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| number = ML073030157
| number = ML073030157
| issue date = 09/25/2007
| issue date = 09/25/2007
| title = 2007/09/25-Corrected Transcript of Evidentiary Hearing Held in Toms River, Nj; Pp. 610 - 878
| title = Corrected Transcript of Evidentiary Hearing Held in Toms River, Nj; Pp. 610 - 878
| author name =  
| author name =  
| author affiliation = NRC/ASLBP
| author affiliation = NRC/ASLBP
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{{#Wiki_filter:Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Amergen Energy Company Oyster Creek Evidentiary Hearing Docket Number: Location: Date: 50-0219-LR; ALSBP No. 06-844-01-LR Toms River, NewJersey DOCKETED" USNRC .:6 -October 26, 2007 (4:07pm), Tuesday, September 25, 2007 OFFICE. OF SRULEMAKINGS AND-.-ADJUDICATION'S STAFE*Work Order No.: NRC-1 780 Pages 61 0-878 NEAL R. GROSS AND CO., INC.Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.Washington, D.C. 20005 (202) 234-4433 elln P lcf e-::--- 6 C Y- 03.9-(SIlC%- 6Y-o' 610 1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2 3 ATOMIC SAFETY AND LICENSING BOARD 4 5 EVIDENTIARY HEARING 6 7 IN THE MATTER OF: 8 AMERGEN ENERGY COMPANY, LLC Docket No.: 50-0219-LR 9 (License Renewal for Oyster ASLBP No.: 06-844-01-LR 10 Creek Nuclear Generating 11 Station)12 II 13 Ocean County Administrative Building 14 Room 119 15 101 Hooper Avenue 16 Toms River, New Jersey 08754 17 18 Tuesday, 19 September 25, 2007 20 The above-entitled matter came on for 21 hearing, pursuant to notice at 8:04 a.m.22 BEFORE: 23 THE HONORABLE E. ROY HAWKENS, Chairman 24 THE HONORABLE PAUL B. ABRAMSON 25 THE HONORABLE ANTHONY J. BARATTA NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 611 1 APPEARANCES:
{{#Wiki_filter:}}
2 On Behalf of the Amergen Energy Company, LLC:'3 DONALD J. SILVERMAN, ESQ.4 ALEX POLONSKY, ESQ.5 KATHRYN SUTTON, ESQ.6 RAPHAEL P. KUYLER, ESQ.7 Of: Morgan Lewis & Bockius, LLP 8 1111 Pennsylvania Avenue, NW 9 Washington, DC 20004 10 (202) 739-5502 11 12 On Behalf of the NRC: 13 MARY BATY, ESQ.14 MITZI YOUNG, ESQ.15 US Nuclear Regulatory Commission 16 Office of the General Counsel 17 Mail Stop 15 D21 18 Washington, DC 20555-0001 19 On Behalf of Citizens: 20 RICHARD WEBSTER, ESQ.21 JULIA LEMENSE 22 Rutgers Environmental Law Clinic 23 123 Washington Street 24 Newark, NJ 07102-3094 25 (973) 353-5695 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com rl 612 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23-24 25 TABLE OF CONTENTS Panel Panel 3: Available Margin ... .............
con't Panel 4: Sources of Water ..... ..........
685 Panel 5: The Epoxy Coating ... ..............
704 Panel 6: Future Corrosion
..... ..........
763 CLOSING STATEMENTS:
Richard Webster on behalf of Citizens Alex Polonsky on behalf of AmerGen ...NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 853 867 www.nealrgross.com 613 1 PROC E ED INGS 2 8:03 A.M.3 CHAIRMAN HAWKENS: Good morning. We are 4 on the record. Welcome back again this morning. This 5 is a hearing in the case of AmerGen Energy Company, 6 Docket No. 50-0219-LR.
For the benefit of those in 7 the audience who were not with us yesterday, AmerGen 8 in this case has applied to renew its operating 9 license at Oyster Creek Nuclear Generating Plant for 10 a 20-year period and AmerGen's application is opposed 11 by six groups. They refer to themselves collectively 12 as Citizens.13 The issue that Citizens has raised is that 14 they argue AmerGen's commitment to take ultrasonic 15 testing measurements of the width of the drywell shell 16 every four years during the renewal period is not 17 sufficient to ensure an adequate safety margin in that 18 shell.19 My name is Roy Hawkens and I'm joined by 20 Judge Tony Baratta, Judge Paul Abramson.
We're 21 members of the Atomic Safety and Licensing Board 22 Panel, a judicial component of the Nuclear Regulatory 23 Commission.
It's our job to resolve the issued raise 24 by Citizens.25 I indicated yesterday that prior to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 614 1 commencement of the hearing, the Board had received 2 three rounds of legal briefs from parties, three 3 rounds of written testimony from their expert 4 witnesses and numerous exhibits, over 125 exhibits 5 were submitted into evidence.6 Yesterday, we heard opening statements by 7 parties' counsel. Following that we started 8 questioning their expert witnesses.
