ML18163A037
| ML18163A037 | |
| Person / Time | |
|---|---|
| Issue date: | 05/16/2018 |
| From: | Weidong Wang Advisory Committee on Reactor Safeguards |
| To: | |
| Wang W | |
| References | |
| NRC-3732 | |
| Download: ML18163A037 (84) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: ACRS Power Uprate Subcommittee - Open SessionDocket Number:N/ALocation:Rockville, Maryland
Date:May 16, 2018Work Order No.:NRC-3732 Pages 1-NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005(202)234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005
-3701 www.nealrgross.com 1 1 2 3 DISCLAIMER 4 5 6 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 7 ADVISORY COMMITTE E ON REACTOR SAFEGUARDS 8 9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.
15 16 This t ranscript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.
19 20 21 22 23 1 UNITED STATES OF AMERICA 1 NUCLEAR REGULATORY COMMISSION 2+ + + + +3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4 (ACRS)5+ + + + +6 POWER UPRATE SUBCOMMITTEE 7+ + + + +8 WEDNESDAY 9 MAY 16, 2018 10+ + + + +11 OPEN SESSION 12+ + + + +13 ROCKVILLE, MARYLAND 14+ + + + +15 The Subcommittee met at the Nuclear 16 Regulatory Commission, Two White Flint North, Room 17 T2B1, 11545 Rockville Pike, at 8:30 a.m., Joy L.
18 Rempe, Chairwoman, presiding.
19 COMMITTEE MEMBERS:
20 JOY L. REMPE, Chairwoman 21 RONALD G. BALLINGER, Member 22 MICHAEL L. CORRADINI, Member 23 WALTER L. KIRCHNER, Member 24 JOSE A. MARCH-LEUBA, Member 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 2 PETER C. RICCARDELLA, Member 1 GORDON R. SKILLMAN, Member 2 3 DESIGNATED FEDERAL OFFICIAL:
4 WEIDONG WANG 5 ALSO PRESENT:
6 JOSH BORROMEO, NRR 7 RALPH GRUMMER, Framatome 8 DAVID MCBURNEY, Framatome*
9 AHSAN SALLMAN, NRR 10 ROBERT SCHAPP, Framatome*
11 ASHLEY S. SMITH, NRR*
12 DAN TINKLER, Framatome*
13 AARON WYSOCKI, ORNL 14 STEPHEN YODERSMITH, Duke 15*Present via telephone 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 3 CONTENTS 1 2 Opening Remarks.................4 3 4 Review Introduction...............7 5 6 LAR Overview..................8 7 8 Public Comments.................54 9 10 Open Session Closed...............55 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 4 P-R-O-C-E-E-D-I-N-G-S 1 8:29 a.m.2 CHAIRWOMAN REMPE: This meeting will now 3 come to order.
4 This is a meeting of the Power Uprate 5 Subcommittee, a Standing Subcommittee of the ACRS.
6And, I'm Joy Rempe and I Chair this 7 Subcommittee.
8 ACRS members in attendance include Ron 9 Ballinger, Dick Skillman, Mike Corradini, Pete 10 Riccardella, Jose March-Leuba and Walt Kirchner.
11 Weidong Wang is the -- of the ACRS staff 12 is the Designated Federal O fficial for the this 13 meeting.14 In this meeting, the Subcommittee will 15 review the safety evaluation for the Brunswick Steam 16 Electric Plant Units 1 and 2 Operating License 17 Amendment Request to allow plant operation in the 18 expanded maximum extended load line limited analysis 19 plus or MELLLA+ domain.
20 As you may recall, this is the fifth plant 21 to submit an LAR for operation in the MELLLA+ domain, 22 but the first to rely on GEH methods with Framatome, 23 formerly AREVA, ATRIUM 10XM fuel.
24 And, in this meeting, we'll hear 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 5 presentations from the NRC staff and representatives 1 from the licensee, Duke Energy Progress, Incorporated.
2 We did not receive written comments or 3 requests for time to make oral statements from any 4 member of the public regarding today's meeting.
5 Part of the presentations by the licensee 6 and the NRC staff will be closed in order to discuss 7 information that's proprietary to the licensee and its 8 contractors pursuant 5 USC 552(b)(c)(4).
9 Attendance at these portions of the 10 meetings that deals with such information will be 11 limited to the NRC staff and its consultants, Duke 12 Energy Progress, Incorporated and those individuals 13 and organizations who've entered into an appropriate 14 confidentiality agreement with them.
15 So, consequently, we'll need to confirm 16 that we only have eligible observers and participants 17 in the room for the closed portions of this meeting.
18 And, we're going to rely on the staff and Duke Energy 19 to assist us with this when we reach that point during 20 the meeting.
21 The Subcommittee today will gather 22 information, analyze relevant issues and facts and 23 formulate proposed positions and actions as 24 appropriate for deliberations by the Full Committee.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 6 The rules for participating in today's 1 meeting have been announced as part of the Notice of 2 this meeting previously published in the Federal 3 Register.4 A transcript of the meeting is being kept 5 and will be made available in the Federal Register 6 Notice.7 Therefore, we request that participants in 8 this meeting using the microphones located throughout 9 the meeting room when addressing the Subcommittee 10 meeting.11 And, the participants should first 12 identify themselves and speak with sufficient clarity 13 and volume so that they may be readily heard.
14 I want to remind everyone, we start --
15 before we start to turn off your noisy little devices 16 and make sure that they don't interrupt us.
17MEMBER KIRCHNER: Getting feedback from 18 somewhere.
19CHAIRWOMAN REMPE: Weidong -- he's working 20 on it? Which actually means we need to --
21 (SIMULTANEOUS SPEAKING) 22CHAIRWOMAN REMPE: Yes, we have to wait 23 until we have a minder, but I'm going to go ahead and 24 say that we're going to soon proceed with the meeting 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 7 and, when we do start the meeting, Jose -- Weidong's 1back. So, are you taking care of the noise? There's 2 some feedback up here.
3 MEMBER KIRCHNER: Someone may have their 4 phone on watching.
5 CHAIRWOMAN REMPE: Maybe --
6MEMBER MARCH-LEUBA: You think it's the 7 phone line?
8CHAIRWOMAN REMPE: Yes, why don't you 9 check and see and maybe Theron can help with that.
10But, when we do start the meeting, I'm 11 going to call on Gregory Suber to start. Okay?
12 Okay, Gregory, go ahead and start.
13 MR. SUBER: Okay, thank you.
14And, good morning. My name is Gregory 15 Suber and I am a Deputy Director in the Division of 16 Operating Reactor Licensing in the Office of Nuclear 17 Reactor Regulation.
18 It is my pleasure to introduce you to the 19 ACRS Subcommittee, the NRC staff who have been working 20 on the Brunswick MELLLA+ review.
21 So, we have presented a number of extended 22power uprates for this Subcommittee. This is the 23 first application with the combination of GEH 24 methodology and Framatome fuel.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 8 The staff's presentation will highlight 1 this important methodology that increases operational 2 efficiencies, by reducing downpowers and control rod 3 manipulation.
4 During this review, the staff leveraged 5 precedents from previous reviews like Grand Gulf, Nine 6 Mile Point, Monticello and Peach Bottom.
7 Additionally, we have reached out to our 8 colleagues in the Office of Research who our user need 9 request to perform plant-specific independent studies 10 for ATWS events with the NRC's TRACE code and with the 11 latest costing thermal hydraulic test loop data.
12 Their assistance was instrumental in 13 completing this review and we'd like to express our 14 gratitude to Research for their participation.
15 As the staff's presentation will show, 16special attention was paid to the interface between 17 the key elements and the first review with the GEH 18 methodology and Framatome fume -- fuel -- it's not 19 fume, it's fuel, sorry about that.
20 We have initiated a review of Browns Ferry 21 which utilizes a similar approach.
22 Thank you for your attention and I will 23 turn it over to Mr. Andy Hon.
24 MR. HON: Thank you, Gregory.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 9 Good morning, Chairman Rempe and 1distinguished members of ACRS. I'm Andy Hon. I'm the 2 Project Manager for the Brunswick MELLLA+ application 3with NRR. And, I'm going to give a quick overview of 4the project. My colleague, Josh, will be leading the 5 technical discussion later on in the closed session.
6 For Brunswick, the plant was approved for 7 EPU uprate in 2002 to allow them to operate at 8 additional 20 percent above the original license power 9 limit.10 However, by doing that, they also lost 11 some of their flexibility in their flow window.
12 And, in 2012, in 2013, both units 13transitioned to AREVA XM11 fuel. And, the MELLLA+
14amendment was submitted last -- in the -- more than 15 last year, actually, November 2016.
