488th Advisory Committee on Reactor Safeguards - December 5, 2001 - Morning Session

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               488th Meeting - Morning Session

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Wednesday, December 5, 2001

Work Order No.: NRC-132                                Pages 1-74

                   NEAL R. GROSS AND CO., INC.
                 Court Reporters and Transcribers
                  1323 Rhode Island Avenue, N.W.
                     Washington, D.C.  20005
                          (202) 234-4433.             UNITED STATES OF AMERICA
                     + + + + +
                   488th MEETING
                  MORNING SESSION
                     + + + + +
                 DECEMBER 5, 2001
                     + + + + +
                ROCKVILLE, MARYLAND
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                 The Advisory Committee met at the Nuclear
           Regulatory Commission, Two White Flint North, Room
           T2B3, 11545 Rockville Pike, at 8:30 a.m., Dr. George
           E. Apostolakis, Chairman, presiding.
           GEORGE E. APOSTOLAKIS      Chairman
           MARIO V. BONACA            Vice Chairman
           F. PETER FORD              Member
           THOMAS S. KRESS            Member-at-Large
           DANA A. POWERS             Member
           STEPHEN L. ROSEN           Member
           WILLIAM J. SHACK           Member.           COMMITTEE MEMBERS:
           JOHN D. SIEBER             Member
           ROBERT E. UHRIG            Member
           GRAHAM B. WALLIS           Member
           JOHN T. LARKINS
           PAUL A. BOEHNERT
           CAROL A. HARRIS
           HOWARD J. LARSON
           .                                 I-N-D-E-X
           AGENDA                                          PAGE
           Opening Remarks by ACRS Chairman . . . . . . . . . 4
           Dresden and Quad Cities Core Power Uprate. . . . . 5
           .                           P-R-O-C-E-E-D-I-N-G-S
                                                    (8:30 a.m.)
                       DR. APOSTOLAKIS:  The meeting will now
           come to order.  This is the first day of the 488th
           Meeting of the Advisory Committee on Reactor
           Safeguards.  During today's meeting, the Committee
           will consider the following:  Dresden and Quad Cities
           core power uprate, discussion of topics for meeting
           with the NRC commissioners, risk-informed 10 CFR Part
           50 Pilot Program, Option 2, and proposed ACRS reports.
                       A portion of this meeting will be closed
           to discuss General Electric nuclear energy proprietary
           information applicable to Dresden and Quad Cities core
           power uprate.
                       In addition, the Committee will meet with
           the NRC commissioners to discuss matters of mutual
           interest.  This meeting is being conducted in
           accordance with the provisions of the Federal Advisory
           Committee Act.  Dr. John T. Larkins is a designated
           federal official for the initial portion of the
                       We have received no written comments or
           requests for time to make oral statements from members
           of the public regarding today's sessions.  A
           transcript of portions of the meeting is being kept,
           and it is requested that the speakers use one of the
           microphones, identify themselves, and speak with
           sufficient clarity and volume so that they can be
           readily heard.
                       I bring the members' attention to the
           items of interest handout, which contains four
           speeches by the commissioners, two on nuclear security
           issues by Chairman Meserve, one on the future of
           radiation protection by Commissioner Dicus and one by
           Commissioner Diaz on predictability and balance.
                       Our first item is the Dresden and Quad
           Cities core power uprate, and Dr. Wallis will lead us
           through this.
                       DR. BERG:  Mr. Chairman, I think Dr. Ford
           would like to make a comment first.
                       DR. APOSTOLAKIS:  Dr. Ford.
                       DR. FORD:  Since I have a --
                       DR. APOSTOLAKIS:  Microphone.
                       DR. FORD:  Since I'm a GE retiree, I have
           a conflict of interest on this topic.
                       DR. APOSTOLAKIS:  So noted.
                       DR. WALLIS:  Well, the Committee will
           remember that we discussed this matter at our last
           meeting, and the Committee had a few questions that
           remained unanswered.  And we also wanted to hear the
           resolution of the outstanding issue regarding large-
           scale tests.  And we hope to be satisfied with what we
           hear today regarding those matters.  So I think we're
           going to start with the staff, then we'll move on to
                       MR. MARSH:  Good morning.  My name is Tad
           Marsh, and I'm the Deputy Director of the Division of
           Licensing Project Management at NRR.  We're here today
           to brief you on the open item on the draft safety
           evaluation, the extended power uprate for Dresden and
           Quad Cities.  The issue specifically before us is the
           large transient tests and the recirc runback test. 
           These items were discussed with you previously at the
           last full Committee meeting, and we have reached
           resolution on them.
                       Specifically, the issue was a proposal by
           the Licensee to not conduct the generator load reject
           test and the main steam isolation valve closure test
           as described in ELTR1.  In addition, per your request,
           we are also here to discuss with the recirc runback
                       Now, if you recall, during the last
           meeting, we had indicated that we were not able to
           discuss these open items with you, because it was
           still being evaluated by the NRR staff and by senior
           management.  This decision that we were pondering at
           that point we have now made, and it was a significant
           decision with both pros and cons.  And we wanted to
           make sure that we had a solid basis for our
                       We've completed our evaluation of the
           Licensee's proposal to not conduct the large transient
           tests, and we've concluded that it is an acceptable
           proposal.  Our conclusion is based on the scope and
           the extent of the modifications that are being made to
           support the power uprate, the numerous tests that the
           Licensee is proposing to perform at the system and
           component level, evaluations of the systems and
           components that are important to the tests under
           consideration and the safety benefit, or lack thereof,
           from these large transient tests.
                       I'd like to emphasize that the decision
           that we're making is associated only with Dresden and
           Quad Cities.  It's not a generic decision that we're
           making.  We will be considering other power uprate
           applications on a case-by-case basis with respect to
           these tests.
                       DR. POWERS:  Tad, are you laying out
           something so that an applicant can reasonable
           anticipate what he should have to do in order to avoid
           having to do the integral tests or is it really a case
           by case sort of thing?
                       MR. MARSH:  Dr. Powers, I think the safety
           evaluation lays out the staff's considerations for
           both the pros and for the cons, and I believe the
           Licensee, in reading the safety evaluation, will see
           the elements that we used in coming to that conclusion
           so that they would know how to apply or what to do.
                       DR. POWERS:  I guess maybe licensees are
           more prescient than I am, because I think I would have
           a hard time saying, "Okay, if I do this, this and
           this, I have high confidence that I will not have to
           do this test."  I think I'd have a hard time doing
                       MR. MARSH:  Okay.  Let's go through the
           presentation.  You hear the considerations, and I
           believe you'll hear a lot of the elements that we did
           that we evaluated that I think would guide licensees. 
           You're going to hear agreement, to a large extent,
           with the specific proposals that were made.  And
           you're going to hear what these tests do and don't do,
           okay?  So to that extent, the plant-specific
           evaluation may be broader than just this particular
           Plant; it may be.  But we wanted to leave ourselves
           some room in case systems, structures, components,
           trips were added to the Plant, which would guide us in
           another way.
                       We've also evaluated the Licensee's
           proposal to not conduct the recirc runback test, and
           we'll be discussing that with you today.
                       Let me now introduce the presenters. 
           Mohammed Shuaibi on my far right will be -- he was the
           Lead Project Manager for Power Uprate -- will be
           talking about the tests, the large transient tests. 
           Also, Stew Bailey, who is to my immediate right here,
           who is the Project Manager for Quad Cities, will be
           presenting the staff's evaluation for the recirc
           runback tests.
                       If no further questions, we'll start with
           the presentation.  Mohammed?
                       MR. SHUAIBI:  Good morning.  My name is
           Mohammed Shuaibi, and I'm going to cover the large
           transient testing, as Tad said.  The tests under
           consideration are those included in ELTR1.  These are
           the load rejection tests and the MSIV closure test. 
           As you know, the load rejection test is included in
           ELTR1 for power uprates greater than 15 percent.  The
           MSIV closure test is included for power uprates
           greater than ten percent.
                       As I'm sure you're aware, the Licensee
           referenced ELTR1 in their application; however, they
           proposed to not do these tests, which are included in
           ELTR1.  So, in effect, what we have is a proposed
           deviation from an approved topical report.
                       The Licensee provided a justification for
           this deviation.  Since the Licensee covered its
           justification in detail during the last few meetings
           with the ACRS, I'm only going to summarize what they
           said.  First, the power uprate is being achieved while
           maintaining a constant steam dome pressure.  This is
           called the constant pressure power uprate -- I'm sure
           you've heard that term before.  Because the steam dome
           pressure is not changing, the effect of the power
           uprate on the Plant is significantly reduced.  This
           also led GE to conclude that these tests are not
           necessary for constant pressure power uprates.
                       DR. POWERS:  When GE put together ELT
           whatever 1, they thought they were necessary.
                       MR. SHUAIBI:  That's true.
                       DR. POWERS:  What caused them to change
           their mind?
                       MR. SHUAIBI:  Basically, ELTR1 covers
           different ways that you could achieve the power
                       DR. POWERS:  That's right.
                       MR. SHUAIBI:  It allows plants to increase
           pressure.  It's not limited to constant pressure power
           uprates.  Also, at the time -- this was back in 1995
           and 1996.  At that time, they had no experience with
           these major power uprates.  And I'm not here to tell
           you that they have significant experience now --
                       DR. POWERS:  They don't have much
           experience now either.
