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Transcript of Meeting with Northern States Power Company Regarding Monticello Plant on 10/15/08, Pages 1-68
ML082980438
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Issue date: 10/15/2008
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Official Transcript of Proceedings NUCLEAR REGULATORY Meeting with Northern States Power Company RE Monticello Plant Docket (n/a)

Rockville, Maryland Wednesday, October 15, 2008 Work Order No.:

Pages 1-68 :i ,I " ""'!l ... _. __*.__

NEAL R GROSS AND CO., Court Reporters and 1323 Rhode Island Avenue, Washington, D.C. (202) 1 UNITED STATES OF NUCLEAR REGULATORY +++++ OFFICE OF NUCLEAR REACTOR REGULATION +++++ MEETING WITH NORTHERN STATES POWER COMPANY (NSPM) DISCUSS ISSUES RELATED TO A FUTURE APPLICATION AMENDMENT REGARDING EXTENDED POWER UPRATE MONTICELLO NUCLEAR GENERATING PLANT, UNIT +++++

OCTOBER 15, +++++ The meeting convened at 9:00 a.m. in Room T-9 F5 at Two White Flint North, 11545 Rockville Pike, Rockville, Maryland, Peter S. Tam, Senior Project Manager, presiding.

NRC PETER TAM, NRR/P1ant Licensing Branch TOM ALEXION, NRR/Generic Communication

& Power CHAKRAPANI BASARAVAJU, NRR/Mechanica1

& Engineering JOHN BOZGA, Region III (via KAMAL MANOLY, NRR/Mechanica1

& Civil ROY MATHEW, NRR/E1ectrica1 Engineering SUBINOY MAZUMDAR, NRR/Instrumenta tion and NITIN PATEL, STEVEN HAMMER, SOO BEE KOK, GABE SALAMON, ALLEN WILLIAMS, ALSO KIRK JENKS, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON.

D.C. 20005-3701 www.nealrarass.com 2

INTRODUCTION BY P. TAM INSTRUMENT SETPOINT STEAM DRYER STRUCTURAL INTEGRITy..... EQUIPMENT QUALIFICATION STATUS OF GRID STABILITy............. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 3 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 P-R-O-C-E-E-D-I-N-G-S 9:09 a.m. MR. TAM: Good morning, I'm Peter Tam and welcome to the Monticello Meeting talking about the impending submittal of the EPU application.

This is a pre-application meeting. We do not have anything in our possession to review. But, in the meeting notice I did reference a letter that I sent to Monticello when they withdrew the previous submittal.

So, why don't we just go around and take care of the administrative things that we cannot hold the meeting yet because they are talking about proprietary stuff. Today's meeting will be fully transcribed and this is our Court reporter.

In order to --for those who are not used to this you need to each time you speak no matter how short you speak --you have to give us your name so that he can look up and identify you. And the transcript will be part of the meeting summary. We'll put in the public domain except for the fact that it's proprietary, but I was told that there was no proprietary information today. Has everybody signed because I need to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 4 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 have the Court reporter look at it? (No response.)

MR. TAM: Yes, I already have some of the names. If you know a person not here please cross out the persons name. All right, who from the licensee is taking the lead? MR. HAMMER: I will. MR. TAM: Okay, do you want us to go through the introduction of everybody first? MR. WILLIAMS:

I'd like that, yes. MR. TAM: All right, let's go around. As I said I'm Peter Tam. MR. PATEL: Ni tin Patel from NRR Electrical.

MR. ALEXION: Tom A1exion from NRR. MR. MATHEW: Roy Mathew from the Electrical Branch, NRR. MR. WILLIAMS:

I'm A1 Williams.

I am the Manager of the Extended Power Uprate Project at Monticello.

MR. HAMMER: I'm Steve Hammer. I'm the Proj ect Manager for the licensing aspects of the extended Power Uprate Project at Monticello.

MR. SALAMON: Gabe Salamon, Licensing Monticello.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 5 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. BASARAVAJU:

Pani Bsaravaju, Mechanical and Civil Engineering Branch, NRR. MR. MAZUMDAR:

Subinoy Mazumdar, Instrumentation and Controls, NRR. MR. JENKS: I'm Kirk Jenks. I'm Nine Mile Point EP Licensing Support. MR. KOK: I'm Soo Bee Kok, I'm from Structural Integrity Associates.

MR. TAM: Great. MR. WILLIAMS:

Great, are we ready to go. Okay, again I'm Al Williams.

I'm Manager of the Extended Power Uprate Project. Good morning everybody.

I would like to talk to you a little bit today is what you are going to see from us at the beginning of November for a license submi ttal for extended power uprate at Monticello Point. So I'll be going through some background of the Plant and of the process to date. We're going to talk about the three items that were specifically listed in the letter that Mr. Tam sent us concerning our initial submittal.

We're also going to talk about the grid stability study which we performed and I'll go into the background there. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 6 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 There are also some what I call minor changes to our license amendment request since the last time it was submitted.

We'll go through those. We'll talk about our overall schedule and then have a summary. So from a background from Monticello.

As some of you may remember we submi tted our initial license amendment request to the NRC on March 31, 2008. It then entered the sufficiency review process per the procedure LIC, I believe it's 109 which is an internal NRC guidance for sufficiency review. After discussion wi th the staff Monticello chose to wi thdraw the license and memo request on June 25th and received a letter from the NRC to that effect. There were three of them specifically listed in the withdrawal letter. First the steam dryer evaluation was deemed not to have sufficient information for the staff to do review. There were also some questions on the equipment qualification in terms of the analysis that was done at the Monticello Plant. And there were questions regarding the instrument setpoint methodology or the reference is TSTF 493. We will address all three of those in this NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 7 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 meeting. It is not our intent to discuss proprietary information in this meeting. The Monticello Plant is performing extended power uprate under these project principles and they guide ever decision we make in the actual proj ect and you'll see that as we go through our presentation.

The first two bullets up there are major principles for this project. First is we're going to maintain or improve the safety and risk profile of the Plant. What that means is is when we perform a modification of the facility we go, we're going to go to some length that either we're going to maintain our margins or we're going to increase the margins of the facility due to that modification.

So in other words, as we go through the review process you're going to see that the Plant that's going to operate at the extended power uprate power level and a lot of areas do the modifications we do we'll have more margins or more operating and safety margins than what the Plant has now. The second bullet is to improve our enhanced equipment reliability.

Monticello received license extension to 2030 a few years ago and we'll go through that. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 8 Part of the point of EPU is to replace equipment that's going to be necessary for that 20 years of operations.

So, EPU is actually part of a bigger project we call life cycle management.

So again our intent is to make sure the Plant can run safely and reliably for the extended license period. There are five sub bullets. Obviously we're going to follow the existing regulatory processes.

We use industry operating experience extensively in our project. We coordinate with other Plant proj ects . A big point here is we try to minimize the impact on day to day operation and what that means is we're trying to give the operators in the control room a Plant that substantially 1S similarly operates as to what they operate today. Now there are a couple of adjustments to that. We do have a couple of mods that have new consoles in the control room that require training.

But we try to minimize those where we can. So for the majority of the mods the only difference the operator will see will see a procedure change that will say instead of running on this point on the dial it will be a little bit further over so NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 9 the monitor it to a different setpoint.

But, in terms of the base operation of the facility we're trying to keep that the same. And then Monticello, as part of excel is also, also has another nuclear Plant Prairie Island. So we try to extract value from standardization or economies to scale. So if there's some modification or some piece of equipment that we can use at both facilities we try to do that. That's a goal we try to meet obviously with Prairie Island being a BWR that can be somewhat difficult at times.Monticello background.