16 The purpose of the increase the 17 operational efficiencies and also reduced need to move 18 the control rod especially near the end of the 19 operating cycle by expanding the license flow window 20 at full power from 80 to 104 percent total core flow.
21 Like Gregory mentioned, this is the first 22 time the application on top the original GEH licensing 23 topical report for the otherwise known as the GEH M+
24 LTR Methodology and also their AREVA Fuel XM11 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 10 analysis.1 This is, for us, it's a typical license 2amendment. The structure of the application as a 3 ususal introduction, no sig, et cetera.
4 But, the core of the application is the M+
5 SAR and also known as the BSEP Safety Analysis Report.
6 If pretty much follow the original GEH 7 MELLLA+ License Topical Report, and also the 8 integrated analyses from both GEH and AREVA, now known 9 as Framatome and others.
10 And then, we also dispositioned other 11 limitations and conditions spelled out in the License 12 Topical Reports.
13And then, you include the markups. So, 14 this is a typical application of the core is the M+
15 SAR that we reviewed.
16 The major four changes requested are 17 pretty much typical to other MELLLA+.
18 The first is the Instrumentation Technical 19 Specification changes so that it will be consistent 20 with the M+ License Topical Report and mainly for the 21DSS-CD methodology to control the stability of the 22 core.23 And then, the next thing is the increase, 24 almost double, the standby liquid control boron 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 11enrichment. Actually, that has been physically 1 implemented at the plant already.
2 The third one is more important, is the 3 operational restrictions that was imposed before --
4 beyond the original EPU. Right now, with a request, 5 it will prohibit feedwater temperature reduction and 6 also single loop operations in the MELLLA+ domain.
7 And, lastly, some administrative changes.
8 Our staff reviewed approaches similar to 9other MELLLA+ like Gregory mentioned earlier. We 10 addressed each section of the BSEP SAR and all the 11 applicable limitations and conditions spelled out in 12 the License Topical Report.
13Our team conducted two audits. The first 14 one is a detailed Safety Analysis Audit of both GEH 15and Framatome. That was done in Rockville here in 16 July last year.
17 And then, earlier this year, we went to 18 the site and audited the simulator and observed the 19operator actions and we discussed with operators on 20 site.21 And, our -- we sent the Committee a draft 22SE about a month ago. At that time, our colleagues at 23 Research are still finishing up their TRACE study.
24 So, at that point, we included a placeholder in our 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 12draft report. Later on, we submitted a -- well, we 1 plugged in to summarize the result of the Research 2 TRACE study.
3 And, that, again, we heard yesterday, 4 that's specifically to model the Brunswick 5configuration. And, that will give the complete 6 result.7 I need to emphasize that what you saw is 8 kind of rough because we had to include the research 9as a plug-in. Some of the references may not be 10correct. The reference 30 in the plug-in actually is 11 pointing to the full report that Dr. Yarsky was 12talking about yesterday. It hasn't been published 13 yet.14So, that is the full report. The research 15 is going to be submitted to the Committee if not have 16done already. So, there's some disconnects in the 17 reference.
18 So, we are polishing the final SE and 19 there's little -- very little change in the technical 20 substance, especially the area we'll discuss today, 21 mostly just to make sure the references are consistent 22 and also some of the words will be better looking 23 back, you know, say it better this way.
24But, you know, we did not change the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 13substance. We will be submitting a final polished 1 version through Weidong and send it to the Committee 2 in about a month's time.
3CHAIRWOMAN REMPE: Okay, just a second, so 4make sure that I've got it on the record and that I 5 understand.
6 There will be some minor changes including 7 correlation of references or word changes so that 8plug-in will be incorporated. And, you're going to 9 send us an updated version of the SE with no 10 substantial changes. And, that's going to come in?
11MR. HON: I'm looking at about three, four 12 weeks time frame.
13 CHAIRWOMAN REMPE: Okay.
14MR. HON: I want to through a technical 15 editor first so that we have it more polished.
16CHAIRWOMAN REMPE: And so, it's real 17 important to have it to the Full Committee a month 18 ahead of time.
19 MR. HON: Yes.
20CHAIRWOMAN REMPE: That's my understanding 21 is -- there were no open items in the SE that you gave 22 us that was a draft, so it looked pretty good.
23 But, we will not see any substantial 24 changes in it --
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 14 MR. BORROMEO: So, this is Josh Borromeo 1 from the staff.
2 There is one change that you will see that 3 is semi-substantial. It's Limitation Condition 9.23 4 which is the Item Value Tracking that is supposed to 5 be submitted after the first MELLLA+ application.
6 GE has done that previously, so we said 7 that wasn't applicable for GE on MELLLA+ applications.
8 AREVA and Monticello came in like two years ago with 9 their EFW on MELLLA+ application.
10 Because of the lower power density of that 11 plant, we said it wasn't necessary for them to provide 12 us that -- all that data.
13 For Brunswick, however, since they're a 14 higher power density, we are going to be requesting 15 that data.
16 Right now, the SE says it's not applicable 17 but we have updated that and that's consistent with 18 what the licensee committed in a supplement to their 19 Safety Evaluation -- to their License Amendment 20 Request.21 CHAIRWOMAN REMPE: Okay.
22MEMBER MARCH-LEUBA: So that's going to be 23 a licensing commitment by the licensee or is it going 24 to be a limitation on the SER?
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 15MR. BORROMEO: It's applying with the 1 limitation and condition. Right now, they said this 2-- originally, when they came in, they said this is 3 applicable. We did a non-accept with an opportunity 4 to supplement where we said, well, I think, you know 5--6 MEMBER MARCH-LEUBA: It's up to you, but 7 typically --
8 MR. BORROMEO: Yes.
9MEMBER MARCH-LEUBA: -- put it in the 10 licensing conditions --
11MR. BORROMEO: Yes, it will be 12 enforceable.
13MEMBER MARCH-LEUBA: Yes, but this -- it's 14 unfortunate but because of the sunset provision that 15 the moment you send it back, this doesn't apply 16 anymore. It's kind of weird to do it that way.
17MR. BORROMEO: So, that's the only 18 substantial difference that you'll see.
19CHAIRWOMAN REMPE: I'm going to really 20 emphasize, again, we have told you a lot, so we have 21 some flexibility.
22 MR. BORROMEO: Right.
23CHAIRWOMAN REMPE: So, this isn't the June 24 meeting or doing this letter and I didn't know about 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 16 this.1MR. BORROMEO: Yes, we identified this 2 maybe a week or so after we sent the SE to --
3 CHAIRWOMAN REMPE: Okay. So, really try 4 hard to get this to us by the first of June, please.
5MR. BORROMEO: Yes, absolutely. Although, 6 all the technical updates are -- I mean, the update is 7 already incorporated. It's --
8 CHAIRWOMAN REMPE: Okay. Again, I don't 9 think we care if it's gone through tech editing.
10 MR. BORROMEO: Okay.
11 CHAIRWOMAN REMPE: But, bet something to 12 ACRS that's not going to change a month in advance.
13 Okay?14 MR. HON: Thank you.
15 CHAIRWOMAN REMPE: Thank you.
16MR. HON: All right, we'll try to send you 17 sooner.18 CHAIRWOMAN REMPE: Okay, thank you.
19MR. HON: Like Josh said, we're not making 20any substantial changes, just polishing it. Thank 21 you.22CHAIRWOMAN REMPE: Okay, thank you for 23 getting that on the record here.
24 MR. HON: Again, this is a very involved 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 17view. We have -- I want to acknowledge the review 1 team on the slide here, especially, of course, the 2 team leader and the support for my research that Dr.
3 Yarsky presented yesterday.
4 Today's presentation agenda is the 5 following. Because this is a combination of GEH and 6 Framatome technology, due to commercial agreement 7 limitations, there's not a full exchange of 8 information between the two vendors.
9 So, we want to be very careful to have the 10 closed sessions that are only applicable to one 11vendor. So, we structured the presentati on as 12 follows.13 Following my presentation, licensee will 14come and give an overview, that will be the public 15 session.16 And then, after that, we take a break and 17 we'll excuse I think people who don't have access to 18 the GEH proprietary information and the licensee will 19 present that part after that.
20 The staff will present our result of the 21review and then we'll swap people out. The only 22 people who have access to Framatome proprietary 23 information will stay at 10:40 or so and present the 24-- I believe the aspect of the application.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 18 Likewise, the staff will immediately 1 follow that and present our results.
