do you have cracks, IGSCC, in those 2 components?

3MR. INCH: The top guide, we have the 4inspection can be performed of the top guide grid 5 beams. That was inspections that were recently added 6 to the VIP program, approximately --

7 MEMBER SHACK: These are enhanced VT1?

8 MR. INCH: These are enhanced VT1, where 9we clear the cell and they have a cleaning process, to 10get the enhanced visual capability. We've done, 11completed an initial deployment of this new tool in 122010, and that worked quite well. So we haven't 13established that Unit 2A baseline yet on the top 14 guide, but we --

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

17MR. INCH: No, no. We've looked at two 18 cells. We've done standard refueling inspections.

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

22But we haven't completed the five percent baseline 23that is recommended as planned for implementation over 24 the next --

25 93 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MEMBER SHACK: Now these are one of these 1 milled top guides, right? Solid, or do you have the 2 interlocking beam kind of thing?

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

5MEMBER SHACK: The 6 is the one that's 6 milled out?

7 MR. INCH: I believe so.

8CHAIRMAN ARMIJO: So these are 9 interlocking, welded?

10MR. INCH: I'll verify that, but I'm 11 pretty sure these are interlocking designs.

12MEMBER SHACK: So there's lots of corners 13 to look at.

14CHAIRMAN ARMIJO: Okay so -- yeah, that's 15the problem. Now the shroud is UT inspectible, but 16 what about the core plate?

17MR. INCH: Core plate at Unit 2, the only 18inspection requirements for core plate are for the 19bolting, and it's part of the program. The evaluation 20that we have right now is a generic evaluation for the 21inspectability of the bolting, and so we have in 22 place, as pretty much all the, most of the BWRs do, an 23interim analyses that shows that the bolting will 24 retain its integrity through the 40-year term.

25 94 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433The VIP is working on alternatives to the 1 inspection recommendations, so --

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

4MR. INCH: Not currently, that's correct.

5CHAIRMAN ARMIJO: Okay. So you're really 6 relying on the analysis and the mitigation afforded 7 by the water chemistry?

8 MR. INCH: That's correct.

9 CHAIRMAN ARMIJO: Okay.

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

17We have taken that fluence out through the 18 60-year term, looked at the peak fluence. We stay 19within the currently accepted range, where hydrogen 20 water chemistry will remain effective.

21MEMBER SHACK: What is that end of life 22 fluence?23 MR. INCH: Let me get back to you. It's 24 less than 10 to the 22, I know that.

25 95 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MEMBER SHACK: It's cold comfort, but --

1MR. INCH: It's above the threshold by 2which radiation-assisted crack growth rate 3acceleration is expected to occur. We also have 4 reduced ductibility of the materials.

5 CHAIRMAN ARMIJO: Sure.

6MR. INCH: So we're within, we're applying 7 the VIP guidance.

8MEMBER SHACK: The normal guide for 9 effectiveness of hydrogen water chemistry, somewhere 10 around three times ten to the 21, and it's sounds like 11 you're probably pushing that.

12MR. INCH: Towards the end of the 60 13 years. Yes, we'll be pushing that number. But let me 14verify, get you a good number on that. But so that 15 covers the slide, I think.

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

20The fluence does everything. It does 21nothing good for you except make power. Your 22radiolysis rate goes up in proportion to the power 23 uprates. So that means the water chemistry gets more 24 aggressive.

25 96 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433But you're compensating that by increasing 1 your hydrogen input rate by the same ratio.

2 MR. INCH: Yes.

3CHAIRMAN ARMIJO: So you are addressing 4 that. Radiation hardening is going to push things in 5the wrong direction. So I looked at your various 6documents, and you're doing everything that I think 7can be done, that addresses the mechanism of this 8 stress corrosion cracking, either IASCC or IGSCC.

9But I just take exception to that 10statement, that it doesn't represent a significant 11increase in potential, because I think it really does, 12and your actions indicate that you kind of think so 13 too. So I don't know where that statement came from.

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

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

23The jet pumps to a lesser extent. As I 24said, it's a 1.9 percent effect there versus an 18 25 97 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 percent on a steam flow.

1DR. WALLIS: So the effect is really a V-2 squared effect? Is that what it does?

3MR. INCH: It's a turbulent -- that's how 4it's evaluated, yes. For those internals, it's a 5 velocity squared due to turbulent loading.

6 DR. WALLIS: Resonance or anything?

7MR. INCH: No. They do a separation 8evaluation to any vortex setting, and that's the 9standard procedure that GE's used. The peak stresses 10for that shroud head remain less than 5,000. GE uses 11a 10,000 psi criteria. So the internals really are 12robustly made. There's significant margin to any FIV 13 issues. 14The top head region where you have the 15 higher steam flow, those velocities remain very low, 16 where you have the spray nozzles and the head or the 17head vent lines. So those stay below two feet per 18second, and the cross-flow configuration has been 19 taken into account, and there's large margins there.

20So the conclusion is, you know, pretty 21clear that there's no impact or detrimental effects on 22 any of the internals due to potential for the FIV.

23Structural effects. You know, the higher 24power levels, you do have higher internal pressure 25 98 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433differences, and there's some small temperature 1 changes. All the analyses are done consistent with 2the original design bases. For Unit 2, there's really 3no structural change has been made to the internals 4that need to be considered. As I said, the 5 thermohydraulic changes are fairly straightforward.

6With the pressure differences and the 7temperature changes, there's a little bit change in 8the carry-under fractions. The way GE does these 9 analyses is with scaling factors to the original 10design, and with that, you know, for example the core 11 plate and core shroud goes from 11,000 to about 1214,000, and that's with primary membrane bending is 13 limiting, with an allowable of 21,450 psi.

14So the shroud head bolt. The limiting 15component there is the T bolt and bearing stress, and 16 that goes from 8,000 to 13,500, with an allowable of 17 18,000. Now that shroud head bolt analyses is taking 18credit for the reduced number of shroud head bolts 19than we actually currently have installed. So it's a 20 conservative evaluation.

21So all the usage factors really didn't 22have for the internals, they didn't have a significant 23 change. The only one of note was really the shroud 24went from .43 to .507. That's primarily due to the 25 99 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 slightly larger temperature variation on heat up and 1 cool-downs. That's not a high cycle fatigue.

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

7We covered pretty well in the questions 8 the, you know, what's been done for IGSCC and IASCC.

9It's procedurally controlled. The program that's been 10implemented has always considered, you know, aging 11effects and the higher fluence level. So the 12selection of the components and the intervals that are 13selected aren't impacted by the higher fluence levels.

14They're still fairly conservative intervals for all 15 the components.

16Like for the shroud, it's a maximum of ten 17years, even with hydrogen water chemistry and 18ultrasonic inspections. We talked about the hydrogen 19water chemistry and noble metals. There is an 20 increase in the hydrogen, just to keep, maintain the 21 three to one molar ratio in the downcomer.

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

24 MR. INCH: At Unit 2, the implementation 25 100 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 of the hydrogen water chemistry currently uses molar 1 ratio. We are evaluation the recently-issued staff 2approved BWRVIP-62-Alpha guidance, where the staff has 3allowed, on an interim basis, to use molar ratio. But 4they want to see electrochemical potential monitoring 5being performed, to credit the hydrogen water 6 chemistry. We haven't implemented that at Unit 2 at 7 this time.

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

10MR. INCH: Yes. That's a very challenging 11 request from the staff right now.

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

14 MR. INCH: Yes.

15CHAIRMAN ARMIJO: You have, also you have 16online noble metal capability, so you don't have to do 17 this during an outage.

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

24 It's much easier to do and less of a plant transient 25 101 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 than the offline process.

