ML061580242
| ML061580242 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/01/2006 |
| From: | Ashley D NRC/NRR/ADRO/DLR/RLRA |
| To: | |
| Ashley D | |
| Shared Package | |
| ML061580399 | List: |
| References | |
| %dam200612, NRC-1087, TAC MC7624 | |
| Download: ML061580242 (99) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Oyster Creek Generating Station License Renewal Title: Docket Number: Location: Date: (05000219)
Rockville, Maryland Thursday, June 1, 2006 Work Order No.: NRC-1 087 Pages 1-129 NEAL R. GROSS AND CO., INC.Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.Washington, D.C. 20005 (202) 234-4433 1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 +++++4 CATEGORY 1 PUBLIC MEETING 5 BETWEEN 6 U.S. Nuclear Regulatory Commission 7 AND 8 AmerGen Energy, LLC, 9 Applicant for Oyster Creek Generating Station 10 License Renewal 11 12 THURSDAY, 13 JUNE 1, 2006 14 +++++15 The meeting was convened in the 16 Commissioners' Conference Room in One White Flint 17 North, 11555 Rockville Pike, Rockville, Maryland, at 18 9:20 a.m., Donnie Ashley, Presiding Official.19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 2 1 NRC PERSONNEL PRESENT: 2 DONNIE ASHLEY 3 HANS ASHAR 4 FRANK GILLESPIE 5 REBECCA KARAS 6 P. T. KUO 7 LOUISE LUND 8 AMERGEN AND EXELON PERSONNEL PRESENT: 9 MICHAEL GALLAGHER 10 JOHN HUFNAGEL 11 AHMED OUAOU 12 FRED POLASKI 13 HOWIE RAY 14 PETER TAMBURRO 15 DONALD WARFEL 16 ALSO PRESENT: 17 KYOTO TANABE, Japan NRC 18 19 20 21 C-O-N-T-E-N-T-S 22 AGENDA ITEM PAGE 23 INTRODUCTIONS 3 24 USE OF ASME CODE SECTION 3 SECTION NE-3213.10 25 FOR LOCALIZED CORROSION AREAS 24 26 VALIDATION OF UT MEASUREMENTS AND 27 BUCKLING ANALYSIS 34 28 USE OF ASME CODE CASE 284-1 45 29 ULTRASONIC TESTING ISSUES 52 30 INSPECTION INCREMENTS WITH UT COMMITMENT 69 31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 3 1 P-R-O-C-E-E-D-I-N-G-S 2 (9:23 a.m.)3 MR. ASHLEY: Okay, I'm going to go ahead 4 and get started now. The other two participants can 5 just call in when they can.6 This is a public meeting between the NRC 7 and AmerGen who is the applicant for Oyster Creek 8 license renewal.9 It's a category one meeting. We will 10 conduct the meeting according to the agenda. At the 11 end of the meeting we will give those people on the 12 phone line and also the folks that are here at 13 headquarters and opportunity to make comments or ask 14 questions of the staff.15 This meeting is being transcribed, and as 16 a result, if when you make your statements or you make 17 your presentations, please state your name and who you 18 represent so that the recorder can pick that up for 19 you.20 Rather than introducing everybody in the 21 room, probably have maybe 25 or 30 people here, I just 22 want to introduce the participants here today.23 And we'll start with our folks, and then 24 we'll give it to you, Mr. Gallagher.
25 Dr. Kuo.26 MR. KUO: P.T. Kuo, division of license 27 renewal.28 MS. LUND: I'm Louise Lund, a branch chief 29 in the division of license renewal.30 MR. ASHLEY: My name is Donnie Ashley. I'm 31 the project manager for Oyster Creek license renewal 32 project.33 MR. GILLESPIE:
Frank Gillespie, director, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 4 1 division license renewal.2 MR. ASHAR: Hans Ashar, NRC.3 MS. KARAS: Becky Karas. I'm the chief of 4 the GSI and civil engineering branch in the division 5 of engineering.
6 MR. GALLAGHER:
Okay, Frank. Can you hear 7 me?8 I'm Mike Gallagher.
I'm the vice 9 president of license renewal for AmerGen and Exelon.10 And I'll turn it over to our team to introduce 11 themselves.
12 MR. TAMBURRO:
I'm Peter Tamburro.
I'm 13 senior mechanical engineer at Oyster Creek.14 MR. OUAOU: My name is Ahmed Ouaou. I'm a 15 civil structural engineer at Oyster Creek.16 MR. RAY: My name is Howie Ray, and I'm at 17 Oyster Creek, the new manager.18 MR. POLASKI: For Polaski, Exelon's license 19 renewal manager.20 MR. WARFEL: Don Warfel, the technical lead 21 for the Oyster Creek project.22 MR. HUFNAGEL:
John Hufnager, the licensing 23 lead for the Oyster Creek project.24 MR. ASHLEY: Thank you very much. We'll go 25 ahead and get started with the agenda.26 We have a very focused agenda today. But 27 first of all, before I get started into the agenda, we 28 really appreciate having the opportunity to meet here 29 at this commissioners' conference room. It's not 30 often we get such nice facilities to meet in.31 This particular meeting is the first of 32 two meetings that will be conducted.
The next meeting 33 is tentatively scheduled for June the 22nd, and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 5 1 think we're going to try to do that in the afternoon 2 so you folks won't have to either drive down early on 3 95 or the night before.4 I'd like to welcome everyone again. We 5 have participants here from the State of New Jersey, 6 from Region 1, and Kyoto Tanabe from the Japanese NRC, 7 NISA.8 And of course the people that are on the 9 phone line with us.10 We're going to talk about two concerns 11 with you, and they're going to be very focused, and 12 we're not looking for answers from you.13 John Hufnagel and I have done this sort of 14 thing many times since the license application was 15 received in July of 2005. Since that time we've had 16 three onsite audits. We've had regional inspection.
17 And I believe that Roy Matthew, the audit team leader, 18 is here. And he is still working on the audit report 19 and the inspection report.20 The next step in this process as we go 21 through is collecting all the information that we have 22 garnered over these months in preparing the safety and 23 evaluation report.24 Part of that has involved the request for 25 additional information.
To date, we've processed 26 about 128 questions, plus or minus a few.27 Normally, that's the reason I mentioned 28 John Hufnagel, we usually do these requests for 29 additional information on the phone. And the way that 30 we do that is, we have a discussion of what our 31 concerns are, and make sure that you understand what 32 our concerns are.33 When we do the phone calls and meetings NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 6 1 for the request for additional information, we're not 2 looking for the answers at this time. Just that you 3 understand where we're coming from.4 In addition, there are several hundred 5 questions that are in the Q&A database, that Matthew 6 and his team and your team put together during the 7 audits that are publicly available in the Adams 8 (phonetic).
9 The next thing that we do after we have 10 the meetings is, we're going to look for your 11 responses.
And then eventually we're going to process 12 the safety evaluation report, and hopefully there 13 won't be any open items. Right now there are probably 14 some open items there that we still have to follow up 15 on. This meeting is going to address some of those.16 Because the thing that we have to make 17 sure of is that we have reasonable assurance that all 18 of your assumptions and all of your calculations and 19 all of the programs that you've put in place will be 20 valid for the period of the extended operation.
21 So with that, I'm going to turn it over to 22 Frank Gillespie, and we'll go ahead and get started on 23 the discussions.
24 MR. GILLESPIE:
Okay, thank you, Donnie.25 The way we've organized this is, I'm going 26 to present kind of a bulletized issue, and kind of a 27 broader context. And on those issues where we think 28 we really need to give you some detail on what our 29 issue is, then I'm going to turn to Hans. And we've 30 already coordinated between Hans and I. He knows 31 which issues. And we've got some notes developed on 32 it. And as we go through the meeting, we'll do our 33 best, then potentially, to put out in a rapid way some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 7 1 meeting minutes to share the notes.2 And one of our concerns is, you've been an 3 applicant who has been very responsive to our requests 4 for RAIs. You have always made it on time. And on 5 the particular issue we're going to address today, you 6 almost overwhelmed us with information.
7 And so Hans in the last two weeks, and we 8 actually had Noel Dudley helping Donnie and Hans, to 9 try to take this large volume of information and say, 10 okay, here are our original questions; map that 11 information into the original questions and say, 12 what's the residual?13 And the residual were such -and this is 14 an interesting comment, and I have to thank Mitzi, 15 who's from our general counsel, who put this in 16 perspective when we were kind of going through this 17 for me, she said, gee, this discussion is far more 18 focussed and detailed than the way we traditionally 19 write RAIs.20 And from that I said, really, we need to 21 sit face to face, because they are very very specific 22 things that we need blanks filled in, and they are all 23 very technically oriented.
And we probably wouldn't 24 do justice in kind of randomizing, because you'd focus 25 on answering the RAI, as opposed to maybe 26 understanding the underlying concern it causes us to 27 write it.28 And so that's when I proposed this set of 29 meetings.
And so therefore I think today is your 30 opportunity to pummel us with questions to ensure 31 complete understanding of the RAIs.32 It is not our opportunity to request from 33 you an answer to them, because I really think you need NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 8 1 time to take -it's very detailed information, and 2 it's the kind of thing you need engineers back at the 3 plant, I think, probably to mull over and look at.4 So I do thank you for your responsiveness, 5 and you overwhelmed us with information.
We've gone 6 through it all. And it really has narrowed it down.7 So now I'm going to go through the 8 bullets, and on specific ones, you're going to see me 9 turning to Hans. But I'm going to go through each 10 bullet and ask you, do you have any questions.
11 If you don't, then I'm turning to Hans, 12 and he's going to go through the specific details.13 And some of them are more straightforward, and we can 14 go through even quickly.15 As Donnie said, we narrowed our focus down 16 to two concerns, and both of these concerns with I 17 want to call uncertainty.
So we are not making a 18 judgement as to adequacy at this time. Or in anyway 19 absolute.
I'm going to suggest that much of what 20 we're talking about deals with the uncertainly in the 21 information, because of some voids in the information 22 that have to come in.23 So we have dry wall corrosion 24 uncertainties.
And then we have some ultrasonic 25 testing issues. And there are two subsets to the 26 ultrasonic testing issues. One is testing in the 27 upper portion, which is really a pressure retention 28 question, and then there is some questions on the 29 lower portion.30 And if that doesn't come out clear as I go 31 through the bullets, you need to ask us about that.32 Because there are two different kinds of points in 33 there, and we're trying to leave this meeting with no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 9 1 confusion on any part. Because these are really fine 2 tuning now, kind of issues that we're in.3 With that, let me -4 MR. GALLAGHER:
And Frank, just so you 5 know, we have Pete and Ahmed and Howie, and they are 6 like our experts on this issue. So they provided a 7 lot of that information that you're talking about that 8 we provided.
So if we really have any detailed 9 questions, these will be the three individuals
-10 MR. GILLESPIE:
But again, I want you 11 asking us questions today, as opposed to putting you 12 in the awkward position of thinking you need to 13 respond.14 And so as Donnie said, there's no reason 15 to respond today.16 MR. GALLAGHER:
Right, and we really 17 appreciate that, Frank, to make sure we really 18 understand the issues.19 MR. GILLESPIE:
So let me start off.20 Dry wall corrosion uncertainties.
There 21 were assumptions in the 1991 GE report. Within these 22 assumptions there's uncertainties in the simulations 23 of degradation calculations in the associated 24 analyses.
This is not a your action, this is an our 25 action. I just want to let you know that as part of 26 our review, we may be doing an independent calculation 27 or something to reinforce the assumptions in the basic 28 calculation itself.29 So that's not an action for you; that's 30 really an action for the staff. And you might say 31 it's by way of almost what we do in other areas of 32 thermal hydraulics and other things, where we'll do a 33 confirmatory calculation.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 10 1 But so you know it's happening, it's going 2 on, we may be coming back to you for data in support 3 of that calculation later.4 Uncertainties in ultrasonic testing 5 results: There are two key issues here that Hans is 6 going to go over in a little more detail.7 One, there's a report that's referenced 8 that has a disclaimer in it. And the disclaimer says 9 something like, no one at GE or AmerGen can be held 10 responsible for the accuracy of this report.11 It sounds like a boilerplate disclaimer.
12 But nonetheless, it's kind of -again, we're really 13 fine tuning, so I'm being very specific here. The 14 disclaimer raises issues of, well, do you believe the 15 report you referenced.
16 The second piece, which is probably more 17 important with this, and now I'm going to turn to H 18 ans on this, is what I'm going to call the evaluation 19 of the grid data itself.20 And so I've broken this one down into two 21 things: the disclaimer, which I'd like to 22 administratively have you -ask you to please look at 23 it and deal with it. Does it still stand?24 And now I'm going to turn to Hans on the 25 grid data evaluation.
26 Hans.27 MR. GALLAGHER:
Yes, okay, and Frank, is 28 this in the lower portion? Because you broke it up 29 into upper and lower?30 MR. GILLESPIE:
In general.31 MR. ASHAR: In general.32 Let me narrate what I have written, 33 because this is transcribed; I cannot be informed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* ° 11 1 about it.2 So attachment 1-A of the GPU letter dated 3 November 26th, 1990, makes a statistical evaluation of 4 the UT measurements data taken up to 1990.5 On the cover page of the report, GPU 6 Nuclear Corporation states in their disclaimer:
The 7 work is conducted by individuals for use by GPU.8 Neither GPU nor the authors of the report warrant that 9 the report is complete or accurate.10 In view of this disclaimer, the applicant 11 is requested to provide a detailed description of the 12 way the UT measurements data, whether taken as part of 13 the 6X6 grid, or isolated readings, were evaluated and 14 used in performing the analysis.15 Do you understand?
16 MR. GALLAGHER:
I don't.17 MR. GILLESPIE:
We're open for questions.
18 MR. ASHAR: Regarding the clarity of the 19 question.20 MR. GALLAGHER:
Okay. What was the report 21 name again?22 MR. ASHAR: It is attachment 1-A to the GPU 23 letter dated November 26th, 1990, which is a 24 statistical inference of the UT data.25 MR. GALLAGHER:
Okay. And your question is 26 related to the disclaimer itself.27 MR. ASHAR: Disclaimer, which is in 1-A has 28 been used, or if something different is used, what 29 kind of confidence level has been used. Because that 30 particular report talks about the mean and confidence 31 level. But whether it is used effectively all the 32 time, we have no idea.33 Because we looked at the report. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 12 1 didn't interpret report.2 MR. ASHAR: Let me see if I can -this is 3 the kind of dialogue we need to have. Because we're 4 down in the details, really, now. Okay?5 MR. GALLAGHER:
Yeah, this is pretty 6 focused.7 MR. GILLESPIE:
And Hans and I have spent 8 a lot of time together in the last week or so. So let 9 me say it and then ask him if I've said it right.10 Basically in the measurements that were 11 taken it's a scanned area with a grid array of 12 measurements.
And it's not clear whether that's a 95 13 percent confidence interval, is it a median value?14 It's not clear how those area level calculations were 15 used. And much of the information that we used in the 16 1991 report, and in fact in the graphs that you sent 17 in in your RAIs literally takes the result of this 18 calculation.
19 But there is really no description of what 20 -how these data points were combined.21 MR. GALLAGHER:
This would be to determine 22 the average thickness for the -23 MR. GILLESPIE:
Thickness data, yes, and 24 the projection of that thickness data as applicable to 25 the liner.26 MR. GALLAGHER:
Now I thought we had 27 provided a description of that in one of our Q&As.28 Ahmed or Pete, do you guys recall that?29 MR. OUAOU: My name is Ahmed Ouaou. I'm 30 with Exelon Oyster Creek.31 We did -this question came up, we did 32 provide response to the question, what type of 33 statistical analysis did you do.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 13 1 It's also in the RAI, and it's part of the 2 -that's why we submit that report.3 MR. GILLESPIE:
So is there anything beyond 4 that that we provided?5 MR. OUAOU: Well, my main question is, 6 have you used that particular report? Or you use 7 something different?
8 MR. TAMBURRO:
My name is Pete Tamburro.9 The attachment one to that letter, is there a document 10 number.11 MR. ASHAR: Yeah, I think you sent to me.12 It came to us.13 MR. GALLAGHER:
This is in your 14 application.