2 So, if it's okay with members of the 3 Committee, we'll follow that.
4 Again, this is a -- what I call an error 5 likely situation for spills so I hope that won't 6 happen today.
7 Thank you for your patience with the 8 arrangement.
9 With that, I'd like introduce Jane 10 Marshall which is our Deputy Director for the 11 Technical Division.
12 Jane?13MS. MARSHALL: As Andy said, my name is 14 Jane Marshall and I'm the Deputy Director for the 15 Division of Safety Systems in the Office of Nuclear 16 Reactor Regulation.
17 Today, we're presenting the staff review 18 of Brunswick Unit 1 and 2 MELLLA+ License Amendment 19 review.20 The primary focus of NRR's review for this 21 application were the new approaches in areas that have 22 been historically challenging in these reviews.
23 To ensure consistency among reviews, the 24 staff used previous MELLLA+ r eviews as well as 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 19 relevant prior Tropical Report reviews.
1 While this review contains several new 2items, I'd like to highlight the main technical 3 challenge for this review was the interface between 4 GEH methods and the Framatome fuel.
5 To support the NRR staff conclusions, 6 particularly the anticipated transient without SCRAM 7 instability, or ATWS-I calculations, the staff used 8 TRAC RELAP Advanced Computation Engine, or TRACE code, 9 confirmatory results which were completed by the 10 Office of Research and presented to the ACRS Thermal 11 Hydraulic Subcommittee yesterday.
12 These confirmatory results are intended to 13 help gain efficiency in the staff's review and help 14 flesh out any unknown issues.
15 In addition to the Office of Research 16 supporting the review, other offices from NRC 17 supported this review, many staff across NRR and we 18 contracted with Oak Ridge National Labs.
19 Thank you, and I'll now turn it over to 20 Josh Borromeo.
21 (OFF MICROPHONE COMMENTS) 22 MS. MARSHALL: Oh, licensee, I'm sorry.
23 CHAIRWOMAN REMPE: So, let's --
24MS. MARSHALL: Turn it over to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 20 licensee.1CHAIRWOMAN REMPE: -- go ahead and do that 2 since we had a tight schedule today. Okay.
3 Andy, can you hit escape again? Yes.
4MR. NOLIN: We're good? We're good to go.
5 CHAIRWOMAN REMPE: Okay.
6MR. NOLIN: Good morning. I'd like to 7 thank you for having Duke Energy here for the 8 discussion on MELLLA+.
9 I'm Jeff Nolin, I'm the General Manager of 10 Engineering at Brunswick.
11 We'll be presenting a few objectives for 12 the discussion today.
13 First, to show the need for MELLLA+, why 14 we're submitting the License Amendment, demonstrating 15 the key aspects of our request and demonstrating 16 readiness.
17 So, there was a discussion already today 18 about the key differences between integration of 19 AREVA, now Framatome, fuel and the GE methodology, so 20 demonstrating our readiness relative to the 21 integration of that aspect.
22 And, the request for submitting the 23 approval, we're looking for a third quarter 2018 24 implementation.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 21 The reasons for that are Unit 2 is -- will 1 be approaching end of life in the current cycle. We 2have a March 2019 refueling outage on Unit 2. So, 3 Unit 2 will be approaching a condition with final 4feedwater temperature reduction in December. We would 5 like to implement in the fall of 2018.
6 We would like -- Duke Energy would like to 7 implement both units at the same time from an 8 integration of procedures, operator training, 9 consistency of maintaining the units.
10MEMBER MARCH-LEUBA: So, then is Unit 1 11 already loaded? The core welding supports MELLLA+?
12 MR. NOLIN: Yes. So, Unit 1 and Unit 2, 13 in a couple of slides --
14 MEMBER MARCH-LEUBA: Okay, keep going.
15MR. NOLIN: Perhaps the next slide, I get 16 to that exact question.
17 So, anyway, our intent is to integrate 18 both units at the same time and support for that 19 relative to the timing of the third quarter of 2018 20 because of the Unit 2 fuel cycle.
21 Next slide?
22 So, Brunswick Nuclear Plant, Brunswick 23 Steam Electric Plant is a two unit GE BWR-4 design.
24 We started commercial operation, Unit 2 was the lead 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 22 unit in 1975, Unit 1 followed shortly after.
1 So, we have 42 and 43 years of operating 2 experience at Brunswick, so we are in the license 3 renewal period of extended operation for both units at 4 Brunswick.
5 Brunswick did do an extended power uprate 6 to 2923 megawatts thermal and we have been operating 7 in with EPU conditions for 13, 14 years now.
8 So, many of the prior license amendments 9 relative to MELLLA+ were integrated with the power 10uprate. Brunswick has been operating with EPU for 11 more than a decade now on each unit.
12 And so, this license amendment is strictly 13 for MELLLA+, not the power uprate.
14MEMBER SKILLMAN: Jeff, were you always 15 24-month operating cycle or were you 18 originally and 16up bumped it 24? Mark, do I need to defer that to 17 you?18 MR. NOLIN: Eighteen originally, we came 19 up to 24 months.
20MEMBER MARCH-LEUBA: Mark, turn your 21 microphone on when you speak.
22 MR. DEWIRE: It is on.
23 MEMBER MARCH-LEUBA: Oh, it is on?
24 MR. NOLIN: No, no.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 23MEMBER MARCH-LEUBA: He was looking maybe 1--2CHAIRWOMAN REMPE: What's the power 3 density of Brunswick? The Brunswick plants?
4 MR. YODERSMITH: We have a backup slide.
5CHAIRWOMAN REMPE: I looked for it on the 6 backup slide, I didn't see the power density like 7 kilowatts per liter.
8 MR. YODERSMITH: Give me one second.
9MR. BORROMEO: I think -- this is Josh 10 Borromeo --
11 MR. YODERSMITH: Page 20.
12 MR. BORROMEO: -- I think they're around 13 59 kilowatts per liter.
14CHAIRWOMAN REMPE: Okay. It'd be good to 15 confirm that and you don't have to do it now, but --
16 MR. YODERSMITH: We -- sorry, we present 17 it in kilowatts per foot here.
18 CHAIRWOMAN REMPE: Okay. But, you think 19 it's 59 kilowatts per liter?
20MR. BORROMEO: It was 4.9 kilowatts per 21 foot and here's how we stack up against the previous 22 submittals.
23 CHAIRWOMAN REMPE: Okay. So, again, I'd 24like to know what it is kilowatts per liter. And, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 24I've been told by the staff it's 59. Could you get 1 that confirmed for me today?
2 MR. YODERSMITH: Sure.
3 CHAIRWOMAN REMPE: Thank you.
4MR. NOLIN: So, we are operating on a 24-5month fuel cycle. So, we have a refueling each March 6 on alternating units.
7 We did transition to Framatome fuel in 82008 in Unit 1, 2009 in Unit 2. So, we have 9 approximately a decade of operating experience with 10 Framatome fuel.
11We are initially ATRIUM 10. We are a full 12core ATRIUM 10XM fuel now. And, our licensed core 13 flow is 104.5 percent as was previously mentioned at 14 full power.
15 The project overview, the reason for the 16 submittal is to expand the flow window at full power.
17 The benefits of that is that we are required with the 18 current flow window to have multiple reactivity 19 manipulations for sequence exchanges.
20So, the MELLLA+ will allow us to reduce 21 the number of downpowers, the number of reactivity 22 manipulations of the plant.
23 MEMBER MARCH-LEUBA: Jeff, on the top of 24 your head, how often do you change route, do you move 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 25 those today?
1MR. NOLIN: There's sequence exchange 2 quarterly.
3MR. THOMAS: Sequence exchanges are about 4every 2500 megawatt days per metric ton. And then, as 5 you get into the latter half of the cycle, maybe two-6 thirds, we sometimes have to do them weekly to stay 7 within our flow window.
8 Essentially, it's the hot access 9 reactivity begins to drop off at the end of cycle.
10MEMBER MARCH-LEUBA: So, about once a 11 week?12 MR. THOMAS: Yes.
13MR. YODERSMITH: Towards the end of cycle, 14 that's about what it is, about once a week, maybe --
15MR. THOMAS: Yes, maybe two-thirds of the 16 way through the cycle.
17MEMBER MARCH-LEUBA: So, MELLLA+ would 18 allow you to extend that probably for a month?
19 MR. THOMAS: Yes.
20 MR. YODERSMITH: Correct, at least.
21MEMBER MARCH-LEUBA: It's a big, big 22 improvement.
23 MR. YODERSMITH: Yes.
24MR. NOLIN: So, in addition to that, it'll 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 26 help with recirc pumps, the operation of the recirc 1 pump seals has been a reliability issue for many 2plants. And so, being able to expand the flow window 3 will also help improve recirc pump seal reliability.
