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 Session Docket Number: N/A Location: Rockville, Maryland Date: May 16, 2018 Work Order No.: NRC-3732 Pages 1-84 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1
2 3
4 DISCLAIMER 5
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
20 21 22 23 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 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 + + + + +
7 POWER UPRATE SUBCOMMITTEE 8 + + + + +
9 WEDNESDAY 10 MAY 16, 2018 11 + + + + +
12 OPEN SESSION 13 + + + + +
14 ROCKVILLE, MARYLAND 15 + + + + +
16 The Subcommittee met at the Nuclear 17 Regulatory Commission, Two White Flint North, Room 18 T2B1, 11545 Rockville Pike, at 8:30 a.m., Joy L.
19 Rempe, Chairwoman, presiding.
20 COMMITTEE MEMBERS:
21 JOY L. REMPE, Chairwoman 22 RONALD G. BALLINGER, Member 23 MICHAEL L. CORRADINI, Member 24 WALTER L. KIRCHNER, Member 25 JOSE A. MARCH-LEUBA, Member NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
2 1 PETER C. RICCARDELLA, Member 2 GORDON R. SKILLMAN, Member 3
4 DESIGNATED FEDERAL OFFICIAL:
5 WEIDONG WANG 6 ALSO PRESENT:
7 JOSH BORROMEO, NRR 8 RALPH GRUMMER, Framatome 9 DAVID MCBURNEY, Framatome*
10 AHSAN SALLMAN, NRR 11 ROBERT SCHAPP, Framatome*
12 ASHLEY S. SMITH, NRR*
13 DAN TINKLER, Framatome*
14 AARON WYSOCKI, ORNL 15 STEPHEN YODERSMITH, Duke 16 *Present via telephone 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
3 1 CONTENTS 2
3 Opening Remarks . . . . . . . . . . . . . . . . . 4 4
5 Review Introduction . . . . . . . . . . . . . . . 7 6
7 LAR Overview . . . . . . . . . . . . . . . . . . 8 8
9 Public Comments . . . . . . . . . . . . . . . . . 54 10 11 Open Session Closed . . . . . . . . . . . . . . . 55 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
4 1 P-R-O-C-E-E-D-I-N-G-S 2 8:29 a.m.
3 CHAIRWOMAN REMPE: This meeting will now 4 come to order.
5 This is a meeting of the Power Uprate 6 Subcommittee, a Standing Subcommittee of the ACRS.
7 And, I'm Joy Rempe and I Chair this 8 Subcommittee.
9 ACRS members in attendance include Ron 10 Ballinger, Dick Skillman, Mike Corradini, Pete 11 Riccardella, Jose March-Leuba and Walt Kirchner.
12 Weidong Wang is the -- of the ACRS staff 13 is the Designated Federal Official for the this 14 meeting.
15 In this meeting, the Subcommittee will 16 review the safety evaluation for the Brunswick Steam 17 Electric Plant Units 1 and 2 Operating License 18 Amendment Request to allow plant operation in the 19 expanded maximum extended load line limited analysis 20 plus or MELLLA+ domain.
21 As you may recall, this is the fifth plant 22 to submit an LAR for operation in the MELLLA+ domain, 23 but the first to rely on GEH methods with Framatome, 24 formerly AREVA, ATRIUM 10XM fuel.
25 And, in this meeting, we'll hear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
5 1 presentations from the NRC staff and representatives 2 from the licensee, Duke Energy Progress, Incorporated.
3 We did not receive written comments or 4 requests for time to make oral statements from any 5 member of the public regarding today's meeting.
6 Part of the presentations by the licensee 7 and the NRC staff will be closed in order to discuss 8 information that's proprietary to the licensee and its 9 contractors pursuant 5 USC 552(b)(c)(4).
10 Attendance at these portions of the 11 meetings that deals with such information will be 12 limited to the NRC staff and its consultants, Duke 13 Energy Progress, Incorporated and those individuals 14 and organizations who've entered into an appropriate 15 confidentiality agreement with them.
16 So, consequently, we'll need to confirm 17 that we only have eligible observers and participants 18 in the room for the closed portions of this meeting.
19 And, we're going to rely on the staff and Duke Energy 20 to assist us with this when we reach that point during 21 the meeting.
22 The Subcommittee today will gather 23 information, analyze relevant issues and facts and 24 formulate proposed positions and actions as 25 appropriate for deliberations by the Full Committee.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
6 1 The rules for participating in today's 2 meeting have been announced as part of the Notice of 3 this meeting previously published in the Federal 4 Register.
5 A transcript of the meeting is being kept 6 and will be made available in the Federal Register 7 Notice.
8 Therefore, we request that participants in 9 this meeting using the microphones located throughout 10 the meeting room when addressing the Subcommittee 11 meeting.
12 And, the participants should first 13 identify themselves and speak with sufficient clarity 14 and volume so that they may be readily heard.
15 I want to remind everyone, we start --
16 before we start to turn off your noisy little devices 17 and make sure that they don't interrupt us.
18 MEMBER KIRCHNER: Getting feedback from 19 somewhere.
20 CHAIRWOMAN REMPE: Weidong -- he's working 21 on it? Which actually means we need to --
22 (SIMULTANEOUS SPEAKING) 23 CHAIRWOMAN REMPE: Yes, we have to wait 24 until we have a minder, but I'm going to go ahead and 25 say that we're going to soon proceed with the meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
7 1 and, when we do start the meeting, Jose -- Weidong's 2 back. So, are you taking care of the noise? There's 3 some feedback up here.
4 MEMBER KIRCHNER: Someone may have their 5 phone on watching.
6 CHAIRWOMAN REMPE: Maybe --
7 MEMBER MARCH-LEUBA: You think it's the 8 phone line?
9 CHAIRWOMAN REMPE: Yes, why don't you 10 check and see and maybe Theron can help with that.
11 But, when we do start the meeting, I'm 12 going to call on Gregory Suber to start. Okay?
13 Okay, Gregory, go ahead and start.
14 MR. SUBER: Okay, thank you.
15 And, good morning. My name is Gregory 16 Suber and I am a Deputy Director in the Division of 17 Operating Reactor Licensing in the Office of Nuclear 18 Reactor Regulation.
19 It is my pleasure to introduce you to the 20 ACRS Subcommittee, the NRC staff who have been working 21 on the Brunswick MELLLA+ review.
22 So, we have presented a number of extended 23 power uprates for this Subcommittee. This is the 24 first application with the combination of GEH 25 methodology and Framatome fuel.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
8 1 The staff's presentation will highlight 2 this important methodology that increases operational 3 efficiencies, by reducing downpowers and control rod 4 manipulation.
5 During this review, the staff leveraged 6 precedents from previous reviews like Grand Gulf, Nine 7 Mile Point, Monticello and Peach Bottom.
8 Additionally, we have reached out to our 9 colleagues in the Office of Research who our user need 10 request to perform plant-specific independent studies 11 for ATWS events with the NRC's TRACE code and with the 12 latest costing thermal hydraulic test loop data.
13 Their assistance was instrumental in 14 completing this review and we'd like to express our 15 gratitude to Research for their participation.
16 As the staff's presentation will show, 17 special attention was paid to the interface between 18 the key elements and the first review with the GEH 19 methodology and Framatome fume -- fuel -- it's not 20 fume, it's fuel, sorry about that.
21 We have initiated a review of Browns Ferry 22 which utilizes a similar approach.
23 Thank you for your attention and I will 24 turn it over to Mr. Andy Hon.
25 MR. HON: Thank you, Gregory.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
9 1 Good morning, Chairman Rempe and 2 distinguished members of ACRS. I'm Andy Hon. I'm the 3 Project Manager for the Brunswick MELLLA+ application 4 with NRR. And, I'm going to give a quick overview of 5 the project. My colleague, Josh, will be leading the 6 technical discussion later on in the closed session.
