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| docket = 05000498, 05000499
| docket = 05000498, 05000499
| license number = NPF-076, NPF-080
| license number = NPF-076, NPF-080
| contact person = Howard K L
| contact person = Howard K
| case reference number = NRC-2739
| case reference number = NRC-2739
| document type = Meeting Transcript, Slides and Viewgraphs
| document type = Meeting Transcript, Slides and Viewgraphs
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{{#Wiki_filter:Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Advisory Committee on Reactor Safeguards Plant License Renewal Subcommittee Docket Number: (n/a) Location: Rockville, Maryland Date: Thursday, November 17, 2016 Work Order No.: NRC-2739 Pages 1-1 NEAL R. GROSS AND CO., INC. Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433 NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com  1  1  2  3 DISCLAIMER 4  5  6 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 7 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 8  9  10  The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting. 15  16  This transcript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies. 19  20  21  22 23 1    NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION + + + + + ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS) + + + + + PLANT LICENSE RENEWAL SUBCOMMITTEE + + + + + THURSDAY NOVEMBER 17, 2016 + + + + + ROCKVILLE, MARYLAND + + + + + The Subcommittee met at the Nuclear Regulatory Commission, Two White Flint North, Room T2B1, 11545 Rockville Pike, at 8:30 a.m., Gordon R. Skillman, Chairman, presiding.
{{#Wiki_filter:Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title:       Advisory Committee on Reactor Safeguards Plant License Renewal Subcommittee Docket Number:     (n/a)
2  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  COMMITTEE MEMBERS:  GORDON R. SKILLMAN, Chairman PETER RICCARDELLA, Member-at-Large RONALD G. BALLINGER, Member WALTER L. KIRCHNER, Member DANA A. POWERS, Member JOHN W. STETKAR, Member MATTHEW W. SUNSERI, Member ACRS CONSULTANT: STEPHEN SCHULTZ DESIGNATED FEDERAL OFFICIAL: KENT HOWARD ALSO PRESENT: ARDEN ALDRIDGE, STP NOC MIKE BERG, STP NOC RUSS CIPOLLA, Intertek PHYLLIS CLARK, NRR/DLR YOIRA DIAZ, NMSS/DSFM ROB ENGEN, STP NOC MICHAEL GARNER, STP NOC JIM GAVULA, NRR* DAVE GERBER, SIA RON GIBBS, STP RAFAEL GONZALES, STP NOC ALLEN HISER, NRR/DLR 3  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  WILLIAM HOLSTON, NRR MATTHEW HOMIACK, NRR LOIS JAMES, NRR/DLR RAIHAN KHONDKER, STP NOC BRET LYNCH, WP JANE MARSHALL, NRR TODD MAXEY, STP  JAMES MEDOFF, NRR/DLR MIKE MURRAY, STP NOC CHANCEY PENCE, STP NOC GREG PICK, Region IV DAVE RENCURREL, STP BILL ROGERS, NRR/DLR DAN SICKING, STP NOC RICK STARK, STP NOC DAVID STUHLER, STP NOC MIKE SVETLIK, STP MARK WALES, STP NOC GARY WARNER, WP DAVE WIEGAND, STP NOC JAMES WILLIAMS, STP NOC PRESTON WILLIAMS, STP NOC JAMES C. YOUNGER, STP NOC KEVIN REGIS, STP NOC *Present via telephone 4  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  C-O-N-T-E-N-T-S Call to Order and Opening Remarks..................5 Staff Introduction.................................6 South Texas Project Nuclear Operating..............7 Company (STPNOC) - South Texas Project, Units 1 and 2 (STP) NRC Staff Presentation SER with Open..............80 Items Overview Opportunity for Public Comment...................133 (None) Committee Discussion.............................134 Adjourn 
Location:         Rockville, Maryland Date:             Thursday, November 17, 2016 Work Order No.:   NRC-2739                             Pages 1-188 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433


