ML062640268
| ML062640268 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/13/2006 |
| From: | Larkins J Advisory Committee on Reactor Safeguards |
| To: | Reyes L NRC/EDO |
| AYALA, JUAN, NRR/DLR/RLRA, 415-4063 | |
| Shared Package | |
| ML062640518 | List: |
| References | |
| G20060792 | |
| Download: ML062640268 (217) | |
Text
EDO Principal Correspondence Control FROM: DUE: 10/20/06 John T. Larkins, ACRS EDO CONTROL: G20060792 DOC DT: 09/13/06 FINAL REPLY: TO: Reyes, EDO FOR SIGNATURE OF Dyer, NRR** GRN **CRC NO: DESC: ROUTING: Questions Raised by Members of the Public During the ACRS Subcommittee Meeting on Palisades Nuclear Plant License Renewal Application DATE: 09/20/06 Reyes Virgilio Kane Silber Johnson Cyr/Burns Zimmerman, NSIR Strosnider,NMSS Brenner, OPA Sosa, OEDO ACRS File ASSIGNED TO: NRR CONTACT: Dyer SPECIAL INSTRUCTIONS OR REMARKS: Coordinate with appropriate offices. Provide copy of response to ACRS.Rbc5NOD E, R 165: F-ý)o -0 1 0 UNITED STATES C NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, DC 20555 -0001 ACRSR-2206 September 13, 2006 MEMORANDUM TO: Luis A. Reyes Executive Director for Operations
/RAI, MRSnodderly for FROM: John T. Larkins, Executive Director Advisory Committee on Reactor Safeguards
SUBJECT:
QUESTIONS RAISED BY MEMBERS OF THE PUBLIC DURING THE ACRS SUBCOMMITTEE MEETING ON PALISADES NUCLEAR PLANT LICENSE RENEWAL APPLICATION During the July 11, 2006 ACRS Subcommittee meeting on Plant License Renewal that was held to review the license renewal application for the Palisades Nuclear Power Plant, members of the public raised several questions.
These questions can be found in the transcript of the meeting (ADAMS Accession No. ML062080468).
Since most, if not all, of these questions do not deal with license renewal issues, the Committee brings this matter to your attention for disposition.
cc: A. Vetti-Cook SECY M. Johnson, OEDO B. Sosa, OEDO J. .amb, OEDO F. Gillespie, NRR L. Lund, NRR L. Padovan, NRR J. Ayala, NRR D. Collins, NRR S. (Min) Lee, NRR EDO --G20060 7 9 2 Official Transcript of 33__ NUCLEAR REGULATORY COMMISSION Title: -,-'Docket Number: %' -_." " '"Location:
- Date: Advisory Committee on Reactor Safeguards Subcommittee on Plant License Renewal (not applicable) p U SUNSI REVIEW COUPLE6T Rockville, Maryland Tuesday, July 11, 2006 Work Order No.: NRC-1132 Pages 1-140 NEAL R. GROSS AND CO., INC. Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS July 11, 2006 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards, taken on July 11, 2006, as reported herein, is a record of the discussions recorded at the meeting held on the above date. This transcript has not been reviewed, corrected and edited and it may contain inaccuracies.
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 ..... 4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 5 (ACRS) 6 SUBCOMMITTEE ON PLANT LICENSE RENEWAL 7 +++++ 8 TUESDAY, 9 JULY 11, 2006 10 .+++++ 11 ROCKVILLE, MARYLAND 12 ..... 13 The Subcommittee met at the Nuclear Regulatory 14 Commission, Two White Flint North, Room T2B3, 11545 15 Rockville Pike, at 1:30 p.m., Dr. John D. Sieber, 16 Chairman, presiding.
17 COMMITTEE MEMBERS: 18 JOHN D. SIEBER, Chair 19 J. SAM ARMIJO, Member 20 MARIO V. BONACA, Member 21 OTTO L. MAYNARD, Member 22 GRAHAM B. WALLIS, Member 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 2 1 ACRS STAFF PRESENT: 2 MICHAEL JUNGE 3 FRANK GILLESPI 4 JUAN AYALA 5 DAVID JENG 6 MATTHEW MITCHELL 7 REPRESENTATIVES OF PALISADES NUCLEAR PLANT PRESENT: 8 DARREL TURNER 9 JOHN BROSCHAK 10 BOB VINCENT 11 PAUL HARDEN 12 MARK CIMOCK 13 LARRY SEAMANS 14 BILL ROBERTS 15 JOHN KNEELAND 16 BRIAN BROGAN 17 ALSO PRESENT: 18 MARK HARTZMAN 19 CORINNE CAREY 20 -ALICE HIRT 21 KAY CUMBOW 22 GARY KARCH 23 KEVIN KAMPS 24 MICHAEL KEEGEN 25 KATHRYN BARNES NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4433 3 1 A-G-E-N-D-A 2 Welcome and Introductions 3 Dr. John Sieber, Chair .........
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3 4 Louise Lund, Branch Chief in License Renewal 5 Branch A, Division of License Renewal ...6 6 Palisades Nuclear Plant Presentation by Palisades 7 Staff ................
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8 1 License Renewal Safety Evaluation Report 2 Overview of the Plant and Application and 3 Discussion of Scoping and Screening Results, 4 Juan Ayala, Project Manager ...... .. 63 5 License Renewal Inspections, Patricia Lougheed, 6 Lead Inspector for License Renewal for Region 7 III ...............
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70 8 Staff's Review of the Aging Management Programs 9 and Aging Management Reviews ... ....... ..86 10 Public Comments ..........
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.. 112 11 12 13 14 15 16 17 18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44 433 4 1 P-R-O-C-E-E-D-I-N-G-S 2 1:34 P.M. 3 CHAIRMAN SIEBER: The meeting will now 4 come to order. This is a meeting of the Plant License 5 Renewal Subcommittee.
I am Jack Sieber, Chairman of 6 the Plant License Renewal Subcommittee for the 7 Palisades plant. ACRS members in attendance are Dr. 8 Graham Wallis, Dr. William Shack, Dr. Mario Bonaca, 9 Dr. Sam Armijo, and Otto Maynard. Michael Junge, to 10 my right, of the ACRS staff is the designated federal 11 official for this meeting.
12 The purpose of the meeting is to discuss 13 the license renewal application for the Palisades 14 Nuclear Plant. We will hear presentations from 15 representatives in the Office of Nuclear Reactor and 16 Regulation, the Region III office in Lisle, Illinois, 17 and the Nuclear Management Company. The Subcommittee 18 will gather information, analyze relevant issues and 19 facts, and formulate proposed positions and actions as 20 appropriate for deliberation by the full Committee.
21 The rules for participation in today's 22 meeting were announced as part of the notice of this 23 meeting previous published in the Federal Register on 24 June 21, 2006. We have received no written comments 25 or request for time to make an oral statement from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4433 5 1 members of the public regarding today's meeting.
2 A transcript of the meeting is being kept 3 and will be made available as stated in the Federal 4 Register notice. Therefore, we request that 5 participants in this meeting use the microphones 6 located throughout the meeting room when addressing 7 the Subcommittee.
Participants should first identify 8 themselves and speak with sufficient clarity and 9 volume so that they can be readily heard. 10 Matters to be discussed this afternoon is 11 the license renewal application and its related safety 12 evaluation report and the inspection and audit report 13 prepared by our Region III office in Lisle, Illinois, 14 the licensee and also the Office of Nuclear Reactor 15 Regulation.
16 The requirements for license renewal are 17 set forth in Title 10 of the Code of Federal 18 Regulations, Part 54, and involve aging management of 19 long-live passive components that are included within 20 the scope of the rule. We will restrict ourselves to 21 discussions of the licensee's treatment of and NRR's 22 review of the aging management and time-limited aging 23 analysis related to those components in scope. 24 We will now proceed with the meeting and 25 I call on Ms. Louise Lund of the Office of Nuclear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234.4 433 6 1 Reactor Regulation to begin. 2 MS. LUND: Thank you. Good afternoon.
My 3 name is Louise Lund. I am the Branch Chief in License 4 Renewal Branch A in the Division of License Renewal.
5 We are here to discuss, as previously stated, the 6 license renewal review for Palisades that form the 7 basis for our safety evaluation.
Beside me also is 8 Frank Gillespi, our Director for the Division of 9 License Renewal. Staff has conducted a very detailed 10 and thorough review of the Palisades Nuclear Plant 11 license renewal application which was submitted in 12 March of 2005. 13 Mr. Juan Ayala, here to my right, at the 14 end of the table, is the project manager for this 15 review. He will lead the staff's presentation this 16 afternoon on the draft safety evaluation report. In 17 addition, we have Ms. Patricia Lougheed who is our 18 team leader for the Region III inspections that were 19 conducted at Palisades Nuclear Plant and she is 20 sitting right behind me. 21 We also have several members of the NRR 22 technical staff here in the audience to provide 23 additional information and answer your questions.
The 24 staff felt that the Palisades Nuclear Plant 25 application was of sufficient quality that it resulted NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202M 23444 133 33 7 1 in the issuance of 174 formal requests for additional 2 information which is on the low end of the amount of 3 RAIs that we have issued for recent plants. 4 I know that the ACRS has been interested 5 in the number of questions that have come out of these 6 reviews in the past and believe that part of this 7 reduction is the result of the generic aging lessons 8 learned report. This application was submitted using 9 the draft GALL report that was issued back in January 10 of 2005. 11 However, it was reconciled with the 12 September 2005 version of the GALL report. In fact, 13 it resulted in a 95 percent consistency between their 14 application and the revised GALL. That made it a good 15 application for us to review in that respect to see 16 the consistency.
17 In addition, the staff at Palisades 18 provided excellent support for our on-site audits in 19 the inspections that were conducted and also the 20 headquarters reviews through the conference calls and 21 the numerous meetings that we had. 22 With that, I would like to turn it over to 23 Bob Vincent who is the manager of this project at 24 Palisades to begin the applicant's presentation.
25 MR. TURNER: Good morning. Good afternoon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4 433 8 1 I should say. My name is Darrel Turner and I am the 2 Manager of Projects at Palisades nuclear site. With 3 me we brought the License Renewal Project team along 4 with a couple of guests from Palisades, the Nuclear 5 Management Company.
6 I would like to introduce those people if 7 I may. In our audience behind the committee is our 8 site Vice President Paul Harden. On my right is our 9 site engineering director Mr. John Broschak.
And as 10 Bob was just introduced, Bob Vincent on my left. He 11 is the Manager of the License Renewal Project itself. 12 With the project team we've got Mark 13 Cimock who is the lead for Civil, Structural, and 14 Mechanical.
We have to his left John Kneeland, Time 15 Limited Aging Analysis lead. To his left is Bill 16 Roberts, our program lead. To the right is Mark 17 Cimock is Larry Seamans, our electrical lead for the 18 project.
19 We are happy to be here and present to you our 20 Palisades plant and answer your questions.
We have a 21 short introduction here. The next slide, please, Bob. 22 I'm going to go to the agenda. We are going to talk 23 a little bit about our plant, a little description, 24 the licensing history since its inception, some major 25 improvements that we have accomplished and performed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 9 1 over the last several years, our current plant status, 2 where we are on operating space. 3 We are going to review our license renewal 4 methodology that went into the application.
I am 5 going to inform you about our commitment management 6 system at Palisades.
We thought that the ACRS would 7 be interested in a few technical issues which we are 8 going to expound upon which you see on the slide. 9 Our plant is owned by Consumers Energy 10 Company and it is operated and run by the Nuclear 11 Management Company. We are situated in the Southeast 12 corner of Lake Michigan just right near the little 13 town of Covert, Michigan, on a site of 432 acres. We 14 have a combustion engineering nuclear steam supply 15 system and our architect engineer for the power plant 16 was Bechtel. We have two-loop reactor cooling system 17 with four primary coolant pumps, two steam generators.
18 Our containment is pre-stressed concrete containment.
19 You may have seen the photo earlier but we 20 have two banks of cooling towers, two draft cooling 21 towers, forced draft with 18 cells each. Our ultimate 22 heat sink is Lake Michigan through our service water 23 system. Our current license power is 2565.4 MWt. We 24 have a design electrical output of 820 megawatts 25 electric net and our probabilistic risk assessment for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 10 1 core damage frequency due to internal events is 2.86 2 E to the minus fifth. Our large early release 3 frequency, as we see, is 3.55 E to the minus seventh.
4 CHAIRMAN SIEBER: There's a couple ways of 5 using forced draft cooling towers. One of them is 6 using as part of a closed cycle condenser cooling 7 system. The other way is to use them as an after 8 cooler for open cycle where they don't run all the 9 time. Which is yours? 10 MR. TURNER: Our cooling tower fans are 11 run all the time. It's a closed cycle system. 12 CHAIRMAN SIEBER: You are closed cycle. 13 Okay. 14 MR. TURNER: Correct.
15 CHAIRMAN SIEBER: Thank you. 16 MEMBER BONACA: On the PRA, this number 17 2.8 E to the minus fifth for a CE type plant at that 18 time seems very low. Have you had improvements with 19 the plant over the years in the auxiliary fuel system 20 or the charging system of that plant? 21 MR. TURNER: Have we had improvements that 22 have improved our core damage frequency is the 23 question?
24 MEMBER BONACA: Yes. 25 MR. TURNER: We have a number of slides NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-44¢33 11 1 that we are going to discuss in just a little bit. 2 MEMBER BONACA: Okay. I'll wait. 3 MR. TURNER: One person I forgot to 4 introduce, excuse me, please, is Brian Brogan who is 5 our Probabilistic Risk Assessment Supervisor who 6 supported the team and we brought him with us. 7 That's a little bit on our plant 8 description.
I would like to turn it over to Bob 9 Vincent, License Renewal Project Manager, to describe 10 some of our licensing history.
11 MR. VINCENT: I'm Bob Vincent, License 12 Renewal Project Leader. 13 CHAIRMAN SIEBER: Could you bring the 14 microphone over? 15 MR. VINCENT: Thank you for the reminder.
16 CHAIRMAN SIEBER: Okay. 17 MR. VINCENT: I'm Bob Vincent.
18 Construction for Palisades was issued in 1967 and 19 consistent with the licensing process of the time. 20 Palisades received a provisional operating license in 21 1971. The initial expiration date was in 2007. Then 22 in 1974 we applied for the full-term operating 23 license.
24 During the period 1978 to 1983 and 25 slightly beyond Palisades was one of the 11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 2344, 433 12 1 participants in the System Evaluation Program. The 2 full-term operating license for the plant was issued 3 in 1991 with an expiration date of 2007. 4 In 2000 we recovered the construction 5 period and our expiration date was changed to March 6 24, 2011, which is the current expiration date. Tm 7 in 2005 our license power level was raised from 2530 8 to 2575.4 MWt. That was a measurement uncertainty 9 recaptured power upgrade. 2565 is the current license 10 power level in Palisades.
11 At this point I would like to turn it over 12 to John Broschak to talk about some of the major 13 improvements and planned upgrades and the current 14 plant status. 15 MR. BROSCHAK:
Good afternoon.
My name is 16 John Broschak and I am the Site Engineering Director 17 for the Palisades station. I will *be providing a 18 brief overview of some of the more significant and 19 major plant modifications that have been performed 20 since original construction.
21 In 1974, '75 the plant was converted from 22 once-through cooling to cooling towers as described in 23 the description.
At that time the condenser was 24 retubed from a Admiral T material to a copper nickel 25 90-10 material.
In 1977 and again in 1987 the spent NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202) 234-4433 13 1 fuel pool storage capacity was expanded.
In 1977 2 additional racks were installed in the pool to raise 3 the capacity to 798 assemblies.
In 1987 some high 4 density racks were replaced in the pool to get it up 5 to 892 usable assemblies and that is the licensed 6 amount of fuel storage in the spent fuel pool at this 7 time. 8 CHAIRMAN SIEBER: Do you use neutron 9 absorbers?
10 MR. BROSCHAK:
Yes, sir. 11 CHAIRMAN SIEBER: What are there? 12 MR. BROSCHAK:
I believe it's a boron 13 material.
14 CHAIRMAN SIEBER: Boroflex?
15 MR. BROSCHAK:
Mark Cimock, our lead 16 mechanic, would like to answer that. 17 MR. CIMOCK: This is Mark Cimock with the 18 Nuclear Management Company. We have some boroflex 19 racks in our fuel pool but we do not credit them as a 20 neutron absorber.
Our analysis does not credit that. 21 But we also have a design that actually has boron 22 carbide plates that are sheaved in stainless steel. 23 We do credit those for neutron absorption.
24 CHAIRMAN SIEBER: Thank you. 25 MR. BROSCHAK:
Again John Broschak.
Back NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 2344 133 14 1 to the major planned improvements.
In 1983 we added 2 a third auxiliary feedwater pump and upgraded that 3 system to safety-grade.
Also, in 1983 we upgraded the 4 control room HVAC to safety-grade.
5 MEMBER BONACA: So you do have steam 6 driven pump? 7 MR. BROSCHAK:
Yes, sir. 8 MEMBER BONACA: And two electric driven 9 pumps? 10 MR. BROSCHAK:
Two electric driven 11 auxiliary feedwater pumps, one steam driven auxiliary 12 pump. 13 MEMBER BONACA: One is capable of 100 14 percent? 15 MR. BROSCHAK:
Yes, sir. 16 MEMBER BONACA: Okay. 17 CHAIRMAN SIEBER: Do you meet all the 18 separation criteria for those pumps from a fire 19 protection standpoint?
20 MR. BROSCHAK:
Yes. 21 CHAIRMAN SIEBER: Different rooms? 22 MR. BROSCHAK:
Yes, sir. 23 CHAIRMAN SIEBER: Okay. 24 MR. BROSCHAK:
In 1985 and 1986 the 25 initial PRA applications were done at Palisades.
Much NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N. (20 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44 ,33 15 1 of this was as the result of the Systematic Evaluation 2 Program issues that were being addressed, mainly the 3 main steam isolation valves. PRA was used as a method 4 for resolving questions that came up as a result of 5 the failure criteria 4 main steam isolation valves. 6 In 1989, again, as a result of PRA 7 insights the plant addressed on its own an issue 8 concerning the lack of diversification of off-site 9 power. There had been history of lightening strikes 10 and other environmental conditions that caused loss of 11 off-site power and through insights using PRA we were 12 able to add additional diversification to the 13 switchyard arrangement to basically eliminate that 14 vulnerability and reduce the risk of the plant to this 15 type of situation.
16 CHAIRMAN SIEBER: Maybe to explain that a 17 little bit, you could tell me a little bit more what 18 equipment you added. Did you add new lines, new 19 breakers?
20 MR. BROSCHAK:
Yes. If I could, I'll 21 refer that to Larry Seamans who is our electrical 22 lead. 23 CHAIRMAN SIEBER: Come over here to this 24 microphone.
25 MR. SEAMANS: I am Larry Seamans, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202) 234 433 16 1 electrical lead for license renewal. What we added at 2 that time was on our switchyard buses we had a 3 connection on one bus and then one hub initially.
4 That hub connection came through disconnects that had 5 to be manually disconnected to get the feedback.
6 At that time we added a motor operated 7 disconnect.
We also added on the other bus a separate 8 feed and then we have the transformer, voltage 9 regulated transformer, and added a separate 10 underground feed back to the plant that goes to either 11 safety bus. 12 MR. VINCENT: Just to add onto that a 13 little bit more -- Bob Vincent again -- for clarity, 14 what we have now is basically three sources of off 15 site power, two immediate access sources, one through 16 the original start-up lines which are a set of 17 overhead lines. The second source is totally from an 18 independent section of the switchyard with a 19 transformer in the switchyard and a set of underground 20 lines that can feed our vital buses directly.
21 Then the third source is back-feed through 22 the main transformer.
With the motor-operated 23 disconnect Larry mentioned, that is almost immediately 24 access feed but we have to manually operate the motor 25 operated disconnect.
We have three prompt access NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 2344 433.o 17 1 feeds. 2 CHAIRMAN SIEBER: How many transmission 3 lines into and out of your switchyard?
4 MR. TURNER: The question is how many 5 transmission lines are into and out of our switchyard.
6 Larry, I would like to defer that one to you as well. 7 MR. SEAMANS: This is Larry Seamans again 8 with the Palisades license renewal team. We have 9 seven total off-site sources that come in. 10 CHAIRMAN SIEBER: Thank you. 11 MR. BROSCHAK:
John Broschak again. 12 Getting back to the list in the presentation.
In 1990 13 we placed the steam generators and also retubed the 14 main condenser and feedwater heaters. At that time 15 the tubing material was changed from the copper nickel 16 to stainless for the main condenser and feedwater 17 heaters.
18 DR. SHACK: And you steam generators are? 19 MR. BROSCHAK:
Alloy 600. 20 DR. SHACK: Thermally treated? 21 MR. BROSCHAK:
They were manufactured at 22 the same time as the'original plant construction and 23 they are alloy 600 thermal treatment.
24 CHAIRMAN SIEBER: I don't know about that. 25 DR. SHACK: The 1990 versions are 600 and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 18 1 you don't know whether they are thermally treated or 2 not? 3 MR. VINCENT: Bob Vincent again. Those 4 were actually manufactured in 1977/78 time frame so we 5 kept them in storage for years before we finally did 6 install them. 7 CHAIRMAN SIEBER: I presume when they were 8 in storage that they were inert in some way? 9 MR. VINCENT: Absolutely.
They were 10 maintained with inert atmosphere internally.
11 MEMBER BONACA: What's the performance of 12 the tubes? 13 MR. TURNER: What's the performance of the 14 tubes is the question?
15 MEMBER BONACA: Yes. 16 MR. BROSCHAK:
Currently 4.5 percent of 17 the tubes are plugged approximately on both 18 generators.
That is in reference to the 3 percent 19 that were preferentially plugged when they were 20 originally installed.
Over the past 16 years of 21 operation there has been approximately 1.5 percent of 22 the tubes additional that have been plugged on each of 23 the steam generators.
24 DR. SHACK: Why did you replace the steam 25 generators?
What was the mode of degradation that did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202( 234-4433 WASHINGTON, D.C. 20005 (202) 234-44 433 I q 19 1 them in? 2 MR. VINCENT: Bob Vincent again. Early in 3 plant life we had chronic steam generator tube 4 leakages problems.
