ML093100169

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Re in the Matter of David Geisen, Exhibits - Volume 1, Exhibits 1 - 70, Staff Exhibits 21 Through 70
ML093100169
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 09/09/2009
From:
NRC/SECY
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
ASLBP 06-845-01-EA, IA-05-052
Download: ML093100169 (319)


Text

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i R A-ý (C- /L,:ý,2-=- Prasoon .K. Goyal Prasoon.K. Goyal To: Andrew To: Andrew J. Siemaszko/FirstEnergy@FirstEnergy Siemaszko/FirstEnergy@FirstEnergy El 12/13/00 01:26 PM 12/13/0001:26 PM cc:

Subject:

DavId C. cc: David Geisen/TE/FirstEnergy@FirstEnergy, Theo C. Geisen/TE/FirstEnergy@FirstEnergy, Swim/TE/FirstEnergy@FirstEnergy, Glenn Swim/TE/FirstEnergy@FirstEnergy, Mcl Mcl ntyre/TFEJFirstEnergy@FirstEnergy

Subject:

Oconee ntyre/TEIFirstEnergy@FirstEnergy Oconee Feedback Feedback Glenn R. R. Theo S. S. FYI Forwarded by Prasoon K. GoyalI/TE/FirstEnergy on 12/13/2000 01:25 PM ...................... Forwarded by Prasoon K. Goyal/TE/FirstEnergy on 12/131200001:25 PM

~                           <wgray@framatech.com>@framate<:h.com on 12/13/2000
                            <wgray@framatech.com>@framatech.com                 12/13/2000 07:58:04 07:58:04 AMAM Please      respond to wgray@framatech.com Please respond            wgray@framatech.com Sent by: by: wgray@framatech.com wgray@tramatech.com To:

To: pkgoyal@firstenergycorp.com *. robert.p.lemberger@fpc.com, dspond@entergy.com, pkgoyal@firstenergycorp.com,

              .dspond@entergy.com,                                          robert.p.lemberger@fpc.com, sleshnoff@pet::o*energy.com, greg.s sleshnoff@peco.energy.com,               .gerzen@exeloncorp.com greg.s.gerzen@exeloncorp.com cc:

cc: dewhitak@duke.energy.com, sfyfitch@framatech.com, mdevan@tramatech.com, dewhitak@duke*energy.colT], sfyfitch@framatech.com, mdevan@framatech.com, dfirth@framatech.com dfirth@framatech.com

Subject:

Oconee

Subject:

Oconee Feedback Feedback David Whitaker David Whitaker called called yesterday yester.day and asked me to pass along les.son learned along aa lesson learned from from the Oconee 1 ongoing RV RV head head penetration situation. David wanted me to make penetration situation. make .sure sure that all of you understood understood that that the amount amount of boric acid observed observed in in the visual inspectioninspection was very small small and that that itit is important to have a clean is important clean head for a good visual inspection. inspection. If If the head is clean, the chances of is not clean, of finding boric acid such such as that observed at Oconee Oconee 1 are not very good. good. 8i Bill 11 u.s. U.S. NRC NRC mre DAVID GEISEN 'l." S~ /.( ~..wwt t. 1-( In re DAVID GEIENf t::JUIIUR Dg Docket # 1A..()5-052 h JI) ?JZ5" Marked lor ID~ Date Marke<:i'for ID" 2' (Tr. P-ý--) 2008 (Tr. p.. .) EV:.Lij:L.., 2008 Offered in Ev: L. Date Offered

                                                                                      , Date                                 2008 (Tr. pp.*.3 l &
                                                                                    ~i=:

7hrough l A DOCKETED USNRC Action: hatifl M d REJECTED Wl1liDRAWtt"

                                                                                                                           /           .

WITHDRAW' USNRC lDlOa: t . ,2006tTr.p.gZ5

                                                                                                      ,2008(Trr.p                   ))

September 9, September 9, 2009 (11:00am) 2009 (11 :OOam) OFFICE OF OFFICE OF SECRETARY SECRETARY RULEMAKINGS AND RULEMAKINGS AND ADJUDICATIONS STAFF ADJUDICATIONS STAFF Proprietary S14H-00892 514H-00892

                                                                                                        ')

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U.S. NRC /' N '1I '1 In re DAVID GEISEN *P" In J f '-H ExhIbIt ,"';z:::£:::;...

                                                                                                                                 #..,tEh
          ý4s            C- /(,3                                           Docket # 1A-05-052 1A-05-052 ID,,

Marked for IDil/L.

                                                                          . Date Marked L 2008 (Tr.      .!
                                                                                                                                 . 25-. )

(Tr. pp..., Offe~d in Ev:

                                                                            . Date Offered         EV:.Jl:./1-. 20082      (Tr. p. 2 z&

(Tr. ) INTRA-COMPANY INTRA-COMPANY MEMORANDUMMEMORANDUM Through Wrtness/Panel:,_""'f-ol.j.>/~f, Wtness/Pan Z./// eI:i ______ _ m_ A~ ===================== Action: Action: ~AD.nTE REJECTED WITHDRAWN REJECTED WITHDRAWN J.2f.L.. 2008 (Tr. Date: _124 1Tr, p. &Z0) _ . To 10 Mechanical/Suuctural Engin Supervisor - Mechanical/Structural Swi1p, Supervisor T. S. Swi Engin-----.c ~",.c. Sjanuary iU, January 2001 jU, 2001 FROM FROM P. K. Goya Mechanical/Structural Engineering Engineer - Mechanical/Structural or Engineer lor Engineering MINL srop MAlL STOP 3210 3210 sacr SUBJECT Trip Materials Committee Meeting Trip Report - BWOG Materials Meeting PHONE PHONE 7351 7351 I attended the B&WOG Materials Committee meeting on January Materials Comrilitt.ee January 22. 2001. in Atlanta, 22,2001, Atlanta. Georgia. The meeting schedule and list of attendees attendees is attached. purpose of this meeting was to discuss the impact of Oconee The main purpose Oconee 1 Reactor Reactor Vessel Head (RVH) thermocouple thennocouple Nozzles and CRDM Nozzle CRDMNozzie Weld Leak Leak identified identified during the last outage. Dave Whiteker Whiteker of Duke discussed the incident at Oconee land I and provided the following highlights: .

           **   Boric Acid -crystals crystals were detected on RVH during the routine visual head         head inspection. They were able to find this leak because their CRDM                flanges do not CRDMflanges leak and the head was in pristine condition.

lcakand

  • Eddy current and ultrasound inspections were performed on all eight thermocouple were performed themiocouple nozzles (rC). and defects nozzies(T/C)and defects found in all nozzles. None of the TIC nozzles were None were in service at Oconee 1. TMfI-I isthe Oconee 1. TMI-l isthe.only only other B&W plant B&Wplant with T/C TIC nozzles. Only Only TMI-I are in service.

T/C nozzles at TMI-l two TIC servicz. Oconee removed Oconeercmoved TIC all T/C nozzles and penetrations from the bottom of the head. The remaining plugged six penetrations remaining two were plugged from the top of of the head.

            "* PT identified identified cracking craclcing in J-groove J-groove weld      of CRDM Nozzle 21. The cracking weld ofCRDMNozzle                      cracking extended into the 00 extended            OD of the nozzle. A boat sample was taken                  metallographic taken for metallographic examination... The most probable root cause examination                                   cause of the Alloy 600 CRDM CRDM Nozzle # 21 was primary water stress corrosion cracking (PWSCC). There was no indication of aggressive chemical species on the crack aggressive                                 crack face. All the crack and its branches branches were ground out. The final weld repair was performned              accordance with the ASME perfonned in accordance                     ASME code using using the  temper the temper   bead   technique. Fillet weld technique. Fillet weld was was   applied   to the   structural strucruraI performed.

weld and final PT perfonned. the total cost of these repairs indicated that thetota:l

            ** Dave indicated                                                   approximately $5.0 repairs was approximately        $5.0 million and total dose was 60 REM. !taIso It also extended extended the outage by two weeks.

that all It was also noted that all the the previous B&WOG efforts previous B&WOG were directed efforts were towards directed towards nozzle cracks and not the welds. identifying and repairing the nozzle identifying DOCKETED DOCKETED S14H-00550 USNRC USNRC September 9, 2009 (11 September (11:00am)

OOam)
                                                                -rE}U~LAZ£*~6C.Y                                   02-~eb6D£od-OJ-f*             C cý OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS                                                         Exhibit Exhibit 24 24 NRC002-0150 NRC002-0150 ADIUDICATIONS      STAFF AD.lUDICATIONS STAFF
  .INTRA-COMPANY INTRA-COMPANY MEMORANDUMMEMORANDUM                                                                ...   ...

eo 026". ED II26IH TO T*. S. Swi?, Supervisor - Mechanical/Structural Enginee'ing OATE Januar 30, 2001 TO T. S. Swi Supervisor - Mechanical/Structural Engineering DATE January 30. 2001 FROM P.K. Goaleior Engineer - Mechanical/Structural Engineering MDL stop 3210 FROM P. K. Goyal. e lOT Engineer - Mechanical/Structural Engineering MAIL STOP 3210 suwjEcr SUBJECT Trip Materials Committee Trip Report - BWOG Materials Committee Meeting Meeting PHoNE PHONE 7351 I attended the B&WOG Materials Committee meeting Materials Committee meeting on January January 22, 2001, in Atlanta, 22,2001, Atlanta. meeting schedule and Georgia. The meeting and list of attendees is attached. The main purpose purpose of of this meeting impact of Oconee meeting was to discuss the impact Reactor Oconee 1 Reactor Vessel Head Vessel Head (RVH) (RVH) thermocouple thermocouple Nozzles Nozzles and CRDM Nozzle Weld Weld Leak identified Leakidenttfied Whiteker of Duke discussed the incident at Oconee during the last outage. Dave Whiteker during Oconee 1 and and provided the following following highlights:

  • Boric Acid crystals crystals were detected on RVH during the routine visual head inspection. They were able to find this leak because their CRDM leakbec:ause flanges do not CRDMflangesdo leak and the head was in pristine condition.
              ** Eddy current and ultrasound inspections were perfonned  performed on all eight thennocouple thermocouple nozzles (TIC)   and  defects nozzlcs(f/C)and defects        found  in  all nozzles. None  of the  T/C TIC nozzles     were in were Oconee 1.

service at Oconee 1. TMI-I is the only other B&W plant with TIC otherB&W T/C nozzles. Only two TIC T/C nozzles at TMI-I are in service. Oconee atTMI-l removed all TIC Oconeercinovedall T/C nozzles and plugged six penetrations from the bottom of the head head... The remaining remaining two were were plugged plugged from the top of the head. cracking in JJ-groove

              ** PT identified CTa(:king          -:gIOOve weld of CRDM Nozzle Nozzle 21. Thecracking The cracking extended into the 00 extended             OD of the nozzle. A boat sample was taken for metallographic metallographic examination... The most probable root cause of the Alloy 600 CRDM Nozzle # 21 examination was primary water stress corrosion cracking (pWSCC). (PWSCC). There was no indication indication of aggressive chemical species on the crack face. All the crack and its branches were final weld repair was performed ground out. The flna1                                        accordance with the ASME performed in accordance technique. Fillet weld was applied to the structural code using the temper bead -technique.

weld and final PT perfonned. performed. the total cost of these repairs was approximately $5.0 million

               ** Dave indicated that thetota:l and total dose was 60 REM. It a1so   also extended the outage by two weeks.

It was also noted that all the previous B&WOG efforts were directed towards identifying and repairing the nozzle cracks and and not the welds. S14H-00550 Exhibit 24 Exhibit Exhibi 24 24f NRC002-0150 Dpnm P~no 11 nf

                                                                                                 *f* ~I~*P~noc          NRC002-0150

January 30. January 30, 200 20011 BWOG Materials SWOG Materials Committee Committee Meeting Meeting Page 2 The Materials The Materials Committee Committee is concemedabout concerned about the future inspections of of B& B&W W plants outages. There will be five outages during the coming outages. outages this year. ANO-l ANO-I and Oconee-2 Oconee-2 spring outages. 1M-I. have spring TM-1, CR-3CR-3 and and Oconee-3 will have fall fall outages. CR-3 has a outages. CR.;3 commitment for CRDM CRDM nozzle ID ID inspection from under the the head head during this this faIl. fall. The inspection is B&WOG funded but not the the repair (s). (s). The Materials Committee is is recommending the following actions to address the above issues to support spring outages. 1.

1. Perform safety Perfonn safety analysis to justifycon~nued justify continued operation operation with CRDM nozzle cracking.
2. technique for CRDM Develop inspection technique CRDMnozzlenozzle weld and consider delivery approach.

approach.

3. Oconee-1 repair and develop generic Optimize Oconee-l generi~ repair procedures.
4. Evaluate other repairs.

5.

5. Support Alloy 600 MRP ITG to develop develop an industry industry plan.

The Materials Committee also stated that complete head cleaning during outages should Materials Committee should be aa top be priority. Also tOP priority. Also the the CRDM CRDM flange leaks should flange leaks should bebe fixed. TheThe headstand headstand should be modified fOr modified for Roman (tool) access access and inspection inspection openings openings added to service struc~.structure. The VC Summer Summer hot leg leg weldcraeking weld cracking was also discussed. discussed. The cracking cracking and leakage was confirmed in "A" wasconfinned "A" hot leg Alloy 821182 weld between between RV nozzle nozzle low alloy steel and and stainless steel. B&WOG hot leg and cold legRV stainless steel. leg RV nozzle nozzle materials materials and welds are not the the same design as VC Summer. However. However, similar materials materials and weld configurations weld configurations are found atat other piping locations in B&W plants. B&WOG inB&W B&WQG NDE NnE committee committee is working working on dissimilar dissimilar metal weld qualification qualification program (Report 47-5006903-00). 47-5006903-00). The The NRC has mandated mandated the use of use of Appendix VIII, "Performance Demonstration YIn. "Performance Demonstration for Ultrasonic Ulttasonic Examination Systems", of Examination Systems", of Section Section XI ofof ASME ASMEB B & PV code for the PVcode the inspection inspection of LWRL WR plant components. components. The required required date to implement implement the requirements requirements of Supplement Supplement 10, 10, "Qualification "Qualification Requirements ReqUirements for Dissimilar Dissimilar Metal Metal Piping Welds", Welds", is November November 22.2002. 22, 2002. This This program program is is being being managed managed by by EPRI EPRI coupled coupled with with NSS design specific specific mockups. mockups. ANO-I ANO-l is planning planning to inspect inspect 12 12 dissimilar dissimilar welds welds in in the spring spring outage. S14H-0055 S14H-00551 1 NRC002-0151 NRC002-0151

January January 30, 30, 2001 2001 BWOG BWOG Materials Committee Materials Committee Meeting Meeting Page Page 33 The The EPRI EPRI Alloy Alloy 600 600 MRP MRP ITGITa isis addressing addressing the the NRC NRC concerns concerns particularly particularlythethe extent extentofof condition, condition, industry industry NDE NDEcapability capability and andthe the impact impact ononleak leak before beforebreak. break. B&WOG B&WOGhas has been been reques^z.d reques=::d to to develop develop Safety Safety Analyses Analyses in in support support of ofAlloy Alloy 600 600 ITG. ITG. The The Materials Materials committee committee hashas been been working working onon Alloy Alloy 600 600issues issues for for the the past past six six years. years. Appendix Appendix A A (attached) (attached) shows shows the the summary summary of ofthe the Alloy Alloy 600 600 program. program. IfIfyou you have have anyany questions, questions, please please contact contactme me at at extension extension7351. 7351. PKG/lmk PKGllmk Attachments Attachments cc: cc: B.B. R. R. Gallatin Gallatin 1056 1056w/aw/a D. C. D. C. Geisen Geisen 3105 3lO5 w/a w/a G. G. T. T. Hayes Hayes 3lO5 w/a 3105 w/a T. A. Lang T.A. Lang 3105 3105 wla w/a G. N. G. N. LeBlanc LeBlanc 3205 3205 w/a w/a T. T. A. A. McDougall McDougall 3105 3105 w/a w/a D. D. J.J. Mominee Mominee 3335 3335 wia w/a Mechanical/Structural Mechanical/Structural Unit Unit 3210 3210w/aw/a S14H-00552 S14H-00552 NRC002-0152 NRC002*0152

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Prasoon K. K.Goyal To: Andrew J. Slemaszko/FiRstEnergy@FirstEnergy Slemoszke/RrstEnergy@FhstEnergy cc: Thee Swlm/TE/RrstEnergy@FirstEnergy. David C. S. Swrm/TE/RirstEnergy@FirstEnergy, Theo S. 03/26/2001 01 :03 PM 01:03 Geisen/TE/ArstEnergy@First~rgy. Mark Geisen/TE/RrstEnergy@FirstEnergy, Mark A. McLaughlin/TE/Flrs'fEnergy@ArstEnergy. McLaughlin/TE/Flrsitnergy@RrstEnergy. John B. B. Cunnings/TE/FirstEnergy@ArstEnergy Cunnings/TE/FirstEnergy@FirstEnergy Subject Cracking

Subject:

Oconee3 CRDM Nozzle Cracking Following Oconee Following Oconee 3 nozzles/ nozzles/ J-grov~ J-grove weld weld have have cracks: 3,7, 3, 11,23,28,34,50,56,68 7, 11, 23. 28. 34. 50. 56, 63 AJI of the above All nozzles have heat # M above nozzles M 3935. DB nozzles # 1, 08 Z 3,4

1. 2. 3. 4 and 5 have the same heat # M3935. Special Special attention should be paid to to these nozzles during the next visual examination of the RV RVhead U.S. NRC U.S. NRC <)- {l.J> '/ Z Inre DAVID GEISEN 54;oEtfibR EINbIt.~

InreDAVIDGEISENJA11 Docket # 1IA-052 A-05-052* . Date Martead-for IDLi 20083(Zr.. "

                                                                          . Date Markedior IOl1/.J-. 2008 (Tr.p.§Z> )

DOCKETED USNRC USNRC Date Date Offe*ed'in Offered in Ev: fi/i.-. 2008 (Tr. p.) '2 Y ) 2008 (Tr. Through~I: Thmugh Witne I-L4.~J;t September 9, 2009 (11:00am) September 9,2009 (1 1:00am) Acbm Action: -

                                                                                 .. /
                                                                                        .          REJECTED    wmtDRAWN REJECTED WFTNDORAWN Da* 2--.. .2008 (Tr. p- 9) 2-& >>                .

OFFICE OF OFFICE OF SECRETARY SECRETARY RULEMAKINGS AND DaB 2 r.p?~ M.uo RULEMAKINGS AND ADJUDICATIONS ADJUDICATIONS STAFF STAFF

          ~-A-T~I                          -                                                0~) S Sc~

PIT.s 27/6< U.S. NRC In Inre NRC re DAVID DAVIDGEISEN c" L J It-. t-- GEISEN__BON {\ ? n L; Exh&bIt ,~ .J.. Docket # 1A-OS-OS2 Prasoon K. Prasoo" K.Goyal Goyal To: Andrew J. Siemaszko/Fi .. . J7 ) o0 215 04/06/01 1l:19,AM MCLaughlin/TE/FirstEn McLaughtin/TE/FirstEn Date Date Marked Marked for ID:L..:f-L-. ID 2008 (Tr. 2008_(Tr2008 p,-~ L-.

                                                   ~~~ ~~:~~: ~::~~~~:~!~

04/06/01 11:19 AM cc: Theo S. Swim/TE/FirstE .r / 0 (Tr.p..... cc: Theo S. Swim/TE/FirstE Date Offered Date Offered inin Ev: /ilq 2008 (Tr. p.oZ&

                                                                                                                              ,2008          pZL(.      ))

nT_./JI.&;~/~t:

Subject:

FW: CRDM

Subject:

                                           """ s Thrugh WrtnessIE CRDM Safety Analys Through                           l./"ne          _______

The generic questions raised by CP&L are good questions also. questions and f(

                                                                                                 ~.

f( Action: AO'fLh E 6 REJECTED WITHDRAWN REJiCTED

 ..................... Forwarded   by                                                  teo /pLL ,2008          (T p. 32A~)

a/so. Prasoon K.Goyal/TE/FirstEnergyon ...................... Forwarded by Prasoon K. Goyal/TE/F(rstEnergy on 04 a

  • 04 DDate:
                                                                                            -r--' . 2008 (Tr.               '. -
r. p......:.......
~        Ar%-              "Gray, "Gray. William William R"                                     04/06/2001 07:12:10 AM
                                               <WGray@framatech.com> on 04/06/2001 R" <WGray@framatech.com>                                         AM
<ndr,77'11 To:           'dewhitak@duke-ener~gy. com
             'dewhitak@duke*energy.       corn (E*

(E-mail)' <dewhitak@duke.energy.com>, 'dspond@entergy. com mail), <dewhitak@duke*energy.cor'n>, corn (E-mail)' <dspond@entergy.com>, (E*mail)" <dspond@entergy.com>, 'pkgoyal@firstenergycorp.

                                                       "pkgoyal@firstenergycorp. corncom (E*

(E-mail)" mail)'

              <pkgoyal@firstenergycorp.com>, 'robert.
              <pkgoyal@firstenergycorp.com>,         "robert. p. lemberger@fpc.

lemberger@fpc. comcorn (E*mail)' (E-mail)*

              <robert.p.lemberger.fpc_com>, 'greg.
              <robert.p.lemberger@fpc.com>.                gerzen@exeloncorp. coam
                                                    'oreg. gerzen@exeloncorp.           (E-mail) com (E*mail)"
             <greg.gerzen@exeloncorp.com>
             <greg.gerzen@exeloncorp.com>

cc: "Fyfitch, Stephen'<SFyfitch@framatech.com>

             'Fytitch,   Stephen* <SFyfitch@framatech.com>

Subject:

FW: CRDM CRDM Safety Safety Analyses Questions Questions FYI---Questions about the B&W plant plant situation and its generic implications DOCKETED DOCKETED FYI***Questions implications USNRC from Vaughn Wagoner of CP&L. September September 9, 2009 (11:00am)(11 :OOam) Bill OFFICE OF SECRETARY OFFICE Original.....

        • -Original Message .....

Message----* RULEMAKINGS From: Wagoner, Vaughn [mailto:vaughn.wagoner@pgnmail.com) [1] RULEMAKINGS AND ADJUDICATIONS STAFF STAFF Sent: Thursday, April 05, 2001 7:37 PM PM . To: Warren Bamford (E*mail); (E-mail); John Hall (E*mail); (E-mail); steve Steve Fyfitch (E-mail); (E-mail); Steve Hunt (E*mail); (E-mail); William William R (E-mail) R Gray (E*mail) Cc: Chuck Cc; Chuck Welty (E* (E-mail); mail); Larry Mathews (E-mail); Larry Mathews (E-mail); Tom Alley (E-mail); (E-mail); Gary Moffatt (E-mail) Moffatt (E*mail)

Subject:

CRDM Safety Analyses Questions Analyses Questions After reviewing the summary information from Oconee (attached), I/ have summary information have put put together a list of questions questions that I'd like you folks to be in a a postion to address address at the pre*m~ting pre-meeting next Wednesday. Wednesday. The questions questions are aimed at at seeing if there is ANYTHINGANYTHING we can deduce from the current inspections, previous previous inspections, and worldwide information information that can be used to take the the heat off plants with near-termroutages, such that they don't have to alter with near-term\outages, current outage plans. We need to collectively think about this real hard, because because IforseeI forsee two possible outcomes outcomes of the meeting meeting next Thursday. One is that the NRC concludes that the INDUSTRY, NRC concludes INDUSTRY, as represented represented by the PWRMRP, PWRMRP, really is working together to solve this problem and the NRC can count on us us do the right thing; or that the industry cannot. to (jo cannot, in fact, work work together together to solve this problemproblem and generic communications communications are in order. II hope the first one is their conclusion. conclusion. Please Please don't justjust look look at these narrowly* narrowly. keep in mind mind the industry objectives of 1)safety industry objectives l)safety first, first. 2)minimizing 2)minimizing cost cost and exposure. exposure. If yanking the insulation off all heads heads right now is the right thing to do, then so be it. But II don't want to look look back in 6 months months or a year year and see that we spent a lot of dose dose and money chasing the wrong wrong S14H-00458 NRC010-0458 NRC010-0458

Prasoon K.Goyal Prasoon K. Goyal To: Andrew J. Siemaszko/FirstEnergy@FirstEnergy, Siemaszko/FirstEnergy@FirstEnergy, Mark A. A. McLaugh lin ITE/FirstEnergy@FirstEnergy McLaughlin/TE/FirstEnergy@Fi rstEnergy 04/06/01 11: 1:19AM 19 AM cc: Theo S. Swim/TE/FirstEnergy, Swim/TE/FirstEnergy. David C. Geisen/TE/FirstEnergy Geisen/TE/FirstEnergy cc: rheoS. Theo .S. Swim/TE/FirstEnergy, Swimn/TE/FirstEnergy, David David C.C. Geiseri/TE/FirstEnergy Geisen/TE/FirstEnergy

Subject:

FW: CRDMSafety CRDM Safety Analyses Analyses Questions Questions The generic questions raised by CP&L are good questions and few of them (are applicable applicable to DBDB . also.. also ...................... Forwarded by Prasoon ...................... Forwarded Prasoon K.K. Goyal/TE/FirstEnergy Goyal/TEtFirstEnergy on 04/06/200 04/06/200111:221 11:22 AM AM c=8t. _-;;;J

                    ~
                              "Gray. William .R" "Gray.          R" <WGray@framatech.com>
                                                  <WGray@framatech.com> on 04/06/2001                 07:12:10 AM 04/06/200107:12:10         AM To:           *dewhitak@duke.energy. corn
             *dewhitak@duke*energy.          com (E-mail)*    <dewhitak@duke-energy.com>, *dspond@entergy.

(E* mail)" <dewhitak@duke*energy.com>, "dspond@entergy. comcorn (E-mail)' <dspond@entergy.com>, "pkgoyal@firstenergycorp. com (E*mail)" <dspond@entergy.com>,*pkgoyal@firstenergycorp. corn (E*mail)* (E-mail)"

              <pkgoyal@firstenergycorp.corn>, *robert.
             <pkgoyal@firstenergycorp.com>,             "robert. p. lemberger@fpc. corn      (E-mail) com (E*  mail)"
              <robert.p.lemberger@fpc.com>. "greg.
             <robert.p.lemberger@fpc.com>.                    gerzen@exeloncorp. com
                                                       *greg. gerzen@exeloncorp.      corn (E*mail)"

(E-mail)"

              <greg.gerzen@exeloncorp.corn>
             <greg.gerzen@exeloncorp.com>

cc: 'Fyfitch,Stephen' "Fyfitch, Stephen" <SFyfitch@framatech.com>

                                      <SFyfitch@framatech.com>

Subject:

Subject:

FW: FW: CRDM Safety Analyses Questions Analyses Questions FYI---Questions about the B&W plant situation and its generic implications FYI***Questions about the B&W plant situation and its generic implications from Vaughn Wagoner of CP&l. CP&L. Bill Original.....Message*****

          • Original Message-....

From: Wagoner, Vaughn [2] [mailto:vaughn.wagoner@pgnmail.com) Sent: Thursday, April 05, 2001 2001 7:37 PM PM To: Warren Warren Bamford (E*mail); (E-mail); John Hall (E*mail);Steve (E-mail); Steve Fyfitch (E-mail); Fyfitch (E*mail); Steve Hunt (E-mail);(E*mail); William R R Gray (E-mail) (E*mail) Cc: Chuck Welty (E-mail); Larry Welty (E*mail); Larry Mathews (E* (E-mail); mail); Tom Alley (E* (E-mail); mail); Gary Moffatt (E-mail) (E~mail)

Subject:

Subject:

CRDM Safety Analyses Questions Questions After reviewing the summary information from Oconee (attached), I have put summary information put together aa list of questionsquestions that I'd like you folks to be in a postion to address at the pre* pre-meeting meeting next Wednesday. The questions are aimed at at seeing if there is ANYTHING ANYTHING we can deduce from the current inspections, inspections, previous inspections, previous inspections, and worldwide information that can be used to take the heat off plants with near*term near-term outages, such that they don't have to alter current outageoutage plans. We need to collectivelycollectively think about this real hard, because II forsee two possible outcomes because outcomes of the meeting next Thursday. One is that the NRC concludes that the INDUSTRY, INDUSTRY, .as as represented by the PWRMRP, PWRMRP, really is working together together to solve this problem and the NRC can count on us us to do the right thing; or that the industry cannot, in fact, work together together to solve this problem problem and generic communications communications are in order. I hope the the first one is their conclusion. Please Please don't just look at these narrowly.* narrowly :- keep in mind mind the industry objectives of 1)safety industry objectives 1)safety first, 2)minimizing 2)minimizing cost and exposure. exposure. If yanking the insulation off all heads right now is the right thing to do, then so be it. But II don't want to look back in 6 months months or a year and see that we spent spent aa lot of dose and money chasing the wrong wrong S14H-00458 S14H-00458 NRCOI0-0458 NRC010-0458

n things. Any responses that you can supply earlier than next Wednesday, including Wednesday. including other/better thoughts, please do so. Thanks!!

<<ONS3    CRDM Summary.doc>> <<Questions
<<ONS3 CRDMSummary.doc>>                                          Analyses.doc>>
                                   <<Questions for Generic Safety Analyses.doc>>

oD . . Summary.doc CRDM Summary.doc ONS3 CRDM oD. Analyses.doc Questions for Generic Safety Analyses.doc S14H-00459 NRC010-0459 NRC010-0459

RAE 0- 1(0(ý u.s. U.S. NRC In In re re DAVID DAVID GEISEN GEISEN_ ) Docket #A 1I A-05-052 rkrv'I,%+ AJnfLnR9

                                                                                                                     /

I J ('f\ c-.t-r Exi/4 I 1'),) 5 bt ._...!:_-__ ExhibIt 5 . From: Kevin A. Spencer/rE/FirstEnergy A. SpencerfTElFirstEnergy Marked for Date Marked ID, for ID:1.l/.J-. 2008 (Tr. 2008 p.12 . ) (Tr. p. To: To: Prasoon K. Prasoon K. GoyalfTEI~irstEnergy@:i.rstEnergy, Goyal/TE/FirstEnergy@FirstEnergy, Thea C. Geisen/TE/FirstEnergy@FirstEnergy, GeisenfTElFirstEnergy@FlrstEnergy, Wilham William A. Theo S S...Swi Mugge/TE/FirstE A. MuggefTElFlrstE* SWi Offered Date Offered Date in Ev: J.i./.i-, ______, (Tr. p. 22 2008 (Tr. 1fJ.

                                                                                                                                                        & )

Z (, Moffitt/C~IIFirstE Through WitnessPanel: Eshelman/TE/FirstEnergy@FirstEnergy, Steven P. Moffitt/CEI/FirstE E.ShelmanfTElFirstEnergy@FirstEnergy,Stevenp. Wrtn~~~~el:--1f..;'IlJ-f/"':""-------

                                                                                                                            !UJ/11 Leisuref/E/FirstEnergy@FirstEnergy, Dale R. Wuokko/TE/FirstEner LeisurefTElFirstEnergy@FirstEnergy,                       WuokkofTElFlrstEner A       Action: . AOMm~ REJECTED        RE                 WITHDRAWN WITHDRAWN cc:

cc:

Subject:

CRDM CRDM Nozzle Nozzle Cracking Cracking Action: Date: (iff '

                                                                                                  .REJECTED Date: 42...., 2008  2008 (Tr. p. 3llA )

(Tr. p. Date: 4/16/2001 6:40:161010 4116/2001 6:40:161010

  -.- ..-----------.--.. Forwarded by Kevin A. Spencer/TE/FirstEnergy on 04/1612001 06:41 AM
 -------------------- Forwarded by Kevin A. SpencerfTEiFirstEnergy on 04116/200.106:41 AM -------------------DOCKETED
      .                                                                     .                                                         DOCKETED USNRC USNRC September September 9,   9, 2009 2009 (1.1:00am)

(1.1 :OOam)

 "Roger Huston" <Roger@licensingsupport.com>
                           <Roger@licensingsupport.com> on 04/1312001 09:08:31 09:08:31 AM                                  OFFICE OFFICE OF      SECRETARY OF SECRETARY RULEMAKINGS AND RULEMAKINGS          AND To:       "'Wuokko" <drwuokko@firstenergycorp.com>,
           Wuokko         <drwuokko@firstenergycorp.com>, *'David
                                                                "'David Lockwood" Lockwood" <David"';H.
                                                                                        <DavidH.

ADJUDICATIONS STAFF ADJUDICATIONS S-rAFF

               -Lockwood @firstenergycorp.com>, <Kevin_A._Spencer@firstenergycorp.com>

_Lockwood@firstenergycorp.com>, <KevinA._Spencer@ firstenergycorp.com> cc: S~ubject: CRDM Nozzle Cracking

Subject:

Cracking attended a meeting at NRC yesterday I attended yesterday whichwhich will likely likely be *of of interest interest for for your your upcoming visit visit by Commissioner Commissioner Merrifield. Merrifield. DaviS-Besse Davis-Besse is is not one of of the plants about the about which there is is safety concern. concern, .but but I would eXpect expect the Commissioner to take advantage advantage of his visit visit to .trytry to understand understand better better a current "hot" current "hot" issue. issue. The issue is is CRDM CRDM nozzle cracking. cracking. Cracks were detected detected at Oconee Oconee 1 late last last year. year, one of .them through-wall and allowing them through-wall allowing leakage.leakage. Cracks were detected detected at Oconee 3 in February. 9 of them leakers. in February, leakers. A k crack crack was found at at ANO-l in ANO-l in March. March. 8PRI's Materials EPRI's Materials Reliability Reliability Project (MRP) (MRP), . with licensing assistance from licensing assistance from NEI, NEI. has been addressing addressing this issue for the industry. industry. It It has been been coupled with the with the MRP MRP response to hot leg cracking cracking at Summer.Summer. I have have attended previous previous meetings on the subject, subject, most of which which described planned actions re: CRDMS, CRDMS. since the program is is in its .earlystages. in its early stages. technical The technical arguments arguments used in in those earlier meetings to alleviate alleviate near-termnear-term concern largely centered centered around .the the stress regime regime in in the CRDM nozzles. nozzles, in in which hoop stresses are expected dominate. and the expectation expected to dominate, expectation that anl' any cracking would therefore therefore be axially axially oriented. oriented. Inspections at Oconee Oconee 3, 3. and now at at ANO, ANO. have have detected detected circumferential circumferential cracking. cracking, which appears to have have highlighted highlighted NRC concern. concern. Yesterday'S Yesterday's meeting was apparently apparently requested by by Brian Sheron Sheron as a result of those concerns. concerns. The The industry presentations presentations were excellent, and satisfied were excellent. satisfied NRC to the point point that no immediateimmediate regulatoryregulatory action action is expected. Issues and questions is expected. remain, remain. however, however, as described described further below. below. First, I will briefly briefly describe the phenomena that have been identified. S14Q-016 44 S14Q-01644 L~cL ~,L T~ s~~- NRC01 9-1644 NRC019-1644

From: Kevin A. Spencer/TE/FirstEnergy A. SpancerfTEiFirstEnargy To: Prasoon K. Prasoon Goyal/TE/FirstEnergy@FirstEnergy, Theo K. GoyalfTEiFirstEnergy@FirstEnergy, SwimiTE/FirstEnergy@FirstEnergy, David Thea S. SwimfTEiFirstEnergy@FirstEnergy, David Geisen/TE/FirstEnergy@FirstEnergy, William A. C. GeisenfTE/FirstEnergy@FirstEnergy, A. MuggefTEiFirstEnergy@FirstEnergy, Mugge/TE/FirstEnergy@FirstEnergy, David L. L. Eshelman/TE/FirstEnergy@FirstEnergy, Steven P. MaffittlCEI/FirstEnergy@FirstEnergy, EshelmanffEiFirstEnergy@FirstEnergy, Moffitt/CEl/FirstEnergy@FirstEnergy, Michael Michael K. K. Leisure/TE/FirstEnergy @FirstEnergy, Dale R. WuokkafTEiFirstEnergy@FirstEnergy LeisureffEiFirstEnergy@FirstEnergy, WuokkolTE/FirstEnergy@FirstEnergy cc:

Subject:

CRDMCRDM Nozzle Cracking Cracking Date: bate: 4/16/2001 6:40:161010 4/16/20016:40:161010

              • ---------***** Forw arded by
              ----........ Forwarded     Kevin A by Kevin     Spencer/T E/FirstE nergy on A.. SpencerfTEiFirstEnergy                  06:4 1 A 04/16/200 1 06:41 on 04116/2001          M.-**

AM . . .- ..---****

  • "Roger Huston" <Roger@licensingsuPPclrt.com>

Roger .Huston" <Roger@icensingsupport.com> on 04/13/2001 04113/2001 09:08:31 AMAM To: To: "'Wuokko'" <drwuokko@firstenergycorp.com>, "David

           *'Wuokko'* .<drwuokko@fir.)tenergycorp.com>,                 Lockwood" <David~H.
                                                               *'David Lockwood"    <DavidH.

_Lockwood @firstenergycorp.com>, .<Kevin_A._Spencer@firstenergycorp.com> _Lockwood@firstenergycorp.com>, <KevinA._..Spencer@ firstenergycorp.com> cc:

Subject:

CRDM CRDM Nozzle Cracking Cracking I attended a meeting at NRC yesterday which will likely be of interest interest for for your upcoming upcoming visit visit by Commissioner Commissioner Merrifield. Merrifield. Davis-Besse is is not one of of the plants about which which there is is safety concern., concern, .but but II would expect the Commissioner Commissioner to take advantage of his visit to try to Understand understand better better a current "hot" issue. issue.. The issue issue is is CRDM CRDM nozzle cracking. nozzle cracking. Cracks Cracks were detected detected at Oconee 1 late last year, year, one of .them them through-wall through-wall and allowing leakage. leakage. Cracks were were detected at Oconee 3in 3 in February, February, 9 of them leakers. leakers. A A crack was found at at ANO-l ANO-lin in March. March. EPRI's Materials Materials ReliabilityReliability Project (MRP) (MRP), , with licensing licensing assistance assistance from from NEI, has been addressing this issue for the industry. NEI, industry. It It has been been coupled with the MRP response to hot leg cracking cracking at Summer. Summer. I have attended attended previous meetings on the subject, subject, most of which described planned planned actions re: CRDMS, CRDMS, since the program is is in in its early stages. technical stages. The technical arguments used in arguments in those earlier earlier meetings to alleviate near-term concern alleviate near-term largely largely centered centered around the stress around .the stress regime in in the CRDM nozzles, nozzles, in in which hoop stresses stresses are expected expected to dominate, dominate, and the expectationexpectation that any cracking therefore be axially oriented. would therefore oriented. Inspections Inspections at Oconee 3, 3, and .nownow at at ANO, have detected ANO, circumferential cracking, detecte.d *circumferential cracking, which appears appears to have have highlighted highlighted NRC concern. concern. Yesterday's meeting meeting was apparently apparently requested requested by Brian Brian Sheron as a result of those concerns. concerns. The industry presentations presentations were were excellent, excellent, and satisfiedsatisfied NRC to the point point that no immediate regulatory action action is expected. is expected. Issues and questions questions remain, remain, however, however, as describeddescribed further below. below. First, I will briefly describe the phenomena phenomena that have have been identified. identified. S14Q-01644 44 S14Q-016 NRC019-1644 NRC019-1644

The joint The joint connecting connecting a CRDM CRDM nozzle nozzle to to the the vessel vessel head, head, and and forming forming the pressure boundary, pressure boundary, is aaJ-weld is j-weld on on the the underside underside of of the the head head around around the the nozzle. The nozzle. rhe material material usedus.ed in in most plants plants isis susceptible susceptible to stress stress corrosion cracking. Residual cracking. Residual stresses stresses fromfrom initial initial welding welding provide provide the the driving driving force. force. It is It is here here .that the cracking that the cracking has been been expected expected to to be axial, axiaL and and that that isis what what has been has been found. found. The new problem problem occurs above above that, that, within the thickness thickness of of vessel head. the vessel head. The nozzles nozzles are installed installed in in the vessel vessel with aa slight slight interference interference fit. fit. were cooled They were cooled to -140F,

                            -140F,   inserted, and inserted,       and allowed allowed to expand expand to to roughly roughly aa half half to one one mill interference interference at   at 70F.

70F. At operating operating temperature t.emperature and pressure, pressure, differential expansion differential expansion creates creates aa small, small, onon the order order of one mill, mill, annular annular crevice around crevice around thethe nozzle. nozzle. Stresses Stresses here,here, away away from the the residual residual stresses stresses of the J-weld, of J-weld, are different. different. What is is happening happening is is that primary primary water water is is leaking through leaking through axial axial cracks cracks in in the welds welds and and filling filling thethe crevice crevice area. area. OD OD stress corrosion stress corrosion cracking cracking is is then then initating initating in in the

                                                                  .the nozzle nozzle and and progresses progresses circumferentially.

circumferentially. Cracking of as much as 180 degree extent Cracking extent has been been found at Oconee Oconee 3.3. The safety safety concern concern is is heightened heightened by the fact fact that this cracking cracking is is outside outside the structural structural boundary boundary formed formed by the J-weld. J-weld. If If a crack progressed progressed completely around the nozzle completely around nozzle and through-wall through-wall for most of of that that distance, distance, then then primary primary system system pressure forces forces alone alone would result in a result .in CRDM ejection CRDM ejection accident. accident. Other loads, loads, such such asas seismic, seismic, could cause a "near-full" crack to break, break, and questions questions were posed about that yesterday. yesterday. The major major argUment argument in in justifying justifying continued operation of the continued operation the fleet is that is that the processes processes that create create these cracks cracks would would take take many years to to prOduce prdduce cracks cracks that could could create create a safety safety problem. problem. There is some disagreement is some disagreementabou,:about how many years w.ouldwould be required, required, since the availableavailable crack growth growth rate data is conditions inside is based on conditions inside the primary system and conditions conditions inin the crevice region are expected crevice region expected to be diffe;ent. different. How different, different, and .how how that that affects crack crack growth grow.th are unknown. unknown. Even without that question, however ,NRC question, however, NRC is is having withwith the industry reliancereliance on a long growth growth period. NRC's concern about that argument is is that for most plants, plants, other than B&W, B&W, operators might operators might not know that the problemproblem had initiated, initiated, and thus might not be able to take action within action within the time required required for it it to progress to a level of concern. concern. plants are not affected B&W plants affected by this concern, concern, because because they cancan detect detect the leakage. small leakage. This isis a function function of the way the reactor Vessel vessel head is is insulated. insulated. The service service structure over a B&W head means that the head

surface, surface, at the nozzle nozzle penetrations, penetrations, is is available available for visual inspection.

inspection. All of the known cracks were first first detected by observing boron precipitate precipitate around nozzles during GL 88-05 visual inspections. inspections. service structures The service at Oconee have beenrnodified been :modified by adding large view portholes (approx. (approx. 6 6 inch diameter) at mid-height facilitate these inspections. mid-height to facilitate inspections. Other B&W plants, plants, presumably including Davis-Besse, presumably including Davis-Besse, inspect through smaller smaller "mouse ho.les" nea!" holes" near where the vessel service structure meets the head. head. Westinghouse and CE westinghouse CE plants are insulated in in different different ways,ways, but all all have insulation on the head itself itself in some way. The number of nozzles available for visual inspection in is is limited unless insulation is removed. It is removed. It isis at these plants that NRC is is concerned a problem could exist without the operator's concerned? operator's knowledge. knowledge. (The (The amount amount of leakage leakage is is far too small to be identified by monitoring primary system leakage or even by detecting radioactivity in in the containment containment atmosphere) atmosphere). . NRC staff remained remained concerned concerned aboutabout this at the the end of yesterday'S yesterday's meeting. meeting. S14Q-01645 NRC019-1645 NRC019-1645

Brian Sheron specifically Brian She:::-on spec-4fically noted that the industry arguments told him nothing about the cur:::-er..t current risk of an accident resulting from this problem. accident resulting problem, or the current current state of the rest of the Eleet.. fleet. (It was at least implied that this (It this problem likely likely exists at other other plants and has only been been detected detected at B&W B&W plants to dace becal.. . se of their unique date because unique ability to detect it). it). MRP is t1RP is committed corru:nitted to providing providing a safety assessment to NRC 4/27. 4/27. That That coincides :with coincides .... it!1 your visitvisit from Commissioner Commissioner Merrifield. Merrifield. Given Given. the apparent apparent significance be~ng significance being placed on this issue by the staff. staff, it is almost it is almost certain that Merrifield's Merrifield's staff. staff, if i f not the Commissioner Commissioner himself, himself. will have have been been briefed on the issue before before his visit. visit. I would expect expect him to use the opportunity opportunity of the plant plant visit visit to learn learn more about it. about it. tI recommend recommend that you have people ready ready to respond in in detail detail to any questions. questions. Drawings Drawings and, and. yet, pictures better yet. pictures (if (if any) should should be available. available. A description description of how D-B its visual does its visual inspections, inspections, if if possible possible presented presented by the engineer engineer who inspections, would performs those inspections, '",ould be helpful. helpful. I do not know that I would would include the issue directly directly in in any presentations presentations you are planning, planning, but would would rather be prepared prepared to jump on any questions he would ask. ask. Please call call me if if you have any additional additional questions. questions. Roger W.W. Huston Huston Licensing Licensing Support Services Support Services 703-671-9738 703-671-9738 http://www.licensingsupport.com S14Q-01646 S14Q*01646 NRC019-1646 NRC019-1646

c~l&2 DOCKETED USNRC September 9,- 2009 (11:00am) DotaW # I1A-05-052 Date Marked for ID.Ž 2006 (Tr .- (Tr.P 2008 ( Date Otfsed inEv:/-4'L ThmoUgh n s p n t: ,:1, L Action:) REJECTED Wffl4DRWVN QIAAK-03205 NR0005 3 tS~ ARMTM-Y 0 t1- APL O9r 51c-kcZ4

I

A 4 I S4A-03208 S14A-03208 'I 4 NRC005-3184 NRC005-3184

I

April 19, 2001 o-

F-0

15

                ,CRDM Nozzle and. Weld Cracking l:*Info'rmation Excha!nge Meeting*
  • Lyn:chb=urg,
                              *Ai April 19, 2001' 19 IilApril 19,2001                                        20
                                                     *S14A-03218       1 NRCOO,5.-3gq

I I

I

U.S. NRC U.S. NRC 5 f fT" In In re DAVID GEISEN re DAVID GEISEN c... -" ExhibIt.?- Exhibt '1 Docket # 1 A-DS-DS2 Docket # 1A-05-052 . Date Date Marked Marked for for IDIJ/L. 2008 (Tr. p. IDLý.$.. . 2008(Tr. p. 225' )

                                  ",.,,,,. ,,,",.,,.;'.       Date Offered Date Through Offered in  in Ev: il/L.,

Ev: /_2-.,2008 Wltness/Panel:--,-;V~' 2008 (Tr. I-,-e~ ____

p. 22 (Tr. p. &Z(P ))

Through Witness/Panel:L*'// Acti~n: Action: ~ 4WEIED REJ~CTED REJECTED WITHDRAWN WITHDRAWN

                                                        , Date:

Date; tJ41-, 2008 2*05,2 (Tr. p,£lU

p. i DOCKETED USNRC September 9, 2009 (1l1:00am)

OFFICE OF OFFICE OF SECRETARY SECRETARY RULEMAKINGS RULEMAKINGS AND AND ADJUDICATIONS STAFF ADJUDICATIONS STAFF iaIlenperbead

                                                             ,tead fgrinding to
                                                                       * .$1A-133226                                   I'
                            -5ecy   67J--<l                                            NRC6         5:4202.;.

-1

CRDM Nozzle and WeldC~¶racking Information Exchanige Meeting L~ynchb~urgVA~ April 19, 2001' Or~i~ginal Inspetion wa~s 4

  • . .. Remote crawler video performed aound all
      ....          ~nozzle   .
        .D~eveoped                 Modific~ation....
   .. Package to Cut Access~
          . even~t temper~ bead wel repair required~

aloe pnnsi the service supfport structure above the head

      .        "Access would be, reqiir' d to place cooe h~eat blankets on tpof head.
            "'-On~eaccess qpehing~cut,ýn&ar nozl               .    ..

although'not re quir'e~d

                                                          *S14A-022

I I

I

Ap Actual Flaw Repair Circumferential crack cutoff perpendicular ~to nozzle IDof nozzle. not grind si nce no ID flaws 152/1152 Weld Overlay fo~und and crack Amal Flaw depth in n~ozzle less

  • than allowable crack d~epth for OD flaw 26 Si4A-0323&8 13 NRCQO5-32141

27 Major Chr9onoogy of <Events

 ~Began    Outage 3/16/01
ýMTearn shift coverage, began 3/18/01
    ,,.Day3/1/0   to 3/19/01 modifi ed headstand    ~
-..3/18/01 com~pleted -vido exam and boron found 3/2091(1st time) and 3/24/01 (2nd
 ~time) installed head on headstan6d 28 SI 4A-03239  4 14

DOCKETED .--U.S. U.S. NRC , £' L t'f '/ v USNRC USNRC "In In re DAVID GEISEN ;:{ i" a... r V exhibit DAVID GEISEN a #~L. L . fTý) Docket # 1A-OS-052 1A-05-052 September September 9, 2009 (11:00am) (11 :OOam) . Date Marked Marked for ID.JJd!-. ID' " 2008 (Tr. p. 2ZL {Tr. p.o..4 OFFICE OF SECRETARY OFFICE SECRETARY RULEMAKINGS AND RULEMAKINGS Date Offered Offered in Ji/.1-. in Ev: _., (Tr. p. 2008 (Tr. p. ;gzL~)

                                                                                                                                                           ..- )

A-COMPANY MEMORANDUM A-COMPANY MEMORANDUM ADJUDICATIONS STAFF Through WJtnesslPanel:_t.::./U+-/~P Through Wnqess!_PaneI: /-,//4 _ _ _ _, ActiOn~ ~DD REJE,~TED Action: REJECTED WITHDRAWN WITHDRAWN Date: i1{I-,,2008 2008 2*. (Tr, (Tr. p. gZ-& ) ro TO Swim Supervisor, Mechanical/Structural T.S. Swim, Mechanical/Structural UnitUnit .. -c---- --,. --..., ... FOM FROM pzaso~enior Prasoon .Goyal, Senior Engineer, MechanicaVStnu:tural Mechanical/Structural Unit MAIL stop STOP 32"10 32"10 suBJECr SUBJECT NEVIMRP NEIIMRP Alloy 600 ITG and NRC Meeting PHONE 7351 I participated participated in the NEI/EPRI NEIlEPRI MRP 600 LTG meeting on April 11, 2001 and NRCIMRP MRP Alloy 600ITG NRC/MRP meeting on on April 12, 2001. l2,2oo1. Both of these meetings were were held in Washington, D.C. The meeting meeting' agenda and the list of 'attendees attendees is attached. The purpose purpose of NRW Alloy 600 ITG meeting was ofMRP was to prepare and coordinate coordinate the industry responseresponse to NRC letter sent to NEI on April 3,2001. 3, 2001. The .letter letter expressed concerns regarding the generic generic implication of Oconee implication Oconee 3 *circumferential circumferential cracks cracks on CRDM nozzles. NRC raised the following concerns/questions:

       ** A  A discussion of how the results of the CRDM cracking (circumferential)

(circumferential) found at Oconee is being being utilized utilized byby the the lv1RP MNRP toto address address this this issue on a generic basis, basis.

  • Discussion of the inspection plans, schedule, scope scope and method to be utilized in performing NDE of of the CRDMs.

CRDMs. This discussion discussion is requested to include a listing of all PWR's that are either in, or will be coming down for, becoming for, an outage during the current current outage session.

      ** The The schedule schedule for and scopescope of a generic safety assessment ofPWR*CRDM's of PWR CRDM's supported supported by deterministic deterministic     and/or  risk-informed.assessments, risk-informed assessments,       that                    technical justification for establishes a teclIDical continued operation continued     operation with with potentially degraded penetrations penetrations until such time as comprehensive comprehensive inspections     can be  performed inspections can be performed         of  the  PWR   CRDMs
  • A discussion discussion of the implications implications of the recent service experience experience (circumferential (circumferential crack) on the commitments commitments made made in response response to GL97-0.1, GL97~1, "Degradation "Degradation of of Control Rod Drive Mechanism Mechanism Nozzle Nozzle and Other Vessel Vessel Closure HeadPenetration,"

Head Penetration," dated April 1, 1997. 1, 1997. MRP ITG group spent considerable MRP considerable time in discussing the facts .about Oconee Oconee 3 event. Mike Robinson of Duke of Duke EnergyEnergy presented an overview overview of Oconee 1 and Oconee Oconee 3 CRDM nozzles cracking. cracking, Five out of of eight instrument nozzles at Oconee eight Oconee 1I were were found cracked cracked and leaking. There were no circumferential circumferential cracks at cracks at Oconee Oconee 1. 1. The The summary summary of Oconee 3 cracks cracks is discussed below. Nine nozzles out of 69 were found found to to be be leaking. Examination of leaking. Examination of nine additional nozzles was performed. This examination nine additional examination did not show any show any significant significant indications. shouldbe indications. It should be noted that Oconee 3 has same heat of material material for 68 nozzles. nozzles. S14A.03314 S14A ..03314 NRC005-3289 P?~L~LA-TG C-Jc, L* Oz-- 0 2--NRCOOS"3289

FINTRA-COMPANY INTRA-COMPANY MEMORANDUM ED 8268-ED8261H1 MEMORANDUM FirstEnew ArstEnerw ro TO T.S. Swim, Mechanical/Structural Unit Swim Supervisor, Mechanical/Structural DATE DATE April 26, 2001 FROM FROM Pmso~enior PrasoontKGoyal, Senior Engineer, MechanicaVStructurai Mechanical/Structural Unit MAIL sTroP MAIL STOP 32"10 3il0 SUBJECT SUBJECT NEIIMRP Alloy 600 ITG and NRC Meeting PHONE PHONE 7351 I participated participated in the NEI/EPRI NEIlEPRI MRP MPW Alloy 600ITG 600 ITG meeting on April 11, 11, 2001 and NRC/MRP NRCIMRP meeting meeting on April 12,2001. 12, 2001. Both of these meetings were held in Washington, D.C. The meeting meeting agenda and the list of attendees is attached. of-attendees The purpose ofMRPof MRP Alloy 600 ITG meeting was to prepare and coordinate coordinate the industry response to NRC letter sent to NEINElon on April 3,3, 2001. The Jetter letter expressed expressed concerns regarding the generic implication implication of Oconee Oconee 3 circumferential circumferential cracks on CRDM nozzles. NRC raised the following following concerns/questions: concerns/questions:

             *0 A discussion of how the results of the CRDM cracking     cracking (circumferential)       found at Oconee (circumferential) found         Oconee is being being utilized by the MRP to address this   this issue on a generic basis.
           *a     Discussion of the inspection plans, schedule, scope and method to be utilized in performing      performing NDE of  of the CRDMs. This discussion is requested to include a listing of all PWR's that are either in, or will be coming down for, for, an outage during the current current outage session.
            *" TheThe schedule schedule for for and   scope of and scope    of aa generic generic safety safety assessment assessment of  of PWR    CRDM's supported PWR CRDM's         supported by by deterministic            risk-informed assessments, that establishes deterministic and/or ris1c-infOimedassessments,                 establishes a technical technical justification justification for continued continued operation with potentially degraded penetrations penetrations until such time as comprehensive comprehensive inspections can be performed of the PWR inspections                                 PWR CRDMs
            **    A discussion of the implications implications of the recent recent service experience (circumferential (circumferential crack) on the commitments.made commitments.made        in  response   to GL97-0.1,   "Degradation GL97-01, "Degradation        of  Control  Rod Drive Mechanism Me.chanism Nozzle and Other Vessel Closure Head  Head.Penetration,"

Penetration," dated April 1, 1, 1997. MRP WRP ITG group spent considerable considerable time in discussing discussing the facts .about about Oconee 3 event. Mike Robinson of Duke Energy Energy presented an overview of Oconee 1 and Oconee 3 CRDM nozzles craCking. cracking. Five Fi ve out of eight instrument nozzles at Oconee 1I were found cracked cracked and leaking. There were no circumferential cracks at Oconee 1. 1. The summary Oconee 3 cracks is discussed below. Nine nozzles out of 69 were summary of Oconee found to be beleaking. leaking. Examination Examination of nine additional nozzles nozzles was performed. This examination examination did notnot show any significant significant indications. It should be notednoted that Oconee 3 has same heat of material material for 68 nozzles. S14A-03314 S14A-03314 NRC005-3289 NRC005-3289

  ~:t~
     '~ vc~by   MAY -I2001 5/4/01 Note to Prasoon:

Prasoon: j _

                               -Prasoon:

Excellent Excellent report!! report!! Thank you. you. FILE'.. Campbell Guy Campbell

                       ..      GGC:n1f GGC:nlf cc: T.

cc: T. S. S.. Swjm Swim . D. C. D. C. Geisen Ceisen FILE: 1-:3~' S. P. S. Moffitt P. Moffitt: SI4A-03315 S14A-03315 NRC005-3290 NRC005-3290

Page 3 April 26. 2001

 *0   Total of 48 indications indications in nine leaking CRDMs CRDMs 39 were axial and located beneath the weld    weld 16
      .16 .out out of 39 indications were through wall

.0* Confirmed Confirmed two above the weld circumferential circumferential cracks Nozzle 56 crack crack was through wall, approximately approximately 17017000 Nozzle 50 except indications on ID was not through except pin hole indications through wall Inspection and metallurgical resultsinclicate circumferential cracks were 00 results indicate that the circumferential OD initiated. The NEI/MRP concluded after Alloy 600 ITG put together a presentation NEIIMRP meeting concluded presentation for NRC meeting. Mike Robinson presented the details of Oconee 3 CRDM cracking at the NRC meeting. NRC (B. MikeRobinson Sharon) Sharon) was very interested interested in knowing the basis of OD/weld OD/weld initiated cracks. Mike said that this was a surprise because the previous analysis showed showed that most of the cracks would be axial. NRC asked whether whether this type of cracking cracking is applicable applicable to other plants (Westinghouse (Westinghouse and Combustion Engineering) Combustion Engineering) besides B&W B&W plants. The answer answer was yes because because the CRDM material material and construction is similar to B&W plants. Mike also told NRC that Duke will be replacing RV head on all Oconee Oconee Units during during 2003 -2004

       -2004 time period period when the steam generators will be replaced.

Steve Fyfith of FfI presented presented the Safety Assessment (SA) for B&WOG B&WOG plants. The SA basically basically indicated that these types of cracks cracks are very tight and the leakage leakage rate is very low. This is confirmed by by Oconee 3 unidentified leak rate being well below 1I gpm inspite of 9 leaking CRDMs. The leakage could be detected detected by the boron deposits on the head during the visual inspection inspection performed performed at every concluded that circumferential outage. SA also concluded circumferential crack could grow to approximately 27000 through wall approximately 270 and still maintain the structural limit. NRC was concerned that right now circumferential circumferential cracks would would not be detected unless these start leaking. They were especially especially concerned about W/CE plants which inspect their heads because of insulation. NRC asked how industry is proposing to address this can not inspecttbeir issue. MRP stated stated that nothing extra could be done during the 2001 2001 spring outages. Industry will be developing a model for weld/OD initiated cracks cracks and prioritize prioritize the plant rankings (similar to GL97-01 response) prior to 2001 fallfall outage. This ranking will based on the EFPY and head temperature. Industry (vendors (vendors and EPRI) is developing NDE and repair techniques to address weld/OD initiated addressweldlOD initiated cracking. NRC said theywiH they will like to participate in the demonstration of NDE techniques. MRP

MRP Actions:
  • 0 Submittal of preliminary Safety Safety Assessment (SA) (SA) - 4127/01 4/27/01
*-   Revision of inspection inspection recommendations recommendations for fall outages-6/30/0 outages - 6/30/011
**   Final Safety Assessment - 6/30/01
    • Long term inspection inspection and evaluation evaluation guidelines guidelines being developed.
    • Continued communication.and Continued.communication .and meetings meetings with NRC as needed.

If you have any questions please contact contact me at extension 7351. PKG/gmw Attachments Attachments S14A-03316 S14A-03316 NRC005-3291 NRC005-3291

Page Page 3 April 26, 2001 April 26. 2001 cc: G.G. Campbell G.O. Campbell DB3080 w/a DB3080w/a D.C. Geisen w/a DB3105 w/a T.A. Lang Lang w/a DB3105 w/a G.N. LeBlanc LeBlanc w/a DB3205 w/a TA. McDougall T.A. DB3105 w/a DB3105 w/a L.W. Myers BY-ADM w/a BV-ADM w/a D.J. Mominee D.l. w/a DB3335 w/a .6 D.P. Weakland Weakland BV BY w/a w/a Mechanical/Structural Unit MechanicallStructural DB3210 w/a DB3210 w/a SI4A-033l 7 S14A-03317 NRCOO5-3292 NRC005-3292

            ~'MAY 12001 5/4/01 Note to Prasoon:

Prasoon: J-I Prasoon: Excellent report!! Excellent report!! Thank you. you.

                        ~uy Juy        Campbell Campbell FILEI GGC:nlf GGC:nlf cc:

cc: T. S. Swim T. S. D.C. Geisen D. C. Geisen FILE: /. j _')J S. S. P. Moffitt P. Moffitt SI4A-03318 S14A-03318 NRC005-3293 NRCOO5-3293

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JidL. , p.M& ) IOFFICE September 9, f--September (111:00am) OFFICE OF NUCLEAR 9 2009 (1 NUCLEAR REACTOR RE< RE( Date Offered in Ev:1 Ev: 2008 (Tr. p.,L-&..

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WASHINGTON, WASHINGTON,D. D. C. 20555-01 - ' ~F-:~tJ~A":-- Through Wit s p`anel: N OF SECRETARY OFFICE OF SECRETARY I I RULEMAKINGS AND RULEMAKINGS AND A '1 30 April 2001 30, 2001 Action: A 9 REJECTED WITHDRAWN WITHDI~WN ADJUDICATIONS ADJUDICATIONS STAFF STAFF pn , ~ 2!n ) Date: Date; 2008 (Tr. p.~-"",,~~

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INFORMATION NOTICE 2001-05: NRC INFORMATION THROUGH-WALL CIRCUMFERENTIAL 2001-05: THROUGH-WALL CIRCUMFERENTIAL CRACKING CRACKING OF REACTOR REACTOR PRESSUREPRESSURE VESSEL HEAD CONTROL ROD DRIVE CONTROL DRIVE MECHANISM MECHANISM PENETRATION NOZZLES AT OCONEE NUCLEAR NOZZLES NUCLEAR STATION, UNIT UNIT 3 Addressees Addressees operating licenses for pressurized All holders of operating nuclear power pressurized water nuclear power reactors except those who who have ceased operations operations and have certified have certified that fuel has been permanently removed permanently removed from the the reactor vessel. Purpose Purpose The U.S. Nuclear Nuclear Regulatory Commission (NRC) Regulatory Commission (NRC) is issuing this information notice notice to alert

       .addressees addressees      to  the  recent  detection recent detection    of through-wall      circumferential circumferential       cracks   in two of the control rod drive mechanism mechanism (CRDM) penetration penetration nozzles nozzles and weldments at the Oconee Nuclear             Nuclear Station, Unit 3 (ONS3).

It is expected It expected that that recipients will review review the information information for applicability to their facilities and consider consider actions, as appropriate. However, -suggestions contained appropriate. However,suggestions contained in this information information notice are not NRC requirements; requirements; therefore, no specific specific actions or written response is required. required. Description of Circumstances Circumstances February 18, 2001, On February 2001, with ONS3 in Mode Mode 5; 5, Duke Energy Corporation Corporation (the licensee) licensee) performed a visual examination visual examination (VT-2)(VT-2) of the outer surface of the unit's reactor reactor pressure pressure vessel (RPV) head head to inspect for indications indications of borated water leakage. leakage. This RPV head inspection was was performed performed as part of aa normal surveillance surveillance during a planned maintenance maintenance outage. The VT-2 VT-2 revealed revealed the presence of small amounts amounts of boric acid residue in the vicinity of nine of the the .

       .69 CRDM B9    CRDM penetration penetration nozzles (Figures 1 and 2). SubsequentSubsequent nondestructive               examinations nondestructive examinations (NDEs)     identified 47 recordable (NOEs) identified          recordable crack indications in      in these nine degraded degraded CRDM penetration nozzles.

nozzles. The licensee initially characterized licensee initially characterized these flaws as either axial or below-the-weld below-the-weld circumferential indications, and initiated repairs circumferential repairs of the degraded areas. NOEs NDEs of nine additional CRDM penetration nozzles nozzles from the same heat of material material were conducted conducted for "extent of 1 ) condition" purposes, but did not detect recordable indications.0 recordable indications.(1) . ML011160588 ML011160588 (1)1) Axial flaws are flaws that propagate propagate along the inside or outside diameter diameter length of the the CRDM nozzle. Below-the-weld circumferential nozzle. Below-the-weld circumferential indications indications are apparent flaws oriented around around the circumference circumference of the nozzle, beneath beneath the RPV head and below the area area where where the nozzle the nozzle is welded to the RPV head. A recordable indication indication is one that exceedsexceeds the NDE NDE acceptance acceptance criteria.

STATES UNITED STATES NUCLEAR REGULATORY REGULATORY COMMISSION COMMISSION OFFICE OF NUCLEAR NUCLEAR REACTOR REGULATION REGULATION WASHINGTON, WASHINGTON, D. C. 20555-0001 April 30, 2001 INFORMATION NOTICE NRC INFORMATION NOTICE 2001-05: THROUGH-WALL THROUGH-WALL CIRCUMFERENTIAL CIRCUMFERENTIAL CRACKING CRACKING OF REACTOR PRESSURE PRESSURE VESSEL HEAD CONTROL ROD DRIVE MECHANISM CONTROL MECHANISM PENETRATION NOZZLES AT OCONEE NOZZLES OCONEE NUCLEAR STATION, UNIT NUCLEAR STATION, UNIT 3 Addressees Addressees All holders of operating licenses for pressurized operating licenses pressurized water nuclear nuclear power reactors except those who who have have ceased ceased operations and have certified certified that fuel has been permanently permanently removed removed from the the reactor reactor vessel. Purpose Purpose The U.S. Nuclear Commission (NRC) Nuclear Regulatory Commission (NRC) is issuing issuing this information information notice notice to alert addressees addressees to the recent detection detection of through-wall circumferential cracks in two of the control through-wall circumferential rod drive mechanism mechanism (CRDM) penetration nozzles (CRDM) penetration nozzles and weldments weldments at the Oconee Nuclear Oconee Nuclear Station, Unit 3 (ONS3). Station, (ONS3). ItIt is expected that recipients recipients will review the information information for applicability to their facilities and consider actions, as appropriate. appropriate. However, suggestions containedcontained in this information notice are not NRC requirements; requirements; therefore, no specific actions or written response is required. required. Description of Circumstances Circumstances On February 18, 2001, 2001, with ONS3 ONS3 in Mode 5, Duke Energy Corporation Corporation (the licensee) performed a visual examination performed examination (VT-2) (VT -2) of the outer surface surface of the unit's reactor pressure pressure vessel (RPV) head to inspect for indications indications of borated borated water leakage. This RPV head head inspection was inspection was performed as part of a normal surveillance performed surveillance during a planned maintenance maintenance outage. The VT-2 VT-2 revealed revealed the presence presence of small amounts amounts of boric acid residue in the vicinity of nine of the the 69 CRDM penetration penetration nozzles (Figures 1 and 2). Subsequent nondestructive examinations Subsequent nondestructive examinations (NDEs) (NDEs) identified 47 recordable recordable crack indications in these nine degraded degraded CRDM CRDM penetration nozzles. The licensee characterized these flaws as either axial or below-the-weld licensee initially characterized below-the-weld circumferential circumferential indications, and initiated repairs of the degraded degraded areas. NDEs of nine additional CRDM penetration penetration nozzles from the same heat of material were conducted for "extent of indications.01 ) condition" purposes, but did not detect recordable indications.(1) ML011160588 ML011160588 (1) Axial flaws are flaws that propagate (1) propagate along the inside or outside diameter length length of the the CRDM nozzle. Below-the-weld circumferential nozzle. Below-the-weld circumferential indications are apparent apparent flaws oriented oriented around around the circumference circumference of the nozzle, beneath the RPV head and below the area where where the nozzle nozzle is welded welded to the RPV head. A recordable recordable indication indication is one that exceeds exceeds the NDE NDE acceptance acceptance criteria.