5  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P R O C E E D I N G S 1  8:29 a.m. 2 CHAIRMAN SKILLMAN:  (presiding)  Ladies 3 and gentlemen, good morning. This meeting will now 4 come to order. 5 I am Gordon Skillman. I am Chairman of 6 the Plant License Renewal Subcommittee. 7 The Subcommittee will review the 8 license renewal application for South Texas Project 9 Units 1 and 2. 10 ACRS members in attendance today are 11 Dana Powers, John Stetkar, Ron Ballinger, Peter 12 Riccardella, Walt Kirchner, and Matt Sunseri. Our 13 ACRS consultant Dr. Stephen Schultz is also in 14 attendance. Kent Howard of the ACRS is the 15 Designated Federal Official for this meeting. 16 This morning we will hear presentations 17 from the Division of License Renewal, Region IV, 18 and South Texas Nuclear Operating Company, the 19 Applicant, regarding this matter. This 20 Subcommittee will gather information, analyze 21 relevant issues and facts, and formulate proposed 22 positions and actions, as appropriate, for 23 deliberation by the full Committee. 24 The rules for participation in today's 25 6  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  meeting have been announced as part of the notice 1 of this meeting published in The Federal Register. 2 We have not received written comments and requests 3 for time to make oral statements from members of 4 the public regarding today's meeting, and the 5 entire meeting will be open to public attendance. 6 There will be a phone bridge line. To 7 preclude interruption of the meeting, the phone 8 will be placed in a listen-in mode during the 9 presentations and Committee discussion. 10 A transcript of this meeting is being 11 kept and will be available, as stated in The 12 Federal Register notice. Therefore, I request that 13 participants in this meeting use the microphones 14 located throughout the meeting room when addressing 15 the Subcommittee. The participants are requested 16 to please identify themselves and speak with 17 sufficient clarity and volume, so that they can be 18 readily heard. 19 I also request that all attendees 20 please silence your personal electronic devices. 21 We will now proceed with the meeting, and I call upon 22 Jane Marshall to begin the presentation. 23 Thank you, Chairman Skillman. 24 As stated, I am Jane Marshall. I'm the 25 7  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Acting Director for the Division of License Renewal 1 in the Office of Nuclear Reactor Regulation. With 2 me here today are members of my management team and 3 several members of my staff. They will introduce 4 themselves as they answer questions today. Also 5 joining us by phone is Greg Pick, who is the Lead 6 Inspector from Region IV. 7 The staff's presentation will be given 8 by Lois James, who is the South Texas Project 9 Safety Project Manager. She will be joined at the 10 table by DLR Senior Technical Advisor Dr. Allen 11 Hiser and Senior Mechanical Engineer Bill Holston, 12 as well as Safety Project Manager Phyllis Clark. 13 At today's ACRS Subcommittee meeting, 14 the staff will present its review and resolution 15 path for the open item for the license renewal of 16 South Texas Project Units 1 and 2. The information 17 we will be presenting was documented in the Final 18 SER. 19 At this time, I would like to turn the 20 presentation over to South Texas Project Nuclear 21 Operating Company and Dave Rencurrel, Senior Vice 22 President for Operations, to introduce his team and 23 commence their presentation. 24 Thank you. 25 8  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. RENCURREL:  Good morning. 1 Yes, as you said, my name is Dave 2 Rencurrel. I am from South Texas, Senior Vice 3 President of Operations. 4 I really would like to take this 5 opportunity to thank the ACRS Subcommittee for our 6 opportunity to present our overview of our license 7 renewal application, and we do look forward to your 8 questions. 9 But, before we get started, I would 10 also like to thank the NRC reviewers for their hard 11 and diligent work in this process and for everybody 12 on the staff, everybody from South Texas, who has 13 also worked very hard in this process. 14 There it is. All right. As you can 15 see, here is an overview of the agenda, which we 16 will be presenting today. I would like to point 17 out that we are setting aside a really special time 18 or focused time to discuss the Safety Evaluation 19 Report open item for aluminum bronze selective 20 leaching. 21 With that, I would like to move into 22 the introductions of the team that we brought 23 today. I will start and, then, we will just move 24 to the left and move down our line. 25 9  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Now my name, as I said, is David 1 Rencurrel. I'm the Senior Vice President of 2 Operations. 3 I began my career over 35 years ago, my 4 nuclear career over 35 years ago in 1981, when I 5 started in the United States Navy as a nuclear 6 officer. In 1988, I joined the South Texas Project 7 and, since then, I have had many different jobs. I 8 got hired in as a young system engineer. I have 9 went through license class, spent time in the 10 control room as a shift technical advisor. I spent 11 time as a work control supervisor, worked in 12 maintenance, system engineering manager, design 13 manager. I was ops manager for a little bit over 14 four years, VP of Engineering and Projects, Site VP 15 for over four years. Now I am in my current role 16 where I am responsible for all projects here 17 onsite. 18 I would like to hand off to Mike 19 Murray. 20 CHAIRMAN SKILLMAN:  Not so fast, Dave. 21 You have a lofty position, huge influence at the 22 site and in the company. What is your vision of 23 the importance of 10 CFR 50 Appendix B? 24 MR. RENCURREL:  I think that is 25 10  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  extremely important. 10 CFR 50 Appendix B is what 1 gives us that consistency and that credibility that 2 we all want. I think that is where that comes from 3 in that regard. 4 CHAIRMAN SKILLMAN:  I asked the 5 question because in the course of time those of us 6 who have been in industry for a long time have 7 watched the devotees of 10 CFR 50 Appendix B fall 8 away. There is always somewhat of a move to cut a 9 corner here or cut a corner there and not recognize 10 how important the 18 points of that regulation are 11 -- 12 MR. RENCURREL:  Yes, sir, I understand. 13 CHAIRMAN SKILLMAN:  -- to the materiel 14 condition of the unit and to the culture of the 15 unit. And so, my question is, how vigilant are you 16 of that?  And what is the shadow that you cast on 17 your organization? 18 MR. RENCURREL:  So, what is -- that is 19 the quality, right? 20 CHAIRMAN SKILLMAN:  Yes, yes. 21 MR. RENCURREL:  That's what I thought. 22 So, here's what we do in regards to independent 23 oversight of their station. Independent oversight, 24 obviously, we have the right dedication and right 25 11  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  resources assigned to that. They act independently 1 in that they report up to a company officer. All 2 right. We ensure that they have a very 3 professional relationship with the staff, that they 4 are honored by the staff and listened to by the 5 staff, that they have the capability to measure our 6 not just compliance, but also our drive towards 7 excellence. 8 We also have monthly reports, for 9 example, that come up to the executives where they 10 get to talk about oversight or the vision of 11 oversight of performance of how the station 12 performs. We have a very prescriptive program of 13 the elevation/escalation, where elevation is where 14 they bring up an issue to site leadership, plant 15 manager and such, where they can talk about 16 prolonged gaps or gaps that aren't being closed. 17 And then, it subsequently goes to escalate, if that 18 doesn't get solved, where, depending upon the 19 level, it can actually go all the way up to an 20 officer or a vice president to be accountably 21 resolved. 22 And then, you roll into the whole 23 concept of corrective actions and the idea of being 24 able to -- it is not just a corrective action 25 12  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  program; it is more of a program to ensure that you 1 have proper problem identification and real 2 resolutions that solve not just the symptom of the 3 problem, but the actual do the hard work of 4 understanding the cause of the problem. And I 5 believe that is extremely important, something we 6 measure very closely for. 7 I believe that in any organization you 8 have to have governance, proper governance, which 9 is the rules, the regulations, the traditions, the 10 meetings that we all interact with, so that you can 11 have proper oversight, so the oversight can come up 12 and measure how your governance is actually 13 operating and working. I believe in all those 14 concepts. 15 I also know that the folks I work with, 16 my boss, our Chief Executive Officer Dennis Koehl, 17 our Chief Nuclear Officer Tim Powell, also believe 18 very strongly in the Appendix B, in the 50.B 19 program. They believe very strongly in the 20 corrective action program and independent 21 oversight. 22 And having said all those words, in 23 conclusion, I would say plants/stations that 24 perform well, stations that perform with 25 13  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  excellence, stations that, quite frankly, meet the 1 business plan needs of the owners and the 2 shareholders have that healthy respect. Plants 3 that don't, they don't meet those; they don't have 4 that performance and they don't meet those business 5 goals. So, it all ties together. 6 CHAIRMAN SKILLMAN:  Yes, I thank you 7 for your explanation. My real question was about 8 your office and your shadow on the QA program. 9 MR. RENCURREL:  Yes, my office and my 10 shadow on the QA program is I know the QA Manager 11 personally and I actually mentor him through his 12 roles. I help him interact with folks on the 13 station. In my role right now, they don't report 14 to me. In my previous roles, they actually 15 reported to me. So, it was much more hands-on in 16 how things are working. 17 My shadow is that I believe very, very 18 strongly in the independence of QA, its 19 independence and conclusion, its independence in 20 their messaging, but we work closely with them in 21 ensuring that that message is presented in a way 22 that can be readily understood and accepted by the 23 staff. 24 I spend time; I go down and talk to the 25 14  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  folks -- they actually sit down the hall from me. 1 I go down and visit with them a lot, pretty much 2 know just about everybody there. And at times I 3 have both defended them and I both chastised them. 4 So, I think I have a very good shadow. 5 CHAIRMAN SKILLMAN:  Dave, thank you. 6 Please proceed. 7 MR. RENCURREL:  Okay. Thank you. 8 MR. MURRAY:  My name is Michael Murray. 9 I'm the Regulatory Affairs Manager at South Texas 10 Project. 11 I have been in the industry for 41 12 years, started as an I&C tech at the Brunswick 13 Plant. I have had 31 years at South Texas Project. 14 I was there for startup of both units. So, I have 15 a long history at South Texas Project. 16 Various management positions. I was 17 I&C Manager, Systems Engineering Manager; spent 18 some time working on the Units 3 and 4 licensing 19 project as I&C, the Design Manager there. And I 20 have met a few of these folks here during that 21 process. And then, currently, I'm Reg Affairs 22 Manager at South Texas Project. 23 MR. GIBBS:  Good morning. I'm Ron 24 Gibbs. My current position is the Manager, 25 15  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Operations, Shift Operations. I'm the Senior 1 License at the South Texas Project now. 2 I've got over 30 years of nuclear 3 experience. Started out as a unit supervisor, STA, 4 at Comanche Peak. Came to the South Texas Project 5 in 1993. Got my Senior Reactor Operator License 6 there in 1995 and worked my way on shift. I 7 started as unit sup, STA, again, up through shift 8 manager. Came off shift in 2013 into an ops 9 manager role and took over as the Senior License 10 January of this year. 11 MR. ALDRIDGE:  Good morning. My name 12 is Arden Aldridge. 13 I have been in the nuclear service for 14 about 38 years. I started in the nuclear submarine 15 service, consultation with some consulting groups, 16 and then, with two utilities. 17 For the last 22 years, I have been at 18 South Texas Project fulfilling various engineering 19 roles and functions. In the last 10, I have been 20 focused on license renewal applications, helping 21 our peer plants prepare three application from 22 preparation to approval. In the last five years, 23 it has been focused as the project lead and the 24 Implementation Coordinator for South Texas. 25 16  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  CHAIRMAN SKILLMAN:  Thank you. 1 MR. BERG:  Good morning. I'm Michael 2 Berg. I'm the Engineering Manager of Design and 3 Programs. 4 I have got 38 years in the nuclear 5 industry, 34 years at South Texas Project. I was 6 one of the original engineering supervisors that 7 took over design control from the architect 8 engineer. 9 I have had various manager roles over 10 the past 25 years and I was the manager over the 11 STP initial license renewal application submitted. 12 CHAIRMAN SKILLMAN:  Gentlemen, thank 13 you. Please proceed. 14 MR. RENCURREL:  Okay. What I would 15 like to do now is give a brief station ownership, 16 overview of station ownership and operation. 17 South Texas Project Nuclear Operating 18 Company is the licensed holder for the station. 19 The station is actually owned by three different 20 companies, Energy Texas, which is an investment-21 owned utility; the City Public Services, San 22 Antonio, which is owned by the municipality San 23 Antonio, Texas, and Austin Energy, which is owned 24 by the City of Austin. So, we are owned by one 25 17  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  investor and two municipalities. To put our 1 generation in context, over 25 percent of the 2 carbon-free electric generation in the State of 3 Texas is produced at South Texas. 4 CHAIRMAN SKILLMAN:  And you get no 5 credit for that whatsoever. 6 (Laughter.) 7 MR. RENCURREL:  Yes, sir. 8 To go over our plant history and some 9 major investments, we received our initial license 10 in 1987 and 1988, respectively, for Unit 1 and Unit 11 2. Since that time, we have made major capital 12 investments. We have replaced our steam 13 generators, all four in each unit. We have 14 replaced our low-pressure turbines. We have 15 replaced both reactor vessel heads in both units. 16 We have also rewound our main generator stators and 17 have replaced the rotors, the main generator 18 rotors, in both units. 19 Looking forward, we have main 20 transformers done on one unit, but we are replacing 21 the main transformers in the other unit in the next 22 outage, and we are working through the replacement 23 of our feedwater heaters that show that there is an 24 ongoing investment in the major improvements of the 25 18  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  plant. Also, as you can see there, the non-welded 1 stress improvement process is being put in place, 2 and that is going to go down in 2017 and 2019. 3 The way our governance works is that we 4 have a business plan. And the way that the owners 5 commit to the long-term safe operation of the 6 station is via that business plan. This business 7 plan is approved annually for the next five years' 8 spend. 9 And so, in a sense, what goes on is the 10 money is allocated or set aside for the next five 11 years' worth of capital investments. However, our 12 plant investment plan itself goes out 20 years 13 where we have levelized out and put in all the 14 capital improvements and all the capital necessary 15 to move forward. 16 If you look at our plant investment 17 plan, you will see that our owners, we have 18 identified and our owners have committed to the 19 capital monies necessary to implement the aging 20 management plan. And so, there is that commitment, 21 not just in words, but in treasure, in regards to 22 implementing the extended license and safely moving 23 into the extended period of operation. 24 With that, I would like to turn it over 25 19  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  to Ron Gibbs, our ops manager. 1 MR. GIBBS:  Good. Thank you, Dave. 2 This morning I will be giving a brief 3 description of the South Texas Project site and 4 station design. 5 South Texas Project is located about 90 6 miles southwest of Houston. You see the star here 7 on the Texas map gives a representation of our 8 location. Here in the center of this aerial map 9 you can see is the South Texas Project site. It is 10 about 12,000 acres. As you can see also in this 11 aerial view, it is largely a rural area, a lot of 12 farming in our community. We are Matagorda County 13 and about 15 miles inland from the Gulf of Mexico. 14 The large body of water here in the 15 center is our main cooling reservoir. Makeup from 16 our main cooling reservoir is the Colorado River 17 you can see here -- that is the main source -- and, 18 also, rainwater. 19 Our station, here is our main cooling 20 reservoir again on the top of the picture. Our 21 essential cooling water pond here is on the bottom. 22 That is commonly called service water in the 23 industry, and this is our ultimate heat sink. 24 Makeup to this is from well water as a primary 25 20  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  means of makeup and rainwater. 1 Just to the right here you can see our 2 switchyard. We have nine 345-KV lines coming into 3 and out of the switchyard. And the units here are 4 in the center of the pictures. We have two 5 Westinghouse four-loop PWRs, Pressurized Water 6 Reactors. Our thermal rate of power is 3853 7 megawatts thermal with a design output of 1250 8 megawatts electric. 9 CHAIRMAN SKILLMAN:  Ron, the essential 10 service water pond there fed from wells, does that 11 mean that that is freshwater -- 12 MR. GIBBS:  Yes. 13 CHAIRMAN SKILLMAN:  -- compared with 14 brackish water? 15 MR. GIBBS:  That's correct. 16 CHAIRMAN SKILLMAN:  Okay. I did not 17 appreciate that when I was reading the application 18 for the safety evaluation. Thank you. 19 MR. GIBBS:  Okay. 20 CHAIRMAN SKILLMAN:  Okay. 21 MR. GIBBS:  Operators are licensed on 22 both units. So, we can operate either unit, and we 23 utilize common operating procedures. 24 Both containment structures are post-25 21  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  tensioned concrete cylinders with steel liner 1 plates, hemispherical tops, and flat bottoms. 2 Each unit has three independent safety 3 trains, including piping, valves, pumps, and diesel 4 generators, our emergency supply for emergency 5 power. And each unit has four safety-related 6 auxiliary feedwater trains, three electric pumps, 7 and one steam-driven pump. 8 And next, I will turn it over to Arden. 9 CHAIRMAN SKILLMAN:  Let me ask you to 10 back up a slide, please. Your aerial, the Mad 11 Island, that is the wildlife management area? 12 MR. GIBBS:  That's correct. 13 CHAIRMAN SKILLMAN:  And so, most of the 14 population down there are alligators and critters?  15 Is that what you've got down there? 16 MR. GIBBS:  That's correct, a lot of 17 alligators, a lot of critters. 18 CHAIRMAN SKILLMAN:  That's 5-6,000 19 acres, 10,000 acres, something like that? 20 MR. GIBBS:  It itself, yes. 21 CHAIRMAN SKILLMAN:  Yes. Thank you. 22 Okay. Okay. 23 MR. GIBBS:  Next, I will turn it over 24 to Arden to walk us through our license renewal. 25 22  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  CHAIRMAN SKILLMAN:  Right. 1 MR. ALDRIDGE:  As I mentioned, my name 2 is Arden Aldridge. I was the license renewal 3 project lead, and I would like to just go through a 4 little chronology of where we have been in 5 preparation of this application. 6 In October of 2010, we submitted our 7 license renewal application against the 8 requirements of GALL Rev. 1. We, then, went 9 through the inspections and reviews. In 2013, we 10 received a Safety Evaluation Report with four open 11 items, and at the same time we put the safety 12 review on hold because of the uncertainty of the 13 waste confidence role on future license decisions. 14 Well, during the year that we put it on 15 hold we continued to work on the project. We 16 updated to GALL Rev. 2, the requirements of GALL 17 Rev. 2. We incorporated lessons learned from 18 License Renewal Safety Evaluation Reports and 19 performed annual updates. We also resolved three 20 of the open items going forward. 21 Here we are in 2016. We completed all 22 the reviews. The Safety Evaluation Report with 23 just one open item was issued on October of 2016, 24 and that open item is the aluminum bronze that we 25 23  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  will talk to later in the application. 1 On the next slide, just a description 2 of the programs, of how they have rolled out. We 3 had 41 aging management programs, of which 33 of 4 them were existing programs and eight new ones. On 5 that slide you will see in GALL consistency we said 6 we were 90-percent consistent with the standard 7 notes alpha through echo of GALL Rev. 1. However, 8 with the enhancements of GALL Rev. 2, that 9 consistency with GALL Rev. 2 is 95 percent against 10 the standard notes. As just a reminder, on the 11 bottom there, reinforcement, we did get reviewed 12 against standard review plan for GALL Rev. 2 and 13 those requirements. 14 On the next page, STP's program's 15 consistency with the GALL is we were consistent 16 with GALL Rev. -- the consistency table is against 17 GALL Rev. 1, but it is just an accounting 18 perspective. We had 21 aging management programs 19 that are consistent with GALL. We have 16 aging 20 management programs that are consistent with 21 exceptions, and we have four plant-specific aging 22 management programs. 23 Approximately 10 of the 16 aging 24 management programs with exceptions are due to the 25 24  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  addition of the requirements of GALL Rev. 2 and the 1 lessons learned that we incorporated. The 2 remaining exceptions would be alternate methods of 3 managing the aging effects specifically for the 4 programs that we developed. 5 As far as the license renewal 6 commitments, those are being tracked and we have 46 7 of them. This slide is just to represent the 8 different categories of commitments that we have 9 established. And up to this date, you can see 10 several of them are closed. Eight of the 46 11 commitments have been closed or have been 12 completed. That leaves us with 38 remaining to 13 implement prior to the period of extended 14 operation. 15 We have an implementation plan, a 16 schedule, and the budget that Dave mentioned to 17 complete these remaining open commitments prior to 18 their scheduled due dates in preparation for 19 entering the period of extended operation in 2027 20 and 2028. 21 CHAIRMAN SKILLMAN:  Before you change 22 that slide, would you give us a little tutorial on 23 your inspections?  The Unit 1 refueling water 24 storage tank welds you had some leaking, outside 25 25  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  tanks? 1 MR. ALDRIDGE:  Yes. 2 CHAIRMAN SKILLMAN:  You repaired those. 3 MR. ALDRIDGE:  Yes. 4 CHAIRMAN SKILLMAN:  You brought them 5 into conformance with their codes. You are on an 6 inspection frequency, that is, an outage inspection 7 frequency. I don't know if that is 24 months or 18 8 months. But it seems as though you found yourself 9 in a predicament with a leaking RWST. And so, you 10 have amended your procedures for inspection. 11 Please tell us more about this. 12 MR. ALDRIDGE:  Thank you, Mr. Chairman. 13 We did have a plant-specific condition 14 on the refueling water storage tank on Unit 1, and 15 it was identified through external leakage. And 16 so, we did an internal inspection and repair. That 17 internal inspection and repair, then, had a root 18 cause performed on that, and we identified that the 19 cause was due to external leakage from water that 20 had entered the room from seals and there was no 21 berm around the tank. So, it had attacked the 22 exterior of the tank. 23 So, the concern for the aging effect of 24 internal stress corrosion cracking was not a 25 26  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  concern. When we did our aging management program, 1 we were committed to performing a confirmatory that 2 the repairs, confirmed that they were effective and 3 that there is no aging degradation going on on the 4 internal side of the tank. In addition, we, then, 5 every refueling outage, we look at the exterior of 6 the tank for external indications of cracking or 7 leakage. 8 CHAIRMAN SKILLMAN:  What is your fuel 9 cycle length, please?  Fuel cycle length? 10 MR. ALDRIDGE:  Yes, 18 months. 11 CHAIRMAN SKILLMAN:  You are on 18 12 months?  Okay. Thank you. 13 MR. ALDRIDGE:  Okay. 14 MEMBER SUNSERI:  I have a question 15 while you are on this page as well. So, we have 16 been following an issue with degraded baffle bolts 17 in the industry. And in South Texas your core is 18 larger. So, I suspect you are unique from the rest 19 of the fleet within maybe the number of baffle 20 bolts and how they are put together. 21 So, my question for you is, are you an  22 upflow or downflow plant?  What has your experience 23 with the baffle bolts been?  And what are you doing 24 to track the issue from an aging management 25 27  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  perspective? 1 MR. BERG:  I will go ahead and answer 2 that question. Certainly, we have been involved 3 with the EPRI Materials Reliability Project and 4 compliance with  MRPG-27. We are an upflow design, 5 and our baffle bolts are 3/16 material. So, when 6 you look at the susceptibility, we are in the 7 lowest susceptibility associated with that. 8 We have done some inspections where we 9 just visually looked at the baffle bolts. We have 10 not found any degradation of the baffle bolts. 11 MEMBER SUNSERI:  Do you do the UT 12 inspections or just the visual? 13 MR. BERG:  Just visual inspection. We 14 will do the UT inspections, per MRPG-27, prior to 15 the period -- 16 MEMBER SUNSERI:  So, you have it right?  17 Yes, okay. I've got it. Thank you. 18 MEMBER KIRCHNER:  Dick, may I ask a 19 question? 20 CHAIRMAN SKILLMAN:  Please. 21 MEMBER KIRCHNER:  From this long list, 22 what are the long poles in the tent?  Not all these 23 are equal in terms of effort and commitment and 24 difficulty. Could you just highlight those that 25 28  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  are -- we know we have one more coming, but -- 1 MR. ALDRIDGE:  Right. 2 MEMBER KIRCHNER:  -- excepting that 3 one, on this long list and the AMPs program, which 4 are taking more of your time or attention or 5 resources? 6 MR. ALDRIDGE:  Yes, sir. When you 7 really  look at, with the enhancements that we have 8 in place and have committed to, program 9 enhancements and program implementation both go 10 hand-in-hand. And we have been in the development 11 phase for all these years. So, those, just because 12 of the numbers, 26 of them remain open for 13 enhancements with nine implementation. The 14 implementation programs, not only are we developing 15 the base procedures and all the requirements that 16 we committed to in the aging management program, 17 but most of those require in-plant inspections, 18 whether they are one-time inspections or the 19 beginning of a periodic. 20 And then, from an analysis perspective, 21 we have already performed the screening on the 22 NUREG-6260 central locations. We just have to go 23 through and upgrade the program to continue to 24 monitor those new locations. So, that would be the 25 29  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  main areas. 1 MEMBER KIRCHNER:  Thank you. 2 CHAIRMAN SKILLMAN:  Please proceed. 3 MR. ALDRIDGE:  Thank you. 4 Okay. And so, really, in conclusion, 5 the license renewal commitments are included in our 6 SAR Supplement, in our FSAR Supplement, Appendix 7 Alpha of the license renewal application. It is 8 managed by our Appendix B Program, and it is the 9 STP condition reporting process and the license 10 commitment management and administrative processes. 11 There are two processes that control those, and 12 they are being tracked for completion under those 13 programs. 14 All right. At this time, I would like 15 to transfer to Mike Berg. 16 MR. BERG:  Okay. I would like to talk 17 about our Safety Evaluation Report open item. This 18 is associated with selective leaching of our 19 aluminum bronze essential cooling water system. 20 The open item focuses on wells 21 themselves. But, prior to getting into the 22 specifics of the open item, I would just like to 23 give a brief overview of the selective leaching 24 process. So, from a high-level background for 25 30  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  selective leaching of our low-pressure essential 1 cooling water system, which is commonly referred to 2 in the industry as service water system, as Ron 3 stated earlier, the material is aluminum bronze, 4 which is a copper aluminum alloy. Selective 5 leaching is a corrosion process where the aluminum 6 in the transformed phase can selectively leach out 7 when you have aluminum that is greater than 8 8 percent and exposed to wetted surfaces. Selective 9 leaching of aluminum leaves micro-voids along the 10 grain boundaries and, when progressed through a 11 wall, leakage/seepage will become visible on the 12 outside surface of the material. 13 So now, I would like to refer to the 14 slide here. So, what we are looking at here, this 15 is a section of pipe. We have a weld and, then, we 16 have got a weld-neck flange. So, the piping itself 17 -- there we go -- the piping itself is made out of 18 wrought material. It has less than 8-percent 19 aluminum, and we have not seen, nor is it 20 vulnerable to, selective leaching. 21 I want to talk about the casting -- 22 MEMBER KIRCHNER:  Just for perspective 23 -- 24 MR. BERG:  Yes. 25 31  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER KIRCHNER:  -- what is the 1 diameter of the pipe there and what is the schedule 2 and such?  What are we looking at in the picture?  3 I can see nuts on the side. So, it looks like it 4 is now 4-inch or -- 5 MR. BERG:  I'm thinking it is 4- or 6-6 inch diameter pipe that we are looking at here. 7 So, let's talk about the casting 8 materials themselves. They are susceptible to the 9 alloying. We first saw the alloying or cast 10 materials on our small-bore piping back in 1988. 11 All of those were replaced. 12 We do programmatically do a walkdown 13 every six months. What we are looking for is 14 copper oxide on the exterior of the pipe, like you 15 see right here. So, the green pipe, and we look 16 for a buildup of residual. 17 If I sectioned this pipe, I would look 18 at the inside of the pipe and I would see some 19 aluminum hydroxide corrosion products where the 20 aluminum has selectively leached inside the pipe 21 and, then, on the outside, again, I see the copper 22 oxide deposits that have occurred. 23 Just over a period of time, on these 24 large-bore castings we were somewhere between five 25 32  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  or ten first initial startup. Over the years, we 1 currently run somewhere between zero or two of 2 these per year, is what we see. 3 CHAIRMAN SKILLMAN:  Is this phenomenon 4 limited to just the cast material? 5 MR. BERG:  So, we are going to talk a 6 little bit later on the welds, which is the open 7 item. But where we have seen it predominantly is 8 in the cast materials. 9 CHAIRMAN SKILLMAN:  Okay. 10 MEMBER SUNSERI:  And it progresses from 11 the exterior of the pipe inward or? 12 MR. BERG:  No, from the interior of the 13 pipe, selective leaching, and then, it takes the 14 aluminum, so the aluminum hydroxide on the inside 15 of the pipe. Once the aluminum comes through to 16 the outside of the wall, then you will see weepage. 17 So, we don't see a lot of leakage. It is really 18 weepage. Or, even in a lot of cases, when we will 19 do the walkdown, we will see the spots and you 20 won't even see any moisture at all. Yes, it is 21 kind of a sponge. 22 CHAIRMAN SKILLMAN:  Do you want to be 23 on the record? 24 MEMBER KIRCHNER:  Have you cut any of 25 33  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  these castings out and done an evaluation? 1 MR. BERG:  Oh, absolutely. We have 2 done a lot of evaluations. 3 MEMBER KIRCHNER:  Do you have any 4 pictures with you to show the phenomenon as it 5 progresses? 6 MR. BERG:  Really, we don't have 7 pictures with us. As part of our license renewal 8 application for our casting materials, we are going 9 to replace the casting materials with materials 10 that are not subject to the selective leaching 11 phenomena. So, our commitment is we are going to 12 change all of these castings out prior to the 13 period of extended operation. 14 MEMBER KIRCHNER:  Well, it begs the 15 question, then, to what? 16 MR. BERG:  We will go with, if we stay 17 with aluminum bronze material, then we will have 18 material probably a wrought-type material that has 19 less than 8-percent aluminum. 20 MEMBER BALLINGER:  Yes, wrought 21 material, it is a two-phase thing where they get 22 something called the gamma-2 phase which is rich in 23 aluminum. It is like dezincification. 24 MR. BERG:  Right. 25 34  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER BALLINGER:  So, you get 1 electrochemical cell buildup and you selectively 2 leach out the aluminum. It is like 3 dezincification. And so, you end up with sort of 4 like a porous structure. 5 MR. BERG:  Right. 6 MEMBER BALLINGER:  But, if you whack it 7 with a hammer, you will find out that it is not 8 so -- that the porosity is a problem. And so, 9 wrought materials are usually not susceptible or if 10 you heat-treated casting, so that you get rid of 11 the solidification microstructure that goes on. 12 And the rates are anywhere from .05 to .5 mLs per 13 year sometimes, or even higher, depending on the 14 structure. 15 MEMBER KIRCHNER:  With the current 16 material? 17 MEMBER BALLINGER:  With the cast 18 material. 19 MEMBER KIRCHNER:  With the casting? 20 MEMBER BALLINGER:  With the cast 21 material. 22 MEMBER KIRCHNER:  Right. And what is 23 the differential with the wrought? 24 MEMBER BALLINGER:  You get rid of this 25 35  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  gamma phase. And so, you don't have the same kind 1 of problem at all for de-aluminization. So, 2 wrought materials are generally not susceptible to 3 the material. And if you are less than -- you said 4 8 or 9 percent -- 5 MR. BERG:  Yes, 8 percent. 6 MEMBER BALLINGER:  I think it is on the 7 order of 8 percent, where if you look at the phase 8 diagram, you can't get that phase. 9 MEMBER KIRCHNER:  Yes. Thank you. 10 MR. BERG:  Okay. So, the focus on the 11 open item is associated with the welds themselves. 12 So, let's move on to that particular area. 13 So, with the welds, we have seen -- 14 first off, we haven't seen any since 1994, but what 15 we see is, it actually is a cracking phenomena that 16 occurs. Okay?  So, from finding the particular 17 condition when it does occur, and it hasn't been 18 since 1994, just operators doing a walkdown, so you 19 will see a light mist spray or maybe some water on 20 the floor. So, the operators would identify that 21 as part of the walkdown and would put in a 22 corrective action program and handle it through 23 that methodology. 24 So, we have seen 10 welds with 25 36  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  cracking. The cracking has some de-alloying 1 associated with that. We have had two of them that 2 occurred, two of the cracks that have occurred in 3 thermal welds. The rest of the cracks, though, 4 have occurred with welds with backing rings, which 5 is the focus of a lot of our work in addressing the 6 open item. 7 MEMBER KIRCHNER:  What is the typical 8 corrective action, then, once you discover this? 9 MR. BERG:  We would cut it out and 10 replace it. When we talk about the open item, 11 there are 10 issues associated with that. When I 12 go through that, I will talk about the specifics we 13 do on how do we do the inspection, acceptance 14 criteria, and then, we will talk about corrective 15 actions. 16 MEMBER RICCARDELLA:  So, is a 17 significant percentage of this piping underground? 18 MR. BERG:  Not percentage-wise, and I 19 don't know what the percentage of the welds because 20 most of the underground piping is of large sections 21 in nature, but we do have some of the welds 22 certainly that are underground with backing rings. 23 MEMBER SUNSERI:  So, maybe you are 24 going to talk about this when you get to the 25 37  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  inspections, but is there an NDE technique for this 1 or? 2 MR. BERG:  This really gets into our 3 corrective action. But we have been working over 4 the last few years with an NDE technique. So, 5 obviously, if it is a cracking-type phenomena that 6 is occurring, ultrasonic NDE will detect that 7 condition. 8 MEMBER SUNSERI:  And are you doing it 9 any? 10 MR. BERG:  So, we would do it if we 11 found a condition where we were seeing cracks at 12 the surface type of thing. Then, we would follow 13 the code requirements and we would have to go 14 characterize that, and we would go do an NDE 15 inspection. 16 MEMBER SUNSERI:  Okay. Because I 17 thought I heard you say you see the misting and all 18 that stuff. So, I mean, it is a safety-related 19 system. I guess that puts you in a tech-spec 20 action statement. 21 MR. BERG:  That is correct. So, we 22 would do an operability -- 23 MEMBER SUNSERI:  The active mode 24 versus -- 25 38  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. BERG:  It would be an operability 1 determination associated with that, which Ron would 2 request, and we would go do the characterizations 3 in accordance with code. 4 And we are going to talk a little bit 5 later on, the proactive piece is prior to the 6 period of extended operation. I will just get to 7 it briefly now. It is that we will do an 8 inspection of -- I'm going to get this wrong -- 20 9 percent with 25 welds with backing rings and 10 without backing rings prior to the period of 11 extended operation. We will actually go in and 12 come apart and look at it. 13 We have looked at others as well. I 14 don't want to let you believe we haven't done any 15 evaluation. We have done evaluations, 16 metallurgical exams of the things where we have 17 found cracking in the past and other ones where we 18 have the castings, you know, we look at the welds 19 as well as part of that. 20 MEMBER SUNSERI:  Okay. 21 CHAIRMAN SKILLMAN:  Mike, let me ask 22 this:  from the inspection report, the 71002 23 inspection report, the comment is, "The team noted 24 the experience regarding the loss of material 25 39  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  caused by selective leaching in aluminum bronze 1 components in the essential service water system is 2 an ongoing aging mechanism."  That is from the 3 71002 inspection. 4 MR. BERG:  Yes. 5 CHAIRMAN SKILLMAN:  The text appears to 6 point only to the essential service water system. 7 Is th is phenomenon anywhere else in any other 8 systems? 9 MR. BERG:  The answer to that is no 10 because we only use aluminum bronze in our 11 essential -- 12 CHAIRMAN SKILLMAN:  Let me ask you one 13 more. Your cathodic protection system is not in 14 scope. At least it isn't in the document that I 15 read. What connection have you made between this 16 phenomenon and the inoperability of your cathodic 17 protection system for what appears to be 10 to 15 18 years? 19 MR. BERG:  Do you want to answer from 20 the TLA perspective? 21 MR. ALDRIDGE:  Yes. Yes, sir. Let me 22 answer from the perspective of the cathodic 23 protection. The piping at South Texas is 24 cathodically protected as part of the buried piping 25 40  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  aging management program, and aluminum bronze is 1 one of the systems that is protected by the 2 cathodic protection. 3 CHAIRMAN SKILLMAN:  Would it be more 4 accurate to say is now protected by, but was not 5 for a long time period?  That is a yes or no. 6 MR. ALDRIDGE:  No. It is always had 7 various degrees of protection. We have enhanced 8 the degree of protection since the regional 9 inspection, and now we are meeting better 10 availability and -- 11 MEMBER STETKAR:  Let's get specific. 12 What  has the historic availability over the life 13 of the plant of your cathodic protection system 14 been? 15 MR. ALDRIDGE:  Thank you, sir. We have 16 the subject matter expert present, and he can give 17 you the numbers. 18 CHAIRMAN SKILLMAN:  Okay. Let's do 19 that, please. 20 MR. KHONDKER:  My name is -- can you 21 hear me? 22 CHAIRMAN SKILLMAN:  Yes. 23 MR. KHONDKER:  Okay. So, my name is 24 Raihan Khondker. I am the Cathodic Protection 25 41  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  System Engineer at South Texas. 1 And the question being asked, what is 2 our historical availability of the cathodic 3 protection system?  Over the past since the 4 inception of the plant, we have maintained the 5 cathodic protection system in the entire protected 6 area. So, we always adhere to the 7 needs/requirements back then, which used to be -- 8 now it is called SBO 0169; back then it was RP. We 9 adhered to that since the beginning and we did 10 maintain the full availability as possible. 11 But, of course, over the course of the 12 years when we saw deteriorations, rectifiers out of 13 service, in some years we did see the rectifiers' 14 ability to go down. But, based on our corrective 15 action program, we have fixed those and we have 16 made sure that availability was always at the 17 higher point more than 80 percent, as we always 18 adhere to. 19 MEMBER STETKAR:  I'm not sure that I 20 got a straight answer to my question. Over the 21 life of the plant, I would like to know what the 22 historic percentage availability has been if I take 23 the time up divided by the total time the plant has 24 been operating as a percentage. You have told me 25 42  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  that you had corrective action programs and things 1 were out of service for a long time. But what is 2 the average historical availability over the life 3 of the plant? 4 MR. KHONDKER:  For that, I will have to 5 go through my trending database. 6 MEMBER STETKAR:  Great. Thank you. 7 MR. KHONDKER:  And then, I have to find 8 it out for you. 9 MEMBER STETKAR:  Thanks. 10 MR. KHONDKER:  But, since I took over, 11 it has been over 80 percent. 12 MEMBER STETKAR:  Okay. Thanks. 13 MEMBER RICCARDELLA:  Does cathodic 14 protection have any influence on this selective 15 leaching process? 16 MR. BERG:  The answer is, no, it does 17 not, but our very piping is coated and it is 18 protected from that standpoint. 19 MR. MURRAY:  Yes, I was going to make 20 sure we got back to that as well, to break that 21 tie. That was, for example, the picture that you 22 saw was not an underground cathodic-protected area. 23 MEMBER BALLINGER:  It is very difficult 24 to use cathodic protection for this problem, yes, 25 43  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  because it is a very local system. 1 MR. BERG:  Okay. Moving on, wrought 2 material is not susceptible, as we have already 3 discussed. The susceptible component population, 4 castings will be replaced. Just a feel for that, 5 400 to 450 castings in the plant. We will replace 6 those prior to the period of extended operation. 7 And again, our focus on our open item 8 is associated with welds or weld repairs with 9 susceptible weld filler material. It will be 10 managed. That includes piping butt-welds and, 11 also, weld preparers on extruded tees. 12 MEMBER STETKAR:  Is that 400 to 450 per 13 unit or per the site? 14 MR. BERG:  Per the site. 15 MEMBER STETKAR:  Thanks. 16 MEMBER BALLINGER:  But castings are 17 susceptible, but you haven't had a problem with the 18 castings, except I read in the SER you had a lot of 19 valve bodies and all kinds of things that were. 20 So, you have had that problem? 21 MR. BERG:  Yes. 22 MEMBER BALLINGER:  But, with the 23 welding, how are you going to get around the 24 problem with welding?  Because you still have the 25 44  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  solidification issue. Are you going to post-weld 1 heat-treat?  What are you going to do to get rid of 2 that problem? 3 MR. BERG:  Okay. So, we will talk 4 about that when we go through the open issue, but 5 it is really with the one-time inspections and with 6 the periodic inspection, particularly the welds 7 with the backing rings. 8 What we do to address that is we would 9 use a weld filler material with nickel in it. 10 MEMBER BALLINGER:  Yes, okay. 11 MR. BERG:  We have found that would 12 prevent having the transformed region. 13 MEMBER BALLINGER:  It is like a Class 14 IV. Okay. 15 MR. BERG:  Okay. So, to get into the 16 open item, our open item, the STP has responded to 17 NRC staff's questions associated with selective 18 leach in aluminum bronze. We did send a response 19 in on September 28th. 20 Just to talk a little, we do have a 21 comprehensive aging management program that 22 addresses selective leaching. That program 23 includes inspections of walkdowns, replacements 24 prior to the period of extended operation. Then, I 25 45  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  am going to talk specifically associated with the 1 welds. It includes one-time volumetric exams, 2 periodic volumetric examination, defines acceptance 3 criteria, and has additional testing elements in 4 it. 5 The specific open item is related to 6 welds, and the Safety Evaluation Report does 7 contain 10 specific issues, which I will discuss 8 further on the following three slides. 9 DR. SCHULTZ:  Mike, I've got a general 10 question related to the recent history for the 11 program. Of course, the overall discussion goes 12 back many years. 13 But, in this year, you put together a 14 fully-revised, well, I will call it a fully-revised 15 program because there were many issues associated 16 with Rev. 1 of the program. And now, this Rev. 2 17 program was submitted to the staff in June of this 18 year. 19 And my question is general, in that, 20 once that was submitted, then there were many 21 questions from the staff related to the new and 22 revised program. So, my general question is, why 23 did that happen?  You had a lot of experience with 24 the program moving forward. You had the 25 46  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  opportunity or made the choice to put in a fully-1 developed to address a number of concerns that the 2 staff had had over the years really. And yet, 3 there were a number of issues that were not, if you 4 will, fully addressed in the new program where you 5 had the opportunity to really set yourself up for 6 full success. And yet, there has been a number of 7 issues in many different areas that the staff found 8 needed additional attention. So, my question is 9 that:  why did that happen?  Can you give me some 10 perspective on that or give us some perspective on 11 that? 12 MR. BERG:  So, there are several phases 13 that I think we have gone through here. First, our 14 first focus was on the casting-type material. I 15 said before we have got about 400 to 450 of those. 16 I believe it is about 56 of them, of the large 17 border castings that we have found that the 18 alloying on, again, as we talked about earlier, 19 with a little bit of copper oxide on the outside 20 surface so far. 21 Our real focus was on the casting-type 22 area. We did a lot of research, testing, did bin 23 testing and strength tied to the de-alloying of our 24 casting materials. Lots of correspondence and 25 47  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  interaction took place between us and the Nuclear 1 Regulatory Commission, and we just ended up in the 2 point of all of that to go to that reasonable 3 assurance to the level that was expected for that; 4 that the easiest answer to that was just to go 5 ahead and replace the castings. And we were doing 6 selective replacements just to do testing anyway. 7 So, that was a change in the program. 8 And then, the next phase came in 9 associated with the welds themselves. Okay?  10 Again, that assurance that, from a welding 11 standpoint, that we would not expect to see any 12 cracks in the future or, even more important, that 13 we don't see anything that would impact the 14 structural integrity of our essential cooling water 15 system. 16 We think we have had that, but there 17 were a series of questions that we had to go 18 through to answer and to come up with some 19 additional research or evaluation of the welding 20 itself just to demonstrate that. 21 DR. SCHULTZ:  So, as you revamped the 22 program, you really went broader in terms of those 23 specific areas that you determined you needed to 24 address?  So, the scope of the program grew 25 48  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  dramatically -- 1 MR. BERG:  Correct. 2 DR. SCHULTZ:  -- based on lessons 3 learned?  And you, then, look at these additional 4 items as a reasonable level of issue that needed to 5 be resolved, given that you have revamped a major 6 part of the overall program? 7 MR. BERG:  That is correct. 8 DR. SCHULTZ:  Thank you. 9 MR. BERG:  Okay. Let's get into the 10 specific 10 issues for our particular open item. 11 So, the first one -- and I am going to do this at a 12 high level -- we added information to bound 13 extruding piping tee repairs. We have about 17 14 tees, extruded tees. Extruded tees are not 15 susceptible to selective leaching, but they do have 16 weld repairs on them. So, part of this is that we 17 will evaluate those repairs. We are just going to 18 make a conservative assumption that that repair is 19 cracked, okay, and then, look at it from that 20 standpoint of structural integrity of that tee. If 21 we cannot demonstrate structural integrity under 22 that condition, we will replace that tee prior to 23 the period of extended operation. 24 No. 2 is clarify the parameters 25 49  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  monitored to address. First is loss of material 1 due to selective leaching, which is monitored 2 through our system walkdowns and destructive 3 examinations. Cracking associated with selective 4 leaching is monitored through volumetric 5 examination of destructive evaluation. And the 6 third area is our root passes phase distribution is 7 verified to be discontinuous phase during our 8 destructive inspections. 9 Item No. 3, clarify the sample size for 10 volumetric inspections. As I said earlier, we will 11 do a one-time inspection on 20 percent with a 12 maximum of 25 welds with and also another sample 13 without backing rings prior to the period of 14 extended operation. And then, we will do periodic 15 examination every 10 years on 20 percent with a 16 maximum of 25 welds with backing rings, just to 17 validate from an aging management standpoint that 18 there is not something that we missed in there. 19 Four, clarify the thresh -- 20 MEMBER RICCARDELLA:  Excuse me. Is 21 that different weld, a different 25 percent for the 22 initial inspection versus the subsequent, the 23 periodic? 24 MR. BERG:  An answer would be yes to 25 50  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  that because, when we do the destructive 1 examination, we will -- 2 MEMBER RICCARDELLA:  Oh, it is a 3 destructive? 4 MR. BERG:  It is a destructive -- 5 MEMBER RICCARDELLA:  I'm sorry, I 6 thought it was -- 7 MR. BERG:  Yes. We do the volumetric, 8 but to look at the phase distribution, it is going 9 to end up being destructive. 10 MEMBER RICCARDELLA:  Okay. And you 11 said there is only about 100 of these welds out 12 there? 13 MR. BERG:  There is actually about 3300 14 welds in the plant. 15 MEMBER RICCARDELLA:  So, you said 20 16 percent was 25 welds. I don't understand. 17 MR. BERG:  Well, the criteria we use is 18 20 percent. A standard in the GALL would be 20 19 percent or 25. So, we are meeting the GALL 2 20 requirements on our sample size. 21 So, we have got about 3300 welds total. 22 About a third of those, or about 1100 of them, have 23 backing rings. 24 Sir, did you get your question 25 51  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  answered? 1 MEMBER RICCARDELLA:  I thought I heard 2 you say a one-time inspection of 20 percent which 3 is about 25 welds. And I don't understand how that 4 fits with 3300 welds total. 5 MEMBER STETKAR:  The criteria, the GALL 6 criteria says 20 percent or a maximum of 25. 7 MEMBER RICCARDELLA:  Oh, oh, oh, oh. 8 Okay. Yes. 9 MR. BERG:  So, I am staying with the 10 GALL requirements, but, in reality, it is 25. 11 MEMBER RICCARDELLA:  Okay. All right. 12 All right. 13 MEMBER BALLINGER:  Is that a rational 14 choice? 15 (Laughter.) 16 I mean, I can understand sticking with 17 the letter of the law, okay, but you have a known 18 issue which you think you are going to have solved, 19 which you might have. And so, to just arbitrarily 20 say we're just going to do 25 and get it over with 21 and move on just doesn't seem to me -- I mean, is 22 there a way, is there some kind of rapid expansion 23 that would occur if you see an issue that is also 24 different from the GALL requirements?  You know, 25 52  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  this is a unique set of cases, I think. 1 MR. BERG:  So, that does get into the 2 next  item here. Okay?  So, let me try to answer 3 your question a little bit more basic to start 4 with. 5 So, again, this condition, we have not 6 seen any crack in the welding since 1994. We have 7 done some research and testing that we believe that 8 we understand why that is the case. We do believe 9 it is a preexisting flaw that seems to be there. 10 So, you expect to see with a preexisting flaw 11 sometime early in life you can see the propagation 12 to the surface. So, we think we fully understand 13 why we haven't seen anything since 1994. We think 14 the 25 sample size is adequate to do confirmation 15 on what we have cut open. We have also cut open 16 some other samples of other removed castings and 17 looked at those as part of coming up with our 18 criteria. So, the 25 is to meet the GALL 19 requirements, but we do believe that that is 20 perfectly acceptable, that condition. 21 If we do find one that doesn't meet the 22 criteria, we would go back to the Generic Letter 23 90-05 criteria. And for every one that we would 24 find that doesn't meet our predictions, we would 25 53  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  increase that sample size by five until we had no 1 welds that had issues on them. So, we will follow 2 the Generic Letter -- 3 MEMBER BALLINGER:  By five or a factor 4 of five? 5 MR. BERG:  By five. 6 MEMBER BALLINGER:  By five. 7 MEMBER RICCARDELLA:  How are the 25 8 samples selected? 9 MR. BERG:  Okay. So, that is No. 5 on 10 the bottom of the page, and those will be randomly 11 selected from the total population of above-ground 12 welds, considering construction and size 13 distributions. We will use ASME Code criteria to 14 do that. 15 MEMBER BALLINGER:  Okay. Randomly 16 selection, with this kind of phenomenon, can't you 17 get a little bit less random?  Because when you do 18 welding and stuff like that, you can record heat 19 input and all those kinds of things. So, is there 20 another set of criteria which you can overlay on 21 this that says we'll do this random 22 characterization, but this particular weld and this 23 particular weld, in our judgment, may be a little 24 bit more susceptible?  Can you modify the 25 54  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  randomness a little bit? 1 MR. BERG:  I don't know. 2 MEMBER BALLINGER:  Modified randomness, 3 I'm not sure that is a good -- 4 MR. BERG:  Yes. I mean -- 5 DR. SCHULTZ:  But the question is, 6 should you modify the GALL process? 7 MR. BERG:  Yes, I'm not sure what 8 criteria that we could actually use to be able to 9 do any more. We use the standard welding process 10 for all the pipe. Again, you are looking focused 11 mainly on those pipes with backing rings to go 12 after. But, because it is a standard process that 13 we used, I am sure that we would see anything where 14 we could say this particular welder or this 15 particular heat, you know, is any different. 16 We have gone back and looked at the 17 heats. We have looked at where we stand with 18 respect to the amount of aluminum in our weld 19 filler material. I'll tell you, it is pretty 20 standard percent aluminum that goes through that 21 whole thing. 22 So, I am really not aware of any 23 criteria that we can use to try to -- 24 MEMBER BALLINGER:  But nickel aluminum 25 55  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  bronze weld material is going to be better, much 1 better. 2 MR. BERG:  Absolutely. 3 MEMBER BALLINGER:  But right at the 4 interface between the weld and the heat-affected 5 zone there is going to be a wrought material which 6 is not going to be wrought anymore. 7 MR. BERG:  Yes. 8 MEMBER BALLINGER:  It is going to be at 9 the melting point and, then, it is going to be 10 requenched. And so, I am wondering whether or not 11 the welds will be fine, but right, you know, 12 adjacent to the weld where that thermal transient 13 has happened, you don't get gamma phase in the 14 piping itself and now get yourself in an issue 15 there. 16 MR. BERG:  So, again, you start off 17 with less than 8 percent. So, if you look at the 18 phase diagram for the wrought material, you know, 19 being less than 8 percent, you would not expect to 20 go through a transformed region. 21 MEMBER BALLINGER:  I agree. 22 MR. BERG:  And -- 23 MEMBER BALLINGER:  But, again, you are 24 going to melt some of that material. 25 56  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. BERG:  Right. 1 MEMBER BALLINGER:  In the 2 solidification process there is a chance that you 3 will get a region during the solidification process 4 where you go where you are above 8 percent. 5 MR. BERG:  Okay. 6 MEMBER BALLINGER:  Okay. I am just 7 curious as to -- 8 MR. BERG:  For two pieces of that, I 9 have got an expert here I can call upon. But the 10 other piece is, when we look at the root pass of 11 the weld, one of the differences there, it is very 12 rapidly-cooled. 13 MEMBER BALLINGER:  Yes. 14 MR. BERG:  So, we have actually looked 15 at that and -- 16 MEMBER BALLINGER:  Okay. 17 MR. BERG:  -- it looks like it is like 18 a maximum of 36 seconds to cool it down. So, there 19 is really not adequate time, even if you end up 20 with greater than 8 percent type of aluminum 21 content, to go to the transformed region. And if 22 you do get some in there, you are usually, instead 23 of at the gamma-2 phase, you are at the beta phase. 24 MEMBER BALLINGER:  Okay. I'm just 25 57  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  saying usually -- 1 MR. BERG:  That is 25, which is less 2 acceptable and it is discontinuous in nature. 3 MEMBER BALLINGER:  Okay. You know the 4 old saying:  the great tragedy of science is the 5 slaying of a beautiful hypothesis by a ugly fact. 6 MR. BERG:  Yes. 7 MEMBER RICCARDELLA:  But as your OE 8 indicated any problems at all with the wrought 9 side, with the piping side of the weld? 10 MEMBER BALLINGER:  The wrought material 11 is never a problem. 12 MEMBER RICCARDELLA:  No, but it is the 13 weld. You are talking about the heat effect has on 14 the weld, but -- 15 MEMBER BALLINGER:  Yes, right where it 16 has been solidified. 17 MEMBER RICCARDELLA:  Yes. 18 MR. BERG:  The answer is no to that 19 question. And going one step further, when we have 20 seen an issue, it has been due to a weld defect 21 that was already there as part of the original 22 construction. 23 MEMBER RICCARDELLA:  And it was in the 24 weld, not in the heat-affected zone? 25 58  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. BERG:  In the weld, correct. 1 MEMBER RICCARDELLA:  Okay. 2 MEMBER BALLINGER:  But don't you have 3 two issues, cracking and de-aluminization? 4 MR. BERG:  Yes. 5 MEMBER BALLINGER:  So, I'm talking 6 about the de-aluminization part, not the cracking 7 part. 8 MR. BERG:  So, the de -- I will try to 9 get there. 10 MEMBER BALLINGER:  It is too many 11 syllables. 12 (Laughter.) 13 MR. BERG:  Yes. So, the de-alloying 14 going on in the casting pipe region, we are taking 15 care of that. And we have seen a lot of that 16 without any, you know, preexisting -- 17 MEMBER BALLINGER:  Okay. 18 MR. BERG:  -- flaws or anything else. 19 When we get into the welds, we do see 20 some de-alloying in the weld surfaces, but 21 everything is telling us it is due to that 22 preexisting flaw. Probably just created an 23 environment because of the type crack and the 24 aqueous condition in there, it has created an 25 59  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  environment that did allow anything in the 1 transformed region to show that de-alloying 2 occurred, maybe weakened the material a little bit, 3 and then, allowed cracking and, then, de-alloying 4 and cracking as it propagates through. We don't 5 really know that for a fact, but what we do know is 6 all of our OE tells us there had to be a 7 preexisting flaw there for this condition to occur. 8 MEMBER RICCARDELLA:  Just to be clear, 9 if we go to that slide 17, the picture, you have 10 never had the type of problem that you have circled 11 there on the wrought piping side of a weld? 12 MR. BERG:  That is correct. 13 MEMBER RICCARDELLA:  Thank you. 14 CHAIRMAN SKILLMAN:  I would like to 15 move on. I want to make it clear that in your 16 prior discussion you communicated that, when you do 17 have evidence, you file a condition report because 18 of the way your tech specs are written. You do an 19 operability determination, and that operability 20 determination directs the action of the site staff? 21 MR. BERG:  That is correct. 22 CHAIRMAN SKILLMAN:  And with that, I 23 believe we -- 24 MEMBER STETKAR:  Hold on. 25 60  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  CHAIRMAN SKILLMAN:  Go ahead, John. 1 MEMBER STETKAR:  We have got all kinds 2 of time here this morning. We don't have to rush 3 through this. 4 CHAIRMAN SKILLMAN:  No, no. 5 MEMBER STETKAR:  Ron, I'm not a 6 materials guy. So, you questioned first the kind 7 of random sampling notion. This is for my own 8 education. 9 In many other of these programs that we 10 have seen, not this particular one, throughout the 11 course of license renewal, where you do have a 12 large population to select from, people establish 13 what they call a risk-informed sampling program. 14 And I don't want to get into the nuances of risk, 15 but they look at places where they would be more 16 likely to find a problem, whether that is a fatigue 17 issue or whether it is cracking of small-bore 18 piping welds, or whatever, and then, sample from 19 those locations. 20 So, I'm asking you, given what we have 21 heard here, is there a more, I'll call it risk-22 informed approach that could be used, rather than 23 just randomly selecting 25 out of 3300, in your 24 opinion? 25 61  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER BALLINGER:  See, I am not a risk 1 guy. So, I hesitate to use the word "risk," but I 2 will use it anyway. 3 That is what I was trying to get at. 4 Basically, modifying the random sample business, 5 knowing that under certain conditions the 6 possibility is that you will get a more susceptible 7 area, so that is exactly what I am suggesting. 8 MEMBER STETKAR:  But, I mean, you know, 9 based on your own experience, is there something 10 that you could think of that would sort of narrow 11 down the field a bit? 12 MEMBER BALLINGER:  I would take a look 13 at the welding procedures, and you already have, 14 and decide, depending on pipe size and heat input 15 and things like that, whether or not there is a 16 possibility that you get the second phase and, 17 then, focus your randomness, if you will, on some 18 of those areas, until you discover that, yes or no, 19 we don't have an issue. And this occurs over a 20 very long period of time, though. 21 MR. BERG:  Correct. 22 MEMBER BALLINGER:  So, it is not like 23 you are going to have some kind of catastrophic 24 failure all the time. 25 62  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. BERG:  Correct. 1 MEMBER BALLINGER:  But you are right, 2 that is the way to do it. 3 MEMBER STETKAR:  Okay. Thanks. 4 MEMBER BALLINGER:  Thanks. 5 MEMBER RICCARDELLA:  I'm not familiar 6 with this type of piping, but, from what I know 7 about code class piping, 25 welds out of 3300 is a 8 minuscule sample. I mean, in code class piping we 9 do typically 25 percent of the welds, and if you 10 find anything in that 25 percent, you are in doing 11 another 25 percent, and if you find anything in 12 that second 25 percent, you do 100 percent. 13 MEMBER STETKAR:  But, again, that is 14 more of a question for the staff -- 15 MEMBER RICCARDELLA:  Yes, yes. 16 MEMBER STETKAR:  -- because they wrote 17 the guidance and they are following the guidance. 18 MEMBER RICCARDELLA:  Right. 19 Understood, yes. 20 MR. BERG:  So, I would like to go ahead 21 and move on to slide 21. 22 CHAIRMAN SKILLMAN:  Yes, please 23 proceed, yes. 24 MR. BERG:  Okay. Item No. 6, we did 25 63  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  determine that there was no impact of the external 1 coatings regarding detecting buried piping leaks at 2 the surface. 3 Seven, we have identified a method to 4 monitor our trend results. 5 I would like to focus a little bit more 6 on Item No. 8, define the acceptance criteria for 7 the weld defects. For visual exams, the acceptance 8 criteria is no detectable leakage. For volumetric 9 examination, it would be no detected twiner 10 indication that is subsurface-connected unless the 11 depth of the indication is contained within the 80 12 percent of the weld root pass. And for destructive 13 examinations, no selective leaching penetrating 80 14 percent of the root pass region, and any found 15 selective leaching is non-propagating. So, it is 16 surrounded by a non-continuous resistant phase 17 distribution. 18 And then, the microstructure of the 19 weld root region will exhibit a non-continuous 20 phase distribution, which is consistent with all of 21 our metallurgical evaluation or metallurgical 22 reports that we have done so far. So, we see a 23 non-continuous phase distribution. So, if you had 24 a little localized de-alloying, it is not going to 25 64  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  have any depth associated with that, being a non-1 continuous. 2 Item No. 9, identify the threshold for 3 increased inspections when adverse inspection 4 results are detected. We talked about that a 5 little bit earlier. That is tied back to Generic 6 Letter 90-05. 7 And the last item is to identify the 8 corrective actions to address all potential 9 inspection results. We will remove any leaking 10 welds and destructively exam to determine the 11 extent of the cracks, the extent of the selective 12 leaching, and the microstructure phase 13 distribution, perform five additional volumetric 14 exams, and perform a structural integrity 15 evaluation to confirm the load-carrying capacity. 16 Move on to the next slide. So, this 17 brings us into one remaining open issue associated 18 with the corrective actions. This remaining issue 19 concerns how to address the extended condition in 20 the unlikely condition that structural integrity 21 evaluation does not support the load-carrying 22 capability or capacity. 23 A method and acceptance criteria to 24 bound the extended condition is being defined. We 25 65  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  have had some initial communications with the NRC 1 staff, and we do feel comfortable that we can 2 address that concern, and it does support a pathway 3 forward and timely response and resolution. 4 DR. SCHULTZ:  Mike -- 5 MR. BERG:  Yes? 6 DR. SCHULTZ:  -- just before you get to 7 the conclusion, as you presented it, the addressed 8 issues, you have presented your response to the 9 staff and you feel you have agreement with the 10 staff that, in fact, your responses have been 11 accepted?  And it is only Item No. 10 that has not 12 been fully resolved?  You have provided a response, 13 but, then, the staff had additional questions 14 related to that? 15 MR. BERG:  Yes, an additional question 16 is what we are working with the staff on to 17 address. 18 DR. SCHULTZ:  Okay. 19 MR. BERG:  And again, we do feel that 20 we have a pathway to timely resolution of that -- 21 DR. SCHULTZ:  On Item No. 10? 22 MR. BERG:  -- item, yes. 23 MR. MURRAY:  Yes, it could be 24 characterized as initial conversations on that -- 25 66  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  DR. SCHULTZ:  Okay. 1 MR. MURRAY:  -- with the understanding 2 of the strategy. 3 DR. SCHULTZ:  Thank you. 4 MEMBER KIRCHNER:  I should have asked 5 this earlier. How many linear feet of pipe 6 comprises this system with the aluminum bronze and 7 how much of it is buried underground?  Just an 8 estimate. I'm not holding you to exact numbers. 9 Where I am getting at is most of your visual at 10 least inspections will be -- 11 CHAIRMAN SKILLMAN:  Well, buried 12 underground versus buried where else? 13 (Laughter.) 14 MEMBER KIRCHNER:  Well, you know, 15 inaccessible. 16 CHAIRMAN SKILLMAN:  Oh, okay. Just 17 making sure. 18 MEMBER KIRCHNER:  Sure. 19 MR. BERG:  I would say I am really 20 giving you kind of an estimate, just based on where 21 our essential cooling water intake structure is to 22 our Class 1E structures -- you can choose a little 23 bit further away -- so, I would say about 3,000 24 foot underground would be my estimate associated 25 67  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  with that. 1 MEMBER KIRCHNER:  And that, the 2 component of piping that is underground, that is 3 primarily welded. The flanges that you have had 4 problems with are at the actual above-ground 5 equipment? 6 MR. BERG:  Yes. So, I will make it 7 real clear. There are no castings or cast material 8 underground. 9 MEMBER KIRCHNER:  Okay. Thank you. 10 Thank you. 11 MEMBER RICCARDELLA:  But, then, above 12 ground -- there's 3,000 feet below underground -- 13 then, what is the remainder of the system, 14 approximate?  I'm sorry. Just ballpark, what is 15 the remainder. If you have 3300 welds, I imagine 16 it is a lot of feet. 17 MR. BERG:  Yes, there's several 18 thousand feet. We have 30-inch pipe; we have 4-19 inch pipe, 10-inch pipe through the plant. I'm 20 thinking in the several thousands, 13,000-ish. 21 Kevin or Rick? 22 MR. STARK:  Good afternoon. Rick 23 Stark, the Pipe Program Engineer at South Texas. 24 Buried underground piping, between the 25 68  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  two units, supply and return, is just over 24,000 1 feet. 2 MEMBER RICCARDELLA:  Buried?  Buried? 3 MR. BERG:  And that is essential 4 cooling water piping? 5 MR. STARK:  That is correct. That is 6 all essential cooling water piping. There is 6-7 inch, 10-inch, and 30-inch. 8 MR. BERG:  I was off by a factor of 9 eight. 10 Thanks, Rick. Thank you. 11 MEMBER SUNSERI:  Hey, Mike, I hate to 12 keep picking on this, but this acceptance criteria 13 for the weld defects, I am confused on it. When 14 you go out and do your 25 inspection, you are going 15 to look at these welds and you are going to apply 16 this criteria? 17 MR. BERG:  Right. 18 MEMBER SUNSERI:  Is that correct?  So, 19 you are going to look at it to see if it is not 20 leaking?  You are going to do a volumetric 21 examination to see if there is anything inside of 22 it?  And then, you are going to cut it out to do a 23 metallurgy examination? 24 MR. BERG:  A metallurgy examination. 25 69  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER SUNSERI:  So, essentially, you 1 are replacing 25 every inspection period then, 2 right? 3 MR. BERG:  That is correct. 4 MEMBER SUNSERI:  Okay. Thank you. 5 MR. BERG:  Okay. So, in conclusion,  6 following the resolution of that remaining issue 7 related to corrective actions, the selective 8 leaching of Aluminum Bronze Aging Management 9 Program, effectively, we will manage the aging of 10 the essential cooling water cast components and 11 welds during the period of extended operation. 12 MEMBER BALLINGER:  Can I get one thing?  13 I'm still fuzzy. You have got several miles, 14 kilometers, of buried piping. You are going to 15 take 25 welds, presumably not buried? 16 MR. BERG:  That is correct. 17 MEMBER BALLINGER:  Okay. And the 18 reason you don't have to take any of the welds from 19 the buried piping is because there is no cast 20 material buried? 21 MR. BERG:  Not really. Because if it 22 is a cast material, we will replace the castings 23 prior to the period of extended operation. 24 MEMBER BALLINGER:  Okay. So, you would 25 70  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  replace the castings? 1 MR. BERG:  And when we replace that 2 weld, we will use the nickel-based material. So, 3 it won't be vulnerable to it. 4 MEMBER BALLINGER:  So, of the 5 underground piping, that will fall into a category 6 where it has either been replaced, the casting has 7 been replaced, or it is wrought material and, 8 therefore, there is no selective leaching issue for 9 the underground piping?  Is that what I'm hearing? 10 MR. BERG:  For the underground?  So, 11 the underground piping is only wrought material 12 already. That is what exists now. So, we will use 13 -- so, from a stress standpoint, the above-ground 14 welds are higher-stress conditions; they are more 15 vulnerable -- so, we will use our operating 16 experience from the above-ground welds for any 17 decisions associated with expansion of scope. And 18 this really ties back in the corrective action, 19 depending on what we see. 20 Again, we think all of our research 21 shows us that we have a boundedness condition and 22 we don't expect to see anything really for the rest 23 of the life of the plant, as we haven't since 1994. 24 Our aging management program will demonstrate that. 25 71  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER BALLINGER:  Thank you. 1 MR. BERG:  Okay. I would now like to 2 turn it over to Dave Rencurrel for closing remarks. 3 CHAIRMAN SKILLMAN:  Before we get 4 there, one of the reasons I was trying to move 5 along is I have got a couple of comments 6 independent from aluminum bronze, and perhaps my 7 colleagues have comments as well. So, may I please 8 go after those right now?  I'm good for your 9 closing comments, but I would like to have this 10 opportunity with the STP staff in front to ask some 11 questions. 12 I'm in your license renewal 13 application. I'm on page 84.  "Cathodic protection 14 is not in scope."  Why?  It is on the record in 15 your document. 16 MR. ALDRIDGE:  Arden Aldridge. 17 Cathodic protection as far as in the 18 scope, let me have Mr. Warner -- 19 CHAIRMAN SKILLMAN:  Please do. 20 MR. ALDRIDGE:  -- who can provide some 21 clarification. 22 CHAIRMAN SKILLMAN:  Okay. 23 MR. WARNER:  Yes, my name is Gary 24 Warner. I'm the Senior Project Manager for License 25 72  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Renewal. 1 Cathodic protection is not in the scope 2 of license renewal because it is not one of those 3 systems that performs an intended function for 4 license renewal. It is a support system that is 5 used to allow you to protect your buried piping. 6 But, in the absence of cathodic protection, you are 7 required to inspect a lot more buried piping than 8 you would if you have adequate cathodic protection. 9 So, based on the other plants in the 10 country plus the way the rule is written, cathodic 11 protection does not perform a license-renewal-12 intended function. 13 CHAIRMAN SKILLMAN:  Thank you for that 14 explanation. 15 I want to reinforce John Stetkar's 16 question about the time availability of cathodic 17 protection because in the Inspection Report the 18 Inspection Report very clearly states that there 19 was a 10-year period that there was no cathodic 20 protection. So, I would like to get the answer to 21 John's question as soon as you can get it to us. 22 MR. ALDRIDGE:  Yes, sir. 23 CHAIRMAN SKILLMAN:  Another question -- 24 MR. MURRAY:  Just for clarity, we owe 25 73  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  you a followup on the operating experience of the 1 cathodic protection system? 2 CHAIRMAN SKILLMAN:  That's correct, as 3 a percentage of time, yes. 4 On your license renewal application, 5 page 112, the statement is -- it is actually 6 2.3-27, but it is on PDF page 112 -- "The essential 7 cooling pond is included with the evaluation of the 8 essential cooling water structures in Section 9 2.4.9."  Please tell us about the actions that you 10 have taken to confirm that the pond is good for 11 your projected PEO. 12 MR. ALDRIDGE:  Arden Aldridge. 13 Yes, the pond is part of our aging 14 management program, the structured monitoring 15 program, and I have a subject matter expert here 16 who can give you some additional details on the 17 inspections that we have performed. 18 CHAIRMAN SKILLMAN:  Please do. 19 MR. ALDRIDGE:  Okay. Mark Wales. 20 MR. WALES:  My name is Mark Wales. I 21 am a civil structural engineer at STP. 22 The pond, it is an underground pond. 23 That is the first thing you need to understand. 24 And it is surrounded by a berm which keeps debris 25 74  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  out of the pond. But, as far as maintenance of the 1 pond, there's not really any maintenance that is 2 required. We do periodically inspect it and use 3 biocides to prevent things from growing in it and 4 in the concrete, and we inspect it as part of the 5 structures monitoring program periodically. But, 6 other than that, there is no specific maintenance. 7 CHAIRMAN SKILLMAN:  Now you stated it 8 is underground. Is it really a surface pond or an 9 underground pond? 10 MR. WALES:  Below grade, that would be 11 a better word for it. The surface water is 2 feet 12 below the ground level. 13 CHAIRMAN SKILLMAN:  Okay. 14 MR. ALDRIDGE:  And I can add a little 15 clarification, too. It is not only with the 16 Structures Monitoring Aging Management Program, but 17 the pond is specifically managed under the Water 18 Control Structure's Aging Management Program that 19 has the different inspections that are performed 20 for silting and volume validation and conditions. 21 So, it is managed there from that perspective. 22 CHAIRMAN SKILLMAN:  Okay. Thank you. 23 Let me bring your attention to page 9-24 12 in your license renewal application. This is 25 75  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  under TLAAs. The subject is your studs, nuts, 1 flanges. But, in this particular section, you are 2 silent on inserts. And the table that you show 3 shows inserts with cumulative usage factor greater 4 than one. So, do you have someone here who can 5 explain the relationship between studs, nuts, 6 flanges, and inserts?  I understand the CUF for the 7 studs, nuts, and flanges, but I do not understand 8 CUF greater than one for inserts. 9 MR. LYNCH:  My name is Bret Lynch. I 10 worked on the time-limiting aging analyses. 11 For standard practice, when we were 12 developing the South Texas application, we took a 13 40-year CUF, Cumulative Usage Factor, and 14 multiplied it by 1.5 to get an estimate of what the 15 CUF would be. On that criteria, we decided either 16 the current CUF was projected to the end of the 17 period of extended operation, which was one of the 18 disposition criterias. If it was over one in this 19 case, we would have to justify managing the usage 20 factor to ensure that the 40-year one would be good 21 for 60 years. So, we were keeping the same number, 22 the design transients, from 40 years for 60 years. 23 CHAIRMAN SKILLMAN:  Okay. Now hold 24 that thought. That suggests in this case, and in 25 76  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  other texts in your application, your TLAA depends 1 upon your cycle-counting program. 2 MR. LYNCH:  That is correct. 3 CHAIRMAN SKILLMAN:  Okay. What is the 4 pedigree of that cycle-counting program and how 5 does the plant manage that program?  What is the 6 pedigree and how do you manage it? 7 MR. LYNCH:  Well, we did perform a 8 baseline to get the current number of transients 9 currently. And then, it is an ongoing program at 10 the plant. I do not own that program. 11 MR. BERG:  So, I will just add to it. 12 Really, it is procedurally-controlled under our 10 13 CFR Appendix B Program. Okay?  And Mike Garner is 14 our engineer that does that cycle counting and 15 manages that program for us. 16 CHAIRMAN SKILLMAN:  Okay. Thank you. 17 Let me see if I have any more here. 18 (Pause.) 19 I'll ask my colleagues, any comments 20 for the Applicant relative to this matter? 21 MEMBER STETKAR:  Yes. They make me do 22 this. It's the voices in my head, I think. But I 23 have to ask this for every license renewal 24 applicant. 25 77  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Inaccessible underground cables, I 1 understand and I read back in 2011-2012, as the 2 program was evolving, there were a lot of RAIs. I 3 understand that your program is now consistent with 4 GALL Rev. 2, is that correct? 5 MR. ALDRIDGE:  That is correct. 6 MEMBER STETKAR:  Okay. Thank you. 7 I noticed that, as I read through 8 things, you have manholes that have solar-powered 9 sump pumps in them. And as best I can tell, you 10 have committed to what is in GALL Rev. 2, which is 11 an annual inspection of manholes or I would 12 categorize it as an episodic inspection if you 13 have, you know, a typical -- I used to do 14 consulting work down at South Texas and they used 15 to call them South Texas frog floaters. 16 (Laughter.) 17 So, you had a particularly heavy rain. 18 As best as I can tell, it is says that, 19 if an inspection determines that a sump pump is 20 inoperable, you will put it into your corrective 21 action program and fix it. Are those sump pumps 22 alarmed?  I mean, is there a better indication of 23 whether they are operating or inoperable than just 24 simply finding that there is water in the manhole 25 78  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  and the sump pump wasn't working? 1 MR. ALDRIDGE:  Yes, sir. The short 2 answer is they are not alarmed. 3 MEMBER STETKAR:  Okay. 4 MR. ALDRIDGE:  However, we do monitor 5 those, and over the years we have improved our 6 inspections there. And the subject matter expert 7 is present. 8 MEMBER STETKAR:  Okay. 9 MR. ALDRIDGE:  And we are doing some 10 enhancements. 11 MEMBER STETKAR:  The reason I am 12 curious is because not only episodic events, but 13 you have had a history of groundwater. 14 MR. ALDRIDGE:  Correct. 15 MEMBER STETKAR:  So, it is a pretty 16 low-lying area -- 17 MR. ALDRIDGE:  Yes. 18 MEMBER STETKAR:  -- and groundwater 19 intrusion is pretty pervasive. 20 MR. ALDRIDGE:  Right. 21 MEMBER STETKAR:  So, I was curious. 22 So, if I could hear what you are doing about those, 23 I would appreciate it. 24 MR. KHONDKER:  My name is Raihan 25 79  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Khondker. I'm the cable program owner at South 1 Texas Project. 2 The question is regarding the sump 3 pumps in our manholes at STP and what we are doing 4 about it. At present, we have solar pumps designed 5 in all the manholes where we have seen water 6 submergence issues. The solar pump design that we 7 have, we have been maintaining them through our 8 preventive maintenance program. We have, depending 9 on what kind of manhole it is and how often, we 10 have seen the trend showing how often the 11 groundwater incurs. We have frequencies from four 12 weeks all the way to annually, depending on which 13 manhole it is, and we go in and inspect the pumps 14 on them. 15 And if we see that a float switch or a 16 pump or any of the control mechanisms are not 17 working, we replace it as a part of the PM. I will 18 say, if there is any water at the floor level, we 19 pump it out. 20 At present, also, what we are doing as 21 a corrective action is that we have redesigned all 22 our pumps. We have a new approved design change 23 package which is allowing me to go and replace all 24 the pumps we have. We are putting higher-duty 25 80  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  pumps. Like we have in the higher ones we are 1 putting 2,000 gallons per hour. In some of them we 2 are putting 1500 gallons per hour, and some of them 3 are below 1,00 gallons per hour. 4 So, these designs are going in as we 5 speak. We are coming out of the outage, and those 6 pumps will be going in as solar pump designs, so 7 that we can keep all the manholes dry. 8 MEMBER STETKAR:  Good. That is 9 encouraging. 10 MR. KHONDKER:  Yes. In total, we have 11 an estimate of 96 pumps that is going to be put -- 12 MEMBER STETKAR:  Ninety-six, wow. 13 MR. KHONDKER:  Ninety-six solar pumps 14 are going in manholes because we have 155 manholes, 15 and out of them, 96 have seen historic -- 16 MEMBER STETKAR:  Since I have got you 17 up and on the -- 18 MR. KHONDKER:  Yes. 19 MEMBER STETKAR:  -- carpet here, you 20 said 155 manholes. Is that 155 in scope for 21 license renewal or just 155 total? 22 MR. KHONDKER:  No, they are not all in 23 scope. 24 MEMBER STETKAR:  Yes. 25 81  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. KHONDKER:  It is a combination 1 because we are looking at manholes, so we look at 2 them all as similar, yes. 3 MEMBER STETKAR:  Sure, sure, sure, 4 sure. 5 MR. KHONDKER:  Not just in scope, no. 6 MEMBER STETKAR:  Great. Thank you. 7 MR. KHONDKER:  No problem, sir. 8 MR. MURRAY:  This is Mike Murray. 9 I do want to point out that you talked 10 about the frog floaters. We have also improved the 11 sealing, the external sealing of those manholes as 12 well. 13 MEMBER STETKAR:  Yes, I have read some 14 of the operating experience. Thank you. 15 CHAIRMAN SKILLMAN:  Colleagues, any 16 further questions, please, for the Applicant? 17 MEMBER RICCARDELLA:  Yes, you indicate 18 you have your plant-specific program for nickel 19 alloys. As I recall, South Texas is somewhat 20 unique in having had a cracking of the bottom head 21 instrument nozzles. Is that part of your plant-22 specific program or is there anything special you 23 are doing on that topic? 24 MR. ALDRIDGE:  Mike Garner, do you have 25 82  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  a specific on the nickel alloy program, on the 1 scope?  Is that what it is for? 2 MR. ALDRIDGE:  In regards to VMI, 3 right? 4 MEMBER RICCARDELLA:  Yes, yes. 5 MR. GARNER:  Are you referring to VMI? 6 MEMBER RICCARDELLA:  Uh-hum. 7 CHAIRMAN SKILLMAN:  Please identify 8 yourself. 9 MR. GARNER:  My name is Michael Garner. 10 I'm the Site Metallurgist for STP. 11 The inspections for VMI will fall under 12 the code case, the guidelines described in the code 13 case, in 722, where we do a VE, a visual 14 examination, an enhanced visual examination, every 15 other year looking at 100 percent penetrations on 16 VMI. And then, every other year that isn't a code 17 inspection, we do a visual as well. It is not 100 18 percent, but it is looking for gross leakage. 19 MEMBER RICCARDELLA:  Okay. Thank you. 20 CHAIRMAN SKILLMAN:  Okay. Colleagues, 21 any further questions? 22 (No response.) 23 Dave, to you, please, sir? 24 MR. RENCURREL:  Thank you very much, 25 83  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  and we would like to thank the ACRS for your 1 questioning. 2 And I would also like to thank the 3 staff. I did not recognize our subject matter 4 experts who came here, too. We brought a little 5 bit under two dozen folks to come and ensure that 6 we had the right answers to your questions. 7 And one point I would like to make is 8 we started off by talking about the robust quality 9 assurance program, Appendix B. We are very 10 committed to the quality assurance program at South 11 Texas. As you heard here, leveraging that 12 independent oversight is one way we know that the 13 commitments we are making are being carried out. 14 With that, I would like to thank you 15 for your time. 16 CHAIRMAN SKILLMAN:  Yes, sir. Thank 17 you very much. 18 With that, ladies and gentlemen, we 19 will take a 16-minute break and we will resume at 20 quarter after 10:00 on that clock. 21 We are in recess. 22 (Whereupon, the foregoing matter went 23 off the record at 9:57 a.m. and went back on the 24 record at 10:15 a.m.) 25 84  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  CHAIRMAN SKILLMAN:  Ladies and 1 gentlemen, we are back in session. 2 To those who are on the bridge line, we 3 respectfully request that you put your phones, *6, 4 on mute. We can hear your family background. 5 (Laughter.) 6 We would like you to please silence 7 your phones, so that there is no background noise 8 affecting other members of the public that are 9 listening in. Would you please do that? 10 Also, Greg Pick, are you there, please? 11 MR. PICK:  Yes, I am. 12 CHAIRMAN SKILLMAN:  Thank you. 13 Greg is our inspector. We want to make 14 sure that our recon team is onboard. He is. 15 With that, let's begin. Lois, to you, 16 please. 17 MS. JAMES:  Thank you. 18 Good morning, Chairman Skillman and 19 Members of the License Renewal Subcommittee. 20 My name is Lois James, and I'm the 21 License Renewal Project Manager for the South Texas 22 Project, or STP, license renewal safety review. 23 We are here today to discuss the review 24 of the STP license renewal application, or LRA, as 25 85  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  documented in the Safety Evaluation Report with 1 open items which was issued in October. 2 Joining me here at the table today are 3 Dr. Allen Hiser, the DLR Senior Technical Advisor; 4 Mr. Bill Holston, Senior Mechanical Engineer, and 5 Ms. Phyllis Clark, Project Manager, who will be 6 running the slides. Mr. Greg Pick, Senior Reactor 7 Inspector in Region IV, is on the phone and will 8 discuss the 71002 inspection results. Sitting in 9 the audience and the phone are other members of the 10 technical staff who participated in the review and 11 conducted several audits and inspections. 12 Next slide, please. I will begin the 13 presentation with a general overview of the staff 14 review. Next, Mr. Pick will present the 71002 15 inspection results. I will, then, present the main 16 sections of the Safety Evaluation Report. Mr. 17 Holston will discuss the open item on the Selective 18 Leaching of Aluminum Bronze Aging Management 19 Program, or AMP. 20 Next slide, please. STP Nuclear 21 Operating Company, or Applicant, submitted an 22 application for the renewal of STP Units 1 and 2 23 operating licenses for an additional 20 years. The 24 staff conducted onsite audits, offsite audits here 25 86  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  in Maryland, and onsite inspections. As you can 1 see, the staff performed additional audits of the 2 open item for selective leaching of aluminum 3 bronze, AMP. 4 During the scoping and screening 5 methodology audit, the team reviewed the 6 Applicant's administrative controls governing the 7 scoping and screening methodology and the technical 8 basis for select scoping and screening results. 9 The scoping and screening methodology audit results 10 were documented in a report dated September 6th, 11 2011. 12 During the AMP audit, the team examined 13 the Applicant's aging management programs and 14 related documentation to verify that the 15 Applicant's programs are consistent with those 16 described in the GALL Report and with the plant 17 conditions and operating experience. The staff 18 reviewed the initial 40 AMPs and documented the 19 results in a report dated September 22nd, 2011. 20 In January of 2016, the Applicant 21 informed the staff of significant changes to the 22 Aluminum Bronze Selective Leaching AMP. These 23 changes redirected the staff's review such that the 24 topic-specific audits conducted in 2012 and 2015 25 87  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  were no longer applicable. 1 In 2016, the staff conducted an audit 2 of the Revised Aluminum Bronze Selective Leaching 3 AMP in two parts. During the week of March 21st, 4 the staff went onsite at STP and, then, a followup 5 day on June 22nd in the NEI offices in Rockville. 6 The audit focused on material 7 information, material process information, 8 microstructure information, and structural 9 integrity evaluations regarding the welds that may 10 be susceptible to selective leaching needed in 11 order for the staff to complete its review. 12 The results of the audit were 13 documented in a report dated August 30th. Region 14 IV will discuss the activities and results of the 15 71002 inspection in a few minutes. 16 Next slide, please. The staff 17 performed its review of the STP LRA and documented 18 its results in two Safety Evaluation Reports with 19 open items. In February of 2013, the staff issued 20 an SER with four open items. We did not come to an 21 ACRS meeting because the staff continued its review 22 of the selective leaching of the Aging Aluminum 23 Bronze AMP. We were uncertain about where the 24 review was going and we thought it was premature to 25 88  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  come to the ACRS at that time. 1 As stated in 2016, the Applicant 2 informed the staff of significant changes to this 3 AMP. The staff was able to make progress in its 4 review and issued an updated SER with open items in 5 October. The Final SER will include the resolution 6 of the open item regarding the aluminum bronze 7 selective leaching. 8 Next slide, please. I will now direct 9 the presentation to Mr. Pick to discuss the 10 inspection activities associated with the license 11 renewal review. 12 Mr. Pick. 13 MR. PICK:  Thank you, Lois. 14 Good morning, Members of the 15 Subcommittee. 16 CHAIRMAN SKILLMAN:  Good morning, Greg. 17 We can hear you loudly and clearly. 18 MR. PICK:  Thank you. 19 So, in our inspection we verified that 20 STP had properly identified those structures, 21 systems, and components included in scope and made 22 appropriate determinations of non-safety-related 23 systems and components affecting safety-related 24 components. 25 89  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  STP had established adequate programs 1 to manage aging of in-scope structures systems and 2 components, as specified in our regulations and 3 their Applicant's license renewal program. 4 The five inspectors on the team had 5 experience and expertise related to mechanical 6 systems and components, electrical systems and 7 components, and structures. Bill Holston also 8 accompanied us for one week of this inspection. 9 During our two-week onsite inspection, 10 our review included five of eight new aging 11 management programs and 14 of 32 existing aging 12 management programs. We walked down numerous 13 structures, systems, components to assess the 14 adequacy of the Applicant's license renewal 15 boundaries, in conformance with their application 16 and the Generic Aging License Renewal Report. 17 These walkdowns enabled us to assess 18 and evaluate whether the existing aging management 19 programs would be successful at managing aging 20 effects for in-scope structure systems and 21 components. 22 Next slide, please. The results of our 23 inspection. We determined that the plan had good 24 material condition. They revised two procedures. 25 90  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  They added susceptibility considerations when using 1 the online fact manager, and they developed 2 guidance in the structures monitoring program to 3 allow for noting changes and trending. This 4 included things such as taking measurements, 5 providing more detailed descriptions, and the use 6 of photographs. 7 They changed two aging management 8 programs as a result of the inspection. They 9 removed the fuel supply line evaluation as part of 10 the Fire Protection Aging Management Program, and 11 they initiated corrective action documents where 12 they will begin trending requirements added for the 13 type of test and accessible medium-voltage cables. 14 And the type of tests, for example, would be power 15 factor, partial discharge, time to remaining 16 reflective time, reflect time, trending each of 17 those types. 18 They changed five application 19 commitments and the related aging management 20 programs. They changed their sampling criteria for 21 selecting fire water piping to flow tests. They 22 will need a flow test 20 percent of the piping up 23 to a maximum of 25 components during their flow 24 testing. They will look at 20 percent or a maximum 25 91  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  of 25. 1 They are going to clarify selecting the 2 representative samples frequency inspection 3 requirements for the structures. They changed the 4 frequency for inside containment to five years, as 5 an example. 6 They are going to clarify the purpose 7 of the benchmark and the essential cooling water 8 structure. They have already done that. 9 They clarified their water control 10 structure monitoring requirements, and they updated 11 the requirements to inspect the interior of their 12 metal enclosed bus boxes. Instead of using 13 external thermography, they are going to look at 14 the internals. 15 Next slide, please. As a result of our 16 inspection, we concluded that the Applicant 17 performed the scoping and screening in accordance 18 with the rule. The information was easily 19 retrievable, auditable, and consistent with the 20 rule requirements. 21 From our reviews, we verified that 22 existing programs effectively managed the aging 23 effects. We verified that the Applicant tracked 24 the completion of enhancements and development of 25 92  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  new programs and a database, as they have already 1 described. 2 Based on our inspection results, the 3 team had reasonable assurance that the programs in 4 place or planned, as described by their commitment 5 table, with manage the aging effects and ensure the 6 intended safety and function of systems, 7 structures, and components within the scope of the 8 rule. 9 Does anyone have any questions? 10 CHAIRMAN SKILLMAN:  Greg, yes, I do. I 11 want to push back a little bit on the broadness of 12 your findings. I am referring to page 54 in the 13 PDF file of the SER. And here it is written, 14 "However, upon further review, subsequent to 15 submittal of the LRA, the Applicant determined that 16 the method used did not identify all non-safety 17 SSCs with the potential to impact the performance 18 of safety-related SSCs."  This goes on to read, 19 "Following this determination, the Applicant 20 performed walkdowns of the applicable MAB and FHB 21 spaces and identified additional non-safety SSCs 22 with the potential to impact safety-related SSCs, 23 and provided this additional information to the 24 staff in response to RAI 2.1-3." 25 93  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Then, that paragraph concludes the 1 staff's concerns are resolved. What gives you 2 comfort that walking down the MAB and the FHB is 3 sufficient for thoroughness in this regard? 4 MR. PICK:  When the team members walked 5 down the areas and did our reviews, what we saw 6 from using the drawings and looking at the safety-7 related components, the things that they said were 8 in scope were in scope. So, during our individual 9 samples, we did not identify anything that they had 10 not previously identified. So, that was the basis 11 of our statement on the sample we took. 12 CHAIRMAN SKILLMAN:  Thank you. No 13 further question on that issue, Greg. 14 MR. PICK:  Are there any other 15 questions? 16 MEMBER STETKAR:  Yes, I had one. And I 17 think I understand, but I wasn't quite sure from 18 your oral presentation what they are doing 19 regarding the fire protection system. Are they 20 doing flow tests according to the -- I don't know 21 if they are NFPA requirements -- they are probably 22 NFPA requirements -- for flow testing. 23 MR. PICK:  They do do the flow tests in 24 accordance with the NFPA. 25 94  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER STETKAR:  Okay. Because you 1 mentioned -- 2 MR. PICK:  That is something we look at 3 during our triannual fire protection inspections. 4 MEMBER STETKAR:  Okay. Good. 5 You did mention something about 20-6 percent sampling or 25 items. What's that?  That 7 is not related to flow testing, though? 8 MR. PICK:  No, no. I misspoke. 9 MEMBER STETKAR:  Okay. 10 MR. PICK:  In the report under fire 11 water system, they had identified they were going 12 to take 10 samples for volumetric examination to 13 see if there were any issues during their 14 enhancement for blockage. What they are really 15 going to do is take a 20-percent sample of the 16 piping or a maximum of 25 samples, because that is 17 what ends up statistically being the maximum they 18 would need to take of the fire water pipe 19 locations. And they are, again, going to base it 20 on location and pipe size. 21 MEMBER STETKAR:  Okay. Thank you. 22 That helps clarify. Thank you. 23 CHAIRMAN SKILLMAN:  Greg, this is Dick 24 Skillman. I have a question, a little different 25 95  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  topic. 1 I'm reading from our Status Report that 2 "The staff determined that the Applicant has a 3 quality Class QC4 that was not addressed in the 4 application."  What can you tell us about QC4 and 5 its applicability to our deliberations today, 6 please? 7 MR. PICK:  I have no knowledge of that 8 classification and I would have to defer that to 9 the licensee. 10 MS. JAMES:  Actually, we have Billy 11 Rogers coming up to the microphone to answer your 12 question. 13 CHAIRMAN SKILLMAN:  Thank you. 14 MR. PICK:  Thank you, Lois. 15 MR. ROGERS:  Good morning. This is 16 Bill Rogers from the staff. 17 So, we looked at that when we were 18 doing the scope-instituting methodology audit. 19 Many applicants have a variety of classifications 20 for components and systems onsite. And if there 21 are multiple quality classifications that might be 22 applicable to the determination of safety-related, 23 we will review those during the audit. 24 In this particular case, there was one 25 96  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  classification, QC4, that it wasn't clear how that 1 related to the determination of safety-related as 2 it would be applied in the implementation of the 3 rule. So, we discussed that. 4 And the answer that was provided to us 5 during discussion and, then, in the followup RAI 6 was QC4 could actually refer to both non-safety-7 related and safety-related components. So, the 8 Applicant had reviewed all of the QC4 components 9 and determined those which are identified, those 10 which were safety-related, and include them within 11 the scope of license renewal for A1, identified 12 those which were non-safety-related, and they would 13 have been included only if they were in scope for 14 A2, non-safety affecting safety; otherwise, they 15 would have been excluded. And we determined that 16 as an acceptable response and it resolved the 17 question. 18 CHAIRMAN SKILLMAN:  Thank you. Thank 19 you. 20 Please proceed. 21 DR. SCHULTZ:  I have one general 22 question, Dick. I would like to ask the question, 23 as one reads through the Inspection Report -- and 24 this is to be expected -- but, as we look at 25 97  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  license renewal and aging management, as you did 1 the inspection, you had the opportunity or the 2 need, of course, to look at the corrective action 3 program, the program health reports, surveillances, 4 as you did your investigations. 5 As you reflect on those programs, 6 corrective action, program health, and 7 surveillance, that are maintained by the sites, did 8 you have any issues or particular concerns related 9 to any of those programs in general? 10 MR. PICK:  During our inspection we did 11 not. I also do fire protection inspections and 12 cybersecurity inspections. When we do our baseline 13 inspections, we also take corrective action program 14 samples. We do look at surveillances, and during 15 those programs we have found that the licensee does 16 follow their tech specs, technical requirements 17 manual, do proper surveillances. And when they 18 find things wrong, they enter them into their 19 corrective action program and they resolve them. 20 DR. SCHULTZ:  Did you find the 21 resolution and process that they used to be robust? 22 MR. PICK:  We do. 23 DR. SCHULTZ:  Thank you. 24 MR. PICK:  Any other questions before I 25 98  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  turn it back over to Lois? 1 CHAIRMAN SKILLMAN:  Colleagues, any 2 more for our inspector?  Colleagues, any more for 3 the inspector? 4 (No response.) 5 Hearing none, Lois, please proceed. 6 Thank you, Greg. 7 MR. PICK:  Thank you. 8 MS. JAMES:  Thank you, Greg. 9 In the next few slides I will be 10 presenting the results as described in the SER with 11 open items. SER Section 2 described the scoping 12 and screening of structures and components subject 13 to the aging management review. The staff reviewed 14 the Applicant's scoping and screening methodology 15 procedures, quality controls applicable to the LRA 16 development, and training of its personnel. 17 The staff also reviewed the various 18 summaries of the safety-related systems, 19 structures, and components, non-safety-related 20 systems, structures, and components affecting 21 safety-related functions, and systems, structures, 22 and components relied upon to perform functions in 23 compliance with the Commission's regulations for 24 fire protection, environmental qualification, 25 99  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  station blackout, pressurized thermal shock, and 1 anticipated transients without a scram. 2 Based on their review, the results of 3 the scoping and screening audit, and additional 4 information provided, the staff concludes that the 5 Applicant's scoping and screening methodology is 6 consistent with the standard review plan and the 7 requirements of 10 CFR Part 54. 8 Next slide. SER Section 3 covers the 9 staff's review of the Applicant's AMPs. For a 10 given aging management review, the staff evaluated 11 the item to determine whether it is consistent with 12 the GALL Report and meets the requirements of 10 13 CFR Part 54. Section 3.1 through 3.6 include the 14 aging management review items in each of the 15 general system areas within the scope of license 16 renewal. If an aging management review was not 17 consistent with the GALL Report, then the staff 18 reviewed the Applicant's evaluation to determine 19 whether the Applicant demonstrated that the aging 20 effects will be adequately managed, so that the 21 intended functions will be maintained consistent 22 with the current licensing basis for the period of 23 extended operation. 24 Next slide, please. The LRA identified 25 100  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  40 AMPs, and the Applicant subsequently added an 1 existing program in response to License Renewal 2 Interim Staff Guidance ISG-2013-01, aging 3 management of loss of coating or lining integrity 4 for internal coatings/linings or on in-scope 5 piping, piping components, heat exchangers, and 6 tanks issued in November of 2014. 7 The left side of the slide identifies 8 the Applicant's original disposition of the AMPs, 9 and the right side identifies the staff review of 10 the AMPs, as documented in the SER with open items. 11 All AMPs were evaluated by the staff for 12 consistency with the GALL Report. 13 Next slide, please. The staff closed 14 two open items associated with the aging management 15 review from the 2013 SER with open items under the 16 review of the aging management program. 17 The first open item. In reviewing the 18 open-cycle cooling water system AMP, the staff 19 found that the LRA did not describe the protective 20 coatings used in the essential cooling water 21 system, nor discuss site-specific operating 22 experience which would provide objective evidence 23 supporting the conclusion that the effects of aging 24 will be adequately managed during the period of 25 101  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  extended operation. 1 Between February and November of 2012, 2 the staff issued Requests for Additional 3 Information, or RAIs, on these topics and 4 documented an open item in the 2013 SER with open 5 items. Subsequently, in November of 2014, the 6 staff issued ISG-2013-01 which encompassed these 7 issues. 8 After reviewing the RAI responses and 9 changes in response to the ISG, the staff 10 determined that the open cycle cooling water system 11 AMP is consistent with the GALL Report and meets 12 the requirements of 10 CFR Part 54. 13 For the second open item, in reviewing 14 the one-time inspection AMP, the staff questioned 15 why the Applicant did not have an AMP to detect and 16 address cracking on the interior surfaces of the 17 RWST or other similar stainless steel tanks. If an 18 AMP is not necessary, the Applicant needed to state 19 the basis for why such an AMP was not necessary. 20 In response to RAIs, STP detailed its 21 activities to characterize the cracking on the Unit 22 1 RWST and its proposed methods to manage the aging 23 effects with both one-time and periodic 24 inspections. Based on the staff's review of the 25 102  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Applicant's response, the concerns regarding the 1 cracking in the Unit 1 RWST were resolved and the 2 corresponding open item is closed. 3 DR. SCHULTZ:  Lois, did you have an 4 expectation that that might be extended to other 5 tanks? 6 MS. JAMES:  Yes, the program extends to 7 other stainless steel tanks. 8 DR. SCHULTZ:  But the focus here was 9 just for the RWST? 10 MS. JAMES:  Well, the question rose 11 from operating experience regarding the RWST. So, 12 that is where the question started. 13 DR. SCHULTZ:  All right. But, in terms 14 of the AMP program going forward, they are going to 15 be -- 16 MS. JAMES:  Considering it -- 17 DR. SCHULTZ:  -- applying it to all 18 tanks? 19 MS. JAMES:  Yes. Yes, sir. 20 DR. SCHULTZ:  Thank you. 21 CHAIRMAN SKILLMAN:  Lois, thank you. 22 Before you leave this section on open 23 items closed -- thank you, John -- before you leave 24 this slide on open items closed, there is another 25 103  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  open item that has been closed. It is open item 1 4.3.2.11-1, the Effects of Thermal Aging on Cast 2 Austenitic Stainless Steel. 3 MS. JAMES:  Yes, sir. 4 CHAIRMAN SKILLMAN:  And written in the 5 documentation is this statement:  "Use of minimum 6 material properties do not provide adequate 7 protection in light of information from the past 29 8 years."  This item was then closed. Would you 9 please provide an explanation of how this 10 determination was made that this open item can be 11 closed? 12 MS. JAMES:  Can I defer that to Section 13 4? 14 CHAIRMAN SKILLMAN:  Sure. 15 MS. JAMES:  I will actually address 16 that on slide 17. 17 CHAIRMAN SKILLMAN:  Yes, that will be 18 fine. Thank you, Lois. Please proceed. 19 MS. JAMES:  Okay. I will now turn the 20 presentation over to Mr. Holston, who will address 21 the open item, the aluminum bronze open item. 22 MR. HOLSTON:  So, the aluminum bronze 23 open item, as you heard the Applicant discussing, 24 initially, the aluminum bronze program was focused 25 104  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  on about 450 cast components that were susceptible 1 to selective leaching. And in January of last 2 year, they came in and said, well, we are going to 3 replace all of those castings because we had 4 questions related to what is the real strength of 5 the component when you de-alloy part of it. When 6 you saw the picture that they showed on the slide 7 with that little area of external de-alloying or 8 the indication you could see, well, how do you 9 really project what is going on inside the pipe to 10 do your operability evaluations? 11 So, those are all being replaced. 12 That, however, left, as was discussed, about 3300 13 welds. Of course, that number will be lower when 14 castings are cut out and replaced, so you are still 15 talking about 2,000 welds, somewhere in that 16 ballpark, that are susceptible to selective 17 leaching. 18 As a result of our review of the 19 changes to the program, you heard we had about a 20 10-part open item, of which nine of those were 21 closed by a submittal that changed the program. It 22 came in in September of 2016. So, I am going to 23 focus that point forward on this. 24 So, one of the key aspects that the 25 105  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Applicant was looking at is they had not had any 1 leaks due to selective leaching in these welds, 2 these susceptible welds, since 1994. So, they did 3 some metallurgical testing. They did some 4 calculations on cooldown rates on welds and all 5 sorts of things, and then, came to postulate that 6 the root pass is less susceptible, and it is less 7 susceptible because the dilution, the higher rate 8 of dilution that occurs in the root pass and the 9 cooldown rate being higher than in subsequent 10 passes. 11 So, in effect, what would happen is 12 they have reduced the susceptibility of the overall 13 weld to selective leaching of this aluminum bronze 14 because the root pass acts as a barrier. I mean, 15 you can almost kind of think of it as, well, it is 16 kind of like a coating and it is isolating the more 17 susceptible passes of the weld from the 18 environment. If you isolate it from the 19 environment, you are not going to have selective 20 leaching occur. 21 And some, that is dependent upon not 22 having a construction-related or an in-service flaw 23 that penetrates through the root pass and, then, 24 unless you can get the environment in the 25 106  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  subsequent passes that are most likely more 1 susceptible. That is where it is postulated they 2 had the through-wall de-alloying up to 1994, was in 3 welds that had, you know, construction-related 4 flaws. 5 So, as the staff and Lois talked about 6 audits we did on site, technical data we reviewed, 7 testing results we reviewed, the root pass as a 8 barrier seemed very plausible to us. However, 9 there wasn't enough testing done. The Applicant 10 had cross-sectioned, you know, about six welds. 11 That was leaning in that direction, that that was 12 plausible. So, we proceeded from that point. 13 So, we can go to the next slide, slide 14 No. 13. I just want to talk about a couple of the 15 conclusions we derived from not only looking at the 16 Applicant's results of their destructive 17 examinations, but also in a lot of review of the 18 technical literature that is available. 19 The de-alloying process occurs at a 20 microstructure level, and it is confined for a 21 localized front at scales with a grain size. Those 22 are some really cool words, right, and he is a 23 metallurgist, but what does it really say to you? 24 If you look at the cross-section of one 25 107  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  of these welds or any material that is susceptible, 1 you basically have a front of de-alloying that goes 2 through. On one side of that front it is 100-3 percent de-alloyed; on the other side of the front 4 it is not de-alloyed. Now, of course, if you can 5 keep exposing the environment as you pass through 6 those grains, those are going to become de-alloyed 7 eventually. However, that is what it is. 8 So, the material on either side of that 9 front that goes through the material is either in 10 its as-received material properties or it is in 11 fully de-alloyed material properties. We concluded 12 from the data that the Applicant had constructed on 13 testing of material properties for the de-alloyed 14 material within the bulk component that there was 15 insufficient data to bound the mechanical 16 properties. 17 We are very fortunate to have a person 18 on staff, Chris Sevanick, who was involved in the 19 Navy Air Program, had actually been involved in 20 developing material properties from testing, and, 21 basically, had to go through all that data. 22 So, based on the number, the size of 23 the population of tests they had, and based upon 24 some of the scatter within those results, we 25 108  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  basically came to a conclusion that you would not 1 give any credit or there would be no strength 2 credit, in other words, no tensile value, for de-3 alloyed properties or fracture toughness credit. 4 Now the Applicant throughout, even back 5 in the eighties when they did their operability 6 evaluations and they did their calculations, never 7 credited any material properties for the de-alloyed 8 portions, right?  And so, that is nothing new or 9 big, but it is important when we talk later about 10 structural integrity. 11 Next slide. So, given what we knew and 12 what the Applicant changed in the programs, I 13 wanted to highlight some of the key features of the 14 program that lead us to a conclusion that we are 15 down to just one last open item. And some of those 16 you have heard already. 17 But in the detection of aging effects 18 program element, the Applicant is going to do 19 volumetric inspections. These volumetric 20 inspections will look to see if there is weld 21 defects, weld defects that could be progressing 22 through the root pass, right?  So, these are not 23 ultrasonic exams that are going to measure how much 24 de-alloying is going on. We are going to talk 25 109  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  about that maybe in a little bit, just as an 1 overview. 2 But those volumetric examinations will 3 provide information that, in fact, based upon a 4 representative sample, we aren't seeing, we haven't 5 seen from the last time they did these volumetric 6 examinations during the plant construction, that 7 there aren't weld defects that are propagating 8 through the root pass. 9 They are going to do destructive 10 examinations in addition. And in doing this, you 11 heard a lot about 25, 20 percent. Twenty percent 12 is immaterial in this case, right, because it is 13 25. So, there is going to be 25 volumetric 14 inspections for the welds with backing rings and 15 welds without. There is going to be 25 destructive 16 examinations of welds with backing rings and welds 17 without. So, in effect, we are going to see 50 18 welds cross-sectioned. 19 There will be continuing inspections 20 for leakage. How the licensee has been managing 21 this selective leaching since the days that it 22 started occurring is every six months they do a 23 walkdown of all the above-ground piping. 24 One of the pictures you saw or the 25 110  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  picture they showed you is very characteristic of 1 what you see if you see selective leaching. I 2 actually did a walkdown with one of the Applicant 3 staff members, and there was a fitting, you know, a 4 much smaller fitting. It was about a 3-inch 5 fitting that showed that little fluorescent break 6 there. 7 Then, in addition, they look at yard 8 areas to detect if there is moisture that is 9 unusual that shouldn't be there. That would seem 10 odd. How do you that?  Well, we explored that with 11 the Applicant. We looked at detailed calculations 12 that demonstrated that, if you have a 10-gallon 13 permatted leak, it will get to the surface within 14 30 days. And they have a huge margin there. They 15 have about a margin of 1,000 gallons, I mean that 16 they can tolerate. 17 I am not a hydrology expert. I looked 18 at the calculations. So, fortunately, the New 19 Reactors Organization, they had a hydrology expert. 20 He reviewed those calculations and felt that they 21 were well-bounded and well-founded. So, albeit, 22 you can't look for leakage on the outside surface 23 of the components that are buried, we can observe 24 for an indirect effect and be convinced that there 25 111  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  is no leakage going on that would affect the 1 intended function. 2 Of course, when they do opportunistic 3 buried pipe inspections, they will actually go in 4 and look at the coatings for those pipes. All this 5 piping is coated that is buried. Of course, that 6 isolates the susceptible weld layers, you know, the 7 crown pass from the environment. 8 So, that is basically what is going to 9 go on with detection of aging effects. Basically, 10 at the end of that, having done the volumetric 11 examinations to show that, yes, after that 12 representative sample, we don't see any defects 13 that are challenging the root pass, and we will 14 have 50 examinations that will actually not only 15 look at is there de-alloying going on, but it will 16 look at the phase, the actual phases within that 17 cross-section that will be sufficient to 18 demonstrate that the theory, which we think is 19 true, is that root pass is more resistant to de-20 alloying and protects the other layers of the weld. 21 And that is one reason why they haven't had any 22 leaks since 1994. 23 Yes, sir? 24 MEMBER RICCARDELLA:  How does the 25 112  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  presence of a backing bar affect this protection -- 1 MR. HOLSTON:  Well, the backing ring 2 does two things. It does one good thing and it 3 does one bad thing. There are two effects that 4 contribute to whether the welds are going to be 5 susceptible. 6 One is, with the dilution, with 7 diluting the welds, you have a lower concentration 8 of aluminum, which with the samples they have taken 9 they have demonstrated it. They can show a 10 difference across the passes as you go. 11 The other thing is the backing ring 12 allows you to have a greater heat sink, which cools 13 it down quicker. If you cool it down quicker, you 14 don't get the gamma-2 or the beta phase that are 15 susceptible to selective leaching aluminum bronze. 16 The downside of having a backing ring 17 is that it gives you kind of a notch. It gives you 18 a localized place where it can concentrate and 19 adverse chemistry that can cause a selective 20 leaching. So, that is why the Applicant 21 identified, you know, we have got a backing ring 22 population. We are going to do 25 of those. We 23 have got a non-backing-ring population. We are 24 going to do 25 of those. 25 113  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER RICCARDELLA:  Okay. 1 MR. HOLSTON:  So, any other questions 2 on detection of aging effects? 3 DR. SCHULTZ:  Bill -- 4 MR. HOLSTON:  Yes? 5 DR. SCHULTZ:  -- one more question. We 6 have kind of bounced back and forth between a 7 representative sample and 25. 8 MR. HOLSTON:  Uh-hum. 9 DR. SCHULTZ:  With regard to the 10 destructive examinations, what are the staff's 11 expectations if, when those are done, issues arise 12 as a result of the investigation?  I mean, you 13 could hypothesize you do the destructive 14 examinations and you find issues. 15 MR. HOLSTON:  Correct. 16 DR. SCHULTZ:  What are the staff's 17 expectations of what will be done if in examining 18 25 and 25 that there are problems identified? 19 MR. HOLSTON:  Can I defer that just to 20 the next slide? 21 DR. SCHULTZ:  Sure. 22 MR. HOLSTON:  Because I am going to 23 address that within corrective actions. 24 DR. SCHULTZ:  Thank you. 25 114  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. HOLSTON:  So, yes, I will go 1 through acceptance criteria and, then, get to that 2 and I will answer your question I think directly. 3 Any other questions on detection, how 4 they are going to detect these aging effects? 5 MEMBER SUNSERI:  Yes. With regard to 6 the underground pipe and just looking for moisture, 7 or what have you, to reach the surface, was there 8 any consideration of using other techniques such as 9 ground-penetrating radar or something like that to 10 get on top of the leaks faster? 11 MR. HOLSTON:  The simple answer to the 12 question is no, because there is a huge -- but the 13 answer to why is that there is a very large margin. 14 They can detect a 10-gallon-per-minute leak. They 15 can tolerate 1,000 gallons per minute. Now, 16 clearly, if they had a 1,000 gallons a minute, that 17 is going to be washing out soil. It could affect 18 structural integrity evaluations. But selective 19 leaching is not a rapidly-propagating phenomenon. 20 You know, you are not going to go from 10 gallons a 21 minute one day and now, suddenly, you are at 500 a 22 month later, right?  It is just not going to 23 happen. So, that is why we didn't -- 24 MEMBER SUNSERI:  Yes. Thank you. 25 115  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER STETKAR:  Bill, should I ask you 1 about the buried and underground piping program now 2 or should I ask you about it at all? 3 MR. HOLSTON:  Well, you can ask me. 4 MEMBER STETKAR:  Okay. 5 MR. HOLSTON:  And why don't you go 6 ahead? 7 MEMBER STETKAR:  Okay. 8 MR. HOLSTON:  We might have Brian Allik 9 answer some of that. Brian Allik is taking some of 10 that over. 11 MEMBER STETKAR:  Yes. Well, let me get 12 to where I was headed. 13 MR. HOLSTON:  Sure. 14 MEMBER STETKAR:  We heard earlier that 15 the license renewal application checked off a box 16 that said the cathodic protection system is not in 17 scope for license renewal. So, does that mean that 18 in their buried and underground piping inspection 19 program they are applying the -- I don't know 20 whether it is Category E or Category F of their 21 inspections. In other words, not taking credit at 22 all for cathodic protection?  Or what are they 23 doing? 24 MR. HOLSTON:  Yes, that doesn't mean 25 116  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  that. What it means is, when we say the cathodic 1 protection system is not within the scope, it is 2 the wires; it is the panels; it is the rectifiers 3 that aren't in scope. 4 So, what we did was we built into Aging 5 Management Program 41 for buried and underground 6 piping the measurement of the cathodic protection 7 from two perspectives. And that is what drives you 8 to those additional inspections in Category E and 9 F, as you mentioned. 10 MEMBER STETKAR:  Yes. 11 MR. HOLSTON:  So, the Applicant has to 12 measure the amount of time the current is turned 13 on. Somebody trips a breaker open for something 14 and it has been off for two months, that is going 15 to be a problem, right?  Because if you don't pull 16 the electricity, you are not going to get the 17 cathodic protection. So, there is a criteria for 18 that, and that is 85 percent of the time it has to 19 be on. 20 We also have a criteria, then, for the 21 effectiveness of it. And that is measured by the 22 annual cathodic protection surveys. You have to 23 demonstrate that you have negative 850 millivolts. 24 Now, with our new ISG we issued, we also accepted 25 117  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  in higher resistivity soils -- that is negative 750 1 or negative 650. We also allow for actually direct 2 measurement of corrosion rates. But, if you can't 3 demonstrate that you are meeting that level of 4 protection, then you have to go to E or F -- 5 MEMBER STETKAR:  Right. 6 MR. HOLSTON:  -- and do the additional 7 inspections. 8 And what demarcates between E and F is, 9 if your plant-specific operating experience is good 10 and meets the criteria in the AMP, then your 11 cathodic protection is upright, up-to-speed, you do 12 E, which is three every 10 years. But, if you also 13 have bad operating experience, then you have got to 14 go to six every 10 years. 15 MEMBER STETKAR:  Right. So, I think 16 what I hear you saying is that they will -- I 17 always hate to say "take credit" -- but they will 18 take credit for cathodic protection with all of 19 those caveats in determining the frequency and 20 extent of their piping inspections? 21 MR. HOLSTON:  Right. Because, in 22 effect, what we are doing is, rather than going to 23 the panel and seeing if it is leaking -- 24 MEMBER STETKAR:  No, no. 25 118  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. HOLSTON:  -- rather than checking 1 the wires, we performance monitor the effects of 2 the cathodic protection system with the 3 availability and the effectiveness. 4 MEMBER STETKAR:  Yes. Thank you. That 5 helps. 6 MR. HOLSTON:  Any other questions on 7 detection of aging effects? 8 (No response.) 9 Okay. For the acceptance criteria, 10 what they will do when they do the volumetric exams 11 is, obviously, they are looking for any plane or 12 flaw that would exceed 80 percent of the root pass 13 if it is connected -- you know, you could have a 14 plane or flaw within. So, here's your water. And 15 so, your inside diameter of your pipe, and you have 16 your pipe, you know, your outer edge of your root 17 pass. If it is up here, we are not really worried 18 about it. We are here with an environment 19 connected plane or flaw. 20 And with the destructive examinations, 21 the microstructure of the root region, we are 22 looking to see that we are reasonably certain they 23 are going to see some gamma-2 in the welds, right?  24 It is not none whatsoever at all, right?  But we 25 119  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  want to see that that is surrounded by the alpha 1 phase which is not susceptible to selective 2 leaching. And if the gamma-2 or the beta phase 3 would exceed 80 percent of the depth of that root 4 pass, then we have an issue. And so, that is the 5 microstructure monitoring. 6 And I did have a typo -- I apologize 7 for that -- in the third acceptance criteria, which 8 is the walkdowns every six months. They will go to 9 monthlies if they have some other problems, but 10 those are just they are looking for leakage, is 11 what the acceptance criteria is for that. 12 CHAIRMAN SKILLMAN:  Bill, has the 13 Applicant ever discovered a geyser?  Have they ever 14 seen a leak great enough to really push water out 15 of the soil? 16 MR. HOLSTON:  I looked at their 17 operating experience when I did the buried pipe 18 audit and saw none, no, sir. 19 CHAIRMAN SKILLMAN:  Okay. Thank you. 20 MR. HOLSTON:  Any questions on 21 acceptance criteria? 22 (No response.) 23 Okay. Next slide, and this gets to the 24 corrective actions I was talking about before that 25 120  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Mr. Schultz was asking about. 1 So, if they find a problem within the 2 volumetrics for weld defects that are penetrating 3 the root pass, they have to do five additional 4 volumetric examinations until they see none. And 5 for the destructive examinations, the criteria is 6 the same. It is, if you see that phased 7 distribution not what we would expect, not 8 supportive of what the theory is, then you have to 9 keep doing five more until you don't see that 10 anymore. The five comes from Generic Letter  11 90-05, which the Applicant commented upon. It is 12 the NRC staff basic position when you find 13 something that is adverse that you look more until 14 you find the issue. 15 Does that answer your question? 16 DR. SCHULTZ:  Yes. Thank you. 17 MR. HOLSTON:  Okay. Now another 18 aspect, though, which is structural integrity 19 calculations conducted with the as-found 20 conditions, so, then, the question is, well, what 21 is a corrective action if you find an issue with 22 structural integrity? 23 So, the staff is concerned with that 24 because, if you find an issue with structural 25 121  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  integrity, you have an issue with the intended 1 function of the system. And so, that is where we 2 are right now with the Request for Additional 3 Information. 4 The licensee has worked with EPRI and 5 done some testing of a UT volumetric method that 6 should be able to actually take the weld and 7 measure the amount of de-alloying that is going 8 inside, from the inside, from the ID to the OD. 9 So, what you could picture, if you are 10 looking at a ring, is here it is penetrating 60 11 percent. That would be bad, right, because it is 12 through the root pass?  But, over here, it is just 13 penetrating 10 percent, and there is none down 14 here. And it just is based upon reasonable theory. 15 We were aware of Vermont Yankee doing 16 the cast iron piping. We just hadn't been aware of 17 anybody doing it for aluminum bronze welding or 18 fittings. 19 And so, our RAI talks about, well, tell 20 us how you are going to demonstrate the method, how 21 you are going to quality people, what the 22 resolution of that process is, and several other 23 questions on sampling size and all of that. So, 24 that is the remaining open item, is, what are you 25 122  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  going to do for corrective actions if the 1 structural integrity evaluation isn't acceptable? 2 CHAIRMAN SKILLMAN:  Bill, as a matter 3 of admin as we look into the new year, is it these 4 RAIs that will not be presented until after March? 5 MR. HOLSTON:  I don't -- well -- 6 MS. JAMES:  We have not issued the RAI 7 yet. So, we have to issue it. They have to have 8 their 30 days to respond and, then, we need at 9 least 30 days to look at what their response is. 10 And in this instance, we have to get 11 another division involved. So, we wanted to give 12 ourselves a little extra time to review what comes 13 in, which is why we are discussing delaying the 14 full Committee from February. 15 CHAIRMAN SKILLMAN:  Thank you. I 16 understand. 17 MR. HOLSTON:  The RAI has been peer-18 reviewed. 19 CHAIRMAN SKILLMAN:  Okay. 20 MR. HOLSTON:  It has been approved by 21 management, but we have to get it out. 22 CHAIRMAN SKILLMAN:  Thank you for the 23 explanation. We were trying to get clear on timing 24 and the workload for the Committee. And this gives 25 123  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  us an explanation of what is happening. Thank you. 1 Please proceed. 2 Go ahead, John. 3 MEMBER STETKAR:  I was going to say, do 4 you have more on this? 5 MR. HOLSTON:  No, no, that is the end 6 of my presentation. If you have any questions -- 7 MEMBER STETKAR:  Let me go back to the, 8 for lack of a better term, risk-informed sampling 9 process. Is the staff good with taking a random 10 sample, you know, throwing a random number 11 generator in and taking a random sample of any 25 12 of the 3300, I think I wrote down here? 13 MR. HOLSTON:  Yes, we are thinking 14 there is about 2,000. Once you cut out the 400-15 some-odd fittings -- 16 MEMBER STETKAR:  All right. I don't 17 want to get down too much. 18 (Laughter.) 19 MR. HOLSTON:  It is a little bit less. 20 MEMBER STETKAR:  But 25 out of a large 21 number -- 22 MR. HOLSTON:  Right. 23 MEMBER STETKAR:  -- randomly 24 selected -- 25 124  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. HOLSTON:  What we did was Matt 1 Homiack, who is back here in the room, he is in 2 Research now, did some calculations, finite element 3 heat transfer calculations to determine how 4 sensitive that is. And he is coming up to the 5 microphone, and I would like to give him credit for 6 the great work he did in that regard. I think he 7 is going to have some positive answers for you. 8 MR. HOMIACK:  Thank you, Bill. 9 So, the Office of Nuclear Regulatory 10 Research has been supporting NRR -- 11 CHAIRMAN SKILLMAN:  Excuse me, sir. 12 Identify yourself, please. 13 MR. HOMIACK:  Matthew Homiack from the 14 Office of Research. 15 CHAIRMAN SKILLMAN:  And, Matt, make 16 sure you speak up in the microphone, so we can 17 hear. 18 MR. HOMIACK:  Will do. Thank you. Is 19 this okay? 20 CHAIRMAN SKILLMAN:  Yes. 21 MR. HOMIACK:  So, there is actually two 22 -- it is a smart sample. There is two sample 23 populations, first of all. One, welds with backing 24 rings and one of welds without. And I believe, 25 125  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Bill, each will get 25 destructive examinations. 1 And so, the reason for looking at those 2 differently is the welds with the backing rings 3 have the operating experience, and the welds 4 without the backing rings are more susceptible root 5 pass to de-alloying because they have a quicker 6 cooldown rate. 7 The Applicant has done some cooling 8 rate analyses, which the staff has done some 9 independent confirmatory calculations as well, and 10 we think their cooldown rates are conservative. 11 MR. HOLSTON:  And Matt, in his 12 calculations, varied heat inputs, the exact 13 question you were asking. Because one of the 14 concerns we had was not so much some variation from 15 welder to welder, but if you are hanging upside-16 down and trying to make that weld versus doing a 17 flat weld, doing a vertical weld, you know, as 18 well-controlled as weld procedures are, it is a 19 little tougher to make some of those welds. And 20 would they have a higher heat input or something? 21 But the calculation, it is not really 22 -- the cooldown rate is not very sensitive to a 23 reasonable range of expectations of heat input from 24 the weld. So, the random sample is reasonable. 25 126  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Now the AMP does say, the aging management say that 1 they will take into effect construction-related 2 factors. 3 MEMBER POWERS:  If I just assume that 4 they have a random population -- 5 MR. HOLSTON:  I'm sorry, I couldn't 6 hear you. What? 7 MEMBER POWERS:  If I assume that I have 8 a random population, in other words, defects are a 9 random sort of thing, which may not be true, but 10 close enough for argument's sake, and I look after 11 three refueling inspections. So, I have a sample 12 of 75. I would probably have a 95-percent chance 13 that I have covered 90 percent of the range of 14 things. 15 So, while the number looks small, it is 16 pretty powerful if you don't have systematic 17 effects. And that, coupled with your walkdown to 18 identify systematic vulnerabilities, it appears to 19 me, though, it is 25 of a large number, the fact is 20 random sampling is a pretty powerful technique for 21 identifying outliers in that range. 22 MEMBER STETKAR:  Well, except for how 23 frequently do they do this destructive examination 24 sampling. 25 127  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MR. HOLSTON:  Well, if they are going 1 to do the destructive examinations, it is a one-2 time destructive examination. Because you want to 3 demonstrate with adequate data that that root pass 4 is less susceptible. 5 MEMBER STETKAR:  So, the sample is not 6 after three refuelings. It is a one-time. It is 7 25. So, you have a little lower confidence. 8 MEMBER POWERS:  Yes, it is a fairly 9 sharp function -- 10 MEMBER STETKAR:  Yes. 11 MEMBER POWERS:  -- that moves up 12 rapidly. 13 MR. HOLSTON:  The actual numbers are 14 that  the 25 is a 90/90 certainty. That is the 15 number. So, where we have adopted that throughout 16 the GALL Report and several aging management 17 programs is, where you are demonstrating that an 18 aging effect is not likely to cause a loss of 19 intended function, we use 90/90. 20 Now, for example, when talking about 21 structural integrity, there is a challenge to 22 structural integrity, the certainty needs to be 23 higher. So, for these welds that we are doing 24 where we have seen some cross-sections, right, 25 128  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  about six welds that they cross-sectioned that 1 support the theory, we want to have enough to say 2 that that is reasonable, that they are not going to 3 de-alloy through the root pass, go into the higher 4 susceptible weld passes, and then, de-alloy 5 through-wall. And so, that is why we are very 6 comfortable with the 25 and the random at this 7 point. But the RAI addresses what happens if you 8 see more consequential results -- 9 MEMBER STETKAR:  Yes, I didn't read the 10 RAI. 11 MR. HOLSTON:  Yes. Yes, we haven't 12 given that to you yet. It is not published yet. 13 MS. JAMES:  It is not publicly-14 available yet. So, it will be public and it will 15 issue in the next week or so. 16 MEMBER BALLINGER:  So I have it clear 17 in my head, the weld heat input and all of that 18 stuff for the various sizes of welds, it is not 19 that much different welds. So that there is not 20 likely that there will be a distinction, there 21 would be a distinction between small diameter or 22 large diameter. That is not going to be an issue 23 that unrandomizes things, if you will? 24 MR. HOLSTON:  That is correct, yes. 25 129  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MEMBER BALLINGER:  Okay. 1 MR. HOLSTON:  And again, we didn't just 2 -- because, well, suppose in the audience that his 3 company did some of the finite element calculations 4 for the cooldown, and we didn't just take that at 5 face value. Matt Homiack did his own independent 6 evaluations to that effect. 7 MEMBER BALLINGER:  Okay. Some of us 8 remember, well, it only happens to small diameter 9 pipes. And then, well, it only happens to slightly 10 larger diameter pipes. And then, yes -- 11 MEMBER RICCARDELLA:  Bill, as you know, 12 the other side of risk-informing this type of a 13 selection is to look at consequences. Is there any 14 ability to distinguish from different piping 15 locations based on the consequences of failure?  16 And what are we looking at?  I mean, are we looking 17 at an actual rupture that we are concerned about or 18 just a leak? 19 MR. HISER:  Okay, so two parts to that. 20 We are sampling to try to demonstrate that all of 21 the 2,000 welds are okay. Are there welds that 22 would have a higher consequent?  Absolutely. 23 Right, because there are welds in the main header. 24 There are welds that directly supply maybe a cooler 25 130  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  for diesel, and those would be more. There are 1 welds that are downstream of the coolers. It has 2 already done its function as long as it doesn't 3 flood the room. All it is doing is going to the 4 bay, or not the bay, to the pond, right? 5 So, we didn't factor in in any 6 selection the consequential because we are 7 confident, based upon what we have seen with the 8 testing results, also with what Matt has done with 9 the backup analyses, that what you see in a weld 10 here that is a very critical weld would be the same 11 thing because the environment is the same here; the 12 weld processes are the same, and the sensitivity to 13 the amount of heat put in with the weld is 14 virtually, you know, it doesn't really affect the 15 potential for additional beta or gamma-2. So, we 16 didn't say, make sure you do all your sampling of 17 your welds upstream or in the main header, or 18 anything like that. 19 MR. HOLSTON:  Well, the consequence, 20 yes. Yes, as Allen is saying, the consequence 21 issue gets into whether what you see affects 22 structural integrity. And so, that is where we 23 have a four-page RAI to address what -- you know, 24 that is why the corrective actions for structural 25 131  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  integrity is still an open item. You know, we are 1 hopeful that this volumetric technique will be 2 something that we can accept it. Of course, with 3 the volumetric technique of that nature, they could 4 look at a lot of welds. They could zero into the 5 more consequential welds in that case. Because, to 6 date, of all the casting failures, castings are a 7 lot more susceptible than the welds are, and on the 8 weld failure side, they have not had one that 9 failed structural integrity criteria. 10 MEMBER RICCARDELLA:  Question. You 11 know, when you say "structural integrity criteria," 12 you say, well, the stresses are higher than the 13 allowable stress, or something like that. But is 14 there any concern at all about a rupture of one of 15 these or are we mainly just concerned about a leak? 16 MR. HOLSTON:  Because of the very low 17 operating pressure at very low operating 18 temperatures, we are not too concerned. And they 19 have very low seismic loads, too. We looked at 20 their seismic analyses. There is nothing huge 21 there. 22 We would be more concerned with a leak 23 than we would be -- but they have done a lot of 24 analyses on the leak rates, the allowable leak 25 132  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  rates versus detectability of those leaks. And we 1 have reviewed all of that, and that is all 2 documented, that we feel they have the 3 detectability to see it before it could approach to 4 a leak that would starve the heat exchanger, or 5 whatever. 6 MEMBER RICCARDELLA:  Thank you. 7 CHAIRMAN SKILLMAN:  Let's proceed, 8 please. 9 Bill, thank you. 10 MR. HOLSTON:  Yes, sir. 11 MS. JAMES:  Okay. We are now on slide 12 16. SER Section 4 identifies the time-limited 13 aging analysis, or TLAAs. Section 4.1 documents 14 the staff's evaluation of the Applicant's basis for 15 identifying plant-specific or generic analysis that 16 need to be identified as TLAAs and determine that 17 the Applicant has provided an accurate list, as 18 required by 10 CFR 54.21(c)(1). 19 Sections 4.2 through 4.7 document the 20 staff's review of the applicable STP TLAAs as 21 shown. Based on its review and the information 22 provided by the Applicant, the staff concludes that 23 the TLAAs will remain valid for the period of 24 extended operation. The TLAAs have been projected 25 133  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  to the end of the period of extended operation or 1 the effects of aging on those intended functions 2 will be adequately managed for the period of 3 extended operations, as required by 10 CFR 4 54.21(c)(1). 5 Next slide, please. There is one TLAA 6 open item from the 2013 SER with open items that we 7 closed in this 2013 SER -- or 2016 SER. In 8 reviewing the effects of thermal aging on CASS, the 9 staff was concerned that the Applicant's thermal 10 embrittlement evaluation of CASS material in the 11 leak-before-break piping relied upon an evaluation 12 and data from 1983. The staff issued RAIs between 13 April 2011 and November 2013 and documented its 14 concerns as an open item in the 2013 SER with open 15 items. 16 In response, the Applicant stated that 17 the referenced material, fractured toughness 18 properties, for their evaluations are shown to be 19 bounding. In addition, the Applicant revised its 20 LRA to identify the fracture mechanics evaluation 21 as a TLAA and dispositioned it in accordance with 22 10 CFR 51.21(c)(1) as an analysis that remains 23 valid for the period of extended operation. 24 The staff confirmed that the Applicant 25 134  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  used a bounding fractured toughness value for its 1 leak-before-break analysis, and that the fractured 2 toughness used is applicable to 60 years. 3 Therefore, the staff concluded that the revisions 4 to the LRA are acceptable, and the open item is 5 closed. 6 Mr. Skillman, do you have more 7 questions?  We have our technical reviewer in the 8 audience. 9 CHAIRMAN SKILLMAN:  No. You have 10 addressed the question that I raised earlier. 11 MS. JAMES:  Okay. 12 CHAIRMAN SKILLMAN:  I'm good. Thank 13 you. 14 MS. JAMES:  The next slide, please. 15 Pending the satisfactory resolution of the open 16 item, the staff will determine whether the 17 requirements of 10 CFR 29(a) have been met for the 18 license renewal for South Texas Project Units 1 and 19 2. 20 This concludes our staff presentation, 21 and we will now be available for any further 22 questions from the Subcommittee. 23 Thank you. 24 CHAIRMAN SKILLMAN:  Lois, thank you. 25 135  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Colleagues, I invite any questions you 1 might have for the staff at this time. 2 (No response.) 3 Hearing none, I have one. There is a 4 very interesting discussion in the Safety 5 Evaluation about whether or not there are vent 6 valves on the aux feedwater pumps. And when you 7 read the text, the text is convoluted. First of 8 all, it says there are some, then there aren't 9 some. Then, some are in and some are out. And I 10 am wondering if anybody can speak to this. 11 MS. JAMES:  Okay. Your question is, do 12 the feedwater pumps have vent valves? 13 CHAIRMAN SKILLMAN:  Aux feedwater 14 pumps. 15 MS. JAMES:  Aux feedwater pumps have 16 vent valves and are they or are they not within the 17 scope of license renewal? 18 CHAIRMAN SKILLMAN:  Yes, and it is page 19 127 in the PDR file of the SER. I don't need to 20 read the text. It just seems as though there was 21 an awful lot of traffic on this subject, and I 22 found it extremely confusing. And I said, oh, wait 23 a minute, most of these pumps do have some kind of 24 a vent valve. Most of them have some valves on 25 136  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  piping that is connected to the casing. So, it is 1 not a substance of issue, but I found the text in 2 the SER very -- 3 MS. JAMES:  Confusing? 4 CHAIRMAN SKILLMAN:  -- confusing. 5 MS. JAMES:  Okay. Well, first, I will 6 take an action item to try to make sure we do 7 something with that in the Final SER. 8 CHAIRMAN SKILLMAN:  It is 127 in the 9 PDR file. 10 MS. JAMES:  Is that Section 2 of the 11 SER? 12 CHAIRMAN SKILLMAN:  This is. 13 MS. JAMES:  It has got to be. 14 CHAIRMAN SKILLMAN:  It's -87. 15 MS. JAMES:  2-, yes. 16 CHAIRMAN SKILLMAN:  2-87 is the text 17 page. 18 MS. JAMES:  Okay. I guess at this 19 point I'm going to have to take that as a takeaway. 20 CHAIRMAN SKILLMAN:  If you would. 21 MS. JAMES:  Yes. 22 MEMBER STETKAR:  Maybe South Texas can 23 tell us whether or not, indeed, the aux feedwater 24 pumps have vents. 25 137  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  CHAIRMAN SKILLMAN:  Yes. 1 MR. GIBBS:  We have vent valves. 2 MEMBER STETKAR:  You actually have to 3 tell us on the record. 4 (Laughter.) 5 MS. JAMES:  Yes. And identify 6 yourself, too. Thank you. 7 CHAIRMAN SKILLMAN:  For those of us who 8 were plant operators, you would think there is 9 probably a vent valve out there, maybe two. 10 MR. GIBBS:  Yes. Ron Gibbs, South 11 Texas operations. 12 Yes, we have vent valves on the aux 13 feedwater pumps. I don't want to lead anybody 14 anywhere, but we installed extra connections for 15 our flex. And maybe that is some of the confusion, 16 how the drawings got updated during this time 17 period. So, we will follow up with Lois to make 18 sure we get the right answer. 19 CHAIRMAN SKILLMAN:  This is not a 20 substantive item, but I was being thorough, and I 21 would certainly like to understand what you are 22 communicating on page 2-87, please. 23 MS. JAMES:  Okay. 24 CHAIRMAN SKILLMAN:  Thank you. Sir, 25 138  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  thank you. 1 MS. JAMES:  And we will respond to you, 2 but we will also update the SER. If you had the 3 question, I am sure someone else had the question. 4 CHAIRMAN SKILLMAN:  Okay. Thank you. 5 MS. DIAZ:  For the purposes of the 6 staff, could you restate the question? 7 MS. JAMES:  Restate the question? 8 MS. DIAZ:  Yes. 9 MS. JAMES:  Okay. I was asked to 10 restate the question. The question is, based on 11 the writeup on page 2-87 of the SER, it was 12 confusing as to whether or not there were vent 13 valves on the aux feedwater pumps and were those 14 vent valves within scope of license renewal? 15 CHAIRMAN SKILLMAN:  That is the 16 question. Thank you. 17 MS. JAMES:  And we will have to get 18 back to you on that. 19 CHAIRMAN SKILLMAN:  Thank you. 20 Colleagues, at this point the staff has 21 completed their presentation. Do any of you have 22 comments for the staff, please? 23 MEMBER KIRCHNER:  Dick, I have just a 24 question. I can't find it in the SER now. I 25 139  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  believe that tests were done on the baffle region 1 for vibration of reactor internals. Can you or the 2 Applicant report back on that?  It is relevant to 3 Matt's earlier question about baffle bolts and what 4 you may have found as a result of that testing. I 5 think you did a scale model test of the conforming 6 region, the baffle conforming region. I just can't 7 find it. I know it is here in the SER and I can't 8 find it. 9 MS. JAMES:  Okay. Jim Medoff is coming 10 to the microphone for the staff. 11 MR. MEDOFF:  This is Jim Medoff of the 12 staff. I was the lead for the reactor internals 13 and I had some assistance with Mark Hughes of the 14 staff. 15 One of the things we check as part of 16 the identification of TLAAs in Chapter 4.1 is 17 whether the preopt testing for initial plant 18 operations, whether any analyses associated with 19 preopt testing are TLAAs. So, we did look at that 20 for the application. We usually would -- in most 21 applications the vibrational analyses are below the 22 endurance limit for the components. So, vibrations 23 didn't come in as a TLAA for the internals. 24 That being said, we do rely on the 25 140  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  MRP-227 report and AMP XIM-16(a) for the internal. 1 Originally, this plant was one that did it under 2 commitment, but due to the delays in the aluminum 3 rods, we did make them update the LRA, update their 4 AMRs and AMPs. So now, we have reviewed the entire 5 AMP, their inspection plan, to make sure it is 6 consistent with MRP-227-A. That would include any 7 inspections of the baffle former region, including 8 the baffle formal bolts. 9 MEMBER KIRCHNER:  Thank you. 10 MR. MEDOFF:  Any more questions on 11 that? 12 CHAIRMAN SKILLMAN:  No, sir. Thank 13 you. 14 Walt, thank you. 15 Colleagues, any other questions at this 16 point for the staff? 17 (No response.) 18 Hearing none, I would ask everybody to 19 remain in place. What we are going to do is to 20 open the phone line. 21 MR. HOWARD:  The bridge is open. 22 CHAIRMAN SKILLMAN:  The bridge is open. 23 Before we go to those who may be on the phone line, 24 I would like to ask if there are any individuals in 25 141  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  the audience that would like to make a statement, 1 please. 2 (No response.) 3 Seeing none, ladies and gentlemen, the 4 bridge line is open. If any individual is out 5 there, would you just please communicate that you 6 are there? 7 MR. GAVULA:  This is Jim Gavula. 8 CHAIRMAN SKILLMAN:  Good morning, sir. 9 Thank you. 10 Anybody else out there? 11 (No response.) 12 No? 13 For anyone that is on the line, would 14 you care to make a comment, please? 15 (No response.) 16 Hearing none, please close the bridge 17 line. 18 I would like to go around the room with 19 my colleagues to determine if there are any more 20 comments that my colleagues may have. 21 Ron, may I start with you? 22 MEMBER BALLINGER:  No further comments. 23 I think I have badgered them enough. 24 CHAIRMAN SKILLMAN:  Thank you, Ron. 25 142  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  Pete? 1 MEMBER RICCARDELLA:  Likewise. 2 CHAIRMAN SKILLMAN:  Thank you. 3 Steve? 4 DR. SCHULTZ:  I have no further 5 comments. I would like to thank the staff and the 6 Applicant for the discussions. Thank you. 7 CHAIRMAN SKILLMAN:  Okay. Dana, 8 anything? 9 MEMBER POWERS:  No. 10 CHAIRMAN SKILLMAN:  Matt? 11 MEMBER SUNSERI:  I appreciate the staff 12 and the Applicant's participation today, and it was 13 helpful to understand what is going on. Thank you. 14 CHAIRMAN SKILLMAN:  Thank you. 15 John? 16 MEMBER STETKAR:  Nothing more. Thank 17 you. 18 CHAIRMAN SKILLMAN:  Walt? 19 MEMBER KIRCHNER:  Thank you to the 20 presenters. 21 CHAIRMAN SKILLMAN:  Okay. Our 22 Designated Federal Official, Ken Howard, any 23 questions or comments at this point? 24 MR. HOWARD:  None. 25 143  NEAL R. GROSS  COURT REPORTERS AND TRANSCRIBERS  1323 RHODE ISLAND AVE., N.W. (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433  CHAIRMAN SKILLMAN:  Okay. To all who 1 have participated and traveled, thank you very 2 much. I wish you a safe journey home. 3 And with that, this meeting is 4 concluded. 5 (Whereupon, at 11:20 a.m., the meeting 6 was adjourned.) 7  8  9  10  11  12  13  14  15  16  17  18  19 SOUTH TEXAS PROJECTAdvisory Committee on Reactor Safeguards License Renewal Subcommittee Meeting November 17, 2016 Dave RencurrelSenior Vice President Operations2
1 1
*Introductions*Station Ownership and Operation*Site and Station Description *License Renewal, GALL Consistency and Commitments*Safety Evaluation Report Open ItemoAluminum Bronze Selective Leaching*Concluding RemarksSOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 20163Agenda SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 20164PERSONNEL IN ATTENDANCEDave Rencurrel Senior Vice President OperationsMichael Murray Manager Regulatory AffairsMike Berg Manager EngineeringRon GibbsManager Operations Arden Aldridge License Renewal Project LeadPlant StaffAMP Subject Matter Experts,  Licensing, Chemistry, Systems Engineering,  Design Engineering,  andPrograms Engineering Specialty Consultants Introduction Operated by STP Nuclear Operating Company (STPNOC) STP Units 1 and 2 are owned by:*NRG South Texas LP*The City Public Service Board of San Antonio (CPS Energy)*The City of Austin, Texas (COA)SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 20165Station Ownership and Operation SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 20166Plant History & Major InvestmentsSouth TexasUnit 1Unit 2Initial License August 21, 1987Dec 16, 1988Steam Generator Replacement20002002Low Pressure Turbine upgrade20062004Replaced RX heads 20092010Main Generator Stator rewind20142012Non-welded Stress Improvement Process  (RPV)20172019Expiration of current LicenseAugust 20, 2027Dec 15, 2028 Ron GibbsManager OperationsSite and Station Description7 SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 20168SITE DESCRIPTION SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 20169STATION DESCRIPTION Arden AldridgeLicense Renewal Project LeadLicense Renewal Application10 SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201611License Renewal Application License Renewal Application (LRA) submitted to NUREG 1801 rev 110/2010NUREG 1800 and 1801 Revision 2 issued12/2010Scoping & Screening, AMP Audits completed 06/2011Scoping & Screening, AMP Inspection completed08/2011Annual Updates 2011, 2012, 20132011-2013Issued initial safety evaluation report (SER) with open item(s)02/2013Safety review paused2/2013-12/2013RAI's, LR-ISG incorporation into LRA1/2014-PresentAnnual Updates 2014, 2015, 20162014-2016Issued safety evaluation report (SER) with open item10/2016
2 3
*Total Aging Management Programs -41*Existing Programs -33  (3) plant specific*New Programs -8 (1) plant specific*Plant Specific -Nickel-Alloy -PWR Reactor Internals -Protective Coating Monitoring and Maintenance  -Selective Leaching of Aluminum Bronze        *Aging evaluations are greater than 90% consistent with GALL Rev 1 and greater than 95% consistent with GALL Rev 2 (standard notes A through E)*GALL Revision 2 lessons learned incorporated through license renewal application supplement and reviewed by the NRC using Standard Review Plan Rev 2.SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201612Aging Management Programs and GALL Consistency TableSOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201613GALL ConsistencyAMPSAMPS ConsistentAMPS Consistent with EnhancementsAMPS Consistent with Exception &  EnhancementsAMPS with ExceptionsPlant SpecificNew  (8)341Existing  (33)    5131113Total AMPS (41)
4                              DISCLAIMER 5
License Renewal commitments -46 total-Program Enhancements (4 complete, 26 open)-Program Implementation (1 implemented , 9 open)-Replace 6 Standby Emergency Diesel Generator bellows (open)-Remove Safety Related Check Valve Seal Caps (complete)-Review NUREG/CR-6260 (Enhanced Fatigue Monitoring locations (open)-Take ground water samples for 24 consecutive months to assure non aggressive (complete) -Calculate Essential Cooling Water leakage rates to validate maximum flaw size (complete)-One time internal inspection of Unit 1 Refueling Water Storage Tank (RWST) bottom and side welds.  (open)SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201614License Renewal Commitments License Renewal commitments are included in UFSAR Supplement (Appendix A to the LRA) and managed through the STP Condition Reporting and Licensing Commitment Management and Administration processes.SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201615License Renewal Commitments and Implementation Safety Evaluation ReportOpen ItemMike Berg Engineering Manager16 SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201617OI 3.0.3.3.3-2 Aluminum Bronze Selective Leaching Wrought Material is non-SusceptibleSusceptible Component Population -Will be replaced with non-susceptible material prior to period of extended operation Welds or weld-repairs with susceptible weld filler material will be managed*piping butt-welds *weld repairs on extruded teesSOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201618Selective Leaching of Aluminum Bronze Background STP responded to the NRC's open items related to Selective Leaching of Aluminum Bronze AMP by letter dated September 28, 2016, "NOC-AE-16003403". OI 3.0.3.3.3-2 Identified ten open issues requiring closure. Nine of the ten open issues have been addressed. The final issue is still open but a pathway forward has been identified to assure timely resolution.SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201619Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8        ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9
Addressed Issues:1. Added information to bound extruded piping tee repairs 2.Clarified the parameters monitored to address loss of material, cracking, and phase distribution.3. Clarified the sample size for volumetric inspectionsOne-time examination of weldsPeriodic examination of welds 4.Clarified the threshold for the number of defective welds resulting in further inspections5.Identified selection criteria for weld inspectionsSOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201620Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
10 11          The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.
Addressed Issues:6. Determined there was no impact of the external coatings regarding detecting buried piping leaks at the surface. 7. Identified a method to monitor or trend results8. Defined the acceptance criteria for weld defectsVisual inspectionVolumetric examinationDestructive examination 9.Identified the threshold for increased inspections when adverse inspection results are detected10. Identified the corrective actions to address all potential inspection results.SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201621Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
16 17          This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.
Remaining Open Issue: 10. Corrective actions do not address all potential inspection results.Followupquestion is being developed by the NRC. Initial communication of the concern supports a pathway forward and timely response and resolution. SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201622Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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==
1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
Conclusion:==
                                + + + + +
Following the resolution of the remaining issue related to corrective actions, the Selective Leaching of Aluminum Bronze Aging Management program will effectively manage aging of the Essential Cooling Water cast components and welds during the extended period of operation.SOUTH TEXAS PROJECT  ACRS SUBCOMMITTEE November 17, 201623Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)
Dave RencurrelSenior Vice President OperationsConcluding Remarks24 END25 Advisory Committee on Reactor Safeguards License Renewal Subcommittee South Texas ProjectSafety Evaluation Report (SER) with Open ItemsNovember 17, 2016Lois M. James, Senior Project ManagerOffice of Nuclear Reactor Regulation Presentation Outline*Overview of South Texas Project (STP) license renewal review*Region IV 71002 Inspection, License Renewal Inspection*SER Section 2, Scoping and Screening Review*SER Section 3, Aging Management Review*SER Section 4, Time-Limited Aging Analyses*Conclusion2 License Renewal Review (Audits and Inspections)*Scoping and Screening Methodology Audit-May 15 -19, 2011(Onsite)*AgingManagement Program (AMP) Audit-June 13 -24, 2011 (Onsite)*Aluminum Bronze Selective Leaching AMP Audits-February 29, 2012 (Rockville)-March 9 -13, 2015 (Onsite)
                                + + + + +
-March 21 -23 (Onsite) and June 22, 2016 (Rockville)*Region IV 71002 Inspection (Scoping and Screening & AMPs)-August 8 -25, 2011 (Onsite)3 SEROverview*SER with Open Item (OIs) issued in 2013*SER with OIs issued in 2016-Closed the OIs from 2013 -Opened OI 3.0.3.3.3-2 -Insufficient details provided regarding applicant's Selective Leaching of Aluminum Bronze AMP4 71002 Inspection*Scope*Non-Safety Systems affecting Safety Systems*Aging Management Programs*Inspection *August 8 -August 25, 2011*Team Inspection on-site for 2 weeks5 6*Results-Good material condition of structures, systems and components-Two implementing procedures changed
PLANT LICENSE RENEWAL SUBCOMMITTEE
-Two Aging Management Programs Changed
                                + + + + +
-Revised Commitments and Corresponding Changes for five Aging Management Programs71002 Inspection 71002 Inspection*Conclusions-Scoping and screening performed in accordance with 10 CFR 54-Information easily retrievable and auditable
THURSDAY NOVEMBER 17, 2016
-Existing programs effectively managed aging effects
                                + + + + +
-Corrective and other actions being tracked for completion-Reasonable assurance that aging effects will be managed and intended functions maintained7 SER Section 2*Structures and Components Subject to Aging Management Review-Section 2.1, Scoping and Screening Methodology-Section 2.2, Plant-Level Scoping Results
ROCKVILLE, MARYLAND
-Sections 2.3, 2.4, 2.5 Scoping and Screening Results8 SER Section 3*Aging Management Review Results-Section 3.1, Aging Management of Reactor Vessel, Internals, and Reactor Coolant System-Section 3.2, Aging Management of Engineered Safety Features
                                + + + + +
-Section 3.3, Aging Management of Auxiliary Systems
The    Subcommittee          met    at the Nuclear Regulatory Commission, Two White Flint North, Room T2B1, 11545 Rockville Pike, at 8:30 a.m., Gordon R.
-Section 3.4, Aging Management of Steam and Power Conversion Systems-Section 3.5, Aging Management of Containments, Structures and Component Supports -Section 3.6, Aging Management of Electrical Commodity Group9 SER Section 3Applicant's Disposition of AMPs*8 new programs3 consistent4 consistent with exceptions1 plant specific*32 existing programs6 consistent13 consistent with enhancements3 consistent with exception8 consistent with enhancements and exceptions2 plant specific*1 existing program added1 plant specificFinal Disposition of AMPs in SER with OIs*8 new programs3 consistent 4consistent with exceptions1 plant specific*33 existing programs5 consistent14 consistent with enhancements1 consistent with exceptions10 consistent with enhancements and exceptions3 plant specificNote: The staff received and is reviewing the 2016 annual update. The final SER will be updated based on the staff's review.103.0.3-AgingManagementPrograms SER Section 3Open Items ClosedOI3.0.3.2.6-2:  Management of fouling of downstream components due to coating degradations upstream*Concern:  AMP may be inadequate*Resolution:  AMP was revised in accordance with staff's guidance in ISG-2013-01, "Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks."OI3.0.3.1.4-1:  Cracking in Unit1 Reactor Water Storage Tank (RWST)*Concern:  No AMP *Resolution:  Revised the One-Time Inspection AMP to include the internal surfaces of the Unit 1 RWST; and revised External Surfaces AMP to include visual inspections of the Unit 1 RWST every refueling cycle.11 Aluminum Bronze Overview*Applicant revised AMP in September 2016.*Replacing all susceptible piping components that have exhibited leakage except for susceptible weld material joining nonsusceptible piping components.*Applicant proposed a basis for why butt welds have not experienced leakage since 1994.-Root pass less susceptible: dilution and cool down rate
Skillman, Chairman, presiding.
-Root pass acts as a barrier
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-No construction related or service induced flaws in root pass, barrier remains intact*Root pass as a barrier seemed plausible; however, basis lacked sufficient data to substantiate12 Staff ConclusionsBased on review of tests and examinations conducted by the applicant, and the review of technical literature by the staff:*Microstructure level dealloying process is confined to a localized front that scales with the grain size. *Material on either side of the dealloying front is either in the as-received or fully dealloyed condition.*Insufficient data to establish lower bound mechanical properties for dealloyed aluminum bronze.*No strength or fracture toughness credit should be given to dealloyed material.13 Program Element OverviewSeptember 2016, AMP revised to address most of the OI*Detection of aging effects:-Volumetric inspections and destructive examinations
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-Visual inspections for leakage
 