The original steam generators had 5 carbon steal support plates. Most of the lateral 6 supports for tubes were carbon steel. That, of 7 course, created a denting problem.
8 We also had a wastage problem with the 9 original tubes primarily down near the tube sheet 10 under the sludge piles. We had a fair amount of 11 morpholine due to wastage. Those were the primary 12 problems early on. 13 CHAIRMAN SIEBER: Was your early chemical 14 treatment the TSP treatment?
15 MR. VINCENT: No. We started out with -16 yes. I'm sorry. We did have trisodium phosphate 17 early on. 18 CHAIRMAN SIEBER: That's where the wastage 19 comes from. 20 MR. VINCENT: Right. 21 CHAIRMAN SIEBER: What is the treatment 22 since the new steam generators have been installed?
23 MR. VINCENT: At this point it's all 24 volatile.
25 CHAIRMAN SIEBER: Molar control? NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUF, N.W. (202 2344433 WASHINGTON.
D.C. 20005 (202) 234-44'33 20 1 MR. TURNER: Hydrazide morpholine.
2 CHAIRMAN SIEBER: Yeah, but you try to get 3 a molar balance.
4 DR. SHACK: Do you follow the EPRI PWR 5 steam generator water chemistry guidelines?
6 MR. VINCENT: Yes, we do. 7 CHAIRMAN SIEBER: Let me ask about the 8 main unit condenser.
After the first retubing do you 9 put copper nickel in there. What was the degradation 10 mechanism that caused you to go to stainless?
11 MR. TURNER: The degradation mechanism 12 that caused us to go to stainless tubes in the 13 condenser?
14 CHAIRMAN SIEBER: Right. 15 MR. VINCENT: The short answer to that one 16 is that I think the 90-10 copper nickel performed 17 rarely well but we wanted to get rid of copper in the 18 system. 19 CHAIRMAN SIEBER: So it wasn't 20 degradation.
You just wanted to change the chemistry 21 of your secondary site. 22 MR. VINCENT: To the best of my memory, 23 yes. 24 CHAIRMAN SIEBER: Have you ever had a 25 problem with microbiologically induced corrosion?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4 133 21 1 MR. BROSCHAK:
This is John Broschak.
2 There are some examples of MIC, microbiologically, 3 induced corrosion throughout the plant. Mark Cimock, 4 I don't know if you have any specific examples.
It is 5 a program that is monitored by the station and we do 6 inspections and periodic replacements based on what 7 inspection results we have. 8 MR. CIMOCK: I don't know if I can add 9 much more. Again, this is Mark Cimock, NMC. I don't 10 think I can add much more to that. I think most of 11 the MIC type issues we've had that have been 12 permanently on secondary or actually the raw water 13 systems. I'm not aware of any problems we've had on 14 the secondary side. 15 CHAIRMAN SIEBER: Usually if you have a 16 lot of defects in condenser tubes it changes your 17 steam generator chemistry sometimes enough to give you 18 lots of problems.
That is really the gist of what I 19 was asking you is how bad was your condenser?
How 20 much damage was it causing to the steam generators 21 that you still now have? I think what you're telling 22 me is that the motivation for going to stainless is 23 not related to degradation of the tubes but to a 24 desire to change the -- to get rid of copper which 25 most utilities have tried to do. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4 4433.o 22 1 MR. CIMOCK: That's correct.
2 MR. BROSCHAK:
John Broschak again. Back 3 to the list. In 1993 Palisades was the first 4 stationed implement an independent spent fuel storage 5 installation under a general license in Part 72. We 6 implemented the VSC-24 system at that time to 7 supplement pool storage capacity.
8 CHAIRMAN SIEBER: All right. 9 MR. BROSCHAK:
1995, again due to PRA 10 insights, we modified the under-reactor vessel floor 11 drains to containment sump. This was a matter of 12 adding ceramic beads so that any designed basis fuel 13 that would potentially be introduced into the sump 14 would be prohibited based on interaction with those 15 ceramic beads. 16 2004 Palisades implemented a second 17 independent spent fuel storage installation to expand 18 capacity this time with the new home system. In 2006 19 just recently Palisades has implemented the most 20 significant of the SAMA improvement and modifications.
21 This was the addition of a non-safety backup diesel 22 generator.
23 This has allowed us to reduce the core 24 damage frequency from approximately four to 10 to the 25 minus fifth down to the 2.86 number understanding that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4433 23 1 the PRA model is a living model. That represented 2 approximately 40 present reduction in the core damage 3 frequency by the addition of that non-safety backup 4 diesel generator.
5 CHAIRMAN SIEBER: So you have three diesel 6 generators?
7 MR. BROSCHAK:
That's correct.
8 CHAIRMAN SIEBER: What is either the 9 kilowatt-hour or horsepower of the non-safety diesel? 10 MR. BROSCHAK:
Non-safety currently 11 installed is 2,000 kilowatts.
That is the amount we 12 need to carry the safety loads required under the 13 conditions that we would use them. 14 CHAIRMAN SIEBER: Okay. 15 MEMBER MAYNARD: Is that a swing diesel 16 that can work on either a safety train or is it one 17 that powers into the normal grid and provides like 18 all-site power would? 19 MR. BROSCHAK:
I guess the terminology 20 swing diesel would be appropriate.
It can power 21 either of the safety buses that would be required to 22 power safety-related loads. 23 CHAIRMAN SIEBER: Can .you connect your 24 safety vessels together?
25 MR. BROSCHAK:
No, we cannot. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, NW. (902) 234-4433 WASHINGTON, D.C. 20005 (202) 2344433 24 1 CHAIRMAN SIEBER: Okay. 2 MR. BROSCHAK:
Currently the plant status 3 is operating at 100 percent power in the 19th cycle of 4 operation.
The next refueling outage is scheduled for 5 the fall of 2007. All NRC performance indicators are 6 green and there are no current NRC inspection findings 7 greater than green. 8 At this point I will turn it back over to 9 Bob Vincent to discuss the license renewal application 10 methodology.
11 MEMBER BONACA: All in all how would you 12 characterize the physical conditions of the plant? 13 MR. BROSCHAK:
Physical condition of the 14 plant is good to excellent.
That is based on feedback 15 we get from external stakeholders that come to visit. 16 The physical condition, I would say, is good to 17 excellent.
18 MEMBER BONACA: We'll ask that question, 19 of course, to the inspectors later on. 20 MR. BROSCHAK:
Yes. 21 DR. SHACK: Have you done much replacement 22 of piping on your secondary side to switch to chrome 23 molly alloys or are you really relying on your 24 Corrosion Erosion Program to monitor that? 25 MR. BROSCHAK:
John Broschak again. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344 433 25 1 have a combination program of selective replacements 2 with the chrome molly in addition to active searching 3 for corrosion and erosion mechanisms and then doing 4 selective replacements as we identified those so it's 5 a combination rather than just a wholesale strategic 6 replacement piping. 7 MR. VINCENT: I am Bob Vincent again. The 8 license renewal application was dated March 22, 2005. 9 It was developed using the standard format of NEI 95 10 10 endorsed by the NRC. The GALL revision used for 11 the application was the 2001 Revision 0 of the GALL 12 and the Standard Review Plan. In the application we 13 addressed all of the issued and draft ISGs that were 14 available publicly at that point. 15 CHAIRMAN SIEBER: How many was that? 16 MR. VINCENT: I believe the number was 15. 17 As I recall there were about 10 that had been issued 18 and I think five were in draft form at that point. 19 From the outset we designed the project of 20 Palisades to be a site-based, site-run project. In 21 the lead positions we staffed with highly experienced 22 plant people. In fact, among the leads I think we 23 represent over 150 years of Palisades site experience 24 and most of the leads had been through SRO training.
25 I think four had been formerly licensed.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20006 (202)234-4433 26 1 It was a highly plant-experienced staff. Then we 2 supplemented that staff with license renewal 3 experienced people we could find who had worked on 4 other sites. We thought that brought the best of both 5 worlds to the project.
6 Scoping, screening, and aging management 7 reviews were performed to industry standards.
8 Throughout the project we tried to stay very much in 9 tune with what was happening in the rest of the 10 industry.
As we saw experience emerge from NRC 11 reviews and other applications that had been developed 12 that were applicable to Palisades, we tried to 13 incorporate that experience.
14 CHAIRMAN SIEBER: What did you do to get 15 the experience?
Did you come to meetings like this 16 that other licensees were having? 17 MR. VINCENT: Yes. Numerous things. 18 CHAIRMAN SIEBER: I would point out that 19 we have Exelon and First Energy here watching you 20 which I think is a great idea. 21 MR. VINCENT: Yes. 22 CHAIRMAN SIEBER: I don't want to relive 23 all these experiences over and over again. 24 MR. VINCENT: We can sympathize.
We were 25 actively involved with the License Renewal Task Force NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 27 1 which was a tremendous benefit to us. We also 2 participated as reviewers for peer reviews at some 3 other plants and we had an industry peer review of our 4 application, provided additional insights using people 5 who had been experienced in license renewal projects 6 at other plants, provided more input from other plants 7 and how they did business.
Just numerous things like 8 that kept us in tune. 9 One area where that made a particular 10 difference in the final result for Palisades was in 11 the area of scoping under 54.4(a) (2), non-safety 12 affecting safety. Rather late in the process we 13 changed our scoping methodology to adopt to spaces 14 approach based one experience actually at Dresden and 15 Quad. That greatly facilitated the NRC reviews in 16 that area. 17 The system descriptions and the boundaries 18 in the application were consistent with the FSER. As 19 I mentioned at the beginning, the AMR results in the 20 application were reconciled to the GALL Revision 0. 21 Then shortly after we submitted our application, we 22 did reassess our AMR results using the draft Revision 23 1 of the GALL and then again after the final Revision 24 1 was issued in September we again did a comparison.
25 We provided the results to the ACRS staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 28 1 to facilitate their reviews and think the use of at 2 least draft of the GALL helped the process 3 considerably.
Since we were in that transitional 4 period between Rev. 0 and Rev. 1 of the GALL, the 5 industry as well as the NRC were interested in 6 statistics, how much Rev. 1 really helped. We can say 7 from experience Rev. 1 was a substantial improvement 8 over Rev. 0. It greatly helped efficiency of the 9 review. 10 The final result is that aging over the 11 extended operating period will be managed by 24 Aging 12 Management Programs at Palisades.
Twenty of those are 13 existing programs based on existing activities.
Four 14 of those programs are new. 15 DR. SHACK: A substantial number of your 16 existing programs seem to have to have enhancements to 17 be consistent with GALL. Do you feel that indicates 18 you had some deficiency in your aging management 19 approach pre-GALL?
20 MR. VINCENT: Two responses to that. One, 21 because of the way GALL was formatted, we essentially 22 repackaged many of our programs.
We were performing 23 many of the activities so we credit that as an 24 existing program but we essentially repackaged some of 25 those with a high-level program document that would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (2021 234-44 133 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 29 basically provide the umbrella, administrative controls over all of the activities.
I would say it was more repackaging than truly changing what we did. There were certainly some enhancements that came out of the review, things that we decided should be strengthened in our existing activities.
That was certainly no surprise.
We learn as we go.DR. SHACK: You weren't terribly successful in managing the aging of your control rod drive houses. Do you think you have changes in your programs that would prevent that? Did you make changes after that? MR. VINCENT: Bill, would you like to comment on that? I would say in general in the control rod drive area we are dealing with some design issues, some early material selection and some -DR. SHACK: Your chemistry controls.
Are you water chemistry controls changed from those days? At least I read it was attributed to stress corrosion cracking, chlorides, and stagnate oxygen. levels. Materials will still crack with chlorides and oxygen. MR. VINCENT: I wouldn't want to compare a compare today with your earlier program. I will say today we are rigorous about complying with the EPRI NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. 2)234-4433 WASHINGTON.
D.C. 20005 (202 2344 I (2 433 30 1 standards for primary and secondary controls.
2 Primary, of course, applies to the control rod drives. 3 I wouldn't make any claims that we do much better or 4 worse today than we did back then. 5 Go ahead, Paul. 6 MR. HARDEN: This is Paul Harden, the site 7 Vice President at Palisades.
I can answer the 8 question on a number of facets. First off, chemistry 9 controls today are much better than they were early in 10 plant life. The EPRI guidelines have -11 DR. SHACK: I mean, it wasn't all that 12 ancient history.
13 MR. HARDEN: Relative to the control rod 14 drive housing cracking issue, it requires a couple of 15 things for the primary water stress version cracking.
16 One of the environment but the other is the residual 17 stresses that drive the cracking.
18 The original housings were designed and 19 manufactured with a technique that left a significant 20 amount of residual stresses.
As a matter of fact, 21 grinding that had been done on the inside of them to 22 smooth out welds left lots of stress risers and things 23 that led to the cracking manifesting itself. 24 When we replaced those housings, we 25 improved both the materials as well as the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 31 1 manufacturing techniques using the latest technology 2 to ensure that all the stresses that historically due 3 to the older manufacturing techniques had stress 4 risers were actually manufactured in a manner that put 5 it in a compressive stress rather than tensile stress 6 to reduce the susceptibility.
7 MR. VINCENT: I would like to touch 8 briefly on commitment management.
SER Appendix A does 9 list the commitments for future action that we made 10 during the course of the NRC review. We have entered 11 those commitments into our plant corrective action 12 tracking program which is the way we manage all our 13 commitments.
14 In addition, program descriptions, the 15 TLAA descriptions, and the commitments will be 16 incorporated into the FSER so we will control the 17 implementation of those commitments.
18 MEMBER WALLIS: Can I say something about 19 commitments here? There are 55 commitments or 20 something like that. Lots of new or enhanced 21 programs.
I was just curious why it took license 22 renewal to sort of initiate all these programs.
I 23 would have thought they would have been initiated as 24 matter of cost anyway because they were needed. It 25 seems as if it took license renewal to get you to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 32 1 all that. 2 MR. VINCENT: Well, most of the 3 commitments do represent enhancements to programs that 4 were already in existence that we decided as a result 5 of license renewal we wanted to make. Some were made 6 to bring us into alignment with the GALL. A major 7 goal during the process was not to make sure 8 everything aligned with the GALL. 9 We were going to manage our activities in 10 the way that we thought made economic sense to get the 11 quality we wanted, etc. Being exactly equivalent to 12 GALL wasn't necessarily a goal but we did make a 13 number of changes to be consistent with GALL. 14 I'm not sure that the total number is too 15 inconsistent with the numbers of commitments that were 16 made by other licensees.
I will point out in that 17 Appendix A list that during the course of the reviews 18 we made a number of short-term commitments to provide, 19 for example, comparison between the GALL version of 20 the chemistry standards, the EPRI standards for 21 chemistry, and the version of the EPRI chemistry 22 standard that we had implemented on site, things like 23 that. 24 Those were short-term commitments.
They 25 were rough numbers, a dozen of those. Those are also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. '202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234.4433 33 1 listed in Appendix A but those are closed so the 2 actual number of commitments for future action is in 3 the low 40s. 4 CHAIRMAN SIEBER: On the other hand you 5 have 40 some commitments and basically five years to 6 do them. Is that correct? 7 MR. VINCENT: That's correct.
8 CHAIRMAN SIEBER: That's a lot of work, or 9 it can be depending on what the scope of each 10 commitment is. 11 MR. VINCENT: That's correct.
12 CHAIRMAN SIEBER: Are you prepared to get 13 that work done before the current license expires? 14 MR. VINCENT: Absolutely.
One thing I 15 would point out, it is not unusual for license renewal 16 project teams to be dissolved basically at the point 17 where the license is issued and then rely on the plan 18 to implement all these new commitments.
We have 19 designed our project so this team will stay in 20 existence through 2007. 21 By the time we are done in 2007 we will 22 have implemented all the new programs.
We'll turn 23 over to the plant effective functioning programs.
We 24 won't rely on them to implement this work in the 25 future. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (20 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44'33 34 1 CHAIRMAN SIEBER: It seems to me that if 2 you take the ordinary plant staff and throw in a big 3 bundle of work like this in a limited amount of time 4 there will be a question, particularly for somebody 5 like me who doesn't know the details of every one of 6 these as to whether you are going to finish. 7 MR. BROSCHAK:
This is John Broschak.
8 What I can tell you is the site staff outside of the 9 license renewal project team has been very engaged and 10 integrated with these activities.
The system 11 engineers in particular have provided their input and 12 reviewed the proposed program changes that were to be 13 made. They certainly aren't as intimate with the 14 details that the project team is but there has been a 15 tremendous amount of interaction with the normal plant 16 staff. 17 Also the way the schedule has been 18 arranged, we expect to see integration of the project 19 teams members and to certain strategic positions of 20 the plant staff. We are very confident that we are 21 not only going to get these programs into place but we 22 are very effectively looking at them. 23 MR. TURNER: This is Darrel Turner. I've 24 got one follow-up just to make it clear. Right from 25 the onset of the license renewal project when we got NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202M 2344 133 35 1 into developing the programs in alignment with the 2 GALL, we included the program engineers, about a dozen 3 of them, in the plant from which we all came to be 4 involved with the development of these programs and 5 revised programs.
6 Not only involved, they were reviewers and 7 subsequent approvers of the programs along with their 8 department heads so we've got a good alignment with 9 the plant people, as John said, to transition over the 10 next year and a half to slightly less than two years 11 every one of those commitments.
12 CHAIRMAN SIEBER: I would like to -- at 13 the risk of disrupting your entire presentation, I 14 would like to go back to something that you said maybe 15 15 minutes ago where you adopted the spaces approach 16 to scoping. I presume that the way you identified 17 what is in scope is to take PNIDs and take a colored 18 pen and mark all the things that are in scope in a 19 spaces environment, particularly where you have walls 20 which may be a boundary point for two over one 21 configurations and so forth. 22 PNID really doesn't lend itself to that 23 kind of thing. How did you deal with determining what 24 is the anchor point, how do I show it on a drawing, 25 how do I make sure that somebody in the future who you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44 33 36 1 may have just hired understands the document that you 2 have so they know what is in scope and apply a program 3 to it. How did you do that? 4 MR. VINCENT: Mark Cimock, our mechanical 5 lead. 6 MR. CIMOCK: This is Mark Cimock, 7 mechanical lead with NMC. What you are saying is 8 true. We started out with PNIDs primarily for the A-I 9 work and scoping which is very conducive to and even 10 some A-3. We had not originally done a spaces 11 approach but we had originally used a couple criteria 12 that we changed in terms of duration and distance.
13 When we went back, the way that we pretty 14 much did that, one thing that helped us considerably, 15 as Bob pointed out, we've all been with the plant for 16 a long time and the major leads involved know the 17 plant quite well. We were able to do a couple things. 18 One is that we did sorts of our equipment 19 database to try to find out what rooms various 20 components existed in and if there was any other item 21 that showed up in that room automatically got put in 22 and we would identify what all those specific 23 components were. We would connect the dots, if you 24 will, between them to include the piping. 25 Then we did a final check basically that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 37 1 looked for any room that we identified wasn't in scope 2 we would walk it down to ensure that there wasn't 3 anything there just to make sure there's no problems 4 with the equipment database.
We are able to do it 5 with a combination of looking at the paper, looking at 6 the equipment database, and filling in with selective 7 walk-downs.
8 As far as how we showed it on the 9 drawings, that did create some confusion sometimes 10 because sometimes the color would stop in the middle 11 of the pipe and then would continue.
There were 12 questions that came out of the RAIs and the audits as 13 to why did this stop here. It was typically because 14 that's where changed areas and changed buildings or 15 rooms. 16 CHAIRMAN SIEBER: When we get to the 17 Region III discussion of what went on, I'm going to 18 ask the same question.
Was the documentation that the 19 licensee provided to you to demonstrate that scoping 20 was properly done, was it clear what was in scope and 21 what was not based on the documents that you looked 22 at? You can wait until it's your turn to answer that. 23 Make a note of that because I think it's important.
24 I think it's an opportunity to make a mistake. Okay. 25 Thank you very much. Appreciate it. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 23444 433 38 1 MR. BROSCHAK:
This is John Broschak.
If 2 it's all right, I'll get back to the presentation.
I 3 don't feel that we've been detailed but I'll keep to 4 the script at this point. 5 CHAIRMAN SIEBER: I'll try harder next 6 time. 7 MR. BROSCHAK:
I would like to go over a 8 few technical issues that we thought would be of 9 interest to the Subcommittee and address them 10 directly.
Those issues will be pressurized thermal 11 shock, intergrandular separation, also known as 12 underclad cracking, and some discussion of Generic 13 Safety Issue 191, or the PWR Sump Performance Issue. 14 For pressurized thermal shock Palisades is 15 projected to reach the screening criteria in 2014 16 using the existing rule in 10 C.F.R. 50.61. We have 17 known this for over 10 years and* have employed 18 aggressive flux reduction strategies through the use 19 of ultra-low leakage cortizines to minimize the impact 20 of that flux influence on reactor vessel 21 embrittlement.
22 We have also participated actively with 23 NRC research programs developing updated methodologies 24 for analyzing this issue and evaluating it. We have 25 alternatives available to manage the issue for the NEAL R. GROSS COURT REPORTERS AND TRANSCIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344433 39 1 period of extended operation.
We are also aware of 2 proposed rulemaking to 10 C.F.R. 50.61 which may 3 preclude the need for a plant specific management 4 strategy but we are not counting on that because we 5 have alternatives that we will implement.
6 CHAIRMAN SIEBER: How many capsules do you 7 have left? 8 MR. BROSCHAK:
I'll refer to John 9 Kneeland, our TLAA Lead. 10 MR. KNEELAND:
This is John Kneeland, NMC, 11 Palisades.
We have three what we call wall capsules 12 remaining in the reactor vessel. They have about a 20 13 percent lead factor on what the vessel would see. We 14 also have one that is called a thermal capsule which 15 sits above the core and does not get the fluence.
16 DR. SHACK: Suppose you got the rule 17 change and the screening criteria went up? Would you 18 let a few more neutrons leak out? Does the low 19 leakage core really inhibit your operation?
20 MR. KNEELAND:
This is John Kneeland 21 again. It is a cost and we would take that into 22 account but we would have to evaluate that against how 23 long we want to operate the vessel. 24 CHAIRMAN SIEBER: In effect, the low 25 leakage cores require more fuel and more expensive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (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 40 fuel management techniques.
