Thermal-Hydraulic Phenomena - October 26, 2001

                Official Transcript of Proceedings


Title:                    Advisory Committee on Reactor Safeguards
                               Thermal-Hydraulic Phenomena Subcommittee

Docket Number:  (not applicable)

Location:                 Rockville, Maryland

Date:                     Friday, October 26, 2001

Work Order No.: NRC-082                             Pages 225-356

                   NEAL R. GROSS AND CO., INC.
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                             OCTOBER 26, 2001
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                            ROCKVILLE, MARYLAND
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                 The ACRS Thermal Phenomena Subcommittee
           met at the Nuclear Regulatory Commission, Two White
           Flint North, Room T2B3, 11545 Rockville Pike, at 8:30
           p.m., Dr. Graham Wallis, Chairman, presiding.
                 DR. GRAHAM WALLIS, Chairman
                 DR. F. PETER FORD, Member
                 DR. THOMAS S. KRESS, Member
                 DR. WILLIAM SHACK, Member
                 DR. VIRGIL SCHROCK, ACRS Consultant
                 DR. JOHN D. SIEBER, Member
                 PAUL A. BOEHNERT, ACRS Staff Engineer                                 I-N-D-E-X
                     AGENDA ITEM                           PAGE
           Introduction by Chairman Graham                  227
           Dresden/Quad Cities Uprate                       227
                 NRR Presentations
           Subcommittee Caucus                              340
                                                    (8:30 a.m.)
                       CHAIRMAN WALLIS:  The meeting will now
           please come to order.  This is a continuation of the
           meeting of the ACRS Subcommittee on Thermal-Hydraulic
           Phenomena, at which we discussed the proposed extended
           power uprates for Dresden and Quad Cities.
                       And we heard yesterday from Exelon, and
           the licensees, and today we are going to hear from the
           staff.  I would call on John Zalenski to get us
                       MR. ZALENSKI:  Thank you so very much.  I
           guess I am a little bit of a bump in the road, in that
           I wanted to take a couple of minutes to talk to the
           letter you sent with respect to the Duane Arnold
           facility, and its marriage or association to Quad
           Cities and Dresden.
                       Our staff is fully prepared to get into
           the details of the review on Dresden and Quad Cities,
           but I thought it would be worth a couple of minutes to
           highlight that your letter has made quite an impact on
           me personally and on the office.
                       And one of the issues that I thought I had
           addressed before the full committee had been my keen
           desire to ensure that we were going to indeed have a
           first-rate product before we ever approved that
           license amendment.
                       The status of that particular safety
           evaluation is that it is not ready to be served, and
           using a phrase that I have used many times in the
           past, we will serve no wine before its time.
                       The technical basis will be robust for
           each of those given sections, and I would submit that
           it would be our intent to provide some sort of a
           highlighted version for your easy review for
           information purposes once we get to the point where
           that is rating the issue.
                       In a small way to show what I believe to
           be a substantive difference between an early draft and
           the product that actually goes out the door, and
           hopefully that may be a little bit closer to some of
           the expectations of some of the members.
                       So to the product itself, I don't want to
           forecast or say that we are going to have it done next
           week, or the week after, but we are putting our
           shoulder down to ensure that the first one out of the
           shoot is done correctly, and it meets management's
           expectations, and is indeed robust.
                       As we go forward the staff sometimes
           relies on previous work and that will be kind of an
           example the staff will rely on.  So it has got a high
           mental, and you have helped us in an interesting way
           to ensure that the mental is put at the right height.
                       There were a couple of other issues in the
           letter that -- oh, by the way, we will be responding
           to the letter formally, but, I really wanted to
           scratch an itch a little bit and if there was
           discussion, I would be more than happy to take some
                       The staff should develop and improve
           guidance on the detail in the safety evaluation.  I
           read this as a generic comment to how the staff does
           licensing work, and we will probably respond in that
                       And some of this is driven by our internal
           processes.  We do have a quality initiative that has
           been germinating for the past year.  It is funded for
           this fiscal year with a senior management leaving that
           particular activity, John Hannon in our plant
           activities branch.
                       I think we will have a lot to say about
           this issue over the next year, and the criteria on
           independent assessments, and things of that sort, I
           think we will probably be talking to you considerably
           about a lot of the guidance that currently exists, and
           a lot of the expectations that currently exist, and
           probably do a little bit better job in assuring how
           our reviews are performed.
                       I am struck by the young lady that rose at
           the full committee and said I reviewed this document,
           and I reviewed that, and I did a lot of these.  But
           none of that ever made it to the safety evaluation.
                       In so many words, we are going to go back
           and ask ourselves should we be a little bit more
           candid to here are the actual things that were done,
           and so I think in short this has certainly got my
           attention, and as we go through Duane Arnold, the bar
           height will be established for what we see for other
           licensees, and the draft that you received from us on
           Quad Cities and Dresden is not at that level.
                       But yet I would not anticipate it having
           not gone through any management reviews.  So if there
           are any questions, I would be more than happy to take
           those.  Otherwise, I would begin turning the meeting
           over to Mr. Bajwa.
                       I will say that I have asked that a number
           of our senior management team responsible for
           oversight of the reviews attend this particular
           subcommittee meeting.
                       Mr. Hannon is here, and Dr. Barrett and
           Mr. Vermeil, and a number of our senior management
           team out of the two principal divisions in support of
           this particular meeting.
                       So by elevating our attendance to some of
           our managers and section chiefs, I am trying to
           overtly indicate that we have heard what you have
           said, and we are trying to be responsive.
                       If there are no questions, I would be more
           than happy to get into the subject at hand at this
                       CHAIRMAN WALLIS:  Well, no, I just wanted
           to thank you for what you have said.  It is very
                       MR. ZALENSKI:  Okay.  Good.  Mr. Bajwa was
           the project director for Region 3 plants.  He is also
           our lead senior SES responsible for power uprates.
                       And I have asked him to provide some
           opening comments on the work that the staff has done,
           and then our project management team and our technical
           review team stand prepared to address a variety of
           review areas.
                       There is one topic area that we will touch
           on that we have not come to resolution with Quad
           Cities and Dresden, and that has to do with integrated
                       And should these plants be expected to
           perform testing of the MSIVs, should they be expected
           to perform other tests, such as suggested in their
           generic topical report -- and one that comes to mind
           is the load reject test, today we are simply not in a
           position to say that we think that those tests are
           necessary to confirm all the work that has been done
           by the staff.
                       My own sense of this is that the decision
           on whether to test or not is independent of can we
           approve this license amendment.  In other words, I
           don't believe that any of us feel that conducting the
           test if necessary to move forward with the technical
           work or not performing the tests.
                       So we have more work to do and we will
           have that issue resolved before we issue the
           amendment.  We just did not have enough time to take
           it through the various levels of management to ensure
           we are aligned within our organization.
                       So with that as kind of an opening
           comment, why don't you go ahead and get started,
                       MR. BAJWA:  My name is Singh Bajwa, and
           moving on to Quad Cities and Dresden, I would like to
           say that we have conducted a thorough review of the
           Dresden and Quad Cities plants in all areas
           potentially affected by the power uprate.
                       We conducted our review from existing
           practices, including the lessons learned from the
           Maine Yankee experience, although we reviewed
           information in many areas of the licensing basis of
           Dresden and Quad Cities units.
                       And beyond that, we have used this
           information, and we will focus our representation
           today on the areas that we believe to be most of
           interest for our power uprate.
                       We will also address areas that the ACRS
           has expressed an interest in.  So as John mentioned,
           we have one open issue which we will not be able to
           speak to it because it is a pre-decisional at this
                       But as John indicated, we will inform ACRS
           at the time we issue the safety evaluation in its
           final form.  With that, I will now turn this to Larry
           Rossbach, the lead project manager for the Dresden and
           Quad Cities power uprate reviews.
                       Larry is also the NRR project manager for
           the Dresden plant.  Also at the table is Mr. Stu
           Bailey, the NRR project manager for the Quad Cities
                       Larry will give an overview of the review
           process used for this application and agenda for the
           meeting.  He will also introduce the other presenters
           at the table.
                       MR. ROSSBACH:  Thank you, Singh.  My name
           is Larry Rossbach, and I am a project manager for the
           NRR, and I am the project manager for Dresden, and
           also for the power uprate project for Dresden and Quad
                       Briefly, to go over our review process,
           the guidelines we use, we use the generic G.E.
           guidelines, and generic evaluations topicals, ELTR-1
           and ELTR-2.
                       These licensing topical reports have
           previously been accepted by the NRC as an acceptable
           guideline for power uprate applications.  And the
           staff uses these topicals as guidelines in our review.
                       In addition, we use the existing NRC
           standard review plan and we rely on previous power
           uprates.  Specifically, the safety evaluation for the
           Monticello Nuclear Generating Station was used as a
           guide for the scope and the depth of the review.
                       In addition, Dresden and Quad Cities
           reviews were really done in parallel with the Duane
           Arnold review, and in some areas even used the same
           reviewers.  So it should look familiar to you being
           done in the same format as the G-topicals, and being
           reviewed in the same manner in-house.
                       As John Zalenski had said, we are on the
           Dresden-Quad Cities project of the comments on the
           Duane Arnold safety evaluation, and we have taken
           those into account to the extent that we could,
           although most of the reports that you have was written
           prior to receiving those comments, and we are
           continuing to work to improve that safety evaluation.
                       As we progress in our review, we do
           sometimes identify the need for additional
           information, and so there was substantial additional
           information submitted by the licensee in response to
           our request.
                       The staff also performed three audits
           during the conduct of this amendment review.  The
           Reactor Systems Branch audited global nuclear fuels
           analysis at the G.E. facility in Wilmington, North
                       the probablistic safety assessment branch
           staff audited the licensee's risk assessment process
           at Exelon's midwest offices, and the plant systems
           reviewer audited analysis at the Dresden site.
                       The principal areas of our review -- and
           again, very similar, and the same as in Duane Arnold,
           but the staff reviewed the results of the licensee's
           evaluations in reactor core and fuel performance, and
           reactor coolant systems, and containment analyses, and
           emergency core cooling system performance evaluation,
           and instrumentation and controls.
                       And the suitability of existing ones and
           the proposed modifications.  The electrical power and
           power conversion systems, and auxiliary systems, and
           radiological consequences, special events and limiting
           operational transients.
                       And probablistic risk assessment review,
           and we reviewed human performance aspects of the
           submittal, and there was an environmental assessment
           done.  The environmental assessment will be published
           separately in the Federal Register.
                       I would like to go over briefly the order
           of our presentation.  The reactor systems review will
           be gone over by Ralph Caruso just to my left, and the
           plant systems review will be summarized by Ralph
                       Following that, we will respond to ACRS
           questions in other areas where we had not prepared a
           full presentation.  As time allows, we may get into
           more detail in those areas.
                       And they include -- and this is partly in
           response to questions that we received from the ACRS
           dealing with material degradation issues, pipe
           support, pipe and support modifications, the need for
           electrical modifications, and the PRA analysis and
           evaluation which we did.
                       With that, I would like to turn it over to
           Ralph Caruso.
                       MR. ZALENSKI:  If I might just jump in for
           a second.  As our staff goes through the presentation,
           it would strike me that it would certainly be fair to
           query which code standards, which reg guides, standard
           review plans, acceptance criteria, specific regulatory
           requirements, the staff is working against.
                       And the staff should be able to clearly
           explain what we did to independently determine that
           something was acceptable.  And so seeding your thought
           a little bit, that would be my expectation to find
           that kind of information in the final report.
                       MR. CARUSO:  Good morning.  My name is
           Ralph Caruso, and I am chief of the BWR nuclear
           performance section and reactor systems in NRR,a nd I
           am going to talk about the nuclear reactor and fuel
           systems review that was done as part of the
           Dresden/Quad EPU review.
                       I am going this with the slides being a
           little bit out of order, the package that you have,
           and so I am going to do my presentation the old
           fashioned way here, and I think I have a crib sheet
           here that tells me where you should be turning as I go
           along, and I will call out the slide numbers that you
           have got.
                       The first one is slide 10, and that has
           got my name on it.  The second slide is slide 11, and
           this is the background.  This is a power uprate of
           approximately 18 percent from the original rated
           normal power level.
                       It involved implementation of MELLLA and
           ARTS, reactor trip system.  It also involved the
           introduction of GE14 fuel into a core that is
           currently supplied by Siemens.
                       The staff, as part of its review, in
           addition to the review in-house that we normally do,
           performed an on-site audit at GNF-Wilmington.  This
           looked at compliance with the analytical methods that
           we have approved and that are being applied by GE to
           analyze this reactor's behavior.
                       And this includes something called G-STAR
           Amendment 22, which is the process that they used to
           develop and approve the GE-14 fuel design.  We
           performed audits of the Dresden and Quad Cities EPU
           system performance, and a design basis safety
           analysis.  And we reviewed as it says here the safety
           analysis reports.
                       DR. SCHROCK:  Ralph, before you leave
           that, I have a question on the first item.  One of the
           problems that I mentioned yesterday in connection with
           the review of this large quantity of paper that was
           received is the fact that we essentially had two sets
           of things that were verbatim to a major extent.
                       And it was very difficult to sort out the
           things that were different for the different plants,
           and I pointed out in the beginning that as I tried to
           do that, I found that in the SARs that the MELLLA
           graphs are not the same for the two plants.
                       And the response to that was initially
           that, yes, they thought that they were the same and
           they should not be different.  But subsequently I got
           the two reports side-by-side, and indeed they are
                       So what is then confusing is why are they
           different?  What is the explanation for why the MELLLA
           is different for the different plants, and why is the
           response from the plant owners that, yes, they should
           be the same, when in fact they are not the same?
                       MR. CARUSO:  It is not clear to me.  What
           do you mean by they are different, and in what sense?
                       DR. SCHROCK:  They are different in the
           sense that different points have different valves. 
           The slope of the main MELLLA line is different on the
           different graphs.
                       The full power, full flow point, is the
           same.  Everywhere else on the graph, the lines are not
           the same.
                       CHAIRMAN WALLIS:  And on the left-hand
           side the boundaries are very different I think.
                       MR. CARUSO:  Well, I can't speak to the
           specifics of exactly where the points are.  I am not
           surprised that they are different, because the plants
           are different, because the fuel designs are different,
           and because the fuel management schemes will be
           different, because they are implementing different
           fuels at different points in life, and there is a lot
           of core design that gets done, which will change those
                       So I am not surprised, and so are you
           looking for an explanation of exactly why the points
           are slightly different?
                       DR. SCHROCK:  Well, there are two parts to
           the point that I am trying to make, and the question
           that I am trying to raise; and the first one is the
           detail of what is correct about the SARs.  Should
           those things be different, and should they be the
                       I am confident that I heard pretty clearly
           yesterday from representatives of the industry that
           they ought to be the same.  Now, you are saying that
           they ought to be different, and I am not surprised
           that they are different.
                       MR. CARUSO:  I am not surprised that they
           are different.
                       DR. SCHROCK:  So there is a point to be
           resolved there.  But the overall point that I am
           trying to get across is that it makes for a very
           inefficient process to be put in the position of
           having to sort out differences between two plants that
           are being resolved simultaneously when these
           differences are not highlighted in the documentation
           that is presented.
                       And where you get two stacks of paper
           which you ought to expect to have to digest in some
           detail, and what you find is that they are essentially
           verbatim, like 95 percent plus.
                       And then you have to discover what is the
           reason for numbers to be different in the two plants
           when there is no explanation in the documentation,
           either in the SARs or in the SERs. That is the problem
           that I am trying to get across to you.
                       DR. KRESS:  Your MELLLA line is not a
           fixed thing.  It ought to vary throughout the whole
           life of the core actually.
                       MR. CARUSO:  I would expect it to vary
           from reload to reload.
                       DR. KRESS:  Yes, and from reload to
           reload, and so I guess it depends on what they choose
           to analyze when they put the thing together.