-Opportunistic buried pipe coating inspections*Acceptance criteria:-Planar defect and dealloying
2 COMMITTEE MEMBERS:
-Microstructure of the weld root region
GORDON R. SKILLMAN, Chairman PETER RICCARDELLA, Member-at-Large RONALD G. BALLINGER, Member WALTER L. KIRCHNER, Member DANA A. POWERS, Member JOHN W. STETKAR, Member MATTHEW W. SUNSERI, Member ACRS CONSULTANT:
-Monthly walkdowns14 Program Element Overview, cont.Corrective Actions:*Additional volumetric and destructive examinations
STEPHEN SCHULTZ DESIGNATED FEDERAL OFFICIAL:
*Structural integrity calculations conducted with as-found conditions*Structural integrity analysis fails -additional inspections by ultrasonic testing (UT) technique capable of detecting loss of material due to selective leaching -Associated Request for Additional Information (RAI) for further information15
KENT HOWARD ALSO PRESENT:
*Time-Limited Aging Analyses-4.1, Identification of Time-Limited Aging Analyses (TLAA)-4.2, Reactor Vessel Neutron Embrittlement Analysis
ARDEN ALDRIDGE, STP NOC MIKE BERG, STP NOC RUSS CIPOLLA, Intertek PHYLLIS CLARK, NRR/DLR YOIRA DIAZ, NMSS/DSFM ROB ENGEN, STP NOC MICHAEL GARNER, STP NOC JIM GAVULA, NRR*
-4.3, Metal Fatigue Analysis
DAVE GERBER, SIA RON GIBBS, STP RAFAEL GONZALES, STP NOC ALLEN HISER, NRR/DLR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
-4.4, Environmental Qualification of ElectricEquipment-4.5, Concrete Containment Tendon Prestress Analyses
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-4.6, Containment Liner Plate, Metal Containment, and    Penetrations Fatigue Analyses-4.7, Other Plant-Specific TLAAsSER Section 416 SER Section 4 Open Item ClosedOI4.3.2.11-1:  Effects of thermal aging on cast austenitic stainless steel (CASS):*Concern:  Leak-Before-Break (LBB) TLAA may not be dispositioned correctly*Resolution:  Revised LRA Section4.3.2.11 to identify the fracture mechanics evaluation as a TLAA and disposition it in accordance with 10 CFR 54.21(c)(1)(i); and the material fracture toughness properties selected for use in the LBB analysis are sufficiently embrittled that they bound the amount of thermal embrittlement that will occur in 60years. 17 ConclusionPending satisfactory resolution of the Open Item, the staff will determine whether the requirements of 10CFR54.29(a) have been met for the license renewal of STP.18  
 