What you are paying for is neutrons that you would otherwise expend into the vessel wall. It seems to me that the balance between the margin that you have in core analysis space and your ultimate power level versus the fluence that you put to the vessel wall. It is manageable but it does cost money to do that. MEMBER WALLIS: Ultra-low leakage sounds impressive.
By how much is it reduced from what it was before? MR. KNEELAND:
This is John Kneeland again. We have reduced it at least in half. MEMBER WALLIS: It's significant.
Ultra low sounds -MR. KNEELAND:
By ultra-low we mean we can't do a whole lot more. CHAIRMAN SIEBER: You would be surprised what you can do when you have to. MEMBER WALLIS: What are these alternatives you mentioned here? MR. BROSCHAK:
We can use site specific material sampling and analysis and using the existing master curve methodology to develop a pressure temperature curve that we could use for the period of extended operation.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON, D.C. 20005 (202) 234-4433 (202) 234-4433 41 1 MEMBER WALLIS: You have scoped that out 2 and satisfied yourselves that would work out okay? 3 MR. BROSCHAK:
Yes. 4 MEMBER MAYNARD: What are you using now to 5 justify 20 additional years of operation.
Take it 6 from 2011 to 2031, I guess. I'm not sure what I'm 7 hearing here, whether you are taking a position were 8 there alternatives available to us or whether you're 9 saying this justifies operation now. We do have other 10 alternatives available to us. 11 MR. BROSCHAK:
The rule requires us to 12 submit our plan three years prior to the expiration of 13 existing license or the time of reaching the screening 14 criteria.
15 CHAIRMAN SIEBER: There are a couple of 16 things that are the issue here. The question is will 17 you exceed the screening criteria before the end of 40 18 years? Then part two of that question is will you 19 exceed it at the end of 60 years? If so, can you 20 manage the fluence or do you go to the alternative 21 calculation methods? What space are you in right now 22 with that vessel? 23 MR. VINCENT: Where we sit currently we 24 will not exceed the screening criteria by the end of 25 the current 40-year license.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4433 42 1 CHAIRMAN SIEBER: Okay. 2 MR. VINCENT: If we took no action, we 3 would exceed the screening criteria during the 4 extended operating period. We understand the actions 5 that will need to be taken. We will manage those 6 actions so in license renewal space we are really 7 talking about option 3 which is the issue will be 8 managed for the extended operating period. 9 We can't say today what choice we will 10 make about which options we will implement.
We know 11 those various technical options are available in the 12 rule change. If it continues on the commissioner 13 approved rulemaking schedule, that will give us 14 another alternative.
15 CHAIRMAN SIEBER: Let's assume that 16 doesn't occur. That doesn't shut you off but it 17 narrows the options we have. Right? 18 MR. VINCENT: Clearly the methodology that 19 the rule bases its limits on is fixed in the rule so 20 to depart from that methodology will require an 21 exemption from that rule. The exemptions could be 22 based, as John mentioned, on master curve technology 23 which has been implemented at a couple of other 24 plants. 25 It's not a new technology to the industry.
NEAL R. GROSS. COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202)234.4433 WASHINGTON.
D.C. 20005 (202) 234-44 433 43 1 There may be some other technical alternatives 2 including the safety analysis that the rule requires 3 to justify continued operation beyond the acceptance 4 criteria embedded in the rule. There are analytical 5 options that may involve exemptions to the rule. 6 MEMBER WALLIS: You could reduce power. 7 You could put in a call which is so low leakage that 8 it actually produces less power than you produce 9 today. 10 MR. VINCENT: Lower-power core is 11 certainly an alternative, yes. 12 MEMBER BONACA: You will have to submit a 13 plan by 2008? 14 MR. BROSCHAK:
2011. 15 MEMBER BONACA: 2011. Oh, three years 16 before you reach -17 MR. BROSCHAK:
Right. 18 MEMBER BONACA: Okay. So you do have time 19 to that point. By the time you are walking through 20 license renewal you have to have a plan. 21 MR. BROSCHAK:
Correct.
22 MEMBER MAYNARD: Even though you get a 20 23 year extension to the license, that still does not 24 authorize you to operate outside the rule. If all 25 these alternatives fell apart, you wouldn't be allow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 44 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 to operate.
MR. BROSCHAK:
Right. CHAIRMAN SIEBER: That's the same condition they are in right now. If you don't meet the criteria, it doesn't make any different how long your license is, you shut down. MEMBER MAYNARD: I think it' s important to note getting the license renewal doesn't authorize operation outside of safety limits or regulations.
CHAIRMAN SIEBER: Another quick question that you can just give me a number for. In order to calculate the integrated fluence to the vessel you have to make an assumption about the capacity factor. What assumption did you use regarding your capacity factor from initial operation until now and what assumption are you using from now until the end of life? MR. VINCENT: John Kneeland, would you like to -MR. KNEELAND:
This is John Kneeland again. We used our actual operating capacity for the past which has been somewhat less than we assume for the future. For the future we're assuming approximately a 90 to 91 percent capacity factor. It's not as much as we'd like. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4 433 45 1 CHAIRMAN SIEBER: It's been increasing.
2 MR. KNEELAND:
The last several years have 3 been very good. 4 CHAIRMAN SIEBER: I'll just leave it at 5 that. 6 MEMBER WALLIS: On the big NRC research 7 program on PTS, wasn't Palisades one of the cuts they 8 made or am I forgetting something?
9 MR. VINCENT: No, Palisades is one of the 10 participants.
11 MEMBER WALLIS: What did they conclude 12 about PTS for Palisades in the light of their most 13 recent work? 14 MR. KNEELAND:
This is John Kneeland 15 again. I have only seen a draft of the study so I 16 can't say for sure what the conclusion is but my 17 understanding is that PTS would not be considered an 18 issue. 19 MEMBER WALLIS: Maybe there is some 20 incentive for NRC to finish up that work. 21 CHAIRMAN SIEBER: Actually, there is more 22 than one plant in that study. I think the conclusion 23 was the same for all. 24 MEMBER WALLIS: It was a very thorough 25 study. It was very impressive to us. We had some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 46 1 comments on it and we were hoping that it would come 2 formally issued and be useful. We still hope that. 3 CHAIRMAN SIEBER: That would be good. 4 MR. VINCENT: We do, too. 5 MR. BROSCHAK:
This is John Broschak.
6 CHAIRMAN SIEBER: And the licensee.
7 MR. VINCENT: NUREG is still not a change 8 in the regulations.
9 CHAIRMAN SIEBER: Right. 10 MEMBER WALLIS: But it might lead to a 11 change in the regulations.
12 MR. VINCENT: Yes, they are working on 13 that. 14 CHAIRMAN SIEBER: Continue.
15 MR. BROSCHAK:
This is John Broschak 16 again. This has fun but we'll move on to the next 17 technical issue. Intergrandular separation or 18 underclad cracking is the phenomenon that was 19 identified in the 1970s and was dispositioned at that 20 time as being acceptable for a 40-year operation 21 period. 22 Westinghouse specific plants has produced 23 a WCAP where they have provided a methodology to NRC 24 and shown acceptable results in terms of crack growth 25 or any effect on the reactor vessel for those plants. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344433 47 1 Palisades has been evaluated using the 2 same mythology and we have produced results that show 3 that there is little or no crack growth. over a 60-year 4 period and that any potential cracks would have no 5 effect on the structural integrity of the reactor 6 vessel. Those results have been reported to the NRC 7 for review and acceptance.
8 MEMBER ARMIJO: The no-crack growth issue, 9 was that by analysis, strictly by analysis, or was 10 there any measurement made? 11 MR. BROSCHAK:
I'll defer to John 12 Kneeland.
13 MR. KNEELAND:
John Kneeland again. It's 14 both. We had in-service inspection results that have 15 shown that some of the cracks that we did see have not 16 propagated at all between the inspections.
We also 17 did a fatigue crack growth evaluation that is part of 18 the WCAP. 19 MEMBER ARMIJO: What was the period of 20 time between those inspections?
21 MR. KNEELAND:
Twelve years, 22 MR. BROSCHAK:
John Broschak.
Those 23 inspections were 1983 and in 1995. 24 CHAIRMAN SIEBER: Now, this item is the 25 confirmatory item -NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-44 433 48 1 MR. BROSCHAK:
Correct.
2 CHAIRMAN SIEBER: -- that's listed in the 3 SER so you have determined that the WCAP is applicable 4 to your plant and you sent that response into the 5 staff a week ago? 6 MR. VINCENT: Yes, it was about a week 7 ago. 8 CHAIRMAN SIEBER: So the staff hasn't had 9 an opportunity to determine whether you meet the 10 requirement or not. 11 MS. LUND: This is Louise Lund. The staff 12 is still reviewing it so we got it in house and it's 13 been sent over to the technical staff. 14 CHAIRMAN SIEBER: Okay. It's important 15 that we know what the status is. It is particularly 16 important that it be resolved before we meet again. 17 I'm glad that the applicant is doing the work to make 18 that happen and perhaps there will be a good outcome 19 from the staff's review. There will be an outcome 20 from the staff's review. Okay. 21 MR. BROSCHAK:
John Broschak, technical 22 issue No. 3, Generic Safety Issue 191, Assessment of 23 Debris Accumulation on PWR Sump Performance.
This 24 Generic Safety Issue is applicable to all pressurized 25 water reactors and the methodology defined in Generic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234.4433 49 1 Letter 2004-02 is being implemented at Palisades in 2 accordance with the requirements of that Generic 3 Letter. Palisades will be installing a passive 4 strainer system in addition to any other required 5 modifications.
6 MEMBER WALLIS: That's what you have 7 already, isn't it? 8 MR. BROSCHAK:
Correct.
9 MEMBER WALLIS: So you are going to 10 install a different one? 11 MR. BROSCHAK; The methodology and the 12 assumptions that are now required to fully address the 13 issue as described in the Generic Letter and in the 14 NEI guidance documents require a different type of 15 strainer system. 16 MEMBER WALLIS: How much bigger will it 17 be? I assume it's going to be bigger. 18 MR. BROSCHAK:
It's going to be much 19 bigger. 20 MEMBER WALLIS: By how much? Is it a 21 factor of 10 or 100 or something like that? 22 MR. BROSCHAK:
Between a factor of 80 and 23 100. 24 MEMBER WALLIS: So you're putting in about 25 as big a strainer as you can fit in. Is that it? NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44 433 50 1 MR. BROSCHAK:
We're putting in the size 2 strainer necessary based on the results of the 3 methodology.
4 MEMBER WALLIS: A hundred times as big as 5 it was before? Do you remember how big it was before? 6 MR. BROSCHAK:
The Palisades arrangement 7 is underneath of the reactor vessel and has two trains 8 with subscreens.
The approximate size of the 9 subscreens is 50 square feet. 10 MEMBER WALLIS: But they were tiny before. 11 MR. BROSCHAK:
They are tiny right now. 12 CHAIRMAN SIEBER: Smaller than they will 13 be. 14 MEMBER WALLIS: Okay. So they are going 15 to something like 5,000 square feet. 16 MR. BROSCHAK:
The order of 3,000, 17 CHAIRMAN SIEBER: Just for the record, I 18 would point out that this issue would be there zhether 19 you were in license renewal space or not, as well as 20 the reactor vessel embrittlement issue. There is 21 nothing that specifically ties this to license 22 renewal. It is good that you tell us what you are 23 doing but it really doesn't have a bearing on the 24 outcome. You've got to do it whether you get your 25 license renewed or not. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (20 234-4433 WASHINGTON.
D.C. 20005 (202) 234-*33 51 1 DR. SHACK: Is the installation primarily 2 cal-sil or a mix? What kind of fraction of cal-sil 3 versus fiber glass? 4 MR. BROSCHAX:
Palisades has a large 5 amount of cal-sil and a large amount of fiber. 6 MEMBER WALLIS: Are you going to take out 7 the cal-sil? 8 MR. BROSCHAX:
At this time we are not 9 planning to take the cal-sil out. 10 MEMBER WALLIS: It is something you might 11 consider doing if you had to because cal-sil is one of 12 the offenders in subscreen blockage.
13 MR. BROSCHAK:
I agree with you totally 14 that the debris that's in PWR containments are 15 offenders in terms of sub-blockage.
The complexity of 16 the issue in terms of particulate or fiber has become 17 quite a fascinating science in terms of understanding 18 exactly how the phenomenon works so I can tell you 19 from the results that I've seen on specific testing 20 that it does get down to a site specific evaluation of 21 your particular mix of debris. 22 That is how we' have these programs 23 structured now. We will make the appropriate removal 24 of insulation and sizing of screens and flow rates 25 that are necessary to meet the requirements in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202M 2344433 WASHINGTON.
D.C. 20005 (202)234-4 433 52 1 Generic Letter. 2 MEMBER WALLIS: Any idea of the volume of 3 insulation that comes off in a large break LOCA? 4 MR. BROSCHAK:
I do but I would not want 5 to quote that in this setting off the top of my head. 6 That has all been submitted on the docket. 7 MEMBER WALLIS: Okay. We' ve heard numbers 8 of several thousand cubic feet. Yours maybe is one of 9 the plants that has a lot. 10 MR. BROSCHAK:
Those are very qualitative 11 terms and I would defer to what has already been 12 submitted on the docket. 13 CHAIRMAN SIEBER: Almost as bad as ultra 14 low leakage.
15 MEMBER WALLIS: There's nobody here who 16 knows the number and more than just a vague statement?
17 You don't have an expert here who knows how much? 18 MR. BROSCHAK:
Since this is not a license 19 renewal we didn't bring those experts with us. 20 MEMBER WALLIS: Something we have to be 21 concerned about if we are going to allow the plant to 22 keep operating.
23 MR. BROSCHAK:
As I have stated here, we 24 will be in full compliance with the Generic Letter 25 requirements by the end of 2007. There's no question NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234.4433 WASHINGTON, D.C. 20005 (202) 234-4433 53 1 in my mind. We understand that this is independent.
2 MEMBER WALLIS: But you will claim to be. 3 MR. BROSCHAK:
No, we will be. 4 MEMBER WALLIS: If the staff knows what 5 those requirements are. You've got to show that 6 you're in compliance which is a very vague sort of 7 statement.
You will make a case and then someone is 8 going to say whether it's good enough or not. I know 9 you intend to be in compliance.
10 MR. BROSCHAK:
We tend to be our own worse 11 critics and make sure that we can make that case to 12 any external stakeholder.
As long as I'm the engineer 13 director we will make a strong case. 14 DR. SHACK: You're going to do a manual 15 injection of sodium hydroxide then to control your 16 sump pH? That will be the intent there rather than 17 doing it without pH control? 18 MR. BROSCHAK:
The Subcommittee has 19 effectively got me off my presentation so I will jump 20 back in. 21 The third bulleted item is to note that 22 due to the information notice on potential chemical 23 effects of the interaction of trisodium phosphate with 24 cal-sil insulation, Palisades is taking prompt and 25 aggressive action to remove trisodium phosphate until NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.Q 20005 (202) 2344 433 54 1 the final solution from the Generic Letter is in place 2 in the fall of 2007. That license amendment request 3 involves removal of trisodium phosphate and 4 implementation of provisions for manual injection of 5 sodium hydroxide.
6 It is worthy to note to the Subcommittee 7 that we have demonstrated through calculation that no 8 buffer is required to meet both off-site dose 'and 9 control room limits and, of course, with federal 10 regulations.
We are choosing to inject the sodium 11 hydroxide to address potential corrosion issues. 12 MEMBER WALLIS: You have aluminum in this 13 part? 14 MR. BROSCHAK:
There is some aluminum in 15 the containment, yes. 16 MEMBER WALLIS: Sodium hydroxide has 17 interactions with aluminum that produces stuff. 18 MR. BROSCHAK:
Correct.
19 MEMBER WALLIS: And affects screens.
20 MR. BROSCHAK:
And that has all been -21 MEMBER WALLIS: We don't know much about 22 it. We know it's in effect but we don't know how to 23 predict it. It would be interesting to see how you 24 are going to predict it. 25 MR. BROSCHAK:
You're right. In addition, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (2021 2344433 WASHINGTON, D.C. 20005 (202) 234-44 133 55 1 an alternate buffering system will be installed as 2 part of the overall solution to the Generic Letter by 3 the fall of 2007. In other words, we do not intend at 4 this time to go back to trisodium phosphate.
5 MEMBER WALLIS: You're looking at a 6 different buffering system all together which would 7 not necessarily be sodium hydroxide.
8 MR. BROSCHAK:
Correct. There is a lot of 9 activity going on with Westinghouse owners group right 10 now to identify more acceptable buffering agents and 11 we would intend to use the output of that work, 12 evaluate for our plan application, and then implement 13 the appropriate item. 14 DR. SHACK: So your license amendment 15 hasn't been approved yet? 16 MR. BROSCHAK:
That license amendment is 17 under review by the staff at this time. 18 MEMBER WALLIS: Is it a fairly simple to 19 take out TSP. It's just sort of sacks of something in 20 containment.
You just take it out. Is it a fairly 21 simple matter to take it out? 22 MR. BROSCHAK:
Yes, sir. In nuclear power 23 some things are simple. This one in particular
-24 MEMBER WALLIS: Removing things from 25 containment can be very tricky but this is a simple NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 2344433 56 1 one. 2 MR. BROSCHAK:
These are fairly large 3 baskets that contain the trisodium phosphate and they 4 need to be picked up and removed and that's -5 MEMBER WALLIS: It's not as if they are 6 inaccessible or anything.
7 MR. BROSCHAK:
No. In fact, we made 8 provisions during our last refueling outage to put 9 them in a lower dose area so that it will be easier to 10 remove them. 11 MEMBER BONACA: I have a question on the 12 inaccessible non-EQ medium voltage cables. I know you 13 have committed to essentially the process of GALL. 14 One of the inspection reports show that you had 15 manhole flooded and that you did not really find it, 16 the NRC inspectors found it. It's hard to understand.
17 I mean, so you do have a program for license renewal? 18 Do you have a program now that you are going to 19 implement?
20 MR. VINCENT: Yes, we do have a program 21 now. Larry, would you like to talk about underground 22 cables? 23 MR. SEAMANS: Yes. This is Larry Seamans, 24 Palisades license renewal. Just prior to the NRC 25 inspection as part of the license renewal I went out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4 433.° 57 1 and looked at these manholes and I at that time found 2 water. There are three manholes.
They are all tied 3 together as far as a drain system. At that point I 4 had the water removed. We did no more until the NRC 5 came on site. 6 At that time -- well, I'm sorry. We did 7 initiate corrective action document at that time also 8 besides pumping it out to get the long-term corrective 9 action into place. A little over a month later the 10 NRC was on-site. We again looked at the holes. The 11 water in there was significantly less but subsequent 12 to that we have initiated corrective action that 13 initiated a periodic activity that removes the water 14 monthly. After the second removal of the water we 15 have seen no more accumulation of water in the monthly 16 reviews.
17 Besides that, the plant about 10 years ago 18 initiated testing of all of these cables safety 19 related, even non-safety related, medium voltage 20 cables that go through these manholes and those are 21 tested on a frequency of every other refueling outage 22 currently.
The commitment for license renewal is that 23 we will test them at least every 10 years. It looks 24 like currently we are on about an every four or five 25 year frequency.
That is what we do currently.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4 t433 58 1 CHAIRMAN SIEBER: How do you test? 2 MR. SEAMANS: Larry Seamans again. The 3 way we test those is with the MEGER. In the future we 4 are actually going to do a MEGER and a polarization 5 index. We have also stated that if there is some 6 other type of testing that comes out and is developed 7 and is proven that we will commit to doing that new 8 type of testing also. 9 MEMBER WALLIS: I think it's a very old 10 technique.
My dad used to do that. 11 MR. SEAMANS: But we have some good 12 results from that, too. 13 MEMBER WALLIS: Lots of your commitments 14 have to do with inspections of varied tanks and things 15 like that. Are you satisfied that you got the 16 technology to do that or are you looking for some 17 improved methods? 18 MR. VINCENT: Bob Vincent. I think in 19 general we are not looking for any new technology to 20 support any of our new programs with the exception 21 that one of the commitments relates to reactor 22 internals.
Currently we are doing visual inspections 23 that are required routinely under ASME Section 11, but 24 we are also -- our commitment is to monitor what is 25 happening with the MRP. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4433 59 1 When the industry recommendations come out 2 on the appropriate future testing or inspection 3 program for internals, we will provide -- we will 4 revise our internal program and submit that to the 5 staff for review. There are only a couple of 6 commitments that are similar to that one. 7 MEMBER WALLIS: There is an industry-wide 8 approach to that. 9 MR. VINCENT: That's correct.
10 MEMBER WALLIS: You are satisfied that you 11 can get enough measurements that are accurate enough 12 and all that? 13 MR. VINCENT: Buried tanks -- Mark, would 14 you like to talk about buried tanks? 15 MR. CIMOCK: This is Mark Cimock, 16 mechanical lead, NMC. We only have one buried tank 17 part of our program which is actually in a vault. 18 It's our fuel source tank. Buried tanks really isn't 19 an issue. The one that we have, like I say, is in a 20 vault. It does have dry compacted sand around it. It 21 is a double-walled tank that has moisture detection.
22 Buried tanks really isn't a problem at Palisades.
We 23 do have a Buried Services Program but that gets into 24 buried piping and it may be another subject all 25 together.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 2344 433 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 60 DR. SHACK: Just in your environmental impact statement you sort of evaluated a number of severe accident management alternatives that had positive values. You implemented one of them that gave you the big benefit. Are you planning on implementing any of the others? MR. HARDEN: This is Paul Harden, site vice president.
With the severe accident management alternatives the station is committed and will continue to evaluate the various alternatives and the benefit that they provide.
However, the list as it is, the benefit provided is each one individually, as you implement one you then have to go back and revisit all the others to reevaluate the benefit because, for example, the supplemental diesel generator that was installed, the benefit for many others that we listed is actually negated by installation of that one so we just completed implementation of the supplemental diesel generator.
We are committed and we have budget in our future budgets to continue to evaluate other alternatives and what benefit they are going to provide and to look for additional ways to reduce the overall plant risk profile.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (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 61 MEMBER MAYNARD: One of those that I didn't understand clearly was on the turbo driven aux feedwater pump. You had installed a turbine driven aux feedwater pump but apparently the one that you have in there can't be operated manually.