7 For Brunswick, the plant was approved for 8 EPU uprate in 2002 to allow them to operate at 9 additional 20 percent above the original license power 10 limit.
11 However, by doing that, they also lost 12 some of their flexibility in their flow window.
13 And, in 2012, in 2013, both units 14 transitioned to AREVA XM11 fuel. And, the MELLLA+
15 amendment was submitted last -- in the -- more than 16 last year, actually, November 2016.
17 The purpose of the increase the 18 operational efficiencies and also reduced need to move 19 the control rod especially near the end of the 20 operating cycle by expanding the license flow window 21 at full power from 80 to 104 percent total core flow.
22 Like Gregory mentioned, this is the first 23 time the application on top the original GEH licensing 24 topical report for the otherwise known as the GEH M+
25 LTR Methodology and also their AREVA Fuel XM11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
10 1 analysis.
2 This is, for us, it's a typical license 3 amendment. The structure of the application as a 4 ususal introduction, no sig, et cetera.
5 But, the core of the application is the M+
6 SAR and also known as the BSEP Safety Analysis Report.
7 If pretty much follow the original GEH 8 MELLLA+ License Topical Report, and also the 9 integrated analyses from both GEH and AREVA, now known 10 as Framatome and others.
11 And then, we also dispositioned other 12 limitations and conditions spelled out in the License 13 Topical Reports.
14 And then, you include the markups. So, 15 this is a typical application of the core is the M+
16 SAR that we reviewed.
17 The major four changes requested are 18 pretty much typical to other MELLLA+.
19 The first is the Instrumentation Technical 20 Specification changes so that it will be consistent 21 with the M+ License Topical Report and mainly for the 22 DSS-CD methodology to control the stability of the 23 core.
24 And then, the next thing is the increase, 25 almost double, the standby liquid control boron NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
11 1 enrichment. Actually, that has been physically 2 implemented at the plant already.
3 The third one is more important, is the 4 operational restrictions that was imposed before --
5 beyond the original EPU. Right now, with a request, 6 it will prohibit feedwater temperature reduction and 7 also single loop operations in the MELLLA+ domain.
8 And, lastly, some administrative changes.
9 Our staff reviewed approaches similar to 10 other MELLLA+ like Gregory mentioned earlier. We 11 addressed each section of the BSEP SAR and all the 12 applicable limitations and conditions spelled out in 13 the License Topical Report.
14 Our team conducted two audits. The first 15 one is a detailed Safety Analysis Audit of both GEH 16 and Framatome. That was done in Rockville here in 17 July last year.
18 And then, earlier this year, we went to 19 the site and audited the simulator and observed the 20 operator actions and we discussed with operators on 21 site.
22 And, our -- we sent the Committee a draft 23 SE about a month ago. At that time, our colleagues at 24 Research are still finishing up their TRACE study.
25 So, at that point, we included a placeholder in our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
12 1 draft report. Later on, we submitted a -- well, we 2 plugged in to summarize the result of the Research 3 TRACE study.
4 And, that, again, we heard yesterday, 5 that's specifically to model the Brunswick 6 configuration. And, that will give the complete 7 result.
8 I need to emphasize that what you saw is 9 kind of rough because we had to include the research 10 as a plug-in. Some of the references may not be 11 correct. The reference 30 in the plug-in actually is 12 pointing to the full report that Dr. Yarsky was 13 talking about yesterday. It hasn't been published 14 yet.
15 So, that is the full report. The research 16 is going to be submitted to the Committee if not have 17 done already. So, there's some disconnects in the 18 reference.
19 So, we are polishing the final SE and 20 there's little -- very little change in the technical 21 substance, especially the area we'll discuss today, 22 mostly just to make sure the references are consistent 23 and also some of the words will be better looking 24 back, you know, say it better this way.
25 But, you know, we did not change the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
13 1 substance. We will be submitting a final polished 2 version through Weidong and send it to the Committee 3 in about a month's time.
4 CHAIRWOMAN REMPE: Okay, just a second, so 5 make sure that I've got it on the record and that I 6 understand.
7 There will be some minor changes including 8 correlation of references or word changes so that 9 plug-in will be incorporated. And, you're going to 10 send us an updated version of the SE with no 11 substantial changes. And, that's going to come in?
12 MR. HON: I'm looking at about three, four 13 weeks time frame.
14 CHAIRWOMAN REMPE: Okay.
15 MR. HON: I want to through a technical 16 editor first so that we have it more polished.
17 CHAIRWOMAN REMPE: And so, it's real 18 important to have it to the Full Committee a month 19 ahead of time.
20 MR. HON: Yes.
21 CHAIRWOMAN REMPE: That's my understanding 22 is -- there were no open items in the SE that you gave 23 us that was a draft, so it looked pretty good.
24 But, we will not see any substantial 25 changes in it --
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
14 1 MR. BORROMEO: So, this is Josh Borromeo 2 from the staff.
3 There is one change that you will see that 4 is semi-substantial. It's Limitation Condition 9.23 5 which is the Item Value Tracking that is supposed to 6 be submitted after the first MELLLA+ application.
7 GE has done that previously, so we said 8 that wasn't applicable for GE on MELLLA+ applications.
9 AREVA and Monticello came in like two years ago with 10 their EFW on MELLLA+ application.
11 Because of the lower power density of that 12 plant, we said it wasn't necessary for them to provide 13 us that -- all that data.
14 For Brunswick, however, since they're a 15 higher power density, we are going to be requesting 16 that data.
17 Right now, the SE says it's not applicable 18 but we have updated that and that's consistent with 19 what the licensee committed in a supplement to their 20 Safety Evaluation -- to their License Amendment 21 Request.
22 CHAIRWOMAN REMPE: Okay.
23 MEMBER MARCH-LEUBA: So that's going to be 24 a licensing commitment by the licensee or is it going 25 to be a limitation on the SER?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
15 1 MR. BORROMEO: It's applying with the 2 limitation and condition. Right now, they said this 3 -- originally, when they came in, they said this is 4 applicable. We did a non-accept with an opportunity 5 to supplement where we said, well, I think, you know 6 --
7 MEMBER MARCH-LEUBA: It's up to you, but 8 typically --
9 MR. BORROMEO: Yes.
10 MEMBER MARCH-LEUBA: -- put it in the 11 licensing conditions --
12 MR. BORROMEO: Yes, it will be 13 enforceable.
14 MEMBER MARCH-LEUBA: Yes, but this -- it's 15 unfortunate but because of the sunset provision that 16 the moment you send it back, this doesn't apply 17 anymore. It's kind of weird to do it that way.
18 MR. BORROMEO: So, that's the only 19 substantial difference that you'll see.
20 CHAIRWOMAN REMPE: I'm going to really 21 emphasize, again, we have told you a lot, so we have 22 some flexibility.
23 MR. BORROMEO: Right.
24 CHAIRWOMAN REMPE: So, this isn't the June 25 meeting or doing this letter and I didn't know about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
16 1 this.
2 MR. BORROMEO: Yes, we identified this 3 maybe a week or so after we sent the SE to --
4 CHAIRWOMAN REMPE: Okay. So, really try 5 hard to get this to us by the first of June, please.
6 MR. BORROMEO: Yes, absolutely. Although, 7 all the technical updates are -- I mean, the update is 8 already incorporated. It's --
9 CHAIRWOMAN REMPE: Okay. Again, I don't 10 think we care if it's gone through tech editing.
11 MR. BORROMEO: Okay.
12 CHAIRWOMAN REMPE: But, bet something to 13 ACRS that's not going to change a month in advance.
14 Okay?
15 MR. HON: Thank you.
16 CHAIRWOMAN REMPE: Thank you.
17 MR. HON: All right, we'll try to send you 18 sooner.
19 CHAIRWOMAN REMPE: Okay, thank you.
20 MR. HON: Like Josh said, we're not making 21 any substantial changes, just polishing it. Thank 22 you.
23 CHAIRWOMAN REMPE: Okay, thank you for 24 getting that on the record here.
25 MR. HON: Again, this is a very involved NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
17 1 view. We have -- I want to acknowledge the review 2 team on the slide here, especially, of course, the 3 team leader and the support for my research that Dr.