15 MR. OUAOU: Again, this is Ahmed. We just 16 don't recall what Attachment 1-A is. And what that 17 is.18 MR. ASHAR: I think title is statistical 19 inference.
20 MR. GALLAGHER:
That calculation was 21 submitted previously.
It's part of the original 22 approach that was developed to calculate the average 23 thickness in thinned areas, submitted back in 1991.24 But that's the calculation we use, and 25 Pete can talk about that.26 MR. TAMBURRO:
This is Pete Tamburro.27 The words that you reference about no 28 claims made by the author, that sounds like a 29 technical data report which describes methodology.
30 It's not intended to be a calculation.
31 So I think we owe it to you to go do the 32 research and see what the intent of that report was.33 I believe we later did calculations which normally NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 14 treated the data.MR. ASHAR: This is what we would like to know, that is the question, basically.
MR. GALLAGHER:
So specifically about that report, how we arrive at our statistical analysis.MR. ASHAR: And what actually you used.MR. GALLAGHER:
And what we used, okay.And I just want to make sure, because I think we provided a lot of that. So I want to make sure we don't just provide the same information, and we're missing something.
So if it's just that we can make sure we sharpen our response MR. GILLESPIE:
Yes, we're trying to be very -this is really a very incremental meeting.We're really trying to deal with the piece that we don't feel that we have.And right now if this is the grid, and you take a six by six measurement
-MR. ASHAR: There's 49 probes in it.MR. GILLESPIE:
There's 49 probes. I think, Hans, a fundamental question was, but you come up with a single point that is than used in the next level of calculation.
We're not pushing the next level of calculation; what we're doing is saying, how was that point come up with? Was it a 95 percent?There's a number of ways that are actually all valid to do it. Was it the median of the 49 measurements?
Was it a 95 percent confidence level? How were those 49 points combined to get to the one point which was than used at the next calculational level.And by the way if there is anything that you want to actually respond to in writing like, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 15 1 really didn't understand that. We think we answered 2 it in response this, this and this, following this 3 meeting, feel free to send us that.4 MR. GALLAGHER:
Okay.5 MR. GILLESPIE:
That's quite -because what 6 I really want to do is, this is a starting point, to 7 get clarity in every one of these details. Because I 8 think we are down in the details. I will fully 9 concede we are really fine tuning it.10 MR. GALLAGHER:
And that's what I was 11 getting at in how that 49 point array, how the 12 statistical analysis is done. I think we've provided 13 that answer. We can look at it.14 And then about the disclaimer, we can 15 specifically talk about that. Because I think like 16 Pete said, the intent on that was, the data was taken 17 in the field, and that was validated.
And that data 18 was used in this analysis.19 And it's just saying, we didn't take the 20 data. All we did was do a statistical analysis.21 MR. GILLESPIE:
So just make it clear on 22 how that report was used, and then we're kind of okay 23 there.24 And if you write us a letter and it says, 25 in reply, in reply RAI this, we think we've answered 26 this specific question, that would allow us to reply 27 back, no, here's the specifics of what is missing in 28 that. And that's a perfectly
-I mean that's all part 29 of the process.30 Believe me, you flooded us with so much 31 information, could we have missed something?
Yes.32 And that's okay.33 MR. GALLAGHER:
We wouldn't have talked NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 16 1 about that disclaimer.
2 Pete, did you have something?
3 MR. TAMBURRO:
Yes, I just wanted to make 4 sure I understood a point you made. You would like a 5 description of how we started with the 49 points and 6 came up with a representative value for those 49 7 points?8 MR. GILLESPIE:
I believe that's the point 9 that Hans and I -Hans, why don't you.10 MR. ASHAR: Let me explain.11 I think some of the readings that you have 12 taken are based on the grid. Some of the measurements 13 you might have taken isolated away from the grid, or 14 may not have used the grid. I'm not sure what was 15 done where.16 But that doesn't matter. The important.
17 thing is how you really used this data in coming out 18 with the final thicknesses at those points, that is 19 important.
20 MR. GALLAGHER:
For the grids.21 MR. ASHAR: For the grids, yes.22 MR. GILLESPIE:
So what we're seeing is a 23 layering in this calculational process, where you 24 start with raw data and then you do one thing to that, 25 and then you do the next thing.26 And we're down at the real fine tuned 27 question here at the bottom. And it's that detail 28 that we're not sure that we have.29 Now it might have been submitted in 1990;30 I give you that. Could you repackage it and get it 31 back to us?32 It may be easier for you to do that than 33 for us to do it again.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 17 1 MR. ASHAR: I might say that you might have 2 even provided some description as a result of the 3 audit.4 MR. GALLAGHER:
Yes, that's what I was just 5 referring to.6 MR. ASHAR: I understand.
I did not have 7 a chance to see everything that they have acquired and 8 have responded to.9 MR. GALLAGHER:
Oh, okay.10 MR. ASHAR: Not all. I am aware of it, 11 most of them, the basic things. But I did not see 12 anything related to this one. But if it is there, 13 just give an answer.14 MR. GALLAGHER:
That would be helpful, 15 because we can pinpoint it, and then we can go from 16 there.17 MR. ASHAR: But to me, it looked like at 18 least in 1990 it appears that this particular report 19 was used, and to what extent it was used is not quite 20 clear. How does it relate to what you did, and 21 responded to as a part of the AMP questions, I don't 22 know.23 MR. GALLAGHER:
Right, okay.24 Now, Pete, Ahmed, you guys okay with 25 understanding that, Howie?26 MR. OUAOU: I understand the question.27 This is Ahmed again with Exelon. Part of that 28 response was provided in the RAI and in the questions.
29 So we'll go back and take a look specifically and look 30 at that concern.31 But we're not providing a response to you.32 MR. GILLESPIE:
No, no, again, it's 33 perfectly acceptable for you to say, go back, go back NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 18 1 to New Jersey and say, you know what, we understand 2 your concern, and we think we addressed this is in 3 these RAIs, and the RAIs we have completed reviewed, 4 in fact with multiple people. And if it makes sense 5 that we're looking at how these 49 points -and there 6 may be points that weren't grid points, that weren't 7 49 points, that were individual measurements, or maybe 8 smaller samples. It's not clear that they were all 9 uniformly 49 points, they were all uniform grids.10 That level of detail was not necessarily seen.11 And I will say that we are trying to get 12 you this information as we're putting our draft SE 13 together so we can get these issues closed out.14 MR. OUAOU: Again, this is Ahmed again, 15 the reason I was kind of, I guess, thinking a little 16 bit, it's such a straightforward question, we can 17 answer that today.18 MR. GILLESPIE:
Again, my promise was, we 19 have a second meeting scheduled, and we'd really like 20 to get it in writing before that meeting so we can 21 have a substantive meeting.22 It was important for me, because of the 23 detailed nature of our concerns, to get them to you 24 and make sure you understood them. And I didn't say 25 they were hard to answer. So just because we have a 26 concern doesn't mean it's difficult to answer. What 27 we wanted to do was get this kind of detail to you so 28 you could answer it, and that was the important 29 aspect.30 MR. GALLAGHER:
I think we understand 31 that.32 USE OF ASME CODE SECTION 3 SECTION NE-3213.10 FOR 33 LOCALIZED CORROSION AREAS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 19 1 MR. GILLESPIE:
The next point was use of 2 ASME Code Section III, Section NE-3213.10
-now you 3 know why I say we'll publish the meeting minutes to 4 this early -was used for localized corrosion areas.5 And this is a comment that is also going to come up 6 later.7 And by the way, this is all dealing with 8 the 1991 GE report. So it's not that you used it;9 it's that it was used in the 1991 GE report. In 10 general that code was written for and applicable to 11 new containment shells. And the methodology for the 12 buckling calculation, it's not clear its applicability 13 to a shell that's actually older and has corrosion.
14 And I'm going to get Hans to amplify that, 15 but in my simplistic terms -I get to be the non-16 engineering interpreter, and he gets to put the 17 details on it -if things corrode in a manner that's 18 pitting or discontinuous, and you have a shape that is 19 much different than the discontinuity from two 20 different sized plates.21 And so this code was specifically 22 developed for one purpose. That doesn't mean it's 23 wrong to use it for this purpose; what it means is, 24 the transition to using it for this purpose wasn't 25 included in the 1991 GE report.26 Now with that I'm going to turn it over to 27 Hans.28 MR. ASHAR: Let me just narrate the way I 29 formulated the question.30 For the localized thin areas, the 31 applicant is using the provision of Section 3213.10 of 32 the subsection NE of Section III of the ASME Code.33 This provision, though not directly applicable to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o.o 20 1 randomly thin areas caused by corrosion, if used with 2 care and adequate conservatism, may provide some idea 3 about the primary stress levels at the junction of the 4 thin and thick areas. The applicant is requested to 5 provide a summary of the process used and to address 6 this issue.7 MR. GALLAGHER:
In this particular 8 analysis, I note that that particular question was 9 looked at earlier when the analysis was originally 10 reviewed and approved.11 And I think, did we have discussion about 12 that in the Q&As?13 MR. OUAOU: This is Ahmed Ouaou again with 14 Exelon. There was a discussion in the Q&As on the 15 issue -on the concern. We spent a lot of time with 16 the audit team talking about the calculation in 17 particular, and it was reviewed by the audit team.18 This same question that you have a concern 19 was asked -again, I have to go back a little bit, 20 because I spent a lot of time looking at the history 21 on this -the same exact question came back in '91, 22 and we -there was a formal report that was generated 23 and submitted to address the question.
It was done by 24 Teledyne; it's not the GE report. It's in response to 25 an RAI.26 Our understanding is that after review of 27 the calculation at the site that it appeared the 28 approach was reasonable that it should not be a 29 concern from a stress concentration perspective.
30 MR. GALLAGHER:
And this review was done 31 when the 1991 account was generated?
32 MR. OUAOU: That's correct.33 MR. GALLAGHER:
So what we were looking at, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* .
21 1 we didn't see how there was any aging management 2 related effect on the differences between the way it 3 was evaluated before and when it was evaluated now.4 MR. ASHAR: Let me again restate.5 The question is, this particular provision 6 in the ASME code is not written for the localized 7 corroded areas. It has been used here between thin 8 and thicker parts to justify the use of, you know, in 9 a particular way.10 Now I can see that there is no other way 11 you can do that except to use this type of provisions.
12 But I want to understand what kind of conservatism you 13 have used.14 Because there are a number of items 15 related to this provision that are in the ASME code.16 For example, for primary membrane stress there is one 17 particular areas where you go up to the square root of 18 RT; for the secondary stress, you go to the 2.5 square 19 root RT, and figure it out as to, now, I want to make 20 sure that you have considered representation of the 21 thin areas in this particular process.22 MR. GALLAGHER:
I think that's helpful, 23 Hans. Because we didn't identify any other specific 24 method to use, other than use this. And then there 25 were some I guess checks that was done for, like, one 26 thing Frank mentioned was about the plate changes;27 that was one check. Another check was done as far as 28 a one-by-one depression, a one-by-one-foot depression 29 in the shell; and then another would be a fairly 30 localized 2-1/2 inch depression.
31 So they were kind of checks that said, 32 they didn't look like there was any significant impact 33 on the analysis.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 22 1 The roughness looked like to us it'd be 2 more of a -maybe it related to a fatigue concern, 3 which really isn't an issue for the drywell.4 So that's why that kind of a review, I 5 think, was done in the 1991 review and analysis, and 6 the staff had accepted that at that point.7 And I don't think there's any methods 8 that's changed since.9 MR. ASHAR: This is for the license renewal 10 we are talking about. So I understand that the staff 11 will issue a report based on certain things.12 But we are looking at this in more depth.13 And we want to understand the mechanism before we go 14 and say, hey, this is the reasonable assurance that 15 something would happen.16 So you might see this as duplicative or 17 something, in your mind, but for us that information 18 is necessary to make that reasonableness estimate.19 So even if you might have done something, 20 you might have responded to this type of question in 21 past, in 1992, 1993, I think we would like you to tell 22 us more about it. If you done it during the audit 23 team, please let us know about it. We can go and 24 check it out in the AMP's responses.
There is nothing 25 -but I just want for you to understand that you 26 understand the question.27 MR. GILLESPIE:
Yeah, this is not to say 28 you haven't done it before, and it's part of 29 everything that happened from the mid-'80s through 30 '91. It wasn't reviewed by the staff for the purposes 31 of the current existing license. But this is a 32 question as part of the renewal review.33 And if we're requesting you to repackage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 23 1 something and send it in as part of this, then that's 2 our request, because we're a second time dealing with 3 what I said was the uncertainties.
We're not saying 4 anything negative about the GE calculation.
What 5 we're saying is, we have a set of reviews reviewing 6 this for another 20 years on your license beyond, and 7 so this is an aging issue.8 I mean we met with ACRS on this yesterday.
9 We're not saying you didn't do it 20 years ago. What 10 we're saying is, it's not really readily available to 11 the staff to be able to include it in their more 12 global judgment on the liner today.13 So if pulling it out of your records and 14 getting the Teledyne report, if that's easy -I didn't 15 say we were asking anything that was hard. I said we 16 were going to try to give you our specific concerns.17 .MR. OUAOU: The Teledyne report was not in 18 QA. But we can provide the Teledyne report and 19 several correspondences to that address the question.20 MR. GILLESPIE:
That would be appreciated.
21 Remember our goal here is to answer the questions.
22 This is a bit collaborative in nature.23 The other thing I have to ask your 24 forbearance in part of our idea of trying to stay on 25 a certain schedule is that things get done in 26 parallel.
And the audit team is in the process of 27 writing a report, and the last I heard they were on 28 page 700. And they have to look at it in an 29 integrative way also. And that is one input to the 30 SE.31 But that's input eventually to Hans.32 Because Hans is the guy who on the line has to really 33 make the safety judgment on behalf of the agency.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 24 1 So I'm asking for your assistance.
If 2 it's a bit of repackaging, or a resubmittal, this is 3 what's going to get the job done.4 MR. GALLAGHER:
Okay, so if we describe 5 this analysis, and what -how we think it was put 6 together to conservatively address some of these 7 issues, then we could do that and talk about the 8 Teledyne work. And I guess, I want to make sure, 9 Hans, do you have any other methodology that we should 10 be looking at?11 MR. ASHAR: Well, yes, I think I'd refer to 12 one report which Sandia developed for big area of 13 containments.
But I don't know to the extent to this 14 particular aspect, it addresses that area.15 What it does is, it models certain 16 enclosuresand certain degradation in containments of 17 various types. It's a Mark I, Mark II, all 18 containments have been considered in those.19 MR. GALLAGHER:
Okay, that report is 20 available?
We hadn't found that report, had we?21 MR. ASHAR: I know. I'll try to get it.22 MR. GALLAGHER:
Can we get that today?23 Because that would be real important to us.24 MR. GILLESPIE:
Yes, if we get the ML 25 number, since we're adjourning at lunch.26 MR. ASHAR: Yes, we'll put it in ADAMS.27 MR. GALLAGHER:
That would be helpful, 28 because we can review that report.29 MR. GILLESPIE:
And it may be as easy as 30 saying, here's what we're done. Here's this other 31 report that's a little newer. And here's why we're 32 consistent with it, and why this makes sense.33 But that's your judgment to do. We're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 25 1 trying to give you our concern, and Hans is trying to 2 give you at least one reference that's available to 3 kind of the NRC sponsor which is kind of a benchmark.
4 And again, we're dealing with the 5 uncertainty of the information at a very fine level, 6 so.7 MR. OUAOU: Again, this is Ahmed Ouaou.8 I just want to ask a question.9 Do I understand you to say that that 10 report, the Sandia report, has a benchmark we should 11 be measuring against?12 MR. ASHAR: I don't think so. The reason 13 I don't recommend that is because it is meant only for 14 internal reference.