We are a GE BWR 3. We were licensed in 1971. We began operation at our original license thermal power limit of 1,670 megawatts thermal. Monticello was actually the first BWR to receive an extended power uprate. In 1998 Monticello increased licensed power to 1,775 megawatts thermal which is where we operate today. A note to that original EPU is that that was mostly an analysis EPU. So when you hear Mr. Hammer talk about the modifications we're doing that's a far bigger scope EPU than what this original EPU was. Our application that we're going to submit to you at the beginning of November is for 2004 NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005*3701 5 10 15 20 25 10 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 megawatts thermal which is 120 percent of the original license thermal power of 1,670 megawatts.

In terms of our schedule we do intend to increase power in two stages. First, after we receive EPU approval, which we are hoping it will be some time in 2010, we will increase power to approximately 1,870 megawatts.

And that number is based on our electrical generator.

The generator will be limited at that point until the 2011 outage where we finish our EPU mods. After the 2011 outage our intent is to increase to the full EPU power level of 2,004 megawatts.

So, our implementation schedule, our actual first implementation we intend to do online. Our first set of modifications are going to be installed in six months in March of 2009 with our upcoming outage. At this point I'd like to turn it over to Steve Hammer to talk about the actual items in the latter. MR. HAMMER: My name is Steve Hammer. I'm the Proj ect Manager for the licensing aspects of extended power uprate at Monticello.

The first thing we want to talk about is some information on the Monticello steam dryer. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 11 The Monticello steam dryer is a GE 1965 product line square hood dryer. This is the original dryer that the Plant was originally started up with. There have been no modifications done to the steam dryer at this point in time. The licensing basis accident for defining the 1imi ted loads for the steam dryer at Monticello is based on the main steam line break outside of containment and that is consistent with what we will be doing moving forward on that. That will remain the limiting design basis of that for the steam dryer. The steam dryer to this point in time has been inspected per the BWR reactor vessel internal project, BWRVIP-130.

And we have very minimal indications on the existing steam dryer from those inspections.

EPRI and the BWRVIP have an initiative to provide a consistent steam dryer methodology.

To this point in time a lot of the work has been done per BWRVIP-182 which provides guidance for steam dryer evaluation methodologies.

This was submitted in January of 2008. There's addi tiona1 work going on right now by a EPRI group to provide a licensing topical report on a continuing dynamics of the CDI methodology.

NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 12 That's currently planned to be submitted in late 2008. I think the goal at this point in time is to actually have that submitted on or about November 41st. It is in final reviews at this point in time. 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 In addi tion, we have followed the guidance provided in Reg Guide 1.20 Rev. 3 with the exception of the '98 startup reporting.

Our steam dryer evaluation approach is per BWRVIP 182 as I mentioned.

That consists of a number of different aspects. One aspect is to provide a screening of the perceptibi1i ty of the existing system to acoustic excitation and to consider validation of that by scale model testing. At Monticello we did both of those aspects. We installed strain gages on the main steam lines to provide measurement of main steam line response both at --originally that was done just to current license thermal power. We'll talk a little bit more about that testing of those signals as we move through this. We used the acoustic circuit model developed by CDI to establish loads on the steam dryer and that load definition is transferred from the main steam lines onto the steam dryer by a load definition of current license thermal power. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 13 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 In our case we are using scale model testing to provide bump up factors that will allow us to evaluate those loads at extended power uprate conditions.

We've done a finite element model of the dryer at current license level power conditions to define loads on the dryer. And we are also --will be using limit curves to define the limits on the dryer during power ascension.

The main steam line strain gage data, as I pointed out installed means, or stain gage is on our main steam system. Based on the CDI methodology and guidance.

Those were installed in 2007. The initial data taken in 2007 was primarily based at me finding loads of current license thermal power. Subsequent to that is as time has gone on and I think everybody is aware we are now everybody is considering me finding a low power data to allow you to eliminate noise on the steam dryer loads. The initial data taken at Monticello did not have the EIC data taken. So there was no consideration of electrical induced currents.

And in addition the low power data that we took in 2007 was more or less not taken intentionally to define low power conditions.

We were doing that more or less NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 14 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 just to test our the data acquisition system. So, in our case we happened to take data at 28 percent power and that's the low power data that we have been using to this point in time. Fil ters were applied to consider pipe bending research pump electrical and vane passing frequency noises and those have been filtered out. We are planning at this point in time of doing sub-model analysis similar to what TVA is doing to address hot points of the high stress points on our dryer and at this point in time we have about four locations that have stress where it shows that will require sub-model analysis or some further refinement of those loads to ensure that we meet the acceptance criteria in the dryer analysis.

We are applying bias and uncertainty inconsistent with the CDr licensing topical report approach and r think we are consistent with what TVA Browns Ferry has done with those aspects. The dryer evaluation results, as pointed out previously, are in previous submittals.

The SRV sand pipe resident frequency is expected to occur upon approximately 162 hertz at Monticello at current license thermal power. We've done a couple of things to try to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 15 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 verify that we will not see the onset of residents at Monticello.

That's been confirmed by two approaches.

One is an analytical approach that shows that the calculated onset of residents requires a steam velocity of 185 feet per second. Our EPU steam velocity based on the heat balance at Monticello is currently proj ected to be 179 feet per second. So we don't based on an analytical approach we do not expect to see the onset of residents.

In addition, we did a scale model test to verify that when acoustic residence occurs a scale model test predicted the onset of residence at about 201 feet per second. Again, showing that we should add margin to the onset of residence.

Our goal at this point in time is that we will ensure that we have a stress ratio under EPA condi tions of greater than 2.0 and we'll have a stress ratio of greater than 2.0 at current license thermal power. MR. MANOLY: Steve, you said your calculations steam velocity 179 which is lower than How is the 185 related to that? MR. HAMMER: Well, the 185 was just an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 16 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 analytical evaluation of where you would hit a velocity that would again steam in Monticello.

Based on analysis 185 per second will create the 162 hertz. So that's the length here. MR. MANOLY: Well, the 201 1S the scale model, huh? MR. HAMMER: 201 is the scale model. MR. MANOLY: So, how do you like expect predictability between the scale model and the calculated numbers? MR. HAMMER: Well, our understanding is tha t wi thin kind of expected accuracy ranges on scale model testing. I mean both of these have a certain amount of uncertainty associated with the analytical approach and the scale model test. You know my guess is that the actual values are probably some place between those values. MR. MANOLY: So, that uncertainty comes before the calculations?

MR. HAMMER: I can't answer that right now. I don't believe it is. MR. MANOLY: But it's something to think about. MR. HAMMER: Yes. In addition, one of the concerns that were identified by the NRC when we NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 17 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 wi thdrew the license amendment is consideration of existing steam dryer clause. We have a fairly limited number of flaws at Monticello or nearly like five. All of these are relatively minor. There's one IGSCC flaws. The others are in welds. The typical well flaws is on the order of 1/8th inch or less. And our goal, we will demonstrate based on analysis that these flaws have no effect on component stiffness and don't effect the FDA model from mobile response due to cracking.

In addition, we will demonstrate that these cracks do not have a potential for growth and we don't expect to see any repeated formations.