4 Yarsky presented yesterday.
5 Today's presentation agenda is the 6 following. Because this is a combination of GEH and 7 Framatome technology, due to commercial agreement 8 limitations, there's not a full exchange of 9 information between the two vendors.
10 So, we want to be very careful to have the 11 closed sessions that are only applicable to one 12 vendor. So, we structured the presentation as 13 follows.
14 Following my presentation, licensee will 15 come and give an overview, that will be the public 16 session.
17 And then, after that, we take a break and 18 we'll excuse I think people who don't have access to 19 the GEH proprietary information and the licensee will 20 present that part after that.
21 The staff will present our result of the 22 review and then we'll swap people out. The only 23 people who have access to Framatome proprietary 24 information will stay at 10:40 or so and present the 25 -- I believe the aspect of the application.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
18 1 Likewise, the staff will immediately 2 follow that and present our results.
3 So, if it's okay with members of the 4 Committee, we'll follow that.
5 Again, this is a -- what I call an error 6 likely situation for spills so I hope that won't 7 happen today.
8 Thank you for your patience with the 9 arrangement.
10 With that, I'd like introduce Jane 11 Marshall which is our Deputy Director for the 12 Technical Division.
13 Jane?
14 MS. MARSHALL: As Andy said, my name is 15 Jane Marshall and I'm the Deputy Director for the 16 Division of Safety Systems in the Office of Nuclear 17 Reactor Regulation.
18 Today, we're presenting the staff review 19 of Brunswick Unit 1 and 2 MELLLA+ License Amendment 20 review.
21 The primary focus of NRR's review for this 22 application were the new approaches in areas that have 23 been historically challenging in these reviews.
24 To ensure consistency among reviews, the 25 staff used previous MELLLA+ reviews as well as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
19 1 relevant prior Tropical Report reviews.
2 While this review contains several new 3 items, I'd like to highlight the main technical 4 challenge for this review was the interface between 5 GEH methods and the Framatome fuel.
6 To support the NRR staff conclusions, 7 particularly the anticipated transient without SCRAM 8 instability, or ATWS-I calculations, the staff used 9 TRAC RELAP Advanced Computation Engine, or TRACE code, 10 confirmatory results which were completed by the 11 Office of Research and presented to the ACRS Thermal 12 Hydraulic Subcommittee yesterday.
13 These confirmatory results are intended to 14 help gain efficiency in the staff's review and help 15 flesh out any unknown issues.
16 In addition to the Office of Research 17 supporting the review, other offices from NRC 18 supported this review, many staff across NRR and we 19 contracted with Oak Ridge National Labs.
20 Thank you, and I'll now turn it over to 21 Josh Borromeo.
22 (OFF MICROPHONE COMMENTS) 23 MS. MARSHALL: Oh, licensee, I'm sorry.
24 CHAIRWOMAN REMPE: So, let's --
25 MS. MARSHALL: Turn it over to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
20 1 licensee.
2 CHAIRWOMAN REMPE: -- go ahead and do that 3 since we had a tight schedule today. Okay.
4 Andy, can you hit escape again? Yes.
5 MR. NOLIN: We're good? We're good to go.
6 CHAIRWOMAN REMPE: Okay.
7 MR. NOLIN: Good morning. I'd like to 8 thank you for having Duke Energy here for the 9 discussion on MELLLA+.
10 I'm Jeff Nolin, I'm the General Manager of 11 Engineering at Brunswick.
12 We'll be presenting a few objectives for 13 the discussion today.
14 First, to show the need for MELLLA+, why 15 we're submitting the License Amendment, demonstrating 16 the key aspects of our request and demonstrating 17 readiness.
18 So, there was a discussion already today 19 about the key differences between integration of 20 AREVA, now Framatome, fuel and the GE methodology, so 21 demonstrating our readiness relative to the 22 integration of that aspect.
23 And, the request for submitting the 24 approval, we're looking for a third quarter 2018 25 implementation.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
21 1 The reasons for that are Unit 2 is -- will 2 be approaching end of life in the current cycle. We 3 have a March 2019 refueling outage on Unit 2. So, 4 Unit 2 will be approaching a condition with final 5 feedwater temperature reduction in December. We would 6 like to implement in the fall of 2018.
7 We would like -- Duke Energy would like to 8 implement both units at the same time from an 9 integration of procedures, operator training, 10 consistency of maintaining the units.
11 MEMBER MARCH-LEUBA: So, then is Unit 1 12 already loaded? The core welding supports MELLLA+?
13 MR. NOLIN: Yes. So, Unit 1 and Unit 2, 14 in a couple of slides --
15 MEMBER MARCH-LEUBA: Okay, keep going.
16 MR. NOLIN: Perhaps the next slide, I get 17 to that exact question.
18 So, anyway, our intent is to integrate 19 both units at the same time and support for that 20 relative to the timing of the third quarter of 2018 21 because of the Unit 2 fuel cycle.
22 Next slide?
23 So, Brunswick Nuclear Plant, Brunswick 24 Steam Electric Plant is a two unit GE BWR-4 design.
25 We started commercial operation, Unit 2 was the lead NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
22 1 unit in 1975, Unit 1 followed shortly after.
2 So, we have 42 and 43 years of operating 3 experience at Brunswick, so we are in the license 4 renewal period of extended operation for both units at 5 Brunswick.
6 Brunswick did do an extended power uprate 7 to 2923 megawatts thermal and we have been operating 8 in with EPU conditions for 13, 14 years now.
9 So, many of the prior license amendments 10 relative to MELLLA+ were integrated with the power 11 uprate. Brunswick has been operating with EPU for 12 more than a decade now on each unit.
13 And so, this license amendment is strictly 14 for MELLLA+, not the power uprate.
15 MEMBER SKILLMAN: Jeff, were you always 16 24-month operating cycle or were you 18 originally and 17 up bumped it 24? Mark, do I need to defer that to 18 you?
19 MR. NOLIN: Eighteen originally, we came 20 up to 24 months.
21 MEMBER MARCH-LEUBA: Mark, turn your 22 microphone on when you speak.
23 MR. DEWIRE: It is on.
24 MEMBER MARCH-LEUBA: Oh, it is on?
25 MR. NOLIN: No, no.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
23 1 MEMBER MARCH-LEUBA: He was looking maybe 2 --
3 CHAIRWOMAN REMPE: What's the power 4 density of Brunswick? The Brunswick plants?
5 MR. YODERSMITH: We have a backup slide.
6 CHAIRWOMAN REMPE: I looked for it on the 7 backup slide, I didn't see the power density like 8 kilowatts per liter.
9 MR. YODERSMITH: Give me one second.
10 MR. BORROMEO: I think -- this is Josh 11 Borromeo --
12 MR. YODERSMITH: Page 20.
13 MR. BORROMEO: -- I think they're around 14 59 kilowatts per liter.
15 CHAIRWOMAN REMPE: Okay. It'd be good to 16 confirm that and you don't have to do it now, but --
17 MR. YODERSMITH: We -- sorry, we present 18 it in kilowatts per foot here.
19 CHAIRWOMAN REMPE: Okay. But, you think 20 it's 59 kilowatts per liter?
21 MR. BORROMEO: It was 4.9 kilowatts per 22 foot and here's how we stack up against the previous 23 submittals.
24 CHAIRWOMAN REMPE: Okay. So, again, I'd 25 like to know what it is kilowatts per liter. And, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
24 1 I've been told by the staff it's 59. Could you get 2 that confirmed for me today?
3 MR. YODERSMITH: Sure.
4 CHAIRWOMAN REMPE: Thank you.
5 MR. NOLIN: So, we are operating on a 24-6 month fuel cycle. So, we have a refueling each March 7 on alternating units.
8 We did transition to Framatome fuel in 9 2008 in Unit 1, 2009 in Unit 2. So, we have 10 approximately a decade of operating experience with 11 Framatome fuel.