15 MR. OUAOU: This is information?
16 MR. ASHAR: To the extent you can use it.17 It is not something that is endorsed for use for 18 anybody.19 MR. OUAOU: Do you know of any other 20 methodology that would take surface corrosion areas 21 that you're concerned with?22 MR. ASHAR: No, I'm not aware of any.23 MR. OUAOU: You're not aware of any?24 Okay, thank you.25 MR. GALLAGHER:
And we had looked at it, 26 that stress ride issue looked like it was more of a 27 fatigue issue, and the containment fatigue really 28 isn't a concern.29 MR. ASHAR: Well, containment for the ease 30 of concern in the area of events, right.31 MR. GALLAGHER:
Right.32 MR. ASHAR: But away from there, you don't 33 have that concern.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o* o 26 1 MR. GALLAGHER:
That's correct.2 MR. GILLESPIE:
But again, this is not 3 saying you don't have the information on site. It's 4 only saying we don't have it in a form which we can 5 identify that it specifically addresses this question.6 And so if you can help put that 7 information in a form that specifically addresses the 8 question -this is why I didn't want to get -this is 9 why I said, let's have a meeting, versus writing RAIs 10 where we didn't -have a total misinterpretation of 11 the RAIs.12 MR. GALLAGHER:
Yes, right.13 MR. GILLESPIE:
So again if you get back to 14 the site, and you want to email us, because emails are 15 on the record, and we try to keep everything on the 16 record, to get further amplification, that's 17 perfectly.
And you know if you have thoughts when you 18 go back, just say -you know.19 MR. GALLAGHER:
Okay, that's helpful, thank 20 you.21 MR. GILLESPIE:
We finished with -this was 22 really the assumptions in the 1991 GE report section.23 And so there were really two bullets that we had in 24 summary. And that was, the first was the 25 uncertainties in ultrasonic testing results, and this 26 was the grid thing we talked about, and then the next 27 one.28 And the first one was just for you to know 29 that we're going to do something of an independent 30 nature to verify the calculation.
And that's not an 31 action on you, that's an action on us.32 VALIDATION OF UT MEASUREMENTS AND BUCKLING ANALYSIS 33 The next major topic -and major doesn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 U 27 1 mean important; major just means it's the next heading 2 on my notes -is validation of UT measurements and 3 buckling analysis.4 In this I have three principal notes, and 5 let me just go through them. And the first note is, 6 UT results indicating increase in shell thickness.
7 And there was this anomalous point.8 And the anomalous point raises questions 9 that are probably unanswerable.
So let me say in 10 retrospect, looking back, the answer to the specific 11 question might be unanswerable going back, but the 12 actions to be taken in the future might be very 13 doable. And that's questions on the accuracy of 14 measurements, the appropriateness of calibration, the 15 .-one point was significantly above the curve.16 So with that, let me turn that one over to 17 Hans, so he can go into details of that concern.18 MR. ASHAR: Okay, I 'm going to narrate that 19 again.20 In the sand pocket region of a drywell 21 shell, the most susceptible base are incorporated into 22 assembly.
However, there are a number of issues that 23 need to be addressed to ensure that the readings are 24 taken at the vulnerable locations and techniques used 25 are reliable.26 I'm talking about the technique right now 27 first, and then I'm going to talk about the other 28 points. That will come with discussion of the other 29 bullets.30 Review of table two indicates that the UT 31 measurements taken from inside the drywell after 1992 32 shows a general increase in the measurement taken from 33 inside the metal thickness.
In some cases it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 2344433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 28 1 increases as much as 50 mils in a two-year time frame.2 MR. GALLAGHER:
What was that number?3 MR. ASHAR: Fifty mils.4 MR. GALLAGHER:
Fifteen?5 MR. ASHAR: Fifty, 5-0.6 MR. GALLAGHER:
Oh, 50.7 MR. ASHAR: Fifty mils within a time frame 8 of two inspections, 1994 and 1996, I think.9 In general it appears that the UT 10 measurements taken after 1992 requires proper 11 calibration considering the coatings on both sides of 12 the drywell shell.13 The applicant is requested to address this 14 issue.15 MR. GILLESPIE:
Now, again, as I said, you 16 can't go back and fix what is.17 MR. ASHAR: Well, Frank, I don't agree. I 18 think if the tests done outside on an epoxy-coated and 19 galvanized inside, and you've calibrated that, the 20 readings taken earlier can be reduced to this.21 It's possible to do it too to the existing 22 -but I don't know what you want to do.23 MR. GILLESPIE:
What you're saying is, if 24 they did some calibration samples, that had the proper 25 codings on either side, there may be the data 26 available in their records to go back and -27 MR. ASHAR: Yes, compare what they have 28 done earlier with or without coatings, you know, that 29 kind of thing.30 MR. OUAOU: Again, this is Ahmed with 31 Exelon. I was surprised, too, that those points were 32 as high as they are. We expected some variation 33 because of surface roughness, of the shell itself.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 29 1 Although we use a template, and we use a 2 probe. If you just happen to move the probe just a 3 little bit you would get a different reading.4 But in that particular
'92, it appears 5 that one set of readings were consistently higher than 6 the rest. And we spent a lot of time trying to find 7 the cause that caused that, and talked to Rich Morante 8 at the site there during the audit review. And 9 frankly, what they came up with I'm not sure that's 10 satisfactory.
11 We just couldn't.
Qualified people were 12 doing the testing, same methodology that was used 13 before. We haven't looked at the potential, because 14 there is a grease where you do UT measurements, 15 potentially, that might not have been removed. We 16 looked at all that, but really couldn't come up with 17 a specific answer why those values were higher.18 MR. TAMBURRO:
Going forward, the potential 19 items that we've looked at, we're going to reduce or 20 eliminate them. For example the grease will be 21 removed prior to the inspections.
We will do 22 calibrations, both on the external coating and the 23 internal coating, to get an understanding of how they 24 affect the measurements.
25 So we intend on reducing all those 26 potential variants out of the future inspections.
27 MR. GILLESPIE:
The importance of this 28 issue may be one, the narrow technical issue itself.29 And it's a good response.
Didn't really need it, but 30 it was a good response.31 But it does contribute to the general 32 thought we have which we'll get to later when we talk 33 about some of the commitments you made already on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 30 1 level of uncertainty.
And these things just 2 contribute to the level of uncertainty of the 3 measurement.
4 And I would use -maybe it's not 5 invalidating the measurement, but it's the uncertainty 6 involved with any individual measurement, and the 7 trend.8 And uncertainty, like I said in the 9 beginning, is kind of what we're trying to reduce or 10 understand through all of these points.11 And so I think the idea that you can only 12 make these measurements just so certain, and just -13 let's just keep it -there's only so much you can do 14 with these kind of UT measurements.
15 But, this seemed to be a very large 16 uncertainty, in fact much in exceedance of some of the 17 things you've actually measured in other areas.18 relative to thickness changes.19 So as long as you understand our concern, 20 this -minimize the contribution of these to 21 uncertainty, and if you can't do anything about the 22 past one, you can't; you did this examination then.23 But this contributes to some of the 24 thoughts we have relative to the 10-year commitment 25 that we'll talk about later.26 MR. ASHAR: I feel that you will have to do 27 some kind of a comparative testing in order to, at 28 least for the future readings that you take is going 29 to influence that.30 If that was the cause, because of a 31 coatings on two sides, this thing we have normal 32 readings that showed more thickness than the other 33 thicknesses, then I think it is something that you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 31 1 ought to look into it and come to grips with it.2 MR. GALLAGHER:
How many points did you 3 have a concern with, Hans, do you remember?4 MR. ASHAR: Well, I just think in general.5 Just like Ahmed said before, in general you can see 6 when you look at the readings that they are increasing 7 in 1996 compared to 1994. 1992 and 1994 are almost 8 same; they are not changing too much in general. But 9 there are a few places where it is about 30 mils 10 higher or 50 mils higher, like that, you know.11 So there's an anomaly here, and that has 12 to be resolved.13 MR. OUAOU: If I may just add, that we're 14 benchmarking other people doing the UT measurements in 15 the past, but that was before 1996. For instance, GE 16 -GPO brought in GE to do some UT measurements.
And 17 I don't believe the methodology has changed in the way 18 we did it.19 Whatever, we couldn't explain it. We 20 couldn't explain why these particular points were that 21 much different than the previous UT measurements.
22 MR. GILLESPIE:
Just keep the word 23 uncertainty in mind, and let's move on. We live with 24 uncertainty; we're not asking for absolutes.
25 The next item is sensitivity studies for 26 localized corroded areas. And I'm going to turn this 27 one over to Hans, because my notes are that we 28 basically have -we've only reviewed the results in 29 the application on these reference sensitivity 30 studies. And that we really weren't provided with an 31 expansion of what was -how was the sensitivity study 32 done, how were uncertainties considered in it; that 33 there's kind of an absence of detail at the next level NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 32 1 down.2 And because we didn't get the detail, I 3 can't give you a specific question on what's missing.4 So let me ask Hans on that one, because I think he's 5 at the same loss I am on that one.6 MR. ASHAR: Yes, that is true.7 I think I did point out about 8 sensitiveness, that they have to be correct enough 9 that we have confidence that the metal thickness is 10 what it's measuring.
That is all I can say at this 11 time.12 MR. GALLAGHER:
What sensitivity studies 13 are we talking about?14 MR. ASHAR: What we are talking about, as 15 I explained earlier, that you take a plate, similar 16 plate, and take the UT measurements outside, without 17 any coatings inside. And then you take the 18 measurements with zinc oxide, whatever coating you 19 have applied inside, and outside epoxy coating, and 20 see -the measurements
-and see if there is any -I 21 mean you have to take enough sample to make sure that 22 you have got confidence in what you are doing, even 23 for the tests. This is what we are thinking.24 It's up to you.25 MR. OUAOU: This is Ahmed with Exelon.26 Inside, we don't have a coated -27 MR. TAMBURRO:
No, we have a protective 28 grease. They're supposed to clean off that in the 29 grid area, clean it off and then do the -30 MR. GILLESPIE:
Then I think you're exactly 31 where I think Hans is at, is, there was no evidence in 32 the submission, I think it talked about doing the 33 representativeness, but there was no description that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 33 1 would say, okay, we do it with the grease steam 2 blasted off and we do it actually under conditions 3 that are in containment where they may wipe it down 4 with acetone or something else to get it clean, just 5 to get a handle on the uncertainty involved in the 6 measurement itself.7 Remember, all the topics we're talking 8 about now are really uncertainties involved in the UT 9 measurements.
And we're trying to get an 10 understanding of, how do you think about them, and 11 what have you don't to make sure you have a handle on 12 the uncertainties.
13 And in this case, it wasn't really -the 14 description, you've already said more here than we've 15 had in the application dealing with the uncertainty.
16 We have an organic grease; we clean it off. So what 17 we're looking for is some understanding so Hans can 18 say, you know what, that's a pretty credible way to 19 understand the uncertainty involved with the 20 measurement technique being applied.21 MR. TAMBURRO:
This is Pete Tamburro again.22 So when you said sensitivity, you're really talking 23 about sensitivity testing of how we do our ultrasonic 24 tests.25 MR. GILLESPIE:
You might say, what you're 26 doing to assure yourselves that you've got a handle 27 that the reading coming out -and I know that every 28 utility has a program that does this kind of 29 qualification thing. It just wasn't described in 30 there. And the sensitivity here is a large component 31 very much of interest, and that information just 32 wasn't there.33 On the other hand, we didn't ask you for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o* ° 34 1 it.2 MR. GALLAGHER:
Okay, thank you.3 MR. GILLESPIE:
So it wasn't your fault it 4 wasn't there; we didn't ask you for it. So we're 5 asking this. That's why we're putting it on the table 6 right now.7 And again, I think you probably have a 8 program there.9 MR. OUAOU: No, this was not in the QA.10 In the QA we said that we're going to take the UT 11 measurements through the epoxy coating on the outside, 12 because it was qualified previously; and we're going 13 to use the most up-to-date techniques to do that.14 MR. GILLESPIE:
What is the most up-to-date 15 techniques for Oyster Creek?16 MR. GALLAGHER:
So we'll give you a 17 description.ý 18 MR. GILLESPIE:
Again, I didn't say any of 19 this was hard; I just said we don't feel we have it.20 MR. GALLAGHER:
Right.21 USE OF ASME CODE CASE 284-1 22 MR. GILLESPIE:
One last one -any 23 questions?
One more under UT measurements, that is 24 going to be the use of ASME Code Case 284-1. And I 25 want to temper this a little bit, because there is 26 already a 284-2, as best I've been told, out. Neither 27 one have been endorsed by the NRC, but not being 28 endorsed by the NRC actually does not invalidate them.29 But it does put a burden on you into 30 having to convince us on the applicability.
And these 31 deal with buckling of the shell.32 And the validation of the underlying 33 assumptions, you can' t depend on ASME, because you' re NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 35 1 using it, and they haven't -we haven't really looked 2 at it on their behalf yet. And that's kind of how I 3 understand the issue.4 But now I want to turn to Hans for the 5 details on this one.6 MR. ASHAR: Yes, this Code Case has been 7 within the agency for a number of years now, since it 8 was, the first one was proposed by Dr. Miller, who had 9 done the testing, and committed to all the results.10 Now we did not endorse it during review of 11 reactors for the buckling analysis, 284-1. We did 12 take a Branch Position during that time. And in 13 addition to what they have done in 284-1, we require 14 them to do more in the bifurcation analysis, and 15 reduce the plasticity index, and those kind of stuff.16 284-2, which ASME still is struggling 17 with, has a number of changes made in this area, and 18 that is -and with the typographical corrections that 19 they are making right now, put into the equations.
20 Because that makes a lot of difference in the research 21 you have.22 So I think that looks to be something 23 acceptable you might accept in the future. Until now 24 there is uncertainty regarding the use of 284-1.25 Now, if it is used only the way I saw it 26 being used is in one particular provision that is 27 quoted in response to the TLAA is that you have 28 assumed that the stresses are uniform along the 29 thickness of the metal.30 Now in the case of a localized corroded 31 area, that may not be the case. Because when you 32 start from a corroded area to an uncorroded area, you 33 lose metal thickness.
But it might have a lower NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* .
36 1 strength than the strength than you go up above at the 2 end of the plate.3 Okay, if it's conservative, that's fine, 4 use it. But I believe it may not be conservative.
5 Because there will be a decreasing strength as you go 6 near the corroded area. And it might show you as the 7 metal thickness, but the strength may be different.
8 MR. GILLESPIE:
Basically you've got that 9 oxide layer on the outside. And we're not saying it's 10 right or wrong. As I said, endorsement or not 11 endorsement doesn't affect the applicability, but it 12 puts the burden on you, because we have not accepted 13 it in this application to give us the explanation of 14 why you still think it remains conservative enough.15 And this is in addition to the RAI. It's 16 kind of the next level of detail down on that RAI.17 :_'.MR. OUAOU: And again, Ahmed with Exelon, 18 we did, spent a lot of time at the site review on this 19 particular item. And the calculations that were based 20 on 284-1 were reviewed.
And the conclusion is that 21 the impact of 284 for what we're using it for is not 22 significant.
23 There are a number of questions that deal 24 with those provided in response to these questions, as 25 well as the previous discussion, back in '91 or 26 whatever, that came up when this was used.27 But one of the things -28 MR. GALLAGHER:
Just one question I have 29 here, isn't this really the same issue as item two, 30 the '91 GE document.31 MR. ASHAR: Well, they have different 32 implications.
One thing is about the area considered 33 for discontinuity analysis, and one is about the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202)234-4433 37 1 buckling analysis itself. So those are two different 2 aspects there.3 MR. GILLESPIE:
In principle you could say 4 it's ASME code and (garbled) code. In principle and 5 philosophically even. One is dealing with some of the 6 assumptions in the GE calculation, and this one is 7 really dealing -8 MR. ASHAR: The buckling analysis.9 MR. GILLESPIE:
-- with the buckling 10 analysis.11 MR. GALLAGHER:
The other one was related 12 to the buckling analysis also, right?13 MR. ASHAR: Well, not necessarily.
14 MR. OUAOU: The difference with 284 is, 15 that's what's actually again the capacity factor.16 MR. ASHAR: Capacity factor. That is where 17 18 MR. OUAOU: -- factors that you use to: 19 correct your allowable stress to come up with a stress 20 at the end.21 MR. GALLAGHER:
So did we provide a 22 description of the use of the Code Case 284?23 MR. OUAOU: It was not in the RAI; it was 24 in questions.