                       MR. CARUSO:  Right.  That's why I am
           saying that I am not surprised that they are
           different, and I can't speak to the particular details
           of each curve.  Let me ask my staff if they have any
           insights as to why they might be different?
                       MR. KENDRICK:  This is Edward Kendrick,
           reactor systems branch.  First of all, the Quad and
           Dresden plants, the pre-EPU are different power
           levels.  The post-EPU is the same thermal power.
                       So the post-EPU MELLLA lines I believe
           should be virtually identical.  And since they started
           from a different one and they used in many cases a
           bounding Unit 5, there could be some differences.
                       The staff, in preparation for the audit,
           looked first at Dresden, and then specifically at
           Dresden-2, which is the lead unit.  And we identified
           the differences, first of all, between Dresden and
           Quad, and then the differences between Dresden-2 and
                       Now, we did not include a table in the
           SER.  We could do that because for our information we
           had to go through and look at Dresden, and then go
           through and look at Quad.  So I think in the SER we
           can tabulate the differences, and why there are
                       MR. CARUSO:  And a great deal of our
           review did not necessarily look at and verify each
           individual point on those curves, because the way we
           do the reviews is to do a sampling to ensure that the
           methodologies that are being applied are being applied
                       So we don't necessarily review every
           individual number and verify each and every individual
                       CHAIRMAN WALLIS:  Well, I was going to ask
           the question that my colleague asked in a different
           way.  I was going to ask did the staff realize that
           these figures, which are key, the power versus flow
           maps, are different for the two plants?
           And did they then ask why.
                       MR. CARUSO:  I don't believe that question
           was explicitly asked, because as I said, I am not
           surprised at all that they are different.
                       CHAIRMAN WALLIS:  I know, and you can say
           that, but the thing is were you aware until my
           colleague mentioned that they were different that they
           were different, and that is the thing that --
                       MR. CARUSO:  I don't think that I
           explicitly had -- that it crossed -- well, I don't
           know.  Ed, did that cross your mind?  He is nodding
           yes.  He did notice that.
                       CHAIRMAN WALLIS:  I think the natural
           circulation line is significantly different, for
           instance, and I don't know why it is different. 
           Anyway, we should probably get off of this point.  We
           have now started asking questions.
                       MR. CARUSO:  Okay.  Review Scope, and this
           is Slide 12.  As part of the review, as I said, we
           have looked at fuel design and operation, and this was
           Amendment 22, and something that we audited at the GE-
           Wilmington facility.
                       Thermal limits, and reactor coolant
           system, and connected systems, ECCS performance, the
           capability of the standby liquid control system, and
           design basis and safety analysis, and ATWS and ATWS
           instability.  This is the scope.
                       And Slide 14 will be next.  As Larry
           Rossbach said, we followed the scope of the ELTR-1 and
           ELTR-2, and the Supplement-1 to ELTR-2, to guide us in
           our review.  And once again in the reactor systems
           area -- and that's what I am here to focus on -- all
           of these analyses were done in accordance with NRC
           approved methodologies, analytical codes, and they are
           all met NRC approved analytical limits.
                       And those limits would range from the
           numbers in the regulations, such as 2200 degrees and
           17 percent oxidation in 50-46, to the general design
           criteria requirements that 99.9 percent of fuel rods
           not experience boiling transition during a transient
                       CHAIRMAN WALLIS:  I'm sorry, but I am
           going to go back to the previous question.  You said
           that specific points weren't calculated or checked on
           the power versus flow map.  I'm sorry, but my mind is
           following a train of thought here.
                       MR. CARUSO:  Okay.
                       CHAIRMAN WALLIS:  How did you satisfy
           yourselves that the MELLLA upper boundary was in fact
           in the right place?
                       MR. CARUSO:  Well, as part of the audits
           that were done, the staff reviewed the calculations
           that were done for linear heat generation rate for the
           LOCA analyses, and for the transients.
                       And the MELLLA line will be developed as
           part of that process.  So we reviewed particular
           points in the process to ensure that the process was
           being followed, and the MELLLA line was therefore
                       DR. KRESS:  You reviewed the process
           instead of the product.
                       CHAIRMAN WALLIS:  Did you make any
           independent calculational checks or anything?
                       MR. CARUSO:  No, we did not.
                       CHAIRMAN WALLIS:  So you checked off that
           they went through the right process?
                       MR. CARUSO:  No, we didn't check it off. 
           What we did was that we sent people to the GE-
           Wilmington facility to look at detailed calculations,
           to look at the inputs and to look at the outputs.
                       And to determine whether the assumptions
           that were made were appropriate and within the stated
           limits and the approved methodologies.  And that the
           outputs were in accordance with the acceptance
                       CHAIRMAN WALLIS:  Well, the reason for
           asking the question is because this is a very key
           point, because you are saying that they are arguing
           that it is now possible to go up to this limit, this
                       It is now possible to operate in a region
           where we have not operated in before, and this is the
           boundary of the new region.  So you have to be really
           sure that you are on good ground if you approve that
           boundary or the methods that led to that boundary.
                       MR. CARUSO:  In the reactor systems area,
           we are -- I don't want to say we are unique, but I
           think we are probably ahead of other organizations,
           other parts of NRR, other disciplines, in that we have
           a well-founded base of analytical methods that have
           been reviewed and approved, and that we have a lot of
           experience with.
                       These methodologies have been reviewed and
           we have -- we do have our own analytical tools that
           have been used to verify these methodologies, and we
           feel that as long as licensees and vendors use those
           methodologies within the acceptance criteria, and
           within the limits of application,we do not feel a need
           to do additional independent assessment unless we have
           specific credible information which would cause us to
           doubt those codes are being applied inappropriately.
                       And in the case of these power uprates,
           because the peak bundles are not changing, and because
           the flow rates are all within current methodological
           limits, we didn't feel that there was any need to do
           any independent assessment.
                       DR. KRESS:  If you did want to do an
           independent assessment would you use RELAP and NAMONA,
           or is --
                       MR. CARUSO:  It would depend entirely upon
           the area.  If it were a LOCA case, we could use TRAC-
           B, and we could use RELAP.  In the area of stability,
           we could use ROMANA.  Well, ROMANA is the one that
           comes to mind.  I think there may be some other codes.
                       But we have contractors available to us,
           and Jose Marsh Luba, the expert on instability, and we
           would call on him if we felt that there was something
           about the operation of this plant that placed it
           outside the appropriate methodology.
                       But because of the way that they did this
           power uprate, everything stayed within the appropriate
           limits, and therefore there was no credible reason for
           us to doubt that the methodologies were not being
           applied correctly.
                       We do occasionally -- I mean, the reason
           that we do these audits is because these power uprates
           called into question whether the methods were being
           applied correctly.
                       That was a prima facie case for doing an
           audit, and that's why we started doing the audits at
           Duane Arnold, and that's why we continued doing them
           for Dresden and Quad Cities.
                       And that's why we continued for Clinton,
           and that was done, I believe, in September, and I
           believe that we are planning going out and doing a
           Brunswick audit sometime later on this winter.
                       So we are looking at these things to check
           to make sure that the methodologies are being applied
           appropriately, but without some credible specific
           issue.  We don't believe that we have the resources to
           go do an independent assessment.
                       CHAIRMAN WALLIS:  Well, an issue might
           arise -- and I haven't done this yet, as my colleagues
           have been looking at these curves in more detail, but
           if we started to compare them and we found that there
           were really big differences between this MELLLA
           boundary in one reference than another, then I think
           we might ask at the full committee meeting again why
           this is so -- and it might indicate that someone
           perhaps needed to check into it.
                       And you are saying that you didn't have a
           good reason to want to make an independent assessment
           of the question, and that may well be true.
                       We began to question it because we noticed
           that there were these differences, that's all.
                       MR. CARUSO:  I understand that, but as I
           said, realize that these changes occur from cycle to
           cycle, and the staff normally doesn't even do reload
           reviews.  They can make changes to these parameters
           without our knowledge when they change fuel designs,
           and when they change core designs.
                       And we would not even see them except as
           a report after they start off.  That could cause --
                       DR. KRESS:  They basically develop a new
           MELLLA line for every reload don't they?
                       MR. CARUSO:  That's correct.  That has to
           be reevaluated every reload.  All of these analyses
           have to be done every reload.  And they are done in
           accordance with these approved methods, and we feel
           comfortable enough with those methods that we didn't
           think that we needed to do independent assessments.
                       DR. KRESS:  Did your audit go to the
           extent of checking the input to the codes to these
                       MR. CARUSO:  Yes.
                       DR. KRESS:  So you really did look at the
                       MR. CARUSO:  As I described I think to
           this committee, or maybe it was to the full committee,
           we had four people that went to the plant, and they
           asked for what are called the design record files, and
           these are the detailed calculations that support
                       And they sat down in a room and they read
           them.  They went through them page by page looking at
           the inputs, and looking at the outputs, and looking at
           the assumptions.
                       And then they asked questions, and they
           sat down with people like Jason Post, who is standing
           up and he wants to say something.
                       MR. POST:  Yes.  This is Jason Post.  I
           have a couple of things.  One is that the differences
           that you see in the power flow maps between the two
           units are mostly in the natural circulation line, and
           the minimum pump speed line.
                       And those were not -- those are historical
           differences between the two sites, and we did not try
           to reconcile those differences for this, because that
           really was not pertinent to the change that was being
                       CHAIRMAN WALLIS:  I don't understand the
           term historical.  I mean are they meaningfully
           different, or is it some mysterious history?
                       MR. POST:  It has to do with the
           instrumentation and the analysis that was done at the
           time that those plants were first built.  And the
           difference is not as great as it is shown.
                       CHAIRMAN WALLIS:  Well, if they are
           similar plants, you would expect natural circulation
           characteristics to be pretty well the same wouldn't
                       MR. POST:  Yes, you would.
                       CHAIRMAN WALLIS:  So why are they so
           different on a map?
                       MR. POST:  As a result of the improved
           methodology over the years, some of the plants have
           gone back and redefined their natural circulation
           lines.  My guess is that one of the units has done
           that a little more accurately than the other unit.
                       But again that wasn't something that was
           pertinent to this design change to MELLLA and EPU.  So
           that was not addressed in this license amendment that
           historical difference was maintained.
                       CHAIRMAN WALLIS:  Well, maybe if we asked
           the question again at the next meeting, you will have
           an explanation other than history?
                       MR. POST:  Certainly.
                       CHAIRMAN WALLIS:  Can you have an
           explanation other than that?
                       MR. POST:  Certainly.  The other statement
           that I wanted to make was that while the actual power
           flow relationship can change from a cycle to cycle
           basis, the MELLLA line itself is a licensed limit, and
           that as a licensed boundary does not change.
                       And that licensed boundary is drawn to be
           bounding over the actual power flow relationship that
           can change slightly from cycle to cycle.  And Israel
           is just coaching me here.  It is also common to both
           plants, and so the MELLLA boundary itself is identical
           between the two sites.
                       It's just extended to a lower core flow in
           one to match the natural circulation line, which is
                       CHAIRMAN WALLIS:  Thank you.
                       DR. KRESS:  So Virgil's observation that
           the slope is different is not true?  The slope is
           actually the same?
                       MR. POST:  That is correct.
                       MR. CARUSO:  It is not the same on the
                       MR. POST:  Excuse me.  I believe the slope
           is the same on the two SARs.  It's just that the lower
           point, the lower left-hand point, is different.  So it
           might appear that the slope is different.
                       CHAIRMAN WALLIS:  This is something that
           we can easily verify since we have two different
           points of view, and we can do a test at the break and
           see who is right.
                       MR. CARUSO:  My next slide is actually
           Slide 21 in your package.  And it is the reactor core
           and fuel performance slide.  And one of the questions
           that often comes up is a question about margin, and
           who owns the margin.
                       And as I stated earlier, we have a number
           of different cycles specific, and licensing thermal
           limits.  And the licensing limits, like the 2200
           degrees, and the 86 gallons per minute for the
           standpoint liquid control system, and the 99.9 percent
           limit for the transient, those are the fixed limits.
                       And licensees are free to work within that
           boundary as much as they want.  They own that margin.
                       CHAIRMAN WALLIS:  And they did in this
                       MR. CARUSO:  And they do.
                       CHAIRMAN WALLIS:  And 1600 became 1600
           exactly, for instance.
                       MR. CARUSO:  That's acceptable.
                       CHAIRMAN WALLIS:  And 1500 psi became
                       MR. CARUSO:  And I will be honest, as the
           first question that I asked when I saw the number was
           how many times did you have to run it to get results.
                       CHAIRMAN WALLIS:  We asked the same thing. 
           We asked about do loops and things.
                       MR. CARUSO:  And I got a very indignant
           response.  He said that the first time that we ran it,
           it was 1499 and that is what it was.
                       DR. SHACK:  I wouldn't run it again
                       DR. KRESS:  Your statement that the
           margins are available to the licensee, does that have
           qualifications to it?  Like it is available if they
           are using the same approved codes that they used
                       MR. CARUSO:  Absolutely.  They have to use
           the methodologies within the limits that are defined
           in the SER, and they have to meet the appropriate
           acceptance criteria.
                       DR. KRESS:  So if I go in and change my
           code, and improve the code, do I still --
                       MR. CARUSO:  We could spend all day
           talking about changes to the codes.
                       DR. KRESS:  Yes, I understand.
                       MR. CARUSO:  There are rules about this,
           some of which are better defined than others, about
           when changes have to be re-reviewed, and it depends on
           whether it is a LOCA code, or a transient code, or a
           stability code.
                       And we have disagreements about that now
           and again.  But generally as long as they stay within
           the acceptance limits, then they can wander within the
           box.  And occasionally we see people do very creative
           things, and we try to convince them of the error of
           their ways when they do that.
                       Once again, as I said here, this is an
           unusual power uprate because it was based not on any
           one particular plant.  Most of the analyses were done
           for what was called Unit 5, and it was a bounding
           analysis of some plant that doesn't actually exist and
           that had parameters that bounded all of the four
           Dresden and Quad Cities units.
                       But our determination was that this
           equilibrium bounding unit -- the analysis of this
           equilibrium bounding unit demonstrated that the
           thermal limits are acceptable, and that the cores that
           will be designed eventually in the future to be used
           in these plants can be appropriately designed, and can
           be appropriately operated.
                       CHAIRMAN WALLIS:  Could you say what the
           thermal limits are again, and what you mean by it?
                       MR. CARUSO:  Up here on top, we have a
           safety limit minimum, minimum critical power ratio,
                       CHAIRMAN WALLIS:  Those are things like
           the 2200 degrees and things like that?
                       MR. CARUSO:  Some of these are 2200, like
           the LOCA limit to the right is there, and the safety
           limit, MCPR, and its derivative, the operating limit
           MCPR, are there to show that you meet the 99.9 percent
           boiling transition.
                       CHAIRMAN WALLIS:  Were these evaluated
           for -- I don't quite understand, but for some typical
           cores, which is a bounding -- some typical bounding
                       MR. CARUSO:  Yes.
                       CHAIRMAN WALLIS:  Well, then you are sure
           that this is somehow outside all the possibilities of
           the various limitations of cause or whatever?
                       MR. CARUSO:  For the purposes of doing the
           power uprate, they did a bounding calculation, but
           then for each individual plant, for each actual core
           design, they will verify that that core design meets
           those limits.
                       CHAIRMAN WALLIS:  The numbers that we were
           presented with, the 1600 degrees, and things like
           that, are the actual specific calculations for
           specific plants aren't they?
                       MR. CARUSO:  I think it depends on the
           analysis.  In some cases, they were plant specific,
           but in some cases they were bounding. I seem to
           remember some were plant specific, but some were also
                       CHAIRMAN WALLIS:  It would seem that
           eventually they all have to be plant specific.
                       MR. CARUSO:  That's correct.
                       CHAIRMAN WALLIS:  And one would expect the
           number to go down when it becomes plant specific if
           the previous one were bounding.