                       MR. SHUAIBI:  Right.  But they do have a
           couple of data points.
                       DR. POWERS:  Which --
                       MR. SHUAIBI:  Which I'll be covering a
           little bit later in terms of how we evaluated that. 
           That's not the basis for our conclusion.
                       DR. POWERS:  You mean GE just said, "Gee,
           we were wrong, we don't need these things anymore"?
                       MR. SHUAIBI:  I think they looked at the
           effects of the power uprate, of a constant pressure
           power uprates on the Plant.  And, basically, they were
           convinced that they were able to model the Plant
           without having to do these tests for confirmation. 
           They were convinced that they can do that.
                       MR. MARSH:  I want to point out there's
           also a proposal before the staff, a modification to
           the licensing topical report to not do these tests,
           which is under staff consideration too.  So I believe
           their thinking has evolved --
                       DR. POWERS:  What I'm trying to understand
           is why their thinking evolved.  I mean somebody said,
           "Gee, GE, this costs us a fortune to do these tests. 
           Change your mind"?
                       MR. SHUAIBI:  I guess, maybe if I could go
           through our presentation, we could tell you why we
           came to our conclusion.
                       DR. POWERS:  Right now I'm trying to
           understand -- I mean if we don't understand why GE
           changed its mind, just say so.
                       MR. SHUAIBI:  We have asked several times
           GE for why it was proposed and what changed that would
           -- you know, what changed since then.  And, basically,
           it is that it is a constant pressure power uprate and
           that the effect of the constant pressure power uprate
           is not that significant on the Plant.  I believe GE is
           here, and they want to talk to this.
                       MR. KLAPPROTH:  Yes.  This is Jim
           Klappworth from GE.  Let me just reiterate, I think,
           Mohammed's statements.  I think that's exactly the
           situation we're in.  When we first came in with the
           ELTR, that approach allowed a pressure increase or no
           pressure increase, and at the time we did not have a
           lot of experience with the extended power uprates, so
           we proposed the large transient testing at that point
           in time.  Since that time, we have evolved in our
           power uprate process and evolved to the CPPU, the
           constant pressure power uprate process.
                       In addition, there's been several plants
           that have done testing -- KKM, KKL -- and we have some
           transient test results from Hatch.  So we have some
           actual plant data that we've been able to actually
           model after the fact and also predict before the tests
           are run.  So we have high confidence that there is no
           need to do the large transient testing.  We don't
           really gain that much from these testings under a
           constant pressure power uprate scenario.
                       DR. POWERS:  What was the rationale for
           having the proposal -- I mean when -- I can never
           remember the acronym -- ELTR1 came in, it considered
           both pressure increases and no pressure increases, but
           the testing was for both.  And there must have been
           some reason for lacking the confidence.
                       MR. KLAPPROTH:  Again, at that time, we
           had no direct experimental test results or predictions
           at that point in time.  We had just started the
           extended power uprates.  And we did not differentiate
           in the ELTR1 between a no pressure and a pressure
           increase power uprate.
                       DR. POWERS:  Trust me, I know that's true. 
           A mystery.
                       MR. SHUAIBI:  Well, maybe -- again, maybe
           we could cover what we evaluated when we through the
           Licensee's proposal, and maybe that will explain, at
           least, how we came up with our conclusion for Quad
           Cities and Dresden again.  We'll be evaluating this on
           a case-by-case basis for the other plants.
                       Okay.  Moving on, the Licensee also stated
           that these tests will not provide new information
           about transient model --
                       DR. WALLIS:  That's a strange conclusion. 
           I mean every time you run a test you might find
           something happens that you were surprised by.  So you
           can never say that a test will never give you any new
                       MR. SHUAIBI:  That is true, Dr. Wallis. 
           I think what I did here is I'm trying to present --
           summarize what the Licensee presented, but I totally
           agree with you.  Any time you run a test, you will
           gain some information, even if it's confirmation that
           you did things correctly.  So there's additional data
           that gets collected, and that is some new information. 
           And if surprises occur, then, yes, you're right.
                       DR. WALLIS:  Then you'd have to use a
           different argument, saying that the expected small
           amount of information to be gained is not worth the
           risk or some task --
                       MR. MARSH:  We're going to get there. 
           We're going to get there.
                       MR. SHUAIBI:  And that is in our
           evaluation.  I'm just summarizing what was presented
           to you before.
                       DR. WALLIS:  But if they made statements
           like that, they're very suspicious statements.
                       MR. SHUAIBI:  Again, once I get to our
           evaluation, you'll see those statements a little
                       DR. WALLIS:  Okay.
                       MR. SHUAIBI:  Okay.  Also, they stated
           that experience with power uprate shows that GE is
           able to predict Plant response following power uprate
           in an acceptable manner, and they provided some
           information related to that.
                       DR. WALLIS:  That means acceptable
           prediction of previous similar tests; is that what it
                       MR. SHUAIBI:  In some cases, it's previous
           similar tests; in other cases, although it was not GE
           that analyzed the transients, they were plant
           transients at Plant Hatch in which no significant
           surprises or no surprises related to power uprates
           were identified.
                       In addition, predictions were made for the
           Dresden and Quad Cities Plants, and the predictions
           showed that no significant change will result from the
           power uprate.
                       And, lastly, the Licensee evaluated
           components important to the transient tests under
           consideration, again, the load rejection test and the
           MSIV closure test, and they concluded that testing is
           not necessary based on the effect of the power uprate
           on those components.
                       And to summarize the Licensee's
           conclusion, based on its evaluation, the Licensee
           concluded that no significant information is expected
           to be gained by performing these tests, and that from
           a risk and safety perspective, unnecessary Plant
           transients should not be induced without a
           commensurate benefit.
                       DR. WALLIS:  They didn't actually make
           some evaluation of the risk and benefit, did they? 
           They made a qualitative argument.
                       MR. SHUAIBI:  They did provide some risk
           information related to performing the task; however,
           it's, I believe, hard to quantify the benefits of the
           test.  But they did provide risk information -- you
           know, the risk associated with performing the test. 
           And we looked at that.
                       Okay.  Moving on to our evaluation of what
           was presented.  The staff evaluated the Licensee's
           request and justification for not doing these tests. 
           First, we considered the scope and extent of
           modification made to the Plant.  We found that the
           major modifications are basically on the secondary
           systems, not on safety systems.
                       Next, we examined the effect of the power
           uprate on the Plant.  Basically, the power uprate will
           result in an increase in power level, obviously, and
           decay heat; increase in steam flow and feed flow, I
           think those numbers were presented as about 20
           percent; decrease in pressure and temperature at the
           turbine inlet, that's a small decrease, I think it's
           less than five percent; and an increase in loading on
           some of the electrical equipment.
                       We then considered the testing that the
           Licensee is planning to perform.  The Licensee's power
           ascension and test plan includes hold points at 50
           percent of the pre-EPU power level, at 75 percent, at
           90 percent and at 100 percent.  The Licensee will
           conduct testing and collect data related to steady-
           state Plant response.
                       In addition, after reaching 100 percent of
           the pre-EPU power level, the Licensee will increase
           power in increments of less than or equal to five
           percent, as recommended in ELTR.  I believe they
           stated at the last meeting that they'll be doing that
           in three percent increments.
                       They will perform additional testing and
           collect more data at each increment, at each increase
           in power to ensure that the Plant is behaving the way
           that they expect it to.  What they'll be doing, too,
           is they'll be projecting new values for some of these
           parameters for the next increment in power level and
           making sure that they're able to predict that.
                       The kind of testing and data collection
           includes vibration, system equipment performance,
           feedwater pump run-out, fuel delta P, and these are
           just examples of the kinds of things that they're
           going to be doing.
                       In addition, the Licensee's performing a
           significant amount of system and component level
           testing.  In addition to post-modification testing,
           the Licensee is testing systems and equipment whose
           performance requirements have changed as a result of
           the power uprate.
                       DR. BONACA:  I need to ask a question. 
           Are these tests part of start-up testing when the
           Plants were being built, so they were standard start-
           up tests?
                       MR. SHUAIBI:  Yes.  So are the load
           rejection tests and MSIV closure tests, though.
                       DR. BONACA:  I mean the question seems to
           be there should be, on the part of GE, some objectives
           that they had regionally that they wanted to achieve. 
           And whether or not the power uprate is so significant
           that it is almost like a new plant that you have to
           do, because I think if it is almost as a new plant,
           then you would say you want to have one.  If it isn't,
           understand the reasons why.  But I just was wondering
           again if we could get more insights from GE regarding
           the original objectives of those tests as part of this
           sort of testing.
                       MR. MARSH:  Care to comment?
                       MR. KLAPPROTH:  I guess at this point --
           this is Jim Klapproth again from GE -- just to
           reiterate the original thinking at the ELTR stage,
           and, again, that was back eight, ten years ago, our
           thinking has evolved, and I guess I really can't
           comment any further as to this issue, other than the
           fact that we have learned, we've been able to model
           these events, we've been able to predict these events
           very well.