Yes.25 MR. GILLESPIE:
So again, we have two 26 processes going on. And the audit guys are still 27 writing their piece up.28 But if you feel you've answered it, but 29 you need to understand Hans' specific concern is still 30 lingering in his parallel collection process is the 31 application of this code.32 And we put this under UT measurement and 33 buckling analysis, because it's how you take the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 38 1 measurement itself, as I understand it, and then 2 incorporate that into the calculation, which is a 3 little different than the translation we talked about 4 in the calculation, the other ASME code piece.5 What I'm trying to do is, we'll get it on 6 the table here. The audit process is going on in 7 parallel.
And if you feel, if you can point to the 8 Q&A that it's answered, and just for convenience, 9 you'll be helping us out, for Hans. We're not trying 10 to make you recreate a whole new report if you've 11 already given us the information.
12 We'll internally check with the audit team 13 on the Q&As on this, but if you want to hold our feet 14 to the fire, because we've already asked it to you, 15 and email it in, that would be appreciated too, and 16 we'll make sure we get the point covered.17 But you need to know right now in the 18 overall evaluation, this is right now kind of an 19 unanswered issue.20 MR. ASHAR: The main thing is that in the 21 response that you provided to the TLAA you say you 22 made use of a particular provision 1700, which is -23 allows you to use it as the same test level throughout 24 the thickness.
Now the point that I am trying to 25 make, it may not be true. So there might be a 26 possible distribution of the strength, and you might 27 have a different output from that pint. The analysis 28 is based on this type of assumption.
29 So I want to make sure that you are doing 30 the right thing.31 MR. GALLAGHER:
Is there a different code 32 case or assumption we should be using?33 MR. ASHAR: No, I think it would be -NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 39 1 because this is very specific to the characterization 2 of the various containments.
You have to make a 3 certain judgment as to how the strength near the core 4 area would be as compared to away from the core area, 5 and make a -if you have done the average strength 6 analysis, it will not be conservative, and you might 7 have to pull your neutral axis up, and it might change 8 the character of you compressive stresses.
That's 9 what I'm thinking about.10 MR. GILLESPIE:
Mike, it's plant specific, 11 and ASME, as I understand it, doesn't really have a 12 lot of code cases that go out to 60 year lives, and 13 deal with longer term corrosion issues, and the 14 specific effects, and how they may modify codes that 15 were actually there for design codes.16 And so we have to look to you to now 17 explain the application.
And we're not saying the 18 application is wrong; we're only saying, you need to 19 explain this piece to us on the application.
20 So we're not telling you to do it 21 different.
We're only saying, again, this contributes 22 to the uncertainty of the application of it. And if 23 you've answered this in the RAI database and you can 24 point that out to us, and we'll check internally, 25 that's fine.26 But this as of this morning is kind of an 27 uncertainty in the engineering case.28 MR. GALLAGHER:
Okay, you guys have any 29 other questions related to that.30 MR. OUAOU: No, understood.
31 MR. GALLAGHER:
Good, because when he 32 starts going into moving the axes on compressive 33 stresses, that's why he has to sit here.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 40 1 MR. GILLESPIE:
Okay, next topic, and in 2 fact, the last topic, and again, we're trying to be as 3 fine tuned and as crisp as we can, because if we sent 4 you some general RAI to try to get where I hope we're 5 getting at this meeting, it would not have the 6 specifics that just transpired right here in it, so 7 that we can nail this thing down.8 ULTRASONIC TESTING ISSUES 9 Ultrasonic testing issues: And now we're 10 shifting not to the technique, and not to the 1981 11 report, but sample size and sample locations.
12 And again, we have -I'm going to say -13 three areas of clarification that are needed.14 And this one is junctions between plates 15 of different thicknesses.
The generalization that I'm 16 understanding is, the reason for which points are.17 being selected where. And now we're really talking 18 about the upper parts., and the representativeness, bad 19 word, how representative the points you're using are 20 to the whole, which if it was demonstrated 20 years 21 ago, it's not clear that there has been a 22 redemonstration, as we're trying to add yet another 20 23 years on to the license.24 And so with that, let me turn this one 25 again over to Hans for some detail.26 MR. ASHAR: I'm going to go through three 27 areas here, okay. The cylindrical portion of the 28 sample size and the spherical portion of the sample 29 size and the sanbed area.30 The samples taken at this time in the 31 upper portion of the cylindrical portion it is taken 32 I think at one elevation of 87 foot 5 inch. Represent 33 a cylindrical portion of a drywell, and then it is our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 41 1 suggestion at least for the future UT results to add 2 one more elevation for taking the samples, which is 3 71.6 inches.4 And what the significance of that 5 particular elevation is that is where the lower 6 thickness meets the knuckle (phonetic) area. And the 7 question here is that if the water even in a small 8 conduit is passing through there, it is going to 9 stagnate in the area there, because the ledges form in 10 that area on the upside. And that is where the water 11 is going to accumulate, or it might be absorbed into 12 the insulation itself, wouldn't know what would 13 happen.14 But that is a sensitive area which could 15 be subject to more corrosion than the straight portion 16 of the cylindrical area.17 So our suggestion for the future is to 18 have you include that area near the junction of the -19 to get a confidence that you are good enough, your 20 sample size, enough locations taken.21 MR. GALLAGHER:
So this is elevation 71.6?22 MR. ASHAR: 71.6, that is the suggestion.
23 You might not have platform there, you might have do 24 something else. So you may change a little bit here 25 and there. But the point is that the dissimilar 26 thickness, wherever you go to the joint between the 27 courses, you know, thickness courses.28 MR. GALLAGHER:
Just where the knuckle is.29 MR. ASHAR: Just before the knuckle.30 MR. TAMBURRO:
This is Pete Tamburro.31 So are you asking to take a representative 32 sample of one plate, and then the weld, and then 33 another plate?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o* o 42 1 MR. ASHAR: Yeah, I think if you use the 2 6X6 grate in the grated area you can cover the whole, 3 including weld and everything, in one grid.4 MR. GILLESPIE:
Remember, the underlying 5 question is, because we're not telling you what to do.6 What Hans has done is very nicely given you a specific 7 example of where he feels the physical configuration 8 forms an area which could be conducive to higher 9 corrosion rates than potentially your sample that 10 you're taking.11 So the real question is the 12 representativeness of your current sample as we go 13 forward for even another 20 years. And it's not that 14 we're asking you to do this everytime; what we're 15 asking you to.do is reinforce the assertion that your 16 current sample is in fact representative.
But we've 17 noted that you haven't been looking at this area which 18 byphysical configuration could be picked out as maybe 19 a high corrosion area.20 So it's kind of the validation of what 21 you're doing, and so it -I guess what we're asking 22 is, remove this uncertainty in your sampling process 23 somehow. And the only way we can think to do it is to 24 pick a high corrosion area that's not being sampled 25 and ensure it actually is -continues to be enveloped 26 if you would by the current area.27 MR. GALLAGHER:
And I guess I'm -I mean we 28 actually did some exploratory on the knuckle area, 29 didn't we, Pete?30 MR. TAMBURRO:
Yes, we did.31 MR. GALLAGHER:
In the past. So we have -32 MR. GILLESPIE:
Sometimes you only have to 33 document what you did if you did a good job.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 43 1 MR. GALLAGHER:
Yeah, this drywell has been 2 very thoroughly looked at over the years. So the 3 chances are, we have that data, and I think we talked 4 about that earlier.5 MR. ASHAR: Yes, I would have relied on the 6 thousand UTs you have done before. But because of the 7 continuing water -8 MR. GILLESPIE:
Yeah, there's an operating 9 history there that gives us a concern in operations.
10 And again, we're updating -you know, in always 11 sampling a measurement, what you're really trying to 12 do is bring the applicability of that calculation up 13 to date, and that's really -- and the only way to do 14 that sometimes is a positive measurement.
15 And so yes, you might have done it 15 16 years ago; but there's been an operating history and 17 an experience base since then which has affected the 18 environment in that gap.19 And so it's your option. You can either 20 explain why 15 years ago applies to today, given all 21 of that operating history, or positive knowledge on 22 both of our parts, versus arguing words and pencil 23 notes, well, take a measurement.
24 MR. GALLAGHER:
No, I think it's a good 25 idea.26 MR. GILLESPIE:
You know what I mean? It 27 eliminates all the bias, and to a degree the 28 uncertainty, and gives you a new point to project.29 Because you're asking for a license for an additional 30 20 years.31 And so we had confidence in that assertion 32 for the remaining portion of your current license, 33 which is 2009, and now we need something a little more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 44 1 to project that past 2009 for an additional half a 2 life.3 MR. GALLAGHER:
Yeah, I think that's a good 4 idea. I just wanted to make sure you knew we'd looked 5 at that.6 MR. GILLESPIE:
I didn't know you had 7 looked at that area, because it wasn't part of the 8 application.
9 But again, you have to understand our 10 concern. It's not just isolated to that area; it's 11 that area combined with operating history subsequent 12 to those measurements being taken.13 Again, to revalidate the trends, 14 revalidate the calculations.
So we're kind of looking 15 at a revalidation process given the operating history.16 MR. GALLAGHER:
Okay, so any other 17 questions on that, guys?18 MR. ASHAR: A similar request in the area 19 where the thickness of I think .622 missed the 1.548 20 thick area. There is the area likely to be -there is 21 some accumulation of water if anything is going on.22 Similar to the cylindrical portion. The junction of 23 the thickness change.24 MR. OUAOU: This is aside that region -25 MR. ASHAR: No, above the same region.26 MR. OUAOU: So from 1.154 to .77.27 MR. ASHAR: Exactly.28 MR. OUAOU: Okay.29 MR. GILLESPIE:
So the plate above the -30 MR. OUAOU: Right.31 MR. GILLESPIE:
That joint right there.32 MR. OUAOU: Yeah.33 MR. OUAOU: This is Ahmed again. One NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 W* o 45 1 thing I'm not totally sure on yet, I understand the 2 differences in the thicknesses.
But typically you 3 grind that so you wouldn't have that. We have to go 4 back to confirm that. So I just wanted to mention, 5 typically you wouldn't leave a discontinuity like that 6 going from one thickness to the other without grinding 7 it.8 MR. ASHAR: Well, if they use a groove weld 9 to weld those two courses, I think you are going to 10 have a ledge. There won't be a transition there.11 MR. GILLESPIE:
Again, the big question is, 12 the representativeness of the current sampling program 13 for areas that when another engineer looks at it says 14 you could have a ledge there.15 Again, we are not here to give you the 16 answer; we're giving you our concerns.
And there are 17 two ways you can do it, and there are a combination of 18 two ways you can explain it.19 ... MR. OUAOU: The only thing I may add is 20 that when the investigative work was going on to come 21 up with the very 1,000 UT measurements to find the 22 thin areas, we didn't stay away -I don't think we 23 stayed away from the areas where we transitioned from 24 one plate to the other, especially when you do that 25 from the outside.26 You move the template along the elevation 27 to see where you have a corrosion, and you don't 28 specifically say I'm going to exclude this area 29 because it's not -30 MR. GILLESPIE:
Again, that was for the 31 life of the current license. And really what you're 32 asking for in renewal space in your application, 33 fundamentally, is to take that projection and now move NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o.o 46 1 it forward now almost 17 years or 20 years to the end 2 of the license, and you're asking the NRC to make 3 another 20-year judgment.4 We're fundamentally remaking the 20-year 5 judgment we made before. And so it's the same 6 technical issues, are still the same technical issues, 7 and again, it's your choice. But what we're looking 8 for is the least uncertainty on the measurement of 9 making this projection forward 20 years that's also 10 rational.
And it's your judgment.11 So you understand, we still have this 12 uncertainty.
We're not negating the finding from 13 1991, but you're asking us to take that and now move 14 it forward, and all Hans is saying is, actually no new 15 positive measure which now we're not arguing 16 calculations or philosophy, there is no new positive 17 measure in-this area of potential.
We're not saying 18 it is a high area, but there is a potential, normal 19 industry practices grind down welds and make them 20 smooth. We're also not disagreeing with that.21 But it seems that you need to understand 22 our concern is, in just looking at the physical 23 arrangement, this is an area of potentially higher 24 corrosion, and we're asking why is your current sample 25 set still representative of that area?26 If the explanation is, we were 1,000 27 percent sure that this was ground down, and that there 28 are no crevices or anything in that grinding that 29 could catch water, that's one way of doing it.30 There are two approaches to everything.
31 MR. GALLAGHER:
And I think what you're 32 saying, Frank, is that some of these areas that helps 33 to narrow the uncertainty.
So I think we -NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433..* ° 47 1 MR. GILLESPIE:
Remember, we're trying to 2 be as clear as possible to you.3 MR. ASHAR: In the pocket region of the 4 drywell shell, the most susceptible bays are 5 incorporated in the sampling, the present sampling is 6 fine.7 However, there are a number of issues that 8 need to be addressed to ensure that readings are taken 9 at whatever locations, and techniques used are 10 reliable.11 It is not clear if the junction between 12 the 1.154 inch plate and the .676 inch plate, which I 13 think I had explained to Ahmed when I was there in 14 audit on April 28th.15 : That area -we do have a concern in that 16 area. Because you took out the sand from the sand 17 pocket area, before you put the ceiling in the 18 junction between the steel and the concrete, quite a 19 bit of amount of water might have seeped through in 20 those areas, and might have caused corrosion in those 21 areas.22 And the way we are writing is, we'd prefer 23 that you try to find out some technique to measure the 24 thicknesses in those areas and alleviate any doubt 25 about there is no corrosion.
Or if there is 26 corrosion, then you know about it, how much it is. Or 27 justify why this area should not be included in the 28 sand pocket areas.29 You understand what junction I'm talking 30 about?31 MR. GILLESPIE:
Let me give you a little 32 more amplification on this, because Oyster Creek is 33 not alone on this. We had an ACRS meeting yesterday NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 48 1 where this area between the concrete steel concrete 2 sandwich, in there, were addressed.
3 And as best I understand it right now, 4 there really is likely -while we have some research 5 going on in this area, and a research letter from Oak 6 Ridge available, this is not an area where I think -7 and I think we recognize this -that there is a lot of 8 commercial activity.
It's accurately being able to 9 measure through concrete, through steel, and into 10 concrete in that environment, without chipping 11 concrete out, and we have to be, at ACRS, talking to 12 a licensee that actually chipped concrete out 13 yesterday.
14 But some of the discussion went on, with 15 ACRS. And again Hans' second comment was, provide us 16 at least with a rationale that is coherent and makes 17 sense. .And some of the points that ACRS raised in 18 challenging.
the staff on our interim staff guidance, 19 where we had to kind of make a rationale for such 1 20 aspects of the fact that the inside containment 21 temperature is like 130 degrees. And therefore it's 22 going to drive moisture out. The lack of oxygen in 23 the area.24 Once it's been sealed, the initial 25 oxidation is going to consume the available free 26 oxygen, and therefore, there is some severe 27 limitations on corrosion.
28 These are the kinds of things we discussed 29 with ACRS in a broad sense of applicability of how 30 we'd see an applicant trying to address the rationale 31 portion of this, if chipping up the concrete was 32 really not rational.33 That explanation I don't believe was in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 49 1 the RAIs or the application.
You have to make it for 2 us. I know what we did as staff to help support our 3 interim staff guidance on why it wasn't more demanding 4 if you would in this area. And these are the kinds of 5 things that were going through our mind. And I want 6 you go away understanding that that's the same thing 7 that was on the record at the ACRS meeting was the 8 kind of rationale the staff had in mind as to why this 9 actually should be. And looking at the chemistry of 10 it, an area of fairly low concern.11 But you have to tell us why for your plant 12 it's a fairly low concern with your operating 13 history. And so then there's timing elements about 14 when the seal went on, when various leakages might 15 have occurred, when water could have accumulated, 16 groundwater levels, and the ACRS asked about, what 17 about concrete, it's porous, it contains water. Then 18 an ACRS member said, yeah, but there is no oxygen-19 left.20 So it's that rationale, or advanced 21 measurement techniques that might or might not be 22 available.
That's not my area; I don't know. As you 23 know we have an Oakridge report, and I think we've 24 already supplied you with our ADAMS number.25 MR. ASHAR: ADAMS number.26 MR. GALLAGHER:
Do we have that report?27 MR. GILLESPIE:
But let me be careful, I do 28 have to be rational, we're not asking you to be in 29 advance of the state of the art of applicable 30 commercial techniques, and again, in RAIs I couldn't 31 say that, but we're trying to keep this in context.32 But we do need a signed understanding from you, in 33 your words, as to why this should be a low susceptible NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 50 1 area.2 And that's your choice on how to do that, 3 and we've supplied you with the one letter report, and 4 since it's a letter report on a NUREG, that tells you 5 right there, it's very advanced information.