IN 2001-05 IN Page 2 of 5 Subsequent dye-penetrant dye-penetrant testing (PT) revealed additional indications in two of the nine revealed additional nine degraded penetration nozzles. degraded penetration nozzles. While affecting further repairs of these indications, the licensee licensee identified that each nozzle nozzle had significant circumferential cracks in the nozzle above the weld. significant circumferential investigations and metallurgical examinations Further investigations examinations revealed that these cracks had initiated from the outside diameter (00) (OD) of the CRDM penetration circumferential crack in penetration nozzles. The circumferential in the #56 CRDM nozzle was through-wall, through-wall, and the #50 #50 nozzle had pin hole hole through-wall 0 indications. These cracks followed the weld profile contour, and were nearly nearly 165 1650 in length. The licensee licensee stated pre-repair ultrasonic testing (UT) stated that pre-repair (UT) examinations identified examinations had identified indications in these areas during indications during the initial inspections, but these indications had been misinterpreted as craze cracking with unusual misinterpreted characteristics. The characterization unusual characteristics. characterization for these two nozzle indications was revised after the initial post-repair PT examinations. The licensee nozzle indications licensee concluded that the root cause concluded penetration nozzle cracking was primary cause for the CRDM penetration primary water stress corrosion cracking (PWSCC). This conclusion conclusion was based on metallurgical orientation, and finite element examinations, crack location and orientation, element analyses. Discussion The 69 CRDM nozzles at ONS3 ONS3 are approximately approximately 5 feet long and are J-groove welded welded to the the inner radius of the RPV head, with the lower end of each nozzle extending extending about inches about 6 inches inside of the RPV head (see Figure below the inside Figure 2). The nozzles constructed from 4-inch 00 nozzles are constructed OD Alloy 600 Inconel Inconel procured procured in accordance accordance with the requirements Specification SB-167, requirements of Specification Section IIIIto Section to the 1965 Edition the 1965 Edition (including (including Addenda Addenda through through Summer 1967) 1967) of of the American American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. During initial Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code. During initial construction, each nozzle was machined machined to final dimensions dimensions to assure a match between between the the RPV head bore and the 00 OD of the nozzle. nozzle. The nozzles were were shrink-fit by cooling cooling to at leastleast minus 140 140 degrees degrees F, inserted inserted into the closure head penetration, and then allowed to warm to temperature (70 degrees room temperature degrees F minimum). minimum). The CRDM nozzles were were tack-welded tack-welded and then permanently permanently welded to the closureclosure head 182-weld metal head using 182-weld metal (see Figure 2). The shielded manual metal arc welding process was used for both the tack weld and the J-groove manual J-groove weld. During weld buildup, the weld was ground and PT inspected inspected at each 9/32 inch of the weld. The final weld surface surface was ground inspected. The weld prep for installation of each ground and PT inspected. nozzle accomplished by machining nozzle in the RPV head was accomplished machining and buttering buttering the J-groove with 182- 182-weld metal. Axial cracking in pressurized pressurized water reactor (PWR) CRDM nozzles has been previously previously identified, evaluated, identified, evaluated, and repaired. Numerous repaired. Numerous small-bore Alloy 600 nozzles nozzles and pressurizer pressurizer heater sleeves have experienced heater experienced leaks attributed to PWSCC. Generally, these components components temperatures of 600 degrees F or higher and to primary water, as are the are exposed to temperatures the ONS3 CRDM ONS3 CRDM nozzles. However, circumferential circumferential cracks cracks above the weld from the 00 OD to thethe inside diameter (ID)(10) have not been previously identified in the U.S. been previously An action plan was implemented implemented by the NRC staff in 1991 1991 to address PWSCC of Alloy 600 penetrations (VHPs) at all U.S. PWRs. This action plan included a review of the vessel head penetrations the safety assessments by the PWR owners groups groups (Westinghouse Owners Group, Combustion Combustion

IN IN 2001-05 Page 3 of 5 Engineering Owners Group, and Babcock Engineering Babcock & & Wilcox Owners Group) submitted for staff review on Ju"ne June 16, 1993, by the Nuclear Nuclear Management Management and Resource Resource Council (NUMARC, (NUMARC, now the the Nuclear Energy Nuclear Energy Institute [NEI]). Institute [NEIl). After reviewing the industry's safety assessments and examining examining the overseas overseas inspection findings, the NRC staff staff concluded, in a safety evaluation safety evaluation (SE) dated November 19, 1993, that PWR CRDM nozzle nozzle and weld cracking was not an immediate immediate safety concern. The bases for this conclusion were that ifif PWSCC occurred occurred (1) the cracks cracks would be predominately predominately axial in orientation, orientation, (2) the axial cracks would result in detectable detectable leakage leakage before catastrophic failure, before catastrophic and (3) the leakage would be detected examinations performed detected during visual examinations performed as part of surveillance walkdown walkdown inspections befor~ before significant significant damage damage to the RPV head would occur. However, the NRC staff noted concerns about potential circumferentialcircumferential cracking cracking (which would need to be addressed addressed on a plant-specific basis), high residual stresses from initial manufacture manufacture and from tube straightening sometimes done after welding, straightening sometimes welding, and the need need for enhanced leakage monitoring. leakage monitoring. By letter dated March March 5, 1996, NEI submitted a white paper entitled "Alloy 600 RPV Head Penetration Penetration Primary Stress Corrosion Corrosion Cracking," which reviewedreviewed the significance significance of PWSCC in in VHPs, described PWR \,THPs, described how the PWR licensees were managing the issue. NEI assumed assumed that the issue issue was primarily an economic issue issue rather than a safety issue, and describeddescribed an economic economic decision tool to be used by PWR licensees licensees to evaluate the probability of a VHP VHP developing developing a crack or a through-wall leak during a plant's lifetime. This information would then be used by a PWR licensee to evaluateevaluate the need to conduct conduct a VHP inspection inspection at their plant. To verify the conclusions in the industry's safety assessments, sampling inspections inspections were were performed at three PWR units in 1994. performed 1994. The results of these domestic inspections were were consistent with the February February 1993 analyses analyses by the PWR owners owners groups, the staff's November November 19, 19, 1993, SE, and the PWSCC found in European European reactors. On the basis of the results of the the first five inspections inspections of U.S. PWRs, the PWR owners owners groups' analyses, and the European European experience, experience, the NRC staff determined that itit was probable probable that CRDM penetrations penetrations at other plants contained contained similar axial cracks, but that such cracking did not pose an immediate- immediate- or near-term safety concern. Further, the NRC staff recognized near-term recognized that the scope and timing of inspections may vary for different inspections different plants, depending depending on their individual susceptibility susceptibility to this this form of degradation. In the long term, however, the staff determined determined that degradation degradation of thethe CRDM and other RPV head penetrations penetrations is an important safety consideration consideration because because of the the possibility of (1) exceeding exceeding the ASME Code safety margins margins ifif the cracks cracks are sufficiently deep and continue to propagate during subsequent subsequent operating cycles and (2) eliminating a layer of defense defense in depth for plant safety. On April 1, 1997, NRC issued GenericGeneric Letter (GL) (GL) 97-01, 97-01, "Degradation of Control Drive Control Rod Drive Mechanism Nozzle Mechanism Nozzle and Other Other Vessel Closure Head Penetrations," which which requested addressees addressees to inform the staff of their inspection activities activities related to VHPs. Based on the the industry's GL 97-01 response, which took credit for periodic inspections of the RPV head, the periodic inspections the staff agreed that the conclusions in its November November 19, 1993, SE remained valid. valid.

IN IN 2001-05 2001-05 Page Page 44 of of 55 The recent identification circumferential cracking significant circumferential identification of significant cracking ofof two CRDM nozzles at CRDM nozzles at ONS3 ONS3 raises raises concerns potentially risk-significant concerns about a potentially generic condition affecting risk-significant generic affecting all domestic domestic PWRs. RPV head head penetrations, penetrations, including including CRDMCRDM nozzles, provide function of provide the function of maintaining maintaining the reactor system (RCS) reactor coolant system (RCS) pressure boundary. Cracking pressure boundary. Cracking ofof CRDM nozzles and welds CRDM nozzles welds is a degradation is a degradation of the primary the primary RCS RCS boundary. Industry experience Industry experience has shown that shown that Alloy 600 600 is susceptible is susceptible to stress cracking (SCC). Further, the stress corrosion cracking environment in the CRDM the environment housing housing annulus annulus will likely be far more will likely more aggressive after any through-wall aggressive after through-wall leakage, leakage, because because potentially highly potentially highly concentrated concentrated borated primary water borated primary water will become oxygenated, increasing become oxygenated, increasing crack crack growth growth rates. The repair activities activities at ONS3 were were extensive. The licensee stated that all flaws would be licensee stated be removed entirely from both weld material and nozzle base metal and repaired removed entirely repaired prior to plant plant restart. The licensee plans plans to perform thorough visual inspection perform aa thorough inspection of the Unit 2 RPV head penetrations during penetrations during the next outage outage and is investigating eventual replacement investigating the eventual replacement of the RPV heads heads on all three units to prevent recurrence of this event. Foreign PWRs prevent recurrence PWRs in France and and Japan Japan have already replaced already replaced a number of their RPV heads. The NRC held aa public meeting with the Electric Power Research Research Institute (EPRI) Materials (EPRI) Materials personnel on April 12, 2001, Reliability Project (MRP) personnel 2001, to discuss CRDM nozzle circumferential cracking cracking issues. During the meeting, the industry representatives said that they were industry representatives developing a generic developing recommendations for revisions of near-term generic safety assessment, recommendations inspections, and long-term inspection and flaw evaluation evaluation guidelines. The ONS3 cracking reinforces the importance importance of examining upper PWR RPV head area examining the upper (e.g., visual under-the-insulation examinations of the penetrations under-the-insulation examinations penetrations for evidence evidence of borated water leakage leakage or volumetric examinations of the CRDM nozzles) and of using appropriate volumetric examinations appropriate NDE NDE methods (e.g., UT, ET, PT, etc.) to adequately characterize cracks. Presently, licensees are adequately characterize not required remove RPV head insulation to visually inspect the head required to remove head penetrations; however, some licensees have recently performed examinations by using performed expanded VT-2 examinations cameras to inspect between the CRDM nozzles and the insulation. insulation. The NRC has recently developeddeveloped a Web page to keep the public informed of generic activities activities on PWR Alloy 600 weld cracking (http://www.nrc.gov/NRC/REACTOR/MRP/index.html). (http://www.nrc.qov/NRC/REACTOR/MRP/index.html). The The NRC will update this Web page and assess the need for further generic action as new information becomes available. This information notice requires no specific action or written response. If If you have any questions about the information in please contact one of the technical contacts in this notice, please listed below or the appropriate Office of Nuclear Reactor Regulation (NRR) project manager.

IN 2001-05 IN 2001-05 Page Page 5 5 of 5 of 5 Related Related Generic Communications Communications 0* Generic Generic Letter Letter 88-05, "Boric Acid Corrosion Corrosion of Carbon Carbon Steel Reactor Pressure Reactor Pressure Boundary Components in PWR Plants," March 1988 March 17, 1988 0* Generic Generic Letter 97-01, "Degradation of Control Rod Drive Mechanism Letter 97-01, Mechanism Nozzle and Other Other Vessel Closure Head Penetrations," April 1, 19971997

    • Information Notice 90-10, "Primary Water Stress Corrosion Information Corrosion Cracking of INCONEL 600,"

1990 February 23, 1990 0* Information Notice 96-11, Information 96-11, "Ingress of Demineralizer Demineralizer Resins Increases Increases Potential for Stress Corrosion Corrosion Cracking Cracking of Control Control Rod Drive Mechanism Mechanism Penetrations," February 1996 14, 1996 0* NUREG/CR-6245, "Assessment of Pressurized Water Reactor Control Rod Drive NUREG/CR-6245, Drive Mechanism Nozzle Cracking," Mechanism Nozzle Cracking," October October 1994 1994 I/RAI RAJ Ledyard B. Marsh, Chief Ledyard Events Assessment, Generic Generic Communications Communications and Non-Power Non-Power Reactors Reactors Branch Division of Regulatory Regulatory Improvement Improvement Programs Programs Office of Nuclear Nuclear Reactor Reactor Regulation Regulation Technical contacts: Technical Ian Jung, NRR NRR James Medoff, NRR 301-415-1837 301-415-1837 301-415-2715 301-415-2715 E-mail: ixj@nrc.gov ixj@nrc.gov E-mail: jxm@nrc.gov jxm@nrc.gov C.E. C. E. (Gene) Carpenter, NRR NRR 301-415-2169 301-415-2169 E-mail: cec@nrc.gov cec@nrc.gov Attachments: Reactor Pressure Vessel Head

1. Figure 1: Oconee Reactor Map Head Map
2. Figure 2: Oconee CRDM NozzleNozzle Penetration (Typical)
3. List of Recently Recently Issued Issued NRC Information Information Notices Notices

IN 2001-05 IN Page 5 of 5 This information information notice requires no specific action or written response. IfIf you have any questions questions about the information in this notice, please please contact one of the technical contacts contacts or' the appropriate listed below or Nuclear Reactor appropriate Office of Nuclear Regulation (NRR) project Reactor Regulation project manager. Communications Related Generic Communications

    **        Generic Letter 88-05, "Boric Acid Corrosion Corrosion of Carbon Steel Reactor PressurePressure Boundary Boundary Components in PWR Plants," March              1988 March 17, 1988
     *0       Generic Letter 97-01, 97-01, "Degradation of Control Control Rod Drive Mechanism Mechanism Nozzle and Other Vessel Vessel   Closure  Head Head  Penetrations," April 1, 1997 1997
     *0       Information Information Notice 90-10, "Primary Water Stress Corrosion Cracking of INCONEL    INCONEL 600,"

February 23, 1990 February 1990

     *0       Information Information Notice 96-11 ,"Ingress
                                          ,"Ingress of Demineralizer Demineralizer Resins Resins Increases Increases Potential for Stress Corrosion Cracking of Control Rod Drive Mechanism Mechanism Penetrations," February 14, 1996    1996
     *0       NNUREG/CR-6245,"Assessment of Pressurized NUREG/CR-6245,"Assessment              Pressurized Water Reactor Reactor Control Rod DriveDrive Mechanism Nozzle Mechanism     Nozzle Cracking," October October 1994 IRA/

IRA! Ledyard B. Marsh, Chief Ledyard Events Events Assessment, Generic Generic Communications Communications and Non-Power Reactors Branch Non-Power Reactors Regulatory Improvement Division of Regulatory Office of Nuclear Improvement Programs Reactor Regulation Nuclear Reactor Regulation Programs I Technical Technical contacts: Ian Jung, NRR James Medoff, NRR NRR 301-415-1837 301-415-1837 301-415-2715 301-415-2715 E-mail: ixj@nrc.gov ixj@nrc.gov E-mail: jxm@nrc.gov C. E. (Gene) Carpenter, NRR NRR 301-415-2169 301-415-2169 E-mail: cec@nrc.gov Attachments: Attachments:

1. Figure 1: Oconee Oconee Reactor Pressure Vessel Head Map Reactor Pressure Map
2. Figure 2: Oconee Oconee CRDM Nozzle Nozzle Penetration Penetration (Typical)

(Typical)

3. List of Recently Recently Issued Issued NRC Information Information Notices Notices Distribution:

IN File IN PUBLIC PUBLIC ADAMS ACCESSION ACCESSION NUMBER: ML011160588 NUMBER: ML011160588 Temple #=NRR-052

                                                                                  #=NRR-052 El Publicly Available       El Non-Publicly Available           oEl Sensitive Sensitive      0El Non-Sensitive Non-Sensitive OFFICE       REXB               Tech Editor      EMCB               EMCB               REXB                C:REXB NAME         IJung*              PKleene*        JMedoff*           CCarpenter* JTappert/txk*l. ILMarsh DATE         04/25/2001         04/25/2001       04/26/2001         04/25/2001         04/26/2001          04/30/2001 OFFICIAL RECORD COPY

Figure 1: Oconee Reactor Pressure Vessel Head Head Map Map r iS I u_ (IN Sin_ _ Service Structure Support Flange

                 "°°b     r. I J 3    02QQ   6 C (9           020 CY         020 d' 01 7           035      0013'3 09   09 (@10   If<l:\'O W             0(::f 30 0Cý
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                                                                                       -
  • Confirmed CRDM leaks ilil~!l Additional CRDMs CRDMs
                                                                                             '~ inspected CRDM CRDM Nozzles (69)                                                                        Thernocouple Nozzles (8)

Thenrocouple (8) (Oconee Unit 1I Only) (Oconee Only)

Figure Figure 2:0co nee CRDM 2:Oconee CRDM Nozzle Nozzle Penetr Penetration (Typical). ation (Typic al)

                           ,I I                  Stainl ess S'teel Slainless   Steal Fiatlg FRngee I.

AiIDoy Alloy 600 600 Weld CR,DM CIRDM NoWNoz~zlee (SB~1 67) (SB-167) Boron Deposit CoOOl9more Counleiboire

                                                             'Regi on Region A410y 600 Cladding 182- Weld 182-Weld

Attachment 3 Attachment IN 2001-05 IN 2001-05 Page 1 of 1 LIST OF RECENTL RECENTLYY ISSUED ISSUED INFORMATION NOTICES NRC INFORMATION NOTICES Information Information Date Date of Notice No. Subject Issuance Issued Issued to 2001-04 Neglected Fire Extinguisher Neglected Extinguisher 04/11/01 04/11101 All holders of licenses for nuclear nuclear Maintenance Causes Fatality Maintenance power, research, and test reactors and fuel cycle facilities facilities 2001-03 Incident Incident Reporting 04/06/01 04/06/01 All industrial industrial radiography Requirements for Radiography Requirements Radiography licensees licensees Licensees Licensees 2001-02 Summary of Fitness-for-Duty Summary Fitness-for-Duty 03/28/01 03/28/01 ~olders of operating licenses All holders licenses Performance Reports Program Performance Reports for nuclear power reactors, and for Calendar Calendar Years 1998 and Years 1998 licensees authorized to possess possess 1999 or use formula quantities of strategic special nuclear nuclear material (SSNM) or to transport formula formula quantities of SSNM 1-01 Importance of Accurate The Importance Accurate 03/26/01 03/26/01 All material material licensees licensees I 01-01 Inventory Inventory Controls to Prevent the Unauthorized Prevent Unauthorized Possession of Radioactive Material 2000-17, Crack in Weld Area of Reactor Reactor 02/28/01 02/28/01 All holders of operating licenses licenses Supp.2 Supp. 2 Coolant System Hot Leg Piping for nuclear nuclear power reactors except at V.C. Summer those who has ceased ceased operations operations and have have certified certified that fuel has has permanently permanently removed from reactor vessel 2000-22 2000-22 Medical Misadministrations Medical Misadministrations 12/18/00 12/18/00 All medical medical use licensees licensees Errors Caused by Human Errors authorized to conduct gamma authorized gamma Involving Involving Gamma Stereotactic Gamma Stereotactic stereotactic radiosurgery stereotactic Radiosurgery (GAMMA KNIFE) Radiosurgery treatments treatments 2000-21 Detached Check Valve Disc Detached 12/15/00 12/15/00 All holders holders of OLs for nuclear nuclear not Detected by Use of power reactors except except those who who Acoustic Acoustic and Magnetic Magnetic have ceased operations and have have Nonintrusive Test Techniques Nonintrusive Techniques certified that fuel has been permanently removed permanently removed from the the reactor reactor OL = = Operating License License CP == Construction Construction Permit

12ft S C-/1/ DOCKETED DOCKETED U.S. NRC U.S.

                                                                                 . In Inre NRC A

DAVID GEISEN re DAVID I. 5+'

                                                                                                              ~It tr GEISEN~iZ...xb 1A-05-052 Docket # 1A-05-052 f\{'

ExhibIt amm , _

                                                                                                                                        ) 0 3 _

USNRC USNRC Date Marked for ID~ Date IDJ/L 2008 (Tr. p. Xz.~~ 8 "TRA-COMPANY MEMORANDUM

           =OFFICE September 9, 2009 11:O0am)
                                               . SeptemberOF 9,2009  (11 :OOam)

SECRETARY Date Date Offered Offered in in Ev: J2:/..i-. Ev: .2_.*, 20082008 (Tr. p. gZ (Tr. p. 9Z S:-) RULEMAKINGS AND OFFICE OF SECRETARY ADJUDICATIONS STAFF RULEMAK/NGS AND

                                                                               =   Through WrtnesS/panel:_..L.tJ~/~ft~
                                                                               - Through      Witness/Panel: .

(

                                                                                                                         /" _ _ _ __

ADJUDICATIONS STAFF Action: ADMITTED REJECTED WITHDRAWN REJECTED TO TO Mechanical/Structural Unit T. S. Swim, Supervisor, Mechanical/Structural Date: Date: l1:/L. 2~(Tr. 2008 Tr. p.p 2> '1(;. ) Fom FROM Mechanical/Structural Unit P. K. Goyal, Senior Engineer, Mechanical/Structural MAIL STOP 3210 MAILsTroP 3210 suBJECT SUBJECT B&WOG Materials Committee Meeting PHONE PHONE 7351 I attended the subject meeting in Cleveland, Ohio on Monday, May 2i 21 through Wednesday, May 23, 200l. 2001. All members of the Materials Committee were present. The meeting agenda is attached. . Davis Besse is participating in the following projects: i)

1) RCS Materials Aging Management Management
2) Concerns **

CRDM Operability Concerns 3)

3) Alloy 690 Procurement Guidelines Procurement and Installation Guidelines.
4) Appendix H Compliance Appendix Compliance
5) CRDM Nozzle PWSCC
6) CRDM Nozzle Weld Inspection Inspection
    . 7)         Resolve Np Dosimeter Bias **

Resolve 8)

8) Internals Program * (partial)

RV Internals (parti~)

9) Plant Fatigue Monitoring Monitoring
  • 10)
10) HPI/MV Nozzle Integrity **

HPJ!MV 11)

11) Pressurizer Cooldown Issues ** **
                 *Deferred
                 *Deferred to year 2002, **DB is paying now others will buy in later     later S14H-01079 Following are the main topics discussed in the meeting.
1) D.
1) Whitakear (Duke D. Whitakear (Duke Engineering)

Engineering) presented presented the results of CRDM nozzle inspection inspection for Ocenee Ocenee 2. Four nozzles (#4, 6, 18 & nozzles (#4,6, & 30) showed showed the axial and circumferential circumferential PT indications. UT examination examination showed axial indications on all four nozzles axial indications nozzles and circumferential circumferential flaw on nozzle number number 18 only. This circumferential circumferential flaw was approximately was approximately 36036° long and located located above the weld. (Note the inspection results results had been been I provided to C. Daft, A. Siemaszko Siemaszko andandM M. McLaughlin.) McLaughlin.) The overalloverall dose for the inspection inspection and repairs was approximately approximately 30 REM. . Dave emphasized the importance Dave emphasized importance of good PT. He said the PT results are used for analysis work to show the show the nozzles were functional/operable nozzles were functional/operable during during the the past past cycles. cycles. UT is helpful helpful in detecting detecting the circumferential circumferential cracks. cracks. Dan Dan Spond Spond (ANO-1) (ANO-i) provided provided the details of ANO-1 ANO-l repair. One nozzle (#21) (#21) had had a crack, which was repaired repaired manually. manually. The The flaw above the weld was left in place. place. SIA SIA performed performed the embedded embedded flaw analysis. The repairs analysis. The repairs were were performed performed by FTI. TheThe repairs repairs were non-code (Section XI) repairs. Total does does for for repair repair and inspection inspection was approximately approximately 1818 REM REM and cost cost approximately approximately $2.0 $2.0 million. million. 7-t:-: A4 7t3ýýC:2-C4V7 cz gK DS C2-- NRC01 0-1079 NRC01 0-1 079

nl""""",",MPANY MEMORANDUM 08TRA-COMPANY MEMORANDUM Rn TO T. S. Swim, Supervisor, Mechanical/Structural Mechanical/Structural Unit DATE DATE June 11,2001 11, 2001 FROM FROM K. Goyal, Senior Engineer, Mechanical/Structural P. K. Mechanical/Structural UnitUnit MAILSTOP 3210 MAILSTOP 3210 SUBJEcT SUBJECT B&WOG Materials Committee Meeting B&WOG Meeting PHONE PHONE 7351 I attended Monday, May 21 through Wednesday, May 23,2001. meeting in Cleveland, Ohio on Monday, attended the subject meeting 23, 2001. All members of the Materials Committee were present. The meeting agenda is attached. participating in the following projects: Davis Besse is participating 1)

1) Materials Aging Management RCS Materials Management
2) CRDM Operability Concerns Concerns
  • 3)
3) Procurement and Installation Alloy 690 Procurement Installation Guidelines Guidelines
4) Appendix H Compliance AppendixH Compliance
5) CRDM Nozzle PWSCC S6)
6) CRDM Nozzle Weld Inspection 7)
7) Resolve Np Dosimeter Bias
  • Resolve 8)
8) RV Internals Program Program * (partial)
9) Plant Fatigue Monitoring Monitoring * .
10) HPIIMV Integrity **

HPJIMV Nozzle Integrity 111) L) Pressurizer Cooldown Cooldown Issues **

                    *Deferredto
                  *Deferred    to year 2002, **DB year 2002,  **DB is is paying  now others paying now          will buy others will buy in in later later              SI4H-01079 S14H-01079 Following are the main topics discussed in the      the meeting.
1) D. Whitakear
1) presented the results ofCRDM Whitakear (Duke Engineering) presented of CRDM nozzle inspection for Ocenee nozzle inspection Ocenee 2. Four nozzles (#4,6,

(#4, 6, 18 & circumferential PT indications. UT

                                  & 30) showed the axial and circumferential                        lIT examination showed showed indications on all four nozzles and circumferential axial indications                              circumferential flaw on nozzle   number 18 only. This nozzle number               This circumferential    flaw was approximately 360 circumferential flaw                                                                               inspection 36° long and located above the weld. (Note the inspection results had been been   provided  to to C. Daft,  A. Siemaszko   and M. McLaughlin.)

andM. McLaughlin.) The overall dose for the the inspection approximately 30 REM. inspection and repairs was approximately importance of good PT. He said Dave emphasized the importance said the PT results are used for analysis work to show the nozzles were functional/operable were functional/operable during the past cycles. lIT UT is helpful in detecting the circumferential circumferential cracks. Dan Spond (ANO-1) (ANO-i) provided provided the details of ANO-l (#2 1) had a ANO-I repair. One nozzle (#21) a crack, which was repaired manually. The flaw above the weld was left in place. SIA performedperformed the embedded flaw performed by FTI. The repairs were non-code (Section analysis. The repairs were performed (Section XI) repairs. Total approximately 18 REM and cost approximately does for repair and inspection was approximately approximately $2.0 million. NRC010-1079 NRC010-1079

Duke Duke had to submit about about seven seven relief requests requests to to perform perform the required required CRDM CRDM repairs. repairs. B&WOG's B&WOG's Materials Committee proposed Materials Committee proposed a task for submitting submitting a Topical Topical Report Report (for (for all B&WOG B&WOa plants) plants) for getting getting NRC NRC approval approval onon these these relief relief requests requests at one one time. Recent Recent discussions discussions with NRC NRC indicate indicate that NRC support the NRC does not support the issuance issuance of this Topical Report. Individual TbpicalReport. Individual utilities would would have toto file their their own relief reports. reports. FTI is is developing second set of developing second of tools both both for the the repairs andand inspection from the top of the RV head. These tools will be ready ready to support support the the fall 2001 outages. FTI had FfI had completed completed both thethe proprietary proprietary and non-proprietary non-proprietary version version of RVRV Head Nozzle and Weld HeadNozzle Weld Safety Safety Assessment Assessment (Doc #.51-5011603-01

                                  # SI-501l603-01and    and 51-5012567-00 51-5012567-00 respectively).

respectively). EPRI MPR had issued issued an interim interim Alloy 600 Safety Assessments to US Power Safety Assessments Power Plants (MPR-44). This This report includes a bar chart (attached) showing barchart time-temperature histogram for addressing showing time-temperature addressing the head nozzle nozzle cracking. B&W plants are are in in the group group of <3 EFPY. . Duke is having problems with the certified design specifications for the new RV head prepared by FTI. Dukeis having problems with the certified design specifications for the new RV head prepared by ¥II. The specification does not have enoughenough details to allow manufacturing manufacturing of head by other than FTI. FfI.

2) Committee Committee Business and PMT Results Committee Committee budget has been been revised revised several times because because of the emerging CRDM nozzle cracking ofthe cracking issues. approximately $2.2 million for the year 2001.

budget is approximately issues. Currently the budget 2001. The materials materials committee committee will be issuing a letter justifying the cancellation cancellation of CR CR-3..J inspection supported by the B&WOG. Steering Committee (SC) accepted the overrun on the first repair tool. Steering Committee will Steering Committee develop .aa standard policy on royalties for tooling when the tooling is used byFfI by FTI on non-B&WOG non-B&WOG plants. SC has numerous questions questions on IMI nozzles. Materials Materials committee chairman/project manager chairmanlprojectmanager will provide this information information to SC in the next meeting.

3) Dosimetry/Fluence analysis Program
3) Cavity DosimetryfFluence E. Giaredoni Giaredoni (FTI)

(FT!) provided provided the background background information on RV fluence monitoring andembrittlement andembrittlement one of the high priority project is to resolve resolve Np dosimeter dosimeter bias issues. This is required to to show thethe fluence uncertainty to be 20% or lesS less when the fluence is used to determine RTPTS RTprs and RT RTNDT. NDT* The copy of the handout is attached. Future Meetings: 11)

. I)       MRP RV internals IrG        meeting planned for August 27-28 in Portland, Maine. This ITa ITG meeting                                                                   ITG has requested a meeting with NRC on September 12th         12'h through 14th, 140, 2001
2) Materials Committee is planning to meet in September September in Washington, D.C., prior or after the ITa after-the ITG meeting with NRC.

If you have any questions please contact me at extension 7351. If PKG/gmw S14H-01080 S14H-01080 NRC010-1080 NRC01 0-1 080

Attachments Attachments bcc: bct: D.C. Geisen DB3105 w/a DB3105w/a T.A. Lang Lang DB3105 w/a DB3105w/a G.N. LeBlanc DB3205 w/a DB3205w/a T.A. McDougall McDougall w/a DB3105 w/a Mominee DJ. Mominee D.l. w/a DB3335 w/a MechanicaVStructural Unit Mechanical/Structural Unit w/a DB3210 w/a SI4H-01081 S14H-01081 NRCOIO-1081 NRC010-1081

                                                             ~A?2-Q             ~U.S.                      'U.S. NRC NRC                     Ct'        (\ (' ,elmm         i"7 1 In re In  re DAVID      GEISEN *2 ,fA.

DAVID GEISEN tt ExhibIt#-___ ~l_ -NTRA-COMPANY ~t#1A~5~52 '

  • NTRA-COMPANY MEMORANDUM MEMORANDUM Docket # 1A-05-052
0826a-.

_____________________________,____________ for IDfl:/l- 2008 Marked forlDLk..... Date Marked Date 2008 (Tr. (Tr. p..._...

p. 825)

Offered in Ev: Date Offered Date EV:!!:::/.J-,,2008 (Tr. p. ?flU;-J 2008 (Tr. ro Distribution TruhWnsf... el ro 'bution y**..,n/*' " 'Action:,-f ThroughWltnessIPanel:.REJECTED ttd,1,4 WnITDRAWN. -

               ,             O.JwAl _ '                                                                      Action:      ~ 'REJE~TED ~WN
-oR          P. K. Gorai, ~elfuo';Engineer -Mechanical/Structural Engineering Date:.

P. K. Go , enior Engineer -Mechanical/Structural Engineering Date: JJ:jL., 2008 ( Tr..EC 2008 (Tr.p. 3Z~ WH.DRAWN

                                                                                                                                                                )

DOCKETED uBJECT Mode 5 Reactor Vessel Head Inspection Recommendation PHONE 7351 USNRC DOCKETED' iUBJECT Mode 5 Reactor Vessel Head Inspection Recommendation PHONE 7351 September 9,USNRC 2009 (11:00am) September 9. 200~ (11 :OOam)

                                                                                                                  .DBE-O 1-0010 1                      OFFICE OF SECRETARY DBE-O 1-001 01                      OFFICE   OF SECRETARY RULEMAKINGS       AND RULEMAK/NGS AND ADJUDICATIONS ADJUDICATIONS STAFF   SMFF The purpose
           ,The    purpose of    of this this memorandum memorandum is        is to to provide provide anan engineering engineering evaluation evaluation for  for responding responding to    to the the question      "Should        Davis-Besse        perform     a visual  head   inspection question "Should Davis-Besse perform a visual head inspection if the plant shutsdown to   if the   plant  shutsdown        to Mode Mode 55 conditions?"

conditions?" Currently, Currently, the the visual visual head head inspection inspection isis planned planned in in 13RFO. l3RFO.

References:

References:

1)

1) Generic Generic Letter Letter GL-97-01 GL-97-01 "Degradation "Degradation of of Control Control RodRod Drive Drive Mechanism Mechanism Nozzle Nozzle and and Other Other Vessel Closure Head Vessel Closure Head Penetrations." Penetrations."
2) BAW-2301.

BAW-2301July, July, 1997, 1997, B&WOG B&WOG Integrated Integrated Response Response to GL-97-01. toGL-97-Ol.

3) BAW-10190P BAW-10190P May, May, 1993, 1993, B&W B&W Designpesign RV Head CRDM RVHead CRDM Nozzle Nozzle Cracking.

Cracking.

4) B&WOG B&WOG Materials Materials Committee Committee "RV "RV Head Head Nozzleý Nozzle andand Weld Weld Safety Safety Assessment" Assessment" preparedprepared by byFTI FrI ANP Document Number ANP Document Number 51-5011603-01. 51-5011603-01.
   "-      5) EPRI EPRI PWR  PWR Materials Materials Reliability Reliability Project Project (MRP)"Interim (MRP)~Interim Alloy Alloy 600 600 Safety Safety Assessment Assessment for     for U.S.

U.S. PWR Plant (MRP-44), Part PWR Plant (MRP-44), Part 2; Reactor Vessel 2; Reactor Vessel Top Head Penetrations "TP-100 TopHeadPenetratiol}s "TP-lO01491, 1491, Part Part 22 (May (May 2001). 2001). J

6) Letter from B.Sheron (NRR), to Alex Marion
6) Letter fromB.Sheron (NRR), to Alex Marion (NEI) dated April 17, 2001 (NEI) dated April 17, 2001 7)
7) NRCNRC Information Infonnation Notice Notice 2001-005 2001-005 "Throughwall "Throughwall Circumferential Circumferential Cracking Cracking of of Reactor Reactor Pressure Pressure Vessel Head Control Rod Drive Mechanism Penetration Nozzles Vessel Head Control Rod Drive Mechanism Penetration Nozzles at Oconee Nuclear Station, at Oconee Nuclear Station, Unit Unit 3."3."  ::. -

Background:

Background:

The The NRCNRC issuedissued aa Generic Generic Letter Letter (Reference (Reference 1) 1) during 1997, describing during 1997, describing the degradation and the degradation and cracking cracking of CRDM (Control Rod Drive Mechanism) nozzles. Each Owners of CRDM (Control Rod Drive Mechanism) nozzles. Each Owners Group (W, B&W and CE) prepared Group (W, B&W and CE) prepared aa Safety Safety Assessment Assessment and and submitted submitted to to the NRC. B&WOG theNRe., B&WOG submitted submittedBA BAW-2301 W -2301 (Reference (Reference 2) 2) inin response response to to the the Genehic Generic Letter.Letter. ItIt stated stated that that the the B&WOG B&WOG plant plant safety safety evaluation evaluation (Reference (Reference 3) 3) remains remains validvalid and and there there isis nono short-termn short-term safety safety concern. concern. ' S14A-00587 S14A-00587 Exhibit Exhibit 131131 Page Page 11 of of 44 Pages Pages NRC005-0587 NRC005-0587

                                                                                                 -D-L ~                       7)s 02---

June 27,2001 27, 2001 Page 3 Davis-Besse's Davis... Besse's susceptibility ranking compared to Oconee-3 Oconee-3 is approximately approximately 2.5 years. This means it it would take approximately approximately 2.5 additional years ofoperation of operation for Davis-Besse to observe observe the same th degradation degradation as noted at the Oconee 3 baselined to February, 200 2001.

1. The next (13

( 13th) ) refueling outage outage for DB is scheduled scheduled in the spring of 2002. Considering Considering the same baseline baseline for DB would show that th approximately approximately 1.3 years are remaining till the next planned head visual examination examination in 13 13t" RFO. This duration is conservative conservative as compared to 2.5 years. This is based on simplified operating time and head temperature comparison. temperature comparison. B&WOG Safety B&WOG Safety Assessment Assessment (Reference (Reference 4) 4) evalu. evaluated both the ated both the axial axial and and circumferential flaws. It circu.mferential flaw.s. It I cL provides time taken for both types of flaws to grow through the wall. It would take approximately approximately 4 i .~ v,' i" years years for an axial 00.OD flaw that is initially O.5~m more years for a through-wall through-wall flaw to .to extend 2 inches through-wall. l~ 0.5 mm deep to grow through..;wall. Inches above weld, thereby creatmg then take four SA-~.': It would thentake creating a leak path. An e

                                                                                                                               ~.'-1...{f!

isolated OD isolated 00 initated circumferential circumferential flaw above the weld would take take more than thah 10 years to grow b~ 6 through-wall. through-wall. A A long circumferential long circumferen. crack. (like tial crack (like ONS ONS 3)3) would take approx. would take approximately im. ate.I Y 3.5 years to 3.5 years to grow. grow . through-wall. Considering these time periods and that DB has 2.5 years available through-wall. Considering available to reach the Oconee3 degradation Oconee3 degradation level. level, it is acceptable acceptable to delay the head inspection until 13RFO. (Spring 2 2002). (02).' catastrophic failure of CRDM nozzle is not expected. Should a catastrophic A catastrophic catastrophic failure occur, the rod rod ejection accident accident and/or LOCA (Loss Of Coolant Accident) Accident) associated with rod ejection ejection are analyzed analyzed accidents accidents in the USAR. MRP MRP interim interim safety assessment (Reference (Reference 5) also provides provides response response to questions from B. Sheron (USNRC). The questions deal with any expanded/required expanded/required operator operator training on beyond design basis accident (DBA) scenarios scenarios involving involving rod ejection(s), ejection(s), small, small, medium and LOCA etc. and any recommendations recommendations regarding increasedincreased operator actions during period of highest rod width (e.g. startup, cool-down cool-down and hot standby standby periods). The failure of one or more CRDMs would Would be similar to that of a hot leg break LOCA in small to mediuinsize medium size range. The response to thisJscenario this scenario is within the guidance provided in existing generic Emergency Guidelines. The resulting LOCA Emergency Response Guidelines. LOCA. wouldwould be bounded bounded by existing design basis analysis. Existing Emergency Emergency Operating Procedures Procedures (EOPs) provide provide guidance for for all ranges of LOCAs and include coverage coverage for multiple events including including Therefore no additional reactivity excursions. Therefore operator action recommendations additional operator recommendations are needed. Recommendation: Recommendation: No catastrophic catastrophic failures are anticipated anticipated in delaying the head inspection from now to 13RFO. There is no short-term short-term safety issue associated with the CRDM nozzle cracking. Based Based on simplified susceptibility susceptibility ranking Davis-Besse Davis-Besse can operate operate for an additional additional 2.5 EFPY (July, 2003) prior to to reaching the same susceptibility as Oconee reaching Oconee 3. 3. Considering Considering these factors Mode 5 head inspection may be deferred. However, 13RFOheadinspection 13RFO head inspection must be performed performed as scheduled. Davis-Besse must continue to participate in in industry/NRC industrylNRC meetings meetings 10 to monitor developing issue. monitor this developing S14A-00589 S14A-00589 NRC005-0589 NRC005-0589

June 27, 2001 Page 4 Prepared by:- Date: 6-27-2001 PI?k.oYAL-Reviewed by:

                   -rSOUIM Date: ---==~+fP~rG...=.'(Jf--,,--'. ._-:-'-~

Approved by: ýL ýý /-;ý-3,/

             ý'   D ,. Cý -c-;r-/TýW z4ra___

Date: Date: al-71cJ:"t.I:.....-....,.-_ _ _......::*v,:.t:.d-.:'B:....:;7.:.£.,0-.: t". I  ; Distribution: G.G. Campbell MS3080 MS3080 S.A. Coakley MS1045 MSI045 D.L.Eshelman D.L. Eshelman MS 1056 MS1056 D.C. Geisen MS3105 S.P. Moffit Moffit MSI054 MS 1054 T.S. Swim Swim MS3210 MS3210 Records Mgmt. MS3020

                                                                                                       .ID. _ _ DD' S14A-00590 S14A-00590 NRC005-0590 NRC005-0590

kMý (- 113 U.S. In NRC U.S. NRC DAVID GEISEN 2 n,-; In re DAVID

                                                                                                                ~ 1 (f                      a '")

ExhIbIt O..2Jt::- ELxhlblt , Docket # 1A-oS-OS2 1A-05-052 . ID~ Date Marked for ID.d /g 2008 (Tlr..,Z , Date Marked for 2008 (tr. p. 2 Z  ;~ From: Prasoon K. K GoyaTEl/FirstEnergy GoyallTElFirstEnergy //L /9 . To: Andrew J. Siemaszko/FirstEnergy@FirstEnergy Siemaszko/FirstEnergy@FirstEnergy Offered in Ev::l::f1-. Date Offered Ev: I , 2008 (Tr. p. ~Z~ (tr. p..*L4 cc: John John B. Cunnings/TElFirstEnergy@FirstEnergy, CunningsITElFirstEnergy@FirstEnergy. Theo Thea S. Witness/Panel: filA Through Witness/Panel: /.A* _ Swim/ITE/FirstEnergy@ FirstEnergy, David C. Geisen/TE/FirstEneA SwimlTElFirstEnergy@FirstEnergy, GeisenITElFirstEnel *~ j EshelmanlTElFirstEnergy@FirstEnergy EshelmanITElFirstEnergy@FirstEnergy* Action: ~D Action: /* *D REJECTED WITHDRAWN REJECTED WITHDRAWN' Plant-specific data verification

Subject:

Plant-specific Date: Date: L14l-. L , 2008 (Tr. p. 82,& ) 2008 (Tr. p. . , )

*Date:

Date: 8:0:191010 7/10/2001 8:0:191010 Please complete the Table 1 (Plant Specific Data Verification Verification Form) RVheadRV head Previous Inspection Previous Inspection Status columns-- FulVPartia/ Statuscolumns-- Full/Partial and results. The table currently shows 100% inspection inspection which is not correct because because of the large boric acid deposits on the head very few CRDMs could be inspected. Also the table shows under PResul!" leakage detected. This will need to be' "Result" no leakage modified. Also be'modified. Also revew Table 2. This form has to be signed and .faxedby faxed ýby July 23rd 23rd....

 --------------- Forwarded Forwarded by Prasoon K. K.GoyalfTE/FirstEnergyon.07/1012001 GoyaVlTE/FirstEnergy .on 07/10/2001 07:35 AM     AM DOCKETED DOCKETED
                                                                                                                           . USNRC September 9, 2009 (11:00am)

September (11 :OOam) . Mark-Fleming Mark <mfleming@domeng.com> on 0710912001 Fleming <mflemlng@domeng.com>.on 07/09/2001 05:30:34 PM 05:30:34 PM OFFICE SECRETARY OFFICE OF SECRETARY! To: pkgoyal@firstenergycorp.com pkgoyal@firStenergycorp.com RULEMAKINGS AND RULEMAKINGS I cc: ADJUDICATIONS STAFF ADJUDICATIONS STAFF Plant-specific data verification

Subject:

Plant-specific verification L I. Attached are two pdf files which contain plant-specific plant-specific temperature, EFPY and design data which may be be included included inin safety-related calculations/data safety-related calculations/data tables prepared by the MRP MRP as part ot of the industry-wide response response to reactor head nozzle cracking. These data data were compiled by the MRP MRP from publicly available data sources sources (e.g.; (e.g., Nucleonics Nucleonics Week, utility utility responses to GL GL 97-01), 97 -O1}. as well as information individual utilities and NSSS information provided by individual NSSS vendors. Some of the data were previously used to support the calculations calculations described described in ("Time-Temperature Comparisons") of "PWR Materials in Appendix B ("Time-Temperature Materials Reliability Project -- Interim Alloy 600 Safety Safety Assessments for US PWR -Plants ,Plants (MRP-44): Part 2: Reactor Reactor Vessel Top Head Penetrations* Penetrations" (TP-1001491. (TP-1 001491, 2001). May 2001). Since the attached attached data may ultimately ultimately be included included in incalculations calculations or tables prepared under a safety-related safety-related QA program, each utility is being being requested to verify these data. To support requested support this data verification verification effort, please do do the following: STEP 1: Print a hard hard copy of both of the attached attached *.pdf

                                                                 * .pdf files (Table 1 and Table 2).

STEP 2: Review the data in each table. Note that you do not need to verify data/results data/results which appearappear in shaded cells, since these are either shaded cells. S14H-00997 S14H ..00997 NRC01 0-0997 NRC010-0997

From: Prasoon K. GoyallTElFirstEnergy Goyal/TE/FirstEnergy To: Andrew J. Siemaszko/FirstEnergy@ Andrew FirstEnergy Siemaszko/FirstEnergy@FirstEnergy cc: John B. Cunnings/TFEFirstEnergy@ FirstEnergy, Theo S. CunningsffElFirstEnergy@FirstEnergy, Swim/TE/FirstEnergy@ FirstEnergy, David C. GeisenITElFirstEnergy@FirstEnergy, SwimffElFirstEnergy@Fin;tEnergy, Geisen/TE/FirstEnergy@FirstEnergy, David L. L. EshelmanfTE/FirstEnergy@ FirstEnergy E:shelmanffElFirstEnergy@.FirstEnergy Plant-specific data

Subject:

Plant-specific data verification verification Date: 7/10/2001 8:0:191010 7/10/2001 8:0:191010 Please complete Please complete the Table 1 (Plant Specific Data Verification Form) RV head Previous Inspection RV head Inspection columns-- FulVPartial and results. The table currently Status columns--Full/Partial currently shows 100% inspection which is not correct because of the large large boric acid deposits on the head head very few CRDMs could be inspected. inspected. Also the table shows under under uResult" leakage detected. This will need to be modified. Also "Result" no leakage Also revew Table 2. This form has to be signed and faxed by July 23rd 23rd....


~---- Forwarded Forwarded byby Prasoon Prasoon K.

K.Goyal/TE/FirstEnergy .on 07/10/2001 07:35 GoyallTE/FirstEnergyon07/10/2001 07:35 AM AM Mark Mark Fleming <mflemlng@domeng.com>.on

                 <mfleming@domeng.com> on 0710912001 07/09/2001 05:30:34 PM To:        pkgoyal@firstenergycorp.com pkgoyal@firstenergycorp.com cc:

Subject:

Plant-specific data verification

Subject:

Plant-specific verification Attached are two pdf files which contain plant-specific plant-specific temperature, EFPY and design data which maybe may be included in safety-related safety-related calculations/data calculations/data tables prepared by the MRP MRP as partpart of the industry-wide response to reactorreactor head head nozzle nozzle cracking. These These data were compiled by the MRP from publicly available available data sources (e.g., Nucleonics Week, utility responses Nucleonics Week, responses to GL 97-01), as well.as well as information information provided by individual individual utilities and NSSS vendors. Some of the data data were were previously used to support the calculations calculations described ("Time-Temperature Comparisons") described in Appendix B ("TIme-Temperature Comparisons") of "PWR MaterialsMaterials Reliability Project -- Interim Alloy 600 Safety Safety Assessments Assessments for US PWR Plants (MRP-44): Part 2: Reactor Vessel Top Head Head Penetrations" (TP-l001491, (TP-1 001491, May 2001). 2001). Since the attached attached data may ultimately be included in in calculations or tables prepared under a safety-related safety-related QA program, each each utility is being requested requested to verify these data. To support this data verification effort, please please do the following: STEP 1: Print a hard copy of both both of the attached **.pdf

                                                             .pdf files (Table 1 and Table Table    2).

STEP 2: Review the data in each table. Note that you do not need need to verify data/results data/results which appear in shaded cells, since since these are either S14H-00997 S14H-00997 NRCOI0-0997 NRC010-0997

derived from or equivalent derived equivalent to other data data values in in the table. IfIf any of the data currently currently shown in in the attached attached tables are incorrect, please cross cross out the incorrect values and denote denote the correct values on the printed hard copy (please initial and date any data changes): STEP 3: After you have verified (and corrected corrected as necessary) the data, please sign and date date both of the forms and fax both of the signed tables to Mark Fleming at .DEI DEI at 703.790.0027. Please note thefol/owing the following regarding Table 11:: a) Information a) Information regarding regarding the "Insulation Type" and "Insulation Clearance" (first row of Table Table 1) has not not yet been obtained from all plants. IfIf this this information does information does not currently appear appear in the attached please attached table, please annotate this information information on the hard copy. In6ulation Il16ulation types reported thus reported thus far are "Reflective," "Blanket," "Block," ,and and "Encapsulated" (however, if if another type is used, please denote it.). To denote insulation clearance, please use the key shown on the table (i.e., (i.e., "C"=

                                                       "C" = contoured insulation Insulation geometry, "H"  "H" = horizontal   insulation geometry, horizontal insulation   geometry, and "S"    "S"= stepped insulation    geometry). Please provide the clearance inSUlation geometry).                                clearance between the insulation insulation and the top headhead surface ifif it is not already already shown in the table. For example, an entry of "S(1~4n)"
                          "S(1-4")" would denote a stepped insulation geometry with a clearance         between 11" clearance of between          and 4".
                                     "and   4".

b) IfIf the month and year of the next planned refueling refueling outage are not already shown on the attached attached table, please please note them in the "Next Refueling Outage Date" column column (second Jaw row of Table 1). 1). Fora For a number of plants, the season 2001 ') of the next refueling season and year (e.g., "fall 2001") refueling* outage are known, known, but the MONTH and year of the next refueling outage are preferred ifif available. c) Data cells associated associated with past inspection inspection experience experience appear blank if if the MRP has not been been informed informed of any previous inspection inspection experience experience fora for.a given plant (other than the basic 88-05 walkdowns). walkdowns). If If previous previous RV headhead / CROM nozzle inspection CRDM inspection experience experience is not currently currently reflected reflected in the table, please annotate. annotate the hard copy with the appropriate appropriate inspection information information (second row of Table 1). . If If you have any questions, please do not hesitate to call Mark Fleming Fleming at 703.790.5544 (if 703.790.5544 (if you need need to reach someone on July 12-13, 12-13, please please ask to speak with Steve Hunt). The MRP requests requests that the signed copies copies of both of the data tables be faxed to DEI by July 23, 2001.2001. Thanks in advance advance for your assistance in in this matter. Mark R. Fleming, Fleming, P.E. Dominion Engineering, Engineering, Inc. MFleming@ DomEng.com E-mail: MFleming@DomEng.com Phone: 703.790.5618 703.790.5618 x239 (direct) 703.790.5544 (general) Phone: 703.790.5544 Fax: 703.790.0027 703.790.0027 Web: . www.domeng.com www.domeng.com S14H-00998 S14H-00998 NRC010-0998 NRC010-0998

Job Name: Dorgan_81154_CDO1 1r"1IIl ............. n_81154_CD01 Internal Unique 10: Internal ID: 429 File Path:

\\Dctsfs05\Blowback\Morgan\81154\C001
\\DctsfsO5\B Iowback\Morgan\81154\CDO1
\Investigation\Folders
\lnvestigation\Folders
\Action Items OTHER\0000000138OTHER\0000000138
\First Energy Davis-Besse     Davis-Besse Data QA - Tabl e 1.pdf 1.pdf

\0

                                                         $14H-00999 S14H-00999 NR.nf1 n.nQQQ

PLANT-SPECIFIC DATA VERIFICATION FORM DATA VERIFICATION Table 1. Operating Time, Temperature, Fabrication, Fabrication, and Inspection Information Information for Reactor Vessel Vessel Head NozzleNozzle PWSCC Assessments Design and Operating Time and Desilln Head Remaln. Diametral Temp. EFPYsto Nozzle EFPVs Range Current EFPY. ReRCh Nozzle thru Head Norm. Oconeel Histogram

                                                                              -Interference                                                      Over Vnlt            NSSS        Material         Head                                                              Feb.                          Temp.         . to         from           Group Fit                                                          Life Name              DesIgn      Suppller l    Fabrlcatorl         (mils)          Type         ClearanceJ          2001           (oF)             (oF) 600ci~       3/1,          (EFPYs)'

B&W BIH BW 0.5 - I.S ,Reflective H(2") 14.7 605 605 Table 1. O Table 0 ~erating ratlng_ Time. Temperature. Fabrication, ime, Temperature, Fabrication, and Inspection Information for Reactor Vessel Head Nozzle Inspection Information Nozzle PWSCC Assessments (cont.) Pre,,;ous Inspection Previous Inspt!ction Status Status Next Next Bare-Bare-Scheduled Metal Metal Refueling Refueling Visual Vnlt Unit or ID Outage Name Name Otage DiIt; or ID Date Full /I Partial Partial Result Comments NDE Davis-Besse Davis-Besse 2()O2 [ spring 2002 Visual I Mar-OO Mar-00 ] 100% 100% No leakage FNo leakage detected detected IB&W insulation B& W plants have gap under insuhidon Notes: Notes: 2 4

            'Key for Material Suppliers:                     Key for for Head Head Fabricators:

Fabricators: 3Key forclearance between insulation and top surface of head: Calculated using a thermal activation I Key for Material Suppliers: lKey J Key for clearance between insulation and top surface ofhead: *Calculatcd using a thennal activation

         - BB == B&.

B&W W Tubular Products BW = B&W BW=B&'W contoured insulation geometry C = contoured geometl)' (sits on top head surface) energy of 50 kcal/mole. kcalhnole. HH - Huntington Huntington CBI - Chicago Bridge & &.Iron Iron H a- horizontal insulation H insulation geometry geometry SS = Sandvik CE =- Combustion Combustion Engineering Engineering S a- stepped insulation insulation geometry lIeometl)' W (Huntington) W = Westinghouse (Huntington) RDM = Dockyard

                                                                   - Rotterdam DockYard Data Verification Verification and Approval Annroval for Use:

The plant-speCific plant-specific data presented above in Table Table 1I (in unshaded cells) have been verified verified and are deemed suitable for use as inputs to safety-related safety-related calculations. calculations.. Any required required changes to the data in Table (in unshaded Table 1(in annotated above and initialed and dated to denote accuracy/suitability unshaded cells) are annotated accuracy/suitability for use as inputs to safety-related calculations. Signed Date cn Printed Printed 6.o 0. z 0

u 0 o 0 Davis-Besse Data QA - Table First Energy Davis-Desse I~xis Table I.xls 7/9/01 719101 Q

~ Q I ~0L Q0 CD Q0 Q

Job Name: Job Name: P organ_81154_CDO1 rgan_81154_CD01 Internal Unique ID: Internal ID: 430 430 .File File Path: Path: \XDctsfs05\BlowbacklMorgan\81154\C \\Dctsfs05\Blowback\Morgan\81154\CD01 DO1 \lnvestigation\Folders \lnvestigation\Folders

  • Action

\Action Items Items OTHER\0000000138 OTHER\0000000138 \First \First Energy Energy Davis-Besse Davis-Besse Data Data QA QA - Tabi Tabl ee 2.pdf 2.pdf . SI4H-01001 S14H-01001 NReNINlinnil NRcn1 0.1 nn1

PLANT";SPECIFIC DATA PLANT-SPECIFIC DATA VERIFICATION VERIFICATION FORM Table 2. Table 2. Time-Temperature Time-Temperature Calculations Calculations for for Reactor Reactor Vessel Vessel Head Head NozzleNozzlePWSCC Assessments PWSCC Assessments TOIDI EFPYs thru Total Februa 20017 thru February 1001 Total Total Current Current Nuc/Weu. Nucl Week Nuc/ Week Nuei Week source

                                                                                                                                                                                          *Source
                                                       *Gross                                                                                                                                                              Current Gross             Groll Gross           Operating Operating          Operatlng Operating                                                                      IsNW Ia NW    Operating Operating    Operatlng Operating  Head NSSS          Production          Capacity             Time Time              Time Time       Source of EFPY Data                                              Uori'       Time       .Time     Head Temp.

Unit NSSS Supplier Production (MWh)t Capadty (MWe), (EFPHs)` (EFPYs)' SroEiDaof EFPY Data or Time (EFPHs) Time (EFPYs) 0171 Source Temp. Unit SuppUer (MWb)' (MWe)' (EFPHs)' (EFPYs)' Utility (EFPHs) (EFPVs) 0* Davis*Besse jDavissBesse _II B&:W

                                        &W          ....    ...
                                                     /18,733,025 11,3Vur-r              925 925       MII _          _         __
                                                                                                        .leonics            __ _ Week-Nucleonics      _

Week _ _ __ _ _ _ _ .N W .5. or NW 605eTi0 605.0 Time-Tem erature Calculations Table 2. Time-Temperature Calculations for Reactor Reactor Vessel Vessel Head Head Nozzle Nozzle PWSCC PWSCC Assessments Assessments (continued). Head Temp. #1 Head Temp. #2 Head Temp. #3 Head Temp. N4 Operating Operating Operating Operating Head Head Operating Operating Operating Operating Head Head Operatlag Operating Operating Operating Head Head Operating Opentlag Operating Operatlng Head Head Period Period Period Temp. Temp. Period Period Period Period Temp. Temp. Period Period Period Temp. Period Period Period Period Temp. Temp. Source of Source of Unit Unit (EFPOs) (EFPHa) CEFPYI) (EFPYs) (oF) (OF) (EFPol) (EFPHs) (EFPYs) (EFPYs) (OF) (CF) (EFPHs) (EFPHs) (EFPYs) (EFPYs) (oF) (OF) (EFPHs) (EFPHs) (EFPYs) CEFPYs) ("F) MHead Temnerature Dat Davis-Besse 0-Deane WOC GL 97-01 Response

           ~

DATA IN SHADEDSHADED CELLS DO NOTREQUIRE DO NOT REQUIRE VERIFICATION. V.:RIFIC/\TION. I.I. Total gross gross generation generation through through February 2001 as tabulated tabulated by the April April 12, 12, 2001, 2001, Issue issue of Nueleollies Ntcleonics Week Week capacity as

2. Gross capacity as tabulated by the April 2001, issue April 12, 2001, issue of or Nucleonics Nucleonic.! Week power hours Effective full power
3. Effective hours calculated calculated as ratio of gross production total gross ortotal produciion to gross gross capacity (effective full power capacity (effective power years calculated by dividing by 8760).

calculated by

4. Operating Operating time normalizedto Donnalizcdto a head temperature of 600°F 600eF using using an activation activation energy of50 of 50 iccaVmole kcallmole and the Arrtoeniusrclationship Arrhenius relationship Data Veriflcation and Data Verification Approval for Use:

and Aunroval Use; The plant-specific data presented in Table Table 22 (in(inunshadcdcells) unshaded cells) have been verified and and are deemed deemed suitable suitable for use as inputs inputs to safety-related calculations. calculations. Any required changes to the data in Table 2 (in unshaded reUs) cells) are annotated above above and initialed and dated to denote denote accWllcy/stiitability use as accuracy/suitability for usc inputs to safety-related safety-related calculations. Signed Signed Date Printed Printed C,) CA

     ,a:.-

Xz 6... z o 0 ~ o0 n N Fitst Energy Davis*Besse First Dala QA *-Table Davis- Besse Daia 2.xls Table 2.ds 7/9/01 Q Q Q Q N

RAS 0-ox U.S. u.s. NRC NRC c+ ,'r- <?.L RA-S C-'1f In re In re DAVID GEISEN -m DAVIDGEISEN Docket## IA-05-052 Docket 1A-05-052 J Ii-*[ ft O-""2) t-r EExhibIt.~ Markedfor Date Marked Date forID / ID.JJ./....L. 2008 (Tr. 2008 (Tr. P.~-:L A-COMPANY MEMORANDUM . Date EV:.ilJ!.-,, 2008 Offeredinin Ev:... Date Offered 2008 (Tr. p.~~ (Tr. p.-R&.)

          ~====================== Through                                                                    Through Wit  Wrtn         nel: h/J anel:       filA*                  _

Action:. REJECTED WITHDRAWN REJECTED WITHDRAWN T.S. Spyim, Supervisor, Date: ~...... , 2008 008(Tr.(Tr. p.9L)

p. &2, U )

TO TO T .S.1r,,,::. S,upervisor.Mechanical/Structural MeChanicaliSlIUC1m"al Unit Unit DOCKETED DOCKETED FROM FROM ~or P.K. Goa,Senior Engineer, P.K. Mechanical/Structural Unit Engineer, Mechanical/Structural Unit MJAILSTOP MAILSTOP 3210 3210 USNRC USNRC September September9,9, 2009 2009 (11:00am) (11 :OOam) suajEr EPRIMPR Alloy SUBJECT *EPRIlMPR Alloy 600600 Workshop Workshop .PHONE PHONE 7351 7351 OFFICE OFFICE OFOF SECRETARY SECRETARY RULEMAKINGS RULEMAKINGS AND AND ADJUDICATIONS ADJUDICATIONS STAFF STAFF participated in II participated in the MRP Alloy the MRP Alloy 600 Workshop and 600Workshop Alloy 600 and Alloy 600 Assessment meeting held Subcommittee meeting Assessment Subcommittee held on on June June 13',13th , 14' an~ 15t'. 14th and 15th* Both Both the the workshop workshop and and meeting meeting were held in Atlanta, w.ere.heldin Atlanta, Georgia. Georgia A A copy copy of of the meeting agenda and the list of participants the meeting agenda and the list of participants is attached. is attached. Lessons Lessons Learned Learned for for Davis Davis Besse: Besse: Following Following are are the the lessons lessons learned learned from from Oconee Oconee and and ANO-1 ANO-l headhead inspections inspections for for boric boric acid: acid:

        ** Service Service structure structure access access is is needed needed in    in order order toto clean clean and and inspect inspect the the head.

head. (Note (Note Davis Davis Besse Besse doesdoes not not have have service service structure structure holes) holes) The The leaking leaking nozzle nozzle may may produce produce very very little little -boric acid acid The head needs to be clean in order The head. needs to be clean in order to see a leaking nozzle to see a leaking nozzle .

        *- The The inspection inspection to  to look look forfor boric boric acidacid should should be be done done in in accordance accordance with with aa procedure procedure (DB needsneeds to  to develop develop aprocedure) a< procedure)                                                                                                           \
        ** Train       VT    inspector      for Train VT inspector for inspection   inspection
        ** Base Base line line pictures pictures (video)

(video) areare needed needed for for next next inspection inspection

        ** Welding          engineer       should   review       the Welding engineer should review the repair methods and    repair   methods      and procedures procedures
        ** Make         record    of  each    nozzle     inspection      -  not Make record of each nozzle inspection..., not a generic statement    a  generic  statement
        *-. Develop Develop EWR    EWR or   or Modification Modification package  package for for the the repair repair of of CRDM CRDM
        ** Procure         CRDM        storage    box.      It Procure CRDM storage box. It can store 18 CRDMs . can   store   18  CRDMs The The purpose purpose of. of. the the workshop workshop was     was to  to update update the the industry industry on on recent recent inspection inspection history history and and repair repair ofof CRDM CRDM penetrations, penetrations. discuss discuss "lesson "lesson learned" learned" andand discuss discuss near-term near-tenn recommendations recommemIations for      for fall fall 2001 2001 andand spring spring 2002 outages.outages.

L. L. Matthews Matthews (Chairman (Chainnan of MRP Alloy ofMRP Alloy 600 600 ITG) ITG) provided provided the overall view the overall view of of Alloy Alloy 6000 6000 issues. issues. AlloyAlloy 600 material has cracked in BWRs, steam generators, pressurizer penetrations, 600 material has cracked in BWRs, steam generators, pressurizer penetrations. PWR pipe and welds PWR pipe and welds andand CRDM penetrations. penetrations. The issues are The issues are asas follows: follows: .

       *0    If      cracks. how If it cracks,      how fast      will it fast will. it grow?

grow?

  • If itit grows,how If grows, how far far can can itit grow grow before before it it becomes becomes aa safety safety concern concern 0
  • Can NDE detect it before it is a safety concern?

Can NDE detect it before it is a safety concern? S

      -      Will Will it     leak?

it leak? S14A-0378 4 514A-03784

                                                                      ý-- jlýEcv'                                           DS       6-z.-,                 NRC005-3734 NRC005-3734

J, W A-COMPANY ftA**GUtmF'AI'lIY MEMORANDUM MEMORANDUM TO TO TWS. srr}X~:A~upervisor, T.S. Mechanical/Structural Unit S im, Supervisor, Mechanical/Structural Unit DATE July 12,2001 12,2001 FROM bofafs;ior Engineer, Mechanical/Structural P.K. G~oya],Senior Mechanical/Structural Unit MAIL STOP MAILSTOP 3210 3210 SUBjECT SUBJECT EPRVMPR EPRIlMPR Alloy 600 Workshop PHONE 7351 I participated participated in the MRP Alloy 600 Workshop and Alloy 600 Assessment Subcommittee meeting held Assessment Subcommittee on June th th June 113 3 "h, 14 th and 15

                              , 14th       1 5th.* Both the workshop and meeting were held in Atlanta, Georgia. A copy of        of the meeting agenda and the list of participants  participants is attached.

Lessons Learned Learned for Davis Besse: Besse: Following are the lessons learned learned from Oconee and ANO-l ANO-1 head inspections for boric acid: S *" Service Service structure access is needed in order to clean and inspect the head. (Note Davis Besse does not have service

          *& The leaking service structure holes) leaking nozzle may produce  produce very little boric acid acid
          *" The head needs to be clean in order to see a leaking                  nozzle leaking noZzle
           *" The inspection inspection to look for boric acid should be done in accordance accordance with a procedure procedure (DB needs to develop      a   procedure)

O develop procedure)

           *" Train VT inspector for inspection
           *" Base line picturespictures (video) are needed for next inspection
  • Welding
  • Welding engineer should review the repair methods and procedures procedures
           *" Make record of each nozzle inspection - not a generic statement        statement
           .0
  • Develop EWR or Modification package for the repair ofCRDM of CRDM
           ** Procure Procure CRDM storage box. It can store 18 CRDMs The purpose The     purpose of. of.the   workshop was the workshop      was to to update the industry on recent inspection inspection history and repair repair of CRDM penetrations, penetrations, discuss "lesson"lesson learned" learned" and discuss near-term    recommendations for fall 2001 and near-teno recommendations                    and spring 2002 outages.