                       MR. CARUSO:  Yes, that's correct.
                       CHAIRMAN WALLIS:  Is that always the case?
                       MR. CARUSO:  I believe so.
                       CHAIRMAN WALLIS:  Does it go down by much? 
           Is it exactly 1600 in the bounding case, and 1599 for
           the plant, or something like that?
                       MR. CARUSO:  I don't think that they are
           going to go down to something like 700.
                       CHAIRMAN WALLIS:  I guess if we saw 1600
           for the plant, then the bounding unit must have been
           somewhere above the limit.
                       MR. CARUSO:  Let's see if I can get
           someone from the licensee to answer that.
                       MR. FREEMAN:  This is John Freeman with
           Exelon.  The 1600 degree was for the upper bound
           calculation on the LOCA analysis.
                       MR. CARUSO:  Oh, you are talking about the
           LOCA number.  Okay.
                       MR. FREEMAN:  I think that is what you
           were driving at, and that was a bounding number based
           on the Unit 5 approach, which covered all of the fuel
           types which were going to be in the reactor.
                       As far as whether some of them are cycle
           specific, or bounding, LOCA -- well, actually, all the
           thermal limits get reevaluated on a cycle specific
           basis.  However, most of them don't change.  The ones
           that we expect to change are the safety limit MCPR,
           the operating limit MCPR.  To a lesser extent, the
           LHGR, depending on how the center line melt and
           plastic strain limits are met.
                       So that is all done on a cycle specific
           basis.  However, I think the big issue was the LOCA
           analysis, and that is bounding.  The ATWS analysis was
                       So we don't expect to see any changes in
           those results without changes to the reactor system
                       CHAIRMAN WALLIS:  So this 1600 degree
           example that we have here is specific to each cycle. 
           So it is a variable.  It changes all the time?
                       MR. CARUSO:  Well, in this case, I think
           as the GE -- I think Dan Pappone did that presentation
           yesterday.  And he explained that they  have a 1600
           degree limit in the GE methodology.  So they may --
                       CHAIRMAN WALLIS:  But the 1600 is the
           actual as well.
                       MR. CARUSO:  And they calculate 1600 as
           the actual number, but they may vary the MAPLHGR
           limit, the linear regeneration rate, to stay below
           that number.
                       So they will use 1600 as the limit, and
           they will vary the heat generation rate to make sure
           that they stay within it.  The number may stay the
           same, and --
                       CHAIRMAN WALLIS:  And part of your
           licensing procedure is not just to say they have
           calculated a number which you approved of, but to say
           that you trust them to keep calculating it and to keep
           it below your limit?
                       MR. CARUSO:  Yes, that's very important.
                       CHAIRMAN WALLIS:  And you trust them to
           keep calculating it all the time because it is cycle
                       MR. CARUSO:  That's a very important
                       CHAIRMAN WALLIS:  And not to let it go
           over the limit.
                       MR. CARUSO:  That is a very important
           point, yes.  We trust them to do these calculations
           appropriately.  But we also verify from time to time
           that they are.
                       CHAIRMAN WALLIS:  So when they show us a
           number which is exactly on the border, 1600 calculated
           equals 1600 allowable, then this is for a particular
           calculation at a particular time that is implied with
           sort of our approval of that if we approve it, and
           they are going to keep doing this, and they are not
           going to allow themselves to go over that?
                       MR. CARUSO:  That's correct.
                       CHAIRMAN WALLIS:  And that they didn't
           understand at the time?
                       MR. CARUSO:  That's correct.
                       CHAIRMAN WALLIS:  And presumably they
           found that they were going over it?  What would they
           do, shut down the plant until they corrected something
           or what?
                       MR. CARUSO:  No, they have to revise some
           aspect of either plant operation or core design to
           make sure they stay below it.
                       CHAIRMAN WALLIS:  So they might then
           operate at a reduced power?
                       MR. CARUSO:  Exactly.
                       DR. KRESS:  They can only go over it on a
           hypothetical basis.
                       CHAIRMAN WALLIS:  Of course, it is a
                       DR. KRESS:  It is a calculation.
                       CHAIRMAN WALLIS:  Okay.  Thank you.
                       MR. CARUSO:  Let's see.  My next slide is
           Slide 28.  Let's see.  I have a general discussion
           here about system performance.  We looked at the
                       For example, the RCI system, the high
           pressure injection systems, and the low pressure
           injection systems, to see whether they would perform
           their design functions at the higher power, higher
           rated power.
                       And because this was a constant pressure
           uprate, those reviews were not very difficult to
           determine that those components would operate
           appropriately, because they see the same steam
           pressure, and they see the same reactor pressure. Most
           of the bounding parameters remain the same for these
                       DR. KRESS:  How did you decide that the
           isolation valves would perform their function just as
           well at the new uprate?
                       MR. CARUSO:  The isolation valves. 
           Actually, they have to be able to close on critical
           flow.  If you have a pipe break outside the MSIV --
                       DR. KRESS:  I understand, and the heat
           didn't change?
                       MR. CARUSO:  The pressure didn't change.
                       DR. KRESS:  Yes, but T did.
                       MR. CARUSO:  T?  Temperature?
                       DR. KRESS:  Critical flow is squared over
           KGRT.  It is steam.  It is close enough.
                       MR. CARUSO:  I don't think it matters. 
           Why did the heat change?
                       DR. KRESS:  Well, I thought you changed
           the outlet temperature.
                       MR. CARUSO:  No.
                       DR. KRESS:  Just the amount of steam flow?
                       MR. CARUSO:  The steam flow rate changed,
           but the steam pressure stays the same.
                       DR. KRESS:  So your blow down rates are
           about the same.
                       MR. CARUSO:  They would be about the same.
                       DR. KRESS:  And your pressure is about the
                       MR. CARUSO:  Right.
                       DR. KRESS:  So the loads on the valves, if
           they could close before, they can close now is what
           you are saying?
                       MR. CARUSO:  Exactly.
                       DR. KRESS:  Okay.
                       MR. CARUSO:  Let's see.  My next slide is
           Slide 29.  As I said, they performed the LOCA analyses
           for the bounding unit using an equilibrium GE-core.
                       This is the core that they eventually
           expect to get to once they replace all the Siemens'
           fuel in about 2, 3, or 4 cycles with GE-14 fuel.
           And we looked at the -- as part of our audit, we
           looked at the pre-EPU and the EPU analyses for LOCA.
                       These were done with the SAFER/GESTR
           methodology that was described yesterday, and as we
           have discussed in the past, the peak limiting bundle
           for these analyses doesn't really change.
                       So there was not much to look at in terms
           of changes to the methodology, and changes to the
           inputs to reflect the fact that it was a mixed core,
           Siemens fuel and GE-14 fuel, and it changes because it
           is GE-14 fuel which is going in for the first time.
                       But other than that, the methodology was
           applied appropriately, and the LOCA analyses
           demonstrated compliance with 50.46.
                       DR. KRESS:  This particular ECCS, to deal
           with LOCA, is it a head spray, or where does that come
           in at?
                       MR. CARUSO:  I need assistance.  This says
           -- well, Dresden has high pressure coolant injection. 
           How many high coolant injection pumps?  One high
           pressure coolant injection pump.
                       DR. KRESS:  And that is in the head coming
           down on top?
                       CHAIRMAN WALLIS:  It is a ring spray, a
           ring with a lot of nozzles on it.
                       MR. CARUSO:  It is a low pressure core
                       CHAIRMAN WALLIS:  We are asking the staff
           if they know or if they understand the system, I
                       MR. CARUSO:  Well, you are asking me off
           the top of my head, and I don't have all 37 BWRs in my
                       CHAIRMAN WALLIS:  I know.  I understand
                       DR. KRESS:  Well, part of my question is
           to see what you guys looked at, and the other part is
           if you flatten out the core profile, and you have got
           more steam coming up around the edges, and less in the
                       And you are basing your validation of your
           code for these ECCS based on something like the old
           tests in Germany and Japan, which didn't have a core
           profile.  It had a different one.
                       And does this put into question the
           validation of the codes that are used to calculate
           these peak clad temperatures?
                       MR. CARUSO:  Interestingly enough, this is
           one thing that we did actually talk to them about,
           spray distribution.
                       DR. KRESS:  Yeah, carry over and the spray
           distribution.  Right.
                       MR. CARUSO:  And it came up in a
           relationship to an issue involving license renewal of
           the BWR, and we were concerned about spray
           distribution over extended -- of a plant at the end of
           60 years, and would it still have the same spray
                       And in talking to G.E. about it, we
           learned that spray distribution is not important for
           the early part of the LOCA because of the assumptions
           that are made as part of the analysis.  They don't
           assume a particular distribution, but for the long
           term cooling portion of the LOCA analysis, spray
           distribution does become important.
                       And let me see if I remember the logic
           here, because this gets very convoluted.  Late in the
           LOCA sequence, the distribution is acceptable.  I am
           trying to remember the reason why we discussed this
           with them.
                       CHAIRMAN WALLIS:  Early in the sequence,
           you have got a pool don't you?
                       MR. CARUSO:  Exactly, and that's why --
                       DR. KRESS:  The pool is up on the top.
                       CHAIRMAN WALLIS:  But then how the pool
           drains will depend upon the amount of steam coming out
           of all of these channels, which is now different
           because you have gotten more heat source on the
           outside from the decay heat.
                       DR. KRESS:  And the question was how much
           of that drained and how much got carried out.
                       CHAIRMAN WALLIS:  Well, there is a
           different pattern of drainage, too, because of the
           flux distribution.
                       MR. CARUSO:  This was discussed.  We had
           a real long discussion with them about this.
                       CHAIRMAN WALLIS:  It was discussed, and so
           you are really sure that you are on good technical
                       MR. CARUSO:  Yes.
                       CHAIRMAN WALLIS:  And you looked at the
           effect of the new distribution of heat source across
           the core on the draining of that pool during a LOCA?
                       MR. CARUSO:  Yes.  The explanations are
           very reasonable.  I was going to suggest at some point
           that it might be a good idea -- well, I won't talk
           about that now.
                       CHAIRMAN WALLIS:  Well, you didn't find it
           necessary to do any independent verification
           calculations or anything on those phenomena?
                       MR. CARUSO:  No.
                       CHAIRMAN WALLIS:  Because I guess one of
           the generic questions that ACRS raised before was when
           do you decide to do your independent verification
           calculations, and when do you accept what you see from
           the applicant.
                       MR. CARUSO:  And as I said earlier, if we
           -- when we are using these approved methods within
           their acceptance criteria, we would do independent
           calculations if we had some specific and credible
           reason to believe that they were not appropriately
           being applied.
                       If we had some issue that had been raised
           by staff members, by the Office of Research, by the
           ACRS, by outside interested parties, that said they
           didn't consider this particular aspect.
                       And there is no way you can tell that from
           their analysis, and then we might do an independent
           analysis in that case.  But realize that the
           methodologies have been validated in many instances
           against the NRC codes already.
                       CHAIRMAN WALLIS:  We have no way of
           independently checking this.  We just have to ask you
           and sort of believe that you have done the job.
                       MR. CARUSO:  You would have to dig through
           piles, and piles, and piles of topical reports.
                       CHAIRMAN WALLIS:  That's correct.
                       MR. ZALENSKI:  For closure on this issue
           did I hear a comment or a question raised regarding
           the validity of our codes based on new data becoming
           available from Japan?
                       DR. KRESS:  No, the comment was that the
           codes -- that their validation was based on old data
           mostly, I think, and those used actual flux
           distributions that were not as flat as these.
                       And the question is does that put into
           question the validity of them, because it is based on
           old data with the wrong flux distribution.
                       MR. CARUSO:  Our question really had to do
           with the spray distribution, and to make sure that
           there was the spray distribution that was assumed as
           part of the analysis.
                       DR. KRESS:  Yes, it is the same issue.  Is
           the flux distribution going to maybe affect the spray
                       MR. BOEHNERT:  And whether the tests are
           still applicable.
                       DR. KRESS:  So that was the nature of the
                       DR. SCHROCK:  I guess I wonder how
           confident a particular analysis is bounding.
                       MR. CARUSO:  Generally, you mean?
                       DR. SCHROCK:  Yes, in general.  Do you
           scratch your head and say now why is this one bounding
           when I am going to make some changes?
                       MR. CARUSO:  Well, that is one of the
           reasons that we did the audits.  We sent people down
           to actually look at the inputs that were used, and the
           people that did the audits, like Ed Kendrick here, are
           experienced in core design and analysis methods.
                       And they know which parameters are
           sensitive, or which parameters can affect those
           analyses, and they looked at the bounding analyses and
           determined that G.E. had used the appropriate
           conservative values as inputs.  And they ran a number
           of sensitivity cases to verify that.
                       CHAIRMAN WALLIS:  Oh, G.E. ran them?
                       MR. CARUSO:  G.E. ran them.  That takes me
           to my next slide, which is Number 30, which is what we
           did as part of the audit reviews.  Fuel thermal
           limits, which is transients; and reactivity
           characteristics, and stability.
                       And we looked at detailed calculations in
           each of these areas to verify that they were done
                       CHAIRMAN WALLIS:  This is a check of
                       MR. CARUSO:  It is a check of the
                       CHAIRMAN WALLIS:  It is not an interactive
           thing, where you look over someone's shoulder and say,
           well, how about trying this and that, and let's see if
           it is really bounding.
                       MR. CARUSO:  No, but because it was done
           at the vendor site, and when people had questions
           about what was in the paperwork, they could
           immediately ask the people who did the work and get an
           answer.  They are interactive in that sense.
                       CHAIRMAN WALLIS:  And that wasn't actually
           sort of together running the code to see what happened
           under certain circumstances or that you were curious
                       MR. CARUSO:  No.
                       CHAIRMAN WALLIS:  It would be interesting
           if you could do that sort of thing.
                       MR. CARUSO:  We are about to do that for
           one of the advanced reactor reviews.  In this case, we
           didn't feel that it was necessary.  Are there any
           questions about the audits?  If not, my last slide is
           Slide Number 33, Conclusions.
                       CHAIRMAN WALLIS:  I guess it is hard to
           know, and I guess what I am thinking about here is how
           do we satisfy you did a good audit?  Well, I guess an
           example would be if you had a case history where you
           found something, and if the audit found nothing, it is
           a kind of evidence-free situation.
                       And we don't know if it is good or bad as
           you didn't find anything, maybe because you didn't try
           hard enough or maybe there is nothing there to find. 
           It is hard to know what to say.
                       But if you had a case history where you
           were actually curious about something, and you
           wondered about it, and when you probed deeper, yes,
           you indeed found that they really knew what they were
           doing, and they convinced you that everything was
                       That might be a little bit more harder to
           convince some independent person that the audit was a
           useful exercise.
                       MR. CARUSO:  I will go back to the Duane
           Arnold review and something that I said last time. 
           None of these audits should be looked at in isolation. 
           It is a series of audits, and we started with the
           Duane Arnold review, looking at areas that we had the
           most interest in.
                       And I am going to admit that we had an
           anterior motives besides doing the power uprates.  We
           wanted to understand how the vendors were doing their
                       So we were looking in places that we
           really didn't think we would find anything related to
           power uprates, but we wanted to just check how they
           had done the calculations.
                       And during the Duane Arnold review, we
           found a couple of significant issues.  We found one
           that led to a Part 21 report, and the next audit that
           we did, we decided that we would look at something
           different, because we only have a certain limited
           amount of time.
                       So we focused on things where we think we
           will find something, and in this case we came up with
           a dry hole so to speak.  But that's not bad.  The next
           time we did the Clinton audit.  I don't know what to
           say about the Clinton audit.  I think
           -- well, I don't want to talk about it.  That is pre-
                       But then we will do another one for
           Brunswick, and we will do another one for the plant
           after that, and at some point we will get tired, and
           we will stop.