6 And so you have to digest the information.
7 Just understand our concern, and the rationale we're 8 looking for.9 Does that make sense?10 MR. OUAOU: I understand.
This is Ahmed 11 with Exelon. We understand the question.12 We did not provide all that detail you're 13 talking about in the application.
We specifically 14 used a NUREG-1001 as a basis why that area is not 15 susceptible to accelerated corrosion.
16 Basically the idea is, if it's embedded in 17 the concrete, you don't have an adverse environment, 18 chloridesand sulfates, you should not -you know, you 19 have an alkaline environment that is not conducive to 20 corrosion of the shell.21 And all those items that you mentioned 22 contribute to why that area is not -23 MR. GALLAGHER:
So we did not provide 24 that.25 MR. OUAOU: We have.26 MR. GALLAGHER:
Where is that, in the 27 application?
28 MR. OUAOU: It's in the application; it's 29 in the questions, Q&A. We did not provide, we did not 30 state that it's totally sealed; the oxygen is limited.31 We didn't get into that detail.32 MR. GILLESPIE:
Yes, and again we didn't 33 ask for it. Again, we're at a level of detail, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 51 1 because you did supply us a lot of information in the 2 RAIs, we're really now fine tuning and focusing in on 3 these real specifics.
4 MR. ASHAR: We did mention about the 5 inaccessible areas, and we did provide certain 6 guidance to if the concrete is like this or that.7 Then you may not have to do much in that area. But 8 Oyster Creek is a little different animal here, 9 because it has a history of contaminated water going 10 into the sanbed area. It might have seeped through in 11 the area with the thinnest part of the steel is there.12 Though it is bearing on concrete, still, it is very 13 thin. And if it is rusting, there are problems with 14 it, and with the analysis, too.15 MR. GALLAGHER:
And as far as the 16 techniques for looking at this, we had looked into 17 that, and we hadn't really found anything.18 Did you see anything, Hans?19 MR. ASHAR: Yeah, in this Oak Ridge report 20 that Frank talked about does have three separate 21 matters came in. Each will have a different 22 applicability.
I don't know which is more suitable.23 I cannot recommend to you that.24 But there is a potential for use of one of 25 those methods. We requested Research to have Oak 26 Ridge National Laboratory conduct a study. They are 27 state of the art kind of report. They give a contract 28 with three separate independent people to develop some 29 kind of techniques to have the metal thickness results 30 being given when the metal is embedded in concrete on 31 both sides; that was the main purpose of it.32 So there is some applicable review.33 MR. GALLAGHER:
And we have that Oak Ridge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 52 1 report?2 MR. OUAOU: We have the -John you have 3 the -yeah, right.4 MR. GILLESPIE:
But again, I really went 5 out of my way to try to keep that in perspective.
6 MR. GALLAGHER:
Right, so we'll take a look 7 at it.8 MR. GILLESPIE:
Sometimes people say, the 9 NRC asked me a question, and that' s telling them to do 10 something.
I'm not. I'm asking, just reevaluate the 11 data. I'm not insisting on people to do the 12 impossible.
But it's the rationale and the details 13 underlying it. You didn't give it to us; we didn't 14 ask for it. And that's why we're here saying, this is 15 that little piece that's missing under here.16 :...... And as we told ACRS yesterday, although we 17 kind of have a generic position, our generic position 18 is really applicable'to facilities that have had no 19 history at all of leakage. And then you step off from 20 that, and when we reviewed Brown's Ferry, they were a 21 little different.
You were a little different.
Your 22 operating histories are slightly different.
23 And so the generic applicability strictly 24 of the new reg what we're saying is, there is some 25 customization you have to do specific to your 26 operating history.27 MR. GALLAGHER:
Okay.28 MR. GILLESPIE:
Ready for the next one?29 MR. GALLAGHER:
Yes.30 MR. GILLESPIE:
Okay.31 INSPECTION INCREMENTS WITH UT COMMITMENT 32 Sanbed region inspection increments 33 associated with UT commitment in letter dated April NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 53 1 4th, 2006, page 3, item two.2 This -actually I'm going to get your 3 commitment
-don't throw it out. It was a good 4 commitment.
Let me try to articulate this one.5 And our thinking is, we're trying to be 6 very consistent with the previous thinking back in the 7 '80s. And also with concepts that we kind of have in 8 the maintenance rule and other things. And the idea 9 is, the intent here is to bring all of this technical 10 information that was developed in the early '90s 11 forward, and essentially revalidate for today.12 I do understand, in the press clippings, 13 although I don't think you've written it to us, that 14 you were going to do some measurements in 2006.15 I read that in the paper. But we probably 16 would -it would be beneficial to have that on the 17 record. And I assume that's your commitment actually 18 to do it, that that's the one you're going to do prior 19 to entering the period.20 MR. GALLAGHER:,That's correct.21 MR. GILLESPIE:
Well, I'm making that leap 22 of faith assumption.
So the measurement you are going 23 to do prior to entering the period is really the first 24 measurement that's been done since 1996, and there's 25 been a significant amount of history since 1996.26 And I'm going to simplify this down to my 27 kind of thinking.
It takes two points to have a line 28 in order to have a slope. And there's been some 29 operating history between '96 and now that one point 30 validates to some degree I'm going to say current 31 thickness for the last 15 years.32 But then you're asking in your commitment 33 to jump to not do anything for 10 years, okay. Now NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 54 1 I'm going to invoke the concept that we have in the 2 maintenance rule, which is kind of more of an OR gate 3 (phonetic) if you would for any measurement which 4 says, if we do the measurement in '06, and we see some 5 level of degradation which is inconsistent with what 6 you would have predicted, then you're going to do 7 something.
8 Then if I go to the maintenance rule, it 9 says, I'm going to increase my surveillance frequency.
10 And then if you increase your surveillance 11 frequency and see with the second measurement that 12 it's stable, then you decrease your surveillance 13 frequency.
14 What we'd ask is it's -there is no 15 criteria for what happens, what you're going to find 16 in '06. It still leads in our mind to a degree of 17 uncertainty.
And we'd like to.ask consideration in 18 terms of what's the basis for 10 years? If you say 19 you're going to do something in '06, and if that's 20 part of some criteria, then we're going to do 21 something within four years after that again.22 Now you are really consistent with our 23 previous judgments from last time, in which you 24 committed to do several I think measurements I think 25 in a row at four-year intervals.
26 But then if you come up with a second 27 measurement, and it's better, then there should be an 28 opportunity to extend it past that.29 So what we're suggesting is, in our minds, 30 we're looking for some sense of commitment to what 31 happens, what's your criteria if you find something, 32 thinner, thicker. What happens if this measurement 33 comes out like the '96 measurement, and comes out as NEAL R, GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 55 1 growing more?2 Then there is a calibration issue I hope.3 And so what we're looking for is I'm going 4 to say a bit of a more disciplined reliability 5 approach to the sampling plan maybe as opposed to the 6 rigidity of 10 years.7 And there's a sense on our part right now 8 that given our current knowledge base, and the 9 uncertainties in operating history, the uncertainties 10 in the '96 measurement itself, which may not be -you 11 might not be able to do anything -it's 10 years ago.12 I'm just being realistic.
13 The coatings are getting older. Yet you 14 aren't going to do the inspections.
We're notý15 questioning your inspection regimes, your commitment, 16 that's very good, to do 100 percent in 30 years of 17 commitments.
But it is getting older, so there is 18 these degree of uncertainties that more progressive 19 sampling -the broad RAI- would be, what is the 20 justification for 10 years?21 Because 10 years is independent of what 22 you find in '06?23 MR. GALLAGHER:
I think one of the things 24 we tried to do, Frank, was, if you look at all those 25 commitments, they're kind of like an integrated 26 package, you know what I mean? Because the agent-27 management program is an integrated package on that.28 And I guess what we were trying to say and 29 maybe it didn't come across, we take the readings 30 before the end of the period and we did have some -31 and our expectation is that the corrosion has been 32 arrested, and has been arrested since 1996. So our 33 expectation is, we would have similar measurements.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 56 1 And then we said, we had the criterion, 2 and I think it was plus or minus 21 mils? And it was 3 based on the uncertainties of measuring and equipment.
4 And then if we were outside of that we 5 would notify the NRC within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />. And we made a 6 commitment to that effect. And that we would have 7 specific actions.8 And those specific actions relate to doing 9 the projection, increase the frequency of the testing, 10 and things like that.11 We didn't put the decision tree in there, 12 but that's our intent.13 MR. GILLESPIE:
Okay, and on this aspect -14 as I said, don't throw out the commitment.
The 15 commitment, it was a very good commitment.
16 Our question really is the decision tree, 17 and we've had this same discussion actually with Nine 18 Mile Island on could you give us the acceptance 19 criteria.20 Because while you can assume that 21 everything will be correct, as the regulator, we 22 cannot assume everything will be correct.23 And so it's a decision tree that affects 24 inspection frequency.
You're reporting to us, all of 25 that was fine. What we're doing is, saying that the 26 specific commitment that says, we're going to do a 27 measurement before we hit the period, and then, 28 really, reading it word for word literal, the next 29 measure is at 10 years.30 We're absent that decision logic that you 31 have internally that would make perfect sense. And so 32 on the frequency thing, we're asking, could you give 33 us a relook at that in 10 years, and either NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o* o 57 1 rationalize why 10 years as an absolute is okay, or 2 provide the commitment of what your decision tree is, 3 relative to frequency of remeasuring versus which 4 goals.5 Again, you're assuming it won't. And 6 we're regulators, so we have to assume it will. And 7 we need to address both sides.8 And quite honestly, I think, in the 9 public's view, they need to have a certain assurance 10 that if this becomes a commitment, or whatever, within 11 the license itself as we reissue it, then it becomes 12 real solid, it's inspectable, and what I'm saying it 13 has all the bells and whistles on it that go with the 14 regulatory process.15 So we'd ask you to relook at the 10-year, 16 and you've just described an internal logic that is 17 not visible to people on the outside who read the 18 literal words of that commitment.
19 So the request is, could you look at the 20 commitment on the 10 years. Because we're reading it 21 like an absolute.
Yeah, you report to us, you'll do 22 all those things, but gee, they never said they'd go 23 in and remeasure.
24 MR. HUFNAGEL:
Frank, this is John Hufnagel 25 from Exelon. Just a clarification.
Because when I 26 was listening to you, I believe you may have said that 27 even if we went in and found essentially the same 28 result with the ultrasound testing, the 10-year 29 frequency may not be enough.30 So I think what Mike described was if we 31 would go in, we would find some degradation, we would 32 consider corrective actions including things such as 33 more frequent inspections.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 58 1 MR. GILLESPIE:
Okay, now we get to the 2 uncertainty issue on that. And that's why I can't 3 give you a specific answer. That's why I said it kind 4 of nebulously.
5 The uncertainty issue is, if you go in and 6 you do the measurements, and let me say you have the 7 same issues that you had in '96 that were kind of 8 inexplicable but why it grew, then 10 years is 9 probably too much.10 And so what I'm dealing with, and I can't 11 do it for you, I'm dealing with, there is an operating 12 history there. There are these uncertainties that in 13 fact you may be within -if it's an asymmetrical 21 14 mil objective, then you still have the same regulatory 15 question, well, it grew again. They don't have to do 16 anything.17 MR. GALLAGHER:
Right, and we would take 18 corrective action. So I guess maybe related to the 19 question John just asked, so I guess the corollary 20 would maybe be, if we were within that plus or minus 21 21 mils, is 10 years okay?22 MR. GILLESPIE:
There is no absolute on 10 23 years. Okay? That was what was in your application.
24 There is an uncertainty connected with these 25 measurements.
There is a specific uncertainty 26 demonstrated in measurements at Oyster Creek 27 specifically over time.28 If you really are trying to bring that 29 forward, you have to make the judgment, is once at the 30 beginning of the period, and doing a second one at 31 four years, and then not doing any more for 16 years, 32 is the right answer.33 Because remember, what you're trying to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 59 1 is take this calculation and all this body of 2 information from the '80s and '90s and reapply it to 3 a new 20-year period. And if you're going to do two 4 measurements, should that second commitment for all of 5 these questions actually be way out there at 10 years?6 Or if you're going to do two measurements anyway, 7 should it be at four years or six years? Because 8 that's giving us assurance on the projection of all 9 this body of data forward.10 And by the 10th year it's not really 11 contributing to the projection doing forward.12 And now I'm going to make a leap of faith 13 to a new topic -14 MR. GALLAGHER:
Before you go there, Frank?15 MR. GILLESPIE:
It'll make sense though if 16 you let me do it.17 MR. GALLAGHER:
All right.18 MR. GILLESPIE:
Because it'll make sense to 19 why I just said what I'm saying. In the interim staff 20 guidance there is an event aspect to it, which says, 21 if you ever see water, you have to go do a 22 measurement.
23 And so it's not mutually exclusive.
And 24 so if you're committed to two measurements on a 25 frequency that allows us to translate this body of 26 information forward for most of the period, we would 27 still ask you, you have not committed to the ISG 28 relative to that event aspect to it, which says, if 29 you see water, you have to measure again.30 And so I'm saying this measurement thing 31 is kind of an integral case. And if you're really 32 good and you never get a leak again, you've still only 33 done two measurements, but you're adding to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.°.o 60 1 principle of moving the body of knowledge forward.2 But if you ever see water again, you are 3 committed to a third measurement.
4 And so it's a package. I'm agreeing with 5 you; it's a package. And that's not in the 6 commitment.
And it's kind of the event based aspect 7 of that ISG which then says, you need to redo your 8 rate calculation and project it forward it forward if 9 you see moisture.10 And that's the package I wanted to get 11 out, because it's not like I'm -we've kind of done 12 something thinking on this, and what are we really 13 trying to achieve relative to the staff's approval of 14 your application, and we're trying to approve is that 15 projection forward for the next 20 years.16 We're not actually trying to specifically 17 find the thin spot at any given year; we're trying to 18 have enough comfort if you would or faith. And it's 19 faith in that calculation we're trying to get, not 20 just a random measurement at a 10-year point of a 21 vessel.22 So it depends on how you look at -what is 23 your objective of doing those measurements.
If the 24 objective is a random point in time, to make everyone 25 feel comfortable with something you've already 26 approved, the first thing is, get the piece already 27 approved.28 MR. GALLAGHER:
We'll definitely look at 29 that, Frank, because again, I think that was our 30 intent, outside this region, we would change the 31 frequency.
32 But one thing I just want to clarify 33 because even sometimes we fall into this trap, and we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 61 1 talk about the individual components of the aging 2 management program.3 Like people would say, hey, the last 4 management we took was '96, and that's a long time 5 ago. You know we have the advantage at Oyster Creek 6 where that area is accessible now, because we made 7 these modifications.
So we've had eyes on on the 8 coding ever since then, that the coding is put on in 9 '92.10 So that was our look, ongoing look, to 11 make sure that corrosion was arrested, and was gone.12 Except so we see that as a real good advantage for us, 13 because we have that area to be accessible.
14 So when you look at the package of UTs and 15 visuals, it's a pretty good one.16 MR. GILLESPIE:
But that's why I just -and 17 Hans, you can jump in, because I might say something 18 wrong here. But you notice coatings wasn't on our 19 list, and you're answer and your commitments in that 20 does reinforce what you just said.21 So again it reinforces if the codings are 22 being expected reasonably vigorously at one time 100 23 percent, and then it'll go to 30 each outage, that's 24 confirming the underlying assumption that moisture 25 isn't present and therefore corrosion doesn't occur, 26 which makes the usefulness of a 10-year out 27 measurement potentially less useful than one that 28 might be in more like a four-year duration that allows 29 us to do what we did in the '80s, to say, okay, you've 30 got enough information to project this forward, and 31 now depend on your commitment on the coatings 32 examination.