L.L. Matthews Matthews (Chairman of MRP Alloy 600 ITG) provided provided the overall view of Alloy 6000 issues. Alloy Alloy .,. 600 material material has cracked in BWRs, steam generators, pressurizer pressurizer penetrations, PWR pipe and welds and penetrations,PWR and CRDM penetrations. penetrations. The issues are as follows:

            **   If it it cracks, cracks, how  how fast fast will   it grow?

will it grow?

           *"    If it grows, how far can it grow before     before it becomes becomes a safety concern.

concern

           *"    Can   NDE Can NDE detect itdetect it before   it safety concern?

it is a safety concern?

            "*   Will it leak?

S14A-0378 4 S14A-03784 NRC005-3734 NRCOOlS*3734

Date Date Received by -JIJl Received by. -JL I16 2001 2001 Vice Vice President President ,.

    - .I                     IRoute Route A     Bv  Iinit. Data
 \1;\::

Et:§. DlR.

 !'Y..1\PJg*

"":;;.('5I D IR. yP, __,... DJJ\']QR. t-~~~ *!-f~1.- ~.o!}PHP COMMENTS: COMMENTS: FIL .LE; -H - FILE: ALE: SI4A-037 85 S14A-03785

',. July 12,2001

   .July     12, 2001 PageZ Page     .2 S        *Will leakage be seen?
      *.CanCan leakage          seen?

leakage be detectable

  • Will leakage before a break?

detectable before break?

        ** Are there                  volumetric techniques acceptable volumetric there acceptable                 techniques available?

available?

      ** How       should we How should      we inspect?

inspect? How often should

       ** How             should wewe inspect?
  • How cracks be repaired How can the cracks repaired and mitigation to and is there mitigation topreventlstop cracking?

prevent/stop cracking? We the induStry inspection and evaluation industry must deal with these issues and ensure safety, develop inspection evaluation guidance and guidance develop repair and mitigation techniques/strategies. and develop techniques/strategies. M.Robinson M. Engineering) presented Robinson (Duke Engineering) presented thethe details details of of Oconee Oconee 1,1,2 and 3 CRDM 2 and CRDM nozzle nozzle cracking cracking Following are the details: details. Following details. Oconee 1I Oconee Nozzle #21 and several Nozzle #21 several thennocomple nozzle were cracked. thennocomple nozzle Total dose for repairs repairs 67 Rem Rem Oconee 2 Oconee #4,6, 18&30 Nozzle #4,.6, Nozzle 18 &.30 had cracks. Total dose for repairs, 31 31 Rem. Oconee 3 Oconee #3, 7, Nozzles #3, 7, 11. 23, 28, 34, 50, 56 & 63 had cracks. Total does 11, 23, repairs, 300 Rem. for repairs, He provided following insight into the nuclear He nuclear safety significance circumferential cracks significance of the two circumferentia,Icracks 1600) at Oconee 3. (approximately 160°) (approximately

     **    Acddent Accident associated                                                ejection accident, associated with complete failure of weld is rod ejection                  which is covered in accident,which              in design basis.

Structural failure requires circumferential

     *" Structural                                                                    considerable margin - 4 years before circumferential crack. Oconee 3 had considerable reaching ASME code allowable.

reaching circumferential crack initiates, it would take more than 6 years to grow through wall.

  • Once circumferential Duke's future plan is to work with NEI, EPRI and industry group on inspection and repair techniques.

with NEI,EPRI w. W. Simms (AN01) (ANO1) presented the details of ANOI nozzle cracking. Nozzle #56 had a circumferential circumferential extending 51° OD crack extending* circumferential crack 51' around the nozzle and an axial crack extending from the circumferential crack about 1.3" Circumferential crack was removed by grinding. The axial 1.3" above the weld. Circumferential crack was left in the nozzle. The embedded embedded flaw repair does not require a temperbead. Total dose for the repairs was 17 Rem. The copy of handout is attached. Jack Strosnider, Director. Jack Engineering NRC presented the regulatory perspectives on CRDM Director, Division of Engineering Management attention to address this issue. He outlined the identified the need for Senior Management cracking. He identified following main points of an inspection plan. . S ** Method-Method - Visual, Volumetric, Qualification

  • Scope - Sampling Statistics
        .Scope
   **Acceptance Acceptance Criteria - ASME Code 814A-03786 S14A.03786 NRC005-3736 NRCOO!?-3736

/ July 12,2001 Page 3

  • Frequency - Crack Growth Rates
 ,0                                Rates
 *0t Short Term - Generic Communication Communication (bulletin)

(bulletin).addressing addressing short term inspection inspection needs. I

  • Long Term - Augmented inspection inspectiQn program requirements.

requirements. Jack reminded industry of various GDCODC requirements requirements e.g. GDC ODCI4;14; Reactor Coolant Coolant Pressure Boundary, etc. He also said that leakage leakage detection, alone, may not constitute compliance compliance with the regulations. NRC isis planning to issue this bulletin in the early August, 2001. 2001. This bulletin will require a response within 30 days. V. Wagoner, Chairman of Assessment Assessment Committee Committee discussed the key results of preliminary safety safety assessment assessment sent to the NRC. The attached meeting notes dated June 28, 2001 provide provide the details. These These notes also provide recommendations for future inspections. provide recommendations If H you have any questions questions please contact me at extension extension 7351. PKG/gmw Attachments Attachments* cc: G.G. Campbell DB3080 w/a DB3080w/a D.C. Geisen DB3105w/a DB3105 w/a T.A. Lang T.A.Lang DB3105 DB3105w/a w/a G.N. LeBlanc ~ D133205 w/a DB3205w/a M.A. McLaughlin McLaughlin DB1048 DB1048w/a w/a T.A. McDougall McDougall DB3105 DB3105w/a w/a L.W. Myers L.W.Myers BV-ADM BV-ADMw/a w/a D.J. Mominee DB3335 DB3335w/a w/a A.J. Siemaszko Siemaszko DB 1056 w/a DBI056w/a Weakland D.P. Weakland BV-GP BV-GPw/a w/a Mechanical/Structural Mechanical/Structural Unit DB3210 w/a DB3210w/a S14A-03787 S14A-03787 NRC005-3737 NRC005-3737

0-19ýr u.S. U.S. In NRC re NRC Inre GEISEN *5Cif ."- ('{' DAVID GEISEN DAVID PP t e.tIM ..... '74

                                                                                                                                                  # .)...........-

A..()5-()52 j /) /0 Docket ## 11A-05-052 Docket Date Date Marked Marked for ID lD:hL. 2008 2006 (fr. Po 2S ,or (Ti. 3 ~ Data bttered Date EV:.l2/i--;/2008(Tr.P~ Offered: ininEv: 2008 (Tr. p. g l (P ) From: Frank From: Frank W. W. KennedyfTElFirstEnergy Kennedy/TE/FirstEnergy Thmo ~I:* Through w"gkn MIA1 . To: To: Rodney M. Rodney M.Cook/FirstEnergy@FirstEnergy Cook/FirstEnergy@ FirstEnergy ArctiorwL ~. Action: A&#TE6 REJECTED REJECTED ~ W~TDM*M cc: cc: ~: l~(, ....(Wr./f) K~& l

                                                                                                     . I                            .

Subject:

FW: NRC

Subject:

NRC Telcon. Telcon. Alloy Alloy 600 Bulletin Bulletin DOCKETED DOCKETED Date: 8/8/2001 15:28:121010 B/8/2001 15:28:121010 USNRC USNRC September 9, 9, 2009 (11 (1 1:00am)

OOam)
---- Forwarded

Forwarded by Frank W. KennedylTElFirstEnergy KennedyfrElFirstEnergy on .08/08/2001 03:25 on .08/0812001 03:25 PM --------

OFFICE OF SECRETARY OFFICE RULEMAKINGS AND RULEMAKINGS ADJUDICATIONS STAFF ADJUDICATIONS Prasoon K. K. Goyal To: 02:55 PM 08/08/2001 .02:55 08108/2001 PM An An drew J. Siemaszko/FirstEnergy@FirstEnergy, SiemaszkolFistEnergy@FirstEnergy, FrankW. Frank W. Kennedy/TE/FiretEnergy@FirstEnergy, Mark A. KennedylTElFirstEnergy@FirstEnergy,MarkA. McLaughlinr/--FirstEnergy@FirstEnergy

                                                          *McLaughlinlTElFirstEnergy@FirstEnergy cc:

Subject:

FW

NRC Telcon.

Telcon. Alloy 600 Bulletin ItItappears appears that that NRC is looking for plant specific info. Thi~ This would create a difficult situation for us when they review they review ourour past past inspection inspection results results....


Forwarded


Forwarded by by Prasoon Prasoon K. K.GoyalfrEIFirstEnergy.on Goyal/TE/FirstEnergy on 08(08/01 08/08101 02:48 02:48 PM ---

                "Gray, William William R"
                <WGray@framatech.
                .<WGray@framatech.                         To:

corn> com> 'de whitak~duke-energy. whitak@duke-energy.com corn (E-mail)* <dewhitak@duke-(E-mail)" <dewhitak@duke-08108/01 01:45 PM 08/08/01 .01:45 energy.com>, 'dspond@entergy. com energy.com>, *dspond@entergy. corn (E-mail)' (E-mail)"

                                                            <-dspond@entergy.com>, 'pkgoyal@firstenergycorp.
                                                            <dspond@entergy.com>,          'pkgoyal.@firstenergycorp. com (E-mail)"    <pkgoyal@firstenergycorp.com>, 'robert.

(E-mail)"<pkgoYal@firstenergycorp.com>. "robert. p. p. lemberger@fpc. lemberger@fpc. corn com (E-mail)' (E-mail)'

                                                           <robert.p.lemberger@        fpc.com>, 'greg.
                                                            <robert.p.lemberger@fpc.com>,           'greg.

gerzen @exeloncorp. corn (E-mail)* gerzen@exeloncorp.*com(E-mail)"

                                                           <greg.gerzen@exeloncorp.com>
                                                            <greg.gerzen@exeloncorp,com>

co: cc:

                                                                                                                            "Fy "Fy fitch, Stephen" <SFyfitch@framatech.com>

fitch, Stephen" <SFyfltch@framatech.com>

Subject:

Subject:

FW FW

NRC NRC Telcon.

Telcon. Alloy 600 600 Bulletin Bulletin The The attachment attachment is is aa set set of of notes notes from from aa phone phone call call between between NRC, NRC, NEI, NEI, and and CP&L CP&L on on Bulletin Bulletin 2001-01. 2001-01. The The discussion discussion focused focused on on the the use use of risk risk assessment assessment in in response response to to 2001-01. 2001-01. Based Based onon thethe notes, notes, It It appears appears that that the the NRC is skeptical about the use of risk assessment NRC is skeptical about the use of risk assessment for for this this situation. situation. S140-04243 S14D-04243 NRC007-1596 NRC007-1596

                                                                         '.~  "
  • J
            , '.: ,,;'~ ~"-   *  ~ I  '
   ..: ,~~~. ~,:Greg':~
                   .Grg--Thanks         ThankSfOr'~~iigih~efor sending these notes.                nofeS:" "

~"""".}If'4J~ij~ . ,!~,,'::,,/::::;...:>' ,:,.., .....,~: '::r ... ::::... Bill. Bill, ..'

                            .~ .... :'-~~.... -':' ... ,.i .. ;i; )  .~; :.i$.~ ., ... ", '~".'.'         * *~:{~
                    ---OriginalOriginal Message---

Message--- From: greg.gerzen@exeloncorp.com From: greg.gerzen@exeloncorp,com [3] @exeloncorp.com

                  .Sent: Tuesday. Tuesday,: August 07;                      07, 2001 7:28 PM              PM                                          .

To: dewhitak@duke-energy.com; dewhitak@duke-energy.com; WGray@framatech.com WGray@framatech.com

Subject:

FW:

Subject:

FW: NRC NRC Telcon. Telcon. Alloy Alloy 600 600 Bulletin Bulletin I just got this. Itsort of sounds like risk assessment isn't something the I just got this. It sort of sounds like risk assessment isn' something the NRC wants to hear. Bill would forward to others please. Greg Gerzen Exelon Nuclear Phone 630-657 630-657-3845 ~3845 Pager 630-307-5124 630-307-5124 email - Greg.Gerzen @exeloncorp.com email-Greg.Gerzen@exeloncorp.com

                          ---- Original Message---
                    > ----Original                    Message---

From: Wagoner, Vaughn

                    > Frorn:Wagoner,                                                [SMTP.vaughn.wagoner@ pgnmail.com]

Vaughn [SMTP:vaughn.wagoner@pgnmail.com] Sent Tuesday.

                     > Sent             Tuesday, August         August 07.2001   07, 2001 6:22 PM                 PM
                     > To: Greg Gerzen (E-mail)

Subject:

FW: NRC Telcon. Telcon. Alloy 600 Bulletin

                    >* >> ----          Original Message---
                                -~--Original                 Message---
                    >>*> From:   From:                       lonescu, Cristina lonescu.            Cristina
                    >* > Sent:  Sent:                       Tuesday, Tuesday. August      August 07,2001    07, 2001 4:06         4:06 PM
                     * > To: Wagoner.
                     >                  Wagoner, Vaughn          Vaughn

Subject:

                     >                                      NRC Telcon. Alloy             Alloy.600             Bulletin 600 Bulletin
                    >>> > Vaughn.Vaughn,
                    >>> > Please see attached               attached for comment. Thanks,
                    >>                  Cristina Cristina
                    > >> <<NRC    <<NRC telcon August 7.doc>>                         7.doc>> <<NRC        <<<NRC talcon      telcon August 7.doc>>

7.doc>> This e-mail This e-mall and and any any of its Its attachments attachments may may contain contain Exelon Corporation proprietary information. information, which is privileged. privileged, confi,dential, confidential, or subject to copyright to copyright belonging belonging to to thethe Exelon Corporation Corporation family family of of Companies'. Companies. This e-mail This e-mail isis Intended Intended solely solely for the use use of ofthe the individual or entity individual or entity to which ititis addressed. addressed. If If you are not the intended recipient of this this e-mail, you e-mail, you are are hereby hereby notified notified that that any dissemination, distribution, any dissemination, distribution, copying, or copying. or action action taken taken in relation to in relation to the contents of the contents of and and attachments attachments to this to this e-mail e-mail is is strictly prohibited and strictly prohibited and may may be be unlawful. unlawful. IfIfyou you have have received received this this e-mail in in error, please notify the sender immediately immediately and 44 S140-04244 SI4D-042 NRC007-1597 NRC007-1597

permanently delete permanently delete the the original original and and any any copy copy ofof this this e-mail e-mail and and any any printout. Thank printout. Thank You You..

          • ~..********************.**.**.... ***.*..* ....*****....*****..*..***

5140-042455 S14D-0424 NRC007-1598 NRC007-1598

August 7, 2001 200 1 NRC/NEI telcon. <Bulletin NRCINEI (Bulletin 2001-01) 2oo1-Oll

Participants:

NRC: Jake Zimmerman, Zimmerman, John Zwolinski, Brian Shearon, A. Hiser, Jack Strosnider, Rich Berret, etc. NEI: Alex Marion, Marion, Kurt Cozens CP&L: Joe Donahue, Donahue, Vaughn Wagoner, Cristina Ionescu Ionescu Purpose of call was for NRC staff to set some expectations expectations for the level of information information that they expected to see in the bulletin responses, especially if risk-infonned risk-informed arguments or probabilistic probabilistic fracture mechanics mechanics was used. Risk Informed If risk informed arguments are used in support support of inspection "standard" for inspection deferrals, the "standard" adequacy will be RG 1.174, including calculations of delta CDF and delta LERF. Comparisons were made to the ANO and Farley submittals for S/G inspection deferrals, deferrals, where one was accepted and one was not. It was emphasizedemphasized that the RG analysis does not allow non-compliance Dot non-compliance withwith the regulations. If the utility determines that is in non-compliance from the regulation, regulation, they should submit an exemption request. Defense in depth must be preserved. The example example sited was if one assumes the LOCA occurs, then you must address factors like insulation/sump insulation/sump interaction, collateral collateral damage, etc. PFM Bottom line is that NRC does not believe that sufficient sufficient data exists to develop meaningful distributions for formany many of the key variables in a PFM analyses - crack growth rates; flaw number, size and location; stress levels, levels, etc. The statement statement was made that it would appear appear to be impossible to develop develop the data in 30 days. This apparently apparently was a topic ofof much interest in the ACRS briefing. Other Other Some licensees have indicated that they may need more time to respond to the "above "above the head" configuration question. NRC indicated that they were not contemplating head" configuration generic contemplating generic extensions, extensions, and would evaluate each plant specific specific response. Because Because 30 days falls on Labor Day, the NRC indicated indicated that the responses must be dated NLT 9/4. The NRC is gearing up to perfonn perform quick reviews of the responses responses and take appropriate appropriate action as required, required, based on the contents of the response. They don't intend to spend weeks with RAIs, etc. The NRC acknowledges acknowledges that the responses are "very "very plant specific" specific" and the licensees licensees should call the NRC PM for plant specific strategy discussions. 8140-04247 S14D-04247 NRC007-1600 NRC007-1600

VaughnWagoner Vaughn industrywas thatindustry indicatedthat Wagonerindicated evaluatinga anumber wasevaluating areas,including numberofofareas, including inspection scope, and definition of "qualified" VT, including figuringout PPM,inspection PFM, scope, and definition of "qualified" VT, including figuring outwhat what means. Staff indicated that they also have effortsunderway leakagemeans.

 "demonstration"ofofleakage "demonstration"                            Staff indicated  that  they  also have efforts     underway PPMand ononPFM    andaccident                andwould analysis,and accidentanalysis,                   verymuch wouldvery            liketotowork muchlike              withususon workwith        onapproaches, approaches, avoidsurprises totoavoid                 theend surprisesatatthe                month.The themonth.

endofofthe meetingon Themeeting 8/15 may be a timetotododothis, on8/1S may be a time this, but both industry and NRC needs to determine if that's the right time and forum but both industry and NRC needs to determine if that's the right time and forum for any for any suchdiscussions. such MRPneeds discussions. MRP communicateour needstotocommunicate desirestotoNRC. ourdesires NRC. S14D-04248 5140-04248 NRC007-1601 NRC007 -1601

U.S.NRC U.S. In NRC DAVIDGEISEN InremDAVID

                                                                                                /  +

GEISEN '7 fI.: r [1' Exhibit#J P--Exhibit

                                                                                                                                 /}5   5
                                                                                                                          # .:"....;;:J_ __

Docket#1IA-05-052 Docket # 1A-OS-OS2* . . ~... Markedfor DateMarked Date to:.$- forID .. 2008 (Tr. p.Q. l 8 (Tr. ) )) From: PrasoonK. From: Prasoon To: Andrew To: K.GoyallTE/FirstEnergy GoyallTElRrstEnergy Siemaszko/RrstEnergy@FirstEnergy,John AndrewJ.J. Siemaszko/FirstEnergy@FirstEnergy, John B. B. EV:~. OfferedininEv: DateOffered Date _., err.p.p.X Z&L) ) 2008(Tr. 2008 Cunnings/FE/FirstEnergy@ FirstEnergy CunningsrrElFirstEnergy@FirstEnergy Through w~.~panel:_fJ~If-l/A-~ ThroughWitnesslPanel:- )'ý/ _ _ _ __ cc: cc: Idm~ ~__ ((~T1 Aa~Ion: RE E ,D W REJECTED f TH 0R.4f WITHDRAWN bcc: bcc: bttl:  !.3jli:.. 2008'2W (fr. 8 r Pp. 2 t..e )) .

Subject:

NRCBulletin

Subject:

NRC Bulletin Date: 8/9/2001 14:18:111010 Date: 8/9/2001 14:18:111010 Please seemy Pleasesee comments in mycomments bold letters. in bold letters. DOCKETED DOCKETED USNRC USNRC September 9, 2009 September.9, 2009 (11:00am) (11 :OOam) OFFICE OF SECRETARY OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS AND ADJUDICATIONS STAFF ADJUDICATIONS STAFF S14P-01208 514P-01208

                                                                         ~a U- GZ
                                                                                  . .,     Exhibit 91 Exhibit Pagelof4 91 NRC024-1207 c...-- Page      1 of 4       NRC024-1207

..... ****v ** Job Name: Job Name: .-, . MORGAN - 82127CD01 MO'RGAN 82127_CD01_ANDREWSIEMASKO.

                             -      ."      - ANDREW- SIEMASKO.- CRDM_N CRDM N  ~ .
. SF SF                  ' .... '...:'   .

Unique ID: ". Internal Unique-ID: Internal,

0939 0939 File Path:
    \\Dctsfs05\BIowback\Morgan\82127\,cdO1
    \\DctsfsOS\Blowback\Morgan\82121\cd01
    \Andrew~Siemasko\crdm\AnDocuments
    \AndrewSiemasko\crdm\AllDocuments,
    \0000000i10000000600
    \0000000;\0000000600                            ,
    \Response
    \Response to NRC BuUetin2001        Bulletin 2001 (inspectio (il1spectio ns).doc SI4P-01209 S14P-01209 NRC024-1208 NRC024-1208

Response to NRC Bulletin 2001-01

Response

(Circumferential Cracking (Circumferential Cracking of Reactor Pressure Vessel Head Reactor Pressure Head Penetration Penetration Nozzles). Nozzles). scope to discuss the issues response is limited in scope The response associate with the type, issues associate qualification requirements, scope, qualification acceptance criteria for the Reactor requirements, and acceptance Reactor Pressure Vessel Head Pressure Vessel inspections within the last Head inspections last 4 years. years .. A Service Service Structure (SS) envelops Structure (SS) Davis-Besse Reactor envelops the Davis-Besse Vessel (RV) head. Reactor Vessel head. There are 18 openings (weep holes) 18 openings bottom of holes) at the bottom of the SS through which SS through which inspections inspections are performed. are performed. There are 69 Control Rod Drive Mechanisms Mechanisms (CRDM) nozzles penetrate RV head. The thermal nozzles that penetrate insulation is located well thermal insulation above the head and above and does not interfere with the visual inspection. The visual interfere with performed by the use of aasmaU inspection is performed mounted on a wire pole. small camera mounted This camera inserted through the weep holes. There camera is inserted There were two inspections inspections performed during the last 4 years. Thefirstlns~Ction years.* The first inslction was performed during performed during the 1111"th RFO (1998) and the second second dllring 12 .. RFO (2000)~ during 12.* (2000). The scope of the inspection was to inspect the entire head visual inspection head (bare metal) metal) area accessible accessible through the weep holes to identify through acid leaks identify any boric acid / deposits. The general leaks* 1 guidance of procedure guidance procedure DB-PF-03010 DB-PF-03010(RCS (RCS Leakage Leakage and Hydrostatic Test)( this and Hydrostatic this procedure need to use boric acid contol procedure is not the right procedure procedure IdoI do not know the # But old PCAQR PCAQR will give the procedure procedure #) was used used for these these Davis-Besse also inspected 100% inspections. Davis-Besse 100% of CRDM flanges for leaks under program. The results of two recent inspections are described 88-05 program. described below. performed during inspection results performed 1998 inspection refueling outage. The boric during 11 RFO refueling boric uneven layer. There were some lumps of scattered over the head in an uneven acid was scattered boric acid. The color of the lumps varied from brown to white. Outside diameter diameter of the motor motor tubes also showed white streaks indicative of leaking leaking CRDM flanges flanges (Need to add what did we do with flange leaks). The boron deposits were were attributed attributed to the leaking CRDM flanges. The head head was cleaned by the use of manual scrubber and vacuum. The head cleaning was limited by the location location and opening size of the weep holes. The head was cleaned cleaned as best as itit could could be considering the dose and the method. performed during 2000 inspection results performed 12RFO refueling outage. during 12RFO inspection was conducted on 4/5/2000. Framatome Reactor Vessel Head inspection Reactor Framatome NPS performed 100% CRDM flanges. Five leaking Control Rod 100% video inspection of CRDMflanges. Drive flanges were identified at locations: F10, 010, Cl 1, F8, and G9. Main D10, C11, Main source of leakage was associated with 010 D10 drive. Positive evidence evidence existed that F8, F10 drives F8, Cl I have limited gasket leakage. AU F1 0 and C11 All 5 CRDM gaskets were replaced and 010 D10 flange machined. All work was performed by Framatome Framatome S$4P-012 1 0 S14P-01210 NRC02~~-1209 NRC024-1209

NPS NPS (delete this sentence). No leaks were identified during subsequent during the subsequent RCS heatup. Visual Visual inspection inspection of the flanges was performed performed via lexan covers covers installed installed on the Service Service Structure. leaking CRDM flanges boric acid deposited Resulting from the leaking deposited on the top of the the insulation was cleaned (vacuumed). After cleaning the area area above the the insulation was videotaped for future use. Initial inspection of the head/no:zzle head/nozzle area indicated indicated some accumulation accumulation of boric boric acid. Deposited on the head boric acid was locatedlocated below the leaking flanges flanges with a clear evidence evidence of down down flow. No evidence of nozzle leakage leakage was detected.(how detected.{how do you know when there was so much boron boron on the top of head?) 95% (Are you comfortable comfortable with 95%) of the nozzles nozzles were inspected. The head cleaning cleaning was limited by the opening size of the weep holes. The head was cleaned cleaned with the demineralized demineralized water as best as it could be considering the considering the dose and the method. method. Subsequent Subsequent video inspection inspection of the clean head and was performed nozzles was performed for future use. SIUP-0 S14P"()1211 12 1 1 NRC024-1210 NRC024-1210

D 9~S C~- (f) ~~ ~~~ID ,5 t,,- ,3 ~ U.S. NRC (1)179 f) In re DAVID GEISEN GEISEN....LE~..xhbtw {:f Exhibet 0~L V\ TJ I Docket # 1A-05-052 Docket # 1A-05-052 1'7/;' Date Marked for ID Date Marked ID~ 2008 (Tr. p.. p. 815 ) From: From: Prasoon Prasoon K. GoyalTEfFirstEnergy K. GoyalfTElRrstEnergy Si lh u h ..- Date Offered Date Offared in Ev: Wttn sle -"st JJJ-. nal' N ! fr p.¥ 2008 (Tr. pi.ý -ý(P ) To: David C. GeisenffEIRrstEnergy@RrstEnergy.TheoS.Swim Geisen/TElFirstEnergy@ FirstEnergy, Theo S. Swim mug  !=!.5-~. *-'""ltif>4.;. . : . - - - - - - cc: Dale R. Wuokko/TlEFirstEnergy@FirstEnergy WuokkoffEiRrstEnergy@ RrstEnergy Action:~pJ Action: .1j) REJECTED wlTHDF~WN REJECTED wrIHDRA*WN

Subject:

NRC Bulletin:

Subject:

Bulletin 2001 2001-01 CircumferentialCracking of RV

                                             -01 CircumferentialCracking                        Head I Date:

RV Head Date: L.~7,008 2008 (Tr.(Tr. p.& 2 G ) Date: Date: .8/11/2001 12:7:251010 8111/200112:7:251010 AA meeting meeting was was held held today today at at 8.30 8.30 am am in in D. Lockwood's office. Following D. Lockwood's Following were were the attendees: attendees: D D Lockwood Lockwood ' DOCKETED DOCKETED , F Kennedy Kennedy USNRC USNRC D Wuokko DWuokko LL Worley Worley September 9, September 9, 2009 2009 (11:00am) (11 :OOam) SS Moffitt Moffitt D Esherman OFFICE OFFICE OFOF SECRETARY SECRETARY DEsherman RULEMAKINGS AND JJMessina Messina RULEMAKINGS AND ADJUDICATIONS ADJUDICATIONS STAFF STAFF PPGoyal Goyal The The subject subject bulletin bulletin waswas disussed disussed for for identifying identifying the the actions actions requiredfor required'for completing completing our our response response by the end of this month by the end of this month 9see 9see attachment). attachment}. It was was agreed agreed that that the the response response willwill include include aa committment committment to perform aa 100% to perform 100% qualified qualified visual visual examination examination of of all all the the nozzles nozzles during during 1,3thRFO. 13thRFO. The MOD 5 head inspection recommendations (JCO The MOD 5 head inspection recommendations (JCO for not inspecting the head by for not inspecting the head by 12/31/01) 12131101) have have beenbeen approved approved by by the the SRB. SRB. Directors Directors would would like like it also also reviewed reviewed by by Jim Jim Martin, Martin. Tim TIm Martin Martin namd MPR amd Beaver MPR (Now(Now Dominion Dominion Engineering). Engineering). F. F. Kennedy Kennedy will will be be sending sending this to this to both both thethe Martins Martins and and Beaver ValleyValley forfor comments. comments. My My action action isisto to send send this this MOD MOO 55 recommendations recommendations to to S.Hunt S.Hunt of of Dominion Dominion and and get get itit reviewed reviewed by by him by 8/16/01. If they are unable to do then contact L. him by 8/16/01. If they are unable to do then contactLWorley. Directors would alsoWorley. Directors would also like like to to write write aa new new or or revise revise thethe existing existing JCOJCOto to cover cover thethe cracks(different crackS(different scenarios) scenarios) which which maymay be befound found during during TMI TMI and and CR3eR3 inspections. inspections. II indicated indicated that that II do do not not enough enough information information or orthe the expertise expertise to to write write this this type type of ofJCO. JCD. TheThe recommendation recommendation is is to to issue issue aa P.O P.O to to an an outside outside consultant consultant to to do do this this work. work. The The work workshould should be be started startedearly early enough enough such such that that we we do do not nothave have toto shutdown shutdown ififTMI/CR TMlICR finds finds cracks. cracks. II will contact Steve Hunt on Monday and ask him will contact Steve Hunt on Monday and ask him if he could meet our if he could meet our schedule schedule or or provide provide his his completion completion date. date. We We will will need need funding funding forfor these these projects. projects. II indicated indicatedtha tha wewe plan ptah for for 100% 100% volumetric volumetric examination examination even even ifif we we do'not do not commit commit to to NRC. NRC. Directors were in agreement

,. Directors were in a9Jeementthat              thatwe weshould should plan plan for for ititin in the the 13thRFO.

13thRFO. ItItwas was pointed pointed out outthat that wewe can can not notclean clean ourourhead head thru the mouse thruthe mouseholesholes andandAndrew Andrew Seimaszko Seimaszko isis requesting requesting 33 large large holes holes -be becut cutinin the the Service ServiceStructure Structurefor tor viewing viewing and and cleaning. cleaning; DBDB ranking ranking was was also also discussed discussed.. We Weareare ranked ranked #:# 77 higher higherthanthan TMITMI (#11) (#11) because because of of higher higherhead head temperature temperature (see (seeattachment).The attachIi19nt).The plants plants ranked ranked #5#5 andand## 66 hadhad agreed agreedto todo do 100% 100% volumetric volumetric examination. examination. t: S14H-01819 S14H-01819

          -r                L                9,-Z                                                        £f62...:-Page Exhibit Exhibit 88 056-z-Page 1 of 11 Page         1 88 of       Page       NRCOIO-1819 NRC010-1819

W From: Prasoon K. GoyallTEIFirstEnergy From: GoyaViTE/FirstEnergy To: David C. GeisenffElRrstEnergy@RrstEnergy, David Geisen/TE/FirstEnergy@ FirstEnergy, Thea Theo S. SwimfTElRrstEnergy@FirstEnergy SwimfrE/FirstEnergy@ FirstEnergy cc: cc: Dale R. WuokkoffEiRrstEnergy@RrstEnergy Dale WuokkoTFE/FirstEnergy @FirstEnergy

Subject:

NRC Bulletin 2001-01 2001-01 CircumferentialCracking CircumferentialCracking of RV Head Head Penetration Penetration Nozzles Nozzles Date: 8/111/2001 12:7:251010 8111/2001 12:7:251010 A meeting was held today at 8.30 am in in D. D. Lockwood's Lockwood's office. Following Following were the attendees: DD LOckwood Lockwood F Kennedy 0 Wuokko DWuokko Worley LL Worley S Moffitt o D Esherman Esherrnan JJMes!)ina Messina P Goyal PGoyal The subject bulletin was disussed disussed for identifying the actions required for completing our response response by the end of this month 9see attachment). attachment). ItIt was agreed that the response response will include a committment to perform perform a 100%100% qualified qualified visual examination of all Ihenozzles ViSUlll examination the nozzles during 13thRFO. The MOD 5 head inspection recommendations (JCO (JCO for not inspecting the head head by 12131/01) 12/31/01) have been approved have approved by the SRB. Directors would like itit also reviewed by Jim Martin, Martin, Tim Martin Martin amd MPR (Now Dominion Engineering).Engineering). F. Kennedy will be sending this to both the Martins and Beaver Beaver Valley for comments. action is My action to send is to send this this:MOD MOD 5 5 recommendations recommendations to S.Hunt S.Hunt of Dominion and get itit reviewed reviewed byby him by 8/16101. 8/16/01. IfItthey are unable to do do then contact L. Worley. Directors would also like to write a contactLWorley. new or revise the existing JCO to cover the cracks(different cracks(different scenarios) which may be found during during TMI and CR3 inspections. I Indicatedindicated that II do not enough information information or the the expertise expertise to write this this type type of of JCO. JCO. The recommendation recommendation is to issue a P.O P.O to an outside outside consultant to do this work. The The work should be started early early enough such that we do not have to shutdown if if TMIICR TMI/CR finds cracks. I will contact contact Steve Hunt on Monday and ask him ifif he could meet our schedule schedule or provide his provide his completion date. completion date. We willwill need funding for these projects. need funding projects. I indicated indicated tha we plan for 100% 100% volumetric volumetric examination examination even if if we do not not commit to NRC. Directors were Directors were in agreement agreement that we we should should plan for it in the 13thRFO. 13thRFO. ItIt was pointed pointed .out out that we we can can notnot clean our head head thru the mouse holes and Andrew thruthe Andrew Seimaszko Seimaszko is requesting 3 large holes large holes be cut in the Serviceý Structure for viewing and cleaning. Service-Structure DB DB ranking ranking was also discussed. was also discussed. We We are ranked ranked # 7 higher higher than TMI (#11) (#11) because because of higher higher head temperature temperature (see attachment).The plants (see attachment).The plants ranked ranked #5#5 and #6

                                                                        # 6 had agreed agreed to do 100%100% volumetric volumetric examination.

examination. S14H-0181 S14H-01819 9 Exhibit 88 Exhibit 88 Page of 1 Page Page 1 Page NRC010-1 NRC010-1819 819

O~s {<AS C-/ 9ý C-I?ff Prasoon K. Goyal J. Siemaszko/FirstEnergy@FirstEnergy, To: Andrew J. Siemaszko/FirstEnergy@FirstEnergy, Mark Mark A. A. McLaugtllin/TE/FirstEnergy@FirstEnergy McLaughlin/TE/FirstEnergy@FirstEnergy 08/13/01 08:45 AM 08/13/0108:45 AM cc: John B. CunningslTEIFirstEnergy@FirstEnergy, Cunnings/TE/FirstEnergy@FirstEnergy,. Dale R. Wuokko/TE/FirstEnergy@FirstEnergy Wuokko/TEIFirstEnergy@FirstEnergy JCO

Subject:

MOD 5 JCO Attached is the lCO JCO for head inspection. inspection. This had been approved approved by D.Geisen and SRB. SRB. This was was written written on 6/27/01 6/27/01 well before the bulletin. bulletin. Andrew Andrew please please read this and your inspection results (written for the bulletin) bulletin) for the last outage'-for differences. My outage'for any differences. My concern is that all these outside outsi.de people may focus fotus on our lack of complete or limited inspection inspection of CROMs. CRDMs. This JCO will also be reviewed byby Tim Tim and Jim Martin Martin and some consultant.

     ~

U.S. NRC U.s. NRC In In re DAVID 18 GEISEN2 DAVID GEISEN

                                                                                                             'f S' t.'fA. iL.Edf  Exhbt.~

3 7 Mode 5.doc Mode S.doc IA-05-052 Docket # 1A-05-052 Oockat DateBIG M Date Markedior 4 2 2008 ailed for IIO:lldL. (Trm p...:g~ 0026M (Tr. Date Off8l'9d

                                                                         *Date    Offered in in Ev: E:./J-.

Ev: ( 2008 (fr.r. p.2?~)

                                                                                                              , 2008(

Through~WItne$slPa(leI: ) / A Trugh WinesPawel:'- Action: ActIon: fJ/ A REJECTED WIfHDP*4WN REJECTED WI'THDRAWN Dat: *.=~(re* g 2A.R* ) DIde: rJ . ' _t.___0

                                                                                         .2008 (Tr. p.                         ,)   .

DOCKETED USNRC USNRC September 9, 2009 (11 September :OOam) (11:00am) OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS AND ADJUDICATIONS STAFF ADJUDICATIONS STAFF S14H-00475 7~kQ6~L~741~: §*GL4Z~? ~ 6L Exhibit 134134 Page 1 of 1 Pages NRC010-0475 NRC01(I*0475

R h--S; C- / /27 u.s. U.S. NRC tn re DAVID GEISEN InreDAVID GEISEN s++sztt#.~..

                                                                                                                          ~

f'Pr-t-t exhibit #.;LL-

                                                                                                                                                    ~2  a Docket # 1I1A-0505 Docket #       A-05-052*                                        .

ID-L~ 2008 (Tr. Marked ior ID:.l2:J.L. Date Marked10r (T. p.] AL Z5' ) From: Frank W. From: W. KennedyITElFirstEnergy Kennedy/TE/FirstEnergy Date Offered in m 4=(Trr.2008 (Tr. p.l} ~ ) Er j.O6 i EV:.IijL. p.2(

 .To:

To: Rodney M. M. CookiFirstEnergy@FirstEnergy Cook/FirstEnergy@ FirstEnergy hMOu0 W~ftSWTWW ......}J~/;.:.p.._* lhroughWltnesslPanel:, 4- _ _. _ -

                                                                                                     ~

cc: Action: Ac~o- REJECTED WITHIIAM REJECTED WIlHDRAWN

Subject:

CRD Nozzle Cracking Meeting SubjectCRD Meeting t..: aq.r: t.~~ZTr 2 2008 err. p. [.~ Le ) Date: 8/15/2001 14:6:51010 8/15i2001 14:6:51010

  ---,- Forwarded -Forwarded by Frank by  Frank W. KennedyfTElFirstEnergy KennedyfTEJFirstEnergy on 08/1512001 08/15i2001 02:03 PM ----- -----

David J. Stephenson alfl1520~o nei To: Charles E. E. 08/15/2001 5 PM

                               .01 :50  PlAM Ackermrani'E/FirstEnergy@ Fi AckermaniTElFirstEnergy@         FirstEnergy rstEnergy cc:                                                         HenryW Henry    W..

Stevens/'TE/FirstEnergy@ FirstEnergy, Edward V.

                                                             .StevensfTElFirstEnergy@FirstEnergy,Edward            V.

Chimahusky/TE/FirstEnergy@FirstEnergy, Frank ChimahuskyfTElFirstEnergy@FirstEnergy, Frank W. W. KennedyiTE/FirstEnergy @FirstEnergy KennedylTElFirstEnergy@FirstEnergy

Subject:

CRD Nozzle Cracktng~1E~: Cracking -Me-Frank Kennedy Kennedy and I attended (by phone) the .8/15/01 8/15/01 NRC/Industry NRC/Industry meeting concerning the NRC request for additior2. additiorta regarding CRD nozzle cracking (NRC Bulletin 2001-01). Guy Campbell, .and information regardingCRDnozzle and Steve Moffit were also in attendance (phone) for a period. Other DB personnel attendance (phone) .Lockwood, Andrew Siemaszko, and Prasoon personnel including David Lockwood, Prasaon Go,GG' were scheduled to be physically physically at the meeting. The purpose of the meeting was to provide provide NRC Expectations for responding to Bulletin 2001-01. Expectations .for 2001-01. The NRC wants to know the currentocondition currentconditicin of the plants (results of inspections to date), date), individual plant configurations, planned configurations, planned inspections, and how the .pl~ntscontinue inspections, plants continue to meetthe meet the applicable applicable regulations. regulations. Plants have been catergorized within 3 been catergorized , groups g'roups (cracks .already already detected)/(within detected)/(within 5 EFPYs of Oconee Oconee 3 (ONS3)/>5 (ONS3)/>5 EFPYs EFPYs of ONS3. The response requiremen response reqUiremen' are broken are broken up into 55 parts. The first part requests requests informantion regarding regarding -details details of the reactor reactor head, CRD nozzles, head,CRDnoz.zles, missile shields, and the results of previous inspections. inspections. The next three questions questions is based on which of the three three categories categories that your plant falls, the more likely that a crack exists plant" failS, requires a more exists requires, concerning plar~ more expedited response concerning plarn inspections inspections and corrective actions. The fifth question question requires notification inspection r~sults, notification of inspection results. Most of the discussio['~ discussiors regarded regarded how to answer these questions, evaluation triteriaforindications/flaws criteria for indications/flaws detected detected as part of the inspection, inspection, arnc arc

 ,the possibility the    possibility of of regulatory regulatory enforcement enforcement for deficiencies.

deficiencies. One One of thethe major unknowns unknowns is crack propagation propagation rate. Another Another major unknown is detectability major unknown -of cracks. detectability.of Since the cracks. Since nozzles nozzles have .a a very tight fit, very small small leak rates have been experienced. experienced. Davis-Besse Davis-Besse falls into the the within 5 EFPys. EFPys. However, Mr. Campbell Campbell noted noted [outside [outside of the meeting] meeting] thatthat DB personnel r÷, personnel ~'3, to confirm confirm .that this catagorization is correct catagorization is correct since there may be individual be individual plant differences that have not plant differences not been conscder-cons;de'<

. such as the continuous continuous headhead vent vent line, line, raised RCS loop, etc.

As' As stated stated during the meeting, the responseresponse due due date is 9/4/01. 9/4/01. DOCKETED DOCKETED USNRC USNRC' September 9, 2009 (11:00am)

                                      $eptember 9, 2009 (11 :OOam)

OFFICE OFFICE OF OF SECRETARY SECRETARY 52 RULEMAKINGS RULEMAKINGS AND AND S140 ..07252 S14D-072 ADJUDICATIONS ADJUDICATIONS STAFF STAFF t~i)LA-r6 - 05' CY1...../ NRC008-1904 NRC008-1904 NRCOO8-1 904

KA5 C-_- kAs c- !go Igo ~~:~,oGE'SEN5'r~Cf U.S. NRC In re DAVID GEISEN )1t-L 7/

                                                                                                                                             ..33-EExhibItb#_....2L..

Date 1A-05-052 Docket ## 1A,,()S-QS2 Docket Marked Date Marked for 10' (1f~ ID:'/,

                                                                                                                              ,2008 2008  (Tr. p.-,~

p. 82 > . From: Prasoon K. GoyalfTE/FirstEnergy From: Prasaon GoyalfTE/FirstEnergy Date Offered Date Offered in Ev: I:I:IP JilL, I tl / 2008 (Tr'.

                                                                                                                                /Y p.~~

(Tr. .,..2008 To: To: sfyfrtch@framatech.com, styftch@ wgray@framatech.co framatech.com, wgray@framatech.co Wrtne~ane: tJ!/ Through WitnessI~anel:_ Through r L - ca: cc: Dale OaleR.R. Wuokko/TEJFirstEnergy@FirstEnergy, WuokkolTElFirstEnergy@FirstEnergy, David David C. ~D Action: A6ý0ýD REJECTED Action: REJECTED WITHDRAWN WITHDRAWN

  ~eisenrrElFJrstEnergy@FirStEner.gy.,
-.G eisen/TE/FirstEnergy@FirstEnergy, Theo     TheoS. S. Swim/TE/FirstEnergy SWimrrElFirstEnergy' Date; I'17)    ILL,Y-..             (T 2oo8 (Tr,       O'Zu)).

KennedyrrEJRrstEnergy@FirstEnergy., Kennedy/TE/FirstEnergy@ FirstEnergy Date:~, 2008 r. p.... a.____ Subject NRC Subject NRC BUlletin BUlletin Date: 8117/2001 8/1712001 11:5:291010 11 :5:291010 performing a 100% Steve ,we will be performing Steve examination in the qualified visual examination 100% qualified neXt outage the next outage April 2002. Framatome Framatome is requested requested toto provide provide a response response to: , 3.b.1 3.b.1 and and 3 b.2 b2 We had a meeting meeting with the directors yesterday. Our future inspection dir9Ctorsyesterday. inspection in 13th RFO in 13thRFO will will be be 100% 100% qualified qualified visual exam exam and wherewhere wewe can not perform perform 100% 100% visual exam of of a nozzle nozzle (s) a volumetric (6) volumetric examination probably ECT) examination (most probably ECn will bebe performed. The results inspection will results of inspection be handled handled via our condition report report program program as to the extent of condition and repair or leave as-is as-is etc. I assume you will addess the leakageleakage thru the annulus annulus to show that we have have adequate adequate or similar gaps as as Oconee Oconee plants allowing the leakage leakage to be detected. detected. Also crack growth (current knowledge) in an eXisting existing circumferential crack(s) would not circumferential crack(s} not result-in aa nozzle(s) nozzle(s} failure failure untill next next RFO. Is it possible possible to go back back to 1998 1998 that is when when a good good head exam was done with no nozzle nozzle leakage.(meaning leakage.(meaning not not taking any credit for 2000 inspection). inspection). When can we We expect expect your response? response? We are asking Framatome to look/explore asking Framatome look/explore the following: Is it possible for DB to move out of <5

  )sitpossible                              <:5 EFPY to > 5EFPY 5EFPY bin in the ranrankings?     Considering the kings? Considering         the following:

following: Both Oconee andANOand ANO plants had identified occurance of PWSCC identified occurance PWSCCin .in their steam generators generators 3 to to 4 years earlier than the CRDM nozzle cracks/leaks. May be it is because nozzlecrackslleaks. because of the chemistry practices. practices. DB had not identified any PWSCC in their SGs. This may give us few more years till the the cracks are detected. , cracks . DB is unique in in the B&W fleet (raised loop} loop) 'and and we have a head ,vent vent line which may move the the coolant around the head providing a unform temperature coolant temperature across across the top of head head compared to other plants plants where where stagnation of hot water water could create higher temperatures and may trap higher temperatures air/hydrogen. Most.of airlhydrogen. Most of the Oconee Oconee crackes were were on the top section section of the head. Also we could use the old equation which uses specific equation whiqh specific nozzlestrsses, nozzle strsses, tensile& tensile& yield strengths strengths besides the head temperature. Please provide your Please your response date. DOCKETED DOCKETED

                                                                    *USNRC USNRC September 9, 2009 (11:00am)

September 9, 2009 (11 :OOam) OFFICE OF SECRETARY OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS STAFF ADJUDICATIONS AND ADJUDICATIONS STAFF S14H-01995 S14H-01995 Exhibit 136 Page 11 of of 1 Pages O~1994 NRCOI0-1994 NRC01 -Ft--k kATC' -!,SC (t4o - DS<S2- 6 2_

From: Prasoon From: Prasoon K. GoyalTE/FirstEnergy Goyal/TElFirstEnergy To: sfyfltch@framatech.com, wgray@framatech.co sfyfitch@framatech.com, wgray@framatech.co cc: Dale Dale R. Wuokko/TE/FirstEnergy@ FirstEnergy, David WuokkoffEIFirstEnergy@FirstEnergy, Davi<i C. GeisenffElFirstEnergy@FirstEnergy, Geisen/TE/FirstEnergy@ SwimffEiFirstEnergy@FirstEnergy, FirstEnergy, Theo S. Swim/TE/FirstEnergy@ Frank W. FirstEnergy, Frank Kenne<iyffElFirstEilergy@FirstEnergy KennedyfUE/FirstEnergy@ FirstEnergy Subject NRC BUlletin Subject BUlletin 8117/2001 11 Date: 8117/2001 :5:291010 11:5:291010 Steve ,we will be performing Steve performing aa 100% qualified visual 100% qualified examination in the visual examination the next neXt outage outage April April 2002. 2002. Framatome is requested Framatome requested to provide response to: provide a response 3.b.1 3.b.1 and and 3 b2b.2 We had had aa meeting meeting with with the the directors yesterday. Our

                                                   <iirectorsyesterday. Our future future inspection inspection in  13th RFO in 13th will     100% qualified will be 100%    qualified visual exam exam and and where where we can not perform 100% 100% Visual visual exam exam of a nozzle nozzle (s)

(s) aa volumetric examination (most probably ECT) will volumetric examination wi"~ perf()rmed. The results of inspection be performed. inspection will be handled via our condition report program as to the extent of condition and report program and repair repair or leave as-is as-is etc. II assume assume you will addess addess the leakage leakage thru the annulus annulus to show that we have adequate we have adequate or similar gaps gaps as Oconee plants allowing the leakage leakage to be detected. Also crack crack growth growth (current knowledge) in an existing circumferential circumferential crack(s) crack(s) would not result ininaa nozzle(s) nozzJe{s) failure untill next failureuntill RFO. RFO. Is it possible possible to go back to 1998 1998 that is when a good head exam was done with no nozzle nozzle leakage.(meaning not ta~ing leakage.(meaning taking any credit credit for 2000 inspection). When 2000 inspection). When can we expect can We expect your response? your response? We are asking Framatome Framatome to look/explore look/explore the following: Is it possible for DB itpossible DB to move move out of <5 EFPY to > 5EFPY 5EFPY bin inin the rankings? Considering the ran kings? ConSidering the following: following: Oconee and ANO plants had identified occuranceof Both Oconee occurance of PWSCC in in their steam generators generators 3 to 4 years earlier earlier than the CRDM nozzle nozzle cracks/leaks. May be it is because because of the Chemistry chemistry practices. practices. DB had not identified any PWSCC in their SGs. This may give us few more years till the identified anyPWSCC the cracks are detected. unique in the B&W fleet (raised loop) and DB is unique and we have a headhead vent line which which may move the the coolant around the head providing a unform temperature across across the top of head compared compared to other plants where where stagnation stagnation of hot water could create create higher higher temperatures temperatures and may trap air/hydrogen. airlhydrogen. Most of the Oconee crackescrackes were on the top section of the head. Also we could use the old equation which tensile& yield strengths whiqh uses specific nozzle strsses, tensile& strengths besides besides the head temperature. temperature. Please provide your response date date... S14H-01995 S14H-01995 Exhibit Exhibit 136136 Page 11 of 11 Pages NRCOIO-1994 NRC01 {I-1994

DOCKETED DOCKETED s USNRC 5ti.. tl6

                        ~A-S L-/~l                              USNRC                       u.s. NRC U.S.

In In re NRC DAVID GEISEN re DAVID I i'f r * #2 exhibit *Lx() September September 9, 2009 (11:00am)

9. 2009 (11 :OOani) Docket#

Docket# 1A-05-052 1A-OS-OS2 INTRA*COMPANY MEMORANDUM INTRA-COMPANY £08268 ED S28... MEMORANDUM OFFICE OF OFFICE OF SECRETARY SECRETARY Marked for 1D431 Date Marked IDtk/.i.-. 2008 p.~Z5 . ) 2008 (Tr. p.-.1.2 RULEMAKINGS AND RULEMAKINGS ADJUDICATIONS STAFF ADJUDICATIONS AND STAFF Date Date Offered Offered in in Ev: Ev: Ji/.:L. 2-*h-, 2008 err. pP*.At~) 2008 (Tr. wrtness/panel:--'C'-+/....;~ T. S. T. S71J S. SwIcn, Supervisor, Supervisor. Mechanical/Structural Mechanical/Structural Unit Unit Through Winess/Pane: Through A~ 6 C _______ REJECTED WITHDR-AWN c!;al1~kgin Action: A09j Action: REJECTED WITHDHAWN FROM FROM P. K. K. Goya , Senior Engineer, ...., MechanicaUStructural Mechanical/Structural Unit Date: \-~ I<l ,2008 (Tr. p. is' 2=k 2008 (Tr ) SUBJECT susJEcT Trip Report Trip Report- NRC Bulletin

                          - NRC                2001-01 Meeting Bulletin 2001-01      Meeting                                     PHONE PHONE 7351" 7351 attended the NRC meeting with EPR!

I attended Bulletin 2001-01, EPRI on Bulletin 2001-0 I, "Circumferential Cracking of RPV "Circumferential Cracking RPY Head Head Nozzles" on Penetration Nozzles" Penetration on August 15,.2001. meeting was held in the NRC 15.2001. The meeting Rockville, Maryland. NRC Office, Rockville, Maryland. purpose of this meeting was for the NRC The purpose NRC to explain expectations for the bulletin response. ex.plain their expectations Following are the lessons learned for Davis Besse. Following 1)

1) qualified visual examination Develop a qualified (VT-2) procedure examination (VT-2) specifically for CRDM nozzle visual procedure specifically inspection.

inspection.

2) Qualify inspectors for this inspection Qualify inspectors inspection
3) credible technical basis for the course of action outlined in the bulletin response.

Provide credibletechrtical

4) Commit additional additional resources resources to manage this issue.

Jack Strosnider, Director of Engineering, Engineering. NRC presented an overview of the bulletin and its purpose. The presented anroverview The information to assess the potential bulletin is to gather information purpose of the bulletin determine ifif significance and to determine potential safety significance additional regulatory action is.~uired. is required. industry in the technical areas: challenges facing the induStry He discussed the following challenges

1) The initiation time and initiation ,time arid the growth*rate of cracks ate growth-rate of are not known or established.
2) conditions (temperature, boron co~entration) environmental conditions Annulus environmental concentration) are not known. Also, their impact on the crack growth is unknown.unknown ..
3) Above the weld crack cra~k may go part through the wall then become circumferential or it may start as become circumferential through wall. The mode of crack propagation is not known. He also discussed that visual examination needs to be done in accordance VT-2 procedure that includes defined accordance with a qualified VT-2procedure defined criteria. Visual examination acceptance criteria capable of reliable detection and source examination must be capable Similarly volumetric identification. SiInilarly volumetric examination qualification should demonstrate the capability examination qualification of detecting 00 OD crackhlg.

cracking. . Hiser, NRC, presented the technical issues involved with Allen Hiser. with the CRDM n<?zzle nozzle cracking. He stressed this issue since more cracking is anticipated in the to manage thisissue that additional resources will be required to-manage communication (NRC/industry) is the key in managing this issue. He emphasized that communication future. He emphasized discussed the following main points: . . I)

1) Code inspections (VT-2) are not adequate and NRC inspections (VT.2) NRC is working on resolving this issue.
2) occurrence of leakage at the same site may be subject to enforcement Second OCCUlTence enforcement.

3)

3) Corrective Corrective action should comply compJy with Criteria XVI of Appendix B.
4) Technical Specifications do not pemit TechnicalSpecifjcations permit pressure boundary leakage.

S14H-00600 514H-00600

                    -A-PZ_-A7-E--                                                                                                     NRC010-0600 NRC010-0600

INTRA-COMPANY MEMORANDUM INTRA-COMPANY EO S26l,.e eo 8268.. MEMORANDUM FtEnergy TO T.S. Supervisor Mechanical/Structural T. S.SS71J Supervisor, Mechanical/Structural Unit DATE DATE August 22, 2001 200 1 FROM FROM c!';al:'k~gineer, P. K. GoaY. 4 enior Engineer, MechanicaVStructural Mechanical/Structural Unit MAILsTop MAIL STOP 3210 3210 suBuECT SUBJECT Report - NRC Bulletin 2001-01 Trip Report- 200 1-0 1 Meeting PHONE 7351 I attended the NRC meeting with EPRI on Bulletin 2001-01, "Circumferential Cracking of RPV Head 200 1-01. "Circumferential Penetration Nozzles" Penetration Nozzles" on August IS, 15, ZOOt. 2001. The The meeting was held in the NRC Office, Office, Rockville, Maryland. The purpose of this meeting was for the NRC to explain their expectations for the bulletin bulletin response. Following are the lessons learned for Davis Besse. 1)

1) Develop Develop a qualified specifically for CRDM nozzle visual examination (VT-2) procedure specifically qualified visual examination inspection.
2) Qualify Qualify inspectors for this inspection 3)
3) Provide credible technical Provide credible technical basis for the course course of action outlined in the bulletin response.

thehulletin

4) Commit additional resources to manage this issue.

Jack Strosnider, Director of Engineering, NRC presented ofEngineering, overview of the bulletin and its purpose. The presented an overview purpose of the bulletin is to gather information to assess the potential togather significance and to determine if potential safety significance additional regulatory action is required required. He discussed the following challenges challenges facing the industry in the technical areas: 1)

1) the growth rate of cracks are not known or established.

The initiation time and the.

2) environmental conditions (temperature, boron concentration)

Annulus environmental concentration) are not known. Also. Also, their impact on the crack growth is unknown.

3) Above the weld crack may go part through the wall then become become circumferential circumferential or it may start as through through wall. The mode of crack propagation is not known. He also discussed that visual crack proi-agation examination accordance with a qualified VT-2 procedure examination needs to be done in accordance procedure that includes defined defined acceptance criteria. Visual examination examination must be capable capable reliable detection and source of reliable volumetric examination qualification Siniilarly volumetric identification. Similarly qualification should demonstrate the capability of detecting OD cracking.

Allen Hiser, NRC, NRC. presented technical issues involved with the CRDM nozzle cracking. presented the technical cracking. He stressed stressed that additional resources will be required to manage this issue since more cracking is anticipated in the future. He emphasized that communication communication (NRC/industry) (NRC/industry) is the key in managing managing this issue. He discussed discussed the following main points:

1) Code inspections (VT-2) are not adequate and NRC is not.adequate is working working on resolving this issue.

2)

2) Second occurrence of Second occurrence leakage leakage at the same site may be subject to enforcement.

enforcement

3) Corrective action should comply with Criteria Corrective Criteria XVI of Appendix B.
4) Specifications do not permit pressure Technical Specifications pressure boundary leakage.

S14H-00600 S14H-00600 NRC010-0600 NRC01 0-0600

August 22, 2001 2 of 2 Page 20f2 Carsuo discussed the use of Mark Cilrsuo regulation. If risk-informed regulation. ofrisk-infonned If utilized then it should comply with analysis should maintain defense-in-depth Also risk-informed analysis Regulatory Guide 1.174. Alsorisk":jnfonned defense-in-depth philosophy and sufficient safety margins. maintain sufficient concact me at extension information please contact If you need additional information extension 7351. PKG/gmw PKG/grnw cc: 0. G. Campbell G. 3080 w/a w/a J. B. Cunnings 1056 w/a B. R. Galetan 1056 w/a w/a D. C. Geisen 3105 w/a T. A. Lang T.A.Lang 3105 w/a 310~ w/a G. N. LeBlanc LeBlanc 3205 w/a D. H.Lockwood H. Lockwood 3065 w/a McLaughlin M. A. McLaughlin w/a 1048 w/a S. S. P. Moffitt Moffitt 1054 w/a w/a D. J. J. Mominee Mominee 3335 w/a w/a Mechanical/Structural Mechanical/Structural Unit 3210 w/a 32.lOw/a ( SI4H-00601 S14H-00601 NRC010-0601

P_ Ps Qt tS - From: From: Prasoon Prasoon K. K*GoyaIlTE/FirstEnergy

                                .GoyalfTElFirstEnergy To:

To: Rodney Rodney M. Cook/FirstEnergy@ M. FirstEnergy CooklFirstEnergy@FirstEnergy cc: cc: Andrew Andrew J. J. Siemaszko/FirstEnergy@FirstEnergy, SiemaszkolFirstEnergy@FirstEnergy, Dale Dale LL Miller/TE/FirstEnergy@ FirstEnergy, Dale MillerITElFirstEnergy@FirstEnergy, Dale R. R. Wuokko/TFE/FirstEnergy@ WuokkoITElFirstEnergy@FirstEnergy, FirstEnergy, DavidDavid H. H. Lockwood/TE/FirstEnergy@FirstEnergy, LockwoodITElFirstEnergy@FirstEnergy, Frank Frank W. W. Kennedy/TE/FirstEnergy@ KennedyITElFirstEnergy@FirstEnergy. FirstEnergy, MarkMark A.A. McLaughlin/TElFirstEnergy@ McLaughlinITElFirstEnergy@FirstEnergy FirstEnergy

Subject:

Subject:

Re:Re: Serial Serial 2731 8-27-of Version 2731 8-27-01 Version lb 1b Date: Date: 8/2712001 8/27/200111:41 11:41:311010

311010 II have have following following comments:

comments: 1)1) April April 1998 1998 inspection inspection .Last

                                     .Last sentence sentenceThe The head head was was videotaped videotaped after aftercleaning.

cleaning. We We need need to to make make sure sure that we have the tapes. It also applies to 2000 that we have the tapes. It also applies to 2000 inspection inspection also. also. . 2)

2) Subsequent Subsequent reviewreviewot of 1998 1998 andand 2000 2000 inspection inspection videotape videotape results.

results. The The discussion discUSSion herehere gives gives an an impression impress/onto to the the reader reader that that we we were were able abletoto look look atatall all the the CRDMs. CRDMs. It It isis very very difficult difficultto to look look atatthe the CRDMs CRDMs when when there there isis boric boric acid acid around around it. it. Do Do wewe want wantto*to-reword reword this?. this?

3) Item i.e requests-a description
3) Item 1.e requests a description of of the the cabling cabling fromfrom the the top top of of the the RV RV headheadto to the the missile missile shield.

shield. WeWe are are silent on this subject. silent on this subject. 4)

4) Please Please delete delete the the straight stra:ight line line shown shown on onthe the right right hand hand sidesideofof Figure Figure 33 and and page page 1919 ofat 19.

19. U.S. NRC ,i

                                                                                                        ~~ ~~~D in re DAVID GEISENGEISEN           51 ~ ff       Exhibit #.~

Docket # IA-05-052 Docket # 1A..()5.()52 5 i7j!.< 2& Date Date Marked Marked for ID~2008 or ID.. (Tr.p.. Z ) 2008(Tr.D-DateOffered Date Offeredin in Ev:

                                                                                                                                   -Ev:1 .Ji/.fi-.2008 (Tr. Pp. gZ- ~ )

2008 (Tr. DOCKETED DOCKETED USNRC USNRC Through Wi&*ss/Panel: Through wrtnesS/Panel:* Nj.fo " September 9, 2009 (11:00am) September 9, 2009 (11 :OOam) AciOOn~ 4,MREJECTED Action: ~. REJECTED WIMhDRAW#N WIJHDRAWN Date: J1111 Date. +2008 (Tr. p. 22- (e ) _

r. P&L.)

OFFICE OF SECRETARY OFFICE RULEMAKINGSOF SECRETARY AND RULEMAKINGS AND ADJUDICATIONS STAFF ADJUDICATIONS STAFF S14D-04404 5140-04404 Exhibit Exhibit 145 145 Page 1 of Page 1 of 11Pages Pages NRC007-1 755 NRCOOj' -1755 DS OL-

ý-A-S .- 1ý3 Prasoon K. Goyal To: Andrew J. Siemaszko/FirstEnergy@FirstEnergy. Siemaszko/FirstEnergy@FirstEnergy, Mark A. A. McLaughlin/TE/FirstEnergy@FirstEnergy Mclaughlin/TE/FirstEnergy@FirstEnergy 08/30101 07:17 AM 08/30/01 AM M. Cook/FirstEnerly@FirstEnergy, Dale l. cc: Rodney M.Cook/FirstEnergy@FirstEnergy, L. Miller/TE/FirstEnergy@FirstEnergy Miller lTE/FirstEnergy@FirstEnergy

Subject:

Head inspection

Subject:

inspection I have not seen any EWR to cut openings in the service structure in 13th

.1                                                                           13th RFO. IfIf we need these it funded and P.O issued should be funded                        Framatome immediately. We do not say anywhere issued to Framatome                                      anywhere in our our response to the                 inspection thru the mouse holes creates the bulletin that inspection                                     an impedement for 100%

creates animpedement 100% visual examination. (management (management need to know this). Even with crawler we may not be able to inspect head because of only 2" gap.. inspect the nozzles at the top of the head gap .. U.S. In NRC GEISEN 5-.). DAVID GEISEN 5ý&4bt reDAVID In re ff I (;.. . am Exhibit ,_'1__ I/,,) cf-..._ Docket ## 11A-05-052 'I S A-05-052 Date Marked-for Mari<e<Hor 10'/4 z-I~  ; ID z-j

  • 2008 (Tr. (Tr. p.
p. gb ,) ")

DOCKETED DOCKETED USNRC USNRC Date Offered Offered in Ev: Ev:_J.i..tf. 2008 (Tr. p.

                                                                                                              , 2008 Through WitneSS/Panel:--,(dp:::.t...,J/-IP-L..-.

p.~Y? September 9, 2009 September 9, 2009 (11 (11:00am)

OOam) Through Witness/Panel. 1 /

Action:. ~ REJECTED REJEC~ED Wfn<<)RAWN WIThDRAWN OFFICE OF SECRETARY OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS ADJUDICATIONS STAFF "ADJUDICATIONS AND STAFF Date: J1fi..

                                                                                .. 4 2008   2008 (Tr. p.~

(sr. p. S-U2-~ ) S14H-00503 514H-00503 Exhibit 89 89 Page 1 of 1 Pages mpRinnn.rnn

           ~
                £l.-Q       /?
                            <--)-2        10     ct(                                  U.S.