1MEMBER SHACK: Thank you, and you don't 2 have to -- I mean this goes on forever. You don't 3ever have to do an offline noble metal injection 4 again?5 MR. INCH: Yes. That's --

6 MEMBER SHACK: That's the goal.

7MR. INCH: That's the qualification of the 8process, yes, that you don't have to ever do an 9offline application. Yes, the details of the process 10 are, you know, I don't think we probably need to get 11 into. But it's a different particle size, much finer.

12 It's engineered to penetrate deeper into cracks, and 13 so --14CHAIRMAN ARMIJO: So this is platinum that 15 you're added or not palladium?

16MR. INCH: Yes. I believe with online, 17they eliminated the, I think it was rhodium that they 18had in there. But it's only platinum. So it's a 19 different cocktail that they're using. But it's 20 fundamentally the same.

21 CHAIRMAN ARMIJO: Okay.

22MR. INCH: I think we already talked about 23the control blade cracking. One of the impacts of 24 power uprate is scaling of the reactor pressure 25 102 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433vessel, you know, nozzles, and one of the -- so the 1scale factors were applied to the design bases fatigue 2 usage, accounting for both 40 and 60 years in design 3 bases.4When we get our license renewal for 60 5years at Unit 2, it was identified that the feedwater 6nozzle and another location in feedwater had the 7 potential to exceed one in the license renewal term.

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

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

21 Those remain the case for the power uprate 22 conditions. The scaling of the -- well, before I go 23to that, the one location that we did select for 24 fatigue monitoring using stress-based monitoring was 25 103 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the feedwater nozzle location. That's not unusual for 1the BWRs. Where that location is part of power 2uprate, we did a fatigue, a refined fatigue usage 3 calc.4MEMBER SHACK: Oh yeah. I guess what 5caught my eye was computing usage with FatiguePro, 6which has generally not been received well, unless 7there's a new version of FatiguePro that eliminates 8 the one stress factor kind of approach.

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

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

18Even with the refined usage, we would still predict 19 the stainless steel clad portion of the feedwater 20 nozzle safe end to be above one.

21 So we're using FatiguePro right now. It 22 was first, the software was first installed in 2008, 23 as a simplified way and a more accurate way to count 24 cycle. We are doing the stress-based monitoring of 25 104 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433this location, and the current FatiguePro software 1does use the simplified greens (ph) function. So the 2 RIS is applicable.

3The EPU scaling is relatively small. It's 4 a six percent to 15 percent change, and --

5MEMBER SHACK: Now does that include an 6 environmental factor?

7 MR. INCH: No.

8MEMBER SHACK: What would happen if I put 9 in an environmental factor?

10 MR. INCH: This usage factor is a design 11bases usage factor. The power, the license renewal 12provisions have evaluations for environmental effects 13in the license renewal term. So the FatiguePro 14monitoring does include environmental usage, and I 15believe there was an environmental usage evaluation 16 done.17I would have to get back to you on this 18particular nozzle, on how environmental fatigue 19 affects these numbers.

20MEMBER SHACK: If you could go back to the 21next bullet, it says there's still a discussion going 22 on, I guess.

23MR. INCH: Well, yes. You know, the whole 24industry is working to address the RIS. There is a --

25 105 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433Structural Integrity is working on a FatiguePro update 1that would address the full NB-32 fatigue methodology, 2and to include environmental fatigue usage in the 3 rules. You know, right now, we're not required in 4 using this to manage below one in the 40 year term.

5So we enter the license renewal term in 62026 at Unit 2, so there's quite a bit of time to get 7this right. We are committed to implementing, you 8know, fatigue monitoring, and as part of that, the RIS 9 requires us to evaluate that, you know, before we're 10actually crediting it for usage below one. So that is 11 what our current status us.

12CHAIRMAN ARMIJO: George, could you go 13 back to Slide 62?

14 MR. INCH: Yes.

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

19MR. INCH: Well, that's the refined 20 calculation.

21CHAIRMAN ARMIJO: But they're two 22 different calculations?

23MR. INCH: Yes. The original calc had a, 24 for multiple events, had --

25 106 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433CHAIRMAN ARMIJO: Well, you would say that 1 was a crude calculation?

2MR. INCH: It was conservative, and you 3 know, there's a way --

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

6MR. INCH: It's the way they did the 7 calcs. If you were less than one, you were done.

8 Everybody knew they were conservative, so --

9CHAIRMAN ARMIJO: Okay. So now this is a 10 refined? 11 MR. INCH: Yes.

12CHAIRMAN ARMIJO: The EPU is a refined?

13 Okay.14MR. INCH: Now when I say "refined," what 15they did is they went back and looked at each 16 particular event, and then for each event, there was 17a thermal FEA, where they looked at what the actual 18 cycling on the stress --

19 CHAIRMAN ARMIJO: It was detailed.

20MR. INCH: It was a detailed accumulation 21 for each event.

22MEMBER SHACK: Now it's got four 23 significant figures rather than three?

24CHAIRMAN ARMIJO: Yeah, right. It's 25 107 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 really good.

1 (Simultaneous speaking.)

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

4MR. INCH: Yes. There's, to get these 5numbers, they started from a natural baseline, and 6then they refined each event, and then refined each 7 cycle and what the usage for each cycle is.

8 9CHAIRMAN ARMIJO: And then they added them 10 up?11 MR. INCH: And then added them up.

12 CHAIRMAN ARMIJO: Okay, got it.

13DR. WALLIS: What is this EPU scaling 14 factor small mean? What's that?

15MR. INCH: You know, relative to what does 16 EPU do to the usage factor?

17DR. WALLIS: But does it mean that without 18the refined calculation, it would actually increase 19 the CUF above one?

20MR. INCH: I'm not sure I understand here.

21DR. WALLIS: Well, to me, it implies that 22 the EPU increases things by 6 percent to 15 percent.

23 MEMBER SHACK: Right.

24DR. WALLIS: So if you use the old CUF 25 108 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 calculation, you get something closer to one?

1 MR. INCH: That's right.

2DR. WALLIS: Okay. So you need to refine 3 the calculation?

4 MR. INCH: Yes sir.

5 DR. WALLIS: Thank you.

6CHAIRMAN ARMIJO: This scaling, it's a 7 stress, scaling on stress?

8 MR. INCH: Yes.

9 CHAIRMAN ARMIJO: Certainly not cycles.

10MR. INCH: Right. It's a scaling on 11 stress.12 CHAIRMAN ARMIJO: Okay, okay.

13 MR. INCH: That's all I have.

14CHAIRMAN ARMIJO: Well, we have a dilemma 15 here. We could take a quick look here. The staff, 16let me ask the staff. Could they get their 17 presentation done in half an hour?

18MR. GUZMAN: Actually, the assigned 19 presenter is not here.

20 CHAIRMAN ARMIJO: Well, that answered my 21 question. I think we'll take an early lunch, and 22we'll be back at 11:30, unless somebody's got an 23 objection to that. At 12:30, I'm sorry.

24 (Simultaneous speaking.)

25 109 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433CHAIRMAN ARMIJO: Okay. We're going to 1 take a lunch. Be back at 12:30. Thank you, Bill.

2(Whereupon, at 11:31 a.m., a luncheon 3 recess was taken.)

4 5 110 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 A F T E R N O O N S E S S I O N 1 12:57 p.m.

2CHAIRMAN ARMIJO: Okay, gentlemen. We're 3going to reconvene. For those who don't know, that 4jackhammer is actually outside. It's not in the 5building, so structurally the building is sound, I 6 think.7MEMBER SHACK: Of course, there's 8 resonance.

9CHAIRMAN ARMIJO: Right. So we'll go 10 ahead. Rich, you put your group is up.