}}
3 WILLIAM HOLSTON, NRR MATTHEW HOMIACK, NRR LOIS JAMES, NRR/DLR RAIHAN KHONDKER, STP NOC BRET LYNCH, WP JANE MARSHALL, NRR TODD MAXEY, STP JAMES MEDOFF, NRR/DLR MIKE MURRAY, STP NOC CHANCEY PENCE, STP NOC GREG PICK, Region IV DAVE RENCURREL, STP BILL ROGERS, NRR/DLR DAN SICKING, STP NOC RICK STARK, STP NOC DAVID STUHLER, STP NOC MIKE SVETLIK, STP MARK WALES, STP NOC GARY WARNER, WP DAVE WIEGAND, STP NOC JAMES WILLIAMS, STP NOC PRESTON WILLIAMS, STP NOC JAMES C. YOUNGER, STP NOC KEVIN REGIS, STP NOC
*Present via telephone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 C-O-N-T-E-N-T-S Call to Order and Opening Remarks..................5 Staff Introduction.................................6 South Texas Project Nuclear Operating..............7 Company (STPNOC) - South Texas Project, Units 1 and 2 (STP)
NRC Staff Presentation SER with Open..............80 Items Overview Opportunity for Public Comment...................133 (None)
Committee Discussion.............................134 Adjourn NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1                      P R O C E E D I N G S 2                                                              8:29 a.m.
3                 CHAIRMAN SKILLMAN:              (presiding)      Ladies 4 and gentlemen, good morning.               This meeting will now 5 come to order.
6                 I am Gordon Skillman.              I am Chairman of 7 the Plant License Renewal Subcommittee.
8                 The    Subcommittee            will    review        the 9 license renewal application for South Texas Project 10 Units 1 and 2.
11                  ACRS    members      in   attendance      today      are 12 Dana      Powers,  John    Stetkar,      Ron      Ballinger,    Peter 13 Riccardella, Walt Kirchner, and Matt Sunseri.                          Our 14 ACRS      consultant  Dr. Stephen      Schultz      is also      in 15 attendance.          Kent    Howard      of    the    ACRS  is     the 16 Designated Federal Official for this meeting.
17                  This morning we will hear presentations 18 from the Division of License Renewal, Region IV, 19 and      South  Texas    Nuclear      Operating        Company,      the 20 Applicant,        regarding          this        matter.           This 21 Subcommittee        will      gather      information,        analyze 22 relevant issues and facts, and formulate proposed 23 positions        and    actions,        as      appropriate,        for 24 deliberation by the full Committee.
25                  The rules for participation in today's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 meeting have been announced as part of the notice 2 of this meeting published in The Federal Register.
3 We have not received written comments and requests 4 for time to make oral statements from members of 5 the      public        regarding          today's       meeting,     and      the 6 entire meeting will be open to public attendance.
7                      There will be a phone bridge line.                          To 8 preclude          interruption            of   the    meeting,    the    phone 9 will      be    placed        in    a  listen-in        mode  during      the 10 presentations and Committee discussion.
11                      A transcript of this meeting is being 12 kept      and      will      be    available,        as    stated    in      The 13 Federal Register notice.                     Therefore, I request that 14 participants            in    this    meeting      use    the  microphones 15 located throughout the meeting room when addressing 16 the Subcommittee.                   The participants are requested 17 to      please        identify          themselves          and    speak      with 18 sufficient clarity and volume, so that they can be 19 readily heard.
20                      I    also        request      that      all  attendees 21 please silence your personal electronic devices.
22                      We will now proceed with the meeting, and I call upon 23 Jane Marshall to begin the presentation.
24                      Thank you, Chairman Skillman.
25                      As stated, I am Jane Marshall.                    I'm the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 Acting Director for the Division of License Renewal 2 in the Office of Nuclear Reactor Regulation.                          With 3 me here today are members of my management team and 4 several members of my staff.                     They will introduce 5 themselves as they answer questions today.                           Also 6 joining us by phone is Greg Pick, who is the Lead 7 Inspector from Region IV.
8                    The staff's presentation will be given 9 by      Lois    James,    who    is    the    South    Texas  Project 10 Safety Project Manager.               She will be joined at the 11 table        by  DLR  Senior    Technical        Advisor  Dr. Allen 12 Hiser and Senior Mechanical Engineer Bill Holston, 13 as well as Safety Project Manager Phyllis Clark.
14                    At  today's      ACRS    Subcommittee    meeting, 15 the staff will present its review and resolution 16 path for the open item for the license renewal of 17 South Texas Project Units 1 and 2.                     The information 18 we will be presenting was documented in the Final 19 SER.
20                    At this time, I would like to turn the 21 presentation        over    to   South    Texas    Project  Nuclear 22 Operating Company and Dave Rencurrel, Senior Vice 23 President for Operations, to introduce his team and 24 commence their presentation.
25                    Thank you.
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8 1                    MR. RENCURREL:         Good morning.
2                    Yes,    as   you    said,      my  name    is    Dave 3 Rencurrel.            I  am    from    South      Texas,  Senior      Vice 4 President of Operations.
5                    I    really      would      like      to    take      this 6 opportunity to thank the ACRS Subcommittee for our 7 opportunity to present our overview of our license 8 renewal application, and we do look forward to your 9 questions.
10                    But,    before      we    get    started,    I    would 11 also like to thank the NRC reviewers for their hard 12 and diligent work in this process and for everybody 13 on the staff, everybody from South Texas, who has 14 also worked very hard in this process.
15                    There it is.            All right.         As you can 16 see, here is an overview of the agenda, which we 17 will be presenting today.                     I would like to point 18 out that we are setting aside a really special time 19 or focused time to discuss the Safety Evaluation 20 Report        open    item    for    aluminum        bronze    selective 21 leaching.
22                    With that, I would like to move into 23 the      introductions        of   the    team      that  we  brought 24 today.         I will start and, then, we will just move 25 to the left and move down our line.
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9 1                   Now  my    name,      as      I  said,  is    David 2 Rencurrel.            I'm    the    Senior        Vice  President        of 3 Operations.
4                    I began my career over 35 years ago, my 5 nuclear career over 35 years ago in 1981, when I 6 started        in  the United      States      Navy  as a   nuclear 7 officer.        In 1988, I joined the South Texas Project 8 and, since then, I have had many different jobs.                            I 9 got hired in as a young system engineer.                          I have 10 went      through    license      class,        spent  time    in      the 11 control room as a shift technical advisor.                        I spent 12 time        as  a  work    control      supervisor,        worked        in 13 maintenance,          system      engineering          manager,    design 14 manager.        I was ops manager for a little bit over 15 four years, VP of Engineering and Projects, Site VP 16 for over four years.              Now I am in my current role 17 where        I  am  responsible        for      all  projects      here 18 onsite.
19                    I  would    like      to      hand  off  to      Mike 20 Murray.
21                   CHAIRMAN SKILLMAN:              Not so fast, Dave.
22 You have a lofty position, huge influence at the 23 site and in the company.                  What is your vision of 24 the importance of 10 CFR 50 Appendix B?
25                    MR. RENCURREL:              I  think    that        is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 extremely important.              10 CFR 50 Appendix B is what 2 gives us that consistency and that credibility that 3 we all want.          I think that is where that comes from 4 in that regard.
5                    CHAIRMAN      SKILLMAN:            I  asked      the 6 question because in the course of time those of us 7 who      have    been  in    industry      for    a long  time    have 8 watched the devotees of 10 CFR 50 Appendix B fall 9 away.        There is always somewhat of a move to cut a 10 corner here or cut a corner there and not recognize 11 how important the 18 points of that regulation are 12 --
13                    MR. RENCURREL:        Yes, sir, I understand.
14                    CHAIRMAN SKILLMAN:              -- to the materiel 15 condition of the unit and to the culture of the 16 unit.        And so, my question is, how vigilant are you 17 of that?        And what is the shadow that you cast on 18 your organization?
19                    MR. RENCURREL:          So, what is -- that is 20 the quality, right?
21                    CHAIRMAN SKILLMAN:            Yes, yes.
22                    MR. RENCURREL:          That's what I thought.
23 So, here's what we do in regards to independent 24 oversight of their station.                  Independent oversight, 25 obviously, we have the right dedication and right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 resources assigned to that.                  They act independently 2 in that they report up to a company officer.                              All 3 right.            We    ensure      that      they      have    a      very 4 professional relationship with the staff, that they 5 are honored by the staff and listened to by the 6 staff, that they have the capability to measure our 7 not      just    compliance,      but    also      our    drive  towards 8 excellence.
9                    We    also    have      monthly        reports,        for 10 example, that come up to the executives where they 11 get      to  talk    about    oversight        or    the  vision        of 12 oversight        of    performance          of      how    the    station 13 performs.          We have a very prescriptive program of 14 the elevation/escalation, where elevation is where 15 they bring up an issue to site leadership, plant 16 manager        and    such,      where      they      can  talk      about 17 prolonged gaps or gaps that aren't being closed.
18 And then, it subsequently goes to escalate, if that 19 doesn't        get    solved,      where,        depending      upon      the 20 level, it can actually go all the way up to an 21 officer        or  a  vice    president        to    be  accountably 22 resolved.
23                    And    then,    you      roll      into    the    whole 24 concept of corrective actions and the idea of being 25 able      to  --  it  is    not    just    a    corrective      action NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 program; it is more of a program to ensure that you 2 have        proper    problem        identification          and      real 3 resolutions that solve not just the symptom of the 4 problem,        but    the    actual      do      the    hard    work        of 5 understanding          the  cause      of  the      problem.      And      I 6 believe that is extremely important, something we 7 measure very closely for.
8                    I believe that in any organization you 9 have to have governance, proper governance, which 10 is the rules, the regulations, the traditions, the 11 meetings that we all interact with, so that you can 12 have proper oversight, so the oversight can come up 13 and        measure    how    your      governance          is  actually 14 operating        and    working.        I  believe      in  all    those 15 concepts.
16                    I also know that the folks I work with, 17 my boss, our Chief Executive Officer Dennis Koehl, 18 our Chief Nuclear Officer Tim Powell, also believe 19 very        strongly    in    the    Appendix        B,  in  the      50.B 20 program.            They    believe        very      strongly      in      the 21 corrective          action        program          and      independent 22 oversight.
23                    And  having      said    all      those  words,        in 24 conclusion,          I    would      say    plants/stations            that 25 perform          well,      stations          that        perform        with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 excellence, stations that, quite frankly, meet the 2 business          plan    needs      of    the        owners  and      the 3 shareholders          have    that    healthy      respect.      Plants 4 that don't, they don't meet those; they don't have 5 that performance and they don't meet those business 6 goals.        So, it all ties together.
7                      CHAIRMAN      SKILLMAN:          Yes,    I thank      you 8 for your explanation.                  My real question was about 9 your office and your shadow on the QA program.
10                      MR. RENCURREL:            Yes, my office and my 11 shadow on the QA program is I know the QA Manager 12 personally and I actually mentor him through his 13 roles.          I  help    him    interact        with    folks  on    the 14 station.          In my role right now, they don't report 15 to      me.        In  my    previous        roles,      they  actually 16 reported to me.              So, it was much more hands-on in 17 how things are working.
18                      My shadow is that I believe very, very 19 strongly            in    the      independence            of  QA,        its 20 independence          and    conclusion,        its    independence        in 21 their messaging, but we work closely with them in 22 ensuring that that message is presented in a way 23 that can be readily understood and accepted by the 24 staff.
25                      I spend time; I go down and talk to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 folks -- they actually sit down the hall from me.
2 I go down and visit with them a lot, pretty much 3 know just about everybody there.                          And at times I 4 have both defended them and I both chastised them.
5 So, I think I have a very good shadow.
6                    CHAIRMAN SKILLMAN:            Dave, thank you.
7                    Please proceed.
8                    MR. RENCURREL:        Okay.        Thank you.
9                    MR. MURRAY:        My name is Michael Murray.
10 I'm the Regulatory Affairs Manager at South Texas 11 Project.
12                    I  have    been    in    the      industry    for      41 13 years,        started    as    an  I&C    tech      at  the  Brunswick 14 Plant.        I have had 31 years at South Texas Project.
15 I was there for startup of both units.                          So, I have 16 a long history at South Texas Project.
17                    Various      management        positions.        I    was 18 I&C      Manager,      Systems      Engineering          Manager;    spent 19 some time working on the Units 3 and 4 licensing 20 project as I&C, the Design Manager there.                              And I 21 have      met    a  few  of    these    folks        here  during    that 22 process.            And  then,    currently,          I'm  Reg  Affairs 23 Manager at South Texas Project.
24                    MR. GIBBS:        Good      morning.        I'm      Ron 25 Gibbs.            My    current      position          is    the  Manager, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 Operations,            Shift    Operations.              I'm  the    Senior 2 License at the South Texas Project now.
3                      I've    got    over      30    years    of  nuclear 4 experience.            Started out as a unit supervisor, STA, 5 at Comanche Peak.              Came to the South Texas Project 6 in 1993.            Got my Senior Reactor Operator License 7 there        in  1995    and    worked      my    way    on  shift.        I 8 started as unit sup, STA, again, up through shift 9 manager.            Came    off    shift      in    2013    into    an    ops 10 manager role and took over as the Senior License 11 January of this year.
12                      MR. ALDRIDGE:          Good morning.          My name 13 is Arden Aldridge.
14                      I have been in the nuclear service for 15 about 38 years.            I started in the nuclear submarine 16 service, consultation with some consulting groups, 17 and then, with two utilities.
18                      For the last 22 years, I have been at 19 South Texas Project fulfilling various engineering 20 roles and functions.                In the last 10, I have been 21 focused        on    license    renewal      applications,        helping 22 our      peer    plants    prepare        three      application      from 23 preparation to approval.                    In the last five years, 24 it has been focused as the project lead and the 25 Implementation Coordinator for South Texas.
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16 1                    CHAIRMAN SKILLMAN:              Thank you.
2                    MR. BERG:          Good morning.            I'm Michael 3 Berg.          I'm the Engineering Manager of Design and 4 Programs.
5                    I  have      got    38    years      in  the  nuclear 6 industry, 34 years at South Texas Project.                            I was 7 one      of    the  original      engineering          supervisors      that 8 took        over    design      control      from      the    architect 9 engineer.
10                    I have had various manager roles over 11 the past 25 years and I was the manager over the 12 STP initial license renewal application submitted.
13                    CHAIRMAN        SKILLMAN:            Gentlemen,      thank 14 you.      Please proceed.
15                    MR. RENCURREL:          Okay.        What  I    would 16 like to do now is give a brief station ownership, 17 overview of station ownership and operation.
18                    South    Texas      Project      Nuclear    Operating 19 Company        is  the  licensed        holder        for  the  station.
20 The station is actually owned by three different 21 companies,        Energy    Texas,      which      is    an  investment-22 owned        utility;    the      City      Public        Services,      San 23 Antonio,        which  is    owned    by  the      municipality      San 24 Antonio, Texas, and Austin Energy, which is owned 25 by the City of Austin.                    So, we are owned by one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 investor        and  two    municipalities.              To  put      our 2 generation        in  context,        over      25    percent    of      the 3 carbon-free        electric      generation          in  the  State        of 4 Texas is produced at South Texas.
5                  CHAIRMAN      SKILLMAN:            And  you    get      no 6 credit for that whatsoever.
7                  (Laughter.)
8                  MR. RENCURREL:        Yes, sir.
9                  To go over our plant history and some 10 major investments, we received our initial license 11 in 1987 and 1988, respectively, for Unit 1 and Unit 12 2.        Since that time, we have made major capital 13 investments.              We    have      replaced          our      steam 14 generators,        all    four    in    each        unit.      We      have 15 replaced        our  low-pressure          turbines.            We      have 16 replaced both reactor vessel heads in both units.
17 We have also rewound our main generator stators and 18 have        replaced    the    rotors,        the      main    generator 19 rotors, in both units.
20                  Looking        forward,            we      have        main 21 transformers done on one unit, but we are replacing 22 the main transformers in the other unit in the next 23 outage, and we are working through the replacement 24 of our feedwater heaters that show that there is an 25 ongoing investment in the major improvements of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 plant. Also, as you can see there, the non-welded 2 stress improvement process is being put in place, 3 and that is going to go down in 2017 and 2019.
4                    The way our governance works is that we 5 have a business plan.                And the way that the owners 6 commit        to  the    long-term        safe      operation      of      the 7 station is via that business plan.                          This business 8 plan is approved annually for the next five years' 9 spend.
10                    And so, in a sense, what goes on is the 11 money is allocated or set aside for the next five 12 years' worth of capital investments.                          However, our 13 plant        investment      plan    itself      goes    out  20    years 14 where        we  have  levelized        out    and      put  in  all      the 15 capital improvements and all the capital necessary 16 to move forward.
17                    If  you    look    at    our      plant  investment 18 plan,        you    will    see    that      our      owners,    we      have 19 identified        and    our    owners      have      committed    to    the 20 capital        monies    necessary        to    implement      the    aging 21 management plan.            And so, there is that commitment, 22 not just in words, but in treasure, in regards to 23 implementing the extended license and safely moving 24 into the extended period of operation.
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19 1 to Ron Gibbs, our ops manager.
2                    MR. GIBBS:      Good.      Thank you, Dave.
3                    This morning I will be giving a brief 4 description          of  the    South      Texas      Project  site      and 5 station design.
6                    South Texas Project is located about 90 7 miles southwest of Houston.                    You see the star here 8 on    the      Texas  map    gives      a  representation        of    our 9 location.          Here in the center of this aerial map 10 you can see is the South Texas Project site.                            It is 11 about 12,000 acres.                As you can see also in this 12 aerial view, it is largely a rural area, a lot of 13 farming in our community.                  We are Matagorda County 14 and about 15 miles inland from the Gulf of Mexico.
15                    The  large    body      of    water    here    in    the 16 center is our main cooling reservoir.                          Makeup from 17 our main cooling reservoir is the Colorado River 18 you can see here -- that is the main source -- and, 19 also, rainwater.
20                    Our station, here is our main cooling 21 reservoir again on the top of the picture.                                  Our 22 essential cooling water pond here is on the bottom.
23 That        is    commonly      called      service      water    in      the 24 industry,          and  this    is    our    ultimate      heat    sink.
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20 1 means of makeup and rainwater.
2                  Just to the right here you can see our 3 switchyard.        We have nine 345-KV lines coming into 4 and out of the switchyard.                And the units here are 5 in      the    center  of    the    pictures.          We  have      two 6 Westinghouse        four-loop        PWRs,      Pressurized      Water 7 Reactors.          Our    thermal      rate      of    power  is    3853 8 megawatts        thermal    with    a  design      output  of    1250 9 megawatts electric.
10                  CHAIRMAN SKILLMAN:              Ron, the essential 11 service water pond there fed from wells, does that 12 mean that that is freshwater --
13                  MR. GIBBS:      Yes.
14                  CHAIRMAN      SKILLMAN:            --  compared      with 15 brackish water?
16                  MR. GIBBS:      That's correct.
17                  CHAIRMAN SKILLMAN:                Okay. I did not 18 appreciate that when I was reading the application 19 for the safety evaluation.              Thank you.
20                  MR. GIBBS:      Okay.
21                  CHAIRMAN SKILLMAN:            Okay.
22                  MR. GIBBS:          Operators are licensed on 23 both units.        So, we can operate either unit, and we 24 utilize common operating procedures.
25                  Both  containment        structures      are    post-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 tensioned        concrete        cylinders          with  steel    liner 2 plates, hemispherical tops, and flat bottoms.
3                    Each unit has three independent safety 4 trains, including piping, valves, pumps, and diesel 5 generators,        our    emergency        supply      for  emergency 6 power.          And    each    unit    has      four  safety-related 7 auxiliary feedwater trains, three electric pumps, 8 and one steam-driven pump.
9                    And next, I will turn it over to Arden.
10                    CHAIRMAN SKILLMAN:              Let me ask you to 11 back      up  a  slide,    please.        Your      aerial,  the      Mad 12 Island, that is the wildlife management area?
13                    MR. GIBBS:      That's correct.
14                    CHAIRMAN SKILLMAN:            And so, most of the 15 population down there are alligators and critters?
16 Is that what you've got down there?
17                    MR. GIBBS:          That's correct, a lot of 18 alligators, a lot of critters.
19                    CHAIRMAN      SKILLMAN:            That's  5-6,000 20 acres, 10,000 acres, something like that?
21                    MR. GIBBS:      It itself, yes.
22                    CHAIRMAN      SKILLMAN:          Yes. Thank    you.
23 Okay.        Okay.
24                    MR. GIBBS:        Next, I will turn it over 25 to Arden to walk us through our license renewal.
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22 1                    CHAIRMAN SKILLMAN:              Right.
2                    MR. ALDRIDGE:          As I mentioned, my name 3 is      Arden    Aldridge.          I    was    the      license    renewal 4 project lead, and I would like to just go through a 5 little          chronology        of    where      we    have    been        in 6 preparation of this application.
7                    In  October      of    2010,        we  submitted        our 8 license            renewal          application              against          the 9 requirements          of    GALL    Rev. 1.        We,    then,      went 10 through the inspections and reviews.                            In 2013, we 11 received a Safety Evaluation Report with four open 12 items,        and  at  the    same    time      we    put    the    safety 13 review on hold because of the uncertainty of the 14 waste confidence role on future license decisions.
15                    Well, during the year that we put it on 16 hold      we    continued      to  work    on    the    project.          We 17 updated to GALL Rev. 2, the requirements of GALL 18 Rev.      2.      We    incorporated        lessons        learned      from 19 License          Renewal      Safety      Evaluation          Reports        and 20 performed annual updates.                    We also resolved three 21 of the open items going forward.
22                    Here we are in 2016.                  We completed all 23 the      reviews.        The    Safety    Evaluation          Report      with 24 just one open item was issued on October of 2016, 25 and that open item is the aluminum bronze that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 will talk to later in the application.
2                    On the next slide, just a description 3 of the programs, of how they have rolled out.                                  We 4 had 41 aging management programs, of which 33 of 5 them were existing programs and eight new ones.                                On 6 that slide you will see in GALL consistency we said 7 we      were    90-percent      consistent        with    the  standard 8 notes alpha through echo of GALL Rev. 1.                          However, 9 with        the    enhancements        of    GALL        Rev. 2,      that 10 consistency with GALL Rev. 2 is 95 percent against 11 the      standard    notes.      As    just    a    reminder,      on    the 12 bottom        there,  reinforcement,          we      did  get  reviewed 13 against standard review plan for GALL Rev. 2 and 14 those requirements.
15                    On    the    next      page,        STP's    program's 16 consistency        with    the    GALL    is    we    were  consistent 17 with GALL Rev. -- the consistency table is against 18 GALL        Rev. 1,    but    it    is    just        an  accounting 19 perspective.          We had 21 aging management programs 20 that are consistent with GALL.                        We have 16 aging 21 management          programs      that      are        consistent        with 22 exceptions, and we have four plant-specific aging 23 management programs.
24                    Approximately          10      of      the    16      aging 25 management programs with exceptions are due to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 addition of the requirements of GALL Rev. 2 and the 2 lessons          learned      that      we    incorporated.                  The 3 remaining exceptions would be alternate methods of 4 managing        the  aging      effects      specifically          for      the 5 programs that we developed.
6                    As    far        as    the        license      renewal 7 commitments, those are being tracked and we have 46 8 of    them.        This    slide      is  just      to  represent        the 9 different        categories      of    commitments        that    we    have 10 established.            And    up    to  this      date,      you  can      see 11 several        of  them    are    closed.          Eight    of    the      46 12 commitments          have      been      closed        or    have      been 13 completed.          That leaves us with 38 remaining to 14 implement          prior      to      the    period        of    extended 15 operation.
16                    We    have      an    implementation            plan,        a 17 schedule,        and  the    budget    that      Dave    mentioned        to 18 complete these remaining open commitments prior to 19 their        scheduled      due      dates      in      preparation          for 20 entering the period of extended operation in 2027 21 and 2028.
22                    CHAIRMAN SKILLMAN:                Before you change 23 that slide, would you give us a little tutorial on 24 your      inspections?            The    Unit      1    refueling        water 25 storage tank welds you had some leaking, outside NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 tanks?
2                  MR. ALDRIDGE:        Yes.
3                  CHAIRMAN SKILLMAN:            You repaired those.
4                  MR. ALDRIDGE:        Yes.
5                  CHAIRMAN      SKILLMAN:            You  brought      them 6 into conformance with their codes.                        You are on an 7 inspection frequency, that is, an outage inspection 8 frequency.        I don't know if that is 24 months or 18 9 months.        But it seems as though you found yourself 10 in a predicament with a leaking RWST.                        And so, you 11 have        amended    your      procedures            for  inspection.
12 Please tell us more about this.
13                  MR. ALDRIDGE:        Thank you, Mr. Chairman.
14                  We did have a plant-specific condition 15 on the refueling water storage tank on Unit 1, and 16 it was identified through external leakage.                              And 17 so, we did an internal inspection and repair.                          That 18 internal inspection and repair, then, had a root 19 cause performed on that, and we identified that the 20 cause was due to external leakage from water that 21 had entered the room from seals and there was no 22 berm      around  the    tank.        So,    it      had  attacked      the 23 exterior of the tank.
24                  So, the concern for the aging effect of 25 internal        stress    corrosion        cracking        was    not      a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 concern.        When we did our aging management program, 2 we were committed to performing a confirmatory that 3 the repairs, confirmed that they were effective and 4 that there is no aging degradation going on on the 5 internal side of the tank.                  In addition, we, then, 6 every refueling outage, we look at the exterior of 7 the tank for external indications of cracking or 8 leakage.
9                    CHAIRMAN SKILLMAN:              What is your fuel 10 cycle length, please?            Fuel cycle length?
11                    MR. ALDRIDGE:        Yes, 18 months.
12                    CHAIRMAN      SKILLMAN:              You  are      on      18 13 months?        Okay. Thank you.
14                    MR. ALDRIDGE:        Okay.
15                    MEMBER    SUNSERI:            I    have  a  question 16 while you are on this page as well.                          So, we have 17 been following an issue with degraded baffle bolts 18 in the industry.            And in South Texas your core is 19 larger.        So, I suspect you are unique from the rest 20 of    the    fleet  within    maybe      the      number    of    baffle 21 bolts and how they are put together.
22                    So, my question for you is, are you an 23 upflow or downflow plant?                What has your experience 24 with the baffle bolts been?                  And what are you doing 25 to      track    the    issue      from      an      aging  management NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 perspective?
2                MR. BERG:        I will go ahead and answer 3 that question.        Certainly, we have been involved 4 with      the EPRI  Materials        Reliability      Project      and 5 compliance with      MRPG-27.        We are an upflow design, 6 and our baffle bolts are 3/16 material.                    So, when 7 you      look  at  the    susceptibility,          we  are    in    the 8 lowest susceptibility associated with that.
9                We have done some inspections where we 10 just visually looked at the baffle bolts.                    We have 11 not found any degradation of the baffle bolts.
12                MEMBER    SUNSERI:            Do  you  do  the      UT 13 inspections or just the visual?
14                MR. BERG:      Just visual inspection.                We 15 will do the UT inspections, per MRPG-27, prior to 16 the period --
17                MEMBER SUNSERI:          So, you have it right?
18 Yes, okay.      I've got it.        Thank you.
19                MEMBER    KIRCHNER:          Dick,  may  I  ask      a 20 question?
21                CHAIRMAN SKILLMAN:            Please.
22                MEMBER KIRCHNER:            From this long list, 23 what are the long poles in the tent?                  Not all these 24 are equal in terms of effort and commitment and 25 difficulty.      Could you just highlight those that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 are -- we know we have one more coming, but --
2                    MR. ALDRIDGE:        Right.
3                    MEMBER    KIRCHNER:            --    excepting      that 4 one, on this long list and the AMPs program, which 5 are      taking    more    of    your      time      or  attention        or 6 resources?
7                    MR. ALDRIDGE:          Yes,      sir. When      you 8 really        look at, with the enhancements that we have 9 in        place      and      have        committed          to,    program 10 enhancements          and    program        implementation        both        go 11 hand-in-hand.          And we have been in the development 12 phase for all these years.                  So, those, just because 13 of      the      numbers,      26    of    them      remain    open      for 14 enhancements          with      nine      implementation.                The 15 implementation programs, not only are we developing 16 the base procedures and all the requirements that 17 we committed to in the aging management program, 18 but      most    of  those    require      in-plant      inspections, 19 whether        they    are      one-time        inspections        or      the 20 beginning of a periodic.
21                    And then, from an analysis perspective, 22 we      have    already    performed        the    screening      on    the 23 NUREG-6260 central locations.                      We just have to go 24 through        and  upgrade      the    program      to  continue        to 25 monitor those new locations.                  So, that would be the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 main areas.
2                    MEMBER KIRCHNER:          Thank you.
3                    CHAIRMAN SKILLMAN:            Please proceed.
4                    MR. ALDRIDGE:        Thank you.
5                    Okay.      And so, really, in conclusion, 6 the license renewal commitments are included in our 7 SAR      Supplement,      in    our    FSAR    Supplement,    Appendix 8 Alpha of the license renewal application.                            It is 9 managed by our Appendix B Program, and it is the 10 STP      condition      reporting      process        and  the  license 11 commitment management and administrative processes.
12 There        are  two  processes        that      control  those,      and 13 they are being tracked for completion under those 14 programs.
15                    All right.        At this time, I would like 16 to transfer to Mike Berg.
17                    MR. BERG:        Okay.      I would like to talk 18 about our Safety Evaluation Report open item.                          This 19 is      associated      with      selective        leaching    of      our 20 aluminum bronze essential cooling water system.
21                    The    open      item        focuses    on      wells 22 themselves.            But,      prior      to      getting    into      the 23 specifics of the open item, I would just like to 24 give      a  brief  overview      of  the      selective    leaching 25 process.          So,    from    a  high-level        background      for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 selective        leaching      of  our    low-pressure      essential 2 cooling water system, which is commonly referred to 3 in the industry as service water system, as Ron 4 stated        earlier,    the    material        is    aluminum  bronze, 5 which        is    a  copper      aluminum        alloy.      Selective 6 leaching is a corrosion process where the aluminum 7 in the transformed phase can selectively leach out 8 when      you    have  aluminum        that    is    greater  than      8 9 percent and exposed to wetted surfaces.                        Selective 10 leaching of aluminum leaves micro-voids along the 11 grain        boundaries      and,    when    progressed      through      a 12 wall,        leakage/seepage        will    become      visible  on    the 13 outside surface of the material.
14                    So now, I would like to refer to the 15 slide here.          So, what we are looking at here, this 16 is a section of pipe.              We have a weld and, then, we 17 have got a weld-neck flange.                  So, the piping itself 18 -- there we go -- the piping itself is made out of 19 wrought        material.        It    has    less      than  8-percent 20 aluminum,          and    we    have      not      seen,    nor    is      it 21 vulnerable to, selective leaching.
22                    I want to talk about the casting --
23                    MEMBER KIRCHNER:            Just for perspective 24 --
25                    MR. BERG:      Yes.
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31 1                    MEMBER      KIRCHNER:            --  what    is      the 2 diameter of the pipe there and what is the schedule 3 and such?          What are we looking at in the picture?
4 I can see nuts on the side.                    So, it looks like it 5 is now 4-inch or --
6                    MR. BERG:      I'm thinking it is 4- or 6-7 inch diameter pipe that we are looking at here.
8                    So,    let's      talk      about      the  casting 9 materials themselves.              They are susceptible to the 10 alloying.          We  first      saw    the      alloying    or    cast 11 materials on our small-bore piping back in 1988.
12 All of those were replaced.
13                    We  do    programmatically            do  a  walkdown 14 every        six  months.      What    we    are    looking    for      is 15 copper oxide on the exterior of the pipe, like you 16 see right here.            So, the green pipe, and we look 17 for a buildup of residual.
18                    If I sectioned this pipe, I would look 19 at the inside of the pipe and I would see some 20 aluminum        hydroxide      corrosion        products    where      the 21 aluminum        has  selectively        leached      inside  the    pipe 22 and, then, on the outside, again, I see the copper 23 oxide deposits that have occurred.
24                    Just over a period of time, on these 25 large-bore castings we were somewhere between five NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 or ten first initial startup.                      Over the years, we 2 currently          run  somewhere        between        zero  or  two      of 3 these per year, is what we see.
4                    CHAIRMAN SKILLMAN:              Is this phenomenon 5 limited to just the cast material?
6                    MR. BERG:        So, we are going to talk a 7 little bit later on the welds, which is the open 8 item.          But where we have seen it predominantly is 9 in the cast materials.
10                    CHAIRMAN SKILLMAN:            Okay.
11                    MEMBER SUNSERI:          And it progresses from 12 the exterior of the pipe inward or?
13                    MR. BERG:      No, from the interior of the 14 pipe, selective leaching, and then, it takes the 15 aluminum, so the aluminum hydroxide on the inside 16 of the pipe.            Once the aluminum comes through to 17 the outside of the wall, then you will see weepage.
18 So, we don't see a lot of leakage.                          It is really 19 weepage.          Or, even in a lot of cases, when we will 20 do    the      walkdown,    we    will    see    the  spots  and      you 21 won't even see any moisture at all.                          Yes, it is 22 kind of a sponge.
23                    CHAIRMAN SKILLMAN:              Do you want to be 24 on the record?
25                    MEMBER KIRCHNER:            Have you cut any of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 these castings out and done an evaluation?
2                    MR. BERG:        Oh,    absolutely.          We    have 3 done a lot of evaluations.
4                    MEMBER      KIRCHNER:            Do    you  have      any 5 pictures        with  you    to  show    the      phenomenon    as      it 6 progresses?
7                    MR. BERG:          Really,        we    don't      have 8 pictures with us.              As part of our license renewal 9 application for our casting materials, we are going 10 to      replace      the  casting      materials        with  materials 11 that      are    not  subject      to    the      selective    leaching 12 phenomena.          So, our commitment is we are going to 13 change        all  of  these      castings        out    prior    to    the 14 period of extended operation.
15                    MEMBER    KIRCHNER:            Well,    it  begs      the 16 question, then, to what?
17                    MR. BERG:      We will go with, if we stay 18 with aluminum bronze material, then we will have 19 material probably a wrought-type material that has 20 less than 8-percent aluminum.
21                    MEMBER      BALLINGER:                Yes,    wrought 22 material, it is a two-phase thing where they get 23 something called the gamma-2 phase which is rich in 24 aluminum.          It is like dezincification.
25                    MR. BERG:      Right.
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34 1                    MEMBER      BALLINGER:              So,    you        get 2 electrochemical          cell    buildup      and    you  selectively 3 leach          out    the      aluminum.              It    is      like 4 dezincification.            And so, you end up with sort of 5 like a porous structure.
6                    MR. BERG:      Right.
7                    MEMBER BALLINGER:            But, if you whack it 8 with a hammer, you will find out that it is not 9 so --        that  the  porosity        is  a    problem.      And      so, 10 wrought materials are usually not susceptible or if 11 you heat-treated casting, so that you get rid of 12 the      solidification        microstructure          that  goes      on.
13 And the rates are anywhere from .05 to .5 mLs per 14 year sometimes, or even higher, depending on the 15 structure.
16                    MEMBER      KIRCHNER:            With  the    current 17 material?
18                    MEMBER      BALLINGER:              With  the      cast 19 material.
20                    MEMBER KIRCHNER:          With the casting?
21                    MEMBER      BALLINGER:              With  the      cast 22 material.
23                    MEMBER KIRCHNER:            Right.      And what is 24 the differential with the wrought?
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35 1 gamma phase.        And so, you don't have the same kind 2 of      problem  at    all    for    de-aluminization.                So, 3 wrought materials are generally not susceptible to 4 the material.        And if you are less than -- you said 5 8 or 9 percent --
6                  MR. BERG:      Yes, 8 percent.
7                  MEMBER BALLINGER:            I think it is on the 8 order of 8 percent, where if you look at the phase 9 diagram, you can't get that phase.
10                  MEMBER KIRCHNER:          Yes.      Thank you.
11                  MR. BERG:        Okay.      So, the focus on the 12 open item is associated with the welds themselves.
13 So, let's move on to that particular area.
14                  So,  with    the    welds,        we  have  seen      --
15 first off, we haven't seen any since 1994, but what 16 we see is, it actually is a cracking phenomena that 17 occurs.        Okay?      So, from finding the particular 18 condition when it does occur, and it hasn't been 19 since 1994, just operators doing a walkdown, so you 20 will see a light mist spray or maybe some water on 21 the floor.        So, the operators would identify that 22 as      part  of  the    walkdown        and      would  put    in    a 23 corrective      action    program      and      handle    it  through 24 that methodology.
25                  So,    we      have      seen        10  welds      with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 cracking.            The    cracking        has      some    de-alloying 2 associated with that.              We have had two of them that 3 occurred, two of the cracks that have occurred in 4 thermal welds.              The rest of the cracks, though, 5 have occurred with welds with backing rings, which 6 is the focus of a lot of our work in addressing the 7 open item.
8                    MEMBER KIRCHNER:            What is the typical 9 corrective action, then, once you discover this?
10                    MR. BERG:        We    would      cut  it  out      and 11 replace        it. When    we  talk      about      the  open    item, 12 there are 10 issues associated with that.                            When I 13 go through that, I will talk about the specifics we 14 do      on    how  do  we    do  the    inspection,        acceptance 15 criteria, and then, we will talk about corrective 16 actions.
17                    MEMBER      RICCARDELLA:                So,    is      a 18 significant percentage of this piping underground?
19                    MR. BERG:        Not percentage-wise, and I 20 don't know what the percentage of the welds because 21 most of the underground piping is of large sections 22 in      nature,      but    we    do    have      some    of  the    welds 23 certainly that are underground with backing rings.
24                    MEMBER    SUNSERI:            So,    maybe  you      are 25 going        to    talk  about    this      when      you  get  to    the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 inspections, but is there an NDE technique for this 2 or?
3                  MR. BERG:          This really gets into our 4 corrective action.            But we have been working over 5 the      last  few    years    with    an    NDE    technique.          So, 6 obviously, if it is a cracking-type phenomena that 7 is      occurring,    ultrasonic        NDE      will    detect      that 8 condition.
9                  MEMBER SUNSERI:            And are you doing it 10 any?
11                  MR. BERG:          So, we would do it if we 12 found a condition where we were seeing cracks at 13 the surface type of thing.                  Then, we would follow 14 the      code  requirements        and    we    would    have    to      go 15 characterize        that,      and    we    would      go  do  an      NDE 16 inspection.
17                  MEMBER      SUNSERI:            Okay.      Because        I 18 thought I heard you say you see the misting and all 19 that stuff.          So, I mean, it is a safety-related 20 system.        I  guess      that    puts      you    in  a  tech-spec 21 action statement.
22                  MR. BERG:          That is correct.              So, we 23 would do an operability --
24                  MEMBER      SUNSERI:              The    active      mode 25 versus --
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38 1                  MR. BERG:        It would be an operability 2 determination associated with that, which Ron would 3 request, and we would go do the characterizations 4 in accordance with code.
5                  And we are going to talk a little bit 6 later        on,  the  proactive        piece      is  prior    to    the 7 period of extended operation.                      I will just get to 8 it      briefly    now.        It    is    that      we  will    do      an 9 inspection of -- I'm going to get this wrong -- 20 10 percent        with    25    welds      with      backing    rings      and 11 without        backing    rings      prior      to  the    period        of 12 extended operation.              We will actually go in and 13 come apart and look at it.
14                  We have looked at others as well.                          I 15 don't want to let you believe we haven't done any 16 evaluation.                We      have          done      evaluations, 17 metallurgical        exams    of    the    things      where  we      have 18 found cracking in the past and other ones where we 19 have the castings, you know, we look at the welds 20 as well as part of that.
21                  MEMBER SUNSERI:          Okay.
22                  CHAIRMAN      SKILLMAN:          Mike,  let    me    ask 23 this:          from    the    inspection          report,    the    71002 24 inspection report, the comment is, "The team noted 25 the      experience      regarding        the      loss    of  material NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 caused        by  selective      leaching        in    aluminum    bronze 2 components in the essential service water system is 3 an    ongoing      aging    mechanism."            That  is  from      the 4 71002 inspection.
5                    MR. BERG:      Yes.
6                    CHAIRMAN SKILLMAN:              The text appears to 7 point only to the essential service water system.
8 Is    th    is  phenomenon      anywhere        else    in  any    other 9 systems?
10                    MR. BERG:          The answer to that is no 11 because          we  only      use    aluminum        bronze    in      our 12 essential --
13                    CHAIRMAN SKILLMAN:              Let me ask you one 14 more.          Your cathodic protection system is not in 15 scope.          At least it isn't in the document that I 16 read.          What connection have you made between this 17 phenomenon and the inoperability of your cathodic 18 protection system for what appears to be 10 to 15 19 years?
20                    MR. BERG:        Do you want to answer from 21 the TLA perspective?
22                    MR. ALDRIDGE:          Yes.      Yes, sir.      Let me 23 answer          from    the    perspective          of    the  cathodic 24 protection.              The      piping      at      South  Texas        is 25 cathodically protected as part of the buried piping NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 aging        management    program,      and      aluminum    bronze      is 2 one      of    the  systems      that      is      protected    by      the 3 cathodic protection.
4                    CHAIRMAN      SKILLMAN:          Would  it  be    more 5 accurate to say is now protected by, but was not 6 for a long time period?                That is a yes or no.
7                    MR. ALDRIDGE:          No.        It is always had 8 various degrees of protection.                          We have enhanced 9 the        degree    of    protection        since      the  regional 10 inspection,          and      now      we    are      meeting    better 11 availability and --
12                    MEMBER    STETKAR:          Let's      get  specific.
13 What        has the historic availability over the life 14 of    the      plant  of  your    cathodic        protection    system 15 been?
16                    MR. ALDRIDGE:        Thank you, sir.          We have 17 the subject matter expert present, and he can give 18 you the numbers.
19                    CHAIRMAN      SKILLMAN:            Okay. Let's      do 20 that, please.
21                    MR. KHONDKER:          My name is -- can you 22 hear me?
23                    CHAIRMAN SKILLMAN:            Yes.
24                    MR. KHONDKER:          Okay.        So, my name is 25 Raihan        Khondker.        I  am    the      Cathodic    Protection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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41 1 System Engineer at South Texas.
2                    And the question being asked, what is 3 our        historical      availability            of    the    cathodic 4 protection        system?        Over      the      past  since      the 5 inception        of  the    plant,      we    have    maintained      the 6 cathodic protection system in the entire protected 7 area.              So,      we      always          adhere    to        the 8 needs/requirements back then, which used to be --
9 now it is called SBO 0169; back then it was RP.                            We 10 adhered        to  that  since      the    beginning      and  we    did 11 maintain the full availability as possible.
12                    But, of course, over the course of the 13 years when we saw deteriorations, rectifiers out of 14 service, in some years we did see the rectifiers' 15 ability to go down.              But, based on our corrective 16 action program, we have fixed those and we have 17 made      sure    that    availability          was    always  at      the 18 higher point more than 80 percent, as we always 19 adhere to.
20                    MEMBER STETKAR:            I'm not sure that I 21 got a straight answer to my question.                          Over the 22 life of the plant, I would like to know what the 23 historic percentage availability has been if I take 24 the time up divided by the total time the plant has 25 been operating as a percentage.                        You have told me NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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42 1 that you had corrective action programs and things 2 were out of service for a long time.                      But what is 3 the average historical availability over the life 4 of the plant?
5                  MR. KHONDKER:        For that, I will have to 6 go through my trending database.
7                  MEMBER STETKAR:          Great.      Thank you.
8                  MR. KHONDKER:        And then, I have to find 9 it out for you.
10                  MEMBER STETKAR:          Thanks.
11                  MR. KHONDKER:          But, since I took over, 12 it has been over 80 percent.
13                  MEMBER STETKAR:          Okay.      Thanks.
14                  MEMBER      RICCARDELLA:              Does  cathodic 15 protection        have  any    influence        on  this  selective 16 leaching process?
17                  MR. BERG:        The answer is, no, it does 18 not,      but  our  very      piping      is    coated  and    it      is 19 protected from that standpoint.
20                  MR. MURRAY:          Yes, I was going to make 21 sure we got back to that as well, to break that 22 tie.        That was, for example, the picture that you 23 saw was not an underground cathodic-protected area.
24                  MEMBER BALLINGER:            It is very difficult 25 to use cathodic protection for this problem, yes, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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43 1 because it is a very local system.
2                  MR. BERG:        Okay.        Moving on, wrought 3 material      is  not    susceptible,          as    we  have  already 4 discussed.        The susceptible component population, 5 castings will be replaced.                  Just a feel for that, 6 400 to 450 castings in the plant.                      We will replace 7 those prior to the period of extended operation.
8                  And again, our focus on our open item 9 is      associated    with    welds      or    weld    repairs      with 10 susceptible        weld    filler      material.          It  will      be 11 managed.          That    includes      piping      butt-welds      and, 12 also, weld preparers on extruded tees.
13                  MEMBER STETKAR:          Is that 400 to 450 per 14 unit or per the site?
15                  MR. BERG:      Per the site.
16                  MEMBER STETKAR:          Thanks.
17                  MEMBER    BALLINGER:            But  castings      are 18 susceptible, but you haven't had a problem with the 19 castings, except I read in the SER you had a lot of 20 valve bodies and all kinds of things that were.
21 So, you have had that problem?
22                  MR. BERG:      Yes.
23                  MEMBER      BALLINGER:              But,    with      the 24 welding,      how    are    you    going      to  get  around      the 25 problem with welding?              Because you still have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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44 1 solidification issue.              Are you going to post-weld 2 heat-treat?        What are you going to do to get rid of 3 that problem?
4                  MR. BERG:        Okay.          So,  we  will    talk 5 about that when we go through the open issue, but 6 it is really with the one-time inspections and with 7 the      periodic    inspection,        particularly        the    welds 8 with the backing rings.
9                  What we do to address that is we would 10 use a weld filler material with nickel in it.
11                  MEMBER BALLINGER:          Yes, okay.
12                  MR. BERG:        We    have      found  that    would 13 prevent having the transformed region.
14                  MEMBER BALLINGER:              It is like a Class 15 IV.      Okay.
16                  MR. BERG:        Okay.        So, to get into the 17 open item, our open item, the STP has responded to 18 NRC      staff's  questions        associated        with    selective 19 leach in aluminum bronze.                We did send a response 20 in on September 28th.
21                  Just to talk a little, we do have a 22 comprehensive          aging        management          program        that 23 addresses        selective      leaching.              That    program 24 includes        inspections      of    walkdowns,        replacements 25 prior to the period of extended operation.                        Then, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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45 1 am going to talk specifically associated with the 2 welds.          It  includes      one-time        volumetric    exams, 3 periodic volumetric examination, defines acceptance 4 criteria,        and  has    additional        testing    elements      in 5 it.
6                    The  specific      open      item    is  related      to 7 welds,        and    the    Safety      Evaluation        Report      does 8 contain 10 specific issues, which I will discuss 9 further on the following three slides.
10                    DR. SCHULTZ:          Mike, I've got a general 11 question        related    to    the    recent      history  for      the 12 program.          Of course, the overall discussion goes 13 back many years.
14                    But, in this year, you put together a 15 fully-revised, well, I will call it a fully-revised 16 program because there were many issues associated 17 with Rev. 1 of the program.                    And now, this Rev. 2 18 program was submitted to the staff in June of this 19 year.
20                    And  my    question      is    general,    in    that, 21 once      that    was  submitted,        then      there  were    many 22 questions from the staff related to the new and 23 revised program.              So, my general question is, why 24 did that happen?            You had a lot of experience with 25 the        program      moving      forward.              You  had      the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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46 1 opportunity or made the choice to put in a fully-2 developed to address a number of concerns that the 3 staff        had    had  over    the    years      really.      And    yet, 4 there were a number of issues that were not, if you 5 will, fully addressed in the new program where you 6 had the opportunity to really set yourself up for 7 full success.            And yet, there has been a number of 8 issues in many different areas that the staff found 9 needed additional attention.                        So, my question is 10 that:        why did that happen?              Can you give me some 11 perspective on that or give us some perspective on 12 that?
13                      MR. BERG:      So, there are several phases 14 that I think we have gone through here.                        First, our 15 first focus was on the casting-type material.                                  I 16 said before we have got about 400 to 450 of those.
17 I believe it is about 56 of them, of the large 18 border          castings      that      we    have      found  that      the 19 alloying          on,  again,    as    we    talked      about  earlier, 20 with a little bit of copper oxide on the outside 21 surface so far.
22                      Our real focus was on the casting-type 23 area.          We did a lot of research, testing, did bin 24 testing and strength tied to the de-alloying of our 25 casting          materials.        Lots      of    correspondence        and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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47 1 interaction took place between us and the Nuclear 2 Regulatory Commission, and we just ended up in the 3 point        of  all    of    that    to    go    to    that  reasonable 4 assurance to the level that was expected for that; 5 that      the  easiest    answer      to  that      was  just    to    go 6 ahead and replace the castings.                        And we were doing 7 selective replacements just to do testing anyway.
8 So, that was a change in the program.
9                    And    then,      the    next        phase    came        in 10 associated          with    the    welds      themselves.            Okay?
11 Again,        that    assurance        that,        from    a    welding 12 standpoint, that we would not expect to see any 13 cracks in the future or, even more important, that 14 we      don't      see    anything        that      would    impact        the 15 structural integrity of our essential cooling water 16 system.
17                    We think we have had that, but there 18 were      a  series    of    questions        that      we  had    to      go 19 through        to  answer      and    to    come      up    with      some 20 additional        research      or    evaluation        of  the  welding 21 itself just to demonstrate that.
22                    DR. SCHULTZ:            So, as you revamped the 23 program, you really went broader in terms of those 24 specific areas that you determined you needed to 25 address?            So,    the    scope      of      the    program      grew NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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48 1 dramatically --
2                    MR. BERG:      Correct.
3                    DR. SCHULTZ:            --    based  on  lessons 4 learned?          And you, then, look at these additional 5 items as a reasonable level of issue that needed to 6 be resolved, given that you have revamped a major 7 part of the overall program?
8                    MR. BERG:      That is correct.
9                    DR. SCHULTZ:        Thank you.
10                    MR. BERG:        Okay.        Let's get into the 11 specific 10 issues for our particular open item.
12 So, the first one -- and I am going to do this at a 13 high        level    -- we      added      information      to    bound 14 extruding piping tee repairs.                        We have about 17 15 tees,        extruded    tees.          Extruded      tees  are      not 16 susceptible to selective leaching, but they do have 17 weld repairs on them.              So, part of this is that we 18 will evaluate those repairs.                  We are just going to 19 make a conservative assumption that that repair is 20 cracked,        okay,  and    then,    look      at  it  from      that 21 standpoint of structural integrity of that tee.                            If 22 we    cannot      demonstrate      structural        integrity    under 23 that condition, we will replace that tee prior to 24 the period of extended operation.
25                    No. 2    is    clarify        the  parameters NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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49 1 monitored to address.                First is loss of material 2 due      to    selective      leaching,        which    is  monitored 3 through        our    system      walkdowns          and    destructive 4 examinations.          Cracking associated with selective 5 leaching          is      monitored          through        volumetric 6 examination        of  destructive        evaluation.          And      the 7 third area is our root passes phase distribution is 8 verified        to  be    discontinuous          phase    during      our 9 destructive inspections.
10                    Item No. 3, clarify the sample size for 11 volumetric inspections.                As I said earlier, we will 12 do      a    one-time    inspection        on    20    percent    with      a 13 maximum of 25 welds with and also another sample 14 without        backing    rings      prior      to  the    period        of 15 extended operation.              And then, we will do periodic 16 examination every 10 years on 20 percent with a 17 maximum of 25 welds with backing rings, just to 18 validate from an aging management standpoint that 19 there is not something that we missed in there.
20                    Four, clarify the thresh --
21                    MEMBER    RICCARDELLA:            Excuse    me.        Is 22 that different weld, a different 25 percent for the 23 initial        inspection      versus      the      subsequent,        the 24 periodic?
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50 1 that        because,    when      we    do        the  destructive 2 examination, we will --
3                  MEMBER      RICCARDELLA:              Oh,  it    is      a 4 destructive?
5                  MR. BERG:      It is a destructive --
6                  MEMBER      RICCARDELLA:              I'm  sorry,        I 7 thought it was --
8                  MR. BERG:      Yes.      We do the volumetric, 9 but to look at the phase distribution, it is going 10 to end up being destructive.
11                  MEMBER    RICCARDELLA:            Okay. And      you 12 said there is only about 100 of these welds out 13 there?
14                  MR. BERG:      There is actually about 3300 15 welds in the plant.
16                  MEMBER    RICCARDELLA:            So,  you  said        20 17 percent was 25 welds.            I don't understand.
18                  MR. BERG:      Well, the criteria we use is 19 20 percent.          A standard in the GALL would be 20 20 percent        or 25.      So,    we    are    meeting    the    GALL      2 21 requirements on our sample size.
22                  So, we have got about 3300 welds total.
23 About a third of those, or about 1100 of them, have 24 backing rings.
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51 1 answered?
2                  MEMBER RICCARDELLA:              I thought I heard 3 you say a one-time inspection of 20 percent which 4 is about 25 welds.            And I don't understand how that 5 fits with 3300 welds total.
6                  MEMBER STETKAR:          The criteria, the GALL 7 criteria says 20 percent or a maximum of 25.
8                  MEMBER    RICCARDELLA:            Oh, oh,  oh,      oh.
9 Okay.        Yes.
10                  MR. BERG:        So, I am staying with the 11 GALL requirements, but, in reality, it is 25.
12                  MEMBER RICCARDELLA:              Okay. All right.
13 All right.
14                  MEMBER BALLINGER:              Is that a rational 15 choice?
16                  (Laughter.)
17                  I mean, I can understand sticking with 18 the letter of the law, okay, but you have a known 19 issue which you think you are going to have solved, 20 which you might have.              And so, to just arbitrarily 21 say we're just going to do 25 and get it over with 22 and move on just doesn't seem to me -- I mean, is 23 there a way, is there some kind of rapid expansion 24 that would occur if you see an issue that is also 25 different from the GALL requirements?                        You know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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52 1 this is a unique set of cases, I think.
2                    MR. BERG:        So, that does get into the 3 next        item here.      Okay?      So, let me try to answer 4 your      question    a  little      bit  more      basic  to    start 5 with.
6                    So, again, this condition, we have not 7 seen any crack in the welding since 1994.                        We have 8 done some research and testing that we believe that 9 we understand why that is the case.                        We do believe 10 it is a preexisting flaw that seems to be there.
11 So,      you    expect  to    see    with      a    preexisting      flaw 12 sometime early in life you can see the propagation 13 to the surface.            So, we think we fully understand 14 why we haven't seen anything since 1994.                        We think 15 the 25 sample size is adequate to do confirmation 16 on what we have cut open.                    We have also cut open 17 some other samples of other removed castings and 18 looked        at  those  as    part    of    coming    up with      our 19 criteria.            So,    the    25    is      to    meet  the      GALL 20 requirements,          but    we    do    believe        that  that        is 21 perfectly acceptable, that condition.
22                    If we do find one that doesn't meet the 23 criteria, we would go back to the Generic Letter 24 90-05 criteria.            And for every one that we would 25 find that doesn't meet our predictions, we would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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53 1 increase that sample size by five until we had no 2 welds that had issues on them.                      So, we will follow 3 the Generic Letter --
4                    MEMBER BALLINGER:            By five or a factor 5 of five?
6                    MR. BERG:      By five.
7                    MEMBER BALLINGER:          By five.
8                    MEMBER    RICCARDELLA:              How  are    the      25 9 samples selected?
10                    MR. BERG:      Okay.      So, that is No. 5 on 11 the bottom of the page, and those will be randomly 12 selected from the total population of above-ground 13 welds,          considering          construction            and        size 14 distributions.            We will use ASME Code criteria to 15 do that.
16                    MEMBER      BALLINGER:              Okay. Randomly 17 selection, with this kind of phenomenon, can't you 18 get a little bit less random?                      Because when you do 19 welding and stuff like that, you can record heat 20 input and all those kinds of things.                        So, is there 21 another set of criteria which you can overlay on 22 this          that    says        we'll          do      this      random 23 characterization, but this particular weld and this 24 particular weld, in our judgment, may be a little 25 bit        more    susceptible?            Can        you  modify        the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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54 1 randomness a little bit?
2                    MR. BERG:      I don't know.
3                    MEMBER BALLINGER:              Modified randomness, 4 I'm not sure that is a good --
5                    MR. BERG:      Yes.      I mean --
6                    DR. SCHULTZ:          But      the    question        is, 7 should you modify the GALL process?
8                    MR. BERG:          Yes,      I'm    not    sure      what 9 criteria that we could actually use to be able to 10 do any more.            We use the standard welding process 11 for all the pipe.                Again, you are looking focused 12 mainly        on  those    pipes      with    backing        rings    to      go 13 after.          But, because it is a standard process that 14 we used, I am sure that we would see anything where 15 we      could      say    this    particular          welder    or      this 16 particular heat, you know, is any different.
17                    We  have    gone    back      and    looked    at    the 18 heats.          We  have    looked      at  where      we    stand      with 19 respect        to  the    amount      of    aluminum      in  our      weld 20 filler        material.        I'll    tell      you,    it  is    pretty 21 standard        percent    aluminum      that      goes    through      that 22 whole thing.
23                    So,    I    am    really        not    aware    of      any 24 criteria that we can use to try to --
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55 1 bronze weld material is going to be better, much 2 better.
3                    MR. BERG:      Absolutely.
4                    MEMBER    BALLINGER:            But  right    at    the 5 interface        between    the    weld    and    the  heat-affected 6 zone there is going to be a wrought material which 7 is not going to be wrought anymore.
8                    MR. BERG:      Yes.
9                    MEMBER BALLINGER:            It is going to be at 10 the      melting    point    and,    then,      it  is  going    to    be 11 requenched.          And so, I am wondering whether or not 12 the      welds    will    be    fine,      but      right,    you    know, 13 adjacent to the weld where that thermal transient 14 has      happened,    you    don't    get    gamma    phase    in    the 15 piping        itself  and    now    get    yourself      in  an    issue 16 there.
17                    MR. BERG:        So,    again,      you  start      off 18 with less than 8 percent.                  So, if you look at the 19 phase diagram for the wrought material, you know, 20 being less than 8 percent, you would not expect to 21 go through a transformed region.
22                    MEMBER BALLINGER:          I agree.
23                    MR. BERG:      And --
24                    MEMBER BALLINGER:              But, again, you are 25 going to melt some of that material.
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56 1                  MR. BERG:      Right.
2                  MEMBER        BALLINGER:                  In          the 3 solidification process there is a chance that you 4 will get a region during the solidification process 5 where you go where you are above 8 percent.
6                  MR. BERG:      Okay.
7                  MEMBER    BALLINGER:            Okay. I  am    just 8 curious as to --
9                  MR. BERG:        For two pieces of that, I 10 have got an expert here I can call upon.                        But the 11 other piece is, when we look at the root pass of 12 the weld, one of the differences there, it is very 13 rapidly-cooled.
14                  MEMBER BALLINGER:          Yes.
15                  MR. BERG:      So, we have actually looked 16 at that and --
17                  MEMBER BALLINGER:          Okay.
18                  MR. BERG:      -- it looks like it is like 19 a maximum of 36 seconds to cool it down.                      So, there 20 is really not adequate time, even if you end up 21 with        greater  than    8    percent        type  of  aluminum 22 content, to go to the transformed region.                        And if 23 you do get some in there, you are usually, instead 24 of at the gamma-2 phase, you are at the beta phase.
25                  MEMBER    BALLINGER:            Okay. I'm      just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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57 1 saying usually --
2                  MR. BERG:        That is 25, which is less 3 acceptable and it is discontinuous in nature.
4                  MEMBER BALLINGER:            Okay. You know the 5 old saying:          the great tragedy of science is the 6 slaying of a beautiful hypothesis by a ugly fact.
7                  MR. BERG:      Yes.
8                  MEMBER    RICCARDELLA:            But  as  your      OE 9 indicated        any  problems        at    all    with  the  wrought 10 side, with the piping side of the weld?
11                  MEMBER BALLINGER:            The wrought material 12 is never a problem.
13                  MEMBER RICCARDELLA:              No, but it is the 14 weld.        You are talking about the heat effect has on 15 the weld, but --
16                  MEMBER BALLINGER:              Yes, right where it 17 has been solidified.
18                  MEMBER RICCARDELLA:            Yes.
19                  MR. BERG:          The answer is no to that 20 question.        And going one step further, when we have 21 seen an issue, it has been due to a weld defect 22 that      was  already    there      as  part      of  the  original 23 construction.
24                  MEMBER RICCARDELLA:              And it was in the 25 weld, not in the heat-affected zone?
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58 1                  MR. BERG:      In the weld, correct.
2                  MEMBER RICCARDELLA:              Okay.
3                  MEMBER BALLINGER:                But don't you have 4 two issues, cracking and de-aluminization?
5                  MR. BERG:      Yes.
6                  MEMBER      BALLINGER:              So,  I'm    talking 7 about the de-aluminization part, not the cracking 8 part.
9                  MR. BERG:        So, the de -- I will try to 10 get there.
11                  MEMBER      BALLINGER:            It  is  too      many 12 syllables.
13                  (Laughter.)
14                  MR. BERG:          Yes.        So, the de-alloying 15 going on in the casting pipe region, we are taking 16 care of that.            And we have seen a lot of that 17 without any, you know, preexisting --
18                  MEMBER BALLINGER:            Okay.
19                  MR. BERG:      -- flaws or anything else.
20                  When we get into the welds, we do see 21 some        de-alloying      in    the    weld        surfaces,        but 22 everything        is  telling        us    it      is    due  to      that 23 preexisting          flaw.        Probably          just    created        an 24 environment        because      of    the    type      crack  and      the 25 aqueous        condition      in    there,        it    has  created        an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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59 1 environment        that      did      allow      anything      in      the 2 transformed        region      to    show        that    de-alloying 3 occurred, maybe weakened the material a little bit, 4 and then, allowed cracking and, then, de-alloying 5 and cracking as it propagates through.                          We don't 6 really know that for a fact, but what we do know is 7 all      of  our  OE    tells      us    there      had  to    be      a 8 preexisting flaw there for this condition to occur.
9                  MEMBER RICCARDELLA:              Just to be clear, 10 if we go to that slide 17, the picture, you have 11 never had the type of problem that you have circled 12 there on the wrought piping side of a weld?
13                  MR. BERG:      That is correct.
14                  MEMBER RICCARDELLA:            Thank you.
15                  CHAIRMAN      SKILLMAN:            I  would  like      to 16 move on.        I want to make it clear that in your 17 prior discussion you communicated that, when you do 18 have evidence, you file a condition report because 19 of the way your tech specs are written.                        You do an 20 operability        determination,          and      that  operability 21 determination directs the action of the site staff?
22                  MR. BERG:      That is correct.
23                  CHAIRMAN      SKILLMAN:          And  with  that,      I 24 believe we --
25                  MEMBER STETKAR:          Hold on.
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60 1                    CHAIRMAN SKILLMAN:            Go ahead, John.
2                    MEMBER STETKAR:          We have got all kinds 3 of time here this morning.                  We don't have to rush 4 through this.
5                    CHAIRMAN SKILLMAN:            No, no.
6                    MEMBER      STETKAR:            Ron,    I'm    not      a 7 materials guy.          So, you questioned first the kind 8 of    random    sampling      notion.        This    is  for  my    own 9 education.
10                    In many other of these programs that we 11 have seen, not this particular one, throughout the 12 course        of license      renewal,      where    you    do  have      a 13 large population to select from, people establish 14 what      they  call  a    risk-informed          sampling    program.
15 And I don't want to get into the nuances of risk, 16 but they look at places where they would be more 17 likely to find a problem, whether that is a fatigue 18 issue        or  whether    it    is    cracking      of  small-bore 19 piping welds, or whatever, and then, sample from 20 those locations.
21                    So, I'm asking you, given what we have 22 heard here, is there a more, I'll call it risk-23 informed approach that could be used, rather than 24 just randomly selecting 25 out of 3300, in your 25 opinion?
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61 1                  MEMBER BALLINGER:            See, I am not a risk 2 guy.        So, I hesitate to use the word "risk," but I 3 will use it anyway.
4                  That is what I was trying to get at.
5 Basically,        modifying      the    random        sample  business, 6 knowing        that    under        certain          conditions        the 7 possibility is that you will get a more susceptible 8 area, so that is exactly what I am suggesting.
9                  MEMBER STETKAR:          But, I mean, you know, 10 based on your own experience, is there something 11 that you could think of that would sort of narrow 12 down the field a bit?
13                  MEMBER BALLINGER:            I would take a look 14 at the welding procedures, and you already have, 15 and decide, depending on pipe size and heat input 16 and things like that, whether or not there is a 17 possibility        that    you    get    the      second  phase      and, 18 then, focus your randomness, if you will, on some 19 of those areas, until you discover that, yes or no, 20 we don't have an issue.                  And this occurs over a 21 very long period of time, though.
22                  MR. BERG:      Correct.
23                  MEMBER BALLINGER:              So, it is not like 24 you are going to have some kind of catastrophic 25 failure all the time.
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62 1                MR. BERG:      Correct.
2                MEMBER BALLINGER:              But you are right, 3 that is the way to do it.
4                MEMBER STETKAR:          Okay.      Thanks.
5                MEMBER BALLINGER:          Thanks.
6                MEMBER RICCARDELLA:                I'm not familiar 7 with this type of piping, but, from what I know 8 about code class piping, 25 welds out of 3300 is a 9 minuscule sample.        I mean, in code class piping we 10 do typically 25 percent of the welds, and if you 11 find anything in that 25 percent, you are in doing 12 another 25 percent, and if you find anything in 13 that second 25 percent, you do 100 percent.
14                MEMBER    STETKAR:        But,      again, that      is 15 more of a question for the staff --
16                MEMBER RICCARDELLA:            Yes, yes.
17                MEMBER STETKAR:          -- because they wrote 18 the guidance and they are following the guidance.
19                MEMBER          RICCARDELLA:                    Right.
20 Understood, yes.
21                MR. BERG:      So, I would like to go ahead 22 and move on to slide 21.
23                CHAIRMAN        SKILLMAN:              Yes,    please 24 proceed, yes.
25                MR. BERG:        Okay.        Item No. 6, we did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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63 1 determine that there was no impact of the external 2 coatings regarding detecting buried piping leaks at 3 the surface.
4                  Seven, we have identified a method to 5 monitor our trend results.
6                  I would like to focus a little bit more 7 on Item No. 8, define the acceptance criteria for 8 the weld defects.          For visual exams, the acceptance 9 criteria is no detectable leakage.                        For volumetric 10 examination,        it    would        be    no      detected    twiner 11 indication that is subsurface-connected unless the 12 depth of the indication is contained within the 80 13 percent of the weld root pass.                    And for destructive 14 examinations, no selective leaching penetrating 80 15 percent        of the  root      pass    region,      and  any    found 16 selective leaching is non-propagating.                        So, it is 17 surrounded        by  a    non-continuous            resistant    phase 18 distribution.
19                  And  then,      the    microstructure        of      the 20 weld      root  region    will      exhibit        a  non-continuous 21 phase distribution, which is consistent with all of 22 our        metallurgical        evaluation          or    metallurgical 23 reports that we have done so far.                          So, we see a 24 non-continuous phase distribution.                      So, if you had 25 a little localized de-alloying, it is not going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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64 1 have any depth associated with that, being a non-2 continuous.
3                    Item No. 9, identify the threshold for 4 increased        inspections          when      adverse    inspection 5 results        are  detected.          We    talked    about    that      a 6 little bit earlier.              That is tied back to Generic 7 Letter 90-05.
8                    And the last item is to identify the 9 corrective          actions      to      address      all    potential 10 inspection        results.        We    will      remove  any  leaking 11 welds        and  destructively          exam      to  determine        the 12 extent of the cracks, the extent of the selective 13 leaching,            and        the        microstructure            phase 14 distribution,          perform      five    additional      volumetric 15 exams,        and    perform        a    structural        integrity 16 evaluation to confirm the load-carrying capacity.
17                    Move on to the next slide.                  So, this 18 brings us into one remaining open issue associated 19 with the corrective actions.                    This remaining issue 20 concerns how to address the extended condition in 21 the      unlikely    condition        that    structural      integrity 22 evaluation        does    not    support        the  load-carrying 23 capability or capacity.
24                    A  method      and    acceptance      criteria        to 25 bound the extended condition is being defined.                              We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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65 1 have had some initial communications with the NRC 2 staff,        and  we  do    feel    comfortable        that    we    can 3 address that concern, and it does support a pathway 4 forward and timely response and resolution.
5                    DR. SCHULTZ:          Mike --
6                    MR. BERG:        Yes?
7                    DR. SCHULTZ:          -- just before you get to 8 the conclusion, as you presented it, the addressed 9 issues,        you  have    presented      your      response    to    the 10 staff        and  you    feel    you    have      agreement    with      the 11 staff        that,    in    fact,      your    responses      have      been 12 accepted?          And it is only Item No. 10 that has not 13 been fully resolved?                You have provided a response, 14 but,        then,    the    staff      had    additional      questions 15 related to that?
16                    MR. BERG:        Yes, an additional question 17 is      what    we    are    working      with      the  staff    on      to 18 address.
19                    DR. SCHULTZ:          Okay.
20                    MR. BERG:        And again, we do feel that 21 we have a pathway to timely resolution of that --
22                    DR. SCHULTZ:          On Item No. 10?
23                    MR. BERG:        -- item, yes.
24                    MR.      MURRAY:            Yes,      it  could        be 25 characterized as initial conversations on that --
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66 1                  DR. SCHULTZ:        Okay.
2                  MR. MURRAY:          -- with the understanding 3 of the strategy.
4                  DR. SCHULTZ:        Thank you.
5                  MEMBER KIRCHNER:            I should have asked 6 this        earlier.      How    many      linear      feet    of      pipe 7 comprises this system with the aluminum bronze and 8 how      much  of  it  is    buried      underground?          Just      an 9 estimate.        I'm not holding you to exact numbers.
10 Where I am getting at is most of your visual at 11 least inspections will be --
12                  CHAIRMAN      SKILLMAN:                Well,      buried 13 underground versus buried where else?
14                  (Laughter.)
15                  MEMBER      KIRCHNER:            Well,    you      know, 16 inaccessible.
17                  CHAIRMAN      SKILLMAN:            Oh,  okay.        Just 18 making sure.
19                  MEMBER KIRCHNER:          Sure.
20                  MR. BERG:        I  would        say  I  am    really 21 giving you kind of an estimate, just based on where 22 our essential cooling water intake structure is to 23 our Class 1E structures -- you can choose a little 24 bit further away -- so, I would say about 3,000 25 foot      underground    would      be  my    estimate    associated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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67 1 with that.
2                    MEMBER      KIRCHNER:              And  that,      the 3 component of piping that is underground, that is 4 primarily welded.              The flanges that you have had 5 problems        with    are    at    the      actual    above-ground 6 equipment?
7                    MR. BERG:        Yes.        So, I will make it 8 real clear.        There are no castings or cast material 9 underground.
10                    MEMBER    KIRCHNER:            Okay.      Thank    you.
11 Thank you.
12                    MEMBER RICCARDELLA:                But, then, above 13 ground -- there's 3,000 feet below underground --
14 then,        what  is    the    remainder          of  the  system, 15 approximate?          I'm sorry.          Just ballpark, what is 16 the remainder.          If you have 3300 welds, I imagine 17 it is a lot of feet.
18                    MR. BERG:          Yes,        there's    several 19 thousand feet.            We have 30-inch pipe; we have 4-20 inch pipe, 10-inch pipe through the plant.                                I'm 21 thinking in the several thousands, 13,000-ish.
22                    Kevin or Rick?
23                    MR. STARK:          Good      afternoon.          Rick 24 Stark, the Pipe Program Engineer at South Texas.
25                    Buried underground piping, between the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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68 1 two units, supply and return, is just over 24,000 2 feet.
3                  MEMBER RICCARDELLA:            Buried?  Buried?
4                  MR. BERG:          And      that  is  essential 5 cooling water piping?
6                  MR. STARK:        That is correct.          That is 7 all essential cooling water piping.                      There is 6-8 inch, 10-inch, and 30-inch.
9                  MR. BERG:        I was off by a factor of 10 eight.
11                  Thanks, Rick.        Thank you.
12                  MEMBER SUNSERI:            Hey, Mike, I hate to 13 keep picking on this, but this acceptance criteria 14 for the weld defects, I am confused on it.                          When 15 you go out and do your 25 inspection, you are going 16 to look at these welds and you are going to apply 17 this criteria?
18                  MR. BERG:      Right.
19                  MEMBER SUNSERI:          Is that correct?          So, 20 you are going to look at it to see if it is not 21 leaking?        You    are    going      to      do a  volumetric 22 examination to see if there is anything inside of 23 it?      And then, you are going to cut it out to do a 24 metallurgy examination?
25                  MR. BERG:      A metallurgy examination.
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69 1                  MEMBER SUNSERI:            So, essentially, you 2 are      replacing    25    every      inspection        period      then, 3 right?
4                  MR. BERG:      That is correct.
5                  MEMBER SUNSERI:          Okay.      Thank you.
6                  MR. BERG:        Okay.        So, in conclusion, 7 following      the  resolution        of  that      remaining      issue 8 related        to  corrective          actions,        the    selective 9 leaching        of    Aluminum        Bronze        Aging    Management 10 Program, effectively, we will manage the aging of 11 the      essential    cooling      water      cast    components        and 12 welds during the period of extended operation.
13                  MEMBER BALLINGER:            Can I get one thing?
14 I'm      still    fuzzy.        You    have      got    several    miles, 15 kilometers, of buried piping.                      You are going to 16 take 25 welds, presumably not buried?
17                  MR. BERG:      That is correct.
18                  MEMBER      BALLINGER:            Okay.      And      the 19 reason you don't have to take any of the welds from 20 the      buried    piping    is    because        there    is  no      cast 21 material buried?
22                  MR. BERG:        Not really.          Because if it 23 is a cast material, we will replace the castings 24 prior to the period of extended operation.
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70 1 replace the castings?
2                  MR. BERG:        And    when    we  replace      that 3 weld, we will use the nickel-based material.                              So, 4 it won't be vulnerable to it.
5                  MEMBER      BALLINGER:                So,    of        the 6 underground piping, that will fall into a category 7 where it has either been replaced, the casting has 8 been      replaced,    or    it    is    wrought      material      and, 9 therefore, there is no selective leaching issue for 10 the underground piping?              Is that what I'm hearing?
11                  MR. BERG:        For the underground?                  So, 12 the      underground    piping      is    only      wrought  material 13 already.      That is what exists now.                So, we will use 14 -- so, from a stress standpoint, the above-ground 15 welds are higher-stress conditions; they are more 16 vulnerable        --  so,      we    will      use    our  operating 17 experience        from    the    above-ground          welds  for      any 18 decisions associated with expansion of scope.                            And 19 this      really  ties    back    in  the      corrective    action, 20 depending on what we see.
21                  Again,    we    think      all    of  our  research 22 shows us that we have a boundedness condition and 23 we don't expect to see anything really for the rest 24 of the life of the plant, as we haven't since 1994.
25 Our aging management program will demonstrate that.
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71 1                    MEMBER BALLINGER:            Thank you.
2                    MR. BERG:        Okay.        I would now like to 3 turn it over to Dave Rencurrel for closing remarks.
4                    CHAIRMAN        SKILLMAN:            Before    we      get 5 there,        one  of  the    reasons      I    was  trying    to    move 6 along        is    I    have      got      a    couple      of    comments 7 independent          from    aluminum      bronze,      and  perhaps        my 8 colleagues have comments as well.                        So, may I please 9 go      after      those    right      now?        I'm    good  for      your 10 closing comments, but I would like to have this 11 opportunity with the STP staff in front to ask some 12 questions.
13                    I'm        in        your          license      renewal 14 application.          I'm on page 84.            "Cathodic protection 15 is not in scope."                Why?      It is on the record in 16 your document.
17                    MR. ALDRIDGE:          Arden Aldridge.
18                    Cathodic      protection        as  far  as  in    the 19 scope, let me have Mr. Warner --
20                    CHAIRMAN SKILLMAN:              Please do.
21                    MR. ALDRIDGE:          -- who can provide some 22 clarification.
23                    CHAIRMAN SKILLMAN:              Okay.
24                    MR. WARNER:          Yes,      my  name    is    Gary 25 Warner.          I'm the Senior Project Manager for License NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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72 1 Renewal.
2                  Cathodic protection is not in the scope 3 of license renewal because it is not one of those 4 systems        that  performs      an    intended      function      for 5 license renewal.            It is a support system that is 6 used to allow you to protect your buried piping.
7 But, in the absence of cathodic protection, you are 8 required to inspect a lot more buried piping than 9 you would if you have adequate cathodic protection.
10                  So, based on the other plants in the 11 country plus the way the rule is written, cathodic 12 protection        does  not    perform        a  license-renewal-13 intended function.
14                  CHAIRMAN SKILLMAN:              Thank you for that 15 explanation.
16                  I  want    to    reinforce        John  Stetkar's 17 question        about  the    time    availability      of  cathodic 18 protection        because    in    the    Inspection      Report      the 19 Inspection        Report    very    clearly      states  that    there 20 was a 10-year period that there was no cathodic 21 protection.        So, I would like to get the answer to 22 John's question as soon as you can get it to us.
23                  MR. ALDRIDGE:        Yes, sir.
24                  CHAIRMAN SKILLMAN:            Another question --
25                  MR. MURRAY:          Just for clarity, we owe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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73 1 you a followup on the operating experience of the 2 cathodic protection system?
3                  CHAIRMAN SKILLMAN:              That's correct, as 4 a percentage of time, yes.
5                  On  your    license      renewal      application, 6 page      112,  the  statement        is      --  it  is  actually 7 2.3-27, but it is on PDF page 112 -- "The essential 8 cooling pond is included with the evaluation of the 9 essential        cooling      water    structures        in  Section 10 2.4.9."        Please tell us about the actions that you 11 have taken to confirm that the pond is good for 12 your projected PEO.
13                  MR. ALDRIDGE:        Arden Aldridge.
14                  Yes,    the    pond    is    part    of  our    aging 15 management        program,      the      structured        monitoring 16 program, and I have a subject matter expert here 17 who can give you some additional details on the 18 inspections that we have performed.
19                  CHAIRMAN SKILLMAN:            Please do.
20                  MR. ALDRIDGE:        Okay.      Mark Wales.
21                  MR. WALES:        My name is Mark Wales.                I 22 am a civil structural engineer at STP.
23                  The  pond,    it    is  an    underground      pond.
24 That is the first thing you need to understand.