But, the final element analysis is showing right now that the stress is an alternated stress and that these locations are very low so we don't expect to see any significant change. MR. MANOLY: How much come off from the crack? MR. HAMMER: It varies, the IGSCC cracks are on a drain channel which has an inspection plate on a drain channel. And those are --that's a fairly incrust section and those are probably through a wall. But there's very li ttle moments there. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 18 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 The differential pressure in that drain channel is open to the inside of the rafters. So we expect the differential pressure to probably one PSI or less that type of thing. So the loads are very small. The other cracks are typically in fillet welds. So they are not expected to be through the wall. But they do --some of them go part way through a weld and there's one or two of them that go all the way through a weld. MR. BASARAVAJU:

What kind of stress is this that go through the well? MR. HAMMER: Excuse me? MR. BASARAVAJU:

What kind of stress levels? MR. HAMMER: I'm not prepared to answer that at this point in time. We've got the stress analysis for the steam dryers still in validation at this point in time and so you know all I'm prepared to say is that they are very low. But I can't give you an exact value. What we expected from the previous analysis which is you know we've redone that analysis, but the previous analysis showed that they were less than 2,000 PSI at all locations.

So, you know at this point in time I can't say what the exact number is for NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 19 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 the new analysis.

Any other questions?

MR. WILLIAMS:

Is it true though that the cracks and or stress points from the previous analysis are not in the same locations?

MR. HAMMER: Oh, the high stress? MR. WILLIAMS:

Yes. MR. HAMMER: Yes, the high stress there is some --they are not in high stress locations.

They are all in low stress locations.

MR. MANOLY: So the restricted IGSCC cracks here? MR. HAMMER: Well no, there's one that IGSCC. That's on the channel drain. The others are believed to be due to fabrication type issues, original weld stress type issues. And all of those are in welds so I don't think are IGSCC. MR. MANOLY: Well, IGC is usually in the heating zone. MR. HAMMER: Well but these are actually in the weld itself. MR. MANOLY: In the weld itself, okay. MR. HAMMER: Yes, okay steam dryer summary. The evaluation will be done per BWRVIP-182.

And it will be in compliance with continuing dynamics, NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 20 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 licensing and topical report approach.

We will impact or evaluate the impact of plausible growth and we will ensure, as I stated before that we are not impacted in the resident response of the steam dryer. So we're not impacting fini te resident analysis and we will show that there is very limited potential for crack growth. And our goal will be to show that we have minimal alternating stress ratios that are greater than 2.0 under EPU formations.

MR. MANOLY: How far along are you on the evaluation?

MR. HAMMER: At this point in time it's in validation and we're working through some of the final details. Maybe I should point out that the analysis as it stands at this point in time is largely based on the 2007 data. One issue that I should probably bring up is that we also, similar to TVA had a scram in late September which allowed us to get a new set of steam dryer, main steam land loads in early October. And right now we are --we plan on using those new loads to address EIC. I mentioned that the original loads did not have EIC in them. So we will both use EIC trying to address those loads from that new data. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 21 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. MANOLY: So you don't --there is no submittal not account for EIe? MR. HA1'1MER:

No. MR. MANOLY: And it's a supposedly a qualifying dryer event, right? MR. HAMMER: Yes, well we ended up with the original submittal.

I don't remember the exact date. But we have stress ratios less than 2.0. MR. WILLIAMS:

This is Al Williams.

There are about 1.8 or so was the EPU minimum alternating stress ratio. MR. MANOLY: So you're trying to bring them up? MR. HAMMER: Yes, we're trying to bring them up. MR. MANOLY: And we need to do some models here. MR. HA1'1MER:

Well, that's going to be the primary means of bringing them up. We'll have to do some model testing. But right now our approach would be similar to what the stress from TVA estimated.

MR. BASARAVAJU:

So the validation would require some models? MR. HAMMER: Right, and we'll start testing for that using the same type of approach.

NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 22 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. MANOLY: I guess what I mentioned completion you heard the same points. Steam is still not in my view it is at a stage where we expected the application would be complete.

The analysis should have been completed before or two years into the application and still debating the analysis.

And I'm trying to really hammer the point that we don't want to view the progress.

We want to complete the progress.

MR. HAMMER: Well, and we are entirely in agreement with that. I think you are as aware as we are for example, we submitted on March 31st and the stress ratio acceptance criteria changed as TVA pointed out in April. So that was one of the primary reasons why we ended up withdrawing our submittals because that criteria changed more or less after we completed our analysis.

Now there's some risk, as we pointed out yesterday, that there is you guys have some concerns about whether the stress ratio of 2.0 is still accurate.

Again, it's the same type of thing. What we're doing is we're doing this analysis wi th the goal of being able to meet your --the past stated criteria of 2.0. So, the risk that we've got is if we, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 23 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 know if we have a fuzzy target on what the stress ratio is. You know it might require some additional work. We will submit based on the analysis.

We will demonstrate that we have created a stress ratio greater than 2.0 and hopefully that can show that we have some substantial margins that can be extracted from both locations.

MR. WILLIAMS:

And one of the other things. One of the messages we've heard clearly from NRC is that you want the industry to have a unified approach on these steam dryer analysis.

And that's kind of the purpose of the CDI topical report. To allow us and the other Plants to come to the NRC with a unified approach.

And that's what we're attending to do. We intend to follow obviously we have to take into account what TVA 1S doing because they are with you for review right now. But, we also communicate with the other potential applicants for EPU's to make sure we all understand both what the topical report says and what each one of us is going to submi t so that we do provide you a consistent approach so that one --we don't get into the same discussions that unfortunately we've been in with another licensee.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234*4433 WASHINGTON, D.C. 20005*3701 www.nealrgross.com 5 10 15 20 25 24 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. MANOLY: Well, you know the CDI approach has been progressing for some time. It was evolving.

It wasn't really set in concrete a year ago, two years ago. It's growing and I would say polishing, polishing the approach based on questions we ask. I mean up to yesterday.

So, things are still kind of --I'd like to say finalized.

But the reality is CDI has system limitations you know. Now maybe it's the size of the company, you're trying to manage too many things at the same time. But the bottom line 1S CDI's ability to progress fast enough shouldn't be the reason that we get applications that are in progress.

And that's the point that I was trying to MR. WILLIAMS:

And we will give you a completed analysis.

And our analysis will be complete with the understanding that the basis for that analysis is going to be a topical report that I know you haven't seen yet because it's going to be submitted about the same time MR. MANOLY: We already know what it's going to say. I mean MR. WILLIAMS:

And it's going to account for any additional information that's come from NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 previous reviews. For example, we understand what had happened In the Hope Creek submittal.

We understand what the understand was there was a meeting yesterday of where TVA is. So we will account for those items in our analysis and provide you a complete analysis to the best of our ability based on the date we're at. Some of the problem we ran into the last time is, as you said things continued to evolve in these analysis and we can't predict the future. All we can do is give you the completed analysis based on the facts we know today. MR. MANOLY: I guess the two issues that were fundamental yesterday were the noise issue and the sub-marvin.

And those really was two factors introduced to bring the load factor into it too. So, I mean it's --well we --I thought it was pretty much clear from the beginning that we were looking for a load factor of two. Now, CDI could not meet that so they had to come up with some ways to polish the numbers to get the numbers higher. I mean, tomorrow they may come up with something new. I don't know, you know. The preferred stamping, that was another factor. That was not NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234*4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 26 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 included in the previous application.

So, we deal with the things as they come along. MR. HAMMER: I would expect our data you guys saw the TVA uniform data yesterday.

I would expect our data to be very similar to that in nature once it's submitted.

MR. MANOLY: And you expect that there are to be no modifications, right? MR. HAMMER: At this point ln time there's no modifications.