U.S. NRC NRC ~I ('(' 4-"7 r \...] '-- - tl D DAVID GEISEN ,) t It-- t-t ExhibIt 0 _ 2 - K krs re DAVID In re Docket 1A-DS-DS2 I ~ J Q Docket ## 1A-05-052 Marked for Date Marked ID~ 2008 for ID is'?5. )) 2008 (Tr. p. 2*6"

                                                                                                        .     ./~lg*                      0Z~

From: From: Dale R. Dale R. WuokkolTE/FirstEnergy WuokkofTElFirstEnergy Date Offered Date Ev.~, In Ev: Offered in (L ., 2008 2008 (Tr.p...-.Ž.4 (Tr. P.L_) To: Rodney M. Rodney M. CooklFirstEnergy@ CooklFirstEnergy@FirstEnergy,FrankW.Kennedyn Witness/Panel:_~N~/..:.p., FirstEnergy, Frank W. Kennedy/'I Through Witness/Panel:. P_ _ _ _, LockwoodfTElFirstEnergy@ FirstEnergy, Lockwood/TE/FirstEnergy@ Prasoon K. FirstEnergy, Prasoon K. GoyaVTE/FirstEnei GoyaVTElFirstEnel * .c.::=~ / FirstEnergy, Mark GeisenffEiFirstEnergy@FirstEnergy, Geisen/TElFirstEnergy@ Mark A. McLaughlinITEiFirstEner! Action: A. McLaugh~lniTvEFirstEnerl ~ . REJECTED Action: AgiMT REJECTED WITHDRAWNWITHDRAWN cc: . . Date: ~, 4.-, 2008 (Tr. (Tr. p. S~le ). ). CEOG meeting on

Subject:

CEOG

Subject:

on BL BL 2001-01 Date: 9/4/2001 10:39:241010 Oate:9/4/2001 10:39:241010 fyi Forwarded by Dale R. Wuokko/TElFirstEnergy

--- Forwarded

--- WuokkoffElFirstEnergy .on on 09/04f01 10:30 AM 09/04101 10:30 AM --- Huston" "Roger Huston"

              .cRoger@licensingsu
              <Roger@licensingsu                      To:                                                    "Wuokko"     <drwuokko@firs "Wuokko'"<drwuokko@firs pport.com>                              cc:

Subject:

CEOG meeting on.BL CEOG meeting 2001-onBL 2001* 08127/01 05:31 PM 08/27/01 PM Dale, I attended between the CEOG attended a meeting between CtOG andand the NRC regarding the NRC staff today regarding the proposed response of CE plants to the Bulletin on vessel penetration vessel head penetration nozzle cracks. Since the Bulletin responseresponse is due thought some due next week, II thought some feedback might be useful. The CEOG purpose purpose was to grease the Skids skids for their members to request deferral by one cycle for their inspections. deferral None of their plants are high inspections. None high susceptiblity (per the Bulletin scheme). susceptiblity scheme). One (Palisades) is low. One (Palisades) DOCKETED USNRC USNRC The presentation emphasized the difficulty of doing the requested inspections on CE plants. Their drives are a uniform distance above the distance above the September 9, September 9, 2009 (11:00am) 2009 (11 :OOam) and B&W. All plants have some form .. elevation like W andB&W. head, not at a uniform elevation OFFICE OF OFFICE OF SECRETARY SECRETARY on-head insulation. Most involve tight-fitting collars around the of on-head the RULEMAKINGS AND RULEMAKINGS AND resting on the head. Insulation removal is going to be nozzles and resting be ADJUDICATIONS STAFF STAFF Time is needed to develop mockups, ADJUDICATIONS required, and will be destructive. Time train, design new insulation, etc. respondents were NRC staff was not particularly receptive. The principal respondents Strosnider;,who was diplomatic, and Brian Sheron, who was not. They Jack Strosnider(who arguments to stated that this is a safety issue, and that they need safety .arguments different. While one of the justify doing anything different. .theNRC goals is unnecessary unnecessary burden reduction, they knew there were going to be burdens from this Bulletin. They found them necessary, and are not particularly receptive to arguments of hardship or excess burden now. are concerned that they now. They are.concerned have a safety issue, and they are not EPRI/MRI/NEI that not as convinced as EPRIIMRIINEI Oconee is the worst plant or that the susceptibility model model accurately relative standing, much less establishes relative less time to aa problem. Sheron stated that the model is just time and temperature, and we all know there are other are other S14D-04539 S140-04539 Exhibit 153 153

   ýE9/7472                         S cS         LQ CNRO2-15                 71~

TK.:z ~ ~ge Page 11 of "7--- of 22 Pages Pages NRC002-0153 NRC002-0153

From: Dale R. A. WuokkolTE/FirstEnergy WuokkofTElFirstEnergy To: Rodney M. Rodney Cook/FirstEnergy@ FirstEnergy, Frank W. Kennedy/TElFirstEnergy@ M. CookiRrstEnergy@RrstEnergy,Frank KennedyfTEiFirstEnergy@FirstEnergy, H. FirstEnergy, David H. LockwoodFrE/FirstEnergy@ FirstEnergy, Prasoon K. LockwoodfTElFirstEnergy@FirstEnergy, K. GoyaVE/TFJirstEnergy@ FirstEnergy, David C. GoyallTElFirstEnergy@FirstEnergy, GeisenTrE/FirstEnergy@ FirstEnergy, Mark GeisenrrEiFirstEnergy@FirstEnergy, Mark A. McLaughlinfTE/FirstEnergy@ FirstEnergy McLaughllnfTElFirstEnergy@FirstEnergy cc:

Subject:

CEOG meeting on BL 2001-01 CEOG meeting Date: 9/4/2001 10:39:241010 .Date:9/4/2001 10:39:241010 fyi Wuokko/TEFirstEnergy on 09/04/01 10:30 AM Forwarded by Dale R. WuokkofTElFirstEnergy


Forwarded. AM---

               "Roger Huston"
              ,<Roger@icensingsu
               <Roger@lIcenslngsu                    To:

To: "Wuokko'" <drwuokko@firs-

                                                                                                          'Wuokko"  <drwuokko@firs pport.com>                            cc:

PM 05:31 PM

Subject:

Subject:

CEOG meeting onBL CEOG meeting 2001 on BL 2001* 08/27/01 05:31 08127101 Dale, I attended a meeting meeting between between the CEOG and the NRC staff today regarding the theCEOG the response .of proposed response of CE plants plants to the Bulletin Bulletin on vessel head head penetration nozzle cracks. Since Since the Bulletin response is due next week, II thought some some feedback might feedback might be useful. useful. The CEOG purpose was to grease the skids for their members members to request deferral deferral by one cycle for their inspections. inspections. None None of their plants are highhigh susceptiblity susceptiblity (per the Bulletin scheme). One (Palisades) (Palisades) is low. The presentation emphasized the difficulty of doing presentation emphasized doing the requested inspections on CE plants. Their drives are a uniform distance inspections distance above the the head, notat not at a uniform elevation like W and B&W. Wand B&W. All plants havehave some form of on-head insulation. Most involve tight-fitting collars around the the nozzles nozzles and resting .on on the head. Insulation Insulation removal is going to be be required, and will be destr.uctive. destructive. Time Time is needed needed to develop mockups, train, train, design new insulation, etc. NRC staff was not particularly NRC particularly receptive. The principal prinCipal respondents werewere Jack Jack Strosnider, who was diplomatic, diplomatiC, and Brian Sheron, who was not. They stated that this is a safety issue, and that they need safety safety arguments arguments to justify doing anything different. While one of the NRC goals goals is unnecessary burden reduction, they knew therethere were going to be burdens from this this Bulletin. They found them necessary, and are not particularly particularly receptive receptive to arguments of hardship hardship or excess excess burden now. They are concerned concerned that they have a safety issue, and they are not as convinced as EPRIIMRIINElthat have a safety issue, EPRI/MRI/NEI that Oconee is the worst plant or that the susceptibility Oconee accurately susceptibility model accurately establishes relative standing, much less time to a problem. establishes problem. Sheron Sheron stated that the mOdel model is just time and temperature, and we all know there are other 8140-04539 SI4D-04539 153 Exhibit 153 Page 11 of Page 2 Pages of 2 Pages NRC002-0153 NRC002-0153

involved -- we just factors involved factors don't know how to model them. just don' them. The The staff staff has has also concluded that inspection concluded that inspection of a fewtew penetrations penetrations ---- on one one plant plant or on sample of representative sample on a representative ofaa fleet -- doesn't fleet-- have much doesn't have much validity validity as as proof proof that there there isn't a problem problem where where there have have not been been inspections. inspections. They They have have put a memo on the web to that that effect. A copy is attached. attached. The TheCEOGCEOG had ~econd.back-pocket. had a second, back-pocket, presentation presentation on a risk argument for why risk argument why OK to defer. If it's OK If anything, reception to that presentation anything. the reception presentation was moremore hostile. hostile. The The analysis analysis was was mostly qualitative. qualitative. It relied on EPRIEPAI pipe pipe break probabilities probabilities to estimate what the the chances chances of of a nozzle nozzle ejection ejection LOCA were. It did did notappear not appear to take anyany factors specific specific to this situation into account. account. NRC NRC thinks there there are are plenty. There There isis a known known cracking cracking problem. problem. The The corrosion corrosion environment environment is aggressive. aggressive. Simple Simple useuse of of pipe pipe break probabilities is therefore probabilities therefore inappropriate. inappropriate. Etc. If If you You are contemplating contemplating asking for fora a delay in performing perfonning inspections that are requested requested by by the Bulletin, Bulletin. be advised advised that a strong strong safety argument argument will be needed. Simply demonstrating demonstrating difficulty difficulty or hardship hardship is not going going to get a very very warm reception. II don't wann reception. don't think that will will be your approach, approach, based based on our past conversations, figured I'd pass along the warning anyway. conversations. but figured Roger W. Huston Huston Licensing Licensing Support Services Services 703-671-9738 703-671-9738 http://www.licensingsupport.com http://www.licensingsupport.com S140*04540 S14D-04540 NRC002-0154 NRC002*0154

              <c-I Piedmont Management Piedmont              Management &                    Technical Services,
                                                                      &. Technical             Services, Inc.

DOCKETED DOCKETED USNRC USNRC U.S. NCLZ L{ L1 September September 14. l-t. 2W 2(X)1l

                                   -- September September 9,   9, 2009 2009 (11:00am)

(11 :OOam) U.S. NRC in reDAVID In 19 DAVID GEISENGEIS2 iv-tT I' / f' r EJdtil._--

                                                                                                                            ý4,1_Edlbt.. -_l OFFICE OF   OF SECRETARY SECRETARY DocWe Docket 0     1A-06-06
  • 1A-05-052 RULEMAKINGS AND RULEMAKINGS ADJUDICATIONS ADJUDICATIONS STAFF AND Date MarkediortD'lUL.

Date Marfted-for I 2008 (Th 200 cn-. p. g2 S ) Date Offered Inev. 1~(8

                                                                                         **OateOtferedInEv:                      'rrcn-.p.gZG )

(f2 .-- Mr.:"lark Mr. ?vICLaughlin Mark McLaughlin Davis-Besse Nuclear Davis-Besse ~uclear Power Power Station Station lhrough~WltnesslPaneI: ThmuouhesPn Action: - Acion: NI REJECTED WMIIDAWN REJECTED WlnIOAAWN 550 1 N. State Route 22 5501 Mail Stop 1048 Mail L048 te.. ~ 241a0 Date: .%2oocrr.(Tr. pP-8'Z G )

                                                                                                  ~ , .2008 Oak Harbor, OH 43449

Dear Mark:

your and Mr. Steve Moffitt's request. I reviewed Davis-Besse's At your preparations to date.foraddressing Davis-Besse's preparations date Joraddressing the reactor reactor vessel top heaad CRDM toph~ CRDMpenetration penetration cracking issues issu~s andthe station's response to NRC and the station's NRC. 7 " Bulletin 2001-01, 1001-01. "Circumferential Cracking of Reactor Pressure "Circumferential Cracking Pr6ssure Vessel Head PenetrationNozzles~" Penetration Nozzles." - - The observations observations listed listed in Attachment Attachment (l) (1) are provided characterize the status and degree provided to characterize degree ofof preparations preparaiions to date. The planning elements. elements below are are emphasized emphasized for consideration consideration by the project project team assembled

 .team    assembled to conduct the planning for this effort.

CRDMInspectio~ L. .CRDM Inspection and Repair Project team team rriembers members are are not in agreement concerning the need agreement concerning need to. to proceed with cutting access holes holes in the Reactor Reactor Service. Structure at the start of l3RFO. 13RFO. Some.Some see this as a contingency contingency action for which all preparationspreparations should be in place and implemented only if required. Itis ifrequired. his noted that on .completion completion of 12RFO, 12RFO, the Reactor Vessel head did have boric

      -acid crystal deposits of considerable considerable depth left in the center  center top area of the head, since cleaning cleaning of this area at that time was not successfulsuccessful in removing removing all the deposits deposits (partly duedue.to    limited access).

to limited Davis-Besse Davis-Besse stated in its response response to NRC Bulletin 200 1-01 L-01 that the top head visual inspections inspections would riotnot be comprorriised compromised due to any pre-existing pre-existing boric borjc acid crystal crystal deposits. Given previous experience in removing boric acid deposits from the head, the likely

       .experience                                                                          likely need to remove these deposits at the center center top head by mechanical mecnanical means, means, the severely restricted restricted access allowed by the service   service -

structure structure mouse holes for mechanical cleaning, the industry industry experience of Duke Power that clearly clearly emphasizes the need for good access to the emphasizes the head for cleaning inspection and the NRC cleaning and inspection commitments and inspection inspection requirements requirements.for for the visual inspection, the most prudent course of of action toto.avoid outage delays would be to access holes in the Reactor Service Structure Structure as soon as possible in 13RFO.

2. The project team intends to perfonn
2. perform a mockup demonstration demonstration of the remotely operated visual inspection equipment. The goal of the demonstration process should be to identify any equipment inadequacies inadequacies and to validate the inspection procedure. If the mockup to be used is generic for .for B&W plants. it is important that any differences, B&Wplants. differences, between the mockup and the actual conditions conditions and access restrictions presented by the configuration of Davis-Besse Reactor Service Structure Structure and RPV head arrangement.

arrangement, be addressed in the qualification of the inspection technique. 2505 South 17"' Street Suite I IS " Wilmin2ton. NC 28-101 1)4101452-3088 Fax q101 452-4413 "email: Pmtsnc@aol.uom S14R-00781 Exhibit 164 164 IT '? T& )t4Pi -Ir./Gj =-- 0k'f o~* DS' ~age D6-0Z__P age 11 of of 55 Pages Pages NRC002-0432 NRC002-0432

3. A \\Intten pro-.:edure should be developed to conduct the visual inspection and should includc written procedure Include a

( diagram of diam-am ot the head:.penete.ation head'-penetr.;l[ion to document document and catalogue inspections to ensure catalogue the inspections ensure complete 360 360 W~,.~,.~..;~~, .degree';';?speSr(i:mc'e)verage,of

                                 .de.2ree'inipetion co,.eraoerdf each                                    eilch penetration, penetration. Useful guidance is provided in the EPRI report
                                     'Visual E\~irlllhatio'n "Visual            E',iiin.Itiori for~akage      foi4ýLakage of PWR Reactor Head Penetrations".          Penetrations~. ~o  No. 1006296.

(~"~~f ._ """~_ .. "" .. '-,~~ ,~ ~ , " ,.*~<','i..""" n~:':*'. t. .

4. To allo\%for the best Tll allo\\ hest possible poss*ible outage scoping. engineerng engineenng analYSIS proceed quickly t6 analysis should proceed to'

" ,t / , ,< . confirm confirm th~lt ihit g~lrs;~rctua:tly:exist iups;ýictuily.exist between the penetrations penetrations and reactor \'essel vessel head. so that leakage

                        .           .from crcackngncpe-etrat onsor welds will be evident from a bare
                                  .t.rQrll.orac\.;.lng.{)I!uetratJ9f.ls:0f                                                                     bare metal top he3.d      inspection It[t IS head inspection.        is
            .... ,.... : anticipated                            that     lack     of   confirmation ot' con finnation              of such   a gap   would
                                                                                                                                   \"'ould   require   NDE    of-those   penetrations oLthose*penetra[lons 50   so
               ~: .*; """"id~i1ti flea.                            *F*"* ..if..::': ......~.
                "'~'''''''"_~ 1..,  i~-~l ...*~ .*'*. ~s..      __
                                                                    ,_.~ "_.r_,,   -<'   ~~('/..  ' ***
5. A significant potential for scope growth exists on thIS this project requiring sophisticated degree of requiring a sophisticated contingency planning. The project team should identify the individual elements contingency elements that can drive increased increased inspection. inspection, repairs or unforeseen equipment problems. problems, For example, ex.ample. mandated inspection expansion expansion requirements from unfavorable unfavorable results in upcoming inspections at TNMI TMl and Crystal River, inspection equipment Crystal equipment failures. difficulties in weld repair or preheat and a greater*

failures, difficulties greater. number of penetrations penetrations requiring requiring NDE NnE as a result of unfavorable visual. inspection results unfavorable initial visuaUnspection are a few of the elements elements that should be beconsidered. considered. . rmtigation strategy should be developed Jor A mitigation for each of the scope growth elements elements the project team identifies. The project team tearn should then make a judgment on the extent that conringencyplans. make ajudgqtent contingency.plans,

                                   'equipment and procedures
                                   'equipment                            procedures should be developed           deve1opedb      as basededonon  the consequence consequence       of each contingent contingent element if it were to materialize. The contingencies element                                                                       contingencies should be reassessed reassessed for mitigation once the results and lessons learned from the TMI and Crystal results                                                                                 Crystal River inspections are available.
6. To ensure ensure all project project team members members have a common understanding understanding of expectations expectatioris for the scope of input and involvement required required of them,them. the next team meeting meeting should discuss this and clarify expectations if needed. Additionally, expectations Adclitionally. the expected involvement of team members during the team members execution execution phase of the project should be addressed, Framatome will actually be performing addressed. since Framatome much of the work. For example, example, is any oversight role expected expected of project projectteam team members.

Frequent team meetings are suggested at least until detailed det~led planning milestones and a comprehensive project plan are developed. This is an experienced comprehensive experienced and capable team and it is important important to obtain team team synergy in identifying ickntifying needed actions and best work flow and sequence. actions From From the observations observations noted in Enclosure Enclosure 1I it is evident that the project project' team has a good start. '

                          . There is much yet to do in turning                              tuming cncepttual'plans conceptual' plans into detailed detailed inspection inspection plans, plans, schedules schedules andand procedures. The procc:dures.                   The project  project team. teamplans               to observe plans to  observe some some of  of the the inspections inspections and and repair    activities for repair activities    for CRDM CRDM penetrations  penetrations scheduled        scheduled in the fall outages at TMI                   TMl and Crystal Crystal River to take advantage advantage of the kS50nslessons learned. This                              information             will  be   utilized   in  providing This infonnation wi 11 be utilized in providing the best possible detailed   the  best  possible   detailed planning for the same                     same effort at Da"'is-Besse        Davis-Besse during the spring 13RFO.

Sincerely, Sincerely. Gregory A. Gibbs Gibbs Principal Principal Consultant Consultant 2 SI4R-00782 S14R*00782 NRC002-0433 NRC002*0433

cc:'

    <:c;"Steve   ~"Ioffin Steve Moffitt Scott Coaklev Scott  Coakle\"

Dave Geisen Dave G\!isen Andy Wilson Andy\Vi Ison . Project Team Members Project Team '\lembers

    .\ttachment (1)

Attachment (L) CRDM Penetration Actions Nozzle Penetration CRDM Nozzle Actions

-V

. 1 J3 SI4R-00 78 3 - 514R-00783., NRC002-0434 NRCOO~~-0434

Attachment Attachmelu I1 CRDM Nozzle CRDM Penetration Actions Nozzle Penetration Actions The foI owing are some of the actions that have been or are planned to be taken to address the The rol k)\\in~ arc some of the actions that have been or are planned to be taken to address the industry industry CRDMCRD\[ nozzle penetration cracking nozzle penetration cracking issue issue at Davis-Besse.

  . A team has been       assembledlo focus planning been assembledto               planning efforts efforts in preparation preparation for 13RFO.visual l3RFOvisual inspection inspedion of of the CRDM CRDM nozzle nozzle top head head penetrations         evidence of penetrations for evidence    of leakage. cleaning cleaning of the RPV head   head to provide      baseline for future inspections, provide a baseline                   inspections, NDE examination examination and flawfla ....; characterization, characterization. and and repair repair of of any identified identified leaking leaking CRDM CRDM nozzle nozzle penetrations.         team consists of penetrations. The team                    of Messrs. Marjk Mar.k Mclaughlin (Project McLaughlin       (project Manager),

Manager), Prasoon Goyal Goyal (Design), (Design), Andrew Siemaszko Siemaszko (RCS System (ReS System Engineer). Chuck Daft Engineer), Daft ([SI (lSI and NDE), NOE), Frank Kennedy Kennedy{Licensing), (Licensing), Mel Mel Hurley Inspection) Hurley (QC Inspection) Brad Baumgardner and Brad Baumgardner (RP).

  )    A Long Range Plan   Plan Project Project Business Business Case Case exists to plan, plan, prepare prepare and purchase purChase materials to be ready to repair              nozzles and perform repair CRDM nozzles               perform CRDM nozzle        inspections assuming the nozzle inspections                      the need to repair four nozzles for planning planning and budgeting purposes.

purposfi;.

  "    A Plant Review Committee                            conducted on September 13, Comminee meeting was conductedonSepteinber                   13,2001 2001 that authorized authorized proceeding with the work identified proceeding                       identified above and obtaining obtaininglhethe necessary necessary executive executive approvals approvals for funding.
  -,." NRC Bulletin       2001-01 was responded Billletin 2001-01           responded toon      September 4, 200t.

to on September 2001. Davis-Besse Davis-Besse committed corrimitted to a ~ final response by January 29.2002 29, 2002 to incorporate incorporate experience experience based on inspection results from d facilities, the ongoing work of the MRP, and the advancement other facilities. advancement of NnE NDE technology technology aridarid development of remote tooling adequate to perform effective development effective an'd and timely surface surface or volumetric volumetric examination from examination underneath the RPV head. fromundemeath

   " A milestone schedule
  -,.                                               project plan for the CRDM penetration inspection and potential schedule and detailed project repair activities does not exist at this time andis and is currently         developed.

currently being dev.eloped.

   -,. A meeting was held September
   "                                             11, 2001 to identify and integrate September 11,2001                                     key CRDM "inspection integrate keyCRDM            inspection andand Services Work 13 RFO schedule. ~ome repair activities into the Reactor Services                                       Some items addressed include Iding a shielded access J~om building bui                               from the water tanks that surround the head st;l.nd     stand to the the' head stand for equipment access, consideration worker and equipment                   consideration of preservation preservation of the as-found-condition as-found-condition of boric    boric acid crystals on the top head during              head cleaning for installation during any headcJeaning          installation      of the RV   stud   de-seismic plates and clamps vice just those for the PI coils, -installation tensioners, removal of all seisrtlic                                                                                  of installation of much equipment as possible under the head stand before positioning of the head stand, as much consideration of when in the RV disassembly sequence to decon under the head ifrequired.

consideration if required, the need to lock the lead screws in place for personnel safety, determination determination of the need to cut holes the. service structure to provide access to the top of the head and addition into the addition to the schedule of the underhead inspection activity.

    > A proposal has been recei
   -,.                            received                                                Inc.. dated August 24. 200 ved from Structural Integrity Associates, Inc.-.dated                            2001.
1. for technical consulting support for for stress analysis. fracture mechanics evaluation, crack growth .

evaluation leakage calculation, evaluation, inspection scope expansion and any needed calculation, structural evaluation. licensing support. licensing S14R-00784 S14R-00784 Exhibit 164 164 Page 4 of 5 Pages NRC002-0435 I11YLUUZ-U4,)O

    ,. ° A   proposal has
         ..\ proposal           b~en received has been                       Fmmatome ANP recei\ed from Framatome           A~P for CRDMCRD\l nozzle visual           inspection. NDE
                                                                                                        \*isual inspection.       \"DE Jnd repair and    repair including      pre-deployment workscope including pre-deplovment          \\orkscope and       deli\Oerables inc[uding input and deliverables*including          input on ASME AS\lE code Cl)lk rdie.f requests, rTelie.f re4ue:-;I<;. fracture   mechanics and analysis.

fracture mechanics analysis.

    ,. A     pn~r!\>alhas
         ..\ pn'poýal           ['een received has been    recei\Oed from S&L S&L for               associated with preparing senoices associated tor services                       preparing aa specitiOcation specification tor(or the   procurement. design Ihe pruicu.emcnt.                      installation design and installation the of the  reactor    vessel head/senoice 5tructur~ ;.tnd vessel   head/service     structure     and ClInt'UIHnent hatch.

containment hatch.

    ,." Conceptual Conceptual planning planning hashas been initiated for RV head         replacement in 1I-RF0.

headreplacementin l-l-RFO. dr.lft decision tree has been

    ,. A draft                                                                    potential results and addressing the potential been prepared addressing                                  and necessary         activities for necessary activities        for visual inspection of the head.

the Visual head.

    > A work request, tag WO
    .,                               WO #875. has   has been   prepared to been prepared      to cut three 12 l2 inch x 24 inch holes. holes~ [20L20 degrees delrrees jJeginning of 13RFO. There apart,oat the beginning apart,,at                                     There is a companion         Engineering Wprk companion Engineering           Work Request No. 01-0378-  Ol-O'373-support for cutting engineering support 00 that requests engineering                          cuuingthe the access holes.

.~

\
    >- Unlike other B&
    >                       B&Wreactors,        Davis-Besse does hot hive W .reactors, Davis-Besse                          access holes to the head in have access                                  the.Reactor intheoReactor Structu~ except Service Structure        e~cept the s~allmouse small mouse holes.                   Inspection and Repair
                                                                         -CRIDM Inspection hoies.CRPM                             Repair project        team project °team members members       disagree     concerning concerning     the need  to  proceed proceed    with   cutting  access access   holes    in the   Reactor Reactor Service Sen ice Structure at the start of 13RFOo Structure                       13RFO. Some see this as         a contingency asac(}otingeilcy      action   for  which     all  preparations preparations should be beinin place. It is noted that on completion completion of                     Reactor Vessel t!2RFO the Reactor ofU2RFO                       Vessel head did have boric bonc acid                              considerable depth left in' crystal deposits of considerable acid crystal                                                iri the center top area of  of the the head, since since cleaning.of this area cleaningof                   at that time was areaoat                       successful in° was not successful          removing all the deposits. Cleaning was in removing hampered by lack of adequate hampered                    adequate access through the service structure. Previous                   ~xperiehce hcisbeen Previous experience            has been that.boric           deposits have to aciddeposits that boric acid                        to be removed by mechanical mechanical      means   as  water    washing       alone  is is not successful.

Davis-Besse Davis~Besse committed in its response to the NRC to perform inspections of the top RPV head surface and CRDM nozzle inspections bare metal surface recommended:by MNP 48, "PWR inspections as recommendedbyMRP "PWR Materials Materials Program Response to NRC Bulletin 2001-01" Reliability Program 200 l-O 1" and further stated that these inspections compromised due to any pre-ex.isting would not be compromised boric acid crystal deposits. pre-existing oboric Given Gi yen previous previous experience removing boric acid deposits from the head, the likely need to experience in removtng remove these deposits at the center top head by mechanical means, the severely restricted access

          ,allowed by the service oallowed               service structure mouse holes too    toallow     mechanical cleaning, the induStry allow Tnechanica!                          industry experience of Duke Power. Power that             emphasizes the need for good access to the head for that clearly emphasizes cleaning and inspection andthe             NRC commitments and,the i'l'RC  commitments and inspection requirements for                for the visual inspection, the most prudent course of action to avoid outage delays would be to cut access holes Service Structure as soon as possible in l3RFO.

in the Reactor Service 13RFO. From the above it is project team has a good star!. is evident that the projecttearn start. There is a lot yet to do in turning plans, contingency plans, schedules conceptual plans into detailed inspection pians,contingency schedules and procedures. 22 S14R-00785 S14R-00785 NRC002-0436 NRC002*0436

C-U.S. 1"",' NRC * /"**.xii#L/j J) U.S. NRC I {\ ..L' U5 e DAVIDGEISEN InInrereDAVID L GEISEN J ~ \'(' ammo ExhibIl._~..;.;;*r;;....-

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401 Pbý 'týS 0 - Ný From: Dale From: Dale L. l. Miller/TE!FirstEnergy MilieriTElFirstEnergy To: To: George.Rombold@exeloncorp.com, mknight@amergenenergy.com. Erdal.Caba@pgnmail.com, George.Rombold@ exeloncorp.com. mknight@amergenener/y.com, ErdaI.Caba@pgnmail.com. Vaughn. Wagoner@pgnmaiLcom. Loretta.v.cecilia@pgnmail.com, Vaughn.Wagoner@pgnmail.com, Loretta.v .cecilia@pgnmail.com. LesSpain@dom.com, Les_Spain@dom.com. Gary_Miller@dom.com. Steve-sarver@dom.com, GaryMiller@dom.com, Steve_sarver@dom.com. sbenne2@entergy~com, sbenne2@entergy;com. mrwilder@duke-energy.com, mrWilder@duke-energy.com, JhamiI2@entergy.com. sherry.bernhoft@pgnmai.com, Jhamil2@entergy.com, sherry .bernhoft@pgnmail.cam. wfoster wfoster@duke-energy.co

                                                                               @duke-energy.co cc:

cc: DavidH. David LockwoodiTEiFirstEnergy@FirstEnergy. Rodney H. Lockwood/TE/FirstEnergy@FirstEnergy, Rodney M. Cook/FirstEnergy@ FirstEnergy, Mark CooklFirstEnergy@FirstEnergy. Mark A. McLaughhnfTE/FirstEnergy@ A. McLaughllniTEiFirstEnergy@FirstEnergy. Prasaon K. FirstEnergy, Prasoon K. Goyal/TE/FirstEnergy@ GoyaliTElFirstEnergy@FirstEnergy. David C_ FirstEnergy, David C. GeiseniTEiFirstEnergy@FirstEnergy. Dale Geisen/TE/FirstEnergy@FirstEnergy, Dale R. WuakkoiTEiFirstEnergy@FirstEnergy. Theo R. WuokkolTE/FirstEnergy@FirstEnergy, Thea S.S.

  • Swim/TE/FirstEnergy@ FirstEnergy, Andrew
,SwimrrEiFirstEnergy@FirstEnergy,              Andrew J. J. Siemaszko/FirstEnergy@        FirstEnergy Siemaszko/FirstEnergy@FirstEnergy

Subject:

CRD

Subject:

CRD Nozzle Nozzle Bulletin 2001-01 Recent Bulletin 2001-01 Recent Developments URGENT Developments --URGENT Date: Date: 15:35:381010 9/28f2001 15:35:381010 9/28t2001 This morning This morning the the CNO CNO of of FENOC FENOC was was contacted contacted by Brian Sheron, NRC Brian Sheron, Associate Director NRC Associate of Project Director of Proleet Licensing and Licensing and Technical Technical Analysis Analysis with regard regard toto our response to the our response bulletin. 'The the bulletin. caller was The caller was strongly strongly suggesting that suggesting that Davis-Besse reconsider our Davis-Besse reconsider our response response to the bulletin and the bulletin consider shutting and consider down by shutting down te by tre end of. end of the year year andand perform perform an vessel head reactor vessel inspection of the reactor an inspection head CRD nozzles. We at Davis-Besse CAD nozzles. Davis-Besse would like would like to conduct conduct a teleconference teleconference of of all of.the susceptibility plants of .the high susceptibility plants on on Monday afternoon (10 Monday afternoon (10 ,*.* -*

J share share any any information information available available relative relative to similar similar contacts contacts and and progress progress on plants plants performing performing inspec:.cr-,

inspee:c,-<; this fall. We will be contacting everyone be.contacting everyone by by phone and/or e-mail phoneandlor e-mail Monday firm up arrangere--'s morning to firm Monday morning arranger.>:,*'*<; Again, Again. my my telephone number is (419) telephone number 321-7284. (419)321-7264. u.s. NRC U.S. In NRC DAVID GEs 1& DAVID In re GEISEN . Jtt 5'

                                                                                                            < 4. P 5 t"     H ae EJta,.!::i bt" i/ I
                                                                                                                                        -... \0 i4(0 Dock8t # IA.04*052 Dooke       1MJ5.052                                      ---

DdsMarkedfor Date MartcactfotlO: 0~/I~I g' 2008 2=08(Th (n'. Po.p &2.5 ) Date Offaract:in Daie Offered in Ev:Ev:.Ji4i-. 2008 (fr. 2008 (Tr.hp-p.glltJ )

                                                                              "'rough~:                            Nih                          .

Aclton: ~ AlIo:n *I D REJECTED W WITHDRAWN HDAN Date:~. D4t.: .4 . 2008 p.g (Tr. p. uP 2008 (fr. U ) DOCKETED USNRC USNRC September 9. September 9, 2009 (11(11:00am)

OOam)

OFFICE OF OF SECRETARY RULEMAKINGS AND RULEMAKINGS

     'ADJUDICATIONS STAFF
     'ADJUDICATIONS S14Q-0 1 1 9 7 S14Q-D1197 Exhibit 151  151
1) S D~ Page 11 of 11 Pages Pages NRCOOI-1751 NRC001-1751 A7

DOCKETED DOCKETED Inre DAVID GEISEN 5

  • Ex-hib*

USNRC September 9, 2009 (1 1:00am) September 9, 2009 (11 :OOam) Discussion Agend Docket U.S. NRC In re DAVID # 1A-05-052 ([ + I'r GEISEN) DC t"t ExhibIt , ! ( L .t U/J OFFICE OF SECRETARY Discussion A,gen,' dG Docket DD a #Mke dfor D5 1A-QS-QS2 ) 7J Q 2 ( OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS AND Date Date Marked Marked for IDi 2 ID:l...::t1... 2008 2008 (r. p.~) 25 , ) (Tr. p.. , ADJUDICATIONS STAFF ADJUDICATIONS STAFF DBNPS DBNPS Bulletin Bulletin 20012001-01-01 R R Date Offered '.in Ev:-j... Izls , 2008 2 08(li 8Z~) (Tr. P........) Date Offered In Ev:~, 0 r. p. ...;;;;;;;~_ BACKGROUND.: BACKGROUND: Through Through Witness/Panel:_________ Wltness/Panel: t-?/P< -

                                      "                                         Action: ~~,

Action: AREJECTED ,REJECTED WITHDRAWNWITHDRAWN

      "     DBNPS is 3.1 EFPY from ONS-3 as of March 20 Date.                                                  (".

(T008

  • DBNPS is 3.1 EFPY from ONS-3 as of March 20 Date: ~2008 (Tr. p. YZ-f...,)

Dae Ip _

      "* Looking Looking at  at only only 0.25 0.25 additional additional EFPY EFPY to   to April    20 c. ... ........

April 20C- "VII,', , ICNI/U I " ONGOING ONGOING ACTIVITIES ACTIVITIES SINCE SINCE BULLETIN BULLETIN RESPONSE

RESPONSE

  • SIA SIA Finite Finite Element Element Analysis Analysis forfor Nozzle Nozzle GapsGaps (McLaughlin/Goyal)

(Mclaughlin/Goyal) Gaps Gaps will will permit permit leakage leakage to to be observed on RPV

                                                ~observedon            RPVhead head'
            "* Visual     Inspection    and   Head   Cleaning Visua,llnspection and Head Cleaning perfonned inperformed            in 11 11 RFO RFO (McLaughlin/Siemaszko)

(McLaughlin/Siemaszko)

            "* Visual Visual Inspection Inspection andand Head Head Cleaning Cleaning Performed Performed in         in 12RFO 12RFO (McLaughlin/Siemaszko)

(McLaughlin/Siemaszko)

            "* Video Vid$o Inspection Inspection Review Review andand Examination Examination Statistics Statistics (McLaughlin)

(Mclaughlin) Further confirmation of no indication of leakage

  • Further confiimation of no indication of leakage attributable to attributable to CRDM CRDM '

Nozzle leakage; clearly CRDM Flange Nozzle leakage; clearly CRDM Flange leakage leakage

             "* Planned Planned Qualified Qualified Visual Visual Inspection Inspection to  tobebe Performed Perfonned During     During 13RFO 13RFO (Spring (Spring 2002) 2002)
       ** " SIA    Fracture Mechanics SIAF~cture       Mechanics on  on Crack Crack Growth Growth Rate Rate (McLaughlin/Goyal)

(McLaughlin/Goyal) Assuming Assuming 180 180degree degree crack, crack, will not reach wlllllot reach allowable allowablecrack cracksizesize inin 22 year year cycle cycle a-Consistent Consistent withwith Oconee Oconee and ANO-1 FM andANO-1 FM analysis analysis

  • Review Review North North Anna-l, Anna-1, CR-3, CR-3, TMI-1 TMI-1 ,, Surry-1 Surry-1 ,,and and ONS-3 ONS-3,fallfall outage outag~

results resultsfor for applicability applicabilitytoto DBNPS, DBNPS, including including lessons lessons learned leamed on on inspection inspection techniques techniques (McLaughlin) (Mclaughlin)

        - Actively Actively evaluating evaluating RPV RPV head head Replacement Replacementduring    during RFO14.

RF014. ALARA ALARACONCERNS CONCERNSOF OFEARLY

                                          ,EARLYSHUTDOWN SHUTDOWN (Coakley)  (COakley)
       ** Personnel Personnel DoseDoseforfor22'inspections inspections (12/01 (12101 andand 03/02) 03/02)
       ** Radwaste Radwaste Generation Generationfor  forearly earlyshutdown shutdown and   and restart restart For ForFENOCFENOC Eyes   Eyes Only Only ECONOMIC ECONOMICIMPACT     IMPACTOF  OFEARLYEARLYSHUTDOWN SHUTDOWN(Coakley)   {Coakley}
       "* Direct DirectCosts Costsofofearly    shutdown by earty.shutdown       by 12/31/01 12131/01 versus versus3/30/023130/02
       "* Outage Outage Length Lengthand andreplacement replacementpower powercosts costs S14M-04099 S14M~04099' Exhibit Exhibit 177 177 Page     1  of Page 1 of66Pages   Pages          NRC017-1258 NRC017 -1258

Discussion Agenda Discussion Agenda DBNPS DBNPS Bulletin Bulletin 2001-01 2001-01 Response

Response

BACKGROUND: BACKGROUND:

  • " DBNPS DBNPS is is 3.1 3.1 EFPY EFPY from from ONS-3 as of March March 2001
  • " Looking Looking at at only only 0.25 0.25 additional additional EFPY EFPY to April 2002 from 12131/0112/31/01 ONGOING ACTIVITIES SINCE BULLETIN ONGOING ACTIVITIESSINCE RES~ONSE BULLETIN RESPONSE
** SIA Finite                                 Nozzle Gaps (McLaughlin/Goyal)

Element Analysis for Nozzle Finite Element (Mclaughlin/Goyal) Gaps will Gaps will permit leakage to be.observed

                    ~rmit leakage                         on RPV head:

lH?observe(/cmRPVhead***

       ** Visual Inspection Inspection and HeadHead Cleaning      performed in Cleaning performed        in 11 RFO (McLaughlin/Siemaszko)

(McLaughlin/Siemaszko)

      ** Visual Inspection Inspection and Head Cleaning PerformedPerformed in  in 12RFO 12RFO (McLaughlin/Siemaszko)

(McLaughlin/Siemaszko) ... . '

       ** Video Inspection        Reviewand Inspection Review      and Examination                   (McLaughlin)

Examination Statistics (Mclaughlin) confiimation of no indication

  • Further confirmation leakage attributable to CRDM indication of leakage leakage; clearly CRDM Flange leakage Nozzle leakage; leakage
       ** Planned Qualified                                     Performed During 13RFO Inspection to be Performed Qualified Visual Inspection                                 13RFO (Spdng 2002) .

(Spring

 *- SIA SIAFracture       Mechanics on Crack Fracture Mechanics                    Growth Rate (McLaughlin/Goyal)

Crack Growth (McLaughlin/Goyal) Assuming 180 degree crack, will not reach degree crack, allowablecrack size in 2 year reach allowable year cycle

        ** Consistent with Oconee andANO-1                    analysis and ANO-1 FM analysis
 **      Review North Review   North Anna-,

Anna--1, CR-3, TMI-1 , Surry-1 ,and , and ONS-3 fall outage outage applicability to DBNPS, including results for applicability learned on inspection including lessons learned inspection techniques (McLaughlin) techniques (Mclaughlin)

 *" Actively Actively evaluating evaluating RPVRPV head head Replacement Replacement duringduring RF014.

RFO14. CONCERNS OF EARLY SHUTDOWN (Coakley) ALARA CONCE.RNSOF (Coakley)

  ** Personnel Dose for 2 inspections (12101                    03/02)

(12/01 and 03102)

  **                                          shutdown and Generation for early shutdown Radwaste Generation Radwaste                                                 restart and restart ForFENOC Eyes Only For ECONOMIC IMPACT OF EARL ECONOMIC                          EARLYY SHUTDOWN (Coakley)
   *" Direct Direct Costs Costs of  of early early shutdown shutdown by by 12131/01 12/31/01 versus versus 3130/02 3/30/02
   *" Outage Outage Length Length andand replacement replacement power power costs costs S14M-04099 S14M-04099 Exhibit 177 Exhibit  177 Page 11 of Page     of 66 Pages Pages  NRC017-1258 NRC017-1258

Discussion Discussion Agenda Agenda I DBNPS Bulletin 2001-01 Response Bulletin .2001-01 Response a* Looking Looking at at only only 0.25 0.25 EFPY EFPY extension extension past past end of year ~) n- Video Video Inspection Inspection Review Review and Examination Statistics (McLaughlin) and Examination (McLaughlin)

                                                        '.              "         ' .. = ...
                                    .              .           .. ' .1-9 ~c...,,.;t# j-f,.~-I t.~ <

I) -)* SIA

  • SIA Gap Gap Analysis Analysis (McLaughlin/Goyal)

(McLaughliniGoyal) .... . J~4 .~AoJt *.. -I,~. , ~Uli- *. 4(. V, ~

              ..                                       .                         rwl~. . b..~~ Am            1)0.J,'          7".t
  *-Results Results of  of North   Anna-1 and North Anna-1        and CR-3         results and CR-3 results                   application tt ~ 1)1 and application                         , r-"     -"e's I"~~.s DBNPS, including          lessons including lessons learnedlearned on   on inspection inspection techniques techniques U           ~ (.~

( Z;,:(- (McLaughlin) f)e1 ~ lI-t.\... )e.f,,: I .pin'" cc1Ji ( JJ (Lc..;~ 8" r'r; t ~ .1.)' o~ r:.,.~ t.(..I. ute.. flV<t;7 e.t/!rY I) A ! .. 'J);/~ E- Nozle NoZ4Je Characteristics Characteristics and and potential potentl~1 for for cracking [matrix] (Goyal) cracking [matrtx] (Goyal)

.,f,. .H ~~L $-.......c- t.~lt..f~ f"',~I.(;),lrw",/c... ~.,*... .sl J-(,$, t
'/~'
   ** SIASIA Fracture Fracture Mechanics          on on Crack        Growth (McLaughlin/Goyal) Mechanics  p,,C,      Crack
                                                     .       Growth (:v,,*Rate Rate (McLaughlin/Goyal)             Pfltt        Q.    ~~~c. t:lJ.t!.      /'0°'
                                                                               /' -f /,;.4 (to,' _ ~
         /J() craCICfS
     , *~to    cY'acics 1.~.R k.(M>C     ~-          b~- - .0-,  .s:L6~.f~{J L3- a            ;~,:,~C'
                                                                                         /(    4-( -" -        ;..~.:...       ..
                                  . '                          .                        ....I,r- ........ ,.,/,---,

Financial/Schedule FinanciaVSchedule Picture Picture of of early early shutdown shutdown (Coakley) . ,'b.-s'--o. -::.. -.J

   ** Direct Direct Costs Costs ofof early early shutdown shutdown                                                                                          I
    *- Outage Outage Length Length andand replacement replacement power    power costs costs
    ** Personnel Personnel Dose Dose forfor 22 inspections inspections (12/01  (12101 and and 03/02) 03/02)
    *- Radwaste Radwaste Generation Generation for  for early early shutdown shutdown and    and restart restart 514M-04100 S14M-04100 NRC01   7-1259 NRC017-1259

Discussion Agenda Agenda DBNPS Bulletin 2001-01 ResponseResponse Conference Call Conference . October 3, 2001, 2001, 9:30 a.m. BACKGROUND: BACKGROUND:

  • " DBNPS DBNPS is is 3.1 EFPY from ONS~3 ONS-3 as of March March 2001
  • " Additional Additional 0.25 0.25 EFPV EFPY from 12131/01 12/31/01 to March2002 March-2002 (13RFO):

Remains

          - Margin of 2 EFPY Remains
**    Qualified Qualified Visual Inspection Inspection to be Performed Performed During During 13RFO 13RFO ONGOING ACTIVITIES ACTIVITIES SINCE BULLETIN BULLETIN RESPONSE:
  • Plant-Specific Finite SIA Plant-Specific Finite Element Analysis for Nozzle Nozzle Gaps Gaps
  • Video Inspection Review Review from RF010, RFO10, RF011, RFO1 1, and RFO 12:

Further confirmation of no indication of leakage

          -Further
          -                                            leakage attributable attributable to CRDM Nozzle leakage; leakage; clearly         Flange leakage clearly CRDM Flange   leakage
 *" SIA     Plant-Specific Fracture SIA Plant-Specific    Fracture Mechanics Mechanics and Allowable Allowable Crack Size Analysis Analysis
  *" Review Review North North Anna-i,    CR-3, TMI-1 Anna-1, CR-3,    TMI-1 , Surry-1, Surry-1, and ONS-3 fall outage outage results results for applicability                       lessons-learned .

applicability to DBNPS, including lessons-Ieamed .

   "  Actively evaluating
  • Actively evaluating RPV head Replacement Replacement during RF014 RFO14 ALARA ISSUES ISSUES FOR SHUTDOWN 12/31/01:

SHUTDOWN BY 12131/01:

   *" Personnel Personnel Dose Dose for 2 inspections inspections (12101 (12/01 and 03/02)
    "  Additional Radwaste
  • Additional Radwaste Generation Generation for 12131/01 12/31/01 shutdown shutdown and restart restart S14M-04101 NRC017-1260 NRC01 7-1260

Discussion Agenda Agenda Bulletin 2001-01 Response DBNPS Bulletin Response BACKGROUND: BACKGROUND:

"    DBNPS is
  • DBNPS is 3.1 EFPY from 3.1 .EFPY from ONS-3 as of March 2001
  • " Looking Looking at at only 0.25 additipnal only 0.25 additional EFPY EFPY toto March March 2002 from 12131/01 12/31/01 ONGOING ~CTIVITIES ONGOING ACTIVITIES SINCE BULLETIN BULLETIN RESPONSE

RESPONSE

  • SIA Plant Specific Finite Element Element Analysis Analysis for Nozzle -Gaps Gaps Gaps will permit leakage Gaps leakage to .beobseTV!HJon be observed.on RPV head
  • Video Inspection Review Review and Examination Examination Statistics (Mclaughlin)

(McLaughlin)

  • Further confirmation confirmation of no indication of leakage attributable attributable to CRDM leakage; clearly CRDM Flange Nozzle leakage; Flange leakage leakage
    ** Planned Planned Qualified Qualified Visual Visual Inspection Inspection to be be Performed Performed During During 13RFO 13RFO (Spring 2002)

..* SIA Plant Specific Fracture Fracture Mechanics Mechanics andand.Allowable Crack Size Analysis

  • SIA Plant Specific Allowable Crack Size Analysis
  • Review North Anna-i, Anna-1, CR-3, TMI-1 , Surry-1 ,and CR--3, TMI-1 , and ONS--3 ON5-:-3 fall outage outage results for applicability applicability to DBNPS, including lessons learned inspection learned on inspection techniques and model crack growth predictiveness techniques predictiveness.
**   Actively evaluating evaluating RPV.head       Replacement during RF014.

RPV.head Replacement RFO14. ALARA CONCERNS OF EARLY EARLY SHUTDOWN SHUTDOWN

 ** Personnel Personnel Dose for 2 inspections inspections (t2l01 (12/01 and 03102) 03/02)
 ** RadwasteGenerationfor Radwaste Generation for early shutdown shutdown and restart S14M-04102 S14M-04102 NRC01 NRC0177-1261
                                                                                                  -1261

Discussion DiScussion Agenda Agenda DBNPS DBNPS Bulletin Bulletin 2001-01 2001-01 Response

Response

BACKGROUND: BACKGROUND:

"* DBNPSDBNPSis   is 3.1 3.1 EFPY EFPY fromfrom ONS-3 ONS-3as   as of of March March 2001 2001
                                                                  ~t.(,.
"* Looking Looking at at only only 0.25 0.25 additional additional EFPY           to Aprll 2002 from EFPYtoAprtt2002             from 12131/01 12131/01 ONGOING ACTIVITIES ONGOING           ACTIVITIES SINCE               BULLETIN RESPONSE SINCE BULLETIN               RESPONSE                                    .   ,    /    ,
  • SIA Finite Element SIA Finite Analysis for Element Analysis Nozzle Gaps for Nozzle Gaps (McLaughlin/Goyal)

(McLaughlin/Goyal) ' Gaps will permit leakage Gspswlll permit leakage to be to be observed on RPV RPV head. heae!.

       "* Visual Visual Inspection Inspection and and Head Head Cleaning Cleaning performed performed in   in 11 11 RFO RFO (McLaughlin/Siemaszko)

(McLaughliniSiemaszko)

       "* Visual Visual Inspection Inspection and and Head Head Cleaning Cleaning Performed Performed in    in 12RFO 12RFO (McLaughlin/Siemaszko)

(McLaughliniSiemaszko)

       "* Video Video Inspection Inspection Review Review and   and Examination Examination Statistics Statistics (McLaughlin)

(McLaughlin)

  • Further confirmation of no indication of leakage attributable to Further confirmation of no indication of leakage attributable to CRDM CRDM Nozzle leakage; clearly CRDM Nozzle leakage; clearty CRDM Flange leakage Flange leakage
       ** Planned Planned Qualified Qualified Visual Visual Inspection Inspection to   to be be Performed Performed DuringDuring 13RFO 13RFO (Spring 2002)1,;                                                                             f       .

. / (Spring 2002) SIA Fracture Mechanics on -'" " ... - r-{

                                                                        "-l".  .,u~#lHc         h.'

y ~ If :';"? <"

                    *                      ... r4 ..        ...... R ,,,(McLaughlin/Goyal)
  • SIA Fracture Mechanics eA GFEiek Gr&'.'ttfol Rate (McLaughlin/Goyal)

Assuming C--" 180 degree O.tcrack, will not not reach m~vallowable diaiysis crack cracksize size in in 22 year year cycle Assuming 180

                        "-~t~  1 c degree     crack, ,* will n A;4g-i    reach   allowable                                  cycle
       -     GOllsiete"t willi Debllse and Id40=1 Fftdlai lalYsls
 "* Review Review North North Anna-i, Anna-1, CR-3, CR-3, TMI-1 TMI-1 ,,Surry-1 Surry-1 ,, andand ONS-3 ONS-3 fallfall outage outage results results for   applicability to for applicability      to DBNPS, DBNPS, including           lessons learned including lessons        learned on on inspection inspection techniques       (McLaughlin) techniques (Mclaughlin)
  "* Actively Actively evaluating evaluating RPV RPV headhead Replacement Replacement during           RFO14.

duringRF014. C('(~"' . . 4J/6G:) (/7.#' .- /6* ':) ALARA ALARA CONCERNS CONCERNS OF OF EARLY EARLY SHUTDOWN SHUTDOWN (Coakley) (Coakley)

  ** Personnel

-...v Personnel DoseDose forfor 22 inspections inspections (12/01(12101 and and 03/02) 03/02) .:5;tb-.-,..-...{ttH L

   ** Radwaste Radwaste Generation Generation for   for early   shutdown and eanyshutdown           and restart restart For For FENOC FENOC Eyes    Eyes Only Only ECONOMIC ECONOMIC IMPACT   IMPACT OF  OF EARLY EARLY SHUTDOWN SHUTDOWN (Coakley)  (Coakley)
   "* Direct Direct Costs Costs of of early early shutdown shutdown by    by 12/31/01 12131/01 versus versus 3/30/02 3/30102
    "* Outage Outage Length Length and and replacement replacement power   power costs costs S14M-04103 S14M-04103 NRC017-1262 NRC017' -1262

2:,;;:.:.1;;j:':i~"~~;:':':'\;l:~~~ . . . !:~~<:::~~~~::,::.,,';':~~"":'~" '~:.:;:'.:<<.~:.\:;:~~~~~:';':;.'~~'~.';;: ;';::.","~-::,,:.~, :,' ".,:;:."::::"::';'~:'i'<':'~<'h\\:::,,;~,~':*:;:';N:,),:,,(,:.i':".~>.>~;..o:.,,"~':"",,;)':.,;, .' ~,).*..;.:-.-: ;""~+.>:",.:n".:":'*r,, ." ..,>:.:..:~,,,,',,,>,)&.:,.., ~'I."" ..*.~~",:"'~"'-':'*':'*"")"'~"_"'~"*w.*."""?.......,. *...-_~._,,~,,'~.. r..____ ....... . Discussion Agenda Agenda DBNPS Bulletin 2001-01 Response Response BACKGROUND: BACKGROUND:

                                                                                                              *" DBNPSis3.1EFPY.fromONS-3 DBNPS is 3.1 EFPY from ONS-3                                                                                                                                                            ,tIC $                     0°f
                                                                                                              *" Summarize        Summarize Past                                                  Past Inspections            Inspections and                                             and Head               Head Cleaning                 ~Ieaning (McLaughlin/Siemaszko)             (McLaughlin/Siemaszko) :.
                                                                                                                                                                                                                                                                                                                                                                                                                                                      ~
                                                                                                              *" Video            Video Inspection                   Inspection Review                                         Review and Examination Statistics                                                                                             Statistics (McLaughlin)                      (McLaughlin)
                                                                                                              *" Looking           Looking at                                   at only      only 0.25                0.25 additional             additional EFPY to April 2002 ONGOING ACTIVITIES ONGOING                                                        ACTIVITIES SINCE BULLETIN                                                                                  BULLETIN RESPONSE
                                                                                                               **                 SIA Finite Element Analysis for Nozzle                                                                                                                              Nozzle Gaps (McLaughlin/Goyal)                                    (McLaughlin/Goyal)

Gaps will permit Gaps perm!t leakage leakage to be observed observed on RPV head / ________

                                                                                                                   ~;~                                                                                                                                                                                                                                                                       .                                            ~
  • v* Results of North Anna-i, Anna.-1, CR-3, TMI-1 TMI-1 ,Surry-1 , Surry-1 ,,and and ONS-3 fall outage outage results and application application to DBNPS, including lessons learned leamed on inspection inspection techniques techniques (McLaughlin) (Mclaughlin)
                                                                                                                ** Nozzle Characteristics                                 Characteristics and potential for cracking [matrix] (Goyal)
                                                                                                       -
  • SIA Fracture Mechanics Mechanics on Crack Growth Rate Rate (McLaughlin/Goyal) (McLaughlin/Goyal)

Assuming 180 degree degree crack, crack,will not reach reach allowable allowab/ecrack cracksize in 22 year cycle

                                                                                                                                             !4el;vL?'                                               4c->.                  t...4-1,-o                                                                                                                         ..'
                                                                                                                 **                Recoil f*,,,,IlIi II I lre, .daUol                               I C t;uI II to,i I                                  1 I 1m
                                                                                                                                                                                                                                                  ,,,,-,t1             lagement for                                       11 RPV head Replacement                                         Replacement during RFO                                RFO114.

14. ALARA ALARA CONCERNS CONCERNS OF EARLY EARLY SHUTDOWN (Coakley) (Coakley)

                                                                                                        '.*                         Personnel Dose Personnel                                                Dose for 22 inspections                                   inspections (12101                                          (12/01 and                         and 03102)         03/02)
                                                                                                                  **                Radwaste Generation Radwaste                                                Generation for early                                                            early shutdown           shutdown and restart It::~,'c :r_I!.~                                                                                                                                                                                          . '

F*,AlA rl~JA~~GIAb'GeHEDULEPlel'URE IL.....,,,,,. , E ICTU. OF EARLY EARLY SHUTDOWN SHUTDOWN (Coakley)

                                                                                                                   **               Direct Costs Direct                            Costs of                          of early      early shutdown              shutdown by                                        by 12131/01      12/31/01 versus                              versus 3/30/02                    3/30/02
                                                                                                                   **               Outage Outage Length                             Length and                              and replacement         replacement power                                               power costs S14M-04104 S14M-04104 NRC017-1263 NRC017-1263

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kA- S C, (' C-l;D to DOCKETED USNRC USNRC September 9, September 2009 (11 9,2009 (11:00am)

OOam)

OFFICE OF SECRETARY OFFICE OF SECRETARY RULEMAKINGS RULEMAKINGS AND AND From: Prasoon K. GoyalfTE/FirstEnergy Goyal/TEiFirstEnergy ADJUDICATIONS STAFF ADJUDICATIONS To: David C. C.GeisenfTEiFirstEnergy@FirstEnergy GeiseniTEFirstEnergy@FirstEnergy cc: Dale R. R. Wuokko/TEiFirstEnergy@FirstEnergy, Wuokko/TE/FirstEnergy@ FirstEnergy, Dale L. L. MillerfTE/FirstEnergy@FirstEnergy, Miller/TE/FirstEnergy@FirstEnergy, Mark A. A. McLaughliniTE*FirstEnergy@FirstEnergy

                   .McLaughliniTEi'FirstEnergy  @FirstEnergy             .

Subject:

Crack Growth Gro"wth Rate (CGR) Date: 7:40:40101.0 10/3/2001 7:40:401.otO Yesterday Yesterday we mainly discussed/focused discussed/focused the CGR GGA of crack crack in the CRDM CADM nozzle tube i.e CGRCGA in Alloy 600 material. The purpose purpose of my my note is that we should also be aware of the CGA CGR in of Alloy 182 ( the weld material CGR in alloy 182 .(crack material ). The eGR (crack in the weld) is expected expectedtoto be 2 to 5 times faster than Alloy 600. MRP expert panel is expected expected to provide provide a r.ecommendation recommendation on alloy 182 182 CGA CGR also. We do not need to to discuss this with NRC. Should NRC ask a question on this subject we need to say that the industry(expert) industry(expert) are in process process of establishing the rate. U.S. NRC u.s. In NRC In re DAVID IML 5+' GEISEN DAVID GEISEN "f

                                                                                                                       ~t '             E       #

LI. a EJChibtt:'l...L-Docket Docket ## 1A-05-052 1A-06-052 Delta Marked'for Date ID:.1lJ.a.. 200 marked for IDJ4z 2008 m. (Tr. p.Q.2 P S' Date Offered In EV:~. Date Ev: i2 i 2008 (Tr. p.8 2(P ) (Tr.I.ELP Through WitnesslPanel:---IfJ:..* Thmugh Witness/Panel:I- if-I:..,.!>. P\._ _ _*_ _ Action:~ ~ REJECTED WITHDRAWN Action: WITHDRXAWN Date; Date.

                                                                                                ¥.        2008 {Tr. p. f3 2~ >>

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DOCKETED ~A- s C-['7 Rfit- C- c:7/I USNRC USNRC September 9, 2009 September (11:00am) 2009 (11 :OOam) From: Rodney Rodney M. CookiFirstEnergy CookiFirstEnergy OFFICE OF SECRETARY

    -OFFICE David H.

H. LockwoodfTE/FirstEnergy@FirstEnergy. Lockwood/TE/FirstEnergy@FirstEnergy, Dale R.

,               RULEMAKINGS AND                       To:        DaVid RULEMAKINGS              AND
          ...SDJUDICATIONS             STAFF
             , '.1111 J'Il .... TIONS STAFF WuokkoiTE.FirstEnergy@ FirstEnergy, Dale Wuokko/TE.'FirstEnergy@FirstEnergy.                  L. MilierITE:FirstEnergy@FirstEnergy Dale L. Miller/TEFirstEnergy@ FirstEnergy cc:

Subject:

Date: 10/312001 7:41 10/3;2001 :441 010 7:41:44101.0 Forwarded by Rodney M.

                                                      ** , .. Forvvarded              M. CooklFirstEnergy Cook:FirstEnergy on 10.03;'0107:38 10.03101 07:38 AM*****

AM ----- Mark Mark A. Mclaughlin McLaughlin 1 0.10.3/01 06:36 10/03/01 AM 0.6:36 AM To: Rodney M. Cook/FirstEnergy@FirstEnergy cc:

Subject:

Cook/FirstEnergy@:FirstEnergy This is not good newsnews

                                                       ..... Forwarded
                                                      **.*. Forvvarded by Mark A. McLaughlinFTEiFirstEnergy on 10/03/01 A. MbLaughlinlTEfFirstEnergy                   06:30 AM -----

10.10.310. 1 0.6:30. ..***

                                                 . 'R.
                                                   "R. A. Mattson'; <rmattson@structint.com>

A. Mattson'; 10/02/01 05:53 PM .

                                                                        <rmattson@structint.com> 10/0210.1                              To: "Prasoon Goyal" <pkgoyal@firstenergycorp.com>,

Goyal" <pkgoyal@firstenergycorp.com>. "Mark McLaughlin". <mmclaughlin@firstenergycorp.com> cc: "Nat McLaughlin"<mmclaughlin@firslenergycorp.cOJl1> Cofie" <ncofie@structint.com> Colie" <ncofie@structint.com>

Subject:

We have done some some checking checking on the gap calculation, calculation, and two of the nozzles nozzles may not have gaps. We will continue checking, but II thought I would tell you this this prior to your NRC call tomorrow tomorrow so that you don't mis-.state mis-state where where we are at. U.S. NRC u.s. In re In NRC DAVID GEISEN.} re DAVID if ,,-.ff GEISENL&t _80M r' 50 edIIbIt ,._____ O _ Docket*, 1A-05-052 Docket# 1A-05-052 . Date Martced'for Date Marked-for IDJJ:JIi. IDL/. 2008 (Tr. (Th p.a.Z5

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RA-SC~l73-Davis Davis Besse Conference Call: BesseConference Call: 10/3/2001 101312001 NRR--W. NRR Bateman, S. W. Bateman, Sanders, A. S. Sanders, Hiser,A. A. Hiser, Lee, J.J. Zimmerman A. Lee, Zimmerman Region III - Jacobson, Holmberg, Collins Region III(See Licensee - Jacobson, attachedHolmberg, included Guy Collins Cambell - Site VP) Ucensee (See attached included Guy Cambell - Site VP) Questionedthe NRR Questioned NRR scope of the scope theApril ofthe 2000 head April 2000 examinations. The head examinations. licensee stated The licensee that100 statedthat 100 percent of the head was inspected which included the CRD percent of the head was inspected which included the CRD housing to head interfaces. housing to head interfaces. However, for However, for 5-6 nozzles near 5-6 nozzles nearthe center of the center ofthe

                                                                     ~he head,       boric acid head, boric             from ORD acid from        CRD flangeflange leakage leakage precluded definitive conclusions that the CRD nozzle welds were not leaking. NRR
.precluded      definitive       conclusions       that   the   CRD      nozzle    welds     were    not     leaking.         NRR requested requested video tapes the video the             tapes of   of the            examinations and head examinations the head                                     nozzle by and aa nozzle        by nozzle       listing of nozzle listing        of inspection inspection results/conclusions. Licensee:

results/conclusions. Licensee to provide this to provide this to NRR by to NRR October25th. byOctober 25th. Ucensee has Licensee estimated aa crack has estimated growth rate crack growth based on rate based on the Peter/Scott model the Peter/Scott model which predicts that Which predicts that -it will take 7.5 years to reach a structurally limiting circumferential flaw size after first detecting it will take 7.5 years to reach a structurally limiting circumferential flaw size after first detecting leakagearound leakage around the the CRDM housing. This CRDM housing. information could This information could be available to be available tothethe NRCNRC inin aafew few weeks. weeks. . NRR stated NRR that ifif the stated that the April inspectionwas 2000 inspection April 2000 considered "a was considered "aqualified" inspection by qualified" inspection bythe thestaff, staff, that the maximum acceptable operating time based on staff that the maximum acceptable operating time based on staff analysis is 18 months. The staff's analysis is 18 months. The staff's analysis assumes analysis assumes that circumferential flaw pre-existing circumferential that aa pre-existing less than flaw less than 165 degrees inin extent 165 degrees extent grows grows an additional 165 degrees in18 months. The staff analysis is based on Oconee data with an additional 165 degrees in 18 months. The staff analysis is based on Oconee data with input input from from an an expert expert panel documented by review documented panel review RES. The by RES. The staff position and staff position analysiswill and analysis will be be documented in documented NUREG with in aa NUREG with an indeterminate issue an indeterminate issue date. date. The licensee noted The licensee noted thatthat growth growth rate is dependant on CRDlocation (residual stress is greater at periphery rod housing welds) rate is dependant on CRD location (residual stress is greater at periphery rod housing welds) and that and that an inspection was unqualified inspection an unqualified done at was done Oconee in at Oconee in the However, the past. However, the past. the licensee licensee intends to

intends review the to review the NRRNRRstaff analysis basis staff analysis basis in detail with more detail in more support from with support their contractors.

from their contractors. Licensee is Licensee is pursuing through the approval through pursuing approval company board the company board of directors for of directors vessel head for vessel head replacement in RFO -14 (next outage after RFO-13 replacement in RFO -14 (next outage after RFO-13 scheduled for April 2002). scheduled for April 2002). informed the NRR informed NRR licensee that the licensee they do that they intend to not intend do not to let let this drag out. issue drag this issue out. Based Based on on NRR NRR analysis operation beyond analysis operation beyond 18 months could 18 months could result result inin operation with structurally significant flaws operation with structurally significant flaws and therefore the staff will continue to pursue and therefore the staff will continue to pursue regulatory actions. regulatory actions. UJ.S.M ?RC u.s. NRC /f' f' f c- n

                                                                                           ~m
                                                                                          )n   18 DAVIO DAVID GM    GEISEN 'J 1 v..tt 84            acNtJIt t2I d-....

Do"k # IA-05-052 DocMet.,A-0H52 17)0 ~ S* Date Markedior ID~ 2008 ('. (Tr. ~_,L) DOCKETED DOCKETED Dete Matiedor lDU 2008 USNRC USNRC DeW Offered in Date Offered in Ev: I ~/g .2008 Ev: 1.19 2008 (Tr. P.~) (Tr. P. -) September 9, September 2009 (11:00am) 9, 2009 (11 :OOam) lhrough witnesslpanel:_...J,~~/4}~ Thmu Witnessi/P anL ____ 4*LL - OFFICE OF OFFICE SECRETARY OF*SECRETARY Action: Ag Actiom: ~ REJECTED WITH~)RAWN REJECTED WITh)RAWN RULEMAKINGS AND RULEMAKINGS AND ~\4L.2008 I-. I 2 , (Tr. p. (fr. p. 8Zlr.) ADJUDICATIONS STAFF ADJUDICATIONS STAFF OS' O~

           "L---                             L-t 1 AS/,**--

7 5 Q _ 2. Exhibit 181 Exhibit 181

                                                                                                         , Page 11 of Page           of 55 Pages Pages           NRC001 -0571 NRCOO,1-0571

lQ/Q2/2001 TLIE 10/Q2/2001 Tt~ 20:29 20:29 FAXFAX 419 419 321 321 8138 8138 SYSTEM SYSTEM ENGRG ENGRG 60oo1 141001 . .l-" .

    .'                                                       Discussion Discussion Agenda Agenda DBNPS Bulletin Bulletin 2001-01 2001-01 Response

Response

Conference Conference Call October October 3, 3, 2001, 2001, 9:30 9;30 a.m. a.m. BACKGROUND: BACKGROUND: a* DBNPS DBNPS is is 3.1 3.1 EFPY from ONS-3 EFPYfrom ONS-3 as as of of March March 2001 2001 0 Additional II Additional 0.250.25 EFPY EFPY from 12/31/01 12131/01 to March 2002 (13RFO): (13RFO):

                              --  Margin Margin of 2 EFPY EFPY Remains Remains II   Qualified Qualified Visual Inspection Inspection to be     Performed During 13RFO be Performed              13RFO ONGOING ACTIVITIES SINCE ONGOING                            SINCE BULLETIN BULLETIN RESPONSE:

RESPONSE

                    " SIA II   SIA Plant-Specific Plant-Specific Finite Element        Analysis for ElementAnalysis      for: Nozzle  Gaps Nozzle Gaps
                   *" Video Video Inspection       Review from HF01 Inspection Review              RFO10,     RFO11, , and RFO 12:

0,* RF011

                              --  Further Further confirmation confirmation of no indication indication of leakage leakage attributable attributable to CRDM Nozzle leakage; clearly NozzJeleakage;         clearly CRDM flange leakage leakage
                  -*      SIA    Plant-Specific Fracture Mechanics SlA Plant-Specific                   Mechanics and Allowable       Crack Size Analysis Allowable Crack          Analysis M Review North Anna-l, CR-3, TMI-1 , Surry-1, and ONS-3 fall outage results
  • Review North Anna-1 CR-3) TMI-1 ,Surry-1, and ONS-3 fall outage results J

for applicability applicability to DBNPS, DENPS, including including lessons-leamed lessons-learned

                  -* Actively evaluating evaluating RPV head Replacementduring Replacement during RF014 RF014 ALARA ISSUES FOR SHUTDOWN         SHUTDOWN BY 12/31/01: 12131/01:
                 ** Personnel Personnel Dose for 2 inspections inspections (12/01 and 03102) 03/02) t.:.'.i(;~~:
       *' **V            -Additiona[Radwaste Generation for 12/31/01 shutdown and restart
                        -AdditiQoarlFBaawasteGeneration s-,

6/o

                                                                                                                      \'Ii.