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74 1 out of the pond.          But, as far as maintenance of the 2 pond, there's not really any maintenance that is 3 required.        We do periodically inspect it and use 4 biocides to prevent things from growing in it and 5 in the concrete, and we inspect it as part of the 6 structures monitoring program periodically.                          But, 7 other than that, there is no specific maintenance.
8                  CHAIRMAN SKILLMAN:              Now you stated it 9 is underground.          Is it really a surface pond or an 10 underground pond?
11                  MR. WALES:        Below grade, that would be 12 a better word for it.              The surface water is 2 feet 13 below the ground level.
14                  CHAIRMAN SKILLMAN:            Okay.
15                  MR. ALDRIDGE:          And I can add a little 16 clarification,        too.        It    is      not  only  with      the 17 Structures Monitoring Aging Management Program, but 18 the pond is specifically managed under the Water 19 Control Structure's Aging Management Program that 20 has      the  different    inspections          that  are  performed 21 for silting and volume validation and conditions.
22 So, it is managed there from that perspective.
23                  CHAIRMAN SKILLMAN:            Okay. Thank you.
24                  Let me bring your attention to page 9-25 12 in your license renewal application.                        This is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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75 1 under        TLAAs. The    subject      is    your    studs,    nuts, 2 flanges.        But, in this particular section, you are 3 silent on inserts.              And the table that you show 4 shows inserts with cumulative usage factor greater 5 than one.          So, do you have someone here who can 6 explain        the  relationship          between        studs,    nuts, 7 flanges, and inserts?              I understand the CUF for the 8 studs, nuts, and flanges, but I do not understand 9 CUF greater than one for inserts.
10                    MR. LYNCH:        My name is Bret Lynch.                I 11 worked on the time-limiting aging analyses.
12                    For  standard        practice,        when  we    were 13 developing the South Texas application, we took a 14 40-year          CUF,    Cumulative          Usage        Factor,        and 15 multiplied it by 1.5 to get an estimate of what the 16 CUF would be.          On that criteria, we decided either 17 the current CUF was projected to the end of the 18 period of extended operation, which was one of the 19 disposition criterias.              If it was over one in this 20 case, we would have to justify managing the usage 21 factor to ensure that the 40-year one would be good 22 for 60 years.          So, we were keeping the same number, 23 the design transients, from 40 years for 60 years.
24                    CHAIRMAN      SKILLMAN:            Okay. Now    hold 25 that thought.          That suggests in this case, and in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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76 1 other texts in your application, your TLAA depends 2 upon your cycle-counting program.
3                    MR. LYNCH:      That is correct.
4                    CHAIRMAN SKILLMAN:              Okay. What is the 5 pedigree        of  that    cycle-counting            program  and      how 6 does the plant manage that program?                        What is the 7 pedigree and how do you manage it?
8                    MR. LYNCH:          Well,      we  did  perform      a 9 baseline to get the current number of transients 10 currently.          And then, it is an ongoing program at 11 the plant.        I do not own that program.
12                    MR. BERG:        So, I will just add to it.
13 Really, it is procedurally-controlled under our 10 14 CFR Appendix B Program.                Okay?      And Mike Garner is 15 our      engineer    that    does    that      cycle    counting      and 16 manages that program for us.
17                    CHAIRMAN SKILLMAN:            Okay. Thank you.
18                    Let me see if I have any more here.
19                    (Pause.)
20                    I'll    ask    my    colleagues,        any  comments 21 for the Applicant relative to this matter?
22                    MEMBER STETKAR:          Yes.      They make me do 23 this.        It's the voices in my head, I think.                    But I 24 have        to    ask  this      for      every      license    renewal 25 applicant.
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77 1                    Inaccessible          underground        cables,        I 2 understand and I read back in 2011-2012, as the 3 program was evolving, there were a lot of RAIs.                              I 4 understand that your program is now consistent with 5 GALL Rev. 2, is that correct?
6                    MR. ALDRIDGE:        That is correct.
7                    MEMBER STETKAR:          Okay.      Thank you.
8                    I  noticed      that,      as    I  read    through 9 things, you have manholes that have solar-powered 10 sump pumps in them.              And as best I can tell, you 11 have committed to what is in GALL Rev. 2, which is 12 an      annual      inspection        of    manholes      or  I    would 13 categorize        it  as  an    episodic        inspection    if    you 14 have,        you  know,      a  typical --          I  used    to      do 15 consulting work down at South Texas and they used 16 to call them South Texas frog floaters.
17                    (Laughter.)
18                    So, you had a particularly heavy rain.
19                    As best as I can tell, it is says that, 20 if an inspection determines that a sump pump is 21 inoperable, you will put it into your corrective 22 action program and fix it.                    Are those sump pumps 23 alarmed?          I mean, is there a better indication of 24 whether they are operating or inoperable than just 25 simply finding that there is water in the manhole NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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78 1 and the sump pump wasn't working?
2                    MR. ALDRIDGE:          Yes,      sir. The    short 3 answer is they are not alarmed.
4                    MEMBER STETKAR:          Okay.
5                    MR. ALDRIDGE:          However, we do monitor 6 those,        and over    the    years      we    have    improved        our 7 inspections there.              And the subject matter expert 8 is present.
9                    MEMBER STETKAR:          Okay.
10                    MR. ALDRIDGE:          And we are doing some 11 enhancements.
12                    MEMBER      STETKAR:            The    reason      I      am 13 curious is because not only episodic events, but 14 you have had a history of groundwater.
15                    MR. ALDRIDGE:        Correct.
16                    MEMBER    STETKAR:        So,      it  is  a    pretty 17 low-lying area --
18                    MR. ALDRIDGE:        Yes.
19                    MEMBER    STETKAR:            --    and  groundwater 20 intrusion is pretty pervasive.
21                    MR. ALDRIDGE:        Right.
22                    MEMBER    STETKAR:          So,    I  was  curious.
23 So, if I could hear what you are doing about those, 24 I would appreciate it.
25                    MR. KHONDKER:            My      name    is    Raihan NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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79 1 Khondker.          I'm the cable program owner at South 2 Texas Project.
3                    The  question        is    regarding      the      sump 4 pumps in our manholes at STP and what we are doing 5 about it.          At present, we have solar pumps designed 6 in      all    the  manholes      where      we      have  seen    water 7 submergence issues. The solar pump design that we 8 have,        we  have  been    maintaining          them through      our 9 preventive maintenance program.                      We have, depending 10 on what kind of manhole it is and how often, we 11 have        seen    the    trend      showing        how  often        the 12 groundwater incurs.              We have frequencies from four 13 weeks all the way to annually, depending on which 14 manhole it is, and we go in and inspect the pumps 15 on them.
16                    And if we see that a float switch or a 17 pump      or    any  of    the    control        mechanisms    are      not 18 working, we replace it as a part of the PM.                          I will 19 say, if there is any water at the floor level, we 20 pump it out.
21                    At present, also, what we are doing as 22 a corrective action is that we have redesigned all 23 our pumps.          We have a new approved design change 24 package which is allowing me to go and replace all 25 the      pumps    we  have.      We    are    putting    higher-duty NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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80 1 pumps.          Like we have in the higher ones we are 2 putting 2,000 gallons per hour.                    In some of them we 3 are putting 1500 gallons per hour, and some of them 4 are below 1,00 gallons per hour.
5                    So, these designs are going in as we 6 speak.        We are coming out of the outage, and those 7 pumps will be going in as solar pump designs, so 8 that we can keep all the manholes dry.
9                    MEMBER      STETKAR:            Good.      That        is 10 encouraging.
11                    MR. KHONDKER:          Yes.      In total, we have 12 an estimate of 96 pumps that is going to be put --
13                    MEMBER STETKAR:          Ninety-six, wow.
14                    MR. KHONDKER:            Ninety-six solar pumps 15 are going in manholes because we have 155 manholes, 16 and out of them, 96 have seen historic --
17                    MEMBER STETKAR:            Since I have got you 18 up and on the --
19                    MR. KHONDKER:        Yes.
20                    MEMBER    STETKAR:        --      carpet here,      you 21 said      155    manholes.        Is    that      155    in scope      for 22 license renewal or just 155 total?
23                    MR. KHONDKER:          No, they are not all in 24 scope.
25                    MEMBER STETKAR:          Yes.
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81 1                MR. KHONDKER:          It      is  a  combination 2 because we are looking at manholes, so we look at 3 them all as similar, yes.
4                MEMBER      STETKAR:            Sure,  sure,    sure, 5 sure.
6                MR. KHONDKER:        Not just in scope, no.
7                MEMBER STETKAR:          Great.      Thank you.
8                MR. KHONDKER:        No problem, sir.
9                MR. MURRAY:        This is Mike Murray.
10                I do want to point out that you talked 11 about the frog floaters.            We have also improved the 12 sealing, the external sealing of those manholes as 13 well.
14                MEMBER STETKAR:          Yes, I have read some 15 of the operating experience.              Thank you.
16                CHAIRMAN      SKILLMAN:            Colleagues,      any 17 further questions, please, for the Applicant?
18                MEMBER RICCARDELLA:              Yes, you indicate 19 you      have  your  plant-specific            program  for    nickel 20 alloys.        As  I  recall,      South      Texas  is  somewhat 21 unique in having had a cracking of the bottom head 22 instrument nozzles.            Is that part of your plant-23 specific program or is there anything special you 24 are doing on that topic?
25                MR. ALDRIDGE:          Mike Garner, do you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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82 1 a    specific      on  the    nickel    alloy        program,    on    the 2 scope?        Is that what it is for?
3                    MR. ALDRIDGE:          In      regards    to      VMI, 4 right?
5                    MEMBER RICCARDELLA:              Yes, yes.
6                    MR. GARNER:        Are you referring to VMI?
7                    MEMBER RICCARDELLA:              Uh-hum.
8                    CHAIRMAN      SKILLMAN:              Please    identify 9 yourself.
10                    MR. GARNER:          My name is Michael Garner.
11 I'm the Site Metallurgist for STP.
12                    The inspections for VMI will fall under 13 the code case, the guidelines described in the code 14 case,        in  722,    where      we    do      a    VE,  a    visual 15 examination, an enhanced visual examination, every 16 other year looking at 100 percent penetrations on 17 VMI.        And then, every other year that isn't a code 18 inspection, we do a visual as well.                        It is not 100 19 percent, but it is looking for gross leakage.
20                    MEMBER RICCARDELLA:              Okay. Thank you.
21                    CHAIRMAN SKILLMAN:                Okay. Colleagues, 22 any further questions?
23                    (No response.)
24                    Dave, to you, please, sir?
25                    MR. RENCURREL:          Thank      you  very      much, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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83 1 and      we    would  like      to    thank      the    ACRS  for      your 2 questioning.
3                    And  I    would    also      like    to  thank      the 4 staff.          I  did  not    recognize        our  subject    matter 5 experts who came here, too.                      We brought a little 6 bit under two dozen folks to come and ensure that 7 we had the right answers to your questions.
8                    And one point I would like to make is 9 we started off by talking about the robust quality 10 assurance        program,      Appendix        B.      We    are      very 11 committed to the quality assurance program at South 12 Texas.            As  you      heard    here,        leveraging        that 13 independent oversight is one way we know that the 14 commitments we are making are being carried out.
15                    With that, I would like to thank you 16 for your time.
17                    CHAIRMAN      SKILLMAN:          Yes,  sir.      Thank 18 you very much.
19                    With    that,      ladies      and    gentlemen,        we 20 will take a 16-minute break and we will resume at 21 quarter after 10:00 on that clock.
22                    We are in recess.
23                    (Whereupon,      the    foregoing      matter      went 24 off the record at 9:57 a.m. and went back on the 25 record at 10:15 a.m.)
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84 1                  CHAIRMAN        SKILLMAN:                Ladies        and 2 gentlemen, we are back in session.
3                  To those who are on the bridge line, we 4 respectfully request that you put your phones, *6, 5 on mute.      We can hear your family background.
6                  (Laughter.)
7                  We  would    like    you      to  please  silence 8 your phones, so that there is no background noise 9 affecting      other  members      of    the      public  that      are 10 listening in.        Would you please do that?
11                  Also, Greg Pick, are you there, please?
12                  MR. PICK:      Yes, I am.
13                  CHAIRMAN SKILLMAN:            Thank you.
14                  Greg is our inspector.              We want to make 15 sure that our recon team is onboard.                    He is.
16                  With that, let's begin.                Lois, to you, 17 please.
18                  MS. JAMES:      Thank you.
19                  Good    morning,        Chairman        Skillman      and 20 Members of the License Renewal Subcommittee.
21                  My  name    is    Lois    James,      and  I'm      the 22 License Renewal Project Manager for the South Texas 23 Project, or STP, license renewal safety review.
24                  We are here today to discuss the review 25 of the STP license renewal application, or LRA, as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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85 1 documented      in  the    Safety      Evaluation        Report    with 2 open items which was issued in October.
3                  Joining me here at the table today are 4 Dr. Allen Hiser, the DLR Senior Technical Advisor; 5 Mr. Bill Holston, Senior Mechanical Engineer, and 6 Ms.      Phyllis  Clark,      Project      Manager,      who  will      be 7 running the slides.            Mr. Greg Pick, Senior Reactor 8 Inspector in Region IV, is on the phone and will 9 discuss the 71002 inspection results.                        Sitting in 10 the audience and the phone are other members of the 11 technical staff who participated in the review and 12 conducted several audits and inspections.
13                  Next slide, please.                I will begin the 14 presentation with a general overview of the staff 15 review.        Next,  Mr. Pick    will      present    the    71002 16 inspection results.            I will, then, present the main 17 sections      of  the    Safety      Evaluation        Report.        Mr.
18 Holston will discuss the open item on the Selective 19 Leaching        of    Aluminum        Bronze        Aging    Management 20 Program, or AMP.
21                  Next    slide,      please.            STP  Nuclear 22 Operating        Company,      or    Applicant,        submitted        an 23 application for the renewal of STP Units 1 and 2 24 operating licenses for an additional 20 years.                          The 25 staff conducted onsite audits, offsite audits here NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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86 1 in Maryland, and onsite inspections.                        As you can 2 see, the staff performed additional audits of the 3 open        item    for    selective        leaching      of  aluminum 4 bronze, AMP.
5                    During      the      scoping        and    screening 6 methodology          audit,        the      team      reviewed        the 7 Applicant's        administrative        controls      governing      the 8 scoping and screening methodology and the technical 9 basis        for  select    scoping      and      screening    results.
10 The scoping and screening methodology audit results 11 were documented in a report dated September 6th, 12 2011.
13                    During the AMP audit, the team examined 14 the      Applicant's      aging      management        programs        and 15 related          documentation          to      verify      that        the 16 Applicant's          programs      are    consistent        with    those 17 described in the GALL Report and with the plant 18 conditions        and  operating        experience.          The    staff 19 reviewed        the  initial      40    AMPs      and  documented        the 20 results in a report dated September 22nd, 2011.
21                    In  January        of    2016,      the    Applicant 22 informed the staff of significant changes to the 23 Aluminum        Bronze    Selective        Leaching      AMP.      These 24 changes redirected the staff's review such that the 25 topic-specific        audits      conducted        in  2012  and    2015 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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87 1 were no longer applicable.
2                    In 2016, the staff conducted an audit 3 of the Revised Aluminum Bronze Selective Leaching 4 AMP in two parts.              During the week of March 21st, 5 the staff went onsite at STP and, then, a followup 6 day on June 22nd in the NEI offices in Rockville.
7                    The      audit        focused          on    material 8 information,            material            process          information, 9 microstructure              information,                and    structural 10 integrity evaluations regarding the welds that may 11 be      susceptible      to    selective        leaching    needed        in 12 order for the staff to complete its review.
13                    The    results        of      the      audit      were 14 documented in a report dated August 30th.                            Region 15 IV will discuss the activities and results of the 16 71002 inspection in a few minutes.
17                    Next    slide,        please.            The      staff 18 performed its review of the STP LRA and documented 19 its results in two Safety Evaluation Reports with 20 open items.          In February of 2013, the staff issued 21 an SER with four open items.                  We did not come to an 22 ACRS meeting because the staff continued its review 23 of    the      selective    leaching      of    the    Aging  Aluminum 24 Bronze        AMP. We  were    uncertain          about  where      the 25 review was going and we thought it was premature to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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88 1 come to the ACRS at that time.
2                    As  stated        in    2016,      the  Applicant 3 informed the staff of significant changes to this 4 AMP.        The staff was able to make progress in its 5 review and issued an updated SER with open items in 6 October.        The Final SER will include the resolution 7 of      the    open  item    regarding      the      aluminum    bronze 8 selective leaching.
9                    Next slide, please.              I will now direct 10 the      presentation      to    Mr.      Pick      to  discuss      the 11 inspection activities associated with the license 12 renewal review.
13                    Mr. Pick.
14                    MR. PICK:      Thank you, Lois.
15                    Good      morning,            Members      of        the 16 Subcommittee.
17                    CHAIRMAN SKILLMAN:              Good morning, Greg.
18 We can hear you loudly and clearly.
19                    MR. PICK:      Thank you.
20                    So, in our inspection we verified that 21 STP      had    properly      identified          those    structures, 22 systems, and components included in scope and made 23 appropriate          determinations          of      non-safety-related 24 systems        and  components        affecting        safety-related 25 components.
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89 1                  STP    had    established        adequate    programs 2 to manage aging of in-scope structures systems and 3 components,        as  specified        in    our    regulations        and 4 their Applicant's license renewal program.
5                  The    five    inspectors          on  the  team      had 6 experience        and    expertise        related        to  mechanical 7 systems        and    components,        electrical        systems        and 8 components,        and    structures.            Bill    Holston      also 9 accompanied us for one week of this inspection.
10                  During our two-week onsite inspection, 11 our      review    included      five      of      eight    new      aging 12 management        programs      and    14  of    32  existing      aging 13 management        programs.            We    walked      down    numerous 14 structures,          systems,      components          to    assess        the 15 adequacy        of    the      Applicant's            license      renewal 16 boundaries, in conformance with their application 17 and the Generic Aging License Renewal Report.
18                  These    walkdowns        enabled      us  to    assess 19 and evaluate whether the existing aging management 20 programs        would    be    successful        at    managing      aging 21 effects        for    in-scope        structure          systems        and 22 components.
23                  Next slide, please.              The results of our 24 inspection.          We determined that the plan had good 25 material condition.              They revised two procedures.
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90 1 They added susceptibility considerations when using 2 the        online    fact      manager,        and      they  developed 3 guidance        in  the    structures        monitoring      program      to 4 allow        for  noting      changes      and      trending.        This 5 included        things      such      as    taking        measurements, 6 providing more detailed descriptions, and the use 7 of photographs.
8                    They      changed        two      aging    management 9 programs        as  a  result      of    the      inspection.        They 10 removed the fuel supply line evaluation as part of 11 the Fire Protection Aging Management Program, and 12 they      initiated    corrective        action      documents    where 13 they will begin trending requirements added for the 14 type of test and accessible medium-voltage cables.
15 And the type of tests, for example, would be power 16 factor,        partial        discharge,          time      to  remaining 17 reflective        time,    reflect      time,      trending    each      of 18 those types.
19                    They        changed            five        application 20 commitments          and      the      related        aging    management 21 programs.        They changed their sampling criteria for 22 selecting fire water piping to flow tests.                              They 23 will need a flow test 20 percent of the piping up 24 to a maximum of 25 components during their flow 25 testing.        They will look at 20 percent or a maximum NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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91 1 of 25.
2                    They are going to clarify selecting the 3 representative            samples          frequency        inspection 4 requirements for the structures.                      They changed the 5 frequency for inside containment to five years, as 6 an example.
7                    They are going to clarify the purpose 8 of the benchmark and the essential cooling water 9 structure.        They have already done that.
10                    They    clarified        their      water    control 11 structure monitoring requirements, and they updated 12 the requirements to inspect the interior of their 13 metal        enclosed    bus    boxes.            Instead    of    using 14 external thermography, they are going to look at 15 the internals.
16                    Next slide, please.              As a result of our 17 inspection,          we    concluded        that      the  Applicant 18 performed the scoping and screening in accordance 19 with        the    rule.        The    information        was    easily 20 retrievable,        auditable,        and    consistent      with      the 21 rule requirements.
22                    From    our    reviews,        we    verified      that 23 existing        programs    effectively          managed    the    aging 24 effects.          We verified that the Applicant tracked 25 the completion of enhancements and development of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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92 1 new programs and a database, as they have already 2 described.
3                    Based    on    our    inspection        results,      the 4 team had reasonable assurance that the programs in 5 place or planned, as described by their commitment 6 table, with manage the aging effects and ensure the 7 intended          safety        and      function        of    systems, 8 structures, and components within the scope of the 9 rule.
10                    Does anyone have any questions?
11                    CHAIRMAN SKILLMAN:              Greg, yes, I do.          I 12 want to push back a little bit on the broadness of 13 your findings.            I am referring to page 54 in the 14 PDF      file    of  the    SER.        And    here    it  is  written, 15 "However,          upon      further        review,      subsequent        to 16 submittal of the LRA, the Applicant determined that 17 the      method      used    did    not    identify      all  non-safety 18 SSCs with the potential to impact the performance 19 of safety-related SSCs."                    This goes on to read, 20 "Following            this      determination,            the    Applicant 21 performed walkdowns of the applicable MAB and FHB 22 spaces        and  identified      additional        non-safety      SSCs 23 with the potential to impact safety-related SSCs, 24 and      provided      this    additional        information    to    the 25 staff in response to RAI 2.1-3."
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93 1                    Then,    that      paragraph        concludes        the 2 staff's        concerns    are    resolved.            What  gives      you 3 comfort that walking down the MAB and the FHB is 4 sufficient for thoroughness in this regard?
5                    MR. PICK:      When the team members walked 6 down the areas and did our reviews, what we saw 7 from using the drawings and looking at the safety-8 related components, the things that they said were 9 in scope were in scope.                So, during our individual 10 samples, we did not identify anything that they had 11 not previously identified.                  So, that was the basis 12 of our statement on the sample we took.
13                    CHAIRMAN      SKILLMAN:            Thank  you.          No 14 further question on that issue, Greg.
15                    MR. PICK:          Are      there    any      other 16 questions?
17                    MEMBER STETKAR:          Yes, I had one.          And I 18 think I understand, but I wasn't quite sure from 19 your        oral    presentation        what        they  are      doing 20 regarding        the  fire    protection        system.      Are      they 21 doing flow tests according to the -- I don't know 22 if they are NFPA requirements -- they are probably 23 NFPA requirements -- for flow testing.
24                    MR. PICK:      They do do the flow tests in 25 accordance with the NFPA.
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94 1                    MEMBER    STETKAR:          Okay.      Because      you 2 mentioned --
3                    MR. PICK:      That is something we look at 4 during our triannual fire protection inspections.
5                    MEMBER STETKAR:          Okay.      Good.
6                    You  did    mention      something      about      20-7 percent sampling or 25 items.                      What's that?        That 8 is not related to flow testing, though?
9                    MR. PICK:      No, no.        I misspoke.
10                    MEMBER STETKAR:          Okay.
11                    MR. PICK:        In    the    report  under      fire 12 water system, they had identified they were going 13 to take 10 samples for volumetric examination to 14 see        if    there    were      any      issues      during      their 15 enhancement        for  blockage.          What      they  are    really 16 going        to  do  is  take    a    20-percent      sample    of    the 17 piping or a maximum of 25 samples, because that is 18 what ends up statistically being the maximum they 19 would        need  to    take      of    the      fire  water      pipe 20 locations.          And they are, again, going to base it 21 on location and pipe size.
22                    MEMBER    STETKAR:            Okay.      Thank      you.
23 That helps clarify.            Thank you.
24                    CHAIRMAN SKILLMAN:              Greg, this is Dick 25 Skillman.          I have a question, a little different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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95 1 topic.
2                  I'm reading from our Status Report that 3 "The      staff  determined      that    the      Applicant    has      a 4 quality Class QC4 that was not addressed in the 5 application."        What can you tell us about QC4 and 6 its      applicability        to    our    deliberations        today, 7 please?
8                  MR. PICK:        I have no knowledge of that 9 classification and I would have to defer that to 10 the licensee.
11                  MS. JAMES:        Actually,        we  have    Billy 12 Rogers coming up to the microphone to answer your 13 question.
14                  CHAIRMAN SKILLMAN:            Thank you.
15                  MR. PICK:      Thank you, Lois.
16                  MR. ROGERS:        Good      morning.      This      is 17 Bill Rogers from the staff.
18                  So,  we    looked    at    that    when  we      were 19 doing        the  scope-instituting              methodology      audit.
20 Many applicants have a variety of classifications 21 for components and systems onsite.                        And if there 22 are multiple quality classifications that might be 23 applicable to the determination of safety-related, 24 we will review those during the audit.
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96 1 classification, QC4, that it wasn't clear how that 2 related to the determination of safety-related as 3 it would be applied in the implementation of the 4 rule.        So, we discussed that.
5                    And the answer that was provided to us 6 during discussion and, then, in the followup RAI 7 was QC4 could actually refer to both non-safety-8 related        and  safety-related          components.          So,      the 9 Applicant had reviewed all of the QC4 components 10 and      determined      those    which      are    identified,      those 11 which were safety-related, and include them within 12 the      scope    of  license    renewal        for    A1,  identified 13 those which were non-safety-related, and they would 14 have been included only if they were in scope for 15 A2,      non-safety      affecting        safety;        otherwise,      they 16 would have been excluded.                    And we determined that 17 as      an    acceptable      response        and      it  resolved      the 18 question.
19                    CHAIRMAN SKILLMAN:              Thank you.        Thank 20 you.
21                    Please proceed.
22                    DR. SCHULTZ:            I    have    one  general 23 question, Dick.            I would like to ask the question, 24 as one reads through the Inspection Report -- and 25 this      is    to  be  expected        --    but,      as  we  look      at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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97 1 license renewal and aging management, as you did 2 the      inspection,        you    had    the      opportunity      or    the 3 need, of course, to look at the corrective action 4 program, the program health reports, surveillances, 5 as you did your investigations.
6                    As    you      reflect      on      those  programs, 7 corrective              action,          program          health,        and 8 surveillance, that are maintained by the sites, did 9 you have any issues or particular concerns related 10 to any of those programs in general?
11                    MR. PICK:        During our inspection we did 12 not.        I also do fire protection inspections and 13 cybersecurity inspections.                  When we do our baseline 14 inspections, we also take corrective action program 15 samples.          We do look at surveillances, and during 16 those programs we have found that the licensee does 17 follow        their    tech    specs,      technical        requirements 18 manual,        do  proper      surveillances.            And  when    they 19 find      things      wrong,      they    enter        them  into    their 20 corrective action program and they resolve them.
21                    DR. SCHULTZ:            Did      you  find      the 22 resolution and process that they used to be robust?
23                    MR. PICK:      We do.
24                    DR. SCHULTZ:          Thank you.
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98 1 turn it back over to Lois?
2                    CHAIRMAN      SKILLMAN:            Colleagues,        any 3 more for our inspector?                  Colleagues, any more for 4 the inspector?
5                    (No response.)
6                    Hearing none, Lois, please proceed.
7                    Thank you, Greg.
8                    MR. PICK:      Thank you.
9                    MS. JAMES:      Thank you, Greg.
10                    In  the    next      few      slides  I  will        be 11 presenting the results as described in the SER with 12 open items.          SER Section 2 described the scoping 13 and screening of structures and components subject 14 to the aging management review.                      The staff reviewed 15 the Applicant's scoping and screening methodology 16 procedures, quality controls applicable to the LRA 17 development, and training of its personnel.
18                    The  staff      also    reviewed      the    various 19 summaries          of      the        safety-related          systems, 20 structures,          and      components,            non-safety-related 21 systems,        structures,        and      components      affecting 22 safety-related functions, and systems, structures, 23 and components relied upon to perform functions in 24 compliance        with    the    Commission's        regulations        for 25 fire          protection,        environmental          qualification, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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99 1 station        blackout,    pressurized          thermal      shock,      and 2 anticipated transients without a scram.
3                    Based on their review, the results of 4 the      scoping    and    screening        audit,        and  additional 5 information provided, the staff concludes that the 6 Applicant's        scoping      and    screening          methodology        is 7 consistent with the standard review plan and the 8 requirements of 10 CFR Part 54.
9                    Next slide.          SER Section 3 covers the 10 staff's        review    of    the    Applicant's          AMPs. For      a 11 given aging management review, the staff evaluated 12 the item to determine whether it is consistent with 13 the GALL Report and meets the requirements of 10 14 CFR Part 54.          Section 3.1 through 3.6 include the 15 aging        management      review      items        in    each  of      the 16 general system areas within the scope of license 17 renewal.          If an aging management review was not 18 consistent        with    the    GALL    Report,        then  the    staff 19 reviewed        the  Applicant's        evaluation          to  determine 20 whether the Applicant demonstrated that the aging 21 effects        will  be  adequately        managed,        so  that      the 22 intended        functions      will    be    maintained        consistent 23 with the current licensing basis for the period of 24 extended operation.
25                    Next slide, please.              The LRA identified NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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100 1 40 AMPs, and the Applicant subsequently added an 2 existing        program    in    response        to    License    Renewal 3 Interim          Staff      Guidance          ISG-2013-01,            aging 4 management of loss of coating or lining integrity 5 for        internal    coatings/linings              or    on  in-scope 6 piping,        piping    components,        heat        exchangers,      and 7 tanks issued in November of 2014.
8                    The left side of the slide identifies 9 the Applicant's original disposition of the AMPs, 10 and the right side identifies the staff review of 11 the AMPs, as documented in the SER with open items.
12 All        AMPs    were      evaluated        by      the    staff      for 13 consistency with the GALL Report.
14                    Next slide, please.                The staff closed 15 two open items associated with the aging management 16 review from the 2013 SER with open items under the 17 review of the aging management program.
18                    The first open item.                In reviewing the 19 open-cycle        cooling      water    system        AMP,  the    staff 20 found that the LRA did not describe the protective 21 coatings        used    in    the    essential          cooling    water 22 system,        nor    discuss          site-specific          operating 23 experience which would provide objective evidence 24 supporting the conclusion that the effects of aging 25 will      be  adequately      managed      during        the  period      of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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101 1 extended operation.
2                    Between February and November of 2012, 3 the        staff    issued        Requests            for    Additional 4 Information,          or      RAIs,      on      these      topics      and 5 documented an open item in the 2013 SER with open 6 items.          Subsequently,        in    November        of  2014,      the 7 staff        issued  ISG-2013-01        which      encompassed      these 8 issues.
9                    After reviewing the RAI responses and 10 changes        in  response        to    the        ISG,  the    staff 11 determined that the open cycle cooling water system 12 AMP is consistent with the GALL Report and meets 13 the requirements of 10 CFR Part 54.
14                    For the second open item, in reviewing 15 the one-time inspection AMP, the staff questioned 16 why the Applicant did not have an AMP to detect and 17 address cracking on the interior surfaces of the 18 RWST or other similar stainless steel tanks.                          If an 19 AMP is not necessary, the Applicant needed to state 20 the basis for why such an AMP was not necessary.
21                    In response to RAIs, STP detailed its 22 activities to characterize the cracking on the Unit 23 1 RWST and its proposed methods to manage the aging 24 effects          with      both        one-time          and    periodic 25 inspections.          Based on the staff's review of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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102 1 Applicant's    response,      the    concerns        regarding      the 2 cracking in the Unit 1 RWST were resolved and the 3 corresponding open item is closed.
4                DR. SCHULTZ:          Lois,      did  you  have      an 5 expectation that that might be extended to other 6 tanks?
7                MS. JAMES:        Yes, the program extends to 8 other stainless steel tanks.
9                DR. SCHULTZ:          But the focus here was 10 just for the RWST?
11                MS. JAMES:          Well,      the    question      rose 12 from operating experience regarding the RWST.                          So, 13 that is where the question started.
14                DR. SCHULTZ:        All right.          But, in terms 15 of the AMP program going forward, they are going to 16 be --
17                MS. JAMES:      Considering it --
18                DR. SCHULTZ:          --    applying      it  to    all 19 tanks?
20                MS. JAMES:      Yes. Yes, sir.
21                DR. SCHULTZ:        Thank you.
22                CHAIRMAN SKILLMAN:            Lois, thank you.
23                Before you leave this section on open 24 items closed -- thank you, John -- before you leave 25 this slide on open items closed, there is another NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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103 1 open item that has been closed.                        It is open item 2 4.3.2.11-1, the Effects of Thermal Aging on Cast 3 Austenitic Stainless Steel.
4                    MS. JAMES:      Yes, sir.
5                    CHAIRMAN SKILLMAN:              And written in the 6 documentation is this statement:                        "Use of minimum 7 material        properties        do      not      provide    adequate 8 protection in light of information from the past 29 9 years."          This  item    was    then      closed. Would      you 10 please        provide      an    explanation            of  how      this 11 determination was made that this open item can be 12 closed?
13                    MS. JAMES:      Can I defer that to Section 14 4?
15                    CHAIRMAN SKILLMAN:            Sure.
16                    MS. JAMES:        I    will      actually  address 17 that on slide 17.
18                    CHAIRMAN SKILLMAN:              Yes, that will be 19 fine.        Thank you, Lois.        Please proceed.
20                    MS. JAMES:        Okay.        I will now turn the 21 presentation over to Mr. Holston, who will address 22 the open item, the aluminum bronze open item.
23                    MR. HOLSTON:          So, the aluminum bronze 24 open item, as you heard the Applicant discussing, 25 initially, the aluminum bronze program was focused NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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104 1 on about 450 cast components that were susceptible 2 to    selective      leaching.          And    in    January    of    last 3 year, they came in and said, well, we are going to 4 replace        all    of    those      castings        because    we      had 5 questions related to what is the real strength of 6 the component when you de-alloy part of it.                              When 7 you saw the picture that they showed on the slide 8 with that little area of external de-alloying or 9 the      indication      you    could      see,      well,    how    do    you 10 really project what is going on inside the pipe to 11 do your operability evaluations?
12                    So,    those      are    all      being    replaced.
13 That, however, left, as was discussed, about 3300 14 welds.        Of course, that number will be lower when 15 castings are cut out and replaced, so you are still 16 talking        about    2,000      welds,        somewhere      in      that 17 ballpark,        that      are    susceptible            to    selective 18 leaching.
19                    As  a    result      of    our      review    of      the 20 changes to the program, you heard we had about a 21 10-part        open  item,    of    which      nine    of  those      were 22 closed by a submittal that changed the program.                              It 23 came in in September of 2016.                      So, I am going to 24 focus that point forward on this.
25                    So,  one    of    the    key      aspects  that      the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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105 1 Applicant was looking at is they had not had any 2 leaks        due  to  selective        leaching        in  these    welds, 3 these susceptible welds, since 1994.                        So, they did 4 some        metallurgical        testing.              They    did      some 5 calculations        on  cooldown      rates      on  welds  and      all 6 sorts of things, and then, came to postulate that 7 the root pass is less susceptible, and it is less 8 susceptible because the dilution, the higher rate 9 of dilution that occurs in the root pass and the 10 cooldown        rate  being      higher        than      in  subsequent 11 passes.
12                    So,  in    effect,      what      would  happen      is 13 they have reduced the susceptibility of the overall 14 weld to selective leaching of this aluminum bronze 15 because the root pass acts as a barrier.                          I mean, 16 you can almost kind of think of it as, well, it is 17 kind of like a coating and it is isolating the more 18 susceptible          passes      of      the        weld    from        the 19 environment.              If    you      isolate        it    from      the 20 environment, you are not going to have selective 21 leaching occur.
22                    And  some,    that    is    dependent    upon      not 23 having a construction-related or an in-service flaw 24 that penetrates through the root pass and, then, 25 unless        you  can      get      the    environment        in      the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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106 1 subsequent          passes      that      are      most    likely      more 2 susceptible.          That is where it is postulated they 3 had the through-wall de-alloying up to 1994, was in 4 welds        that    had,    you      know,      construction-related 5 flaws.
6                    So, as the staff and Lois talked about 7 audits we did on site, technical data we reviewed, 8 testing results we reviewed, the root pass as a 9 barrier        seemed    very    plausible        to  us. However, 10 there wasn't enough testing done.                        The Applicant 11 had      cross-sectioned,        you    know,      about  six    welds.
12 That was leaning in that direction, that that was 13 plausible.        So, we proceeded from that point.
14                    So, we can go to the next slide, slide 15 No. 13.        I just want to talk about a couple of the 16 conclusions we derived from not only looking at the 17 Applicant's            results          of        their      destructive 18 examinations, but also in a lot of review of the 19 technical literature that is available.
20                    The  de-alloying        process      occurs      at    a 21 microstructure          level,    and    it    is  confined    for      a 22 localized front at scales with a grain size.                          Those 23 are      some    really    cool    words,      right,    and  he    is    a 24 metallurgist, but what does it really say to you?
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107 1 of these welds or any material that is susceptible, 2 you basically have a front of de-alloying that goes 3 through.        On one side of that front it is 100-4 percent de-alloyed; on the other side of the front 5 it is not de-alloyed.              Now, of course, if you can 6 keep exposing the environment as you pass through 7 those grains, those are going to become de-alloyed 8 eventually.      However, that is what it is.
9                  So, the material on either side of that 10 front that goes through the material is either in 11 its      as-received  material        properties        or  it  is      in 12 fully de-alloyed material properties.                      We concluded 13 from the data that the Applicant had constructed on 14 testing of material properties for the de-alloyed 15 material within the bulk component that there was 16 insufficient        data      to      bound        the    mechanical 17 properties.
18                  We are very fortunate to have a person 19 on staff, Chris Sevanick, who was involved in the 20 Navy      Air Program,      had    actually        been  involved        in 21 developing material properties from testing, and, 22 basically, had to go through all that data.
23                  So, based on the number, the size of 24 the population of tests they had, and based upon 25 some        of the  scatter      within        those    results,        we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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108 1 basically came to a conclusion that you would not 2 give      any    credit    or    there      would      be  no  strength 3 credit, in other words, no tensile value, for de-4 alloyed properties or fracture toughness credit.
5                    Now the Applicant throughout, even back 6 in    the    eighties    when    they    did    their    operability 7 evaluations and they did their calculations, never 8 credited any material properties for the de-alloyed 9 portions, right?            And so, that is nothing new or 10 big, but it is important when we talk later about 11 structural integrity.
12                    Next slide.        So, given what we knew and 13 what      the    Applicant      changed      in      the  programs,        I 14 wanted to highlight some of the key features of the 15 program that lead us to a conclusion that we are 16 down to just one last open item.                      And some of those 17 you have heard already.
18                    But in the detection of aging effects 19 program        element,    the    Applicant          is  going    to      do 20 volumetric          inspections.                  These      volumetric 21 inspections        will    look    to    see      if    there  is    weld 22 defects,        weld  defects      that    could      be  progressing 23 through the root pass, right?                      So, these are not 24 ultrasonic exams that are going to measure how much 25 de-alloying        is  going      on.      We    are    going  to    talk NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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109 1 about        that  maybe    in    a  little      bit,    just    as      an 2 overview.
3                    But those volumetric examinations will 4 provide        information      that,    in    fact,    based    upon      a 5 representative sample, we aren't seeing, we haven't 6 seen from the last time they did these volumetric 7 examinations        during      the    plant      construction,        that 8 there        aren't    weld    defects      that      are  propagating 9 through the root pass.
10                    They    are      going      to    do    destructive 11 examinations in addition.                  And in doing this, you 12 heard a lot about 25, 20 percent.                        Twenty percent 13 is immaterial in this case, right, because it is 14 25.          So,  there    is    going    to      be  25  volumetric 15 inspections for the welds with backing rings and 16 welds without.          There is going to be 25 destructive 17 examinations of welds with backing rings and welds 18 without.          So, in effect, we are going to see 50 19 welds cross-sectioned.
20                    There    will      be    continuing        inspections 21 for      leakage. How    the    licensee        has    been  managing 22 this      selective    leaching      since      the    days  that        it 23 started occurring is every six months they do a 24 walkdown of all the above-ground piping.
25                    One  of    the    pictures        you  saw    or    the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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110 1 picture they showed you is very characteristic of 2 what      you  see  if  you    see    selective        leaching.          I 3 actually did a walkdown with one of the Applicant 4 staff members, and there was a fitting, you know, a 5 much      smaller    fitting.          It    was      about    a    3-inch 6 fitting that showed that little fluorescent break 7 there.
8                    Then,    in    addition,        they    look  at    yard 9 areas        to  detect    if    there    is      moisture      that      is 10 unusual that shouldn't be there.                        That would seem 11 odd.        How do you that?        Well, we explored that with 12 the Applicant.          We looked at detailed calculations 13 that      demonstrated      that,      if  you      have  a  10-gallon 14 permatted leak, it will get to the surface within 15 30 days.        And they have a huge margin there.                      They 16 have about a margin of 1,000 gallons, I mean that 17 they can tolerate.
18                    I am not a hydrology expert.                  I looked 19 at      the    calculations.          So,    fortunately,        the      New 20 Reactors Organization, they had a hydrology expert.
21 He reviewed those calculations and felt that they 22 were      well-bounded      and    well-founded.            So,  albeit, 23 you can't look for leakage on the outside surface 24 of the components that are buried, we can observe 25 for an indirect effect and be convinced that there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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111 1 is      no    leakage    going    on    that      would    affect        the 2 intended function.
3                    Of course, when they do opportunistic 4 buried pipe inspections, they will actually go in 5 and look at the coatings for those pipes.                        All this 6 piping is coated that is buried.                        Of course, that 7 isolates the susceptible weld layers, you know, the 8 crown pass from the environment.
9                    So, that is basically what is going to 10 go on with detection of aging effects.                        Basically, 11 at    the    end  of    that,    having      done    the  volumetric 12 examinations          to    show      that,      yes,    after        that 13 representative          sample,      we    don't      see  any    defects 14 that are challenging the root pass, and we will 15 have 50 examinations that will actually not only 16 look at is there de-alloying going on, but it will 17 look at the phase, the actual phases within that 18 cross-section            that      will        be      sufficient            to 19 demonstrate        that    the    theory,        which    we    think        is 20 true, is that root pass is more resistant to de-21 alloying and protects the other layers of the weld.
22 And that is one reason why they haven't had any 23 leaks since 1994.
24                    Yes, sir?
25                    MEMBER      RICCARDELLA:              How    does        the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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112 1 presence of a backing bar affect this protection --
2                    MR. HOLSTON:          Well,      the  backing      ring 3 does two things.              It does one good thing and it 4 does one bad thing.                There are two effects that 5 contribute to whether the welds are going to be 6 susceptible.
7                    One    is,    with      the        dilution,      with 8 diluting the welds, you have a lower concentration 9 of aluminum, which with the samples they have taken 10 they        have  demonstrated        it.        They    can  show      a 11 difference across the passes as you go.
12                    The  other    thing      is    the    backing      ring 13 allows you to have a greater heat sink, which cools 14 it down quicker.            If you cool it down quicker, you 15 don't get the gamma-2 or the beta phase that are 16 susceptible to selective leaching aluminum bronze.
17                    The downside of having a backing ring 18 is that it gives you kind of a notch.                        It gives you 19 a    localized      place    where      it  can      concentrate        and 20 adverse        chemistry        that    can      cause      a  selective 21 leaching.            So,      that      is    why      the    Applicant 22 identified, you know, we have got a backing ring 23 population.          We are going to do 25 of those.                        We 24 have      got  a  non-backing-ring          population.          We    are 25 going to do 25 of those.
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113 1                    MEMBER RICCARDELLA:            Okay.
2                    MR. HOLSTON:          So, any other questions 3 on detection of aging effects?
4                    DR. SCHULTZ:        Bill --
5                    MR. HOLSTON:        Yes?
6                    DR. SCHULTZ:        -- one more question.                We 7 have      kind  of  bounced      back    and      forth  between        a 8 representative sample and 25.
9                    MR. HOLSTON:        Uh-hum.
10                    DR. SCHULTZ:          With        regard    to      the 11 destructive        examinations,          what        are  the  staff's 12 expectations if, when those are done, issues arise 13 as    a    result  of  the    investigation?            I  mean,      you 14 could          hypothesize        you      do        the    destructive 15 examinations and you find issues.
16                    MR. HOLSTON:        Correct.
17                    DR. SCHULTZ:          What      are  the  staff's 18 expectations of what will be done if in examining 19 25 and 25 that there are problems identified?
20                    MR. HOLSTON:          Can I defer that just to 21 the next slide?
22                    DR. SCHULTZ:        Sure.
23                    MR. HOLSTON:          Because        I am  going      to 24 address that within corrective actions.
25                    DR. SCHULTZ:        Thank you.
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114 1                  MR. HOLSTON:            So,      yes,  I  will        go 2 through acceptance criteria and, then, get to that 3 and I will answer your question I think directly.
4                  Any other questions on detection, how 5 they are going to detect these aging effects?
6                  MEMBER SUNSERI:            Yes.        With regard to 7 the underground pipe and just looking for moisture, 8 or what have you, to reach the surface, was there 9 any consideration of using other techniques such as 10 ground-penetrating radar or something like that to 11 get on top of the leaks faster?
12                  MR. HOLSTON:          The simple answer to the 13 question is no, because there is a huge -- but the 14 answer to why is that there is a very large margin.
15 They can detect a 10-gallon-per-minute leak.                            They 16 can      tolerate    1,000      gallons      per      minute.        Now, 17 clearly, if they had a 1,000 gallons a minute, that 18 is going to be washing out soil.                        It could affect 19 structural        integrity      evaluations.            But  selective 20 leaching is not a rapidly-propagating phenomenon.
21 You know, you are not going to go from 10 gallons a 22 minute one day and now, suddenly, you are at 500 a 23 month        later,  right?        It    is    just    not  going        to 24 happen.        So, that is why we didn't --
25                  MEMBER SUNSERI:          Yes.      Thank you.
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115 1                    MEMBER STETKAR:          Bill, should I ask you 2 about the buried and underground piping program now 3 or should I ask you about it at all?
4                    MR. HOLSTON:        Well, you can ask me.
5                    MEMBER STETKAR:          Okay.
6                    MR. HOLSTON:          And      why  don't    you      go 7 ahead?
8                    MEMBER STETKAR:          Okay.
9                    MR. HOLSTON:        We might have Brian Allik 10 answer some of that.              Brian Allik is taking some of 11 that over.
12                    MEMBER STETKAR:          Yes.      Well, let me get 13 to where I was headed.
14                    MR. HOLSTON:        Sure.
15                    MEMBER STETKAR:            We heard earlier that 16 the license renewal application checked off a box 17 that said the cathodic protection system is not in 18 scope for license renewal.                So, does that mean that 19 in their buried and underground piping inspection 20 program        they    are    applying        the --      I  don't    know 21 whether it is Category E or Category F of their 22 inspections.        In other words, not taking credit at 23 all      for    cathodic    protection?            Or  what  are    they 24 doing?
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116 1 that.          What it means is, when we say the cathodic 2 protection system is not within the scope, it is 3 the wires; it is the panels; it is the rectifiers 4 that aren't in scope.
5                    So, what we did was we built into Aging 6 Management        Program    41  for    buried      and  underground 7 piping the measurement of the cathodic protection 8 from two perspectives.              And that is what drives you 9 to those additional inspections in Category E and 10 F, as you mentioned.
11                    MEMBER STETKAR:          Yes.
12                    MR. HOLSTON:          So, the Applicant has to 13 measure the amount of time the current is turned 14 on.        Somebody trips a breaker open for something 15 and it has been off for two months, that is going 16 to be a problem, right?                Because if you don't pull 17 the      electricity,      you    are    not      going  to  get      the 18 cathodic protection.              So, there is a criteria for 19 that, and that is 85 percent of the time it has to 20 be on.
21                    We also have a criteria, then, for the 22 effectiveness of it.              And that is measured by the 23 annual cathodic protection surveys.                        You have to 24 demonstrate that you have negative 850 millivolts.
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117 1 in higher resistivity soils -- that is negative 750 2 or negative 650.            We also allow for actually direct 3 measurement of corrosion rates.                      But, if you can't 4 demonstrate        that    you    are    meeting      that  level      of 5 protection, then you have to go to E or F --
6                  MEMBER STETKAR:          Right.
7                  MR. HOLSTON:          -- and do the additional 8 inspections.
9                  And what demarcates between E and F is, 10 if your plant-specific operating experience is good 11 and      meets  the    criteria        in    the    AMP,  then      your 12 cathodic protection is upright, up-to-speed, you do 13 E, which is three every 10 years.                      But, if you also 14 have bad operating experience, then you have got to 15 go to six every 10 years.
16                  MEMBER STETKAR:            Right.        So, I think 17 what      I  hear  you    saying      is  that      they  will    -- I 18 always hate to say "take credit" -- but they will 19 take      credit    for  cathodic      protection        with  all      of 20 those        caveats    in    determining          the    frequency      and 21 extent of their piping inspections?
22                  MR. HOLSTON:            Right.        Because,        in 23 effect, what we are doing is, rather than going to 24 the panel and seeing if it is leaking --
25                  MEMBER STETKAR:          No, no.
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118 1                  MR. HOLSTON:          -- rather than checking 2 the wires, we performance monitor the effects of 3 the        cathodic      protection            system      with        the 4 availability and the effectiveness.
5                  MEMBER STETKAR:          Yes.      Thank you.      That 6 helps.
7                  MR. HOLSTON:        Any      other  questions      on 8 detection of aging effects?
9                  (No response.)
10                  Okay.        For    the    acceptance    criteria, 11 what they will do when they do the volumetric exams 12 is, obviously, they are looking for any plane or 13 flaw that would exceed 80 percent of the root pass 14 if it is connected -- you know, you could have a 15 plane or flaw within.              So, here's your water.              And 16 so, your inside diameter of your pipe, and you have 17 your pipe, you know, your outer edge of your root 18 pass.        If it is up here, we are not really worried 19 about        it. We    are    here      with    an  environment 20 connected plane or flaw.
21                  And with the destructive examinations, 22 the      microstructure      of    the    root    region,  we      are 23 looking to see that we are reasonably certain they 24 are going to see some gamma-2 in the welds, right?
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119 1 want to see that that is surrounded by the alpha 2 phase        which    is    not      susceptible          to  selective 3 leaching.          And if the gamma-2 or the beta phase 4 would exceed 80 percent of the depth of that root 5 pass, then we have an issue.                    And so, that is the 6 microstructure monitoring.
7                    And I did have a typo -- I apologize 8 for that -- in the third acceptance criteria, which 9 is the walkdowns every six months.                      They will go to 10 monthlies        if  they      have    some    other      problems,      but 11 those are just they are looking for leakage, is 12 what the acceptance criteria is for that.
13                    CHAIRMAN      SKILLMAN:            Bill,    has      the 14 Applicant ever discovered a geyser?                      Have they ever 15 seen a leak great enough to really push water out 16 of the soil?
17                    MR. HOLSTON:            I      looked    at    their 18 operating        experience      when    I    did    the  buried      pipe 19 audit and saw none, no, sir.
20                    CHAIRMAN SKILLMAN:            Okay. Thank you.
21                    MR. HOLSTON:              Any    questions          on 22 acceptance criteria?
23                    (No response.)
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120 1 Mr. Schultz was asking about.
2                    So, if they find a problem within the 3 volumetrics for weld defects that are penetrating 4 the      root    pass,    they    have    to      do  five  additional 5 volumetric examinations until they see none.                            And 6 for the destructive examinations, the criteria is 7 the      same.        It    is,    if    you      see  that    phased 8 distribution          not      what      we      would    expect,        not 9 supportive of what the theory is, then you have to 10 keep      doing    five    more    until      you    don't  see    that 11 anymore.          The    five    comes      from      Generic    Letter 12 90-05, which the Applicant commented upon.                          It is 13 the        NRC  staff    basic      position        when  you      find 14 something that is adverse that you look more until 15 you find the issue.
16                    Does that answer your question?
17                    DR. SCHULTZ:        Yes.      Thank you.
18                    MR. HOLSTON:          Okay.        Now  another 19 aspect,        though,      which      is    structural      integrity 20 calculations            conducted          with        the    as-found 21 conditions, so, then, the question is, well, what 22 is a corrective action if you find an issue with 23 structural integrity?
24                    So,  the    staff    is    concerned    with    that 25 because,        if  you    find      an    issue      with  structural NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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121 1 integrity,          you  have    an    issue      with  the  intended 2 function of the system.                  And so, that is where we 3 are      right    now  with    the    Request      for  Additional 4 Information.
5                    The licensee has worked with EPRI and 6 done some testing of a UT volumetric method that 7 should        be  able    to    actually        take  the    weld      and 8 measure        the  amount    of    de-alloying        that  is    going 9 inside, from the inside, from the ID to the OD.
10                    So, what you could picture, if you are 11 looking at a ring, is here it is penetrating 60 12 percent.          That would be bad, right, because it is 13 through the root pass?                But, over here, it is just 14 penetrating          10  percent,      and    there    is  none      down 15 here.        And it just is based upon reasonable theory.
16                    We were aware of Vermont Yankee doing 17 the cast iron piping.              We just hadn't been aware of 18 anybody        doing  it    for    aluminum        bronze  welding        or 19 fittings.
20                    And so, our RAI talks about, well, tell 21 us how you are going to demonstrate the method, how 22 you        are    going      to    quality        people,    what      the 23 resolution of that process is, and several other 24 questions on sampling size and all of that.                                So, 25 that is the remaining open item, is, what are you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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122 1 going        to  do    for    corrective            actions    if      the 2 structural integrity evaluation isn't acceptable?
3                    CHAIRMAN SKILLMAN:              Bill, as a matter 4 of admin as we look into the new year, is it these 5 RAIs that will not be presented until after March?
6                    MR. HOLSTON:        I don't -- well --
7                    MS. JAMES:        We have not issued the RAI 8 yet.        So, we have to issue it.                They have to have 9 their        30  days  to    respond      and,      then,    we  need      at 10 least 30 days to look at what their response is.
11                    And in this instance, we have to get 12 another division involved.                  So, we wanted to give 13 ourselves a little extra time to review what comes 14 in, which is why we are discussing delaying the 15 full Committee from February.
16                    CHAIRMAN      SKILLMAN:              Thank    you.          I 17 understand.
18                    MR. HOLSTON:          The RAI has been peer-19 reviewed.
20                    CHAIRMAN SKILLMAN:            Okay.
21                    MR. HOLSTON:          It has been approved by 22 management, but we have to get it out.
23                    CHAIRMAN SKILLMAN:              Thank you for the 24 explanation.          We were trying to get clear on timing 25 and the workload for the Committee.                      And this gives NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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123 1 us an explanation of what is happening.                    Thank you.
2                  Please proceed.
3                  Go ahead, John.
4                  MEMBER STETKAR:          I was going to say, do 5 you have more on this?
6                  MR. HOLSTON:          No, no, that is the end 7 of my presentation.          If you have any questions --
8                  MEMBER STETKAR:          Let me go back to the, 9 for lack of a better term, risk-informed sampling 10 process.        Is the staff good with taking a random 11 sample,        you  know,      throwing          a    random    number 12 generator in and taking a random sample of any 25 13 of the 3300, I think I wrote down here?
14                  MR. HOLSTON:          Yes,      we  are  thinking 15 there is about 2,000.              Once you cut out the 400-16 some-odd fittings --
17                  MEMBER STETKAR:            All right.        I don't 18 want to get down too much.
19                  (Laughter.)
20                  MR. HOLSTON:        It is a little bit less.
21                  MEMBER STETKAR:          But 25 out of a large 22 number --
23                  MR. HOLSTON:        Right.
24                  MEMBER        STETKAR:                  --    randomly 25 selected --
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124 1                    MR. HOLSTON:          What      we  did  was      Matt 2 Homiack, who is back here in the room, he is in 3 Research now, did some calculations, finite element 4 heat        transfer    calculations            to    determine          how 5 sensitive that is.                And he is coming up to the 6 microphone, and I would like to give him credit for 7 the great work he did in that regard.                          I think he 8 is going to have some positive answers for you.
9                    MR. HOMIACK:        Thank you, Bill.
10                    So,  the    Office      of    Nuclear    Regulatory 11 Research has been supporting NRR --
12                    CHAIRMAN      SKILLMAN:            Excuse    me,      sir.
13 Identify yourself, please.
14                    MR. HOMIACK:          Matthew Homiack from the 15 Office of Research.
16                    CHAIRMAN      SKILLMAN:            And,  Matt,      make 17 sure      you  speak  up    in  the    microphone,        so    we    can 18 hear.
19                    MR. HOMIACK:          Will do.        Thank you.          Is 20 this okay?
21                    CHAIRMAN SKILLMAN:            Yes.
22                    MR. HOMIACK:        So, there is actually two 23 --    it    is  a  smart    sample.        There      is  two    sample 24 populations, first of all.                One, welds with backing 25 rings and one of welds without.                          And I believe, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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125 1 Bill, each will get 25 destructive examinations.
2                    And so, the reason for looking at those 3 differently        is  the    welds    with      the  backing      rings 4 have        the  operating      experience,          and    the      welds 5 without the backing rings are more susceptible root 6 pass      to  de-alloying      because      they    have  a  quicker 7 cooldown rate.
8                    The    Applicant      has      done    some    cooling 9 rate        analyses,    which      the    staff      has  done      some 10 independent confirmatory calculations as well, and 11 we think their cooldown rates are conservative.
12                    MR. HOLSTON:            And      Matt,    in      his 13 calculations,          varied      heat      inputs,      the      exact 14 question        you    were    asking.          Because    one    of    the 15 concerns we had was not so much some variation from 16 welder to welder, but if you are hanging upside-17 down and trying to make that weld versus doing a 18 flat      weld,  doing    a  vertical        weld,    you  know,        as 19 well-controlled          as    weld    procedures      are,    it    is    a 20 little tougher to make some of those welds.                                And 21 would they have a higher heat input or something?
22                    But the calculation, it is not really 23 -- the cooldown rate is not very sensitive to a 24 reasonable range of expectations of heat input from 25 the weld.          So, the random sample is reasonable.
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126 1 Now the AMP does say, the aging management say that 2 they      will    take    into    effect        construction-related 3 factors.
4                    MEMBER POWERS:            If I just assume that 5 they have a random population --
6                    MR. HOLSTON:          I'm      sorry,    I  couldn't 7 hear you.        What?
8                    MEMBER POWERS:          If I assume that I have 9 a random population, in other words, defects are a 10 random sort of thing, which may not be true, but 11 close enough for argument's sake, and I look after 12 three refueling inspections.                    So, I have a sample 13 of 75.          I would probably have a 95-percent chance 14 that      I  have  covered      90    percent        of  the  range      of 15 things.
16                    So, while the number looks small, it is 17 pretty        powerful    if    you      don't        have  systematic 18 effects.          And that, coupled with your walkdown to 19 identify systematic vulnerabilities, it appears to 20 me, though, it is 25 of a large number, the fact is 21 random sampling is a pretty powerful technique for 22 identifying outliers in that range.
23                    MEMBER STETKAR:            Well, except for how 24 frequently do they do this destructive examination 25 sampling.
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127 1                    MR. HOLSTON:          Well, if they are going 2 to do the destructive examinations, it is a one-3 time destructive examination.                    Because you want to 4 demonstrate with adequate data that that root pass 5 is less susceptible.
6                    MEMBER STETKAR:          So, the sample is not 7 after three refuelings.                It is a one-time.              It is 8 25.      So, you have a little lower confidence.
9                    MEMBER    POWERS:        Yes,      it  is  a    fairly 10 sharp function --
11                    MEMBER STETKAR:          Yes.
12                    MEMBER      POWERS:            --    that    moves        up 13 rapidly.
14                    MR. HOLSTON:        The      actual    numbers        are 15 that        the 25 is a 90/90 certainty.                    That is the 16 number.        So, where we have adopted that throughout 17 the      GALL    Report    and      several        aging    management 18 programs is, where you are demonstrating that an 19 aging        effect  is    not    likely      to      cause  a  loss        of 20 intended function, we use 90/90.
21                    Now,    for    example,        when    talking      about 22 structural        integrity,        there      is      a  challenge          to 23 structural        integrity,      the    certainty        needs      to      be 24 higher.          So,  for    these    welds      that    we  are      doing 25 where        we  have  seen    some      cross-sections,            right, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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128 1 about        six    welds    that      they    cross-sectioned            that 2 support the theory, we want to have enough to say 3 that that is reasonable, that they are not going to 4 de-alloy through the root pass, go into the higher 5 susceptible          weld      passes,        and        then,    de-alloy 6 through-wall.            And    so,    that    is    why  we  are    very 7 comfortable          with    the    25    and    the    random    at    this 8 point.          But the RAI addresses what happens if you 9 see more consequential results --
10                    MEMBER STETKAR:          Yes, I didn't read the 11 RAI.
12                    MR. HOLSTON:        Yes.          Yes,  we  haven't 13 given that to you yet.              It is not published yet.
14                    MS. JAMES:          It      is    not    publicly-15 available yet.            So, it will be public and it will 16 issue in the next week or so.
17                    MEMBER BALLINGER:              So I have it clear 18 in my head, the weld heat input and all of that 19 stuff for the various sizes of welds, it is not 20 that much different welds.                    So that there is not 21 likely        that  there    will    be    a    distinction,        there 22 would be a distinction between small diameter or 23 large diameter.            That is not going to be an issue 24 that unrandomizes things, if you will?
25                    MR. HOLSTON:        That is correct, yes.
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129 1                    MEMBER BALLINGER:          Okay.
2                    MR. HOLSTON:        And again, we didn't just 3 -- because, well, suppose in the audience that his 4 company did some of the finite element calculations 5 for the cooldown, and we didn't just take that at 6 face value.          Matt Homiack did his own independent 7 evaluations to that effect.
8                    MEMBER BALLINGER:              Okay. Some of us 9 remember, well, it only happens to small diameter 10 pipes.        And then, well, it only happens to slightly 11 larger diameter pipes.              And then, yes --
12                    MEMBER RICCARDELLA:              Bill, as you know, 13 the other side of risk-informing this type of a 14 selection is to look at consequences.                      Is there any 15 ability        to    distinguish        from        different    piping 16 locations        based  on    the    consequences        of  failure?
17 And what are we looking at?                  I mean, are we looking 18 at an actual rupture that we are concerned about or 19 just a leak?
20                    MR. HISER:      Okay, so two parts to that.
21 We are sampling to try to demonstrate that all of 22 the 2,000 welds are okay.                    Are there welds that 23 would        have  a  higher        consequent?          Absolutely.
24 Right, because there are welds in the main header.
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130 1 for diesel, and those would be more.                            There are 2 welds that are downstream of the coolers.                          It has 3 already done its function as long as it doesn't 4 flood the room.            All it is doing is going to the 5 bay, or not the bay, to the pond, right?
6                    So,    we      didn't      factor        in  in      any 7 selection          the    consequential            because      we      are 8 confident, based upon what we have seen with the 9 testing results, also with what Matt has done with 10 the backup analyses, that what you see in a weld 11 here that is a very critical weld would be the same 12 thing because the environment is the same here; the 13 weld processes are the same, and the sensitivity to 14 the      amount    of  heat    put    in      with    the  weld        is 15 virtually, you know, it doesn't really affect the 16 potential for additional beta or gamma-2.                          So, we 17 didn't say, make sure you do all your sampling of 18 your      welds    upstream      or    in    the      main  header,        or 19 anything like that.
20                    MR. HOLSTON:          Well,      the  consequence, 21 yes.          Yes,  as  Allen    is    saying,        the  consequence 22 issue        gets    into    whether      what        you  see  affects 23 structural integrity.                And so, that is where we 24 have a four-page RAI to address what -- you know, 25 that is why the corrective actions for structural NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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131 1 integrity is still an open item.                      You know, we are 2 hopeful        that    this    volumetric        technique    will        be 3 something that we can accept it.                        Of course, with 4 the volumetric technique of that nature, they could 5 look at a lot of welds.                  They could zero into the 6 more consequential welds in that case.                        Because, to 7 date, of all the casting failures, castings are a 8 lot more susceptible than the welds are, and on the 9 weld      failure    side,      they    have      not    had  one      that 10 failed structural integrity criteria.
11                    MEMBER    RICCARDELLA:              Question.          You 12 know, when you say "structural integrity criteria,"
13 you say, well, the stresses are higher than the 14 allowable stress, or something like that.                          But is 15 there any concern at all about a rupture of one of 16 these or are we mainly just concerned about a leak?
17                    MR. HOLSTON:          Because of the very low 18 operating          pressure        at      very        low    operating 19 temperatures, we are not too concerned.                          And they 20 have very low seismic loads, too.                          We looked at 21 their        seismic    analyses.          There      is  nothing      huge 22 there.
23                    We would be more concerned with a leak 24 than we would be -- but they have done a lot of 25 analyses        on  the    leak    rates,        the    allowable      leak NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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132 1 rates versus detectability of those leaks.                          And we 2 have        reviewed    all      of    that,      and    that  is      all 3 documented,          that      we      feel        they    have        the 4 detectability to see it before it could approach to 5 a leak that would starve the heat exchanger, or 6 whatever.
7                    MEMBER RICCARDELLA:            Thank you.
8                    CHAIRMAN      SKILLMAN:            Let's    proceed, 9 please.
10                    Bill, thank you.
11                    MR. HOLSTON:        Yes, sir.
12                    MS. JAMES:        Okay.        We are now on slide 13 16.          SER  Section      4  identifies          the  time-limited 14 aging analysis, or TLAAs.                    Section 4.1 documents 15 the staff's evaluation of the Applicant's basis for 16 identifying plant-specific or generic analysis that 17 need to be identified as TLAAs and determine that 18 the      Applicant    has    provided      an    accurate    list,      as 19 required by 10 CFR 54.21(c)(1).
20                    Sections 4.2 through 4.7 document the 21 staff's        review    of    the    applicable        STP  TLAAs      as 22 shown.          Based on its review and the information 23 provided by the Applicant, the staff concludes that 24 the      TLAAs    will  remain      valid      for    the  period      of 25 extended operation.              The TLAAs have been projected NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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133 1 to the end of the period of extended operation or 2 the effects of aging on those intended functions 3 will        be    adequately      managed      for    the    period        of 4 extended          operations,        as    required        by  10        CFR 5 54.21(c)(1).
6                    Next slide, please.              There is one TLAA 7 open item from the 2013 SER with open items that we 8 closed        in  this  2013      SER    --    or    2016  SER.          In 9 reviewing the effects of thermal aging on CASS, the 10 staff        was  concerned      that    the    Applicant's      thermal 11 embrittlement          evaluation        of  CASS      material    in    the 12 leak-before-break piping relied upon an evaluation 13 and data from 1983.                The staff issued RAIs between 14 April        2011    and  November        2013      and  documented        its 15 concerns as an open item in the 2013 SER with open 16 items.
17                    In response, the Applicant stated that 18 the        referenced        material,          fractured        toughness 19 properties, for their evaluations are shown to be 20 bounding.          In addition, the Applicant revised its 21 LRA to identify the fracture mechanics evaluation 22 as a TLAA and dispositioned it in accordance with 23 10      CFR    51.21(c)(1)      as    an  analysis      that    remains 24 valid for the period of extended operation.
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134 1 used a bounding fractured toughness value for its 2 leak-before-break analysis, and that the fractured 3 toughness          used    is    applicable            to    60    years.
4 Therefore, the staff concluded that the revisions 5 to the LRA are acceptable, and the open item is 6 closed.
7                    Mr. Skillman,        do        you    have      more 8 questions?          We have our technical reviewer in the 9 audience.
10                    CHAIRMAN      SKILLMAN:            No.      You      have 11 addressed the question that I raised earlier.
12                    MS. JAMES:      Okay.
13                    CHAIRMAN      SKILLMAN:          I'm    good.      Thank 14 you.
15                    MS. JAMES:        The    next      slide,    please.
16 Pending        the  satisfactory        resolution        of  the    open 17 item,          the    staff      will      determine          whether        the 18 requirements of 10 CFR 29(a) have been met for the 19 license renewal for South Texas Project Units 1 and 20 2.
21                    This concludes our staff presentation, 22 and      we    will    now    be    available          for    any  further 23 questions from the Subcommittee.
24                    Thank you.
25                    CHAIRMAN SKILLMAN:            Lois, thank you.
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135 1                    Colleagues, I invite any questions you 2 might have for the staff at this time.
3                    (No response.)
4                    Hearing none, I have one.                  There is a 5 very        interesting        discussion            in    the      Safety 6 Evaluation        about    whether      or    not      there    are      vent 7 valves on the aux feedwater pumps.                          And when you 8 read the text, the text is convoluted.                            First of 9 all,      it  says  there    are    some,      then    there    aren't 10 some.        Then, some are in and some are out.                      And I 11 am wondering if anybody can speak to this.
12                    MS. JAMES:      Okay.        Your question is, do 13 the feedwater pumps have vent valves?
14                    CHAIRMAN      SKILLMAN:                Aux    feedwater 15 pumps.
16                    MS. JAMES:        Aux  feedwater        pumps      have 17 vent valves and are they or are they not within the 18 scope of license renewal?
19                    CHAIRMAN SKILLMAN:            Yes, and it is page 20 127 in the PDR file of the SER.                        I don't need to 21 read the text.            It just seems as though there was 22 an    awful    lot  of  traffic      on  this      subject,      and    I 23 found it extremely confusing.                  And I said, oh, wait 24 a minute, most of these pumps do have some kind of 25 a vent valve.            Most of them have some valves on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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136 1 piping that is connected to the casing.                        So, it is 2 not a substance of issue, but I found the text in 3 the SER very --
4                  MS. JAMES:      Confusing?
5                  CHAIRMAN SKILLMAN:            -- confusing.
6                  MS. JAMES:        Okay.        Well, first, I will 7 take      an  action  item    to    try    to      make  sure    we      do 8 something with that in the Final SER.
9                  CHAIRMAN SKILLMAN:                It is 127 in the 10 PDR file.
11                  MS. JAMES:          Is that Section 2 of the 12 SER?
13                  CHAIRMAN SKILLMAN:            This is.
14                  MS. JAMES:      It has got to be.
15                  CHAIRMAN SKILLMAN:            It's -87.
16                  MS. JAMES:      2-, yes.
17                  CHAIRMAN      SKILLMAN:          2-87  is  the    text 18 page.
19                  MS. JAMES:        Okay.          I  guess  at    this 20 point I'm going to have to take that as a takeaway.
21                  CHAIRMAN SKILLMAN:            If you would.
22                  MS. JAMES:      Yes.
23                  MEMBER STETKAR:          Maybe South Texas can 24 tell us whether or not, indeed, the aux feedwater 25 pumps have vents.
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137 1                    CHAIRMAN SKILLMAN:            Yes.
2                    MR. GIBBS:      We have vent valves.
3                    MEMBER STETKAR:            You actually have to 4 tell us on the record.
5                    (Laughter.)
6                    MS. JAMES:            Yes.          And    identify 7 yourself, too.          Thank you.
8                    CHAIRMAN SKILLMAN:            For those of us who 9 were      plant    operators,      you    would      think  there        is 10 probably a vent valve out there, maybe two.
11                    MR. GIBBS:        Yes.        Ron  Gibbs,    South 12 Texas operations.
13                    Yes,  we    have    vent      valves  on  the      aux 14 feedwater        pumps.        I  don't    want      to  lead  anybody 15 anywhere,        but  we  installed        extra      connections      for 16 our flex.        And maybe that is some of the confusion, 17 how      the  drawings      got    updated        during  this      time 18 period.        So, we will follow up with Lois to make 19 sure we get the right answer.
20                    CHAIRMAN      SKILLMAN:            This  is    not      a 21 substantive item, but I was being thorough, and I 22 would        certainly    like    to    understand      what  you      are 23 communicating on page 2-87, please.
24                    MS. JAMES:      Okay.
25                    CHAIRMAN      SKILLMAN:          Thank  you.      Sir, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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138 1 thank you.
2                  MS. JAMES:      And we will respond to you, 3 but we will also update the SER.                        If you had the 4 question, I am sure someone else had the question.
5                  CHAIRMAN SKILLMAN:            Okay. Thank you.
6                  MS. DIAZ:        For    the      purposes    of    the 7 staff, could you restate the question?
8                  MS. JAMES:      Restate the question?
9                  MS. DIAZ:      Yes.
10                  MS. JAMES:        Okay.          I  was  asked      to 11 restate the question.                The question is, based on 12 the      writeup  on    page    2-87    of      the  SER,  it      was 13 confusing      as  to    whether      or  not      there  were      vent 14 valves on the aux feedwater pumps and were those 15 vent valves within scope of license renewal?
16                  CHAIRMAN      SKILLMAN:              That    is      the 17 question.      Thank you.
18                  MS. JAMES:          And we will have to get 19 back to you on that.
20                  CHAIRMAN SKILLMAN:            Thank you.
21                  Colleagues, at this point the staff has 22 completed their presentation.                    Do any of you have 23 comments for the staff, please?
24                  MEMBER KIRCHNER:            Dick, I have just a 25 question.        I can't find it in the SER now.                          I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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139 1 believe that tests were done on the baffle region 2 for vibration of reactor internals.                      Can you or the 3 Applicant report back on that?                      It is relevant to 4 Matt's earlier question about baffle bolts and what 5 you may have found as a result of that testing.                            I 6 think you did a scale model test of the conforming 7 region, the baffle conforming region.                      I just can't 8 find it.        I know it is here in the SER and I can't 9 find it.
10                  MS. JAMES:      Okay.        Jim Medoff is coming 11 to the microphone for the staff.
12                  MR. MEDOFF:        This is Jim Medoff of the 13 staff.        I was the lead for the reactor internals 14 and I had some assistance with Mark Hughes of the 15 staff.
16                  One of the things we check as part of 17 the      identification      of    TLAAs      in    Chapter  4.1      is 18 whether        the  preopt      testing        for    initial    plant 19 operations,        whether      any    analyses        associated      with 20 preopt testing are TLAAs.                So, we did look at that 21 for the application.              We usually would -- in most 22 applications the vibrational analyses are below the 23 endurance limit for the components.                      So, vibrations 24 didn't come in as a TLAA for the internals.
25                  That    being    said,      we    do  rely  on    the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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140 1 MRP-227 report and AMP XIM-16(a) for the internal.
2 Originally, this plant was one that did it under 3 commitment, but due to the delays in the aluminum 4 rods, we did make them update the LRA, update their 5 AMRs and AMPs.        So now, we have reviewed the entire 6 AMP,      their inspection      plan,      to      make  sure  it      is 7 consistent with MRP-227-A.                That would include any 8 inspections of the baffle former region, including 9 the baffle formal bolts.
10                  MEMBER KIRCHNER:          Thank you.
11                  MR. MEDOFF:          Any      more    questions        on 12 that?
13                  CHAIRMAN      SKILLMAN:            No,  sir.      Thank 14 you.
15                  Walt, thank you.
16                  Colleagues, any other questions at this 17 point for the staff?
18                  (No response.)
19                  Hearing none, I would ask everybody to 20 remain in place.            What we are going to do is to 21 open the phone line.
22                  MR. HOWARD:        The bridge is open.
23                  CHAIRMAN SKILLMAN:              The bridge is open.
24 Before we go to those who may be on the phone line, 25 I would like to ask if there are any individuals in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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141 1 the audience that would like to make a statement, 2 please.
3                    (No response.)
4                    Seeing none, ladies and gentlemen, the 5 bridge        line  is  open.        If  any    individual  is    out 6 there, would you just please communicate that you 7 are there?
8                    MR. GAVULA:        This is Jim Gavula.
9                    CHAIRMAN SKILLMAN:              Good morning, sir.
10 Thank you.
11                    Anybody else out there?
12                    (No response.)
13                    No?
14                    For anyone that is on the line, would 15 you care to make a comment, please?
16                    (No response.)
17                    Hearing none, please close the bridge 18 line.
19                    I would like to go around the room with 20 my colleagues to determine if there are any more 21 comments that my colleagues may have.
22                    Ron, may I start with you?
23                    MEMBER BALLINGER:            No further comments.
24 I think I have badgered them enough.
25                    CHAIRMAN SKILLMAN:            Thank you, Ron.
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142 1                Pete?
2                MEMBER RICCARDELLA:            Likewise.
3                CHAIRMAN SKILLMAN:            Thank you.
4                Steve?
5                DR. SCHULTZ:            I      have    no  further 6 comments.      I would like to thank the staff and the 7 Applicant for the discussions.                Thank you.
8                CHAIRMAN      SKILLMAN:              Okay.        Dana, 9 anything?
10                MEMBER POWERS:        No.
11                CHAIRMAN SKILLMAN:            Matt?
12                MEMBER SUNSERI:          I appreciate the staff 13 and the Applicant's participation today, and it was 14 helpful to understand what is going on.                    Thank you.
15                CHAIRMAN SKILLMAN:            Thank you.
16                John?
17                MEMBER STETKAR:            Nothing more.          Thank 18 you.
19                CHAIRMAN SKILLMAN:            Walt?
20                MEMBER    KIRCHNER:            Thank    you  to      the 21 presenters.
22                CHAIRMAN      SKILLMAN:              Okay.          Our 23 Designated      Federal      Official,          Ken    Howard,      any 24 questions or comments at this point?
25                MR. HOWARD:        None.
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143 1                  CHAIRMAN SKILLMAN:              Okay. To all who 2 have      participated      and    traveled,        thank  you    very 3 much.        I wish you a safe journey home.
4                  And    with      that,        this    meeting        is 5 concluded.
6                  (Whereupon, at 11:20 a.m., the meeting 7 was adjourned.)
8 9
10 11 12 13 14 15 16 17 18 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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SOUTH TEXAS PROJECT Advisory Committee on Reactor Safeguards License Renewal Subcommittee Meeting November 17, 2016
 