                       In fact, back when we were here with the,
           I guess the Subcommittee in June of this year, we
           presented the results of the KKM test.  I'm not sure
           if it was KKM or KKL.  It was a KKL test, and we
           showed that we were able to model these events very
           well.  So based on that predictive capability and the
           additional Hatch test and the fact, again, that the
           Dresden/Quad Cities power uprate is a zero pressure
           increase power uprate, we feel there's no need for
                       DR. BONACA:  I understand.
                       MR. MARSH:  Well, from the standpoint of
           the original purposes of the test, and that is why the
           staff wants these tests to be done originally, it is
           as you say.  This is part of the start-up testing
           program.  When there is a new plant that's been
           constructed with new systems, new structures, new
           components, new electronics, new trips, new integrated
           operations that you want to verify, it is important to
           run these tests up to a certain point, which is
           normally the full power point.
                       The question is when you increase power by
           a certain point, does it raise questions about those
           system structures and components, trip set points to
           the extent that you need to run an integrated system
           test?  In our judgement, it does not.
                       And that's the -- we looked at the safety
           benefit that you would achieve from doing this test,
           whether there's enough questions that would be raised
           and answered by this power uprate, and we've come to
           the conclusion that there is not.  There's enough
           testing that's done reaching going up to the new full
           power level to flush any types of weaknesses that
           would occur.
                       DR. BONACA:  I understand.  I was asking
           the question because if in fact we had some memory of
           what the original objectives were, regarding the very
           points that you made -- instrumentation --
                       MR. MARSH:  Exactly.
                       DR. BONACA:  -- then one could, you know,
           pretty well evaluate why a power uprate of 20 percent
           or 30 percent, or whatever it's going to be, is really
           necessary, because -- but, I guess, we don't have now
           a detailed --
                       MR. MARSH:  If the Plant were modifying
           itself in some fundamental way, that is adding new
           trip features, if it were challenging limits in some
           fundamental way or if there were code prediction
           questions, such that we were unsure that ODYN's
           capability to predict how the Plant would perform, I
           think we'd be at a different place.
                       DR. BONACA:  Okay.
                       MR. ROSEN:  Well, using that exact logic,
           Tad, I would conclude that the recirc runback test
           fits that, that you ought to run them, because it's
           new systems and new equipment.  I mean it fits exactly
           to use that logic.  So help me through why even if
           that logic applies to the large transient test, but if
           applied to the recirc test, it would seem to lead you
           to a different conclusion than I anticipate you'll
           tell us in a minute.
                       MR. MARSH:  Can I leave us to that point
           to lead us through that logic, rather than diverting
           at this point?
                       MR. ROSEN:  But just park that thought.
                       MR. MARSH:  Okay.
                       MR. ROSEN:  I mean I think you just made
           an argument for the recirc runback test.
                       MR. MARSH:  Okay.
                       MR. SHUAIBI:  Okay.  We also evaluated the
           effect of the power uprate on mechanical and
           electrical components important to the tests under
           consideration.  We looked at the effect on MSIVs, we
           looked at the effect on control rod insertion, relief
           and safety relief valve performance, turbine stop
           valves, turbine control valves, scram signal timing,
           turbine bypass systems, main generator, an on-class 1-
           E switch gear, unit aux transformer, reserve aux
           transformer.  We looked at all that to convince
           ourselves that in fact these tests are not needed and
           that the Licensee can justify and that we could accept
           this proposal.
                       Based on this evaluation, we concluded
           that the effects of the power uprate on these
           components are small.  Components are covered by other
           tests.  In cases, for example, of the MSIV, we have
           tech spec requirements that say that the valve must
           close no faster than three seconds, no later than five
           seconds, things like that.  Components are covered by
           other tests, and/or the effects are adequately covered
           in models used for the analyses.  In certain areas
           where there's no testing, we look to see, well, what
           do we normally expect in that area?  And we found that
           it's adequately covered in the modeling.
                       We also considered the need for performing
           these tests for code validation.  We do not need these
           tests for code validation.  As you know, analytical
           codes are validated using data from numerous test
           facilities and operational experience at other BWRs or
           at BWRs, in general, that bound proposed operation of
           Dresden and Quad Cities.
                       We then examined the applicability of the
           tests to safety analyses.  Obviously, these are real
           Plant transients that would happen.  Non-safety
           related equipment would be there to mitigate these
           events.  Anticipatory trips, which were discussed
           before, will be there to trip the Plant.  And all
           those reasons together, you know, these tests are
           going to be much more benign than the actual safety
           analyses.  So although, as Dr. Wallis said before, you
           would get some information, that information doesn't
           necessarily confirm that the safety analyses are done
           correctly.  We do those by other means.
                       We also considered power uprate experience
           presented by the Licensee.  The Licensee presented
           information related to Hatch, which was uprated to 113
           percent of the original rated thermal power, and the
           KKL Plant, which uprated to 117 percent of original
           rated thermal power.  I'd like to note, and I think we
           said this before, that we do not consider the
           experience at Hatch and KKL to be directly applicable
           to Dresden and Quad Cities.  Obviously, these Plants
           are not identical and the tests may have been done for
           different reasons.  For example, KKL, I believe, was
           a scram avoidance test, because they have different
           runback capabilities.
                       In addition, this experience alone would
           not be sufficient to approve the Licensee's request if
           all that they presented was the Hatch and KKL data. 
           We do not believe that we would be here today telling
           you that we accept this.  However, because of the
           implementation of similar modifications at those
           Plants to those that were done at Quad Cities and
           Dresden, we do believe that to some extent GE's
           ability to predict the effect of the power uprate on
           component performance is validated.  Again, it
           wouldn't by itself be sufficient, but we do believe
           that it's another data point that we could rely on.
                       To summarize our evaluation, we believe
           that the combination of system and component
           evaluation proposed and proposed testing at Quad
           Cities and Dresden is sufficient to satisfactorily
           demonstrate successful Plant modification without
           performing these large transient tests.  We believe
           that the benefits of large transient tests are not
           sufficient to justify the challenges to the Plant and
           its equipment, the potential risk associated with
           these tests and the burden.
                       We did not identify any safety concerns
           that would warrant the performance of these tests.  In
           addition, the Licensee's application meets all
           regulatory requirements without performing these
                       So based on our evaluation, we concluded
           that the value added of these tests at Dresden and
           Quad Cities is minimal, and therefore we accept the
           Licensee's proposal to not perform these tests.  And,
           again, I'll reiterate what Tad said earlier:  This is
           for Dresden and Quad Cities.  We'll be looking at
           other plants when they come in, or as we're reviewing
                       And that concludes my presentation on
           large transient testing.  I'll take any questions now.
                       MR. MARSH:  Dr. Powers, you asked a
           question whether licensees would know what the staff
           would find acceptable or not in terms --
                       DR. POWERS:  I think I'm still kind of at
           sea on this, because there's not a number, there's not 
           a quantification.  This is a sense sort of thing.
                       MR. MARSH:  Yes.  Our safety evaluation
           has in it a table, and the table talks about the
           components, the features of the Plant that are
           affected by or that would affect the test itself.  And
           it talks about the tests that are already on those
           structures and components, technical specifications or
           surveillances or how they're covered by the existing
                       That really forms, I think, the guidance
           to licensees about how we judged structures and
           equipment and its relevance to these tests.  And if
           plants had changed those structures and systems or if
           they were not tests, as we described in that table,
           then they would have to justify deviations from -- or
           justify not doing a test in that context.
                       DR. BONACA:  Why did you have to develop
           a table?  Why didn't the Licensee have to develop a
           table referring to the original tests explaining the
           basis so that you could support it or not?  I don't
           understand.  I don't understand.  The Licensee comes
           and says, "We don't want to do the test," and gives
           some words.  And now you are here developing a basis
           for it in your SER.
                       MR. MARSH:  Right.  And is your question
           why are we doing that?
                       DR. BONACA:  No, I'm saying why shouldn't
           it be part of the application?  I mean I don't have
           anything against not running the tests, but there is
           a lot of information licensees -- that GE developed
           originally to justify the tests, what the objectives
                       MR. MARSH:  Right.
                       DR. BONACA:  And if you take those
           objectives, you could probably, easily demonstrate
           that you don't need these tests by doing certain
           things.  Now, we haven't seen that.  All I hear is
           that the SER has a table -- and we haven't seen that
           either -- that explains these details that Dr. Powers
           is asking for and other licensees would want to know. 
           It seems like a reversal of roles.
                       MR. MARSH:  Well, the Licensee did provide
           information that -- you want to answer?
                       MR. HAEGER:  Well, in some sense -- my
           name's Al Haeger, I'm with Exelon.  We did provide a
           table in our submittal of the analysis of the
           components and how they're tested and why we believe
           that that covers the points that were made by the NRC. 
           So we did provide a table to them.  Now, we did not
           specifically talk about the original purpose of these
           tests.  We hadn't thought of that at the time.  Since
           then we have seen some other licensees start to do
           that.  But our submittal did provide a table of the
           components and how they're tested and why we believe
           the effects of EPU were minimal.
                       MR. SHUAIBI:  That was actually provided
           in response to an RAI, but, yes, they did provide a
           table.  I don't know if it's the same table that
           you're talking about, but they did provide a table of
           these components and what effect the power uprate has
           on these components and their evaluation of the
           effects and why it's not necessary to do these tests
           in order to confirm that.