4 So, it has some benefits beyond the 5 reactivity manipulations as well.
6CHAIRWOMAN REMPE: So, I don't recall 7other MELLLA+ applicants coming in and saying this 8 about the pump seals. And, is there evidence to say 9 yes, that's occurred with the ones that have gone in 10 to MELLLA+? Or have they not had much experience or 11 is this a well-substantiated issue?
12 MEMBER MARCH-LEUBA: I believe the issue 13 is, I mean, because they cannot go below 99 percent 14 flow, they have to be running at full power all the 15 time. The maximum you can crank out of them.
16 When they go to MELLLA+, they can be 17 running at 80 percent of it.
18CHAIRWOMAN REMPE: But, is there evidence 19 to support this claim that it's really helping with 20seals? I just -- I've not seen any other applicant 21 come in with that.
22MR. THOMAS: I think it's the opposite.
23 I think it's the evidence is that the staying 24 consistently at the higher flows is adverse to the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 27 seals.1MR. NOLIN: We've seen since -- I 2 mentioned earlier that we have approximately a decade 3at post-EPU. And, our experience was that the recirc 4 pump seals have been more challenged by operating at 5 a 100 percent flow consistently.
6 So that --
7CHAIRWOMAN REMPE: Well, in the recent 8 years, you've seen --
9 MR. NOLIN: -- experience at Brunswick.
10 MR. DEWIRE: Yes.
11CHAIRWOMAN REMPE: Have you had to replace 12 them?13MR. NOLIN: We're doing a design change to 14 the seals to support the sustained operation at high 15flow. So, we're doing other things to improve recirc 16 pump reliability. But this will also help it.
17 CHAIRWOMAN REMPE: Okay, thank you.
18MR. NOLIN: So, a prior question about 19 readiness for the station for implementation on each 20unit. So, we've -- the Phase I prior to 21 implementation, plant modifications and training, we 22 did do the upgrade of our standby liquid control 23 system.24 We increased the enrichment from 47 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 28percent to 92 percent on each unit. And, that is 1 complete.2 We did the APRM EPROM modifications a 3couple years ago in each unit. So, the physical 4 changes with the power range monitors have been 5 completed.
6 And, Mark DeWire, our senior license 7 holder will also discuss the operator training. So, 8 we've been through a couple of cycles of operator 9 training on MELLLA+ for readiness.
10 The implementation phase, we'll implement 11--12MEMBER MARCH-LEUBA: Sorry, go back to 13that. You do parallel training because you have to 14 train your operators to what is today applicable?
15 But then, on Friday afternoon you talk 16 about what you'll be doing next year?
17 MR. NOLIN: So, we have -- Mark will get 18 into that in much more detail.
19MR. DEWIRE: Yes, if you can just hold 20 that question until I get up with my presentation, 21 then I'll address your question.
22 MEMBER MARCH-LEUBA: We'll wait.
23 MR. DEWIRE: Thank you, sir.
24 MR. NOLIN: So, the implementation phase 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 29 will consist of implementing the tech specs procedure 1changes. We'll also go through a testing phase in the 2 MELLLA+ domain which will include level and pressure 3 perturbations in a series of five test conditions.
4 And then, the implementation of the detect 5 and suppress solution for the MELLLA+.
6 So, the plant is physically ready and the 7 implementation will be integrated on both units at the 8 same time.
9 With that, I'd like to turn it over to 10 Roger Thomas, he's our Manager in Nuclear Fuels.
11MR. THOMAS: Thanks and, as Jeff said, 12John Siphers was originally scheduled to give this 13 presentation, but because of the weather, his flight 14 was cancelled, so I am acting as his understudy today.
15 I am Manager of Brunswick Nuclear Design 16 which is a unit within John's group.
17 So, the focus of my part of the 18 presentation is something that's already been touched 19 on, is some of the unique aspects of our LAR compared 20 to some of the previous ones.
21 We, of course, did follow the generic 22 MELLLA+ LTR, but there was a division of labor between 23 Framatome and GE that will be described in greater 24 detail in some of the proprietary presentations.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 30 But, briefly, GEH, their division of labor 1was to evaluate the overall plant response. They 2 focused on ATWS, ATWSI, long-term stability and DSS-3 CD.4 Framatome focused on those areas of the 5 analysis specific mostly to the fuels, the kinds of 6 analysis that you would typically see on a reload or 7 cycle specific basis.
8 As also previously been mentioned that GEH 9 and Framatome both have long and extensive experience 10 modeling the Brunswick plant.
11 GE, from initial startup, through extended 12 power operation and beyond, all the way to 2008 at 13 which time we transitioned to ATRIUM 10 fuel and in 14 2008. And then, later, in 2011, to ATRIUM 10XM.
15 Framatome has modeled the core and the 16 plant through that period all at extended power 17 uprate.18 Another thing that might be unique is that 19 the cap credit, because we have had extended power 20 uprate for some time, we are proposing no changes to 21 our cap credit that we currently have.
22 MELLLA+ doesn't impact cap credit and the 23 NRC has a slide where they go into greater detail on 24 that. So, we're standing pat on that.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 31 All right, so, looking at vendor 1 methodology applicability, that's also something 2 that's been touched on. It's something that we were 3 challenged on early on.
4 Specifically, the challenge was, how --
5 are GE methods applicable to AREVA fuel, excuse me, 6Framatome fuel? And, whether or not Framatome methods 7 are applicable in the expanded MELLLA+ flow regime?
8 So, starting with Framatome, there are no 9 SER restrictions on Framatome methodology that are 10 impacted by MELLLA+.
11 And, the Brunswick core and assembly 12 conditions that we will have in MELLLA+ are equivalent 13 to core and assembly conditions of other plants for 14 which Framatome's methodology was benchmarked.
15 And, of course, they elaborate on that in 16 the report that you see there in the first bullet.
17 GEH methods are applicable to MELLLA+, of 18 course, and they are capable of modeling Framatome 19 fuel.20 There was an extensive transfer of 21 information about the characteristics and the 22 dimensions of the fuel from Framatome to GEH. GEH 23 explicitly modeled the ATRIUM 10XM fuel.
24 Duke had an interface role there where 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 32 what we did is we developed a GEH thermal hydraulic 1model for them in ISCOR. We translated the X-code 2results. And, this is something we have done many 3times in the past for other reasons. So, it was just 4 a matter of going a different direction.
5 And, in response to some RAIs, we also 6 provided steady state core simulator comparisons 7 between Framatome and GE and they showed excellent 8 agreement and excellent results.
9 And, they prove, for the purposes of the 10 work that GE is doing, that they could satisfactorily 11 model the ATRIUM, or excuse me, yes, the ATRIUM 10XM 12 fuel.13MEMBER MARCH-LEUBA: Roger, did I hear you 14correctly, instead of passing -- you passing the 15 Framatome, call it equivalent diameter from the fuel 16 to GE, you actually rolled the ISCOR model for them?
17MR. THOMAS: We created an ISCOR model for 18them. And, it was the equivalent to Framatome's X-19 cover modeling.
20MEMBER MARCH-LEUBA: So, instead of 21 parsing the dimensions of the fuel --
22 MR. THOMAS: No, no, no.
23 MEMBER MARCH-LEUBA: -- you created --
24MR. THOMAS: No, fuel dimensions were 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 33 passed.1CHAIRWOMAN REMPE: So, in some of the 2 information I read, some dimensions might have been 3 passed, but they basically said, we gave -- GEH gave 4 a range of conditions or parameters and sent it over 5the fence. And, AREVA or Framatome said, yes, that'll 6 bound it.7 So, what exactly -- and maybe we could get 8 into the proprietary --
9 MR. THOMAS: That was -- yes, that's --
10CHAIRWOMAN REMPE: -- and discussion, too.
11MR. THOMAS: Yes, the details of that are 12 proprietary, but the concept is on, if not the next 13 slide, the slide after that.
14 CHAIRWOMAN REMPE: Okay.
15 MR. THOMAS: Okay, so, GEH key analysis, 16 so, this is where we speak to this a little bit.
17 So, in the previous slide, I mentioned 18 that GEH analyzed anticipated transient without SCRAM 19 and ATWS with instability.
20 The uncertainties and the ranges that you 21 mentioned are what AREVA provided were nominal 22 dimensions, nominal and so, GE identified to AREVA 23what the important sensitive parameters would be in 24 their analyses.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 34 And, they said, can you give us the 1 uncertainties for these?
2 That's a very sensitive thing, so, what 3 they did is they bounded the ranges. I think it was 4 kind of like, you know, The Price is Right game, 5 higher, lower, higher, lower, ding, ding, ding, ding.