Dave Rencurrel Senior Vice President Operations 2
 
Agenda
* Introductions
* Station Ownership and Operation
* Site and Station Description
* License Renewal, GALL Consistency and Commitments
* Safety Evaluation Report Open Item o Aluminum Bronze Selective Leaching
* Concluding Remarks SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 3
 
Introduction PERSONNEL IN ATTENDANCE Dave Rencurrel                  Senior Vice President Operations Michael Murray                  Manager Regulatory Affairs Mike Berg                      Manager Engineering Ron Gibbs                      Manager Operations Arden Aldridge                  License Renewal Project Lead Plant Staff                    AMP Subject Matter Experts, Licensing, Chemistry, Systems Engineering, Design Engineering, and Programs Engineering Specialty Consultants SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016          4
 
Station Ownership and Operation Operated by STP Nuclear Operating Company (STPNOC)
STP Units 1 and 2 are owned by:
* NRG South Texas LP
* The City Public Service Board of San Antonio (CPS Energy)
* The City of Austin, Texas (COA)
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016        5
 
Plant History & Major Investments South Texas                          Unit 1      Unit 2 Initial License                              August 21, 1987 Dec 16, 1988 Steam Generator Replacement                          2000      2002 Low Pressure Turbine upgrade                        2006      2004 Replaced RX heads                                    2009      2010 Main Generator Stator rewind                        2014      2012 Non-welded Stress Improvement                        2017      2019 Process (RPV)
Expiration of current License                August 20, 2027 Dec 15, 2028 SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016                  6
 
Site and Station Description Ron Gibbs Manager Operations 7
 
SITE DESCRIPTION SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 8
 
STATION DESCRIPTION SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 9
 
License Renewal Application Arden Aldridge License Renewal Project Lead 10
 
License Renewal Application License Renewal Application (LRA) submitted to NUREG 1801 rev 1  10/2010 NUREG 1800 and 1801 Revision 2 issued                            12/2010 Scoping & Screening, AMP Audits completed                        06/2011 Scoping & Screening, AMP Inspection completed                    08/2011 Annual Updates 2011, 2012, 2013                                2011-2013 Issued initial safety evaluation report (SER) with open item(s)  02/2013 Safety review paused                                            2/2013-12/2013 RAIs, LR-ISG incorporation into LRA                            1/2014-Present Annual Updates 2014, 2015, 2016                                2014-2016 Issued safety evaluation report (SER) with open item            10/2016 SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016              11
 
Aging Management Programs and GALL
* Total Aging Management Programs - 41
* Existing Programs - 33 (3) plant specific
* New Programs - 8            (1) plant specific
* Plant Specific
          - Nickel-Alloy
          - PWR Reactor Internals
          - Protective Coating Monitoring and Maintenance
          - Selective Leaching of Aluminum Bronze
* Aging evaluations are greater than 90% consistent with GALL Rev 1 and greater than 95% consistent with GALL Rev 2 (standard notes A through E)
* GALL Revision 2 lessons learned incorporated through license renewal application supplement and reviewed by the NRC using Standard Review Plan Rev 2.
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016                    12
 
GALL Consistency Consistency Table AMPS              AMPS AMPS        Consistent Consistent with AMPS with Plant AMPS Consistent        with          Exception & Exceptions Specific Enhancements Enhancements New (8)            3                                          4        1 Existing (33)        5            13                  11      1        3 Total AMPS (41)
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016                      13
 
License Renewal Commitments License Renewal commitments - 46 total
-  Program Enhancements (4 complete, 26 open)
-  Program Implementation (1 implemented , 9 open)
-  Replace 6 Standby Emergency Diesel Generator bellows (open)
-  Remove Safety Related Check Valve Seal Caps (complete)
-  Review NUREG/CR-6260 (Enhanced Fatigue Monitoring locations (open)
-  Take ground water samples for 24 consecutive months to assure non aggressive (complete)
-  Calculate Essential Cooling Water leakage rates to validate maximum flaw size (complete)
-  One time internal inspection of Unit 1 Refueling Water Storage Tank (RWST) bottom and side welds. (open)
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016            14
 
License Renewal Commitments and Implementation License Renewal commitments are included in UFSAR Supplement (Appendix A to the LRA) and managed through the STP Condition Reporting and Licensing Commitment Management and Administration processes.
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016      15
 
Safety Evaluation Report Open Item Mike Berg Engineering Manager 16
 
OI 3.0.3.3.3-2 Aluminum Bronze Selective Leaching SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 17
 
Selective Leaching of Aluminum Bronze Background Wrought Material is non-Susceptible Susceptible Component Population - Will be replaced with non-susceptible material prior to period of extended operation Welds or weld-repairs with susceptible weld filler material will be managed
* piping butt-welds
* weld repairs on extruded tees SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016    18
 
Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
STP responded to the NRCs open items related to Selective Leaching of Aluminum Bronze AMP by letter dated September 28, 2016, NOC-AE-16003403.
OI 3.0.3.3.3-2 Identified ten open issues requiring closure.
Nine of the ten open issues have been addressed. The final issue is still open but a pathway forward has been identified to assure timely resolution.
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016    19
 
Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
Addressed Issues:
: 1. Added information to bound extruded piping tee repairs
: 2. Clarified the parameters monitored to address loss of material, cracking, and phase distribution.
: 3. Clarified the sample size for volumetric inspections One-time examination of welds Periodic examination of welds
: 4. Clarified the threshold for the number of defective welds resulting in further inspections
: 5. Identified selection criteria for weld inspections SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016                20
 
Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
Addressed Issues:
: 6. Determined there was no impact of the external coatings regarding detecting buried piping leaks at the surface.
: 7. Identified a method to monitor or trend results
: 8. Defined the acceptance criteria for weld defects Visual inspection Volumetric examination Destructive examination
: 9. Identified the threshold for increased inspections when adverse inspection results are detected
: 10. Identified the corrective actions to address all potential inspection results.
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016                21
 
Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
Remaining Open Issue:
: 10. Corrective actions do not address all potential inspection results.
Followup question is being developed by the NRC. Initial communication of the concern supports a pathway forward and timely response and resolution.
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016                        22
 
Selective Leaching of Aluminum Bronze Aging Management Program (AMP)
 
== Conclusion:==
 
Following the resolution of the remaining issue related to corrective actions, the Selective Leaching of Aluminum Bronze Aging Management program will effectively manage aging of the Essential Cooling Water cast components and welds during the extended period of operation.
SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016    23
 
Concluding Remarks Dave Rencurrel Senior Vice President Operations 24
 
END 25
 
Advisory Committee on Reactor Safeguards License Renewal Subcommittee South Texas Project Safety Evaluation Report (SER) with Open Items November 17, 2016 Lois M. James, Senior Project Manager Office of Nuclear Reactor Regulation
 
Presentation Outline
* Overview of South Texas Project (STP) license renewal review
* Region IV 71002 Inspection, License Renewal Inspection
* SER Section 2, Scoping and Screening Review
* SER Section 3, Aging Management Review
* SER Section 4, Time-Limited Aging Analyses
* Conclusion 2
 
License Renewal Review (Audits and Inspections)
* Scoping and Screening Methodology Audit
  - May 15 - 19, 2011 (Onsite)
* Aging Management Program (AMP) Audit
  - June 13 - 24, 2011 (Onsite)
* Aluminum Bronze Selective Leaching AMP Audits
  - February 29, 2012 (Rockville)
  - March 9 - 13, 2015 (Onsite)
  - March 21 - 23 (Onsite) and June 22, 2016 (Rockville)
* Region IV 71002 Inspection (Scoping and Screening & AMPs)
  - August 8 - 25, 2011 (Onsite) 3
 
SER Overview
* SER with Open Item (OIs) issued in 2013
* SER with OIs issued in 2016
  - Closed the OIs from 2013
  - Opened OI 3.0.3.3.3 Insufficient details provided regarding applicants Selective Leaching of Aluminum Bronze AMP 4
 
71002 Inspection
* Scope
* Non-Safety Systems affecting Safety Systems
* Aging Management Programs
* Inspection
* August 8 - August 25, 2011
* Team Inspection on-site for 2 weeks 5
 
71002 Inspection
* Results
  - Good material condition of structures, systems and components
  - Two implementing procedures changed
  - Two Aging Management Programs Changed
  - Revised Commitments and Corresponding Changes for five Aging Management Programs 6
 
71002 Inspection
* Conclusions
  - Scoping and screening performed in accordance with 10 CFR 54
  - Information easily retrievable and auditable
  - Existing programs effectively managed aging effects
  - Corrective and other actions being tracked for completion
  - Reasonable assurance that aging effects will be managed and intended functions maintained 7
 
SER Section 2
* Structures and Components Subject to Aging Management Review
  - Section 2.1, Scoping and Screening Methodology
  - Section 2.2, Plant-Level Scoping Results
  - Sections 2.3, 2.4, 2.5 Scoping and Screening Results 8
 
SER Section 3
* Aging Management Review Results
  - Section 3.1, Aging Management of Reactor Vessel, Internals, and Reactor Coolant System
  - Section 3.2, Aging Management of Engineered Safety Features
  - Section 3.3, Aging Management of Auxiliary Systems
  - Section 3.4, Aging Management of Steam and Power Conversion Systems
  - Section 3.5, Aging Management of Containments, Structures and Component Supports
  - Section 3.6, Aging Management of Electrical Commodity Group 9
 
SER Section 3 3.0.3 - Aging Management Programs Applicants Disposition of AMPs          Final Disposition of AMPs in SER with OIs
* 8 new programs
* 8 new programs 3 consistent                                  3 consistent 4 consistent with exceptions                  4 consistent with exceptions 1 plant specific                              1 plant specific
* 32 existing programs
* 33 existing programs 6 consistent                                    5 consistent 13 consistent with enhancements                  14 consistent with enhancements 3 consistent with exception                      1 consistent with exceptions 8 consistent with enhancements                  10 consistent with enhancements and exceptions                                    and exceptions 2 plant specific                              3 plant specific
* 1 existing program added            Note: The staff received and is reviewing the 2016 annual 1 plant specific                update. The final SER will be updated based on the staffs review.
10
 
SER Section 3 Open Items Closed OI 3.0.3.2.6-2: Management of fouling of downstream components due to coating degradations upstream
* Concern: AMP may be inadequate
* Resolution: AMP was revised in accordance with staffs guidance in ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.
OI 3.0.3.1.4-1: Cracking in Unit 1 Reactor Water Storage Tank (RWST)
* Concern: No AMP
* Resolution: Revised the One-Time Inspection AMP to include the internal surfaces of the Unit 1 RWST; and revised External Surfaces AMP to include visual inspections of the Unit 1 RWST every refueling cycle.
11
 
Aluminum Bronze Overview
* Applicant revised AMP in September 2016.
* Replacing all susceptible piping components that have exhibited leakage except for susceptible weld material joining nonsusceptible piping components.
* Applicant proposed a basis for why butt welds have not experienced leakage since 1994.
  - Root pass less susceptible: dilution and cool down rate
  - Root pass acts as a barrier
  - No construction related or service induced flaws in root pass, barrier remains intact
* Root pass as a barrier seemed plausible; however, basis lacked sufficient data to substantiate 12
 
Staff Conclusions Based on review of tests and examinations conducted by the applicant, and the review of technical literature by the staff:
* Microstructure level dealloying process is confined to a localized front that scales with the grain size.
* Material on either side of the dealloying front is either in the as-received or fully dealloyed condition.
* Insufficient data to establish lower bound mechanical properties for dealloyed aluminum bronze.
* No strength or fracture toughness credit should be given to dealloyed material.
13
 
Program Element Overview September 2016, AMP revised to address most of the OI
* Detection of aging effects:
  - Volumetric inspections and destructive examinations
  - Visual inspections for leakage
  - Opportunistic buried pipe coating inspections
* Acceptance criteria:
  - Planar defect and dealloying
  - Microstructure of the weld root region
  - Monthly walkdowns 14
 
Program Element Overview, cont.
Corrective Actions:
* Additional volumetric and destructive examinations
* Structural integrity calculations conducted with as-found conditions
* Structural integrity analysis fails - additional inspections by ultrasonic testing (UT) technique capable of detecting loss of material due to selective leaching - Associated Request for Additional Information (RAI) for further information 15
 
SER Section 4
* Time-Limited Aging Analyses
  - 4.1, Identification of Time-Limited Aging Analyses (TLAA)
  - 4.2, Reactor Vessel Neutron Embrittlement Analysis
  - 4.3, Metal Fatigue Analysis
  - 4.4, Environmental Qualification of Electric Equipment
  - 4.5, Concrete Containment Tendon Prestress Analyses
  - 4.6, Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses
  - 4.7, Other Plant-Specific TLAAs 16
 
SER Section 4 Open Item Closed OI 4.3.2.11-1: Effects of thermal aging on cast austenitic stainless steel (CASS):
* Concern: Leak-Before-Break (LBB) TLAA may not be dispositioned correctly
* Resolution: Revised LRA Section 4.3.2.11 to identify the fracture mechanics evaluation as a TLAA and disposition it in accordance with 10 CFR 54.21(c)(1)(i); and the material fracture toughness properties selected for use in the LBB analysis are sufficiently embrittled that they bound the amount of thermal embrittlement that will occur in 60 years.
17
 
Conclusion Pending satisfactory resolution of the Open Item, the staff will determine whether the requirements of 10 CFR 54.29(a) have been met for the license renewal of STP.
18}}

Latest revision as of 11:15, 30 October 2019

Transcript of Advisory Committee on Reactor Safeguards Plant License Renewal Subcommittee Meeting - November 17, 2016
ML16350A327
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Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 11/17/2016
From: Kent Howard
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NRC-2739
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Advisory Committee on Reactor Safeguards Plant License Renewal Subcommittee Docket Number: (n/a)

Location: Rockville, Maryland Date: Thursday, November 17, 2016 Work Order No.: NRC-2739 Pages 1-188 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 1

2 3

4 DISCLAIMER 5

6 7 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 8 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 9

10 11 The contents of this transcript of the 12 proceeding of the United States Nuclear Regulatory 13 Commission Advisory Committee on Reactor Safeguards, 14 as reported herein, is a record of the discussions 15 recorded at the meeting.

16 17 This transcript has not been reviewed, 18 corrected, and edited, and it may contain 19 inaccuracies.

20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

+ + + + +

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS (ACRS)

+ + + + +

PLANT LICENSE RENEWAL SUBCOMMITTEE

+ + + + +

THURSDAY NOVEMBER 17, 2016

+ + + + +

ROCKVILLE, MARYLAND

+ + + + +

The Subcommittee met at the Nuclear Regulatory Commission, Two White Flint North, Room T2B1, 11545 Rockville Pike, at 8:30 a.m., Gordon R.

Skillman, Chairman, presiding.

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2 COMMITTEE MEMBERS:

GORDON R. SKILLMAN, Chairman PETER RICCARDELLA, Member-at-Large RONALD G. BALLINGER, Member WALTER L. KIRCHNER, Member DANA A. POWERS, Member JOHN W. STETKAR, Member MATTHEW W. SUNSERI, Member ACRS CONSULTANT:

STEPHEN SCHULTZ DESIGNATED FEDERAL OFFICIAL:

KENT HOWARD ALSO PRESENT:

ARDEN ALDRIDGE, STP NOC MIKE BERG, STP NOC RUSS CIPOLLA, Intertek PHYLLIS CLARK, NRR/DLR YOIRA DIAZ, NMSS/DSFM ROB ENGEN, STP NOC MICHAEL GARNER, STP NOC JIM GAVULA, NRR*

DAVE GERBER, SIA RON GIBBS, STP RAFAEL GONZALES, STP NOC ALLEN HISER, NRR/DLR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 WILLIAM HOLSTON, NRR MATTHEW HOMIACK, NRR LOIS JAMES, NRR/DLR RAIHAN KHONDKER, STP NOC BRET LYNCH, WP JANE MARSHALL, NRR TODD MAXEY, STP JAMES MEDOFF, NRR/DLR MIKE MURRAY, STP NOC CHANCEY PENCE, STP NOC GREG PICK, Region IV DAVE RENCURREL, STP BILL ROGERS, NRR/DLR DAN SICKING, STP NOC RICK STARK, STP NOC DAVID STUHLER, STP NOC MIKE SVETLIK, STP MARK WALES, STP NOC GARY WARNER, WP DAVE WIEGAND, STP NOC JAMES WILLIAMS, STP NOC PRESTON WILLIAMS, STP NOC JAMES C. YOUNGER, STP NOC KEVIN REGIS, STP NOC

  • Present via telephone NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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4 C-O-N-T-E-N-T-S Call to Order and Opening Remarks..................5 Staff Introduction.................................6 South Texas Project Nuclear Operating..............7 Company (STPNOC) - South Texas Project, Units 1 and 2 (STP)

NRC Staff Presentation SER with Open..............80 Items Overview Opportunity for Public Comment...................133 (None)

Committee Discussion.............................134 Adjourn NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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5 1 P R O C E E D I N G S 2 8:29 a.m.

3 CHAIRMAN SKILLMAN: (presiding) Ladies 4 and gentlemen, good morning. This meeting will now 5 come to order.

6 I am Gordon Skillman. I am Chairman of 7 the Plant License Renewal Subcommittee.

8 The Subcommittee will review the 9 license renewal application for South Texas Project 10 Units 1 and 2.

11 ACRS members in attendance today are 12 Dana Powers, John Stetkar, Ron Ballinger, Peter 13 Riccardella, Walt Kirchner, and Matt Sunseri. Our 14 ACRS consultant Dr. Stephen Schultz is also in 15 attendance. Kent Howard of the ACRS is the 16 Designated Federal Official for this meeting.

17 This morning we will hear presentations 18 from the Division of License Renewal, Region IV, 19 and South Texas Nuclear Operating Company, the 20 Applicant, regarding this matter. This 21 Subcommittee will gather information, analyze 22 relevant issues and facts, and formulate proposed 23 positions and actions, as appropriate, for 24 deliberation by the full Committee.

25 The rules for participation in today's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 meeting have been announced as part of the notice 2 of this meeting published in The Federal Register.

3 We have not received written comments and requests 4 for time to make oral statements from members of 5 the public regarding today's meeting, and the 6 entire meeting will be open to public attendance.

7 There will be a phone bridge line. To 8 preclude interruption of the meeting, the phone 9 will be placed in a listen-in mode during the 10 presentations and Committee discussion.

11 A transcript of this meeting is being 12 kept and will be available, as stated in The 13 Federal Register notice. Therefore, I request that 14 participants in this meeting use the microphones 15 located throughout the meeting room when addressing 16 the Subcommittee. The participants are requested 17 to please identify themselves and speak with 18 sufficient clarity and volume, so that they can be 19 readily heard.

20 I also request that all attendees 21 please silence your personal electronic devices.

22 We will now proceed with the meeting, and I call upon 23 Jane Marshall to begin the presentation.

24 Thank you, Chairman Skillman.

25 As stated, I am Jane Marshall. I'm the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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7 1 Acting Director for the Division of License Renewal 2 in the Office of Nuclear Reactor Regulation. With 3 me here today are members of my management team and 4 several members of my staff. They will introduce 5 themselves as they answer questions today. Also 6 joining us by phone is Greg Pick, who is the Lead 7 Inspector from Region IV.

8 The staff's presentation will be given 9 by Lois James, who is the South Texas Project 10 Safety Project Manager. She will be joined at the 11 table by DLR Senior Technical Advisor Dr. Allen 12 Hiser and Senior Mechanical Engineer Bill Holston, 13 as well as Safety Project Manager Phyllis Clark.

14 At today's ACRS Subcommittee meeting, 15 the staff will present its review and resolution 16 path for the open item for the license renewal of 17 South Texas Project Units 1 and 2. The information 18 we will be presenting was documented in the Final 19 SER.

20 At this time, I would like to turn the 21 presentation over to South Texas Project Nuclear 22 Operating Company and Dave Rencurrel, Senior Vice 23 President for Operations, to introduce his team and 24 commence their presentation.

25 Thank you.

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8 1 MR. RENCURREL: Good morning.

2 Yes, as you said, my name is Dave 3 Rencurrel. I am from South Texas, Senior Vice 4 President of Operations.

5 I really would like to take this 6 opportunity to thank the ACRS Subcommittee for our 7 opportunity to present our overview of our license 8 renewal application, and we do look forward to your 9 questions.

10 But, before we get started, I would 11 also like to thank the NRC reviewers for their hard 12 and diligent work in this process and for everybody 13 on the staff, everybody from South Texas, who has 14 also worked very hard in this process.

15 There it is. All right. As you can 16 see, here is an overview of the agenda, which we 17 will be presenting today. I would like to point 18 out that we are setting aside a really special time 19 or focused time to discuss the Safety Evaluation 20 Report open item for aluminum bronze selective 21 leaching.

22 With that, I would like to move into 23 the introductions of the team that we brought 24 today. I will start and, then, we will just move 25 to the left and move down our line.

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9 1 Now my name, as I said, is David 2 Rencurrel. I'm the Senior Vice President of 3 Operations.

4 I began my career over 35 years ago, my 5 nuclear career over 35 years ago in 1981, when I 6 started in the United States Navy as a nuclear 7 officer. In 1988, I joined the South Texas Project 8 and, since then, I have had many different jobs. I 9 got hired in as a young system engineer. I have 10 went through license class, spent time in the 11 control room as a shift technical advisor. I spent 12 time as a work control supervisor, worked in 13 maintenance, system engineering manager, design 14 manager. I was ops manager for a little bit over 15 four years, VP of Engineering and Projects, Site VP 16 for over four years. Now I am in my current role 17 where I am responsible for all projects here 18 onsite.

19 I would like to hand off to Mike 20 Murray.

21 CHAIRMAN SKILLMAN: Not so fast, Dave.

22 You have a lofty position, huge influence at the 23 site and in the company. What is your vision of 24 the importance of 10 CFR 50 Appendix B?

25 MR. RENCURREL: I think that is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 extremely important. 10 CFR 50 Appendix B is what 2 gives us that consistency and that credibility that 3 we all want. I think that is where that comes from 4 in that regard.

5 CHAIRMAN SKILLMAN: I asked the 6 question because in the course of time those of us 7 who have been in industry for a long time have 8 watched the devotees of 10 CFR 50 Appendix B fall 9 away. There is always somewhat of a move to cut a 10 corner here or cut a corner there and not recognize 11 how important the 18 points of that regulation are 12 --

13 MR. RENCURREL: Yes, sir, I understand.

14 CHAIRMAN SKILLMAN: -- to the materiel 15 condition of the unit and to the culture of the 16 unit. And so, my question is, how vigilant are you 17 of that? And what is the shadow that you cast on 18 your organization?

19 MR. RENCURREL: So, what is -- that is 20 the quality, right?

21 CHAIRMAN SKILLMAN: Yes, yes.

22 MR. RENCURREL: That's what I thought.

23 So, here's what we do in regards to independent 24 oversight of their station. Independent oversight, 25 obviously, we have the right dedication and right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 resources assigned to that. They act independently 2 in that they report up to a company officer. All 3 right. We ensure that they have a very 4 professional relationship with the staff, that they 5 are honored by the staff and listened to by the 6 staff, that they have the capability to measure our 7 not just compliance, but also our drive towards 8 excellence.

9 We also have monthly reports, for 10 example, that come up to the executives where they 11 get to talk about oversight or the vision of 12 oversight of performance of how the station 13 performs. We have a very prescriptive program of 14 the elevation/escalation, where elevation is where 15 they bring up an issue to site leadership, plant 16 manager and such, where they can talk about 17 prolonged gaps or gaps that aren't being closed.

18 And then, it subsequently goes to escalate, if that 19 doesn't get solved, where, depending upon the 20 level, it can actually go all the way up to an 21 officer or a vice president to be accountably 22 resolved.

23 And then, you roll into the whole 24 concept of corrective actions and the idea of being 25 able to -- it is not just a corrective action NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 program; it is more of a program to ensure that you 2 have proper problem identification and real 3 resolutions that solve not just the symptom of the 4 problem, but the actual do the hard work of 5 understanding the cause of the problem. And I 6 believe that is extremely important, something we 7 measure very closely for.

8 I believe that in any organization you 9 have to have governance, proper governance, which 10 is the rules, the regulations, the traditions, the 11 meetings that we all interact with, so that you can 12 have proper oversight, so the oversight can come up 13 and measure how your governance is actually 14 operating and working. I believe in all those 15 concepts.

16 I also know that the folks I work with, 17 my boss, our Chief Executive Officer Dennis Koehl, 18 our Chief Nuclear Officer Tim Powell, also believe 19 very strongly in the Appendix B, in the 50.B 20 program. They believe very strongly in the 21 corrective action program and independent 22 oversight.

23 And having said all those words, in 24 conclusion, I would say plants/stations that 25 perform well, stations that perform with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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13 1 excellence, stations that, quite frankly, meet the 2 business plan needs of the owners and the 3 shareholders have that healthy respect. Plants 4 that don't, they don't meet those; they don't have 5 that performance and they don't meet those business 6 goals. So, it all ties together.

7 CHAIRMAN SKILLMAN: Yes, I thank you 8 for your explanation. My real question was about 9 your office and your shadow on the QA program.

10 MR. RENCURREL: Yes, my office and my 11 shadow on the QA program is I know the QA Manager 12 personally and I actually mentor him through his 13 roles. I help him interact with folks on the 14 station. In my role right now, they don't report 15 to me. In my previous roles, they actually 16 reported to me. So, it was much more hands-on in 17 how things are working.

18 My shadow is that I believe very, very 19 strongly in the independence of QA, its 20 independence and conclusion, its independence in 21 their messaging, but we work closely with them in 22 ensuring that that message is presented in a way 23 that can be readily understood and accepted by the 24 staff.

25 I spend time; I go down and talk to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 folks -- they actually sit down the hall from me.

2 I go down and visit with them a lot, pretty much 3 know just about everybody there. And at times I 4 have both defended them and I both chastised them.

5 So, I think I have a very good shadow.

6 CHAIRMAN SKILLMAN: Dave, thank you.

7 Please proceed.

8 MR. RENCURREL: Okay. Thank you.

9 MR. MURRAY: My name is Michael Murray.

10 I'm the Regulatory Affairs Manager at South Texas 11 Project.

12 I have been in the industry for 41 13 years, started as an I&C tech at the Brunswick 14 Plant. I have had 31 years at South Texas Project.

15 I was there for startup of both units. So, I have 16 a long history at South Texas Project.

17 Various management positions. I was 18 I&C Manager, Systems Engineering Manager; spent 19 some time working on the Units 3 and 4 licensing 20 project as I&C, the Design Manager there. And I 21 have met a few of these folks here during that 22 process. And then, currently, I'm Reg Affairs 23 Manager at South Texas Project.

24 MR. GIBBS: Good morning. I'm Ron 25 Gibbs. My current position is the Manager, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 Operations, Shift Operations. I'm the Senior 2 License at the South Texas Project now.

3 I've got over 30 years of nuclear 4 experience. Started out as a unit supervisor, STA, 5 at Comanche Peak. Came to the South Texas Project 6 in 1993. Got my Senior Reactor Operator License 7 there in 1995 and worked my way on shift. I 8 started as unit sup, STA, again, up through shift 9 manager. Came off shift in 2013 into an ops 10 manager role and took over as the Senior License 11 January of this year.

12 MR. ALDRIDGE: Good morning. My name 13 is Arden Aldridge.

14 I have been in the nuclear service for 15 about 38 years. I started in the nuclear submarine 16 service, consultation with some consulting groups, 17 and then, with two utilities.

18 For the last 22 years, I have been at 19 South Texas Project fulfilling various engineering 20 roles and functions. In the last 10, I have been 21 focused on license renewal applications, helping 22 our peer plants prepare three application from 23 preparation to approval. In the last five years, 24 it has been focused as the project lead and the 25 Implementation Coordinator for South Texas.

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16 1 CHAIRMAN SKILLMAN: Thank you.

2 MR. BERG: Good morning. I'm Michael 3 Berg. I'm the Engineering Manager of Design and 4 Programs.

5 I have got 38 years in the nuclear 6 industry, 34 years at South Texas Project. I was 7 one of the original engineering supervisors that 8 took over design control from the architect 9 engineer.

10 I have had various manager roles over 11 the past 25 years and I was the manager over the 12 STP initial license renewal application submitted.

13 CHAIRMAN SKILLMAN: Gentlemen, thank 14 you. Please proceed.

15 MR. RENCURREL: Okay. What I would 16 like to do now is give a brief station ownership, 17 overview of station ownership and operation.

18 South Texas Project Nuclear Operating 19 Company is the licensed holder for the station.

20 The station is actually owned by three different 21 companies, Energy Texas, which is an investment-22 owned utility; the City Public Services, San 23 Antonio, which is owned by the municipality San 24 Antonio, Texas, and Austin Energy, which is owned 25 by the City of Austin. So, we are owned by one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 investor and two municipalities. To put our 2 generation in context, over 25 percent of the 3 carbon-free electric generation in the State of 4 Texas is produced at South Texas.

5 CHAIRMAN SKILLMAN: And you get no 6 credit for that whatsoever.

7 (Laughter.)

8 MR. RENCURREL: Yes, sir.

9 To go over our plant history and some 10 major investments, we received our initial license 11 in 1987 and 1988, respectively, for Unit 1 and Unit 12 2. Since that time, we have made major capital 13 investments. We have replaced our steam 14 generators, all four in each unit. We have 15 replaced our low-pressure turbines. We have 16 replaced both reactor vessel heads in both units.

17 We have also rewound our main generator stators and 18 have replaced the rotors, the main generator 19 rotors, in both units.

20 Looking forward, we have main 21 transformers done on one unit, but we are replacing 22 the main transformers in the other unit in the next 23 outage, and we are working through the replacement 24 of our feedwater heaters that show that there is an 25 ongoing investment in the major improvements of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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18 1 plant. Also, as you can see there, the non-welded 2 stress improvement process is being put in place, 3 and that is going to go down in 2017 and 2019.

4 The way our governance works is that we 5 have a business plan. And the way that the owners 6 commit to the long-term safe operation of the 7 station is via that business plan. This business 8 plan is approved annually for the next five years' 9 spend.

10 And so, in a sense, what goes on is the 11 money is allocated or set aside for the next five 12 years' worth of capital investments. However, our 13 plant investment plan itself goes out 20 years 14 where we have levelized out and put in all the 15 capital improvements and all the capital necessary 16 to move forward.

17 If you look at our plant investment 18 plan, you will see that our owners, we have 19 identified and our owners have committed to the 20 capital monies necessary to implement the aging 21 management plan. And so, there is that commitment, 22 not just in words, but in treasure, in regards to 23 implementing the extended license and safely moving 24 into the extended period of operation.

25 With that, I would like to turn it over NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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19 1 to Ron Gibbs, our ops manager.

2 MR. GIBBS: Good. Thank you, Dave.

3 This morning I will be giving a brief 4 description of the South Texas Project site and 5 station design.

6 South Texas Project is located about 90 7 miles southwest of Houston. You see the star here 8 on the Texas map gives a representation of our 9 location. Here in the center of this aerial map 10 you can see is the South Texas Project site. It is 11 about 12,000 acres. As you can see also in this 12 aerial view, it is largely a rural area, a lot of 13 farming in our community. We are Matagorda County 14 and about 15 miles inland from the Gulf of Mexico.

15 The large body of water here in the 16 center is our main cooling reservoir. Makeup from 17 our main cooling reservoir is the Colorado River 18 you can see here -- that is the main source -- and, 19 also, rainwater.

20 Our station, here is our main cooling 21 reservoir again on the top of the picture. Our 22 essential cooling water pond here is on the bottom.

23 That is commonly called service water in the 24 industry, and this is our ultimate heat sink.

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20 1 means of makeup and rainwater.

2 Just to the right here you can see our 3 switchyard. We have nine 345-KV lines coming into 4 and out of the switchyard. And the units here are 5 in the center of the pictures. We have two 6 Westinghouse four-loop PWRs, Pressurized Water 7 Reactors. Our thermal rate of power is 3853 8 megawatts thermal with a design output of 1250 9 megawatts electric.

10 CHAIRMAN SKILLMAN: Ron, the essential 11 service water pond there fed from wells, does that 12 mean that that is freshwater --

13 MR. GIBBS: Yes.

14 CHAIRMAN SKILLMAN: -- compared with 15 brackish water?

16 MR. GIBBS: That's correct.

17 CHAIRMAN SKILLMAN: Okay. I did not 18 appreciate that when I was reading the application 19 for the safety evaluation. Thank you.

20 MR. GIBBS: Okay.

21 CHAIRMAN SKILLMAN: Okay.

22 MR. GIBBS: Operators are licensed on 23 both units. So, we can operate either unit, and we 24 utilize common operating procedures.

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21 1 tensioned concrete cylinders with steel liner 2 plates, hemispherical tops, and flat bottoms.

3 Each unit has three independent safety 4 trains, including piping, valves, pumps, and diesel 5 generators, our emergency supply for emergency 6 power. And each unit has four safety-related 7 auxiliary feedwater trains, three electric pumps, 8 and one steam-driven pump.

9 And next, I will turn it over to Arden.

10 CHAIRMAN SKILLMAN: Let me ask you to 11 back up a slide, please. Your aerial, the Mad 12 Island, that is the wildlife management area?

13 MR. GIBBS: That's correct.

14 CHAIRMAN SKILLMAN: And so, most of the 15 population down there are alligators and critters?

16 Is that what you've got down there?

17 MR. GIBBS: That's correct, a lot of 18 alligators, a lot of critters.

19 CHAIRMAN SKILLMAN: That's 5-6,000 20 acres, 10,000 acres, something like that?

21 MR. GIBBS: It itself, yes.

22 CHAIRMAN SKILLMAN: Yes. Thank you.

23 Okay. Okay.

24 MR. GIBBS: Next, I will turn it over 25 to Arden to walk us through our license renewal.

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22 1 CHAIRMAN SKILLMAN: Right.

2 MR. ALDRIDGE: As I mentioned, my name 3 is Arden Aldridge. I was the license renewal 4 project lead, and I would like to just go through a 5 little chronology of where we have been in 6 preparation of this application.

7 In October of 2010, we submitted our 8 license renewal application against the 9 requirements of GALL Rev. 1. We, then, went 10 through the inspections and reviews. In 2013, we 11 received a Safety Evaluation Report with four open 12 items, and at the same time we put the safety 13 review on hold because of the uncertainty of the 14 waste confidence role on future license decisions.

15 Well, during the year that we put it on 16 hold we continued to work on the project. We 17 updated to GALL Rev. 2, the requirements of GALL 18 Rev. 2. We incorporated lessons learned from 19 License Renewal Safety Evaluation Reports and 20 performed annual updates. We also resolved three 21 of the open items going forward.

22 Here we are in 2016. We completed all 23 the reviews. The Safety Evaluation Report with 24 just one open item was issued on October of 2016, 25 and that open item is the aluminum bronze that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 will talk to later in the application.

2 On the next slide, just a description 3 of the programs, of how they have rolled out. We 4 had 41 aging management programs, of which 33 of 5 them were existing programs and eight new ones. On 6 that slide you will see in GALL consistency we said 7 we were 90-percent consistent with the standard 8 notes alpha through echo of GALL Rev. 1. However, 9 with the enhancements of GALL Rev. 2, that 10 consistency with GALL Rev. 2 is 95 percent against 11 the standard notes. As just a reminder, on the 12 bottom there, reinforcement, we did get reviewed 13 against standard review plan for GALL Rev. 2 and 14 those requirements.

15 On the next page, STP's program's 16 consistency with the GALL is we were consistent 17 with GALL Rev. -- the consistency table is against 18 GALL Rev. 1, but it is just an accounting 19 perspective. We had 21 aging management programs 20 that are consistent with GALL. We have 16 aging 21 management programs that are consistent with 22 exceptions, and we have four plant-specific aging 23 management programs.

24 Approximately 10 of the 16 aging 25 management programs with exceptions are due to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 addition of the requirements of GALL Rev. 2 and the 2 lessons learned that we incorporated. The 3 remaining exceptions would be alternate methods of 4 managing the aging effects specifically for the 5 programs that we developed.

6 As far as the license renewal 7 commitments, those are being tracked and we have 46 8 of them. This slide is just to represent the 9 different categories of commitments that we have 10 established. And up to this date, you can see 11 several of them are closed. Eight of the 46 12 commitments have been closed or have been 13 completed. That leaves us with 38 remaining to 14 implement prior to the period of extended 15 operation.

16 We have an implementation plan, a 17 schedule, and the budget that Dave mentioned to 18 complete these remaining open commitments prior to 19 their scheduled due dates in preparation for 20 entering the period of extended operation in 2027 21 and 2028.

22 CHAIRMAN SKILLMAN: Before you change 23 that slide, would you give us a little tutorial on 24 your inspections? The Unit 1 refueling water 25 storage tank welds you had some leaking, outside NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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25 1 tanks?

2 MR. ALDRIDGE: Yes.

3 CHAIRMAN SKILLMAN: You repaired those.

4 MR. ALDRIDGE: Yes.

5 CHAIRMAN SKILLMAN: You brought them 6 into conformance with their codes. You are on an 7 inspection frequency, that is, an outage inspection 8 frequency. I don't know if that is 24 months or 18 9 months. But it seems as though you found yourself 10 in a predicament with a leaking RWST. And so, you 11 have amended your procedures for inspection.

12 Please tell us more about this.

13 MR. ALDRIDGE: Thank you, Mr. Chairman.

14 We did have a plant-specific condition 15 on the refueling water storage tank on Unit 1, and 16 it was identified through external leakage. And 17 so, we did an internal inspection and repair. That 18 internal inspection and repair, then, had a root 19 cause performed on that, and we identified that the 20 cause was due to external leakage from water that 21 had entered the room from seals and there was no 22 berm around the tank. So, it had attacked the 23 exterior of the tank.

24 So, the concern for the aging effect of 25 internal stress corrosion cracking was not a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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26 1 concern. When we did our aging management program, 2 we were committed to performing a confirmatory that 3 the repairs, confirmed that they were effective and 4 that there is no aging degradation going on on the 5 internal side of the tank. In addition, we, then, 6 every refueling outage, we look at the exterior of 7 the tank for external indications of cracking or 8 leakage.

9 CHAIRMAN SKILLMAN: What is your fuel 10 cycle length, please? Fuel cycle length?

11 MR. ALDRIDGE: Yes, 18 months.

12 CHAIRMAN SKILLMAN: You are on 18 13 months? Okay. Thank you.

14 MR. ALDRIDGE: Okay.

15 MEMBER SUNSERI: I have a question 16 while you are on this page as well. So, we have 17 been following an issue with degraded baffle bolts 18 in the industry. And in South Texas your core is 19 larger. So, I suspect you are unique from the rest 20 of the fleet within maybe the number of baffle 21 bolts and how they are put together.

22 So, my question for you is, are you an 23 upflow or downflow plant? What has your experience 24 with the baffle bolts been? And what are you doing 25 to track the issue from an aging management NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 perspective?

2 MR. BERG: I will go ahead and answer 3 that question. Certainly, we have been involved 4 with the EPRI Materials Reliability Project and 5 compliance with MRPG-27. We are an upflow design, 6 and our baffle bolts are 3/16 material. So, when 7 you look at the susceptibility, we are in the 8 lowest susceptibility associated with that.

9 We have done some inspections where we 10 just visually looked at the baffle bolts. We have 11 not found any degradation of the baffle bolts.

12 MEMBER SUNSERI: Do you do the UT 13 inspections or just the visual?

14 MR. BERG: Just visual inspection. We 15 will do the UT inspections, per MRPG-27, prior to 16 the period --

17 MEMBER SUNSERI: So, you have it right?

18 Yes, okay. I've got it. Thank you.

19 MEMBER KIRCHNER: Dick, may I ask a 20 question?

21 CHAIRMAN SKILLMAN: Please.

22 MEMBER KIRCHNER: From this long list, 23 what are the long poles in the tent? Not all these 24 are equal in terms of effort and commitment and 25 difficulty. Could you just highlight those that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 are -- we know we have one more coming, but --

2 MR. ALDRIDGE: Right.

3 MEMBER KIRCHNER: -- excepting that 4 one, on this long list and the AMPs program, which 5 are taking more of your time or attention or 6 resources?

7 MR. ALDRIDGE: Yes, sir. When you 8 really look at, with the enhancements that we have 9 in place and have committed to, program 10 enhancements and program implementation both go 11 hand-in-hand. And we have been in the development 12 phase for all these years. So, those, just because 13 of the numbers, 26 of them remain open for 14 enhancements with nine implementation. The 15 implementation programs, not only are we developing 16 the base procedures and all the requirements that 17 we committed to in the aging management program, 18 but most of those require in-plant inspections, 19 whether they are one-time inspections or the 20 beginning of a periodic.

21 And then, from an analysis perspective, 22 we have already performed the screening on the 23 NUREG-6260 central locations. We just have to go 24 through and upgrade the program to continue to 25 monitor those new locations. So, that would be the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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29 1 main areas.

2 MEMBER KIRCHNER: Thank you.

3 CHAIRMAN SKILLMAN: Please proceed.

4 MR. ALDRIDGE: Thank you.

5 Okay. And so, really, in conclusion, 6 the license renewal commitments are included in our 7 SAR Supplement, in our FSAR Supplement, Appendix 8 Alpha of the license renewal application. It is 9 managed by our Appendix B Program, and it is the 10 STP condition reporting process and the license 11 commitment management and administrative processes.

12 There are two processes that control those, and 13 they are being tracked for completion under those 14 programs.

15 All right. At this time, I would like 16 to transfer to Mike Berg.

17 MR. BERG: Okay. I would like to talk 18 about our Safety Evaluation Report open item. This 19 is associated with selective leaching of our 20 aluminum bronze essential cooling water system.

21 The open item focuses on wells 22 themselves. But, prior to getting into the 23 specifics of the open item, I would just like to 24 give a brief overview of the selective leaching 25 process. So, from a high-level background for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 selective leaching of our low-pressure essential 2 cooling water system, which is commonly referred to 3 in the industry as service water system, as Ron 4 stated earlier, the material is aluminum bronze, 5 which is a copper aluminum alloy. Selective 6 leaching is a corrosion process where the aluminum 7 in the transformed phase can selectively leach out 8 when you have aluminum that is greater than 8 9 percent and exposed to wetted surfaces. Selective 10 leaching of aluminum leaves micro-voids along the 11 grain boundaries and, when progressed through a 12 wall, leakage/seepage will become visible on the 13 outside surface of the material.

14 So now, I would like to refer to the 15 slide here. So, what we are looking at here, this 16 is a section of pipe. We have a weld and, then, we 17 have got a weld-neck flange. So, the piping itself 18 -- there we go -- the piping itself is made out of 19 wrought material. It has less than 8-percent 20 aluminum, and we have not seen, nor is it 21 vulnerable to, selective leaching.

22 I want to talk about the casting --

23 MEMBER KIRCHNER: Just for perspective 24 --

25 MR. BERG: Yes.

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31 1 MEMBER KIRCHNER: -- what is the 2 diameter of the pipe there and what is the schedule 3 and such? What are we looking at in the picture?

4 I can see nuts on the side. So, it looks like it 5 is now 4-inch or --

6 MR. BERG: I'm thinking it is 4- or 6-7 inch diameter pipe that we are looking at here.

8 So, let's talk about the casting 9 materials themselves. They are susceptible to the 10 alloying. We first saw the alloying or cast 11 materials on our small-bore piping back in 1988.

12 All of those were replaced.

13 We do programmatically do a walkdown 14 every six months. What we are looking for is 15 copper oxide on the exterior of the pipe, like you 16 see right here. So, the green pipe, and we look 17 for a buildup of residual.

18 If I sectioned this pipe, I would look 19 at the inside of the pipe and I would see some 20 aluminum hydroxide corrosion products where the 21 aluminum has selectively leached inside the pipe 22 and, then, on the outside, again, I see the copper 23 oxide deposits that have occurred.

24 Just over a period of time, on these 25 large-bore castings we were somewhere between five NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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32 1 or ten first initial startup. Over the years, we 2 currently run somewhere between zero or two of 3 these per year, is what we see.

4 CHAIRMAN SKILLMAN: Is this phenomenon 5 limited to just the cast material?

6 MR. BERG: So, we are going to talk a 7 little bit later on the welds, which is the open 8 item. But where we have seen it predominantly is 9 in the cast materials.

10 CHAIRMAN SKILLMAN: Okay.

11 MEMBER SUNSERI: And it progresses from 12 the exterior of the pipe inward or?

13 MR. BERG: No, from the interior of the 14 pipe, selective leaching, and then, it takes the 15 aluminum, so the aluminum hydroxide on the inside 16 of the pipe. Once the aluminum comes through to 17 the outside of the wall, then you will see weepage.

18 So, we don't see a lot of leakage. It is really 19 weepage. Or, even in a lot of cases, when we will 20 do the walkdown, we will see the spots and you 21 won't even see any moisture at all. Yes, it is 22 kind of a sponge.

23 CHAIRMAN SKILLMAN: Do you want to be 24 on the record?

25 MEMBER KIRCHNER: Have you cut any of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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33 1 these castings out and done an evaluation?

2 MR. BERG: Oh, absolutely. We have 3 done a lot of evaluations.

4 MEMBER KIRCHNER: Do you have any 5 pictures with you to show the phenomenon as it 6 progresses?

7 MR. BERG: Really, we don't have 8 pictures with us. As part of our license renewal 9 application for our casting materials, we are going 10 to replace the casting materials with materials 11 that are not subject to the selective leaching 12 phenomena. So, our commitment is we are going to 13 change all of these castings out prior to the 14 period of extended operation.

15 MEMBER KIRCHNER: Well, it begs the 16 question, then, to what?

17 MR. BERG: We will go with, if we stay 18 with aluminum bronze material, then we will have 19 material probably a wrought-type material that has 20 less than 8-percent aluminum.

21 MEMBER BALLINGER: Yes, wrought 22 material, it is a two-phase thing where they get 23 something called the gamma-2 phase which is rich in 24 aluminum. It is like dezincification.

25 MR. BERG: Right.

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34 1 MEMBER BALLINGER: So, you get 2 electrochemical cell buildup and you selectively 3 leach out the aluminum. It is like 4 dezincification. And so, you end up with sort of 5 like a porous structure.

6 MR. BERG: Right.

7 MEMBER BALLINGER: But, if you whack it 8 with a hammer, you will find out that it is not 9 so -- that the porosity is a problem. And so, 10 wrought materials are usually not susceptible or if 11 you heat-treated casting, so that you get rid of 12 the solidification microstructure that goes on.