                       DR. POWERS:  And the components in that
           table do get tested as we make these incremental three
                       MR. SHUAIBI:  Several ways that things get
           tested.  For example, the MSIVs know they're not going
           to be --
                       DR. POWERS:  Well, yes, but --
                       MR. SHUAIBI:  Yes.  There are several ways
           that components are getting tested.  Some have tech
           spec requirements, some are -- some data is being
           taken as they're going up in power.  And if you have
           one in mind, I could probably go through that with
                       MR. MARSH:  The table has in it, for
           example, safety relief valves.  Those aren't tested
           during this power ascension.  The point that's made in
           the table is that there's no change in set point to
           the safety relief valves, but there is a change in
           capacity.  We rely on more safety relief valves to
           open as a result of the increased power.  Turbine stop
           valves, the control valves are in that table.  There
           is some testing of that, but I don't believe it's done
           in increments on the way up.  There's some testing
           that's described in the table that you would do
           normally, and it's still contained in the
           requirements.  Can you remember the features that's in
           the table?
                       DR. POWERS:  I can assure you I do not
           remember the table.
                       MR. MARSH:  Okay.  The point we're trying
           to convey is staff looked at the safety benefit from
           these tests and found it was not sufficient safety
           benefit.  I don't want you leave with the impression
           that there's no benefit to tests.  There would be
           benefit to tests.  You'd get information, you could
           confirm.  There are reasons why these tests may be
           good to do.  And what the staff was faced with was
           trying to make a judgment about the merit, the
           usefulness of the tests compared to the safety benefit
           of the tests.  And the difficulty in the decision was
           there are some good arguments for doing these tests. 
           We had to look carefully at the safety benefit and the
           impact that you would be -- what you use these tests
           fundamentally for and how can you come to a
                       So we -- we're conveying to you the basis
           for making the decision, but I don't want to leave you
           with the impression that it was all that clear, that
           we ran to the decision because it was overwhelmingly
           so.  We had to very carefully consider the pros and
           the cons.  And the staff -- there are still members of
           the staff who think we should be doing these tests. 
           So I don't want to leave you with the impression that
                       DR. POWERS:  What is their argument?
                       MR. MARSH:  Well, let me give you some of
           the arguments.  First, it's consistent with the
           topical report.  Staff approved the topical report,
           and GE proposed doing these tests, so that formed an
           Agency opinion.  Okay?  Now, we can argue why it was
           proposed, the bases for it, why we're deviating, but
           it still formed an Agency opinion.  So that's the
           reason why.
                       It is a demonstration of integral Plant
           performance, which from a safety perspective you'd
           think that would be a proper direction to go.  But
           from the standpoint of what do you fundamentally
           challenge in this test, are you fundamentally
           challenging safety set points, are you challenging
           safety equipment?  You're not.
                       But you can see your conservative thinking
           leads you towards we should be doing a test.  And then
           we had to weigh carefully the impact, the benefit, the
           purpose, what you gain from it.  And we came to the
           conclusion that it was not necessary.  But we want to
           leave ourselves the thought that if something does
           change, if there's a system or a structure or if
           there's a code issue, we may have to.
                       DR. KRESS:  In making this judgment, did
           you run the analysis through the standard back fit
           regulatory analysis?  Is that the kind of judgment you
                       MR. MARSH:  Probably not, though some of
           the thinking may be there, but in the rigorous way. 
           It's a topical report, so you don't have to do that in
           that regulatory process.
                       DR. KRESS:  No, but it's a place where
           there are real criteria and real limits and
           cost/benefit levels that you can make judgments on. 
           And I just wondered if you actually went to a
           quantification of those things.
                       MR. MARSH:  We did not do that.  We did
                       DR. KRESS:  It's a judgement call.
                       MR. MARSH:  It's a judgment.  We did ask
           ourselves in terms of the four performance goals, our
           pillars, what are the merits and demerits of these
           tests from the standpoint of our four performance
           goals?  Does it increase safety?  Is it an increased
           regulatory burden?  Does it improve public confidence? 
           We asked ourselves those questions too.
                       DR. KRESS:  Trouble is the answer to those
           are qualitative.
                       MR. MARSH:  They are qualitative.  If they
           all aligned in a particular direction, that would
           guide you in a certain decision, but they don't.  They
           don't.  Some of them conflict.  And from the
           standpoint of safety, which is fundamental, we could
           not disagree with the Licensee's proposal from that
                       MR. ROSEN:  The two tests we're talking
           about are the generator load reject and the main steam
           isolation valve closure.
                       MR. MARSH:  Right.
                       MR. ROSEN:  You would agree, would you
           not, that those two occurrences are anticipated
           operational occurrences within the life of the Plant?
                       MR. MARSH:  True.  Yes, sir; they are.
                       MR. ROSEN:  So that in fact the Plant is
           going to run these tests one day.
                       MR. MARSH:  At Hatch.
                       MR. ROSEN:  And the only difference
           between doing it now and doing it then is that the
           Licensee and the staff get to choose the time of the
           test, rather than letting the Plant choose the time of
           the test.
                       DR. KRESS:  And you can set the boundary
           conditions a little better, I think.
                       MR. ROSEN:  Yes, and the Licensee could
           have additional staff available, additional monitoring
           equipment, management awareness --
                       MR. MARSH:  True.
                       MR. ROSEN:  -- could assure that no other
           activities are going on in the Plant at the time that
           could distract operators from their -- so we're going
           to have a tests, we just don't know when it's going to
                       MR. MARSH:  That's probably true.  Hatch
           had one, and in fact that's a part of the staff's
           observations, that the test was not required for
           Hatch, yet they had one.  And the Plant performed as
           it was projected to perform.  There weren't any
           surprises.  So you're probably right.  These are AOOs. 
           It's not a Condition 2 or a Condition 3 or Condition
           4 event, which are the big challenges to safety.  The
           issue is do you have to mandate when it's going to
           occur with all the bells and whistles that go with
           that and to what end?
                       MR. SHUAIBI:  To clarify that, we're not
           saying that Hatch did the test.  Hatch had an event. 
           They had several load rejection events.  And we went
           back and we looked at those, and there was really
           nothing of significance there that would tell us, you
           know, that these Plants ought to do the --
                       DR. KRESS:  What code was used to predict
           the results of these tests?  Is that a ODYN --
                       MR. SHUAIBI:  ODYN code, yes.
                       DR. KRESS:  And you look at ODYN code and
           say, "We know the parameters in there within a certain
           level of confidence, and if we run this test, it won't
           increase that confidence enough to say that the
           predictions would give me better confidence."  That's
           kind of the judgment type call you make.
                       MR. SHUAIBI:  Well, validation of the
           codes is done, like we said earlier, through --
                       DR. KRESS:  It's already done other ways
                       MR. SHUAIBI:  -- many, yes, other ways.
                       DR. KRESS:  -- so that gives you a certain
           level of confidence.
                       MR. SHUAIBI:  Right.
                       DR. KRESS:  And the only reason to run
           these other tests is to see if the code's missing
           something or to improve its confidence level.  And
           you're saying that the test just doesn't --
                       MR. SHUAIBI:  I want to add something on
           this issue.  I think we discussed this in detail in
           coming up with our conclusion here.  We do not
           believe, although it's been stated before by others,
           we do not believe that theses tests are necessary for
           the codes, and we did not ask that these tests be done
           for validation of the codes.  We have other ways of
           validating codes.  And we have a draft SRP and Reg
           Guide on all the kinds of things that you need to do
           to validate codes and how you would run plants within
           the boundaries established on those codes and
           correlations, et cetera.
                       These tests are really component response
           tests to ensure that these components that you're
           relying on are going to respond in a way that you
           expect them to.  So it's not a code issue; it's a
           component issue.  It's how you model the components
           when you run the codes.  Are you modeling them
           correctly?  Is the valve going to shut the way that
           you expect it to?
                       DR. KRESS:  I have trouble with separating
           that out as not being a code issue, but I guess --
                       MR. SHUAIBI:  Well, I guess, it's -- you
           know, there's the code issue of correlations and
           things like that, and then there is the modeling of
           the components that go into the decks that run the
                       DR. KRESS:  Well, I consider that's part
           of the code.
                       MR. SHUAIBI:  Okay.
                       MR. MARSH:  Jerry Wermiel is here from the
           Reactor Systems Branch.  Jerry, do you want to add
           anything to that?
                       MR. WERMIEL:  No.  I thought Mohammed did
           a -- this is Jerry Wermiel, Chief of Reactor Systems
           Branch.  I thought Mohammed's response was right on
           the mark.
                       MR. MARSH:  Okay.
                       DR. WALLIS:  The arguments for not doing
           the tests are that it challenges the Plant in some way
           so there's some risk involved?  Is there a risk of the
           equipment won't work so well the next time around
           because it's been through the test or something?  And
           then there's the burden.  Is that that they have to --
           they don't produce power for a period of time? 
           There's a cost?  How big are these things?
                       MR. SHUAIBI:  We didn't actually -- as we
           said earlier, we didn't actually go through the back
           fit process.  First, I think it would be very hard to
           quantify the benefits of this test.
                       DR. KRESS:  Yes, I don't know how you --
                       MR. SHUAIBI:  I mean regardless of whether
           it's code validation or anything else.  I mean you
           could probably get some estimates on cost, but what is
           -- that's the burden of this test.  But what is the
           benefit of this test?