NRCOOI-0572 NRC001-0572

10/02/2001 10/02/2001 TUE 20: 29 FAX TIlE 20:29 FAX 419 321 8138 419321 8138 SYSTEM ENGRG SYSTEM ENGRG Z002 I4J 002

              .. y.

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DAVIS-BESSENUCLEAR DAVIS-BESSE NUCLEARPOWER POWERSTATION STATION CONFERENCECALL PLANNEDCONFERENCE PLANNED CALLPARTICIPANTS PARTICIPANTS BULLETIN2001-01 BULLETIN 2001-01RESPONSE

RESPONSE

October 9ctober 3, 2001 3,2001

                                                                     .9:30 AM
                                                                      . 9:30AM Davis-Besse Davis-Besse StevenMoffitt, Steven                            Technical Services Director-~Technical Moffitt.Director                 Services DavidGeisen, David       Geisen. Manager Manager- - Design  BasisEngineeing DesignBasis    Engineerjng DavidLockwood, David                               Regulatory Affairs Manager-.-'Regulatory Lockwood,Manager                        Affairs Scott   Coakley,    Manager    - Outage Management Scott Coakley, Manager- Outage Management MarlcMcLaughlin, Ma&                               Manager-1600 ProjectManager McLaughlin.Project               - 1600 PrasoonGoyal, Prasoon               Senior NuclearEngineer Goyal, Senior   Nuclear  Engineer Miller, Supervisor Dale Miller, Dale                             Compliance Supervisor--Compliance Rod Cook, Rod              ComplianceEngineer Cook. Compliance       Engineer Wuokkot Supervisor DaleWuokko, Dale                               Licensing Supervisor-.~Licen5ing Framatome ANP Framatome         ANP Alvin AlvinMcKlmMcKim SreveFyfitch Steve      Fyf'rtch Doug Killian Doug       Killian NRC001 -0573 NRC001-0573

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           .3tlW USfNRC     NO. 449       P.5 NO. 449       P.S tot., *A. ->        _,*. <,,
      £                              I-i,
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DOCKETED C- ~ USNRC September 9, 2009 (11:00am) September (11 :OOam) OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS AND ADJUDICATIONS ADJUDICATIONS STAFF STAFF From: Mark A. McLaughlinlTEfFirstEnergy McLaughlin/TEIFirstEnergy To: Andrew J. SiemaszkolFirstEnergy@FirstEnergy, Andrew WilsonITElFirstEnergy@FirstEnergy. SiemaszkofFirslEnergy@FirstEnergy, Andrew S. Wilson/TE/FirstEnergy@ FirstEnergy, Bradley J. BaumgardneriTEiFirstEnergy@FirstEnergy, Daft/TE/FirstEnergy@ FirstEnergy, Frank W. BaumgardnerlTEiFirstEnergy@ FirstEnergy, Charles T. DaftfTElFirstEnergy@FirstEnergy. Kennedy,TE/FirstEnergy@FirstEnergy. Kennedy/TEiFirstEnergy@ FirstEnergy. James James A. KalmbachiTEiFirstEnergy@ Kalmbach/TEiFirstEnergy@ FirstEnergy, Melvin Melvin D. D. HurleyrTEfFirstEnergy@ HurleyITEiFirstEnergy@ FirstEnergy, FirstEnergy, Prasoon K. Goyal/TE.FirstEnergy@ FirstEnergy, Rodney GoyaliTEiFirstEnergy@FirstEnergy, Rodney M. M. LeMay/TEiFirstEnergy@FirstEnergy, Terry A. CookiFirstEnergy@FirstEnergy. Thomas E. LeMayITEiFirstEnergy@FirstEnergy. Cook/FirstEnergy@FirstEnergy, A. T abbi3rt1FirstEnergy@FirstEnergy, David JJ.. JakseticiTEiFirstEnergy Tabbert/FirstEnergy@IFirstEnergy, @FirstEnergy, William JakseticfTE/FirstEnergy@FirstEnergy, William D. Hilkens/FirstEnergy @FirstEnergy Hilkens/FirstEnergy@FirstEnergy cc:

Subject:

FW: Photo of the Crystal River VHP indication indication Date: 13:37:491010 10/3/2001 13:37:491010

      • .* Forwarded-Forwarded Mark A.

by Mark McLaughlin/TEiFirstEnergy on 10/03/01 12:41 PM A. McLaughlinlTEfFirstEnergy PM-.**** Prasoon K.K. Goyal To: Mark A. McLaughlin.Te.:: McLaughlin;TE. = 10/03/01 01:20 PM 10/03/0101:20 FirstEnergy Daft/-E/FirstEnergy @FirstEnergy DaftfTElFirstEnergy@ cc: GeiseniTEF;rs:E David C. Geisen/TEFirs:~ Swim/TE/FirstEnergy@ FirstEnergy, Scott SwimfTEiFirstEnergy@FirstEnergy. Scott A. Coakley/'FEFirstEnergy @ A.CoakleyfT5FirstEnergy g FirstEn-ýe Firstl=~e'

Subject:

FW: Photo of FW:Photo of the the Cr'is~a: Cr.sa: : FYI. FYI.

.**.* Forwarded-Forwarded by Prasoon K. GoyallTE/FirstEnergy on 10/03/01 01:15 K. Goyal/TE/FirstEnergy                      PM -----

01: 15 PM .***. greg.gerzen @exelon greg.gerzen@exelon corp.com corp. com To: scott-boggs @fpl.com. b,r scott_boggs@fpl.com, b'- Richard. Labott@PSEG.com, dspond@entergy.com, Richard.Labott@PSEG.com, GMOFFATT@scana.com. dspond@entergy.com. GMOFFA IT@scana.com. 10103/01 12:40 10/03/01 12:40 PM LKMATHEW @southernco.com, pkgoyal 0firstenerg', KMoore @framatech.com. LKMA KMoore@framatech.com. THEW @southernco .. com. pkgoyal@firstenerg, SFyfitch @framatech.com, teherrmann@cal.ameren.com, SFyfitch@framatech.com, vaughn.wagoner# pg: teherrmann@cal.ameren.com. vaughn.wagoner@pg* cc: cc:

Subject:

FW: Photo Photo of the Crystal -; U.S. In re in NRC U.S. NRC m DAVID GEISEN)V, AID GElSEN I

                                                                                                               ~ J.      f\t 1Vlt' t~ ExhIbIt.,

Exihbkt#2. 5 ~

  • .ri Oockst # 1IA-05-052 Docket A-05-052 .'

G::-eg :::;e::-zen Greg 7erzen Date Marked Marksdfof for 10: ~/"i ID: I z. 2008 (Tr.p. 200 (Tr. gZS

p. ŽL-Ev: ~

Nuclear Exel-on :-;1...!.clear 2xe2..*~:-:.

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Through w~anet: Thirough *wREnkE~zL. ,ttl jt:- emaii - Greg.Gerzenaexeioncorc.cc-e~ail Greg.Gerzen@exelo~co:;.cc~ Action: ~ A~TdREJECTED REJE~ WrrHCAAWN W13NORAWN

 >             Original.Message---
      -----Ori~inal   ----- Message---~- .-                                                     L 2 O(PZ-'~

f2'-te Date: J1:j..L.2008 (rio'. p. ~0Lr )

 >   ?ro~:

From: Gerzen, Greciorv Gerzen, G::-egory S.S. Sent:

 > Se~t:              Nedr:.esday, Oczober Wednesday,       Oc;:ooer 03.03, 2001 11:33          AM1 11:33 A.J.'
 > To: Bohlke,            William :!.;

Bohlke, 'thlliam Xeei.szer, James R..; H.; :*:e::'s;:er. Warner, Mark R.; 'tlar:-:er, Gesior, Roman Mark E; Gesior, Ror:-.ar: A.; Kramer, Jack; Oliver, Bradley

 > i\.; :<::-amer, Jac:c; 0:" i','e::-, 3::-adley S.        S.

S14D-015786 5140-05786

                                                                                     'xc.ro~
                                                                                      *)U       Exhibit 184 Tý_ý
  • 0L A-FE -i -

l) Exhibit 184 Page 1 of 4 Pages NRC002-0427 NRC002-0427

     > S'Tbect:                 Photo
                                ?ho-:o of          0: ~he the Crystal C::-ysta! Ri-:er           74? indication
                                                                               ?:..-;e:- '.":-!?   :"::dicat:..orr
     " Here
        ",e::-e     .s
'5 The Crystal
e C::-ys::.al River Ri';er vessel vessel hed ::02 -j penetration (CRDM) pe:;.e~:-ation (CRDM) indicanion.

i::dicati.o:1_

     >    <<C<>S*aL                9 m'.er czrn32_ l.jpg>>
     "    <<:::-.:.:::;:=': ?:.-:e::- ::::::-:::,32_1. jpg>>

Greg e

     > =::-:e l.o:"'~ : :*..:.c::" -::"::::-
        *hone P            630-657-3345
      > ?::c~e 63Q-657-33~~

Pager 530-307-5124

      >?age::-       '530 -3 0-512 4,
     > enail e~ai: -- Greg.Gerzen"e-'eloncorp.ce=

G::-eg_(;e::-::er:~e:<elor;corp_co::-. This

     '::tis e-maiI e-:r.ail and      ar:d any      any of    of its its attachments attacl"_'!'.en::.s may
'.8.y contain contain Exelon Exelon Coroora:ion Co::-po::-a::ior:

proprietary proprietary information, i,.fo::-ma::'ion, which which is is privileged, pri'Jileged, confidential, confidential. or or subject subjec::. to to copyright copy::-:'g::'t belonging belorrgi:-:g to to thethe Exelon Sxelor_ Corporation Corporation family :amily of of Companies. Companies_ This T~is e--ail e-:t.ail is is intendedi:1tended solely solely for for the::.:'e use

                                                                                           .:lse ofof the the individual individual or  or entity e:1tit:,r
0 which to -",hich it it: is is addressed.

addressed. If IE you you areare not :lot the the intended intended recipient recipient of h of:::::"s e-mail, e-r;:ail, you yoU are are hereby he:::-eby notified notified that that any any dissemination, dissemi:;.ation, distribution, dist::-ibutio::., copying, copyi:;.g, or or actionac'.:ion taken taken .in .i:1 relation relatim: to to the the contents contents of of and and attachments attac~-::e::::s to this e-mail is to thi.s e-mail is stricc:ly prohibi::ed and strictly prohibized and mayrr.ay be be unlawful. unlawful. If If you you have

-.a-ie received this e-mail in error, please received this e-mail in error, please notify the sender irr~ediately and notify the sender immediately and permanently per:nanen::.ly delete delete -he the original original and a:-:d any ar.y copy copy of of this this e-mail e-mail and and any a::y orintouz.

p:-i:1tou::.. Thank Than~ You. You,

                                   ,  ,I, ".-:' ~:\ .',  "'.' ,"

S14D-05787 5140-05787 NRC002-0428 NRC002-0428

\. From: From: Mark Mark A.A. McLaughlintTEiFirstEnergy McLaughlih/TEiFirstEnergy To: Andrew Andrew J. J. SiemaszkoiFirstEnergy@FirstEnergy, SiemaszkoiFirstEnergy@FirstEnergy, Andrew Andrew S. S. Wilson/TE/FirstEnergy@ FirstEnergy. Bradley WilsonfTE/FirstEnergy@FirstEnergy, Bradley J. J. BaumgardnerFTEiFirstEnergy@ BaumgardnerfTEiFirstEnergy@ FirstEnergy, Charles T. FirstEnergy, Charles T. Daft/TE/FirstEnergy@ FirstEnergy. Frank DaftfTEiFirstEnergy@FirstEnergy, Frank W. W. KennedypTEFirstEnergy@ KennedyiTEiFirstEnergy@FirstEnergy, FirstEnergy, James James A. A. KalmbachfTE/FirstEnergy@FirstEnergy. KalmbachfTEiFirstEnergy@ FirstEnergy, Melvin Melvin D.D. HurleyrTE'FirstEnergy@FirstEnergy, Prasoon K. GoyalfTE/FirstEnergy@FirstEnergy, HurleyfTEiFirstEnergy@FirstEnergy, Prasoon K. GoyalfTEiFirstEnergy@FirstEnergy, Rodney Rodney M. M. Cook/FirstEnergy@ FirstEnergy. Thomas CooklFirstEnergy@FirstEnergy, Thomas E. E. LeMay/TE!FirstEnergy@ LeMayfTE/FirstEnergy@FirstEnergy, FirstEnergy, Terry Terry A.A. Tabbert/FirstEnergy @.FirstEnergy, David TabbertlFirstEnergy@FirstEnergy, David J. J. Jaksetic/TE/FirstEnergy @ FirstEnergy, William JakseticfTElFirstEnergy@FirstEnergy, William D. D. HilkensiFirstEnergy @ FirstEnergy Hilk.ensiFirstEnergy@FirstEnergy cc: cc:

Subject:

Subject:

FW: FW: Photo Photo of of the the Crystal Crystal River River VHP VHP indication indication Date: Date: 10/3/2001 10/3/2001 13:37:491010 13:37:491010

  ----- Forwarded    by by Mark Forwarded-----  Mark A. A. McLaughlin/TEiFirstEnergy McLaughlinlTE/FirstEnergy on       on 10/03/01 10103/01 12:41 12:41 PM- PM .----

Prasoon Prasoon K. K. Goyal Goyal 10/03/01 01:20 PM To: To: Mark Mark A. A. McLaughlinTE. McLaughlin,T:=:. ~ 10103/0101:20 PM Daft/TE/FirstEnergy@ DafVTElFirstEnergy@ FirstEnergy FirstEnergy cc: cc: David David C. C. GeiseniTEFirs:E GeisenITEFirs:~ Swim/TE/FirstEnergy@ FirstEnergy, Scott SwimITEiFirstEnergy@FirstEnergy, Scott A. Coakley/TfEFirstEnergy @FirstfEýe' A.CoakleyIT5FirstEnergy:@ FirstE~e'

Subject:

Subject:

FW: FW: Photo Photo ofof the the Cry sta: :: Cry5!a: FYI. FYI.

   ----- Forwarded  -Forwarded by by Prasoon Prasoon K. K. GoyalTE/FirstEnergy GoyaliTEIFirstEnergy on     on 10/03/01 10103/01 01:15 01: 15 PM     -----

PM----- greg.gerzen @exelon greg.gerzen@exelon corp.com corp.com To: To: scott.boggs @fpl.com. b,r scott_boggs@fpl.com. blr Richard.Labott@PSEG.com, Richard. Labott@PSEG.com, dspond@entergy.com, dspond@entergy.com, GMOFFATT@scana.com. GMOFFATT@scana.com. 10103/01 12:40 PM KMoore@framatech KMoore@framatech.com. .com, LKMATHEW @southernco.com, pkgoyal Q firstenerg', LKMATHEW@southernco.com.pkgoyal@firstenerg't. SFyfitch @framatech.com, teherrmann@cal.ameren.com, SFyfitch@framatech.com. teherrmann@cal.ameren.com. vaughn.wagoner vaughn.wagoner@pg.*O pg-cc: cc:

Subject:

Subject:

FW.: FW: Photo Photo of of the the Crystal Crystal -; Greg 3erzen G::-eg::;e::-zen Exe2.D.r 2ze~G:: )uclear

                ):I..!cl-ear Phone
    ?~o~e.30-657-3845 630-657-3845 Pager Page::- 630-307-5124 630-307-512~

emaiL ecail -- Greg. Gerzenaexeioncos,.cc-. Greg.Gerzen@exe1o~co=;.cc~

    >S---.--    Original Message
        ---~-Origina1                       -----
                                 ~essage-----
   >> From:
        ?rom:            Gerzen,       Gregory Gerzer., G::-egory S.5.
   >> Sent:

5e::t:: Wednesday,

                         \'ledr..esday. Oczober Occober 03,     03. 2001     11: 33 AM 2001 11:33        .A.'1
   >> To:

To: Bohike, Bohlke, William ~.; Xeister,

                             *.-Ji11iam ?t.;        :*:e:'s:::er. James James R.;R.; Warner,
                                                                                     'i'Ia!:"::er, Mark Mark E;E; Gesior, Gesior, Roma-Kor..ar:.
   >> A.;

fl..; Kramer,

               !<ramer. Jack.;

Jac~; Oliver, 0: :.*..e:::. Bradley 3radley S.5. 86 S14D-057 5140-05786 Exhibit Exhibit 184 184 Page Page 11 of of 44 Pages Pages NRC002-0427 NRC002-0427

0 SSub~ezt: hoto of :he Crystal Ri.'er V:HP indication

> -e.e ~s

>::e:-e

s :.:::e
     > <<*'SPa the C:-ys:;al Crystal ih'/er
                        *=.er River vessel vessel-et cr, ý32_l.Jpg>>
e*j pe:;.e~::-ation penetration (CRDMI (CRDM) i::dicacio:1.

indication. 0 > <<::--,':3~:::'  ?: __ :e:- ~:-.::::,32_1. jpg>>

> Greg      Ier-e:
> ::::(elo:-,

Ex..elon :;-..:.c:'.:::,:::-

ula 6 3
                   -65 7 ,5 Phone 630-657-33~5

>> ~hc~e

> :Pager      603752

> :?age~ S30-307-S124 email- - Greg.Ger=e~~exeloccorp.co~ >> e~ai: Greg.Gerzengexeloncorp.com This e-:r.ai1 '::tis e-mail ar.dand any of its its ::tttacl'~'T.en,:s attachments ;::>.aymay contain contain Exelbn Exelon Corporation Corpora::ion proprietary ir.forma::ion. proprietary information, which is is pri'Jileged. privileged, confidentiaL confidential, or subject: subject copyright belongi::gto to copy;:,':'g::t belonging to the .=:xelon Exelor. Corporacion Corporation :amily family of Corr.panies. Companies. e-mail is This e-:r.aE is intended solely fo;:' for ':he use of the individual zhe :lse en!it,/ individual or e!1tity which it to ~hich it isis addressed. addressed. If you are not the intended recipient IE recipient of :histhJs e-mail,.* you e-r..aL! you are hereby notified zhat any dissemination, notified ;:1-:a;: dissemination, discributio~. distribution,

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relation to the contents contents of andattac:-,,..::e::::s and attac"ýments to this e-mail is is scrict::!.y strictly prohibited prohibi:;ed and rr.ay may be unlawful. unlawful. If If you have

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error, please notify notify the sender sender itr.reediately inmrediately ar.d and permanently permanen:;ly delete delet.e the original original and any aroy copy of this e-mail and ar.¥ any orinzout. printout:. Thank Than~ You, You. 5140-05787 S14D-05787 NRC002-0428 NRC002-0428

Job Name:

  • ORGAN_80957_CD03_ROD_COOK_NOTES ORGAN~80957 _C D03_RO D_COOK_NOTES Internal Unique 10:

ID: 068 File Path:

 \\dctsfs05\blowback\Morgan\80957\CD03
 \\dctsfs05\blowback\Morgan\80957\CD03
 \ROD_COOK_NOTES\crdnos\00000001
 \ROD_COOK_NOTES\crd_nos\00000001
 \0000000039\Crystal River crdm32_1.jpg*
 \0000000039\Crystal       crdm32_1.jpg S14D-05788 5140-05788 NRC002-0429 NRC002-0429

S14D-05789 514D-05789 v NRC002-0430 NRC002-0430

ý A-S C- r7-ý( DOCKETED DOCKETED USNRC USNRC September 9, September 9, 2009 2009 (11:00am) (11 :OOam) OFFICE OF OFFICE OF SECRETARY SECRETARY RULEMAKINGS AND RULEMAKINGS AND From: From: Prasoon K. Prasoon K. Goyal/TEFFirstEnergy GoyalfTEiFirstEnergy ADJUDICATIONS STAFF ADJUDICATIONS STAFF To: To: David C. GeisenfTEiFirstEnergy@FirstEnergy GeisenrTEFFirstEnergy@FirstEnergy cc: Mark A. Mark A. McLaughlin/TE/FirstEnergy@ McLaughlinfTEiFirstEnergy@FtrstEnergy, Dale L. FirstEnergy, Dale L. MillerfTEiFirstEnergy@FirstEnergy, MilleriTE/FirstEnergy@ FirstEnergy, Dale WuokkofTEiRrstEnergy@FirstEnergy, Theo Dale R. Wuokko/TE/FirstEnergy@FirstEnergy, Thea S. SwimFE/FirstEnergy@ FirstEnergy SWimfTElFirstEnergy@FirstEnergy

Subject:

Oconee3

Subject:

Inspection Oconee3 Inspection Date: Date: 10/3/2001 14:7:141010 10/3/2001 14:7:141010 discussed OC I discussed DC 3 inspection inspection results with Dave results with Whitekar. He Dave Whitekar. chairman of the materias He is The chairman materias committe and committe and is involved involved with material material and and welding welding issues issues at all Duke nuclear at all plants. He stated nuclear plants. stated DC 33 last outage was that OC was in Spring Spring 2000. OC came down in Feb. 2001 DC 3 came 2001 to leaking valve to fix aa leaking valve problem. At that problem. that time they decided decided to inspect head and found a 165 degree inspect the head circumfer~ntial degree circumferential crack on on nozzle 56. II asked him why they missed the leakage nozzle # 56. detection on this leakage detection nozzle in this nozzle in the the spring of 2000. He He said there were two reasons 1) they did not know what they were looking know what looking for ( quantities of boron sitting on they were looking for large quantities on the head) and 2) the head was was notnot clean. I told him that NRCNRC thinks that there may be an existing 165 there.may 165 degree circ. plants which may circ. crack in plants have detected by the visual examination have not been detected based on DC examination based inspection. NRC estimated OC 3 inspection. estimated that it will take 1818 months allowable size which months for this size crack to grow to allowable which is 330 degrees. Therefore Therefore plants should plants qualified visual perform qualified should perform inspection after visual inspection every 18 after every 18 months. Duke had told NRC NRC several times several degree crack did 165 degree times that this 165 did not grow in one cycle. Also in one have taken would have Also itit would taken several cycles several cycles to grow to this size. Duke had also told NRC that NRC crack growh rate is on high NRC crack growh high side as compared

side indicated that we should continue challenging compared to the industry. Dave indicated challenging NRC crack crack growth rate.

Other information: Other discussing with Duke for one of their new planning to replace their head. TMI is discussing TMI is planning new heads. CR3 replacing their head. We should is also thinking of replacing should immediately get in line to order the new head head.... U.S. NRC U.S. In NRC ~ Ii. f'{ ttX ~ ExhtbIt#~....... c [j Inre DAVID GEISEN reDAVIDGEI 1A-05-052 ,/, Docket ## 1A.()5-()52 00ckBt J z,J ~ 0'2'--- Date Marked Dat Marked ftor ID for Io-~ , 2008 (Tr. (Tri p. p..~.~.2 ..)

                                                                                           ~.             11")9               (li gz~)).

Otfetr in Ev: Date QffeftKtIn

                                                                         .Date                    Er.~ 2008 (Tr.r. P               p.~       ,

1'Io.PnI.".. *wttnessIP.anal: *,,)1 Through IIh~~". Wtespni.4Lh-.--- "/ t;-, -- Action: A Mon: ' REJECTED WITHDRAWN REJECTED WITHDRAWN Date~ Date.0

                                                                                     ..
  • 2008 (Tr. p.

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SI4H-04106 S14H-04106

                                                                                                     ~~6J..----'

Exhibit 186 186 TP, QL AW~m~'6 Exhibit Page Page 1 of 1 of 11 Page Page NRC002-0111 NRCOO:~-0111

IcM (2- U.S. NRC ini DAVID wft.eL.ý Date Mailcedtwowr 200_M._p jE A~ion:REIJ jjD 1 WITHDRAWN~

                                                 )4 J.~2OO(Tr.D. 7 Date I

i DOCKETED I rA DOCKETED I. I USNRC USNRC September 9, 2009 (11:00am) I I September 9, 2009 (11 :OOam) OFFICE OF SECRETARY OFFICE OF SECRETARY RULEMAKINGS RULEMAKINGS AND AND ADJUDICATIONS STAFF ) ADJUDICATIONS STAFF GO 0

                                           .~,

i . I p.)'67--- Exhibit Page Exhibit193193 1 of 18 Pages Page 1 of 18 Pages NRC004-0815 NRC004-0815

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NRC NRC Bulletin Bulletin 2001,01, 2001 ~01,

                           . "Circumferential "CircumferenfialCracking                            Cracking of                       of Reactor Pressure Pressure Vessel Head Penetration                                         Penetration Nozzles" 3.~    .      .;.-;... .:.

3- ' Presenters: Presenters: ~:r 1i, Guy GuyG. G. Campbell Cam. "*Vic i F.ENO C ..~ 3 ,:1.-:...

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                                                                                                   .' a Reasonable Basis for Assurance Provide Reasonable                                             Assurance that Davis-Besse is safe *t operate Davis-Besse                   oPerate until next refueling                                                refueling outage (Mar~h,~?O (March 2Q0-                                ..jouldouldcontinue continue 24                24 month month opera operati.y. ., . c              K .                                . iI,         "      .
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fh-. Requests that. iq~.desig*n. vide design informati ...... . .,ous . us Inspection inspection results', '8 *. :: :. tw' . .' ....... p.l§lns

                                                                                           *.nplans base upon p fh- ~espons~;', '*                                                                    b~f~' upop plantlant rankln.Q_ In Susce                                       Sd ... .s.p'ubhshed           published In in EPRI 1\71 RP-48. . :~> . .<<
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             ~ Ranked Davis-Besse Davis-Besse .'as~ 7th out of 69 plants.
             ~~   6.6 actual EFPY,   EFPY ,,:pw                      .                   *nee                                nee* 3 but3.1EFPY      but 3.1 EFPY away after away   after normal.zii norrrl~' . ':' .9                          g ,o.      '    ..:
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           \There            is a reasonable isa         reasonable basis for Assurance                                                                           Assurance Davis-Besse is s.safe that Davis-Besse                                                         fe to operate based on deterministic and, deterministic                and .pr..btIc assessments until
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refuelin'~r:'.*-*' next refueling- " g02)- 2). .

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to the NEI Relatig Re ' e ** , ** _' e 29~::'::2'OO e29,'1" ,

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                                                                             ýPr*gram Response
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1991 *- Originally CRDM cracking was identified identified at Bugey Unit 3in 3 ýin France France June, 1993 - Safety Assessment Written by all three NSSS Owners Group (NUMARC) October,\J1994 October 1994 - NUREG/CR-6245, NUREG/CR-6245, "Assessment of Pressurized Water Reactor Reactor Control Rod Drive Mechanism Mechanism Nozzle Nozzle Cracking April, April. 1997 - NRC Generic Letter 97-01 "Dearadation "Degradation of Control Rod Drive Mechanism Mechanism Nozzle and Other Vessel . Closure Head Penetrations", was issued. Industry Industry Responded Responded with Probabilistic Rankings and head inspection plans. Electric.Power Research Institute (EPRI) -Crack G.~~wth 1997 - ElectricPower Growth and Microstructural Microstructural Characterization Characterization of Alloy 600 Vessel Head Penetration Materials, TR Penetration Materials, ..109136 (Propriet.. TR-109136 LJrn,\riot!!3'fl1 j . . June,}OOO Jun~ Re~ea!C.h lnstitut 2000 - Electric Power Research '. ro of Alloy 182 Weld Metal ininPWR Environments Environments (MRP-21) (MRt' 21)

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Leaki~g:N"O*:::~*~;IIe.**~ December, 2000 - One Leaking INonee .0colnee .. Leaking- i" 2001 - Nine Leaking' February, 2001- Oconee' :t "

                                                                                                                                                   ,~. I March, 2001-March,   2001- One Leaking N .zz. .                            mllf]Im.':TJl~~1
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April, 2001-2001 - Four Leaking Nozzes .afOconee~-2'*~ Leaking Nozzles at'Ocoriee.' :2 ,.*; .., '-':' .,£

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April 2001 - Framatome Apri12001- Framatome ANPANP:- RV Head:.N¢~l~aOa.\Xel~af~~-Assessment, Head: v*l*.'and Wel&Safety-Assessment, 51-5011603-01 51-5011603-01 (FTI ANP Proprietary) and 51-5012567-00 (Non-proprietary) {) 1-5012567-00 (Non-propnetary) .~. '.. ':'~:?".:;.:;?;,lij~~;".~j*~' ~" April 30, 2001 - NRC IN Ap'ril30, IN 2001-05, "Through-wall Circumferential Circumferential Crackin! Crac~in9 of Reactor Pressure Vessel Head Control Rod Drive Mechanism PenetraUon Nozzles Mechanism Penetration Nozzles at Oconee Nuclear Station, Unit atoconee Umt 3 May, 2001 - Electric Power Research Research Institute (EPRI) (EPRI) -- PWR Materials Materi~ls Reliability Program Interim Alloy 600 Safety Assessments for U.S,U.S. PWR Plants (MRP-44),(MRP-44), TP-1001491 TP-1001491,, Part 2

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June 29, 2001-2001 -EPRI EPRI-- PWR PWR Materials Materials Reliability Program Response to NRC Review Comments Transmitted Transmitted by Letter Dated June 22, 2001, 2001, to the NEI Relating to MRP-44(MRP-50) MRP-44 (MRP-50) August 3,3, 2001 --NRC 2001-01, "Circumferential NRC Bulletin 2001..;01, "Circumferential Cracking of Reactor Pressure Pressure Vessel Head Penetration Nozzles. August .19, 2001 --EPRI August.19,2001 EPRI-- PWR Materials Reliability Reliability Program Response to NRC Bulletin Bulletn 2001-01 (MRP-48), (MRP-48), 1006284 1006284 August 24, 2001 - Davis-Besse enters contract with SIA. September 4, 2001 - Davis-Besse responds to' Nf:.{!~tiIJllelm B -t00.1-01 September 28,o2001 24, 201EI..

                              .September   --NRR NRR ira  transmitsý yia.* *ee n                 .... t NEI.

September Dr. ian $ "l(QJ]~tf3leiCOn

                    ..September 28, 2001 -- Dr.a;rian~n.~              I                          R       Saunders urging fall inspection at Davis-S Besse                      :'. :' . . >* "',                                     .   -.        :.
  • October 3, 2001 -:NRR confererl ith Davis.- to undertarid.NRC Bulletn 2001-01, October 3, 2001 -NRR con:terelnc,ef~au!WI Cracking of "Circumferential Cracking ReactorF...,~OQQIiI~!*"~.l~

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RV HEAD INSU1.A.TION INSULATION SERVICE STRUCTURE STRUCTURE CRDM NOZZLES THERMOCOUPLE NOZZLE-THERMOCOUPLE NOZZLE-(ONS-1 AND TMI--1 TMI-1 ONLY) ONLY) SUPPORT SUPPORT STEEL ACCESS* HOLES 8 OR 9 ACCESS HOLES IN SERVICE STRUCTURE IN STRUCTURE SUPPORT (ONS-1, (ONS-1, ONS-2, ONS-3, CR-3, AND TMI-1 TMI-1 ONLY) ONLY) 18 18 ACCESS OPENINGS OPENINGS 2" 2" MIN GAP BETWEEN "MOUSE-HOLES" "MOUSE-HOLES" ALL TOP INSULATION AND TOP B&WOG PLANTS B&WOGPLANTS / OF RV HEAD I I z FENOC

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                   /    ,ý- I                                         ,.

iNak Circular Circular Cracks Cracks - e Cracks - Axial Cracks Axial (I Flange Leaks Leaks ....... :..... Lifting Lug Lftng LugTo (3 Total)/ Total) in 12RFO -- kinl12RFO (..... ")

                                                      -*'.0'.***

CRDM Nozzles Nozzles (69 Total) Total) Structure Service structure Service Support Flange z FENOC

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I-DOCKETED USNRC USNRC F/ý-s C--ý ? R2 U.S. U.S. NRC In re In NRC re DAVID DAVID GEISEN GEISEN 51It\ tt N' exhibit ,_ Exhbkt #

                                                                                                                                      *S { _
                                                                                                                                          \.0 I'Mv~kt a 1A.Nr-,-tIK September 9, 2009 September       2009 (11:00am)

(11 :OOam) Docket # 1A-D5-052 . OFFICE OFFICE OF SECRETARY SECRETARY RULEMAKINGS RULEMAKINGS AND AND Commission Tehna CommIssion. Asstant E Tech leal Ass' n IStant E Date Marked Date Marked for ID 10'~ 4 d Jv 2008 (fr. p. 2008 (Tr. p. 825- . ) ADJUDICATIONS ADJUDICATIONS STAFFSTAFF October 11, October 11 t 2001 Date Offered Date Offered in Ev:Ev:~, .. , 2008 2008 (Tr. (fr. p...2 p.jj}G> ( )

Introduction:

WrtnesslPanel:~cJ~/P.~ Through Witness/Panel: .4aI/ _ _ _ _ _ __

Introduction:

                                                                             ~                   ;

Action: Action: A[ A~ ITT REJECTED WITHDRAWN WITHDRAWN On October 11,2001, October 11. 2001, members management team provided

                                              ~e FiretEnergy members of the    Fi~rgy Nuclear Nuclear O the Commission Tec O~ Date:

Tee t.o, I ~I

                                                                                         ~

r=-, 2008 2008 (Tr. (Tr. p. 8w ) ) management provided a briefing to the Oavis-Besse position related to NRC Bulletin Davis-Besse 2001-01, "Cirun,,i,,,uLiI Bulletin 2001-01, "Clrcunm:mmm:u %ajiCKrng vraCKmg OT OJ ieactor Meaaor Pressure Vessel Head Pressure Head Penetration Penetration Nozzles: attendees are Nozzles." The attendees are listed isted in Attachment. in the Attachment. meeting objective FENDe'S stated meeting FENOC'S objective was to provide reasonable basis for assurance provide aareas'Onable assurance that Davis-Besse is Besse Is safe to operate operate until the next next scheduled scheduled refueling refueling outage March 2002 and that the outage in March the plant should plant should continue continue on 24 month month operating operating cycles. PosItions: Plant-Specific Positions: Plant-Specific FENOCprovided FENOC provided the following positions Identified Identified during their review of the bulletin:

  • All All CRDM CRDM penetrations penetrations werewere verified verified to be free from the characteristic characteristic boron deposits deposits using video recon;lings recordings from the previous 2 refueUngoutages.

refueling outages. Theseyvideos These ,videos were made made before and after cleaning cleaning the head.

  • Plant speCific Plant element analysis shows specific finite element shows that *65 65 out of 69 penetrations penetrations will open up sufficiently Indication.

sufficiently to provide visual indication. .

  • remaining four CRDM penetrations The remainingfourCRDM penetrations are located located in the lowest stress area. No No circumferential cracks have -been circumferential identifilKf at other been identlflf other plants In in this .region (Top of the the head). .
    *        "TheDavis-Besse The   Davis-Besse critical crack size is 273 degrees. That includes a safety factor of three in accordance accordance with the ASME  ASME code. -
  • Davis-Besse haS has a better as-built record of their head head and the interference interference fits than other plants. .AsAs such, Davis-Besse Davis-Besse has done done more and better better quality inspections than other plants.

Analytical Assumptions: Analytical analyzed potential.cracking. Given these positions, the licensee analyzed potential cracking. They determined that, by conservative analysis, a potential crack would not grow to critical crack size before their next refueling outage. The following assumptions utilized. assumptions were utiflzed:

    **       An initial crack size of 180 degrees at the beginning of Cycle 12 (1998). This crack was not identified hiifi either of the next 2 visual inspections;
   **                     propagates in two directions:

The crack propagates directions;

  • Industry accepted crack growth rates rates for Alloy 600 are applicable; and
  • No credit was given for decreasing stresses as the crack grows.
                                                                                                         $--37 D~62-Exhibit 194 194
                ?~L                  A~7~z~                                                 Page 1 of 4 Pages             NRC004-1782 NRC004-1782

" -- I Lolz-'Oo3c7 Commission Technical AsslstantAssistant Briefing Briefing October October 11,11, 2001

Introduction:

Introduction:

On October 11, 2001, members of ~e 2001, members ArstEnergy Nuclear the FirstEnergy Operating Company (FENOC) Nuclear Operating (FENOC) management team provided a briefing to the Q,rnmlsslon management Technical Assistants regarding the Commission Technical the Davis-Besse position position related to NRC .Bulletin 2001-01, "Circumferential Bulletin .2001-01, uCircumferential Cracking of Reactor Pressure Vessel Head Penetration Nozzl~." attend~es are fisted Nozzles." The attendees listed in in the Attachment. FENOC'Sstated FENOC'S stated meeting objective objective was to provide provide a reasonable reasonable basis for assurance assurance that Davis-Besse Is safe to operate aperate.until until the next scheduled refuefing refueling outage in March 2002 and that the the plant should continue on 24 month operating operating cycles. Plant-Speclflc positions: Plant-SpeciflePositions: FENOC provided the following positions Identified FENOCprovided Identified during their review of the bulletin:

  • All CRDM penetrations penetrations were verified to be free from the characteristic characteristic boron deposits deposits using video recon;Jings recordings from the previous 2 refuefingrefueling outages. These videos were made before and after cleaning the head.

cleaning .the

 **        Plant specific specific finite element analYSis analysis shows that 65 out of 69 penetrations penetrations will open upup sufficiently sufficiently to provide visual indication.

indication.

  • The remaining four CRDM penetrations penetrations are located fnthein the lowest stress area. No No circumferential circumferential cracks have*been IdentifllKlat havebeen identifbd at other plants In plants in this region (Top of the the head).
  • Davis-Besse critical crack size is The Davis-Besse includes aa safety factor of is 273 degrees. That includes three in three accordance with the ASME code.

In accordance

  • Davis-Besse has a better as-built as-built record ofthefr of their head and the interference interference fits than other plants. As such, Davis-Besse has done done more and better quality inspections inspections than otherpJants.

other plants. Analytical Assumptions: positions, the licensee Given these pOSitions, licensee analyzed cracking. They determined that, by analyzed potential cracking. conservative analysis, conservative analysiS, aa potential crack would not grow to critical crack size before their next refueling refueling outage. The following assumptions were utilized:

  **       An initial crack size of 180180 degrees at the beginning beginning of Cycle 12 (1998).

(1998). This crack was not identified if either identifiediti either of the next 2 visual inspections; visuallnspedions;

  **       The crack propagates propagates In  in two directions; directions;
  **        Industry accepted accepted crack growth rates lor     for Alloy 600 are applicable; and
  *°       No credit was given for decreasing stresses as the crack grows.
                                                                                                   $-37 Exhibit 194 Exhibit   194 Page 1 Page    1 of of 44 Pages Pages     NRC004-1 782 NRC004-1782
                                                                                                                          \

o ficensee also presentee The licensee presenteti their vendor-specific risk assessment thelr-vendor-specific assessmeint that provided provided an estimated estirTlated core damage frequency of 3.4 E ..-7. damage frequency 7. Differences Differences wIth with Staff: representatives stated that their anaJyticai FENOC representatives analytical results differed with the staff's on the

                                                                                                         $laff's oil the fo1lowing following points (Note that  thatthe the .."staff   positions" stated below are as provided by FENOC):

staff positions-1.

1. The staff does not believe that Davis-Besse has a qualified method for visual inspection inspection penetration welds.

of the penetration FENOC stated that while whlle the inspections performed during the past 2 outages theinsp~ctions outages were not conducted with these t~esespecific specific failures Inmind, they were video taped. These video fallures in video tapes were of sufficient quality that permitted reinspectlonreinspection of the head looking for the de~its. FENOe characteristic boron deposits. FENOC stated that they are completing completing the process to qualify qualify this visuaJ technique for 65 of the 69 penetrations. visual inspection technique penetrations.

2. The staff stated that a given crack could grow to critical size within 18 months.

FENOC's analysis indicates As discussed above, FENOC'sanalysis Indicates that it would take more than 4 years years for that amount of growth to occur.. occur** Request for Additional Dialog: Dialog: FENOC management requested FENOe requested that additional dialog take place prior to the NRC taking action additional,dialog in this area. They stated that Davis-Besse Davis-Besse has been placed In in a high-risk group based on their their Inspections, and their vendor type, past inspections, theIr effective effective full-power years. However, FENOe FENOC stated process requires that the plant-specHic that due p.rocess plant-specific nature ,of evaluated. The of this phenomena be eValuated. management managementstated stated their intent to take whatever whatever action Is is necessary. Therefore, they considered Imperative that NRC provide the basis for their conclusions. The following specific considered it imperative specHic concerns were raised:

1. FENOe managers stated that, during an October 3, 2001 teleconference, FENOC managers teleconference, they requested that NRR provide the specifics of the analysis and the models used that indicates indicates appreciably appreciably faster growth rate than that determined FENOC. The staff has determined by FENOC.

provided documentation of this analysis. not provideddocumentatfon

2. FENOC stated that they also requested the specific NRC risk analysis that resulted in a FENoe core damage frequency of 2E-2 to 1.4E-3, differed from their vendor specific 1.4E-3, as this dHfered specHic analysis of 3.4 E-7, noting that their number was categorized categorized as a very small increase in increase in risk in in accordance accordance with Regulatory Guide Guide 1.174. The staff has not provided provided documentation documentation~ of this analysis.
3. that, during the October 3 call, they informed the staff that they had FENOC stated that,duringthe video tapes of the head, a finite element analysIS, and a crack growth rate model that element analysis,
                 . differed differed from the NRC's. FENOe     FENOC also        informed the staff that they would submit all data arso informed                                             data for staff review. The staff has not requested  requested to review this data.

Summary: NRC004-1783 NRC004-1783

FENOC closed FENOC olosed their indicating that presentation by Indicating their presentation that their their plant-specific deterministic and plant-13pecHic deterministic and assessments of probabHistic assessments probabilistic of the cracking issue CijDM cracking the CRDM provided a reasonable basis issue provided a reasonable basis for for assurance that assurance Davis:Besse is that Davis-Besse Is safe safe toto operate until March 2002. operateuntil.March Tl'1eystated that, as 2002. They-stated as such, such, FENOC does FENOC does not not have have indicatibn indication of need for of aa need early shutdown for early They stated Davis-Besse. They shutdoWn of Davis-Besse. that the that the prmary need at the primary need present time the present time is for .the staff for review the staff review Davis-Besse's analysis and Davis-Basse's analysis and prOVideFENOC provide FENOC with with specific specific information information related related to to the the NRC's NRC's analysis. analysis. Staff Staff Meeting: Meeting: following the briefing, Immediately following Immediately officials met briefly FENOe officials briefing, FENOC the staff. The briefly with the follOwing was The following was decfded: decided:

  • The NRC staff would
              'The                would continue

(:ontinue to to take action as was deemed take action deemed necessary throughout the necessary throughout the review of new FENOC information. of new information.

  • The ongoing staff review and The analysis Is and analysis is in preparation predecisional, and as such, preparation and predecisional, cannot can not be provldedto FENOe at this time.

provided to FENOC .

  • FENOe would FENOC provide, on October would provide. October 12, submission of their data schedule for submission 2001, aa.scheclute 1Z 2001, data next few business over the next business days. ensuring the quality of the submittals.

days, while ensuring

  • NRRstaff
               .NRR                               documentation provided in preparation staff would review the ,documentation                                             a staff-level preparation for astaff-level meeting with FENOC.

meeting FENOC.

  • meeting would be held.

A meeting during the week ending October presumably during held, presumably October 20, 2001, 2001. to discuss the FENOC analysis, provided that diScuss tflat the information represented a new information submitted represented

             .pasHian
             . position to the staff.
     **        Both sides agreed to attempt a rapid .resolutionresolution of this issue.

NRC004-1784 NRC004-1784

  ;I Attachment Attachment Technical Assistant Briefing Attendees Attendees Presenters:
        ~                                 President - FENOe Campbell. Vice President Guy G. Campbell,                       FENOC
        .. Steven P. Moffitt, Director, Technical Services.

Services-

        .. David C. Geisen.

Geisen, Manager, Design Basis Engineering Engineering

        .. David H. Lockwood, Manager.       Regulatory Affairs Manager, Regulatory   Affairs
        .. Steve Fyfitch,                Engineering Fyfitch, Framatome Engineering FENOC FENOC Attendees:
        .. Roy Lessy, Attorney, Attorney. Akin, Gump, et. al, ai,
        .. Mike Doweling Doweling
        .. Gerald Wolf Technical Assistants Assistants Darrell Roberts,    OCM/Merserve Roberts. OCMlMerserve Rich Croteau,     OCMIDiaz Croteau. OCMlDiaz Sunil Weerakkody, Sunil Weerakkody. OCMIDicus OCM/Dicus Tom HII~

Hiltz, OCMIDlcus OCM/DIcus Beall, OCM/McGaffigan Jim Beall, OCMlMcGaffigan Other NRC Attendees:

        ..                         OEDO David Loveless, OEOO
         ~     Stacey Stacey Rosenberg,     OEDO Rosenberg, CEOC
        ..a          Bateman. NRR Bill Bateman. NRA
        ..      Allen Hiser.
               *Alen          NRR Hiser, NRR NRC004-1785 NRC004-1785
                               ýA-s               c-(

(2- (ýcr ý- ~ From: Dale Dale R. Wuokko/TE/FirstEnergy WuokkorrElFirstEnergy To: Lockwood/TE/FirstEnergy@ FirstEnergy, Mark David H. LockwoodfTElFirstEnergy@FirstEnergy. Mark A. A. McLaughlinfTE/FirstEnergy@ FirstEnergy, David C. GeisenrrEiFirstEnergy@ McLaughlinrrElFirstEnergy@ FirstEnergy. Geisen/TE/FirstEnergy@FirstEnergy, FirstEnergy. Rodney Rodney M. Cook/FirstEnergy@FirstEnergy, Michael K. M. CooklFirstEnergy@FirstEnergy.Michael K. DOCKETED DOCKETED Leisure/TE/FirstEnergy@FirstEnergy, leisurerrElFirstEnergy@FirstEnergy. Prasoon K. GoyalrrElFirstEnergy@FirstEnergy, Prasoon K. Goyal/TfEFirstEnergy@ FirstEnergy, USNRC USNRC Steven Steven P. Moffitt/CEI/FirstEnergy@FirstEnergy, MoffitVCEIlFirstEnergy@FirstEnergy. Lonnie W. WorleylTE/FirstEnergy@ FirstEnergy. Dale l. WorleyrrElFirstEnergy@FirstEnergy. L. MillerrrElFirstEnergy@FirstEnergy, Miller/TE/FirstEnergy@ FirstEnergy, Kendall . September 9, 2009 September 9, 2009 (11 ('11:00am)

OOam) ByrdfT~JFirstEnergy@ FirstEnergy W. Byrd/TEiFirstEnergy@ FirstEnergy cc:

OFFICE OF OFFICE OF SECRETARY SECRETARY RULEMAKINGS AND RUlEMAKINGS AND ADJUDICATIONS

Subject:

Your Two em ails emails STAFF ADJUDICATIONS STAFF Date: 10/19/2001 9:40:351010 9:40:351010 Please note note the second second paragraph paragraph below. below. Our letter on Wed. 10/17101 letter sent onWed. 10/17/01 will correct their misunderstanding. misunderstanding.' ,

                                 ---- Forwarded Forwarded by :Dale Dale R. WuokkorrEiFirstEnergy Wuokko/TJEFirstEnergy on 10/19/01 09:36 AM  AM----
                              ."Doug-las. Pickett" DV.P1@nrc.g0v> 10/17/01 10:29 AM                 To: <Dale-r.

_wuokko@firstenergycorp.comf> cc:

Subject:

Your Two emails Dale - I received your two emailsthis emails this morning. I have have received inputs from the received the last two SE inplJts the tech staff on the the spent fuel re-rack amendment. II hope to put together together the package today and get itit to OGC tomorrow morning morning and request their concurrence concurrence by noon on Friday.

                 \

II have not received received any word from tech staff regarding the bulletin response. I've heard encouraging encouraging words describing describing your 100% 100% inspection inspection from your last outage. I'll keep you informed. informed. Doug I UANRC

                                                                                           ~bww
                                                                                              ~ DAVID     OEMSEN.If-{

DAVID GEISEN 5' ftýEkd ExhIbIt,S BM 7 Do"ks ## 1M)5.()52 Docket IA-06-052 .

                                                                                               *ts Marked Date   Mauked fororl1D4L IDJl/.;L. 2008      (Tr..hp.. g?5 2008 (Tr.             )

Offeled in EV:~ Date OffaracHn Ev Z4 2008 (Tr. 2008 (Tr.P.p.&~ -- ') Thmugh

                                                                                          'Through W             S 14Pa WttnessIPaneI:       rur6.

I Q-06 J 48 . Ac Action:* Date: ' o.t= REJECTED WITHDRAWN

                                                                                                            .2008 CTr. p. gw ,

WITHDRAWN SI4Q-016 514Q-01648 4B

                                                                                 -,(                             {)S62,.---                       ,

7-eVvý- P L Pýjý--- - NRC003-1211 NRC003-1211

DOCKETED USNRC U~NRC U.S. In is NRC U.S. NRC L -I-L2If GEISE14- 'T4L DAVID GEISEN:J r9 DAVID C'-11 Efht#J 5 t1 ExhibIt ,_ () In September September 9, 2009 2009 (11 (11:.00am)

OOam) Docke # 1Ml6-052 Doctcst 1A-06-052 Maliredfor'~

OFFICE OF OFFICE OF SECRETARY ADJUDICATIONS SECRETARY RULEMAKINGS AND RULEMAKINGS ADJUDICATIONS STAFF AND STAFF November 6, 2001 November 6,2001 DetB Da~oMai*ed forlý Date Offewd Data Off.ecHn In ev:* Er.W 2008 (Tr. 2 p.W ) (Tr.p.,...... p,x 2008 (Trp.2. 20 (Tr. Z 4)

                                                                          ~~

Thmug WFus- an- /L/ Action:AcftL Nih EJECTED WITHDRAWN REJECTED W1TH[lftAWN LICENSEE: LICENSEE: FirstEnergy Company FirstEnergy Nuclear Operating Gompany Date: . 2008(LZ

                                                                                          ,2008            'R (Tr. Po V-t )              .'

FACILITY: FACILITY: Davis:'Besse Unit 1 Nuclear Power Station, Unit Davis-Besse Nuclear

SUBJECT:

SUBJECT:

MEETING

SUMMARY

MEETING OCTOBER 24, 2001,

SUMMARY

OF OCTOBER 2001, TO DISCUSS DISCUSS THE LICENSEE'S LICENSEE'S RESPONSE TO BULLETINBULLETIN 2001-01 On October October 24, 2001, 2001, the Nuclear Nuclear Regulatory Regulatory Commission statt met in Rockville, Maryland; Commission staff Maryland, with representatives of FirstEnergy Nuclear Operating CompanyCompany-and their contractors. The purpose purpose meeting was to discuss the licensee's proposal to defer inspections of the meeting recommended by inspections recommended 2001-01, "Circumferential Cracking of Bulletin 2001-01, of Reactor Pressure Vessel Head Penetration Penetration Nozzles," to their 13th 13th refueling outage which is scheduled scheduled to begin begin in March March 2002. The bulletin recommends inspections be performed recommends that inspections performed prior to December 31, 2001. A list of the meeting 31, 2001. participants is included participants included as Attachment Attachment 1, and a copy of the meeting handout handout is provided as Attachment 2. Attachment The meeting meeting was requested by the licensee licensee in order order to provide newhew information information to the staff to justify their proposal proposal to defer reactor vessel head penetration inspections until their March penetration inspections March 2002 licensee had recently submitted two technical refueling outage. The licensee technical reports for staff review review that supplemented supplemented their original bulletin response. The reports consisted of "RV Head Nozzle and Head Nozzle Weld Safety Assessment" by Framatome Framatome ANP and "Finite Element Element Gap Analysis of CRDM Penetrations Penetrations (Davis-Besse)" by Structural Integrity Associates, Inc. .Inc. The staff had performed a preliminary preliminary review of these documents provided a request for additional documents and provided additional information information (RAI) (RAI) that the licensee would need to address. The meeting focused focused on the licensee's licensee's assessment assessment that reasonable reasonable assurance assurance exists to defer performance of the recommended performance recommended inspections and that a 24-month 24-month fuel cycle could be justified. The staff and licensee discussed discussed varying assumptions used to generate generate crack growth rate models. The staff indicated that they could not make any conclusions regarding the the acceptability of the licensee's acceptability mode~ prior to seeing the licensee's licensee's model responses to the RAJ. licensee's responses RAI. In In addition, the licensee addition,the licensee requested requested documentation documentation of the staffs generic technical assessment. The staff committed to issue their crack growth rate model approximately approximately one week prior to the the Advisory Advisory Committee Committee on Reactor Safeguards Safeguards meeting scheduled for November 9, 2001. 2001. r*&-, PAT- 7:- -SY1/2 2- W' m~ O2~-~

NUL-IIJLj -

                                                          --2         In closing statement~,

In statements, the staff staff requested videotapes of previous .inspections inspections of the reactor pen~tration leakage vessel head where no penetration leakage was identified. identified. The licensee stated their intentions intention.s to provide a docketed response response to the staffs RAI early next week. IRA! IRA! Stephen P. Sands, Project Manager, Section 2 Directorate IIl Project Directorate 1\1 Division of Licensing Management licensing Projects Management Office of Nuclear Reactor Regulation Docket No. 50-346 List of Meeting Participants Attachments: 1. list Attachments: Participants Meeting Handout

2. Meeting Handout cc w/atts: See next page page

1111..'

                                                           -                                                               2-In closing statements, the staff requested In                                             videotapes of previous requested videotapes       previous inspections inspections of the reactor ofthe  reactor leakage was identified. The licensee stated their intentions penetration leakage where no penetration vessel head where                                                                          intentions to provide a docketed                      staff's RAI early next week.

docketed response to the staffs IRA! Section 2 Stephen P. Sands, Project Manager, Section Stephen Ill Project Directorate 111 Division of Licensing Projects Management Management Office of Nuclear Regulation Nuclear Reactor Regulation 50-346 Docket No. 50-346 Attachments: 1. Meeting Participants

1. List of Meeting Participants
2. Meeting Handout Handout cc w/atts: See next page page ADAMS ACCESSION NO: NO.:. ML012980360 ML012980360 OFFICE OFFICE PM:LPD3 LA:LPD3 LA: LPD3 SC:EMCB SC:EMCB SC:LPD3 NAME NAME SSands THarris KWichman KWichman AMendiola AMendiola IRA! by IRA/by GDick DATE 11/01/01 11/02/01 11/02101 11/05/01 11/06/01 RECORD COPY OFFICIAL RECORD COpy

MEETING PARTICIPANTS PARTICIPANTS OCTOBER OCTOBER 24, 2001 NRC FirstEnergy Nuclear FirstEnergy Nuclear Operating Operating Company Strosnider Jack Strosnider Steven Steven Moffitt Moffitt John Zwolinski David Geisen Bill Bateman Kendall Byrd Keith Wichman David Lockwood Lockwood Allen Hiser Hiser Gerald Wolf Gerald Larry Burkhart Doug Pickett Collins Jay Collins David Loveless Loveless Dominion Resources Resources Jin Chung Bajwa Singh Bajwa Fontecilla Herb Fontecilla Jabbour Kahtan Jabbour Simon Sheng Andrea Lee Bechtel Stephen Sands Stephen Sands Steve Long Long Altheia Wyche Wyche Framatome ANP Framatome ANP Calvert Calvert Cliffs Fyfitch Stephen Fyfrtch Getachew Getachew T Tesfaye esfaye Alvin McKim McKim Peter Scott Stanley Levinson Scientech Enzinna Bob Enzinna Shoppman Mike Shoppman Deana Raleigh Deana Raleigh Jim Mallay Mallay Licensing licenSing Support Services Services Akin, Gump & & Strauss Strauss Roger Huston Roy Lessy HGP. Inc. Structures Inteciritv Associates, Structures Integrity Associates. Inc. Dan Salter Dick Mattson Mattson In addition to the above In above attendees, a telephone conference bridge was set up and individuals telephone conference individuals tied into the the bridge identified identified themselves representing the Davis-Besse themselves as representing Davis-Besse site, the Electric Power Research Research Institute Institute (EPRI), Oak Ridge National Laboratory, Southern Nuclear, Dominion Dominion Resources, Salem Generating Generating Station, and the Nuclear Information Resource Nuclear Information Resource Service. Attachment Attachment 1

OIL. . ni-. 11 DISTRIBUTION FOR DISTRIBUTION FOR MEETING

SUMMARY

OF MEETING

SUMMARY

OF OCTOBER 2001, WITH OCTOBER 24, 2001, FIRSTENERGY NUCLEAR WITH FIRSTENERGY NUCLEAR OPERATING COMPANY OPERATING COMPANY Hard Copy w/atts Hard Copy w/atts PO 111-2 PD 111-2 Reading Reading PUBLIC PUBLIC GGrant, Rill GGrant, Rill SSands SSands AMendiola AMendiola Hard Hard Copy wIAtt 1 Copy w/Att OGC OGC ACRS ACRS E-mail wIAtt E-mail w/Att 1 SCollins SCollins BSheron BSheron JZwolinski JStrosnider JStrosnider WBateman WBateman KWichman KWichman AHiser AHiser SBajwa SBajwa lBurkhart LBurkhart JColiins JCollins DLoveless DLoveless JChung JChung KJabbour SSheng ALee ALee SLong SLong JZimmerman JZimmerman

NRC FORM 658 U.S. NUCLEAR NUCLEAR REGULATORY REGULATORY COMMISSION COMMISSION I (9-1999) NRC FORM 658 TRANSMITTAL TRANSMITTAL OF MEETING HANDOUT OF MEETING HANDOUT MATERIALS MATERIALS FOR FOR IMMEDIATE

                                     -'MIVIED'A    TE PLACEMENT PL.ACEMENT IN      IN THE PUBLIC            DOMAIN PUBLIC DOMAIN This form is to be filled out (typed or hand-printed)

Thisform person who announced hand-printed) by the person announced the meeting (i.e., the person who issued the meeting notice). The completed form, and the attached form,_ and attached copy of meeting handout o/meeting handout materials, materials, will be sent to the Document Control Desk on the same day of ContrOJ-Deskon of the meeting; under underno circumstances Circumstances wi/I will this be done later than the working day after the meeting. later than meeting. Do not include includeproprietary materials. proprietary materials. [AT DATE OFMEEIG OF MEETING attached document(s), The attached waslwere handed document(s), which was/were handed out in this meeting, is/are to be placed meeting. iSfare placed L10/420 10/24nOOl public domain as soon as possible. The minutes in the public near future. tuture. Following are administrative details are administrative minutes of the the meeting will be issued details regarding this meeting: issued in the the Docket Docket Number(s) 05000346 PlantlFacility Plant/Facility Name Name Nuclear Power Station, Unit 1 Davis-Besse Nuclear TAC Number(s) TAC Number(s) (if (if available) MB2626 MB2626 Meeting Notice Reference Meeting Notice October October 18, 2001 Meeting Purpose of Meeting (copy from meeting notice) To discuss the licensee's proposal to defer reactor vessel recommended by Bulletin head penetration inspections recommended Bulletin 2001*01 2001-01 to their April 2002 2002 refueling outage. NAME OF PERSON WHO ISSUEO ISSUED MEETING MEETING NonCE N01ICE TITLE Stephen Sands Forthcoming MeetingMeeting with FirstEnergy Nuclear Operating OFFICE NRR DIVISION DLPM BRANCH LPD3 Distribution of this form and attachments: Docket File/Central File PUBLIC14Q prol NRC FORM 658658 (9-1999) 91°g PRINTED ON PRINTED ON RECYCLED RECYCLED PAPER PAPER was designed using This form was using InForms InForms

NRC NRC .Bulletin 2001-01, 2001-01, "Circumferential "Circumferential Cracking Cracking of of Rea'ctor ReactorPressure Pressure Vessel Head Penetration Head Penetration Nozzles" Nozzles" Attendees: Steven Steven Moffitt, Director Director ..- Technical Services Technical Services David Geisen, Manager Manager ..- Design Design Basis Engineering Engineering David David Lockwood, Manager - Regulatory Lockwood, Manager Affairs Regulatory Affairs Kendall Kendall Byrd, SupervisorSupervisor .. Nuclear Nuclear Engineering Engineering Gerald Wolf, Gerald Wolf,Senior Senior Engineer Engineer ..- Regulatory Regulatory Affairs Affairs Mike Dowling, Vice President Mike Dowling, President - First Energy Services Services Alvin McKim, McKim, Framatome Framatome Steve Fyfitch,Framatome> Fyfitch, Framatome ..... Stanley Levinson, Levinson, Framatome. Framatome Peter Scott, Framatome Framatome

     *Bob       Enzinna, Framatome Bob Enzirlna,          Framatome Dick Mattson, Structural Integrity AssociatesAssociates Roy Lessy, Akin,           Gump, Strauss, Hauer & Feld, L.L.P.
                          -Akin, Gump,Strauss, FENOC

I'f;'''1D'~~~, C1*

                                           ---'--~~

C NRC ~NRC 2001-01 response Bulletin 2001-01 provided response provided 7~ Telephone September 28 Telephone call received on September 28 Teleconference on October i:rVTeleconference October 3

~Briefdrop SBrief drop   by oil on 'October October 11   11 0 ,-.1<
                 "':'.FENOC
, *q .,';"2 FENOC 2

Reasonable Assurance Provide Reasonable that Davis-Besse Assurance that Davis-Besse is safe to o.perate operate until next refueling outage outage (March 2002) (M'arch 2002) and should continue 24 month operating o'perating cycles cycles FENOC 3

,1 0

II

N/IC IIRCRui 81111111in2551-1O 2001-01 Titled, "Circumferential "Circumferential Cracking Cracking of Reactor Pressure Press:,u:re Vessel Head Head Penetration Nozzles," Penetration Nozzles," dated dated Aug:ust August 3, 2001 . i~ 'Requests Requests that plants plants, provide provide design design , information,

  !nform~tion, previous             previous inspection inspection results, and future future inspection In:,s'pe'cilon plans.           pia ns,'             ,

7~ Response requirements were

               ~esp'onse*req.u.jr~r:ne'nts                  based upon were,base~   upor) plant plant rankin ra. ,.n.,. k. ln. g.'._. . in ln. Susceltibility Sus.ceptlblhty Model Model as published published in In EPRI EPRI I1RP-48. N/I*RP-48.                   '

FENOC FENOC 4

beuilityModel

                   $PSCllllllbiIilJllJ!.tl.dlll S

EPRI - PWR Materials Materials Reliability Program Response to N-RC Response NRC Bulletin 2001-01 2001-01 (MPR-48), 1006284, dated August 2001 1,,006:-284, Davis-Besse as 7th out of 69 plants. i:lr Ranked Davis-Besse

   ~ ) 6~6actual 6.6 actual             from Oconee EFPY away fro'm   Oconee 3 but 3.1 EFPY away after normaUzing normalizing on head temperatures temperatures down to 600 d~egrees.

SOO degrees. " *

   'i:lr Mod:el Model is purposely simplistic. in: that PWSCC is simplistic in influenced by Envir~nment(Chemistry tl7lfl*uenced     Environment (Chemistry & Temperature),

Stress, and Tim'e. Stress, Time. The model model does not account account for Stress, Chemistry, Material Variability, or specific plant as-built conditions. FENOC FENOC 5 ~i III

IDaivs-Resse NSRC RullelinReSlonse SReferenced inspections f-lReferenced inspections of the head during 11 RFO (April 1998) and 12 RFO (April 2000) f-lr :Re-reviewed Re-reviewed vi'deo video inspections inspections of head in light of boron leakage leakage seen at Oconee and Arkansas Nuclear Nuclear One.

 ý~N:ohead No head penetration penetration ,leakage leakage was identified.
  ~r  Committed to . submit follow-.up follow-up response on January 29, 2002 based u'pon:further upon further industry *developments.

developments.

i. Com'mitted fl Committed to perform perform aa qualified qualified visual inspection inspection of Reactor Pressure

. Reactor Pressure Vessel head in 13RFO13RFO currently scheduled to begin in March 2002. scheduled FENOC FENOC 6 v

AnalyslJs

                        ...... iAi.it....... .3 ..*. .1.........    ............. iI **.* '.l..... 5.1.1 ..

DBNPS's evaluation evaluation is based on our visual inspections inspections performed in 10,11, 10, 11, and 12 RFO (May 1996, April 1998, and April 2000 respectively) The inspection results afford us assurance that all but 4 nozzle penetrations penetrations were inspected in 1996. All but 19 penetrations were inspected penetrations inspected in 1998. And all but 24 24 penetrations penetrations were inspected in in 2000. The limiting nozzle population isthose is those nozzles that could could 1998 or 2000. not be inspected in '1"998' It is conservatively conservatively assumed assumed that that.for for these penetrations, an axial through through weld flaw occurs immediately immediately upon startup from 1ORFO (May from'10"R'FO (May 1996) . 106 FENOC FENOC 7

AnallSes, conl

                    .001'",. .F .** ..1. ..... 1 PAi., ... ..M...   ,.IiL ... ). i.e.Mi¥.. .*. " ........ 1.1........................ .

