ML072841102
| ML072841102 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/18/2007 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| SECY RAS | |
| References | |
| 50-219-LR, AmerGen-Intervenor-15, RAS 14325 | |
| Download: ML072841102 (49) | |
Text
Citizens Exhibits 15 R45s4(
,og6-Official Transcript of Proceedings 4
3-*,3 7 6 NUCLEAR REGULATORY COMMISSION
Title:
Advisory Committee on Reactor Safeguards Subcommittee on Plant License Renewal Docket Number:
Location:
Date:
(not applicable)
Rockville, Maryland PROCESS US TEMPLATE: A SUNSI REVIE ING ADAMS CRS/ACNW-005 W COMPLETE DWW No.
Noa 5fiu_-
2
- _9-R L--
Thursday, January 18, 2 6" ED by: Applicant/I, NRC :,
IDEhMIFIED o0
~
fj IVA Action Takcen:
ADM TT rWOPhAMA Work Order No.:
NRC-1 398 Pages 1-371 DOCKETED USNRC October 1, 2007 (10:45am) onj 0
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
,AO.p.5Fs7"lcop OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF sC6Y-oy-e
DISCLAIMER UNITED STATES NUCLEAR REGULATORY COMMISSION'S ADVISORY COMMITTEE ON REACTOR SAFEGUARDS January 18, 2007 The contents of this transcript of the proceeding of the United States Nuclear Regulatory Commission Advisory Committee on Reactor Safeguards, taken ori January 18, 2007, 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.
.,2
1 1
UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY CQMMISSION 3
+ + + +. +
4 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) 5 SUBCOMMITTEE ON PLANT LICENSE RENEWAL 6
OYSTER CREEK GENERATING STATION 7
8
- THURSDAY, 9
JANUARY 18, 2007 10
+ + + + +
11 The meeting was convened in Room T-2B3 of 12 Two White Flint
- North, 11545 Rockville
- Pike, 13 Rockville,
- Maryland, at 8:30 ar.m.,
DR.
OTTO L.
14 MAYNARD, Chairman, presiding.
15 MEBERS PRESENT:
16 OTTO L.
- MAYNARD, Chairman 17 GRAHAM B.
- WALLIS, Vice-Chairman 18 WILLIAM J.
- POWERS, ACRS Member 21 JOHN D.
SIEBER, ACRS Member 22 SAID ABDEL-KHALIK, ACRS Member 23 J.
SAM ARMIJO, ACRS Member 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 NRC STAFF PRESENT:
2 LOUISE LUND 3
DONNIE ASHLEY 4
MICHAEL JUNGE 5
BARRY GORDON 6
RICH CONTE 7
JIM DAVIS 9
NOEL DUDLEY 10 P.
T.
KUO 11 SUJIT SAMMADAR 12 13 ALSO PRESENT:
14 MIKE GALLAGHER 15 PETE TAMBURRO 16 FRED POLASKI 17 AHMED OUAOU 18 HARDIYAL MEHTA 19 HOWIE RAY 20 TOM QUINTENZE 21 JOHN O'ROURKE 22 TIM O'HARA 23 JON CAVALLO 24 MARTY McALLISTER 25 JASON PETTI S
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24.
25 ALSO PRESENT (Continued):
MIKE HESSHEIMER PAUL GUNTER RICHARD WEBSTER NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I-N-D-E-X 2
AGENDA ITEM PAGE 3
Opening Remarks 6
4
- 0. Maynard, ACRS 5
Staff Introduction 8
- 6 Louise Lund, NRR 7
AmerGen Oyster Creek Presentation 10 8
A.
Drywell Shell Corrosion Overview 17 9
Fred Polaski 10 B. Drywell Shell Thickness Analysis 53 11 Dr. Hardayal Mehta (GE),
12 Ahmed Ouaou
.13.
C.
Drywell Sand Bed Region 120 14 John O'Rourke, Jon Cavallo, 15 Pete Tamburro, Howie Ray 16 D. Embedded Portions of the Drywell Shell 180 17 John O'Rourke, Barry Gordon, 18 Howie Ray 19 E. Upper Drywell Shell 235 20 John O'Rourke, Howie Ray 21 NRC Staff Presentation 22 A.
introduction/Overview 247 23 Donnie Ashley, NRR 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1I-N-D-E-X (Continued) 2 AGENDA ITEM (Continued)
PAGE 3
NRC Staff Presentation (Continued) 4 B. NRC inspection during 2006 outage 248 5
Richard Conte, Region I 6
Tim O'Hara, Region I 7
Michael Modes, Region I 8
C. Status of Open Items/Licensee 260 9
Commitments 10 Donnie Ashley, NRR 11 Hans Ashar, NIRR 12 D. Confirmatory Analysis of Drywell -
266 13 Sandia Model 14 Hans Ashar, NRR 15 Jason Petti, SNL 16 E. Socket Welds 305 17 Jim Davis, NRR 18 Public Comment 308 19 Paul Gunter (NIRS) 20 Richard Webster (RELC) 21 Subcommittee Discussion 353 22
- 0. Maynard, ACRS 23 24 25 S.
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P-R-O-C-E-E-D-I-N-G-S 2
(8:33 a.m.)
3 OPENING REMARKS 4
CHAIRMAN MAYNARD:
This meeting will now 5
come to order.
This is a meeting of the Plant License 6
Renewal Subconmmittee.
I am Otto Maynard, Chairman of 7
the Plant License Renewal Subcommittee for the Oyster 8
Creek license renewal application.
9 ACRS members in attendance are Jack 10 Sieber, Said Abdel-Khalik, Sam Armijo, Dana Powers, 11 Graham Wallis, Bill Shack, and Mario Bonaca.
Michael 12 Junge of the ACRS staff is the designated federal 13 official for this meeting.
He is to my right.
14 The purpose is this meeting is to review 15 the license renewal application for the Oyster Creek 16 generating station, the draft safety evaluation report 17 and associated documents with focus on questions that 18 were raised during the October 3rd, 2006 License 19 Renewal Subcommittee meeting.
20 We will hear presentations from 21 representatives of the Office of Nuclear Reactor 22 Regulation, Region I
- office, and AmerGen Energy 23 Company.
The subcommittee will'gather information, 24 analyze relevant issues and facts, and formulate 25 proposed positions and actions as appropriate for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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deliberation by the full Committee.