You can't control the flow manually so one of the SAMAs was to install a control system for that where you could control it manually.
Did I misread that? MR. VINCENT: Brian Brogran, our PRA lead, will address it. MR. BROGAN: Brian Brogan from PSA. Simply what we are going to do is proceduralize throttling that turbine driver during the station blackout of that. We have controls in place. What we have to do is just match flow with decay heat. It's something that we have in other pieces of procedures that address Appendix R and other issues but we want to formalize it for this specific application.
MEMBER MAYNARD: Okay. So the equipment is there. You're talking about procedures and criteria.
MR. BROGAN: That's correct. It is a simple thing to do and we want to proceed with that action.CHAIRMAN SIEBER: So y NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON.
D.C. 20005 ou're going to MM234-4433 2344433 62 1 throttle the steam valve into the program? 2 MR. BROGAN: Correct.
3 CHAIRMAN SIEBER: In what parameter will 4 you look at that is available at the steam valve to 5 tell you how much to throttle?
6 MR. BROGAN: We are going to have pressure 7 indication up stream and down stream and we should be 8 able to correlate that back into the requisite flow. 9 CHAIRMAN SIEBER: What you are really 10 trying to achieve is the right level. 11 MR. BROGAN: Correct.
12 CHAIRMAN SIEBER: Not the right flow and 13 not the right pressure but level. 14 MR. BROGAN: We want to maintain level. 15 CHAIRMAN SIEBER: Whoever is operating 16 that valve won't know what the level is. You'll have 17 to be on the telephone or something.
Is that correct? 18 MR. BROGAN: Yes, that's correct.
19 CHAIRMAN SIEBER: And you aren't going to 20 do anything about that. That's a hard thing to do. 21 MR. HARDEN: If I can, this is Paul Harden 22 again. That list of SAMA candidates, those are 23 concepts at this point in time. The only one that has 24 been taken through the study phase to in-depth layout 25 all the details and what would be required is the one NEAL R. GROSS COURT REPORTERS AND TRANSCRrBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 63 1 we just finished implementation of with the 2 supplemental diesel generator.
3 For each one of those, as Brian and his 4 staff do the work to now go back and reevaluate the 5 candidates, we'll then take it through a study phase 6 to scope out what exactly would it take to ensure 7 ourselves we can do that and- do that safely. Then 8 once we understand what that would take evaluate the 9 cost benefit from the risk reduction we would gain. 10 CHAIRMAN SIEBER: Okay. I presume you 11 would prefer I not help you design it. 12 MR. HARDEN: Tell them it's hard to do. 13 CHAIRMAN SIEBER: Any other questions from 14 the Committee?
If not, thank you very much for your 15 presentation.
What I would like to do is start into 16 the SER overview and perhaps do the scoping and 17 screening results. Then we can take a break after 18 that and then we'll come back and do the on-site 19 inspection results.
20 MS. LUND: Thank you. I'm going to go 21 ahead and turn this over. Thank you for the Palisades 22 license renewal staff to give their presentation and 23 I'm going to turn it over to Mr. Juan Ayala who is the 24 project manager for the Palisades review with the NRC 25 staff. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344 433 64 1 MR. AYALA: Good afternoon.
My name is 2 Juan Ayala .and I am the project manager for the 3 staff's review of the Palisades license renewal 4 application.
Joining me today I have Patricia 5 Lougheed who is the inspection team leader from Region 6 III. Also, I have Robert Hsu who is the audit team 7 leader. Also present in the audience is members of 8 the technical staff that are here to answer any 9 questions I cannot answer for you. 10 These are the topics that we'll be 11 covering today. I'll start with an overview of the 12 plant and the application followed by discussion of 13 the scoping and screening results. I'll turn it over 14 to Patricia who will talk about the license renewal 15 inspection and then I'll take over and talk about the 16 aging management review and the time-limited aging 17 analyses.
18 The license renewal application was 19 submitted by letter dated March 22, 2005. Palisades 20 is a combustion engineering PWR with dry AMB 21 containment and illustrated at 2565 MWth and 865 MWe. 22 MEMBER WALLIS: You have a different 23 number from what they have. 24 MR. AYALA: The number that the applicant 25 had is net capacity.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (20 234-4 433 65 1 MEMBER WALLIS: 820 they have. 2 MR. AYALA: That number is net capacity.
3 This is what it's rated at. 4 MEMBER WALLIS: They actually operate it 5 at 820. 6 MR. AYALA: They operate at 865 and then 7 they use -- I guess if the applicant can answer that 8 a little bit more. 9 MR. KNEELAND:
This is John Kneeland.
820 10 is the maximum that we put out to the grid so that 865 11 minus in-house loads equals the 820. 12 MEMBER WALLIS: Ah, okay. It's just nice 13 to have the same number presented by the staff and the 14 applicant.
15 MR. AYALA: Okay. I'll continue.
Once 16 again, I'm Juan Ayala. The operating license DRP-20 17 expires March 24, 2011 and the plant is located five 18 miles south of South Haven, Michigan.
19 This slide right here shows that the SER 20 was issued June 1, 2006, with no open items and one 21 confirmatory item that I'll talk about a little bit 22 later on. The license conditions are the standard 23 license conditions for all license renewal 24 applications that have gone through.
25 There were 174 RAIs issued as was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 2344433 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 66 mentioned earlier. That is consistent with the review from some of the other plants that have gone through renewal. There were also 412 questions asked during the AMR and AMP audits. MEMBER WALLIS: How do you keep track of questions?
Do you have a transcript or something?
MR. AYALA: We have all the questions
-MEMBER WALLIS: Are they written down? CHAIRMAN SIEBER: They are all written down. MR. AYALA: All the questions are written down and the applicant has a database that when we ask a question they keep track of it and they provide those responses to us. MEMBER WALLIS: You also ask verbal questions?
MR. AYALA: Yes, we do. Those verbal questions are not captured in the 412. It's just the questions that we provide in a written format that are captured here. MEMBER MAYNARD: The applicants usually do a pretty good job of documenting and keeping track of all the questions that are asked. MEMBER WALLIS: It would be good to know that you have 412 adequate answers as well. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 2344433 67 1 MR. AYALA: Right. All of these -2 MEMBER WALLIS: Did you get 412 adequate 3 answers? 4 MR. AYALA: Yes, we did. 5 MEMBER WALLIS: Okay. Thank you. 6 CHAIRMAN SIEBER: Or we wouldn't be here. 7 MR. AYALA: As Louise mentioned earlier, 8 the application is 95 percent consistent with GALL 9 Rev. 1. The application was submitted using Rev. 0 10 and we did reconciliation with the September Rev. 1 11 and that helped us in the review process. There were 12 some minor components that were brought into scope and 13 we will address those at the appropriate time. This 14 slide here shows the dates of the audits and regional 15 inspection.
16 During the scoping and screening 17 methodology the audit team reviewed the current 18 licensing basis for the aux feedwater system and 19 determined that the aux feedwater pump pipe insulation 20 was not included in the scope of license renewal. The 21 applicant didn't include it and as a result of the 22 staff's review, the applicant brought this component 23 to scope of license renewal.
24 In Section 2.2, plant-level scoping, no 25 omission of systems or structures were found in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234.4433 68 1 scope of license renewal. For mechanical system the 2 staff performed 100 percent scoping review of 29 3 mechanical systems. During the scoping and screen 4 review the staff was also on site and performed a 5 review of some of these mechanical systems.
6 This aided the staff in answering a lot of 7 the questions and reducing the need for RAIs. As a 8 result of this, very few items -- I have zero items 9 there. I was just talking to Patricia and she said 10 there were two items that refer to the regional 11 inspection team and she will address those in her 12 presentation.
13 Some of the components that were brought 14 into scope are listed on the slide here. There are 15 quite a few so I'll just show them up there and if you 16 have any questions on any, I can go into any of those. 17 MEMBER BONACA: There are-not a few. For 18 example, why are the feedwater heaters not included?
19 MR. AYALA: The feedwater heaters -20 MEMBER BONACA: Is it a issue of 21 methodology that you didn't capture it or is it just 22 an individual judgment of the engineer that they were 23 not being scoped? 24 MR. AYALA: I see that the applicant has 25 her hand up and I think they want to say something so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 2344433 69 1 let me turn it over to them. T 2 MR. SEAMANS: For the feedwater heater 3 it's feedwater heater 1A and IBravo. They were in 4 scope if you looked at the drawings.
It happened to 5 be that in the description that was in the system 6 description, it did not have them in there. As far as 7 the components themselves, they were in a list of 8 equipment but somehow we missed it in the description 9 and that is what he's talking about. That is where we 10 missed adding that to that description.
11 MEMBER BONACA: The bottom line is that 12 you don't feel that these exceptions here mean that 13 methodology
-14 MR. AYALA: There were several examples in 15 here where they were in scope in the drawing but they 16 weren't mentioned in the application and the 17 description so after talking to them they supplemented 18 the application and included a description for these 19 components in there. Since they were through RAIs, 20 that's why I have them listed up here. 21 MEMBER WALLIS: Air compressors are active 22 elements, aren't they? It's just the casing or 23 something that is in license renewal? 24 MR. AYALA: Yes. Active components are 25 not screened out. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 202) 2344, 433.o 70 1 MEMBER WALLIS: When you say ai4 2 compressors, what do you mean? Aren't they active 3 components?
4 MR. AYALA: Yes. They screened out the 5 active components per NEI 95-10. What was screened 6 were the housing and -7 MEMBER WALLIS: Housing? 8 MR. AYALA: Right.- Moving on, in Sections 9 2.4, Containment, Structures, and Supports, and 10 Section 2.5, Electrical and Instrumentation and 11 Control, there were no omissions of components in both 12 of these sections.
13 In conclusion to the scoping and screening 14 methodology summary, it is the staff's determination 15 that the applicant's scoping methodology meets the 16 requirements of 10 C.F.R. 54.4. 17 CHAIRMAN SIEBER: Okay. 1 think this is 18 a -- unless there are questions from the members, this 19 would be a good time to take a break so let's do that 20 and come back at quarter after 3:00. 21 (Whereupon, at 3:01 p.m. off the record 22 until 3:21 p.m.) 23 CHAIRMAN SIEBER: I would like to 24 introduce from Region III Patricia Lougheed who was in 25 charge of the inspection process for this. Patricia.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234.4433 71 1 MS. LOUGHEED:
Thank you. As Dr. Sieber 2 said, my name is Patricia Lougheed.
I am the Lead 3 Inspector for License Renewal for Region III which is 4 the region which has Palisades in it. I'm not used to 5 operating the computer so you have to -6 As is normal for license renewal 7 inspections we did a two-week inspection that combined 8 scoping, screening, and aging management.
We 9 scheduled these inspections somewhat to support NRR 10 reviews, although we ended up doing this before 11 Monticello which you all looked at a couple of months 12 ago so this has been a long while since I've actually 13 been involved with Palisades.
14 As is usual with the Region III 15 inspection, I had a team of five very experienced 16 inspectors.
We found that this has been a benefit for 17 the Region III inspections that we have used. The 18 same people consistently throughout the license 19 renewal inspections so that we know that from one 20 plant to another that we are looking at the same type 21 of things to the same depth. We did do it in 22 accordance with our inspection procedure.
23 Scoping and screening.
To start, I'll 24 have to admit this slide contains an error. I made 25 this from my exit slides actually while I was on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON, D.C. 20005 (202) 234-4433 72 1 vacation.
I did not have access to my inspection 2 report and I looked at the inspection report this 3 morning. We actually looked at 14 systems rather than 4 11. My team snuck a couple extra in on me from what 5 was in my original plan. 6 We did look at a combination of 7 electrical, mechanical, and structural systems with an 8 emphasis on plant physical walk downs and also on 9 those systems where we felt there was a safety, non 10 safety boundary where components would be in scope or 11 out of scope. 12 We weren't too worried that the folks in 13 NRR caught everything that was in scope. What we were 14 worried about were the ones where the boundaries were 15 rather nebulous particularly in the A-4 area of non 16 safety that could impact safety and that's where we 17 really concentrated our inspection efforts.
18 Basically I'm going to go into a little 19 bit more detail here than what is on the slide. The 20 systems that we found, there was one case in 21 electrical power where we found a component
-- couple 22 components that had not been scoped in. However, they 23 were active components so they automatically screened 24 out as soon as they were scoped in. 25 Juan had mentioned that there were a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202) 23444'33.o 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 73 couple areas that NRR did ask'us to look at. One of those had to do with the heating, ventilation, and cooling, particularly the penetration subcooling HVAC. That was an area that was out of scope and we looked at it and the reasons why that system was there and determined that it did not need to be in scope. We also specifically looked at the HVAC for the engineer safeguards and the auxiliary feedwater system because those are safety related systems and we wanted to verify that the cooling for them indeed was not needed. We had no problems with what the licensee had done. We also looked on the spent fuel pump cooling at the boron carbide panels and the boroflex panels to verify that those were appropriately screened in and that appropriate consideration was taken for the types of panels there were and the use of the boron. We had no problems with those. CHAIRKMA SIEBER: Let me ask a question..
When the licensee told us -- we asked the licensee a question about neutron absorbing panels and so forth and spent fuel pool and they indicated they did not take credit for boroflex.
If you don't take credit for it, would it be screened out? MS. LOUGHEED:
I think that some of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4 433 74 1 panels are screened out. I'm going to have to ask 2 Mark because it's been a while since I've looked at 3 Palisades.
4 CHAIRMAN SIEBER: Okay. 5 MR. CIMOCK: This is Mark Cimock with NMC. 6 The fuel racks are in scope for structural support of 7 the fuel rods but as far as the boroflex component of 8 them, they were not credited because they were not 9 considered in the criticality-analysis.
We actually 10 did credit some soluble boron and analysis of those. 11 The other panels that we did take credit for were the 12 boron carbide encased in stainless steel panels. 13 CHAIRMAN SIEBER: They are in scope. 14 MR. CIMOCK: And they are in scope. The 15 boron carbide themselves do have an antenna function 16 of neutron absorption and we've had some back and 17 forth in the RAI string. There's a long RAI string 18 but basically the end result was that we felt they had 19 no aging effect for current management but that we 20 were going to do some blackness testing to confirm 21 that both before the end of the current operating 22 period and within 10 years after the extended period 23 of operation.
24 CHAIRMAN SIEBER: Okay. Thank you. 25 MS. LOUGHEED:
Basically the other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344 433 75 1 question you had asked whether the regional inspectors 2 were able to clearly to see from the documents we 3 reviewed where the boundaries lay. We looked at a 4 number of different things when we were looking at 5 boundary.
The first thing is that from Palisades they 6 are kind of unique that I would say probably 99 7 percent of their equipment is in scope. 8 It seemed like everywhere we went things 9 were actually in scope. In fact, if you read the 10 inspection report there was one system that we chose 11 which was shut down cooling which other plants have 12 said, "That's non-safety related. It doesn't need to 13 be in scope." 14 In Palisades it was 100 percent in scope. 15 We looked at the drawings but we primarily were 16 relying on the system scoping documents.
What I 17 remember and what I just confirmed from the licensee 18 is that they are planning on taking the information, 19 or at least some of the information from those scoping 20 and screening documents I'm putting it into their 21 plant equipment database and that will be the official 22 way of telling what components are in scope for the 23 future rather than a marked-up set of drawings.
24 CHAIRMAN SIEBER: I have a question then 25 about that. As I recall, plant equipment databases, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 23444*33 76 1 in some places they call them Q lists or what have 2 you, it consist of components as opposed to lengths of 3 pipe being in the supports and things like that which 4 in a lot of plants are typically not in the plant 5 equipment database because it's not really equipment.
6 It's the stuff in between the pieces of 7 equipment.
What is in your plant equipment database 8 does it include all these long-lived passive 9 components and lengths of pipe and so forth that 10 typically aren't in most folks' equipment list? 11 MR. VINCENT: This is Bob Vincent. You 12 are correct. The equipment database really has all 13 the components that have tag numbers, ID numbers.
14 Clearly in license renewal we have commodities that 15 don't have tag numbers. While I can't tell you right 16 this minute how we are going to track things that we 17 have treated as commodities from an aging management 18 review perspective, clearly we have to define the 19 population that's in those commodities and capture 20 those. 21 Whether that's kind of a new component 22 type in an equipment database that we call a commodity 23 and have some definition or whether we use some other 24 mechanism for that we haven't decided yet. 25 CHAIRMAN SIEBER: So you really don't have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44 433 77 1 a system for doing it, right? 2 MR. VINCENT: Other than the reports that 3 define those commodities currently.
4 CHAIRMAN SIEBER: Drawings that are marked 5 up. 6 MR. VINCENT: Today that's true. 7 CHAIRMAN SIEBER: Let me ask then if you 8 look at your Section 11 ASME program, it deals with 9 the same kinds of things. It doesn't deal with 10 components.
It deals with lengths of pipe and hangers 11 and other structural members and things like that. 12 The drawings of significance to track all 13 that is usually isometric drawings and each piece of 14 pipe will have a line number on it between -- you 15 know, if it's a piece of pipe that is between 16 component A and component B, sump pump and the heat 17 exchanger or valve. You can track things for Section 18 11 purposes that way. Would you intend to do 19 something similar to that to track what is in scope 20 with regard to license renewal? 21 MR. VINCENT: What you are describing for 22 ASME Class 1, 2, and 3 is correct. We have those pipe 23 segments identified.
24 CHAIRMAN SIEBER: Well, you've got half 25 the job done. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 132 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44 433 78 1 MR. VINCENT: We clearly have those which 2 leaves non-safety related piping assets that we are 3 talking about. I can't tell you we are going to use 4 the same type of approach but we clearly have to 5 capture those and track those. 6 CHAIRMAN SIEBER: Some place along the 7 line somebody has to examine what you did with regard 8 to applying aging management that involves the 9 examination to specific systems. You need a way to 10 know, to walk into a room and say, "There's a pipe up 11 in the ceiling. It's in scope because it's on this 12 document," as opposed to reading some broad definition 13 some place and saying, "It must be in scope. I think 14 it's in scope," but it isn't written down any place. 15 MR. VINCENT: You're right. We absolutely 16 agree with that. We need a definitive reference to 17 show exactly what is and what is not. 18 Mark, do you want to add to that? 19 MR. CIMOCK: This is Mark Cimock. I 20 understand exactly what you're talking about. Right 21 now the way that this is controlled our scoping and 22 screening documents, AMR documents, program based 23 documents are still live. We've been updating them as 24 RAIs come in and as things change along the way. 25 What you are referring to is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20008 (202) 2344433 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 79 conversion to go forward method. We are still looking at some options and what you are seeing are very good points and there's a few ways we can do it. We haven't settled on the one. The way that we are currently doing it is basically all our AMRs, aging management review reports, and our scoping and screening reports were basically generated by a large database that we captured this all on. For these commodity groups like the pipe segments and stuff we have created equipment IDs, if you will, that are license renewal specific.
One option obviously is to load that in with a little more definition, as you were talking about, point A to point B. The way we currently do it we might have aux feedwater pipe carbon steel would be a commodity for pipe that is now -- which parts of that you look at the color-coded system drawing.
What we have to decide, and we haven't yet, it may be a combination of loading these things in with a broad description with the color-coded drawings to show you the details similar to what we have for ISI type of color-coded drawings.
Or it may be putting that intelligence into the equipment ID. We are still in a transition phase and we haven't finalized that yet but I can assure you that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-44¢33 1 80 1 will be very clear so that we know what we do have to 2 examine and what we don't. As Patricia said, in some 3 cases like in the aux building for a certain system 4 everything in the building so you say all aux building 5 piping. 6 CHAIRMAN SIEBER: That makes it easy. On 7 the other hand, not everything is like that. 8 MR. VINCENT: Right. It would be easier 9 probably for us if we were to put it in verbiages to 10 write exclusionary statements rather than 11 inclusionary.
12 CHAIRMAN SIEBER: I keep thinking in terms 13 not so much as the site vice president or those kinds 14 of jobs like general manager or NRC staff person, but 15 the poor slob that is out in the plant saying, "I 16 wonder where that is? I know I have to do this. 17 Which one?" I would think that some place along the 18 line there should be some kind of inspection at the 19 time the renewed license starts that actually looks at 20 the documentation to see if you can really identify 21 where all the stuff is. 22 Some of it is easy, you know. All the 23 ASME stuff is easy because you already did it for the 24 Section 11 program. All the non-safety stuff unless 25 everything in the room is in scope, there needs to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.Q 20005 (202)2344433 81 1 some other kind of database somewhere along the line. 2 That gives you something to do in the next five years 3 along with some other things you might want to do 4 during that time. That is not a simple job. It's 5 probably a pretty good size database.
6 MR. VINCENT: This is Bob Vincent again. 7 I would add to what I said before. In a couple of 8 areas, though, it is fairly straightforward to track 9 that. For example, we have a fairly robust system 10 walk-down program that will a lot more robust once we 11 make the changes we plan to. 12 Those walk-down programs really cover an 13 entire system. We'll provide more guidance for the 14 person doing the walk-down to make sure they cover the 15 entire system but it will cover the entire system. In 16 the structural area the structural inspections that 17 are already done under the maintenance rule are being 18 enhanced and they are really oriented more to a spaces 19 type approach.
20 Basically inspect pipe supports, 21 structural members, concrete, etc. in a space. Again, 22 that will be all encompassing and we don't necessarily 23 need to track pipe segment by pipe segment with that 24 kind of approach.
What we have to sort out is where 25 that approach applies and where we need to track it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202) 2344433 82 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 segment by segment.
CHAIRMAN SIEBER: I think your point is well taken, particularly if the Aging Management Program that you are applying is something like chemistry.
The chemistry applies through the whole system so you don't need to care if it's this piece of pipe or that piece of pipe. On the other hand, if it involves some direct examination, you've got to know what you're dealing with. I won't belabor the point but I keep trying to think if I were young again and I was assigned the job of doing this, how would I do it. MS. LUND: This is Louise Lund. I just want to mention before Patricia goes on is that they do have another license renewal inspection that the regions do before the period of extended operation and I know just listening to Patricia and her supervisor, Anne Marie Stone, I know they have had some discussions about what the context would be of the inspections and what we would need to focus on. I think these discussions have already started.