Assuming Assuming flaw initiation at the beginning beginning of cycle 11 11, , a circumferential circumferential through through wall flaw will not reach the the allowable allowable flaw size before before November November 2003. Clearly, operating operating to March March 2002 is acceptable acceptable given that we have analyzed analyzed conservatively conservatively at each step of our evaluation. /\1 0%

    ---                                                                                                                                      FENOC FENOC 8

Facts. (. penetrations were verified to be free from All CRDM penetrations All "popcorn" type boron deposits using video recordings "popcorn" recordings I ORFO, I11IRFO from 10RFO, RFO or 12RFO.12RFO. i:l: A review of of visual recordings well as eye-witness accounts recordings as well served as the accounts served the means of the inspection. inspection. ,r ~ The original VHS format was original VHS was transferred formal to allow a frame by transferred to .avi file format by frame review. review. FENOC 9

Facts Feets All through wall flaws in the US industry All through industry reported reported to date have been identified date identified by by visual inspection. visual inspectionM ~ There have been no through 7 There circumferentialflaws above the J-weld through wall circumferential region J-we/d region that visual leakage that have not exhibited visual reactorvessel head. OD of the reactor leakage on the 00 head. ~ CRDM nozzles that underwent sampling of CROM The sampling NDE type inspections underwent NOE part of an inspections as part an extent of condition circumferential flaws above the J-weld. condition did not exhibit circumferential J-weld. FENOC 10 10

Facts A conservative conservative plant plant specific specific finite finite element analysis analysis shows that least 65 out of 69 penetrations that at least penetrations will open open up sufficiently to provide provide visual visual indication. indication. ~SStructural Integrity Associates Structural/ntegrity Associates (SIA) performed performed the finite finite element analysis. analysis. ~ Drive penetrations Drive penetrations1, 1, *2; 2;2,- and 4 did 3, and did not relax theirinterference relax their interference fits sufficiently enough to claim claim that an unimpeded path exists from the top of the J-weld to the 00 unimpeded path OD of the head. interference fit is head. The minimum interference 0. 00002". only 0.00002". is.only drives did 'tl These drives did not nece:ssarily necessarilyhave the highesthighest interference fits. Their interference fits. Their location location differential stress and exhibited the lowest differentia/stress and that thatlimited limited their their penetration penetration elongation. elongation. absence of high differentia/. This absence differential.strf3ss stress may also also explain why no circumferential circumferentialflaws have been found in the industry industry at these locations. locations. 7X A detailed detailed Framatome Framatomeanalysis analysis of B&W B&W plants plants shows all penetrations penetrations opening opening up. F..-NC' e, FENOC 4 c11 FENOC 11

Facts Maximum allowable allowable flaw size is at least 273 degrees which is still a safety factor degrees (aligns with factor of 3 (aligns ASME code) ASME code) . ~ ,%'~ specific SIA Davis-Besse specific PreliminaryDavis-Besse Preliminary analysis indicates SIA analysis indicates that the maximum achieve a safety factor allowable flaw size to still achieve allowable factor of 3 may be as as high as as 302 degrees. degrees. 12' FENOC

          ....   "'  .. , C*'12                                                    FENoe 12

iI$$HI1P luff Initial flaw depth of 0.5 mm, 172 17200 around the the nozzle, is assumed assumed to exist immediately immediately upon achieving a full penetration achieving penetration axial flaw. BASIS:

     ~
     ,N    This is a conservative conservative flaw initiation site size.

z-i..~ It is further conservatively It assumed that multiple starting flaws could exist conservatively assumed and that these would eventually link* together.* eventually link together. .

      ~
      ~It   It is conservative conservative in       by assuming this starting point, we also are in that by assuming that we have already had several years of flaw propagation assuming                                                         propagation axially through the Alloy 182 weld material.

/ FENOQ~ FENOC FENOC <VC (' C) 13 13

takes at It takes least 3.5 at least years to grow 3.Syears grow circumferentially through through wall wall to aa flaw size of flaw size of 1800 1800 BASIS: BASIS:

   ~ V 1800 1800        used by was used was               Framatome in their by Framatome               Safety Assessment.

their Safety Assessment.

    ~         conservative in
    ,ý It is conservative      in that t.he Framatome that the                 analysis showed Framatomeanalysis                 that aa single showed that      single initiation                take 10years would take initiation site would            10 ,years to 'grow           pOint but this point grow to this             that multiple but that multiple initiating flaws initiating           could link flaws could          up to shorten linkup                    flaw growth the flaw shorten the                 timeframe to groWth timeframe    to 3.5 3.5 years.                                      '
               "...C"*'14                          1"FENOC                             FENOC CE LI.fIN 14

As AssumptioRS J,' .J, . . . . . . . . . . . . . f . . liws

                                                                              ....  ..  * ;P,m. Ii ..

Industry accepted crack Industry accepted crack growth growth rate rate models models for for Alloy 600 Alloy 600 are are applied. applied. BASIS: BASIS: {;{SThe propagation rate used crack propagation The crack used in Framatome analysis in the Framatome was derived analysis was derived from applying from Peter Scott the Peter applying the Scott model model which which is (stress intensity is K (stress intensity factor) factor) dependent. dependent. 1}{ The ýOr materials based model is aa materials The model based model developed from model developed steam generator from steam generator and is data and empirical data empirical applied conservatively is applied conservatively to CRDM CRDM material database. material database.

~

5- The environment The equivalent to environment is equivalent to primary water chemistry. primary water chemistry. FENOC 15 15

                    ~-------- ~~-

Assumptions 1... ( ..*. :... ;,.1 I..,.. "...: "..0 .J.. "" I ,11 J.s.............. s. '. takes at It takes least 44 years at least years to grow grow from the the flaw size size of 1800 maximum allowable 1800 to aa maximum allowable flaw flaw size size of 2700 270 0 BASIS: BASIS: Modeled by

  • iX Modeled Framatome in by Framatome in their Safety Assessment.

their Safety alternative method Applying an alternative

*f.l Applying                               method we                we see         that the see that          the Framatome                    method is Framatome method        is conservative.

conservative. ForFor example, using mean radius of nozzle which equates to using mean radius of nozzle which equates to aa circumference of circumference 10.62, to of 10.62, to flaw flaw from from **180180 to 270. degrees to 270 d~grees would to 45 equate to would equate 45 degrees in each direction degrees each direction for a circumferential distance a circumferential distance of 1.33 inches. Then of 1.33 inches. Then applying accepted linearized applying an accepted lineari~ec:l.grpwth growth rate rate of of 0.2 inches/year through Alloy inches/year through Alloy 600. material 600 years to 6.6 years yields 6.6 material yields 'propagate the to"propagate the 1.33 1.33 inches in each inches in direction. each direction. C,

     )                                                                    --66 1..                                                        FENOC FENOC 16
                                                                          -v

RBasonable Reasonuble Assurance

       .1 i i ** i. ..... "_". X:'i ......... J ;        :. . .. 1.. d.

Assurance

                                                                          .,P,.:' 1 1.......... " .. , . .; ......... h.l!1. .. _,  .... .lilli.M Ii.

Results of Analysis: Analysis: conservative analysis shows This conservative ~hows that a potential flaw would not grow to maximum allowable allowaole flaw flaw before the ,13th size before 3th refueling refueling outage. 17 FENOC 17 17

Iisk-inlfurmedfEvalluhtion Risk-llllormBdEvaluation

  • SNSSS estimated vendor-specific risk NSSS vendor-specific incremental core estimated incremental assessment provides risk assessment provides frequency of damage frequency core damage 3.4 E-7 of 3.4 E-7 iJ? Preliminary t, specific risk assessment plant specific Preliminary plant assessment conservatively estimates conservatively incremental core estimates incremental core damage damage frequency as frequency which is 6.7 E-6, which as 6.7 categorized as is categorized "small" per as "small" per RG 1.174.

1){SPreliminary Preliminary specific risk plant specific risk assessment assessment conservatively incremental large estimates incremental conservatively estimates early release large early release 1.0 E-8, which frequency as 1.0 frequency categorized as "very small" which is categorized 1.174. per RG 1.174. FENOC FENOC 18

                                       *v

Summaty:

                     ~$irA.
                       ........ ;:e,JtQs .... c;;. . . . . t%CXt=:u:::zas::s:.:z::ae::c_ ~  ..

Reasonable Assurance There is Reasonable Assurance that Davis-Besse Davis-Besse is safe to operate operate based on deterministi.c deterministic and and assessments until the next refueling probabilistic assessments probabilistic refueling outage (March 2002) and continue on 24-month operating cycles. K!7 FENOC FENOC 19 19

RV RV HEAD HEAD INSULATION INSULATION SERVICE SERVICE STRUCTURE STRUCTU RE CRDM NOZZLES THERMOCOUPLE THERMOCOUPLE NOZZLE-NOZZLE (ONS-1 (ONS-1 ANDAND TMI-1 TMI-1 ONLY) ONLY) SUPPORT SUPPORT STEEL STEEL OR 99 ACCESS 88 OR ACCESS HOLES HOLES IN IN SERVICE SERVICE STRUCTURE STRUCTURE SUPPORT SUPPORT (ONS-i, (ONS-1. ONS-2, ONS-2. ONS-3, CR-3, ONS-3. CR~3. AND AND TMI-1 TMI-1 ONLY) ONLY) 18 18 ACCESS ACCESS OPENINGS-OPENINGS 2" 2" MIN MIN GAP GAP BETWEEN BETWEEN "MOUSE-HOLES" "MOUSE-HOLES" ALL ALL INSULATION AND INSULATION AND TOP TOP B&WOG B&WOG PLANTS PLANTS OF OF RV RV HEAD HEAD I 4 L. 20 FENOC 20

P,A7 Q2-e2D 357 357 UNITED UNITED STATESSTATES OF OF AMERICA AMERICA DOCKETED DOCKETED USNRC USNRC ( NUCLEAR NUCLEAR REGULATORY REGULATORY COMMISSIONCOMMISSION Sept(ember 9, 2009 (1 1:00am) September 9, 2009 (11 :OOam)

                                           + + + + +                                               OFF-ICE OF SECRETARY OFFICE    OF SECRETARY R ULEMAKINGS     AND AND ADJRULEMAKINGS UDICATIONS STAFF ADVISORY COMMITTEE ADVISORY      COMMITTEE ON      ON REACTOR           SAFEGUARDS (ACRS)

REACTOR SAFEGUARDS (ACRS) ADJUDICATIONS STAFF 5 487TH MEETING 487TH MEETING 6 -I-++ + +

                                           + + + + +

7 FRIDAY, FRIDAY, NOVEMBER 9,9, 2001 NOVEMBER 2001 9 + + V+E+ ++ ++M+ ROCKVILLE, MARYLAND 10 ROCKVILLE, MARYLAND

                                          +   ++   + ÷+

11 + + + + + 12 12 13 13 The The conmittee committee met met at at thethe Nuclear Nuclear Regulatory Regulatory 14 1 Commission, Connnission, Two Two White White Flint Flint North, North, T2B3, T2B3, 11545 11545 15 Rockville ROckville Pike, Pike, Rockville, Rockville, Maryland, Maryland, at at 8:30 8:30 a.m., a.m., 16 1 George George E. E. Apostolakis, Apostolakis, Chairman,Chairman, presiding. presiding. 17 COMMITTEE COMMITTEE MEMBERS: MEMBERS: U.S. U.S.NRC NRC InIn rereDAVID L i r-

 .18 1  GEORGE GEORGEE. E. APOSTOLAKIS, APOSTOLAKIS, Chairman Chairman                       DAVIDGEISEN GEISEN ./TO-=t Docket## 1A-05-052 Docket       1A-05-052            .

19 19 MARIO MARIO V. V. BONACA, BONACA, Vice Vice Chairman Chairman Da% jfo Date Marked for 10: 1~1 2 t $ m.p. 2z5 ) 20 20 NOEL F. NOEL DUDLEY, Member F. DUDLEY, Member Date Offeradin Ev: )'1.- / 'f..,2)W DateOffeudniEv_"_ (Tr.p,RzW 10(Tr. p ) Thn'Jugh WJtnessIPaneI:~~~ _ _ __ 21 F. F. PETER PETER FORD, FORD, Member A E'CT AdioR:, _~ REJEC 2 Member -D WITHDRAWN WlTlHDRAWN 22 22 THOMAS S. THOMAS KRESS, Member S. KRESS, Member /DaIa:.1.J4L.2008 err.

                                                                                      ,2     O:           ~ ) .

23 23 GRAHAM M. GRAHAM LEITCH, Member M. LEITCH, Member 21 2 DANA DANA A. A. POWERS, POWERS, Member Member 22 STEPHEN STEPHEN L. L. ROSEN, ROSEN, Member Member S14J-1661 S14J-1661 NEALR. NEAL R.GROSS GROSS COURT REPORTERSAND COURTREPORTERS ANDTRANSCRIBERS TRANSCRIBERS RHODE ISLANDAVE., 1323RHODE:ISLAND 1323 AVE., NKW. N.W. (202)234-4433 (202) 234-4433 WASHINGTON, D.C. 20005-3701 WASI-:IINGTON. D.C. 20005-3701 wwwiealrg=oss.com www.nealrgross.com os: 0 ~ NRC014-1656 NRC014-1656

358 358 COMMITTEE MEMBERS: COMMITTEE MEMBERS: (CONT * ) (CONT.) i/" WILLIAM J.J. WILLIAM SHACK, Member SHACK, Member JOHN D. JOHN D. SIEBER, SIEBER, MemberMember 4 GRAHAM B. GRAHAM B. WALLIS, WALLIS, MemberMember 5 ACRS STAFF PRESENT: PRESENT: 6 JOHN D. JOHN D. SIEBER, SIEBER, ACRS ACRS 7 DURAISWAMY, ACRS/ACNW SAM DURAISWAMY, 8 HOWARD J. HOWARD LARSON, ACRS/ACNW J. LARSON, ACRS / ACNW 9 BAHADUR, ACRS/ACNW SHER BAHADUR, ACRS/ACNW CAROL A. HARRIS, ACRS/ACNW A. HARRIS, ACRS/ACNW

io JOHN T. LARKINS, ACRS T. LARKINS, ACRS/ACNW
                                                                / ACNW
                  .12     MAGGALEAN W. WESTON MAGGALEAN                WESTON 113   MEDHAT MEDHATM.      M. EL ZEFTAWY 114    MICHAEL MICHAEL T.            MARKLEY T. MARKLEY 15   ALSO PRESENT:

PRESENT: 116 LARRY MATHEWS MATHEWS 117 STEVEN MOFFAT STEVEN MOFFAT

          "-.:. ;-1  -18  wAR'R'EN WARREN 'BANFORD ANFORD

' * .* ,19 ALLEN* H~SER ALLEN. HI-SErR,.,'., 20 ED'* HACKETT ED 'HACKE-T*T

      *q .',         21   KEN ,BYIW,         ,,

22 ..kTY MERRION - 2323 JACK STROSNIDER 224 RAJ PATHANIA 2525 GEISEN DAVE GEISEN* S14J-1662 S14J-1662 NEAL R.R.GROSS AND TRANSCRIBERS COURT.REPORTERS AND COURT.REPORTERS TRANSCRIBERS AVE, N.W. ISLAND AVE., RHODE ISLAND Epp 1323 RHOOE N.W. (202) 234-4433 (202) WASHINGTON, D.C. 20005-3701 WASHINGTON, www.neabgrass.corn www.nealrgross.com UI NRC014-1657 NRC014-1657

359 359 1 22 ALSO PRESENT: ALSO PRESENT: (CONT.) (CONT * ) 33 MARK REINHART MARK REINHART 4 TOM KING TOM 5 PRASAD KADAMBI N. PRASAD N. KADAMBI 6 ERIC J. ERIC J. BENNER BENNER JIM LYONS JIM LYONS McGAF:FIGAN (Comni EDWAIUJ McGAFFIGAN EDWARD ssioner) (Conunissioner) TONY ULSES STEWART BAILEY STEWART 1 14 13: 15 16 .17 18 19 2C 21 22 22 23 23 224 25 S14J-1663 S14J-1663 22f NEAL R. NEAL R.GROSS GROSS COURT REPORTERS COURT AND TRANSCRIBERS REPORTERS AND TRANSCRIBERS ISLAND AVE.. RHODE ISLAND 1323 RHODE 1323 N.W. AVE. N:W. (202)234-4433 (202) 234-4433 WASHINGTON. D.C... 20005-3101 WASHINGTON, D.C 20005-3701 www.nealrgross.corn www.nealrgross.com NRC014-1658 NRC014-1658

396 396 1 visible leakage visible leakage boron boron deposit. deposit. 2 MEMBER MEMBER POWERS: POWERS: All All right.right. Thank Thank you. you. 3 MR. MR. MOFFAT: MOFFAT: Additionally, Additionally , we perform our we perform our 4 own plantplant specific specific analysis analysis that essentially would essentially would

 .5 look at the end point      point as   as it          relates to safety it relates               safety factor factor 6 of 3 using  using the code  code we've we've discusseddiscussed previously previously and 7  have have a number number that's slightly slightly bigger    bigger than than the industry a data        to    date   as    it    applies i tapplies                to Davis-Besse.

Davis-Besse. That That 9 number number is is 302 degree flaw as safety safety factor of 3. 3. 10 We also believe believe -- -- 11 MEMBER MEMBER FORD: Excuse me, me, physically, physically, what what 12 12 allows you to make that difference difference in in material material 13 13 properties? properties? I mean what's the -- -- 14 MR. MOFFAT: MR. MOFFAT: II'll'11 let you take that, Dave. Dave. 15 MR. MR. GEISEN: Well, Well, we had the -- the 1 analysis was done by Structural analysis Structural Integrity Associates Integrity Associates 17 and when they did their analysis analysis they were looking at at 18 the -- -- using the fracture mechanics mechanics with the noz.zles nozzles 19 and looking at our worse case nozzle nozzle in in our particular particular 20 strengths of materials what does that take us out to. 21 MEMBER FORD: MEMBER So it'sit's aa larger qualifying, 22 larger than you mentioned than who? Industry average? Industry 23 MR. MOFFAT: MR. Nominally 270 plus or minus 224 several several over over here. here. Quite aa body of information 25 yesterday, but that's the general characterization characterization NEAL NEAL R. R.GROSS S14J-1700 S14J-1.700 REPORTERS AND COURT REPoRTERS AND TRANSCRIBERS TRANSCRIBERS 1323 RHODE 1323 RHODE ISLAND ISLAND AVE., AVE., N.W. N.W. (202) 234-4433 (202) 2344433 WASHINGTON, WASHINGTON, D.C. D.C. 20005-3701 20005-3701 w Jwwealrgross.com www.neaJrgross.com NRC014-1695

397 397

  .1 between between roughlyroughly 260 and    and 272.

272. 2 MEMBER FORD: MEMBER FORD: Okay. Okay. 3 MR. MR. MOFFAT: MOFFAT: Additionally, Additionally, in in order order to to 4 look back,back, as I said previously, with a said previously, new set of of 5 eyes, eyes, assumed an initial initial flaw size size thatthat would have have

  ,E occurred occurred          immediately immediately            subsequent subsequent              to      our         1996 1996 7  retrospective, if retrospective,           if you will,will, and believe  believe that we would      would 8  still still                 reasonable assessment have a reasonable           assessment that we can proceed          proceed 9                   refueling outage based on that until our refueling                                             that initial initial flaw    flaw 10    size.

size. 1i And then finally the last deterministic deterministic 12 aspect I'd I'd like to go over briefly briefly is just the fact as is just as .13 13 Larry was showing, showing, we are over the three adjusted adjust~ 14 effective effective full power power years plus at Oconee Unit 3. 3. 15 Essentially, Essentially, we're at roughly 6EFPY 6 EFPY as far as the ,1 EFPY, but as adjusted EFPY, adjusted for time and temperature, temperature, we're 17 a bit a bit 3. over 3.* 18 CHAIRMAN BONACA: VICE CHAIRMAN question on the A question the 19 1998 1998 and 2000 inspections, .you inspections,' you said that they were were 20 limited. 21 MR. MOFFAT: MR. Yes sir.sir. 22 VICE CHAIRMAN BONACA: What was the extent extent 23 of the inspection? of 224 MR. MR. GEISEN: I'll I'll talk to that. What we 225 did is did is recognize recognize -- -- this is is Dave Geisen.Geisen. With Wi th regard NEALR.GROSS NEAL R. GROSS S14J-1701 S14J-1701 COURT REPORTERS AND TRANSCRIBERS TRANSCRIBERS RHODE ISLAND AVE~ 1323 RHODE AVE.. N.W. (202)234-4433 (202) WASHINGTON,. 2000-3701 D.C. 20005-3701 WASHINGTON, D.C. www.nealrgross.comr wwwnealrgross.com NRC014-1696 NRC014-1696

398 398 1 to to these these inspections, inspections, recognize that they recognize they were were not not 2 done looking for this done looking particular phenomenon. this particular phenomenon. They They 3 were looking for other were looking other things. things. The The two two inspections inspections 4 done in done 1998 and 2000 in 1998 2000 were really looking looking for the

5. impact impact of boric boric acid leakageleakage from leaky leaky flanges that that 6 we we had subsequently repaired had subsequently repaired and what what waswas the impactimpact 17 to that.

that. So the viewview thatthat we we got from those was was in in 8 many cases some of of the drives you couldn't even get a you couldn't 9 good view of. of. 110 There were many cases, cases, the camera angle angle 11i was looking upwards because because it it was looking at looking the 112 structural material structural. material of the service structure on top of service structure of 13 the head. 114 When we looked looked at a 1996 data, you got got

1. more of aa downward look at these nozzles because because we we 116 specifically following around a vacuum and probe were specifically probe 117 that was looking for head wastage wastage as result of the 118 boron being deposited deposited on head. So what really comes Sb comes 19 down to it the best video we have on this goes all it, ,the all 220 the way back to 1996. 1996.

221 MR. MOFFAT: MR. essentially those are some So essentially 222 of the characteristics characteristics specific to our power plant ?-s as 23 plant specific speci~ic information, as we discussed, given 2 that the body of knowledge related to this issue, what what 25 we've done is Framatone and our own engineering is using Framatone NEALMRR. GROSS NEAL S14J-1702 COURT REPORTERS COURT REPORTERS ANi:> TRANSCRIBERS AND TRANSCRIBERS 1323 RHODE

                                   .1323 RHODE ISlAND   AVE. N.W.

ISLAND. AVE.. (202) 2344433 (202) 234-4433 WASHINGTON, D.C. 20005-3701 WASHINGTON. 20005-3701 www.nealrgross.oom www.riealrgross.com NRC014-1697 NRC014-1697

                                         ý P - P rs U.S. NRC In Inre NRIC re DAVID DAVIDGEISEN fLrff
                                                                                                                                                    ~v..              ExhibIt ,_k2 I     0
                     ****                                                     UNITED UNITED STATES STATES Docket # 1A-OS-OS2 Date Marked GEISEN______it_

d flO' for IDii d1#- Y (Tr. p. .'SZS) 2008 (1i

                                                                                                                                                                 -2008                .
/             .,,,,,                                  NUCLEAR NUCLEAR REGULATORY COl                         COI       Date Ma.rke . or                                          r. p.-         ..~

,~. . ,:- WASHINGTON. D.C.20m*ooc WASHINGTON. D.C. 205S-GDO Date Offered in Date Offered inEv:Ev: JidL. p. (Tr. p.j?2w 2008 (Tr. )) i -/.9~s~i25~ ~~~Q'-l ~ ~t) . <o<tCV\~ Nove,;;:er N.e , Nov~ember 27 Through 27., 27, WitnesslP-ael: 2;f. Through WrtnessJP-anel: / .

     .91~0*
         -25*

I/i'll/I-E~ a O()f,... . ~.R. . Action:. 11 J ~ Action:"A4 AZ--.J REJECTED REJECTED WITHDRAWN () WITHDRAWN Date: ~.2008(Tr.p.~) 1/1"11/ I' \ r7 /

                          . _..           -                  -. ..          \...V.                            Date:                                                          .
                                                      !'.~~~7     a      .j     tiCr. I-  ~SeciIon 22 2/1 ,           2008 (Tr. p.

MEMORANDUM M1"MUNM*NUUMV] TO: I .U: A..nthony J.

                                             .' Anthony        j. Mendiola, Menluola, Chief, CnHeO,   Section                                                       '       .

Project Project Directorate Directorate III III I I 1--L-lJ I " " ... L.;.UV CUI~UN CJIbUN .,I Division of Licensing Division Licensing ProjectProject Management Management Office of Nuclear Reactor Office Reactor Regulation Regulation FROM: Stephen sa.ndS, Stephen Sands, Project Project Directorate III Project Project Man. III Manager, Section 2

a. ger, Section 2~.~ / r--J \: .1 Division 0' Division o' Licensing Project Project Management Management '

Office of Office of Nuclear Reactor Requlation Rer4ulation (

SUBJECT:

SUBJECT:

FORTHCOMING MEETING NITH FORTHC0MING WITH FIRSTENERGY FIRSTENERGY NUCLEAR NUCLEAR OPERATING COMPANY OPERATING DATE & DATE & TIME: Wednesday, November2~, Wednesday, November 28, 2001 10:00 a.m.*a.m. - 12:00 12:00 a.m. LOCATION: LOCATION: u.s. U.S. Nuclear Regulatory Commission Commission One White Flint North 11555 Rockville Pike, Rooen Room 0-684** O-6B4"" Rockville, Maryland Rockville, Maryland PURPOSE: To discuss information To information related to supplemental supplemental information information regarding regarding inspection inspection plans and commitments for the Davis-Besse Nuclear the.Davis-Besse Nuclear Power Station, Unit 1, in response Station,Unit response to NRC Bulletin 2001-01. NRC Bulletin 2001-01. (Portions(Portions of this this

                                                -meeting may be closed due
                                                *meeting                              due to discussion of Proprietarv proprietary information.)

information.) PARTICIPANTS:* PARTICIPANTS:- NRC NRC FirstEnergy FirstEnergy S. Collins Collins R. Saunders R. Saunders J. Strosnider G. G. Campbell Campbell W. Bateman W. Bateman D~ Lockwood D. Lockwood K. Wichman Wichman D. Geisen D. A. Hiser Hiser S. Moffitt S. Moffitt S. Sands Sands Docket Docket No. No. 50-346 cc: See See next page page CONTACTS: CONTACTS:. Stephen Stephen Sands, 301-415-3154 301-415"3154 Dougias Pickett, Douglas 301-415-1364 Pickett, 301-415-1364

             *Meetings "Meetings betweenbetween NRC           technical staff NRC technical             staff and and applicants applicants .or  or licensees licensees areare open open for:interested for interested members members of      of the the public, public, petitioners, petitioners. intervenors, intervenors, or    or other other parties parties to attend attend as   as .observers observers pursuant pursuant to    to Commission Commission Policy   Policy Statement Statement on "Staff Meetings  Meetings Open  Open to thethe Public:

Public: Final Final Policy Policy Statement," Statement," 65 65 Federal Federal Register 56964, 56964, 9/20/2000. 9/2012000. However, However, portions portions of this this :meeting meeting .may may not not be be open open to 10 the the public. public. A non-proprietary non-proprietary summary summary of of the the meeting meeting will be prepared will.be prepared and and will will bebe available available. uponupon request. request.

             ** Stakeholders Stakeholders wishing wishing to    to participate participate via  via telephone telephone may    m'ay call call the the bridge bridge atat (301)

(301) 231-5539 231-5539 or or (800) (800) 638-8081 638-8081 and and enter.8873# enter .8873# at at the the prompt prompt DOCKETED DOCKETED USNRC USNRC 514D-07273 S104D-07273 September September 9, 9, 2009 2009 (1l1:00am) (11 :OOam) OFFICE OFFICE OF.SECRETARY OF.SECRETARY RULEMAKINGS RULEMAKINGS AND AND ADJUDICATIONS ADJUDICATIONS STAFF STAFF 77~A~~-L A-7 6-~{~LK~NRCOO08-1 925

AM44.*****6&*"UNITED STATES

     --             -'.                                        UNITED STATES
.. ~. ....... NUCLEAR NUCLEAR REGULATORY REGULATORY. COMMISSION COMMISSION

':. . <, WASHINGTON. WASHINGTON. D.C. O.C. 20555-0001 20555*0001 ~

   ---Jl:>~25     ~~~<;)). ~ ~t> . Cj<t~                 1I tL                                                ~. ©.. ~ U. Y g ~'

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  • November 27, 2001 E)CT- 0 \ - OOlo3<1 Offie oNNovembere27, 2001
         '"'                                                                                                 DEC      J 3XlI MEMORANDUM MEMORANDUM TO: Anthony        Anthony J. Mendiola, Chief, J. Mendiola,    Chief, Section 22                       TOLEDO EEDISON TOLEDO                 S Project Directorate Project   Directorate III                                    IllLD---*                           N licensing Project Division of Licensing Division                   Project Management Management Office of Nuclear Office                Reactor Regulation NuClear Reactor      Regulation FROM:

FROM: Stephen Sands, Project Stephen Sands, Project Directorate Directorate IIl III Manager, Section 2 _ Project Manager, ~/~ ..r-J \: ,I Division o' Management o'~ 0' Licensing Project Management Nuclear Reactor Office of Nuclear Reclulation Reactor Rec,ulation

SUBJECT:

SUBJECT:

FORTHCOMING MEETING FORTHC0MING FIRSTENERGY NUCLEAR MEETING NITH FIRSTENERGY NUCLEAR OPERATING COMPANY OPERATING DATE & DATE & TIME: November 28, 2001 Wednesday, November2l:i,2001 Wednesday, 10:00 a.m. - 12:00 10:00 12:00 a.m. LOCATION: LOCATION: Nuclear Regulatory U.S. Nuclear Commission Regulatory Commission One One White White Flint North North 11555 Rockville Pike, Room 11555 Rockville O-6B4"" Room 0-6B4** Rockville, Maryland Rockville, Maryland PURPOSE: PURPOSE: information related to supplemental To discuss information supplemental information information regarding regarding inspection plans and commitments Davis-Besse Nuclear commitments for the Davis-8esse Nuclear Power Station, Unit 1, in response to NRC Bulletin 2001-01.2001-01. (Portions this (Portions of this meeting may be closed due to discussion of proorietary meeting information.) proprietary information.) PARTICIPANTS:* PARTICIPANTS:' NRC FirstEnergy FirstEnergy S. Collins R. Saunders Saunders J. Strosnider Strosnider G. Campbell W. Bateman W. Bateman D. Lockwood D.Lockwood K. Wichman K. D. D. Geisen A. Hiser A. S. Moffitt Moffitt Sands S. Sands Docket No. 50-346 See next page cc: See page CONTACTS: Stephen Sands, 301-415"3154 301-415-3154 Douglas Pickett, 301-415-1364 Dougias 301-415-1364

           *Meetings between
           'Meetings                                                                licensees are open for interested between NRC technical staff and applicants or licensees                          interested members of the public, petitioners.

petitioners, intervenors, or other parties to attend as observers observers pursuant to Commission Policy Statement on "Staff Meetings Meetings Open to the Public: Final Policy Statement," 65 Federal Register 56964, 9/20/2000. However, portions of this meeting may not FederalRegister be open to the public. A oe non-proprietary summary of the meeting will be A non-proprietary be prepared prepared andand will be be available upon request.

           **- Stakeholders wishing to participate via telephone m*ay       may call thethe bridge at at (301)

(301) 231-5539 or (800) 638-8081 and (800) and enter 8873# 8873# at the prompt 5140-07273 S14D-07273 NRC008-1 925 NRC008-1925

Mr. Guy Guy G. G. Campbell Davis-Besse Davis-Besse Nuclear Nuclear Power Power Station, Station, Unit Unit 1 Nuclear Operating FirstEnergy Nuclear FirstEnergy Operating Company Company cc: cc: Mary"E. O'Reilly Mary'E. O'Reilly Harvey Harvey B. Brugger, Supervisor Supervisor FirstEnergy FlrstEnergy Radiological Assistance Radiological Assistance Section Section 76 South Main 76 Main Street Bureau Radiation Protection Bureau of Radiation Protection 44308 Akron, OH 44308 Akron, Department of Ohio Department of Health Health P.O. Box 118 Box 118 Manager - Regulatory Manager Regulatory Affairs Affairs Columbus, OH 43266-0118 Columbus,OH 43266-0118 Nuclear Operating FirstEnergy Nuclear FirstEnergy Operating Company Company Davis-Besse Davis-Besse Nuclear Power Station Nuclear Power Station O'Claire, Chief, Carol O'Claire, Radiological Branch Chief,Radiological Branch 5501 5501 North State - Route North State Route 2 Ohio Emerger. Emerger:;y Management Agency

                                                             -y Management Oak Harbor, OH 43449-9760 43449-9760             2855 West West D           Granville Road Alin Granville D: )lin Columbus, C t1 43235-2206 43235-2206 Jay E. Silberg, Jay      Silberg, Esq.

Shaw. Pittman, Potts Shaw, Pittman, Potts Director Director and Trowbridge Trowbridge Depatment of Commerce Ohio Depa.tment Commerce 2300 N 2300 Street, NW. N Street. Division Division of Industrial Compliance Industrial Compliance Washington, DC 20037 Washington, 20037 Bureau of Operations Bureau Operations & & Maintenance Maintenance Tussing Road 6606 Tussing Road Regional Administrator Regional Administrator P.O. Box 4009 U.S. Nuclear NuClear Regulatory Commission Reynoldsburg, OH Reynoldsburg, OH 43068-9009 43068-9009 801 Warrenville RoadRoad Lisle, IL 60523-4351 lisle,IL.60523-4351 Ohio Environmental Protection Agency Ohio Environmental DERR--Compliance DERR--Compliance Unit 0 Michael A. Schoppman Michael Schoppman ATTN: A TIN: Zack A. Clayton Clayton Framatome Framatome ANP ANP p.o. 1049 P.O. Box 1049 1700 Rockville Pike, Suite 525 Columbus, OH 43266-0149 Col!Jmbu5,OH 43266-0149 Rockville, MD 20852 Rockville. 20852 Ohio State of Ohio Inspector Resident Inspector Public Utilities Commission U.S, Nuclear Regulatory U.S. Regulatory Commission 180 East Broad Street

                                                .East Broad    Street North State Route 2 5503 North                                  Columbus, OH 43266-0573 43266-0573 Oak Harbor.

Harbor, OH 43449-9760 43449-9760 Attorney General Manager Plant Manager Department of Attorney Operating Company FirstEnergy Nuclear Operating 30 East Broad Street Davis-Besse Nuclear .Station Nuclear Power .Station Columbus, OH 43216 Columbus,OH 43216 5501 North State - Route 2 43449-9760 Oak Harbor, OH 43449-9760 President, Board of County Of county Commissioners of Ottawa County Port Clinton, OH 43252 S144D-0727 4 5140-07274 NRC008-1926 NRC008-1926

DOCKETED USNRC USNRC kITS C-LO~

                                                                                             ~.~re DAVID
                                                                                                       ~~~ID GEISEN U.S. NRCc September   9, 2009 (11 September 9,2009       (11:00am)
OOam) In GEISEN 5-I- ft f- ExhibIt 8d t &1 I NRC NRC FORM 658 q(9-1999)

(9-1999) 0 FFICE OF OFFICE OF SECRETARY RULEMAKINGS SECRETARY RULEMAKINGS AND

                                                            - - - - - - - Docket # 1A-05-052 fl,~r~p.fin~   I A-c-n%

Date Marked for ID: Il/i/ V 2008 (Tr p Date Marked for ID:.L4JL. .. 2008 (fr. p....... g25 ) AlDJUDICATIONS STAFF ADJUDICATIONS STAFF Date Offered Date Offered in in Ev: Ev: JJ1f1:. , 2008

                                                                                                                                            ~008 (fr.  (Tr. p.. 31 0 )

TRANSMmAL OF MEETING HANDOUT TRANSMITTAL HANDOUT M, Through WltneSS/Panel:'""""":""+-tJ~/:.....8 Witness/Pane:___ / ___P ___ _ __ IMMEDIATE IMMEDIATE PLACEMENT IN IN THE PUBlPUBL Action: _~ M REJ~~ED WITHDRAWN REJECTED WITHDRAWN Date: .J24L. , 2008(Tr, 2008 (fr. p. p.- gkV )) . This form is to be filled out (typed or hand-printed)by the person or hand-printed) announced the meeting person who announced meetiilg (i.e., the person person who issued the meeting notice). notice). The completed form, and the attached attached copy of meeting handout handout materials, will be sent to the Document materials, Document Control Control Desk on the same day of the meeting; under no meeting; under circumstances will this be done later circumstances than the working day after laterthan after the meeting. meeting. Do not include proprietary materials. include proprietary materials. DATE OF OF MEETING MEETING The attached document(s), which was/were attached document(s), handed out in this meeting, is/are to be placed was/were handed 11/28/2001 1112812001 in the public domain as soon as possible. The minutes of the meeting meeting will be issued in the the near future. Following are administrative regarding this meeting: administrative details regarding Docket Number(s) Docket 50-346 50-346 Plant/Facility Name Plant/Facility Name DAVIS-BESSE DAVIS-BESSE TAC Number(s) TAG Number(s) (if(if available) available) MB 2626 Reference Meeting NoticeNotice ADAMS NO. ML013310537 ML013310537 Purpose of Meeting Meeting (copy from meeting meeting notice) notice) information related to supplemental To discuss information supplemental information regardind inspection information inspection plans and commitments for Davis-Besse commitments Davis-Besse in response response to Bulletin 2001-01 NAME OF PERSON WHO ISSUED MEETING NOTICE NAME TITLE TITLE STEPHEN P. SANDS STEPHEN PROJECT MANAGER PROJECT MANAGER OFFICE NRR NRR DIVISION DLPM BRANCH PD 1II-2 111-2 Distribution of this form and attachments: !Docket File/Central File / M06BLIC I NRC FORM 658 658 (9-1999) (9.'999) PRINTED RECYCLED PAPER PRINTED ON RECYCLED. This form was designed designed using using InForms InForms T OL yc-c - ýf 'na--e 6S:---

NRC FORM 658 U.S. U.S. NUCLEAR NUCLEAR REGULATORY REGULATORY COMMISSION COMMISSION (9-1999) TRANSMITTAL OF MEETING HANDOUT TRANSMITTAL HANDOUT MATERIALS MATERIALS FOR FOR PLACEMENT IN IMMEDIATE PLACEMENT IMMEDIATE IN THE PUBLIC DOMAIN DOMAIN This form is to be filled out (typed or This orhand-printed) hand-printed) by the personperson who announced announced the meeting (i.e., (i.e., the person who issued issued the meeting notice). The completed form, attachedcopy of meeting handout form, and the attached handout materials,will be sent to the Document Control materials, Control Desk on the same day of the meeting; meeting; under under no circumstances circumstances will this this be done done later later than.the the working day afterafter the meeting. meeting. include proprietary Do not include materials. proprietary materials. DATE OF MEETING MEETING attached document(s), The attached document(s), which was/were was/were handed out in this meeting, is/are to be placed 11/28/2001 1112812001 in the public domain domain as soon as possible. The minutes of the meeting meeting will be issued in the the administrative details regarding this meeting: near future. Following are administrative Docket Number(s) 50-346 50-346 Plant/Facility Name Plant/Facility Name DAVIS-BESSE DAVIS-BESSE TAe Number(s) (if TAC (ifavailable) MB 2626 MB2626 Reference Meeting Notice Reference Notice ADAMS NO. ML013310537 ML013310537 Purpose of Meeting Meeting (copy from meeting notice) To discuss information related to supplemental information related supplemental information regardind regardind inspection plans and commitments commitments for Davis-Besse in response to Bulletin Bulletin 2001-01 NAME OF NAME OF PERSON PERSON WHOWHO ISSUED MEETING NOTICE TITLE TITLE STEPHEN STEPHEN P. P. SANDS SANDS PROJECT MANAGER PROJECT MANAGER OFFICE OFFICE NRR DIVISION DLPM BRANCH BRANCH PD 111-2 111-2 IDistribution of this form and attachments-Distribution of this form and attachments:

 )ocket File/Central File
 )UBLIC INRC FORM 658 (9-1999)

(9*1999) PRINTED ON RECYCLED PAPER Th;s foon was designed using InForms This form (nForms

Igfefifs Agenda ~ Introduction/Background Introduction/Background Steve Moffitt ~ Deterministic Model Deterministic Dave Geisen ~ Probabilistic Risk Assessment Probabilistic Assessment Ken Byrd ~ Inspection Plans Inspection Plans Mark McLaughlin McLaughlin

                   ',~' 'T:",1 :1,' I'

~ Closing Summary Steve Moffitt Moffitt FENOC I

Today'sOuicftive Todays Objective ProvideReasonable Provide Assurancethat ReasonableAssurance that Davis-Besseisissafe Davis-Besse operateuntil safetotooperate until February 16,2002*.: February16, 2002~t TION4

  • oc* FENOC fENOC 2

Background:

Background:

      ~r  NRC Bulletin 2001-01 2001-01 response provided
      ~z  Telephone Telephone call received     September 28 received on September  28
      ~ Teleconference
      *-  Teleconference on October 3
      ~O Brief drop by visit on on October October 11 11
      ~                              October 24 Meeting with NRR Staff on October
      ,iý-Meeting                            24
      ~

i N NRR RR Staff and ACRS meetings on November and-AC.R"S &9 November 8 &

      ~
      ,i-              NRR Staff on November Meeting with NRR           November 13
      ~- Teleconference Teleconference      November 26 on November

ýFATION 4 FENOC FENOC

                                                             '3 cELLE 6                           3                        -

DeterministicAspects DeterministicJAspects DBNPS's evaluation is based on visual inspectIons inspections performed performed in 10, 11,11, and 12 RFO (May 1996, April 1998, and April 2000). The inspection inspection results afford us assurance that all but 4 nozzle nozzle penetrations were inspected in 1996, all but 19 inspected penetrations inspected in penetrations inspected 1998, and all but 24 penetrations inspected in 2000. nozzle population is those nozzles The limiting nozzle nozzles that could not inspected in 1998 be inspected 1998 or 2000. It is conservatively It conservatively assumed assumed that for these penetrations, penetrations, an axial through-weld through-weld flaw oCGurs occurs immediately immediately upon startup from from 10 RFO (May 1996).1996). FENOC 4

ILniIalFlnwSize lo/lial Flaw Size Initial flaw depth of 0.5 mm, 172 17200 around the the nozzle, is assumed assumed to exist immediately immediately upon achieving achieving a full penetration penetration axial axial flaw. BASIS: BASIS: i This is a conservative i:.l conservative flaw initiation site size.

  • ItIt is further conservatively i:.l conservatively assumed that multiple starting flaws could exist and that these would eventually eventually link together.

i It is conservative i:.l th~tby conservative in that by assuming this starting point, wewe assuming that wehave also are assuming we ""have already already had several years of flaw propagation propagation axially through the Alloy 182 weld material. material.

  % *FENOC                                                   FENOC 5

Use ol Nso ofModified ModiHed Scoff Seon ModelModel Modified Scott The Modified Model is still deemed Scott Model credible as deemed credible as mean curve for crack growth a mean growth rates. i:l Data received received to date negate the curve. date does not negate curves have been Numerous curves i:l- Numerous developed and to aa certain been developed degree, they all rest on engineering degree, engineering judgement. ii:l The data from OTSGs for Alloy 600 is relevant Alloy 600 relevant for developing developing the CGR conservative in that the Alloy CGR curves and in fact is conservative Alloy are still relevant .and properties are properties and because cold-working of the because any cold-working the tubes at the tube support sneet would increase support sheet increase the failure rate 600, will make non-worked Alloy 600; over non-worked make this conservative. /_P FENOC FENOC 6

Iisk-Ilnformed Risk-InformedEvaliiationlEvaluation i:lSDavis-Besse provides a~ bounding assessment provides Davis-Besse risk assessment bounding estimation of risk. Bounding estimation conservative assumptions Bounding or conservative assumptions were were used used to to resolve uncertainties. uncertainties. i:l Studies of sensitivitywas i" Studies sensitivity was performed significant performed for all significant parameters. parameters. i:l indicate incremental ir Results indicate would* be bounded incremental CDF would bounded in the "small" category'and expected to be "very small" categol)rand expected per RG 1.174. Incremental LERF and Public health risk is expected

  • i){ Incremental expected to be negligible.

negligible. TION4

ý,,?7 FENOC 7T7 FENOC. =-

7

Risk-InformeduEvaluation Risk-Informedlvaluation Nozzle leak IenkFreguency Frequency The Davis-Besse Davis-Besse plant specificspecific PSA has used u~ed the method method Framatome analysis which from the generic Framatome which applies a constant leak initiation frequency. i The constant i:l constant rate over predicts the number of leaks in in early cycles. ',"'",' .','0' i:lr Impact Impact of inspection inspection on conditional probability of a conditional probability leak at at a future date is not quantified. quantified. FENOC FENOC 8 ' . . : , _ ...... r ( .;;::-....

Risk-informed Risk-InformedEvalualion Evaluiation Nozzle leak Noole LakFrequ~ency Frequency Other approaches approaches have assumed that the onset of leakage leakage can be approximated approximated by a two parameter parameter Weibull cumulate probability cumulate probability distribution.

~
*-The The Davis-Besse risk assessment Davis-Besse         assessment was modified to apply a Weibull WeibuJi distribution.

distribution. ~Studies

*Studies were perforrned performped to investigate investigate the sensitivity to to the Weibull scale and shape parameters.

~i-The The conditional conditional probability of a leak by a future date date given no leak now can be calculated calculated if a nozzle nozzle has been leakage detected. inspected and no leakage FENOC FENOC 9

Risk-InformodEvalualion NozzlueLek Nozzle leakFreguenlcy Ilequency Leaks for various Predicted Leaks Predicted Weibull Leak various Weibull Initiation Models Leak Initiation Models Expected Number Expected Number of Leaking Leakine CRDM Nozzles Nozzles Davis- EPRlMRP EPRI MRP Davis-Davis- Davis- Upper Davis- Besse Median Median EPRlMRP EPRI MRP Shape Shape Besse Besse Davis- Besse Upper Besse EFPY (95%) Refueline Refueling Besse EFPY (95%) Projection Projection WeibuU Weibull Parameter Parameter EFPY Corrected Projection Outaee Outage EFPY Corrected Projection I.S Shape 1.5 Shape Model Model Modified Modified to 600F 1.5 Shape 1.5 Shape Parameter Projection Parameter Pro.iection Scale Scale Parameter Parameter Parameter Parameter to 10 10.56 10.56 12.91 12.91 5.0 1.0 1.0 9.5xl0- s 9.5x10o- 0.02 0.02 11 II 12.33 15.07 6.3 6.3 13 1.3 1.7xlO-33 1.7x10- 0.36 0.36 2 12 14.06 17.18 7.6 1.6 1.9xlO-1.9x10- 4.00 4.00 13

  -13     15.81    19.32 19.32         8.9 8.9           1.9 1.9           0.17        28.3
    -     16.37 16.37    20.00 20.00         9.3           2.0           0.32        43.7 FENOC I0 10

Is-Iiformed Risk-Informed iEIvalualio Evalualion Past/InspICft/ons Pas/lnspec/ions i:r Inspections Inspections were were assumed assumed to havehave aa failure failure probability probability ofof 1.00 1.00 if boron boron inhibited inhibited detection detection ofof nozzle nozzle leakage. leakage.

      ~r   Inspections Inspections were were assumed assumed to havehave aa failure failure probability probability ofof 0.05'if no boron 0.05.)([19 boron was was present.
      ~r   Sensitivities Sensitivities were were performed performed to  to investigate investigate the the effect effect of of various various leakage leakage detection detection probabilities.

probabilities. 4CE'1'r% U.401o , FENOC FENOC 11

Risk-Informed Risk-IuformedEvaluation Ivalualion Probabi/hityOf Circumf ~erent/iuCracking ProbabilityofCircumferential Cracking -2r Evidence i:l Evidence from recent B& B&W inspections W plant inspections indicated that not all axial cracks has indicated have cracks have resulted in initiation of ofcircumferential circumferential cracking. cracking.

*- B&W plants have experienced i:l                      experienced 27 axial cracks cracks and 6 circumferential circumferential cracks.

i:lSProbability initiation of a circumferential Probability of the 'initiation crack is estimated estimated to be 0.22 based on B&W B&W evidence. OC FENOC FENOC 12

Iisk-luformedEvuliuatio Risk-Informed Evaluation Noole Failure Nozzle FailufeProbability ProliabliAY

~r Probability of CRDM nozzle failure is determined by performing a Monte determined                         Monte Carlo Carlo simulation on the Scott deterministic deterministic crack growth model.*

model. 7~ Conservative.:or assumptions were Conservative or bounding assumptions were used when data Wa's"tiot .used wags*not available. ~ Studies were performed performed to investigate investigate the the sensitivity to all significant significant inputs. FENOC FENOC 13

                           ,I.,J

Risk-Informed Risk-IiformedfEvaluationvalufaion Noole Nozzle Failure FailureProbability Proljauiift--Consel1lative Assumptions Conservative Assumplitns ~SInitial Initial crack size - Applied a uniform distribution from 0-180 degrees. ~ f Stress Profile - Uses the worst case stresses. ~*" Crack Growth _Rate Coefficient - Applies crack growth rate coefficient-from coefficient from heat 69. kTJON4

         "    '   _     . C 4   ~  v1            FENOC 14 14

Iisk-lIf ormedEvalufation Risk-Informed Evalualion FailureProbablutVY-NooleFailure Nozzle SCnsitflity Su ProbabilitY -SensitivitY ries Studies f~ Initial crack size Initial crack size i:lr Initial crack depth... Initial crack depth . . i~ Temperature Temperature ir Stress Profile

     ~ Stress        Profile FETIOC Crack Growth n~ Crack                   Rate Coefficient Growth Rate      Coefficient 41LI-                =11%FENOC           FENOC kCELLO G                              15 15                     -- . ~

Risk-Informedlvaluation i~sk-~lnformneIEvauIatiuo Conditional COle Damage/Release CoonlitioalCore M/mage leelasse PlobabililY IBM=ia uiItV

~ Davis-Besse "i-   Davis-Besse conditional conditional core damage damage probability probability for aa 0.1   ft2 medium LOCA                   3 0.1 ft2                    is 2.7 x 10-10-3..
~

n Conditional Conditional large-large- early early release probability probability for aa medium LOCA is about about 4.0 x 10- 6 10-6..

~ The conditional.
*"                     cor,e.,.q~mage conditional core,,, amage probability probability for this this analysis analysis is less less than applied in the PSA because because the the medium LOCA LOCA range range in the PSA is 0.02 ft    ft2 -- 0.5 ftft2.

2 2. RATION FENOC FENOC 16 IV

IiSk-lfurmedfvaliiafiui Risk-Infolmed [valuation Results Results Upper (95%) EPRI MRP EPRIMRP Constant Initiation Initiation Projection Projection Shape Parameter Parameter Frequency Frequency 1.5 Shape Modified Modified Scale Scale Parameter Parameter Parameter Best Best Best Best Bounding Bounding Bounding Bounding Bounding Bounding Estimate

                   . Estimate                Estimate CDF          1.8 E-6    9.9 E-8   1.1 E-6      6.3 E-8   3.3 E-7     1.9 E-8 LERF         2.6E-9 2.6 E-9   1.5E-10 1.5 E-I0   1.7E-9 1.7 E-9     9.4E-11 9.4  E-ll 4.9E-10 4.9 E-lO    2.8E-1I 2.8  E-11 Person REM    0.16     9.2 E-3      .11
                                   .Il        5.9E-3 5.9 E-3  3.1 E-2      1.7 E-3 1.7 FENOC FENOC 17

Iisk-IiformedfEvaluiation Risk-Informlld Evaluation Unique Aspects ofDavis-Besse Ufniuuelspects RiskAssessment Olavis-BesseIiskAssessmenI

        *-    Inspection Information
        'tf Inspection    Information - Davis-Besse      Davis-Besse inspections do do not indicate evidence evidence a nozzle    nozzle leaks.
        ~-                   Information - 64 of 69 Davis-Besse Material Heat Information                             Davis-Besse nozzle material heats have no history of axial or circumferential circumferential leaks at other plants.
                                 ',1 " ."'~ *.' 11:".~ .

ATIOAv EWP * ,- FEN O C FENOC 18

                                                          ,IL,*

Risk-inf Risk-Infolmod ormedfvIIiuationIvaluation Conclusions CORiCIMPHSi1$ ii:.f CDF CDF -- The The plant specific risk plant specific risk assessment assessment conservatively conservatively estimates a bounding- incremental core damage frequency estimates a bounding- incremental core damage frequency to to be in be in the range which the range which is categorized as is categorized as "small" "smafl" per RG 1.174. per RG 1.174. The The actual incremental core actual incremental damage frequency core damage frequency would would bebe categorized categorized as as "very small" per RG smal!""per RG 1.174.1.174. it tl LERF LERF -- The The plant plant specific specific risk risk assessment assessment conservatively conservatively estimates a bounding incremental large early estimates a bounding i_':l~.f~!!1ental large early release release frequency which frequency which is categorized as is categorized as "very "very small" small" per RG 1.174. per RG 1.174. The actual incremental release frequency The actual incremental release frequency i~,negligible.i.s negligible. ttPublic Health Risk - The plant specific risk person rem per tl Public Health Risk - The plant specific risk person rem per year year is is negligible. negligible. TION. c"% FENOC FENOC ,. *,e 19 19 --- 1._-.-.-,_Z

Inspection IiispectioiiPlans Plans 13RFO:

 , 13RFO:

iX

     ~ 1000/0 i-     100% qualified visual 1:l100%)

100% NDE NDE

     ~*-         characterization if found.

Flaw characterization

     ~*-   Data will be made available for industry use.

iXA- Vessel HeadHead Replacement available Replacement at first available opportunity RATIO 4 e F~MFENOC. FENOC 20 K

Davis-Besse lavis-ResseSpecific Specific Features andActions asodActios

        -Record of inspection ilRecord       inspection from last three outages.

i-Only B&W ttOnly B&W plant with a plant with a continuous continuous head head vent vent which which provides high confidence confidence in temperature measurements. temperature measurements. iýReduce reactor vessel head temperature ilReduce 605OF to temperature from 605°F 598 0 F. 598°F. 7Additional il Additional training for Operators iss~~s raised in Operators on issues Bulletin 2001-01. 2001-01.

       ,Maximize availability of redundant i!Maximize                    redundant critical safety systems.
~tRATJON   CRs
            ~)   Scope reductions reductions @@ T-9 r-9 && T-6
            );>P Additional FIN FIN team supervisors
             ý
            );0  Additional shop scheduling Additional                     coordinator positions scheduling coordinator Challenga C.halh~nge of an Ir:ldetenninate Indeterminate RFO Schedule Schedule to Outage Management Vlanagement Effectiveness EffectivenE:ss
 ** Expedited Expedited new fuel delivery schedule schedule
 "     Balancing
  • Balancing budgets, cost, and schedule risks in determining determining when needed parts will be be ordered ordewd
** Revised Revised background background check process process implications implications
** Shrinking Shrinking number "N"  "N" stamp vendors & commercial commercial grade dedication dedication
    • Development Development of of revised radiation worker training practical practical factor curriculum curriculum Discussion summary rid actions:

Mr- Bergendahl Mr. Bergendahl indicated that the reason site management management selected Work Management Management as the focus tocus area forfbr this CNRB meeting was their concern concern for why we're in such a reactionary reactionary mode to emergent emergent issues. Mr. Campbell Mr. Campbell indicated that as the FENOe FENOC sponsor sponsor of Work Management Management he was surprized and embarrassed embarrassed that we are not using Change Change Management Management more effectively effectively and management and management clearly clearly needs to be more intrusive and define define what "good" "good'" is and monitor monitor performance for perfi>rmance meeting expectations. He thanked for meeting thanked the membership membership for their observations. Operate Plant/Training (On Operate the Plantlfraining (OT) Mr. Kane repol1ed Mr. reported on the OT Subcommittee Subcommittee review. The following Subcommittee Subcommittee presented. A discussion summary is presented at the end of the section. observations were pre!;ented. Focus Work focus Work Management Management (Mr. Kane's field notes are included included in Attachment Attachment A) A)

    • Roll up of interviews Roll observations interviews and observations
       -- There     are communication There are communication problems problems
      -- There      are perceived There are   perceived teamwork problems
      - Implementation Implementation of the process ineffective 5                                          FEDB. 000011 FEDB*    000011 DOJ003-000562 DOJ003-000562

ComPany Nuclear Comp:omy Revi,~w Board Nuclear' Review Mc{:ting November 29, 2001 Meeting Date November

    --    Not Nul capturing capturing work management management failures
    --    Planning &  & scheduling scheduling of work not integrated
** Considerations Considerations
    - Need analysis/d~lta-resist analysis/dnta-resist quick fixes t.ixes
   - Dowment Document accountability accountability  for all  schedule schedule changes
    - Staff FIN with parts, Radiation Protection Protection (RP),

(RP). && Opcrationss frolks Ifolks

    - ImplemenC Implement short cycle scheduling tool for low eM         CM BfLB/L plants
    - Move to all Work   Work Week Week Manager (WWM) being         being active SRO and man Work Control O~nter Contr'ul   Center (WCC)

(WCC) on their work week days

   - CrAftCraft resources resources removed with no regard regard to getting work done; training commitment commitment time must be integrated integrated with work schedule-tail is wagging the dog
      -   Every Every work management management meeting meeting should document negative em!cts       effects on on schedule schedule
    --- Priority Priority orof work is driven by personality; personality; everything everything can't be of equalequnl importance importanfe
    -     Need Need to move to where we plan work before we schedule, insure System Health work is done, and risk of aggregate B/L is evaluated-improve H{~alth                                                       evaluated-improve, material material condition condition
     -- Tagging Tagging staff understaffed-need understaffed-need electrical electrical and I&C tagging research aid; packages late Q.perate Q.ru;rate the Plant.'Training    Subcommittee Observations Plant/Training Subcommittee
  • Management
  • l\.lanagement
   -- Resource Resource reductions reductions are perceived perceived to be adversel,y adverselly affecting   performance in affecting performanct:     in chemistry, training, and operations
   -. Repeated Repeated Tagging Taggi.ng Program failures demand management            attention-cormnon management attention-common process   weaknesses process weaknesses     suggested  by  interviews Operations

.' Operations Equipment Equipment issues are EDG air start system, RPS couch relay failur<:s, failures, & AFW

                                                                                           & AFW MOV BTI!aken.

MOV Breakers

   -- Staffing plan suggests adequate adequate SROs 4s    #5 in 2003
   --     Several openings requiring over time coverage Procedure changes
   -- Procedure        changes are being done on shift

..* Chemistry

   -- Equipment issues are condenser inleakage, fuel failures, MIU         M/U water syst.em, system, MSDD skid inadequate, inadequate, RE4597 (Containment RMS) TIM        T/M operations operations RE4597 operating operating w/o wlo charcoal  canister-question if grab samples required to charcoal canister-question source term during unmonitored release provide source                                  releasl!
    • Training training
    --    Consider Consider using water plant as a training lab after MiU        MIU water      modification is water modUfication installed installeeJI with witb budget cut of new lab building building 6                                        FEDB-000012 FEDB- 0000 12 DOJ003-00056-3 DOJ003-000563

Comp;:my Nuclear Company Nuclear' Review Review Board Board Mecting MedingDate Date November November 29, 29,2001 2001

     --     Management Management involved involved inin observations, observations, teaching, teaching, CRCs, CRCs, STCSIC
     --     Management       not  responding      to  resource    needs Management not responding to resource needs forinstructional  for  instructionalneeds needs like like FITS FITS mod mod
  • Tour/Cbservations Tour/Observations Turbine TurbineBuilding Buildinghousekeeping housekeepingmuch much improved improved
     - - , Radiological Radiological Restricted Area (RRA) access Restricted    Area    (RRA)      accessarea area very very professional professional
     -._. Work      areas  in  Personnel    Shop     Facility Work area~, in Personnel Shop Facility improved    improved
       -- Control Control room roomcommunications communicationsprofessional professional
     -.-. RRA RRA and andEDG EDG #1   I housekeeping housekeeping improved; improved;leaksleaksnoted noted ononEDG EDGfuel fuel filters filters Noted    some    labeling   problems      on  tanks
       -, Noted some labeling problems on tanks & breakers      &   breakers Discu;sior. summary and actions:

ItItwas wa:~ suggested suggested thatthat Mr. Mr. Steve Steve Moffitt Moffitt follow follow up up on 011 aa Temporary Temporary Modification Modification on on Containment Containment MonitoringMonitor'il1lg in in light light of of the the Reactor Reactor HeadHead Control Control Rod Rod Drive Drh'e nozzle nozzle cracking issue cracking llssue and and possible possibJeleakage. leakage. Mr. Bergendahl took Mr.IBergendahl took an an action action to to look look atlit developing developing guidance guidance for for Opeirators OpeJ:-ators toto recognize Reactor recognize ReactorVessel Vessel Head Head and and Steam Steam Generator Generatortube tubeleakage leakage telltales telltalesand :tnd their their potential implications. (Action - DH pot'~[ltial implications. (Action- DB 11/29/01-01) 11f29/01-01) Mr. Mr. KandaKanda tooktookan an administrative administrative action action toto ensure ensure that that the theTuesday's Tuesday's PlantPlant Status Status presentations presf'ntations include include the the identification identification of of plant plant challenges challenges to to safety safety for for CNRB CNRB probing. probing. Contiauration ConiigurMion Control/Equipment C;ontrol!EguipmentReliabilityReliability(CMi (eM) Mr. Mr. jackJack Martin Martin reported reported on onthe the CM eM Subcommittee Subcommittee reviewreview results. results. Mr. Mr. Tim TimRausch Rausch and and Ms Ms Jeannie Jeannie Rinckel Rincke! participated participated inin the the presentation. presentation The The following following Subcommittee Subwmmittee obser-vations observationswere wef1~presented. presented. AA discussion discussionsummary summaryisis presented presentedatat the the end end of the section. oftlle section_ Work WorkManagement Managem~nt 1.1. Over Overthe thelast lastyear yearthe the System SystemHealth HealthReports Reports(SHR) (SHR)havehavebeen beenupgraded upgradedtoto identify identify what work items are needed to be completed to resolve

      \,,,hat work items are needed to be completed to resolve problemswith     problems    withsystems systemsin    in
    ,"red" or in "yellow" status. These items together with the operator concerns are the "red" or in "yellow" status. These items together with the operator concem; are the ones (mes most most aflecting affectingsystem systemand and plant plantreliability.

reliability. The Theintent intenthas hasbeen beento togive give these these items particular visibility and priority in the work management system. items particular visibility and priority in the work management system. This has not This has not worked workedout outasaswell wellasashoped. hoped. For Forexample, example,for for2Q01, 2QOI,41 41 of 64 critical of64 criticalwork workitemsitems were were scheduled scheduled and and only only 3232actually actuallycompleted. completed. For For3Q0 3Q01,1, 50 50of 70 critical of70 criticalwork work items were scheduled but only 22 completed. Two CRs have items were scheduled but only 22 completed. Two eRs have been written onthis been written on this inatter. matter. 77 FEDB- 000013 FEDB~000013 DOJ003-000564 DOJ003-000564

Cornpnny Company NuclearNuclear Review Review Board Board Meeting Meeting Date Date November November 29, 2001 29,2001 This This situation situation needs needs close close attention attention by by the the production pmd'(Jction managers managers (production (production team). Each of these work items should team). Each of these work items should be revi4!wed and its be reviewed and its status status assessed. assessed. Priority Priority should should be be given given toto planning planning all all of of these these jobs, jobs, identifying identifying all all restraints fe!straints and and resolving resolving items. items. The The status status of of these these critical critical SHR SHR itemsitems together together with with operator concerns should be reviewed weekly by operator concerns should he reviewed weekly by the production team until the production team until itit is is under under management manag(':ment control.control.

22. ItIt would would appear appear that that aa large large backlog backlog of of engineering engineering work work will will be be needed needed to to support support mainterance work that has accumulated. I was unable mainterance work that has accumulated. I was unable to get a clear idea of howto get a clear idea of how much much workweek work has been impacted, however, this situation workweek work has been impacted, however, this situation needs resolution. II have needs resolution. have several several suggestions suggestions that that have have proven proven effective effective at at other other sites.
    "* AllAll engineering enginel~ring work  work requests requests should sbould be   be screened screened by     by aa multi-discipli.ary multi-disdplinary committee committee to   to ensure ensure the  the work work isis really really needed needed and    and whether whether aa non-   nOI1-engineering       solution      might    be   more engineering solution might be more appropriate.        appropriate.
   "* AllAll new new work work should should be   be initially initially planned planned within within 30    30 days days and and engineering engineet"iog and   and long   lead   parts     identified. Not    planning      the    work long lead I)arts identified. Not planning the work until the workweel, processuntil   the    workweek         process starts starts isis not n~)t aa success success path.

p:lth. We We need need to to schedule schedVlle already already planned planned work work not not vice vice versa. versa.

    "    Avoid Avoid engineering engineering work    worl{ that that is is not not needed.

needed!. As As during during CycleCycle 12, 12, considerable considerable engineering effort went into Cycle 13 MODs engincerirng effort went into Cycle 13 MODs that will not be done. that will not be done. It It would would appear appear th th at at about about 30 30 MODs MODs were were designed designed yet yet will will not not be be installed. installed. This This was was despite a CNRIB discussion and agreement that despite a CNRB discussion and agreement that this situation would be this situation would be avoided. avoided. This This hashas aa further fUJ'ther negative negative downside downsidf! on on morale morale in in the the engineering engineering groups. gr*()ups.

  • Better Bdter management m~lnagemelI1t and and screening screening of of the the engineering ellgineering workloadworkload to to those those items items genuinely genuinely needed needed to to support support the the station station cancan likely Iillcely improve improve productivity producti'vity and and create a desire to work create a desire 'Work longer hours.longer hours.
  • The The newnew Rapid Rapid Response Response Team Team in in engineering engineering will will likely likely be be most most helpful belpful ifif the the above abovli: items items are ate addressed.

addressed. II will will put put Glenn Glelln McIntyre McIntyre in in touch touch withwith thethe supervision of a successful effort su pervision of a successful effort at PSE&G at PSE&G 3.

3. The production team Thel.roduction te:am meeting meeting needs needs to to be be accountability accoullitability forum forum to to deal deal with with work that leaks out of the schedule after T-12.

work that leltks out ofthe schedule after T-12. Work management: needs Work management needs to to generate geoel'ate the data data to make make this this meaningful. meaningful. 4.