11MR. GUZMAN: Good afternoon again. My 12name is Rich Guzman. Before we transition over to the 13staff giving their presentations on the materials and 14mechanicals and civil engineering reviews, the 15licensee requested to give some clarifications from 16 the morning meeting. I thought this would be a good 17time to provide that, before we start delving into the 18 materials and steam dryer discussions.

19MR. WENGLOSKI: Good afternoon. Phil 20Wengloski, Constellation Energy Nuclear Group. I just 21 wanted to clarify my response. It was brought to my 22attention on the control blade cracking issue, that my 23 answer could have been taken one of two different 24 ways. 25 111 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433The response I intended to give, which was 1 consistent with George's Slide 60, is that we do not 2have the control blade models, marathon models as 3susceptible to the cracking. We may have other 4marathon models present in the core, but not the 5 models that are susceptible to cracking.

6 CHAIRMAN ARMIJO: Is yours a C lattice 7 plant?8 MR. WENGLOSKI: That's correct.

9 CHAIRMAN ARMIJO: Yes, but I saw the 10 comment about C lattice plants having susceptibility 11to this problem, and I think that's very -- I don't 12 want to (papers shuffling). Anyway, it doesn't make 13 any sense to me. But you do have marathon blades in 14 a C lattice plant?

15 MR. WENGLOSKI: Correct.

16CHAIRMAN ARMIJO: And GE has told you 17 that's not susceptible?

18MR. WENGLOSKI: Right. The models that 19 we're using are not susceptible to cracking.

20CHAIRMAN ARMIJO: Time well tell, but 21 okay. But you do have marathon blades?

22 MR. WENGLOSKI: Correct.

23 CHAIRMAN ARMIJO: Okay.

24 MR. WENGLOSKI: Any further questions?

25 112 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 CHAIRMAN ARMIJO: No.

1 MR. WENGLOSKI: Thank you for that.

2MR. INCH: Yes, George Inch. The peak 3effluence were approaching 22 EFPY (ph), probably out 4 two years. So it's approximately 2E to 21 each 5location on the H4 well, projected out at EPU 6effluences until the end of 40 years would be 2E to 7the 21. Then it goes to 4E to the 21 at that H4 8 location.9CHAIRMAN ARMIJO: That's at 60 year or 54 10--11 MR. INCH: The 54 EFPY in 60 years, yes.

12 So it looks like we're just below at the 60 year mark 13--14 MEMBER SHACK: Well, people have various 15 opinions.16 CHAIRMAN ARMIJO: About how long it will 17 last, how long it will work.

18MR. INCH: The top guide clearly is above 19 that at these locations.

20MR. GUZMAN: Okay. With that, we'll go 21ahead and start our presentation. Pat Purtscher will 22be giving his brief on the materials engineering 23 review. Pat, you want to get started?

24 MR. PURTSCHER: Okay. We looked for the 25 113 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433reactor vessel embrittlement, and there are several 1factors that we always consider. The EPU is going to 2increase the total fluence in the vessel, so we're 3going to check initially the material surveillance 4 program.5 That's the fundamental program we use to 6 monitor. We build with the limiting materials in the 7 plants. At Nine Mile, they are enrolled in the BWR 8 VIP integrated surveillance program.

9As part of that program, they're not a 10host plant. They're limiting materials are 11characterized by capsules that are in other plants, 12BWR plants. So the change in effluence for Nine Mile 13doesn't directly affect the capsules that will be used 14 to characterize the limiting beltline materials.

15 They do still have two capsules in their 16reactor vessel that are being irradiated, but there's 17no current plans to use those at this point. They're 18backup capsules. Some of the other factors that we 19look at are all related to Appendix G requirements.

20The PT limits, the upper shelf energy projections for 21all the materials in the beltline, and then there's an 22inspection exemption that's been granted for the circ 23 weld on the vessel.

24So we examine that to see if that, how 25 114 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433that changes with the increased fluence. In all 1cases, they have passed, they still meet these 2requirements from Appendix G, with significant margins 3 remaining. So there really is no concern from the 4staff, based on this increased fluence due to the EPU.

5Next slide. We're now going to look at 6the internals and the core support materials. Again, 7due to the -- now that the fluences are higher on the 8 internals than they're on the reactor vessel itself, 9 and as they mentioned in their presentation, now the 10top guide, the shroud and the core plate are all 11exceeding what we take to be the threshold for 12 radiation-assisted stress corrosion cracking.

13So now we consider them to be susceptible 14materials once they get above that threshold. To 15address that, they have instituted, you know, using 16 BWRVIP-62, that's been characterized as a Category 3 17plant, they're using noble metal additions to mitigate 18the possibility of stress corrosion cracking. This is 19 following all the EPRI guidelines.

20So they are following all the industry 21standards, and the staff sees no issues related to the 22 increased fluence.

23 MEMBER SHACK: Well, there was sort of a 24 discussion this morning that as a Category 3B plant, 25 115 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433where they're only looking at molar ratio, you guys 1take a somewhat skeptical view of that, and you're 2 asking them to do ECP measurements.

3MR. PURTSCHER: Well, but they did do one 4time measurement of EPC when they instituted noble 5metal online additions. So they did it once, and kind 6of validated the secondary parameters that they're 7 monitoring.

8 So as long as they monitored, as long as 9 they checked that once, and there have been no major 10changes to the noding and the environment, we feel 11that's enough justification. So with that one time 12 measurement, to validate it.

13 So really that's, to the vessels and the 14internals, that's really the summary. Just to say it 15again, the EPU has a minimal effect on the 16 embrittlement issues, the upper shelf values, the PT 17limits and the surveillance program. These three 18internal components we've talked about, that exceeded 19the threshold for IASCC, are being managed by BWRVIP 20 documents that have been accepted the staff.

21 So this, since there should be no problem 22 associated with the increased fluence related to the 23 EPU. So we're satisfied with their submittal. Okay.

24 Any questions?

25 116 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433MR. TSIRIGOTIS: My name is Alexander 1 Tsirigotis. I work in the Mechanical and Civil 2Engineering Branch, which reviews the EPU impact on 3the structural integrity of the system structural 4 components.

5Mainly, the pressure retaining components 6and the supports, the reactor pressure vessels and 7 supports, the control mechanisms, reactor situation 8pumps and supports, reactor pressure vessel internals 9and core support --, and the seismic and dynamic 10qualifications of the mechanical and electrical 11 equipment.

12The approach to evaluate the Nine Mile 13Point 2 EPU impact on the structural integrity of the 14-- follows the guidance which is provided in the 15staff-approved Z topical report entitled "Constant 16Pressure Power Uprate," and it's licensing report 17 NEDC-33004P-A.

18This is commonly referred to at the BWR 19EPU as the CLTR. The CLTR also refers into two other 20Z topical reports, the ELTR-1 and ELTR-2, which 21provide more detail on the generic guidelines and 22 generic evaluations.

23 These two topical reports, together with 24associated NRC staff position paper on safety 25 117 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433evaluation, incorporated in the topical reports, have 1been applied for all BWR extended power uprate 2 submittals, since the NRC review and acceptance or 3 endorsement for --.

4The staff approved the CLTR is for 5constant pressure power uprates, commonly referred to 6as CPPUs. With a power increase up to 20 percent from 7 the plant's 100 percent original thermal power, and 8with a minimum and maximum steam and feedwater flow 9 increases up to about 24 percent.

10The CPPU approach assumes that the maximum 11reactor pressure dome remains unchanged from the 12licensed power level, and the dome temperature is also 13 unchanged. The Nine Mile Point 2 proposed EPU does 14not change the current plant maximum normal operating 15 reactor dome pressure, and it increases the original 16thermal power by 20 percent, with a maximum steam and 17feedwater flow increases of nearly 24 percent.