12 We are initially ATRIUM 10. We are a full 13 core ATRIUM 10XM fuel now. And, our licensed core 14 flow is 104.5 percent as was previously mentioned at 15 full power.
16 The project overview, the reason for the 17 submittal is to expand the flow window at full power.
18 The benefits of that is that we are required with the 19 current flow window to have multiple reactivity 20 manipulations for sequence exchanges.
21 So, the MELLLA+ will allow us to reduce 22 the number of downpowers, the number of reactivity 23 manipulations of the plant.
24 MEMBER MARCH-LEUBA: Jeff, on the top of 25 your head, how often do you change route, do you move NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
25 1 those today?
2 MR. NOLIN: There's sequence exchange 3 quarterly.
4 MR. THOMAS: Sequence exchanges are about 5 every 2500 megawatt days per metric ton. And then, as 6 you get into the latter half of the cycle, maybe two-7 thirds, we sometimes have to do them weekly to stay 8 within our flow window.
9 Essentially, it's the hot access 10 reactivity begins to drop off at the end of cycle.
11 MEMBER MARCH-LEUBA: So, about once a 12 week?
13 MR. THOMAS: Yes.
14 MR. YODERSMITH: Towards the end of cycle, 15 that's about what it is, about once a week, maybe --
16 MR. THOMAS: Yes, maybe two-thirds of the 17 way through the cycle.
18 MEMBER MARCH-LEUBA: So, MELLLA+ would 19 allow you to extend that probably for a month?
20 MR. THOMAS: Yes.
21 MR. YODERSMITH: Correct, at least.
22 MEMBER MARCH-LEUBA: It's a big, big 23 improvement.
24 MR. YODERSMITH: Yes.
25 MR. NOLIN: So, in addition to that, it'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
26 1 help with recirc pumps, the operation of the recirc 2 pump seals has been a reliability issue for many 3 plants. And so, being able to expand the flow window 4 will also help improve recirc pump seal reliability.
5 So, it has some benefits beyond the 6 reactivity manipulations as well.
7 CHAIRWOMAN REMPE: So, I don't recall 8 other MELLLA+ applicants coming in and saying this 9 about the pump seals. And, is there evidence to say 10 yes, that's occurred with the ones that have gone in 11 to MELLLA+? Or have they not had much experience or 12 is this a well-substantiated issue?
13 MEMBER MARCH-LEUBA: I believe the issue 14 is, I mean, because they cannot go below 99 percent 15 flow, they have to be running at full power all the 16 time. The maximum you can crank out of them.
17 When they go to MELLLA+, they can be 18 running at 80 percent of it.
19 CHAIRWOMAN REMPE: But, is there evidence 20 to support this claim that it's really helping with 21 seals? I just -- I've not seen any other applicant 22 come in with that.
23 MR. THOMAS: I think it's the opposite.
24 I think it's the evidence is that the staying 25 consistently at the higher flows is adverse to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
27 1 seals.
2 MR. NOLIN: We've seen since -- I 3 mentioned earlier that we have approximately a decade 4 at post-EPU. And, our experience was that the recirc 5 pump seals have been more challenged by operating at 6 a 100 percent flow consistently.
7 So that --
8 CHAIRWOMAN REMPE: Well, in the recent 9 years, you've seen --
10 MR. NOLIN: -- experience at Brunswick.
11 MR. DEWIRE: Yes.
12 CHAIRWOMAN REMPE: Have you had to replace 13 them?
14 MR. NOLIN: We're doing a design change to 15 the seals to support the sustained operation at high 16 flow. So, we're doing other things to improve recirc 17 pump reliability. But this will also help it.
18 CHAIRWOMAN REMPE: Okay, thank you.
19 MR. NOLIN: So, a prior question about 20 readiness for the station for implementation on each 21 unit. So, we've -- the Phase I prior to 22 implementation, plant modifications and training, we 23 did do the upgrade of our standby liquid control 24 system.
25 We increased the enrichment from 47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
28 1 percent to 92 percent on each unit. And, that is 2 complete.
3 We did the APRM EPROM modifications a 4 couple years ago in each unit. So, the physical 5 changes with the power range monitors have been 6 completed.
7 And, Mark DeWire, our senior license 8 holder will also discuss the operator training. So, 9 we've been through a couple of cycles of operator 10 training on MELLLA+ for readiness.
11 The implementation phase, we'll implement 12 --
13 MEMBER MARCH-LEUBA: Sorry, go back to 14 that. You do parallel training because you have to 15 train your operators to what is today applicable?
16 But then, on Friday afternoon you talk 17 about what you'll be doing next year?
18 MR. NOLIN: So, we have -- Mark will get 19 into that in much more detail.
20 MR. DEWIRE: Yes, if you can just hold 21 that question until I get up with my presentation, 22 then I'll address your question.
23 MEMBER MARCH-LEUBA: We'll wait.
24 MR. DEWIRE: Thank you, sir.
25 MR. NOLIN: So, the implementation phase NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
29 1 will consist of implementing the tech specs procedure 2 changes. We'll also go through a testing phase in the 3 MELLLA+ domain which will include level and pressure 4 perturbations in a series of five test conditions.
5 And then, the implementation of the detect 6 and suppress solution for the MELLLA+.
7 So, the plant is physically ready and the 8 implementation will be integrated on both units at the 9 same time.
10 With that, I'd like to turn it over to 11 Roger Thomas, he's our Manager in Nuclear Fuels.
12 MR. THOMAS: Thanks and, as Jeff said, 13 John Siphers was originally scheduled to give this 14 presentation, but because of the weather, his flight 15 was cancelled, so I am acting as his understudy today.
16 I am Manager of Brunswick Nuclear Design 17 which is a unit within John's group.
18 So, the focus of my part of the 19 presentation is something that's already been touched 20 on, is some of the unique aspects of our LAR compared 21 to some of the previous ones.
22 We, of course, did follow the generic 23 MELLLA+ LTR, but there was a division of labor between 24 Framatome and GE that will be described in greater 25 detail in some of the proprietary presentations.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
30 1 But, briefly, GEH, their division of labor 2 was to evaluate the overall plant response. They 3 focused on ATWS, ATWSI, long-term stability and DSS-4 CD.
5 Framatome focused on those areas of the 6 analysis specific mostly to the fuels, the kinds of 7 analysis that you would typically see on a reload or 8 cycle specific basis.
9 As also previously been mentioned that GEH 10 and Framatome both have long and extensive experience 11 modeling the Brunswick plant.
12 GE, from initial startup, through extended 13 power operation and beyond, all the way to 2008 at 14 which time we transitioned to ATRIUM 10 fuel and in 15 2008. And then, later, in 2011, to ATRIUM 10XM.
16 Framatome has modeled the core and the 17 plant through that period all at extended power 18 uprate.
19 Another thing that might be unique is that 20 the cap credit, because we have had extended power 21 uprate for some time, we are proposing no changes to 22 our cap credit that we currently have.
23 MELLLA+ doesn't impact cap credit and the 24 NRC has a slide where they go into greater detail on 25 that. So, we're standing pat on that.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
31 1 All right, so, looking at vendor 2 methodology applicability, that's also something 3 that's been touched on. It's something that we were 4 challenged on early on.
5 Specifically, the challenge was, how --
6 are GE methods applicable to AREVA fuel, excuse me, 7 Framatome fuel? And, whether or not Framatome methods 8 are applicable in the expanded MELLLA+ flow regime?
9 So, starting with Framatome, there are no 10 SER restrictions on Framatome methodology that are 11 impacted by MELLLA+.
12 And, the Brunswick core and assembly 13 conditions that we will have in MELLLA+ are equivalent 14 to core and assembly conditions of other plants for 15 which Framatome's methodology was benchmarked.