4. The.Theequipment equipment reliability reliability program program is is now now starting starting to to develop develop and and apply apply thethe equipment

(~uipment reliability templates to our major systems and components. reliability template~; to our major systems and components. This is starting to This is starting to result result in in changes changes needed needed to to the the PMs. PMs. Based Based on on experience experience at at other other plants plants this this will, willbebe aa large large and End unanticipated unanticipated workload workload on on the the planning planning organization organization for for aa number number of of years years toto 8 FEDB. 0000 14 8 FEDB_ 000014 DOJ003-000565 DOJ003-000565

Company Nuclear]Nuclear ReviewReview Board Meeting Date November 29, 2001 Meding core. lI unde.-stand corne. understand that that the the planners are already overloaded and an~ are resisting planning the F'M planning PM changes changes that have been submitted in in aa timely manner. This Trhis needs to needs to be as!iesse

  • mmitteeAction: Action: Steve SteveMoffitt Moffitt Assessment. Asse5sment. Inspection InspectionAnd And Evaluations Evaluation~~ Quality Assessment (QA) Quality Assessment (QA) presented presented an an integrated integrated Self-Assessment/QA Self-AssessmentlQAactivity activity planplanforfor 2001 which was 2001 which was reviewed reviewed by bythe the committee committeeand and commended commended Chuck ChuckAckerman Ackerman .For for putting putting it:it together. togetht::r. Quality QualityAssessment As!ieSsment over overthe thelast last 18 18months months has hasbeen been reviewinIg reviewing engineering engineering activities more then ever before and has uncovered activities more then ever before and has uncovered problems in the problems in theEQ,EQ, Vendor Ve,ndorManualManual
    program, program, and and so'ftware so~ftware areas.
    areas. Contractor f:;omractorOvernight Overl,ight Tim TimRauschRauschalsoalsoreviewed reviewed progress progress on onaaCritical CriticalSuccess Succe~isArea AreaInitiative Initiativeintended intendedtoto improve improvecontractor contractoroversight oversightand and performance perfonnanceatat Perry. Perry. This Thisinitiative initiativeseems seemsto tobe beaa step step ininthe fight direction and should deal with the types of problems the right direction and should deal with the types of problems encountered in the recent encountered in the recent Perry Perryoutage.outage. ItItwas wasagreed a.greedthatthatthis this initiative initiativeshould shouldbe be of ofinterest interestto toall allFENOC FENOC plants. plants. This topi.c would This topi.c wouldbe beaagood goodcandidate candidatefor foraaCNRB CNRB presentation presentationatataafuturefuture meeting. meeting. 1212 FEDB- 000018 FEDB* 0000 18 DOJ003-000569 DOJ003-000569 Company Company Nuclear Nuclear Review Review BoardeBoard Meeting November 29,2001 Date November Met:ting Date 29, 2001 Problemn Sclving tr:Q.QI~:}l~~.lvi[Jg The The new tezhnical new te:hnical issue issue problem problem resolving resolving process process isis now now available available atat Perry. Perry. A A presenatioi will be presen ;atio::I will given at be given today's meeting. at today's meeting. Dis;cussion summary and actions: Mr. MJr. Jack hck Martin Martin suggested suggestE:d that th:u aa tutorial tutorial be be given given to to management management and al1Jd Operators Operators on the Work Management system so they better on th,c Work Management system so they better understand the c:onsequences understand the consequences emergent emergent changeschanges have have on on thethe site site inin total. total. Performance Perform:mce indicators indic.ators needneed to to look look at at the the whole whole WM 'VM process. process. Mr. Mr. Moffitt Moffitt took: iOo~; an an action action for for aa CNRB CNRB presentation prcsentntion at at the the MayMay meeting mt~eting on on the the . Equilpiment I<~quipment Reliability ReJjability Program. Program. (Action(Action -- DR DB 11/29/101-02) 1 l/29/f) 1-02) It It was wa:. suggested sUI~gested that that Ms.Ms. Jeannie Jeannie Rinckel Rinckel looklook into into anticipated nnticipated actions actions needed needed to to better ass ure against fiuel b(:ttel' assure against fuel failures. failures. Loss )?revention ILPM Los~Uf'revention fLPl Mr. Mr. Ron Ron Berryman Berryman reported reported on on the the LP U' Subcommittee; Subcommittee review review results. results. The The following following Subcommittee Subc(tmmlttee ob,;ervations observations were were presented. present.ed. Tie T:1e meeting meeting of the CNRtB ()fth,~ CNRB Loss Loss Prevention Prevention Subcommittee Subcommittee was was convened convened at at 0930 0930 onon November November 28, 20<H. The focus of the meeting was to determine the effectiveness of 28, 2001. The focus of the meeting was to determine the effectiveness ofthe the overall assessment process at (werall as!ieSsment process at Davis-Besse. Davis-Besse. The The fbllO\ving l1owing areas areas were were reviewed: reviewed:
    • Q QA CA Audit Audit Organization Organization and and Auditing Auditing Developments Developments
      • Recert Audits/Surveillances Recert Audits/Surveillances
      • Self-Assessments Self-Assessments
      • Emergency Emergency Preparedness Preparedne:ss Activities Activities
      • Staticn Trending/Self-Evaluation Station Trending/Self-Evaluation
      • Corrective Corrective Action Ac:tion Program Program
      • Regulatory Performance Regulatory PerformanGe quality**ssessment Audýt Program The Thc~ Subcommittee Subcommittee reviewed reviewed the the current current staffing staffing of ofthe the group group and and the the current current status status of ofthe the 200 1 audit plan and plans for 2002. It was noted that in 2001 audit plan and plans for 2002. It was noted that in 2002 the group would be2002 the group would be implementing impll~menting aa continuous continuous audit audit strategy.
    strategy. Additionally, Additionally, four four audits audits andand five five surveillance's surveillance's were wen: reviewed reViewed by by the the members members and and the the responsible responsible Auditors Auditors or or Surveillance Surveillance Specialists. Spt:cialists. The The following following are ar~ the the major major points points noted. note:d. do ** The The staffing  !;tafiing for for the the group group isis seen seen as,ru, aa strength strength based based on on the the number number of of individuals individuals and and iheir experience at Iheir experience at the the site and in site and in the the industry. Add:tionally, the industry- AddW.tionally, efforts underway the efforts undf:!rway toto 13 13 FEDB-F'EDB~ 00001!9 0000 19 DOJ003-000570 DOJ003-000570 Cornp,;.ny Comp~,.ny Nuclear Nuclear' Review Revi,ew Board Board Meeting Meeting Date Date November November 29, 29, 2001 2001 quazlf quc!lity new new individuals individuals are are very very good. good There There is IS some some concern concern withwith the the potential potential forfor los.; los:; of of expertise exp(~rtise over over time time due due to to personnel personnel rotating rotating outalit of of the the group. group. Continuity Continuity and and na:intaining suficient maintaining suficient experience experience in in the the Oversight Oversight organization organization should should be be monitored. monitored. .. Thes Th'3 quarterly quarterly sirveilance sJrveiEance produced produced by by the the group group is aa very '/ery good good roll-up roll-up of of issues issues andand is Hffecl:ive in providing management with useful information is dfective in providing management with usefuJ information Considera.tion should Consideration should be be given given to to subdividing subdividilJ11~ sections sections intointo groups; groups; e.g. e.g. Engineering Engineering into into Plant PIant F.:nginf:ering aind Engineering Illnd Design Design Engineering. Engineering. This This may may provide provide additional additional focinu. focm,. oSIP, Ii: was *...vas noted noted that that one one required required auditaudit element, element, Equipment Equipment Qualification, Qualification, was was missed. missed. This Tbis was was due due inin part part to to ineffective ineffective corrective corrective actions actions from from aa Notice Notice of of Violation Violation issued issued in 1998. As part of the Basic Cause performed under in 1998. As part of*the Basic Cause performed under CR 01-0427, seven additional CR 01-0427, seven additional elcments ekments were were identified identified that that had had notnot been been assessed assessed at at an an appropriate appropriate frequency frequency or or level. b/el. 'TheseThese e.ements, el,ements, including including Special Special Nuclear Nuclear Material Mat'erial Accountability, Accountability, ComputerComputer Software Software Control, Control, Inservice Inselvice Inspection Inspection and and Testing Testing and and others others had had no direct direct audit audit requirements requirements but but should should have hav<~ been been assessed assessed as as part part of ofhigher higher level level audits.. audits. TheThe remedial remedial and and corrective corrective actions actions taken taken as as aa result result ofof this this CR CR are are appropriate. appropriate.
      • A-idits AJdits and and surveillances sUiveillances are are detailed detailed and and ofofgood good quality.
    quality. The The surveillances surveillances performed performed on 011 thethe Emergency Emergency Diesel Diesel Generator Generator air air starting starting system system and and 1313 RFO RFO Modifications Modifications were were very very good, good, providing providing useful useful andand timely timely information. information The The surveillance surveillance on on modifications modifications identified identified aa problem problem with with update update of ofcontrolled controlled documents. documents. This This problem problem apparently apparently extends extends beyond beyond the the plant plant modification modification process. process The The audit audit covering covering the the EQEQ Program revealed significant program deficiencies. Program revealed significant program deficiencies. It should be noted that n~ It should be noted that nD self-a;sessments a;sessments (if of the the EQ EQ program program had had been been performed performed which which could could have have identified identified this this program program weakness. weakness. Self-Assessment ~,elf::.t\ssessrl)ent Program Yrogram Review Revi~~ An An overview overview of ofthe the status status ofofthe the program program was was provided provided by by the program program owner owner including including progress on the 2001 schedule and program changes. progress on the 2001 schedule and program changes. Additionally, eight Self- Additionally, eight Self-Assessments ASSessments were were reviewed. reviewed. Overall, Overall, the the program program was was considered considered very very healthy healthy andand well well implemented. impl'emented. The The following follcwing are are the the major major points points noted: noted: 01 .) Assignment Assignment of ofcrosscutting crosscutting or or broad-based broad-based Self-Assessments SeU:Assessments sponsoredsponsored by by the the Self-Self-Assessment Advisory Board is considered ,\ssessment Advisory Board considered a strength. a strength. 'D '. .elf-Assessments Self-Assessments are are generally generally of ofgood good quality quality andand are are assisting assisting the the station station inin ý:ontInuous ;ontinuous improvement improvement efforts.efforts.
      • Self-Assessments Self-Assessments seem seem to to be be using using moremore benchmarking.
    benchmarking. This This has has the the effect effect ofof improving improving the the overall overall quality. quality. Emergaey EIll'~rgeJ1~Prejaredness Preparedness AA review review of of the the current current activities activities and and results results of of audits audits andand corrective corrective actions actions was was perbormed performed for Emergency for Emergency Preparedness. Preparedness. The The manager manager presented presented details details onon these these areas areas as as well well asas aa discussion discus:;ion of of the actions actions taken taken by by the the group group after a:fler September September 11. 11. Overall Overall this this are'l isis well area well managed managed and and effectively effectively implemented. implemented. 14 14 FEDB* 000020 FEDB- 000020 DOJOO_3_000i7 DOJ003-000'n 11 Company Company NlJclear Nuclear Review Board Meeting Meetirig Date November'29, November H, 2001 Ltation Trending and Slati'~LIr,!,J1di~?lDd Self-Evaluation Self-Evaluation T"Fthe program Tte piogram (lwn*ers owners presented the current trends identified idelltified via condition condition reports. Additionaly, AdditionaLy, the new self-evaluaion process self-evalua':ion process was present,~d presented and discussed. The f,)llowing following are the ma~lor maior poin':s poin~:s noted: ** The The Self- Fvaluation process is very thorough and should provide managemel1t Self-Evaluation management with useful information inf,)rmation and a basis basis; for focusing resources on key issues. ** TheI he collegial review that is is part of the Self-Evaluation Self-Evaluation will result in better oversight oversight identifying common by identifying common issues. issues Correctivc; QJrre::;tivc~Action. Action Progt-am. Program. The rhe program owner and Quality Quality Programs Programs representatives representatives presented the current cur:rent status ofof the program program including indicators and trends trends. Additionally, Additionally, a selection of Condition ofColrldition Reports Repoi1s was reviewed icviewed to determine determine the overall quality of the reports. The following are the major points noted: rioted: "here are weaknesses in .' -:'hen~ in the performance performance of Basic and Root causes. These These were identiliec identiJlec during the INPO IJ'-IPO assist visit and the recently completed Regulatory Affairs completed Regulatory ,udit. The members <'udit members agreed agreed that actions should be taken to improve the overall quality quality of reports.. (If these (eports *, Management lvtanagemem shou'.d continie contin'JI;; the efforts to reduce redw;;e the backlog of older corrective actions. The actions currently in place should be eflective Hctions. efiective in eliminating eliminating them. .. T r'he response The investigations of Significant respons ;! time for investigations l Significant Conditions Conditions Adverse to Quality was !een
    een as c.a strength.
    ** The 4,' The 1'001 rool cause calise performed pelformed for for CR 2001-2623, Safety Tagging was reviewed. reviewed.. One of of *he corrective actions was to create a site specific procedure 'he procedure or guideline to further ,efine how tthe ,iefine he program is is to be implemented at Davis-Besse. It was also noted that  ;:here
    here is a FENOC FENOC commoncommon process safety tagging procedure procedure and that the station
    agging procedure
    agging procedure has has been been altered altered to support support the IENOC FENOC procedure. It is not clear clear
    hat this relationship rela.tionship between common process procedures proc.edures and site specific sp(;:cific guidelines is consistent with management IS management expectations.
    ** Overall Overall the progr<lm program is effective ;Identifying and resolving issues at the plant. effective in :ldentifYing R~~llato[Y..f~ai;!] R egidatory .ffai rs A Regula.torj Regulatory Affairs representative representative presented presented the results of NRC inspections, planned inspections inspections and NRC perfbrmrace indicator status. Performance ]\/RC performance Performance in in this area is art:a is satisfactory. ~;atisfactory. Saf.ty Evaluation Review ESR_ Mr. K. C. C. Prasad reported reported on the SJG.R SER Subcommittee Subcommittee meeting results. The following Sub;-ommittee observations were SubGommittee wt:re presented. At tthis his meeting we reviewed 13 Safety Evaluations Evaluations (SF) (SE) performed performed under the old old program, 10 Regulatory Applicability Determinations Regulatory Appli,;ability Determinations (RADs), (RADs), and 10 Screens performed 15 15 FEDB-FEDB* 000021 DOJ003-000572 D0J003-000572 Comjpý;iny COOljp:tny Nuclear Nudear Review Review Board Board Meeting Meding Dite Oate November November 29, 29, 2001 2001 under under the the new program. The new program. The subcommittee subcommittee did did not not receive receive anyany 50.59 50.59 evaluations evaluations performed ander the new rule. I was informed that that perforrnedLlnder the new rule. I was informed that that there ri1ay be two evaluationsthere 6itay be two evaluations in in
    he review process
    he review process under the under the new new program.
    program SE Review Although Although we we [ave have submitted submi.tted formal fomlal comments comments on on only only one one safety safety evaluation, evaluation, the the subcommittee subcommittee felt felt -:hat ~:hat some some of of the the other other safety safety evaluations evaluations could could use use additional additional discussion dlscussion or justification to make ihern or justification to make them stano-alone stand-alone. We We have )wve soecific s;Jecific comments c:omments on on SE SE 01-015. 01-015 This This SE justifies lowering SEjustilles lowering the the set se1 point point of ofthethe condensate conciensate pump pump discharge discharge header header control control valve. valve. The The function function of ofthis this valve valve isis to to prevent prevent the th,~ ptrmps pumps fromfrom running running out. out. There There was was nono discussion discussion of of pump pump flowflow capability capability at at lower lower setpoint setpoint inin thethe safety saff.:ty evaluation. evaluation. MAthoughAJthough condensate condensate pump pump isis aa non-safety non-safety pump, pump, failure failure of of the the pump pump has has both both power power generation generation and and safety safety implications. implications. We We havehave reviewed reviewed the the pump curve and concluded that at the revised setpoint the pump cur\'c~ and concluded that at the revised setpoint the pump has sufficient margin to pump has sufficient margin to run run outout flow. flow. The Th(! preparer preparer told told us us the the design design report report addressed addressed this this issue. issue. However However the the sucbcc.mmittee sLbccmmittee felt felt that that the the safety safety evaluation evaluation shouldshould have have addressed addressed this this aspect. aspect. RAD and Screen Review This review This review diddid notnot identifi. identi~{ any any improperly improperly dispositioned dispositioned RADs RADs or or Screens. Screens. Documentation Documentation orjustification or justi:fication provided provided inin thesethese documents documents could could be be significantly significantly improved improved The The information information presentedpresented narrowly narrowly focused focused on on Updated Updated Safety Safety Analysis Analysis Report Report (USAR)(LJSAR) wordingwording rather rather than than thethe USAR USAR required required functions. functions RAI:s RADs lack lack - ClearClear description description of of the the activity activity being being evaluated evaluated - Strong justifications on why Strong justifications on why 10CFR50.59 or IOCFR'50.59 or other oth~r regulations regulations do do not not apply ap:;Jly Scre.ns Scre~ns lack lack - Why Why the the activity activity is is being being performed performed Whal is the function Wha1 is the function Low How that that function function affectsaffects USAR USAR function function Why Why the the activity activity doesdoes not not adversely adversely impact impact thethe USAR USAR function function For For axample example Screen Scr,een 01 -0811 had 01-0811 had aa detailed detailed discussion discussion of ofthethe activity activity andand potential potential effects effects of ofthe the activity. activity. However However itit failed failed to to identify identifY that that there there i4 is no no adverse adverse impact impacl on on design design iiinction function (in (in this thiscase*:aseRCSReS pressure pressure boundary). boundary). QA Surveillance Results QA QA perforred ,I performed a surveillance surveillance of ofthe the new new 50.59 50.59 programri. prograrrl. This This surveillance surveillance resulted resulted in in sev,.ral (- 12) condition sevc:ral (-12) condition reports. reports. 16 16 FEDB- 000022 FEDB-000022 DOJ003-000573 DOJ003-000573 Compiany Nuclear Review Board Com!p:1ny'fudcar Meeting Date November 2:9, 2001 Th2 Th~ basic concern identified in in these CRs is is lack of rigor and poor documentation documentation in in preparod RArDs and Screens. This issue is not new. Several previous pr(:p(lr,~d RAD:; condition reports previous condition r(:ports dent ifiifred concern prior to implemen'tation eli this conc,:rn implementation of the new 50.59 rule. As a n:sult result, colective sig.nificance condition report cOllective significance report CR 01-3009 was generated. This CR CR requin:s a requires a Root Cause Team evaluation evaluation. The 'ream Team met yester-day. yesterday. I attended thai: attended that neetirg. This rool t1le:etirg. root cause team will also be investigating investigating why previous previous corrective actions actions failed o correct the t'aileclo th,~ issul; issue. Plantl Stat,; Revorls The E:avis-Be~se [avis-BI~;sc (DB) (DB) Plant status was presented presented on Tuesday, Tuesday, November November 27, fi"omfiom 0730 0730 to 0900. 09 1)0. Members M(:mbus tn in attendance attendance included: Bill Kanda., Greg Kane, Jack Jack Martin, Ron B3erry Berrynan, nan, Tim l'v[artin, Martin, and K. C. Prasad. Others in in attendance were site Directors: [Tward Howard Bergencahl, Bergen<:.ahl, John lohn Messina, Steve Moffitt, and Lonnie Worley; CNRB Administrator: Administrator: Allan VanDenabeele; Subcommittee Administrators: Jon Hook, John VanDenabee1e; and Subcommittee O'Nell, O'Ndl, Tony Stallard, Stallard, and Dennis Schreiner. Schreiner Davis-Besse _Qpratinm,!jaatus Mr. H-[oward Bergendahl Mr. Howard Bergendahl presented Following DB plant status. Howard indicated that presented the following the p'.ant p:antnasrhas been been on line 558 days with with only a 20 hour period when the brea.kers breakers were opened for the Stator Cooling Water strainer cleaning. AA discussion summary isis presented strainer cleaning. presented at the end of ofthis section, Ihis :;ectiOI1. Curr;nt Plant Sta.us
      • Power Level Power ltvel== 100 100 percent percent 38 Days DilYS cn on Lin-Line
    • " Capacity Factor Capacity Factor Cycle - 99.91 percent Cycle percent Year-to-Date Year-to-Date (YTD) percent (YTD) - 99.50 percent
    • lIfuel uel Reiiability Reliability We crossed crossed -our our action level 1 in early April and ReactorReactor Coolant activity activity trended up tLntil crossed action level 2 in late September. The Iodine 131 activity has been l.ntil we crossed hovering hoveling just. just below Action Action level 2 since our October down power.
    " '{Year ear ToTo Date (YTD) Risk Dat'~ (YTD) Risk Performance Performance The cLlrrenttrend The carrent trend indicator has DB"s DB's performance performance at 86 percent. This is justjmt above the the maximum goal of 85 percent. maximum perct:nt. The monthly indicator is currently "White" due to currently "White" 17 17 FEDB- 000023 DOJ003-000574 DOJ003-000574 Company Nucicar (__'ornp.qny NuclearReview ReviewBoard Board lVlce/illgDate Meeting November29, DateNovember 29,2001 200t greater greaterthan thaI!planned plannedunavailability t.navailabilityof ofservice servicewater water pump pumpnumber number 3.3. TheTheyear year end end risk risk peri:ormance projection pcrCormanc;~ projection remains "Green." remains "Green." o HuHunan-nan Per.orrnance PerEormance(I-IP) (lIP) 1::11: Event Free Clock declined Thm Event Free: Clock declined toto "White" October due "White" inin October due toto one one reset. reset. The The Plant Plant isis currently at 53 Event Free Days and the six month currently at 53 Event Free Days and the six month average is up to 30 days. Floridaaverage is up to 30 days. Florida Power and Light was in to benchmark our Human Perfoirmance initiatives and several PO'Ncr and Light was in to benchmark our Human Performance initiatives and several ideas ide:lswere were gained gain,~d from from theirtheirvisit. visit.
      • iperating History Operating History The Th~ Plant has run Plant has run atat 100 100 percent per,:;ent power power for for the the cycle cycle except except forfor short short reductions reductions forfor Main l\1",in Turbine valve testing and condenser cleaning. The plant was also off Turbine valve testing and condenser cleaning. The plant was also offline line for for aa total total of of20 hours inin October 20 hours October during during aa short short outage outage for Turbine Stator for Turbine Stator Cooling CoolingWater Water s':niner cleaning and Condenser tube leak repair. Sodium levels on the secondary side srainer cleaning and Condenser tube leak repair. Sodium levels on the secondary side remain remain high indicating that high indicating there isis still that there still aa leak.
    leak oo Significant Significant Items Items ---. Condition Condition Reports Reports and and Audits Audits >)- Evaluation EVilualion of'Letdown of Lt:tdown for for an an Appendix Appendix RR Fire- Fire*- Self-Assessment Self-Assessment 20001-0108 2001-0108 >-;.. Intake Structure Flooding Issue Intake Structure Flooding Issue with Pumps Removedwith Pumps Removed y Ineffeci:ive r Indfec 1:iveCorrective Corrective: ActionAction Related Related to to the the 10 II) CFR CFR 50.59 50.59 Process Process >Y Configuration Configuration Control Control issues related to Implemented issues related to implemented ModificationsModifications - Recent: Recenc Activities Activities [NPO y D-JPO Plant Plant Evaluation Evaluation Exit meeting inin Akron Exit meeting Akron -- 11/01/01 11/01/01 CClrrective Action >~ Corrective Action INPO INPO Assist Assist Visit 11112/1) I-- 11/15/01 Visit -- 11/12/01 11/15/01
    • II Pant P: ant and ar1d NRC NRC Performance Perf.Jrnlance Indicators Indicators
    -- Plant ?erformance lIndicators Plant':>erformance ltndicators"Yellow" "Yellow" >>- Control Rocm Deficiencies Control Room Deficiencies -- Plant Perfbrmance Indicators Plant Perfbrmance Indicators "Red""Red" Emergency ,<\.c Power >;.. Einergency AC Power Safety System Performance Safety System Performance >>> Fuel R.eliability Indicator Fuel Reliabil.ity Indicator >). Chemistry Chemistry Performance Performance IndicatorIndicator 1}> INPO INPO Indicator Index Indicator Index - NRC NRC Performance Performance IndicatorsIndicators are: are: all all "GREEN" "GREEN"
      • Licensee Licensee Event Event Reports Reports (LElRs)
    (LERs) since since last last CNRB CNRB None (No LERs None (No LERs issued in 200 1)issued in 2001)
    • MRC Notice NRC Notice of ofViolations Violations (NOVs)
    (NOVs) No cited -. 1\0 cited NOVs in - NOV,; in 2001 2001 -. No -- ]\'0 non-cited NOVs since 1I0n-l;ited NOVs since last last CNRB CNRJ3 o Audits ,\udilS since since last last CNRB CNRB (defer (de:f.er discussion discussion to to Loss Loss Prevention Prevention Subcommittee Report) Subcommittt~e Report) 19 FEDB-FEDB* 000024 18 000024 DOJ003-00057 DOJ003*0005755 Compr.nyNuclear Cornl),-.ny Review Board Nuclear Review Board Meeting Meeting Date Datl' November November29, 29,2001 2001 Operati,)nsAudit Operations Audit . p fOcurement/Mah~ri alCorntrol Procurement/Material Control -- Fire Prolecl Fire Prulecl ion ion -- Securip'/ Security -- Nuclear Fuel Nuclear Fuel Operations Operations '.Audit {Audit Exited, EKited, Report Report to10 Follow) Follow) - - Corrective CorrectiveAction Action (Audit (Audit Exited, Exited, Report Report toto Followa) Follow) Emergency Preparedness (Audit Exited. Report Emerg,E:ncy Preparedness (Audit Exited, Report toto Follow) Follow) a* Projected ProjectedKKey ey Events; Events U:ntil Until Next NextCNRB CNRB - Core Core Design Institute of Nuclear Power Design Institute of Nuclear Power Operatio.Is Opera.tio,lS (INPO) (lNPO) Assist Assist Visil Visit 12/03/01 12/03/01 -- 1Y207/01 1:2/07101 - JUMA Audit 12/03/01 JU1111A Audit 12/03/01 -- [2/13/01 [2/]3/01 -- Operations Operatlons Training Accreditation Training Accreditation Renewal Renewal Board Board Meeting --01/16/02 Meeting-- 01/16/02 Reactor Head Inspection Reactor Head Inspection Plan Plan 0... 2001 L.OO1 DaviBDavis Besse Besse INPO Th!PO Evaluation EvaluationResults Results ----- Strrengths Strengchs Identified 13 versus 3 in 1999 Identified 13 versus 3 in 1999 >';.- Control Control RoomRoom Operator Operaror UseUse of ofError Error Prevention Prevention Fools Tools ';.- Radioactive Radioe,ctiveLiquid Liquid Effluent efluent Reductiofns Reductions  ;' Dcse Dcse Savings Savings through through Mockups Mockups and and Training Training y Maintenance Se'~tjon Use of Performance Indicators Maintenance ' Section Use of Performance Indicators >);> Maintenance MainH!nanCe Employeae Employee Use Use of ofError Error Prevention Prevention Tools Tools >~ Engineering Engineering Programs Programs Ownership Ownership and and Results Results ~ Effective M Effecti ve Corrective CorrectiveAction Action Program Program Quality Assurance alignmentwith >~ Quality Assurance alignment with Station Station >~ Review Review and and Use Use ofofOperating Operating Experience Experience >);> Contractor ContractorTraining Training]Program Program >);- Training of Plant Experiences inin Presentations Training Use of Plam Experiences Use Presentations >> Instructor In;tructor Performance Improvement Performance Improvement Methods f\1ethods >> The The TOP TOP TeamTeam -- Areas Areas for for Improvement [mprovernent Identified Identified 14 versus 22l1 in 14 versus in 1999 1999 Operations' Reinforcement of Y Operations' Reinforcement of High Standard~; ' High Standards > O(perations' Opera,tions' Abnormal Abnormal Procedures Procedures Format Format >> Implementation Implementation of the Safety Tagging Process of the Safety Tagging Process Y Make--up Water Make-.up Water Treatment Treatment Quality Quality and and Condenser Condenser TubeTube Leakage Leakage >};. Sampling Sampling ard and Analysis Analysis Techniques Techniques inin Chemistry Chemistry .> Chemistry .);> ChemIstry Laboratory Laboratory Quality Quality Control Control Practi,:es Practi,:;cs >);> Outage Personnel Contaminations Outage Personnel Contaminations >);> Control Control and and Storage Storage ofofRadioactive Radioactive Material Material );> DDiesel Diese*: Generator Generator Performance Performance >).;> Circu'.t Circu:t Breaker Breakelr Failures Failures >>- Work Work Management Process Management Process Implementation fmplementation >> Equipment Equipment Deficiency Questioning Deficiency Questioning and and Evaluation Evaluation 19 9EDB- 000025 DOJ003-000576 DOJ003-000576 ('oin[)vjny Comp,wy Nuclear Nuclear Revi(..-w Revil~w Board Board Meeting Meetillg V)ate Vale November No\'ember 29, 29, 2001 2001 y Fuel Fuel Performance Performance Issues Issues >;- Root Cause Determinations Root CHuse Determinations Narrowly Narrowly Focused Focused -- Most Mos,! Signif cant ---- Positives Signif;lcant Positives (Executive (Executive Summary) Summary) y- 3eiiable Reliabk Oper.ticns, Operations, No No Events Events >};- Management ream \1anagement Team Focus and Focus and Prioritization Prioritization y- Training Training and and Line Line Management Management Teamwork Teamwork >).- Error Error Prevention Prevention Behaviors Behaviors -- Most Most Significant Significant- - Negatives Negativ(~s (Executive (Executive Summary) Summary) y *.Operations Operations Reinfbrcing Reinforcing High High Standards Standards >:;;. Engineering Engineering Rigor Rigor andand Equipment Equipment Performance Performance Organizational Effectiveness
    . Organizational Effectiveness in Resolving Safety in Resolving Safety Tagging Tagging and and WorkWork Maiagement Ma'lagement
    - Insight!; Insight!; During During Visit Visit >~ Some Jobs Some Jobs DelayedDelayed >~ Response Response to to Tagging Tagging Issues Issues >~ Response Response to to Technical Technical Questions Questions ));> Operator Operator Alignment Alignment _Sum~n_~r~__rdiscussion and actions: Regard Regarding ing failed failed filel; filel; the the Board Board questioned questioned whether whether act',on aellon level level 22 brings brings anyany additional 2~dditional action;. The action >. The answer am,wer was was no, no, only only heightened heightened awareness-awareness ItIt was was indicated indicated that that site site policies policifS and and procedures procedures were were reviewed reviewed to to confirm confirm thatthat no no other other actions actions were were required. required. It It was also indicated that the failure mechanism is believed to be was also indicated that the failuH: mechanism is believed to be grid n-etting which does notgrid fretting which does not presert pr,~sert aa risk risk significant .iignificant challenge challenge to to plant plant operations. operations. Regarding Regarjing the the Condenser Condenser tube tube leak; leak; the the Board Board questioned questioned whether whether otherother techniques te,;hniques werewere being pursuecd for finding the leak. Mr. Bergendahi being pursued for finding the leak. Mr. Bergendahl indicated that we were looking indicated that we were looking throughout throughout the the industry, industry, and and internally internally withwith FirstEnergy FirstEnergy fossilfossil people, people, for for techniques techniques to to find tlnd the the leak. leak. The The leak leak hashas been been isolated isolated toto one one loop loop ofofone one water water box. box. Mr. Mr. Jack Jack Mar::in MaLin commented c:omm(:nted that that process process implementation implementation problemsproblems have have been be(~n identified identified inin the past (both the p~;.st (both internally int,;:mally and and externally). externally). Examples Examples given given were: were: tagging, tagging, vendor vendor manuals, manuals, ar.d and Equipment Equipment Qualification. Qualification. lagging Tagging problems problems have have again again been been identified identified by by INPO. INPO. Mr. Martin suggested that greater accountability Mr. )\lartin suggeste,d that I~reater accountability needs to be estnblished with needs to be established with process proeess owners owners to lto assure aSliure that that their their processes processes are al'e both both functional fUllctional and all1d effectively effectively implemented. implfmented. He He indicated indicated that that performance performance indicators illldica.tors should should be be established established and and self-assessments performed by the process owner sdf-assessments performed by the process owner to better assure the effective to better assure the effective irnpkmentation impkmelll1lation of of their their process. process. Mr. Mr. Martin Martin also also suggested suggested that that we we look look at at Fred Fred von von ikhn's Aho's processproc(!Ss effectiveness eflecti.vene:is memo. memo. Mr. ML Moffitt Moffitt indicated indicated we we had had aa -copy copy of ofFred's Fred's memo. memo. He He alsoalso indicated indicated that that an an effort effort was was made made over over thethe last last six six months months to to make make sure sure every process had an owner, but we need to go the nex~t step evelY process ha(:i an OWOl:~r, but we need to go the nex:t step to establish process owner to establish process owner accot.ntabilitie, accOt.ntabiliti*~s s fo:,r fi)r assuring assuring the the effectiveness effectiveness of oftheir their processes. processes. 20 20 FEDB- 000026 FEDB- 000026 DOJ003-000577 DOJ003-000577 Cojjnl).jny Nuclear Revie", Board Mcdillg Meeting Vate Date November 29, 2001 R'egarding ihe Kegarding the iNP1O lNPO repeat repeat tagging issue, Mr Mr. Jack Martin indicated indicated that Perry Perry also has had taý:ging ilac tllfging problems. plClblerns. ItIt was was indicated that this indicated that this area area does not yet have a common process does not process prccedaire. prccedJre Mr. Martin suggested sUI~gested that this problem problem should be assessed IFENOC as a ]fi'ENOC issue.... Mr. issue Mr. Kc.flda Karida indicaled indicated that I.hat Quality Assessment is looking at this issue. During discllss;on discusslon of Work Management Management issues, Mr. Jack Martin Martin indicated that the System Health Report is pretty clear dear on identifying what system upgrades/mods upgrades/roods and priorities are neede6b. needeo. He cluestioned questioned whether the deferral deferral of some of this work is is due to organizational organizational eftfctiveness efD~cti'lenes3 issuce. Mr. Bergendahl issue:;,. Mr Bergendahl indicated that site llIanagement management is concerneJ concemej for the lack 0:' oi' our ability to get schedu'ed schedu;ed work done per the schedule. This '[his i.s is why Work Manaq*emerct \1anaf:emect has been identified as the Focus focus Area for Ibr CNRB review this week week. Beaver V_2le_'_QLeratiilg Status Mi. Bill Pearce presented Mr. presented the following Beaver Valley (BY) Beaver Yalley (BV) plant status. A discussion surnrmry pn~sen*:ed surnrnmtry is presen:ed at the end or [his of this section section. C_(urtrent Status (_Jnit I .. Power Level= Level ::= 100 percent percent <I 2 1 Days on Line 21 Unit 1I Auto Reactor Reactor Trip - 11/6/01 11/6/01 - "e" "C" Slearn Steam Generator Generator low--low low .. low level Unit I Auto Reactor Trip (Subcritical) 11/8/01I - N36 Intermediate (Subcritical) - 11/8/0 rntermediate Range Control Power Fuse Blown 0* Ci.pacity Factor (through October) ('.pacity 14./15-90.0 Cycle \4/ 15 - 900 Year-to-Da':e - 82.8 Year-to-Da,:e 82.8 *a FuelFleel Reliabil.ity Ounrently, 'Valley Unit 1 has no dett:ctable
    unently, Beaver Valley detcr-table fuel defects.
    Status is GREEN. Cycle 14 completed completed wit~, no detectable fuel defects. wit[ ..W YTDYrD Risk Performance Perr.:mnance For October 2001, the Monthly Risk Performance Performance [Ildicator Indicator fi)r for BV-1 BV-I is 87.3 percent, 87.3 percent, and is is classified as WHITE YTD status is is GREEN. Unit 2 0 Power fotic:es of Violatior, were ofViolatior, were issued issued inin the the most recent inspection most recent inspection reporl:s. repoi1S. InspectiQ:1 Report ]\RC Inspection NRC Report 2001-302 2001-302-- Oetcber 1, Issued Octcber -- Issued J. 2001 2001 Unit I Unit 1 Rea*ctor Operator and Senior ReaGtor Operator Initial Reactor Operator and Senior Reactor Operator Initi,~ E:{amination Report Examination Report 2Y5 ROs and 2/5 ROs 1/1 SRO and 1/1 passed examination SRO passed examination NRC Inspection Report -RC Inspection 2001-008 (Both Report 2001-008 (Both Units).- Units)-lssued October 17, Issued October 17, 2001 2001 Examination of activities related to safety and Examination of a*;;tivities related to safety and compliance. compliance. .23 23 FEDB. 000029 PEDB- 000029 DOJ003-000580 DOJ003-000580 Comp~_ny Nuclear Coimpf[fny Nuclear Review Review Board Mee[ing Date Meeting November 29, DAe November 2'/), 2001 I Non-cittd Non-cited violati.:m (Green) violati:lI1 (Green) Audit findings since, last CNRB Four F our Audit Reports Repolts have been issued. Supply Chain / Procurement Engineering Program Procurement Engineering Program (BV(13V-C-01-04) -C-O 1-04) Results indicate the Program is Not Nct Fully Effective Effective 24 Condition Conditicn Reports issued issued Engine'~ring Engine.iring and !Design (13V-C-01-10) Design Control (13V-C-Ol-10) Rew1t~ Result 5 indicate the Program is Not Fully Effective 3 Cor~dition Repof1S 311 Cor,dition Reports issued Health Physics P::ogram (BV-C-0 Phy~ics P::'ogram I-1l1) (B V-C-O 1-11) Rcsul:s indicate Rcsuh~; indicate the Program is is Not Fully Effective 26 Condition Repors issllt:d COlldition Reports issued Site Radiological Effluent & Radiological Effluenl .& Environmental Monitoring P!"(lgram Program (BV-C-01.-12) (B\'-C-O 1-12) Result; Re5ult; Indicate Indicate the Program is is Effective Effective 2 Coiltion Reports issu<~d Condition Report!; issued The Fitne!:s Fitness For Duty Audit is complete, report preparation-r'~port in preparation Aidits in .tudit5 in .)rovress: Jrogress: Training Training Software Control Scd'tware Document Control & & Records Management Records Management !-rI ted Jkey events until next CNFRB aIt Eecembe; Lecembe( 10, 10, 2001 - NRC Inspection Inspection---- ModificatioIs Modificatio,1S 4.. Eecernber I>ecernbcr 10, 2001 --INPO INPO Assist Visit -- ALARA *e December Ilecernber 17, 2001 - NRC Inspection-Inspection- Radiation :tvlonitoring Monitoring fnstrumentation Instrumentation Discussion summarid actions: Due Du.e toto time constraints constraints this presentation only reviewed major points and no CNRB actions acti,ons were identified. 24 24 FEDB- 000030 DOJ003-000581 ("ompany Ntu--Icar Company Nudear Review Reviiew Board R'le,:ting November' 29, 2001 M{'I~tillg Date November jPerry_0OucaL-DgStatus M... Tim Raus;ch \1:-. Rau:;ch preseried presented the following Perry Perr), plant sLatus. A discussion summary IS status. A is preserted preserted at the tbe end of tbis sectie,r offlis sectic,1r7. II Pc wer Level Pc Leye\*--- ]100 percent 00 percent D Days t On Line-- Line .. 120 120 .. (Cpacity Factcr CLpacity Factor -- Cycle. Cyde* 74.4 percent percent --- YTD - 70.2 percent 702 percent It FLt.el Reliability Fte] Reliability - Defect free Risk lPerformance Yeal-to-Date Yea'~-to-Date risk: performance isis "GREEN" risk performance "GREFN" at 84 percent of tile the r;sk risk index with a goal of of being less than or equal ,~qual to 90 percent. F-iumýn Perfot mance "E II ent-Free Clock - 15 days E/ent-Free *.. DaysDays since ~ince last LTA L T A - 657 657 ,6 E:ror Rate E ~ror Ratl! YTD - .48 YD Peny has has operated at 100 percent percent power since the last last eN CNlRB meeting1 RB meet i ng. Sjgpigi cant Items Since Last CNRB ..* NRC Ins~'ections i\RC Inspections - Security Security .- 5C.59 50,59
    • .. completed Audits compl,eted
    - Document DocuMent Control - AGce~~s Access Authorization Authorization Plant Pedbrrnance Indicator The September The Sept-ember Plant Performance Perfbrmance Indk:ators Indicators had RHR RIR Safety System Performance Perfonnance and and Corr ective Maintenance Corr~ctive Maintenance WorkloRd Workload as "RED" "RED" and Event EVI~nt Free Clock as "YELLOW." "YELLOW." 25 -FEDBO-000031 DOJ003-000582 DOJ003-000582 Company 1'\ Cornp:lny NlIC"ear uc';ear Revii~w Review Board Board Meeting Meeting Dale Wile November 2,'), 2001 Novernber2l), NRC Peýrformance Indicator NRC Performa.ice ':ndicatof!; NRC Perfonna1cc '.ndicators3 are are all all "GREEN" "GREEN," ._Eks, N-RC--NOVs, Audit Findings; oo LERs-LERs-, o, NRC NOVs NO(Vs ..--None ..* Audit findings -- Document Control - 13 13 Acces. Authorization --- Acces, Authorization - 3 Si.nifizant Conditi n Reports til CI- ()01-3455 CF. Temperature transmitters exhibir ]-]4: 5 Temperature exhibi: common low luw cal data o til CF CF~ 01-38K7 Ol*:J8P Fire brigade Fire brigade member member respirator respirator tit fit tess expired test expired "SCT, 01-3917 CI~ 01**3917 DG air compressor corapressor head loosens during compressor operation ,t CR C CI~ 0 01--39',3 ] .. 39:;3 Drywell Dryv/ell radiation monitor inoperable during work activities , CR 01*-40~; ite1:.. 01--40")11 Collective Collective signiii<:ance significance review review of ofindeper.dent independent veri'ication verit'lcation process L39ijc ted Ke Events II INTO meeting ]i-iPO meeting II NRC J'B licerse exam . C licer'se March 2002 exam 'March II ]\NRC OfTil;e NRC Office of of'Investigation Investigation Discussion summarU' and actions: Due: Due to to lime time constraints constraints this presentation only reviewed chis presentation reviewed major points and no CNRB actions actiolls were denrified.demified. !.i(l~_~!!!.!~.!1!dmeJnt License Araendment and :and Technical Specification Presentations Technkal Specitkation Prescntations Davis-Besse License ALmendment Request (LAR) LAR -- 01 LA~ -.0012 -- WI -0012 The proposed proposed change reduces reduces the allowable pressurizer pressurizer high level limi:t from 305 incahes limit from 305 in,~hes to 228 to 228 inches and revises the TS Action to allow up to one hour to restore pressurizer pressIJrizf,:r level levd 10 to within limits prior to commencing commencing a plantplant shutdown. 26 FEDB-000032 FEDB-000032 DOJ003-000583 DOJ003-000583 Company Sudear Compnmy Review Board Nuclear Review Meding 0,11(' Meeting November 29, Wte November 29, 2001 Di~;Cl::s;ion by Board members resulted in Dlisc:s;on approval or ill approval of'the the License Amendment. A CR was reque:sied tJ reques:.ed t3 address addre!;s the new set point being being below the alarm set plJint point. CR 01**3235 01--3235 was -nitiated by Licensing.
    nitiated LAR -- 01-0008 - The IAR -*0)-0008 rhe proposed changes delete the action of either either: reducing core thermal reducing cart:
    power power and the high neut:ron neuUon flux reactor trip setpoint, or Illolliroring momnitoring quadrant quadrant power power tilt at an inc-eased inc-eased frequency when a single Reactor Protccriull Protection SYS[CI11 System (RPS) (RPS) High Flux or or Flux-.Flux-.Flow f-inctional unit is Flux* [I FluxoFlow flnctional inoperable. is inoperable Additi:nally, Aciditi:lI1ally, changes to the fom1at format and content of T55 T-bles 33 TS T'lbles 3.3-1, "Reactor Protection -1, "Reactor Syster:i Instrumentation," and 4.3 Systen Instlllmentation," 4_3-1, -1, "Reactor Prolection System Instrumentation "ReactJr Protection Surveillance Requirements," are p:oposed Surveillance Hequirements," p:oposed to clarify clarit*, these tables cOllsistent consistent with the B&W B&W Irrproved Improved Stc.lldard Stanidard Technical Specifications Specifications Discu:;sion by Board members resulted in approval of the License DisCll:;sion Ljcense Amendment. A ll1endment. LAR LAH - Ol-OOll01-0011 -- _. The proposed change revises TS Section 6.9, ",Administrative Controls "r\dministrative Controls -- Reporting Requirements," ... Reporting Requirements," to eliminate eliminate the requirenlent requirement to submir submiT startup stal1up reports to the NRC. \iRe. Discussion by Boa.rd Boad members resulted r~:sulted inin approval of the License L.icense Amendment.  !\mendment. D*r ha.gge R,' uq.t {R_. CR - 01**08001-.080 - Propcses Propcses to change the Improved improved Technical Technical Specifications,. Specifications., NUREGs 1430 -- 1430*- 1434,14_"34, TS 3.5.14, Technical Specifications 5.5.14, Techni';al Specifications US) (TS) Bases Cont ol Program, COI1(iO! [)rogram, to provide consi;tenc,' con:;i ;teney to changes changes to 10 CF]R, CFR 50.59 50.59 published in in the Federal Register dated October October 4, 19,)9. Specifically, the term "unreviewed 19'~9. Specitk:ilIy, "unreviewed safety question" question" isis being bei ng deleted and replaced with -evised wording. v"ith :*evis:;d Disct.ssion DisCLSsio:1 by Board members res.,;ulted r,esulted in approval of the: the Change Request.  !{cquest Beaver Valley_ License Amendment Req.est LLARI [AR - lA-296/2A-16 LAR 1A-296/2A-169, -- Proposes to convert 1 ), -. BtVFS Technical Specifications convert the BVPS Specifications to the cun~ent Standard Technical Specifications canrent Sptcificatio ns for Westinghouse Westinghouse Plants (NUREG 1431, Rev. (NURE.G 1431, 2). The cOllver~.lon conversion LAR IS is dm1eJoped developed and formatted in accordance with the NRC and in accordance NIEI guidance for conversion NEI guidanCl! conversion LARs. The conversion conversion LARLA.R is is divided divided into multiple sections that corn~spond tl1m correspond to the sections of the Technical Specifications. The sections will Technical Speeifications. be will be reviewed by the CNRB r*eviewed C-NRB over an 18 month period. The :\lRC NRC submittal submittal will be made when all sectio:ns sl:ctio:ns have beenbeen reviewed by the CNRB. The lirst first completed sections are being being reviewed at this CNRB. CNRB meeting meeting and are listed below: 1.0 Use & & Application 2.. 0 ~,afety 2..0 Safety Limits ~o LCO & 2.0 LeO & SR Applicability Applicability 27 FEDB- 000033 FEDB*000033 DOJ003-000584 DOJ003-000584 Compan ny Nuclear Comp:l Nuclear Review Board November 29, Meeting Date November Mecting 29, 2001 ,I1.!0U 1/),~~ ),= ign i ri FealUrc:'. Fea ure>, Discus~,jonJy Discus,,ion 'y Board members resulted in approval approval of Sections 1I through 4. Though the Board indicated that the change was safe and acceptable, the following question indicated th;,.t question from T. Martin was identified as an open item: l'v'lartin item Do the: less restrictive No Significant the les~; Significant Hazards Hazards Determinations Determinations (NSDT)) (NSHD) have adequate adequate tecnical teclnical base~; baseCS to ,nswer "no" answer "00:)" to questions 1I and 3? (refe:-ence NRC RIS 2001-22) (refe:-ence 2001-22) Pro hi em Solvin a/Trou bleshooting Process Mr. Scott Sennn J\Jr. Senian presented presented this Critical Critical Success Area Iniftative Jnifative (CSAI-P-03) (CSAI-P-03) A discussion summer) is presented at the end of this section, summery section. WVj)yis this Critical Success Wh.Y.i.uJli~._Criti~<!! SUCc~.i Area lleeded? needed? .. To provide a consistent consistent methodical approach to probll~m problem solving .. To0 ensure~hat T ensure -hat problems prob\em~; such as we have experienced experienced (e.g (e.g. manway man way gasket leaks and stator water l,~ak:;), are resolved wate:r tubing leak:), resolved efficiently and effectively the first time. time b provide a to:)o\ To pro'vidE: tool to useUSE: in support of CR investigations Problem Solvingp Policy Prob ~rn-.SJ21 vi!}gl~olicy III, The purpo3e He o:~this policy is to provide a systematic approach purpose o:"this problem solving approach to problem ac.ivities ac-ivities fl)[ for all plan: iss;ues (technical plant issues (technical 'or or not), to ensure ensure they are performed perfomled consistenfly and eITectively consistenTly effectively wiIhout without adverse consequences to nuclear safety, personnel sa:'ety or plant performance. saety performance. '" Development of this policy was based on benchmarking D/welopment benchmarking of plants, such as Salem and Hope Crc!:k, Creek, where where tools such as this have been successfullysUCCl~ssfully implemented, as wellwell as troubleshcotirng troubkshcoting guidelines guidelines from our own FENOC facilities. ", The policy is ,;vritten written wi.th with the flexibility to implement it in its entirety entirety as a written plan, or to utilil,e utiliue it as a reference reference tool to provoke thought,thought:, for less significant activities, activities. .St~,s s.t~~ of aaRr~,blel:1l Problern Soln. Solving; Plan to Gather data G:tther .. 1 Develop problem statement Develop ~lrobJem statement .. .l6entiliy feilure modes / possible caus.es [c,emilY t1,jlure causes fJ P-epare P'epare a problem solving plan ~;olving pla.n summary o u Evaluate the p--ossible Evaluate possible causes u P .epare *epan~ andaid implement imnplerrent the action~tction plan It Confinr the cause of the problem Confll1n It Identify and implement implement the solution to th(~ the problem problem .., Provide confilmation confirmation the problem com~cted problem is corrected 28 FEDB.- 0000.34 28 FEDB. 0000:34 DOJ003-000585 DOJ003-000585 Coml~;InY Co mpny .'1udear .Nuclear Revi~w Review Board Nleding Oate  !\Iel'lillg Date i\oveOlber November 29, 2001 (Ja_ her Dati (!.<!).M;rJ)alj oo COllect physical evidence Coilect ph)sicaJ evidence Such SlIcf. as photographs, COWPLlIf'1 data, iirzative photographs, con0pufer IIdl [ative logs, chart chart recorders, alarm conditions and personnel slatemelllS. statemenms. Quarantine Quarantine the failed equipment, apprcpri ate. if apprcpriate. o* Construct an event timelme timeline to help organize organize data associated associaled with; wit I: Ithe he failure. ** Determine the design and licensing basis ba~js tor for the compcnen compc*ncnt or sysl sý.stei. ern. ** Determine nonraal non'nal equipment functions Finctions and normal system opeation. ope:athion. Compare Compare n,) -mal OJ conditions to the abnormal symptoms idellti 'mal cor,ditions identiriec. riec. Q£fir~ 1)efire thetheJ~LQblen: Problen: " Stc~te Stlte the problem utilizing the available facts, objectively describing describing the undesirable undesirable ac ion or event aClion event Use a tirneliretimelir.e if needed needed. Specify Specify the problemn problem \vithwith a thorough de;criptior de ;criptior of 'what, what, where, wh{:re, when and extent of conditioncondition tili~nli.t~ Identiy_ failure / po~.ible C:fl,uses modes /4rossible faiLL!!t;:J!l..Qcies causes II Ihntify all o Identi~! aH pos.~ible pos .ible failure modes. OIl Idntify all pos,sible o Idl:nti~l possible causes and rank them in in order ur of likelihood likelilhood -- Inost most likely cause cause fir:;t. fi r:;t. CIJ Use th(~ tfEe the knowledge knowledge of experie:1ced experie:nced personnel, dra\,iugs. personnel, dra and documents. \\ IllgS. illld " U~e Use the INFO n\iPO Webpage, Nuclear Nuclear Network, EPIX Einjineering l;::n!:"incering database, etc. to search for t)f' additional information on the problem. additional ilformation ~" Develop cause tables. 1repare a £.~I.~i!r~ Problem SolviQgJPlan ProJ,lem Solving Plan S.!llllrnaD' Summan, *I~ The purpose of oraa Problem SolvingSolving Plan (PSP) Suni-imary, Summary, is to provide e\t:ctronic electrontic access a.c;:;ess to the key points and ~;tatus status of a PSP to all site personnel, while allowing the allowing inv/estigatimn tE:am in'/estigati::m team to continue continue working working without interruption. interruption. The PSP Summary Summuy will be periodically periodkally updaled updated by the Owner to ensure th*e Issue Owner ensure the information informat ion is current. Evalu ite .1b.~J'Oss:lble Eyall!lte the Possible CausesCclli.~;'§ ,, Test possible II causes against known possible (;auses known information, informatioll, the "IS" is'- and the "is not." tJll~ "is not.' II T Test possible possible causes against the facts. Do they support Suli)port or disprove each cause? II"Dltermine: Ddermim which facts need to be obtained in order to confirm or disprove each eaeh j)cissib'.e cause possib:e Pl~@re Pvegare aTLd Implt~ment anLd Implement the Action ActioIt Plan ** Develop D~veJ()p Action Plan to gather gathl~r facts toto prove prove or disprove disproJve remaining remaining possible causes. II "IdentitV Identify potential consequences of the problem solving p<)tential adverse cOl1sequenc:es solving!i dala data gathering gathering efforts aid asses~~ and asses.,; the impact on o:n nucl~!ar nuclear safety, p~~rsonnel personnel saf~ty gem~ration. sat>Iy and risk to generation. II Detertine if Plan isis to be performed Determine performed as an [PTE. IPTE. II, Obtain a peer review review of the I'\anPlan and its approval. Confirm tl}.sU:aus!~ i:onfirm the Cause of the Problem D, Verify questionable questionable ac60n action plan results. results 29 FEDB- 000035 FEDB* 000035 DOJ003-000586 DOJ003-000586 Company Nutciear 'Company Nudear Revkw Revie'w IBoard Board Meeting Meeting Date Noveml)er November 29, 29, 2001 200t II Validate Val dale assuml:tions. assumrtions. Using fact~, .. Using facts prove prove or disprove all remaining possible possible causes. .. Per-::Orm independent :~eview of results. SPer-:"brm independent review results i.(h~!ltj!} ___andInpklenent -Wetl0 {lndJ.mplen:lent tr~.soluti<m the Solution '*" We gh ALL the collected. Wegh collected evidc-nce evidc:lce with the determinec. risks, then correct the affected componem. componenT Ask Asi': q'uestions questions - avoid pitfalls pitfalls II Do D*::> we havehavt: all !:he inf'ormation available? ':he information available? II Do,.s D:),~s aryor.e aryore have unidentified concerns'? unidentified concerns? a II Are An the the risks risks we. we areare taking taking worth worth thethe Gonse:qucnccs? consequences? ,* Ar( Are we focusing on the "favorite" "favorite" alternative to the exclusion exdusion of others? itSAr(:An we making a decision before we are ready? deci.sion befi)re II Is tile dcci; t:1f deei;; on consisrent consis:ent with conservative decision conservative decision making principles? Pcolicv )t;.Y!~QQmeqt polic\~ Devei~opmerit Mile~.ml~ Milestones "It Develop Policy, issue for site review and resolve comments Develop PClliey,
    • <II Perform va:idationvalidation and verifica':ion verififca'ion of Policy and obtainobtain VP approval for use a: Perry
    .. Pre Prc vide training tra:ning to Operations, Maintenance Operations, Maintenance and Engineering Engineering personnel .. Prc Pre vide electronic electronic acc-ess ac<~ess to Policy Policy documents documents
    • '. De Develop
    . . elop a Problem Solving Process NOP for 1\'OP fbr use at all all. FENOC FENOC facilities facilities Discutssion sunmmar and actions: Th:.s Th.s P.licy P.)iicy is in a NOP  :%treat a:1d NOP'orrnat anad currently Engineering Director final review currently awaits Engineering review- I. It will go on the FENOC \vill PENOC Web page by the end of the year. year. The Board qUfstioned questioned what would initiate the use of this Policy. It was indicated this indicated that this Policy isis an added management management tool to be initiated by management management when urgency is an issue Mr. Sernan Seman indicated Indicated that certain plant plarit situations would also kick off the use of this Policy (e.g, (e.g, Operability Reviews). Mr. Campbell questioned Mr. C.lmpbell que;tioned what training/lPlatform training/platform will be used to developdevelop this skill. Mr. Lew Myers indicated we should all adopt the Kepner Tregoe (KT) Ivlyen: indicat.ed (KT) process. Mr. Campbell said W~ wx need to tr) look at the skillskill sets from a FENOC perspective. Reactor Vessel Head Issues Mr. Me. Dave Dave Gei3enGehen presented presented the Reactor Vessel Head issues and associated risk analysis. A.discussion A discLlssion summary i~is.presented presented at the end of this section. NR_ 3ulletin 2001-0 NRC~3ullt:J:.i.n)OO ,l-O1I ~ F ,equests that plants prc.vide Rt.que!;ts provide design information, previous inspection results, and fut:ure fU'~ure inspection plans plans 310 30 FEDB- 0000 3 6 FEDB*000036 DOJ003-000587 DOJ003-000587 Corn Complny p Any Nth(:Ieajr-Nudeair' Review Review BoardBoard MeetingDate Meeting November29, DateNovember 29,2001 2001 requi[-ementswere Re,p{Jn~e requirements *,. Response werebased basedupon rankinginillSusceptibility plantranking upon plant Modd asas SusceptibilityModel pulblished in EPRI NMRP-48. p_lblished ill EPRI MRP-48. Su')_l!;ce .tibihli Model
    C(~J1i\2iUJ..YJ*1 od!~
    (EPPI (EPRl -- PWR Materials Reliability PWRMaterials Reliability Program Response toto NRC Program Response NRC Bulletin Bulletin 20(01-01 2001-01 (MIPR-(MPR-48), M062,4, dated 48), l(i062~4, dated August 2001)August 2001)
    • .. R.anked Ra'lkcd Davis-l3esse Davis-Besseasas 7th outof 7thout of6969 plant!,
    plants
      • 6-(61': actual actual EFPY away flom Oconee33but EFPY away fiom Gconee but3.13.1 EFPY EFPY awayaway after afternormalizing nonnalizingon 011head head ter-Aperatures ter'1peratures down downto to600 600 degrees.
    degrees & .. Model purposelysimplistic Model isispurposely simplistic in inthat influenced by PWSCC isisinfluenced thatPWSCC Environmelll(Clemistry byEn~iron*nem (ClemistI), &8: l'emperature), Stress, and Time. The model does not account for 1'emperature), Stress, and Time. The model does not account for Stress, Stress, Chemistry, Chemistry, Material V3riability, oror specific \1atelial Variability, specific plantplantas-built a.s-built conditions. conditions. I-)avis-Besse's; [).Qvi:~Bes~58~NRC Bulletin Response NRC Bulletin. ResI!SlnSe W OJ Referencec Referencecinspections inspections of ofthe theheadhead during during 11J 1RFORFO (April (April 1998) 1998) and and 1212RFO RFO (April (April 2030) 20:)0)
    • 19 Re-reviewed Re-revitwed.video VIdeo irisl)(ctions insp(:ctions of ofhead head inin light lightofof boron boron leakage leakageseen seen atatOcon.ee
    ()con-~e andand Arkansas Arkansas NuclearNuclear One.One. III Nc, Nc, head headprenetration penetration leakage leakage was was identified. identified.
    • 110 Ccmmitted.
    Ccmmitted to ~;ubmit follow-up response to i:ubmit follow-up response on onJanuary January 29,29, 2002 2002based based upon uponfurnher funher incustry developments. incustry de-velopments ,.. C(cmmitte(d Ccmmitte(toto perform performaaqualified qualified visualvisual inspection inspection of ReactorPressure ofReactor PressureVesse. Vesse head head in in 13RFO 13 RFO currently scheduledtoto begin cUI'rently scheduled March 2002. begininin March 2002, Plant-.bpcific Deterministic Asp.cts
    e1mL:_ULe~tfu;_ Det ~:rmini:ili~ Asp(~1S
    ,.., Qualified Qualifkd -isual inspection perfbrmed yisual inspection performedinin 1996, 1996, additional inspections in additional inspections in 1998 1998 & &, 2000 2000 <II Initial site 3pecific finite element analysis shows that 6:5 of Initial ~;ite )pecific finite element analysis shows that 65 of 69 nozzles will alia? 69 nozzles will allow lez.kage. le<.kage. Subsequent Subs{:quent revision revisionshows shows allcJl will will allow allow leakage. !Ieakage. <II Conservative Conservativeinitial initialflaw flaw size size <II Over Oller33 adjusted adjustedeffective effective full-power fuIl .. power years years less less operation operation thanthanOconee OconeeUnit Unit ::;; Boundlingor Conservative Inputs f3()UI~lin,g '2L.~:ons~~rvati\~!~Jnputs III Nozzle Nozzle Leak F:requency Leak Frequency III fPr:bability Pnbabilityof ofOD OD Crack Crack Initiat Initiationion STi-ne III to OD Crack Tine to OD Crack Initiation Initiation 'II In tial Flaw Inlial Flaw Distribution Distribution ... CI ack C.rrowth Model Crack Growth Modd Stresses Stresses It
    • Failure Definition F::ilure Definition Lt:akage Detection
    ,It Leakage Detection ," Probability Pr obabi IiI)' of ofCore )amage Core Damage Q::h(~ Sensitivities O:her Sen:iiti vitie~~Investigjated Inves:tigslted OJ Initial crack size Initial I::rack si,~e OJ Initialcrack lnitial crack depthdepth 31 3K FED13-000037 FEDB* 00003 7 DOJ003-000588 DOJ003-000588 C'onipaiy Nuclear CompalY Nuclear Review Review Hoard Board rMeelting Mee Date November 2~), 1ting Date 29, 2001 .. "Fnr.peratui T Tcrrperatun: "  :~tress Stress Profile Profilc Stress rnten:;ity Stress [nterr;ity Factor -c1'm'r.arv Re-ilts Prc1)miraIy'~~~Jltj Heat 69 Ca5e:Case: ,n CD) - J.6.E-5 CDF  ? 6.-- / year *u LEf~F LEItF - 55.4,1-8 4E-8 Iiyear year Heat 69 wito Heel with HE;:P REP ass,umed assumed to be 05 0.5- '0" CDF- - 6.8E-5 CD::- 6.8E-5/year / year ,b II> LERF - 9.60-8 LEltF - 9.6E-8 "'year year Results R~;;~lts Heat 6~1 I*leal results are 'ouncing (9 results Jouncing due to many assumptions. Summary of bounding assumption~; inc:\udes the following: assumptions includes .. L.Ekk L(~c In'liation Frequency In:tiation .. Prcbabi..it, Prcbabiitj of OD Crack Initiation to Time to 0[1 O0) Crack Initiation .. Cra.ck Creck Growth tv10del Model Stl:-esses Stresses .., Prchability Pre bability of Core Damage Usingr Using actual feld results for Cire actuc.l hid Circ Cracks versus axial crac<<s cracks and applying a Weibull distribution distriblltion for initiation rates yields the following bounding bounding values: f-leat 6)
    Heat 6), Case