13 And the rates are anywhere from .05 to .5 mLs per 14 year sometimes, or even higher, depending on the 15 structure.

16 MEMBER KIRCHNER: With the current 17 material?

18 MEMBER BALLINGER: With the cast 19 material.

20 MEMBER KIRCHNER: With the casting?

21 MEMBER BALLINGER: With the cast 22 material.

23 MEMBER KIRCHNER: Right. And what is 24 the differential with the wrought?

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35 1 gamma phase. And so, you don't have the same kind 2 of problem at all for de-aluminization. So, 3 wrought materials are generally not susceptible to 4 the material. And if you are less than -- you said 5 8 or 9 percent --

6 MR. BERG: Yes, 8 percent.

7 MEMBER BALLINGER: I think it is on the 8 order of 8 percent, where if you look at the phase 9 diagram, you can't get that phase.

10 MEMBER KIRCHNER: Yes. Thank you.

11 MR. BERG: Okay. So, the focus on the 12 open item is associated with the welds themselves.

13 So, let's move on to that particular area.

14 So, with the welds, we have seen --

15 first off, we haven't seen any since 1994, but what 16 we see is, it actually is a cracking phenomena that 17 occurs. Okay? So, from finding the particular 18 condition when it does occur, and it hasn't been 19 since 1994, just operators doing a walkdown, so you 20 will see a light mist spray or maybe some water on 21 the floor. So, the operators would identify that 22 as part of the walkdown and would put in a 23 corrective action program and handle it through 24 that methodology.

25 So, we have seen 10 welds with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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36 1 cracking. The cracking has some de-alloying 2 associated with that. We have had two of them that 3 occurred, two of the cracks that have occurred in 4 thermal welds. The rest of the cracks, though, 5 have occurred with welds with backing rings, which 6 is the focus of a lot of our work in addressing the 7 open item.

8 MEMBER KIRCHNER: What is the typical 9 corrective action, then, once you discover this?

10 MR. BERG: We would cut it out and 11 replace it. When we talk about the open item, 12 there are 10 issues associated with that. When I 13 go through that, I will talk about the specifics we 14 do on how do we do the inspection, acceptance 15 criteria, and then, we will talk about corrective 16 actions.

17 MEMBER RICCARDELLA: So, is a 18 significant percentage of this piping underground?

19 MR. BERG: Not percentage-wise, and I 20 don't know what the percentage of the welds because 21 most of the underground piping is of large sections 22 in nature, but we do have some of the welds 23 certainly that are underground with backing rings.

24 MEMBER SUNSERI: So, maybe you are 25 going to talk about this when you get to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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37 1 inspections, but is there an NDE technique for this 2 or?

3 MR. BERG: This really gets into our 4 corrective action. But we have been working over 5 the last few years with an NDE technique. So, 6 obviously, if it is a cracking-type phenomena that 7 is occurring, ultrasonic NDE will detect that 8 condition.

9 MEMBER SUNSERI: And are you doing it 10 any?

11 MR. BERG: So, we would do it if we 12 found a condition where we were seeing cracks at 13 the surface type of thing. Then, we would follow 14 the code requirements and we would have to go 15 characterize that, and we would go do an NDE 16 inspection.

17 MEMBER SUNSERI: Okay. Because I 18 thought I heard you say you see the misting and all 19 that stuff. So, I mean, it is a safety-related 20 system. I guess that puts you in a tech-spec 21 action statement.

22 MR. BERG: That is correct. So, we 23 would do an operability --

24 MEMBER SUNSERI: The active mode 25 versus --

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38 1 MR. BERG: It would be an operability 2 determination associated with that, which Ron would 3 request, and we would go do the characterizations 4 in accordance with code.

5 And we are going to talk a little bit 6 later on, the proactive piece is prior to the 7 period of extended operation. I will just get to 8 it briefly now. It is that we will do an 9 inspection of -- I'm going to get this wrong -- 20 10 percent with 25 welds with backing rings and 11 without backing rings prior to the period of 12 extended operation. We will actually go in and 13 come apart and look at it.

14 We have looked at others as well. I 15 don't want to let you believe we haven't done any 16 evaluation. We have done evaluations, 17 metallurgical exams of the things where we have 18 found cracking in the past and other ones where we 19 have the castings, you know, we look at the welds 20 as well as part of that.

21 MEMBER SUNSERI: Okay.

22 CHAIRMAN SKILLMAN: Mike, let me ask 23 this: from the inspection report, the 71002 24 inspection report, the comment is, "The team noted 25 the experience regarding the loss of material NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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39 1 caused by selective leaching in aluminum bronze 2 components in the essential service water system is 3 an ongoing aging mechanism." That is from the 4 71002 inspection.

5 MR. BERG: Yes.

6 CHAIRMAN SKILLMAN: The text appears to 7 point only to the essential service water system.

8 Is th is phenomenon anywhere else in any other 9 systems?

10 MR. BERG: The answer to that is no 11 because we only use aluminum bronze in our 12 essential --

13 CHAIRMAN SKILLMAN: Let me ask you one 14 more. Your cathodic protection system is not in 15 scope. At least it isn't in the document that I 16 read. What connection have you made between this 17 phenomenon and the inoperability of your cathodic 18 protection system for what appears to be 10 to 15 19 years?

20 MR. BERG: Do you want to answer from 21 the TLA perspective?

22 MR. ALDRIDGE: Yes. Yes, sir. Let me 23 answer from the perspective of the cathodic 24 protection. The piping at South Texas is 25 cathodically protected as part of the buried piping NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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40 1 aging management program, and aluminum bronze is 2 one of the systems that is protected by the 3 cathodic protection.

4 CHAIRMAN SKILLMAN: Would it be more 5 accurate to say is now protected by, but was not 6 for a long time period? That is a yes or no.

7 MR. ALDRIDGE: No. It is always had 8 various degrees of protection. We have enhanced 9 the degree of protection since the regional 10 inspection, and now we are meeting better 11 availability and --

12 MEMBER STETKAR: Let's get specific.

13 What has the historic availability over the life 14 of the plant of your cathodic protection system 15 been?

16 MR. ALDRIDGE: Thank you, sir. We have 17 the subject matter expert present, and he can give 18 you the numbers.

19 CHAIRMAN SKILLMAN: Okay. Let's do 20 that, please.

21 MR. KHONDKER: My name is -- can you 22 hear me?

23 CHAIRMAN SKILLMAN: Yes.

24 MR. KHONDKER: Okay. So, my name is 25 Raihan Khondker. I am the Cathodic Protection NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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41 1 System Engineer at South Texas.

2 And the question being asked, what is 3 our historical availability of the cathodic 4 protection system? Over the past since the 5 inception of the plant, we have maintained the 6 cathodic protection system in the entire protected 7 area. So, we always adhere to the 8 needs/requirements back then, which used to be --

9 now it is called SBO 0169; back then it was RP. We 10 adhered to that since the beginning and we did 11 maintain the full availability as possible.

12 But, of course, over the course of the 13 years when we saw deteriorations, rectifiers out of 14 service, in some years we did see the rectifiers' 15 ability to go down. But, based on our corrective 16 action program, we have fixed those and we have 17 made sure that availability was always at the 18 higher point more than 80 percent, as we always 19 adhere to.

20 MEMBER STETKAR: I'm not sure that I 21 got a straight answer to my question. Over the 22 life of the plant, I would like to know what the 23 historic percentage availability has been if I take 24 the time up divided by the total time the plant has 25 been operating as a percentage. You have told me NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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42 1 that you had corrective action programs and things 2 were out of service for a long time. But what is 3 the average historical availability over the life 4 of the plant?

5 MR. KHONDKER: For that, I will have to 6 go through my trending database.

7 MEMBER STETKAR: Great. Thank you.

8 MR. KHONDKER: And then, I have to find 9 it out for you.

10 MEMBER STETKAR: Thanks.

11 MR. KHONDKER: But, since I took over, 12 it has been over 80 percent.

13 MEMBER STETKAR: Okay. Thanks.

14 MEMBER RICCARDELLA: Does cathodic 15 protection have any influence on this selective 16 leaching process?

17 MR. BERG: The answer is, no, it does 18 not, but our very piping is coated and it is 19 protected from that standpoint.

20 MR. MURRAY: Yes, I was going to make 21 sure we got back to that as well, to break that 22 tie. That was, for example, the picture that you 23 saw was not an underground cathodic-protected area.

24 MEMBER BALLINGER: It is very difficult 25 to use cathodic protection for this problem, yes, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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43 1 because it is a very local system.

2 MR. BERG: Okay. Moving on, wrought 3 material is not susceptible, as we have already 4 discussed. The susceptible component population, 5 castings will be replaced. Just a feel for that, 6 400 to 450 castings in the plant. We will replace 7 those prior to the period of extended operation.

8 And again, our focus on our open item 9 is associated with welds or weld repairs with 10 susceptible weld filler material. It will be 11 managed. That includes piping butt-welds and, 12 also, weld preparers on extruded tees.

13 MEMBER STETKAR: Is that 400 to 450 per 14 unit or per the site?

15 MR. BERG: Per the site.

16 MEMBER STETKAR: Thanks.

17 MEMBER BALLINGER: But castings are 18 susceptible, but you haven't had a problem with the 19 castings, except I read in the SER you had a lot of 20 valve bodies and all kinds of things that were.

21 So, you have had that problem?

22 MR. BERG: Yes.

23 MEMBER BALLINGER: But, with the 24 welding, how are you going to get around the 25 problem with welding? Because you still have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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44 1 solidification issue. Are you going to post-weld 2 heat-treat? What are you going to do to get rid of 3 that problem?

4 MR. BERG: Okay. So, we will talk 5 about that when we go through the open issue, but 6 it is really with the one-time inspections and with 7 the periodic inspection, particularly the welds 8 with the backing rings.

9 What we do to address that is we would 10 use a weld filler material with nickel in it.

11 MEMBER BALLINGER: Yes, okay.

12 MR. BERG: We have found that would 13 prevent having the transformed region.

14 MEMBER BALLINGER: It is like a Class 15 IV. Okay.

16 MR. BERG: Okay. So, to get into the 17 open item, our open item, the STP has responded to 18 NRC staff's questions associated with selective 19 leach in aluminum bronze. We did send a response 20 in on September 28th.

21 Just to talk a little, we do have a 22 comprehensive aging management program that 23 addresses selective leaching. That program 24 includes inspections of walkdowns, replacements 25 prior to the period of extended operation. Then, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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45 1 am going to talk specifically associated with the 2 welds. It includes one-time volumetric exams, 3 periodic volumetric examination, defines acceptance 4 criteria, and has additional testing elements in 5 it.

6 The specific open item is related to 7 welds, and the Safety Evaluation Report does 8 contain 10 specific issues, which I will discuss 9 further on the following three slides.

10 DR. SCHULTZ: Mike, I've got a general 11 question related to the recent history for the 12 program. Of course, the overall discussion goes 13 back many years.

14 But, in this year, you put together a 15 fully-revised, well, I will call it a fully-revised 16 program because there were many issues associated 17 with Rev. 1 of the program. And now, this Rev. 2 18 program was submitted to the staff in June of this 19 year.

20 And my question is general, in that, 21 once that was submitted, then there were many 22 questions from the staff related to the new and 23 revised program. So, my general question is, why 24 did that happen? You had a lot of experience with 25 the program moving forward. You had the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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46 1 opportunity or made the choice to put in a fully-2 developed to address a number of concerns that the 3 staff had had over the years really. And yet, 4 there were a number of issues that were not, if you 5 will, fully addressed in the new program where you 6 had the opportunity to really set yourself up for 7 full success. And yet, there has been a number of 8 issues in many different areas that the staff found 9 needed additional attention. So, my question is 10 that: why did that happen? Can you give me some 11 perspective on that or give us some perspective on 12 that?

13 MR. BERG: So, there are several phases 14 that I think we have gone through here. First, our 15 first focus was on the casting-type material. I 16 said before we have got about 400 to 450 of those.

17 I believe it is about 56 of them, of the large 18 border castings that we have found that the 19 alloying on, again, as we talked about earlier, 20 with a little bit of copper oxide on the outside 21 surface so far.

22 Our real focus was on the casting-type 23 area. We did a lot of research, testing, did bin 24 testing and strength tied to the de-alloying of our 25 casting materials. Lots of correspondence and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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47 1 interaction took place between us and the Nuclear 2 Regulatory Commission, and we just ended up in the 3 point of all of that to go to that reasonable 4 assurance to the level that was expected for that; 5 that the easiest answer to that was just to go 6 ahead and replace the castings. And we were doing 7 selective replacements just to do testing anyway.

8 So, that was a change in the program.

9 And then, the next phase came in 10 associated with the welds themselves. Okay?

11 Again, that assurance that, from a welding 12 standpoint, that we would not expect to see any 13 cracks in the future or, even more important, that 14 we don't see anything that would impact the 15 structural integrity of our essential cooling water 16 system.

17 We think we have had that, but there 18 were a series of questions that we had to go 19 through to answer and to come up with some 20 additional research or evaluation of the welding 21 itself just to demonstrate that.

22 DR. SCHULTZ: So, as you revamped the 23 program, you really went broader in terms of those 24 specific areas that you determined you needed to 25 address? So, the scope of the program grew NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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48 1 dramatically --

2 MR. BERG: Correct.

3 DR. SCHULTZ: -- based on lessons 4 learned? And you, then, look at these additional 5 items as a reasonable level of issue that needed to 6 be resolved, given that you have revamped a major 7 part of the overall program?

8 MR. BERG: That is correct.

9 DR. SCHULTZ: Thank you.

10 MR. BERG: Okay. Let's get into the 11 specific 10 issues for our particular open item.

12 So, the first one -- and I am going to do this at a 13 high level -- we added information to bound 14 extruding piping tee repairs. We have about 17 15 tees, extruded tees. Extruded tees are not 16 susceptible to selective leaching, but they do have 17 weld repairs on them. So, part of this is that we 18 will evaluate those repairs. We are just going to 19 make a conservative assumption that that repair is 20 cracked, okay, and then, look at it from that 21 standpoint of structural integrity of that tee. If 22 we cannot demonstrate structural integrity under 23 that condition, we will replace that tee prior to 24 the period of extended operation.

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49 1 monitored to address. First is loss of material 2 due to selective leaching, which is monitored 3 through our system walkdowns and destructive 4 examinations. Cracking associated with selective 5 leaching is monitored through volumetric 6 examination of destructive evaluation. And the 7 third area is our root passes phase distribution is 8 verified to be discontinuous phase during our 9 destructive inspections.

10 Item No. 3, clarify the sample size for 11 volumetric inspections. As I said earlier, we will 12 do a one-time inspection on 20 percent with a 13 maximum of 25 welds with and also another sample 14 without backing rings prior to the period of 15 extended operation. And then, we will do periodic 16 examination every 10 years on 20 percent with a 17 maximum of 25 welds with backing rings, just to 18 validate from an aging management standpoint that 19 there is not something that we missed in there.

20 Four, clarify the thresh --

21 MEMBER RICCARDELLA: Excuse me. Is 22 that different weld, a different 25 percent for the 23 initial inspection versus the subsequent, the 24 periodic?

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50 1 that because, when we do the destructive 2 examination, we will --

3 MEMBER RICCARDELLA: Oh, it is a 4 destructive?

5 MR. BERG: It is a destructive --

6 MEMBER RICCARDELLA: I'm sorry, I 7 thought it was --

8 MR. BERG: Yes. We do the volumetric, 9 but to look at the phase distribution, it is going 10 to end up being destructive.

11 MEMBER RICCARDELLA: Okay. And you 12 said there is only about 100 of these welds out 13 there?

14 MR. BERG: There is actually about 3300 15 welds in the plant.

16 MEMBER RICCARDELLA: So, you said 20 17 percent was 25 welds. I don't understand.

18 MR. BERG: Well, the criteria we use is 19 20 percent. A standard in the GALL would be 20 20 percent or 25. So, we are meeting the GALL 2 21 requirements on our sample size.

22 So, we have got about 3300 welds total.

23 About a third of those, or about 1100 of them, have 24 backing rings.

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51 1 answered?

2 MEMBER RICCARDELLA: I thought I heard 3 you say a one-time inspection of 20 percent which 4 is about 25 welds. And I don't understand how that 5 fits with 3300 welds total.

6 MEMBER STETKAR: The criteria, the GALL 7 criteria says 20 percent or a maximum of 25.

8 MEMBER RICCARDELLA: Oh, oh, oh, oh.

9 Okay. Yes.

10 MR. BERG: So, I am staying with the 11 GALL requirements, but, in reality, it is 25.

12 MEMBER RICCARDELLA: Okay. All right.

13 All right.

14 MEMBER BALLINGER: Is that a rational 15 choice?

16 (Laughter.)

17 I mean, I can understand sticking with 18 the letter of the law, okay, but you have a known 19 issue which you think you are going to have solved, 20 which you might have. And so, to just arbitrarily 21 say we're just going to do 25 and get it over with 22 and move on just doesn't seem to me -- I mean, is 23 there a way, is there some kind of rapid expansion 24 that would occur if you see an issue that is also 25 different from the GALL requirements? You know, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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52 1 this is a unique set of cases, I think.

2 MR. BERG: So, that does get into the 3 next item here. Okay? So, let me try to answer 4 your question a little bit more basic to start 5 with.

6 So, again, this condition, we have not 7 seen any crack in the welding since 1994. We have 8 done some research and testing that we believe that 9 we understand why that is the case. We do believe 10 it is a preexisting flaw that seems to be there.

11 So, you expect to see with a preexisting flaw 12 sometime early in life you can see the propagation 13 to the surface. So, we think we fully understand 14 why we haven't seen anything since 1994. We think 15 the 25 sample size is adequate to do confirmation 16 on what we have cut open. We have also cut open 17 some other samples of other removed castings and 18 looked at those as part of coming up with our 19 criteria. So, the 25 is to meet the GALL 20 requirements, but we do believe that that is 21 perfectly acceptable, that condition.

22 If we do find one that doesn't meet the 23 criteria, we would go back to the Generic Letter 24 90-05 criteria. And for every one that we would 25 find that doesn't meet our predictions, we would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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53 1 increase that sample size by five until we had no 2 welds that had issues on them. So, we will follow 3 the Generic Letter --

4 MEMBER BALLINGER: By five or a factor 5 of five?

6 MR. BERG: By five.

7 MEMBER BALLINGER: By five.

8 MEMBER RICCARDELLA: How are the 25 9 samples selected?

10 MR. BERG: Okay. So, that is No. 5 on 11 the bottom of the page, and those will be randomly 12 selected from the total population of above-ground 13 welds, considering construction and size 14 distributions. We will use ASME Code criteria to 15 do that.

16 MEMBER BALLINGER: Okay. Randomly 17 selection, with this kind of phenomenon, can't you 18 get a little bit less random? Because when you do 19 welding and stuff like that, you can record heat 20 input and all those kinds of things. So, is there 21 another set of criteria which you can overlay on 22 this that says we'll do this random 23 characterization, but this particular weld and this 24 particular weld, in our judgment, may be a little 25 bit more susceptible? Can you modify the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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54 1 randomness a little bit?

2 MR. BERG: I don't know.

3 MEMBER BALLINGER: Modified randomness, 4 I'm not sure that is a good --

5 MR. BERG: Yes. I mean --

6 DR. SCHULTZ: But the question is, 7 should you modify the GALL process?

8 MR. BERG: Yes, I'm not sure what 9 criteria that we could actually use to be able to 10 do any more. We use the standard welding process 11 for all the pipe. Again, you are looking focused 12 mainly on those pipes with backing rings to go 13 after. But, because it is a standard process that 14 we used, I am sure that we would see anything where 15 we could say this particular welder or this 16 particular heat, you know, is any different.

17 We have gone back and looked at the 18 heats. We have looked at where we stand with 19 respect to the amount of aluminum in our weld 20 filler material. I'll tell you, it is pretty 21 standard percent aluminum that goes through that 22 whole thing.

23 So, I am really not aware of any 24 criteria that we can use to try to --

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55 1 bronze weld material is going to be better, much 2 better.

3 MR. BERG: Absolutely.

4 MEMBER BALLINGER: But right at the 5 interface between the weld and the heat-affected 6 zone there is going to be a wrought material which 7 is not going to be wrought anymore.

8 MR. BERG: Yes.

9 MEMBER BALLINGER: It is going to be at 10 the melting point and, then, it is going to be 11 requenched. And so, I am wondering whether or not 12 the welds will be fine, but right, you know, 13 adjacent to the weld where that thermal transient 14 has happened, you don't get gamma phase in the 15 piping itself and now get yourself in an issue 16 there.

17 MR. BERG: So, again, you start off 18 with less than 8 percent. So, if you look at the 19 phase diagram for the wrought material, you know, 20 being less than 8 percent, you would not expect to 21 go through a transformed region.

22 MEMBER BALLINGER: I agree.

23 MR. BERG: And --

24 MEMBER BALLINGER: But, again, you are 25 going to melt some of that material.

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56 1 MR. BERG: Right.

2 MEMBER BALLINGER: In the 3 solidification process there is a chance that you 4 will get a region during the solidification process 5 where you go where you are above 8 percent.

6 MR. BERG: Okay.

7 MEMBER BALLINGER: Okay. I am just 8 curious as to --

9 MR. BERG: For two pieces of that, I 10 have got an expert here I can call upon. But the 11 other piece is, when we look at the root pass of 12 the weld, one of the differences there, it is very 13 rapidly-cooled.

14 MEMBER BALLINGER: Yes.

15 MR. BERG: So, we have actually looked 16 at that and --

17 MEMBER BALLINGER: Okay.

18 MR. BERG: -- it looks like it is like 19 a maximum of 36 seconds to cool it down. So, there 20 is really not adequate time, even if you end up 21 with greater than 8 percent type of aluminum 22 content, to go to the transformed region. And if 23 you do get some in there, you are usually, instead 24 of at the gamma-2 phase, you are at the beta phase.

25 MEMBER BALLINGER: Okay. I'm just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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57 1 saying usually --

2 MR. BERG: That is 25, which is less 3 acceptable and it is discontinuous in nature.

4 MEMBER BALLINGER: Okay. You know the 5 old saying: the great tragedy of science is the 6 slaying of a beautiful hypothesis by a ugly fact.

7 MR. BERG: Yes.

8 MEMBER RICCARDELLA: But as your OE 9 indicated any problems at all with the wrought 10 side, with the piping side of the weld?

11 MEMBER BALLINGER: The wrought material 12 is never a problem.

13 MEMBER RICCARDELLA: No, but it is the 14 weld. You are talking about the heat effect has on 15 the weld, but --

16 MEMBER BALLINGER: Yes, right where it 17 has been solidified.

18 MEMBER RICCARDELLA: Yes.

19 MR. BERG: The answer is no to that 20 question. And going one step further, when we have 21 seen an issue, it has been due to a weld defect 22 that was already there as part of the original 23 construction.

24 MEMBER RICCARDELLA: And it was in the 25 weld, not in the heat-affected zone?

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58 1 MR. BERG: In the weld, correct.

2 MEMBER RICCARDELLA: Okay.

3 MEMBER BALLINGER: But don't you have 4 two issues, cracking and de-aluminization?

5 MR. BERG: Yes.

6 MEMBER BALLINGER: So, I'm talking 7 about the de-aluminization part, not the cracking 8 part.

9 MR. BERG: So, the de -- I will try to 10 get there.

11 MEMBER BALLINGER: It is too many 12 syllables.

13 (Laughter.)

14 MR. BERG: Yes. So, the de-alloying 15 going on in the casting pipe region, we are taking 16 care of that. And we have seen a lot of that 17 without any, you know, preexisting --

18 MEMBER BALLINGER: Okay.

19 MR. BERG: -- flaws or anything else.

20 When we get into the welds, we do see 21 some de-alloying in the weld surfaces, but 22 everything is telling us it is due to that 23 preexisting flaw. Probably just created an 24 environment because of the type crack and the 25 aqueous condition in there, it has created an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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59 1 environment that did allow anything in the 2 transformed region to show that de-alloying 3 occurred, maybe weakened the material a little bit, 4 and then, allowed cracking and, then, de-alloying 5 and cracking as it propagates through. We don't 6 really know that for a fact, but what we do know is 7 all of our OE tells us there had to be a 8 preexisting flaw there for this condition to occur.

9 MEMBER RICCARDELLA: Just to be clear, 10 if we go to that slide 17, the picture, you have 11 never had the type of problem that you have circled 12 there on the wrought piping side of a weld?

13 MR. BERG: That is correct.

14 MEMBER RICCARDELLA: Thank you.

15 CHAIRMAN SKILLMAN: I would like to 16 move on. I want to make it clear that in your 17 prior discussion you communicated that, when you do 18 have evidence, you file a condition report because 19 of the way your tech specs are written. You do an 20 operability determination, and that operability 21 determination directs the action of the site staff?

22 MR. BERG: That is correct.

23 CHAIRMAN SKILLMAN: And with that, I 24 believe we --

25 MEMBER STETKAR: Hold on.

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60 1 CHAIRMAN SKILLMAN: Go ahead, John.

2 MEMBER STETKAR: We have got all kinds 3 of time here this morning. We don't have to rush 4 through this.

5 CHAIRMAN SKILLMAN: No, no.

6 MEMBER STETKAR: Ron, I'm not a 7 materials guy. So, you questioned first the kind 8 of random sampling notion. This is for my own 9 education.

10 In many other of these programs that we 11 have seen, not this particular one, throughout the 12 course of license renewal, where you do have a 13 large population to select from, people establish 14 what they call a risk-informed sampling program.

15 And I don't want to get into the nuances of risk, 16 but they look at places where they would be more 17 likely to find a problem, whether that is a fatigue 18 issue or whether it is cracking of small-bore 19 piping welds, or whatever, and then, sample from 20 those locations.

21 So, I'm asking you, given what we have 22 heard here, is there a more, I'll call it risk-23 informed approach that could be used, rather than 24 just randomly selecting 25 out of 3300, in your 25 opinion?

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61 1 MEMBER BALLINGER: See, I am not a risk 2 guy. So, I hesitate to use the word "risk," but I 3 will use it anyway.

4 That is what I was trying to get at.

5 Basically, modifying the random sample business, 6 knowing that under certain conditions the 7 possibility is that you will get a more susceptible 8 area, so that is exactly what I am suggesting.

9 MEMBER STETKAR: But, I mean, you know, 10 based on your own experience, is there something 11 that you could think of that would sort of narrow 12 down the field a bit?

13 MEMBER BALLINGER: I would take a look 14 at the welding procedures, and you already have, 15 and decide, depending on pipe size and heat input 16 and things like that, whether or not there is a 17 possibility that you get the second phase and, 18 then, focus your randomness, if you will, on some 19 of those areas, until you discover that, yes or no, 20 we don't have an issue. And this occurs over a 21 very long period of time, though.

22 MR. BERG: Correct.

23 MEMBER BALLINGER: So, it is not like 24 you are going to have some kind of catastrophic 25 failure all the time.

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62 1 MR. BERG: Correct.

2 MEMBER BALLINGER: But you are right, 3 that is the way to do it.

4 MEMBER STETKAR: Okay. Thanks.

5 MEMBER BALLINGER: Thanks.

6 MEMBER RICCARDELLA: I'm not familiar 7 with this type of piping, but, from what I know 8 about code class piping, 25 welds out of 3300 is a 9 minuscule sample. I mean, in code class piping we 10 do typically 25 percent of the welds, and if you 11 find anything in that 25 percent, you are in doing 12 another 25 percent, and if you find anything in 13 that second 25 percent, you do 100 percent.

14 MEMBER STETKAR: But, again, that is 15 more of a question for the staff --

16 MEMBER RICCARDELLA: Yes, yes.

17 MEMBER STETKAR: -- because they wrote 18 the guidance and they are following the guidance.

19 MEMBER RICCARDELLA: Right.

20 Understood, yes.

21 MR. BERG: So, I would like to go ahead 22 and move on to slide 21.

23 CHAIRMAN SKILLMAN: Yes, please 24 proceed, yes.

25 MR. BERG: Okay. Item No. 6, we did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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63 1 determine that there was no impact of the external 2 coatings regarding detecting buried piping leaks at 3 the surface.

4 Seven, we have identified a method to 5 monitor our trend results.

6 I would like to focus a little bit more 7 on Item No. 8, define the acceptance criteria for 8 the weld defects. For visual exams, the acceptance 9 criteria is no detectable leakage. For volumetric 10 examination, it would be no detected twiner 11 indication that is subsurface-connected unless the 12 depth of the indication is contained within the 80 13 percent of the weld root pass. And for destructive 14 examinations, no selective leaching penetrating 80 15 percent of the root pass region, and any found 16 selective leaching is non-propagating. So, it is 17 surrounded by a non-continuous resistant phase 18 distribution.

19 And then, the microstructure of the 20 weld root region will exhibit a non-continuous 21 phase distribution, which is consistent with all of 22 our metallurgical evaluation or metallurgical 23 reports that we have done so far. So, we see a 24 non-continuous phase distribution. So, if you had 25 a little localized de-alloying, it is not going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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64 1 have any depth associated with that, being a non-2 continuous.

3 Item No. 9, identify the threshold for 4 increased inspections when adverse inspection 5 results are detected. We talked about that a 6 little bit earlier. That is tied back to Generic 7 Letter 90-05.

8 And the last item is to identify the 9 corrective actions to address all potential 10 inspection results. We will remove any leaking 11 welds and destructively exam to determine the 12 extent of the cracks, the extent of the selective 13 leaching, and the microstructure phase 14 distribution, perform five additional volumetric 15 exams, and perform a structural integrity 16 evaluation to confirm the load-carrying capacity.

17 Move on to the next slide. So, this 18 brings us into one remaining open issue associated 19 with the corrective actions. This remaining issue 20 concerns how to address the extended condition in 21 the unlikely condition that structural integrity 22 evaluation does not support the load-carrying 23 capability or capacity.

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65 1 have had some initial communications with the NRC 2 staff, and we do feel comfortable that we can 3 address that concern, and it does support a pathway 4 forward and timely response and resolution.

5 DR. SCHULTZ: Mike --

6 MR. BERG: Yes?

7 DR. SCHULTZ: -- just before you get to 8 the conclusion, as you presented it, the addressed 9 issues, you have presented your response to the 10 staff and you feel you have agreement with the 11 staff that, in fact, your responses have been 12 accepted? And it is only Item No. 10 that has not 13 been fully resolved? You have provided a response, 14 but, then, the staff had additional questions 15 related to that?

16 MR. BERG: Yes, an additional question 17 is what we are working with the staff on to 18 address.

19 DR. SCHULTZ: Okay.

20 MR. BERG: And again, we do feel that 21 we have a pathway to timely resolution of that --

22 DR. SCHULTZ: On Item No. 10?

23 MR. BERG: -- item, yes.

24 MR. MURRAY: Yes, it could be 25 characterized as initial conversations on that --

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66 1 DR. SCHULTZ: Okay.

2 MR. MURRAY: -- with the understanding 3 of the strategy.

4 DR. SCHULTZ: Thank you.

5 MEMBER KIRCHNER: I should have asked 6 this earlier. How many linear feet of pipe 7 comprises this system with the aluminum bronze and 8 how much of it is buried underground? Just an 9 estimate. I'm not holding you to exact numbers.

10 Where I am getting at is most of your visual at 11 least inspections will be --

12 CHAIRMAN SKILLMAN: Well, buried 13 underground versus buried where else?

14 (Laughter.)

15 MEMBER KIRCHNER: Well, you know, 16 inaccessible.

17 CHAIRMAN SKILLMAN: Oh, okay. Just 18 making sure.

19 MEMBER KIRCHNER: Sure.

20 MR. BERG: I would say I am really 21 giving you kind of an estimate, just based on where 22 our essential cooling water intake structure is to 23 our Class 1E structures -- you can choose a little 24 bit further away -- so, I would say about 3,000 25 foot underground would be my estimate associated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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67 1 with that.

2 MEMBER KIRCHNER: And that, the 3 component of piping that is underground, that is 4 primarily welded. The flanges that you have had 5 problems with are at the actual above-ground 6 equipment?

7 MR. BERG: Yes. So, I will make it 8 real clear. There are no castings or cast material 9 underground.

10 MEMBER KIRCHNER: Okay. Thank you.

11 Thank you.

12 MEMBER RICCARDELLA: But, then, above 13 ground -- there's 3,000 feet below underground --

14 then, what is the remainder of the system, 15 approximate? I'm sorry. Just ballpark, what is 16 the remainder. If you have 3300 welds, I imagine 17 it is a lot of feet.

18 MR. BERG: Yes, there's several 19 thousand feet. We have 30-inch pipe; we have 4-20 inch pipe, 10-inch pipe through the plant. I'm 21 thinking in the several thousands, 13,000-ish.

22 Kevin or Rick?

23 MR. STARK: Good afternoon. Rick 24 Stark, the Pipe Program Engineer at South Texas.

25 Buried underground piping, between the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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68 1 two units, supply and return, is just over 24,000 2 feet.

3 MEMBER RICCARDELLA: Buried? Buried?

4 MR. BERG: And that is essential 5 cooling water piping?

6 MR. STARK: That is correct. That is 7 all essential cooling water piping. There is 6-8 inch, 10-inch, and 30-inch.

9 MR. BERG: I was off by a factor of 10 eight.

11 Thanks, Rick. Thank you.

12 MEMBER SUNSERI: Hey, Mike, I hate to 13 keep picking on this, but this acceptance criteria 14 for the weld defects, I am confused on it. When 15 you go out and do your 25 inspection, you are going 16 to look at these welds and you are going to apply 17 this criteria?

18 MR. BERG: Right.

19 MEMBER SUNSERI: Is that correct? So, 20 you are going to look at it to see if it is not 21 leaking? You are going to do a volumetric 22 examination to see if there is anything inside of 23 it? And then, you are going to cut it out to do a 24 metallurgy examination?

25 MR. BERG: A metallurgy examination.

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69 1 MEMBER SUNSERI: So, essentially, you 2 are replacing 25 every inspection period then, 3 right?

4 MR. BERG: That is correct.

5 MEMBER SUNSERI: Okay. Thank you.

6 MR. BERG: Okay. So, in conclusion, 7 following the resolution of that remaining issue 8 related to corrective actions, the selective 9 leaching of Aluminum Bronze Aging Management 10 Program, effectively, we will manage the aging of 11 the essential cooling water cast components and 12 welds during the period of extended operation.

13 MEMBER BALLINGER: Can I get one thing?

14 I'm still fuzzy. You have got several miles, 15 kilometers, of buried piping. You are going to 16 take 25 welds, presumably not buried?

17 MR. BERG: That is correct.

18 MEMBER BALLINGER: Okay. And the 19 reason you don't have to take any of the welds from 20 the buried piping is because there is no cast 21 material buried?

22 MR. BERG: Not really. Because if it 23 is a cast material, we will replace the castings 24 prior to the period of extended operation.

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70 1 replace the castings?

2 MR. BERG: And when we replace that 3 weld, we will use the nickel-based material. So, 4 it won't be vulnerable to it.

5 MEMBER BALLINGER: So, of the 6 underground piping, that will fall into a category 7 where it has either been replaced, the casting has 8 been replaced, or it is wrought material and, 9 therefore, there is no selective leaching issue for 10 the underground piping? Is that what I'm hearing?

11 MR. BERG: For the underground? So, 12 the underground piping is only wrought material 13 already. That is what exists now. So, we will use 14 -- so, from a stress standpoint, the above-ground 15 welds are higher-stress conditions; they are more 16 vulnerable -- so, we will use our operating 17 experience from the above-ground welds for any 18 decisions associated with expansion of scope. And 19 this really ties back in the corrective action, 20 depending on what we see.

21 Again, we think all of our research 22 shows us that we have a boundedness condition and 23 we don't expect to see anything really for the rest 24 of the life of the plant, as we haven't since 1994.

25 Our aging management program will demonstrate that.

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71 1 MEMBER BALLINGER: Thank you.

2 MR. BERG: Okay. I would now like to 3 turn it over to Dave Rencurrel for closing remarks.

4 CHAIRMAN SKILLMAN: Before we get 5 there, one of the reasons I was trying to move 6 along is I have got a couple of comments 7 independent from aluminum bronze, and perhaps my 8 colleagues have comments as well. So, may I please 9 go after those right now? I'm good for your 10 closing comments, but I would like to have this 11 opportunity with the STP staff in front to ask some 12 questions.

13 I'm in your license renewal 14 application. I'm on page 84. "Cathodic protection 15 is not in scope." Why? It is on the record in 16 your document.

17 MR. ALDRIDGE: Arden Aldridge.

18 Cathodic protection as far as in the 19 scope, let me have Mr. Warner --

20 CHAIRMAN SKILLMAN: Please do.

21 MR. ALDRIDGE: -- who can provide some 22 clarification.

23 CHAIRMAN SKILLMAN: Okay.

24 MR. WARNER: Yes, my name is Gary 25 Warner. I'm the Senior Project Manager for License NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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72 1 Renewal.

2 Cathodic protection is not in the scope 3 of license renewal because it is not one of those 4 systems that performs an intended function for 5 license renewal. It is a support system that is 6 used to allow you to protect your buried piping.

7 But, in the absence of cathodic protection, you are 8 required to inspect a lot more buried piping than 9 you would if you have adequate cathodic protection.

10 So, based on the other plants in the 11 country plus the way the rule is written, cathodic 12 protection does not perform a license-renewal-13 intended function.

14 CHAIRMAN SKILLMAN: Thank you for that 15 explanation.

16 I want to reinforce John Stetkar's 17 question about the time availability of cathodic 18 protection because in the Inspection Report the 19 Inspection Report very clearly states that there 20 was a 10-year period that there was no cathodic 21 protection. So, I would like to get the answer to 22 John's question as soon as you can get it to us.

23 MR. ALDRIDGE: Yes, sir.

24 CHAIRMAN SKILLMAN: Another question --

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73 1 you a followup on the operating experience of the 2 cathodic protection system?

3 CHAIRMAN SKILLMAN: That's correct, as 4 a percentage of time, yes.

5 On your license renewal application, 6 page 112, the statement is -- it is actually 7 2.3-27, but it is on PDF page 112 -- "The essential 8 cooling pond is included with the evaluation of the 9 essential cooling water structures in Section 10 2.4.9." Please tell us about the actions that you 11 have taken to confirm that the pond is good for 12 your projected PEO.

13 MR. ALDRIDGE: Arden Aldridge.

14 Yes, the pond is part of our aging 15 management program, the structured monitoring 16 program, and I have a subject matter expert here 17 who can give you some additional details on the 18 inspections that we have performed.

19 CHAIRMAN SKILLMAN: Please do.

20 MR. ALDRIDGE: Okay. Mark Wales.

21 MR. WALES: My name is Mark Wales. I 22 am a civil structural engineer at STP.

23 The pond, it is an underground pond.

24 That is the first thing you need to understand.

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74 1 out of the pond. But, as far as maintenance of the 2 pond, there's not really any maintenance that is 3 required. We do periodically inspect it and use 4 biocides to prevent things from growing in it and 5 in the concrete, and we inspect it as part of the 6 structures monitoring program periodically. But, 7 other than that, there is no specific maintenance.

8 CHAIRMAN SKILLMAN: Now you stated it 9 is underground. Is it really a surface pond or an 10 underground pond?

11 MR. WALES: Below grade, that would be 12 a better word for it. The surface water is 2 feet 13 below the ground level.

14 CHAIRMAN SKILLMAN: Okay.

15 MR. ALDRIDGE: And I can add a little 16 clarification, too. It is not only with the 17 Structures Monitoring Aging Management Program, but 18 the pond is specifically managed under the Water 19 Control Structure's Aging Management Program that 20 has the different inspections that are performed 21 for silting and volume validation and conditions.

22 So, it is managed there from that perspective.

23 CHAIRMAN SKILLMAN: Okay. Thank you.

24 Let me bring your attention to page 9-25 12 in your license renewal application. This is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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75 1 under TLAAs. The subject is your studs, nuts, 2 flanges. But, in this particular section, you are 3 silent on inserts. And the table that you show 4 shows inserts with cumulative usage factor greater 5 than one. So, do you have someone here who can 6 explain the relationship between studs, nuts, 7 flanges, and inserts? I understand the CUF for the 8 studs, nuts, and flanges, but I do not understand 9 CUF greater than one for inserts.

10 MR. LYNCH: My name is Bret Lynch. I 11 worked on the time-limiting aging analyses.

12 For standard practice, when we were 13 developing the South Texas application, we took a 14 40-year CUF, Cumulative Usage Factor, and 15 multiplied it by 1.5 to get an estimate of what the 16 CUF would be. On that criteria, we decided either 17 the current CUF was projected to the end of the 18 period of extended operation, which was one of the 19 disposition criterias. If it was over one in this 20 case, we would have to justify managing the usage 21 factor to ensure that the 40-year one would be good 22 for 60 years. So, we were keeping the same number, 23 the design transients, from 40 years for 60 years.

24 CHAIRMAN SKILLMAN: Okay. Now hold 25 that thought. That suggests in this case, and in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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76 1 other texts in your application, your TLAA depends 2 upon your cycle-counting program.

3 MR. LYNCH: That is correct.

4 CHAIRMAN SKILLMAN: Okay. What is the 5 pedigree of that cycle-counting program and how 6 does the plant manage that program? What is the 7 pedigree and how do you manage it?

8 MR. LYNCH: Well, we did perform a 9 baseline to get the current number of transients 10 currently. And then, it is an ongoing program at 11 the plant. I do not own that program.

12 MR. BERG: So, I will just add to it.

13 Really, it is procedurally-controlled under our 10 14 CFR Appendix B Program. Okay? And Mike Garner is 15 our engineer that does that cycle counting and 16 manages that program for us.

17 CHAIRMAN SKILLMAN: Okay. Thank you.

18 Let me see if I have any more here.

19 (Pause.)

20 I'll ask my colleagues, any comments 21 for the Applicant relative to this matter?

22 MEMBER STETKAR: Yes. They make me do 23 this. It's the voices in my head, I think. But I 24 have to ask this for every license renewal 25 applicant.

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77 1 Inaccessible underground cables, I 2 understand and I read back in 2011-2012, as the 3 program was evolving, there were a lot of RAIs. I 4 understand that your program is now consistent with 5 GALL Rev. 2, is that correct?

6 MR. ALDRIDGE: That is correct.

7 MEMBER STETKAR: Okay. Thank you.

8 I noticed that, as I read through 9 things, you have manholes that have solar-powered 10 sump pumps in them. And as best I can tell, you 11 have committed to what is in GALL Rev. 2, which is 12 an annual inspection of manholes or I would 13 categorize it as an episodic inspection if you 14 have, you know, a typical -- I used to do 15 consulting work down at South Texas and they used 16 to call them South Texas frog floaters.

17 (Laughter.)

18 So, you had a particularly heavy rain.

19 As best as I can tell, it is says that, 20 if an inspection determines that a sump pump is 21 inoperable, you will put it into your corrective 22 action program and fix it. Are those sump pumps 23 alarmed? I mean, is there a better indication of 24 whether they are operating or inoperable than just 25 simply finding that there is water in the manhole NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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78 1 and the sump pump wasn't working?

2 MR. ALDRIDGE: Yes, sir. The short 3 answer is they are not alarmed.

4 MEMBER STETKAR: Okay.

5 MR. ALDRIDGE: However, we do monitor 6 those, and over the years we have improved our 7 inspections there. And the subject matter expert 8 is present.

9 MEMBER STETKAR: Okay.

10 MR. ALDRIDGE: And we are doing some 11 enhancements.

12 MEMBER STETKAR: The reason I am 13 curious is because not only episodic events, but 14 you have had a history of groundwater.

15 MR. ALDRIDGE: Correct.

16 MEMBER STETKAR: So, it is a pretty 17 low-lying area --

18 MR. ALDRIDGE: Yes.

19 MEMBER STETKAR: -- and groundwater 20 intrusion is pretty pervasive.

21 MR. ALDRIDGE: Right.

22 MEMBER STETKAR: So, I was curious.

23 So, if I could hear what you are doing about those, 24 I would appreciate it.

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79 1 Khondker. I'm the cable program owner at South 2 Texas Project.

3 The question is regarding the sump 4 pumps in our manholes at STP and what we are doing 5 about it. At present, we have solar pumps designed 6 in all the manholes where we have seen water 7 submergence issues. The solar pump design that we 8 have, we have been maintaining them through our 9 preventive maintenance program. We have, depending 10 on what kind of manhole it is and how often, we 11 have seen the trend showing how often the 12 groundwater incurs. We have frequencies from four 13 weeks all the way to annually, depending on which 14 manhole it is, and we go in and inspect the pumps 15 on them.

16 And if we see that a float switch or a 17 pump or any of the control mechanisms are not 18 working, we replace it as a part of the PM. I will 19 say, if there is any water at the floor level, we 20 pump it out.

21 At present, also, what we are doing as 22 a corrective action is that we have redesigned all 23 our pumps. We have a new approved design change 24 package which is allowing me to go and replace all 25 the pumps we have. We are putting higher-duty NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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80 1 pumps. Like we have in the higher ones we are 2 putting 2,000 gallons per hour. In some of them we 3 are putting 1500 gallons per hour, and some of them 4 are below 1,00 gallons per hour.

5 So, these designs are going in as we 6 speak. We are coming out of the outage, and those 7 pumps will be going in as solar pump designs, so 8 that we can keep all the manholes dry.

9 MEMBER STETKAR: Good. That is 10 encouraging.

11 MR. KHONDKER: Yes. In total, we have 12 an estimate of 96 pumps that is going to be put --

13 MEMBER STETKAR: Ninety-six, wow.

14 MR. KHONDKER: Ninety-six solar pumps 15 are going in manholes because we have 155 manholes, 16 and out of them, 96 have seen historic --

17 MEMBER STETKAR: Since I have got you 18 up and on the --

19 MR. KHONDKER: Yes.

20 MEMBER STETKAR: -- carpet here, you 21 said 155 manholes. Is that 155 in scope for 22 license renewal or just 155 total?

23 MR. KHONDKER: No, they are not all in 24 scope.

25 MEMBER STETKAR: Yes.

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81 1 MR. KHONDKER: It is a combination 2 because we are looking at manholes, so we look at 3 them all as similar, yes.

4 MEMBER STETKAR: Sure, sure, sure, 5 sure.

6 MR. KHONDKER: Not just in scope, no.

7 MEMBER STETKAR: Great. Thank you.

8 MR. KHONDKER: No problem, sir.

9 MR. MURRAY: This is Mike Murray.

10 I do want to point out that you talked 11 about the frog floaters. We have also improved the 12 sealing, the external sealing of those manholes as 13 well.

14 MEMBER STETKAR: Yes, I have read some 15 of the operating experience. Thank you.

16 CHAIRMAN SKILLMAN: Colleagues, any 17 further questions, please, for the Applicant?

18 MEMBER RICCARDELLA: Yes, you indicate 19 you have your plant-specific program for nickel 20 alloys. As I recall, South Texas is somewhat 21 unique in having had a cracking of the bottom head 22 instrument nozzles. Is that part of your plant-23 specific program or is there anything special you 24 are doing on that topic?

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82 1 a specific on the nickel alloy program, on the 2 scope? Is that what it is for?

3 MR. ALDRIDGE: In regards to VMI, 4 right?

5 MEMBER RICCARDELLA: Yes, yes.

6 MR. GARNER: Are you referring to VMI?

7 MEMBER RICCARDELLA: Uh-hum.

8 CHAIRMAN SKILLMAN: Please identify 9 yourself.

10 MR. GARNER: My name is Michael Garner.

11 I'm the Site Metallurgist for STP.

12 The inspections for VMI will fall under 13 the code case, the guidelines described in the code 14 case, in 722, where we do a VE, a visual 15 examination, an enhanced visual examination, every 16 other year looking at 100 percent penetrations on 17 VMI. And then, every other year that isn't a code 18 inspection, we do a visual as well. It is not 100 19 percent, but it is looking for gross leakage.

20 MEMBER RICCARDELLA: Okay. Thank you.

21 CHAIRMAN SKILLMAN: Okay. Colleagues, 22 any further questions?

23 (No response.)

24 Dave, to you, please, sir?

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83 1 and we would like to thank the ACRS for your 2 questioning.

3 And I would also like to thank the 4 staff. I did not recognize our subject matter 5 experts who came here, too. We brought a little 6 bit under two dozen folks to come and ensure that 7 we had the right answers to your questions.

8 And one point I would like to make is 9 we started off by talking about the robust quality 10 assurance program, Appendix B. We are very 11 committed to the quality assurance program at South 12 Texas. As you heard here, leveraging that 13 independent oversight is one way we know that the 14 commitments we are making are being carried out.

15 With that, I would like to thank you 16 for your time.

17 CHAIRMAN SKILLMAN: Yes, sir. Thank 18 you very much.

19 With that, ladies and gentlemen, we 20 will take a 16-minute break and we will resume at 21 quarter after 10:00 on that clock.

22 We are in recess.

23 (Whereupon, the foregoing matter went 24 off the record at 9:57 a.m. and went back on the 25 record at 10:15 a.m.)

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84 1 CHAIRMAN SKILLMAN: Ladies and 2 gentlemen, we are back in session.

3 To those who are on the bridge line, we 4 respectfully request that you put your phones, *6, 5 on mute. We can hear your family background.

6 (Laughter.)

7 We would like you to please silence 8 your phones, so that there is no background noise 9 affecting other members of the public that are 10 listening in. Would you please do that?

11 Also, Greg Pick, are you there, please?

12 MR. PICK: Yes, I am.

13 CHAIRMAN SKILLMAN: Thank you.

14 Greg is our inspector. We want to make 15 sure that our recon team is onboard. He is.

16 With that, let's begin. Lois, to you, 17 please.

18 MS. JAMES: Thank you.

19 Good morning, Chairman Skillman and 20 Members of the License Renewal Subcommittee.

21 My name is Lois James, and I'm the 22 License Renewal Project Manager for the South Texas 23 Project, or STP, license renewal safety review.

24 We are here today to discuss the review 25 of the STP license renewal application, or LRA, as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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85 1 documented in the Safety Evaluation Report with 2 open items which was issued in October.

3 Joining me here at the table today are 4 Dr. Allen Hiser, the DLR Senior Technical Advisor; 5 Mr. Bill Holston, Senior Mechanical Engineer, and 6 Ms. Phyllis Clark, Project Manager, who will be 7 running the slides. Mr. Greg Pick, Senior Reactor 8 Inspector in Region IV, is on the phone and will 9 discuss the 71002 inspection results. Sitting in 10 the audience and the phone are other members of the 11 technical staff who participated in the review and 12 conducted several audits and inspections.

13 Next slide, please. I will begin the 14 presentation with a general overview of the staff 15 review. Next, Mr. Pick will present the 71002 16 inspection results. I will, then, present the main 17 sections of the Safety Evaluation Report. Mr.

18 Holston will discuss the open item on the Selective 19 Leaching of Aluminum Bronze Aging Management 20 Program, or AMP.

21 Next slide, please. STP Nuclear 22 Operating Company, or Applicant, submitted an 23 application for the renewal of STP Units 1 and 2 24 operating licenses for an additional 20 years. The 25 staff conducted onsite audits, offsite audits here NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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86 1 in Maryland, and onsite inspections. As you can 2 see, the staff performed additional audits of the 3 open item for selective leaching of aluminum 4 bronze, AMP.

5 During the scoping and screening 6 methodology audit, the team reviewed the 7 Applicant's administrative controls governing the 8 scoping and screening methodology and the technical 9 basis for select scoping and screening results.

10 The scoping and screening methodology audit results 11 were documented in a report dated September 6th, 12 2011.

13 During the AMP audit, the team examined 14 the Applicant's aging management programs and 15 related documentation to verify that the 16 Applicant's programs are consistent with those 17 described in the GALL Report and with the plant 18 conditions and operating experience. The staff 19 reviewed the initial 40 AMPs and documented the 20 results in a report dated September 22nd, 2011.

21 In January of 2016, the Applicant 22 informed the staff of significant changes to the 23 Aluminum Bronze Selective Leaching AMP. These 24 changes redirected the staff's review such that the 25 topic-specific audits conducted in 2012 and 2015 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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87 1 were no longer applicable.

2 In 2016, the staff conducted an audit 3 of the Revised Aluminum Bronze Selective Leaching 4 AMP in two parts. During the week of March 21st, 5 the staff went onsite at STP and, then, a followup 6 day on June 22nd in the NEI offices in Rockville.

7 The audit focused on material 8 information, material process information, 9 microstructure information, and structural 10 integrity evaluations regarding the welds that may 11 be susceptible to selective leaching needed in 12 order for the staff to complete its review.

13 The results of the audit were 14 documented in a report dated August 30th. Region 15 IV will discuss the activities and results of the 16 71002 inspection in a few minutes.

17 Next slide, please. The staff 18 performed its review of the STP LRA and documented 19 its results in two Safety Evaluation Reports with 20 open items. In February of 2013, the staff issued 21 an SER with four open items. We did not come to an 22 ACRS meeting because the staff continued its review 23 of the selective leaching of the Aging Aluminum 24 Bronze AMP. We were uncertain about where the 25 review was going and we thought it was premature to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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88 1 come to the ACRS at that time.

2 As stated in 2016, the Applicant 3 informed the staff of significant changes to this 4 AMP. The staff was able to make progress in its 5 review and issued an updated SER with open items in 6 October. The Final SER will include the resolution 7 of the open item regarding the aluminum bronze 8 selective leaching.

9 Next slide, please. I will now direct 10 the presentation to Mr. Pick to discuss the 11 inspection activities associated with the license 12 renewal review.

13 Mr. Pick.

14 MR. PICK: Thank you, Lois.

15 Good morning, Members of the 16 Subcommittee.

17 CHAIRMAN SKILLMAN: Good morning, Greg.

18 We can hear you loudly and clearly.

19 MR. PICK: Thank you.

20 So, in our inspection we verified that 21 STP had properly identified those structures, 22 systems, and components included in scope and made 23 appropriate determinations of non-safety-related 24 systems and components affecting safety-related 25 components.

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89 1 STP had established adequate programs 2 to manage aging of in-scope structures systems and 3 components, as specified in our regulations and 4 their Applicant's license renewal program.

5 The five inspectors on the team had 6 experience and expertise related to mechanical 7 systems and components, electrical systems and 8 components, and structures. Bill Holston also 9 accompanied us for one week of this inspection.

10 During our two-week onsite inspection, 11 our review included five of eight new aging 12 management programs and 14 of 32 existing aging 13 management programs. We walked down numerous 14 structures, systems, components to assess the 15 adequacy of the Applicant's license renewal 16 boundaries, in conformance with their application 17 and the Generic Aging License Renewal Report.

18 These walkdowns enabled us to assess 19 and evaluate whether the existing aging management 20 programs would be successful at managing aging 21 effects for in-scope structure systems and 22 components.

23 Next slide, please. The results of our 24 inspection. We determined that the plan had good 25 material condition. They revised two procedures.

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90 1 They added susceptibility considerations when using 2 the online fact manager, and they developed 3 guidance in the structures monitoring program to 4 allow for noting changes and trending. This 5 included things such as taking measurements, 6 providing more detailed descriptions, and the use 7 of photographs.

8 They changed two aging management 9 programs as a result of the inspection. They 10 removed the fuel supply line evaluation as part of 11 the Fire Protection Aging Management Program, and 12 they initiated corrective action documents where 13 they will begin trending requirements added for the 14 type of test and accessible medium-voltage cables.

15 And the type of tests, for example, would be power 16 factor, partial discharge, time to remaining 17 reflective time, reflect time, trending each of 18 those types.

19 They changed five application 20 commitments and the related aging management 21 programs. They changed their sampling criteria for 22 selecting fire water piping to flow tests. They 23 will need a flow test 20 percent of the piping up 24 to a maximum of 25 components during their flow 25 testing. They will look at 20 percent or a maximum NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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91 1 of 25.

2 They are going to clarify selecting the 3 representative samples frequency inspection 4 requirements for the structures. They changed the 5 frequency for inside containment to five years, as 6 an example.

7 They are going to clarify the purpose 8 of the benchmark and the essential cooling water 9 structure. They have already done that.

10 They clarified their water control 11 structure monitoring requirements, and they updated 12 the requirements to inspect the interior of their 13 metal enclosed bus boxes. Instead of using 14 external thermography, they are going to look at 15 the internals.

16 Next slide, please. As a result of our 17 inspection, we concluded that the Applicant 18 performed the scoping and screening in accordance 19 with the rule. The information was easily 20 retrievable, auditable, and consistent with the 21 rule requirements.

22 From our reviews, we verified that 23 existing programs effectively managed the aging 24 effects. We verified that the Applicant tracked 25 the completion of enhancements and development of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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92 1 new programs and a database, as they have already 2 described.

3 Based on our inspection results, the 4 team had reasonable assurance that the programs in 5 place or planned, as described by their commitment 6 table, with manage the aging effects and ensure the 7 intended safety and function of systems, 8 structures, and components within the scope of the 9 rule.

10 Does anyone have any questions?

11 CHAIRMAN SKILLMAN: Greg, yes, I do. I 12 want to push back a little bit on the broadness of 13 your findings. I am referring to page 54 in the 14 PDF file of the SER. And here it is written, 15 "However, upon further review, subsequent to 16 submittal of the LRA, the Applicant determined that 17 the method used did not identify all non-safety 18 SSCs with the potential to impact the performance 19 of safety-related SSCs." This goes on to read, 20 "Following this determination, the Applicant 21 performed walkdowns of the applicable MAB and FHB 22 spaces and identified additional non-safety SSCs 23 with the potential to impact safety-related SSCs, 24 and provided this additional information to the 25 staff in response to RAI 2.1-3."

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93 1 Then, that paragraph concludes the 2 staff's concerns are resolved. What gives you 3 comfort that walking down the MAB and the FHB is 4 sufficient for thoroughness in this regard?

5 MR. PICK: When the team members walked 6 down the areas and did our reviews, what we saw 7 from using the drawings and looking at the safety-8 related components, the things that they said were 9 in scope were in scope. So, during our individual 10 samples, we did not identify anything that they had 11 not previously identified. So, that was the basis 12 of our statement on the sample we took.

13 CHAIRMAN SKILLMAN: Thank you. No 14 further question on that issue, Greg.

15 MR. PICK: Are there any other 16 questions?

17 MEMBER STETKAR: Yes, I had one. And I 18 think I understand, but I wasn't quite sure from 19 your oral presentation what they are doing 20 regarding the fire protection system. Are they 21 doing flow tests according to the -- I don't know 22 if they are NFPA requirements -- they are probably 23 NFPA requirements -- for flow testing.

24 MR. PICK: They do do the flow tests in 25 accordance with the NFPA.

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94 1 MEMBER STETKAR: Okay. Because you 2 mentioned --

3 MR. PICK: That is something we look at 4 during our triannual fire protection inspections.

5 MEMBER STETKAR: Okay. Good.

6 You did mention something about 20-7 percent sampling or 25 items. What's that? That 8 is not related to flow testing, though?

9 MR. PICK: No, no. I misspoke.

10 MEMBER STETKAR: Okay.

11 MR. PICK: In the report under fire 12 water system, they had identified they were going 13 to take 10 samples for volumetric examination to 14 see if there were any issues during their 15 enhancement for blockage. What they are really 16 going to do is take a 20-percent sample of the 17 piping or a maximum of 25 samples, because that is 18 what ends up statistically being the maximum they 19 would need to take of the fire water pipe 20 locations. And they are, again, going to base it 21 on location and pipe size.

22 MEMBER STETKAR: Okay. Thank you.

23 That helps clarify. Thank you.

24 CHAIRMAN SKILLMAN: Greg, this is Dick 25 Skillman. I have a question, a little different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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95 1 topic.

2 I'm reading from our Status Report that 3 "The staff determined that the Applicant has a 4 quality Class QC4 that was not addressed in the 5 application." What can you tell us about QC4 and 6 its applicability to our deliberations today, 7 please?