                       DR. WALLIS:  No, look at the burden.  I
           mean there is some benefit and it's in public
           confidence, and here's a test which would suggest --
           which they propose to do, and if they had done it,
           they could say, "Well, we've gone out of our way to do
           the test, and we've got more confidence, which is good
           for public relations."
                       MR. SHUAIBI:  True, true.  But in doing a
           cost/benefit, you would need to look at both sides.
                       DR. WALLIS:  So what's the cost to them? 
           Is it that they don't produce power for some period of
           time?  Is that the big thing that makes them reluctant
           to do the test?
                       MR. SHUAIBI:  Well, I think in terms of
           burden -- and maybe they'd want to talk about this a
           little bit -- but what we looked at as being a burden,
           it's not just the fact that they're going to be down
           when they trip the Plant; it's they're going to be
           down, they're going to have additional staff that's
           going to be at the Plant, there's going to be a lot of
           evaluation of the data.  You don't run the test and
           come right back up.  We looked at all that in terms of
           burden, but that's only one aspect of it.  I mean I'm
           not here to say that because of burden we're not doing
           these tests.
                       There's a lot of stuff that we looked at
           that's convinced us that these tests are not
           necessary.  We looked at the equipment and how that's
           going to be affected by the power uprate.  We looked
           at -- and that's what we looked at to convince
           ourselves that it's not necessary.  And then we also
           looked at the burden, and we also looked at the risk
           associated with it.
                       I mean the risk argument is -- it's kind
           of -- it's pretty balanced on the risk side, because
           you could say that there's risk associated with it,
           but you can't come up with a definitive number that
           says, "But here's the benefit from it," so that you
           could compare it to.  I mean it's really qualitative
           in that.  So you have a number on the risk associated
           with it, nothing on the benefit.
                       So I think what we're here to say is we
           looked at the components and how they are affected by
           the power uprate.
                       DR. KRESS:  Have these tests been run at
           these Plants at the previous power level?
                       MR. MARSH:  I believe they have.  I mean
           I believe that's part of the start-up testing program. 
           Please refute that if that's wrong, but I believe
           that's part of the start-up testing program, the
           initial start-up testing program.
                       DR. KRESS:  So you have the equivalent of
           these tests at the old power level.
                       MR. KLAPPROTH:  We do have tests, and we
           do have transients.  I believe within the last two
           years we've had one of each of these at Dresden and
           Quad units.
                       DR. KRESS:  So you do have a lot of
                       MR. KLAPPROTH:  We do have a lot of
           information at the current power level.
                       DR. KRESS:  And so all you're doing is
           extrapolating to a new power level.
                       MR. KLAPPROTH:  Right.
                       MR. MARSH:  It leaves you with a question,
           though, and the question -- one of the questions, what
           is the original purpose of the test?  I think we've
           answered that.  But it leaves you with the question
           of, well, I've increased power by about 20 percent. 
           Suppose they increase the power by 30 percent or 40
           percent?  At what point would the staff say, "You know
           that's enough of a challenge to a system or enough
           questions about the code or enough issues about plant
           modifications that I want to run the test."  It leaves
           us with that question that's not answered.
                       DR. BONACA:  Well, that's exactly why I
           was going back to the original tests.  They were not
           done superficially, okay?  They were plants.  I
           remember the detail.  There were justifications,
           specific reasons why you're running the test.  And I
           just am surprised that that information hasn't been
           developed to justify why it's not being right now if
           the information is available.  Now, clearly, it's a
           long time since the last plant was started up, and
           maybe information has been lost, I don't know.  But
           something -- I mean that would have kept us from being
           here for a long time discussing it among ourselves
           what may be in the mind of the people who recommend
           that we don't perform the test.
                       MR. MARSH:  I agree.
                       MR. ROSEN:  Specifically, with respect to
           the main steam isolation valve test, the steam flow
           rates through those lines will be 20 percent higher.
                       MR. MARSH:  Right.
                       MR. ROSEN:  So those valves will never
           have closed against that much more steam flow.  Now,
           my recollection of those valves is that they are
           assisted by flow.  The closure is assisted by the
           flow.  So more flow may actually be better.
                       MR. MARSH:  You still have a restriction
           of timing.
                       MR. ROSEN:  Right.  You can't go too fast,
           and you can't go too slow.
                       MR. MARSH:  It can't be less than three;
           it can't be more than five, right.
                       MR. ROSEN:  But it is a complex system,
           that valve, and it's a huge valve which may be
           assisted by increased flow in terms of its closing,
           but it may be assisted too much in the sense it may
           close too quickly.
                       DR. KRESS:  What's the downside of closing
           too quickly?  Are you getting water --
                       MR. MARSH:  Too fast of a transient on the
                       DR. KRESS:  Too fast.
                       MR. MARSH:  Too much of a power feedback
           into the reactor.  The pressure increases too fast,
           and it causes too much fuel feedback.  But they're
           testing the MSIVs.
                       MR. SHUAIBI:  They do MSIV testing in
           accordance with the tech spec surveillance
           requirements.  Now, they're not testing the MSIVs with
           20 percent additional flow.
                       MR. ROSEN:  But the point is that -- that
           was exactly the point.
                       MR. SHUAIBI:  Yes.  But they do test the
           MSIVs.  It's part of the IST Program.  They test
           MSIVs, and they have limits on both sides in the tech
           specs.  They have a limit for how fast they can close
           and how slow they would close.  And looking at that
           from -- you know, there's a three-second limit and a
           five-second limit.  On the five-second limit, these
           valves are supposed to shut against steam line breaks
           and areas which remain the same for this case.  On the
           other side, we looked at what exists today to require
           the Plant to go back and do testing to make sure that
           it will close.  There's not a 20 percent additional
           flow test that release from 100 percent power.
                       DR. WALLIS:  I wonder if it's time to move
           on to the other question.
                       MR. MARSH:  Yes.  Can we do that?  Move on
           to the other -- the recirc runback test?  Okay. 
                       MR. BAILEY:  Okay.  This is Stewart
           Bailey.  I'm the Project Manager for Quad Cities, and
           as you requested, I will give you a brief overview of
           the recirc runback system and the testing that the
           Licensee has proposed to do that.  First, to make sure
           that we're on the same page, the recirc runback system 
           that the Licensee is adding is really for trip
           avoidance only.  That is its function.
                       Currently, the Licensee, in operating the
           feedwater system, runs three of four condensate pumps
           and two of three feedwater pumps.  As a result, they
           have installed spare of each pump.  The way their
           system operates right now is if one of these pumps
           should fail for any reason, there is an auto-stop at
           the standby pump, and that will recover the feedwater
           flow and prevent the reactor scram, okay?
                       If you look at the way the Plant will be
           operating following EPU, when they're greater than the
           current power level, they need to run these installed
           spare pumps.  They'll be running four out of four
           condensate, three out of three feedwater pumps.  And,
           therefore, they've lost the ability to auto-start an
           installed spare to prevent the scram.  What the
           Licensee has done is they've added a recirc runback
           system that will recover, essentially, some of the
           ability that they're losing to prevent that scram.
                       Basically, what they're doing, I think we
           know some of the details of it, is the flow will be
           reduced to about 70 percent.  And if you look at the
           flow control line, that corresponds to roughly the
           current full power level.  So the runback system
           brings them back into the -- basically, back into
           their current operating conditions and allows the
           feedwater system to recover reactor vessel level.
                       The system that they put in place is very
           similar to the runback system that's used at other
           plants.  I believe it's very similar to the system
           that's been into -- that's already in service at Peach
           Bottom.  There is some additional logic to it, because
           it's only required at high steam flow rates, when
           you're at the point where you cannot install -- just
           rely on the installed spare or rely on the reduced
           number of pumps.
                       Now, the Licensee has proposed and is
           going to be conducting a significant amount of testing
           on the recirc runback system, okay?  This testing is
           being done essentially in accordance with their post-
           modification testing procedures.  On the feedwater
           system, they're doing a number of instrument
           calibrations, they're taking a look at the logic for
           the staggered pump trips, they'll be tuning the level
           control.  They have a series of tests where they
           adjust feedwater position and/or reactor vessel water
           level input and check for the stability of the
           feedwater system.  And they'll be doing tests on the
           feed reg valve position changes and what not.
                       On the recirc system that they're
           installing, they will be doing tests on its circuitry
           and its alarms.  They have calibrations of the recirc
           pump runback speed limiters of the scoop tube final
           position, and they will be doing full logic functional
           tests on that.  A series of overlapping tests so that
           there is some overlap between the systems that are
           being tested, and this gives them the confidence that
           this system will perform as intended.
                       The Licensee does not intend to conduct an
           integral test of the system.  They do not intend to,
           for example, trip a pump and exercise the runback
           system and see whether or not it actually avoids
                       MR. ROSEN:  But you'd agree that the Plant
           will conduct that test some day.
                       MR. BAILEY:  I think it's highly probable
           that they will lose one of their condensator feedwater
           pumps, and the system --
                       MR. ROSEN:  And the runback system will
           come into play.
                       MR. BAILEY:  That is correct.  Whether I
           would characterize it as a test, I might stop short of
           that, but, yes, I think they will exercising this
                       MR. MARSH:  I agree.