16 And, of course, they elaborate on that in 17 the report that you see there in the first bullet.
18 GEH methods are applicable to MELLLA+, of 19 course, and they are capable of modeling Framatome 20 fuel.
21 There was an extensive transfer of 22 information about the characteristics and the 23 dimensions of the fuel from Framatome to GEH. GEH 24 explicitly modeled the ATRIUM 10XM fuel.
25 Duke had an interface role there where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
32 1 what we did is we developed a GEH thermal hydraulic 2 model for them in ISCOR. We translated the X-code 3 results. And, this is something we have done many 4 times in the past for other reasons. So, it was just 5 a matter of going a different direction.
6 And, in response to some RAIs, we also 7 provided steady state core simulator comparisons 8 between Framatome and GE and they showed excellent 9 agreement and excellent results.
10 And, they prove, for the purposes of the 11 work that GE is doing, that they could satisfactorily 12 model the ATRIUM, or excuse me, yes, the ATRIUM 10XM 13 fuel.
14 MEMBER MARCH-LEUBA: Roger, did I hear you 15 correctly, instead of passing -- you passing the 16 Framatome, call it equivalent diameter from the fuel 17 to GE, you actually rolled the ISCOR model for them?
18 MR. THOMAS: We created an ISCOR model for 19 them. And, it was the equivalent to Framatome's X-20 cover modeling.
21 MEMBER MARCH-LEUBA: So, instead of 22 parsing the dimensions of the fuel --
23 MR. THOMAS: No, no, no.
24 MEMBER MARCH-LEUBA: -- you created --
25 MR. THOMAS: No, fuel dimensions were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
33 1 passed.
2 CHAIRWOMAN REMPE: So, in some of the 3 information I read, some dimensions might have been 4 passed, but they basically said, we gave -- GEH gave 5 a range of conditions or parameters and sent it over 6 the fence. And, AREVA or Framatome said, yes, that'll 7 bound it.
8 So, what exactly -- and maybe we could get 9 into the proprietary --
10 MR. THOMAS: That was -- yes, that's --
11 CHAIRWOMAN REMPE: -- and discussion, too.
12 MR. THOMAS: Yes, the details of that are 13 proprietary, but the concept is on, if not the next 14 slide, the slide after that.
15 CHAIRWOMAN REMPE: Okay.
16 MR. THOMAS: Okay, so, GEH key analysis, 17 so, this is where we speak to this a little bit.
18 So, in the previous slide, I mentioned 19 that GEH analyzed anticipated transient without SCRAM 20 and ATWS with instability.
21 The uncertainties and the ranges that you 22 mentioned are what AREVA provided were nominal 23 dimensions, nominal and so, GE identified to AREVA 24 what the important sensitive parameters would be in 25 their analyses.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
34 1 And, they said, can you give us the 2 uncertainties for these?
3 That's a very sensitive thing, so, what 4 they did is they bounded the ranges. I think it was 5 kind of like, you know, The Price is Right game, 6 higher, lower, higher, lower, ding, ding, ding, ding.
7 Okay, that'll bound it. All right? That's kind of 8 how it went.
9 And, Framatome will have to speak to how 10 those ranges actually bound their uncertainties. All 11 right?
12 Additionally, coming out of the LAR audit 13 that we had last July, GEH uses a different Tmin 14 correlation, I guess you would call it. And, or they 15 have a preferred one, but the NRC requested that they 16 provide -- they do additional sensitivities using the 17 homogeneous nucleation plus contact temperature model, 18 which I have to read to say that.
19 But, those were also provided in a 20 response to an LAR. And, I believe the key conclusion 21 here is, even with all of those parameters and 22 sensitivity studies applied, the results were still 23 favorable overall to the result and to support of the 24 MELLLA+ LAR.
25 So, again, there's a lot of proprietary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
35 1 information supporting those three bullets there, and 2 it will be addressed in some of the follow on.
3 All right, one of the things that we also 4 did, some of this has also been touched on a little 5 bit, is mitigating actions.
6 Clearly, MELLLA+ is a more challenging 7 area of operation for the plant. So, we wanted to 8 talk what actions made sense to sort of soften that 9 impact.
10 The first is the adoption of the Detect 11 and Suppress Solution Confirmation Density. We're 12 currently in Option 3 for non-MELLLA+ operation. We 13 will be transitioning to the DSS-CD for this which 14 adds the additional layer of checking and that 15 additional algorithms associated with that.
16 The second thing we did which Jeff also 17 touched on was we have already increased our SLCS B-10 18 enrichment from 46 to 92 or greater. And, what this 19 did for us is, it actually reduced the heat load and 20 suppression pool for the ATWS analyses in MELLLA+
21 relative to our original license condition.
22 So, in the box at the bottom, we compared 23 the two at 2436 and 75 percent flow which is several 24 power uprates ago that the result was 189 degrees.
25 And, you can see that there's an approximately 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
36 1 degree improvement there which is a quantifiable 2 increase in the safety margin that we have for the 3 plant. So, that was a very positive result.
4 MEMBER MARCH-LEUBA: The other licensees 5 -- previous licensees have opted also to a speed up 6 their operation -- operator actions from 120 to 90 7 seconds, the water level reduction.
8 However, you decided to keep it at 120.
9 MR. THOMAS: Yes.
10 MEMBER MARCH-LEUBA: And, yesterday in 11 open session, we were told that in reality you're 12 trained to 96 seconds.
13 MR. THOMAS: That's right.
14 MEMBER MARCH-LEUBA: Which is 80 percent 15 of 120.
16 CHAIRWOMAN REMPE: So, there's some slides 17 coming up in this open session on this, so because I'm 18 going to try and keep us on schedule, I'd like to let 19 them have the opportunity to answer that question 20 later.
21 MR. THOMAS: Yes, that --
22 CHAIRWOMAN REMPE: I think it fits in a 23 better slide.
24 MR. THOMAS: Yes.
25 CHAIRWOMAN REMPE: Okay? Sorry.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
37 1 MR. THOMAS: That's okay.
2 Okay, and the final topic that I have is 3 Safety Limit MCPR. Unlike some of the previous 4 MELLLA+ LARs, we are proposing that there's no penalty 5 required for the safety limit MCPR in MELLLA+.
6 Framatome has a great deal of information 7 in their proprietary session that will support this.
8 But, what I can say is the primary concern that 9 prompted the previous penalties was the increased void 10 fractions and the concern that, as you move to those 11 increased void fractions you would see increases in 12 your uncertainties.
13 And, there was a lack of operating data to 14 justify those uncertainties.
15 Framatome will present operating 16 experience that includes data in those ranges that 17 validates the use of their existing uncertainties.
18 And, we will also present some Brunswick 19 specific information that shows that as we increase --
20 as we go along the line of increasing void fractions, 21 we do not see a negative trend in our applied 22 uncertainties. So, both of those will be presented in 23 the Framatome session.
24 So, the conclusion of that would be that 25 operation in the MELLLA+ region is within the analysis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
38 1 capabilities of Framatome methods and uncertainties 2 and so, no safety limit penalty is warranted.
3 So, with that, I'll turn it over to Mark 4 DeWire to address operator actions and training.
5 MR. DEWIRE: Good morning, I am Mark 6 DeWire. I'm Assistant Ops Manager for the Shift at 7 the Brunswick Nuclear Power Plant.
8 We're going to talk about operator 9 training. It was conducted in two cycles over the 10 year 2017 and it began in the spring, May/June time 11 frame where we started with just classroom discussion 12 which included a high level overview of the changes 13 that were coming and what we are intending to 14 accomplish.
15 Came back around in 2017 in the fall with 16 more classroom training which was on tech spec 17 changes, procedure updates and included a tech spec 18 workbook to allow the senior licensed operators to 19 work through that and understand the tech spec 20 changes.
21 And then, we also went into the simulator, 22 we did the hands on training, did demonstrations and 23 the hands on training where we focused more on the 24 time critical operator action of 120 seconds for 25 initiating water level reduction which get into your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
39 1 question.