6Okay, that'll bound it. All right? That's kind of 7 how it went.
8 And, Framatome will have to speak to how 9those ranges actually bound their uncertainties. All 10 right?11 Additionally, coming out of the LAR audit 12 that we had last July, GEH uses a different Tmin 13correlation, I guess you would call it. And, or they 14 have a preferred one, but the NRC requested that they 15 provide -- they do additional sensitivities using the 16 homogeneous nucleation plus contact temperature model, 17 which I have to read to say that.
18 But, those were also provided in a 19response to an LAR. And, I believe the key conclusion 20 here is, even with all of those parameters and 21 sensitivity studies applied, the results were still 22 favorable overall to the result and to support of the 23 MELLLA+ LAR.
24 So, again, there's a lot of proprietary 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 35 information supporting those three bullets there, and 1 it will be addressed in some of the follow on.
2 All right, one of the things that we also 3 did, some of this has also been touched on a little 4 bit, is mitigating actions.
5 Clearly, MELLLA+ is a more challenging 6area of operation for the plant. So, we wanted to 7 talk what actions made sense to sort of soften that 8 impact.9 The first is the adoption of the Detect 10and Suppress Solution Confirmation Density. We're 11 currently in Option 3 for non-MELLLA+ operation. We 12 will be transitioning to the DSS-CD for this which 13adds the additional layer of checking and that 14 additional algorithms associated with that.
15 The second thing we did which Jeff also 16 touched on was we have already increased our SLCS B-10 17 enrichment from 46 to 92 or greater. And, what this 18 did for us is, it actually reduced the heat load and 19 suppression pool for the ATWS analyses in MELLLA+
20 relative to our original license condition.
21 So, in the box at the bottom, we compared 22 the two at 2436 and 75 percent flow which is several 23 power uprates ago that the result was 189 degrees.
24 And, you can see that there's an approximately 15 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 36 degree improvement there which is a quantifiable 1 increase in the safety margin that we have for the 2 plant. So, that was a very positive result.
3 MEMBER MARCH-LEUBA: The other licensees 4-- previous licensees have opted also to a speed up 5 their operation -- operator actions from 120 to 90 6 seconds, the water level reduction.
7 However, you decided to keep it at 120.
8 MR. THOMAS: Yes.
9MEMBER MARCH-LEUBA: And, yesterday in 10 open session, we were told that in reality you're 11 trained to 96 seconds.
12 MR. THOMAS: That's right.
13 MEMBER MARCH-LEUBA: Which is 80 percent 14 of 120.15CHAIRWOMAN REMPE: So, there's some slides 16 coming up in this open session on this, so because I'm 17 going to try and keep us on schedule, I'd like to let 18 them have the opportunity to answer that question 19 later.20 MR. THOMAS: Yes, that --
21CHAIRWOMAN REMPE: I think it fits in a 22 better slide.
23 MR. THOMAS: Yes.
24 CHAIRWOMAN REMPE: Okay? Sorry.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 37 MR. THOMAS: That's okay.
1 Okay, and the final topic that I have is 2Safety Limit MCPR. Unlike some of the previous 3 MELLLA+ LARs, we are proposing that there's no penalty 4 required for the safety limit MCPR in MELLLA+.
5 Framatome has a great deal of information 6 in their proprietary session that will support this.
7But, what I can say is the primary concern that 8 prompted the previous penalties was the increased void 9 fractions and the concern that, as you move to those 10 increased void fractions you would see increases in 11 your uncertainties.
12 And, there was a lack of operating data to 13 justify those uncertainties.
14 Framatome will present operating 15experience that includes data in those ranges that 16 validates the use of their existing uncertainties.
17 And, we will also present some Brunswick 18 specific information that shows that as we increase --
19 as we go along the line of increasing void fractions, 20we do not see a negative trend in our applied 21uncertainties. So, both of those will be presented in 22 the Framatome session.
23 So, the conclusion of that would be that 24 operation in the MELLLA+ region is within the analysis 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 38 capabilities of Framatome methods and uncertainties 1 and so, no safety limit penalty is warranted.
2 So, with that, I'll turn it over to Mark 3 DeWire to address operator actions and training.
4MR. DEWIRE: Good morning, I am Mark 5DeWire. I'm Assistant Ops Manager for the Shift at 6 the Brunswick Nuclear Power Plant.
7 We're going to talk about operator 8training. It was conducted in two cycles over the 9 year 2017 and it began in the spring, May/June time 10 frame where we started with just classroom discussion 11 which included a high level overview of the changes 12 that were coming and what we are intending to 13 accomplish.
14 Came back around in 2017 in the fall with 15 more classroom training w hich was on tech spec 16 changes, procedure updates and included a tech spec 17 workbook to allow the senior licensed operators to 18 work through that and understand the tech spec 19 changes.20 And then, we also went into the simulator, 21 we did the hands on training, did demonstrations and 22 the hands on training where we focused more on the 23 time critical operator action of 120 seconds for 24 initiating water level reduction which get into your 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 39 question.1 So, the ATWS training's not a new concept.
2 We have been training -- always been training on ATWS.
3 The 120 seconds, we had started training to that a 4 year and a half to two years ago when we first knew 5 that MELLLA+ was coming our way.
6 So, we worked our way through that and we 7 designated it as a time critical operator action.
8 So, I'll keep going on to the next slides.
9 So, the operating crews were trained on 10the time critical actions, as I mentioned. Each crew 11 was given three high power ATWS simulator scenarios to 12be performed. And then, as mentioned earlier, in 13 February 2018, the NRC came down and did an audit and 14 observed the performance of the high power ATWS time 15 critical actions with no comments.
16 Twelve operating crews that --
17MEMBER SKILLMAN: Can you back a slide, 18 please?19 MR. DEWIRE: Yes, sir.
20 MEMBER SKILLMAN: So, the NRC comes down 21and takes a look. Are the crews informed when the 22 event is going to occur or how to ensure that the crew 23 really knows when to take that action and that they're 24 not pre-staged waiting like a vulture to meet their 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 40 120 seconds.
1MR. DEWIRE: Right. So, that's a good 2 question.3 So, the crews know there's an ATWS coming, 4 they're in there for that specific event, so you can't 5 hide that from them.
6 However, the plant is put through a 7 transient and then they worked their way into the 8ATWS. So, they're not standing by with people at the 9ready at various locations. They're dealing with a 10 simulator scenario and they're working their way in to 11 ultimately the ATWS actions on it.
12 So, I don't have people preprogrammed 13 standing over ready to go.
14MEMBER SKILLMAN: That's probably as good 15 as you can do. So, thank you.
16MR. DEWIRE: As mentioned, 12 operating 17crews at three scenarios, so 36 total scenarios. The 18 average time was 85 seconds. The standard deviation 19was 16 seconds. And, we were able to successfully 20 demonstrate that we could perform the time critical 21operator actions within the 120 seconds and with 22 margin.23CHAIRWOMAN REMPE: Okay, so now I want to 24 stop and have you answer Jose's question about why not 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 41 go to 96 seconds.
1 I also am curious, what was the longest 2 time someone took?
3MR. DEWIRE: Hundred and twenty-one 4 seconds, one operating crew.
5CHAIRWOMAN REMPE: So, that's above the 96 6 metric we were told about yesterday.
7MEMBER MARCH-LEUBA: How about the 120 --
8 so, if you do 121, that will fail, right?
9 MR. DEWIRE: That's correct.
10 MEMBER MARCH-LEUBA: They have to retake 11 it?12MR. DESIRE: That's correct. So, they 13fail the time critical operator action. So, we go 14 into the training process and they get remediated and 15 they do it again.
16MEMBER MARCH-LEUBA: Remedial training, we 17 have people going through that.
18MR. DEWIRE: So, the 120 -- so, the 85 19 seconds, when we get back to the 120 second question, 20 we did benchmarking and we brought in and we actually 21 changed the initial operator actions for reactor 22 operator.23 We gave them a hard car where they could 24 secure the recirc pumps and they could initiate SLC 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 42 based on their actions and reading the control board.
1When we looked at other ways to get 2 leveled down rapidly required just to the design of 3 our plant, pretty significant engineering change to 4get the level to come do wn with like the push of a 5button or something like that. It takes operator 6 action.7 And, when you incorporate INPO's IER 17-5 8 with leadership trades and maintaining command and 9control, we felt prudent to maintain command and 10 control with the control room supervisor directing the 11 initiation of the reactor wide level reduction.
12 So, given that philosophy, we were able to 13 demonstrate right around 85 seconds is where we come 14 in with that time critical. Maintaining the command 15 and control yet allowing the operator to take actions.