                       DR. KRESS:  From the reactor safety
           evaluations, your previous slide, I sort of have a
           two-part question.  For the site calculations, 10 CFR
           100, did they redo an origin calculation to get a new
           inventory, or did they just scale up the previous
           inventory in some way, like using the power ratio
                       MR. BAILEY:  What the did -- this is
           Stewart Bailey, and I am the project manager for Quad
           Cities.  They did run origin for the new core loadings
           and for the 24 cycle, and they used that to develop
           scaling factors on the critical isotopes.
                       And they combined that with some of their
           previous analysis to evaluate the changes in the off-
           site dose.
                       DR. KRESS:  And I have a question to ask
           G.E. or that I asked the applicant people yesterday
           about the PRA, and the use of LERF.  With a different
           core inventory, with different power and a different
           amount of products in the core, should the definition
           of what constitutes an acceptable LERF be the same or
           should it change?
                       MR. BAILEY:  I am not going to touch that. 
           Mark Rubin will.
                       MR. RUBIN:  Good morning.  I am Mark Rubin
           from the PRA branch.  I think we have kicked this
           around with the committee a couple of times.  It is
           certainly a very valid point as we have mentioned
                       Generally, we see a large variety of power
           levels in currently operating plants, and when we are
           developing the guidance for Reg Guide 1.174, it was
           thought that we should try to be design independent,
           and site independent, and go with a LERF that would
           certainly be confirmatory on the Commission safety
                       We have plants at higher power levels
           operating now, and clearly have higher inventory,
           given a LERF.  We are sticking with the 1.174 criteria
           at this time.  I believe if we were to start the
           licensing plants at significantly higher power levels
           than currently operating, we certainly would want to
           reconfirm the LERF definitions, but at this time we
           think that this is appropriate.
                       DR. KRESS:  Because the power levels are
           generally within the mean of the distribution?
                       MR. RUBIN:  Yes, sir.
                       DR. KRESS:  I think that is a good answer.
                       DR. SCHROCK:  How about the way in which
           origin is used?  And one of the difficulties that I
           have in hearing that everything is done with
           previously approved codes, the codes can be used in a
           variety of ways, and Origin is an example, as it is
           designed it is a point reactor.
                       And so it doesn't do for you any spacial
           evaluation of different compositions in different
           parts of the core.  If you are going to use it to do
           that, then you have got to apply it in a particular
                       Another limitation that it has is that the
           composition of the core is constant during a time
           step, and so the limitation that you may place on the
           time step will have an impact on the accuracy of
           results that you get from the application of the code.
                       So what I am asking is do you look at how
           Origin is employed in different parts of the analyses
           that are necessary on these evaluations?  It comes up
           in a number of ways; for the radiological consequence,
           for the activities, for a wide range of things.
                       In a sense, it is a more general question. 
           It is how do you assure yourself that what you regard
           as an adequate previously approved code, which you
           then have confidence in the results for a new
           application, is being applied in a way that you should
           still have that confidence.
                       MR. CARUSO:  Well, for the -- I can't
           speak to Origin, because I was not involved in
           reviewing the origin code.  We don't have the
           individual here.
                       But I think the question is probably also
           applicable to the other codes that we deal with, and
           I guess you could say, well, how do we know that they
           are not doing and creating a notalization, for
           example, or creative time steps control.
                       And the answer is that we when we do the
           review of the LOCA codes, for example, we approve
           explicit notalizations, and they are required to do
           time step studies to verify that the time steps that
           are used demonstrate convergence.
                       There are lots of criteria that go into
           approving a method to make sure that people don't use
           it too creatively.  And if you go look at the way the
           vendors have set up their calculational systems, they
           are very rigid because they can't afford to have to
           defend lots of creative solutions.
                       And so they do things in rather rigid
           ways, and we found this of all the vendors.  They all
           proceed this way.  So it is our experience that with
           codes like the LOCA codes, they are rather set in
           their ways.
                       So they don't do things very creatively
           with those codes, because it is not worth it to them
           from an economic basis, and we try in approving the
           methodologies to define the box so that they can't be
           too creative.
                       I can't answer with regard to the origin
           calculation, but I understand the question that you
           are asking.
                       DR. SCHROCK:  And another question
           regarding the approved codes.  According to the SAR
           and I believe also your draft SER, one of the ECCS
           LOCA codes that is in the table of approved codes is
           said not to have been previously approved, but to be
           currently under review and that is TASK.
                       MR. CARUSO:  Yes.
                       DR. SCHROCK:  Can you tell us the status
           of that?
                       MR. CARUSO:  I can give you some history
           behind this.  This is actually -- this is one of those
           examples of something of a change that might not be
           considered to be a change.
                       G.E. had previously been using a code
           called SKAT.  The same four letters rearranged
           slightly different.  That was the code that was
           explicitly approved in the methodology for -- I
           believe it is a LOCA methodology.
                       And along the line they are allowed to
           make changes to the LOCA methods to a certain extent
           without our approval.  And in this case, they made a
           change that involved a change in the name of the code,
           and they didn't think it was a change that required
           our review.
                       During an industry audit of their
           methodologies, the industry found this change and said
           we think you should send this to the NRC for review. 
           And the staff, when they found out about it, said,
           yes, we agree.
                       So G.E. submitted the code to us for
           review, and I just go the draft SER from Tony Ulyses
           this morning, and he believes that it is acceptable. 
           He thinks it is a relatively minor change, and we will
           be approving that.
                       So the change from SCAT to TASC is one of
           these changes that they are allowed to do, but we
           always do have disagreements about when is a change
           significant and when is it not.  And those are things
           that we can work out with them.
                       DR. SCHROCK:  I guess if my experience is
           relevant to what the committee knows about these
           codes, there is a large question mark as to what
           really the codes contain.
                       So what you have just described as a
           process of approval of a new code, which isn't going
           to come to the committee for review, it is one of
           about six things that are indicated as being a part of
           the ECCS LOCA evaluation, I don't know what they do.
                       And so I don't know how I can say yes, I
           think the ACRS ought to agree that NRR has a sound
           basis for saying that they have reviewed all of this,
           and it is in fact well accepted.  There is something
           missing in here as I see it, and I may not be seeing
           it the way as members of the committee.
                       I don't see how you can expect to have
           people look at what you have said and accept what you
           have said if you don't show them what it is that you
           are talking about.
                       MR. CARUSO:  Well, the LOCA codes are an
           unusual case, in the sense that 50.46 explicitly
           allows licensees and vendors to make changes to LOCA
           codes without approval of the staff.  It is written in
           the regulation.
                       They are required to report to us
           periodically, at least on an annual basis, when they
           do make those changes.  And the effect of those
           changes on PCT limits.  But this is in the regulation.
                       And so it gets -- well, the difficulty is
           that it is not spelled out very well in the regulation
           what exactly is -- well, I shouldn't say that, because
           the regulation does have a criteria.  It has a 50
           degree criteria when the accumulation of temperature
           changes reaches 50 degrees, licensees are required to
           make a report to us, and they are required to redo
           their analyses.
                       But when you talk about whether those
           changes have to be approved by the staff, the staff
           has an opportunity to discuss them with the vendors,
           and decide whether they should be reviewed.
                       But we do approve minor changes to
           methodologies all the time without coming in to ACRS. 
           I am not sure though that you wouldn't want to see
           every one of them.
                       So we make a judgment as to whether
           something is major or significant, and we consult with
           the ACRS staff to see whether you would like to review
           it, and most of the time the answer is no.
                       MR. ZALENSKI:  In fact, there is another
           provision in there, in 50.46, when the licensee trips
           50 degrees, that is a 30 day report.  When they trip
           20 degrees, that goes into their annual report as to
           changes that they have looked at and anticipated, and
           maybe adopted, or maybe not adopted.
                       DR. SCHROCK:  But these are the results of
           calculations and the ability to judge that the
           calculation is an adequate calculation that I am
           really questioning.
                       CHAIRMAN WALLIS:  What you are saying is
           that they could put complete nonsense into the physics
           and get 10 degrees.
                       DR. SCHROCK:  Yes.
                       MR. CARUSO:  And that's why I said we
           tried to write the acceptance of the methodologies in
           such a way that they can't be too creative.  And we
           try to do that, and that's why we like to do these
           audits, because these audits give us an opportunity to
           go see how creative they are.  That's why we thought
           that this was a nice opportunity for us.
                       CHAIRMAN WALLIS:  Are we breaking this up
           and trying to do --
                       MR. CARUSO:  No, I'm done.
                       CHAIRMAN WALLIS:  You're done?
                       MR. CARUSO:  I'm done.
                       CHAIRMAN WALLIS:  So how many of these
           have you covered?  I have lost track.
                       MR. CARUSO:  The last one was number --
           well, page 30.
                       CHAIRMAN WALLIS:  And all these other
           numbers before that you have covered in some other
           sort of order?
                       MR. CARUSO:  Actually, a lot of those were
           backup slides.  I was going to offer those up if you
           had questions about particular issues, such as
           stability of thermal limits, or fuel design, and I
           could give you details.
                       CHAIRMAN WALLIS:  So your bottom line one
           of all these numbers here is?
                       MR. CARUSO:  Is Number 33, which says that
           they used appropriate methods.
                       CHAIRMAN WALLIS:  And they got appropriate
                       MR. CARUSO:  And they got appropriate
           answers.  And we looked at them, and we looked at how
           they did it specifically as part of the audit, and we
           didn't find anything unusual.
                       And we have not heard any credible
           specific evidence raised that the methods are not
                       DR. SHACK:  Just following up on Virgil's
           question.  What kind of changes are they making when
           they are making these changes all the time?  I mean,
           can you think of some examples?  Are they changing
           correlations, or they are not changing numerical
                       MR. CARUSO:  Well, no, they don't change
           numerical methods.  They might change a correlation. 
           I mean, very frequently, they will -- well, for
           example, they will come up with a new fuel design.
                       So they have got to put a new correlation
           into the model to account for the new fuel design, and
           I have had some people doing a bunch of those.  A lot
           of times they find errors.
                       DR. SHACK:  Right.
                       MR. CARUSO:  But they are usually minor. 
           They are minor errors, and a lot of what gets reported
           to us is that we have identified that we made a non-
           conservative assumption about the start of the ISI
           pump, and instead of starting at 28 seconds, it starts
           at 32 seconds.  Something like that.
                       DR. SHACK:  Okay.  A lot of these affect
           input assumptions?
                       MR. CARUSO:  Right.  A lot of them affect
           input assumptions.  I can't think of any off the top
           of my head that affected internal workings of the
                       CHAIRMAN WALLIS:  So you said you were
           done.  What is the next move?
                       MR. CARUSO:  Plant systems.
                       CHAIRMAN WALLIS:  Thank you very much,
                       MR. BAILEY:  Starting on 35.
                       MR. CARUSO:  Oh, let me ask one other
           question.  Is there anything that I need to take away
           from this session as a testing or a query, or
           something that you would like us to talk about
           specifically at the next session in front of the full
           committee that I have not covered?
                       CHAIRMAN WALLIS:  Well, it is hard to say
           exactly what will happen at the full committee
           meeting.  It is a fresh game, you know, and then our 
           mines will be working between now and then.
                       MR. CARUSO:  But nothing that you can
           think of right now?
                       CHAIRMAN WALLIS:  I think you ought to
           read the transcript.  Does any member have anything
           that they wish to add at this time?  If not, let's
           move on then.
                       MR. ARCHITZEL:  My name is Ralph
           Architzel, and I am the lead reviewer for the plant
           systems branch review for the extended power uprates
           for Dresden and Quad Cities.  There were additional
           reviewers that looked at various areas during this
           review, and they were Ron Young, and he is not with us
           today, but other members are here that looked at the
           HVAC control room features.
                       Steve Jones looked at some of the spent
           fuel pool issues, and Rob Elliott looked at the
           strainer delta-P calculation aspects of it, and it's
           not really related to EPU, but it got resolved during
           the course of the EPU.
                       And in addition, Rich LaBelle assisted
           with the containment performance reviews, along with
           Ben Gitnick, who is our ISL contractor, during the
           Duane Arnold audit.
                       Basically, the plant systems branch -- if
           you could go on to the next slide, and the slides are
           a little bit changed from what I saw last night.
                       Basically, the plant systems branch has a
           wide breadth of responsibilities.  The way that we
           performed our review is that it is somewhat different
           than reactor systems, but I will go over it right now.
                       We reviewed the design operation
           requirements for the systems, using the UFSAR.  We did
           examine application for conformance with the approved
           topical report, and the statements in the topical
           report safety evaluation, and that was quite an
           extensive review just to get that information and
           digest it, because I was not one of the original
           reviewers for the EPU.
                       We assured Agency regulations and reg
           guides are met under EPU conditions, and that is the
           reg guide standards, and in this context, you have to
           go back to the licensing basis for the plant as well.
                       So it is not always a straight correlation
           for a standard review plan, or for the regulatory
           guides.  We held telephone conferences, quite a few,
           to clarify the applications, and to systems design and
           operation, and the responses.
                       And in that context, these applications
           aren't sometimes quite as extensive as what you see on
           the FSAR.  So there is -- where we search for
           additional clarifications are in areas where there
           wasn't quite the detail that we felt was necessary to
           make the safety decision.
                       We issued RAIs to resolve questions
           regarding the licensee's EPU evaluation results, and
           the supplement to documented information.  In our
           review, we did coordinate with different branches
           because we do have a wide breadth of responsibility,
           and where others might have the lead.
                       This included working with the PRA branch
           on the impacts on our affected systems, and we worked
           with the inspection programs branch on start-up test
           issues, and station blackout input with the electrical
                       And the radiological source term with
           Steve Levine when we are doing the control room HVAC
           reviews.  Our conclusion was that the EPU did not
           adversely affect the operational basis of the
           responsible areas that we had under our review.  Go to
           the next slide.
                       The next series of slides basically is a
           tabulation of the areas where we provided input into
           the EPU safety evaluation report.  I assume you have
           it and that you have read it.
                       I don't know that I want to go over all
           these unless you really had questions.  There were
           certain areas where we had significant review items,
           and I have asked Rick for those, and they are on the
           last page, but right now I will just flip through
           these areas, unless the committee has any questions.
                       DR. KRESS:  I have a question about the
           containment performance, and it has to do with source
                       MR. ARCHITZEL:  All right.
                       DR. KRESS:  There is this alternate source
           term that is in 10 CFR 100 to show compliance with the
           thing, and there is one for BWRs and one for PWRs.
                       The question that I have is whether that
           is the source term that they used to show that they
           meet 10 CFR 100?  And does the fact that you have a
           different power, should it influence the design basis
           source term from the standpoint of bypass around the
           suppression pool, and the temperature and
           effectiveness of the suppression pool in removing
           source terms?
                       MR. BAILEY:  This is Stewart Bailey, the
           PM for Quad Cities.  The licensee did not go to the
           alternate source term as a part of this update.
                       DR. KRESS:  They used the old source term?
                       MR. BAILEY:  They were originally a TAD
           14844 source term, and they ran the origin runs to get
           appropriate scaling factors, and usually just scaling
           up the critical isotopes.  They have not gone to
           alternate source term yet.
                       DR. KRESS:  Did they take credit for
           sprays, containment sprays?  I understand that this
           particular --
                       MR. BAILEY:  My understanding is that they
           did not.  They would have to clarify that.  Our
           reviewer, or the person who reviewed all of the dose
           analysis in detail is not here today.  But my
           understanding is that they did not credit the spray
           for iodine scrubbing.
                       DR. KRESS:  But do you know what they used
           for a suppression pool decontamination factor?
                       MR. BAILEY:  I don't know that offhand.
                       DR. KRESS:  I guess I would have to ask
           the people --
                       MR. ARCHITZEL:  Yes, as that was not
           within my review.
                       DR. FORD:  Could I ask a question of the
           previous graph about radiological source terms?  In
           that analysis that you did, you referred to Hydrogen
           16.  A case has been made that because you are using
           Noble Chem that Hydrogen 16 would be reduced.
                       Was there any analysis that was done as to
           how well the Noble Chem is going to stand up to the
           high flow rates, in terms of this adherence?