2 The rules for participation in today's 3
meeting were announced as part of the notice for this 4
meeting previously published in the Federal Register 5
on January 25th, 2006.
That's 71 FR 4177.
6 We have received requests for time to make 7
oral statements from Paul Gunter of Nuclear 8
Information Resource Service and from Richard Webster 9
of the: Rutgers Environmental Law Clinic.
These 10 statements will be considered as part of the 11 Committee's information-gathering -process.
We have 12 provided time on today's agenda for these oral 13 statements.
14 Comments should be limited to the issues 15 associated with the Oyster Creek generating station 16 license renewal application or draft safety evaluation 17 report with focus on questions that were raised during 18 the October 3rd, 2006 License Renewal Subcommittee 19 meeting.
20 We have received no written comments from 21 members of the public regarding today's meeting.'
I 22 will say that we did receive information from Mr.
23 Webster in response to some questions that were at the 24 last meeting and also copies of some of their proposed 25: o presentation material NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE. NW.
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A transcript of the meeting is being kept and will be made available as stated in the Federal Register notice.
Therefore, we request that participants in this meeting use the microphones located throughout the meeting roQm when addressing the Subcommittee.
Participants should first identify themselves and speak with sufficient clarity and volume so that they can be readily heard.
It's going to-be important to follow the agenda today.
I am sure we will deviate some, but we do have important presentations from the license, from the NFRC staff, and from members of the public.
So I will be watching the time.
And we all need to be paying attention to that, make sure we do focus on the right areas to get the right issues addressed in today's meeting.
I will now proceed with the meeting.
And I call on Ms.
Louise Lund of the Office of Nuclear Reactor Regulation to begin.
MS.
LUND:
Well, thank you.
STAFF INTRODUCTION MS.
LUND:
And good morning.
My name is Louise Lund.
I am the Branch Chief of License Renewal Branch A in the Division of License Renewal.
'Beside me is Dr.
P.
T.
- Kuo, our Acting Director for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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Division of License Renewal.
2 The staff has continued their review of 3
the Oyster Creek generating station license renewal
-4 application, which was submitted in July of 2005.
Mr.
.5 Donnie Ashley,-- here to my right, is the project 6
manager for this review.
He will lead the staff's 7
presentation in the afternoon.
8 In addition, we have several NRC members 9
from Region I to discuss inspections that were held 10 last October at Oyster Creek.
We also have several 11 members of the NRC technical staff in the audience to 12 provide additional information and answer your 13 questions.
14 As Dr. Maynard said at the last meeting in 15 October last year,. the ACRS Subcommittee had a number 16 of questions.
As a result of the meeting, the 17 Committee requested additional information, 18 specifically about the drywell
- shell, from the 19 applicant, which they provided and included historical 20 information and data as well as the' results of the 21 inspections that were held in October of 2006.
22 AmerGen has put together a comprehensive 23, presentation to address the questions put forward by 24 the Committee.
In addition, the NRC staff provided a 25 draft and final report of the analysis of a drywell 5
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shell performed at Sandia to support the staff's 2
review.
We have representatives of Sandia here to 3
answer any questions you may about their work.
4 Using insights from this work, the staff 5
issued an update to the safety evaluation in December, 6
which we provided to the Comnmittee.
You will be 7
hearing about this information in more detail during 8
the meeting today.
In addition, you will be hearing 9
from the regional inspectors that were present during 10 the inspections in October.2006 and their observations 11 of AmerGen's inspections.
12 With that, I-would like to turn this 13 presentation over to Mike Gallagher, who is the Vice 14 President of Exelon's license renewal group, to begin 15 the applicant's presentation.
16 AMERGEN -
OYSTER CREEK PRESENTATION 17 MR.
GALLAGHER:
Good morning.
My name is 18 Mike Gallagher.
And I'm Vice President of License 19 Renewal. Projects for AmerGen and Exelon.
Also with me 20 here from our management team is Tim Rausch --
he's 21 our Site Vice President at Oyster Creek-- and Rich 22 Lopriore.
He's our Senior Vice President for 23 Mid-Atlantic Operations.
24 On October 3rd, we last met and made a
)25 summary presentation on our license renewal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 10 i1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 132 MR.I O'HARA:
We were looking at the coating on the drywell, but the general condition'was looked at and noted.
Any conditions that the licensee thought were not correct were put in their corrective action process and analyzed.
MR.
GALLAGHER:
-And,
- remember, this picture is from 1992, Dr. Wallis.
MEMBER SHACK:
I mean, I thought these floors were finished up to make them smooth, to make sure that you can drain the water.
So, I mean, it presiimably doesn't look like*this anymore.
MR. GALLAGHER:.
Yes.
These pictures:are from 1992.
That's correct.
MR.
POLASKI:
As we go on to the next several slides,, we will show'you what it looks like today or what it looked like in
'92 after the --
MR.
O'ROURKE:
And slide 59 leads us into those photographs.
We'll show you the condition of the drywell shell as repairs were in progress.
Slide 60 shows the photograph of the shell after cleaning and the corrosion products removed.
It also shows the sand bed floor after the -coating was applied.
That's a partial answer. to Dr.
Shack's question.
S The next photograph shows --
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..,25 133 VICE-CHAIRMAN WALLIS:
What's that thing in the background?
It looks like a sheet of plastic or something.
What is that?
MR.
POLASKI:
Yes.
That very well could be plastic.
You remember these pictures were taken during the actual application, repairs still in launch.
So you will see plastic in that area.
VICE-CHAIRMAN WALLIS:
Well, the sand bed floor needed quite a bit of repair it looks like.
MR. O'ROURKE:
Slide 61 shows the shell as it's being coated with the primer coat and also again a view of the sand bed floor.
Slide 62 sliows the shell after the epoxy coating was applied.
It also shows the caulk seal that was applied to the interface between the external shell and the sand bed floor.
And I
will note that *there are some additional photos in your reference books.
MEMBER ARMIJO:
Was that caulk sealing kind of pressurized to kind of get it into the gap or was it just kind of surface, like you do with a bathtub or something?
MR. O'ROURKE:
Pete, do you have an answer to that question?
MR.
TAMBURRO:
The caulk ceiling was-a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 134 fairly viscous epoxy caulking.