2 So, the ATWS training's not a new concept.
3 We have been training -- always been training on ATWS.
4 The 120 seconds, we had started training to that a 5 year and a half to two years ago when we first knew 6 that MELLLA+ was coming our way.
7 So, we worked our way through that and we 8 designated it as a time critical operator action.
9 So, I'll keep going on to the next slides.
10 So, the operating crews were trained on 11 the time critical actions, as I mentioned. Each crew 12 was given three high power ATWS simulator scenarios to 13 be performed. And then, as mentioned earlier, in 14 February 2018, the NRC came down and did an audit and 15 observed the performance of the high power ATWS time 16 critical actions with no comments.
17 Twelve operating crews that --
18 MEMBER SKILLMAN: Can you back a slide, 19 please?
20 MR. DEWIRE: Yes, sir.
21 MEMBER SKILLMAN: So, the NRC comes down 22 and takes a look. Are the crews informed when the 23 event is going to occur or how to ensure that the crew 24 really knows when to take that action and that they're 25 not pre-staged waiting like a vulture to meet their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
40 1 120 seconds.
2 MR. DEWIRE: Right. So, that's a good 3 question.
4 So, the crews know there's an ATWS coming, 5 they're in there for that specific event, so you can't 6 hide that from them.
7 However, the plant is put through a 8 transient and then they worked their way into the 9 ATWS. So, they're not standing by with people at the 10 ready at various locations. They're dealing with a 11 simulator scenario and they're working their way in to 12 ultimately the ATWS actions on it.
13 So, I don't have people preprogrammed 14 standing over ready to go.
15 MEMBER SKILLMAN: That's probably as good 16 as you can do. So, thank you.
17 MR. DEWIRE: As mentioned, 12 operating 18 crews at three scenarios, so 36 total scenarios. The 19 average time was 85 seconds. The standard deviation 20 was 16 seconds. And, we were able to successfully 21 demonstrate that we could perform the time critical 22 operator actions within the 120 seconds and with 23 margin.
24 CHAIRWOMAN REMPE: Okay, so now I want to 25 stop and have you answer Jose's question about why not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
41 1 go to 96 seconds.
2 I also am curious, what was the longest 3 time someone took?
4 MR. DEWIRE: Hundred and twenty-one 5 seconds, one operating crew.
6 CHAIRWOMAN REMPE: So, that's above the 96 7 metric we were told about yesterday.
8 MEMBER MARCH-LEUBA: How about the 120 --
9 so, if you do 121, that will fail, right?
10 MR. DEWIRE: That's correct.
11 MEMBER MARCH-LEUBA: They have to retake 12 it?
13 MR. DESIRE: That's correct. So, they 14 fail the time critical operator action. So, we go 15 into the training process and they get remediated and 16 they do it again.
17 MEMBER MARCH-LEUBA: Remedial training, we 18 have people going through that.
19 MR. DEWIRE: So, the 120 -- so, the 85 20 seconds, when we get back to the 120 second question, 21 we did benchmarking and we brought in and we actually 22 changed the initial operator actions for reactor 23 operator.
24 We gave them a hard car where they could 25 secure the recirc pumps and they could initiate SLC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
42 1 based on their actions and reading the control board.
2 When we looked at other ways to get 3 leveled down rapidly required just to the design of 4 our plant, pretty significant engineering change to 5 get the level to come down with like the push of a 6 button or something like that. It takes operator 7 action.
8 And, when you incorporate INPO's IER 17-5 9 with leadership trades and maintaining command and 10 control, we felt prudent to maintain command and 11 control with the control room supervisor directing the 12 initiation of the reactor wide level reduction.
13 So, given that philosophy, we were able to 14 demonstrate right around 85 seconds is where we come 15 in with that time critical. Maintaining the command 16 and control yet allowing the operator to take actions.
17 MEMBER MARCH-LEUBA: So, you're saying the 18 design of the control -- the pump control requires you 19 to roll them back slowly? You cannot just read them?
20 MR. DEWIRE: They do. They run -- they 21 get run back on the SCRAM signal from the reactor 22 protection system and then --
23 MEMBER MARCH-LEUBA: No, I'm talking --
24 sorry, I was talking about -- I said pumps, I meant 25 feedwater pumps.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
43 1 MR. DEWIRE: The feedwater pumps are 2 directed from -- so, the order to terminate and 3 prevent will come from the control room supervisor 4 then the reactor operator would take action, it would 5 be another hard car.
6 MEMBER MARCH-LEUBA: How long does it take 7 to terminate and prevent?
8 MR. DEWIRE: Eighty-five seconds.
9 MEMBER MARCH-LEUBA: No, no, I mean, it 10 probably takes 80 seconds to start --
11 MR. DEWIRE: All right, so the valve 12 strokes on the feedwater systems are probably around 13 80 seconds for them to complete total stroking. But, 14 the one feed pump is tripped off, the other feed pump 15 is run down, it's discharged pressure so it cannot 16 inject.
17 So, it's terminated that way and you're 18 waiting on the valves for the prevention.
19 MEMBER MARCH-LEUBA: Okay, thank you.
20 MEMBER SKILLMAN: How significant were the 21 changes to the operating procedures to accommodate the 22 successful outcome here?
23 MR. DEWIRE: Not very, the only --
24 MEMBER SKILLMAN: Just a couple of --
25 MR. DEWIRE: Yes, the only thing we really NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
44 1 added was we allowed the RO more flexibility to take 2 action at the control board with the initiation of SOC 3 and the tripping of the recirc pumps.
4 MEMBER SKILLMAN: Okay, thank you.
5 CHAIRWOMAN REMPE: So, is this the only 6 time critical operator action associated with MELLLA+
7 or does the initiation of like SLC injection --
8 MR. DEWIRE: SLC injection of less than 9 five minutes is a time sensitive with -- time 10 sensitive operator action.
11 CHAIRWOMAN REMPE: But, it's not time 12 critical, it's a different --
13 MR. DEWIRE: Right, it's a different 14 category.
15 CHAIRWOMAN REMPE: -- category and how you 16 train for it and treat it?
17 MR. DEWIRE: Right. But, again, we added 18 that to the hard car so that was one of the immediate 19 actions that the rad dropper is going to take.
20 MEMBER MARCH-LEUBA: Plus, in my 21 experience the SLC -- the boron injection always 22 happens before it's needed because the EOP's still 23 your -- if you think you're going to get there, push 24 the button, is that correct?
25 MR. DEWIRE: Right. So, he's going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
45 1 look at power level and if it's greater than a ceratin 2 percent, he's going to initiate SLC.
3 MEMBER MARCH-LEUBA: And then --
4 MR. DEWIRE: But, that boron enrichment, 5 I've been there since '95, licensed since 2000. It is 6 a significant difference with that enriched boron and 7 how fast power comes down.
8 MEMBER MARCH-LEUBA: Yes, but what -- I 9 was trying to say is that the boron injection time, 10 you can call it critical, you never -- your crews are 11 never going to fail it, right? Is that your 12 experience?
13 MR. DEWIRE: Right, it's pretty quick 14 right off the bat.
15 CHAIRWOMAN REMPE: Are we good to go on 16 guys?
17 MR. DEWIRE: All right.
18 CHAIRWOMAN REMPE: Thank you.
19 MR. DEWIRE: Yes, ma'am.
20 So, in conclusion, implementation of the 21 MELLLA+, we're talking about the benefits, greater 22 flexibility in using core flow to control reactivity.
23 That's near and dear to my heart as an operator with 24 reactivity manipulation in a cycle.
25 Reduces the number of plant downpowers, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
46 1 reactivity manipulations and increases the station's 2 capacity factor for the operating cycle.
3 We'll be ready to implement MELLLA+
4 License Amendment, we talked about the installation of 5 the hardware changes with the DSS-CD firmware and the 6 SLC enrichment.