CHAIRMAN SIEBER: That is sort of the point of my question is to encourage people to think about that.MS. LUND: That's a good point. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHiNGTON, D.C. 20005 (202) 234-4433 (PM2 234-4433 83 1 MS. LOUGHEED:
And I did write that down 2 as a comment of something to add into what we should 3 look at for the 95003 which is the inspection that's 4 done just prior to or, if I had my way, right after 5 the license renewal extension took effect. 6 CHAIRMAN SIEBER: I think it's an 7 important thing and I apologize for interrupting your 8 presentation.
9 MS. LOUGHEED:
No, it's a good point. 10 CHAIRMAN SIEBER: And I will stay quiet 11 for at least 30 seconds.
12 MS. LOUGHEED:
Okay. Aging Management.
13 We looked at 14 AMP and two TLAA programs.
Our review 14 differs from NRR a little bit in that we are looking 15 at what is actually existing in the plant to see if 16 they are meeting today pretty much what they have 17 committed to do in the future and to get an 18 understanding of where the enhancements are to see if 19 they understand what those enhancements really are and 20 what needs to be done. 21 I know there was some discussion earlier 22 about the water in the manholes.
I do have to echo 23 Larry's comment. He did find that back several months 24 prior to our inspection and did write a corrective 25 action document.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202)23444 33.o 84 1 Unfortunately, what happened was the 2 corrective actions kind of fell in the crack a little 3 bit so that when we went back out in October he was 4 chagrined to find some water in there again. 5 Following our finding it the second time, then the 6 corrective actions that he had planned from the first 7 time did actually take place so there's not water now. 8 I know that there has been some discussion 9 about the MEGERing and the type of testing being done. 10 That is one of those areas where there is a commitment 11 done or license renewal to improve the testing 12 programs.
We are going to have to wait for another 13 five years or so before they take effect on that. 14 They are keeping them dry now which is an important 15 thing. 16 CHAIRMAN SIEBER: It's important, I guess, 17 for everybody to recognize that if you have manholes 18 and underground cable ducks in a place where it rains 19 occasionally, they are going to be wet. If you aren't 20 pumping them out, you are missing the boat. 21 MS. LOUGHEED:
And we have found that at 22 several region plants. We are actually looking at 23 that now as part of our regular -- not part of a 24 license renewal program. It's part of our regular 25 inspection program.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, NW. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234.44*3_ o 85 1 CHAIRMAN SIEBER: Okay. 2 MS. LOUGHEED:
Again, we spend a lot of 3 time in the plant during these inspections.
We try to 4 do lock-downs to verify how things are actually being 5 done rather than relying just on paperwork reviews.
6 Over all there is not very much here. Palisades we 7 had very, very few problems with. 8 We found that their programs were very 9 well put together, their plant staff very 10 knowledgeable.
We felt that what they had done was 11 definitely adequate for license renewal. We wish they 12 had gone first so they could have shown some of the 13 other guys -- I'll leave that. 14 Again, the scoping and screening programs 15 as well, we didn't have any problems with them. Very 16 minor issues if at all. We don't see any impediments 17 to the license renewal process.
18 That concludes my portion. No, it 19 doesn't. I forgot. I get to talk about current 20 performance, although that is not really part of the 21 inspection.
That's still current operations.
There 22 is a slide coming up. They are in the licensee 23 response column, all greens, of our NRC action matrix. 24 We don't have any cross-cutting issues at this time. 25 We continue to follow the baseline reactor oversight NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202) 234-4 433* o 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 86 process where we do routine inspections.
That's the slide. These are the recent inspection findings.
There is one I would kind of like to highlight, one under barrier integrity that was found in the fourth quarter of 2005. That actually was a through-wall leak on a heat exchanger, something which we hope that the enhancements that are going to be made to the service water, open cycle cooling water system will help prevent in the future. However, it was something just to demonstrate that even if issues slip through and problems exist that they are identified in a timely manner and corrected before they become big problems for the plant. CHAIRMAN SIEBER: Is this is a tube leak? MS. LOUGHEED:
I believe it was a tube leak. CHAIRMAN SIEBER: In what heat exchanger?
Do you know? MS. LOUGHEED:
I looked at that yesterday and I don't remember.
MR. HARDEN: This is Paul Harden, Site Vice President.
It was in our non-safety related containment air cooler coil. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 87 1 MS. LOUGHEED:
Okay. 2 CHAIRMAN SIEBER: So under an action 3 sequence where you've got containment pressurization, 4 leakage would be from containment through that leak to 5 the outside? 6 MS. LOUGHEED:
Right. 7 CHAIRMAN SIEBER: Okay. 8 MS. LOUGHEED:
And it was correctly 9 prompted.
Overall I believe none of the other 10 findings on here really had anything to do with 11 license or could be conceived to have anything to do 12 with license renewal.
13 CHAIRMAN SIEBER: I presume that finding 14 was licensee identified?
15 MS. LOUGHEED:
Self-revealing, yes. 16 CHAIRMAN SIEBER: Okay. 17 MS. LOUGHEED:
Back to Juan. 18 MR. AYALA: Thank you, Patricia.
Now I am 19 going to go into the staff's review of the Aging 20 Management Program and aging management reviews. The 21 staff reviewed 24 Aging Management Programs.
Of those 22 20 are existing AMPs and four are new, as the 23 applicant stated. Thirteen of those are consistent 24 with GALL, 10 of them are consistent with exceptions 25 or enhancements, and one is plant specific.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 344433 WASHINGTON, D.C. 20005 (202) 234-44 133.o 88 1 CHAIRMAN SIEBER: Could you describe the 2 one that is plant specific?
3 MR. AYALA: I'm going to get into that one 4 in a slide. 5 CHAIRMAN SIEBER: Okay. I'll wait. 6 MR. AYALA: Okay. The Buried Services 7 Corrosion Monitoring Program is a new AMP consistent 8 with GALL which uses visual inspections of external 9 surfaces.
The applicant had initially committed to 10 performing visual inspections of buried piping within 11 10 years after entering the period of operation.
As 12 a result of the staff's review, the applicant will now 13 perform visual inspections within 10 years prior to 14 entering the period of extended operation and within 15 10 years of entering the period of extended operation.
16 There is one below-grade tank, as the 17 applicant mentioned earlier, and that is the diesel 18 fuel oil storage tank. As they mentioned, it is 19 contained in a vault and not exposed to soil. 20 CHAIRMAN SIEBER: Since we are talking 21 about tanks, if I look at the picture on the 22 application of the plant, I see a lot of tanks. 23 Probably tanks like the RWST. In Westinghouse plants 24 they would call them coolant recovery tanks, 25 condensate storage tanks and so forth, various tanks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234.4433 89 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 that aren't buried but they sit on the ground. Since they sit on the ground you can't inspect from underneath.
You can't dig a tunnel under the tank to get to the bottom of it so you have to inspect it from the inside. Some of those tanks will build up kind of a sludge or something on the bottom of the tank as it settles out. Are the bottoms of the surface constructed tanks inspected the same as it would have been if it were a below-ground tank? Is that part of the Aging Management Program? Perhaps the licensee can tell me about that.Palisades.
MR. ROBERTS: Bill Roberts, Programs Lead, Bottom thickness testing? CHAIR1MAN SIEBER: Yes. MR. ROBERTS: On the inside. That's what we plan on doing. CHAIRMAN SIEBER: Okay.That's ultrasonic?
MR. ROBERTS: Right, for thickness.
CHAIRMAN SIEBER: Okay. MR. AYALA: Moving on, the Bolting Integrity Program is an existing program consistent with enhancements.
The applicant is going to revise their master ISI plan. They are going to evaluate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. 02) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4 433 (2 W 90 1 high-strength bolting used in component supports.
2 Non-safety related bolting will be 3 monitored by the System Monitoring Program and 4 structural bolting including fastener will be managed 5 by the Structural Monitoring Program. ASME Class 1, 6 2, and 3 bolting is inspected by the ASME Section XI 7 ISI program once per 10-year interval.
The inspection 8 is going to involve bolts two inches or larger. 9 Bolting Integrity Program will incorporate 10 the guidance of EPRI and the staff determined that the 11 guidelines reflected industry practice and meets the 12 recommendations in GALL. 13 CHAIRMAN SIEBER: For structural bolting, 14 I presume that the indication of a problem is when the 15 bolting fails for structural bolts. You don't run 16 around doing ultrasonic examinations through the shank 17 of the bolt. What is considered a failure in 18 structural bolting? 19 MR. AYALA: David Jeng -20 MR. JENG: This is David Jeng of the 21 Division of Engineering.
The concern is about the 22 high strength structure bolting, 150 psi, and we are 23 concerned about cutting aspect in so much the regular 24 material normally control it and managed by the 25 Structural Monitoring Program. In high-strength NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 91 1 structural bolting, then they commit to technical 2 variation of cracking or not. 3 CHAIRMAN SIEBER: Well, it seems to me 4 that being able to monitor high-strength bolts is 5 important because of the seismic issues. If you get 6 a seismic event, even though the bolting may be 7 satisfactory for normal plant operation without a 8 seismic event, the combination of plant operation and 9 the seismic event raises the stress intensity pretty 10 high. You may have self-revealing cracks that turn 11 into failures.
12 MR. JENG: Seismic induced stresses and 13 other stresses are covered by the design configuration 14 requirements.
15 CHAIRMAN SIEBER: Okay. Thank you. 16 MR. AYALA: Okay. Moving on to the Boric 17 Acid Corrosion Program, the applicant stated that this 18 program was consistent with GALL with enhancements.
19 Three enhancements that the applicant provided were 20 also provided as commitments and they are listed on 21 the slide here. 22 Enhancements are scheduled for 23 implementation prior to the period of extended 24 operation and the staff found that with these 25 commitments the program is consistent with GALL. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234.4433 WASHINGTON, D.C. 20005 (202}23444
'33 92 1 The Flow-Accelerated Corrosion Program is 2 an existing program consistent with GALL. The license 3 renewal application originally stated that the trigger 4 point for conducting engineering evaluation for non 5 safety related piping was less conservative than that 6 of safety-related piping. As a result of the staff's 7 review the applicant will use the same criteria that 8 they used for safety-related piping for non-safety 9 related piping. 10 The Reactor Vessel Integrity Surveillance 11 Program. The applicant stated that the program is 12 consistent with enhancements.
The staff reviewed 13 these enhancements and these enhancements were also 14 once again submitted as commitments and are listed 15 here. With the four enhancements the staff found that 16 the program is consistent with GALL. The next slide 17 shows the other two commitments and enhancements that 18 the applicant provided.
19 Moving on, the System Monitoring Program 20 is a plant-specific program that the applicant had in 21 the application.
It is consistent with GALL and 22 XIM29, above-ground carbon steel tanks, and is used to 23 identify the greater conditions on external surfaces, 24 piping, tanks, and other components and equipment 25 prior to the loss of systems in components that tend NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 23444 433 93 1 to function.
2 The applicant will credit opportunistic 3 inspections of external surfaces when insulation is 4 removed. If insufficient data exist, the applicant 5 will remove additional insulation from additional 6 locations to increase the sample. The data will be 7 available to the regional staff for review and 8 determination if the sample size is sufficient.
9 Moving on to the aging management reviews.
10 MEMBER BONACA: Before we move to that, I 11 have a question.
Some of these problems you would 12 expect to have them in place already. I was thinking 13 about the boric acid corrosion problem that you had on 14 page 25. 15 MR. AYALA: Yes. 16 MEMBER BONACA: There are three 17 commitments.
One is revise procedures to include 18 criteria for observing susceptible SSC for boric acid 19 leakage, etc. I would expect that after Davis-Besse 20 people have implemented already procedures of this 21 nature. Are these significant changes for license 22 renewal or do they have already problem that does this 23 kind of inspections?
24 MR. AYALA: If I can ask the applicant if 25 they can address the implementation of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 24-4433 WASHINGTON, D.C. 20005 (202) 2344433 94 1 enhancements.
2 MR. ROBERTS: Bill Roberts, Program Lead, 3 Palisades.
I think that Bob Vincent typified this 4 earlier. A lot of our commitments is we took maybe a 5 narrow view and said we think our programs comply but 6 we are going to say that we need this enhancement 7 implemented to be fully consistent with the GALL. 8 If I would go through these three 9 commitments, the first one on the slide there, revise 10 procedures to include criteria for observing 11 susceptible SSC for boric acid leakage and degradation 12 during system walk-downs.
We have a separate boric 13 acid inspection program and separate procedures.
14 What we want to do here is make sure that 15 the system walk-down procedures also includes a 16 criteria and so to come full circle we want to make 17 sure that the boric acid -- we take credit from the 18 system honoring program and the walk-downs for boric 19 acid component.
We felt that was an enhancement.
20 The second one revised the procedures to 21 include explicit acceptance criteria.
I think our 22 acceptance criteria was always any signs of boric acid 23 but we hadn't really spelled that out to the degree 24 that we think it's necessary to call us consistent 25 with GALL. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344 433.o 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 95 I think the Region challenged us on that and we said, "Yeah, you're right. We need to come up with some more explicit acceptance criteria rather than just any signs of boric acid. Maybe we need to do a little more extended condition and determine if it was a drip from another pipe or internally came from the pipe that it's on, that kind of thing. The third one, revise the procedures.
We have the maintenance rule structural monitoring program which, again, looks at the structural aspects of the plant. This is again reference, I think, to the walk-down procedures.
We want to make sure that the system walk-down procedure also observe structural members and components and look for boric acid also. We don't just want the structural monitoring program to be the only program that's going to look for boric acid in the structures.
We want the system monitoring program to look at that. That is my explanation as to why we chose to call those enhancements and not just flat out say we are consistent with the GALL from the get go. MEMBER BONACA: Thank you. MR. AYALA: Once again, Juan Ayala. Moving on to the aging management review results. The staff performed a 100 percent review of 29 plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 2344433 96 1 systems, 10 structures, and nine commodity groups. In 2 the auxiliary systems the LRA did not identify any 3 aging management program for degradation of neutron 4 absorbing panels. The applicant does not have a 5 coupon program for the boring carbide panels. 6 As a result of the staff's review the 7 applicant has committed to performing industry 8 approved neutron absorption testing to monitor for 9 degradation.
In the interim the applicant also 10 sampled spent fuel pool water on a monthly basis for 11 total organic carbon with typical values around 0.2 12 PPM. This will provide an indication of degradation
.13 of material.
14 For thermal sleeves the applicant stated 15 that thermal sleeves did not serve an intended 16 function and no aging was required.
As a result of 17 the staff's review the applicant added the aging 18 effects for cracking due to stress corrosion cracking 19 and primary water stress corrosion cracking.
20 The applicant will manage stainless steel 21 sleeves with the ASME Section XI ISI Program and the 22 Water Chemistry Programs.
Alloy 600 nozzle of sleeves 23 are managed by the alloy 600 and Water Chemistry 24 Programs.
For feedwater nozzle thermal sleeves, loss 25 of material due to general corrosion is managed by the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, NW. (202) 234.4433 WASHINGTON, D.C. 20005 (20)234-4433 97 1 Water Chemistry Programs and credits inspections of 2 adjacent nozzles using the ADME Section XI program.
3 Loss of material due to FAC is credited -- credits the 4 FAC program and inspections of adjacent nozzles.
5 Moving on to inaccessible concrete.
The 6 applicant stated and the staff verified that below 7 grade environment is non-aggressive.
Periodic testing 8 of ground water will be performed as part of the 9 Structures Monitoring Program at least every five 10 years. 11 The staff found that the applicant had 12 appropriately addressed the aging effects and 13 mechanisms as recommended by GALL. As shown on the 14 table here, the results are well below acceptance 15 criteria and no adverse trends exist. 16 Moving on to the electrical and I&C 17 components.
The application grouped these as nine 18 commodity groups and they are listed on the right 19 here. The staff reviewed these and found that 20 everything was consistent with GALL and there was no 21 action required by the applicant.
22 Moving on to the Time-Limited Aging 23 Analyses, these were the TLAAs described in the 24 license renewal application.
I'm going to first start 25 by talking about reactor vessel neutron embrittlement.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344433 98 1 There are three analyses affected by irradiation 2 embrittlement.
These are PTS, upper shelf energy, and 3 pressure temperature limits. 4 I'm going to go into a deeper discussion 5 on the first two. For the 60-year operation the 6 applicant used 42.37 EFPY in their calculations.
As 7 the applicant mentioned, the capacity factor that they 8 are using is 91 percent.
9 RV pressurized thermal shock. Limiting 10 material is intermediate shell and lower shell axial 11 welds. As a result of the calculation, the screening 12 criteria will be exceeded in 2014 and this calculation 13 was verified by the staff. In the next slide we'll 14 address the options that the applicant has to address 15 this concern.
16 Palisades' plan for PTS are as follows: 17 The applicant can continue to use an ultra-low leakage 18 core design and submit final PTS resolution three 19 years before 2014. Some of the options that the 20 applicant has is that they can further reduce flux and 21 preheating safety injection water, or perform thermal 22 annealing of the reactor vessel. 23 MEMBER WALLIS: Has thermal annealing ever 24 been done on a U.S. reactor? 25 MR. AYALA: No. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 99 1 MEMBER WALLIS: This would be a novel 2 thing to do. 3 PARTICIPANT:
It's been done in Europe. 4 MEMBER WALLIS: It's been done in Europe, 5 yes, but it hasn't been done over here. 6 MR. MITCHELL:
This is Matthew Mitchell, 7 Chief of the Vessels in the Internals Integrity 8 Branch. I would in response to Dr. Wallis's 9 observations say that we did a number of years ago 10 complete an annealing demonstration project at an 11 unused facility.
The technology at least in that 12 sense for thermal annealing was effectively 13 demonstrated.
You are correct, there has been no 14 actual annealing of a U.S. vessel. 15 MEMBER WALLIS: Thank you. 16 CHAIRMAN SIEBER: When you do an 17 annealing, how can you tell when you're done that you 18 actually annealed it? 19 MR. MITCHELL:
Again, Matthew Mitchell.
20 Part of the process for exercising 5066, the thermal 21 annealing rule, would require a licensee to undertake 22 a material program to demonstrate the benefits that 23 were gained as a result of the annealing process.
24 That would likely be as a result of testing sample 25 coupons to a simulated annealing process to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202344433 100 1 demonstrate what type of material property recovery 2 would have been effected by the thermal annealing.
3 CHAIRMAN SIEBER: But that would not 4 examine the actual vessel itself in any way? 5 MR. MITCHELL:
Well -6 CHAIRMAN SIEBER: Just coupons, right? 7 MR. MITCHELL:
There would be other 8 options available.
Of course, one could contemplate 9 taking actual material samples from the vessel itself. 10 However, I think that would probably be secondary.
11 CHAIRMAN SIEBER: I would rather not do 12 that. 13 MR. MITCHELL:
Yeah. I think having the 14 right material available in the appropriately 15 irradiated condition to then subsequently perform 16 effectively the annealing process on to demonstrate 17 property recovery would be probably the preferred 18 method of demonstration.
19 CHAIRMAN SIEBER: Okay. 20 MR. AYALA: Thank you, Matt, for that. 21 Once again this is Juan Ayala. Moving onto reactor 22 vessel upper shelf energy. The limiting plate is the 23 lower shell plate and it is expected to exceed the 24 acceptance criteria in 2021. This calculation was 25 also confirmed by the staff and the options for this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. NW. (12) 234.4433 WASHINGTON, D.C. 20005 202 234-44 33 101 1 concern will be addressed in the next slide. 2 The limiting weld is the intermediate to 3 lower shell circumferential weld. The analysis for 4 this was found acceptable and the calculation was 5 confirmed by the staff. The plan that Palisades has 6 for addressing upper shelf energy is to submit an 7 equivalent margin analysis three years before 2021. 8 MEMBER WALLIS: Presumably that works out. 9 Presumably this 50 ft-lbs is a conservative first 10 estimate and then when you do a more thorough job you 11 can prove that it's okay even with a lower value? 12 MR. MITCHELL:
Again, Matthew Mitchell.
13 Like the screening criteria that we are familiar with 14 in 5061, the 50 ft-lb limit that's in 10 C.F.R. Part 15 50, Appendix G, has been exceeded by more than one 16 facility.
An equivalent margins analysis has been 17 routinely successful at demonstrating equivalent 18 margins of safety down, I would say, significantly 19 below the values he listed for the limiting plate at 20 Palisades.
21 MEMBER WALLIS: The difference between 22 48.97 and 50 doesn't seem like very much. You would 23 think they could figure out how to improve that 24 somehow.
25 MR. MITCHELL:
It's, shall I say, a matter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202 234.4433 WASHINGTON, D.C. 20005 (202) 234-44 33 I W 102 1 of literal compliance with the regulation.
If you go 2 below the 50 ft-lbs then it does require an enhanced 3 analysis.
I would suspect such an analysis to be 4 successful.
5 MR. AYALA: Okay. Moving on, for the 6 metal fatigue TLAA the CUF for criterion is met for 7 all components.
If there are any locations where 8 environmental effects of fatigue will not -- where the 9 minimum will not be reached, the Fatigue Monitoring 10 Program will ensure that the CUF remains below 1 for 11 the period of extended operation.
The staff found 12 these evaluations acceptable.
13 DR. SHACK: When they did the 14 environmental analysis they came up with a CUF of 4.4 15 or something for the limiting component.
The Fatigue 16 Monitoring Program sits there and counts cycles. 17 Let's just assume that they count the cycles and the 18 cycles actually happen to coincide with the stuff that 19 they did the analysis and sometime the CUF will equal 20 1. What do you do then? 21 MR. AYALA: Mark Hartzman.
22 MR. HARTZMAN:
This is Mark Hartzman from 23 the Engineering Mechanics Branch. I think the 24 monitoring program does more than just count cycles. 25 It actually calculates CUFs on a continuous basis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 2344433 WASHINGTON, D.C 20005 (202) 234-4433 103 1 apparently.
Therefore, it's both. It counts cycles 2 and when it sees that the CUF is approaching 1 it will 3 take some sort of measure.
4 DR. SHACK: But every time I read this it 5 sounds as though the Fatigue Monitoring Program is 6 computing CUF ASME code version and it's not applying 7 an environmental correction.
I'm not sure exactly how 8 you make the connection and what you would do if you 9 do hit the CUF of 1. 10 MR. HARTZMAN:
They are supposed to 11 replace or repair -- repair or replace.