16MEMBER MARCH-LEUBA: So, you're saying the 17 design of the control -- the pump control requires you 18to roll them back slowly? You cannot just read them?
19MR. DEWIRE: They do. They run -- they 20 get run back on the SCRAM signal from the reactor 21 protection system and then --
22MEMBER MARCH-LEUBA: No, I'm talking --
23 sorry, I was talking about -- I said pumps, I meant 24 feedwater pumps.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 43MR. DEWIRE: The feedwater pumps are 1 directed from -- so, the order to terminate and 2 prevent will come from the control room supervisor 3 then the reactor operator would take action, it would 4 be another hard car.
5MEMBER MARCH-LEUBA: How long does it take 6 to terminate and prevent?
7 MR. DEWIRE: Eighty-five seconds.
8MEMBER MARCH-LEUBA: No, no, I mean, it 9 probably takes 80 seconds to start --
10MR. DEWIRE: All right, so the valve 11strokes on the feedwater systems are probably around 1280 seconds for them to complete total stroking. But, 13 the one feed pump is tripped off, the other feed pump 14 is run down, it's discharged pressure so it cannot 15 inject.16 So, it's terminated that way and you're 17 waiting on the valves for the prevention.
18 MEMBER MARCH-LEUBA: Okay, thank you.
19MEMBER SKILLMAN: How significant were the 20 changes to the operating procedures to accommodate the 21 successful outcome here?
22 MR. DEWIRE: Not very, the only --
23 MEMBER SKILLMAN: Just a couple of --
24MR. DEWIRE: Yes, the only thing we really 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 44 added was we allowed the RO more flexibility to take 1 action at the control board with the initiation of SOC 2 and the tripping of the recirc pumps.
3 MEMBER SKILLMAN: Okay, thank you.
4CHAIRWOMAN REMPE: So, is this the only 5 time critical operator action associated with MELLLA+
6 or does the initiation of like SLC injection --
7MR. DEWIRE: SLC injection of less than 8 five minutes is a time sensitive with -- time 9 sensitive operator action.
10CHAIRWOMAN REMPE: But, it's not time 11 critical, it's a different --
12MR. DEWIRE: Right, it's a different 13 category.14CHAIRWOMAN REMPE: -- category and how you 15 train for it and treat it?
16MR. DEWIRE: Right. But, again, we added 17 that to the hard car so that was one of the immediate 18 actions that the rad dropper is going to take.
19MEMBER MARCH-LEUBA: Plus, in my 20 experience the SLC -- the boron injection always 21 happens before it's needed because the EOP's still 22 your -- if you think you're going to get there, push 23 the button, is that correct?
24MR. DEWIRE: Right. So, he's going to 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 45 look at power level and if it's greater than a ceratin 1 percent, he's going to initiate SLC.
2 MEMBER MARCH-LEUBA: And then --
3 MR. DEWIRE: But, that boron enrichment, 4I've been there since '95, licensed since 2000. It is 5 a significant difference with that enriched boron and 6 how fast power comes down.
7MEMBER MARCH-LEUBA: Yes, but what -- I 8 was trying to say is that the boron injection time, 9 you can call it critical, you never -- your crews are 10never going to fail it, right? Is that your 11 experience?
12MR. DEWIRE: Right, it's pretty quick 13 right off the bat.
14CHAIRWOMAN REMPE: Are we good to go on 15 guys?16 MR. DEWIRE: All right.
17 CHAIRWOMAN REMPE: Thank you.
18 MR. DEWIRE: Yes, ma'am.
19 So, in conclusion, implementation of the 20 MELLLA+, we're talking about the benefits, greater 21 flexibility in using core flow to control reactivity.
22 That's near and dear to my heart as an operator with 23 reactivity manipulation in a cycle.
24 Reduces the number of plant downpowers, 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 46 reactivity manipulations and increases the station's 1 capacity factor for the operating cycle.
2 We'll be ready to implement MELLLA+
3 License Amendment, we talked about the installation of 4 the hardware changes with the DSS-CD firmware and the 5 SLC enrichment.
6 We've completed training on MELLLA+, the 7 procedures and required operator actions.
8 The final PRNM nuclear monitoring setpoint 9 engineering change is being finalized and 10 implementation of a test plan has also been 11 established.
12 And, with all that, we're -- as mentioned, 13 we're requesting approval for the third quarter of 14 2018 implementation.
15MEMBER MARCH-LEUBA: So, go to MELLLA+, 16 you don't have to change any hardware other than 17 EPROMs and things like that?
18MR. DEWIRE: That's correct. It's already 19 installed, it's a matter of turning it on.
20 MEMBER MARCH-LEUBA: Good, perfect.
21CHAIRWOMAN REMPE: So, despite the fact 22 we're a little bit behind, there's a slide 22 that you 23 prepared and I just would like you to -- it's a backup 24 slide and I was looking through your backup slides 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 47before the meeting -- that one. Could you talk a 1 little bit about that one, please?
2MR. YODERSMITH: Yes, so this is our -- my 3 name is Stephen Yodersmith with Duke Energy.
4 So, this is our test conditions that we'll 5be walking through during our test window. So, we'll 6 start at test condition A and that'll be where we 7 start our testing window.
8 And then, we'll come down to each of these 9 test points, B, C, D, E and the various testing at 10 those points to collect data for MELLLA+ transition.
11 And then, after --
12 MEMBER MARCH-LEUBA: Stephen, those test 13 points, is that when you're testing your control 14 systems, I think?
15 MR. YODERSMITH: That's correct.
16 So, yes, let me get to --
17MEMBER MARCH-LEUBA: You'll be performing 18 perturbations on your systems, CD control work fine?
19 MR. YODERSMITH: So, we'll be performing 20 perturbations on the control systems, pressure 21testing. We'll also be gathering TIP data so that 22 test condition A, we'll be gathering TIP data.
23 And also, at test condition E, we'll be 24 gathering TIP data.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 48MEMBER MARCH-LEUBA: That'll be transient 1 TIP, you know, are your going to wait there for 12 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />?3MR. YODERSMITH: So, it'll be steady 4 state, not steady state xenon, it'll be steady state 5 power level, so we won't wait there for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />, but 6 we will come to that test condition.
7 MEMBER MARCH-LEUBA: Only for one hour?
8MR. YODERSMITH: That's -- yes, it usually 9 takes about four hours to get the TIP data, so we'll 10sit there for that time period. We'll ask operations 11to maintain power at that power level. And so, it'll 12 be a good TIP set which is consistent with the way we 13 gather TIP --
14MEMBER MARCH-LEUBA: Actually, with 15 MELLLA+ we suggest comparison or you know harder to do 16 for the computer guys.
17 MR. YODERSMITH: Yes, that's right. And 18 so, this supports our, you know, we're taking TIP set 19 down at this test condition E in support of what was 20 discussed earlier that we don't need a safety penalty.
21 And so, this will be -- this will provide 22 additional confirmation that, yes, our uncertainties 23 at this lower point, this higher power flow point 24 don't show any inconsistencies with our uncertainties 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 49 at the more normal operating conditions.
1MEMBER MARCH-LEUBA: Maybe I should ask 2 the staff about this, but is this a licensing 3 condition? It's not on the SER.
4 MR. YODERSMITH: We --
5MEMBER MARCH-LEUBA: This second 6 amendment?
7MR. YODERSMITH: Yes, that's correct, yes.
8MEMBER MARCH-LEUBA: I think we're in 9 that, which I like better than a condition on the SER 10 because once you've done it, you don't have to do it 11 again.12MR. YODERSMITH: Yes, so our plan is to 13take this data during MELLLA+ startup. The plan is 14 not to collect data here regularly, and so, our plan 15 is, hey, we're going to -- on each unit, we're going 16 to go collect that TIP data at that test condition and 17 analyze it and make sure it's within our existing 18 license uncertainties.
19 And then, if there's no plans to 20 consistently get data there, but we will get it before 21 we allow operation in the MELLLA+ region.
22 MR. MARCH-LEUBA: Thank you.
23 CHAIRWOMAN REMPE: Yes, thank you.
24 MR. YODERSMITH: You're welcome.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 50CHAIRWOMAN REMPE: That helps with our 1 review.2MEMBER SKILLMAN: Let me ask this, please.
3 As I look at your slide 17 which is your conclusion, 4 what jumps out at me is the DSS-CD firmware.
5 And, the question I'd like to ask is this, 6 what confidence does the station have that the EPROM 7 and the other changes that are essential for this 8 amendment are what those EPROM and other hardware 9 changes need to be to stay within your -- the envelop 10 for which you seek approval?