MR. MANOLY: Before you submit you should really MR. WILLIAMS:

I want to address that. We have a dryer that's 37 years old. A dryer has minimal flaws, four or five. It is a fairly, call it benwall dryer. In other words, it has some flexibility to it and the modifications associated with providing a higher structure ratio are to stiffen it. As we've looked at that on site, as we've evaluated that the risk to doing the mod are higher than the risks that it's going to solve. Or higher than the results that we're going to have. For example, as we looked at it it appears that the actual welding that we'd have to do to the steam dryer could put us at more risk. In other NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 27 words, we could burn through a plate and we could end up with a dryer that's in worse shape than we have now. So, as a company we've looked at that and said that's not a risk that we want to pursue. So our approach all along with our current dryer has been to try and license it with no modifications.

So that's the process we're taking. MR. MANOLY: Do you have a square dryer or a slanted dryer? MR. WILLIAMS:

Square hood dryer. MR. MANOLY: Square hood dryer. The process original dryer? MR. WILLIAMS:

It's a smaller version of the Quad Cities dryer, that's correct. MR. BASARAVAJU:

They have no corrugated plates? MR. WILLIAMS:

No, that modification is no longer available for steam dryers. It's been found to have limited effectiveness.

So, let's get back to margins. When we look at risks and margins for the facility what I worry about and what my management worries about is that by doing this modification we could actually reduce our margins. This is a difficult modification NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 28 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 to make. This piece of equipment has been in the reactor for 37 years. It's contaminated, it's got high dose rates. We'll have to do the work under water. It's the kind of modification we're trying to not do. As a matter of fact, of all the options we're looking at for EPU the modification of the dryer is the one that we are not pursuing at all. If we can't license this dryer we have to step back and decide what other paths we want to take. MR. MANOLY: So hopefully you're not in the same boat as Susquehanna because they qualified they tried to qualify the dryer and then finally they realized after so many mods that it's not practical to do it and they had to replace the dryer. MR. WILLIAMS:

We are looking at contingencies if we get to the point where we feel we can't license the dryer. Those contingencies are being considered by senior management and we'll make those decisions based on our discussions wi th the staff. (Whereupon, off the record from 9:42 a.m. until 9:45 a.m.) MR. HAMMER: All right, just to summarize NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 29 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 our --we will be doing the steam dryer analysis using the BWRVrp-182 criteria.

The CDr license and report methodology.

That methodology will be very similar to what TVA is doing. We expect our data to be fairly similar to the TVA Unit 1. We're going to have very clear data with reasonable noise signals on it. Fairly typical of what you see. Right now the approach is very consistent wi th what's been done by these uni ts in the past. The number of high stress locations right now that exceed or don' t meet the 2.0 criteria is very limited. Right now we expect to have to do the substructure modeling we believe on about three points. What we are currently doing is based on the new data that we got in start up from our October outage is we are considering evaluating those high stress locations with this new data and we believe the new data might also result in us being able to improve our stress margins so that all of that is still in progress and it's still in validation at this point in time. So MR. MANOLY: You expect --you're done wi th all of the evaluations before you submit the NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 30 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 application?

MR. HAMMER: Absolutely, we will not be submitting until the final analysis is complete.

And as you are aware there's a lot going on with CDr right now. TVA and Monticello and all, but right now we still believe that that hopefully will all come together on or about November 1st. So that's a potentially doable target. MR. MANOLY: Okay, is the structural authori ty integrity doing poor or just on select products?

MR. HAMMER: Structural integrity is doing portions of the steam dryer analysis.

They are doing the sub-model evaluation.

They are doing the flaw evaluation for us, those types of things. MR. MANOLY: We'll be included in that report, right? MR. HAMMER: Yes. MR. BASARAVAJU:

This October 2008 data, is it going to be CLTP data or non-flow data? MR. HAMMER: Both, what we did is we took data at seven different power levels on start up from the outage. And what we did there was we took Erc data at every location also. So now we have a complete set of data. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005*3701 www.nealrgross.com 5 10 15 20 25 31 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. BASARAVAJU:

So that can be used if you need MR. HAMMER: That will be used to support the final evaluation.

MR. MANOLY: So you shouldn't be really thinking about replacing the dryer then. MR. WILLIAMS:

From a structural standpoint, we believe the dryer we have will perform to the limits that have been set. Like every other piece of equipment in our Plant we have to evaluate it's performance at the higher power levels. Depending on what models are used there may be some question about the new dryers or the dryers ability to perform at 120 percent power. MR. BASARAVAJU:

Is it moisture carryover?

MR. WILLIAMS:

Yes, moisture carryover is the biggest issue. It is not a safety issue. However, obviously we do not want to run a high moisture carryover because it can impact the turbine. It will impact dose rates in the long term to the unit. And that's not something we want to do in the long term. So, we don't have the facts we need to evaluate the performance.

So all we can do is either base it on a model which has again really no bench NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 32 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 marking basis or receive approval for the dryer and then as you step up use actual performance data on the dryer and then make our decision as to how well we're going to do in the future. What we do know is that there is no modification that's available to eliminate this moisture carryover problem. MR. MANOLY: What's your current moisture carryover?

MR. WILLIAMS:

About .04 percent coming out of the dryer. MR. MANOLY: That's CLTP, right? MR. WILLIAMS:

Yes. MR. MANOLY: And the set limit is .1? MR. WILLIAMS:

Our limit 1S .1. MR. MANOLY: .1? MR. WILLIAMS:

Yes. MR. HAMMER: That's the design value. MR. MANOLY: So if you exceed that you're going to have to do something?

MR. WILLIAMS:

We're going to have to either evaluate the limit or evaluate the performance of the dryer and decide what other actions we need to take and those decisions are not a project decision, their a Plant and a Plant Manager safety decision.

NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 33 So, obviously there will be a few different people involved in those discussions.

MR. HAMMER: And what you'll see in our license amendment, for example from a dose consequences standpoint, we used the bonding assumption here. We assumed the carryover of up to .5 for the dosing analysis.

So that's a pretty conservative approach.

MR. BASARAVAJU:

If you decide to replace, what kind of dryer will you be using. Will it be the cylinder type or a metal design? MR. WILLIAMS:

No, we are looking obviously that's part of our contingency for the project is to decide if we need to replace the dryer what we're going to do. We're evaluating a number of different dryer designs. What we won't do is replace it with the same design we have now because it doesn't get rid of the problem. So, we have to have a newer design. There are a number of manufacturers that can make a steam dryer that will both meet the structural requirements and the performance requirements.

So, we're evaluating all of those and should we decide from a performance standpoint that the dryer needs to be replaced we'll pick one of them NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 34 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 and go through Reg Guide 1.20 which would require certain activities, not the least of which would be instrumentation of the dryer. MR. HAMMER: Any other questions?

MR. MANOLY: No, thank you. MR. HAMMER: Okay, the next issue that we want to discuss today is equipment qualification.

During the process where we withdrew the application it was one of the issues that was discussed in those letters. Monticello has completed the environmental qualification analysis required to support the Plant operation and extended operation power uprate conditions.

The resul ts show that two transmi t tal applications are required for EPU implementation.

What we plan on doing as those transmitters with some further work could be qualified to support EPU operations.

But in order to improve margins we are going to improve, replace these and a number of other older obsolete components to support the project. MR. WILLIAMS:

This is --let me jump in. As we talked about the beginning the project principles, one of the big project principles is to increase the margins of the facility.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 35 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 These two transmitters that we are saying are "required by EPU" we feel pretty strongly that we could do more detailed analysis and say they are okay. But that doesn't meet our principle.