12 DR. SHACK: They can't inspect and 13 analyze? 14 MR. HARTZMAN:
Maybe they can. Supposedly 15 the analysis that goes into the Fatigue Monitoring 16 Program is already what- one would call a pencil 17 sharpened analysis so, therefore, at that point they 18 are most likely to either repair or replace. Maybe 19 the applicant cares to address that. 20 DR. SHACK: Am I right that the CUF that 21 you're computing in the fatigue monitoring program 22 does not include an environmental enhancement, or does 23 it? 24 MR. HARTZMAN:
I can't address that 25 because I didn't review that program.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-44..
104 1 MR. KNEELAND:
This is John Kneeland, NMC. 2 The numbers that you see due include the environmental 3 correction factor. The particular number that you're 4 referencing, the 4.65, I believe it is, we have 5 updated that calculation in a later submittal.
We 6 used an overly conservative environmental factor in 7 that particular case. We should have used a much 8 smaller number and that number is now less than 1. 9 MR. HARTZMAN:
At the time the SER was 10 written we didn't have that information.
11 DR. SHACK: Oh, okay, because you then 12 manage it through the fatigue program. When you hit 13 the 1 you just replace the compound.
14 MR. HARTZMAN:
Right. Well, repair or 15 replace.
16 DR. SHACK: Or replace. Right. 17 MR. HARTZMAN:
That's the commitment.
18 DR. SHACK: So then the Fatigue Monitoring 19 Program does include an environmental enhancement 20 factor? 21 MR. HARTZMAN:
That is correct.
22 DR. SHACK: It's never clear to me when I 23 read that. 24 MR. AYALA: Once again, Juan Ayala. 25 Moving on to environmental qualification of electrical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHNGTON.
D.C. 20005 (202) 234.44 ,33 33vw.. .
105 1 equipment.
The staff reviewed the applicant's TLAA 2 and determined that it was acceptable and concluded 3 that the evaluation was acceptable for the EQ 4 components.
5 Okay. Moving on to underclad crack 6 growth. This is the only confirmatory item that we 7 have in the Safety Evaluation Report. This is a new 8 TLAA that is not in the application and came about as 9 a result of the staff's audit revieW. The applicant 10 addressed the issue of underclad crack as a TLAA that 11 stated that the bonding fracture mechanics and staff 12 approved WCAP would be applicable to Palisades.
13 The staff just received last week a plant 14 specific WCAP and is in the process of reviewing it. 15 This plant specific WCAP uses the same methodology 16 used in the staff-approved WCAP. We will address that 17 issue in the final SER. 18 To summarize the TLAAs, the TLAA list is 19 complete and acceptable.
The analysis have been found 20 to either remain valid for the period of extended 21 operation projected to the end of the period of 22 extended operation or will be managed during the 23 period of extended operation.
There are also no plant 24 specific exceptions.
25 In conclusion, the staff has concluded NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 106 1 that there is reasonable assurance that the activities 2 authorized by the renewed license will continue to be 3 conducted in accordance with the current licensing 4 basis. That concludes our presentation.
5 MEMBER BONACA: Question for Patricia.
I 6 wasn't here when you started the presentation.
I 7 wanted to ask about the physical conditions of this 8 plant. You recently -- well, you've been looking at 9 a number of plants. 10 MS. LOUGHEED:
I have to admit that I have 11 not been at Palisades in a while other than the 12 inspection in October and Palisades is not a plant 13 that I normally go to. Having said that, the licensee 14 is working on improving the physical condition of the 15 plant. It does meet our minimum standards.
I think 16 there are others. I would hesitate to say it was 17 excellent but it is definitely not poor in any way. 18 MEMBER BONACA: There was an inspection 19 report where, for example, they are quoting extensive 20 corrosion in a diesel -21 MS. LOUGHEED:
Yes. There were a few 22 components.
These are non-safety related components 23 where there has been corrosion and the licensee was 24 aware of it. As of right now there is no requirement 25 for them to monitor that. They did write corrective NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 2344433 107 1 action documents for it. It was not on any of the 2 safety related stuff. It was all non-safety related 3 components.
4 I think the utility has made some 5 decisions in the recent past because they have decided 6 to seek a new owner and to seek license renewal, 7 whereas previously they had been thinking strongly 8 about shutting down in a few years and that has 9 affected how they have maintained the plant. 10 MEMBER BONACA: Thank you. 11 CHAIRMAN SIEBER: Any additional questions 12 from any of the members? Okay. If there are no 13 questions, I want to thank the staff for their 14 presentation and their hard work. 15 MR. GILLESPI:
I would like to -- I don't 16 know if you noticed it in the presentation.
It takes 17 us two years to figure out if we did something right 18 because we're on a 22-month review schedule.
19 Palisades was nice enough to step up and actually use 20 a draft GALL document and do a comparison.
They did 21 in this whole process go a bit above and beyond to 22 help us prove, you might say, the goodness of a GALL 23 document that doubled in scope. Also to help we've 24 created a new document.
25 I know ACRS hates to hear this because when we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 108 1 created the audit reports it was an extra 700 pages 2 you had to read. An important document that came out 3 of the audit process that evolved at Palisades in the 4 couple of plants that volunteered was the question and 5 answer database which is on the official record where 6 the audit team actually looks at the application and 7 says knowing nothing else but what's in the 8 application with every question we can think of. 9 Then they send that to the applicant and 10 that becomes kind of the first step in the audit 11 process. Additional questions are developed and that 12 database actually becomes almost a supplement to the 13 application with the additional detail we are 14 dependent upon. 15 It has actually become now with current 16 reactors since Palisades kind of a critical element in 17 the whole process of documenting what happens in an 18 audit on the public record as opposed to summarizing 19 something in an audit report because it's the 20 applicant's own words that answer the questions.
21 They have contributed to an improvement in 22 the process and improvement in our openness in how we 23 are moving forward. Now we have to figure out how to 24 eliminate.
We've created this new thing, this new 25 database.
Now we have to try to hopefully get rid of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234.4433 WASHNGTON.
D.C. 20005 (202) 234.4433 109 1 something in the middle there. 2 Maybe the audit report isn't as important 3 now that we have the question and answer database.
4 That raises that question.
I do want to thank the 5 licensee for bearing with us and trying something a 6 little new which we have met, I think, with some 7 success both in process and documentation.
8 MS. LUND: I just wanted to mention from 9 a programmatic standpoint we welcomed Patricia to our 10 staff on a rotational basis just this week and it 11 really helps us to get regional inspector insight into 12 our programs.
Anyway, she's going to be with us for 13 the next couple of months. 14 DR. SHACK: Where is this question and 15 answer database now? 16 MR. GILLESPI:
Actually, I know you hate 17 to hear this, but it's in ADAMS. I know, isn't that 18 deadly? In fact, I'm going up to Pilgrim and Vermont 19 Yankee next week. I apologize for not being here 20 tomorrow for Nine Mile but I'm going to be at Oyster 21 Creek for the draft environmental safety. P.T. Kuo, 22 who normally would be here if I'm not here, has been 23 on three weeks of sick leave for some surgery he had 24 done. 25 I apologize for not being here tomorrow.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 205 (202) 2344 433 110 1 We are actually going to take copies of the question 2 and answer database with us to the public meetings 3 which are the exit meetings, if you would, from the 4 audits because that really becomes kind of the public 5 documentation of what took place at the audits. 6 DR. SHACK: This is on the license renewal 7 website there where you have the application and the 8 environmental impact statement.
9 MR. GILLESPI:
When I sat today with the 10 guys, I said, "We've got this question and answer 11 database.
It's really good stuff. It's the 12 licensee's own words about how we responded.
They 13 said, "Well, it's in ADAMS." I had the same reaction 14 and we are working maybe to get it on the website.
15 It's just a decision we hadn't made yet but it is a 16 significant body of information which is very focused 17 and it is the next stepping-off point from the 18 application.
19 MS. LUND: Very much like the RAIs. It 20 gets supplemented over time and then it gets provided 21 in one lump sum at the end, you know, when all have 22 been answered.
I guess we have been treating it a lot 23 like the RAI responses in that, you know, it goes all 24 into ADAMS rather than we don't put RAI responses on 25 the website. I guess this is something that we just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 2 234-44 33 33 111 1 have to kind of consider how to -2 MR. GILLESPI:
I really hesitated to go to 3 a meeting with the general public and have to give 4 them an ADAMS number. What we are actually doing is 5 the two project managers are going to leave their e 6 mails and we will e-mail a copy to anyone who actually 7 wants a copy of that database because it's very 8 timely. It's like two weeks or three weeks after the 9 audit it's available and so it's more like instant 10 gratification of what really went on. 11 CHAIRMAN SIEBER: I actually found 12 something in ADAMS a couple of weeks ago. 13 DR. SHACK: If they give you the number, 14 it's okay but how do you get the number? 15 MR. GILLESPI:
We are going to give out 16 the number. We are kind of reexamining a publication 17 documentation of everything we are doing because we 18 are doing a lot of good stuff but if it gets hidden in 19 ADAMS no one knows it. At least to have them 20 available and maybe sorted in some reasonable way 21 where we can get information would be good. 22 DR. SHACK: Some place that it could be 23 Googled.
24 MR. GILLESPI:
Yes, some place you could 25 Google it. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-44 133 112 1 CHAIRMAN SIEBER: You can Google ADAMS at 2 its own Google. 3 DR. SHACK: Yes, I know, but there's a 4 difference between Google and the ADAMS search. 5 CHAIRMAN SIEBER: Well, thanks very much. 6 Appreciate that. 7 DR. SHACK: Google works. 8 CHAIRMAN SIEBER: Again, thanks to the 9 staff. Just to follow up on your remarks, I see 10 improvements in this process both from the standpoint 11 of the application and the staff including the region 12 based staff as we go along. Hopefully by the time we 13 have done all the plants it will be a really good 14 process.
15 DR. SHACK: The next go-around.
16 CHAIRMAN SIEBER: I think that is a credit 17 to licensees and also to the staff to try to make the 18 process work that is thorough and has meaning for the 19 application that is being applied to. I give my 20 congratulations.
The documents are getting easier, 21 better organized and easier for me to read and 22 understand.
That's important.
Again, thanks to 23 everyone here that contributed to this process.
24 Are there additional questions, 25 statements, or remarks by anyone? NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 2000D (202) 2344 t33.° 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 anyone hear 113 MS. CAREY: Yes. Can I speak up? Can me? Hello? CHAIRMAN SIEBER: Yes. MS. CAREY: Hi. Do I count? CHAIRMAN SIEBER: I don't know who you are.MS. CAREY: I'm Corinne Carey in Grand Rapids, Michigan.
CHAIRMAN SIEBER: Oh, good. MS. CAREY: I appreciated your joke there about actually finding something on ADAMS. Incidentally, is ADAMS or ATOMS? CHAIRMAN SIEBER: ADAMS. MS. CAREY: Oh, okay. CHAIRMAN SIEBER: Automatic something or the other. MS. CAREY: I'm relatively an amateur at all this, of course, but I appreciate that many of you have spent many long hours in training and all of that in working out these hopeful solutions to nuclear power, etc. I am strongly questioning many of the things about this process.
Among other things that you are not considering the very issue that this nation is at war about. We are at war on terrorism and you are not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 114 1 considering it on our nuclear plant? This is 2 incredible to me and how you can call that outside the 3 scope according to a letter that I've been reading 4 here from Valkyre. Is that his name? It just seems 5 to me that you have no right to not change the 6 procedure.
I don't care what your procedure has been 7 in the past. 8 In fact, there have been times when I have 9 driven right up to the reactor fence all by myself, 10 just an ordinary person, etc., etc., partly just to 11 see what would happen if I did it. Now, of course, I 12 assume that is not allowable but, in the meantime, how 13 can you not include the issues of terrorism on 100 14 some nuclear bombs just sitting and waiting to get hit 15 that are scattered throughout our country? 16 CHAIRMAN SIEBER: Would you like me to 17 address that? 18 MS. CAREY: Yes, please. 19 CHAIRMAN SIEBER: As I am sure you are 20 aware, the responsibility of the Nuclear Regulatory 21 Commission do extend to a wide variety of things, one 22 of which is license maintenance, license renewal, and 23 compliance.
Another one is security.
We do not mix 24 and match. When we deal with a specific subject, we 25 follow the regulations that exist on that subject, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHOOE ISLAND AVENUE. N.W. 1202( 234-4433 WASHINGTON.
D.C. 20005 (202) 234-41 433 3 T v 115 1 that does not mean that issues like security and so 2 forth are not being addressed for the Palisades plant 3 or any other plant. 4 MS. CAREY: Well, I assume it certainly is 5 but to not include that in the process of renewal for 6 another 20 years when I understand that the original 7 engineer design of any nuclear power plant was 30 8 years. Then the original NRC licensing was done for 9 40 years which I understand was an industry 10 requirement or request because of financial need to 11 break even or however you describe it. But then to 12 add another 20 years and Grand Rapids is 70 miles down 13 wind but that's not far enough if things go wrong. 14 CHAIRMAN SIEBER: Well, my grandchildren 15 live there so I have something at stake, too. 16 MS. CAREY: Then why are you anywhere near 17 approving it? 18 CHAIRMAN SIEBER: We haven't said whether 19 we are going to approve it or not. 20 MS. CAREY: No, but you have denied any 21 kind of legal process that hundreds of 22 environmentalists and other citizens.
They are 23 citizens.
They are not even a lot of them 24 environmentalists but they are saying, 'They're 25 risking us? They're risking my land, my home, my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234.4433 WASHINGTON.
D.C. 20005 (202) 234-4433 116 1 children, my grandchildren, great-grandchildren., 2 How can you not look at terrorism as part 3 of that when the world -- when this country has killed 4 -- has had 25,000 and more of our people die fighting 5 a war on terrorism and you are not including it in 6 renewal procedures?
Sounds like a nut, doesn't it? 7 MEMBER WALLIS: We are considering it in 8 a different context, as my colleague explained.
We 9 look at the security of plants but we don't include it 10 in this particular hearing on license renewal. It's 11 a different context. We are addressing it in a 12 different place, but we are certainly addressing the 13 security and the terrorism issue. 14 MS. CAREY: Well, not in the letter that 15 I got. 16 MEMBER WALLIS: Well, unfortunately it is 17 a subject of security so we don't do it in public 18 because we don't want the terrorist to hear what we 19 say about security of nuclear plants. 20 MS. CAREY: Well, I appreciate that. We 21 don't want to give anybody any ideas. Believe me, if 22 even a little former fourth-grade teacher can think of 23 some ideas of what could happen, I'm sure that anybody 24 that was really determined to do something could come 25 up with some horrible things. But to officially NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-4433 117 1 exclude it from the procedure of renewal and to 2 consider renewing the plant when it's already 3 embrittled it doesn't make any sense at all. 4 CHAIRMAN SIEBER: Okay. Well, we 5 certainly appreciate your comments and you are part of 6 the record here. 7 MS. CAREY: Thank you. 8 CHAIRMAN SIEBER: It will appear in the 9 transcript.
10 MS. CAREY: Good. 11 CHAIRMAN SIEBER: You can get it under 12 ADAMS. 13 MS. CAREY: One voice of millions.
14 CHAIRMAN SIEBER: Okay. Thank you very 15 much. 16 MS. BARNES: May I make a comment? May I 17 ask a question?
18 MS. CAREY: Are you asking me? 19 MS. BARNES: I'm asking the group there. 20 CHAIRMAN SIEBER: I'm sorry. I can't hear 21 you very well. 22 MS. BARNES: Oh, yes. Can I make a 23 comment, ask a question?
This is Katherine Barnes. 24 CHAIRMAN SIEBER: Oh, okay. Sure. 25 MS. BARNES: I have a concern. I recently NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202( 234-44 t33 118 1 read that there was some flooding of radioactive 2 effluent onto the soil within the compound in 1990 and 3 Consumers Power -- I think it was Consumers Power at 4 that time -- had asked for exemptions to a clean up. 5 They said by leaving the soil there that they didn't 6 think it was affecting anybody because the people 7 didn't have wells and used city water. Because it was 8 a fenced-in compound they didn't think anybody but 9 their workers would be there. I was wondering, did 10 they clean that up or did you allow that to just sit 11 there? 12 CHAIRMAN SIEBER: I'm not familiar with 13 that incident so I can't respond to your question.
14 MS. BARNES: Okay. Well, there's -15 MS. LOUGHEED:
Ma'am. 16 MS. BARNES: -- some documentation on it. 17 MS. LOUGHEED:
Ma'am, there will be a 18 meeting in a few weeks of the inspection process 19 called the Mid-Cycle Assessment.
That would be an 9 20 excellent meeting to address that question.
21 MS. BARNES: Okay. 22 MS. LOUGHEED:
They would be able to 23 answer it. 24 MS. BARNES: Okay. I have another 25 question and that is about Pack Sore. I understand it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 23444 133 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 119 has bad wells and is sitting in kind of a cask that is actually on unstable ground and it is surrounded by other casks. Now, they know that's a problem cask, that it could -- that the wells could break, it could leak. My question is why aren't they dealing with it? Why are they just having it there and have they ever assessed how much time it would take them if that cask started to leak to get all those other casks out of the way so that they could even deal with it. Just by letting it sit there is seems like negligence to me. Why aren't they handling that? Why aren't they doing something about that cask? MS. LOUGHEED:
Again, ma'am, this is Patricia Lougheed of the Regional Inspection Office. That is a question that should be asked of the regional folks that are assessing current operation and not license renewal. It sounds like you have a problem with what is going on today. MS. BARNES: This is something that has been continuing.
The cask has been there for quite a while.MS. LOUGHEED:
Right. It's something that is currently there that you have a problem with that's current and you don't necessarily want to wait another NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. 234.4433 WASHINGTON.
D.C. 20005 (202) 234-14433 I 120 1 four or five years before it gets addressed so I would 2 say-3 MS. BARNES: I'm just saying that -4 MS. LOUGHEED:
It should be -5 MS. BARNES: -- if it is part of license 6 renewal it should be addressed.
These are major 7 issues that could cause major problems.
8 MS. LOUGHEED:
Ma'am? 9 MS. BARNES: I just wondered because I 10 didn't hear any mention of the problem in the 11 discussion today. To me I believe these are very 12 important issues. 13 MS. LOUGHEED:
I agree that they are 14 important issues but it sounds like they are current 15 issues and so you should be taking them up in the mid 16 cycle assessment meetings because they are current 17 problems.
I believe that you would find a more 18 receptive audience than one which is looking at a 19 licensing process, not a current process.
20 MS. BARNES: This would be part of the 21 license because these are conditions there. 22 MS. LOUGHEED:
Ma'am? 23 MS. BARNES: I live near a re-licensed 24 plant that disaster is waiting to happen and has 25 possible soil contamination which by this time, since NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 FLODE ISLAND AVENUE. NW. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 23444 t33 121 1 1990, 16 years ago, has probably leaked into the Great 2 Lakes. 3 MS. LOUGHEED:
So you're saying you are 4 not concerned today. You are only concerned in 2014. 5 MS. BARNES: I'm concerned with the 6 relicensing that they are even considering relicensing 7 a plant that has shown that it's negligent.
I mean, 8 it has had so many near disasters.
Besides terrorism 9 they are not taking other things into account--
the 10 track record. They are not taking into account the 11 contamination of soil. They are not taking into 12 account the problems in the past. 13 They are not taking into account 14 deteriorating water quality or the cancer pocket, the 15 health of the residents in that area. There are so 16 many things that have happened there. At one point 17 they turned off the alarms because they didn't want to 18 disturb people so they turned off the alarm system for 19 a while. There's just a lot of things that have gone 20 on here. 21 Someone within the nuclear industry that 22 used to work there, he said he wouldn't work there 23 anymore, that he didn't like the way they run things. 24 He said it is well known within the nuclear industry 25 that Palisades is the most likely to blow of all the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202( 234-4 433 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 nuclear power plants in the United States. We have a right to be concerned.
My whole life, my whole family, my friends, the ecosystem, the Great Lakes, that precious water, everything is at stake. I think this should be part of the relicensing because these are important issues. Your scientists and experts there should be looking at these things as well. CHAIRMAN SIEBER: Well, unfortunately we are restricted by the Code of Federal Regulations Part 54 which describes what we review -- when we consider license renewal. The issues you raise I'm sure are important to you and a lot of folks. I suggest and agree with Patricia that it ought to be brought up at the mid-cycle assessment meeting that the region holds in the vicinity of the plant. I think that is an appropriate forum for you to state your concerns.
MS. BARNES: Do you know when that meeting will be, sir?MS. LOUGHEED:
This is Patricia Lougheed.
I do not know when that meeting will be but I will be happy to find out and get back to you. MS. BARNES: Okay. I would very much appreciate it. Thank you. MS. CAREY: Excuse me. How are you going NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. 234-4433 WASHINGTON, D.C. 20005 (202) 234.(2C 4433 123 1 to get back to us if you don't know who we are and 2 where we live? 3 MS. LOUGHEED:
That's what I was just 4 about to ask. 5 MS. CAREY: Well, thank you. 6 MS. LOUGHEED:
So is there a contact? 7 CHAIRMAN SIEBER: Perhaps that is 8 something we can do off-line because I would prefer 9 not to have people's names and addresses in the public 10 record. 11 MS. CAREY: That's a dilemma.
12 MS. LOUGHEED:
I believe -13 MS. BARNES: The project directors have 14 our e-mails and phone numbers and such. 15 MS. CAREY: But we don't live anywhere 16 near together.
We are miles apart. 17 CHAIRMAN SIEBER: Okay. 18 MS. LOUGHEED:
Juan has the information.
19 CHAIRMAN SIEBER: Okay. Thank you. 20 MS. BARNES: Thank you for letting us 21 speak. 22 CHAIRMAN SIEBER: Okay. You're welcome 23 and we appreciate hearing your point of view. 24 MS. CAREY: Yes. Well, we'll continue to 25 listen if you have other comments.
NEAL R. GROSS COURT REPORTERS AND TRANSCRrBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-44, 33 33 124 1 CHAIRMAN SIEBER: Well, I think that we 2 have come to the time in our meeting where we can 3 close the transcript.
4 MS. HIRT: I also have a question.
I'm 5 Alice Hirt. I live in Holland, Michigan.