11 MR. YODERSMITH: We're very confident in 12 the DSS-CD firmware so --
13 MEMBER SKILLMAN: Why are you confident?
14 MR. YODERSMITH: So, as part of the 15 engineering change package that we did in 2016 when 16 this firmware was installed, we did extensive factory 17 acceptance testing and we also did extensive site 18 acceptance testing of the firmware itself.
19 So, knowing that we've got the latest and 20 greatest firmware from GE with the latest and greatest 21DSS-CD solution loaded on there, so extensive SAT 22 testing.23 We are currently operating with Option 3, 24 so we've got the settings set such that Option 3 is 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 51 our primary solution and DSS-CD is not active.
1 As part of our engineering change package 2 that will be implementing upon MELLLA+ approval, we'll 3 do extensive site acceptance test -- additional site 4 post-mod testing would be the right term for it.
5 After we put in the new setpoints, we'll 6 run through our MST, our maintenance surveillance test 7 procedures for those EPROMs which will have been 8 checked out at GE beforehand and run through and make 9 sure that, yes, we are getting the trips where we're 10 supposed to get the trips.
11 We are getting the annunciators where 12 we're supposed to get the annunciators and we'll run 13 through all that testing as part of post-mod testing.
14MEMBER SKILLMAN: For the documentation 15 for that change package --
16 MR. YODERSMITH: Yes, sir?
17MEMBER SKILLMAN: -- to what extent was 18 that covered by GE's and/or your Appendix B program?
19MR. YODERSMITH: Yes, so the -- all the 20 documents -- the sworn documents that we got from GE 21 in support of that mod were developed in accordance 22 with their Appendix B program. And, our engineering 23 change process is to our engineering change to our 24 Appendix B program.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 52 MEMBER SKILLMAN: Yes, sir, thank you.
1 MR. YODERSMITH: Yes, sir.
2 MEMBER MARCH-LEUBA: And, just follow up 3 on a tiny detail, do you do a hash of the firmware to 4 make sure -- in many times of digital controls, people 5 put the wrong EPROM. The manufacturer will send you 6 the wrong EPROM to use in the plant.
7 MR. YODERSMITH: Yes.
8MEMBER MARCH-LEUBA: I mean, the Unit 1 9 and Unit 2 are there to any one?
10MR. NOLIN: There's a significant process 11relative to digital changes of the nuclear plant 12today. So, the firmware and software revision levels 13 are required to be verified by the change and any 14 subsequent PM replacements are corrective maintenance.
15 MEMBER MARCH-LEUBA: When you download a 16 program from the internet, the good size, that's what 17 gives you hash that you can check that it hasn't 18 changed.19 MR. NOLIN: That's right.
20MEMBER MARCH-LEUBA: It would be 21 worthwhile to think about it.
22 MR. YODERSMITH: Yes, so the --
23MEMBER MARCH-LEUBA: Maybe GE needs to 24 think about it.
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 53MR. YODERSMITH: The EPROMs were hashed at 1 GE's facility --
2 MEMBER MARCH-LEUBA: They were?
3MR. YODERSMITH: -- before they were 4 packaged to verify that, yes, this is exactly what we 5 need and what was tested during the FAC.
6 MEMBER MARCH-LEUBA: Okay.
7MR. YODERSMITH: And then, they were sent 8 to site using our cybersecurity process which allow --
9 which requires certain tamper tape to be installed on 10 the boxes and other provisions before they can be 11 accepted at site to be installed.
12 So, we've followed our cybersecurity rules 13 as far as purchasing firmware.
14MEMBER MARCH-LEUBA: Joy's going to say we 15leave it, I love what you said. I'm wasting time.
16 But, I love you said you think of cybersecurity over 17receiving the wrong EPROM. Typically, you don't think 18 of a cybersecurity on USB drives, on CDs, on the 19 internet.20 MR. YODERSMITH: Oh, yes.
21 MEMBER MARCH-LEUBA: But, even an EPROM, 22 your cybersecurity has a plan for it.
23MR. YODERSMITH: Yes, that's right. Anything 24 digitally related, our cybersecurity program gets into 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 54 the purchasing requirements of that.
1 MEMBER MARCH-LEUBA: That's really good, 2 thank you.
3CHAIRWOMAN REMPE: Because you want to 4 catch your plane, I'm going ahead at this point.
5 We're going to -- I think we're done with 6this session. And, I'm going to ask for public 7 comments because this is going to be the end of the 8 open portion of the meeting.
9So, can you get the line open? And, is 10 there anyone in the room who wishes to make a comment?
11 (NO RESPONSE) 12 MR. BROWN: The line's open.
13CHAIRWOMAN REMPE: Okay. Is anyone on the 14 line who wishes to make a comment or if there's anyone 15 out there, if you just would confirm that you're 16 there, it would help us to know that there's someone 17 out there.
18 (NO RESPONSE) 19CHAIRWOMAN REMPE: I'm not hearing 20 anybody.21 PARTICIPANT: We're here.
22CHAIRWOMAN REMPE: Oh, okay, that's good.
23 PARTICIPANT: We're here, yes.
24 CHAIRWOMAN REMPE: Any comments?
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 55 PARTICIPANT: None.
1 CHAIRWOMAN REMPE: Okay, not hearing any 2 comments, I'm going to --
3 (OFF MICROPHONE COMMENTS) 4CHAIRWOMAN REMPE: So, not hearing any, 5 I'm going to close the open session.
6We're going to take a ten minute break.
7 And so, will the first folks, I think it's GEH and the 8 licensee, if they'll be at the front at 10:30 or 9:35, 9 we'll start up with that.
10 And, during this ten minutes, whoever 11 needs to check, make sure that the other folks aren't 12 in the room. Okay?
13 Thank you.
14 (Whereupon, the above-entitled matter went 15 off the record at 9:25 a.m.)
16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433WASHINGTON, D.C. 20005-3701(202) 234-4433 ACRS Power Uprate Subcommittee Brunswick Steam Electric Plant Units 1 & 2Maximum Extended Load Line Limit Analysis Plus (MELLLA+)May 16, 2018 1
IntroductionAndy Hon, PEProject ManagerDivision of Operation Reactor LicensingOffice of Nuclear Reactor Regulation 2
Brunswick MELLLA+ Background
- 20% EPU was approved in 2002 but reduced the licensed flow window at the new licensed full power level from ~24% to 6% total core flow.
- Transitioned to full core AREVA (Framatome) fuel in in 2008/2009 and ATRIUM 10XM full core in 2012/2013.
- MELLLA+ amendment request was submitted 11/9/2016 to increase operational efficiencies and reduce control rod manipulations
-expanding the licensed flow window at full power by ~20% to 85-104.5% total core flow
.*First LAR adopting approved licensing topical reports (LTR) for bothGEH (TRACG) andAREVA ATRIUM TM10XM fuel.
3 LAR Contents
- LAR Body-Introduction, No Significant Hazards Consideration, etc.
-33006-Integrates analyses from GEH, AREVA (Framatone) and others*Disposition of Limitation and Conditions from the LTR SEs.
- Proposed Mark
-ups of license changes
- Supporting documents 4
LAR Major Topics
-similar to other MELLLA+
- T.S. Instrumentation consistent with the LTR and other plants to implement the Detection Suppression Solution
-Confirmation Density (DSS
-CD) for Rx core T
-H stability.
- Operational Restrictions
-prohibit FW Temperature Reduction and Single Loop Operations in MELLLA+ domain.*T.S. Administrative Requirements changes 5
NRC Staff Safety Evaluation
- Similar to other plants' MELLLA+ SE
- Included a summary of RES sensitivity study using TRACE computer modelling of Brunswick MELLLA+ conditions.