                       MR. ARCHITZEL:  Let me just explain that
           my part of that review was basically asking or had
           some questions about the use of Noble Chem, and
           whether they wanted to credit it for reduced hydrogen
           usage, or excuse me, when they came to the limit on
           the recombiners.
                       So there are different aspects that have
           been involved on whether they were going to use or
           credit Noble Chem, and they stated in their response
           to the RAI that that was not their licensing basis. 
           But they planned to use it.
                       As far as the aspect that you are talking
           about, the degradation of Nobel Chem, I did not look
           at that area, and I am not --
                       MR. BARRETT:  This is Rich Barrett with
           the NRR staff.  A number of questions this morning do
           seem to relate to the way in which the radiological
           consequences -- the source term, et cetera -- were
           calculated, and we do not have our reviewer here
                       If the Committee would be interested in
           having someone here, we could probably arrange to do
           that this morning.
                       CHAIRMAN WALLIS:  Maybe you could arrange
           for someone to come after the break, since there have
           been several questions, and that would be helpful. 
           Can you do that, Rich?
                       MR. BARRETT:  Yes, we will look into that.
                       CHAIRMAN WALLIS:  Thank you.
                       MR. ARCHITZEL:  At this point, I would
           just like to return to the list of areas and quickly
           go over them, and then if there are questions, I do
           have backups for some of the areas of review.
                       Main steam isolation valves, residual heat
           removal/LPCI/containment cooling and shutdown cooling
           systems, are basically the modes that reflect on the
           containment response, and not to the heat portion of
                       DR. FORD:  Will the discussion on the
           steam separator performance, will that come in later
           on in materials degradation?
                       MR. ARCHITZEL:  The discussion is a
           limited discussion, and the limited review that I did
           on the steam separator performance is strictly to
           verify that they were going to test the moisture
           carryover and you heard a discussion yesterday, but
           that was the response that they got in the REI.
                       As far as the structural part of the
           separators, and what the staff reviewed, that would be
           the mechanical engineer --
                       MR. BAILEY:  Dr. Ford, you are interested
           in hearing from mechanical engineering on the
           structural integrity of the dryer?
                       DR. FORD:  Yes.
                       MR. BAILEY:  I think we can arrange that.
                       DR. FORD:  Well, it is really just the
           process that you went through to assess their analysis
           that there would not be a big impact of fluence use
           vibration, for instance.
                       CHAIRMAN WALLIS:  The loss of parts or
                       DR. FORD:  Loose parts analysis, and just
           the process that you went through.
                       CHAIRMAN WALLIS:  So you will have
           somebody on after the break then?
                       MR. BAILEY:  Yes.
                       MR. ARCHITZEL:  If there are no questions
           on this slide, we will go on to the next slide.  In
           the containment systems performance area, we did
           review the containment pressure temperature response,
           and this is one of the areas where you may have
           additional questions.
                       CHAIRMAN WALLIS:  Did you do an
           independent calculations of any of these things?
                       MR. ARCHITZEL:  What we did in the
           containment systems area is that we coordinated with
           the Duane Arnold review, and the independent review
           that was done for Duane Arnold.
                       I participated in that review and those
           calculations, and it contained code that was used
           there as the same containment code that was used for
           Duane Arnold and Dresden.
                       We also had those reviewers, Rich LaBelle
           and ISL, look over the containment response portions
           of the application, and they participated in the
           review of the additional questions and the details
           that we searched for, in terms of being able to make
           our safety decision.
                       We did not do independent calculations for
           the containment response for Duane Arnold and Dresden,
           but we relied on that containment response.  We may in
           the future do additional independent calculations, and
           mass energy release is an area that we may look at,
           but at the moment it was to compare it to the codes
           that G.E. used for this evaluation.
                       MR. BAILEY:  And I guess another part of
           that is that we took a look at their inputs and
           methodologies.  We had done confirmatory analysis of
           their containment response within the last 3 years. 
           So we have looked at what they are doing recently.
                       MR. ARCHITZEL:  And that was more in the
           MPSH area, which is a different slide.  We did have
           those calculations.  This may go fairly quickly,
           because if there aren't any questions, we can on --
                       DR. KRESS:  Well, the containment dynamic
           loads, does that include the loads on the suppression
           pool --
                       MR. ARCHITZEL:  Yes, it does, but
           basically those loads were bounded as per the EPU, and
           aspects like whether or not the -- you know, with the
           same pressure as the driving source initially, EPU is
           a second order effect sort of on the containment
                       So there wasn't a tremendous amount of
           difference impacted by the EPU except in the long
           term.  Now, the TORUS temperature went up for two
           reasons.  One, the analysis methods changed.  They
           used a more realistic blow down.
                       That gets the energy into the suppression
           pool faster, and they also no assumed thermal
           equilibrium between the TORUS air space temperature
           and the water and the TORUS, and the higher
           suppression pool temperatures, and the MPSH needs were
           increased because of the EPU.
                       And those are the types of things that we
           looked at, and we asked for curbs, and we have curbs
           for the containment pressure response, and trying to
           understand what was happening at different points. 
           But we did not do any analyses.
                       The safety relief valve discharge loads
           and things like that were not affected, because there
           is a time when it affects the drain down, and we also
           looked at aspects like with the increased temperature,
           and with the squenchers, and the steam that was coming
           out of the squenchers intersect with the suction of
           the ECCS pumps.
                       And they provide discussions and envelopes
           for that would not be in the phenomena, and so
           therefore they didn't have a local pool temperature
           effect addressed or limit addressed.
                       On the very last page, I happen to have a
           list of the ones that are on 46, are the areas where
           we had additional input, and one of them was the
           4.2.5, and there is no more information there than the
           net positive suction head.
                       And I guess I would like to say on the net
           positive suction head that that was one of these cases
           where it was an existing open issue before the EPU
                       Most or a lot of our review items or
           aspects, the EPU has a negative effect on net positive
           suction head by raising that pressure, and therefore
           there was an increased demand, and it was addressed in
           the ELTR about the potential need for plants to take
           credit for net positive suction head, and there will
           be an additional need for net positive suction head.
                       And in this instance, that effect is
           there, and we have looked at it.  I could show you the
           credit they have requested, versus the existing
           credit.  There is no additional credit requested in
           the very beginning of the transient for either Dresden
           or Quad Cities.
                       But with time that credit does go up for
           periods of time and it hangs in there longer.  So if
           I could take a curve and show you how it is affected
           if you are interested.
                       CHAIRMAN WALLIS:  Is this still acceptable
           to you, that we take this credit?
                       MR. ARCHITZEL:  Right.  We tried to
           minimize the credit that we allow them to receive.  So
           the questions were along the lines of did you examine
           and replace the pumps, or some type of other mechanism
           to reduce the pressure, and of course that was not
           economically feasible was the answer that we got back.
                       So in that instance would the EPU have any
           approval for the potential additional over credit.  We
           looked at it, and it was not a major increase in over
           credit over what has currently been granted.
                       CHAIRMAN WALLIS:  And there is no basis
           for saying that the pump performance is likely to be
                       MR. ARCHITZEL:  Well, the cavitation, they
           do have cavitation at Dresden and Quad Cities after
           the peak as you heard yesterday.  When I went to the
           audit, I did see the testing that was done, and it was
           like about an hour-and-a-half testing at cavitation
                       And so there is cavitation, and even
           though we have granted that credit, they still don't
           have enough credit for 290 until about the 10 minute
           point, where they take credit for operator action.
                       The procedures are in place to reduce the
           flow for the operators, and so there is no reason to
           really believe that it would necessarily go that long,
           the cavitation route.
                       And part of the questions that I was
           asking was also to make sure that the operators
           actually weren't going to throttle back those flows
           and leave the extra pumps running if they did have
           sufficient MPSH.
                       So I guess if the question is if we are
           comfortable with the net positive suction head credit
           that we are granting, the open issue that existed did
           deal with strainer differential pressure.
                       And it has taken a long time to get that
           resolved, and there have been open issues.  Actually,
           Quad Cities did not have credit for containment over
                       They had an application in-house which we
           had not approved.  We rejected it because the methods
           that they had used were not in accordance with the
           URG.  Very lately, we have gotten the submittal that
           does follow the URG recommendations and SER.
                       We have looked at it, and we have not
           written the SER yet, but that should not be a problem
           for this uprate then.  But as for the strainer and
           differential pressure, and the unique strainers they
           have got, they developed a head loss.
                       CHAIRMAN WALLIS:  So the final SER will
           explain why you feel comfortable in some detail?
                       MR. ARCHITZEL:  Well, actually the
           strainer differential pressure influence in this EPU
           was in the conservative or the effect of raising the
           temperature actually results in a lowered differential
                       So in that aspect, it is not a concern,
           but we will explain that in the SC.
                       MR. BOEHNERT:  What was the issue with the
           fuel pool cooling?
                       MR. ARCHITZEL:  The issue for the fuel
           pool cooling is strictly the increased decay heat and
           how you handle increased decay heat.  We are taking
           new looks at fuel pool coolants these days, and what
           single failure exists, and it turns out that with
           Dresden there is a difference between Dresden and Quad
                       And that they use and credit the RHR fuel
           pool system, and they have a dedicated RHR -- well,
           excuse me, a dedicated shut down cooling system at
           Dresden, and Quad Cities has the residual heat removal
                       But basically it is the single failure. 
           We examined the single failure that they are talking
           about, and with the RHR pump, it is just identifying
           the single failure, and we got into discussions about
           do you really have an RHR backup or you don't you,
           administratively, and things like that.
                       And what temperature are you going to go
           to, and what are your makeup rates, and do you exceed
           the design of 150 degrees or not.  You get a little
           more detail, and there is very short sentences in the
                       So finding out all the details of how that
           worked, and what administrative controls were in place
           to assure that you had a backup, and assumed the right
           single failure.
                       The make-up rates were not really stated
           correctly in the application, and so we got an
           understanding of it really has significantly more
           makeup, and they provided us the boil off rate, and
           those types of issues.
                       CHAIRMAN WALLIS:  There is no ultimate
           heat sink?
                       MR. ARCHITZEL:  The ultimate heat sink
           -- and if you are on to that page.
                       CHAIRMAN WALLIS:  I am looking at the
           slide behind you there that says that was an area --
                       MR. ARCHITZEL:  Well, you are one ahead of
           my slide, but okay.  In the area of ultimate heat
           sink, the staff review is not complete on the ultimate
           heat site.  This is another area -- well, the EPU
           effect just for Dresden.
                       At Quad Cities another fairly short
           discourse provided by the licensee, but the basic
           bottom line is that with dam failure at Quad Cities,
           the pool behind that dam separates from the plant
           after a defined amount of time, and that defined
           amount of time is what they currently need to provide
           portable pumps for their ultimate heat sink.
                       Dresden is the area where we have not
           completed our review at this point, and one of the
           principal reasons that I did go to the site to do an
           audit on their calculation of the situation.
                       This is another existing open issue.  The
           licensee discovered problems with their design basis
           reconstitution several years ago, and after they
           discovered those problems -- they are dealing
           basically with which volumes are available in the
           seismic aspects of the system and the timing of the
           operator actions.
                       And we evaluated those conditions before
           the EPU, and we provided the region a TIAA response to
           what areas to look at, and basically the EPU effect is
           to shorten the time period for manual actions go get
           portable pumps, and make up into the canal, which they
           consider their seismic -- if you will, a seismic
                       There still is no seismic source from that
           point into the isolation condenser.  So that is part
           of the staff approvals that is really part of the
           issue that is still open, but basically the new
           information came out fairly late, and the EPU effect
           is not significant from a safety standpoint.
                       We have looked at that, the 4.5 days to
           the 4 days is the latest information that we have
           received, there is other information, for example,
           that with EPU that you need 2.9 million gallons in the
           intake canal, versus 2.5 million before.
                       That is just boiling water, and it is not
           really what you really need, and so the 30 days is not
           -- and whether that was in their licensing basis is
           questionable.  So it is not clear if there ever were
           a 30 day type of a plant.
                       And these are just discussions in the
           history that we are evaluating.  And there are also
           aspects that are currently under review, like proposed
           modifications to add a seismic Class One capability
           within several years for the IPEEE.
                       CHAIRMAN WALLIS:  I was going to ask you
           about seismic.  Are you the right person to ask?
                       MR. ARCHITZEL:  I can describe my
           understanding of what is seismic and what is not
           seismic with the Dresden plant.
                       CHAIRMAN WALLIS:  Well, we were given this
           IPEEE part of the draft on the SER, and it talks about
           that it is an inadequate seismic margin at some point.
                       MR. ARCHITZEL:  Well, I guess that is
           where you consider, and Donnie maybe could talk a
           little bit to those numbers that you heard some about
           yesterday, and the impact is not tremendously safety
           significant of those future modifications.
                       CHAIRMAN WALLIS:  It may not be safety
           significant, but are they meeting the regulations
           then, in terms of --
                       MR. ARCHITZEL:  Well, let me just say that
           for the current regulations -- and Donnie can talk
           about the safety aspects of it, but for the current
           regulations and with the seismic makeup that they
           have, the isolation condenser, which would last now
           and which would last before, 20 minutes approximately.
                       They are keeping that power level just
           like the bypass valves, and they have got a set power
           level, and it is a fraction of the existing power
           level when it uprates, and so for 20 minutes they have
           a make-up capacity that is seismic.
                       In addition to that, they have the
           containment, and they have got the ability for a day
           of containment.  But the remainder of the seismic
           capability to make up to the isolation condenser, they
           have diverse sources.
                       And the diverse sources have some seismic
           rigidity, but they are not safety related.  You
           wouldn't credit them an existing plant today.  And we
           have looked at some of the seismic statements.  There
           is one statement in the SEP that the far water system
           was qualifiable.
                       MR. BAILEY:  I think we are talking two
           different things here, in terms of the low rigidity
           that is discussed in the safety evaluation, and I
           don't believe that that applies here.  Can you give an
                       CHAIRMAN WALLIS:  I am referring to this
                       MR. BAILEY:  That is not really the issue
           we are talking about for the ultimate heat sink.
                       CHAIRMAN WALLIS:  No, it's not.
                       MR. BAILEY:  For the ultimate heat sink
           that the staff review is still ongoing, we are trying
           to make sure that we understand all of the scenarios,
           and all of the available water, and --
                       CHAIRMAN WALLIS:  And that is a different
                       MR. HARRISON:  This is Donnie Harrison
           from the PRA branch, and the reference you are making
           to the .09G HCLPF value is a reference out of the
           IPEEE for Quad Cities.
                       CHAIRMAN WALLIS:  Right.
                       MR. HARRISON:  And it was recognizing that
           that was, if you will, an unacceptably low seismic
           capacity for a plant.  At that time the licensee was
           still in the process of making modifications, and most
           of that was I believe Cable Tray and Anchorage.
                       And since that time I think at Quad
           Cities, they are going to complete all their
           modifications by the next outage, the completion of
           the next outage for each of those two plants.
                       At that time the concern that the staff
           was raising was there is not going to be a
           reevaluation to see where the plant is.  So the staff
           used some numbers from Dresden, partly because the
           Dresden -- well, we had the information on Dresden,
           and the seismic hazard at Dresden is actually a little
           higher than Quad.
                       So we felt comfortable as just being a
           perspective of where the risk was for the .09G plant,
           as opposed to going up to, let's say, your design
           basis at 1202.4 from a HCLFP value.
                       And that was provided mainly to raise the
           issue and to get a risk perspective of where the plant
                       CHAIRMAN WALLIS:  Is there going to be a
           presentation from the staff on the risk perspectives?
                       MR. HARRISON:  We can at any time you
           want, yeah.
                       CHAIRMAN WALLIS:  And that is where we
           could revisit this seismic margin issue then perhaps.
                       MR. HARRISON:  Sure.
                       CHAIRMAN WALLIS:  So we will have that
           again later in the morning, or timing willing, I
                       MR. ARCHITZEL:  We will do that after the
           break.  And we can work out the order of presentation
           after the break.