We can replace these transmitters which are pretty old transmitters with new models which have more margin and are more accurate.

They meet their project goal. So rather than perform a bunch of analysis just to say we don't have any. In the submi t tal you're going to see we're going to say we have these two transmitters but we're doing that to meet our project principles.

So you will see the completed modification paperwork which is the discussion we had during our EPU process. But, I wanted to make sure you understood the background as to why those two are going to be listed in the submittal.

MR. HAMMER: The last bullet here discusses the 10 CFR 50.49 qualification files. As discussed in the call where we agreed to withdraw the license amendment, the plans for completion of those files will be prior to EPU implementation.

So, when we make the submittal those files will still be outstanding.

But they will be completed NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 36 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 prior to implementing the EPU. MR. PATEL: I have a question.

This is Nitin Patel. Do you know the model numbers of the transmitters that you are replacing or MR. HAMMER: They're Rosemont MR. PATEL: 153? MR. HAMMER: I want to say they are 1139's. But I don't remember.

They are fairly old. They are really old. MR. PATEL: Okay, now so do you have any idea right now what are the temperatures variations inside and outside the building?

MR. HAMMER: Yes, we have those and you'll see that as part of the amendment.

I guess we submitted that as one of the questions that we came about with the last acceptance review process. Now one of the questions, we're going to have to revise that letter a little bit based on the results of ongoing work. We'll refine that analysis based on some additional testing that was done in the Plant. We believe that that original question from the NRC was aimed primarily at radiation.

So right now we were --our current proposal is that we'd just like to respond to the radiation aspects. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 37 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 But if you guys aren' t interested in seeing the additional changes let me know, so. MR. PATEL: You are to use the RAIs ln future submittals.

Let me clarify some aspects on the EPI so it doesn't you know it might be able to minimize generalities.

In the submittal we would like to know the changes in the three EPU and of course MR. HAMMER: For all aspects? MR. PATEL: for all aspects inside company and outside company. We don't need all of the calculations.

I think you have been doing that. One of the programs you're using marketing and temperature curves. But we'd like to have a comparison of the curves, you know to reinforce the EPU the temperature curves. MR. HAMMER: You want to see the curves? MR. PATEL: I want to see the curves. MR. HAMMER: Not just the peak parameters?

MR. PATEL: Neither values for the peak parameters, the peaks in the parameters and also the curves, comparison of the curves, and your EQ qualification cards. All the qualification cards to demonstrate that most EPU parameters are still handled NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 38 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 by existing EPU programs and most of the equipment are handled by existing EPU codes because we are identifying the two transmitters that you want to modify. And then also you can separate events and not do any modifications.

MR. HAMMER: Well some of that, you know might be of limited utility. For example, the qualification curve the qualification curves in the EQ files are in the past history, the new history and what will end up happening is the 54 files might do erroneous evaluations to be able to show that we still meet qualification requirements.

And you know we can provide all of those curves, but we can't provide that erroneous qualification for example at this point in time. We've got a basis for what we consider to be acceptable.

Well, let me we'll consider that. We'll see what we can find. MR. PATEL: Well, the other thing is you know since you demonstrate you know the forced EPU is still handled by the EQ program. If it falls out of the EQ profile then you have to go for justification in the MR. BOZGA: Excuse me, this is NRC. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 39 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. TAM: Hi, this is Peter Tam. MR. BOZGA: Yes, Peter the line is breaking up. Is there a reason why. I can't hear the conversation.

I apologize.

MR. TAM: Can you hear me. Can you hear me? MR. BOZGA: I can hear you clearly. MR. TAM: Okay, I think our speakers were not facing you. MR. BOZGA: Okay. MR. TAM: All right, we'll change that. MR. BOZGA: rrhank you. MR. TAM: Is this John Bozga? MR. BOZGA: Yes, John Bozga, NRC Region III power operate. MR. TAM: Okay, who else? MR. BOZGA: Just myself. MR. TAM: All right, thank you John. MR. BOZGA: Thank you Peter. MR. PATEL: This is Nitin Patel from NRE Electrical.

MR. BOZGA: Thank you. MR. PATEL: The subject we are discussing right now are equipment qualification.

MR. BOZGA: Okay. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgro55.com 5 10 15 20 25 40 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. PATEL: And I'm having a discussion wi th licensee right now what we expect in their submittal ln the AEP equipment qualification.

MR. BOZGA: Okay. MR. PATEL: What we expect in the submi ttal is the changes in the parameters.

The parameters itself, the change in the parameters.

For example, like temperature radiation outside and inside containment and also the comparison of the curves of the temperatures outside and inside containment.

Second thing we expect in the submi ttal is the --any modifications of the equipment that they are expecting or they are going to provide and also the replacement if they are going to do any replacement also equipment we need to know about it. Like you have identified two transmi tter modifications over here. And if they are falling out of the existing EQ program then also we would like to have the explanation and justifications for those equipment that are falling out of the existing EQ program and how they are qualified for, you know their 40 years of qualified life. I f you're al so adding any equipment to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 41 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 existing EQ program then we would like you know have l it identified in the submittal that these are the equipment you/re adding and how you are planning to qualify those equipment.

Sometimes what happens is you know some of the areas are now becoming harsh because of the EPI. And you might saYI well okay this transmitter say for l example 854 is already in the EQ program and now we are bringing this transmitter now it/s falling into the EQ program and that transmitter is going to qualify. We would like to have you upgrade the transmitter for the EQ program. For example like if you are doing any I modifications on 845 Rosemont transmitter you are changing that origin because it is EQ equipment every ten years. For here you haven I t changed that but from the maintenance.

So you might want to perform the maintenance on that to being it to the EQ category.

MR. HAMMER: What we/ve got --we have we/ve done that review. There are five cable types that are being added to the EQ program. But they are all cable types that already in the EQ program. MR. PATEL: Okay. MR. HAMMER: SOl our fiber net cables. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 42 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 there are actually three cable types. So, we don't expect to --we need to revise our files or recognize that these new cables are part of the EQ program. But it doesn't constitute any new qualification reports or anything like that. MR. PATEL: Well the cables it might be true. But what I'm saying is for example like MR. HAMMER: And we reviewed, there is no equipment.

So in our case that's just these five cables. MR. PATEL: Okay, other thing if sometimes you know, during the EPU you might --the situation might happen where you might be dropping some equipment from the EQ list because they were there to begin with not EQ equipment.

So, if you are going to drop some equipment like that we would like to know, have the fillet weld effect analysis on those equipment.

MR. HAMMER: We're not going to do that at this point in time. That would be a great thing to do and we'd love to do that. We just haven't had time to do that. MR. PATEL: And you know some of the licenses done that and you know we would like to have the fillet welds effect analysis on that. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 43 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. HAMMER: Yes, we're not going to we're don't plan to do that. MR. PATEL: And at the time of the submi t tal we would expect you to have a complete analysis and your plan of replacement or re-qualifying any equipment that's needed to be done. MR. HAMMER: Yes. MR. PATEL: So, do you have any questions regarding EQ? MR. WILLIAMS:

That was completely understood.

Your last statement was completely understood from our previous discussions.

MR. PATEL: Okay. MR. WILLIAMS:

And that's the point with these two transmitters.

The analysis obviously is complete and the modification paperwork will be complete.