18 Therefore, we found that it meets the limitations of 19 the topical reports.

20In addition to the main steam and 21feedwater piping, which are the main systems that are 22affected by the EPU due to its increase in the flows, 23 other piping systems that are mostly affected by the 24EPU due to increased system temperatures and pressures 25 118 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433within those systems are the extraction steam, the 1feedwater heater vents and drains, the moisture 2 separator heater vents and drains, and the auxiliary 3 condensate.

4The licensee's evaluation of flow-induced 5vibration levels for piping follows the vibration 6acceptance criteria found in ASME OM-S/G Part 3, which 7provides requirements for pre-operational and initial 8start-up vibration testing of nuclear power plant pipe 9 and systems.

10The OM-S/G Part 3 provides monitoring 11requirements, acceptance criteria, and it includes 12equations for calculating the vibratory alternating 13 stress for Class 1 and Class 2 and 3 piping, and for 14thickness for Class 1 piping. It also contains 15 guidance and visual inspection methods, displacement 16methods and vibrational deflectional values for 17 various pipe sizes and spans.

18The structural evaluations for the system 19structures and components under EPU conditions employ 20the current plant design base methodology and 21acceptance criteria. The structural evaluations also 22met design basis code and record allowable values.

23That's why we found there is reasonable assurance 24that the plant SSAs (ph) important to safety as 25 119 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 structurally adequate to perform the internal design 1 functions under the EPU conditions.

2MEMBER SHACK: But you can't really be 3sure they're not going to need any modifications to 4the pipe supports until you run that FIV test, right?

5 I mean they could well need to do something.

6 MR. TSIRIGOTIS: The SIV test?

7 MEMBER SHACK: The FIV test.

8MR. TSIRIGOTIS: Oh yes. You are right 9 about that. During the -- so far, the evaluations 10 that they have done, they have found out that they 11don't need any piping modifications or any support 12modifications or additions. During the start-up 13testing, they had a plan in place which they will 14 monitor the vibration levels, and if there is a need 15for any modifications through the corrective code, 16they will provide corrective actions to do that work.

17 CHAIRMAN ARMIJO: But that will indicate 18 that their analysis wasn't really that good --

19 (Simultaneous speaking.)

20MR. TSIRIGOTIS: They have already done --

21I understand what you're saying. They have already 22done walk-downs to establish the baseline. From those 23 walk-downs, they have identified whether there is an 24 issue with the vibration levels that the pipe's 25 120 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 supposed to see.

1CHAIRMAN ARMIJO: That's where they'll put 2 instrumentation.

3MR. TSIRIGOTIS: Right, right. They have 4 instrumentation. They have -- there are locations 5 which have been gauged, strain gauges, and --

6 CHAIRMAN ARMIJO: Accelerometers.

7MR. TSIRIGOTIS: Accelerometers where 8 needed. The OM-S/G Part 3 is being applied in just 9about every power uprate, and it's during the initial 10 start-up also for the plants.

11MEMBER SHACK: What's been the experience?

12I mean if they found they need to add supports, or the 13 analysis have been generally satisfactory?

14MR. TSIRIGOTIS: So far from what we've 15seen in the power uprates from the walk-downs, they 16haven't identified, from what I know at least, they 17 haven't identified an issue where they needed to add 18something, mainly because when they established the 19baseline, they project that baseline to the EPU flows, 20with velocity square, which is customary to do so. If 21 they find an issue, then they take a corrective 22 action. 23 DR. BONACA: I have a question regarding 24 environmental qualification.

25 121 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 MR. TSIRIGOTIS: Uh-huh.

1 DR. BONACA: There is a statement in the 2 SER that says that, you know, for inside containment, 3 licensee noted that post local conditions, radiation 4 levels will increase above the levels using the 5current EQ program. Then it says the NRC staff 6reviewed the increase EQ evaluation and confirmed that 7 the increase should not affect the qualification of 8 the equipment. What would be the basis for that?

9MR. TSIRIGOTIS: I'm sorry. I can't hear 10you very well. Are you reading from the SER, from the 11 staff SER?

12 DR. BONACA: Yes, yes, page 57.

13MR. TSIRIGOTIS: 57. That's not my page.

14 (Simultaneous speaking.)

15 DR. BONACA: Yeah, inside containment.

16MR. TSIRIGOTIS: Is that Section 2.2.5, 17 seismic and dynamic qualifications of mechanical and 18 electrical equipment?

19DR. BONACA: It must be, yes. Do you have 20 the page?

21 (Off record discussion.)

22MR. TSIRIGOTIS: I don't see that. That's 23not in my evaluation. That's the same part. I think 24 it might be in the electrical part. Anyway, it's in 25 122 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 the SER.

1 (Simultaneous speaking.)

2DR. BONACA: -- stand by. Clearly, the 3 radiation field must be higher. Why is --

4 (Simultaneous speaking.)

5 MR. TSIRIGOTIS: (reading to self) 6MR. GUZMAN: What we can do is we'll take 7 that -- I just need to get back to the safety 8 evaluation, and find out the technical staff --

9DR. BONACA: What's the basis for it, yes.

10 MR. TSIRIGOTIS: This is not my writing.

11I will find out whose review this falls under, and 12 we'll get back to you.

13DR. BONACA: Okay, I appreciate it.

14 Thanks.15CHAIRMAN ARMIJO: Okay. Any other 16 questions from the committee?

17 (No response.)

18CHAIRMAN ARMIJO: All right. I think 19 we're ready to move on to the next topic.

20MR. GUZMAN: The next topic is intended to 21 be in closed session.

22 CHAIRMAN ARMIJO: So we're going to go 23into closed session. Again, remind everyone here, it 24 should only be folks from Nine Mile and their 25 123 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433consultants, and make sure the bridge line is closed.

1(Whereupon, at 1:15 p.m., the meeting 2 adjourned to closed session.)

3 4 124 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 O P E N S E S S I O N 1 4:35 p.m.2 CHAIRMAN ARMIJO: If not, we're going to 3come out of closed session and do a public session, 4 and at this point, I'll ask if there are any comments 5 for members of the public, either on the bridge line 6or open the door so they can come in to this room. Is 7 there anyone on the bridge line who would like to make 8 a comment? If so, please identify yourself.

9 (No response.)

10CHAIRMAN ARMIJO: Maybe the bridge line 11 isn't open yet. Peter will -- is it open now?

12 DR. YARSKY: The bridge line is open.

13CHAIRMAN ARMIJO: Okay. The bridge line's 14 open. Is there anyone, a member of the public, who 15 would like to make a comment concerning this review?

16 If so, please identify yourself.

17 (No response.)

18CHAIRMAN ARMIJO: Okay. How about someone 19 in here, n this meeting room?

20 (No response.)

21CHAIRMAN ARMIJO: Okay. I'm going to take 22 that as there's no comment from the public. At this 23 point, I'd like to turn it over, just as far as 24 Subcommittee discussion. I'd just like to go around 25 125 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433the table, and see if there's any added points that 1 the members would like to make, and then after that, 2maybe try and give the staff and licensee some 3 guidance on the full Committee meeting, because this 4obviously all has to get done in two hours. So that's 5 the challenge. Joy?

6MEMBER REMPE: Some education. During the 7discussion, this last topic, there was a mention of an 8upcoming audit. Could you provide a little more 9 background? I think Stephen was the one who mentioned 10it and was talking to people in the crowd. What 11exactly is going to happen here? Is there going to be 12 an end to end audit or what exactly is it?