And it was forced into that gap with a trowel and pushed in there.
MR.
GALLAGHER:
Thanks, Pete.
VICE-CHAIAMAN WALLIS:
So if there's no water there, it doesn't matter, does it?
MR.
O'ROURKE:
That's correct.
I'm looking at slide 63.
VICE-CHAIRMAN WALLIS:
How about the draining of the. sand bed floor?
It presumably has to run around circumferentially to find a drain.
bid you worry about leveling it off or putting a slope on it or it slopes to the drain or what?
How did you do that?
IV1R.
O'ROtRKE:
That is correct.
The directions were to slope.
When the floors were finished, the direction was to, slope it away from the drywell and toward the drain.
VICE-CHAIRMAN WALLIS:
All right.
MR. O'ROURKE:
And remember Fred's earlier discussion that there are five sand bed drains, VICE-CHAIRMAN WALLIS:
Right.
MR.
O'ROURKE:
-- as opposed to the one on the --
VICE-CHAIRMAN WALLIS:
The one on the top, S
right.
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 135 MR. O'ROURKE:
the unique trough up above.
Continuing with the background and history for the sand bed region, the epoxy coating applied to the external shell was a
three-part coating system designed for applications on corroded surfaces.
The first coat that I showed ih a previous slide in the photograph was a rust-penetrating sealer designed to penetrate rusty surfaces, reinforce the rusty steel substrate, and ensure adhesion of the epoxy coating.
Two coats of epoxy coating were then applied.
This coating is designed for more severe surfaces than we expect at Oyster Creek, a couple of which are noted on the slide.
Prior to application of the coating, it was tested-in a mock-up for coating thickness and absence' of holidays or pinholes.
And we used two coats to minimize any chance of pinholes or holidays.
And the coats are of a different color to facilitate future inspections.
Fred?
MR.
POLASKI:
Thank you, John.
I would now like to --
you have heard from Mr. O'Rourke about -the corrective actions taken to stop the corrosion of the drywell shell in the sand NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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bed region.
One of the key aspects of the corrective 2
action was application of the epoxy coating to the
.3 exterior surface of the shell.
4 Our next presenter is Mr. Jon Cavallo, who 5
will speak about the coating on the drywell shell.
6 Mr. Cavallo is the Vice President of Corrosion Control
- 7.
Consultants Alliance Incorporated.
He's a registered 8
professional engineer in six states and holds a
9 Bachelor's degree from Northeastern University in
- 10.
Boston, Massachusetts..
11 He also is a
Certified society of 12 Protective Coatings protective coatings specialist and 13 holds registration as a certified protective coatings 14 engineer from the National Board of Registration for 15 Nuclear Safety-Related Coating Engineers and 16 Specialists.
17 He is active in a number of technical 18 societies, including ASTM,. National Association of 19 Corrosion Engineers, National Society of Professional 20 Engineers;,
and the Society of Protective Coatings.
21 Mr. Cavallo served as the editor of the 22 EPRI report "Guideline on Nuclear Safety-related 23 Coatings Division I,"
assisted in development of and 24 teaches EPRI code in his training courses.
He's also 25 the principal investigator of the EPRI report NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W.
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"Analysis of Pressurized Water Reactor on Qualified 2
Original Equipment Manufacturer Buildings" and since 3
2000 has been a member of the NEI PWR containment sump 4
task force.
5 Mr. Cavallo?
6 MR.
CAVALLO:
Thanks, Fred.
Good morning, 7
gentlemen.
8 I was asked to take an independent look-at 9
the approach that Oyster Creek has taken' to mitigating 10 the corrosion on the exterior shell of the drywell in 11 the sand bed region.
12 First off, I went back and looked at the 13 background and history from a regulatory standpoint of 14 good guidance that we received to approach this 15 project.
16 The 'Oyster Creek protective coatings 17 monitoring and maintenance program, aging management 18 is consistent with NUREG-1801, which is a GALL report 19 volume II, appendix XI.S8, which is the appendix 20 devoted to coatings condition assessment.
- However, 21 you should note that that appendix only covers coating 22 service level I coatings, which is coatings inside of 23 the primary pressure boundary inside the drywell.
24 Oyster Creek in my opinion wisely extended 25 that requirement to the service level* II
- coating,
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which they applied to the exterior of the drywell 2
using many of the same quality approaches that are 3
used in containment coatings.
4 Next slide, please.
The-coatings applied
.5 to the exterior of the drywell, which we have seen 6
some photographs of in the previous presentation, 7
coating service level II, the evaluation and continued 8
monitoring of those coatings -are conducted in 9
accordance with ASME section 11, subsection IWE by 10 qualified VT inspectors.
In other words, they are 11 inspected the same way using the same techniques that 12 are used inside the containment, both BWRs and PWRs.
13 The coated areas are examined at a minimum 14 for visual anomalies.,
which includes
- flaking, 15 blistering, peeling, discoloration, and other signs of 16 distress.
This approach is consistent again with the 17 NUREG-1801 and its attendant ASTM standards.
18 The whole premise of ASME section' 11, 19 which is used for examination of the pressure 20 boundaries in PWRs and BWRs, is the degradation of'a 21 vessel that's got a coating on itwill be indicated by 22 a visual precursor defect in the coating.
23
- And, again,
-the ASME section I1, 24 subsection IWE protocol is to remove that coating and 25' examine the substrate.
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manner to look for any continuing corrosion of the S
2 drywell shell on the exterior there, the sand bed 3
region.
4
- Now, I
wanted to spend a little time 5
discussing how barrier coatings such as the one that 6
John described. prevent corrosion of the scale 7
substrates.
8 Basically we have four conditions 9
n!cessary for metallic corrosion:
an anode; a
10 cathode; an electrical conductor; and some type of an 11 electrolyte, which is a
liquid that conducts 12 electricity.
13 We as coatings engineers can only do one 14 thing.
We can't control the anodes*.
We can't control 15 the cathodes.
We can't control the electrical 16 conductors because they were already inherently in the 17 steel.
So what we do is apply a barrier coating 18 system, which isolates the moisture, the electrolyte, 19 and breaks the corrosion cycle.
20 This is what has been done in the Oyster 21 Creek sand bed region.
Repeating what John told you, 22 the Oyster Creek sand bed region coating system is 23 really a three-step process.