- Conducted two audits
-Safety analyses
-July 2017 in Rockville
-Simulator
-February 2018 on site 6
NRC Staff Review Team 7Office of Nuclear Reaction RegulationJ. Borromeo (Lead)M. BiroM. BreachM. ChernoffJ. DozierA. HonJ. HugheyD. KiM. PanickerA. Sallman R. StattelA. SmithM. SmithA. Wysocki (ORNL)Office of Nuclear Regulatory ResearchA. BielenK. GibsonC. GingrichN. HudsonJ. StaudenmeierP. Yarsky AgendaTimePresenter(s)Topic08:30ACRS Openingintroduction08:35NRC staffReview introduction 08:45LicenseeLAR overview 09:15ACRSPublic comments09:20BreakClosed Sessions Below09:30Licensee/FRLARdetails (Framatomeproprietary)10:05Licensee/GEHLAR details (GEH proprietary)10:40NRC staff/ORNLReviewdetails (GEH proprietary)11:15NRC staff/ORNLReviewdetails (Framatomeproprietary)11:45ACRS Discussions and closing remarks12:00Meeting adjourn 8
Technical Staff Management Representative Opening RemarkJen WhitmanActing Branch ChiefReactor System BranchDivision of Safety SystemsOffice of Nuclear Reactor Regulation 9
Brunswick Steam Electric Plant Units 1 and 2 MELLLA+(Maximum Extended Load Line Limit Analysis Plus)Advisory Committee on Reactor Safeguards Subcommittee Meeting BSEP Station Overview and MELLLA+ Project OverviewJeff Nolin -BSEP GM Nuclear Engineering 2
ObjectivesShow Need for MELLLA+Describe Key Aspects and Answer Questions
Demonstrate Readiness Requested Approval supporting 3Q 2018 Implementation 3
BSEP Station OverviewGeneral Electric BWR-4, Mark I ContainmentBegan commercial operation in 1975 (Unit 2) and 1976 (Unit 1), OLTP 2436 MWtEPU (120% OLTP) 2923 MWtfully implemented in 2004 (Unit 1) and 2005 (Unit 2)24 month operating cycleTransitioned to Framatome Fuel in 2008 (U1) and 2009 (U2)Full Core Framatome ATRIUM 10XM FuelLicensed for Increased Core Flow (ICF) (110% at reduced power, 104.5% at CLTP 2923 MWt) 4 MELLLA+ Project Overview -Background and Benefits BackgroundEPU reduced the licensed flow window at rated power from approximately 24% to 6% Total Core Flow. MELLLA+ will expand the licensed flow window at 100% power from 99-104.5% to 85-104.5% Total Core Flow.
5 BenefitsFewer reactivity manipulationsReduction in down-powers Increase station capacity factor Lower Reactor Recirculation Pump (RRP) speeds:increase RRP seal lifetime increase net electric generation due to lower pump power usage MELLLA+ Project Overview -Implementation Progress and PlansPhase 1 (Pre-MELLLA+ Approval) -Plant Modifications and TrainingStandby Liquid Control (SLC) Boron-10 (B10) enrichment upgrade (Completed in 2016 & 2017)APRM EPROM modifications (Completed Mid 2016 on both Units)Plant Operators Introduced to MELLLA+ (2017 Cycle 3 Training)Operators provided with overview of hardware and procedure changes includi ng revised Power/Flow maps along with simulator exercises on new time critical operator action. (2017 Cycle 6 Training)Phase 2 (Post MELLLA+ Approval) -Online Updates and TestingImplement new Technical Specifications, Engineering Changes (ECs), ProceduresSpecial Testing in MELLLA+ Domain including Level Control, Pressure Control, APRM / LPRM / TIP / OPRM data evaluations, Fuel Thermal Margins, RecircSystem Performance, and Moisture CarryoverTransition to Detect & Suppress Solution -Confirmation Density (DSS-CD) Stability Option from Option III 6
MELLLA+ Design and AnalysesJohn Siphers -GM Nuclear Fuel Design 7
MELLLA+ Design and AnalysesThe M+ SAR follows the guidelines contained in the generic MELLLA+ Licensing Topical Report (M+LTR), NEDC-33006P-A.Although the M+LTR is a product of GEH, BSEP utilizes Framatome A10XM fuel. As such, the safety evaluations provided in the M+SAR are the results from both GEH and Framatome.GEH evaluated the overall plant response with M+, ATWS, ATWSI and long term stability solution DSS-CD. GEH has a long experience of modeling BSEP from startup through EPU operation.Framatome performed the remaining typical reload specific fuels analyses. Framatome has been modeling BSEP at EPU conditions since the original ATRIUM 10 transition in 2008 and ATRIUM 10XM since 2011.Consistent with the M+LTR, the evaluation of BSEP Emergency Core Cooling System Net Positive Suction Head demonstrated there is no adverse impact and therefore no change to Containment Accident Pressure credit is warranted with MELLLA+.
8 MELLLA+ Design and Analysis -Vendor Methodology ApplicabilityANP-3108P, Applicability of Framatome BWR Methods to Brunswick Extended Power Flow Operating Domain (EPFOD)No SER restrictions on Framatome methodology that are impacted by EPFODBSEP core and assembly conditions in MELLLA+ are equivalent to core and assembly conditions of other plants for which the methodology was benchmarkedGEH methods are applicable to MELLLA+ and are capable of modeling Framatome fuelTransfer of information from Framatome to GEH allowed explicit modeling of the fuelDuke developed and provided a GEH thermal hydraulic model (ISCOR) for ATRIUM 10XMNRC RAI SRXB-RAI-11 response provided steady-state core simulator comparisons for BSEP MELLLA+ cycle using GEH and Framatome methodsShows GEH methods modeled the A10XM fuel and core characteristics in a satisfactory manner 9
MELLLA+ Design and Analysis -Key GEH Analyses 10GEH analyzed Anticipated Transient Without Scram (ATWS) and ATWS with Instability (ATWSI) scenarios. To address the effect of any uncertainty in GEH modeling A10XM, fuel parameter sensitivities were performed.For ATWSI, additional sensitivities were executed utilizing the homogenous nucleation plus contact temperature model for T minand plant data was utilized to determine an appropriate feedwater temperature reduction rate.
MELLLA+ Design and Analysis -Key MELLLA+ Mitigating Actions 11BSEP will transition from Option III to Detect and Suppress Solution -Confirmation Density (DSS-CD) for thermal hydraulic stability (THI) protection. To set the DSS-CD amplitude discriminator, GEH analyzed BSEP limiting events to demonstrate adequate margins.BSEP increased the Standby Liquid Control System (SLCS) B-10 enrichment (47 to 92% B-10) such that the ATWS heat load to the suppression pool was reduced at 2923 MW th/85% flow when compared to original power 2436 MW th/75% flow conditions (19.8% B-10).2436 MW th/75% Flow peak pool temperature was 189.4 F while EPU/MELLLA+ is 174.0 F.
MELLLA+ Design and Analysis -SLMCPRBSEP does not have any SLMCPR penalties for operation in EPU. No additional SLMCPR penalty is warranted for MELLLA+.The primary concern prompting a penalty is incr eased void fractions due to operation at higher power/flow ratios and lack of operating data to justify current licensing uncertainties.Framatome operating experience includes data that validates use of existing uncertainties with Framatome methods at the BSEP MELLLA+ high power/flow ratios.Therefore, operation in the MELLLA+ region is within the analysis capabilities of Framatome methods and uncertainties and no SLMCPR penalty is warranted.
12 Operator Actions and TrainingMark DeWire -BSEP Assistant OPS Manager -Shift 13 Operator Actions and Training -Overview 14Operator Training was Conducted During Two Cycles of 2017
- Cycle 3 (May/June 2017)
- MELLLA+ Introduction (Classroom Only)
- Cycle 6 ( Oct/Nov 2017)
- MELLLA+ Procedure and Equipment Changes (Classroom)
- MELLLA+ Tech Spec Workbook (Classroom)
- Equipment Demonstrations (Simulator)
- ATWS Proficiency Training (Simulator)
- Operator training included training on:
- MELLLA+ Operating Restrictions, Technical Specification changes, and procedure updates
- Time Critical Operator Action (TCOA) to initiate reactor water level reduction during ATWS within 120 seconds Operator Actions and Training -ATWS Time Critical Operator Actions ATWS TCOA Training
- Operating crews were trained on MELLLA+ ATWS time critical actions
- Three high power ATWS simulator scenarios performed per crew
- February 2018 NRC Audit observed performance of high power ATWS time critical actions 15 Operator Actions and Training -ATWS Time Critical Operator Actions ATWS TCOA timing results:
- 12 operating crews were timed initiating ATWS reactor water level reduction (36 scenarios)
- Average time to initiate reactor water level reduction was 85 seconds
- Standard deviation was 16 seconds
- Operating crews have demonstrated ability to perform TCOA within required times with margin 16 ConclusionsImplementation of MELLLA+ will provide significant benefits:
- Operators will have greater flexibility in using core flow to control reactivity
- Reduces the number of plant downpowersand reactivity manipulations
- Increases the station's capacity factor during the operating cycle Brunswick will be ready to implement the MELLLA+ License Amendment
- Installation of the DSS-CD firmware and SLC enrichment change complete
- Training on MELLLA+ equipment, procedures and required operator actions is complete
- Final PRNM setpointEngineering Change is being finalized
- Implementation test plan establishedRequested Approval supporting 3Q 2018 Implementation 17 Questions 18