                       CHAIRMAN WALLIS:  And we are approaching
           the break as we approach the end of this presentation.
                       MR. ARCHITZEL:  Well, I think that is
           about it for ultimate heat sink.  Part of the issue
           also is whether the calculations were conservative or
           not, or formalized, and those issues are still being
                       DR. SCHROCK:  And that issue is limited to
           the Dresden?
                       MR. ARCHITZEL:  That's correct.
                       DR. FORD:  And the feed water issues and
           corrosion, that will come in later?
                       MR. ARCHITZEL:  Yes.  There is something
           there on feed water, and about flushing out and how
           the system changed, which was not in the application. 
           And getting additional information on the logic behind
           running the pumps and saving the plan, and the plant
           availability on how you run it, and where the suction
           trips come in.
                       And actually trying to maintain the plant
           on line was the focus of my review in the feed water
           area.  And the next slide.
                       CHAIRMAN WALLIS:  This is the last one.
                       MR. ARCHITZEL:  That's it.  And the last
           one was just going over the -- well, it is sort of an
           open listing of areas that we reviewed, and if you had
           questions, I could go into more.  But if you don't
           have questions, then -- you know.
                       CHAIRMAN WALLIS:  Are we ready for a break
           now?  Are there any questions from members of the
                       MR. HANNON:  Excuse me, but this is John
           Hannon.  I wanted to make sure that one of the points
           that Ralph made is clear, because it relates back to
           one of your concerns on the Duane Arnold review, and
           John Zalinski asked me to follow up on that.
                       One of your points was that the staff
           should develop criteria for when independent
           assessments should be performed to compliment our
           reviews of the applicant's submittal.
                       And this is one case where we did it on an
           ad hoc basis.  We sent Ralph to the site to do some
           independent verification of the calculations that they
           had done for the ultimate heat sink.
                       And the point that I wanted to make is
           that we do do that on an ad hoc basis when it appears
           to be appropriate.  And this is a case where we
           thought it would be appropriate for us to do it.
                       MR. ARCHITZEL:  And also when I went to
           the site also, you looked at the calculations for the
           net positive suction head that the licensee had done. 
           So it was two different areas where we examined,
           including that.
                       CHAIRMAN WALLIS:  Thank you.  So are we
           ready for a break?  So we will take a break until 25
           until 11:00, a 15 minute break; and after the break my
           colleague, Jack Sieber, is going to Chair, and I am
           going to turn the Chair over to him.
                       I would ask my colleagues to send me
           comments on this whole issue so I can prepare a letter
           for the full committee.
                       (Whereupon, the meeting was recessed at
           10:19 a.m., and resumed at 10:36 a.m.)
                       MR. SIEBER:  I would like to call the
           meeting to order.  In looking at the agenda, we have
           on the last page a response to ACRS questions, which
           I think we should go through at this time.
                       And then we had some additional questions
           on source term in the PRA, and so we can deal with
           those at the staff's convenience.  You can arrange
           however you want to give the remaining presentations.
                       MR. BAILEY:  We wanted to make a small
           change in the agenda to address your request for a PRA
                       MR. SIEBER:  Okay.
                       MR. BAILEY:  Donnie Harrison will present
           his PRA analysis, and if this is all right with you,
           then we would return to the responses to ACRS
           questions portion.
                       MR. SIEBER:  Okay.  That's fine.
                       MR. BAILEY:  And for clarification, we did
           not get somebody or we were not able to get somebody
           here to answer the questions related to the
           radiological analysis.
                       MR. SIEBER:  Okay.
                       MR. BAILEY:  So if there are questions or
           information you would like us to bring to the full
           committee, we can offer you that.
                       DR. KRESS:  I think those were mostly
           clarification questions that I had, and I can dig in
           to the stuff we have and get them out.
                       MR. BOEHNERT:  So why don't you stand by
           and we will let you know if we want something in
           follow-up on that.
                       MR. BAILEY:  All right.  Very well.
                       MR. SIEBER:  Okay.  Why don't we begin.
                       MR. HARRISON:  Good morning.  My name is
           Donnie Harrison, and I did the PRA portion of the
           review of the power uprate.  And these slides are just
           back up information in response to your questions.
                       MR. BOEHNERT:  We will need copies of
                       MR. HARRISON:  We will walk you through
           it.  If we could just move on to the next slide. 
           Basically, the information that we received from the
           licensee is provided on this slide, as well as what
           the staff used in its review.
                       We have the original submittal by the
           licensee, which was just a couple of paragraphs if I
           remember correctly.  That was supplemented in about
           the February time frame to address the key areas of
           review that the staff typically looks at in the risk
                       We then had a series of -- one major round
           of RAIs with a series of clarifications and meetings
           and such, and conversations on, and again this covers
           the areas of internal events, external events,
           shutdown operations, and then also just an area of PRA
           quality, and does the plant reflect the as-built as
           operated facilities.
                       The staff review looked at the licensee
           provided information.  We also looked at other areas. 
           For example, much of the external events questions
           from the staff were derived from the Ses that were
           written on the IPEEEs.  We also pursued areas that
           maybe the SE called out on the IPE.
                       DR. KRESS:  And how exactly did you assess
           the quality of the PRA?
                       MR. HARRISON:  The quality of the PRA was
           done in a couple of different ways.  One is in July,
           at the end of July, we actually -- two members of the
           staff took a trip down to the Exelon facility to look
           at their maintenance procedures and processes, to see
           how Exelon actually ensures for themselves that their
           models are up to date to ensure that the models
           actually reflect significant changes to the facilities
           that go on throughout a period of time.
                       They did -- and I will return Dr.
           Burchill's compliment.  They did an excellent job of
           providing us information, and providing us a whole
           series of their PRA materials, their procedures.  We
           understand that it is an evolving process, and it is
           getting better all the time.
                       DR. KRESS:  Has their PRA undergone the
           industry peer review process?
                       MR. HARRISON:  Both PRAs have undergone
           that.  Dresden went through it twice, and if you talk
           to Dr. Burchill, he will say the first time was
           probably premature for them to go through.
                       And they learned a lot of lessons and
           reflected that in the Quad Cities and in the revision
           to the Dresden PRA.  So both events were both received
           by March, and with their evaluation criteria, all of
           them were -- all of the elements were at a high level
           that could be used in a risk informed submittal
           supporting deterministic information.
                       DR. SHACK:  Was that the owners' group one
           or the NEI?  I mean, could we assign a Level-3 to this
           thing?  I mean, was there a number?  I am not sure
           whether the owner's group gives you that.
                       MR. SIEBER:  The BWR owners group.
                       MR. HARRISON:  They assign a number for
           each of the 11 elements.  For 10 of the elements, they
           received a three; and for the 11th one they received
           a four.  So, higher is better than lower.  So it was
           a 3-4.
                       MR. BOEHNERT:  Out of what?
                       MR. HARRISON:  Out of four.  That is a
           good question.  So, yes, the staff actually spent some
           time, a few days, at the facility just to look at the
           process.  We looked at their -- they have a software
           program that is kind of like an XL spreadsheet that
           they track the modifications going on at the plant.
                       They evaluate those modifications to see
           if they need to do an update immediately of the PRA,
           or if it is something that they can wait until their
           next periodic update.
                       Today, they have never had anything rise
           to the level that requires that immediate update.  One
           of the things that the staff noted in its draft SE
           write-up was given all of the changes going on with
           the plant with this power uprate, and things in
           parallel with this power uprate, the staff would
           probably recommend doing an update on these
           PRAs just to make sure that everyone is reading from
           the same sheet of music.
                       But again that is more of a statement of
           what the staff would recommend, and it is not a
           required thing.
                       MR. SIEBER:  If I look at the Section 10
           of the safety evaluation, I see a lot of places -- and
           I guess I have both Dresden and Quad Cities here --
           where a statement was made that the delta-risk was
                       Does that mean that they actually modeled
           the changes in the PRA and then looked at the numbers,
           or does it mean that in the PRA the issue wasn't even
           modeled at all?
                       MR. HARRISON:  What I would say is that
           there is a couple of things that the licensee did. 
           There were places where they put something in the
           model and recalculated, and reran the model.
                       There is places where they used a
           simplified model, where they were making the design of
           the -- let's say the recirc run back circuit, and that
           was in design at the same time they were doing their
           PRA evaluation.
                       So they put in a simple model and ran that
           through and saw what the impact was.  Other cases --
           and typically in response to the staff's RAIs, they
           may provide us a calculation that says that the loss
           of off-site power fast transfer is a new event that we
           are going to evaluate.
                       And that we will just give you the
           calculation to show you that the number is 10 to the
           minus 10, or that the loss of off-site power
           initiating event frequency would have been increased
           by 2 times 10 to the minus 6, but it is a very simple
                       So there is a smattering of different
           approaches, depending on what the issue was, and how
           we are dealing with it.
                       MR. SIEBER:  Is it possible to pick that
           out of the safety evaluation report on which method
           they used when they were rerunning the model, or --
                       MR. HARRISON:  I think I pointed out in
           the write-up where they used simplified models or
           simplistic calculations.  I tried to make it clear
           -- and that is where after going into each of those
           sections the staff made a conclusion that it was using
           a simplistic model.
                       If it had been a risk-informed submittal,
           we might have sought for the licensee to confirm that
           the design and the simple model either match, or the
           simple model actually bounds it for sure.
                       So I think that would come out.  We don't
           necessarily go through and say here is all the
           modeling changes that they did.
                       MR. SIEBER:  Right.  Well, I think that
           would be too extensive, and would make this too long.
                       MR. HARRISON:  Right.  As it is, for a
           section that is supposed to be an insight section, it
           is still 20 pages long.
                       MR. SIEBER:  Right.
                       MR. HARRISON:  I hope that there is a lot
           of insights.
                       MR. SIEBER:  Okay.  Thank you.
                       MR. HARRISON:  We can move on, and the
           next few slides are just going to repeat really what
           Dr. Burchill mentioned yesterday, with maybe a
           different slant on it from the staff's perspective.
                       They evaluated the key areas, and in the
           initiating events area, component reliability, success
           criteria, and operator actions.  They addressed all
           those areas.
                       There were some impacts pretty much
           identified either by the staff or by the licensee in
           each area.  Again, as you mentioned, each area seemed
           to have -- we are talking a percent here or two
           percent there change in CDF.
                       We weren't seeing any major changes.  The
           next result is that there is -- and I think yesterday
           that you saw Exelon had a CDF delta increase of 9
           percent, and I listed 8 percent.
           Maybe we count different.  I have probably got more of
           an error in the way that I added them.
                       Quad Cities is looking at a five percent,
           and those are very small risk increases.  The LERF
           numbers again are 10 percent at Dresden, and 4 percent
           at Quad Cities.
                       The difference between Dresden and Quad
           Cities, I would probably argue, is mostly because the
           base CDF and base LERF numbers at Quad Cities are
           about twice as high as they are at Dresden, and
           therefore, the change in risk is half at Quad Cities.
                       DR. KRESS:  So the actual deltas were 
           about the same?
                       MR. HARRISON:  Yes, for the most part. 
           The numerical number would be about the same.  Again,
           we would just point out that there were simple models
           and simplistic calculations performed, as well as on
           the transformers, and there was some question on the
           switch gear and the breakers.
                       And there were some tests that the
           licensee stated that they were going to perform to
           show that they were acceptable, and they might have to
           make some field modifications to make that acceptable.
                       It wasn't clear to me that those tests had
           been completed and that the modifications had actually
           been implemented.  So that was to recognize that there
           was some uncertainty there.
                       And then on the thermal hydraulic area,
           the staff recognizes that they did an analysis of what
           their typical thermal level will be, and not what
           their licensed thermal level would be, which means
           that they did the thermal hydraulics runs using MAP
           about two percent below what the licensed level is.
                       And the staff recognizes that puts us into
           a little bit of an uncertainty area as far as success
           criteria and operator action time.  But again we are
           only talking about two percent in a 17 percent uprate,
           and we don't see that as being something that would
           trip us into a concern.
                       DR. SCHROCK:  Did they have some reason
           for doing that?
                       MR. HARRISON:  The rationale again is that
           the PRA is supposed to reflect more of your realistic
           operations, and the plant will typically be operating
           at a lower thermal limit to achieve the same
           electrical output, except for I think during the
           summer months.
                       And there might be periods during the
           summer where they actually have to increase that to
           get that output.  So, yes, it was mostly just to get
           a realistic perspective.
                       Again, the staff would have preferred that
           they do it at the license level to just take any doubt
           out.  So that was just to recognize that that was the
                       DR. KRESS:  Did they do any uncertainty
                       MR. HARRISON:  No.  They did do
           sensitivity analysis I think in the past, and I think
           you heard some of that yesterday.  But there were no,
           if you will, sensitivity calculations done at a higher
           thermal limit, or at least not provided to the staff
           to verify that they were acceptable in that area.
                       DR. FORD:  To somebody in the public, the
           use of your words, use of simplified models and
           simplistic calculations, is somewhat negative.  Could
           they have used a more professional approach?
                       MR. HARRISON:  This is not questioning
           their professionalism.  This is more of just
           recognizing -- and maybe I need to change my words,
           but recognize the fact that in some cases they were
           designing a circuit, or designing a feature at the
           same time that they were modeling that feature.
                       And Exelon took the approach of trying to
           bound that, and they bounded it by using simple
                       DR. FORD:  But that --
                       DR. SHACK:  Simplified bounding.
                       MR. HARRISON:  Simplified bounding, or
           simplified conservative models.  Again, there is not
           a confirmation at the end to ensure that the circuit
           that they actually did install is bound.  I mean,
           there is uncertainty there.
                       And again if this had been a risk informed
           scenario, we would probably be chasing down that
           confirmatory analysis to make sure that what was
           installed is truly bounded by what they actually
                       Typically, an example would be that on the
           reactor recirculation pump run back feature.  They
           increased their turbine trip initiating event
           frequency by a few percent, and ran it through their
           model, and did not take credit for at Dresden the fact
           that the recirc pump would keep you from tripping.
                       So in that sense the staff then has
           confidence that their analysis should have bound the
                       DR. FORD:  The only reason why I am
           bringing up this question is that this is open to the
           public, and someone in the public could construe that
           as being a simple, but inadequate, analysis, and that
           is not your meaning.
                       MR. HARRISON:  Right.  That is not my
           meaning.  I am meaning to say that it is a -- if you
           want to use a conservative -- well, I don't like using
           bounding in PRA language, but that seems like an
                       It is a conservative approach to trying to
           address the condition you are in, where you are
           designing a component while you are modeling it at the
           same time.  So it just recognizes that fact.  If we
           could move to the next slide.
                       We also looked at external events and
           shutdown operations and PRA quality, and we have
           already touched a little bit on the last one.  The
           staff spent quite a bit of time on the external events
           portion, primarily in the area of seismic outliers.
                       The IPEEE for both of these stations
           identified outliers in the seismic margins analysis,
           and we aggressive pursued those with the licensee. 
           And especially for the seismic dam failure, which I
           think you have heard about now at least partially
                       We saw after addressing those scenarios
           specifically from a risk specific to see where we
           were.  At Dresden, the rest of the plant meets its
           seismic margins analysis criteria for a .3G focus
           scope plant.
                       We didn't pursue those things that were
           already at that level.  We wanted to see where the
           outliers were.  The results of that were that we had
           some -- I think if you add it all up on the seismic
           side, it comes out just a little below 10 to the minus
           5 as the risk.
                       And that includes not just the outliers,
           but also taking into account the fact that you could
           lose the isolation condenser seismically as well.  And
           if you add that on, you get it right around 10 to the
           minus 5 as a CDF value.
                       And the isolation condenser does meet the
           .3G margins analysis, but I put that in just as a
           perspective.  On the fire analysis, they indicated
           that there was a small risk increase that is mostly
           due to operator actions.