24 First off, the surface preparation was 25 done in accordance with SSPS SP2 hand too! cleaning, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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which I think gets back to Dr. Wallis' question about 2
what was done.
That removes loose rust, loose mill 3
scale, and loose coating.
And loose is defined as 4
determined by moderate pressure with a dull putty 5
knife by code.
6 With that level of surface prep, which was 7
appropriate, they then applied a pre-prime, which is 8
an: epoxy, which penetrates into the semi-irregular 9
shape of the substrate, and then applied two coats --
10 VICE-CHAIRMAN WALLIS:
About that 11 pre-prime, it is a very key thing, isn't it?
I mean, 12 if you leave too much dry rust on' then it doesn't 13 really adhere to the steel.
14 MR.
CAVALLO:
Exactly.
I am going to in 15 a little bit talk about how this was controlled as a 16 special process similar to welding.
17 VICE-CHAIRMPN WALLIS:
Okay.
Okay.
18 MR. CAVALLO:
I didn't mean to cut you 19 off, sir.
20 VICE-CHAIRMAN WALLIS:
No, no.
I just 21 wanted to focus on that particular thing.
The 22 pre-prime is an important step in this.
23 MR.
CAVALLO:
Yes,.sir, it is, absolutely.
24 And, remember, our coating systems such as this one 25 are actually designed.
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can paint..
It's not true.
2 So we have selected a system with good
.3 history in this type of application.
Then we applied
. 4 two coats of the Devran 184 epoxy, which is a standard 5
epoxy phenolic, which is used a lot for this region, 6
which provides that barrier for moisture.
7
- And, finally, we saw pictures of the 8
Devmat 124S caulking, which was applied by troweling 9
into the interface-between the concrete floor and the 10 steel substrate; again another moisture barrier.
11 MEMBER ARMIJO:
Just to understand, the 12 pre-prime, is it intended?
Is it preferred that it be 13 in contact with the metal or is it okay that it's in 14 contact with a surface oxide that is adherent to the 15 metal?
16 MR.
CAVALLO:
- Both, actually.
It's 17 designed as an adhesion promoter.
It soaks into any 18 crevices in that remaining corrosion.
And, remember, 19 this is very tightly adherent 'corrosion-and mill 20 scale.
21 MEMBER ARMIJO:
Right.
22 MR.
CAVALLO:
And also it's an epoxy 23 polyamine.
So it does bond to the steel substrate 24 that may be exposed.
So you have a' combination of 25 both conditions.
And it is an adhesion promoter and S.
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142 1I gives something for the next two coats to stick to.
- 2.
VICE-CHAIRMAN WALLIS:
You mean if you 3
have a pit, it just bridges over the pit,'does it?
4 MR.
CAVALLO:
No.
It actually soaks in.
5 It's a fairly slow-drying material.
And it acts a lot 6
like our old bridge paint did.
It's to simulate that.
7
- Now, my conclusion is in basically 8
reviewing the approach and the engineering involved.-is 9
that this coating' system is appropriate for the 10 intended s ervice, which is to prevent further 11 corrosion of the-steel in the sand bed region'drywell 12 shell.
13 Some of the reasons I. came to that o
14 conclusion are that'we have created now a very benign 15 corrosion environment.
Before the sand was removed, 16 we actually almost had an emergent condition.
We had 17 moisture trapped -in there held against the surface by 18 the sand.
Now we have'a'dry --
19 CHAIRMAN MAYNARD:
VIm' sorry.
' Can you 20 wait just a minute?
We're trying to get this muted.
21 We are getting' some noise from one of the lines.
So 22 if the pe6ple on the telephone will'be quiet, we'll go 23 ahead and continue with the discussion.
Go ahead,
- 24.
Jon.
25 MR. CAVALLO: All right. 'So,- anjways, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIVES 13CU RHODE RSLAND AVE., N.W.
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have removed all the sand.
We removed the water.
We 2
have a benign environment, a fairly low radiation dose 3
rate.
So I don't worry about any sort of-radiation 4
damage.
This coating typically good to 1 times 109 5
rads or more total lifetime dose.
And we're. never 6
going to see anything like that.
7
- Finally, it's an enclosed space.
It's 8
shielded from atmospheric moisture, shielded from the 9
site environment.
So we have now a very benign 10 environment.
11 The coating system is compatible with that 12 environment.
Back to your question about the adhesion 13
- promoter, that adhesion promoter which is your 14 penetrating sealer is designed to adhere to a
15 minimally prepared'surface is what we're talking about 16
- here, where we're leaving some corrosion product 17 behind.
And also the two-coat applied over top of 18 that is used an awful lot in chemical tanks.
So our 19 environment is far less severe than that.
20 And, then finally, this coating system can 21 be successfully applied by brush and roller.
Because 22 of their very tight environment, we couldn't get into 23 very sophisticated spray equipment, such things like 24 that.
So this is appropriate to be applied that way.
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I think is quite noteworthy..
They actually create a 2
mock-up of the sand bed region with the drywell shell 3
before they actually applied the coating in service.
4 And they did surface preparation and coasting 5
application using the same mechanics in this mock-up 6
area with the restricted access.
7 This was a proof of principle on the 8
coating system and also was used to train the 9
mechanics: who did the surface prep and the coating 10 work.
This includes the caulking also.
11 And then, finally, what they did was 12 actually do a holiday test, which was an electrical 13 test, to see whether or not they had pinholes on this 14 mock-up.
So this was treated very similar to a 15 special process like we would have for welding.
So it 16 was well over and above what you normally see in an 17 outside containment coating's work effort.
So there
.18 was quite a bit put into that.
19 MEMBER SIEBER:
So a. holiday as referred 20 to in your previous slide is a pinhole?
21 MR.
CAVALLO:
- Yes, sir.
And usually 22 holidays are not visible.. They're solvent blistering.
23
- Now, 1 am going with periodic condition 24 assessment maintenance if there is any required.
And 25 I am not sure there ever will be any.
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The first slide.
2 The drywell shell is constructed first, 3
.and then on each side the interior and exterior 4
concrete was poured in.
When you have wet concrete in
.5 contact with steel, the toncrete mixture is at very 6
high pH, and this forms a.passive film on the surface 7
of the carbon steel, and it's a very resistent film.