33 And so at least and I'm going to ask Hans, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 62 1 because I -and so there is a thought process there 2 that is different than just picking 10 years because 3 it's in the middle.4 Hans.5 MR. ASHAR: Yeah, I think programmatically, 6 I think the way you have committed to coating 7 inspections, if during the inspection of coatings, you 8 see seepage of water that you have seen earlier in 9 2004, 2006 time frames, then there is always a 10 question as to what is going on.11 And that's why what Frank is trying to 12 explain is that you've got to have a program based on 13 what you find rather than straightforward to 10 years.14 And I think Frank did describe it very 15 vividly, but I'm trying to simplify it. That's what 16 we are looking at here. Programmatically.
17 MR. GALLAGHER:
And I think that was our 18 intent, but we can clarify that.19 MR. GILLESPIE:
So the summary is, could 20 you relook at the purpose of the 10 years, and is the 21 10 years really serving the purpose of bringing this 22 data point forward so that we can make the same 23 decision now for the next 20 years we made before for 24 the last 20 years.25 MR. GALLAGHER:
You guys have some 26 questions?
27 MR. OUAOU: Well, the only thing I really 28 want to add -this is Ahmed with Exelon -is the UT 29 measurements we're using in the sanbed region is to 30 confirm that in fact corrosion is not undergone, which 31 is stated, it's arrested.32 But you've got to remember, on a forty-33 year basis, we're still doing UT measurements on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 63 1 upper region of the drywell, which is not coated, and 2 it really should bound the other areas.3 MR. GILLESPIE:
Again, you're making my 4 case why 10 years may be a random point that is just 5 out there that was picked because it's in the middle, 6 as opposed to being a point that in a real early part 7 of a period contributes to reinforcing the fact that 8 the body of knowledge in the inspection techniques for 9 both how you apply that corrosion rate you're finding 10 at the top which is uncoated, and how you look at the 11 coatings, is doing.12 All the reasons you're giving me are 13 reasons why you want to reinforce your technical bases 14 early as opposed to late. That's all I'm saying. I'm 15 just asking you to think about it.16 MR. OUAOU: The only thing I want to point 17 out is, the basis for .the 10 years we used for was 18 certainly not random. It's based on the ISI interval.19 MR. GILLESPIE:
Okay, the ISI period is 20 also 10 years.21 MR. OUAOU: That was the basis for it.22 MR. GILLESPIE:
We've actually had some 23 discussions with people that the whole ASME code 24 issue, which is not yours, is given us great pain in 25 aging management as you know with relief, because the 26 code is written to cycles, et cetera, et cetera, that 27 are really based on a 40-year life.28 And so we're, again, that may be the code, 29 but that is not -I'm trying to say, it could be a 30 technical rationale, other than it's convenient with 31 the code for doing it. And because of your answer and 32 commitments in the coatings, because of the 33 reinforcing measurements at the top in the uncoated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 64 1 areas, we're looking for as much definitive 2 information early in the period that there will be 3 success during the period as we can, relative to 4 projections.
5 And again, the kicker in here is, we'd be 6 looking at the event part of the ISG which then 7 applies to future -because you got a 16-year period 8 I just suggested in there. But the ISG would say, 9 if water shows up, you're doing UTs again. I mean 10 that's what the ISG says.11 But if you're real good and you never have 12 a leak, because of the inspections and the projections 13 and that, and then the validity of your projections 14 are doubly reinforced early in the period.15 So I'm asking you to look at the rationale 16 for the 10 years, andwhat I'm suggesting is, in light 17 of how we thought about the maintenance rule when we 18 were writing that, and what we were doing and what was 19 happening in the maintenance area. I'm applying those 20 same principles.
21 Remove the uncertainty early, and that 22 allows you to have a justification and a rationale for 23 the extension, and why a more minimal surveillance 24 program is unsatisfactory.
25 MR. GALLAGHER:
And Frank, do you have any 26 thought in mind for what an early interval would be?27 MR. GILLESPIE:
No. If you can rationalize 28 10 years as being early in providing the moving 29 forward into the entire period of that -30 MR. ASHAR: We'll look at it.31 MR. GILLESPIE:
-- we'll look at it. But 32 the uncertainties involved -and I will admit, this is 33 -there is some subjectivity to this. I mean this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 65 1 not an algorithm that we can put into a spreadsheet 2 and do a calculation on.3 But there are a numiber of uncertainties, 4 the residual ones we went over today, which we're 5 looking for clarity in. And I think what you as an 6 applicant are trying to do is reduce or minimize those 7 uncertainties to the degree possible for the maximum 8 period of operation.
9 And what we're suggesting is, 10 years 10 leaves a great deal of uncertainty in our minds 11 relative to the sample selections, and projecting this 12 vast body of data and this calculation forward.13 Again, we're dealing with taking a vast 14 amount of information which was reviewed now almost 15 15, 16 years ago, it was probably developed close to 16 18 years ago, and bringing that forward for a new 20-17 year period.18 .And yes, that was satisfactory for the 19 last 20 years of the license, but now we're making a 20 new finding that it's satisfactory for yet even 21 another 20 years.22 MR. GALLAGHER:
Okay, I think we understand 23 it. Okay.24 MR. GILLESPIE:
With that, I've got one 25 other issue, and this -to close out containment, and 26 to let people know that what we've talked about here 27 is only a small piece of the whole.28 And this has no action for you. But 29 actually in looking at the whole thing, we were really 30 trying to look holistically as a staff at the entire 31 containment structure.
And we did note that your last 32 appendix J integrated leak rate test was in 2000, 33 which means your next one is due in 2010, which is NEAL R.GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 66 1 really close to the beginning of the period.2 And while that is not a design test, there 3 are other things going on as part of our body of rules 4 that do affect the integral look that we take at 5 things like the containment shell.6 And so I didn't want people to think that 7 we only looked at what we talked about at this 8 meeting, which I'm hoping was very focused and quite 9 narrow to our residual concerns.10 But that we do see that kind of under the 11 rules you have to pick a date, 2008 or 2010 plus or 12 minus a year under 10 years, and that's probably 13 either one within six months of the renewal period.14 So there are other things going on to give 15 us increased assurance of the operability of the 16 shell. And-because this isn't just a meeting between 17 you and us, I want people -and this is an example of 18 other things that we're considering.
So we're not 19 just narrow people. We're not just looking at the 10 20 years and asking about that. We actually found some 21 really satisfactory things, and just in compliance 22 with the regular body of rules that was going on.23 And with that, I'm down to my topic called 24 general discussion, but Im' about worn out.25 GENERAL DISCUSSION 26 I would ask you and then I'll ask -or 27 perhaps I should ask Hans if he has anything else he 28 would like?29 MR. ASHAR: No, I don't think I have 30 anything more than what you described, no.31 MR. GILLESPIE:
I would like to ask you as 32 an applicant
-I mean we're trying to be real crisp 33 here, because we want to get on with the job.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 67 1 MR. GALLAGHER:
John, do you think we have 2 succinctly what the issues are we need to respond back 3 on would be?4 MR. HUFNAGEL:
I have a lot of notes, Mike.5 It would take me more than a couple of minutes to go 6 through these notes. So I'm not sure I can go and 7 summarize all that right now. But I think between us 8 I'm sure we have enough notes and understanding.
9 MR. GILLESPIE:
And we're going to do our 10 best, by the way, John, to get what Hans was reading.11 We went through a lot of effort to try to really 12 narrow this down. But we do have the audit process 13 you know kind of going on in parallel.
And we'll try 14 to get these meeting notes out in a timely way for us, 15 and timely for us, given our secretarial situation, 16 can be long.17 But in this case we're going to push this 18 to kind of the front of the list, and try to maybe -19 I need to get these notes in a public forum.20 And again, if there is a follow on email 21 needed to clarify the issue, that's fine.22 The other question that came up, because 23 normally we would have probably followed this meeting 24 with a formal set of RAIs. When I saw what Hans had 25 written in coordination with the bullets we wanted to 26 covered, the RAIs are really embedded in his detailed 27 words. And these, I think, are more -are better 28 words than we generally send in kind of our 29 whitewashed versions of RAIs that require phone calls 30 for clarity on. 1 31 So we will try to get the meeting notice, 32 the meeting minutes out, with basically Hans' comments 33 and the bullets, as quickly as possible.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 68 1 Now, if we do that, then my intention 2 would be not to issue a separate document of RAIs in 3 prep for your opportunity to come back and talk to us.4 And the other thing is, we'd like to ask 5 that you send something in in writing before that 6 meeting so that we can really be kind of at the end of 7 the road at that meeting. And the question I have of 8 you is, when we were setting this up, we scheduled it 9 so we could talk to you, and scheduled the next 10 meeting so you could talk to us. But that is actually 11 your option.12 If we don't need a meeting, and you'd 13 rather answer these in writing, I would just ask that 14 you get back to us in a timely enough way so that we 15 can cancel the meeting at least a week before.16 And it's really your option, but we were 17 trying to set this whole thing up to make sure that we 18 had all. the vehicles for communications.
And since 19 we have a 10-day noticing period for public meetings, 20 and it takes a couple of extra days -it really takes 21 about 15 days to do it -then we had to in a positive 22 way set up both meetings at once just to have a 23 process put in place.24 But it's your application and it's your 25 answers and it's your choice. So right now we do have 26 it scheduled.
Donnie was going to put a notice out, 27 but I would ask for the other people in the public who 28 might want to participate, a timely notification of 29 them is an obligation we have.30 And so let me leave that to you and not 31 even ask you to answer that question today. But you 32 can get back to us on how you want to do th at.33 MR. GALLAGHER:
I think what we're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 69 1 do, Frank, is we'll meet and go over what issues we 2 think we have. Maybe John and Donnie can communicate 3 to ensure that these are the things we're going to be 4 providing in a written format, and we would want to 5 get that to you a few days before the 22nd, and 6 whether we meet or not, we can determine that at a 7 later date. And talk with Donnie about that.8 MR. GILLESPIE:
I'll leave that to Donnie 9 and John, then, 10 MR. GALLAGHER:
And then so that would be 11 our -the things that we talked about providing, we 12 would provide that in writing; that's what you're 13 looking for.14 MR. GILLESPIE:
Hans and I are going to try 15 to get everything that we have in writing out as part 16 of the meeting minutes with Donnie. I think it's 17 going to be a more fruitful meeting if everyone, all 18 the participants, has it in black and white. And then 19 you leave that with either a markup or a nonmarkup, 20 and everyone knows where we stand on these issues.21 Because I think we've really narrowed some things down 22 here.23 MR. GALLAGHER:
That's what I was going to 24 say. Like the issues, like the thank you for getting 25 clear with us on what these issues are. Because I 26 think they are very pinpointed, and I think that will 27 help us really see what information you need to close 28 the issues.29 Like you said, we provided a ton of 30 information, and we have it down to just a handful 31 right now to really get you just the information you 32 need.33 MR. GILLESPIE:
By the way, we're not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 70 1 looking for another ton. We're really trying to see -2 if these answers end up coming in 57 pages long, then 3 we've miscommunicated what we think our residual 4 concern.5 MR. GALLAGHER:
Okay.6 MR. GILLESPIE:
So really, as you're doing 7 it, keep it in perspective.
And if that requires 8 calling Donnie, say, you know what, Frank said he 9 didn't expect the Encyclopedia Britannica for every 10 question.
We think these concerns are very focused.11 MR. GALLAGHER:
Right, right.12 MR. ASHLEY: In addition -this is Donnie 13 Ashley -in addition, John, to your notes and the rest 14 of our notes, we're going to try to get a quick 15 turnaround on the transcript so that you can have that 16 available to you as well. And we'll have that in 17 ADAMS just as quickly as we can.18 MR. GILLESPIE:
Final part of this meeting 19 I'll turn over to Donnie, and that's I believe 20 requests from any members of the public, or anyone 21 else, to ask questions
-22 MR. GALLAGHER:
Wait, Frank, did you have 23 a question?24 MR. HUFNAGEL:
Just a brief, if I may -25 John Hufnagel here -just a brief comment that it goes 26 without saying, but I'll be working with Donnie to try 27 to coordinate the next three weeks such that as he's 28 working on pulling together the notes from this 29 meeting, and we're working on providing the 30 information as we understand it, that there will 31 hopefully be a brief period where we can check what 32 we've done against the meeting notes prior to us 33 sending it in.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 71 1 So we'll obviously need to coordinate to 2 do that.3 MR. GILLESPIE:
That's why we're going to 4 do everything we can to get these notes out pretty 5 quickly for everybody whose participated in listening 6 in on the meeting.7 MR. HUFNAGEL:
Thank you.8 MR. GALLAGHER:
Thanks.9 MR. GILLESPIE:
And Donnie, now I think 10 it's time to ask -11 MR. ASHLEY: I would like to continue on 12 because we only have the phone for a short period of 13 time, and I don't want to lose the people that are on 14 the bridge.15 Can I go ahead, Frank?16 MR. GILLESPIE:.Go ahead..17 MR. ASHLEY: We've got a little bit of.18 housekeeping for the purposes of the transcript that 19 I need to take care of. I need to verify the spelling 20 of your names for the people who are on the telephone 21 bridge. And in particular order, Ron Zak with the New 22 Jersey DEP, would you spell your name for me, please?23 MR. ZAK: Z-a-k.24 MR. ASHLEY: Tom Quintenz from Oyster 25 Creek?26 MR. QUINTENZ:
Q-u-i-n-t-e-n-z.
27 MR. ASHLEY: Thank you.28 Nick Clunn with the Astbury Park Press, 29 would you spell your name please for the reporter?30 MR. CLUNN: C-l-u-n-n.
31 MR. ASHLEY: Thank you.32 Mr. Webster?33 MR. WEBSTER: Richard, R-i-c-h-a-r-d NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 72 1 Webster W-e-b-s-t-e-r.
2 MR. ASHLEY: And your organization, sir?3 MR. WEBSTER: Directors Environmental Law.4 MR. ASHLEY: Thank you.5 Mr. Brown, Jeff Brown?6 MR. BROWN: B-r-o-w-n.
7 MR. ASHLEY: And your organization, Mr.8 Brown?9 MR. BROWN: Is G-r-a-m-m-e-n.
10 MR. ASHLEY: Thank you.11 Ms. Gotsch?12 MS. GOTSCH: G-o-t-s-c-h, same 13 organization.
14 MR. ASHLEY: Thank you.15 Mr. Atherton?16 MR. ATHERTON:
A-t-h-e-r-t-o-n.
17 MR. ASHLEY: And you represent?
18 MR. ATHERTON:
I'm working with Jersey 19 Shore Nuclear Watch.20 MR. ASHLEY: Thank you, sir.21 Ms. Gbur.22 MS. GBUR: G-b-u-r, Jersey Shore Nuclear 23 Watch.24 MR. ASHLEY: Thank you.25 Mr. Warren?26 MR. WARREN: W-a-r-r-e-n, and I'm also with 27 Jersey Shore Nuclear Watch.28 MR. ASHLEY: Thank you very much.29 Is there anyone that came on the line that 30 I didn't mention your name?31 MR. LAIRD: Name is Jim L-a-i-r-d, Exelon.32 MR. ASHLEY: Thank you, Mr. Laird.33 MR. PINNEY: My name is Richard Pinney. P NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 73 1 as in Paul -i-n-n-e-y, New Jersey DED.2 MR. ASHLEY: Anyone else that we didn't 3 recognize?
4 In the interest of having an opportunity 5 for the people that are on the phone bridge, is there 6 anyone who would like to ask the staff a question, or 7 to make a statement at this time?8 MR. ATHERTON:
My name is Atherton.
I have 9 a technical background in technical and nuclear 10 engineering.
And the first complaint I have is, half 11 the conversation I heard was inaudible.
And I didn't 12 know whether it was bad technology in the electronics 13 that you have for transmitting this, or some other 14 cause. And I did phone the public affairs office to 15 complain about that, and I was hoping you got the 16 message.17 But toward the end of the conversation you 18 were slightly more audible. So I missed out on a lot.19 And I do have a couple of questions I'd like to ask or 20 get clarification for. Is that possible?21 MR. ASHLEY: Go ahead, Mr. Atherton.22 MR. ATHERTON:
I'm going to back up to the 23 specifics concerning the issue of uncertainty and 24 sensitivity analysis and the like.25 The basic question would be, is there the 26 potential, since I didn't catch all the information 27 that was taking place back and forth, is the potential 28 for harm to the shell or the liner significant enough 29 with the uncertainties involved so that it would be 30 better not to use uncertainty as a sole means of 31 analyzing the situation, but to approach it from the 32 worst case analysis perspective; and if so, why?33 MR. GILLESPIE:
Yeah, this is Frank NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.° 74 1 Gillespie.