                       MR. BAILEY:  When the staff took a look at
           this and the need for the testing, as you mentioned,
           the fact that this is a new system would lend some
           weight to the Licensee performing an integrated test
           of this.  Similar to the logic we used for not doing
           the large transient testing where they haven't done
           significant new mods or trips, here they have done
           what could be considered a significant mod and added
           logic into it, okay?
                       But the staff's fundamental consideration
           when looking at this is that the recirc runback does
           not perform a safety function, okay?  The recirc
           runback is really there for trip avoidance only, to
           recover some of the ability that the plant used to
           have in responding to a loss of a pump in the
           feedwater system.
                       MR. ROSEN:  But you'd agree that
           preventing initiating events, for example, a reactor
           scram, is a worthy goal.
                       MR. BAILEY:  I believe that it is a worthy
           goal.  The staff has considered, though, that they can
           approve the extended power uprate without this feature
           installed, okay?  The licensing topical report, ELTR1,
           acknowledges the fact that some plants will be running
           their installed spares, and therefore they will no
           longer have this capability.
                       MR. ROSEN:  So the staff would be willing
           to accept --
                       MR. BAILEY:  That's correct.
                       MR. ROSEN:  -- without the recirc runback
           system and let the Plant trip for a condensate pump or
           a feedwater pump.
                       MR. BAILEY:  That is correct.  And when we
           were looking at the risk evaluations associated with
           the power uprate, the Licensee did not credit this
           feature.  The increase in scram initiation off the
           feedwater transient just looked at the additional
           probability of failing these pumps, and we didn't
           credit any recovery from the recirc runback.
                       So these are some of the considerations. 
           In additional ELTR1 didn't require an integral test of
           the runback system on plants that already have it,
           okay?  So these are decisions that have been made by
           the staff, and due to the limitations on what this
           system actually does, the result, if this system
           should fail to perform its function, is that you get
           a reactor trip, and you end up in a stable condition.
                       MR. ROSEN:  ELTR1 is a GE document.
                       MR. BAILEY:  ELTR1 is a GE document, yes.
                       MR. ROSEN:  It's not a staff document. 
           We're getting a little confused here by saying ELTR1
           doesn't require, as if it were some sort of regulatory
           requirement.  It isn't; it's simply a GE document.
                       MR. BAILEY:  The staff has approved ELTR1.
                       MR. MARSH:  You're right, though.  It's
           not a regulatory document; it's a proposal which the
           staff has accepted.
                       MR. ROSEN:  Right.
                       MR. BAILEY:  Okay.  So I guess the bottom
           line is since this does not perform a safety function,
           does not prevent anything from reaching any safety
           limits, okay, that was one of the staff's primary
           considerations in whether or not a test of the system
           would be needed.  In contrast --
                       MR. ROSEN:  And here again you're using
           the word "requirement" in this final slide -- there is
           no requirement for an integral test.
                       MR. BAILEY:  Correct.
                       MR. ROSEN:  One could read that with a
           bold heading, "NRC Staff Conclusions."  I can almost
           read like there is no regulatory requirement.  Really,
           I think what you're saying is you don't feel that on
           balance it's needed.
                       MR. MARSH:  Exactly.
                       MR. BAILEY:  I don't think it's needed on
           balance.  I think there are several people who believe
           it would be prudent to run this test to verify.  What
           they have done is they've run the ODYN codes to
           predict reactor vessel water level and to see whether
           or not they've lowered the reactor vessel water level
           sufficiently to prevent the scram, or whether the
           runback goes back sufficiently to prevent the scram. 
           Running this test, of course, would verify that, and
           it would give them information that they could use to
           tune their feedwater system response, tune the recirc
           runback system or perhaps initiate a further reduction
           in reactor vessel water level.  But I think it stops
           at the level of prudence, and as you've noted, the
           probability is high that they will be exercising this
           system sometime in the future.
                       MR. MARSH:  Okay.  Mr. Chairman, that
           completes our presentation on these testing issues. 
           I hope you've gotten a sense of the staff trying to
           weigh the pros and the cons for each of these, and
           there are pros and cons associated with each of these
           tests.  And we've constructed for you, I believe, our
           bases for coming to where we are.  So thank you very
                       DR. WALLIS:  Does this change the SER? 
           Are we going to get a final SER?
                       MR. MARSH:  Yes.  You will be getting a
           final safety evaluation for the large transient tests. 
           I believe that's true for the recirc runback tests or
           is it --
                       MR. BAILEY:  No, the recirc runback tests
           we did not go into detail, because it did not perform
           a safety function.
                       MR. MARSH:  Okay.
                       DR. BONACA:  That's right.  Same
           difference there.
                       DR. WALLIS:  So we're going to be asked to
           make an evaluation without seeing this final SER
           version of the --
                       MR. MARSH:  You will certainly see the
           large transient test safety evaluation change.  It's
           a new section.
                       DR. WALLIS:  When will we see it?
                       MR. MARSH:  We're ready.  I thought that
           was already here.  Did we not send that to you yet?
                       DR. WALLIS:  No.
                       MR. MARSH:  Okay.  It will be here today.
                       MR. ROSEN:  And it discusses the recirc
           runback as well?
                       MR. BAILEY:  No, it doesn't, because there
           is not the safety function associated with the recirc
           runback system.
                       MR. ROSEN:  So we will get not further
           information than that on the whole question of recirc
           runback, will we?  The information we have is what
           you've provided today.
                       MR. MARSH:  Right.  Right.  Exactly. 
           We'll get you the safety evaluation for the large
                       DR. WALLIS:  Are there any other changes
           to the SER?
                       MR. MARSH:  I don't believe so.  Singh,
           any changes to the safety evaluation?  Okay.  I don't
           believe so.
                       MR. ROSSBACH:  Larry Rossbach, Project
           Manager.  We have resolved a number of small or open
           items that were in the report, and we've done a lot of
           editing in response to your comments on the Dwayne
           Arnold report.  So, yes, there are a number of
                       MR. MARSH:  But wasn't that set down
           before, Larry?  Wasn't that before the last full
           Committee report?
                       MR. ROSSBACH:  No, it wasn't.
                       MR. MARSH:  Okay.
                       MR. ROSSBACH:  Just the original draft.
                       MR. MARSH:  Okay.
                       DR. WALLIS:  So we may be being asked to
           write a letter without seeing the final SER.  If there
           have been changes as a result of our previous comments
           on Dwayne Arnold, then they might be significant.
                       MR. MARSH:  Okay.  Singh, do you want to
           say something?
                       MR. BAJWA:  No.  I was just going to say
           that the final safety evaluation becomes final when it
           is issued, so the only way we can provide you is once
           we actually issue the document.
                       MR. MARSH:  How can we help?  We'll give
           you the draft updated, the latest draft that we have?
                       DR. WALLIS:  I think that would be useful.
                       MR. MARSH:  Okay.  We can do that.  Which
           includes the large transient parts too, the large
           transient sections?
                       DR. POWERS:  I'll remind you that our
           Senior Fellow has given us a comparison of before and
                       MR. MARSH:  Okay.
                       DR. BONACA:  Okay.  Any further --
                       DR. WALLIS:  Any further questions for the
           staff at this time?  Let's move on then.
                       MR. MARSH:  Thank you.
                       DR. WALLIS:  Thank you very much.  We're
           ready when you are.
                       MR. NOSKO:  Thank you very much, Mr.
           Chairman, and once again, thank you for allowing us to
           come to the Committee.
                       We have been asked to provide a statement
           of concurrence with the staff review.  My name is John
           Nosko.  I'm the Project Manager for the Extended Power
           Uprate project for Exelon Nuclear.  And I am here to
           do that.
                       Specifically, first, for the subject of
           large transient testing, we, of course, do concur with
           the presentation, as you heard from the staff.  I
           believe we've clearly laid out our position in
           previous submittals.  I would, however, like to make
           sure that we clear up the apparent misunderstanding
           that was laying there on the table about the no new
           information.  We did provide a letter the 18th of May
           on this very subject, and we did note in there that it
           was our conclusion that conducting large transient
           tests will not provide significant new information
           regarding transient modeling or the performance of
           Plant components.  And I would like to make sure that
           -- I don't believe we have gone through the absolute
           of saying "no new information," so just to clarify
                       And as a final point of note, that last
           bullet on this slide, of course, we would, with any
           flat transient, we will be collecting data if and when
           any of these transient events occur at the Stations,
           and we will be making a very thorough and careful
           evaluation of those results against the predicted
           Plant performances.  So, yes our conclusion to the
           Committee members is that large transient tests are
           not warranted.
                       MR. HAEGER:  This is Al Haeger.  There was
           some question on the burdens, Dr. Wallis.  The primary
           burden is the thermal cycle on the Plant and its
           components, and some of our components are sensitive
           to that and require -- may require repair after that. 
           And so inducing two of these transients within a short
           time, of course, would be an extra cost.  And a
           secondary cost, of course, is the down time, which is
           about two days for each of them.
                       MR. NOSKO:  Okay.  Moving on then to the
           recirc runback test and the should we or should we not
           trip a feed pump as part of a performance test for
           that new operating feature, I believe Mr. Bailey
           summarized it very well, that the modification has
           been designed to provide us with operating margin
           only, help us ride out a low-level scram.  We believe
           that the scope of our plan testing does provide
           adequate demonstration of the capability of this
           modification to perform its intended function.  And
           our conclusion is, as the staff has concluded, that
           the feed pump trip at power is not warranted.