8 And as the concrete hardens, even though 9
it becomes very hard, it still contains pores in the 10 concrete and the concrete contains it's called pour 11 water, and this pour water is, again, very high pH and 12 it mitigates corrosion.
13 So looking at the slide,
- again, the 14 concrete.
The shell is constructed first, covered 15 both surfaces of the imbedded steel with concrete.
16 The high pH is like 12.5 to 14 during the hydration of 17 the cement, which is one of the mixtures in the.
18 composite concrete material.
It forms a passive'film 19 on the surface which mitigates corrosion, and again, 20 that's why this system is used for constructing 21 buildings, tunnels, swimming pools, whatever.
2.2 Going to Slide 116, the reactor cavity
- 23.
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region, and there may be some. concern for that.
2 But a chemical analysis of this water, 3
- again, it's reactor cavity water which is very high 4
purity to begin with, reveals that the pH is greater 5
than seven.
The fluoride content was 0.045 parts'per 6
million, and the sulfate concentration was 0_32 parts 7
per million.
That's very high purity.
8 And the next line I have there is an 9
average of 3,600 waters, potable waters, natural 10 waters around the United States, and it shows that the 11 typical concentration is much higher; orders of i2 magnitude higher in chloride and orders of magnitude 13 higher in salts.
14 DR.
WALLIS:
So why was there so much 15 corrosion on the outside originally?
16 MR.
GORDON:
It doesn't take --
in that 17 particular area, in the sand region, there's no 18 concrete there to protect it.
19 DR.
WALLIS:
But still why is it 20 aggressive though?
It should be neutral.
21 MR.
GORDON:
Oh, I mean, pure water will 22 certainly corrode steel, but I'm talking about in the 23 area' where it is imbedded in concrete.
It's a
24 different environment.
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rules on what kind of water is aggressive to concrete, 2
and the GALL report and the EPRI studies have all 3
supported the same:level, and both these levels of the 4
water obtained from the sand bed region is high purity 5
and is not an aging concern.
6 Continuing with Slide 117, then the water 7
would have been the same high quality as we saw as 8
listed in the previous
- slide, but it would* be 9
interacted with the high pH pour water, concrete pour 10 water, and it would provide a passive film for the 11 carbon steel.
12 Again, per the GALL report and for the 13 EPRI report, which is listed here, since the pH is 14 greater than 5.5 and the chloride content is.way below 15 500 ppm and the sulfate is below 1,500 ppm, there is 16 not an aging concern for imbedded steel in concrete.
17 Now let's look at the surprise water that 18 was found during the last inspection on the interior
- 19.
surface and see why that is also not a concern.
A 20 chemical analysis was performed on this water, and the 21 next slide will actually show what this water looks 22 like.
Again, the pH of this water was 8.4 to 10.2, 23 and this is even after it's exposed to the CO2 in the 24
- air, which would lower the pH.
So the pH is probably 25 at least two points higher than this.
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High pH,ý and that's what you want to 2
maintain a passive film on carbon steel.
3 The chloride content, again, 13.6 to 14.6 4
ppm.
It's way below the limit of 500 ppm.-
5 Sulfate, again, 228 to 230, way below the
- 6.
1,500.
7 The calcium content is just presented here 8
as a point of interest, and we'll discuss that in the 9
next slide.
There's no GALL or EPRI concern with 10 that.
11 So this water that you have looked at in 12 the trench five is considered high purity concrete 13 pour water, which mitigates corrosion of carbon steel.
14 Again, this water that was found there complies with-15 the GALL and EPRI and ACI recommendations.
16 The next slide shows the trench five, the 17 water that was found in trench five, and the calcium 18 content, which I illustrated on the previous slide 19 indicates that the water was there for quite some 20 time.
Water leaches out calcium hydroxide first from 21 concrete and it's an indication it took some time to 22 get there and, again, it mitigates corrosion.
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also high puree and will not lead to any degradation 2
of the carbon steel.
3 MR.
ARMIJO:
Where did this water come 4
from?
5 MR.
GORDON:
This is apparent during a 6
maintenance.
7 MR. ARMIJO:
It was a spill.
8 MR. GORDON:
Yes, spills and things like 9
that.
10 MR.
GALLAGHER:
As we mentioned in the 11 beginning, it's equipment leakage.
So the design of 12 the drywell and the equipment leakage collection 13 system, and so any leakage would come down, go in the 14 sub pile room, go in a trough, and then goes into the 15 suMp.
So it's designed that way to collect any 16 leakage.
That's where this leakage came from.
17 MR.
ARIAIJO:
But did this water migrate 18 through the concrete or did it just kind of flow over 19 the top of something and just pour into this hole?
20 MR.
POLASKI:
It could have come from two 21 sources.
The investigation showed that the trough 22 that we pointed out earlier in the sub pile room that 23 all of the leakage is supposed to flow into and then 24 drain to the sump did have some leakage in it.
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2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 212 some of that water did migrate through the concrete and showed up in these troughs.
The other thing is John mentioned earlier that we have now installed caulking at the edge of the
- curve, you know, against the scale of the drywell.
Most other BWRs have that caulked.
Oyster Creek did not.
Oyster Creek is unique.
It has a curve there, but if there was any leakage that got on the shell of the drywell and ran
- down, it could have gotten directly below the concrete.
Either of those ways could have accounted for. this.
MR. GORDON:
And, again, this slide shows the water, and you can see the carbon steel there, the bare carbon steel.
This has some superficial corrosion on it.
What happens to the steel, that's not protected by the water, basically the side pH water.
MR.
SHACK:
Did you make inspections or, okay, there is inspections later.
PARTICIPANTS:
Yes.
MR.
GORDON:
What happens to the steel that isn't protected by this high pH, high purity water?
When the drywell is inerted, the cathodic
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point.
2 Any possible subsequent steel corrosion 3
would occur only during the brief outages, which are 4
just a few, you know, ten days per year on average, 5
and you wouldn't expect to see much atmospheric 6
corrosion.
7 Finally, the transport of any oxygenated 8
water that may come in from equipment manipulation 9
would be affected by the high pH core water and also 10 it would have to displace the oxygen depleted water 11 before you'd see any corrosion.