We'll implement those changes likely in the 2009 audit. MR. HAMMER: The one difference here what you're asking for compared to the previous amendment acceptance review questions is you're asking for the time history profiles.

Those weren't provided previously.

We can do that. MR. PATEL: Okay. MR. HAMMER: NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 44 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. PATEL: I mean I don't need your erroneous calculation on each and e very equipme nt. MR. HAMMER: Yes. MR. PATEL: That's not the point I'm making. MR. HAMMER: You just want to see how those compare MR. PATEL: To the existing EQ MR. HAMMER: --to the EQ files, right. MR. PATEL: And if they are falling out of the EQ --you know your EQ bonding profile then we'd like to know some explanation and justification for that. MR. HAMMER: Sure, that's a fairly substantial quantity of information and we'll have to consider how to do that. That's a lot more information than what we provided the last time around. We didn't provide all those timing histories and all the EQ program profiles for example the last time we were here, but we could do that. We just provided the peaks. All we did was provide the peaks. MR. PATEL: Peaks and descents from the numerical values? NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 45 MR. HAMMER: Yes, we provided numerical values for the peaks for all parameters in all areas. MR. PATEL: That might be only half of the curves probably in the areas that you might be have to provide. MR. HAMMER: I'll have to look at that. Monticello typically did not qualify things to a volume curve to cover the entire building for example. MR. PATEL: Okay. MR. HAMMER: We have --my guess 1S we're going to have a number of curves that are not --I'll have to look and determine exactly how much that is. We'll have to figure that out and we'll see what we can do to satisfy you. MR. PATEL: We can have another conference call if you guys need to discuss about that after you come back. MR. HAMMER: One of the other things we're doing going forward on this proj ect now is we're going to try and qualify many more things to involve a profile that covers the reactor building.

MR. PATEL: Okay. MR. HAMMER: But right now what's in there is they've done a lot of work for what they call a qualified each and every area. And they've got 85 NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 46 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 areas. I'm a little concerned I might have to give the 85 curves which I don't know if you want to see that. But we'll run that kind of thing. But we'll see what we can pull together and if we need some more conversation we'll come and talk to you. MR. PATEL: Okay, that's about. Do you have any questions regarding that EQ area? MR. MANOLY: I just have --going back to --I have one question.

Are you going to submit the power ascension test program and the limit curves and application?

MR. HAMMER: We have the power ascension test program. It's one of the enclosures of the limit curves off the top of my head I don't remember exactly if they are in the data at this point. I would have to verify that. MR. MANOLY: You should be able to. MR. HAMMER: Yes, you should be able to do that. All right MR. MATHEW: This is Roy Mathew. So you're clear on what you have to do in the EQ area? MR. HAMMER: Yes, I believe so. MR. MATHEW: If you make a statement in the wrong way saying you know all equipment are NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 47 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 founded by what you're looking for is the basis. I will make sure that what you're stating in the license amendment we have verified it. So, the curve the EPU condition and the EPU condition what are one of the profiles you had to show us to demonstrate.

That's the bottom line. MR. HAMMER: Some of the background to grid stability.

The first license amendment we were unable to get the Midwest Independent System Operator to allow us to have a grid stability analysis that was complete through 2004 and megawatts thermal within the time frames of the original submittal.

So at that point in time we were --we had a license condition that covered that eventuality.

MR. WILLIAMS:

We actually submitted that 1,870 MR. HAMMER: Yes. MR. WILLIAMS:

wi th the intent of resubmitting the 2004 once MISO was complete.

MR. HAMMER: And, we would not --the license amendment was based on not exceeding that 1,870 megawatt thermal power level until that final MISO approval study had been completed.

At this point in time MISO has completed the study for both stage one, which was the original NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 48 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 value ln 1,870 and they've also completed stage two which is the full power uprate. They have the stability analysis at this point in time shows that there is no impact upon grid stability at either power level. There are actually no grid modifications or site modifications that are required in order to support stability and MISO performed that stability analysis with and without capacitor banks. So, the last bullet that we're talking about here notes that in order to meet our interconnection requirements wi th MISO we are required to have a capability of providing a 0.95 lead and lagging power factor. And in order to satisfy that requirement we will have to install capacitor banks in order to meet that MISO requirement.

But, as noted the capacitor banks aren't really required to verify or ensure grid stability.

So, at this point in time we are in process of negotiating with MISO the final design on those capaci tor banks and the final schedule for those capacitor banks. MR. WILLIAMS:

And the location.

MR. HAMMER: And the location.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 49 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. MATHEW: And so the grid analysis isn't done then, the grid analysis.

Okay, in the past the thing that occurred you needed to change some of the breakers.

You don't need that anymore? MR. HAMMER: What the previous analysis that we --we had a independent contractor that did a grid stability analysis that was representative of what we expected MISO to be able to do. And that independent contractor was proj ecting that there might be some modifications that were required.

But the final MISO analysis that we have at this point in time does not identify any grid modifications.

So there are no grid changes. MR. MATHEW: So there are no electrical equipment that needs to be MR. HAMMER: What you'll see in the license amendment for offsite power. There's no required modifications for grid stability.

We will note this capacitor bank to meet our leading leg and power factor requirements with MISO. The other thing that's happening as you go through the license amendment you'll note that we are replacing some of our 4.16, 4 kV buses in the site 138 kV switchgear and that factors into this type of analysis because you know when we have to replace the NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 50 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 1R transform and the 2R transform which are normal offsite power sources and some of the switch gears. So, the modifications that we've got are aimed at providing the capability to provide a reliable source of in house power for the new reactor feed pumps primarily because we're increasing the house load quite a bit. So, it's really an improving margins, as Al pointed out on the existing 4 kV switchgear.

You can't show adequate margins, wi th the new motors, wi th the existing 4 kV switchgear.

So we have to replace those. So that's the only modifications we've done. MR. PATEL: And that will be identified in the submittal?

MR. HAMMER: They are identified in the submittal, yes. MR. PATEL: Okay. MR. MATHEW: This switchgear analysis will be provided to us or MR. HAMMER: Yes, we will provide an enclosure 14 covers grid stabili ty and we will provide essentially a new enclosure 14 that provides this and I think we also will provide these. MR. TAM: I'm curious, because in the previous submittal we have problems.

You were put on NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 51 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 a cue saying that it would take so many years to improve stage two. What happened because now you say it's completed?

MR. HAMMER: I would --I would say that MISO stepped outside of the process for us. MR. WILLIAMS:

Well, let's go further. MISO recognized that the process they had had a lot of what they would call speculative empowering increasing on the grid. There were a number of wind producers that had gotten in the cue between the time we put in our phase request and our phase two. What MISO recognized is that most of those were again speculative.

So they applied to FERC to make a change to their process which effectively allowed them to do as Steve mentioned.

It allowed them to do our analysis out of their cue order because they had verification if you will that we were going to install the new capacity.

Obviously we need approval from the state and from the NRC. Bu t, we had a --it wasn't a speculative venture on our part. So they were allowed to go outside. So that's what they did for us, is did that, did our analysis outside of their normal cue process. MR. HAMMER: And MISO recognized that if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 52 they stayed with the original cue process they were potentially challenging grid reliability and Monticello because they could not do reviews fast enough in order to support the needed power generation requirements that Monticello has. MR. PATEL: Any bet on diesel generators?

MR. HAMMER: No, the diesel generator loads are not changing.