2 MR. ATHERTON:
You're barely audible. I 3 heard the Frank.4 MR. GILLESPIE:
This is probably because 5 we're using 20-year-old technology for our phone 6 system here.7 MR. ATHERTON:
And how did you spell your 8 last name, sir?9 MR. GILLESPIE:
Gillespie, G-i-l-l-e-s-p-i-10 e.11 MR. ATHERTON:
Okay.12 MR. GILLESPIE:
The context of this meeting 13 was very incremental, in addition to a lot of 14 information that we've already gotten in the request 15 for additional information.
16 And in some ways, if you -have you read 17 all the additional information that's been sent in to 18 us that's been made available?
19 MR. ATHERTON:
Unfortunately I haven't had 20 the opportunity to do that yet. I just received a 21 disk a couple of days ago, and I haven't had the 22 opportunity to go through that yet.23 The general question concerned, I doubt 24 the information that I'm seeking is going to be on the 25 disk, because I'm questioning whether you should use 26 uncertainty analysis versus worst case analysis.27 MR. GILLESPIE:
Well, to some degree, I 28 think you'll find in the applicant's information, and 29 this is a little beyond the narrow scope of this 30 meeting, but in general, in the applicant's 31 information, there are discussions about measurements 32 taken in the upper portion of this light bulb shell, 33 which is uncoated, which presents a -any application NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o* ,
75 1 it would make a case, it presents a case that is far 2 less conservative than the bottom section of the shell 3 which is uncoated.4 And so there are some assumptions on rates 5 where projections are made where exactly what you're 6 saying I think has been taken into consideration.
7 Now what could be up for discussion is 8 different people's view of what worst case is. And 9 you have to go through the material and give me a 10 specific, but it's really kind of a blend of, we 11 basically have an estimate line, and the estimate 12 comes from various data sources that get combined to 13 make the estimate.14 And we're trying to have the highest 15 possible confidence in the estimate and the calculated 16 projections.
And the projections have been made; the 17 measurements have been made. And that's why the focus 18 of a lot of the discussion here was the residual 19 questions on the part of the staff to ensure that we 20 understand the uncertainties involved in that 21 projection.
22 But that projection involves some 23 assumptions on corrosion rates which some people would 24 say in their minds is worst case of the situation in 25 the environment of the facility.26 So I think both in different viewers, 27 different readers' views, have probably been done, and 28 we're wrestling with that total decision right now.29 So it's not uncertainty is everything or 30 nothing; it just happens to be our residual concern.31 (Telephone operator voice interrupts) 32 MR. ASHLEY: Mr. Atherton, are you still 33 with us?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 76 1 MR. GILLESPIE:
Anyway, for whoever was 2 listening.
3 MR. ASHLEY: Just a second, Frank? Is 4 anyone still on the line?5 (Loud telephone noise)6 MR. ASHLEY: They cut us off.7 MR. GILLESPIE:
We had inadequate safety 8 margin in our bridge.9 (Technical interruption) 10 MR. ASHLEY: We'll try to pick up Mr.11 Atherton as he comes back on.12 Did anyone else have a comment so we can 13 continue on?14 MR. ATHERTON:
Hello.15 MR. ASHLEY: Yes.16 MR. ATHERTON:
This is Peter Atherton.
I 17 don't want what happened.
But I suddenly got 18 disconnected during Mr. Gillespie's part.19 MR. ASHLEY: We did to. We're glad to have 20 you back again.21 MR. GILLESPIE:
Go ahead.22 MR. ATHERTON:
Well, Mr. Gillespie was 23 talking about the use of a version of the worst case 24 analysis for a bottom uncoated part of the containment 25 structure or the shell.26 MR. GILLESPIE:
The bottom part -27 MR. ATHERTON:
And that's where I lost you.28 MR. GILLESPIE:
The bottom part -and this 29 is difficult, because what we've got is a staff here 30 that's gone through literally thousands of pages of 31 documentation to come down to these residual comments.32 And in going through that there are 33 estimates made with corrosion rates that are believed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 77 1 by the applicant
-and this is a finding we're trying 2 to make -is believed by the applicant to be 3 reasonably conservative in nature.4 And there is a coating on the bottom 5 portion of this light bulb fixture containment, and 6 they have measurements from the top part of the 7 containment, which is uncoated, but in a similar 8 environment on the inaccessible side.9 And I believe the applicant has made some 10 projections using this, and then making the case that 11 the coating really provides this uncoated area 12 measurements are in essence a worst case in their 13 projection.
14 And therefore we've looked at that as a 15- staff, and all their information.
And this 16 information was really focusing on the uncertainties 17 that were connected to that projection.
18 It's not that we're.making judgments on 19 the uncertainties, but we're trying to make sure that 20 we have the soundest possible number and a good 21 understanding of what could be viewed by some as a 22 worst case projection.
23 Now others could view this projection and 24 the numbers used as not being the worst case, and so 25 I'm very hesitant to use the word, worst case.26 It's a projection that I think is 27 generally believed, actually representing a 28 measurement in an environment that is more harsh than 29 the environment it's being applied on to a carbon 30 steel piece of metal.31 And that's what's in the application.
And 32 so this meeting is trying to deal with making sure 33 that when we make whatever judgment we need to make, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 78 1 that we understand what the pluses and minuses 2 connected with that are.3 And so the staff has actually read the 4 application, and so we had that part done, and we 5 really weren't questioning the rate. We were 6 questioning the uncertainties around it to make sure 7 we could make an appropriate finding.8 MR. ASHLEY: Thanks a lot, Frank.9 Mr. Atherton, you still with us?10 MR. ATHERTON:
Yes, can anybody hear me?11 MR. ASHLEY: Yes, sir.12 MR. ATHERTON:
I'm having connection 13 problems.14 Let me back up just a little bit farther.15 On a very general or holistic view of the containment 16 structure, the plant was approved originally to last 17 40 years. That essentially meant back in those days, 18 the '60s and '70sa, that the major components of the 19 plant would not fail for a total of 40 years.20 We're seeing the drywell apparently 21 degrade prematurely which was not anticipated 40 years 22 ago.23 The projecting that type of discovery into 24 the future for 20 more years, how are we to know as 25 members of the public that you're going to have 20 26 good years left on the material that was supposed to 27 last 40 years and hasn't?28 MR. ASHLEY: Who's speaking?29 MR. ATHERTON:
My name is Atherton.30 MR. ASHLEY: Okay, go ahead.31 MR. GILLESPIE:
Well, that's exactly the 32 finding we're being asked to make as part of the 33 license renewal.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.o 79 1 And first I would refute your assertion 2 that every component in the plant was designed to last 3 40 years.4 In the basic underlying premise of 5 operation is a large number of surveillances, tests 6 and inspections.
And the intent is that the structure 7 and the license be safe for the term of the license, 8 and that includes special tests and analysis, which 9 would detect, prior to violating or causing a safety 10 issue, the degradation of components.
11 And what we're really talking about is 12 taking that same principle and pushing it forward 13 another 20 years. In fact, many of the components in 14 the plant have seen a less severe environment than 15 they were projected in their original design.16 And it's .that baseline and moving it 17 tforward, hat we're doing with renewal, which is why 18 there are extra -commitments in the overall renewal 19 effort to extra special tests and analysis.20 The intention is not to say it will last 21 20 years; that's an economic issue. It's to say that 22 the licensee has processes and procedures in place 23 that we can inspect and that they can follow that will 24 detect and remediate anything that would cross a 25 safety margin.26 And that's a different statement than 27 saying, we're saying it will last 20 years. In fact 28 if they would do a test and do a projection in 29 accordance with our interim staff guidance for the 30 renewal period, see water, and do an event test and 31 find out they were approaching minimum wall thickness, 32 they have to do an operability analysis under the 33 current requirements, which also project forward. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 80 1 they have a decision to make to either repair or shut 2 down.3 And instances of this we have in other 4 cases in pressurized thermal shock where we're 5 evaluating licenses for 20 years where the pressurized 6 thermal shock analysis for other licensees will not 7 make it to 20 years. But there is a requirement in 8 the rules that if you don't make it you shut down, or 9 you can replace your vessel.10 And so it's not saying everything will 11 last the period of the license; it's saying the plant 12 will operate safely for the period of the license, and 13 we have reasonable assurance of that.14 MR. ASHLEY: Thanks, Frank, I appreciate 15 that.16 Mr. Brown or Ms. Gotsch, do you have a 17 question or comment?18 Ms.. Gubr;, are you on the line? Did you 19 have a question or comment?20 MS. GUBR: I have a question.
In the 1996 21 inspection report --22 MR. GILLESPIE:
The 1996 inspection report?23 All the -- that's actually beyond the scope of this 24 meeting, and our general counsel is here. And I 25 understand that that is tied up in the litigation 26 issues right now.27 All of the NRC's information that we have 28 from 1996 in the NRC inspection reports are public 29 information.
The licensee's information, which the 30 NRC at this time does not and has not possessed, is 31 actually tied up in the litigation right now, and 32 we're really not in a position to comment on that.33 MR. ASHLEY: Go ahead, Mr. Webster.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* .
81 1 MR. WEBSTER: Okay, great.2 With regard to the drywell liner and the 3 UT measurements, I guess I'm somewhat surprised that 4 the licensee had already known that the '96 results 5 weren't good, but nonetheless based predictions 6 forward on those '96 results. It seems to me, though, 7 that the QAQC for those results should have identified 8 the level a long time ago, so I'd just like a 9 clarification of why the rejecting wasn't treated 10 closer to the time.11 MR. GILLESPIE:
This is Frank Gillespie 12 with the NRC. And since this is really an opportunity 13 for people to ask the NRC for clarification on what we 14 said, I will answer from the NRC's perspective that 15 right now the. people sitting in this room were 16 generally not involved in the details of what happened 17 in 1996. -18 But in looking at that anomaly, I think it 19 would be unfair to say that that was -I forget what 20 your word was -but I'll use an irrelevant 21 measurement.
It was a measurement, as we heard from 22 the licensee at this meeting, they looked into it and 23 examined it. They saw it as anomalous.
But there was 24 really no reason probably at the time to either 25 exclude it or not include it.26 MR. WEBSTER: There were three measurements 27 taken, and that '96 result was one of those three. If 28 you take that '96 result out of the analysis the 29 uncertainties become huge.30 MR. GILLESPIE:
And what I'm going to 31 suggest is, that's the exact question that staff has 32 just asked the licensee on uncertainties.
33 MR. WEBSTER: Absolutely, that's why I --NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 82 1 MR. GILLESPIE:
And so I'm just saying, I'm 2 not in a position, and I'm not trying to put anyone in 3 a position to defend what was done over 10 years ago.4 But because of the anomalous look at the results, 5 we're really focusing on removing that uncertainty 6 that we specifically pointed out as we project 7 forward.8 So we fundamentally have just asked the 9 licensee to respond to that question.
And we've, by 10 design at this meeting, asked the licensee not to feel 11 obligated to respond today to the staff's concerns.12 So I guess we're in agreement.
13 One of our concerns you heard from Hans 14 Ashar and I were on the calibration techniques.
And 15 I think the licensee responded, they recognize that 16 there are certain-coatings and stuff that they have to 17 reallyobe very careful of when they're doing these, 18 and so we have to see what they answer.19 You're asking for the answer we've asked 20 for, and it's just not the right time for the answer 21 yet.22 MR. WEBSTER: Now the second issue that I 23 think also relates to the questions you're asking is 24 about how the actual raw measurements get 25 incorporated.
One of our concerns is that the 26 uncertainties in these measurements become hidden in 27 the way they're presented, because you take the 28 measurements, get an average and put into one 29 measurement, which is then put on a scatter graph.30 And then when you look at the scatter graph you don't 31 actually see the underlying uncertainty.
All you see 32 is some scatter of averages, which is much less than 33 the actual scatter and the underlying results.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 83 1 Now one of the concerns I have, and we've 2 reviewed these documents from the licensee, and it 3 seems that they're editing the data, that they omit.4 They actually omit an outlier from the analysis.
And 5 again I think this is another way where the 6 uncertainty is made to appear lower than it really is.7 MR. GILLESPIE:
Let me try to answer that.8 Now this is going to be dangerous.
Because I was an 9 engineer 35 years ago, but I'm going to -Hans has 10 been training me for three weeks, Hans Ashar, who is 11 our expert. So let me take a shot at the answer.12 One, you have to understand, we've 13 basically asked the same question that we need to have 14 a good understanding about how that lower level 15 combination of numbers-was done.16 That was a concern we had, and that's a 17 question we asked.18 Two, you also have to differentiate; 19 there's two phenomena of interest here. One is 20 pressure during an accident, and the other is 21 buckling.22 And the interest in the buckling sense, 23 which is really the sandbed region interest, is 24 buckling down at the lower level, is one of general 25 area corrosion, a very broad degradation, and not one 26 of pitting.27 In fact in any structural member you can 28 actually drill holes in it, and you do not 29 significantly reduce its structural strength.30 And so knowing that principle I would not 31 want to draw a conclusion on information we don't 32 know. And that's why we've asked for information on 33 how they've done the statistical combination; what was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 84 1 their basis for whatever, throwing out outliers, in a 2 95 percent confidence interval.3 But for the purposes of buckling, a 4 localized thinning spot is not a principal concern.5 MR. WEBSTER: Well, I told you, I 6 understand that. But my point is that if you permit 7 that as part of the uncertainty analysis, then you 8 tend to regard the measurement
--9 MR. GILLESPIE:
Again, I don't know how 10 they've been included or how they've been admitted, or 11 has it followed standard practice.
We've asked that 12 question, and I hope within the next month we'll have 13 a little more amplifying information, and I could give 14 you a more satisfactory answer.15 We're sharing the same concern.16 MR. WEBSTER: Absolutely.
I understand.
17 I'm very pleased to see that we do share the same 18 question.19 My present issue 20 MR. .ASHLEY: Mr. Webster, this is Donnie 21 Ashley. You said you had two.22 Hold the third one, and let me get 23 through, make sure we can touch base with everyone.24 If we have time we'll come back to you. I have some 25 uncertainty about all four here.26 Let me leave this -27 MR. GILLESPIE:
Just in case we get cut off 28 from everybody, email Donnie Ashley and we will get 29 back to you by email on any questions that we don't 30 get to, because our phone system doesn't seem to be 31 working as good as I'd like it to.32 MR. ASHLEY: Thanks, Frank.33 Mr. Clunn from the Astbury Park Press, do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o* o 85 1 you have any questions or comments?
Nick Clunn? I 2 guess we lost him a few minutes ago.3 Ronzak (phonetic) or Ridgepenny (phonetic) 4 with New Jersey DEP, any questions or comments from 5 you?6 MR. PINNEY: No, we have no questions 7 here.8 MR. ASHLEY: Okay. Dennis Zannoni, would 9 you like to come down to the podium? I would like for 10 you to go ahead so they can hear your comments as 11 well.12 Mr. Warner, if you'd wait just one second.13 MR. ZANNONI: Dennis Zannoni, Z-a-n-n-o-n-14 I.15 I',d also like to thank the Nuclear 16 Regulatory Commission for having this meeting. I 17 think it's obviously necessary.