12 So basically imbedded steel in concrete is 13 not a concern on either the interior or the exterior 14 of the drywell.
15 CHAIRMAN MAYNARD:
Are. you going to 16 provide more justification for the superficial 17 corrosion that you saw there or cover that in the 18 inspection?
I
- mean, you made a
statement that 19 there's some superficial rust there.
I'd like to have 20 a little bit more to go on than just that.
How do you 21 know it's superficial?
22 MR.
GALLAGHER:
Yes, Howie, answer that.
23 MR.
RAY:
Yes, so that's going to actually 24 lead into the infraction to be performed.
25 CHAIRMAN MAYNARD:
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2 3
4 5
6 7
8 9
10 11i 12 13 14 15 16
.17 18 19 20 21 22 23 24 25 214 covered there MR. POLASKI:
We will cover it in a couple of slides.
MR.' GALLAGHER:
- And, Dr.
- Maynard, basically the bottom line is on the interior when we did UTs in the trench, and so you cbuld easily wipe off the corrosion, and then we UTed the whole trench area and we have that data in here.
MR. POLASKI:
So any other questions on --
DR. ABDEL-KHALIK:
How much farther do you think beyond the trench that you dug in. does the water extend or is the concrete in intimate contact with the steel along this entire bottom surface?
MR.
POLASKI:
The concrete that's on the inside --
DR.
ABDEL-KHALIK:
Right.
MR.
POLASKI:
as we said before, the concrete or the drywell shell was welded together and then the concrete was poured on the outside and then on the inside.
So it is in intimate contact.
DR. ABDEL-KHALIK:
So if it is in intimate contact, why is there water in the top part that you dug out?
MR.
POLASKI:
- Well, even though it's in intimate contact, you can still get water into that.,
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215 1
There isn't really a gap there, but water can get in 2
between, you know, soaked into the concrete along the 3
steel.
4 MR. GALLAGHER:
- Yes, the concrete pour 5
water throughout the concrete slab, and you know, so 6
there's water there.
7 MR.
RAY:
Yes, the concrete is poured in 8
different sections.
So there's actually a pass where 9
the water can get into the concrete or could migrate 10 through the different paths and seek its elevation, to 11 answer your question.
12 DR.
ABDEL-KHALIK:
Can you speak up a 13 little bit louder?
14 MR. RAY:
Yes.
The concrete was poured in 15 several different layers.
So there are --
16 DR.
ABDEL-KHALIK:
Horizontal halves?
17 MR.
RAY:
Horizontal, yes.
18 DR. ABDEL-KHALIK:
So, I mean, if I look 19 at this picture, how much water is there and how much 20 water don't I see?
21 MR.
POLASKI:
We believe based on what we 22 found, when we found this water there was about five 23 inches in the bottom of Trench 5.
It was pumped out 24 and then it filled back in again.
So it was coming
- i.<
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areas.
2 We believe that the whole inside of the 3
drywell below the floor has water in there.
4 MR. ARMIJO:
So you think there's water in 5
this lower part of the sphere --
6 MR.
POLASKI:
Yes.
7 MR.
ARMIJO:
between the concrete and 8'
the shell-9 MR.
POLASKI:
- Yes, that's correct.
10 MR.
ARMIJO:
And the source is the sump.
11 MR.
POLASKI:
- Well, the source is 12 equipment leakage.
It wasn't from the sump itself, 13 but from the troughs that then lead into the sump 14 indicated there was leakage out of that trough.
15
- However, there would have been water in 'the past if 16 there was a leakage in the 'drywell, and again, there 17 was some small amount of leakage in the drywell; if it 18 got 'on the drywell shelf, could have run down and 19 gotten directly below.
It could have been there for 20 years.
21 MR. GALLAGHER:
Let's be clear.
The 22 trough that we're talking about is this trough that 23 goes 360 degrees on the interior of the sub pile room.
24 That's designed to collect the water and then move it 25 to the sump.
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There were some defects in this trough so 2
that some water could have got into the concrete.
We 3
don't know how far, you know, water is down there.
4 We're assuming it's down there and that we've taken 5
action to have an aging management program, assuming 6
it's there to check, and that.s what we've done.
7 MR.
ARMIJO:
- Well, the water level, you 8
- know, if it's in direct contact, if it
- refills, the 9
water level is coming from somewhere.
That's at least 10 that elevation or higher.
11 MR.
GALLAGHER:
- Yes, and this elevation 12 here is the highest at that point.
It's higher than 13 the bottom of the trench was.
We've corrected this 14 trough.
So we wouldn't expect anymore water to get in 15 there, but we added it to our aging management program 16 to verify that, to verify if there's any ongoing 17 effect.
18 But this trough elevation,
- see, right 19
- here, if you look at the side, that's the bottom of 20 the trough, and then the bottom of the trench we're 21 talking about is at the bottom of the sand bed floor.
22 So any water you have coming down here 23 going into the trough, if the trough was not finished 24 correctly, would have gone into the concrete.
So we 25 fixed that.
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MR.
A-RMIJO:
But it's feasible the whole 2
bottom of that shell could have water in it.
3 MR.
GALLAGHER:
And that's what we're 4
presuming..
We haven't verified it, you know, because 5
we only excavated down here.
6 MR.
POLASKI: We're assuming there's water 7
- there, but Mr.
Gordon's presentation is just 8
addressing what would the conditions be, and once that 9
water gets in there --
10 MR.
GALLAGHER:
It should be benign.
11 MR.
POLASKI:
it should be benign.
-A 12 passive layer was ' there when the concrete was 13 initially poured.
14 MR.
SHACK:
It would be better if it 15 wasn't there.
16 MR. GALLAGHER:
That's correct.
17 MR.
GORDON:
But you know, concrete, even 18 if it's very well cured and very old, it still has 19 this moisture in it.
It's like a very hard sponge 20 with this concrete pour with a high pH pure water.
So 21 it really is basically a hard sponge, and it works 22 very successfully with steel.
23 DR. ABDEL-KHALIK:
But that would not be 24 the source of the water you're seeing.
I mean, you pumped it out and the thing filled up again.
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MR.
RAY:
The source of the water was 2
coming through the trough.
We paired a void there, 3
and we won't have that-source of water.
4
'DR. ABDEL-KHALIK:
Okay.
If you went and 5
looked at it today, it would be full of water again?--
6 MR. RAY:
We would not expect it.