13 DR. SHAH: This is Vik Shah. I think we 14have to plan it out before we finalize what kind of 15audit we'll be doing. I think we are going to review 16the (breaking up) 194, and during that review, we will 17be having an audit. I think we will have a (breaking 18 up).19MEMBER REMPE: I'm having trouble 20 understanding you.

21 CHAIRMAN ARMIJO: It's breaking up.

22DR. BASAVARAJU: We have already submitted 23 a topical report.

24 MEMBER REMPE: Who submitted it? Say it 25 126 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 again. Who submitted the topical?

1DR. BASAVARAJU: BWR Vessel Internals 2 program. They submitted a topical report, BWR 194.

3 MEMBER REMPE: Okay.

4 DR. BASAVARAJU: And it just came in for 5 review, and that is the one which will summarize and 6 give all the steam dryer evaluation, the ACM and the 7structural evaluation. So during that review, we were 8planning to have an audit, but we have not still 9 identified the times or extent. So that's --

10 MEMBER REMPE: Thank you.

11MEMBER BANERJEE: What is the time scale?

12I don't want to go out of turn, because this is new 13 information. What is the time scale for review of the 14 topical and I assume it will come to us as well?

15 DR. BASAVARAJU: Yes.

16DR. SHAH: It's about two years, right 17 Pani?18DR. BASAVARAJU: Yes. It's a topical 19 report. Because this is an important topical report, 20we may accelerate it. But the typical topical report 21 reviews, NRC's time is for two years.

22CHAIRMAN ARMIJO: Okay. So it won't help 23us for Nine Mile. Bill, nothing. Said? No, any 24 comments.25 127 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433DR. BONACA: No. Well, a little input.

1I thought in general that this was a good application.

2I felt it was thorough and the steam dryer issue, 3there are a number of questions which were raised 4 today. I think that I feel pretty comfortable with 5 what I saw.

6 CHAIRMAN ARMIJO: Thank you.

7DR. BONACA: Anyway, I will make comments 8 to you.9CHAIRMAN ARMIJO: Yes, okay, in your 10 report. Mr. Wallis?

11DR. WALLIS: Well, I thought on most 12issues, Nine Mile Point people did a very good job.

13I'm still working on the steam dryer. I'm still 14 puzzled, because I'm told that this small scale test 15 was only used to establish resonance, and yet I read 16the report, the objective was to develop a bump-up 17factor relating (coughing) to those anticipated at 18 EPU, to use in the acoustic circuit model.

19I mean the whole thing says, the whole 20purpose of the report is to develop numbers to put 21into a model. I'm really puzzled by this assertion 22that none of that was the case. I don't understand 23that, and I'm still working on the numbers. I have 24learned some things which have been very helpful about 25 128 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 some of the issues I raise, and I thank the 1 participants for doing that for me.

2 CHAIRMAN ARMIJO: Sanjoy.

3MEMBER BANERJEE: Nothing more than I said 4 already.5 CHAIRMAN ARMIJO: Nothing more. Jack?

6MEMBER SIEBER: I have no comments or 7 questions at this time.

8CHAIRMAN ARMIJO: Okay, all right. Well, 9 my view is I think the Nine Mile people and staff are 10very well prepared for this. I think we can beat the 11steam dryer to death, but and we obviously can't, 12 won't be able to spend that much time at the full 13 committee meeting.

14So that between the staff and the Nine 15 Mile, I think we really need one good presentation, 16without any repetition at all. So you're going to 17have to sort that out. I think the plant's in -- the 18impression I got from the presentation, the plant's in 19 very good shape for EPU.

20I think the work you've done on the 21materials, and on the various upgrades and 22modifications, that goes a long way to making me feel 23 pretty comfortable --

24MEMBER SHACK: And they use that good 25 129 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 barrier clad --

1CHAIRMAN ARMIJO: And they use my 2 cladding, so that's great.

3 (Laughter.)

4CHAIRMAN ARMIJO: But I'm still surprised 5at how conservative the fuel design is. It's got more 6capability, but that's okay. But overall, I think 7you're well-prepared. I think our problem will be to 8 manage the time, so that you get, the full Committee 9 gets a good feel for the entire plant, and that we 10 don't let the steam dryer dominate everything.

11So that's going to be hard to do, but I 12 think since so many of us have heard this 13presentation, and as soon as we get Mr. Wallis' report 14and Mario's reports, we probably can sort out our 15questions and focus down. But overall, I think you're 16 well-prepared. We'll work with Rich.

17MR. GUZMAN: I was hoping I could close 18 out one quick action item, and I wanted to make sure 19I responded to Dr. Bonaca's question and concern on 20 part of the safety evaluation, and I'll just restate 21 it. The section is part of the Electroengineering 22review, under Environmental Qualifications for 23 Electrical Equipment.

24The statement said that "The NRC staff 25 130 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433reviewed the licensee's environmental qualification 1evaluation, and confirmed that the increase should not 2 affect the qualification of the EQ equipment located 3inside containment." The question is why? Because 4 they should not. Does it or does it not?

5The staff recognizes the obscurity in that 6 wording, and so it was in error, and we should or we 7 will correct that, and --

8MEMBER SHACK: No, I think the question 9 was that the statement was made that it exceeded the 10environmental qualification, and then the statement 11 followed that --

12 MR. GUZMAN: Okay.

13 MEMBER SHACK: It's still all right.

14 MR. GUZMAN: Still all right, okay.

15MEMBER SHACK: It was that first line that 16 was the killer.

17MR. GUZMAN: Okay, yes. So right. So the 18 preceding statement says the licensee noted that the 19radiation levels would increase above the levels used 20 in the current EQ program.

21 MEMBER SHACK: Right.

22MR. GUZMAN: And NRC staff review 23 confirmed that these increases should not affect the 24 qualifications. So I guess the question is why, and 25 131 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433if you go further in the safety evaluation, I mean 1recognizing that the "should not" was not the 2 appropriate words. It should have said, for lack of 3 a better word, "would not" or "will not."

4But further down in the safety evaluation, 5 it does go into the, you know, that the staff reviewed 6the licensee's assessment of the effects of the 7 proposed EPU on EQ equipment, and ultimately we 8reviewed it against 10 C.F.R. 5049, which is the 9 electrical equipment qualification.

10MEMBER SHACK: Maybe you should give 11 something like "Despite this step." 12MR. GUZMAN: Right. So we recognize that 13 the wording needed to be tightened up. It certainly 14 should have been more definitive and explain it. So 15 we will make sure on the final --

16DR. BONACA: This is an example of the way 17 that the information is provided. There were two 18 other, three other in the SER, I believe goes to the 19 outside containment portion. There is a statement 20that simply says that's okay, and the question is why 21 is it okay?

22 I mean it's counterintuitive that if you 23have a higher radiation field, it doesn't make any 24 difference. There has to be some reason why, and I 25 132 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433mean the qualification exceeded the value. Therefore, 1 there was margin. But something should be said.

2 MR. GUZMAN: And as you know, I mean the 3intent is to give you the best product that we can for 4the draft safety evaluation. But in parallel, what we 5tried to is we actually send the draft safety 6 evaluation to the licensee. They provide some 7comments to us and we will incorporate those comments, 8as well as another round of quality check by the 9 staff, to strengthen the product, which would be the 10 final safety evaluation.

11So there will be some changes, and we will 12 note that one, as well as the other ones that you did 13 note.14 DR. BONACA: Okay, thank you.

15 CHAIRMAN ARMIJO: Okay. Well with that, 16 I think I'd again like to thank Nine Mile Point and 17the staff. Good presentations. Good discussion, and 18 with that we're going to adjourn the meeting. Thank 19 you.20(Whereupon, at 4:46 p.m., the meeting was 21 adjourned.)