    <II CDF ([IF 1.1E-6/year 1.IE-6/ yea .,. LERF I1.7E-9 . 7E-9 /year / year .. Pe-sonPe:'son REVI RE\1 0.11 0.11 Ar. alyv es  !'\ral'iies 0D III INPS'ss [~valuation DHNPS' ,valuation is based on our visual inspections inspections performed performed in 10, 11,11, and 12 RFO RFO (May 19%, 1956, April 1998, and April April 1998, Apdl 2000 2000 respectively) respectively) III The inspection inspection results afford aJford us assurance that all but 4 nozzle penetrations were assurancelhat inspected inspected in 1996. All All but penetrations were 19 penetrations were inspected inspected in 1998. And all all but 24 24 peietrations peJetra.tioHs were inspeGted inspected in 2000. TLe H,e limfiting limiting nozzle popalation is thos.e nozzle populatiori those nozzles that could not be inspected inspected in 1998 oror 2,000. 2000. ill ItIt.5 .s conservatively conservatively assumed assumed that for these penetrations, aXial through penetrations, an axial through weld weld flaw occurs immediately occurs immediately upon startup staltup from 1010 RFO (May 1996) 1996) 3:2 32 YEDB"OoO39 FEDB-000038 DOJ003-000589 DOJ003-000589 Company Company Nuclear l";uclear Review Review Board Board Meeting Date Meeting November21), DateNovember 29, 2001 2001 Initial Flaw Siz.. In.i1iaU~law --,'iiz.,~ Initial flaw Initial flaw dep',:hdept h o,," of0.5 O. 5ram, mm, 1720 1720 around around the the nozzle, nozzle, isis assumed assumedtotoexist existimmediately immediatelyupon upon achieviig a ftill penetration achievilg a full penetration axial flaw. axial flaw. a;iis 13l~ill;il
    • .. This 1:1is isisaaconsei conservativevative flaw flaw initiation initiationsite site size.
    size.
    • ~ ItIt i;i:; further conservatively assumed further conservatively assumed that multiple that multiplestarting startingflaws flawscould could exist exist and and that that the~e would eventuall.y the;e would eventually link together. link together.
    . It L; cor.ser*vati\,e in that by assuming this starting point, we also are assuming that we *b It i:; car.sel~/ati',e in that by as:;uming this starting point, we also are assuming that we ha% ha\e e already already had had several several years yearsof offlaw flaw propagation propagationaxielly axicllythrough throughthe the Alloy Alloy 182 182weldweld ma erial. maerial. !,Jse cf Moclified Scott l).s.(~J;,fMocbll,~d S(:ott Model MQ.QJ~ The Modified The M'Jdified ~;cott Model Scott Model isi:;still stilldeemed deemed credible credibleasas aa mean meancurve curvefor for crack crack growtq:h growth rates. rates. ".. Da:a received to date does not Da:a re<~civcd to date docs not negate the curve. negate the curve.
    • .. Nu merous ;urves havebeen Numeroljs~ur\es have been developed developed and and toto aacertair.
    certair.degree, degree, they theyallall rest reston on engineering engineeringjudgement. judgement "o The data from OTSGs for Alloy 600 is relevant for developing the CGR Th,~ data fnm OTSGs for Alloy 600 is relevant for developingthe CGRcurves curves and and in in fac: is conservative in that the Alloy properties are still relevant fac: is conservative in that the Alloy properties are still relevant and because any cold- and because any cold~ working working of ofthe the tubes tubes atat the the tube tube support support sheet sheetwould would increase increasethe the failure failure rate rate over over non-worked Alloy 600, will make nOIl-,-vorked Alloy 600, will make this conservative. this conservative. Allowz.ble f\liov~blc Crack Cra_ck Size Size Determination De1s'!Jninati!;~ Vh::ee ;eparate allowable Th~e(:;eparate allowable (safety (safetyfiactor fa,:;tor of 3) determinations ofJ) determinations have have been been documented: documented: .. VIRP-.4 (Dorninion Engineering) vRPA4 (Dor:1inion Enginee:rlng) - 273 degrees. - 273 degrees. ..S EMfC2 F:v1C2 -- (NR(2 (NRC funded) funded) --270 270 degrees. degrees. II> S 1A (I'avs-Besse plant S fA (Dav!s-Besse plant specific) --302 specific) 302 degrees. degrees. Why 'Whythe the differernce? difference? Variable Variable Dominion Dominion SIA S[A EMC2 EMC2 PP 2,500 2,500 psi psi 2,185 2,185 psig psig 2,500 2,500 psi psi 7flow vnaw 51,950 51,950 psi psi 69,900 69,9002 psi psi (Y+U)2.4 (Y+U)2.4 (43,290 (43,290 psipsi ?)?) 2 in Ai..c /\1><,<< 6.,J045 in 6.0J045 in22 5.90 5.90 in 2  ?? Awl,, 6.5744 in 6.67 in22 A""l! 6.5744 in2 6.67 in  ? FS FS 3.0 3.0 3.0 3.0  ?? What Whau10es does larg.erAllowable larg~liJlowal2ls< Crack Crac[Size Size do do for us? fOLus'Z Applying it to ,:he CGR models Applying it to lhe CGR models d4~"eloped so far, the developed so far, theadditional additional 32 32 degrees degreeswould would result result in in the foliowing additional the foliowing additionallllntime when comparedruntime when compared to to the theNRC NRC Assessment Assessment --Figure Figure23. 23. ..S32.S 32; Bounding.. Bounding .. 66 additional additional months. months. ,.. 31:331 :~ Bounding .. 8 additional months. Bounding -. 8 additional months. .., 313 31; Bounding-. Bounding .. 10 10 additional additional months. months. ,.. 313: Mean
    • 20 additional 3 1:~ Me:an* 20 additiomJ months. months.
    ,.. 31 31;i Mean Mean **22 22 additional additional months. months. 33 FEDB-000039 FEDB-000039 DOJ003-000590 DOJ003-000590 Cornpany Nuclear Company Nuctear Review Review IBoardBoard Meeting Date November 29,2001 29, 2001 Smm LLa :wY ~).u IlLfTI1i:Y liased Hased on dekrmmisticdet.crm'inistic and probabilistic probabilistic assessments assessments independent of the NRC's NRC's preliminary preJimillary stair assessment, there is is reasonable reasonable assurance assurance that Davis-Besse Davis-Besse is IS safe to to c)perale until the next refueling omage
    )pemte outage (March 2002).
    Discussion ~~!!J:!mi![y Qi2(dJ:3~.ion sumimary and actions: liCt:i~H1s~ 'This This is is ~learly ;learly :he most important safety issue at Davis-Be:;se. Davis-Besse. From a risk perspective perspective the the core damage frequency fr'~quency numbers are very low. A Februa-y Februa:.y 16, 16, 2002 shutdown date was pro-osed proi)osed to the NRC based on a solid risk analysis and w,~ the: NFRC we expect their acceptance acceptance of our our arguments. k. A.t,. discussed earlier, Howard Bergendahl Bergendahl has an action to make sure that Operators Opera.tors are aware aware of tdltail telltail indicators indkators of problems and have the necessary necessary guidance guidance to appropriat-e actions when management take appropriat.~ management is not immediately immediately available. Mr. LEW Me Lcw Myers also pointed out that itit is important '~o co keep our our local stakeholders infcrrmnd of the inie,rnwd 'the situation and the basis of our decision making making. Mr. Kanda asb~d asked ftor t~)r concerns concerns from the Board. The consensus of the Board Board was that the risk. a.nalysis risk analysis presented seemed thorough and they indicated p!"esented 5;eemed indicated the plant appears safe to to operate:. Mr. lM4oflfitt operate Motlfitt took an action to assess the potential missile effects of a CRDM nozzle failure. (Action DB-ll/29/01-03) nOL;zl'e DR-11/29/01-03) CNRI3 Administration The Perry October October 4, 2001 meeting minutes w(~re 4,2001 were approved. Mr. MT. Saven Sayven discussed the Perry specific requirements contained in Ru.1 requirements contained R.l.1 and 8.1.2 8.1 2 of the -NRB Policies; Cl\RB Polide~; and Practices. Practices He said that these paragraphs paragraphs state that 'thethe CNRB is res.on;ible respon ,ihle fo( fov an an annual assessment assessment of the effectiveness effective:ness of the Quality Assurance Assurance prcgra~n to ensure prcgran ensur,(: that it meets the Nuclear Repair and Repair (NR &R) program requirements and requirements and flat tfat art an annual review and reporting reporting of the adequacy of the Emergency Plan has Plan has been been completed. Both Both of of th,ese these actions are the responsibility responsibility of t1he the Loss Prevention (LF') Prevention (LF) subcommittee. subcommittee. He went on to say that to ensure ensure clear documentation documentation of of the completion co mp\ction of theseof these. requirements is captured captured in in. CNRB Main Committee meeting minutes, Mr. Hen-yman.; Berryman.; the LP Subcommittee Subcommittee Chairman, Chairman, provided written responses regard:ing regarding t]iose acrions. Those those aCl:ions. Those statements statements indicate indicate that the requirements requirements have been met as _oY.ow:;:
    o[ow;:
    ŽIAi. ~\11. B1-rryrnan 13~rryman said said in his written response tlhat that he had reviewed reviewed the requirements requirements and concluted concluded that the th(: requirements have been met for Perry through the LP subcommittee activities activities as reported report,;:d to the CNRB: CNR3:
    1. The
    1. rhe subcommittee has performed perfomle:d an assessment assessment of the effectiveness effectiveness of the the: QA QA Program tc tc ensure en~ure that it it: meets the NR&R NR&R Program, regulatory, and and FENGe FENOC recluirements by reviewing the QA audits and surveillances requirements surveillances performed for this this 34 FEDB- 000040 34 FEDB- 000040 DOJ003-000591
    Company Comp iny Nuclear Reviiew Revilew Board J\1e'~ting Meeting Date November 29, 2001 pur-po~e. Jurpo~e. 22 The SubCOllunit';ee subcomnmittee has reviewed reviewed the adequacy of the Emergency Plan (EP) thrc.ugh thrcugh fc:iew review of audits, sdf-assessment~" self-assessments, and NILC inspection. NRC inspection activities. in addition, In the LP Subcommittee Subcommirtee ChairmanChairman met with the EP Manager Manager twice during the y,~ar year to to review pro,~,r2Jn performance review prograzn perfonnance indicators and major activities. Mr. Mr Saven also abo indicated indicated that tbat the the! CNRB Policy and Practices Practices is under revision 10 to reflect the new neN 50.59 pre,:;ess and the incorporation 5('.59 proeess ir,corporation of Beaver Valley into the Quality Quality Assurance Assurance Program Manual. Progrcm Manual. The 50.59 changes changes have been drafted drafied based on input MW. Prasad input from Mr. and the revision will rc'"ision \Nill be sent out oU': to the vice presidents presidents prior to obtaining obtaining Mr. Saunders ap.;ro,,al. aP:Jro"al. Review/Clos ure of Previous CNRB Actions: The B T3Iard )ard agreed agl eed to close the following actions. 1)13-3/29/01 J -02, DB-J/29/0 -02, Review SOER on Breaker Breaker Problems at San Onofre Onofi-e and do a study a case study SCIER 98-2 Breaker Project on SeiER Management issues. The CM Subcommittee Project Management Subcommittee heard a presertatie,n ,resertatc-ioI of thetil{: case study and recommended recommended closure of this action. The Action was was closed. D[3-3/29/01, Check into making the LAR DB-3J29/O'I, LAR process process procedure a common proC(:ss. process. Mr. Van]) :nabe:elt; VanJ) .nabeele indicated indicated that Mr. Kevin Kevin Ostrowski .ostrowski said that the LAR LAR would would be added to to common processes, but the list of conunol1 recormnended it not be b'lt that due to its low priority he recommended be carriedt as a CG\RE, carried C'iRE open action. The Board Board agreed. Recalp of ]Mkceting4jActon Item:; Note: Suggestions and ations actions made during the cour~;e course of this meeting are Identified identified withir the text: text with bold type. CNRBJý Action Cl'>1RB Action ---- DB 11/29/01-01, 11/29/01-01, Mr. Bergendahl took an action to look at developing developing guidance ::or :bor Opt!raton. Operators to recognize Reactor Reactor Vessel Vessd Head and Steam Generator Generator tube tube luikage teJtal;::s leakage te'.ltal.s and arld their potential implications. implic:atiol1ls. (See (See page 7) Adrniliistrativ,- Action - Mr. Kanda Admi'1istratilJl! Kanda took an administrative administrative! action to ensure ensure that Tuesday's Tuesday's Plant Status prese1tations presentations include the identification identification of plant challenges to safety for CNRB safety fhr probing. CNt$I C'ilLB Action 11/29/01-02, Mr. Moffitt took an action for aa CNRB pr,esentation Action - DB 11129/01-02, presentation at the May meeting on the Equipm~nt Equipment Reliability Reliability Program. (See (See page 13)13) CNIU3 Action - DB C:--rRB 1/29/01-02, Mr. Moffitt took an DB 111/29/01-m, act:ion to assess the potential an adon potent::al missile effects ofa effects of a ClIDM CRDM nozzle failure.failure!. (See (See page 36) 35 FEDB- 000041 DOJ003-000592 DOJ003-000592 Comp.all)* Nucl,--ar C'ompaiiy Nlickar Reviieýv IRcyiew Board Board Meeting Date November Meeting Date Novembcr 29, 2001 29,2001 4 eCetiIlIQ CoIdCjsio as 11 eetillE critique 11,Mveetinri sheet results critiqlH: sheet presented in results are presented, in Attachment 3. Attachment :3. The CNRB The rncding was Cl'RB rneeting called te was called order at 0730 tc order hours and adjourned 0730 hours hours on 1700 hours adjourned at 1700 on N ovebernr 2, \io\'ernber 29,2001001 Sufficient membership was Suflicient membership was available :tor a quorum. available :For quorum. Based on Based (*n thz ccmpl,~tion of th,:: ccmpletion meeting, CNRB of this meeting, CNRB andand Subcormittee review responsibilities Subcorrunittee review responsibilities f~)r the jocuments for Attachment C are listed in Attachment Jocurnents listed considered closed. are considered closed . .'\ ppr(~ed and Appra:yed I ecornrn.en,~' al1d tecommended to ee Board cd to for approval: Board for approval: . .,;,1/ ~~,,-1 ~:~ . ~ c.~___ --z:::~~~ \ . Date: /2J(iA~L I Date:_ _ W. 1,.L. Kanda, CNRBPCNRB.f~ airman ' . Al pro* *3y oarc. Date: _-IO-07 WChairman t' S, Co .*rou e 36 36 FEDB- 000042 FEDB-DOJ003-000593 DOJ003-000593 Attachment A Comp iny Nuclear Compwy Nudear Review Board Boardi Meeting Me4!ting Date November 29, 2001 Mr. JKane's
    \1.-. Kane's F,eld Feld notes fr-om f,-om Work Mafiageinent IlIsses:;ment:
    \Vork Management assessment: There There were interviev.s conducted were inteJvlCv,s conducted and observations made in the zxea anc observations management. 2Iea of work management Meetings of workweek workweek progress at T-9 T -9 and present present workweek were were attended. a.ppea&s to be There appca::s attended_ Thcrc be little data availaole to analyze why wcrk schedules schedules are so unstable unstable from T-12 to T-0. T-O. There is is little ~ docur.:ritation cf do(:uLlUltation who/why changes c,f wllO/why changes have been. Management appears to be seeking been made. ManagcmGnt seeking G.a.quick fix witlout witl:out data dat BelowBe):)w are are: some facts as we observed and some considerations to be: evabated evaliated as potentiad potential corrective corrective actions FA C'TS FACT~; 11/ CM Cr-.l B// low (al:out B/L Ie*,;, (at-out 1.0)1~*O) but still still using the 12 week schedule process process "iii MNlnager of work control position shared 'with
    \l;;nager -with manager outage management OUUtgc management
    .," FIN Fn~ team under.:taffed under<;taffed III Work V/ork schedule r.ear i.ear nen-existent ncn-existent *., Fa:lures in Fa:lure~ in work managemnent not always 'Nork management always captured/documented captured/documented .. Work week schedule meetings minutes not taken to document document changes changes *~ accountabilitv for ~;chedule Nc accountability schedule changes changes ~* Syy item S ;tem eng: engineering neering no: represenced at T-9 no'. represcnce;d T -9 meeting .. Only 1I of 4 WWA'Ms O \VVv'Ms are active S'Os SROs ~* Exzessive ,,:hed:Jle Ex::essive 3,;hedule chamges changes between between T-2 & & T-O T-0 ~* ThIre i.5 Th::re is a lack of priority priority system for work; work; everything everything is a 400 series. The loudest group appears to get the work they want wanl done IiJJ slakeholdc:rs of T-9 work week Som-e stakehold,::rs SOl1e with work unf:uniliar with \r.,eek unfamiliar activity work activity IiJJ Tagging rec.uesi s late in Tasging rt(:uesl'; in arriving arriving, 1"orT-2 for T-2 work (14 (14 of 28) of28) CONS [DEltAI[DERA'l IONS ... Need to switch w 1:o short cycle INPO supportedsupported planning technique tecimique 41 FI. team needs ops, parts, and RP members Hi'>J' members o <II Need Need tc capture all work management management failures for trending
    • Need
    <II Need tc move to tel a philosophy philosophy where all 'NWMs WWMs hold active al;tiVl: SROs. Suggest they man the WSC de:;k during their workweek. The shift engineer engineer could assist and perform perform function during back back shifts. Suggest S/M be; be given work activities that will schedule schedule while they are on duty 0 Noted 00 Ncted near:y neary all I&C work activities were removed from T-9 schedule (1/28-*2/3) (1/28-.2/3) due to no no re, ources in rc!ources ill shop. shcp. Training Tr3.ining stripped stripped the shops and line Irumagement numagement accepted 1NithOUt without seeking seeking an altematc alternate solution 1:0 t:o deal with training need. Core: Core business like PMs deleted and and drove adlitional adjitional work to prepare prepare PMDs to allow allov: use of grnce. grace. o E'Very oD work management E"ery ,',:ork management meeting meeting should. should. have have minutes showing attendance and capturing minutes showing captturing the the negative changes negativ change;; 1:: made to the schedule, why changed, and who changed changed the schedule. schedule_ ,O W)fk 'D WVk iJstructions instructions are designed to be vague; this challenges challenges understanding understanding the work scope and and necssary c1eaml1ce nc:;cssary clearance needs.ne:eds. 37 37 FEDB- 000043 FEDB* 000043 DOJ003-000594 DOJ003-000594 Attachment B B Company Nudcar N ui:lear Review Board Board Meeting Date November 29, 29, 2001 2001 ~~un'c" Survey CNRB ~ovclI\lJer -- CNRB November 2001 Mccl[ing Meeting Activities Average! rating, Avcrag,' rating reslllts results (FJi:NOC/Offsite (FENOC/Offsite members) fc,r for meeting presentations (\1at('.rial Coverage, Cla~'ity, (Material Coverage, Cla-ity, and Value) Value). TheThe rating scale was was as as follows: j =Ioor, 2=below average, jl=poo.G.l.=below average,3>average, 4::1@()d, S=exccllent) 3=average, 4El9d, 5=excellent) Material Clarity Value Comments CP Sub-Comm. Report 3.7 3.6 F3.8 ýVM -Sub-Commn. Report -4 41 4.4 ** Excellent analysis/presentation analysis/presentation of WM issues CM Sub-Coriii. Report --------* ..---------*-*--------4 4.3 4.2 4.3 3.8 -------- LP Sub-Commn. Report 4 ** Lack of definitive answer on compli.mcecompliance ** Not insightful, insi Yhtful, don't know ifwe're if we're that good good. SER Sub-Comm. Sub-Comm. Repilrt Report 3.5 1.5 1-3.5 3.7 Presentation slanted towards the po~.itive *# Presentation positive ** Met Met need *+ Didn', Didn't really rally focus on management management problems + Gen<:rat.::d GeneratA Q&A plus good actions + good discussion of actions taken to resolve issue
    • Very g())d
    . Failed t(~discuss _~-.!:aikd proble~~. ______ to discuss non-tech problems DB Plaiu Status I)B Plallt Sta~tus 44 ! 4 4.2 4.2 ** Safety Significant disclls~;ed Significant Issues not discussed +* Handout too small to read read +* Good Presentation of INPO finding; findings 13V Plant St itus BV Plant Sutlls 3.9 3.9 3.9 3.9 + Limited time for presentation presentation and discussion discussion ?Y
    ~y Plant St;itus Stltus . 3.7 3.7 3.7 3.7 +
    .. Limited time for presentation presentation and discussion d.iscussion -+-----+---_ ..* Handout.. too small to io read--- read _AR 01.-00 2 3.5 3.2 3.2 3.2 Same Same LAR 0 -0008 33.5s 3 3.2 3. 2 3.2 Same Same --+-----------------------------i LAR 01-00 i I 3.5 3 33.2 Same FS-ame CR 0 1-0080, 3.6 3.8 3.4 3.8 3.4 ----j-- ------------------ LAR lA-2%6/2A- 16 ] 3 3.3 ** Concern sensitivity to NSHC 3.3 T33 -----_._-------j -.--t--- Reactor Ve:;sel Flead Reac\oJ Ve;sel Ecad 4.4 4.4 4.6 4.6 4.6 *.. Good Discussion Discussion ..* Good Job ..+ Excellent Excellent presentation presentation of issue ane. good issue ant, good discussion discussion of of risk Problem Solving/ Problem Sclving/ 3.7 3.T 3.7 3.3 ** Problem not CNRB issue Mgmt. Problem is'sue -just ....just need need the results results Troubleshcoting Troubleshcoting Prozess Pro:::ess *o Info is covered covered in root foot cause training, training, but trngtrng is not not given given IDwoall people people on site site + ~.s~nificant .. No significant insight communi~l:.::.ed=-_______, insight commurnicaLed 138 38 FEDB- 000044 DOJ003-000595 DOJ003-000595 Cornp;iny Cornp<iny Nuclear Nu.::lear Review Review Board Board Meeting Date Meeting Date November November 29, 29, 2001 2001 iernea Conin'inls~ 4~ Recommend Recommc::nd liul filIi CNRB CNRB presentation presentation on on Equipment EquijJITIcnrReliability Reliability luiprovernent Improvement Plan Plan
    • ~ CNO 3 faled. :o look at head penetration issue, staff awareness O*mB fa.led. :0 lo*)k a1 head penetration issU(:, staff awarene~;s sllould aaleak should leak occur occur w/conseqnences w/conseqnences 4<I- CN013 f(l ilc(~ o'0 address Cj*mB failec adjress clle:etive c:)lle:;tive rsk nsk fromn frolll RCS leakage, S/G RCS leakage, S/G tube tubelcak leak potential, potential, RCS Activity, Fuel RCS Activity, Fuel Failires Fail .Ires
    +.. Gocd Goed Meeting i'vle::ting +.. TheThe WM\VM insiylhis ill5i,~hts clearly clearly showshow that thatwe we have have limited limited understanding understanding atat the the management managementlevellevel of the
    )fthe basic bas.i: process proGess and and howhow itit isis designed designed to[0 work.
    work. AllAll 33sites sitesshould should rectify rectify this. this. +-4> Adtition Adl.itiofl ofof1-AC.*A re.presentatives rCJfcsenlativcs atat subcommittee subcommitteemeetings m;etingsseen seenasas positive. positive.
    • -4> Parficiparion of all WK Directors or their representatives Pa rlicipa*.ioIl of all WK Director, or their representatives ill W.I. in WM Subconmiftee Subcommittee provided provided significani signiIicalll bcnefit bendi1 toto DB DB staff.
    staff oo Regarding Reg:uding, C14RBCJ~RB reviewreviewofofTech Tech Spec. Sp,~c. changes, changes, itit will will be be difficult, difficalt, ififnot not inmpossible, impossible, for for outside outside members meL1bers to10 r-,view r.!view the thcchanges cll<l.ngestotoensure ensuretechnical technicaladequacy adequacy(for (forconversion conversion totoImproved Improved Tech.Tech. Spc-s). Spc :s) Suggest Suggest aa CNRB CNRB Subcommittee Subcommittee be be set up toto review set up review and and recommend recommend approval approval ofofits its packages packages to10 ((NRB. NRB. This Thisisis too100 big bi,E: ofa ofa task task for forthe the whole wholeCtqRB. CNRB. 39 39 FEDB-000045 DOJ003-000596 DOJ003-000596 Attachment Attachment C Companiy Comp,fln), Nuclear Nuiclear Review Review Board Meeting Date November Meeting November 29',2001 29, 2001 RE(QLIRED REVIEW FOR CNRIM T rarismiittal __ate_- Aril 12, 2001 Transmittal Number - DBCNRB 01-0028 o Fx:-01-00121, Fx-O 1-00 121, Log"1"o LogNc. J1-4175, lnspectioii Rep0l1 -4175, [nspcction Report 01-)3 0 J-03 ThJiS.m-IihtltL e)ai: =: ixril 1.2,_2001 Transmiital Number -: DBCNRB 01-0027 .. SCNRB CNRB Meet.ng Meetng Minutcs, Minutes, March 29, 2001 lr).:uansrnz ttal I~ate=--p_ 2552001 _____ Transmittal Transmittal Number Number = DBCNRJJQ1:!)035 0= DBCNRE 01-0035 (Reviewed (Reviewed at Perry 5/10101 5/10/01 meeting) .. LA.R No. No_ 00-0005, revise Containment Containment Equipment Hatch closure: closure requirements re(\uirements during refueling. 'J LAR No. 01-*0004, LAR -r-;o. 01.-0004, revise revise Steam Generator repair roll requirements. requirements. 'rransinttal TrallsmLtal . ___ .... _ _ _ _ _ _ [)at,- Dat~ ___ ,= Mav =_\1av ,,_ 77...1..----.- 2001_ _ _ Number I)BCNRB Transmittal Number:=; 01-0044 PBCNRELQ.l:')044 *,. Ext-0]-00IS3, Ext-01-00193., Log No. Inspection Report 01-06 No 1-4184 Inspection 0 1-06 Transmittal )at := Septenber1.8 2001 rr<I!1slTIittalDat~_=_S_~Rtelnb~;!...1lL2001 Transmittal Number Number == DBCNRB 0 1-0077 DBCNRB 01-0077 (Reviewed at Perry 10/4/01 (Reviewed 10/4/0] meeting) meeting) *" LARUlR No. 01-0005, 01-0005, SFRCS Instrumentation Setpoints and Instrumentation Setpointsand Surv'eillance Interval~; Surveillance Intervals *" LAR No. No_ 00-0006, Power Uprate Uprate Transmittal Dale = Se*ptnber 25 2001 Transmittal Transmittal Number =- DBCNRJ3 DBCNR)} 01-0079 0] -0079 ..aSER Subcommittee Meeting SER Subcomm'lttee Meeting Minutes 186, September 4, 2001 September 4,2001 Transrn itial Dalae = October 10, 2001 Transmittal Number = DBCNRJ3 01-0089 .. Serial Letter SUlal Supplemental Information to LAR 98-0013, Letter 2732, Supplementallnfonnation 98-0013, Spent Spent Fuel Storage Capacity Transmittal Date Novem:nber 14 2001 Transmittal Number DBCNRdB 01-0102 o tt LARJ No. LAR No. 01-0012, 01 -0012, Pressurizer Pressurizer Level ".. L\RLAR No. 01-0008, RPS Instrumentation ~\[o. 01-0008, RPS Instrumentation ..o LAR :t-Jo. L\R No. 0)01-001], -00] ], Administrative Controls -- Administrative Controls -- Startup Startup Process Process 40 40 FEDB- 000046 FEDBM 000046 DOJ003-000597 DOJ003~000597 Comp~ny Compr ny Nuclear Review Board Nuc.lear Meeting Date November 2-9, 2'1}, 2001 RF~~J1R~~D RJ~;VIEW R__Q1,IREI) REVIEW FOR LP SlJBCOI\1l\lITfEE SUBCOMMITTEE .ransmittal D)ate =Aril 12* 2001 Transmittal Number := DBCNRB 01-0034 *SNMinthly Qu:ality Repor1 .t'o.Lmthly QU:llity Repoit February ** Condition Reports 2000-2024, 1999-*0336 1999-0336 ** hl-O: E>I-0:-00121,-00121, Log No. NM. 1-4175 1-4175 - Inspection Report Repor1 01-03 ** SLrveiJance SurveiLlance SR-O SP-01-12N.'GRG-02 1-E\JGRG*02
    • SuveiJance Surveil lance SR-00-RPRWP-01 SR-OO-RPRWP-Ol
    ** SCTVeiJance Su rveiLlance SR-O SR-01-CORAC-0I l-CORAC-O 1 Self-Assessrnent
    • Self-A ssessment Repcrt Report Critique Dated 4/3/01
    [r-lansms'iltal DateMay 2001_ Transmittal Number = DBCNRB 01-0042 *.. M-nthly M:mthly Quality Report March *.. Quality Quality Trend Sumn~ary Sumnary 2000 - Condition Condition Reports ".. Fxt-01-00193, Log ht-01-00193, Log No. 1-4184 1-4184 - Inspection Rep0I1 Report 01-06 01-06 "., SLrX'ceilance SLlveillance SR-01-TRMIN-01 SR-O l-TRAIN-D 1 .." Srveillance SLrvei Ilance SR-00-RPRWP-02 SR-00-RPRWP-02 .." Si.rveillance SR-01-RPRWP-03 SLrveillance SR-OI-RPRWP-03 .." SLivei Ilance SLIvei llance SR-01-OPSCH-03 SR-O 1-0PSCH-03 Tr-ansrrittal Date :=June 13,_2001 Transmittal Number= Number = DBCNRB DBCNRB 01-0051 .,* Monthly Quality Report April " Quality II Quality Trend SummarySummary 11Itst Quarter Quarter 2001 II StIf-Assessment Self-Assessment CritiqueCritique Comments Comments 5/30/01 5/30/01 II St-rveillance Suveillance SR-01-QUART-01 SR-OI-QUART*Ol '0 Scrveillance Suveillance SR-00-RPRWP-04 SR-OO-RPRWP-04 II Audit AR-01-PROMC-01 AR-O I-PROMC-01
    • Audit AR-O II AR-01-FLREP-01 l-FlREP-O 1 II Suveillance SR-01-MAINT-01 Surveillance SR-Ol-1Vl!AINT-Ol
    *II Suveillance SLrvei [lance SR-01-EMIPRP-01 SR-OI-E\1PRP-Ol
    • Strveillance II Slrveillance SR-01-ENGRG-04 SR-OI-ENGRG*04 Transtr ittal Date = July 12 ,_2001 Transmittal Number = DBCNRB 01-0050 DBCNRB 01-0060
    ..* CR 1999-1259 1999-1259 and CR CR, 1999*-0932 1999.-0932 ** SiLrvei [lance SR-OI-TRAIN-02 Suveillance SR-0 I-TRAIN-02 G Si.rveillance II SR-01-SECUR-01 Slrveillance SR-Ol-SECUR-Ol 0II St.rveillance SR-01-PNGRG..05 Slrveillance SR-OI-ENGRG*O'i *II Survei.llance Suveillance SR-01-ENGRG.-06 SR-OI-ENGRG-06 FEDB- 000047 41 41 DOJ003-000598 DOJ003-000598 Cump:wy Company Nuclt,,ar NlIc1t~ar Review HoardBoard Meeting Date November Meeting November 29,2001 29, 2001 *, I -RPRWP-05 Surveillance SR-O l-RPR \VP-05 ** Exi-01-00294, EX1-01-00294, Log No. 1-4191, 1-4191, NRC Inspection Report. Repon 01-07 ** Mcnthly Monthly Quality Report - May I.-'rar..sni*-at Date- August 8_,2001 Transmittal Number = DBCNRB 01-0067 II CR 1999-0903 and CR 2000-1. CH 1999-0903 001 2000-1001 II Suriveillance SR-OI-CHEMC-02 Surveillance SR-.0I-CH-EMC-02 II Self Assessment Report Critique Dated 7/24/01 7/24/0 I II Monthly Quality Program Prognm Report -.- June nd t> Quality Quality Trend Trend Report Report 22nd Quarter Qual1er 2001 c> , Su:.veillance SR-.0 I-QUART-02 Su*-Yeillance SR.-*O l-QUAR T-D2 ** E*XT -C]1-00416, Log No EXT -C1-00416, 1-419R --NRC N\o- 1-4198 Inspection Report 01-10 NRC IIlspection 01-10 T'ransmittal =a-September 13, 2Q01 Transmittal Number = DBCNRB 01-0075 .,do Condition Report Repol1 CR 2000-0426 2000-0426 u" Monthly Quality Program Report Quality Program Report _.-- July July u" Surveillance Report SR-0 I-ENGRG-09 Surveillance Report SR-O J-ENGRG-09 ou Surveillance Report SR-0I-CORAC-02 Surveillance SR-O I-CORAC-02 Transmittal Date = October 10, 2001 Transmittal Number DBCNRB 01-0087 .. A, Adit Aldit Report AR-01-SECUR-02 AJR-Ol-SECUR-02 '. MonthLy Quality Program Report ---- August ,,~t[onth:.y August Surveillance Rep.ort .. Surveillance Report SR-OI-RPRWP-06 SR-01-RPRWP-06 Surveillance Report SR-01-MAINT-02 .. Surveillance SR-01-MAINT-02 ..a Surveillance Surveillance Report SR-Ol-PROCE-Ol SR-01-PROCE-01 ** Surveillance Surveillance Report SR-01-TSTCA-01 Report SR-OI-TSTCA-OI T.ranssnttal [)ate = October 24, 2001 Transmittal Number -=DBCNRB 01-0092 ** Audit Report Audit Report AR-Ol**NFUEL-Ol AR-0I-NFUEL-0 I *" Surveillance Surveillance Report SR-01-SECUR-02 SR-Ol-SECUR-02 *" Condition 99-0878, 00-4114, 01-0785, C(,ndition Reports: 99-0878, 01-07HS, 01-0982, 01-1007, 01-00,23, 01**0147, 01-00~*3, 01-.01.47, 01.*1390, 01-1390, 01-1393,01-1508,01-1687,01-1973, 01-1393, 01-1508, 01-1687, 01-1973, 01-1969 01-1969 ** Self-Assessment Self-Assessment Report CritiqueCritique- _. 10116/01 10/16/01 ** Self-Assessment Self-Assessrnent Report Critique Scores Transmittal Date = November 14, 2001 Transmittal Number = J2I3CNRB DBCNRBI 01-0100 *" Suveillance Strveillance Report SR-0I-ENGRG-07 SR-OI-ENGRG-07 ** Sl.rvelliance St.rveillance Report SR-01-ENGRG-08 SR-OI-ENGRG-08 42 42 FEDB* 000048 t'EDB- 000048 DOJ003-000599 DOJ003-000599 4'_-:onipaay NucL!ar COmpall)' Review Hoard! Nuclear Review Boardl R wMeeting Date November Meeting 29, 2001 November 2~', " Surveillance Report SR-O SUJ"veil.anceReport SK-01-ENORG-1 l-ENGRG-IlI
    • Condition Rep0I1s:
    Reports: 0:1-1966, 011-1966. 01-2623
    • Monthly
    \IIclnthly Quality Reporl Rep0l1 '" September
    " Quality
    • Quality Trend Report Report"-- 3'd 3 Quarter Qu arter R[W UIRED .R.I!:Vl~W REQIIIR~D REVIEW FOR OP SUBCOMMITTEE SUBCOMMITTEE
    "!rarnsmi*al 'f ransmltlal DatDaieG_== Ma. 7. 2001 1\:1ay~_20Ql_____ NJmber -=_D13CNRB Transmittal Number = DBCNRB 01 01-0041 ~QQ4l Surveillance SR-.01-OPSCH-03 *£ Surveilance SR"O 1-OPSCH-03 *S SUI-veilance ur-vell ance SR**OI-TRAIN-O1 SR-C.l-TRAIN-01 '"rar smital I)at c = June 13, 2001 Transmittal Namber DBCNRB 01-0050 * . Audit Audit ~;" R-O R-01-.FIMEP-01 I .. FIREP-O I ** Surveillance SLu-veillance SR-*O SR-.01-EMNPRP-C01 l-EMPRP-O 1 arsnmi:tal Datle- JLil. 12* 2001 . .. Transmittal Number = DBCNVRB 01-0059
    • Suriveillance :.R-.01-TRAJN-02 SL:lveiliance SR-O 1-TRAlN-02
    "-ransmi-tal Date = Auusi: 82001_ Transmrittal Number =-DBCNRB 01-0066 "* SUrveillance SR-O SUlveillance .SR- 1l-CHEMC-02 -CIFEMC-02 ** Station Review Board
    Station Revi{:w Boare! meeting minutes 3188 - 3201 3201 Transnii:tal Daate =S eptember 13 2,)01 Number -=ý DBCNRB Transmittal Nlmber 01-(0073 DBCNRB 01-0073
    ** Review Boare! Station Review 3Board Meeting Meeting Minutes 3202 - 3216 3216 Transrni:tal Date ==J)ctober..10, J[!!!lsmiJ9.1Qatt: October 10, 2001 2031 Transmittal Transmittal Number =:=: DBCNRB 01-0085 01-0085 ** Station Review Board Board Meeting Minutes 3217 - 3221 Transmiital Date = October 10, 20')1 Transmittal Number =: DBCNRB 01-0098 *a Station Review Station Review Board MeetingMeeting Minutes 3222 - 3224 REQUJIRED REVIEW FOR CM SSUBCOMMITTEE Transrniiital Datc = Mav_7 2C001 - Transmittal Number = DBCNRB 01-0039 41 ~;y,tem *System Health Repon Repori Jth Ih Quarter 2001 43 FEDB-FEDB*, 000049 000049 43 DOJ003-000600 DOJ003-000600 Comp~ny Nuclear Review Nuclear Review Board Board Meeting Meeting Date November November 219, 2001 29,2001 Transtrittal Dale =-June 13 2001 Transmittal Number = DBCNRB 01 -3048 ".. [)'~sig[) )esigri Basi ~ Assessment Basis Assessment Report Repol1 I" 1,\ Quarter QUaIter 2001 *.. Audit Audit AR-01-FIREP-01 AR-OI-FlREP**Ol *.. Surveillance SR.-01-ETNGRG-04 Surveillance SR-O l-ENGRG*04 JJ:ilnsrrittC!L12i!.L~_=)uly Transrmittal Dae = July IlL1~OOl ý2001 _____ . Transmittal Transmittal N'umber T. 1\umber ==DBCNRB DBCNRB 01 -3057 01-:)057 *.. Surveillance Surveillance SR-SR-O I-ENGRG-05 I-ENGRG-05 ".. Surveillance Surveillance SI-01-ENGRG-06 SR-O l-ENGRG-06 "fransrittal Dat:e = Septembe3 2001 Transmittal Number IDBCNRB 01-10071 nd ..* System Health Report 2 System Quarter 2 "dQuarter D<~sign nd *.. Dsign Bases Bases Assessment Assessrnent Report RepOit 22nd Quarter Transrrittal Date =-October 10, 2001 Transmittal Number Number = 1)BCNRB DBCNRB 001-0083 1-0083 ..* Surveillance Report SR-01-TSTCA-01 Surveillance Report SR-OI-TSTCA-Ol Transrr itial Da-*e - October 24, 2001 Transmittal Transmittal Number Number == DBCNRB 0 1-0091 DBC!\TRB 01-0091 ..* Aaidit Report A*ldit Report AR-01C-NFUEL-01 AR-OI-NFUEL-O I *d ..* S~rsterl1 Health Report Systerm Rep0l1 3' j3d Quarter Transrritial Daqe =.Novenber 14 2001 Transmitta~ Transmittal Number == DBCNRB 01-0096 01-0096 ..o Surveillance Surveillance SR'-0l-ENGRG--07 SR-O l-ENGRG**07 ".. Surveillance SR-01-FNGRG..08 Surveillance SR-OI-K\IGRG**08 o.. Surveillance: SurveillancE: SR-0I-ENGRG-SR-OI-ENGRG*11 II RI~!.!JIRED RE.QUIRED RE-VIEW FOR R!£VU:W FOR WM SUBCOMMITTEE SUBCOMMITTEE Transnrital Da:e =-June 13 2001 Transmittal Number = DBCNRB 0 1-0046 ..* SurveJlancE: Surve.1lance SR-OI-RPRWP**04 SR-01-RPRWP..04 If SurveJlance SR-OI-MfAINT-Ol Survellance SRk-01-MAINT-01 ..o AUDIT AR-OI-FIREP-Ol AR-01-FIREP-01 Transmittal Date = July 12.001 Transmittal Number = DBCNRB 01-0055 0 It Surveillance SR-O Surveillance SR-01-RPRWP..05 l-RPRWP**05 44 FEDB- 0OO"' DOJ003-0006011 DOJ003-00060 Company Nudear lCompany ReviEw Board Nutlear Review Hoard NNeeting Meelting Date Date November November 2), 21), 2001 tt a] [)at2 :,Ocblober 'Jji!l}g!lj.l<;lUtlr~ TIransrn 10, 2001 '~".Dctob:~JO, 2001 Transmittal Trammittal Number Number == == DBCNRB 01-0081 OI-008} ~ Surveillance Survcillance SR-01-RPRWP-06 SR-Ol-RPRWP-()6 'J Surveillance SR-01-MAINT-02 SurveiJlance SR-O I-MAINT-02 .. Surveillance Surveillance SR-01-TSTCA-C1 SR-Ol-TSTCA-O I Iransin tt a] [)at,- = November 14 2001 _ Transmittal Number = D)BCNRB 01-0094 .. Surveillance SR-01-ENGRG-07 Surveillance SR-O l-ENGRG-07 ..0) Surveillance SR-01-ENGRG-08 Surveillance SR-OI-ENGRG-08 .. Surveillance Surveillance SR-01-ENGRG-SR-OI-ENGRG-III1 ,RE.Q!JIR1~:D REQUIRlED Rf;:VIEW FOIL REVIEW FOR SER SUBCOMMllTTEE SUBCOMMIITTEE Transrnmttal [)at. -- _!;egrteber 25_2001 Transmittal Number == DBCNRB. Transmittal OBCNRB 01 -0078 Ot:D078 <J SER Subcommittee SfR S:lbcommittee Meeting "Meeting Minut~es September 4, 2001 Minutes 186, Septcmber 45 FEDB- OOOOS FEDB* 0000511. DOJ003-000602 P A-r--a Sý Th ) 01 03~/-{:' Dave Geisen 3-27-02 Dave 3-27-02 -- My involvement in evaluating the Reactor Head has has been been minimal until Generic Letter Letter 97-01 involving cracking of the inconel inconel CRDM nozzles. nozzles. I was involved in in the the BWOG Steering Committee since March, BWOG Steering 2000. 1I was somewhat involved in 12RFO. We evaluated the acceptability of ofusing water water waShiilgofthe washing of the Head. We left*some We left some boric boric acid on the Head Head in 2000. Andrew Siemaszko and Glenn McIntyre handled the issues. The Condition Condition Report was not very thoroughly evaluated. II signed signed removal removal ofBACC of BACC issues issues as as aamode mode restraint for the R12 restart on the basis that boric acid would be would be removed removed and and the Head evaluated. evaluated. This wasn~ wasn't done. I did this in my capacity asas the engineering representative engineering rm representative to the OCC at the time. rm not sure sure when I learned that we had not cleaned the Head completely. II know know became became aware aware of of it it in in reviewing reviewing the videos of the inspections while preparing preparing for the NRC interactions in August, 2001. interactions in August, 2001. At that point, I was disappointed but not worded since we all hadbad a conviction that there wasn't conviction wasnft a problem with boric acid corrosion on a 6000f 600"F Head. As of As of mid-2001, mid-2001 , we we re-reviewed re-reviewed the data and Head inspection information. The problem probably was that we that we started started with aa preconceived preconceived notion that we don't have much, if any, Head leakage and interpreted the data accordingly. the data accordingly. We had already decided decided that we couldn't getget.damage damage from leakage on a hot Head. rm not rm not sure sure to to what extent we participated in EPRI'sMRP. EPRTs MRP. rll actively in the ru find out. We participate actively BWOG. We BWOG. We chair six of chair six subcommittees. rn the subcommittees. of the Ill chair the Steering Steering. Group next year (later determined that EPRI MRP EPRI MRP participation has been been Guy Campbell and Prasoon Goyal). U.S. NRC (63 Ii.nAVID GEI~1.A .i DOCKETED DOCKETED USNRC USNRC D0tS OIC~ vd I Ev. I 200M94 September 9, 2009 (1 1:00am) September 9, 2009 (11 :OOam) OFFICE OF SECRETARY RTZESýE WMV NDR OFFICE OF SECRETARY RULEMAKINGS AND RULEMAKINGS AND ADJUDICATIONS STAFF AQ(rr ADJUDICATIONS STAFF ( 2S4-00613 254-00613 75,/4jZ -7c:oJ<-§ /)S-, d~ .NRC026-2908 NRC026-2908 A--,ft-s c-ooa(ý-ýr ooalf-r:- Dave Geisen Dave Geisen DOCKETED DOCKETED USNRC USNRC J~.me June 18, 18, 2002 Interview responses Interview responses are are paraphrases and summations, not representing quotations or September September 9, "2009 (11 9,"2009 :OOam) (11:00am) information. transcript quality infonnation. Randy Rossomme. Interviewed by Randy OFFICE OF SECRETARY SECRETARY RULEMAKINGS AND RULEMAKINGS ADJUDICATIONS STAFF 1.
    1. Did you review the contents of Docket 50-346, Serial 2731, dated September 4,2001 4, 2001 ADJUDICATIONS STAFF before it was issued?
    I was going to verify response was agreed on. I helped craft the response. Prasoon Lockwood's office. Lockwood and Moffit also Goyal and Andrew helped. Met in Lockwood's involvecL involved. Q. Was Prassoon involved, he states he only did a review? Yes, I would say he was in meetings on this.
    2. How much time were you given to review the letter?
    Just a couple of days to put it together. It was in dis~ussion discussion for awhile. a while. Two or three days to draft, then in review for about a week.
    3. Why were you to review the letter?
    ~; In re ~~~ID GEISEN 5+~ f+ #-::~~Lt_ U.S. NRC Verify it met the intent we wanted. DAVID GEISEN Exhibit # 'L Docket ## 1A-05-052 Docket 1A-05-Q52 )1 .) \} 5 ID~ 2008*(Tr. p;g~6_ '7
    4. Did you find any inconsistencies inaccuracies in the letter?
    inconsistencies or inaccuracies Date Mar1<edfor Marked for IDJ. 2008(Tr. p-,. .. ,-.. Not asked. Date Offered Date Offered in in EV:$, Ev: 2008 (Tr.p. g (Tr. p. Z-{P 1brough~' Through Wbetn1aneI:Panel: ,fJ /f;. M F
    5. How did you confirm Not asked confinn accuracy?
    accuracy? Da1a:., Action: Do*e: REJECTED WJT'HI)RAWtI 9LEDý REJECTED (fr. p. 2008 (Tr. aZl< ) WIMhORAM
    6. On page 2, what in your mind was meant by the phrase that the "inspection "inspection was to inspect the bare metal RPV head bare metalRPV that was accessible?"
    head that accessible'!" That was looking at a lot of plants who said they couldn't couldn't get there without cutting apart apart the head, and mirror insulation was conformed conformed to the head. We were addressing it from from that view point.
    7. Were
    7. you aware Were you aware that there was that there was boric boric acid on the head impeding impeding a complete complete inspection inspection of of the RPV head? (If RPV head? (Ifso so did can can you quantify it? Did you tell anyone?)
    anyone?) 254-00596 2S4-00 596 \ ( ~ykPL'f}T~ -:=-Sc-cy D~ j)J'<0"2-NRC026-2891 NRC026-2891 / ,L. ., .~ *tj. . /{. -, I found out there was boric acid on the head when reviewing tapes from this letter. rI 12RFO at the end of the outage in involvement I had in 12RFO thought it was clean. The only involvementlhad central, I was dispositioning mode restraint that it doesn't need to be a mode outage central, because we were going to clean the head, and this was restraint because was first time II knew that it 'I- ~,. ~ didn't happen., Andrew was beginning to map the head from the video happen.. At this time Andrew video .IJ. inspections. f~J .cI~L Q. Did VP know? At some point we recanted stating we had boric .acid acid on head. We weren't real concerned at one-point of our as-left position as much as our as found in '. t"'~- We weren't real concerned at one-point of our as-left position as much as our as found in \ , <- t.. ....... ) 12RFO. 12RFO. II don't think so on this letter.
    8. Was the boric acid on the head limiting accessibility accessibility to a bare bare metal inspection?
    No, it was viewed from a structural structural view. question requests that any limitation to accessibility be described. Was this
    9. The question requirement requirement satisfied satisfied in your mind at the time?
    yes accordance with NG-EN-00324.
    10. Also on page 2, it states the head was inspected in accordance NG-EN-00324.
    procedure applicable to the Was this procedure RPV head? Applicable to the whole RC system. IT didn't specifically call out the head, but it was Applicable to the whole RC system. IT didn't specifically callout the head, but it was applicable. procedure stipulate L What does this procedure 1I1. to be done when boric acid is found? stipulate is :to found? Clean Clean it
    12. Was the procedure complied with relative to the head?
    I thought we were. inspected in accordance statement be made that the head was inspected not, how could the statement
    13. (If not. accordance with procedure NG-EN-00324?)
    NG-EN-00324?) inspection. The question the NRC Clearly not with the procedure, but we did the inspection. NRC was going after was how do we ensure the inspection the inspection was done. At the time the NRC was looking for popcorn deposits at nozzle tube to head interface. looking interface. What we were takingtaking inspection. Clearly it didn't meet requirements in bulletin.(2001-credit for was general inspection. bulletin.(2001-01). So 01). we knew So we right off knew right that bat off that bat that that we were not we were going to not going satisfy the to satisfy the new bulletin. new bulletin. conformance with
    14. (If not, was DBNPS in confonnance with GL 88-05?)
    2S4-00597 254-00597 NRC026-2892 NRC026-2892 guess you would have I guess have to to say say no. 15.
    15. What NG-EN-00324 say does NG-EN-00324 What does possible cause say is a possible cause of red-brown boric acid?
    red-brown boric now Don't now
    16. Was there red-brown
    16. Was boric acid on red-brown boric on the head?
    Not asked asked
    17. On page 3, 3, the letter discusses that no visible evidence of visible evidence nozzle leakage of nozzle leakage was evidence nozzle leakage?
    detected. What would evidence leakage? Oconee, we were Based upon Oconee, were looking popcorn deposits. What we were seeing looking for popcorn seeing was was flow coming downdown the the nozzles. nozzles. evidence of nozzle leakage where the boric acid had accumulated?
    18. Could you detect evidence
    18. accumulated?
    next one. I don't think we thought about We did, but not sure if it was this letter or next about it here. concerned that there could be a nozzle leak from a crack on the DB
    19. Were you ever concerned head?
    Actually I[ thought we were far enough No. Actually sU5ceptiblity that we enough away from susceptiblity we wouldn't wouldn't have have one. how did you resolve this issue?)
    20. (If so, how Not asked referenced that occurred
    21. Were you involved in the videotape review referenced
    21. May 2001 occurred after May re-confirm indications to re-confirm and ANO- 1?
    indications of boron leakage were not similar to ONS andANO-I? Andrew did this. He went to ANO-) Andrew ANO- I while they were doing there inspection and he had knowledge. and we were using his eyes as a calibrated eyeball to make those first had knowledge, calls.
    22. (If so, what was the criteria? Pictures or tapes? Descriptions?)
    Descriptions?) Pictures we had gotten was only from one direction, no real good video tape. Andrew Pictures helped taking the video in Arkansas. But we got still shots. So Andrew Andrew who participated participated was more of an expert.
    23. (If so, who else?)
    Not asked 254-00598 2S4-00598 NRC026-2893 NRC02G-2893
    24. (If (If so, any concern about what any concern could be the cause of the boric what could boric acid on the the head?)
    head?) Andrew was Andrew was not concerned when not concerned coming back when coming Arkansas. Said back from Arkansas. peace in was at peace Said he was in his soul that that DB DB didn't didn't have have it.
    25. (If so, would characterize the boric would you characterize head as significant?)
    deposits on the head boric acid deposits significant?) Not asked letter:states that
    26. On page 4, the letter-states thatDBNPS identified either DBNPS had not previously identified either leakage leakage ot cracking from or cracking adequately answer the question from its nozzles. Did this adequately presented was question presented was if DB had experienced either previously experienced had previously leakage from or cracking either leakage VHP nozzles?
    cracking in VHP nozzles? difference in meaning. No difference inspection plan flow chart.
    27. On page 18 there is a CRDM inspection chart Does this flow chart performing CRDM inspections at DBNS?
    approach to performing represent the historical approach DBNS? Part of it is. This was to address the Oconee aspects of it. We Oconee aspects didn't view We didn't ourselves as view ourselves susceptible nozzles, so we always were on flange side of flow chart. When we came susceptible for nozzles, came with this flow chart, I was under premise we didn't up with didn'.t.have boric acid on the head. Now have boric I don't think I knew about the boric bpric acid until after this letter seeing this chart. reviewing the letter, did you talk to anyone about the obscured
    28. In reviewing obscured nozzles?
    nozzles? obscured at this point. Found out later. Not obscured later. We were focused on circumferential cracking.
    29. Why weren't the obscured noziles nozzles talked about in the letter?
    Our focus was on when we did last time we did good qualified as-found inspection. I am qualified as-found encompassing. We weren't talking about as-not sure our intial view of videos were all encompassing. as-but as-found. So we tasked Andrew with a nozzle by nozzle review. It was when left, buras-found. progressed I became aware of the boric acid. Prior to this letter Andrew this progressed Andrew really never made it clear th
    30. Did you review the October 17 2735)?
    1 7 th letter to the NRC (Serial 2735)? yes
    1. On page 1, 331. I, the wording again states "did identify." Does this mean there could "did not identify." could have been leakage, but it just wasn't identified?
    What we were were saying was we realized at this point we had to go back to 1996 for a good thorough inspection. We kilew knew we had portions obscured, but by looking at subsequent subsequent inspections we did not identify cracks in the areas we could inspect. Clearly we couldn't couldn't take credit for those areas areaS obscured. This gave as a a warm feeling because because all the other 2S4-00599 284-00599 NRC026-2894 NRC026-2894 plants that that had leakage had it evenly dispersed. So if we had them they would have been centralized which was centralized unlikely. was*unJikely. (if Yes, did that concern
    32. (if concern you?)
    you?) No. text then gives a qualifier of "in the CRDM nozzle to head areas
    33. The text areas that could be be inspected. What did this mean to you?
    We couldn't inspect everything. This is why went back to may 1996. couldn 'tinspect
    34. It says video-tapes video-tapes had be re-reviewed. Do you participate in this review?
    Andrew. Andrew. "35.
    35. On page 2 it states that whole head visual inspections inspections of the RPV head was performed performed in IORFO, lORFO, IIRFO, 1IRFO, and arid 12 RFO. What What does whole head inspection inspection mean to you?
    Put the probe everywhere everywhere and looked at everything everything instead of a sampling. Could you see see head everywhere? From what I know now, headeverywhere? no. now,oo.
    36. Was a whole head inspection inspection performed
    ~rformed in each of those outages? Guess what we were saying we were inspecting above and below the flanges. Whether Whether we could get good data off the inspections is not what we are saying.
    37. (If no, what objection did you raise?)
    raise?) Not asked
    38. On page 3 it states that the boric acid deposits were "clearly "clearly attributable" attributable" to leaking motor tube flanges. Did you agree with that statement?
    Streaks and runs coming down on motor tubes that would Streaks not have happened would .not happened because of of nozzle. Hindsight you can have two leaks in same area and have one obscured by the the other one.
    39. (If yes, what evidence was there that made it "clearly attributable?)
    attributable?) Not asked yes, did you ever discuss in 12RFO . 40. (If yeS, 12RFO the possibility of a leaking leaking nozzle? nozzle? How was thatresolved?) that resolved?) . Not asked asked 2S4-00600 254-00600 NRC026-2895 NRC026-2895
    41. (If no, how did you address your disagreement?)
    41. disagreement?)
    Not asked Notasked
    42. Page 3 also states that the boric acid accumulations accumulations were indicative of CRDM flange leakage. What do deposits from CRDM flange leakage leakage; Jeakage look like?
    You are getting to streaking and the large amount of boric boric acid above the insulation in those same area. Even the boric acid on the insulation insulation was hard and crusted.
    43. On attachment attachment 2, page 2 of 2, it states the entire entire RPV head was inspected. Is that true? (Note page 2 of 5 says 65 of 69 inspected).
    The reason we put that note on there was there was no orientation orientation on the tape, so we couldn't COUldn't make the chart for 1996. Instead we were saying we did do 100% 100% inspection inspection (video-tape) (video-tape) however we could not talk about specific specific nozzles.
    44. The letter references and applies Framatome ANP document 51-5012567-01 51-5012567-01 several times, and it is attached times. attached to the letter. Did you review this document?
    yep yep
    45. Did you provide any infonnation information for this evaluation by Framatome?
    Frarnatome? Really developed developed at Framatome, Framatome, and we don't have the technical abilities they do.
    46. It states that the B&WOG safety evaluation concludes a leak would be detected during a walk-downinspection walk-down inspection of the RPV head area. interpretation, what area In your interpretation, would this walk-down walk-down inspection inspection entail?
    Pretty much what we were doing, going in and looking for leakage. We actually had Framatome do these inspections on several years to comply to this. There is nothing Framatome implied in this that the head has to be cleaned.
    47. On page 7 of 56, the document characterizes characterizes that boric acid from flange leakage would leave leave behind a "snow" "snow" of boric acid crystals. Does this characterize characterize the boric boric acid accumulation accumulation seen on the head?
    In some areas yes. Other areas were hard. We felt that some of our flanges the buildups above the insulation had moisture, so we thought it was occuring at Mode Mode 3 as well, well, causing causing the harder harder deposits.
    48. On page 28 it discusses a human reliability analysis for detecting CRDM nozzle leakages, based on not doing inspections.
    leakages, inspections. Did you read this section? Yes, what this is something something that Ken Byrd was commenting on this. Bob Assena (sp) was was involved from Framatome. involved from Framatome. We We copied copied some some of this this right out into our evaluation. evaluation. 2S4-00601 254-00601 NRC026-2896 NRC026-2896 I think when when we did ours, we did ours, we decided to go with we decided much higher number with a much because Oconee number because Oconee missed theirs. This missed This was was aa probability probability they would would miss miss it. Oconee clearly missed Oconee had clearly missed their cracking their cracking nozzles nozzles before. When asked about before. When growth rates crack growth about crack rates to 165 degrees in a 165 degrees short time, Oconee short said they missed it. So Oconee said So we assumed a probability we assumed missing it probability of I1 for missing on on obscured obscured ones (If yes, with the history of
    49. (If of growing boric the head, did this section boric acid on the concern section concern you? Another you? Another way of with 24 of of asking, with nozzles obscured, how of 69 nozzles how was the 6%
    viable? Or another way, with another way, with your knowledge from 1996, your knowledge was DB in the 111% 1996, was  % range?) range?)
    50. October 3&t 50.October 30th letter: Page Page 3 notes that supplemental inspections that supplemental are required inspections are required for all all obscured nozzles. Was there any thought obscured inspections were the fact these inspections thought that the done for were not done previous outages previous merited shutting down to do it?
    outages merited concern was Our concern wascircumfernetial cracking not axial. This was an outer drive concern, circumfernetial cracking concern, so so we felt we were were okay to wait until spring?
    50. On page II 11 it stated that some deposits were small. How could some boron deposits could we detect these these boric acid on the head?
    with boric In hindsight, yes this would be difficult, but we dido didn't 'thave that mind set. We had dry have .that boric acid from boric the flanges. from :the
    51. There was a question on page 11
    51. 11 relative DB exam in April of 2000 relative to if the DB 2000 used a written procedure?
    written procedure? It wasn't a work procedure. We know that is probably what the NRC wanted wanted to here, but was aa program procedure ours was in activities to be performed. procedure that was specific inactivities
    52. Okay, but was the Boric Acid Corrosion Control Program Program procedure followed in 2000? \ \( \
    '-.I ~ I know now? No. We didn't pull the procedure and documentation Based on what Iknow documentation to -.:i.~ verify this when we we wrote this letter. . ,>I\..
    . \.'
    Ii'. .,' .... ' SU\ J ' 1 I ,
    53. It also states that a head cl~ing performed in 2000 to pp~fora cleaning was performed qualityRPV, for a quality RPV ,.j'~ c...,5 \.}O' bare metal visual inspection in April 2002. How How is this true i 3.5 is /~ '" 1) oJ the head is covered with boric acid? .' -
    r t} i \J Reading this, I must not yet have known the head wasn't cleaned in 12RFO. I must have gained that knowledge even after this letter. th 54 But in the October 17 17 tb letter there are maps of of boric acid still on the head, and you helped develop thatthat letter? Those are as-found maps. I don't think I yet connected the as-left portion. We were conditions. focused on as-found conditions. 2S4-00602 254-00602 NRC026-2897 NRC026-2897
    55. Did you read the attached B&W owners group materials committee safety evaluation evaluation from December 19971 1997?
    Yes
    56. On page A2-3 A2-311 it discusses there basis for determining this was not an unreviewed unreviewed safety question. It takes credit for wastage inspections every refueling outage. We clearly weren't doing that for the entire head, so how could we take credit credit for this?
    The leakage would be detected as unidentified leakage. Don't forget we also had two perceptions perceptions on this as well. First we had a pre-conceived pre-conceived notion that at greater than 600 degrees, boric acid on the head was not a problem, therefore therefore we were invincible. Second, in past cleaning attempts, attempts, the areas we cleaned cleaned had no wastage and therefore there was not a concern, as CRDM cracking should occur randomly randomly across the head. 254-00603 2S4-00603 NRC026-2898 NRC026-2898 U.S. U.S. NRC NRC GEISENi L _r B / -5""- In re DAVID In re DAVID Docket GEI:SENI~:.::.!:.L_Exltti' IP' # 1A-05-052 Docket # 1A-OS-OS2 "". ,p _~'~ Date Marked for ID'+/-,4 2008 (Tr. p...... Date Marked for ID$,. 2008 (Tr. p. G") Date Offered in Ev: 4Ž , 2008 (Tr. p. ) Date Offered in Ev: /z/~. lu/ 2008 (Tr. p. a2 <9 ) Through Witness/Pane1 Through Witness/PanU--1./U~o,-,,;:J:...:._ _ _ __ Action ADiIEDREJECTED _---------. "I WITHDRAWN ~~~REJ@C;~ Date;4~ 2 08p6() wITHDRAWN Date: I 2008 (Tr. p. - ) DOCKETED USNRC September 2009 (11:00am) September9,9,2009 (11 :OOam) OFFICE OF SECRETARY OFFICE OF SECRETARY RULEMAKINGS RULEMAKINGS AND ADJUDICATIONS AND STAFF DOJ006-016989 DOJ006-016989 ADJUDICATIONS STAFF 16989 DOJ006-0 16989 P-,A s --<--  ; -2o7 N Pictures taken in 12RFO of the reactor vessel head flange showing boric acid With flange showing with rust deposits deposits flowing out of the weep holes. U.S. U.S. NRC NRC EW rr Lf),ýU-(' /' ~ A ~ G, DOCKETED In re DAVID GEISEN.J'f' In 1'9 GEIE 5 *,2 ,-IT BMW ~--."
    • DOCKETED USNRC DOOk0t#1A)-50 Oockst # 1A-05-052 1'7) a 82 c;-
    ID'~ p.-~ USNRC oate MaI1ced Date Marked for for I .17- 2008
    2. 008 (r.
    (n'. p - September 9, 2009 (11:00am) September 9, 2009 (11 :OOam) OFFICE OF SECRETARY .' Oate~inEv:~~(Tr.p.~) Date O~f erec in Ev. 200 (Tr.-O-~ OFFICE OF SECRETARY RULEMAKINGS AND RUlEMAKINGS AND Th~~~*~0~/~A~------ Tnough wwarleLI4i) ,/ Acto: ~ REJECTEDs0 Action~ REJECTED ~ ADJUDICATIONS STAFF ADJUDICATIONS STAFF Date: lJfi2. 2006 (Tr~ p. f3Zlfz ) '(~ 11 11 ?AftL/t~T*cj~Q OSd2-nf"\ mngz-nimQccz mr) InneLn1Ia~~~ Pictures taken in 12RFO Pictures 12RFO of the reactor vessel head flange showing showing boric deposits boric acid with rust deposits flowing out of the weep holes. 11 11 nmnnA-n1QAAA f~-~S L~~j'm.ý.ý.u~~.f c~ I:)C-W 1..W . 1y N Tape 96-07, GO CD Time 16:18. View from weep hole #13 #13 with N47 on theleft edge, N27 behind the left edge,N27 behind and to the right of N47, N11 NI 1 behind and to the right of N27, N31 toward the right side of the the frame, and N15 behind behind and to the left of N31. ofN31. These These deposits do not depOSits do not show the crusted boron stalactites on the underside of the insulation boron or stalactites insulation that was typically seen from flange leakage leakage in prior outages. . U.S. NRC Jn re DAVID GEISEN '4ctT Extoibitt# -7 Mý 4 4 A -r-re DOCKETED DOCKETED USNRC USNRC Date Marked for ID Z 2008 (Tr. p. ) Date Offered in Ev: 2008 (Tr.p.St ) .September 9, 2009 September 9, 2009 (11:00am) (11 :OOam) f - Through OFFICE OF OFFICE SECRETARY OF SECRETARY RULEMAKINGS AND RULEMAKINGS AND Action: 7 REJECTED WITHDRAWN ADJUDICATIONS STAFF ADJUDICATIONS STAFF 9. b ) ,2008 (Tr. r /~ Canma View I \ Bk Arid *'1* KEYPLAN REACTOR VESSEL CLOSURE HEAD I
    • ReACTOR VESSEL BOLTING ClOSURE DETAILS FIGUREHEAO
    'v kEY PlAN BOLTrNG OETAIlS fiGURE e-7, DS62-0-r6 nn- ir)nr.-n1,aAAz n().lnnl:Ln1 Q~~~ III ~"u ":. I r. 01 dcl ~ Window,; Mrdu," P1ftY<'f "0 lqrý ýý " -- 4~I r . ' , " l Zl PM Tape 96-07, CD Time 16:18. View from weep hole #13 #13 with N47 on the left edge, N27 behind and to the right of N47, N11 N1 1 behind and to the right of N27, N27, N31 toward the right side of the the frame, and N15 behind behind and to the left of N31 N31.. These deposits do not show the crusted boron or stalactites on the underside underside of the insulation insulation that was typically seen from flange leakage leakage in prior outages. outages . s1J%~-L IA 0" on CPI o-o 'S a-QSS P Ž4tý 4, 4f,
    • Camera View
    ]Bk',AddciDq KEY PLAN REACTORVESSELaOSUiF INEAC
    • Boric: Acid Depccila kEY PLAN REACTOR BOLTINGVESSEl DETAILSFIGR~EAO ClOSURf 1101. TlNG DETAILS FI GURE nr).innA-n1QRA*i
    KJt-£ ~ L- 07 CRDM Nozzle Nozzle. #56 )56 April Apri119. 2001 Oconee 3, Nozzle Nozzle 56. "Spaghetti-like" deposits can be seen behind the leaking nozzle. DOCKETED u.s. NRC U.S. NRC Lf'. 1;]'- / /!' re DAVID GEISEN 2S ~ tT Exhi-it Exhibit ##_~_~_ USNRC USNRC In In ,. _ Z.. September 9, 2009 (11 :0Oam) Docket ## 1A-05-052 Docket 1A-05-052 -, . 5 IO~ 8~ _) i September 9, 2009 (11 :OOam) OFFICE OF SECRETARY Marked for IDkL4 Date Marked 2008 (Tr. 2006 (Tr. p. OFFICE OF SECRET RULEMAKINGS AN~RY . RULEMAKINGS AND ADJUDICATIONS STAFF ADJUDICATIONS STAFF Date Offered'in Offered in Ev. Ev: JjjJi. 2006 (Tr. p.Ak& 2008 p. ) Through Wi ThrouWEh W' . anel44.2A)./ aneI: Iv/e ..... ActiOn: Action: REJECTED wITHDRAWN REJECTED WITHDRAWN Date: -~ Date: 2008 (Tr. p .2008 au) 13 'Týlk A-TE, _.::_ 5,2:C\( D2,8-6r n-l-, no.innA-n1!QAAA CRDM CRLDM Nozzle #56 #56 April 19, 2001 April19, Oconee Oconee 3, Nozzle 56. "Spaghetti-like" deposits can be seen behind the leaking nozzle. 13 nc).innr%-ni QAA u.s. U.S. NRC NRC /'. i\f I" Ci .'V f.v ~ C-.-:2 I D DAVID GEISEN 2 TiA F - In re DAVID In Exhibit #...,;v Ext*ftft- ....__ ( r> r c~KI~U~ Docket .1A-05-052 Docket # .1A-{)5.{)52 Date MarKed Date Io--$,. 20 for IM ~. Maiked for 2008 p. 82~' l (Tr. DateOffdi Date Ev: 11f2-.. Offered'in E(L--/ (W2o008(Tr.p. 2008 (fr. p.!?ZlP : Through Wltne6slPanet:--f-:;.N4!i.L.Pr~ Th~rough Mw ~s/Pae A) /P( _____ Action: ~. R~ebTED WITHDRAWN Action: A'REJECTED WITHDRAWN ~ ~,2008 Dal* (Tr. p. colu P. ,2008 (Tr. ) Holmberg ReVIews Holmberg Reviews DOCKETED DOCKETED USNRC USNRC September September 9, 2009 2009 (0li:00am) (11 :OOam) OFFICE OFFICE OFOF SECRETARY SECRETARY RULEMAKINGS RULEMAKINGS AND AND ADJUDICATIONS ADJUDICATIONS STAFF STAFF
    1) S 0)-
    ~. UIA,ý jr-LkrE;ý! 1M8 Lh-t-g-  !;[!0cr Od-g EECý ý C:2 ý- g DOJ006-016828 DOJ006-0 16828 - (69) (6.9)' CRD.M CRDM (60) Nozzles Nozzles Stud Holes Holes (18) Weep Holes Holes Support Ste-el for Steel I~s.ulatlo h Insulation Reactor Vessei Head rvlap Reactor Vessel Map DOJ006-016829 DOJOD6-0 16829 1996 1996 e6i. 0m 05 00 o No Visual O Acceptable Acceptable Visual o O Unacceptable Visual Unacceptable Visual DOJ006-016830 DOJ006-0 16830 1998 1998 o o Visual O Acceptable Visual o O Acceptable Visual Unacceptable Visual Unacceptable Visual Designated Designated by FENOC as Affected Affected Area from Leaking Flange(s) DOJ006-016831 DOJ006-0 16831 2000 (. , 15 o No Visual \ O Acceptable Visual o 0 Acceptable Visual Unacceptable Unacceptable Visual Visual Designated Designated by FENOe FENOC as Affected Affected Area from Leaking Flange(s) DOJ006-016832 DOJ006-016832 1998 o 0 Vi lIal Acceptable Visual7W Acceptable Visual o O Unacceptable Visual Unacceptable Visual Designated Designated by FENOC FENOC as Affected Affected Area from Leaking Leaking Flange(s) Flange(s) Designate by FENOC Designate FENOC asas Visual Visual Inspection Inspection Satisfactory. Satisfactory. No Video Video Record Record Required. Required. DOJO06-O DOJ006-0 16833 16833 2000 3 Ii II \ CD o Visual O Acceptable Visual o O Acceptable Visual Unacceptable Visual Unacceptable Visual Designated by Designated by FENOC as Affected FENOC as Affected Area from Leaking Flange(s) Flange(s) O Designate by FENOC as Visual Inspection Satisfactory. No Video Record Required. Satisfactory. 00J006-0 16834 DOJ006-016834 ( DOCKETED DOCKETED USNRC USNRC Davis-Besse Davis-Besse Organization Organization Circa-2001 C~rca2001 September 9, 2009 (11:00am) September 9, 2009 (11 :OOam) OFFICE OF SECRETARY OFFICE OF SECRETARY RULEMAKINGS AND RULEMAK/NGS AND ADJUDICATIONS STAFF ADJUDICATIONS STAFF SIte VIce President CampboR (unIil12101) aergendahl (stadlng 12101) T Technk:al SelVlces (Engineering) Support SelVtceS Wait Managemenl Director Director Director Mofflll Worley Messina I Design BasIs Engineering Plant Englneellng Regulatory Alia Irs Oulage Management Work Control Manager Manager Manager Manager Manager Eshelman (unlU 121011 Geisen Aogers (starilng 12101) .. Lockwood Coakley Nelson I 1 I MechanfcallStlUclural Mechanical Systems LIcensIng SupeNlsor Compliance Supesvlsor Project Manager Supervisor SupelVisor MCintyre (unlD 02/01) Wuokko Miller McLaughlil Swim Cunnlngs (starling 02101) I -I I . Design Engineer Syslem Engineer Syslem EngIneer System EngIneer Compnance Engineering Goyal Slemaszko Haley Chlmahusky Cook u.s. NRC U.S. NRC -, fI....1J. .7 In In re re DAVID GEISEN=2t~ "# DAVID GEISEN,5ý'- T r ExhibtExhibIt ........0--=- Docket # IA4-05052 Docket # 1A-05-052 . t? Jo'9~- Date DateMarked Markedfor ID~ forIDL zŽ. 2008 (Tr:p.p. >' bE ~ 2008(Tr. Date 0IIamd inEv: [)aleOfferedin Ev: 17&~ ." CTr. p.~ '" ) ,r. ,,L Th~ WitnesslPanel:'~7fA--H-~---- ActiActiOn: on(ALA,* .AOMfilEiD DQ REJECTED REJECTED WITHDRAWN WITHDRAWN Date:. (~ Date:.4ý (Tr.pp. (9<:,,) 2008 (rr.
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