                       And with that, the Committee also had, I
           believe, three additional questions that they would
           like Exelon to address, and we will be bringing people
           forward to answer those three questions at this point
           in time.  The first speaker will be Dr. Jens Andersen
           from Global Nuclear Fuels.
                       MR. HAEGER:  Let me summarize the
           question, as I understand -- as we understood it from
           last time.  It's regarding fuel energy deposition
           limits and it was to justify the use of the 170
           calorie per gram energy deposition limit that was used
           for determining that the potential instability during
           an ATWS event was acceptable in the light of the data
           that some of the members, or one of the members had
           seen regarding fuel failures at different exposures.
                       We have provided these in writing.  I
           would hope that you had seen those answers in writing. 
           Is that correct?
                       MR. SIEBER:  Yes.
                       MR. HAEGER:  Did you get those?
                       MR. SIEBER:  Yes.
                       MR. HAEGER:  Okay.  Thank you.
                       DR. POWERS:  I certainly have not seen
           them, but I've been off in Europe looking at high
           burn-up fuel assemblies getting exposed to power
           insertions and blowing apart.
                       DR. ANDERSEN:  This is Jens Andersen from
           Global Nuclear Fuel.  Al Haeger just reiterated the
           question, and the issue that for the EPU we really --
           we are not extending the burn-up limits.  The burn-up
           limits are the same as they have always been.  We are
           not increasing the duty on the fuel and really no new
           phenomena introduced.
                       What we have seen in previous analysis for
           the -- typically, when we looked at the ATWS
           instabilities and the duties that could be imposed on
           the fuel, we have seen enthalpy energy depositions in
           the fuel that are significantly lower than the current
           limit.  As discussed in the report, NEDO-32047, that
           was submitted a long time ago on the ATWS
           instabilities, what we saw was maximum energy
           depositions that was in the range of about 30 to 80
           calories per gram.  Eighty calories per gram was
           typically off fresh fuel, high-power bundles.  Highly
           exposed fuel out in its third cycle were down in the
           30 calories per gram.  That is significantly below the
           current failure limit.
                       DR. POWERS:  Well, what -- I mean you keep
           saying "current failure limit."  The current failure
           limit, I think, for BWR fuel is like 170 calories per
           gram.  And I haven't seen a fuel assembly -- or fuel
           rod survive 170 calories per gram for burn-ups above
           25, 30 gigawatt days for ton.  I mean it's just not a
           meaningful limit anymore.  I mean you're telling me
           something that's of no impact whatsoever.
                       MR. HAEGER:  Well, we need to finish the
           answer to the question, okay?
                       DR. ANDERSEN:  What we are seeing is that
           -- clearly, the point I'm making is that we are not
           extending the burn-up limit as part of the EPRI
           analysis.  And the Robust Fuel Working Group, they're
           looking at what the burn-up limit should be.  And I
           understand that they may want to change those burn-up
           limits for high-exposure fuel.
                       What we are seeing is that the energy
           depositions we are getting for fresh fuel in the order
           of 70 to 80 calories per gram, which is less than half
           of the current failure limit.  And I believe it's less
           than what EPRI is thinking about reducing the failure
           limit to for high-exposure fuel.  For high-exposure
           fuel, what we typically see are energy depositions
           that are in the order of 30 calories per gram, which
           is about a factor of five less than the current
           failure limit.
                       DR. POWERS:  Now compare it to where fuel
           rods are failing in reactivity insertion events.
                       DR. ANDERSEN:  What our accidents for
           activity insertion events are, we did an extensive
           analysis of that following the complete event.  And
           what we do is with the rod bank withdrawal sequence we
           are limited to the maximum rod thrust of less than one
           percent delta K over K.  For a rod drop accident of
           one percent delta K over K for fresh fuel, we get
           roughly 70 calories per gram.  Forty gigawatt days per
           ton, we are down in the order of 25 to 30 calories per
                       Again, high-exposure fuel, the energy
           deposition is almost an order of magnitude less than
           the current failure limits.  Therefore, we believe
           that there is no safety issue, even in light of the
           fact that if we're considering to lowering the current
           failure limits.
                       DR. POWERS:  Well, since you're not going
           to quote the levels at which fuel rods are coming
           apart, maybe I'll just quote some numbers to compare
           against.  We have fuel rods disassembling at 80
           calories per gram, 50 calories per gram and one
           remarkable rod at, depending on how you count, either
           36 or 18 calories per gram.  I mean to say -- quoting
           against this 170 calories per gram is of historical
           interest only.
                       DR. ANDERSEN:  Yes, I understand that. 
           And I also understand that that particular test -- I
           presume that you are referring to the CABRI test -- is
           really not representative of BWR and the way BWR fuels
           operate and the power that BWR fuel could be exposed
                       DR. POWERS:  I think that's a very fair
           statement, because, admittedly, a PWR rod, what not,
           and, quite frankly, I'm not absolute positive any BWR
           rods have been tested, which itself says something.
                       MR. HAEGER:  Well, our point, in
           conclusion, is simply that adoption of more
           restrictive limits for an EPU, in which no other
           effects are changing, is not warranted at this time.
                       DR. POWERS:  I think what you're saying --
           and I think I agree with you -- is that right now
           you're in compliance with what the staff's required. 
           It's just not an issue here.
                       MR. HAEGER:  And we do feel that it's low
           potential safety significance based on the data that
           we have.  We understand --
                       DR. POWERS:  Well, I don't know about that
           one.  That's kind of -- that one I think we could
           argue over, maybe over a beer sometime.  The next
           statement that you make is there's no -- the EPU puts
           no additional load on the fuel.  That's one that's a
           bit of a mystery to me.  Could you explain that a
           little more?  Why isn't there a 20 percent more load
           on the fuel here?
                       DR. ANDERSEN:  The peak power level of the
           fuel doesn't really change.
                       DR. POWERS:  Change.
                       DR. ANDERSEN:  The rod lines -- the
           maximum rod line does not change.  So peak power of
           the fuel is really the dominant effect of --
                       DR. POWERS:  That's what you're saying.
                       DR. ANDERSEN:  -- what controls the load.
                       DR. POWERS:  It definitely puts more load
           on the fuel, but it's not changing the peaks is what
           you're saying.
                       DR. ANDERSEN:  Right.
                       DR. KRESS:  Unless the instability
           magnitudes change because of increased burn-up.
                       MR. HAEGER:  Yes, and we discussed that
           last time, and I believe --
                       DR. KRESS:  And they did change some, but
           best I remember, they --
                       MR. HAEGER:  I believe that GE last time
           presented a sensitivity study that said that the
           generic ATWS analysis applied -- it looked like it
           applied to the EPU condition, in fact, the MELLA Plus,
           in fact, testing that they've been doing.
                       DR. KRESS:  Yes.  Okay.  So you get the
           same sort of --
                       MR. HAEGER:  That's correct.
                       DR. ANDERSEN:  The rod line doesn't
                       DR. KRESS:  Yes.
                       MR. HAEGER:  Okay.  We'll go on then.  We
           have the next group of two questions Keith Moser is
           going to respond to.  Keith is our Reactor Internals
           Program Manager for Exelon.  As I understand, the
           second question was referring to the dryer lug
           attachment inspection frequency, and we came back with
           that last time but really didn't address the
           significance of that frequency.  Keith is here to do
           that first.
                       MR. MOSER:  Yes.  First of all, what I
           want to do is say we just got out of the Dresden 2
           outage, we went back and we looked at the dryer before
           we installed the mod, and then we went and looked at
           the lugs.  And then after we got the mod done, put the
           dryer back in, we looked at all the four set points to
           make sure we had contact.
                       Now, after 32 years, these were holding up
           really well.  We saw no degradation.  So with that and
           the fact that when we did the modeling and the
           endurance limit was 10,000 psi, code limit of 13,600
           psi, so you already have like a 36 -- I'm sorry --
           yes, 36 percent safety factor inherent in that, and we
           met the 10,000 psi endurance limit.
                       We have a pretty good basis for saying
           that the ten-year interval established by Section 11
           is appropriate.  But because we know that there's BWR-
           4s, BWR-6s that have this problem, we've made the
           determination that after one cycle we're going to go
           back and take another look for all four units and make
           sure that we don't have a problem and then we'll go
           back and reassess if the ten-year interval is an
           appropriate length for us to go.  Does that answer
           your question?
                       DR. FORD:  Yes.  The reason for the whole
           topic to start with was that during one of the
           presentations that were made you said that there would
           be an increased vibratory stress transferred to the
           lug, which originally made we think of the fact that
           the failure mode is not necessarily fatigue on which
           the core is based, just stress corrosion cracking of
           the lug.  And it is generally the incidence of stress
           corrosion cracking will increase with a small
           vibration load regardless of fatigue as being the
           phenomena of failure.
                       And I wondered how your inspection
           periodicity might be changed because of that
           particular phenomena, that is stress corrosion
           cracking accelerated by a small superimposed and
           increased vibration load?  And that was the physical
           origin of the question.  The fact that you are going
           to maintain your inspection periodicities, as I
           understand it from your reply, less than ten years, it
           should mitigate that problem.