It 7
still had a little moisture in the bottom Trench 5 8
when we started back up.
With the operating cycle, we 9
would expect that to evaporate off.
10 MR.
SIEBER:
Did you find cracks in the 11 concrete?
12 MR.
RAY:
No,
- we've done structural 13 monitoring, logged into the concrete, and had no 14 significant cracks.
The only void we found was in 15 that trough, and we did verify there was leakage 16 through there with a leak test.
17 MR.
POLASKI:
Any other questions?
Okay.
18 MR.
SHACK:
It just seems like 40 years of 19 operation to find a trough has a hole in it.
20 MR.
POLASKI:
Yes.
21 MR.
ARMIJO:
When the trough was first 22 excavated, was there any data that showed that there 23 was water in the trough when it was first built?
24 MR.
GALLAGHER:
The trench?,
25 MR. ARMIJO:
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trench.,
When that was opened up the first time, did 2
people find that full of water?
3 MR.
GALLAGHER:
When it was opened up the 4
first
- time, I don't think there was any water in 5
there, but we did find we did have some information 6
that there was water there at one point, and in 7
subsequent checks it wasn't there.
So that's why we 8
thought there was not a water environment in the lower
.9 elevation of the drywell, and that's why we hadn't 10 included that as an environment in our LRA.
11 One thing we did though.
We said, well, 12 let's look at these trenches again, and that's when we 13 identify this and put it in our corrective action 14 system to update our LRA.
15 MR. ARMIJO:
Have you ever experienced 16 recirc water pump seal leak?
17 MR.
GALLAGHER:
Plant --
Tom Quintenze.
18 MR.
QUINTENZE:
I'm Tom Quintenze, 19 AmerGen.
20 The question, I believe, was have you ever 21 experienced recirc pump seal leaks.
22 MR.
ARMIJO:
Yes.
23 MR. QUINTENZE:
And the answer to that is 24 yes.
i25 MR-ARMIJO:
Would that be the source of ANEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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this water?
2 MR.
QUINTENZE:
It could be the source of 3
water.
In earlier years we did have some significant 4
- leak, but current history indicates that we've 5
maintained our--unidentified leak rate, which would be 6
leakage from a recirc pump seal at a very low level, 7
on the order of.1 to.2 gallons per'minute.
8 MR.
GALLAGHER:
We know. that we do have 9
equipment leakage, like control rod drives.
There's 10 some leakage from them typically. They're right above 11 the sub pile room, you know, right above this room 12 here, and water drips down in all BWRs, and that's the 13 case.
14 As Tom mentioned, there is an unidentified 15 leakage criteria, no more than five gallons a minute 16 unidentified leakage in your primary containment, and 17 you know, we meet the technical specification limits 18 by far.
But this is designed to collect that leakage, 19 any leakage like that and then take it away to the 20 sump and then pump it out of containment.
21 MR.
ARMIJO:
Thank you.
22 MR.
SIEBER:
Given enough time though, 23 that's a lot of water.
24 MR.
GALLAGHER:
Yes.
25
-MR. POLASKI:
All right.
We've now heard NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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222 1
about the effect of water on carbon steel imbedded in 2
concrete and how we expect minimal corrosion on the 3
imbedded part of the drywell shell.
I'd now like to 4
have Mr. Howie Ray present the results of inspections 5'
-that were performed during October 2006 refueling 6
outage for the imbedded portion of the drywell shell.
17 MR. RAY:
Thanks, Fred.
8 During the 2006 refuel outage, visual 9
inspections of the surface of the trenches did show 10 minor corrosion.
It was easily removed with no 11 material loss of metal or degradation of the surface, 12 and the visual examinations were done satisfactorily 13 at those surfaces.
14 And as we just discussed, you know, that 15 superficial effect was what you would expect based on 16 the technical (speaking from an unmiked location).
17 The UT measurements taken in trenches were 18 used to compare the total corrosion on the inside and 19 outside between 1986 and 2006.
It is known that there 20 was significant corrosion that was ongoing in the 21 exterior surface that was not imbedded up to 1992 when 22 the sand was removed.
23 The material' loss identified was 24 consistent with the corrosion rates on the outside of
.25 the dryweli before the sand was removed in 1992.
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So the next slide illustrates the 1986 2
readings versus the 2006 readings for both Trench 5 3
and Trench. 17.
This did not include the additional 4
six iniches of surface UTs that we exposed.
We'll 5
discuss that later.
6 What's 'critical here is there is a.
7 difference of 38 mils for both of those trenches, but 8
thatwe would note that that occurred between the 1986 9
and 1992 time frame, before the san was removed, and 10 you had significant corrosion going.
So that would 11 not be an unexpected corrosion rate.
12 CHAIRMAN MAYNARD:
Okay.
How do you know 13 that that occurred over that time frame as opposed to 14 something. that has recently started?
It's kind of 15 hard to get a rate.
16 MR.
RAY:
Well, we're assuming that, but 17 we know we had significant corrosion going on while 18 the sand was' there.
We've shown that on the graphs 19 with both of them.
Bay 17 and Bay 5 both had 20 significant corrosion rates going on.
21 So if you took that across those years 22 that you had the sand installedwith the water, we can 23 assume it.
We can't verify that, but you do have 24 still good coating on the outside and you have a 25 technical justification that says that water in this NEAL R. GROSS COURT REPORTERS AND TRANSCRABERS 1323 RHODE ISLAND AVE., N.W.
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area would not cause significant corrosion inside the 2
drywell.
3 MR. GALLAGHER:
And.part of the basis is, 4
when we get to the next slide, when we interrogated 5
the six inches below the concrete floor, the corrosion 6
rate --
Howie, why don't you go into that and you can 7
show him that --
the corrosion rate which is really 8
over the entire period of time since that shell was 9
imbedded in concrete.
10 MR.
ARMIJO:
Before you go, did you find 11 water to the same extent in Trench 17 as you did in 12 Trench 5?
13 MR.
PAY:
No, we did not.
The Trench 17 14 is about. six inches shallower than the trench in Bay 15 5.
16 MR.
GALLAGHER:
So it's a
higher 17 elevation.
There was a little moisture in
- there, 18 but --
19 MR.
ARMIJO:
If there had been* water 20 there, it would. have drained to a lower level?
21 MR. GALLAGHER:
Yes.