22 23 24 25 ACRS Subcommittee on Power Uprates NRC Staff Review Nine Mile Point, Unit 2 Extended Power Uprate October 5, 2011 2 Opening Remarks Louise Lund Deputy Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 3 Opening Remarks

  • NRC staff effort
  • Pre-application review and public meetings
  • 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 4 Introduction Rich Guzman Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 5 Introduction
  • Objective* Background
  • 3467 to 3988 MWt, 15 % increase (521 MWt)
  • 20 % increase above original licensed thermal power
  • EPU Review Schedule
  • No linked licensing actions under review
  • Supplemental responses to NRC staff RAIs
  • EPU Implementation 6 Topics for Subcommittee
  • Anticipated Transient without Scram and Stability* Fuel Methods - IMLTR
  • Materials and Mechanical & Civil Engineering
  • Steam Dryer Analysis
  • Review of open items / Conclusions Nine Mile Point, Unit 2 Extended Power Uprate ACRS Subcommittee Meeting Materials Engineering Patrick Purtscher Vessel & Internals Integrity Branch October 5, 2011 1

2 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 3 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 4 Conclusion
  • EPU has minimal impact on RV embrittlement issues
  • Three RVI components exceed threshold for IASCC, but adequately managed;Core plate - BWRVIP-25-ATop guide - BWRVIP-26-AShroud - BWRVIP-76-A 5 QUESTIONS 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

7 Review Scope

  • EPU impact on structural integrity of systems, structures, and components (SSCs):
  • Pressure-retaining components and their supports* RPV and supports
  • RPV internals and core supports
  • Seismic and dynamic qualification of mechanical

and electrical equipment.

8 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.

9 Conclusion

  • Reasonable assurance that plant SSCs important to safety are structurally adequate to perform intended design functions under EPU conditions.

10 QUESTIONS Power/FlowOperatingMap 1 ACRSSubcommitteePresentation NineMilePoint2 ExtendedPowerUprate October5,2011 NineMilePoint2 ExtendedPowerUprate SamBelcher SVP SiteOperations NMP2EPUOverview NMP2EPUAgenda-Overview SamBelcher-PlantModifications DaleGoodney-PowerAscensionTesting PhilAmway-AnticipatedTransientWithoutScram(ATWS) PhilAmway andStability-CLOSEDSESSION FuelMethods(IMLTR) PhilWengloski-Material,Mechanical/CivilEngineeringTopics GeorgeInch-CLOSEDSESSION SteamDryerAnalysis GeorgeInch 3 NMP2EPUOverview GEBWR5 MarkIIContainment ThermalPower- OriginalLicenseThermalPower(OLTP) 3323MWth- CurrentLicenseThermalPower(CLTP) 3467MWth StretchUprate104.3%(1995)- EPUThermalPower(120%OLTP) 3988MWth Implement2 nd Quarter2012 4 NMP2EPUOverview(cont'd) AttributesoftheNMP2constantpressurepoweruprate:- NMP2isnotrequestinganyContainmentAccidentPressure (CAP)credittosupportECCSNPSH- Nonewfuelintroduction;thecurrentcoreandtheEPUcoreare composedentirelyofGE14fuel- TheAlternativeSourceTermforaccidentradiological consequenceswaspreviouslyimplementedusingtheEPUpower levelasabaseassumption NMP2hasimplementedMaximumExtendedLoadLineLimit Analysis(MELLLA)expandedoperatingdomain 5 NMP2EPUOverview(cont'd)TheNYISOhasreviewedandapprovedtheEPUfull poweroutput nogridmodificationsarenecessaryThefirsttwophasesofEPUmodificationshavebeen installedThethirdandfinalphaseofmodificationsneededto supportEPUoperationwillbecompleteby2 nd Quarterof2012 6 NineMilePoint2 ExtendedPowerUprate DaleGoodney EPULeadProjectEngineer PlantModifications PlantModificationsGeneralApproachPlantParametersInstallationTimelineMajorModificationsNMP2PlantImprovements 8

PlantModifications GeneralApproachEngineeringstudieswereperformedtoevaluate structures,systemsandcomponentstodeterminethe plant'sabilitytooperateatEPUconditions

- Analyzedeffectsofincreaseinsteamflow,feedwaterflow, reactorpowerandelectricaloutput- EvaluationswerebasedonNEDC 33004P A,"LicensingTopical ReportConstantPressurePowerUprate," Revision4(CLTR)- Analysesarebasedonthetargetpowerlevelof120%OLTP- OperatingExperiencewasevaluatedandapplied 9 PlantModifications GeneralApproach (cont'd)Designandoperatingmarginswereidentifiedand evaluatedforbothNSSSandBOPsystemsOver20physicalplantmodificationsweredescribedin theLicenseAmendmentRequest- RestoreMaterialCondition- Instrumentationfordatacollectionandanalysis- UpgradestorestoredesignandoperatingmarginatEPU conditionsInstallationbeganin2007andwillcontinuethrough 2012RefuelingOutage 10 PlantModifications PlantParameterChanges Parameter CLTP (104.3%OLTP)EPU(120%OLTP)ThermalPower(MWth)3467 3988 ReactorPressure(psia)1035 1035 RatedSteamFlow(Mlb/hr)15.002 17.636 RatedFeedwaterFlow(Mlb/hr)14.970 17.604 GeneratorOutput(Mwe)1211 1369 FeedwaterTemperature(°F)425.1 440.5 11 PlantModifications InstallationTimeline 12 2007and2008 2010and20112011through2012Refueling* MainSteam(MS)Line VibrationMonitoring StrainGages* PartialBypassAroundthe Condensate Demineralizers

  • Replace3 rd PointFeedwater Heater* ReplaceFeedwaterHeater DrainPumpsandMotors* InstallPipingVibration Monitoring
  • InstallShieldingfor EquipmentQualification
  • UpgradeFeedwaterPumpsandGearSets* ReplaceFeedwaterPumpMotorCables* RecirculationRunbackInitiationandRunbackRate* ReplaceHighPressureTurbine* ReplaceLowPressureTurbineCrossAroundRelief Valves* ReplaceLowPressureTurbineAtmosphericRelief Diaphragms
  • SteamDryerModifications
  • FeedwaterHeaterRerate* GeneratorIsolatedPhaseBusDuctCooling Improvements
  • ImproveMainTransformerCooling* InstrumentReplacementandScaling* ImproveTurbineBuildingHVAC* TurbineBuildingClosedLoopCooling Enhancements
  • ExtractionSteamExpansionJointReplacement
  • MainSteam/FeedwaterPipeSupports MajorPlantModificationsCondensateandFeedwater- FeedwaterPumpUpgrades- HeaterDrainPumpsandMotors- ReactorRecirculationRunbackSteamPath- HighPressureTurbine- Cross AroundReliefValves- MoistureSeparatorReheaterand5 th/6 th PointFeedwater HeaterRequalification

- SteamDryer13 MajorPlantModifications(cont'd)Electrical/I&C- IsophaseBusDuctCooling- MainTransformerCooling- TechnicalSpecificationInstrumentSetpoints- BOPInstrumentRescalingandSetpointsAuxiliarySupportSystems- TurbineBuildingHVAC- TurbineBuildingClosedLoopCooling 14 NMP2PlantImprovements NMP2hasimplemented,orisplanningtoimplement priortoEPU,anumberofupgradestorestoremargin, improveequipmentreliabilityandreducerisk.Examples are:- ReplacedThirdPointFeedwaterHeatersin2010- IncreasedStandbyLiquidControlReliefValveMarginin2010- PerformedCoolingTowerUpgradesin2008and2010- NewFeedwaterPumpSealsin2012- ReplaceJetPumpInletMixersin2012- SeveralPRA relatedriskreductionimprovements.Since2008, CoreDamageFrequency(CDF)hasbeenreducedby78%15 NineMilePoint2 ExtendedPowerUprate PhilAmway EPUOperationsLead SRO PowerAscensionTesting PowerAscensionTestingPreparationApproachScheduleTestPlanAcceptanceCriteriaandActions 17 PowerAscensionTesting PreparationTestObjectiveDevelopment