7 We've completed training on MELLLA+, the 8 procedures and required operator actions.
9 The final PRNM nuclear monitoring setpoint 10 engineering change is being finalized and 11 implementation of a test plan has also been 12 established.
13 And, with all that, we're -- as mentioned, 14 we're requesting approval for the third quarter of 15 2018 implementation.
16 MEMBER MARCH-LEUBA: So, go to MELLLA+,
17 you don't have to change any hardware other than 18 EPROMs and things like that?
19 MR. DEWIRE: That's correct. It's already 20 installed, it's a matter of turning it on.
21 MEMBER MARCH-LEUBA: Good, perfect.
22 CHAIRWOMAN REMPE: So, despite the fact 23 we're a little bit behind, there's a slide 22 that you 24 prepared and I just would like you to -- it's a backup 25 slide and I was looking through your backup slides NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
47 1 before the meeting -- that one. Could you talk a 2 little bit about that one, please?
3 MR. YODERSMITH: Yes, so this is our -- my 4 name is Stephen Yodersmith with Duke Energy.
5 So, this is our test conditions that we'll 6 be walking through during our test window. So, we'll 7 start at test condition A and that'll be where we 8 start our testing window.
9 And then, we'll come down to each of these 10 test points, B, C, D, E and the various testing at 11 those points to collect data for MELLLA+ transition.
12 And then, after --
13 MEMBER MARCH-LEUBA: Stephen, those test 14 points, is that when you're testing your control 15 systems, I think?
16 MR. YODERSMITH: That's correct.
17 So, yes, let me get to --
18 MEMBER MARCH-LEUBA: You'll be performing 19 perturbations on your systems, CD control work fine?
20 MR. YODERSMITH: So, we'll be performing 21 perturbations on the control systems, pressure 22 testing. We'll also be gathering TIP data so that 23 test condition A, we'll be gathering TIP data.
24 And also, at test condition E, we'll be 25 gathering TIP data.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
48 1 MEMBER MARCH-LEUBA: That'll be transient 2 TIP, you know, are your going to wait there for 12 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />?
4 MR. YODERSMITH: So, it'll be steady 5 state, not steady state xenon, it'll be steady state 6 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 7 we will come to that test condition.
8 MEMBER MARCH-LEUBA: Only for one hour?
9 MR. YODERSMITH: That's -- yes, it usually 10 takes about four hours to get the TIP data, so we'll 11 sit there for that time period. We'll ask operations 12 to maintain power at that power level. And so, it'll 13 be a good TIP set which is consistent with the way we 14 gather TIP --
15 MEMBER MARCH-LEUBA: Actually, with 16 MELLLA+ we suggest comparison or you know harder to do 17 for the computer guys.
18 MR. YODERSMITH: Yes, that's right. And 19 so, this supports our, you know, we're taking TIP set 20 down at this test condition E in support of what was 21 discussed earlier that we don't need a safety penalty.
22 And so, this will be -- this will provide 23 additional confirmation that, yes, our uncertainties 24 at this lower point, this higher power flow point 25 don't show any inconsistencies with our uncertainties NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
49 1 at the more normal operating conditions.
2 MEMBER MARCH-LEUBA: Maybe I should ask 3 the staff about this, but is this a licensing 4 condition? It's not on the SER.
5 MR. YODERSMITH: We --
6 MEMBER MARCH-LEUBA: This second 7 amendment?
8 MR. YODERSMITH: Yes, that's correct, yes.
9 MEMBER MARCH-LEUBA: I think we're in 10 that, which I like better than a condition on the SER 11 because once you've done it, you don't have to do it 12 again.
13 MR. YODERSMITH: Yes, so our plan is to 14 take this data during MELLLA+ startup. The plan is 15 not to collect data here regularly, and so, our plan 16 is, hey, we're going to -- on each unit, we're going 17 to go collect that TIP data at that test condition and 18 analyze it and make sure it's within our existing 19 license uncertainties.
20 And then, if there's no plans to 21 consistently get data there, but we will get it before 22 we allow operation in the MELLLA+ region.
23 MR. MARCH-LEUBA: Thank you.
24 CHAIRWOMAN REMPE: Yes, thank you.
25 MR. YODERSMITH: You're welcome.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
50 1 CHAIRWOMAN REMPE: That helps with our 2 review.
3 MEMBER SKILLMAN: Let me ask this, please.
4 As I look at your slide 17 which is your conclusion, 5 what jumps out at me is the DSS-CD firmware.
6 And, the question I'd like to ask is this, 7 what confidence does the station have that the EPROM 8 and the other changes that are essential for this 9 amendment are what those EPROM and other hardware 10 changes need to be to stay within your -- the envelop 11 for which you seek approval?
12 MR. YODERSMITH: We're very confident in 13 the DSS-CD firmware so --
14 MEMBER SKILLMAN: Why are you confident?
15 MR. YODERSMITH: So, as part of the 16 engineering change package that we did in 2016 when 17 this firmware was installed, we did extensive factory 18 acceptance testing and we also did extensive site 19 acceptance testing of the firmware itself.
20 So, knowing that we've got the latest and 21 greatest firmware from GE with the latest and greatest 22 DSS-CD solution loaded on there, so extensive SAT 23 testing.
24 We are currently operating with Option 3, 25 so we've got the settings set such that Option 3 is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
51 1 our primary solution and DSS-CD is not active.
2 As part of our engineering change package 3 that will be implementing upon MELLLA+ approval, we'll 4 do extensive site acceptance test -- additional site 5 post-mod testing would be the right term for it.
6 After we put in the new setpoints, we'll 7 run through our MST, our maintenance surveillance test 8 procedures for those EPROMs which will have been 9 checked out at GE beforehand and run through and make 10 sure that, yes, we are getting the trips where we're 11 supposed to get the trips.
12 We are getting the annunciators where 13 we're supposed to get the annunciators and we'll run 14 through all that testing as part of post-mod testing.
15 MEMBER SKILLMAN: For the documentation 16 for that change package --
17 MR. YODERSMITH: Yes, sir?
18 MEMBER SKILLMAN: -- to what extent was 19 that covered by GE's and/or your Appendix B program?
20 MR. YODERSMITH: Yes, so the -- all the 21 documents -- the sworn documents that we got from GE 22 in support of that mod were developed in accordance 23 with their Appendix B program. And, our engineering 24 change process is to our engineering change to our 25 Appendix B program.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
52 1 MEMBER SKILLMAN: Yes, sir, thank you.
2 MR. YODERSMITH: Yes, sir.
3 MEMBER MARCH-LEUBA: And, just follow up 4 on a tiny detail, do you do a hash of the firmware to 5 make sure -- in many times of digital controls, people 6 put the wrong EPROM. The manufacturer will send you 7 the wrong EPROM to use in the plant.
8 MR. YODERSMITH: Yes.
9 MEMBER MARCH-LEUBA: I mean, the Unit 1 10 and Unit 2 are there to any one?
11 MR. NOLIN: There's a significant process 12 relative to digital changes of the nuclear plant 13 today. So, the firmware and software revision levels 14 are required to be verified by the change and any 15 subsequent PM replacements are corrective maintenance.
16 MEMBER MARCH-LEUBA: When you download a 17 program from the internet, the good size, that's what 18 gives you hash that you can check that it hasn't 19 changed.
20 MR. NOLIN: That's right.
21 MEMBER MARCH-LEUBA: It would be 22 worthwhile to think about it.
23 MR. YODERSMITH: Yes, so the --
24 MEMBER MARCH-LEUBA: Maybe GE needs to 25 think about it.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
53 1 MR. YODERSMITH: The EPROMs were hashed at 2 GE's facility --
3 MEMBER MARCH-LEUBA: They were?
4 MR. YODERSMITH: -- before they were 5 packaged to verify that, yes, this is exactly what we 6 need and what was tested during the FAC.