We're staying with the exact same loads in the diesel genera tors. It's let's assume at this point in time. MR. PATEL: Any impact other than what you have identified on any DC or AC systems? MR. HAMMER: Well, we got in some problems last time when we were all talking about DC systems for example. The only impact on DC systems is really the control logic for the 4 kV changes. You know we've got DC power that feeds the control logic switch operations and really operations on the existing 4 kV buses. That will change when we go to new 13 kV buses. Our judgement is those loads should decrease.

They should drop wi th EPUs. So the DC impacts are very, very minimal and probably bounded by the current analysis.

The AC stuff that we're changing, as I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 53 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 pointed out the existing 4 kV buses don't have enough margins. So what we'll do is we'll have breakers and we'll have much more significant volt interrupt readings.

We're very low on margins in that also. And we're also talking about moving some selected motor patrol centers around in the plant and the goal of all of those changes is to improve the margin of the in house distribution system so that we have more margin on the existing in house distribution system. Right now there is fairly tight margins in a number of locations.

MR. PATEL: Okay. MR. MATHEW: Okay so, number four submittal, you will be submitting all of them in the morning. One submittal, not like the two state MR. HAMMER: Yes, right we'll have one submittal that covers total operations.

There will be no limits on that submittal at this point. MR. PATEL: This is Nitin Patel. Regions, are there any questions?

MR. BOZGA: No. MR. PATEL: On EQ and grid? MR. BOZGA: No. MR. PATEL: Okay. MR. HAMMER: Yes, the other issue that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005*3701 www.nealrgross.com 5 10 15 20 25 54 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 have --another area that MR. PATEL: Thank you very much. MR. HAMMER: that was part of the acceptance review issues was the instrument setpoint calculation methodology.

Monticello employees and NRC approved GE setpoint methodology.

Setpoints are calculated from the analytical limit and margins are calculated between the analytical limit and the allowable value, and between the allowable value and the nominal setpoint.

MR. MAZUMDAR:

Question, I am Subinoy Mazumdar from Instrumentation and Controls.

Now, you have used the term margin. Margin normally means added tolerance.

We normally use the term tolerance.

So you mean here tolerance or accuracy? (No response.)

MR. MAZUMDAR:

Margin normally means extra fat in the system. Not the current one. MR. HAMMER: Maybe the easiest way to respond to that is we did make a lot of these issues were addressed at the same set of questions were addressed for our PRM submittals.

So, there is a September 16, 2008 which RAI responds on the PRM submittal and that provided a sample calculation that showed our typical approach.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 55 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. MAZUMDAR:

We don't call it margin there. We call it accuracies or tolerances.

MR. HAMMER: That's probably a more correct MR. MAZUMDAR:

Yes. MR. WILLIAMS:

From a project principle statement I agree. If we're talking this instrument setpoint calculation the margins we're referring to are a little bit broader than what we're discussing here. MR. MAZUMDAR:

Right, right. MR. HAMMER: The AL/AV margin or tolerance, probably I should point out that's probably more of an appropriate term, includes measuring accuracy, primary element to accuracy, instrument look back or see the calibration errors. The allowable value and nominal trip setpoint tolerances include loop accuracy under calibrated conditions, calibration errors and drift errors. MR. MAZUMDAR:

In this case also some of the tolerances you are repeating them in both the cases. And I think from allowable value to nominal trip setpoint the loop accuracy should not be there. MR. HAMMER: Yes, the only response I've NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 56 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 got at this point in time --I'm not necessarily an expert in setpoint methodology, but this as I pointed out as we are consistent with a GE setpoint methodology program. MR. MAZUMDAR:

No, all right. MR. HAMMER: Okay, next. In our extended power uprate transmittal there's two setpoints that are calculated that are associated wi th this response.

The analytical limit to nominal trip setpoint one contains all errors and is equivalent to the limited trip setpoint in RIS 2006-17. The nominal trip setpoint two is calculated at 98 percent confidence that the allowable value is not exceeded during testing. And this is consistent with what was provided with MR. MAZUMDAR:

On that 90 percent we normally insist on 95 percent. MR. HAMMER: Okay, the final setpoint is selected to satisfy both nominal trip setpoints one and nominal trip setpoint two and is equivalent to the nominal setpoint in RIS 2006-17. Continuing on with the methodology.

Examples of as found and as left tolerances are included in set calculations.

As I mentioned one example of the sample calculation was provided in our NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 57 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 PRNM response from September 16th of this year. And our intention right now is to use that same example for most of the EPU MR. MAZUMDAR:

Do you have that calculation?

MR. HAMMER: We have that, yes we have that. MR. MAZUMDAR:

I have not --because Hukam Garg was working on it before. I have not seen that calculation.

MR. HAMMER: The MNG procedures require shift manager determination of immediate applicabili ty if an instrument is found to be out of tolerance.

The condition is entered into corrective action process. MR. MAZUMDAR:

When you say out of tolerance which one you are talking about because there are three numbers. As found tolerance, as left tolerance, and the nominal values? MR. HAMMER: We are not within as found tolerance.

The requirements of our program include notification of management to consider the impacts of that. And the shift manager will get involved with that. MR. MAZUMDAR:

What about if you cannot set it within there as left tolerance?

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 58 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. HAMMER: If you can't set it within the as left tolerance some will set it. The conditions entered into the corrective action process of the as found tolerances exceeded and all setpoints are reset to the nominal trip setpoint within the as left tolerance calibration.

The deviations with that would be covered by the corrective action process with the full operations.

MR. MAZUMDAR:

You will go by writing out this 493 is not approved.

So we will not review anything against that. MR. HAMMER: Right. MR. MAZUMDAR:

But once that is approved you will abide by that? MR. HAMMER: Yes. MR. WILLIAMS:

And I can answer that. In the past submittals, not just EPU, but in the past submittals from Monticello we've said exactly that. We recognized that the TSTF 493 is still under negotiations.

We've added in the past a commitment that says when it's approved we'll meet the conditions associated with it. MR. HAMMER: One thing that might actually be helpful to us is you said you weren't aware of the NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234*4433 WASHINGTON, D.C. 20005*3701 5 10 15 20 25 59 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 September 16, 2008 PRNM submittal.

The response to the questions from the acceptance review from EPU are very largely to be based on that submittal.

We're going to point to that submittal for essentially all of our responses.

What we will do is the evaluation of LSSS. We'll be covered for EPU by itself. But all of the other aspects and how we control within our process and the sample cut we're going to point to that previous submittal.

So it might be helpful to us if you would take a look at that and then see if that meets your requirement.

MR. MAZUMDAR:

Hukam would look into. Peter, Hukam has that one, right? MR. TAM: Pardon me? MR. MAZUMDAR:

The September 16th submittal.

MR. TAM: Yes, we have it. MR. MAZUMDAR:

Hukam has that? MR. TAM: Huh? MR. MAZUMDAR:

Hukam has that. Hukam is out, but you have it right. You don't know. Any way, it has come and somebody in our branch will review it. MR. TAM: Yes, somebody in your branch is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 60 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 reviewing it. MR. MAZUMDAR:

Okay. MR. TAM: I just don't remember the name of that person. MR. H.AMlYIER:

And you know, if you have any issues with that type of stuff if you'll let us know we'd appreciate it. Okay, the last issue is changes to the LAR. As we noted here we have three general issues wi th the non-acceptance items. That was a steam dryer, EQ, and insulation issues. Those are being addressed in the revision of the LAR. The acceptance of the review questions are being docked. So the questions that we had during the acceptance review process the last time around we are capturing those in enclosure 16 we're pointing to those as a means of addressing some of those issues at this point in time. The acceptance review questions that were not docketed, which is the three open issues in EQ, steam dryer, and the pi tista stuff, those are in enclosure 17 and we'll provide a separate response for those in enclosure

17. Industry RAIs is one of the comments that came from the staff the last time is the staff stated NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 61 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 that in the acceptance review process is your standard is that you'd like to see that all industry RAIs from recent sites have been evaluated.