22 MR.
RAY:
It was seeking its elevation.
23 It was voiced in Bay 17, but there's no standing 24 water.
25 DR. ABDEL-KHALIK:
The statement that was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
?2r (Whereupon, the foregoing matter went off the record at 4.: 49 p.m. and went back on the record at 5:04 p.m.)
CHAIRMAN MAYNARD:
All right.
I'd like to bring the meeting back into session.
I'd like to just start briefly by saying I appreciate everyone's participation.
We've had a lot of discussion today, had input from the licensee, had it from the NRC staff,.had it from members of the public, and that's something for us to all take into account, think about.
We'll have another meeting on this subject at our full committee meeting, and so we'll have. some time to look over this and maybe --
I don't know --
NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nea1rgross.cor 353 One of the things we need. to be identifying is what specific information may be needed in the full committee presentation so that we can provide guidance to the staff and licensee on things that we want to specifically have in that.
We will not have as much time, and so we will need to focus on key areas.
So with that, let's take a ten minute break.
Actually we'll come back at five o'clock and we'll do our round table discussion.
That's closer to 12 minutes.
I
354 1
generate more questions of our own and we'll see where 2
things go.
3 What I'd like to do now is to go around 4
the table, get any thoughts that the members have and, 5
again, one of the things is if there's any specific 6
areas that they think we need to cover in the full 7
committee meeting specifically, like the one that we 8
talked about, we need to identify that so that the 9
staff and the licensee can be prepared to address 10 that.
11 So I'd like to start with Mario, and just 12 what comments you may have or discussion items.
13 DR.
BONACA:
My first comment is that we 14 have a large amount of data.
I certainly would want 15 to review them before the full meeting just to digest 16 some of the information 17 A couple of general comments I have.
- One, 18 clearly we have been presented with an assertion that 19 the corrosion has been stopped and then that the 20 drywell, therefore, can operate until 2029.
I have 21 to reflect more about the inspections of the 22 monitoring program that they're proposing, whether or 23 not I think it's adequate.
24 At first glance I think that I would like 25 to see certainly a more aggressive inspection program NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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in the short term, and I'm not sure about looking at 2
it now and then in ten years doing inspections agaiin.
3 So, I
- mean, the monitoring program is 4
somethingI'll pay attention to,. and I would like to 5
see discussed definitely at the full.. committee
'6 meeting.
7 I have raised a number of times the issue 8
of controlling sources of water.
I mean, they may 9
have done as much as they can to do that, but still 10 during the refueling they have one gpm, water that 11 comes down and will go down to the trough, and I'm 12 sure of that.
13 But the question is have we done enough to 14 control sources of water to,assure that there is no 15 further accumulation.
16 The other thing that, you know, is more 17 like the issue of how the epoxy is doing, I mean, is 18 there any corrosion taking place behind the epoxy?
I 19 don't know if the UT they're planning to do is going 20 to tell us or is sufficient.
I mean, maybe there 21 should be some poking'in some location to see if there 22 is some weakness behind that.
23 But any, my attention is more focused on 24 these programs that will give us some more comfort 25 regarding the condition of the drywell and the ability INEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 3
4 5
6 7
8 9
10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 to go for additional 20 years.
Those are my comments.
CHAIRMAN MAYNARD:
All right.
Bill.
MR.
SHACK:,
- Well, the surprise for me today was the notion..that we have water in the imbedded region.
That concerns me a little bit.
I mean' I fully agree with the argument that it's a
fairly benign environment and the corrosion rates are low, and in a containment that didn't have the already substantial corrosion that this one does, I would sort of agree that'its probably not a problem.
But this is a containment where there isn't a
whole lot of margin, and you
- know, the estimate was you had 41 mils lost and that was less than one mil per year.
- Well, I do the arithmetic and I get more like tow mils per year, and you do have data on these 106 points.
Many of them are down in the region where you are looking through the thing at the imbedded region, and I think there's some data there that one could look at to try to really see *just what you think the corrosion rates are in that imbedded area and understand that a little better.
I'm fairly comfortable with the notion that if the epoxy coating is in good condition, that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W.
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I
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the corrosion on the OD is arrested, and that the 2
visual examination is a
good thing there.
I'm a 3
little less convinced with the small margins that we 4
have that the corrosion in the imbedded region is as 5
negligible.
6
- Again, the buckling analysis, again, I
7 think that we have, to settle on both the legalistic 8
requirements of who's analysis that you can accept, 9
but it seems to me. that perhaps it is time to take a 10 more realistic you know, you haven't got enough 11 margin to do the uniform thinning model anymore.
12 The Sandia one does seem to-indicate that 13 you have enough left.
It makes it more difficult to 14 assess just how much margin you have because it's 15 difficult, but again, I'd like to hear more discussion 16 over the kind of credit that should be given.
Since 17 there is no internal pressure, you know, whether the 18 circumferential tension really does give you credit 19 that you can account for, whether it's already built 20 into the IGAN value analysis that you get out of the 21 finite element model.
I'm not 100 percent convinced 22 that I'm not double counting here.
You know, some 23 more discussion of that would be helpful to me.
24 DR. BONACA:
Yes, I had another comment I 25 forgot to mention which was one of the assumed thinner NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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358 1
areas of one square foot.
It would have been 2
interesting to know how large an area you could 3
tolerate, but that's a question I believe Sam raised, 4
and I'm behind that.
5 CHAIRMAN MAYNARD:
Okay.
Dr. Wallis.
6 DR.
WALLIS:
- Well, I think we got a lot 7
more information than we got last time.
I think that 8
a lot of people made considerable effort to present 9
things professionally.
10 The question for me is this buckling 11 analysis and how good does it have to be.
We got 12 close enough to it could be a condition where you 13 wouldn't accept the results.
Do we have to --
I have 14 to look at these things again in some detail to see 15 whether I'm satisfied or whether I want to maybe even 16 ask for some more analysis.
17 I think the buckling analysis is the most 18 important issue here, and I'm not really sure whether 19 it's adequate or not yet.
20 CHAIRMAN MAYNARD:
Sam.
21 MR.
ARMIJO:
Okay.
I was impressed, and 22 I'd like to thank AmerGen and everybody who put this 23 package together.
It was exactly what we asked for.
24 As far as the information, it was well presented, easy 25 to read and that was very good.
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