8 MR. PICK: I have no knowledge of that 9 classification and I would have to defer that to 10 the licensee.

11 MS. JAMES: Actually, we have Billy 12 Rogers coming up to the microphone to answer your 13 question.

14 CHAIRMAN SKILLMAN: Thank you.

15 MR. PICK: Thank you, Lois.

16 MR. ROGERS: Good morning. This is 17 Bill Rogers from the staff.

18 So, we looked at that when we were 19 doing the scope-instituting methodology audit.

20 Many applicants have a variety of classifications 21 for components and systems onsite. And if there 22 are multiple quality classifications that might be 23 applicable to the determination of safety-related, 24 we will review those during the audit.

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96 1 classification, QC4, that it wasn't clear how that 2 related to the determination of safety-related as 3 it would be applied in the implementation of the 4 rule. So, we discussed that.

5 And the answer that was provided to us 6 during discussion and, then, in the followup RAI 7 was QC4 could actually refer to both non-safety-8 related and safety-related components. So, the 9 Applicant had reviewed all of the QC4 components 10 and determined those which are identified, those 11 which were safety-related, and include them within 12 the scope of license renewal for A1, identified 13 those which were non-safety-related, and they would 14 have been included only if they were in scope for 15 A2, non-safety affecting safety; otherwise, they 16 would have been excluded. And we determined that 17 as an acceptable response and it resolved the 18 question.

19 CHAIRMAN SKILLMAN: Thank you. Thank 20 you.

21 Please proceed.

22 DR. SCHULTZ: I have one general 23 question, Dick. I would like to ask the question, 24 as one reads through the Inspection Report -- and 25 this is to be expected -- but, as we look at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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97 1 license renewal and aging management, as you did 2 the inspection, you had the opportunity or the 3 need, of course, to look at the corrective action 4 program, the program health reports, surveillances, 5 as you did your investigations.

6 As you reflect on those programs, 7 corrective action, program health, and 8 surveillance, that are maintained by the sites, did 9 you have any issues or particular concerns related 10 to any of those programs in general?

11 MR. PICK: During our inspection we did 12 not. I also do fire protection inspections and 13 cybersecurity inspections. When we do our baseline 14 inspections, we also take corrective action program 15 samples. We do look at surveillances, and during 16 those programs we have found that the licensee does 17 follow their tech specs, technical requirements 18 manual, do proper surveillances. And when they 19 find things wrong, they enter them into their 20 corrective action program and they resolve them.

21 DR. SCHULTZ: Did you find the 22 resolution and process that they used to be robust?

23 MR. PICK: We do.

24 DR. SCHULTZ: Thank you.

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98 1 turn it back over to Lois?

2 CHAIRMAN SKILLMAN: Colleagues, any 3 more for our inspector? Colleagues, any more for 4 the inspector?

5 (No response.)

6 Hearing none, Lois, please proceed.

7 Thank you, Greg.

8 MR. PICK: Thank you.

9 MS. JAMES: Thank you, Greg.

10 In the next few slides I will be 11 presenting the results as described in the SER with 12 open items. SER Section 2 described the scoping 13 and screening of structures and components subject 14 to the aging management review. The staff reviewed 15 the Applicant's scoping and screening methodology 16 procedures, quality controls applicable to the LRA 17 development, and training of its personnel.

18 The staff also reviewed the various 19 summaries of the safety-related systems, 20 structures, and components, non-safety-related 21 systems, structures, and components affecting 22 safety-related functions, and systems, structures, 23 and components relied upon to perform functions in 24 compliance with the Commission's regulations for 25 fire protection, environmental qualification, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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99 1 station blackout, pressurized thermal shock, and 2 anticipated transients without a scram.

3 Based on their review, the results of 4 the scoping and screening audit, and additional 5 information provided, the staff concludes that the 6 Applicant's scoping and screening methodology is 7 consistent with the standard review plan and the 8 requirements of 10 CFR Part 54.

9 Next slide. SER Section 3 covers the 10 staff's review of the Applicant's AMPs. For a 11 given aging management review, the staff evaluated 12 the item to determine whether it is consistent with 13 the GALL Report and meets the requirements of 10 14 CFR Part 54. Section 3.1 through 3.6 include the 15 aging management review items in each of the 16 general system areas within the scope of license 17 renewal. If an aging management review was not 18 consistent with the GALL Report, then the staff 19 reviewed the Applicant's evaluation to determine 20 whether the Applicant demonstrated that the aging 21 effects will be adequately managed, so that the 22 intended functions will be maintained consistent 23 with the current licensing basis for the period of 24 extended operation.

25 Next slide, please. The LRA identified NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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100 1 40 AMPs, and the Applicant subsequently added an 2 existing program in response to License Renewal 3 Interim Staff Guidance ISG-2013-01, aging 4 management of loss of coating or lining integrity 5 for internal coatings/linings or on in-scope 6 piping, piping components, heat exchangers, and 7 tanks issued in November of 2014.

8 The left side of the slide identifies 9 the Applicant's original disposition of the AMPs, 10 and the right side identifies the staff review of 11 the AMPs, as documented in the SER with open items.

12 All AMPs were evaluated by the staff for 13 consistency with the GALL Report.

14 Next slide, please. The staff closed 15 two open items associated with the aging management 16 review from the 2013 SER with open items under the 17 review of the aging management program.

18 The first open item. In reviewing the 19 open-cycle cooling water system AMP, the staff 20 found that the LRA did not describe the protective 21 coatings used in the essential cooling water 22 system, nor discuss site-specific operating 23 experience which would provide objective evidence 24 supporting the conclusion that the effects of aging 25 will be adequately managed during the period of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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101 1 extended operation.

2 Between February and November of 2012, 3 the staff issued Requests for Additional 4 Information, or RAIs, on these topics and 5 documented an open item in the 2013 SER with open 6 items. Subsequently, in November of 2014, the 7 staff issued ISG-2013-01 which encompassed these 8 issues.

9 After reviewing the RAI responses and 10 changes in response to the ISG, the staff 11 determined that the open cycle cooling water system 12 AMP is consistent with the GALL Report and meets 13 the requirements of 10 CFR Part 54.

14 For the second open item, in reviewing 15 the one-time inspection AMP, the staff questioned 16 why the Applicant did not have an AMP to detect and 17 address cracking on the interior surfaces of the 18 RWST or other similar stainless steel tanks. If an 19 AMP is not necessary, the Applicant needed to state 20 the basis for why such an AMP was not necessary.

21 In response to RAIs, STP detailed its 22 activities to characterize the cracking on the Unit 23 1 RWST and its proposed methods to manage the aging 24 effects with both one-time and periodic 25 inspections. Based on the staff's review of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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102 1 Applicant's response, the concerns regarding the 2 cracking in the Unit 1 RWST were resolved and the 3 corresponding open item is closed.

4 DR. SCHULTZ: Lois, did you have an 5 expectation that that might be extended to other 6 tanks?

7 MS. JAMES: Yes, the program extends to 8 other stainless steel tanks.

9 DR. SCHULTZ: But the focus here was 10 just for the RWST?

11 MS. JAMES: Well, the question rose 12 from operating experience regarding the RWST. So, 13 that is where the question started.

14 DR. SCHULTZ: All right. But, in terms 15 of the AMP program going forward, they are going to 16 be --

17 MS. JAMES: Considering it --

18 DR. SCHULTZ: -- applying it to all 19 tanks?

20 MS. JAMES: Yes. Yes, sir.

21 DR. SCHULTZ: Thank you.

22 CHAIRMAN SKILLMAN: Lois, thank you.

23 Before you leave this section on open 24 items closed -- thank you, John -- before you leave 25 this slide on open items closed, there is another NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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103 1 open item that has been closed. It is open item 2 4.3.2.11-1, the Effects of Thermal Aging on Cast 3 Austenitic Stainless Steel.

4 MS. JAMES: Yes, sir.

5 CHAIRMAN SKILLMAN: And written in the 6 documentation is this statement: "Use of minimum 7 material properties do not provide adequate 8 protection in light of information from the past 29 9 years." This item was then closed. Would you 10 please provide an explanation of how this 11 determination was made that this open item can be 12 closed?

13 MS. JAMES: Can I defer that to Section 14 4?

15 CHAIRMAN SKILLMAN: Sure.

16 MS. JAMES: I will actually address 17 that on slide 17.

18 CHAIRMAN SKILLMAN: Yes, that will be 19 fine. Thank you, Lois. Please proceed.

20 MS. JAMES: Okay. I will now turn the 21 presentation over to Mr. Holston, who will address 22 the open item, the aluminum bronze open item.

23 MR. HOLSTON: So, the aluminum bronze 24 open item, as you heard the Applicant discussing, 25 initially, the aluminum bronze program was focused NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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104 1 on about 450 cast components that were susceptible 2 to selective leaching. And in January of last 3 year, they came in and said, well, we are going to 4 replace all of those castings because we had 5 questions related to what is the real strength of 6 the component when you de-alloy part of it. When 7 you saw the picture that they showed on the slide 8 with that little area of external de-alloying or 9 the indication you could see, well, how do you 10 really project what is going on inside the pipe to 11 do your operability evaluations?

12 So, those are all being replaced.

13 That, however, left, as was discussed, about 3300 14 welds. Of course, that number will be lower when 15 castings are cut out and replaced, so you are still 16 talking about 2,000 welds, somewhere in that 17 ballpark, that are susceptible to selective 18 leaching.

19 As a result of our review of the 20 changes to the program, you heard we had about a 21 10-part open item, of which nine of those were 22 closed by a submittal that changed the program. It 23 came in in September of 2016. So, I am going to 24 focus that point forward on this.

25 So, one of the key aspects that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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105 1 Applicant was looking at is they had not had any 2 leaks due to selective leaching in these welds, 3 these susceptible welds, since 1994. So, they did 4 some metallurgical testing. They did some 5 calculations on cooldown rates on welds and all 6 sorts of things, and then, came to postulate that 7 the root pass is less susceptible, and it is less 8 susceptible because the dilution, the higher rate 9 of dilution that occurs in the root pass and the 10 cooldown rate being higher than in subsequent 11 passes.

12 So, in effect, what would happen is 13 they have reduced the susceptibility of the overall 14 weld to selective leaching of this aluminum bronze 15 because the root pass acts as a barrier. I mean, 16 you can almost kind of think of it as, well, it is 17 kind of like a coating and it is isolating the more 18 susceptible passes of the weld from the 19 environment. If you isolate it from the 20 environment, you are not going to have selective 21 leaching occur.

22 And some, that is dependent upon not 23 having a construction-related or an in-service flaw 24 that penetrates through the root pass and, then, 25 unless you can get the environment in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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106 1 subsequent passes that are most likely more 2 susceptible. That is where it is postulated they 3 had the through-wall de-alloying up to 1994, was in 4 welds that had, you know, construction-related 5 flaws.

6 So, as the staff and Lois talked about 7 audits we did on site, technical data we reviewed, 8 testing results we reviewed, the root pass as a 9 barrier seemed very plausible to us. However, 10 there wasn't enough testing done. The Applicant 11 had cross-sectioned, you know, about six welds.

12 That was leaning in that direction, that that was 13 plausible. So, we proceeded from that point.

14 So, we can go to the next slide, slide 15 No. 13. I just want to talk about a couple of the 16 conclusions we derived from not only looking at the 17 Applicant's results of their destructive 18 examinations, but also in a lot of review of the 19 technical literature that is available.

20 The de-alloying process occurs at a 21 microstructure level, and it is confined for a 22 localized front at scales with a grain size. Those 23 are some really cool words, right, and he is a 24 metallurgist, but what does it really say to you?

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107 1 of these welds or any material that is susceptible, 2 you basically have a front of de-alloying that goes 3 through. On one side of that front it is 100-4 percent de-alloyed; on the other side of the front 5 it is not de-alloyed. Now, of course, if you can 6 keep exposing the environment as you pass through 7 those grains, those are going to become de-alloyed 8 eventually. However, that is what it is.

9 So, the material on either side of that 10 front that goes through the material is either in 11 its as-received material properties or it is in 12 fully de-alloyed material properties. We concluded 13 from the data that the Applicant had constructed on 14 testing of material properties for the de-alloyed 15 material within the bulk component that there was 16 insufficient data to bound the mechanical 17 properties.

18 We are very fortunate to have a person 19 on staff, Chris Sevanick, who was involved in the 20 Navy Air Program, had actually been involved in 21 developing material properties from testing, and, 22 basically, had to go through all that data.

23 So, based on the number, the size of 24 the population of tests they had, and based upon 25 some of the scatter within those results, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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108 1 basically came to a conclusion that you would not 2 give any credit or there would be no strength 3 credit, in other words, no tensile value, for de-4 alloyed properties or fracture toughness credit.

5 Now the Applicant throughout, even back 6 in the eighties when they did their operability 7 evaluations and they did their calculations, never 8 credited any material properties for the de-alloyed 9 portions, right? And so, that is nothing new or 10 big, but it is important when we talk later about 11 structural integrity.

12 Next slide. So, given what we knew and 13 what the Applicant changed in the programs, I 14 wanted to highlight some of the key features of the 15 program that lead us to a conclusion that we are 16 down to just one last open item. And some of those 17 you have heard already.

18 But in the detection of aging effects 19 program element, the Applicant is going to do 20 volumetric inspections. These volumetric 21 inspections will look to see if there is weld 22 defects, weld defects that could be progressing 23 through the root pass, right? So, these are not 24 ultrasonic exams that are going to measure how much 25 de-alloying is going on. We are going to talk NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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109 1 about that maybe in a little bit, just as an 2 overview.

3 But those volumetric examinations will 4 provide information that, in fact, based upon a 5 representative sample, we aren't seeing, we haven't 6 seen from the last time they did these volumetric 7 examinations during the plant construction, that 8 there aren't weld defects that are propagating 9 through the root pass.

10 They are going to do destructive 11 examinations in addition. And in doing this, you 12 heard a lot about 25, 20 percent. Twenty percent 13 is immaterial in this case, right, because it is 14 25. So, there is going to be 25 volumetric 15 inspections for the welds with backing rings and 16 welds without. There is going to be 25 destructive 17 examinations of welds with backing rings and welds 18 without. So, in effect, we are going to see 50 19 welds cross-sectioned.

20 There will be continuing inspections 21 for leakage. How the licensee has been managing 22 this selective leaching since the days that it 23 started occurring is every six months they do a 24 walkdown of all the above-ground piping.

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110 1 picture they showed you is very characteristic of 2 what you see if you see selective leaching. I 3 actually did a walkdown with one of the Applicant 4 staff members, and there was a fitting, you know, a 5 much smaller fitting. It was about a 3-inch 6 fitting that showed that little fluorescent break 7 there.

8 Then, in addition, they look at yard 9 areas to detect if there is moisture that is 10 unusual that shouldn't be there. That would seem 11 odd. How do you that? Well, we explored that with 12 the Applicant. We looked at detailed calculations 13 that demonstrated that, if you have a 10-gallon 14 permatted leak, it will get to the surface within 15 30 days. And they have a huge margin there. They 16 have about a margin of 1,000 gallons, I mean that 17 they can tolerate.

18 I am not a hydrology expert. I looked 19 at the calculations. So, fortunately, the New 20 Reactors Organization, they had a hydrology expert.

21 He reviewed those calculations and felt that they 22 were well-bounded and well-founded. So, albeit, 23 you can't look for leakage on the outside surface 24 of the components that are buried, we can observe 25 for an indirect effect and be convinced that there NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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111 1 is no leakage going on that would affect the 2 intended function.

3 Of course, when they do opportunistic 4 buried pipe inspections, they will actually go in 5 and look at the coatings for those pipes. All this 6 piping is coated that is buried. Of course, that 7 isolates the susceptible weld layers, you know, the 8 crown pass from the environment.

9 So, that is basically what is going to 10 go on with detection of aging effects. Basically, 11 at the end of that, having done the volumetric 12 examinations to show that, yes, after that 13 representative sample, we don't see any defects 14 that are challenging the root pass, and we will 15 have 50 examinations that will actually not only 16 look at is there de-alloying going on, but it will 17 look at the phase, the actual phases within that 18 cross-section that will be sufficient to 19 demonstrate that the theory, which we think is 20 true, is that root pass is more resistant to de-21 alloying and protects the other layers of the weld.

22 And that is one reason why they haven't had any 23 leaks since 1994.

24 Yes, sir?

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112 1 presence of a backing bar affect this protection --

2 MR. HOLSTON: Well, the backing ring 3 does two things. It does one good thing and it 4 does one bad thing. There are two effects that 5 contribute to whether the welds are going to be 6 susceptible.

7 One is, with the dilution, with 8 diluting the welds, you have a lower concentration 9 of aluminum, which with the samples they have taken 10 they have demonstrated it. They can show a 11 difference across the passes as you go.

12 The other thing is the backing ring 13 allows you to have a greater heat sink, which cools 14 it down quicker. If you cool it down quicker, you 15 don't get the gamma-2 or the beta phase that are 16 susceptible to selective leaching aluminum bronze.

17 The downside of having a backing ring 18 is that it gives you kind of a notch. It gives you 19 a localized place where it can concentrate and 20 adverse chemistry that can cause a selective 21 leaching. So, that is why the Applicant 22 identified, you know, we have got a backing ring 23 population. We are going to do 25 of those. We 24 have got a non-backing-ring population. We are 25 going to do 25 of those.

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113 1 MEMBER RICCARDELLA: Okay.

2 MR. HOLSTON: So, any other questions 3 on detection of aging effects?

4 DR. SCHULTZ: Bill --

5 MR. HOLSTON: Yes?

6 DR. SCHULTZ: -- one more question. We 7 have kind of bounced back and forth between a 8 representative sample and 25.

9 MR. HOLSTON: Uh-hum.

10 DR. SCHULTZ: With regard to the 11 destructive examinations, what are the staff's 12 expectations if, when those are done, issues arise 13 as a result of the investigation? I mean, you 14 could hypothesize you do the destructive 15 examinations and you find issues.

16 MR. HOLSTON: Correct.

17 DR. SCHULTZ: What are the staff's 18 expectations of what will be done if in examining 19 25 and 25 that there are problems identified?

20 MR. HOLSTON: Can I defer that just to 21 the next slide?

22 DR. SCHULTZ: Sure.

23 MR. HOLSTON: Because I am going to 24 address that within corrective actions.

25 DR. SCHULTZ: Thank you.

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114 1 MR. HOLSTON: So, yes, I will go 2 through acceptance criteria and, then, get to that 3 and I will answer your question I think directly.

4 Any other questions on detection, how 5 they are going to detect these aging effects?

6 MEMBER SUNSERI: Yes. With regard to 7 the underground pipe and just looking for moisture, 8 or what have you, to reach the surface, was there 9 any consideration of using other techniques such as 10 ground-penetrating radar or something like that to 11 get on top of the leaks faster?

12 MR. HOLSTON: The simple answer to the 13 question is no, because there is a huge -- but the 14 answer to why is that there is a very large margin.

15 They can detect a 10-gallon-per-minute leak. They 16 can tolerate 1,000 gallons per minute. Now, 17 clearly, if they had a 1,000 gallons a minute, that 18 is going to be washing out soil. It could affect 19 structural integrity evaluations. But selective 20 leaching is not a rapidly-propagating phenomenon.

21 You know, you are not going to go from 10 gallons a 22 minute one day and now, suddenly, you are at 500 a 23 month later, right? It is just not going to 24 happen. So, that is why we didn't --

25 MEMBER SUNSERI: Yes. Thank you.

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115 1 MEMBER STETKAR: Bill, should I ask you 2 about the buried and underground piping program now 3 or should I ask you about it at all?

4 MR. HOLSTON: Well, you can ask me.

5 MEMBER STETKAR: Okay.

6 MR. HOLSTON: And why don't you go 7 ahead?

8 MEMBER STETKAR: Okay.

9 MR. HOLSTON: We might have Brian Allik 10 answer some of that. Brian Allik is taking some of 11 that over.

12 MEMBER STETKAR: Yes. Well, let me get 13 to where I was headed.

14 MR. HOLSTON: Sure.

15 MEMBER STETKAR: We heard earlier that 16 the license renewal application checked off a box 17 that said the cathodic protection system is not in 18 scope for license renewal. So, does that mean that 19 in their buried and underground piping inspection 20 program they are applying the -- I don't know 21 whether it is Category E or Category F of their 22 inspections. In other words, not taking credit at 23 all for cathodic protection? Or what are they 24 doing?

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116 1 that. What it means is, when we say the cathodic 2 protection system is not within the scope, it is 3 the wires; it is the panels; it is the rectifiers 4 that aren't in scope.

5 So, what we did was we built into Aging 6 Management Program 41 for buried and underground 7 piping the measurement of the cathodic protection 8 from two perspectives. And that is what drives you 9 to those additional inspections in Category E and 10 F, as you mentioned.

11 MEMBER STETKAR: Yes.

12 MR. HOLSTON: So, the Applicant has to 13 measure the amount of time the current is turned 14 on. Somebody trips a breaker open for something 15 and it has been off for two months, that is going 16 to be a problem, right? Because if you don't pull 17 the electricity, you are not going to get the 18 cathodic protection. So, there is a criteria for 19 that, and that is 85 percent of the time it has to 20 be on.

21 We also have a criteria, then, for the 22 effectiveness of it. And that is measured by the 23 annual cathodic protection surveys. You have to 24 demonstrate that you have negative 850 millivolts.

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117 1 in higher resistivity soils -- that is negative 750 2 or negative 650. We also allow for actually direct 3 measurement of corrosion rates. But, if you can't 4 demonstrate that you are meeting that level of 5 protection, then you have to go to E or F --

6 MEMBER STETKAR: Right.

7 MR. HOLSTON: -- and do the additional 8 inspections.

9 And what demarcates between E and F is, 10 if your plant-specific operating experience is good 11 and meets the criteria in the AMP, then your 12 cathodic protection is upright, up-to-speed, you do 13 E, which is three every 10 years. But, if you also 14 have bad operating experience, then you have got to 15 go to six every 10 years.

16 MEMBER STETKAR: Right. So, I think 17 what I hear you saying is that they will -- I 18 always hate to say "take credit" -- but they will 19 take credit for cathodic protection with all of 20 those caveats in determining the frequency and 21 extent of their piping inspections?

22 MR. HOLSTON: Right. Because, in 23 effect, what we are doing is, rather than going to 24 the panel and seeing if it is leaking --

25 MEMBER STETKAR: No, no.

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118 1 MR. HOLSTON: -- rather than checking 2 the wires, we performance monitor the effects of 3 the cathodic protection system with the 4 availability and the effectiveness.

5 MEMBER STETKAR: Yes. Thank you. That 6 helps.

7 MR. HOLSTON: Any other questions on 8 detection of aging effects?

9 (No response.)

10 Okay. For the acceptance criteria, 11 what they will do when they do the volumetric exams 12 is, obviously, they are looking for any plane or 13 flaw that would exceed 80 percent of the root pass 14 if it is connected -- you know, you could have a 15 plane or flaw within. So, here's your water. And 16 so, your inside diameter of your pipe, and you have 17 your pipe, you know, your outer edge of your root 18 pass. If it is up here, we are not really worried 19 about it. We are here with an environment 20 connected plane or flaw.

21 And with the destructive examinations, 22 the microstructure of the root region, we are 23 looking to see that we are reasonably certain they 24 are going to see some gamma-2 in the welds, right?

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119 1 want to see that that is surrounded by the alpha 2 phase which is not susceptible to selective 3 leaching. And if the gamma-2 or the beta phase 4 would exceed 80 percent of the depth of that root 5 pass, then we have an issue. And so, that is the 6 microstructure monitoring.

7 And I did have a typo -- I apologize 8 for that -- in the third acceptance criteria, which 9 is the walkdowns every six months. They will go to 10 monthlies if they have some other problems, but 11 those are just they are looking for leakage, is 12 what the acceptance criteria is for that.

13 CHAIRMAN SKILLMAN: Bill, has the 14 Applicant ever discovered a geyser? Have they ever 15 seen a leak great enough to really push water out 16 of the soil?

17 MR. HOLSTON: I looked at their 18 operating experience when I did the buried pipe 19 audit and saw none, no, sir.

20 CHAIRMAN SKILLMAN: Okay. Thank you.

21 MR. HOLSTON: Any questions on 22 acceptance criteria?

23 (No response.)

24 Okay. Next slide, and this gets to the 25 corrective actions I was talking about before that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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120 1 Mr. Schultz was asking about.

2 So, if they find a problem within the 3 volumetrics for weld defects that are penetrating 4 the root pass, they have to do five additional 5 volumetric examinations until they see none. And 6 for the destructive examinations, the criteria is 7 the same. It is, if you see that phased 8 distribution not what we would expect, not 9 supportive of what the theory is, then you have to 10 keep doing five more until you don't see that 11 anymore. The five comes from Generic Letter 12 90-05, which the Applicant commented upon. It is 13 the NRC staff basic position when you find 14 something that is adverse that you look more until 15 you find the issue.

16 Does that answer your question?

17 DR. SCHULTZ: Yes. Thank you.

18 MR. HOLSTON: Okay. Now another 19 aspect, though, which is structural integrity 20 calculations conducted with the as-found 21 conditions, so, then, the question is, well, what 22 is a corrective action if you find an issue with 23 structural integrity?

24 So, the staff is concerned with that 25 because, if you find an issue with structural NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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121 1 integrity, you have an issue with the intended 2 function of the system. And so, that is where we 3 are right now with the Request for Additional 4 Information.

5 The licensee has worked with EPRI and 6 done some testing of a UT volumetric method that 7 should be able to actually take the weld and 8 measure the amount of de-alloying that is going 9 inside, from the inside, from the ID to the OD.

10 So, what you could picture, if you are 11 looking at a ring, is here it is penetrating 60 12 percent. That would be bad, right, because it is 13 through the root pass? But, over here, it is just 14 penetrating 10 percent, and there is none down 15 here. And it just is based upon reasonable theory.

16 We were aware of Vermont Yankee doing 17 the cast iron piping. We just hadn't been aware of 18 anybody doing it for aluminum bronze welding or 19 fittings.

20 And so, our RAI talks about, well, tell 21 us how you are going to demonstrate the method, how 22 you are going to quality people, what the 23 resolution of that process is, and several other 24 questions on sampling size and all of that. So, 25 that is the remaining open item, is, what are you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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122 1 going to do for corrective actions if the 2 structural integrity evaluation isn't acceptable?

3 CHAIRMAN SKILLMAN: Bill, as a matter 4 of admin as we look into the new year, is it these 5 RAIs that will not be presented until after March?

6 MR. HOLSTON: I don't -- well --

7 MS. JAMES: We have not issued the RAI 8 yet. So, we have to issue it. They have to have 9 their 30 days to respond and, then, we need at 10 least 30 days to look at what their response is.

11 And in this instance, we have to get 12 another division involved. So, we wanted to give 13 ourselves a little extra time to review what comes 14 in, which is why we are discussing delaying the 15 full Committee from February.

16 CHAIRMAN SKILLMAN: Thank you. I 17 understand.

18 MR. HOLSTON: The RAI has been peer-19 reviewed.

20 CHAIRMAN SKILLMAN: Okay.

21 MR. HOLSTON: It has been approved by 22 management, but we have to get it out.

23 CHAIRMAN SKILLMAN: Thank you for the 24 explanation. We were trying to get clear on timing 25 and the workload for the Committee. And this gives NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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123 1 us an explanation of what is happening. Thank you.

2 Please proceed.

3 Go ahead, John.

4 MEMBER STETKAR: I was going to say, do 5 you have more on this?

6 MR. HOLSTON: No, no, that is the end 7 of my presentation. If you have any questions --

8 MEMBER STETKAR: Let me go back to the, 9 for lack of a better term, risk-informed sampling 10 process. Is the staff good with taking a random 11 sample, you know, throwing a random number 12 generator in and taking a random sample of any 25 13 of the 3300, I think I wrote down here?

14 MR. HOLSTON: Yes, we are thinking 15 there is about 2,000. Once you cut out the 400-16 some-odd fittings --

17 MEMBER STETKAR: All right. I don't 18 want to get down too much.

19 (Laughter.)

20 MR. HOLSTON: It is a little bit less.

21 MEMBER STETKAR: But 25 out of a large 22 number --

23 MR. HOLSTON: Right.

24 MEMBER STETKAR: -- randomly 25 selected --

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124 1 MR. HOLSTON: What we did was Matt 2 Homiack, who is back here in the room, he is in 3 Research now, did some calculations, finite element 4 heat transfer calculations to determine how 5 sensitive that is. And he is coming up to the 6 microphone, and I would like to give him credit for 7 the great work he did in that regard. I think he 8 is going to have some positive answers for you.

9 MR. HOMIACK: Thank you, Bill.

10 So, the Office of Nuclear Regulatory 11 Research has been supporting NRR --

12 CHAIRMAN SKILLMAN: Excuse me, sir.

13 Identify yourself, please.

14 MR. HOMIACK: Matthew Homiack from the 15 Office of Research.

16 CHAIRMAN SKILLMAN: And, Matt, make 17 sure you speak up in the microphone, so we can 18 hear.

19 MR. HOMIACK: Will do. Thank you. Is 20 this okay?

21 CHAIRMAN SKILLMAN: Yes.

22 MR. HOMIACK: So, there is actually two 23 -- it is a smart sample. There is two sample 24 populations, first of all. One, welds with backing 25 rings and one of welds without. And I believe, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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125 1 Bill, each will get 25 destructive examinations.

2 And so, the reason for looking at those 3 differently is the welds with the backing rings 4 have the operating experience, and the welds 5 without the backing rings are more susceptible root 6 pass to de-alloying because they have a quicker 7 cooldown rate.

8 The Applicant has done some cooling 9 rate analyses, which the staff has done some 10 independent confirmatory calculations as well, and 11 we think their cooldown rates are conservative.

12 MR. HOLSTON: And Matt, in his 13 calculations, varied heat inputs, the exact 14 question you were asking. Because one of the 15 concerns we had was not so much some variation from 16 welder to welder, but if you are hanging upside-17 down and trying to make that weld versus doing a 18 flat weld, doing a vertical weld, you know, as 19 well-controlled as weld procedures are, it is a 20 little tougher to make some of those welds. And 21 would they have a higher heat input or something?

22 But the calculation, it is not really 23 -- the cooldown rate is not very sensitive to a 24 reasonable range of expectations of heat input from 25 the weld. So, the random sample is reasonable.

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126 1 Now the AMP does say, the aging management say that 2 they will take into effect construction-related 3 factors.

4 MEMBER POWERS: If I just assume that 5 they have a random population --

6 MR. HOLSTON: I'm sorry, I couldn't 7 hear you. What?

8 MEMBER POWERS: If I assume that I have 9 a random population, in other words, defects are a 10 random sort of thing, which may not be true, but 11 close enough for argument's sake, and I look after 12 three refueling inspections. So, I have a sample 13 of 75. I would probably have a 95-percent chance 14 that I have covered 90 percent of the range of 15 things.

16 So, while the number looks small, it is 17 pretty powerful if you don't have systematic 18 effects. And that, coupled with your walkdown to 19 identify systematic vulnerabilities, it appears to 20 me, though, it is 25 of a large number, the fact is 21 random sampling is a pretty powerful technique for 22 identifying outliers in that range.

23 MEMBER STETKAR: Well, except for how 24 frequently do they do this destructive examination 25 sampling.

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127 1 MR. HOLSTON: Well, if they are going 2 to do the destructive examinations, it is a one-3 time destructive examination. Because you want to 4 demonstrate with adequate data that that root pass 5 is less susceptible.

6 MEMBER STETKAR: So, the sample is not 7 after three refuelings. It is a one-time. It is 8 25. So, you have a little lower confidence.

9 MEMBER POWERS: Yes, it is a fairly 10 sharp function --

11 MEMBER STETKAR: Yes.

12 MEMBER POWERS: -- that moves up 13 rapidly.

14 MR. HOLSTON: The actual numbers are 15 that the 25 is a 90/90 certainty. That is the 16 number. So, where we have adopted that throughout 17 the GALL Report and several aging management 18 programs is, where you are demonstrating that an 19 aging effect is not likely to cause a loss of 20 intended function, we use 90/90.

21 Now, for example, when talking about 22 structural integrity, there is a challenge to 23 structural integrity, the certainty needs to be 24 higher. So, for these welds that we are doing 25 where we have seen some cross-sections, right, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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128 1 about six welds that they cross-sectioned that 2 support the theory, we want to have enough to say 3 that that is reasonable, that they are not going to 4 de-alloy through the root pass, go into the higher 5 susceptible weld passes, and then, de-alloy 6 through-wall. And so, that is why we are very 7 comfortable with the 25 and the random at this 8 point. But the RAI addresses what happens if you 9 see more consequential results --

10 MEMBER STETKAR: Yes, I didn't read the 11 RAI.

12 MR. HOLSTON: Yes. Yes, we haven't 13 given that to you yet. It is not published yet.

14 MS. JAMES: It is not publicly-15 available yet. So, it will be public and it will 16 issue in the next week or so.

17 MEMBER BALLINGER: So I have it clear 18 in my head, the weld heat input and all of that 19 stuff for the various sizes of welds, it is not 20 that much different welds. So that there is not 21 likely that there will be a distinction, there 22 would be a distinction between small diameter or 23 large diameter. That is not going to be an issue 24 that unrandomizes things, if you will?

25 MR. HOLSTON: That is correct, yes.

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129 1 MEMBER BALLINGER: Okay.

2 MR. HOLSTON: And again, we didn't just 3 -- because, well, suppose in the audience that his 4 company did some of the finite element calculations 5 for the cooldown, and we didn't just take that at 6 face value. Matt Homiack did his own independent 7 evaluations to that effect.

8 MEMBER BALLINGER: Okay. Some of us 9 remember, well, it only happens to small diameter 10 pipes. And then, well, it only happens to slightly 11 larger diameter pipes. And then, yes --

12 MEMBER RICCARDELLA: Bill, as you know, 13 the other side of risk-informing this type of a 14 selection is to look at consequences. Is there any 15 ability to distinguish from different piping 16 locations based on the consequences of failure?

17 And what are we looking at? I mean, are we looking 18 at an actual rupture that we are concerned about or 19 just a leak?

20 MR. HISER: Okay, so two parts to that.

21 We are sampling to try to demonstrate that all of 22 the 2,000 welds are okay. Are there welds that 23 would have a higher consequent? Absolutely.

24 Right, because there are welds in the main header.

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130 1 for diesel, and those would be more. There are 2 welds that are downstream of the coolers. It has 3 already done its function as long as it doesn't 4 flood the room. All it is doing is going to the 5 bay, or not the bay, to the pond, right?

6 So, we didn't factor in in any 7 selection the consequential because we are 8 confident, based upon what we have seen with the 9 testing results, also with what Matt has done with 10 the backup analyses, that what you see in a weld 11 here that is a very critical weld would be the same 12 thing because the environment is the same here; the 13 weld processes are the same, and the sensitivity to 14 the amount of heat put in with the weld is 15 virtually, you know, it doesn't really affect the 16 potential for additional beta or gamma-2. So, we 17 didn't say, make sure you do all your sampling of 18 your welds upstream or in the main header, or 19 anything like that.

20 MR. HOLSTON: Well, the consequence, 21 yes. Yes, as Allen is saying, the consequence 22 issue gets into whether what you see affects 23 structural integrity. And so, that is where we 24 have a four-page RAI to address what -- you know, 25 that is why the corrective actions for structural NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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131 1 integrity is still an open item. You know, we are 2 hopeful that this volumetric technique will be 3 something that we can accept it. Of course, with 4 the volumetric technique of that nature, they could 5 look at a lot of welds. They could zero into the 6 more consequential welds in that case. Because, to 7 date, of all the casting failures, castings are a 8 lot more susceptible than the welds are, and on the 9 weld failure side, they have not had one that 10 failed structural integrity criteria.

11 MEMBER RICCARDELLA: Question. You 12 know, when you say "structural integrity criteria,"

13 you say, well, the stresses are higher than the 14 allowable stress, or something like that. But is 15 there any concern at all about a rupture of one of 16 these or are we mainly just concerned about a leak?

17 MR. HOLSTON: Because of the very low 18 operating pressure at very low operating 19 temperatures, we are not too concerned. And they 20 have very low seismic loads, too. We looked at 21 their seismic analyses. There is nothing huge 22 there.

23 We would be more concerned with a leak 24 than we would be -- but they have done a lot of 25 analyses on the leak rates, the allowable leak NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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132 1 rates versus detectability of those leaks. And we 2 have reviewed all of that, and that is all 3 documented, that we feel they have the 4 detectability to see it before it could approach to 5 a leak that would starve the heat exchanger, or 6 whatever.

7 MEMBER RICCARDELLA: Thank you.

8 CHAIRMAN SKILLMAN: Let's proceed, 9 please.

10 Bill, thank you.

11 MR. HOLSTON: Yes, sir.

12 MS. JAMES: Okay. We are now on slide 13 16. SER Section 4 identifies the time-limited 14 aging analysis, or TLAAs. Section 4.1 documents 15 the staff's evaluation of the Applicant's basis for 16 identifying plant-specific or generic analysis that 17 need to be identified as TLAAs and determine that 18 the Applicant has provided an accurate list, as 19 required by 10 CFR 54.21(c)(1).

20 Sections 4.2 through 4.7 document the 21 staff's review of the applicable STP TLAAs as 22 shown. Based on its review and the information 23 provided by the Applicant, the staff concludes that 24 the TLAAs will remain valid for the period of 25 extended operation. The TLAAs have been projected NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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133 1 to the end of the period of extended operation or 2 the effects of aging on those intended functions 3 will be adequately managed for the period of 4 extended operations, as required by 10 CFR 5 54.21(c)(1).

6 Next slide, please. There is one TLAA 7 open item from the 2013 SER with open items that we 8 closed in this 2013 SER -- or 2016 SER. In 9 reviewing the effects of thermal aging on CASS, the 10 staff was concerned that the Applicant's thermal 11 embrittlement evaluation of CASS material in the 12 leak-before-break piping relied upon an evaluation 13 and data from 1983. The staff issued RAIs between 14 April 2011 and November 2013 and documented its 15 concerns as an open item in the 2013 SER with open 16 items.

17 In response, the Applicant stated that 18 the referenced material, fractured toughness 19 properties, for their evaluations are shown to be 20 bounding. In addition, the Applicant revised its 21 LRA to identify the fracture mechanics evaluation 22 as a TLAA and dispositioned it in accordance with 23 10 CFR 51.21(c)(1) as an analysis that remains 24 valid for the period of extended operation.

25 The staff confirmed that the Applicant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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134 1 used a bounding fractured toughness value for its 2 leak-before-break analysis, and that the fractured 3 toughness used is applicable to 60 years.

4 Therefore, the staff concluded that the revisions 5 to the LRA are acceptable, and the open item is 6 closed.

7 Mr. Skillman, do you have more 8 questions? We have our technical reviewer in the 9 audience.

10 CHAIRMAN SKILLMAN: No. You have 11 addressed the question that I raised earlier.

12 MS. JAMES: Okay.

13 CHAIRMAN SKILLMAN: I'm good. Thank 14 you.

15 MS. JAMES: The next slide, please.

16 Pending the satisfactory resolution of the open 17 item, the staff will determine whether the 18 requirements of 10 CFR 29(a) have been met for the 19 license renewal for South Texas Project Units 1 and 20 2.

21 This concludes our staff presentation, 22 and we will now be available for any further 23 questions from the Subcommittee.

24 Thank you.

25 CHAIRMAN SKILLMAN: Lois, thank you.

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135 1 Colleagues, I invite any questions you 2 might have for the staff at this time.

3 (No response.)

4 Hearing none, I have one. There is a 5 very interesting discussion in the Safety 6 Evaluation about whether or not there are vent 7 valves on the aux feedwater pumps. And when you 8 read the text, the text is convoluted. First of 9 all, it says there are some, then there aren't 10 some. Then, some are in and some are out. And I 11 am wondering if anybody can speak to this.

12 MS. JAMES: Okay. Your question is, do 13 the feedwater pumps have vent valves?

14 CHAIRMAN SKILLMAN: Aux feedwater 15 pumps.

16 MS. JAMES: Aux feedwater pumps have 17 vent valves and are they or are they not within the 18 scope of license renewal?

19 CHAIRMAN SKILLMAN: Yes, and it is page 20 127 in the PDR file of the SER. I don't need to 21 read the text. It just seems as though there was 22 an awful lot of traffic on this subject, and I 23 found it extremely confusing. And I said, oh, wait 24 a minute, most of these pumps do have some kind of 25 a vent valve. Most of them have some valves on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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136 1 piping that is connected to the casing. So, it is 2 not a substance of issue, but I found the text in 3 the SER very --

4 MS. JAMES: Confusing?

5 CHAIRMAN SKILLMAN: -- confusing.

6 MS. JAMES: Okay. Well, first, I will 7 take an action item to try to make sure we do 8 something with that in the Final SER.

9 CHAIRMAN SKILLMAN: It is 127 in the 10 PDR file.

11 MS. JAMES: Is that Section 2 of the 12 SER?

13 CHAIRMAN SKILLMAN: This is.

14 MS. JAMES: It has got to be.

15 CHAIRMAN SKILLMAN: It's -87.

16 MS. JAMES: 2-, yes.

17 CHAIRMAN SKILLMAN: 2-87 is the text 18 page.

19 MS. JAMES: Okay. I guess at this 20 point I'm going to have to take that as a takeaway.

21 CHAIRMAN SKILLMAN: If you would.

22 MS. JAMES: Yes.

23 MEMBER STETKAR: Maybe South Texas can 24 tell us whether or not, indeed, the aux feedwater 25 pumps have vents.

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137 1 CHAIRMAN SKILLMAN: Yes.

2 MR. GIBBS: We have vent valves.

3 MEMBER STETKAR: You actually have to 4 tell us on the record.

5 (Laughter.)

6 MS. JAMES: Yes. And identify 7 yourself, too. Thank you.

8 CHAIRMAN SKILLMAN: For those of us who 9 were plant operators, you would think there is 10 probably a vent valve out there, maybe two.

11 MR. GIBBS: Yes. Ron Gibbs, South 12 Texas operations.

13 Yes, we have vent valves on the aux 14 feedwater pumps. I don't want to lead anybody 15 anywhere, but we installed extra connections for 16 our flex. And maybe that is some of the confusion, 17 how the drawings got updated during this time 18 period. So, we will follow up with Lois to make 19 sure we get the right answer.

20 CHAIRMAN SKILLMAN: This is not a 21 substantive item, but I was being thorough, and I 22 would certainly like to understand what you are 23 communicating on page 2-87, please.

24 MS. JAMES: Okay.

25 CHAIRMAN SKILLMAN: Thank you. Sir, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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138 1 thank you.

2 MS. JAMES: And we will respond to you, 3 but we will also update the SER. If you had the 4 question, I am sure someone else had the question.

5 CHAIRMAN SKILLMAN: Okay. Thank you.

6 MS. DIAZ: For the purposes of the 7 staff, could you restate the question?

8 MS. JAMES: Restate the question?

9 MS. DIAZ: Yes.

10 MS. JAMES: Okay. I was asked to 11 restate the question. The question is, based on 12 the writeup on page 2-87 of the SER, it was 13 confusing as to whether or not there were vent 14 valves on the aux feedwater pumps and were those 15 vent valves within scope of license renewal?

16 CHAIRMAN SKILLMAN: That is the 17 question. Thank you.

18 MS. JAMES: And we will have to get 19 back to you on that.

20 CHAIRMAN SKILLMAN: Thank you.

21 Colleagues, at this point the staff has 22 completed their presentation. Do any of you have 23 comments for the staff, please?

24 MEMBER KIRCHNER: Dick, I have just a 25 question. I can't find it in the SER now. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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139 1 believe that tests were done on the baffle region 2 for vibration of reactor internals. Can you or the 3 Applicant report back on that? It is relevant to 4 Matt's earlier question about baffle bolts and what 5 you may have found as a result of that testing. I 6 think you did a scale model test of the conforming 7 region, the baffle conforming region. I just can't 8 find it. I know it is here in the SER and I can't 9 find it.

10 MS. JAMES: Okay. Jim Medoff is coming 11 to the microphone for the staff.

12 MR. MEDOFF: This is Jim Medoff of the 13 staff. I was the lead for the reactor internals 14 and I had some assistance with Mark Hughes of the 15 staff.

16 One of the things we check as part of 17 the identification of TLAAs in Chapter 4.1 is 18 whether the preopt testing for initial plant 19 operations, whether any analyses associated with 20 preopt testing are TLAAs. So, we did look at that 21 for the application. We usually would -- in most 22 applications the vibrational analyses are below the 23 endurance limit for the components. So, vibrations 24 didn't come in as a TLAA for the internals.

25 That being said, we do rely on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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140 1 MRP-227 report and AMP XIM-16(a) for the internal.

2 Originally, this plant was one that did it under 3 commitment, but due to the delays in the aluminum 4 rods, we did make them update the LRA, update their 5 AMRs and AMPs. So now, we have reviewed the entire 6 AMP, their inspection plan, to make sure it is 7 consistent with MRP-227-A. That would include any 8 inspections of the baffle former region, including 9 the baffle formal bolts.

10 MEMBER KIRCHNER: Thank you.

11 MR. MEDOFF: Any more questions on 12 that?

13 CHAIRMAN SKILLMAN: No, sir. Thank 14 you.

15 Walt, thank you.

16 Colleagues, any other questions at this 17 point for the staff?

18 (No response.)

19 Hearing none, I would ask everybody to 20 remain in place. What we are going to do is to 21 open the phone line.

22 MR. HOWARD: The bridge is open.

23 CHAIRMAN SKILLMAN: The bridge is open.

24 Before we go to those who may be on the phone line, 25 I would like to ask if there are any individuals in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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141 1 the audience that would like to make a statement, 2 please.

3 (No response.)

4 Seeing none, ladies and gentlemen, the 5 bridge line is open. If any individual is out 6 there, would you just please communicate that you 7 are there?

8 MR. GAVULA: This is Jim Gavula.

9 CHAIRMAN SKILLMAN: Good morning, sir.

10 Thank you.

11 Anybody else out there?

12 (No response.)

13 No?

14 For anyone that is on the line, would 15 you care to make a comment, please?

16 (No response.)

17 Hearing none, please close the bridge 18 line.

19 I would like to go around the room with 20 my colleagues to determine if there are any more 21 comments that my colleagues may have.

22 Ron, may I start with you?

23 MEMBER BALLINGER: No further comments.

24 I think I have badgered them enough.

25 CHAIRMAN SKILLMAN: Thank you, Ron.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

142 1 Pete?

2 MEMBER RICCARDELLA: Likewise.

3 CHAIRMAN SKILLMAN: Thank you.

4 Steve?

5 DR. SCHULTZ: I have no further 6 comments. I would like to thank the staff and the 7 Applicant for the discussions. Thank you.

8 CHAIRMAN SKILLMAN: Okay. Dana, 9 anything?

10 MEMBER POWERS: No.

11 CHAIRMAN SKILLMAN: Matt?

12 MEMBER SUNSERI: I appreciate the staff 13 and the Applicant's participation today, and it was 14 helpful to understand what is going on. Thank you.

15 CHAIRMAN SKILLMAN: Thank you.

16 John?

17 MEMBER STETKAR: Nothing more. Thank 18 you.

19 CHAIRMAN SKILLMAN: Walt?

20 MEMBER KIRCHNER: Thank you to the 21 presenters.

22 CHAIRMAN SKILLMAN: Okay. Our 23 Designated Federal Official, Ken Howard, any 24 questions or comments at this point?

25 MR. HOWARD: None.

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

143 1 CHAIRMAN SKILLMAN: Okay. To all who 2 have participated and traveled, thank you very 3 much. I wish you a safe journey home.

4 And with that, this meeting is 5 concluded.

6 (Whereupon, at 11:20 a.m., the meeting 7 was adjourned.)

8 9

10 11 12 13 14 15 16 17 18 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433

SOUTH TEXAS PROJECT Advisory Committee on Reactor Safeguards License Renewal Subcommittee Meeting November 17, 2016

Dave Rencurrel Senior Vice President Operations 2

Agenda

  • Introductions
  • Station Ownership and Operation
  • Site and Station Description
  • Safety Evaluation Report Open Item o Aluminum Bronze Selective Leaching
  • Concluding Remarks SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 3

Introduction PERSONNEL IN ATTENDANCE Dave Rencurrel Senior Vice President Operations Michael Murray Manager Regulatory Affairs Mike Berg Manager Engineering Ron Gibbs Manager Operations Arden Aldridge License Renewal Project Lead Plant Staff AMP Subject Matter Experts, Licensing, Chemistry, Systems Engineering, Design Engineering, and Programs Engineering Specialty Consultants SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 4

Station Ownership and Operation Operated by STP Nuclear Operating Company (STPNOC)

STP Units 1 and 2 are owned by:

  • The City Public Service Board of San Antonio (CPS Energy)

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 5

Plant History & Major Investments South Texas Unit 1 Unit 2 Initial License August 21, 1987 Dec 16, 1988 Steam Generator Replacement 2000 2002 Low Pressure Turbine upgrade 2006 2004 Replaced RX heads 2009 2010 Main Generator Stator rewind 2014 2012 Non-welded Stress Improvement 2017 2019 Process (RPV)

Expiration of current License August 20, 2027 Dec 15, 2028 SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 6

Site and Station Description Ron Gibbs Manager Operations 7

SITE DESCRIPTION SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 8

STATION DESCRIPTION SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 9

License Renewal Application Arden Aldridge License Renewal Project Lead 10

License Renewal Application License Renewal Application (LRA) submitted to NUREG 1801 rev 1 10/2010 NUREG 1800 and 1801 Revision 2 issued 12/2010 Scoping & Screening, AMP Audits completed 06/2011 Scoping & Screening, AMP Inspection completed 08/2011 Annual Updates 2011, 2012, 2013 2011-2013 Issued initial safety evaluation report (SER) with open item(s) 02/2013 Safety review paused 2/2013-12/2013 RAIs, LR-ISG incorporation into LRA 1/2014-Present Annual Updates 2014, 2015, 2016 2014-2016 Issued safety evaluation report (SER) with open item 10/2016 SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 11

Aging Management Programs and GALL

  • Existing Programs - 33 (3) plant specific
  • New Programs - 8 (1) plant specific
  • Plant Specific

- Nickel-Alloy

- PWR Reactor Internals

- Protective Coating Monitoring and Maintenance

- Selective Leaching of Aluminum Bronze

  • Aging evaluations are greater than 90% consistent with GALL Rev 1 and greater than 95% consistent with GALL Rev 2 (standard notes A through E)

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 12

GALL Consistency Consistency Table AMPS AMPS AMPS Consistent Consistent with AMPS with Plant AMPS Consistent with Exception & Exceptions Specific Enhancements Enhancements New (8) 3 4 1 Existing (33) 5 13 11 1 3 Total AMPS (41)

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 13

License Renewal Commitments License Renewal commitments - 46 total

- Program Enhancements (4 complete, 26 open)

- Program Implementation (1 implemented , 9 open)

- Replace 6 Standby Emergency Diesel Generator bellows (open)

- Remove Safety Related Check Valve Seal Caps (complete)

- Review NUREG/CR-6260 (Enhanced Fatigue Monitoring locations (open)

- Take ground water samples for 24 consecutive months to assure non aggressive (complete)

- Calculate Essential Cooling Water leakage rates to validate maximum flaw size (complete)

- One time internal inspection of Unit 1 Refueling Water Storage Tank (RWST) bottom and side welds. (open)

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 14

License Renewal Commitments and Implementation License Renewal commitments are included in UFSAR Supplement (Appendix A to the LRA) and managed through the STP Condition Reporting and Licensing Commitment Management and Administration processes.

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 15

Safety Evaluation Report Open Item Mike Berg Engineering Manager 16

OI 3.0.3.3.3-2 Aluminum Bronze Selective Leaching SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 17

Selective Leaching of Aluminum Bronze Background Wrought Material is non-Susceptible Susceptible Component Population - Will be replaced with non-susceptible material prior to period of extended operation Welds or weld-repairs with susceptible weld filler material will be managed

  • piping butt-welds
  • weld repairs on extruded tees SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 18

Selective Leaching of Aluminum Bronze Aging Management Program (AMP)

STP responded to the NRCs open items related to Selective Leaching of Aluminum Bronze AMP by letter dated September 28, 2016, NOC-AE-16003403.

OI 3.0.3.3.3-2 Identified ten open issues requiring closure.

Nine of the ten open issues have been addressed. The final issue is still open but a pathway forward has been identified to assure timely resolution.

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 19

Selective Leaching of Aluminum Bronze Aging Management Program (AMP)

Addressed Issues:

1. Added information to bound extruded piping tee repairs
2. Clarified the parameters monitored to address loss of material, cracking, and phase distribution.
3. Clarified the sample size for volumetric inspections One-time examination of welds Periodic examination of welds
4. Clarified the threshold for the number of defective welds resulting in further inspections
5. Identified selection criteria for weld inspections SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 20

Selective Leaching of Aluminum Bronze Aging Management Program (AMP)

Addressed Issues:

6. Determined there was no impact of the external coatings regarding detecting buried piping leaks at the surface.
7. Identified a method to monitor or trend results
8. Defined the acceptance criteria for weld defects Visual inspection Volumetric examination Destructive examination
9. Identified the threshold for increased inspections when adverse inspection results are detected
10. Identified the corrective actions to address all potential inspection results.

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 21

Selective Leaching of Aluminum Bronze Aging Management Program (AMP)

Remaining Open Issue:

10. Corrective actions do not address all potential inspection results.

Followup question is being developed by the NRC. Initial communication of the concern supports a pathway forward and timely response and resolution.

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 22

Selective Leaching of Aluminum Bronze Aging Management Program (AMP)

Conclusion:

Following the resolution of the remaining issue related to corrective actions, the Selective Leaching of Aluminum Bronze Aging Management program will effectively manage aging of the Essential Cooling Water cast components and welds during the extended period of operation.

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 23

Concluding Remarks Dave Rencurrel Senior Vice President Operations 24

END 25

Advisory Committee on Reactor Safeguards License Renewal Subcommittee South Texas Project Safety Evaluation Report (SER) with Open Items November 17, 2016 Lois M. James, Senior Project Manager Office of Nuclear Reactor Regulation

Presentation Outline

  • SER Section 2, Scoping and Screening Review
  • SER Section 4, Time-Limited Aging Analyses
  • Conclusion 2

License Renewal Review (Audits and Inspections)

  • Scoping and Screening Methodology Audit

- May 15 - 19, 2011 (Onsite)

- June 13 - 24, 2011 (Onsite)

- February 29, 2012 (Rockville)

- March 9 - 13, 2015 (Onsite)

- March 21 - 23 (Onsite) and June 22, 2016 (Rockville)

  • Region IV 71002 Inspection (Scoping and Screening & AMPs)

- August 8 - 25, 2011 (Onsite) 3

SER Overview

  • SER with Open Item (OIs) issued in 2013

- Closed the OIs from 2013

- Opened OI 3.0.3.3.3 Insufficient details provided regarding applicants Selective Leaching of Aluminum Bronze AMP 4

71002 Inspection

  • Scope
  • Non-Safety Systems affecting Safety Systems
  • Inspection
  • August 8 - August 25, 2011
  • Team Inspection on-site for 2 weeks 5

71002 Inspection

  • Results

- Good material condition of structures, systems and components

- Two implementing procedures changed

- Two Aging Management Programs Changed

- Revised Commitments and Corresponding Changes for five Aging Management Programs 6

71002 Inspection

  • Conclusions

- Scoping and screening performed in accordance with 10 CFR 54

- Information easily retrievable and auditable

- Existing programs effectively managed aging effects

- Corrective and other actions being tracked for completion

- Reasonable assurance that aging effects will be managed and intended functions maintained 7

SER Section 2

- Section 2.1, Scoping and Screening Methodology

- Section 2.2, Plant-Level Scoping Results

- Sections 2.3, 2.4, 2.5 Scoping and Screening Results 8

SER Section 3

- Section 3.1, Aging Management of Reactor Vessel, Internals, and Reactor Coolant System

- Section 3.2, Aging Management of Engineered Safety Features

- Section 3.3, Aging Management of Auxiliary Systems

- Section 3.4, Aging Management of Steam and Power Conversion Systems

- Section 3.5, Aging Management of Containments, Structures and Component Supports

- Section 3.6, Aging Management of Electrical Commodity Group 9

SER Section 3 3.0.3 - Aging Management Programs Applicants Disposition of AMPs Final Disposition of AMPs in SER with OIs

  • 8 new programs
  • 8 new programs 3 consistent 3 consistent 4 consistent with exceptions 4 consistent with exceptions 1 plant specific 1 plant specific
  • 32 existing programs
  • 33 existing programs 6 consistent 5 consistent 13 consistent with enhancements 14 consistent with enhancements 3 consistent with exception 1 consistent with exceptions 8 consistent with enhancements 10 consistent with enhancements and exceptions and exceptions 2 plant specific 3 plant specific
  • 1 existing program added Note: The staff received and is reviewing the 2016 annual 1 plant specific update. The final SER will be updated based on the staffs review.

10

SER Section 3 Open Items Closed OI 3.0.3.2.6-2: Management of fouling of downstream components due to coating degradations upstream

  • Concern: AMP may be inadequate
  • Resolution: AMP was revised in accordance with staffs guidance in ISG-2013-01, Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping Components, Heat Exchangers, and Tanks.

OI 3.0.3.1.4-1: Cracking in Unit 1 Reactor Water Storage Tank (RWST)

  • Concern: No AMP
  • Resolution: Revised the One-Time Inspection AMP to include the internal surfaces of the Unit 1 RWST; and revised External Surfaces AMP to include visual inspections of the Unit 1 RWST every refueling cycle.

11

Aluminum Bronze Overview

  • Applicant revised AMP in September 2016.
  • Replacing all susceptible piping components that have exhibited leakage except for susceptible weld material joining nonsusceptible piping components.
  • Applicant proposed a basis for why butt welds have not experienced leakage since 1994.

- Root pass less susceptible: dilution and cool down rate

- Root pass acts as a barrier

- No construction related or service induced flaws in root pass, barrier remains intact

  • Root pass as a barrier seemed plausible; however, basis lacked sufficient data to substantiate 12

Staff Conclusions Based on review of tests and examinations conducted by the applicant, and the review of technical literature by the staff:

  • Microstructure level dealloying process is confined to a localized front that scales with the grain size.
  • Material on either side of the dealloying front is either in the as-received or fully dealloyed condition.
  • Insufficient data to establish lower bound mechanical properties for dealloyed aluminum bronze.
  • No strength or fracture toughness credit should be given to dealloyed material.

13

Program Element Overview September 2016, AMP revised to address most of the OI

  • Detection of aging effects:

- Volumetric inspections and destructive examinations

- Visual inspections for leakage

- Opportunistic buried pipe coating inspections

  • Acceptance criteria:

- Planar defect and dealloying

- Microstructure of the weld root region

- Monthly walkdowns 14

Program Element Overview, cont.

Corrective Actions:

  • Additional volumetric and destructive examinations
  • Structural integrity calculations conducted with as-found conditions
  • Structural integrity analysis fails - additional inspections by ultrasonic testing (UT) technique capable of detecting loss of material due to selective leaching - Associated Request for Additional Information (RAI) for further information 15

SER Section 4

  • Time-Limited Aging Analyses

- 4.1, Identification of Time-Limited Aging Analyses (TLAA)

- 4.2, Reactor Vessel Neutron Embrittlement Analysis

- 4.3, Metal Fatigue Analysis

- 4.4, Environmental Qualification of Electric Equipment

- 4.5, Concrete Containment Tendon Prestress Analyses

- 4.6, Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses

- 4.7, Other Plant-Specific TLAAs 16

SER Section 4 Open Item Closed OI 4.3.2.11-1: Effects of thermal aging on cast austenitic stainless steel (CASS):

  • Concern: Leak-Before-Break (LBB) TLAA may not be dispositioned correctly
  • Resolution: Revised LRA Section 4.3.2.11 to identify the fracture mechanics evaluation as a TLAA and disposition it in accordance with 10 CFR 54.21(c)(1)(i); and the material fracture toughness properties selected for use in the LBB analysis are sufficiently embrittled that they bound the amount of thermal embrittlement that will occur in 60 years.

17

Conclusion Pending satisfactory resolution of the Open Item, the staff will determine whether the requirements of 10 CFR 54.29(a) have been met for the license renewal of STP.

18

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