                       However, again, using Dresden as an
           example, their methodology is what I would call a
           progressive screening criteria type methodology, where
           if you get an acceptable answer, you stop analyzing.
                       MR. SIEBER:  That was strictly a control
           room fire.
                       MR. HARRISON:  That was a control room
           fire, and they took a 50 percent chance of going to
           core damage if I lose the control room.  So any kind
           of operator actions that changed by 5, 10, 15 percent,
           are never going to raise to the level that would
           offset that high of a conditional core damage
           probability, unless you find out that you just can't
           do it.  That would be about the only way to get there.
                       I think we have talked in the past about
           shutdown operations for BWRs.  Typically, you have
           long times to boil, and it is not a concern as much as
           it would be for, say, a PWR.
                       MR. SIEBER:  They did not have a shutdown
                       MR. HARRISON:  They do not have a shutdown
           PRA.  They do have a risk management program called
                       MR. SIEBER:  Yes, and I am not sure that
           you get a quantitative number out of that.  You get a
           color, and it really just looks at multiple paths.
                       MR. HARRISON:  Right, success paths.
                       MR. SIEBER:  So I am not exactly sure how
           you can draw a conclusion that says negatively small
           increase in risk from using an ORAM as a tool.
                       MR. HARRISON:  Right.  We are not basing
           our conclusion there on a model.  It is more of a
           qualitative conclusion saying operator actions will be
           reduced by some amount because of the higher decay
                       However, they do have a risk management
           process in place, and I think there was a discussion
           yesterday about their backup cooling systems, and that
           whole topic becomes moot because of their short
           refueling cycles, and refueling outages.
                       If you are only out for 20 days and it
           takes you 26 days of cool down to get to a point where
           you could use a pump, it becomes a non-issue.  That
           pump is not available.
                       So given that, we are just acknowledging
           the fact that there would be some impact, but we don't
           believe that it would be significant.
                       MR. SIEBER:  Okay.  Now, I do not recall
           anyplace in the safety evaluation where the idea that
           the refuelings are probably going to be a day or so
           longer because of the higher decay heat level.  Was
           that evaluated at all, and will that have an impact on
           shutdown risk?
                       MR. HARRISON:  I would answer that in two
           ways.  No, I did not evaluate that, but off the top of
           my head, if you are -- and again if I am not going to
           get -- well, yes, there would be some increased risk,
           because you are operating another day out there.
                       MR. SIEBER:  Right.
                       MR. HARRISON:  Again, the backup systems
           that would be available are marginal at that point
           anyway.  So you would be just progressing your risk
           management just a little further.
                       You could also argue that backwards and
           say then if I can shorten my outage by a day or two I
           save risk.  Given the drive of the industry, the
           shorter they go -- it is an economics question.
                       The licensee is going to drive for a short
           outage, and if he can shorten that outage, he will. 
           So there is no way to quantify that type of an answer.
                       On PRA quality, like I said before, they
           did go through the owners group peer certification
           process.  The last two bullets just point out the fact
           that with simple models and simplistic calculations,
           you don't necessarily have a hundred percent
           confidence that everything is precise.
                       When you are in PRA, nothing is precise. 
           So there is a little bit of -- I would like to make me
           feel a little if they did a few extra things, but they
           don't think -- I don't think that would be -- it
           wouldn't change the answers and that is the bottom
                       The last bullet really just recognizes
           that in the IPEEE the plant too credit for conditions
           that do not exist, and they are in the process of
           making modifications to make that fit.
                       And as part of our review, I believe they
           conducted their -- they had a seismic condition with
           the dam failure, and they had assumed that the LOCA
           conditions were fine.
                       And as part of our questioning, I think
           they went back and did the study that they had
           committed to in the IPEEE a few years ago, and the
           results of that were that they do need to add a means
           of -- an alternate means of -- or a seismically
           qualified means of getting a containment cooling
           service water path in.
                       MR. SIEBER:  But those modifications were
           just hangers in supports, right?
                       MR. HARRISON:  Those modifications for
           Quad Cities were mostly anchorage.  For Dresden, it is
           not.  For Dresden, the modifications that we are
           talking about are the portable pumps, the hoses, the
           connections, being able to route the lines through,
           and drop the pumps in, and get the water where you
           need it.
                       MR. SIEBER:  Right.
                       MR. HARRISON:  That is how they are going
           to address the seismic issues at Dresden.  It is not
           going to be a hard-wired implant system.  The next
           slide just goes over what we concluded through our
                       Again, this recognizes that we identified
           a number of issues, and the licensee -- the
           methodology that they used, and the simple
           calculations, this just kind of goes over that again.
                       With the last couple of bullets just
           recognizing that they had been risk informed, we would
           probably require some type of confirmation that the
           simple models and the simple calculations truly are
           bounding the conditions.
                       And to actually analyze the procedures
           that they are creating for like load shedding in a
           transformer, to verify that their screening human
           error probability really is screening, and there is
           not something out there that might be higher.
                       The last bullet there just says, however,
           the submittal is not risk informed.  They are meeting
           their deterministic requirements, and the information
           that we have does not make us question the adequate
           protection of the plant.
                       So with that conclusion, we pass it back
           to the deterministic folks to address the issues in
           their areas, and that's all that I had on the risk
           assessment piece of it.  Are there any questions?
                       MR. SIEBER:  Does anyone have any
           questions?  If not, thank you very much.
                       DR. FORD:  Again -- well, I'm sorry, but
           just about the last thing, when you say that submittal
           is not risk-informed.  It doesn't have to be risk-
           informed does it by the regulations?
                       MR. HARRISON:  No.
                       DR. FORD:  The deterministic requirements,
           are they adequate?
                       MR. HARRISON:  That is not a judgment for
           me to make.  That is a judgment for each of the
           deterministic branches that do their reviews
           collectively and come together as a basis for the
           final solution.
                       MR. SIEBER:  Actually, the submittal is
           risk-informed, and the decision making was not.
                       MR. HARRISON:  Was not, yes.  And we may
           be talking about technical questions, but risk
           information is provided, but in the terminology of
           risk informed, it is not risk informed.
                       MR. SIEBER:  Right.
                       MR. HARRISON:  And again we kind of talked
           past ourselves.
                       MR. RUBIN:  This is Mark Rubin from the
           staff.  It was not submitted as a risk informed
           licensing action.
                       DR. FORD:  Well, the reason that I am
           bringing it up is that it might sound nitpicking, but
           again I come to this public perception being that it
           is out there, and that bold statement of not risk
                       On the face of it, it would sound
           negative.  It is not negative.  It just is not
           required.  It is a factual statement.
                       MR. HARRISON:  And it is a factual
           statement in that it just recognizes that the LTAR
           requires them to provide risk information.  We review
           that information, and it is not conveying that there
           is something wrong with the submittal the way it is. 
           I don't want to convey that.  Thank you.
                       MR. BOEHNERT:  Again, I would like to get
           copies of your slides.
                       MR. HARRISON:  I will make them now and
           give them to you.
                       MR. BOEHNERT:  Thank you very much.
                       MR. ROSSBACH:  Okay.  Next in our
           presentation -- well, actually, we didn't have further
           presentations prepared, but we do have reviewers
           available to answer questions in these other areas.
                       The first one we have listed is material
           degradation issues, and it is because in your letter
           responding to Duane Arnold, you pointed out the
           significance of flow assisted corrosion and irradiated
           stress corrosion cracking to the evaluations.
                       Although in yesterday's licensee's
           presentation, you seemed to be satisfied with that,
           but we do have reviewers here if there are questions
           in these areas.
                       MR. SIEBER:  Do we have any questions?  I
           recall someone suggesting that they would like further
           information on seismic.
                       DR. FORD:  As an independent person with
           a conflict of interest, I have no problems at all with
           the materials degradation.  I was more interested in
           just the process by which you evaluated those
           potential degradation modes.  And I don't know if this
           is the forum to ask those questions.  For instance --
                       MR. ROSSBACH:  Would you like us to
           address the process?
                       DR. FORD:  -- in the flow area, a lot
           depends on the CHECWORKs and its qualification, et
           cetera.  Did you perform or did you oversee that
           qualification of the use of CHECWORKs?
                       MR. PARCZEWSKI:  Yes, we did look at it,
           you know, because this is the only way --
                       MR. BOEHNERT:  Could you identify yourself
           for the record, Kris?
                       DR. FORD:  Kris Parczewski, from Material
           Chemical Engineering Branch, NRR.  You need to look at
           the other CHECWORKs prediction, and we were satisfied
           that there were relatively low, and what is most
           important is that the licensee has the program,
           ongoing program.
                       And you can always verify, and if you are
           going to verify the prediction, then he will be able
           to project it in the future.  So this will be a well
           controlled process for the licensee.
                       And I find that it is not really a very
           significant change due to a power uprate.  The highest
           one is obviously in the feed water because of the high
           velocity change.
                       The other components are considerably
           smaller changes, and so it is not very significant
                       DR. FORD:  There are a few other minor
           questions in the area of flow induced vibrations, for
           instance, and in the new design of putting in a steam
           dryer.  Were those reviewed?
                       MR. ROSSBACH:  That would be the
           mechanical engineering branch.
                       DR. FORD:  And the transfer of those loads
           to the support brackets, and the effect they may have
           on stress corrosion cracking in that area which is not
           protected by Noble Chem.
                       MR. MANOLY:  My name is Ken Manoly, and I
           am a section chief in the Mechanic Branch, and I would
           like to address your questions on the steam dryers. 
           I have one slide to maybe give you a summary of what
           are the conclusions in that area.
                       We noticed that you were interested in the
           topic last time and that's why we gave it more of a
           focused attention this time, and pretty much the
           conclusions from both plant reviews, both from Dresden
           and Quad, were pretty much the same.
                       That there is no increase in the actual
           pressure of the temperature, and the core flow is not
           much increased.  The only increase is in the steam
           flow, and to get into flow induced vibration, maybe I
           can get into detail if you want to get into that.
                       The key thing to emphasize in the
           submittal is that the component is not faulty, but
           they still want to ensure its integrity for the fault
           condition, which is a main steam line break.
                       And for that they evaluate the stresses to
           the ASME NG Section 3, which is fairly new.  It came
           way after the plant was built.  The stresses all meet
           the code limits.
                       DR. FORD:  Just to interrupt you and to
           save time, I can see all those factual things there. 
           What is not covered is when we had the Duane Arnold
           review, they stated that there would be a transference
           of those stresses to the dryer support brackets welded
           to the RPV.
                       MR. MANOLY:  Right.
                       DR. FORD:  I assume the same would apply
           in this situation, too.
                       MR. MANOLY:  That's true.
                       DR. FORD:  Was there an analysis done on
           your behalf of the impact that it might have on
           environmentally specific cracking on that welded
                       MR. MANOLY:  Well, we didn't do that
           analysis.  We responded to questions in REIs about the
           adequacy of the anchorages.
                       DR. FORD:  Good.
                       MR. MANOLY:  And they said to evaluate the
           anchorages, and they were fine.
                       DR. FORD:  And how would that be managed,
           by the inspection process?  Would the dryer brackets
           also be inspected by BWRVIP-06?
                       MR. MANOLY:  Yes.  I think with every
           refueling that the dryers are inspected and removed.
                       DR. FORD:  And the brackets, the brackets
           are also inspected?
                       MR. MANOLY:  I am not certain, but I can
           get back to you on that.  I am not quite so certain
           about the brackets.
                       DR. FORD:  The reason that I keep pushing
           this is because if they fail, then the whole thing
           falls, or potentially falls.
                       MR. MANOLY:  Right.  That would be a very
           easy thing to verify, the statement in the VIP,
           because we have the VIP SERs already written up.
                       DR. FORD:  I am moving along here, Jack,
           and I am just trying to get a feeling of the
           assessment that went through.  On the cracking issues,
           the cracking of the main structural welds in the
           reactor, in the core shroud, for instance, H-4 and H-
           3, H-6 welds, was there any analysis done on how the
           increase in flux of 17 percent, how that is going to
           affect the cracking of those components?
                       MR. MANOLY:  I will have to defer that to
           the materials branch.
                       MR. CARPENTER:  This is Gene Carpenter
           with the materials and chemical engineering branch. 
           Basically, what we have done with the core shroud or
           other internals is that we have asked licensees to
           take a look at just what their fluence levels are.
                       And when they get to a certain threshold
           limit, that drops them into a higher crack growth rate
           regime, and at that time they have an increased amount
           of inspection that is required.
                       DR. FORD:  Okay.  Is the current -- I have
           forgotten the VIP numbers.  There are so many of them. 
           But are those fluence values that might be accrued in
           the next -- since they are going for license renewal
           in the next 10 years, are they likely to get into
           fluence regions where they might be a marked increment
           in cracking susceptibility?
                       MR. CARPENTER:  Some licensees have
           already reached the 5E to the 20th neutrons per square
           centimeter fluence value, which is what we consider
           the threshold value.
                       And as these reactors age, they obviously
           have more internals coming to that point.  Now, when
           I say some licensees, what I am saying is that is at
           the core shroud.  We are not talking about the vessel.
                       DR. FORD:  I asked a question the other
           day about the delta-P across the access hole covers,
           and I presume there will be an increased delta-P, and
           they mentioned that they had a redesign of the access
           hole covers.  Was that analyzed or examined by the
           staff?  Is there any increase in the cracking of --
           and I am not too sure what the redesign is.  Are they
           still welded designs or bolted designs for the access
           hole covers?
                       MR. MANOLY:  I cannot respond to the
           question right now.  I need to get back to you to see
           what information we have on it.
                       DR. FORD:  It is not a major safety issue
           I don't believe.  Thank you.  Those are the only major
           questions that I had.  I just wanted to understand
           what the process was.
                       MR. SIEBER:  Do we have anything else that
           the staff would like to present?
                       MR. ROSSBACH:  Earlier, we did have one
           question from the ACRS dealing with the pipe supports
           modifications, and if you want any information on
           that, I can tell you that some main steam and TORUS
           attached piping systems were determined to require
           support modifications to bring the piping within code
           level stress limits.
                       Now, some TORUS attached piping support
           MODS are required due to higher power uprate thermal
           loads, and some main steam support modifications are
           required as a result of applying the turbine stop
           valve closure loads.  If you want any elaboration on
           that the staff is here.
                       MR. SIEBER:  Well, that is basically in
           the SER, almost verbatim.  So does anyone have any
           questions?  Okay.  I would like to -- I think we are
           done now, and so I would like to thank the staff for
           their presentation, and also Exelon and G.E.
                       I think it was very informative, and very
           knowledgeable, and you certainly brought enough people
           with you to cover anything and everything that we
           could have asked.
                       What I would like to do now though is
           spend some time with the members so that we can get an
           idea of what members comments are at this point so
           that we can provide those comments to Dr. Wallis while
           he begins drafting a letter.
                       I presume that the staff wants a letter
           from us at their next full meeting, and so with that,
           Dr. Shack, do you have any comments that you would
           like to make?
                       DR. SHACK:  No.  I missed much of
           yesterday's presentation and so I feel a little
           restricted about making comments and so I will just
           defer to the members who attended the full session.
                       MR. SIEBER:  Okay.  Dr. Ford.
                       DR. FORD:  There seems to me to be five
           kind of areas in the materials degradation area that
           needed or should have been addressed, and in large
           part were.
                       And those include the flow induced
           vibration, and the flow assisted corrosion, the
           embrittlement of the pressure vessel, and the whole
           question of cracking of the main structural welds in
           the reactor, all of which could conceivably be
           affected one way or the other.
                       I think they all have been addressed both
           by the licensee and analysis done by the staff of all
           of those.  And I don't think that with the ACRS that
           they should be discussed in any detail.  I don't think
           there is a major problem that cannot be managed with
           the management programs that exist.
                       It would be an idea just to put those up
           as I mentioned yesterday in just one page just to
           record that they have been analyzed.  And one area
           that wasn't discussed yesterday was a question of
           Nitrogen-16, which would depend very much on the
           adherence of Noble Chem with the higher flow rates.