6 MS. CUMBOW: And I also have a question.
7 My name is Kay Cumbow and I live in Brown City, 8 Michigan.
9 MS. HIRT: My question is -- this is Alice 10 Hirt -- what are you -- are you still considering the 11 fact that the waste is piling up on the beach and that 12 is out of scope also? You don't really seem concerned 13 that 20 more years of nuclear waste on Lake Michigan 14 is important?
Is that also out of scope, sir? 15 CHAIRMAN SIEBER: What waste are you 16 referring to? 17 MS. HIRT: The radioactive waste. 18 PARTICIPANT:
What waste? 19 MS. HIRT: The waste on the nuclear power 20 plant that is now sitting on the shores of Lake 21 Michigan.
I am wondering if it is out of scope to be 22 concerned about the waste piling up there on the beach 23 for 20 more years if this license is renewed. I would 24 like to know if that issue is out of scope. 25 CHAIRMAN SIEBER: I don't know whether NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 2344433 125 1 it's covered in the environmental impact statement or 2 not. I don't know. 3 MS. HIRT: It's certainly in my scope. I 4 live within 50 miles of the plant and I have a feeling 5 that it is out of scope because we have tried to bring 6 this issue before the Atomic Safety Licensing Board 7 and we have been ruled out of scope on every issue we 8 have brought forward. Just want to remind you that we 9 don't consider it out of scope. 10 MS. BARNES: Also the casks are sitting on 11 these pads which you mentioned in your meeting. They 12 are sitting there like a bunch of bowling balls just 13 waiting to be knocked over. If one goes, then more 14 will go. 15 MS. CUMBOW: My name is Kay Cumbow and I 16 also would like to ask a question.
17 CHAIRMAN SIEBER: Go ahead. 18 MS. CUMBOW: I had several actually.
One 19 is that EPRI just had a report published June of this 20 year that showed intergrandular cracking at Davis 21 Besse not only in 600 but also in alloy 182. I 22 wondered how much of 182 is in the Palisades power 23 plant. 24 Also, the steam generators you mentioned 25 that they were also -- the new ones that were put in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (0) 234-44 133_ ° 126 1 in the early 1990s that they were also made with -- I 2 believe it was in the 1990s -- that they were made 3 with 600 and that seems like a big red flag because 4 they had such big problems with them plugging.
Also, 5 you mentioned that there were only four formally 6 licensed engineers and that seemed like a small number 7 of engineers that were formally licensed.
8 One of the questions I had was somebody 9 asked about how to tell if annealing works and they 10 said that you test the sample coupons but Palisades 11 has no original sample coupons left in the reactor.
12 One question I had was how efficient is it 13 to keep on using Palisades as they are using ultra-low 14 leakage. It just seems like efficiency comes into the 15 package because we are the taxpayers and taxpayers 16 subsidize a whole lot of the cost of nuclear power 17 plants and there are more efficient ways to make 18 electricity.
19 The other question I had was about 20 earthquakes because of the proximity to the New Madrid 21 earthquake zone. The last time there were three huge 22 earthquakes down there in the New Madrid zone and in 23 St. Louis those quakes actually made waves on Lake 24 Michigan and rang church bells in Maine and broke 25 windows in Washington, D.C. It just seems like that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202) 234-4 433 127 1 should be taken into account, especially because the 2 pads that hold those huge heavy casks are built right 3 on sand dunes. 4 The last point I would like to make is 5 that Palisades does have a pretty incredible history 6 when the NRC had a watch list Palisades was on and off 7 that watch list continuously and it seems to me blind 8 on the part of the Nuclear Regulatory Commission that 9 they did away with the watch list. It seems like it 10 didn't make any sense at all. 11 The other thing is that in 1986 Palisades 12 had actually 4,000 repair orders that were backlogged.
13 I agree that was back in 1986 but I am just telling 14 you there is quite a bit of history here and it's not 15 a pretty history.
16 The other thing was in 1979 there was a 17 huge leak of radioactive iodine and the NRC actually 18 went out and checked fishing boats to check people's 19 fish for radioactive iodine. Palisades was fine 20 during that time. They were fine because when they 21 realized they were releasing radioactive iodine, they 22 did not stop. 23 I could go on and on. The public has 24 plenty that concerns us like the chemical 25 contamination that is based on Lake Station, Michigan.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 234-44 433 128 1 There's a lot of unanswered questions about this 2 plant. I would appreciate if somebody could answer 3 some of the questions that I had -- all the questions 4 I had. 5 MEMBER WALLIS: Do you want to try that? 6 CHAIRMAN SIEBER: You go ahead. 7 MEMBER WALLIS: I was thinking while you 8 were speaking about who would be the right person to 9 answer your questions.
I don't think this 10 subcommittee can answer your questions at this time. 11 They are more questions for somebody else and it 12 probably falls to the NRC in some way. 13 Then also what you have said is on the 14 record. This meeting we are having today is to gather 15 information.
It's not as if we are making a decision 16 today so how your comments go into the final decision 17 I think is yet to be decided, but they are on the 18 record and I don't think they will disappear.
Thank 19 you very much.C 20 MS. CUMBOW: Could I ask your name, sir? 21 MEMBER WALLIS: You want my name? 22 MS. CUMBOW: Um-hum. 23 MEMBER WALLIS: I'm Graham Wallis. 24 MS. CUMBOW: Okay. You know, not knowing 25 anyone or seeing any name cards it's a little hard to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 1021 234.44 433 129 1 know who is talking. What is your position, Mr. 2 Wallis? 3 MEMBER WALLIS: I am actually the Chairman 4 of the ACRS. 5 MS. CUMBOW: Of the ECRS. 6 MEMBER WALLIS: ACRS. 7 MS. CUMBOW: Oh, ACRS. Okay. Thank you. 8 MR. KARCH: My name is Gary Karch. I 9 would like to say that as a member of the public I 10 have to complain about the quality of the audio on 11 this conference call that we're connected with. 12 About the only person I could ever hear 13 clearly aside from these comments right at the end, 14 which were very clear, one of the only other persons 15 I heard well was Patricia was the only one I could 16 hear clearly. It may not have been on purpose but it 17 seems the net result is that the public could not hear 18 the proceedings clearly so I wanted to complain about 19 that. 20 You professionals are capable of talking 21 about highly technical issues here and you can split 22 atoms but you can't, you know, create a decent audio 23 system for the public to hear clearly. Therefore, my 24 other question is will there be minutes available, 25 transcript of this proceedings and how soon will that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202M 2344433 WASHINGTON, D.C. 20005 (202) 34444 130 1 be available?
2 CHAIRMAN SIEBER: There is on the NRC 3 website a copy of transcripts of ACRS meetings and 4 subcommittee meetings.
I don't know how quickly they 5 appear but I usually read them and it seems to me 6 like three weeks or four weeks after the meeting is 7 held that the transcript appears on the website. You 8 will want to go to the category Electronic Reading 9 Room on the website.
10 MR. KARCH: Okay. 11 CHAIRMAN SIEBER: When you get there you 12 look for All Document Collections.
When you get there 13 you look for ACRS and it will have schedules, meeting 14 agendas, and transcripts.
15 MR. KARCH: Right. 16 CHAIRMAN SIEBER: Look up today's date. 17 MR. KARCH: Okay. Very good. 18 MS. BARNES: Could I ask one more 19 question?
I understand that the precautionary 20 principle is being applied by the IJC, International 21 Joint Commission, which is, of course, the treaty 22 arrangement between the United States and Canada for 23 the safety and welfare of the Great Lakes. Now, how 24 does the NRC apply the precautionary principle?
25 CHAIRMAN SIEBER: I have no idea, ma'am. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (2) 234-4 433....
131 1 MS. BARNES: As I would define 2 precautionary principle, it is up to the industry and 3 the NRC and any other corporate or producer of deadly 4 waste to prove it does no harm rather than the 5 longstanding position that has been taken which is 6 that, nPublic, you prove that it was our chemical that 7 you died from," etc. Since the precautionary 8 principle is getting more and more recognition among 9 credible regulators and producers of all kinds of 10 products, how does that currently fit into the NRC 11 code? 12 CHAIRMAN SIEBER: Well, frankly, until you 13 discussed it here I had never heard of that. 14 MS. BARNES: Oh. 15 CHAIRMAN SIEBER: So I am not aware of 16 that. 17 MS. BARNES: Oh. Well, I would appreciate 18 if you would Google it. It is an extremely important 19 principle that has been, oh,. at least 10 years in 20 application to my understanding.
21 MS. HIRT: Excuse me. This is Alice Hirt 22 again and I have one more quick question if I may be 23 given that chance. I would like to ask 24 straightforward to the NRC people and the Nuclear 25 Management people at this meeting today do you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. 1202) 234-4433 WASHINGTON, D.C. 20005 (202) 23444 33 33 132 1 original coupons in the reactor vessel that can be 2 removed to check levels of embrittlement?
Could you 3 answer that please straightforward?
Original coupons 4 of the original material that the vessel was created 5 from. 6 MS. LOUGHEED:
Ma'am, I don't believe we 7 are prepared to answer that at this meeting.
8 MS. HIRT: It has a lot to do with the 9 issue. 10 MS. LOUGHEED:
Ma'am, I understand that it 11 has a very -- that it is relevant.
I'm just saying we 12 are not prepared to answer it at this meeting.
13 MS. HIRT: There is no one there that can 14 address -15 MS. LOUGHEED:
We do not have the right 16 people. 17 MS. HIRT: -- that issue? 18 MR. KARCH: You came unprepared to answer 19 questions from the public? 20 MS. LOUGHEED:
Yes. This is not a public 21 meeting. This is a meeting for the ACRS. 22 MS. HIRT: If you cannot answer that, I 23 would like the answer to that question sent to me as 24 soon as possible, please. Surely someone can answer 25 that question.
If not this afternoon tomorrow.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W (202) 2344433 WASHNGTON.
D.C. 20005 (202) 234-4433 133 1 MR. KNEELAND:
This is John Kneeland of 2 the NMC. We answered this question earlier in the 3 meeting.
4 MS. HIRT: I've been listening ever since 5 the meeting started. I know you said that there were 6 three -- I can't say the exact wording. I did hear 7 everything that was said but that does not answer my 8 exact question.
It did not say they were original, 9 very original capsules.
10 MR. KNEELAND:
They are three of the 11 original capsules that were fabricated in 1966. 12 MS. BARNES: Those are not original.
1966 13 is not -- 1966? Do you have written proof of that? 14 MR. KNEELAND:
Yes, ma'am. 15 MS. HIRT: We would like to see that, 16 please. 17 MS. BARNES: We would because we have seen 18 other things that say that is not so. 19 MS. HIRT: Could you please provide that 20 to one of us? I'll give you my name and address and 21 I would like to see that proof, please. 22 MR. KARCH: You did not allow him to 23 finish what he had. Could you say what you have? 24 MR. KNEELAND:
We have three surveillance 25 capsules remaining in the reactor vessel that have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHNGTON, D.C. 20005 (202) 234-4 133 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 134 been there since the beginning of plant operation.
We have an additional surveillance capsule that sits just above the reactor vessel that has been in there since the beginning of plant operation.
MS. BARNES: I have a question.
This is Katherine Barnes again. MS. HIRT: Thank you. I look forward to seeing that information and documentation.
MR. JUNGE: We have somebody here we need to let speak and ask questions for now if you don't mind holding your question, please. MR. KAMPS: Thank you. My name is Kevin Kamps and I work at Nuclear Information and Resource Service here in Washington, D.C. I have been asked by a number of intervenors who went before the Atomic Safety Licensing Board to represent them here today. I just wanted to say that I heard a lot during the course of this afternoon about plans and commitments in the future. I think that the ACRS as a whole should take -- and the NRC staff as well should take plans and commitments from this company with a grain of salt. One of the people on the phone brought up cask No. 4 as an example of promises by this company that have been broken in the past. The company NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (202) 234-4433 135 1 publicly stated, and it was reported in the local 2 newspapers that that container would be unloaded 3 because it had problems.
Here we are 12 years later 4 and that cask is still sitting there. 5 Another very relevant promise that was 6 stepped away from in the past had to do with the 7 embrittlement problem. Again, the company said 8 publicly that it would anneal the reactor vessel and 9 that has not happened.
I think this challenge goes as 10 much to the NRC as it does to the company and that is 11 it seems like every time that Palisades comes up 12 against the embrittlement standard at NRC that 13 standard is weakened or changed in some way. 14 It is incredible that here we are in the 15 year 2006. Palisades again is brushing up against the 16 NRC's screening criteria for pressurized thermal shock 17 and, wouldn't you know it, there's another proposed 18 change in the rules. We can only assume that is going 19 to accommodate Palisades reactor yet again not for 40 20 years of operations but for 60 years. 21 We are very concerned about the safety 22 implications of this and we call upon the ACRS and the 23 NRC to uphold NRC safety regulations.
That is the 24 mission of this agency. The stakes are too high to do 25 anything else. I would like to point out to the ACRS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. (202) 2344433 WASHINGTON.
D.C. 20005 (202M 234-44 433 W ....I f .. ...
136 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 because they might not be aware of this. The NRC staff might not be aware of this as well but the company went before regulators in Michigan on May 10th of this year. The meeting had to do with the sale of the plant and Patricia brought that up earlier that this plant is for sale. The company identified five areas that are leading it to want to sell this plant. As I understand it, at the end of June that was the time line, the deadline for submissions, bids from other companies.
I know that Exelon had a representative here today so I'm curious if they might be one of the bidders. Detroit Edison has expressed interest publicly.
Anyway, Consumers Energy listed the following five areas as reasons for wanting to sell the plant. Reactor vessel head replacement at a cost of $100 million. Steam generator replacement.
Reactor vessel embrittlement concerns.
Increasing NRC fees and fire' protection regulations.
No. 5, containment coatings on sump strainers.
I just find a disconnect or a contradiction between the company making all these commitments, promises, plans for the future while at the same time putting the plant up for sale.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENLE. N.W. WASHINGTON.
D.C. 20005 MM 234-44M (202) 234.4433 137 1 One big picture question I have is does 2 the company that buys this facility have to comply 3 with all the commitments that have been made by the 4 current owner. That is one question.
Another 5 question I have from today's presentation is although 6 the steam generator was discussed during the course of 7 today, it wasn't mentioned that there was another 8 replacement in the works. 9 There's a lot of connection between 10 current operations and 20 additional years at this 11 facility.
For safety sake and for protection of 12 public health we hope that they will be rigorously 13 addressed before this license extension is granted 14 because we see a lot of promises but I don't think 15 that promises can be accepted from this company. I 16 think facts on the ground are the only thing that can 17 be accepted.
Thanks for the opportunity to ask these 18 questions.
19 CHAIRMAN SIEBER: Okay. Thank you. I 20 think that we are to the point now where we can close 21 the record. 22 MR. KEEGEN: Could I raise one question?
23 This is Michael Keegen in Michigan.
24 CHAIRMAN SIEBER: One question.
25 MR. KEEGEN: Yes, one question.
Regarding NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE N.W. (202) 234-4433 WASHINGTON, D.C. 20005 (202) 23444 133 133 138 1 the third cycle interval in-service inspection of the 2 reactor internals, my understanding is that will occur 3 after the relicensing process. How can the ACRS 4 approve relicensing when they haven't looked under the 5 hood, so to speak? Did that get addressed?
I didn't 6 hear it. 7 CHAIRMAN SIEBER: Yeah. I'm contemplating 8 your question.
You are, of course, aware that every 9 plant whether it has a renewed license or an original 10 license is on a 10-year ISI cycle. 11 MR. KEEGEN: Correct.
12 CHAIRMAN SIEBER: That means that the 13 basic structure of the plant all the components during 14 various outages during that 10-year interval are 15 inspected to make sure that they have integrity.
The 16 idea of having a structured timed program like that is 17 to be able to measure degradation.
18 If you were to advance one of those 10 19 year intervals to now to accommodate license renewal, 20 then there will be a period where you would not have 21 information.
That would be a concept that violates 22 the ASME code which is what -23 MR. KEEGEN: I believe that is what 24 precisely is occurring.
They have requested a delay 25 of that inspection until beyond their relicensing.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. (202) 234-4433 WASHINGTON.
D.C. 20005 (20 2344433 1 2 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 139 They have actually over the course of 35 years they have not done their third 10-year inspection yet and it is being deferred deferred.
CHAIRMAN SIEBER: Well, I think that's an issue that is current operation and I'm sure that the staff can address that. MR. KEEGEN: Wouldn't the ACRS be concerned about having the results of that inspection prior to issuing a 20-year license renewal? That is my question.
CHAIRMAN SIEBER: I really don't know what the answer to that question is until the issue is resolved.
MR. KEEGEN: It's unresolved, and yet you are making a decision for 20 more years of license extension.
That's my point. CHAIRMAN SIEBER: We are not making a decision.
MEMBER WALLIS: Let me suggest this might be something we will look into because we are not making a decision today. MR. KEEGEN: Very good. Very good. That is satisfactory if you look into it and it's part of the public record. CHAIRMAN SIEBER: Okay. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE, N.W. 234-443 WASHINGTON.
D.C. 20005 ( 2342"M3 140 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 MR. KEEGEN: MS. BARNES: Thank you. Thank you for letting us speak. CHAIRMAN SIEBER: You're welcome. Any other comments?
If there are no further comments, I think that we can close the transcript at this point. I want to thank everyone who has participated in the meeting today for their work and their patience with the process. This meeting is adjourned. (Whereupon, at 4:59 p.m. the meeting was adjourned.)
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVENUE. N.W. WASHINGTON.
D.C. 20005 (202) 234-4433 (202) 234-4433 CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: Name of Proceeding:
Advisory Committee on Reactor Safeguards Subcommittee on Plant License Renewal Docket Number: n/a Location:
Rockville, MD were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
Charles Morrison Official Reporter Neal R. Gross & Co., Inc. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com Palisades Nuclear Plant License Renewal Safety Evaluation Report Staff Presentation to the ACRS Juan Ayala, Project Manager Office of Nuclear Reactor Regulation July 11,12006 1
)Introduction
- Overview* Section 2: Scoping and Screening Review* License Renewal Inspections
- Section
- Section 3: Aging Management Review Results 4: Time-Limited Aging Analyses (TLAAs)2 C ( Overview* LRA submitted by letter, dated March
- CE PWR-DRYAMB containment 22, 2005 e 2565 MWth, 865 MWe* Operating License DRP-20 expires March 24, 2011 PNP located 5 miles S of South Haven, M! "/ : 3 D Overview
- SER issued June 1, 2006
- No Open Items
- One Confirmatory item
- Four (4) license conditions
- 174 RAis issued, 412 audit questions
- ~95% consistent with-. draft-GALL Report, Revision 1.
- Minor components brought into scope 4 Review Highlights
- Scoping and Screening Methodology Audit -June 27 -July 1,. 2005
- Regional Inspections
-October 24 -28, 2005 -November 14 -18, 2005 ,5 Section 2: Scoping and Screening Review Section 2.1-Scoping and Screening Methodology
- On-site Audit- June 27-July 1, 2005* Staff audit and review concluded that the applicant's methodologysatisfies the rule (10 CFR 54.4(a) and 10 CFR 54.21) -AFW Pump Room pipe insulation brought into'scope Section 2.2 Plant-Level Scoping No omission of systemrfs' orstructures within the scope of license renewal 6 C_C Section 2: Scoping and Screening.
Review Section 2.3
- 29 meche-Mechanical Systems tnical systems* 100% reviewed
- On-site review of mechanical -systems
- 0 items referred to Regional inspection team 7 JS Section 2: 'Scoping and Screening Review Section 2.3 -Mechanical Systems Components brought into scope -Steam generator feedwater ring -Boric acid pump filters -Air supply line and air reservoirs
-Solenoid valves -First and second stage air compressors,
- including the load/unload -valves Feedwater heaters.,..'
Primary system make-up storage tank underground piping 8 Section 2: Scoping and Screening Review Section 2.4 -.Containment, Structures, and Supports
- No omission of structures or supports within the scope of license renewal Section 2.5 -Electrical and Instrumentation
& Control o No omission of electrical and instrumentation
& control systems components within the scope of license renewal 9 Section 2: Scoping and. Screening Summary
- The applicant's scoping methodology .meets the requirements'of 10 CFR Part 54 ° Scoping and screening results, as amended, included all SSCs within the scope of license renewal and subject to AMR 10 C .C C *License Renewal Inspections Patricia Lougheed Region III 11
.)Overview
- Two-week onsite inspection from October 24 to November 16, 2005* Scheduled to support NRR reviews* Team of five experienced inspectors
- Inspection performed in accordance with NRC Inspection Procedure 71002 12 C.C Scoping and Screening
- Reviewed 11 systems
- Looked at electrical, structural, and mechanical systems
- Emphasized plant physical walk downs
- Concentrated on non-safety systems whose failure could impact safety systems 13
_D Scoping and Screening Conclusions " Systems appropriately scoped " Some -minor inconsistencies identified " Scoping and screening acceptable for license renewal 14 A C (. C Aging Management
- existing plant documentation
- operational experience information e corrective actions to current plant issues and
- proposed enhancements and commitments
- Followed up on NRR review efforts o Performed plant walk downs 15 Aging Management Conclusions
- Aging Management Programs adequate for period of extended operation when enhanced or implemented in accordance with commitments 16 Overall Conclusions
- Palisades scoping, screening and aging management programs sufficient for extended operation o Region 1.1 does not see any inspection impediments to renewing the operating license 17 Current Performance
- Licensee is in the Licensee Response Column (Column 1) of the NRC's Action Matrix
- NRC does not currently have any cross cutting issues open at Palisades
- Revised Reactor Oversight Process continues to be followed 18 0 0 Performance Indicators Performance Indicator.