                       MR. MOSER:  I believe it will.  Also, I
           talked to Sam Ranganath about this and Dave Randall,
           and in these cases, for the BWR-4 and BWR-6, it was
                       DR. FORD:  Okay.  It was transgranulas?
                       MR. MOSER:  Well, they didn't take a vote
           sample, per se, but it was classic.  It may have had
           a small starter point with IGSCC, but it's pretty
           clear that it was fatigue in this case.
                       MR. HAEGER:  The final question was on
           flow accelerated corrosion.  We had a predictive model
           that showed an increase in wear rate in some portions
           of the feedwater system, from a projected 19 mils per
           year to 21 mils per year.  And we didn't have at our
           fingertips what the thickness of the pipe was at that
           time and then some replacement frequency information,
           so we've provided that here.
                       MR. MOSER:  Yes.  And once again, we're
           talking about some fairly significant pipe -- 120 for
           the schedule, 18-inch diameter and 24-inch diameter. 
           And what we're looking at with the CHECWORKS model,
           we're looking at a place where 2010 is where we're
           saying we think we may want to be thinking about
           replacement, not necessarily replacing.  But we're
           going to inspect in 2008.
                       Now, prior to the EPU, we were saying we
           could go all the way out to 2010 and then thinking
           about replacing in 2012, but, you know, we're talking
           about something that's fairly thick, fairly
           significant.  The projected wear rates are actually
           overestimated, if you will, and we feel like we're
           very conservative in this manner.
                       MR. HAEGER:  We should emphasize these are
           localized components.  These are things like reducers
           or elbows, not entire pipe sections, obviously.
                       MR. MOSER:  Actually, the component was --
                       DR. POWERS:  Actually a hole in any part
           of the pipe is a hole.
                       MR. MOSER:  Well, yes, but we --
                       DR. POWERS:  It doesn't matter whether
           it's local or --
                       MR. MOSER:  We thought you may be
           envisioning entire pipe replacements or something, I
                       MR. HAEGER:  And the component that was
           most susceptible was the concentric reducer.
                       DR. WALLIS:  What are the actual wear
           rates?  You have had inspections of those components.
                       MR. MOSER:  Yes.  They're --
                       MR. HAEGER:  Thirteen to 16.  I think the
           pre-EPU actual rate was 13.
                       DR. WALLIS:  So they're comparable but
                       MR. HAEGER:  Yes.  Right.
                       MR. MOSER:  And then the thing you have to
           do with -- we have two inspection data points and with
           CHECWORKS you want to do the predictive module rather
           than just count on two data points.  So we're being
           somewhat conservative.  Any other questions?
                       MR. HAEGER:  Okay.  Well, again, we want
           to thank the Committee for allowing us to come back,
           and we'll look forward to your deliberations.  Thank
                       DR. WALLIS:  Are there any other questions
           for the staff or Exelon or GE?
                       DR. POWERS:  Well, let me ask a question. 
           The answer may be it's covered by a different part. 
           And that is we're going into a combination of power
           uprate and inevitably using our fuel to hire burn-ups,
           and we have a concern in this power uprate about the
           possibility of getting into an oscillatory regime. 
           And we have a process -- a procedure for recovering
           should we ever get into that oscillatory regime that
           is -- it's not trivial.
                       I mean it does involve dropping the level
           of water, injecting some boron and bringing the water
           up.  Do we understand what kinds of stresses, lateral
           stresses that puts the fuel under, and are we
           confident that that fuel survives those lateral
                       MR. HAEGER:  Dr. Andersen, I don't know if
           you can help with that.  That's something I wouldn't
           be prepared to discuss.
                       DR. ANDERSEN:  I'm not prepared to discuss
           the stresses on the fuel.
                       MR. HAEGER:  I guess the only response we
           can give is that the ATWS instability study that --
           and help me out if this is not right -- but that study
           was a generic study that since GE has confirmed that
           they believe applies to power uprate.  Now, I don't
           know if that covers lateral stresses on the fuel or
                       DR. ANDERSEN:  What the study showed was,
           as I discussed earlier, that the energy depositions
           that you had in the fuel was substantially lower than
           what the current failure limits are.  As I said
           earlier, the energy depositions, the max energy
           deposition we saw on fresh fuel was in the order of 70
           to 80 calories per gram.  For highly-exposed fuel, it
           was down in more like 25 to 30 calories per gram.
                       What we did see that in the absence of an
           mitigating event, that you could get translations on
           the fuel and some fuel failures on a very small
           fraction of the fuel in the core.  Those failures were
           oxidation failures, not stress failures.
                       DR. POWERS:  Let me ask a question about
           that and power input.  Originally, you quoted power
           inputs for a rod bank withdrawal.  In the oscillation,
           we're talking about a little bit different; that is,
           a series of cycles that each -- which is putting power
           into the fuel.  Seems to me that the power and input
           then depends on the number of oscillatory cycles you
           go through.
                       DR. ANDERSEN:  That is correct, but if you
           look at the net energy deposition in the fuel, that is
           equal to zero, because the heat removal rate to the
           coolant is equal to the energy deposition into the
                       DR. POWERS:  Oh, yes?  Temperature doesn't
           go up at all?
                       DR. ANDERSEN:  If you fail to relieve it,
           then the temperature goes up, and that's correct.  It
           will go up and you will get a failure in a small
           fraction of the fuel.  If you look at the old report,
           the NEDO-32047, we showed that that could happen to a
           small fraction of the fuel that had the highest power
           oscillations.  When we analyzed how large a fraction
           of the fuel that could be exposed to that failure
           mechanism, it was less than half a percent of the
           fuel.  And that was deemed acceptable at that point.
                       DR. POWERS:  And if we use a lower failure
           criteria, what does that percentage go up?
                       DR. ANDERSEN:  The failure rate was really
           not associated with the energy deposition.  The
           failure rate was associated with the fuel during the
           periodic oscillation exceeding the minimum fuel
           burning temperature and failing to relieve it.  And
           then the failure was really an oxidation failure at
           high temperature.  So it was really not associated
           with the energy deposition.
                       DR. POWERS:  And I don't know if it's
           appropriate in response to your question to comment on
           operator mitigation, but, certainly, that's a
                       MR. HAEGER:  Yes.  That's a question that
           we continue to wrestle with.  And I never know how to
           come down on this.  I mean you test the operators with
           the current configuration in the Plant, and they do
           very well.
                       DR. POWERS:  That's right.
                       MR. HAEGER:  And so now we're going to say
           that the higher power, where they have a little less
           time, they'll still be able to do very well.
                       MR. HAEGER:  Tim, do you want to comment
           on that?
                       MR. HANLEY:  My name is Tim Hanley from
           Quad Cities.  The way we test and train the operators
           really is that they can initiate it based on the
           parameters they're monitoring, not a specific time
           period.  So their reaction to the ATWS event in a
           uprated core versus a non-uprated core is not
           significantly going to change, because it's based on
           parameters that they're monitoring, not specific time
                       DR. BONACA:  I mean I understand what
           you're saying, but if the parameter reaches a certain
           point at which he has to take action in ten seconds,
           right, it would make a difference --
                       MR. HANLEY:  It certainly would if it was
           making changes in that time period, but we're talking
           on the order of minutes, not in the order of seconds
                       DR. BONACA:  But this argument has been
           made many times that way.  I think there is still a
           sensitivity to the timing.
                       MR. HANLEY:  Well, certainly, certainly. 
           If it was changing it to a matter of seconds or from
           ten seconds to five seconds, that would make a
           difference, but we're talking in the order of minutes
           where the operators have an opportunity to assess the
           situation, monitor the parameters and take the correct
                       DR. WALLIS:  These extreme oscillations
           that you gathered in ATWS, your understanding of that
           is based on codes and theory or are there some sort of
                       DR. POWERS:  Well, a couple of events.  A
           full-scale event at La Salle.
                       DR. WALLIS:  Okay.  So does that give
           confidence that you really understand what would
           happen with these power uprates with the ATWS
                       MR. HAEGER:  Again, we have covered this
           in the past, but Dr. Andersen?
                       DR. ANDERSEN:  Well, these are complicated
           coupled thermal-hydraulic neutronics oscillations.  We
           do have full-scale reactor test data for thermal-
           hydraulic coupled neutronics oscillations.  We also
           have some unplanned event.  We have full-scale testing
           that has been conducted on several European plants.
                       Particular tests were conducted at the
           Leibstadt, the KKL Plant.  We also have the event that
           happened in 1988 at La Salle.  We have used those
           events to qualify our codes, and we actually predict
           those events very well.
                       DR. WALLIS:  Anything else?  Then I would
           thank you very much.  And I will hand the meeting back
           to the Chairman.
                       DR. APOSTOLAKIS:  Thank you, Dr. Wallis. 
           We're 11 minutes early.  Very good.
                       DR. WALLIS:  Well, with thermal-hydraulics
           things go quickly.
                       DR. APOSTOLAKIS:  They go very quickly,
                       DR. POWERS:  Because a momentum equation
           doesn't come up.
                       DR. APOSTOLAKIS:  Okay.  We'll recess
           until 10:30.
                       (Whereupon, at 9:58 a.m., the ACRS
           Advisory Committee Meeting was recessed until 10:30

Page Last Reviewed/Updated Monday, August 15, 2016