18 i So having the next meeting if it's 19 conducted~in the afternoon would also help me, since 20 I have to drive up, since we're facing a very 21 substantial budget deficit in New Jersey as you 22 probably heard.23 First, I want to mention that -and this 24 is mostly for Frank's edification, because he is 25 coming to our office I guess within two weeks with 26 some of his staff, to give you a little bit of the 27 flavor of what we're going to talk about, and it does 28 relate to what we're covering here, and that is, there 29 is a little bit of confusion on the ruling made by 30 ASLB and its staff's attorneys, and it's mostly a 31 question directed at the attorney, that we would like 32 the NRC to clear up the fact that we are not a party 33 or involved with the contention on the liner or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433.° 86 1 drywell shell in any way.2 And I guess ASLB made that clear, but some 3 kind of communication has come down the path, and it' s 4 affecting our ability to do work, that we're somehow 5 tied up with that.6 It would be nice if you could clarify that 7 here today, but I know you're not.8 We're going to pick that up when we talk 9 too, because it is affecting what we're doing. We go 10 to meetings, and people are confused about what our 11 role is.12 We do have three appeals to the 13 Commission, but they have nothing to do with the 14 liner.15 -And we have a good reason for that, 16 because we have our own staff that have made their own 17 conclusions, and I have to tell you, quite frankly, I 18 was at a meeting here discussing the same drywell line 19- issue when the company was going for a conversion from 20 the full term operating license to the -or from the 21 provisional operating license to the full term 22 operating license, and it was only at the insistence 23 of New Jersey that they took very aggressive 24 protective corrective actions. I don't know if even 25 anybody here at the AmerGen table was here. But 26 removing the sand and all of that was very, very 27 positive, and we view that in a way that we thought at 28 the time was good for until April, 2009.29 So our position right now, and Ron is 30 online, and he's our expert actually on the drywell 31 shell -he keeps telling me to call it a shell, not a 32 liner -is right now positive.
And the rigor that I 33 see addressed here for that one issue, I wonder if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o* o 87 1 that's going to spill into many, many other issues 2 that we feel an equal amount of rigor is needed.3 Because you guys are going into some depth 4 here that we are going to talk about again to see if 5 it applies in maybe some other areas that could 6 benefit from that, more so than the liner.7 Anyway, that said, we also need to have 8 some kind of -we don't know when the commission is 9 bound. If not, I understand it's not to make 10 decisions on the appeals that we submitted.
Again, it 11 has bearing, because the more they wait, the less we 12 can interact with NRC staff on those specific issues.13 And if they made a decision one way or the 14 other, then we could get on with it. So we'll 15 probablyzsubmit that in writing, but I'm just giving 16 youa, flavor of some of the topics that we're going to 17 talk about.18 Now specific to this meeting. Frank, you 19 said earlier in the meeting you said you may -the NRC 20 may recalculate something.
And then later you said 21 they will recalculate something.
22 I just need to know, you are going to 23 recalculate something.
What are you going to 24 recalculate?
25 MR. GILLESPIE:
Our intention right now is 26 to do a comparative calculation to the GE calculation 27 of 1991.28 MR. ZANNONI: The one with the disclaimer?
29 MR. GILLESPIE:
The one with -well, that 30 was a piece of it. That report fed into the data that 31 went into that calculation, and our intention would be 32 to do kind of a comparative calculation.
33 Ours doesn't need to be as rigorous as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 88 1 theirs, because we're doing it as a confirmatory 2 measure, not as a decision tool on their part. So 3 we're likely going to do that to get a perspective 4 ourselves on the conservatisms that have been assumed 5 in that calculation.
6 And so it's just an independent look. And 7 we do this in thermal hydraulics.
We do it in a 8 seismic area. We do it in a lot of different areas 9 occasionally.
10 The other piece is, we have six more Mark-11 Is coming in, and so for the renewal group, we're kind 12 of setting a precedent.
Because all of those same 13 questions exist on all of those same containments.
14 And so part of this calculation will be 15 giving us knowledge to a specific operating history 16 and a specific calculation that GE did.17 MR. ZANNONI: Is it going to be done in 18 house or contracted?
19 1 MR. GILLESPIE:
Part of this meeting is not 20 discussing how the NRC will do this piece of the 21 review.22 MR. ZANNONI: I'll ask it at some point in 23 the future. It tells what kind of depth you're going 24 to do which is pretty -if it's in house it's one 25 thing -26 MR. GILLESPIE:
Well, we're going to have 27 outside experts helping us. And any report that's 28 done will be public.29 MR. ZANNONI: You mentioned, I guess for my 30 own information and information concerning New Jersey, 31 are there other -the rigor that you -the depth and 32 the rigor that I send that you're requesting from 33 AmerGen for Oyster Creek, have there been other plants NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 89 1 that have similar drywells gone through similar rigor?2 Or is this something new that you are going to ask 3 plants to take a closer look at that have already 4 gotten license renewal?5 MR. GILLESPIE:
There's two questions.
The 6 answer is yes, everyone else is going through a 7 virtually similar process. But everyone has different 8 operating histories.
9 I'll give you a specific one. We're going 10 to ACRS, Nine Mile Point. Nine Mile Point has an 11 operating history with no visual leakage. They also 12 have welds around their seals. And so seals, for 13 example, at bellows, are not an issue.14 They have actual electronic alarm systems 15 ýon their drains. They actually have a float alarm on 16 -there is a ledge in there that goes under the seal.17 And they put bore scopes up there and looked in with 18 .TV cameras and saw dust.19 And so it's a form of rigor, but it's a 20 different operating situation, and a slightly 21 different design. So I would suggest that in essence 22 all the licensees with this kind of containment are 23 going through the same process, and the same level of 24 detail, and trying to be just as certain about their 25 projections, and the projections being used there, 26 they're taking them from the torus at the water level 27 where they do UTs, and it's a very aggressive area.28 MR. ZANNONI: Plants that have already been 29 approved?30 MR. GILLESPIE:
No, this one is in house.31 Brown's Ferry we did a similar rigorous review. And 32 they had some unknown leakages, and they committed to 33 an inspection regime. And theirs was the 10-year kind NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 90 1 of one. And that's through, and that license has been 2 issued.3 Brunswick does not have a shell; it has a 4 liner. And the design difference there is, the 5 structural elements, the concrete, is not the steel;6 the steel is basically a seal.7 And so the answer is yes. Now the 8 difference here is, the visibility of Oyster Creek is 9 different than the others. And so a lot of what we do 10 with these other facilities is closer -you know what 11 I mean -- it's not quite as visible.12 So every one is going through, you could 13 say, an equal type of review, customized to their 14 operating history, the operating conditions and the 15 past events.16 MR. ZANNONI: I know Donnie is going to cut 17 me off. But just one last comment for the public 18 that's listening, I know Peter Atherton did mention 19 about confidence that the public is looking for, not 20 only in this issue but all of license renewal.21 I'll just throw out, and I always mention 22 this, that in addition to AmerGen's huge workload to 23 meet all the requirements
-they got the NRC looking 24 at it -we also as a state have a group of about 15 to 25 20 professionals, I already mentioned that we have a 26 very sound expert in structural stuff on staff who has 27 worked with Oyster Creek for awhile. And this hearing 28 if anything comes out of it, hopefully it will be 29 positive.30 So the net result here, and I don't want 31 anybody to miss this, and it's too bad the press 32 wasn't here, is that this is getting a lot of eyes and 33 a lot of attention.
So that has to give the public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON.
D.C. 20005-3701 (202) 234-4433* o F 91 1 some sense of, they're not alone in this process.2 So that's why I exist just to put it 3 bluntly, so thanks.4 MR. ASHLEY: Thank you, Mr. Zannoni.5 MR. ASHAR: This is Hans ASHAR, NRC.6 Let me say that for the general analysis 7 purpose, the applicant has taken an approach where 8 they are taking an average, but in addition to that, 9 they also do the discontinuity analysis for the thin 10 areas. Thin areas are where there are small sparks 11 which might have been missed in averaging they might 12 have counted as thin areas, but they have taken a 13 number of places which are thin, and they have 14 analyzed separately to understand the discontinuity 15 stresses and their ability to withstand the loads 16 they're supposed to withstand.
17 MR. GILLESPIE:
Okay, this is Frank 18 Gillespie. .Let me amplify a little more. Because now 19 I'm going to take what Hans just said and say, that's 20 also part of the actual sample of the smaller area 21 that's scanned.22 This is a very, very, very large vessel, 23 and the representative nature of the sample that was 24 earlier worked on with literally thousands of 25 measurement points by the applicant to ensure that 26 even those areas that are scanned, and the 49 points 27 that are averaged, are the right areas to be scanned.28 And that's why we did ask an additional 29 question here to reconfirm right now the 30 representative nature of those areas, exactly so you 31 couldn't get a substantial elongation or a major flaw.32 So there's two things. One is the 49 33 points, which is a smaller, very small area, and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* ° 92 1 other is the location of those small areas through the 2 vessel itself.3 And if you would look at the much earlier 4 data of all the thousands of points that were done and 5 reviewed by the NRC, it's that representative nature 6 that actually covers your large perforation kind of 7 question.
It's not the 49 measurement points which 8 were averaged, for maybe a 6 by 6 inch kind of area.9 MR. ASHLEY: Thanks, Frank.10 In closing I appreciate everyone's 11 participation.
I appreciate
-- I'm sorry, we're going 12 to be out of time, and the phone is going to shut you 13 off in about two minutes.14 But we do appreciate everyone's coming out 15 to participate in this meeting. :And again, if you 16 need additional information, or if you have questions, 17 send me email. My email address is on the website.18 And once again, thanks to everyone, and 19 we'll adjourn-at this point.20 MR. GILLESPIE:
Thank you.21 (Whereupon at 11:58 p.m. the 22 proceeding the above-entitled matter went off the 23 record to return on the record at 11:58 a.m.)24 MR. GUNTER: That's all right. This is 25 Paul Gunter, G-u-n-t-e-r.
26 I'm with Nuclear Information Resource 27 Service.28 There's a whole lot of questions, and I'm 29 sorry that Richard Wester wasn't able to complete, but 30 we'll go ahead and supplement the record by email.31 And I guess that could be incorporated into the 32 transcript as well? Can we have email questions 33 incorporated into the transcript?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 93 1 MR. ASHLEY: I don't think we can have 2 email questions in the transcript.
But we can include 3 it in the summary. We'll put it in the meeting 4 summary.5 MR. GUNTER: Okay, that's fine, that's fair 6 enough.7 MR. GILLESPIE:
And our meeting summaries 8 are all put on our website.9 MR. GUNTER: You know for the sake of time 10 I'm just going to ask one question here, and it gels 11 back earlier to a comment that Frank made with regard 12 to the 1990 GE report, and the assumptions that went 13 into the corrosion and degradation.
14 I thought I heard you say that the NRC has 15 -they've identified a degradation uncertainties 16 within that GE report. Was that correct? Was I 17 correct in hearing that?18 , And I think that was the basis of your 19 going back and doing the recalculations; right?20 So I'm asking first of all for 21 clarification on what you've identified in the GE 22 report that raised degradation uncertainties.
And if 23 you could identify those for us right now.24 MR. GILLESPIE:
Okay, I'm not sure how much 25 detail Hans is in a position to go into. It was an 26 accumulation fo fundamentally the underlying 27 assumptions that went into it. And they appear to be 28 conservative, but one of the only ways to test the 29 overall conservatism of the assumptions is just to do 30 a calculation with an independent person making an 31 independent view of it.32 But Hans, you did that?33 MR. ASHAR: Yes, if you heard us on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 94 1 first or second questions that we had for the 2 applicant, you might have heard that we requested the 3 applicant to at least clarify as to what has been said 4 in their statistical inference report that is attached 5 to the GE report by the way they interpreted the 6 measurements, and how they statistically put together, 7 both that particular report findings were used, or 8 some other metrics were used. That was our question 9 to .them before, and I'm looking for those answers.10 MR. GUNTER: Right. So it's not so much 11 that you're questioning the degradation mechanism 12 itself?13 MR. ASHAR: No.14 MR. GUNTER: So one of our concerns is 15 that, for example, I think it's been referenced here 16 a number of times that there was -in order for the 17 sandbed region. to be -for the UT to resume at the 18 sandbed, there was the event trigger for the presence 19 of water.20 But it's always been our concern that -21 there was I believe a '95 exemption that provides for 22 a 12-gallon-per-minute leak rate, and that constitutes 23 what we believe to be a significant event.24 So during the refueling outages, there is 25 this '95 exemption that provides, to reiterate, 12 26 gallons a minute leak rate.27 So it's been a question for us why we've 28 not seen this reevaluation with UT at the sandbed, and 29 more particularly for the embedded region, so I think 30 it's been raised here this morning that there needs to 31 be a closer look at a number of areas for the 32 reevaluation with UT. Crevice corrosion should be one 33 of these areas, we believe. And I don't know what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433* o 95 1 level of confidence we have on the seals around -2 between the steel liner and the concrete.
But I think 3 that it's reasonable that we shouldn't be relying upon 4 -that these seals are necessarily going to be high 5 confidence seals.6 So as you are looking at the ledges that 7 were raised here today, we would strongly advise that 8 the UTs be resumed at the levels below the sandbed 9 region.10 Hans, do you think that that is a 11 reasonable request?12 MR. ASHAR: Well, because this area is not 13 accessible from any side, there is a state of the art, 14 which is not being used by so many people. And we 15 recommended its use if they can do that.16 So we are trying to understand from them 17 :-what they are going to do to gain the confidence that 18 that area is being considered in a sample size.19 MR. GILLESPIE:
I'd also like to say, we 20 have a broader level of operating experience than just 21 Oyster Creek. And so we do have some sense, and a 22 generic idea of -there are some licensees who 23 actually went in and chipped concrete up and did some 24 measurements.
Not all of them. They did that in a 25 response to the generic letter in 1987 we put out.26 The other element is, we do kind of have 27 an understanding of the environment.
But we need the 28 applicant to tell us what that environment is, and why 29 it's okay.30 They're going in and looking at the 31 coatings in those areas. Basically you've committed 32 to verifying those 100 percent, and a third, as you've 33 been doing each time, for the three bays each time, or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 96 1 something.
2 I don't know the details of that, and when 3 the little person goes in this gap and does this 4 inspection, whether they can eyeball the seals or not.5 MR. GUNTER: Again, I've not seen a 6 commitment to the seals.7 MR. GILLESPIE:
Okay. I'm going to leave 8 it to Hans, as the expert, to say whether we need a 9 commitment to that.10 The other thing is, at least in the prints 11 I saw, when we looked at the drain arrangement without 12 the sand, it looked like the low points is where the 13 drains were located in the sandbed area.14 So there are some actual physical 15 limitations on the accumulation it appears of water 16 that actually could accumulate by those seals.17 We're asking the licensee to come in and 18 put all.. of these things together in this integral 19 discussion of this area that is sandwiched with 20 concrete.21 It's more than just the chemistry that I 22 mentioned we talked to ACRS about. And so that's on 23 their plate to explain it.24 It may not be everything that someone else 25 may want, but we're charged with making an adequate 26 protection or reasonable assurance finding, and we do 27 have like I said other operating experience from other 28 plants, so we're not totally isolated here.29 Yes.30 MR. ZANNONI: I think someone in the room 31 knows the answer to this question, but is water an 32 intrusion on this vessel part of license renewal 33 space? I was told it wasn't. I mean it could leak, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 97 1 it could flow, but it doesn't have a basis in license 2 renewal space.3 MR. GILLESPIE:
Let me say it this way.4 MR. ZANNONI: I was told that it did.5 MR. GILLESPIE:
The component is large, the 6 component corrodes, and the component has a safety 7 function.8 That means the component is part of 9 license renewal and has to be addressed.
In fact that 10 means it has to have an aging management program.11 And if the water is allowed then the aging 12 management program has to be such that it ensures the 13 component's safety function will not be compromised 14 with the water there.15 And so the water leakage is not part of 16 renewal.17 But the environment, which is a high 18 corrosive environment that the water creates, is part 19 of license renewal. And so that's really why we're 20 talking. Because part of the general solution for 21 most licensees
-and I'll get off Oyster Creek now -22 most licensees are using is a combination fo coatings 23 -we just did Monticello with ACRS -they have a 24 primer coating on the external surface. So it's a 25 combination of coatings, leak control and leakage 26 monitoring.
27 Both leak control and leakage monitoring, 28 which put their seals in scope, because they said, 29 okay, part of our aging management program for this 30 environment is the seals, and we're not going to have 31 leakage in the seals, so we'll have highly reliable -32 and so no.33 But certainly the absence of water makes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 98 1 2 3 4 5 6 7 8 9 10 11 aging management far easier.MR. ZANNONI: That's a helpful clarification.
MR. GILLESPIE:
Thank you, Mr. Zannoni.Let me not make this mistake again. Is there anyone else who has a question or a comment in the room?Mr. Recorder, you can turn it off.(Whereupon at 12:08 p.m. the proceeding in the above-entitled matter was adjourned)
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433