                       I personally don't think it is a problem,
           but it is something that should be addressed
                       MR. BAILEY:  Would you like to discuss
           that now?
                       DR. FORD:  Well, I am just asking has it
           really been looked at and are people satisfied.  Can
           it be managed.
                       MR. CARPENTER:  This is Gene Carpenter
           again with materials and chemical engineering branch. 
           We have been looking quite closely at the chemistry
           that is involved with the BWR internals, and
           specifically hydrogen water chemistry and the Noble
           Chem issues.
                       Obviously if you have an increase in N-16,
           you are going to have an increase in shine, and so it
           is a very easy problem to ascertain that you have.
                       We have also asked the industry to go back
           and have a monitoring program to ensure that the NMCA
           is appropriately applied, and that it is maintained
           throughout the operating cycles so that they do need
           to know when they are going to reapply it to maintain
                       We have also asked them to have an
           effective hydrogen water chemistry program in place,
           and we have been making some great strides towards
           that.  So the N-16 problem, I think, is under control.
                       MR. SIEBER:  Well, that was actually
           discussed in the safety evaluation report and the
           issues were does this provide additional safety to
           workers, and does it affect equipment qualification,
           and things of this nature.
                       And obviously N-16 without some additional
           offsetting treatment is proportional to the change in
           power, and that the safety evaluation radiological
           evaluation indicated that the increase was negligible
           as far as to workers and potential dose off-site.
                       And in equipment qualifications space, I
           think they had to run or get additional data on
           Rosemont transmitters.  And there were some
           transmitters that were installed that weren't EQ, and
           that had to be changed out to make them EQ.
           And so I think the N-16 issue was pretty well covered.
                       MR. CARPENTER:  Yes.
                       MR. SIEBER:  And as far as fluence is
           concerned, it seems to me that the Dresden and Quad
           Cities reactor vessels are fairly large compared to
           the core that is inside them.  So there is some
           absorption that takes place, which means that the
           fluence does go up by 17 percent at the vessel wall or
           the shroud.
                       And so the impact isn't as great as one
           might presume, and also in that type of vessel there
           are other plants that operate with higher power
           levels, and so that doesn't make Dresden or Quad
           Cities any different than those plants, at least in my
           way of reasoning.
                       DR. FORD:  That is my point.
                       DR. SHACK:  Just to come back to Peter's
           question, and again it is a question for Gene.  The
           way the hydrogen water chemistry will run under the
           Noble Chem is that they may not be continuously
           modeling potential.
                       And so they will probably be putting in a
           fixed amount of hydrogen, which means that if they
           lost their Noble metal coating, what would really
           happen would be their susceptibility to cracking would
           go up for a portion of the cycle.
                       MR. CARPENTER:  That is correct.
                       DR. SHACK:  And then with an N-16 concern,
           their susceptibility would increase presumably until
           the end of the cycle and they found out that they had
           somehow mis-estimated the potential wear rate for the
           Noble Chem.  Isn't that the way it would work
                       MR. CARPENTER:  That is the way that it
           would work, and we have also asked the industry to go
           back and have a way to monitor during the operation
           that they do have an effective hydrogen water
           chemistry in place at least 80 percent of the time,
           which we believe is sufficient to ensure the crack
           growth rate will maintain itself at a sufficiently low
                       MR. SIEBER:  Okay.  I guess from my
           standpoint, I am not -- I need to study some more
           about the unit auxiliary transformer and the RAT to
           assure myself in my mind that what has been done is
           okay from an electrical standpoint and I will do that
           on my own.
                       I did have another question where I would
           note that a number of set points have been changed,
           and the safety evaluation, the draft safety evaluation
           discusses the set point change methodology, which I
           presume originally came from Commonwealth Edison?
                       MR. BAILEY:  Actually, it was done more
           recently.  We just approved a new revision or a new
           version of their set point methodology with the ITS or
           improved tech specs, which was granted to these two
           plants this March.
                       MR. SIEBER:  Since March?
                       MR. BAILEY:  Yes, since March.
                       MR. SIEBER:  And do you have a safety
           evaluation specifically for subpoint methodology?
                       MR. BAILEY:  It is part of the approved
           tech spec safety evaluation.
                       MR. SIEBER:  Which is probably huge,
                       MR. BAILEY:  It is big.
                       MR. SIEBER:  Is there a chance that
           somebody could send me the pages that relate to the
           set point methodology?
                       MR. BAILEY:  You would like the pages
           related to the set point methodology?
                       MR. SIEBER:  Right, because you referenced
           them, and I remember Commonwealth Edison set point
           methodology from a few years back, and so I would like
           to assure myself that what they are doing now is in
           conformance with the way that the industry is doing
                       MR. BAILEY:  Okay.  It was done as part of
           their transition to a 24-month fuel cycle.
                       MR. SIEBER:  Okay.  But just send me the
           pages, as opposed to sending me the whole thing,
           because my office is now full of papers.  Dr. Kress.
                       DR. KRESS:  One of my points that I would
           like to have a little more help from the staff was how
           they were able to assure themselves that the LOCA
           codes to meet the figures of merit, and Appendix K
           requirements were still valid for flat flux, knowing
           that the validation was based on 2D and 3D type tasks,
           which did not have a flat flux.
                 I would like to know how they assured themselves
           that the codes were still valid.  The other thing that
           I would be interested in is maybe a little more on
           Virgil's point about the Origin code, and how they
           assured themselves that it was used properly to get
           the right inventory.
                       MR. SIEBER:  Okay.
                       DR. KRESS:  And I guess I would like to
           see a little better explanation of why the MELLLA
           curves were different, even though I understand that
           there is good reason for them to be different.  But
           maybe a little explanation of why precisely they were
                       MR. SIEBER:  Okay.
                       MR. BAILEY:  I understand at the break
           that the licensee has looked at them again, and sees
           only differences in the low flow region.  Did you want
           to --
                       MR. PAPPONE:  I don't know where the
           proper forum is to address that is, but we can address
           that with the staff or with the ACRS afterwards, or at
           any time.
                       MR. BAILEY:  Okay.
                       MR. SIEBER:  Well, I think if we are going
           to discuss it, we ought to discuss it while we are in
           formal session, as opposed to having a sidebar that is
           not on the record.
                       MR. BAILEY:  Dan, can you give a
           description of what we learned about those curves.
                       MR. PAPPONE:  This is Dan Pappone from
           G.E.  As I said yesterday, when we draw that MELLLA
           line on the power flow map, we are using a generic
           line for all the plants and all the product, and so
           that licensing line does not change.  The line on that
           map for Dresden and Quad Cities, that line is the same
           for that.
                       DR. SCHROCK:  Say that one time again?
                       MR. PAPPONE:  The line itself is the same. 
           It is following the same equation as was proposed for
           the license.
                       MR. BAILEY:  Are there scaling factors
           that make the figures look different?
                       MR. PAPPONE:  Where the point of confusion
           is coming in --
                       DR. SCHROCK:  Let me say that Point A has
           numerical values in the little table in the set of 43
           pressure, and 23 full.
                       MR. PAPPONE:  Right.
                       DR. SCHROCK:  And I don't have the other
           one in front of me, but the numbers were more like 58
           and something else.
                       MR. PAPPONE:  Right.  The difference
           between the two flow maps is in the natural
           circulation line, and we do have to investigate why we
           have a difference in the two lines, and what the basis
           for that is.
                       But that corner point, I can take the
           equation for the rod line, which is a function of core
           flow, and put in that core flow value, and calculate
           the corresponding power value.
                       MR. BAILEY:  And the points going down to,
           but not including, this natural cert point, would also
           be calculated from the same equation for both plants?
                       MR. PAPPONE:  That's right.  If you laid
           a ruler on that line, you would see a slight curve. 
           If you would also take a look at each corresponding
           core flow, that power value would be the same.  It is
           a piece that we need to go back and investigate for
           the basis for the natural circulation line, and the
           difference between the plants.
                       DR. SCHROCK:  And so that is an item to be
           followed up on prior ot the full committee meeting?
                       MR. PAPPONE:  That's right.  We don't have
           that information.
                       DR. SCHROCK:  But let me ask it another
           way.  I think the question that Graham followed up
           with was that this line is in operation limits, and so
           if during your maneuvers you approach that line, you
           have to back off?
                       MR. PAPPONE:  That's right.
                       DR. SCHROCK:  The position of the line in
           the vicinities, say, of core flow of 50 and minimal
           power on the order of 60, is different on the two
           presentations in the two SERs.  So which of those is
           it that --
                       MR. PAPPONE:  Well, you may be seeing
           different sizes of the plots if you put the two
           together, and you may be looking at physical plot
           scales, but the equation for that line is the same for
                       DR. SCHROCK:  I don't understand how the
           equation can be the same and then when you use the
           equation to plot a line, you get a different line.
                       MR. PAPPONE:  That's what I am saying.  If
           I go to each one of those points along the line for a
           given core flow for either unit, I get the same power.
                       It is just that the difference in those
           two plotted lines, the natural circulation line, and
           in one case it is minimum and in the other it is 32
           percent, it is not quite the same.
                       So where those points that are identified
           in the table, we are looking at different core flow
           going into the calculation, and so we have a
           corresponding different power.  Does that make sense?
                       DR. SCHROCK:  Not yet.
                       MR. PAPPONE:  So the difference in failing
           is the core flow.
                       MR. BAILEY:  And what you are measuring is
           in percent?
                       MR. PAPPONE:  Absolutely.
                       MR. NIR:  This is Israel Nir from G.E. 
           Let me help you.  This is a quick mathematical
           exercise.  Look at the two maps and establish what is
           the power level associated with 40 percent core flow,
           and you will find that in both maps it is 58 or
           approximately 58.
                       And I am just selecting one point, and
           that should convince you that these two lines are
           identical, except that one of them is extended further
           relative to the other all the way to natural
           circulation.  But the same equation is used in the
           definition of the two lines.
                       MR. PAPPONE:  Right.
                       DR. SCHROCK:  Does that explain the
           differences in the position of Point A?
                       MR. PAPPONE:  No, Point A is --
                       DR. SCHROCK:  Point A is a different thing
           in each case?
                       MR. PAPPONE:  That's right.  And that is
           the piece where we have to go back and get the
           explanation for why that natural circ curve is showing
           differently.  We have a similar situation where one
           unit plotted that minimum speed line --
                       MR. NIR:  Let me make another
           clarification.  As part of this effort, we redefined
           the power level and the MELLLA boundary.  Those are
           indicated on the flow map.  There are certain portions
           of the power flow map that are not affected by power
           uprates, and the introduction of MELLLA.
                       And those lines are the natural
           circulation, the cavitation lines, and these are the
           same or maintained the same as a power uprate.  And
           the differences that you observe are differences that
           exist now.  Those features that are new are identical.
                       DR. SCHROCK:  So you believe there is a
           difference in the natural circulation characteristics
           of Quad Cities versus the Dresden plants?
                       MR. NIR:  There is a difference in the
           presentation and we need to get back with you as to
           the reason.
                       MR. PAPPONE:  That piece may tie back to
           the historical source that was provided and that Jason
           talked about earlier.
                       DR. SIEBER:  Dr. Schrock, do you have any
           additional comments that you would like to give us?
                       DR. SCHROCK:  Well, first of all, the open
           issues, and the testing question I find a little
           puzzling.  I thought that the authorities case was
           that testing would be unnecessary sounded pretty
                       It is still unclear to me what the G.E.
           position was.  I heard that G.E. a new submittal
           related to this, and I guess we didn't hear very
           clearly a position put forth from G.E. representatives
           about that, and if they could comment further on that.
                       It is a little unclear to me on why the
           staff is unable to address that position of G.E. and
           the utility with regard to this issue.  I don't know
           what evidence is missing that is going to be
           forthcoming in the making of that decision.  So I just
           find that whole thing a bit puzzling.
                       And I understand the revision done on
           Duane Arnold, and that we are not to take these graphs
           for Dresden and Quad Cities is being final either, but
           it is not clear to me where that stands with regard to
           the nature of the modifications that are going to be
           made, and that there are very many weaknesses in these
                       And over-reliance on such statements as
           that the submittal is done in accordance with existing
           approved codes and using existing codes, and therefore
           the results must be accepted, and that seems to me to
           be overly simplistic.
                       And I don't think you need a one inch
           thick SER to relay that message if that is really what
           the SER has to say.  I found the SER in both of these
           cases to be rather weak statements of how the staff
           has come to the conclusion that the SERs should be
                       That is not to say that I don't think that
           they are acceptable.  It looks to me like they are,
           but I do think that there are many ways in which
           things can be done with this sweep of codes that will
           produce different results.
                       And put them in the hands of different
           users, and they will come up with different results,
           and guaranteed almost every time.  So, again I have
           not heard enough to convince me that the staff knows
           that the codes are applied in the right way to get the
           answers that justify saying that the thing is an
           acceptable uprate.  That's really all I have.
                       MR. SIEBER:  Well, I think that will give
           us some meat that we can work on over the next 10 days
           or so.
                       MR. BOEHNERT:  Yes.  I think I will get
           with Graham and we will come up with some agenda items
           for the licensing.
                       MR. SIEBER:  That will be very good. 
           Well, again, I would like to thank the staff, the
           Exelon, and General Electric, for their presentations.
                       MR. ROSSBACH:  Mr. Sieber, I would want to
           address a little bit of information on the question on
           the access hole cover that was raised.
                       MR. PARCZEWSKI:  Dr. Ford, you asked a
           question about the access hole cover, and we asked the
           question in the RAI and we evaluated the new
           replacements and the loads increased from 70 ksi to 80
           ksi, but that is still way below their limit of
                       DR. FORD:  This is a bolted design?
                       MR. PARCZEWSKI:  Yes.
                       MR. NIR:  This is Israel Nir of G.E.
           again.  Just for the record, there was a couple of
           times that you mentioned the G.E. position on the
           large transient.  Let me just remind the subcommittee
           that we were here back in June of this year, and
           provided you some background on the constant pressure
           power uprate.
                       If you go back to the minutes you will
           find that we provided you some information related to
           Hatch on start up tests, and elevated power up to
           roughly 114 percent.  We also provided you some
           background on large transient events related to
           constant pressure.
                       And we will be happy to discuss it
           further, and I think it will be needed to be in a
           closed session and clarify our position.
                       DR. SCHROCK:  So the reason that we didn't
           hear any G.E. position in this meeting is that it was
           an open meeting?
                       MR. NIR:  That is the reason, yes, and I
           cannot get into any details, but we fully support
           Exelon's position.
                       DR. SCHROCK:  All right.
                       MR. SIEBER:  Are there any additional
           comments or statements?  Yes, sir?
                       MR. BAJWA:  Just a closing comment on the
           staff's presentation.  I would like to thank you for
           the opportunity to present our review of the Dresden
           and Quad Cities extended power uprate.
                       The Commission has given a high priority
           to these amendments.  These are the first applications
           of many that I am sure that we will see for power
           uprates of this magnitude.  I would like to emphasize
           that the NRR staff has undertaken an extensive review
           of these applications and for all areas affected by
           the uprate have been reviewed and evaluated.
                       The staff has critically examined the
           methodologies and their application of this power
           uprate request, and the exception of the open item as
           we have mentioned, and that were discussed today on
           the testing issue.
                       And I would like to emphasize that these
           applications are not risk-based applications, and the
           evaluations which were conducted on the deterministic
           evaluation analysis have demonstrated that the
           proposed increased power level for Dresden and Quad
           Cities units are acceptable and meets the regulatory
                       This concludes the staff's presentation,
           and if you have any questions, we would be glad to
           answer them.
                       MR. SIEBER:  Thank you very much, and I
           think with that, it is a quarter-to-12, and so we have
           met all of our goals, and so I will adjourn the
                       (Whereupon, the meeting was concluded at
           11:45 a.m.)


Page Last Reviewed/Updated Tuesday, August 16, 2016