I T-1 WM;!, 19 Inspection Findings I I III I I III I I I I Most Significant Inspection Findings IQ/20C8 3Q12005 20 C_C Section 3: Aging Management Review Results*3.1 Reactor Coolant System e*3.2. .3.3 Engineered Safety Features Auxiliary Systems* 3.4 Steam and Power Conversion Systems e 3.5 Containments, Structu Component Supports res, and* 3.6 Electrical and I&C Components 21 J D Aging Management Programs (AMPs)* 24 AMPs-20 existing AMPs, 4 new AMPs -Consistent with GALL Report Consistent with GALL Report with exceptions/
enhancements 10 Plant-specific
-1 22 C C Buried Services Corrosion*
Monitoring Program New AMP Consistent with GALL 10-year frequency If insufficient data exist, focused inspections will be performed
-Include inspections of opportunity -Only one below-grade tank ° Diesel fuel oil storage tank is contained in a vault and not exposed to soil 23 Bolting Integrity Program -Existing AMP Consistent with enhancements (2) -(.1) review and revise the ASME ISl master plan and plant maintenance procedures to reflect GALL Report. -guidance and -(2) evaluate high-strength bolting used in component supports for cracking* System Monitoring Program -Non-Safety Related bolting 0 Structural Monitoring Program-Structural bolting
- ASME Section X1 IWB, IWC, IWD, IWF ISI Program -ASME Class 1, 2, and 3 bolting 24 C ( Boric Acid Corrosion Program
- Enhancements were provided as commitments e Three (3) Commitments
-Revise procedures to include criteria for observing susceptible SSC for boric acid leakage and degradation during system walkdown inspections.
-Revise procedures to include explicit acceptance criteria for boric acid inspections.
Revise procedures to include inspection of structural steel and non-ASME component supports for evidence of boric acid residue and boric acid wastage/corrosion.
25 Flow-Accelerated Corrosion Program
- NSR piping brought to- same criteria as safety-related piping 26 C C Reactor Vessel (RV) Integrity Surveillance Programr
- Enhancements were submitted as commitments " Four (4) Commitments Ensure that pressure-temperature and LTOP curves are updated to bound the extended' operating period. Curves will -be updated and submitted to NRC for approval prior to the period of extended operation Document and establish the requirement to save and store all pulled and tested RV surveillance capsules for future reconstitution use.27
- 9) .0 °K)D Reactor Vessel (RV) Integrity Surveillance Program Four (4) Commitments (continued) -Ensure-that at least one surveillance capsule remains in the RV and is tested during the period of extended operation to monitor the effects of neutron irradiation.
Develop a program level procedure to implement and control Technical Specification and FSAR activities associated with the RV Integrity Surveillance Program.28 C. C C System Monitoring Program
- Plant specific AMP consistent with GALL. AMP XI.M29, "Aboveground Carbon Steel Tanks" o Used to identify degraded conditions on external surfaces of piping, tanks, and other components and equipment o Opportunistic inspections of external surfaces when insulation is removed
- Commitment
-If there is insufficient data, applicant will remove insulation in additional locations to increase sample size 29 Section 3: Aging Management Review Results So100% Review -29 plant systems -10. structures
-9 commodity groups 30 SC C Auxiliary Systems
- SFP Neutron Absorbing Sheets -For fuel racks with boron carbide panels, no .coupon program exists Applicant has committed to performing industry approved neutron absorption testing to monitor for degradation.
- Thermal Sleeves -Aging effects requiring management added for cracking due to SCC and PWSCC -Managed with ASME Section XI ISI and Water Chemistry Programs 31 D.D Aging Management of In-Scope I naccessible Concrete Acceptance PNP Criteria 1966 1996 2004 pH >5.5 6.1 -7.7 N/A 7.0 Chlorides
<500 ppm .4.0-39 23 139 Sulfates <1500 ppm 9.47 -33.17 15.2 11.5
- Below-grade environment is non-aggressive
- Periodic testing of ground water will be performed as part of the .Structures Monitoring Program 32 C C1 Electrical and I&C Components 9 commodity groups reviewed -Electrical cables and connections not subject to 10 CFR 50.49 EQ requirements
-Electrical cables and connections used in instrumentation circuits not subject to 10 CFR 50.49 EQ requirements that are sensitive to reduction in conductor IR -Electrical Portion of the Non-EQ Electrical and i&C Penetration Assemblies (Cables and Connections)
-Fuse Holders -Non-Segregated Phase Bus and Connections
-High-Voltage Transmission Conductors
-High-Voltage Switchyard Bus and Connections
-Inaccessible medium-voltage (2kV to 15kV) cables and connections not subject to 10 CFR 50.49 EQ requirements
-High-Voltage Insulators 33
._)Section 4: Time-Limited Aging Analyses* (TLAA)* 4.1 TLAA Process
- 4.2 Reactor Vessel Neutron Embrittlement
- 4.3 Metal Fatigue
- 4.4 Environmental Qualification of Electrical Equipment
- 4.5 Concrete Containment Tendon Prestress Analysis
- 4.6 Containment Liner Plate and Penetrations Load Cycle
- 4.7 Plant Specific TLAA -4.7.1 Crane Load Cycles -4.7.2 Alloy 600 Nozzle Safe Ends Life Assessment Analysis -4.7.5 Reactor Pump Fly Wheel Fatigue or.Crack Growth Analysis -4.7.6 Reactor Vessel Underclad Cracking (New TLAA)34 OtRE -Section 4-Overview Section 4.2: Reactor Vessel and Internals Neutron Embrittlement -Three analyses affected by irradiation embrittlement identified as TLAAs e Pressurized Thermal Shock
- Upper Shelf Energy. e Pressure Temperature Limits *Applicant used 42.37 EFPY (60 years).35 J.....Section 4 .-Overview RV Pressurized Thermal Shock Limiting Screening Calculated 42.37 Conclusion Material Criteria EFPY RTpTs for PTS value Intermediate 270 OF Applicant:
287 OF Screening shell and (Calculation Criterion is lower shell- Confirmed exceeded in axial welds a2014 (W521 4) by Staff)36 Section 4- Overview Palisades Plan for PTS Continue to use an ultra low leakage core design Submit final PTS resolution three years before 2014 (10 CFR 50.61)
- Options
- Change of operation:
further flux reduction and preheating the safety injection water
- Thermal annealing of the reactor pressure vessel (10 CFR 50.66)37 J 9 6.Section 4-Overview* RV Upper Shelf Energy (USE)Limiting Plate Acceptance Calculated USE Conclusion and Weld Criterion Value for 42.37 for USE EFPY Lower shell Projected USE 48.97 ft-lbs Acceptance plate > 50 ft-lbs (Calculation criterion is (D-3804-1)
Confirmed exceeded in by Staff) 2021 Intermediate to Projected USE 50.83 ft-lbs Acceptable lower shell circ. > 50 ft-lbs (Calculation
[TLAA satisfies Weld Confirmed
§54.21 (c)(1)(ii)]
(9-112) by Staff)38 c c Section 4-Overview* Palisades Plan for USE -Submit Equivalent Margins Analysis (EMA)three years before 2021 (10 CFR 50, Appendix G)39
',) 5) Section 4.3: Metal Fatigue
- Acceptability Criterion:
Cumulative Usage Factor,-CUF
_ 1.0 for all ASME Class 1 piping components based on a 60-year life
- Staff accepted the evaluations in accordance with 10 CFR 54.21 (c)(1)(i),(ii) and (iii)1.40 C C Section 4.4: Environmental Qualification ( (EQ) of Electrical Equipment
- Applicant's EQ Program consistent with. GALL AMP X.E1, "Environmental Qualification of Electrical Equipment"
- Staff concluded the EQ Program is adequate to manage the effects of aging on the intended function of electrical components
- The staff accepted the evaluation in accordance with 10 CFR 54.21 (c)(1.)(iii) 41
,j'9D A Reactor Vessel 711Cr. Underclad Cracking Confirmatory Item: Underclad Crack Growth-Technical basis is WCAP 15338-A which has been approved.
by the staff -Staff- is verifying a plant specific WCAP, using-the same methodology as WCAP 1 .PNP 5338-A, for 42 C C-A. TLAA Summary..
- TLAA list was complete and acceptable in accordance with 10 CFR 54.3
- 10 CFR 54.21 (c)(1) -(i) -analyses remain valid for PEO (ii) analyses projected to the end of the PEO (iii) -effects of aging will be adequately managed for the PEO
- There are no plant-specific exemptions in accordance with 10 CFR 54.21 (c)(2)43 Conclusions The staff has concluded that there is reasonable assurance that the activities authorized by the. renewed license. will continue to be conducted in accordance with the CLB° Any changes made to the in accord with the Act and Commission's regulations with 10 CFR 54.29(a)PNP CLB are the and to comply 44 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee
~a.q3 July 11, 2006 W-61 6ý-r ,.,OF Palisades Nuclear Plant Presentation to ACRS Ucense Renewal Subcommittee Attendees " Darrel Turner -Site Manager of Projects " John Broschak -Site Engineering Director " Bob Vincent -License Renewal Project Manager " Paul Harden -Site Vice President " Mark Cimock -Mechanical and Civil/Structural Lead " Larry Seamans -Electrical Lead .w Bill Roberts -Programs Lead " John Kneeland -TLAA Lead " Brian Brogan -Site PRA / Safety Analysis Lead 2 1 Palisades Nudear Plant Presentallon to ACRS License Renewal Subcommittee Agenda " Description of Plant " Plant Licensing History " Major Plant Modifications
- Current Plant Status " License Renewal Methodology " Commitment Management " Technical Issues -Pressurized Thermal Shock -Intergranular Separation
-GSI-191 3 Palisades Nuclear Plant Presentation to ACRS Ucense Renewal Subcommittee Plant Description " Owned by Consumers Energy Company " Operated by Nuclear Management Company " 432 Acre Site Located in Covert, Michigan " Combustion Engineering NSSS / Bechtel AE -2 Loops, 4 Primary Coolant Pumps, 2 Steam Generators " Pre-Stressed Concrete Containment 4 N.-2 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee Plant Description " Forced Draft Cooling Towers " Ultimate Heat Sink is Lake Michigan via Service Water System " Licensed Power 2565.4 Mwt. " Design Electrical Output 820 Mwenet w Plant PRA Shows Overall CDF (Internal Events) 2.86E-05/yr; LERF 3.55E-71yr 5 fmMb 5 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee Licensing History m 1967 -Construction Permit Issued .1971 -Provisional Operating License (POL) Issued to Expire In 2007 m 1974 -Applied for Full Term Operating License (FTOL) n 1978 -1983 -NRC Systematic Evaluation Program u 1991 -FTOL Issued to Expire in 2007 w 2000 -License Expiration Changed to March 24,2011
- 2005 -Licensed Power Raised from 2530 Mwt to 2565.4 Mwt ~wum 6 3 Paisades Nuclear Plant Presentation to ACRS Ucense Renewal Subcommittee Major Plant Modificationsllmprovements n 1974-75 -Converted Once-Through Circulating Water to Cooling Towers, Retubed Condenser m 1977, 1987- Expanded Spent Fuel Pool Storage a 1983 -Added Third Auxiliary Feedwater Pump and Upgraded System to Safety-Grade x 1983 -Upgraded Control Room HVAC to Safety-Grade 7 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee Major Plant Modificationsllmprovements
- 1985-86 -Initial PRA Applications at Palisades
- 1989 -Diversified Connection Paths to Offsite Power Supplies (PRA Insight)
- 1990 -Replaced Steam Generators
- 1990 -Retubed Main Condenser and Feedwater Heaters
- 1993 -Implemented Dry Spent Fuel Storage (VSC-24) Itma 8 &j 4 Palisades Nuclear Plant Presentation to ACRS Ucense Renewal Subcommittee Major Plant Modificationslimprovements
- 2004 -Implemented Second Dry Spent Fuel Storage System (NUHOMS)
- 2006 -Implemented SAMA Improvement Non-Safety Backup Diesel Generator Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee Current Plant Status m Operating at 100% Power in 19th Cycle n Next Refueling Outage Fall 2007 n All NRC Performance Indicators are Green Pj n No NRC Inspection Findings >Green 10 0011 5 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee License Renewal Application Methodology is LRA Dated March 22, 2005 n NEI 95-10 Standard Format a NUREG 1801 (GALL) Revision 0 (2001) [ NUREG 1800 (SRP-LR) was Revision 0 (2001) n Interim Staff Guidance Documents (ISGs) were Addressed in LRA w Project was Staffed-with Plant-Experienced Leads and LR-Experienced Support ifu~ 110 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee License Renewal Application Methodology a Scoping, Screening and Aging Management Reviews Performed to Industry Standards a Experiences of Prior Applicants Incorporated a Implemented Spaces Approach for 10 CFR 54.4(a)(2)
[ LRA System Descriptions and Boundaries Consistent with FSAR is AMR Results in LRA Reconciled to GALL Revision 0 (2001)6* .9c 12~atmW 12 6 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee License Renewal Application Methodology
- Assessed Consistency of Results with January 2005 Draft Revision 1 of GALL a Reassessed Consistency after Final GALL Revision I Issued in September 2005
- 24 Aging Management Programs (4 new, 20 existing)
"1 ~svmm13 Palisades Nuclear Plant Presentation to ACRS License Renewal Subcommittee Commitment Management w Commitments for Future Action are Confirmed In SER Appendix A s Commitments are Tracked in Plant Corrective Action Program m Program Descriptions, TLAA Descriptions, and Commitments will be Incorporated Into FSAR ._~7 Palisades Nuclear Plant Pfesentatlon to ACRS Lcense Renewal Subcommittee Technical Issues " Pressurized Thermal Shock " Intergranular Separation " GSI-191, Assessment of Debris Accumulation on PWR Sump Performance IK"W>15 140 Pressurized Thermal Shock (PTS) a Reach 10 CFR 50.61 Screening Criterion in 2014 a AggressiveFlux Reduction Implemented by Ultra-low Leakage Core Design a Participating in NRC Research Program Developing Updated Technical Methodology a Alternatives are Available to Manage Issue for Period of Extended Operation a Proposed 10 CFR 50.61 Rule Change may Preclude Need for Plant-Specific Management Strategy (%J 8 Intergranular Separation (Under-Clad Cracking) " Generic Industry Question in 1970s -Acceptable for 40 Years " Westinghouse Evaluated for 60 Years in WCAP 15338 (NRC Accepted Methodology and Results) " Palisades Evaluated Using Same Methodology " Palisades Results Consistent with WCAP-15338
-Little/No Growth Over 60 Years -No Effect on Structural Integrity
- Results Reported to NRC for Review and Acceptance mgta17 bi2 GSI-191: "Assessment of Debris Accumulation on PWR Sump Performance" " GSI-1 91 Applicable to All PWRs (GL 2004-02) " Palisades will install Passive Sump Strainers by 12/31/07 i License Amendment requested for Removal of Tn-Sodium Phosphate and Manual Injection of Sodium Hydroxide n Alternate Buffering System will be installed by 12/31/2007 Im-E--~18 9 Backup Slides 10 Palisades Aging Management Programs " Alloy 600 Program " ASME Section XI IWB, IWC, IWD, IWF Inservice Inspection Program
- Bolting Integrity Program " Boric Acid Corrosion Program " Buried Services Corrosion Monitoring Program (new) " Closed Cycle Cooling Water Program " Compressed Air Program " Containment Inservice Inspection Program " Containment Leakage Testing Program " Diesel Fuel Monitoring and Storage Program " Fire Protection Program " Flow Accelerated Corrosion Program 21 .4J .')Palisades Aging Management Programs (cont) w Non-EQ Electrical Commodities Condition Monitoring Program (new) a One-Time Inspection Program (new) a Open Cycle Cooling Water Program w Overhead Load Handling Systems Inspection Program n Reactor Vessel Integrity Surveillance Program a Reactor Vessel Internals Inspection Program a Steam Generator Tube Integrity Program n Structural Monitoring Program n System Monitoring Program a Water Chemistry Program a Electrical Equipment Qualification Program a Fatigue Monitoring Program (new) zz22 .+/-I c 11 SAMA Candidates The following SAMA Candidates are Being Evaluated: , Modify Turbine-driven AFW Pump procedures to Support Indefinite Operation Without AC, DC or Air Services " Add Nitrogen Backup to Critical instrumentation to Reduce Importance of Loss of Instrument Air " Insulate Emergency Diesel Generator Exhaust Ducts to Reduce Potential for Room Overheating " Replace Bus Undervoltage Relays with Seismically Qualified Models ,, Modify PCS Cooldown Procedures to Reduce Probability of Reactor Coolant Pump Seal Failures &M9*23 _:4J _ M-C'), SAMA Candidates (cont)
- Install Direct Drive Diesel Injection Pump to Back Up Turbine-driven AFW Pump a Install Additional Emergency Diesel Generator is Install Permanent, Dedicated Cooling Water Line to Emergency Diesel Generators n Provide Additional Field Flashing Capability to Emergency Diesel Generators
- Replace Air-Operated Containment Sump Valve with Motor-Operated Valve i24 12 mm 13 2005 Palisades Performance a Highest Production Year, 5% Higher Than Previous Best a 9 of Last 10 Years Are Top-10 Generation Years a NMC Fleet Standardized Organization Fully Implemented at Palisades a Lowest Yearly Radiation Dose Record, 50% Lower Than Previous Best w Industry 'Top Quartile' On-Line Corrective Work Order Backlog at 9 a Industry 'Top Quartile' On-Line Elective Maintenance Backlog at 263 a New Reactor Head Has Been Forged 27 14
- Auxiliary Systems
- SFP Neutron Absorbing Sheets -For fuel racks with boron carbide panels, no coupon program exists -.Applicant has committed to performing industry approved neutron absorption testing to monitor for degradation.
- Thermal Sleeves -Aging effects requiring management added for cracking due to SCC and PWSCC -Managed with ASME Section Xl ISI and Water Chemistry Programs 31 D)Aging Management of In-Scope Inaccessible Concrete Acceptance PNP Criteria .1966 1996 2004 pH >5.5 6.1 -7.7 N/A 7.0 Chlorides
<500 ppm 4.0.-39 23 139 Sulfates <1500 ppm 9.47 -33.17 15.2 11.5
- Below-grade environment is non-aggressive
- Periodic testing of ground water will be performed as part of the-Structures Monitoring Program 32 C Electrical and I&C Components 9 commodity groups reviewed -Electrical cables and connections not subject to 10 CFR 50.49 EQ requirements
-Electrical cables and connections used in instrumentation circuits not subject to 10 CFR 50.49 EQ requirements that are sensitive to reduction in conductor IR Electrical Portion of the Non-EQ Electrical and I&C Penetration Assemblies (Cables and Connections)
-Fuse-Holders
-Non-Segregated Phase Bus and Connections
-High-Voltage Transmission Conductors
-High-Voltage Switchyard Bus and Connections
-Inaccessible medium-voltage (2kV to 15kV) cables and connections not subject to. 10 CFR 50.49 EQ requirements
-High-Voltage Insulators 33
_D Section 4: Time-Limited Aging Analyses (TLAA)* 4.1 TLAA Process
- 4.2 Reactor Vessel Neutron Embrittlement
- 4.3 Metal Fatigue
- 4.4 Environmental Qualification of Electrical Equipment
- 4"5 Concrete Containment Tendon Prestress Analysis
- 4.6 Containment Liner Plate and Penetrations Load Cycle
- 4.7 Plant Specific TLAA -4.7.1 Crane Load Cycles -4.7.2 Alloy 600 Nozzle Safe Ends Life Assessment Analysis -4.7.5 Reactor Pump Fly Wheel Fatigue or Crack Growth Analysis -4.7.6 Reactor Vessel Underclad Cracking (New TLAA)34 Section 4- Overview Section 4.2: Reactor Vessel and Internals Neutron Embrittlement Three analyses affected by irradiation embrittlement identified as TLAAs
- Pressurized Thermal Shock ° Upper Shelf Energy Pressure Temperature Limits
- Applicant used 42.37 EFPY (60 years)35
.D..j)Section 4-Overview e RV Pressurized Thermal Shock Limiting Screening Calculated 42.37 Conclusion Material Criteria EFPY RTpTs for PTS value Intermediate 270 OF Applicant:
287. OF Screening shell and (Calculation Criterion is lower shell Confirmed exceeded in axial welds .2014 (W5214)by Staff)36 Section 4 Overview Palisades Plan for PTS -Continue to use an ultra low leakage core design -Submit final PTS resolution three years before 2014 (10 CFR 50.61) Options
- Change of operation:
further flux reduction and preheating the safety injection water
- Thermal annealing of the reactor pressure vessel (10 CFR 50.66)37 Section 4-,Overview
- RV Upper Shelf Energy (USE)Limiting Plate Acceptance Calculated USE Conclusion and Weld Criterion Value for 42.37 for USE EFPY Lower shell Projected USE 48.97 ft-lbs Acceptance plate > 50 ft-lbs (Calculation criterion is (D-3804-1)
Confirmed exceeded in by Staff) 2021 Intermediate to Projected USE 50.83 ft-lbs Acceptable lower shell circ. > 50 ft-lbs (Calculation
[TLAA satisfies Weld Confirmed
§54.21 (c)(1)(ii)]
(9-112) by Staff)38
-Overview C Section 4* Palisades Plan for USE -Submit Equivalent Margins Analysis (EMA)threeyears before 2021 (10 CFR 50, Appendix G)39
_D Section 4.3: Metal Fatigue " Acceptability Criterion:
Cumulative Usage Factor, CUF._ 1.0 for all ASME Class 1 piping components based on a 60-year life
- Fatigue Monitoring Program will ensure that the CUF remains __ 1 for PEO o Staff accepted the evaluations in accordance with 10 CGFR 54.21 (c)(1 )(i),(ii) and (iii)40
.Section 4.4: Environmental Qualification (EQ) of Electrical Equipment
- Applicant's EQ Program consistent with GALL AMP X.E1, "Environmental Qualification of Electrical Equipment"
- Staff concluded the EQ Program is adequate to manage the effects of aging on the intended function of electrical components
- The staff accepted the evaluation in accordance with 10 CFR 54.21 (c)(1)(iii) 41 9_D Reactor Vessel Underclad Cracking , Confirmatory Item: Underclad Crack Growth-Technical basis is WCAP 15338-A which has been approved by the staff -Staff is verifying a plant. specific WCAP, using the same methodology as WCAP PNP 15338-A, for 42 m" TLAA Summary I,
- TLAA list was complete and acceptable in accordance with 10 CFR 54.3
- 10 CFR 54.21 (c)(1) -(i) analyses remain valid for PEO -(ii) analyses projected to the end of the PEO -(iii) effects of aging will be adequately managed for the PEO
- There are no plant-specific exemptions in accordance with 10 CFR 54.21 (c)(2)43 I-)1)Conclusions The staff has concluded that there is reasonable.
assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the CLB* Any changes made to the in accord with the Act and Commission's regulations with 10 CFR 54.29(a)PNP CLB are the and to comply 44