- SatisfactoryEquipmentPerformance

- Careful,MonitoredApproachtoEPUPower- MeetEstablishedRequirementsRoles&ResponsibilityDevelopmentIndustryBenchmarkingTestPlanandImplementingTestProcedure DevelopmentPowerAscensionTestTraining 18 PowerAscensionTesting-ApproachSimilartoapproachusedinotherEPUs- Incremental TestingBaselinedataat75%,90%,95%and100%CLTPGreaterthan100%CLTP- Dataacquisitionperformedinincrementalstepsof1%and 2.5%- ActiveTestingandNRCDataReviewatincrementalstepsof 5%19 PowerAscensionTesting-Approac h(cont'd)NoLargeTransientTesting- IndustryOEindicatesthatplantswillcontinuetorespondto transientsasdesignedfollowingEPUimplementation

- PlantspecificOEat104.3%OLTP(GeneratorLoadRejectand MSIVClosure)- NMP2haspreviouslyperformedLargeTransientTestingand documentedresults- Plantoperatorswillbetrainedonlargetransienteventsinthe simulator- Analyticalmethodsandtrainingfacilitiesadequatelysimulate largetransientevents 20 PowerAscensionTesting- ScheduleDatacollection-1%intervalsDataevaluation-2.5%intervalsEPUMajorTestingPlateau-5%intervals- Passivedatacollection(e.g.vibration,radiation monitoring,plantparametermonitoring)

- Activecontrolsystemstabilitydynamictesting Pressureregulatorsteptest Feedwaterlevelcontrolsteptest- DataAnalysis- PlantManagement(PORC)Review- NRCReview 21 EPUPowerAscensionTesting- TestPlan MajorTesting 22 PowerAscensionTesting- AcceptanceCriteria andActions Level1AcceptanceCriteria: Alimitassociatedwith plantsafety IfLevel1criterionisnotmet:- Abortthetest- Reducepowertolastknownsafecondition- UsetheCorrectiveActionProgramtoevaluatethe conditionandtodetermineandimplementrequired actions- RepeattestingtoverifythattheLevel1criterionis satisfied- Documentproblemresolution 23 PowerAscensionTesting- AcceptanceCriteria andActions(cont'd) Level2AcceptanceCriteria:Alimitassociatedwith plantorequipmentperformancethatdoesnotmeet designexpectationsbutisnotimmediatelyadverseto plantsafety IfLevel2criterionisnotmet:- Placethetestonholdandconfirmtheplantisinasafe condition- UsetheCorrectiveActionProgramtoevaluatethe conditionandtodetermineandimplementrequired actions- RepeattestingtoverifytheLevel2criterionissatisfied unlesstheas foundconditionisdeterminedsatisfactory

- Documentproblemresolution24 PowerAscensionTesting- AcceptanceCriteria andActions(cont'd) OtherAcceptanceCriteria:Alimitassociatedwithplant surveillancerequirements,plantoperatingprocedures, roundsoralarmresponses Whenthiscriteriaisnotmet,plantprocedureswillbe followed 25 NineMilePoint2 ExtendedPowerUprate PhilAmway EPUOperationsLead SRO LongTermStabilitySolution OptionIIIandATWS- Stability Events LongTermStabilitySolution- OptionIII/ATWS NRRAuditatNineMilePoint2 LongTermStabilitySolution-Optio nIII- OscillationPowerRangeNeutronMonitor(OPRM)- OPRMSettings- BackupStabilityProtection(BSP)- 2003NMP2StabilityEvent- EffectsofEPUontheLongTermStabilitySolution ImpactofEPUonATWS- StabilityEvents- NMP2ATWSMitigationDesignFeatures- PreparationforSimulatorDemonstration

- MSIVClosurewithFailuretoScram- TurbineTripwithFailuretoScram- Conclusions 27 NRRAuditatNMP2 PerformedOctober28,2009todemonstrateprocedureactions andoperatorresponsetoATWStransientsatEPUconditions conformtoregulatoryrequirements ReviewedimplementationofLongTermStabilitySolution- OptionIII Observedoperatorperformanceinplantreferencesimulator- MSIVClosurewithFailuretoScram- TurbineTripwithFailuretoScram Includedreviewofrelatedproceduresandmitigationstrategies Requestedfollowupinformationwhenplantreference simulatorwasmodifiedtoprovideATWS Stabilitytransient responsedata 28 OscillationPowerRangeMonitor(OPRM) 1998-NUMA CPowerRangeNeutronMonitorOPRMhardware installed(Amendment80) systemtuningperformedforplant specificsettings 2000-Reacto rProtectionSystem(RPS)OPRMtripsarmed (Amendment92) 2002- ImplementedPlantSpecificDeltaCPROverInitialCPR VersusOscillationMagnitude(DIVOM)curveperGESafety Communication01 01,StabilitySetpoint Calculationusing GenericDIVOMCurve 2003- Implementedfilterfrequencyandperiodtolerance settingsperGESafetyCommunication03 20,StabilityOptionIII PeriodBasedDetectionAlgorithmAllowableSettings 29 OPRMSettingsCyclespecificDIVOManalysisisperformedusing TRACGmethodologyCyclespecificamplitudesetpoint isdefinedintheCore OperatingLimitsReportOPRMtripswillbeenabled>26%RTPand<60% recirculationdriveflowtomaintainthesameenabled regionintermsofMWth power 30 BackupStabilityProtection(BSP)BSPregionsaredeterminedusingcyclespecificODYSY decayratiocalculationsBSPregionsaredefinedonplantpower/flowoperating mapsOperatoractionsaredefinedinplantprocedureswith routinetrainingreinforcementBSPexitregionproceduresareenforcedatalltimes 31 2003NMP2StabilityEvent Componentfailureresultedinhightolowspeedtransferof bothReactorRecirculationpumps OPRMPeriodBasedDetectionAlgorithm(PBDA)initiated anautomaticreactorscrambecauseofcorewide oscillations ThereactorwasproperlytrippedbythePBDA UnexpectedConfirmationCount(CC)resetsoccurredprior tothescram Postscramanalysisdeterminedthattwoparameter settingsneededtobechangedtoaddressCCresets Parametersettingchangeshavebeenimplementedper BWROGrecommendations 32 EffectsofEPUonLongTermStabilitySolution NomethodschangesforEPU Maximumrodlineremainsthesame(MELLLAboundary) OPRMarmedregionmaintainsthesamelevelofstability protection Cyclespecificsetpoint analysiswillcapturecoredesign variations OptionIIIlongtermsolutionremainsunchanged OptionIIIOPRMsetpoints willbedevelopedbasedonplant specificDIVOMcurvesfortheEPUcyclespecificreload analysis 33 NMP2ATWSMitigationDesignFeaturesHighRPVpressureinitiatesATWSsystems T=0seconds- AutomaticAlternateRodInsertion(ARI)- AutomaticReactorRecirculationPumpTrip(RPT)toslow speed T=25secondsandpower>4%- AutomaticFeedwater Runback- AutomaticReactorRPTtooff T=98secondsandpower>4%- AutomaticBoronInjection 34 PreparationforSimulatorDemonstrationSimulatordemonstrationperformedpriortooperator trainingforEPUconditionsOperatingcrewwasprovidedwithabriefingonEPU powerlevel,steamandfeedwater flowsAnSROotherthantheEPUOperationsLead participatedinthedemonstrationtoavoidbiasing operatorresponseSimulatordemonstrationconfirmedthatcurrent proceduresandstrategiessuccessfullymitigateATWS events 35 MSIVClosurewithFailuretoScram3988MWth at99%coreflow(MELLLAboundary)MaximumSuppressionPooltemperature90°FMinimumSuppressionPoollevel199.5feetMaximumServiceWatertemperature84°FNoControlRodMotionTheaboveworstcaseconditionsareconsistentwith designanalysisinputs 36 MSIVClosurewithFailuretoScram(cont'd)BothloopsofSuppressionPoolcoolinginserviceat ratedflowin404secondsvs actiontimeof1080 secondsHotshutdown(<0.1%power)achievedin406secondsPeakSuppressionPooltemperatureremainsbelow HeatCapacityTemperatureLimitwith5°FmarginContainmentparametersremainwellwithindesign analysisPlantreferencesimulatorcriticalparameterresponse closelymatchedthedesignanalysisforthisevent 37 TurbineTripwithFailuretoScram3988MWth at99%coreflow(MELLLAboundary)MaximumSuppressionPooltemperature90°FMinimumSuppressionPoollevel199.5feetMaximumServiceWatertemperature84°FNoControlRodMotionTheaboveworstcaseconditionsareconsistentwith designanalysisinputs 38 TurbineTripwithFailuretoScram(cont'd)BothloopsofSuppressionPoolcoolinginserviceat ratedflowin425secondsvs.actiontimeof1080 secondsHotshutdown(<0.1%power)achievedin465secondsPeakSuppressionPooltemperatureremainsbelow HeatCapacityTemperatureLimitwith19°FmarginContainmentparametersremainwithindesignanalysisPlantreferencesimulatorcriticalparameterresponse closelymatchedthedesignanalysisforthisevent 39 ConclusionsExistingprocedures,operatoractiontimesand strategiesareeffectiveinmitigatingATWSandATWS instabilitytransientsNMP2featuresanATWSRPTfunction.Asaresult, transientpowerlevelsareprimarilybasedonthe maximumcontrolrodlinewhichisunchangedforEPUOperatorscanperformactionsinatimelymannerto bringtheplanttosafeshutdown 40 NineMilePoint2 ExtendedPowerUprate GeorgeInch PrincipalEngineer Mechanical/StructuralLead Material,Mechanical/Civil EngineeringTopics RPVInternalsFluenceFlowInducedVibration(FIV)StructuralEffects(Non FIV)IntergranularStressCorrosionCracking(IGSCC)and IrradiationAssistedStressCorrosionCracking(IASCC)42 RPVInternals-Fluence Irradiationassistedstresscorrosioncracking(IASCC)fluencethresholdis 5E20n/cm 2 ThefollowingcomponentsexceededtheIASCCfluencethreshold:

- TopGuide(BWRVIP 26 A)- Shroud(BWRVIP 76 A)- CorePlate(BWRVIP 25 A) Continuedimplementationofthecurrentprograminaccordancewiththe BWRVIPrecommendationsassuresthepromptidentificationofany degradationofreactorvesselinternalcomponents NMP2UtilizesHydrogenWaterChemistryandNobleMetals Reactorvesselwaterchemistryconditionsmaintainedconsistentwiththe EPRIandestablishedindustryguidelines Peakfluenceincreasedoesnotrepresentasignificantincreaseinthe potentialforIASCC 43 RPVInternals-Flo wInducedVibration VibrationlevelsforEPUwereestimatedbyextrapolatingvibration datafromprototypeplantorsimilarplantsandonGEHBWR operatingexperience Thefollowingcomponentswereevaluated:a)shroudheadand separatorassembly;b)jetpumps;c)coredeltaPline;d)guide rods; e)in coreguidetubesandcontrolrodguidetubes;f)jetpumpsensing lines;g)feedwatersparger;h)fuelassembly,topguide,andcore plate;i)RPVtopheadspareinstrumentnozzle;j)RPVtopheadvent nozzle;k)RPVheadspraypipeandheadspraynozzle;l)corespray piping ResultsshowthatcontinuousoperationatEPUconditionsdoesnot resultinanydetrimentaleffectsonthesafety relatedreactorinternal components 44 RPVInternals- StructuralEffects(Non FIV) Evaluations/stressreconciliationwasperformedconsistentwiththe DesignBasisAnalysis Originalconfigurationsoftheinternalcomponentsutilized,unlessa componenthadundergonepermanentstructuralmodification Effectsofthermal hydraulicchangesduetoEPUwereevaluated EPUloadscomparedtothoseintheexistingdesignbasisanalysis Forincreasesinload,linearlyscaledthecritical/governingstresses basedonincreaseinloads-compar eresultingstressesagainstthe allowablestresslimits AllstressesandfatigueusagefactorsarewithinthedesignbasisASME codeallowablevalues RPVinternalcomponentsdemonstratedtobestructurallyqualified foroperationatEPUconditions 45 RPVInternals- IGSCCandIASCC ProcedurallycontrolledprogramconsistentwithBWRVIPissued documents Componentsinspectedinclude:corespraypipingandspargers;core shroudandcoreshroudsupport;jetpumpsandassociated components;topguide;lowerplenum;vesselinnerdiameter attachmentwelds;instrumentationpenetrations;steamdryerdrain channelwelds;andfeedwaterspargers Programassurespromptidentificationsofanydegradation Hydrogenwaterchemistryandnoblemetalapplicationstomitigate thepotentialforIGSCCandIASCC RecentControlBladeCrackingOE- NotapplicabletoGEHMarathon"C" latticemodels- GEHconcludednolifetimereductionfor"C" lattice 46 FatigueMonitoringProgramNMP2implementedFatigueProforfatigue monitoringin2008independentofEPU- Automatedeventtrackingandusagebasedoncycle countingformostevent Assumeddesignbasiseventseverity,recordsactualevent severity- StressbasedmonitoringofFWnozzlelocationto improvetheaccuracyofusage 47 FatigueMonitoringProgram(cont'd)CLTP40yearCUF EPU40yearCUF CarbonSteelSafeEnd 0.965 0.6537 StainlessSteelClad 0.916 0.8299 48 TheEPUevaluationperformedrefinedfatigueusage calculationsfortheFWnozzle- Reducedusagefromoriginaldesignbasis FWnozzlehighusagedefinedbyoff normalrapidcycling eventsoccurringduringpartiallossoffeedwaterheatingand hotstandbyoperation- EPUscalingfactorsmall(between6%and15%)- Stressbasedfatiguemonitoringanticipatedtodemonstrateusage less than1.0for60years FatigueMonitoringProgram(cont'd) FatigueProimplementedatNMP2usesasinglestressterm forstressbasedmonitoring

- SimplifiedGreensfunction- RIS 2008 30isapplicabletoNMP2 NMP2isfollowingindustrydevelopmentstoreconcile RIS 2008 30issue- FatiguePro4 ASMECodeSubarticleNB 3200fatigueanalysismethodology EnvironmentalFatiguerules(NUREG/CR 5704/6583/6909)

- NMP2isconsideringalternativeconfirmatoryanalysesasproposedby RIS 2008 30 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

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

Interim Methods Applicability of GE Methods to Expanded Operating Domains Dr. Peter Yarsky RES/DSA/RSAB Nine Mile Point Unit No. 2 Extended Power Uprate ACRS Subcommittee Meeting 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 staff's SE for the IMLTRPani - can you please print out 2 colored copies of the attached and give them to me later today.

Thanks, Rich 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