So, what we did is we didn't review Hope Creek assessment RAI until we looked at actually four si tes with the goal of trying to verify that the submittal had enough detail ln it to be able to respond to the questions that we raised at those sites. That resulted in US identifying 25 areas that were enhanced to varying extents to address those recent RAIs. So that is also one of the changes that we're making. The steam dryer submittal is being enhanced.

There was an enclosure in the previous submittal that covered the steam dryer. That will be updated to show the new steam dryer results and as we pointed out in the grid stability summary there was enclosure that discusses grid stability issues in the last panel. That will be revised to reflect the completion of the entire grid stabili ty study for this license amendment.

So, that's the changes that we expect to provide in the license amendment at this point. And wi th that now I'd like to turn it back over to Al NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 62 Williams to discuss schedule.

MR. WILLIAMS:

Okay, the NRC has seen a revision of this schedule before. Listed up top are the viewing outages that Monticello has. We're on a two year cycle. The next outage is in March of 2009 followed by 2011. As we discussed we'll be doing some set of mods in the 2009 outage so that we can do a partial implementation or partial power uprate during that cycle. And we'll complete the modifications in 2011. There is an independent submittal in with the NRC. We've made reference to it. The power-range nuclear monitoring submittal has been with the NRC since February for review. We've asked for that for implementation in 2009 to allow us to install that during the outage. It also shows the schedule that we've gone through. In March we submitted a EPU at 1870 and then withdrew.

You see our proposed schedule for the EPU evaluation of 2004. We are projecting approval of that in early 2010 at which point we will --once we gain approval we will implement partially the extended power uprate. There is an additional submittal that will likely be provided to the NRC after EPU approval.

NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005*3701 5 10 15 20 25 63 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 That's MELLA+, MELLA+ and DSS-CD. It is our intent to submit that after EPU has been approved.

I would characterize that submittal as not required for EPU, but rather to again provide us some operating margins at the 120 percent power levels. So, we do intend to submit power plus some time at the end of the first quarter or the second quarter of 2010 and when that's --we recognize that we will be the first plant to show about a year review. We're hoping that we can work with the staff to achieve that. MR. ALEXION: A question on that slide. The DSS-CD stability solution what good is that? MR. WILLIAMS:

I'm going to let Steve do that. MR. HAMMER: DSS-CD has it's a different stability solution than the old PRN solution.

And what it is the way I would understand is it's something of a enhancement to the stabili ty solution three, the GE provisions.

And they haven't licensed that to this point in time. But, right now GE's proposed if you're going to implement MELLA+ then do that with DSS-CD. MR. ALEXION: Does that like pick up where option three resolved?

MR. HAMMER: Yes, it's basically a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 64 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 replacement of option three. So it's --and it's GE, it's their direction for the future. It's the same basic knowledge that their using wi th the PRNM system. But it's kind of an enhancement to that module. MR. ALEXION: Is that possibly a meeting for the EPU? MR. HAMMER: What we are doing right now, we are replacing the PRNM system. If you go with the PRNM system option three is the desired implementation solution for having PRNM system installed.

Right now we are at option 1B print and you know what since we're going and installing the PRNM system GE's standard with PRNM is option three. We could have stayed wi th the existing PRNM as an option 1B but that would have required a different set of modifications to the whole PRNM system. So since our plan was to have that installed in 2009 we're reflecting that system. MR. ALEXION: That's currently under review with the staff. MR. HAMMER: That's currently under review. MR. ALEXION: If that was to happen --if that review was to be delayed would that effect the EPU? NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 65 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 MR. WILLIAMS:

No, that's where we could go to the other set of modifications.

PRNM is not required for EPU's, it's preferred.

We could implement a different set of modifications to our existing components which would allow us to join the committee.

We do not want to go that way for the simple reason that the PRNM system is in reality a better system. So, that's our intent. MR. HAMMER: Plus there are some major issues with the PRNM system. This is a good change. MR. MAZUMDAR:

Could I ask one more. You have any set limit except points? MR. HAMMER: Do we have --no, for EPU, no our screen shows that we will not have safety limit. MR. WILLIAMS:

Any other questions on that? (No response. ) MR. WILLIAMS:

The final slide in summary we do intend to submit our license amendment request early in November 2008. Our submittal target is November 1st. However, soon after setting November 1st as the target I notice that it was a Saturday.

So, November 3rd will likely be the date that you see our submittal.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 5 10 15 20 25 66 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 It does address specifically the prior items that have been discussed between the industry and the staff and you'll see that in a separate enclosure in the LER. And also considers any response to where they are applicable RAIs from previous EPU submittals.

So, we believe we've addressed in summary, we believe we've addressed the items in the letter. We have addressed the RAIs. There was a fairly small subset of items that didn't get specifically addressed from previous points and we've corrected the independent system operator issue which was a significant discussion topic between the staff and Monticello.

So, we believe you are going to see a submittal that meets and responses to all the issues we had in the previous one. So we're hopeful we can work with the staff to get this approved and the time frame has never been set by the processes.

with that I'll open it up to any questions.

MR. TAM: Let me ask the NRC staff, whoever is in the meeting. Do any of you have a caucus? MR. MAZUMDAR:

I don't have any. MR. TAM: So we can stop the caucus. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w. (202) 234-4433 WASHINGTON, D.C. 20005*3701 www.nealrgross.com 5 10 15 20 25 67 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 don't have too many of us left here. I think we have communicated our messages.

As I said before we have a full transcript and if you want us to clarify anything after the meeting, after you look at the transcript you can call us and we can hold some phone calls. Understand we are very close to the submi ttal date. But still if you can address anything before you submit I think it will still be best. MR. SALAMON: Did we miss anything in the presentation.

Any areas of concern? MR. TAM: Hearing none we --are you a visitor or are you with MR. KOK: I'm from Structural Integrity, I'm a contractor.

I'm working for MR. TAM: Oh, so you're working for them. So you're with them, all right. So we don't really have any observers of the meeting. Before we adjourn the meeting I have the usual NRC public meeting feedback form. So for those who are interested please fill out the form and mail it back. For some reason the address, NRC address is not complete.

But you can see the NRC return address and try to complete it at the bottom. All NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 5 10 15 20 25 68 1 2 3 4 6 7 8 9 11 12 13 14 16 17 18 19 21 22 23 24 right, or you can just give it to me. Any seconds or any other things to say. Region III, do you have anything to say? MR. BOZGA: No, thank you Peter. MR. TAM: All right. MR. HAMMER: Thank you for all of your time and consideration.

We appreciate your feedback and MR. TAM: I apologize for our physical facility giving us all kinds of problems today. But, we overcame it. MR. WILLIAMS:

Thank you all again. MR. TAM: All right, so this meeting 1S adjourned.

MR. BOZGA: Thank you. (Whereupon, the meeting was adjourned at 10:35 a.m.) NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., (202) 234-4433 WASHINGTON, D.C. 20005-3701 CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: Monticello Plant Name of Proceeding:

Meeting with Northern States Power Company Docket Number: (n/a) Location:

Rockville, Maryland were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. Official Neal R. Gross & Co., NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE, (202) 234-4433 WASHINGTON, D.C 20005-3701

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