7 MEMBER MARCH-LEUBA: Okay.
8 MR. YODERSMITH: And then, they were sent 9 to site using our cybersecurity process which allow --
10 which requires certain tamper tape to be installed on 11 the boxes and other provisions before they can be 12 accepted at site to be installed.
13 So, we've followed our cybersecurity rules 14 as far as purchasing firmware.
15 MEMBER MARCH-LEUBA: Joy's going to say we 16 leave it, I love what you said. I'm wasting time.
17 But, I love you said you think of cybersecurity over 18 receiving the wrong EPROM. Typically, you don't think 19 of a cybersecurity on USB drives, on CDs, on the 20 internet.
21 MR. YODERSMITH: Oh, yes.
22 MEMBER MARCH-LEUBA: But, even an EPROM, 23 your cybersecurity has a plan for it.
24 MR. YODERSMITH: Yes, that's right. Anything 25 digitally related, our cybersecurity program gets into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
54 1 the purchasing requirements of that.
2 MEMBER MARCH-LEUBA: That's really good, 3 thank you.
4 CHAIRWOMAN REMPE: Because you want to 5 catch your plane, I'm going ahead at this point.
6 We're going to -- I think we're done with 7 this session. And, I'm going to ask for public 8 comments because this is going to be the end of the 9 open portion of the meeting.
10 So, can you get the line open? And, is 11 there anyone in the room who wishes to make a comment?
12 (NO RESPONSE) 13 MR. BROWN: The line's open.
14 CHAIRWOMAN REMPE: Okay. Is anyone on the 15 line who wishes to make a comment or if there's anyone 16 out there, if you just would confirm that you're 17 there, it would help us to know that there's someone 18 out there.
19 (NO RESPONSE) 20 CHAIRWOMAN REMPE: I'm not hearing 21 anybody.
22 PARTICIPANT: We're here.
23 CHAIRWOMAN REMPE: Oh, okay, that's good.
24 PARTICIPANT: We're here, yes.
25 CHAIRWOMAN REMPE: Any comments?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
55 1 PARTICIPANT: None.
2 CHAIRWOMAN REMPE: Okay, not hearing any 3 comments, I'm going to --
4 (OFF MICROPHONE COMMENTS) 5 CHAIRWOMAN REMPE: So, not hearing any, 6 I'm going to close the open session.
7 We're going to take a ten minute break.
8 And so, will the first folks, I think it's GEH and the 9 licensee, if they'll be at the front at 10:30 or 9:35, 10 we'll start up with that.
11 And, during this ten minutes, whoever 12 needs to check, make sure that the other folks aren't 13 in the room. Okay?
14 Thank you.
15 (Whereupon, the above-entitled matter went 16 off the record at 9:25 a.m.)
17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
ACRS Power Uprate Subcommittee Brunswick Steam Electric Plant Units 1 & 2 Maximum Extended Load Line Limit Analysis Plus (MELLLA+)
May 16, 2018 1
Introduction Andy Hon, PE Project Manager Division of Operation Reactor Licensing Office 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 both GEH (TRACG) and AREVA ATRIUMTM 10XM fuel.
3
LAR Contents
- LAR Body
- Introduction, No Significant Hazards Consideration, etc.
- Follows the Approved GEH MELLA+ LTR NEDC-33006
- Integrates analyses from GEH, AREVA (Framatone) and others
- 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.
- Standby Liquid Control (SLC) Boron Enrichment increased from 47% to 92%.
- 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 Office of Nuclear Reaction Regulation J. Borromeo (Lead) M. Biro M. Breach M. Chernoff J. Dozier A. Hon J. Hughey D. Ki M. Panicker A. Sallman R. Stattel A. Smith M. Smith A. Wysocki (ORNL)
Office of Nuclear Regulatory Research A. Bielen K. Gibson C. Gingrich N. Hudson J. Staudenmeier P. Yarsky 7
Agenda Time Presenter(s) Topic 08:30 ACRS Opening introduction 08:35 NRC staff Review introduction 08:45 Licensee LAR overview 09:15 ACRS Public comments 09:20 Break Closed Sessions Below 09:30 Licensee/FR LAR details (Framatome proprietary) 10:05 Licensee/GEH LAR details (GEH proprietary) 10:40 NRC staff/ORNL Review details (GEH proprietary) 11:15 NRC staff/ORNL Review details (Framatome proprietary) 11:45 ACRS Discussions and closing remarks 12:00 Meeting adjourn 8
Technical Staff Management Representative Opening Remark Jen Whitman Acting Branch Chief Reactor System Branch Division of Safety Systems Office 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 Overview Jeff Nolin - BSEP GM Nuclear Engineering 2
Objectives Show Need for MELLLA+
Describe Key Aspects and Answer Questions Demonstrate Readiness Requested Approval supporting 3Q 2018 Implementation 3
BSEP Station Overview General Electric BWR-4, Mark I Containment Began commercial operation in 1975 (Unit 2) and 1976 (Unit 1), OLTP 2436 MWt EPU (120% OLTP) 2923 MWt fully implemented in 2004 (Unit 1) and 2005 (Unit 2) 24 month operating cycle Transitioned to Framatome Fuel in 2008 (U1) and 2009 (U2)
Full Core Framatome ATRIUM 10XM Fuel Licensed for Increased Core Flow (ICF) (110% at reduced power, 104.5% at CLTP 2923 MWt) 4
MELLLA+ Project Overview - Background and Benefits
Background
EPU 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.
Benefits Fewer reactivity manipulations Reduction 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 5
MELLLA+ Project Overview - Implementation Progress and Plans Phase 1 (Pre-MELLLA+ Approval) - Plant Modifications and Training Standby 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 including 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 Testing Implement new Technical Specifications, Engineering Changes (ECs), Procedures Special Testing in MELLLA+ Domain including Level Control, Pressure Control, APRM / LPRM / TIP /
OPRM data evaluations, Fuel Thermal Margins, Recirc System Performance, and Moisture Carryover Transition to Detect & Suppress Solution - Confirmation Density (DSS-CD) Stability Option from Option III 6
MELLLA+ Design and Analyses John Siphers - GM Nuclear Fuel Design 7
MELLLA+ Design and Analyses The 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 Applicability ANP-3108P, Applicability of Framatome BWR Methods to Brunswick Extended Power Flow Operating Domain (EPFOD)
No SER restrictions on Framatome methodology that are impacted by EPFOD BSEP core and assembly conditions in MELLLA+ are equivalent to core and assembly conditions of other plants for which the methodology was benchmarked GEH methods are applicable to MELLLA+ and are capable of modeling Framatome fuel Transfer of information from Framatome to GEH allowed explicit modeling of the fuel Duke developed and provided a GEH thermal hydraulic model (ISCOR) for ATRIUM 10XM NRC RAI SRXB-RAI-11 response provided steady-state core simulator comparisons for BSEP MELLLA+ cycle using GEH and Framatome methods Shows GEH methods modeled the A10XM fuel and core characteristics in a satisfactory manner 9
MELLLA+ Design and Analysis - Key GEH Analyses GEH 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 Tmin and plant data was utilized to determine an appropriate feedwater temperature reduction rate.
10
MELLLA+ Design and Analysis - Key MELLLA+ Mitigating Actions BSEP 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 MWth/85% flow when compared to original power 2436 MWth/75% flow conditions (19.8% B-10).
2436 MWth/75% Flow peak pool temperature was 189.4 F while EPU/MELLLA+ is 174.0 F.
11
MELLLA+ Design and Analysis - SLMCPR BSEP 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 increased 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 Training Mark DeWire - BSEP Assistant OPS Manager - Shift 13
Operator Actions and Training - Overview Operator 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 14
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
Conclusions Implementation of MELLLA+ will provide significant benefits:
- Operators will have greater flexibility in using core flow to control reactivity
- Reduces the number of plant downpowers and reactivity manipulations
- Increases the stations 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 setpoint Engineering Change is being finalized
- Implementation test plan established Requested Approval supporting 3Q 2018 Implementation 17
Questions 18