Each party has 9 designated the identity and the number of their expert 10 witnesses.
AmerGen and the NRC staff have several 11 expert witnesses.
Citizens elected to go with a 12 single expert witness, Mr. Hausler. We have six 13 topics that the Board identified that it was 14 interested in exploring.
We got through two of those 15 topics yesterday.
Those two topics were the drywell 16 physical structure, history, and the commitments by 17 AmerGen. The second topic was the acceptance 18 criteria.
The third topic, we got to it in a very 19 advanced stage of discussion was available margin, but 20 we're going to finish up on that topic today and we 21 have three additional topics to discuss. They are 22 sources of water, the epoxy coating, and future 23 corrosion.
24 Would counsel for the parties please 25 identify themselves for the record?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 615 1 MR. POLONSKY:
This is Alex Polonsky with 2 Morgan, Lewis & Bockius, counsel to AmerGeni.3 MR. SILVERMAN:
Don Silverman, also with 4 Morgan, Lewis & Bockius.5 MS. SUTTON: Kathryn Sutton, Morgan, Lewis 6 & Bockius.7 MS. BATY: For the NRC staff, Mary Baty 8 and Mitzi Young.9 MR. WEBSTER: For Citizens, I'm Richard 10 Webster, Eastern Environmental Law Center. I teach at 11 Rutgers Environmental Law Clinic.12 CHAIRMAN HAWKENS: Thank you. And is it 13 true that the expert witnesses you brought to today's 14 session are the same witnesses that were introduced 15 yesterday?
16 MR. POLONSKY:
This is Mr. Polonsky for 17 AmerGen. For Panel 3 those witnesses have remained 18 the same.19 CHAIRMAN HAWKENS: The witnesses, I 20 believe you introduced 14 yesterday.
They remain the 21 same?22 MR. POLONSKY:
Yes, actually it was .15 23 with the addition of Dr. Mehta from GE. Yes, those 24 witnesses remain the same and they should all be 25 present here right now and they were sworn yesterday.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 616 1 CHAIRMAN HAWKENS: And we will introduce 2 them as we go from topic to topic.3 NRC staff, is that correct, you also have 4 the same witnesses from yesterday?
5 MS. BATY: Yes.6 CHAIRMAN HAWKENS: Thank you. I see Dr.7 Hausler. He is for Citizens.8 Before paneling our expert witnesses, are 9 there any evidentiary matters that need to be raised.10 Amergen?11 MR. POLONSKY:
None, Your Honor.12 CHAIRMAN HAWKENS: NRC staff?13 MS. BATY: No.14 MR. WEBSTER: Maybe I misunderstood.
I 15 had a discussion with AmerGen's counsel about the 16 availability of written records for the UT scanning.17 MR. POLONSKY:
There was some question 18 after Mr. Jon C. or Chris Hawkins gave his testimony 19 yesterday about confirmatory UT measurements taken in 20 the external sand bed region during the 2006 refueling 21 outage. There was some question whether that follow 22 up or confirmatory UT measurement thickness, 23 measurement readings resulted in any additional 24 documentation that would be in addition to what had 25 already been previously disclosed to the parties.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 617 1 We confirmed with Mr. Hawkins that no 2 record, written record, was made of those confirmatory 3 readings at the time and so it is AmerGen's position 4 that the documentation that's already been produced 5 and the exhibits already submitted accurately 6 represent the documentation that was taken by Mr.7 Hawkins.8 MR. WEBSTER: And Citizens is very happy 9 to stipulate to that fact that the documents in the 10 record reflect the records taken for the external UT 11 measurements.
12 CHAIRMAN HAWKENS: Thank you. Are there 13 any other evidentiary matters?14 Mr. Webster?15 MR. WEBSTER: Well, we're still awaiting 16 confirmation on one document which we expect. AmerGen 17 said they would get it to us today.18 CHAIRMAN HAWKENS: All right, I note that 19 two of the parties provided Ms. Wolf with additional 20 proposed questions which she gave to the Board, the 21 confidential questions NRC staff and Citizens.
Did 22 AmerGen provide any additional questions?
23 MR. POLONSKY:
We did not provide any, 24 Your Honor, and we don't believe any are necessary.
25 CHAIRMAN HAWKENS: All right, thank you.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 618 1 Let's empanel the third panel please and would each 2 party please introduce their expert witnesses on this 3 panel?4 MR. POLONSKY:
This is Mr. Polonsky for 5 AmerGen. For Panel 3 we have Mr. Fred Polaski, Mr.6 Peter Tamburro, Dr. David Gary Harlow, Mr. Martin 7 McAllister and behind me, Mr. Julien Abramovici.
8 MS. BATY: For the NRC staff, we have Dr.9 Davis, Dr. Hartzman, Hansraj Ashar, Arthur Salomon, 10 and Tim O'Hara.11 MR. WEBSTER: And for Citizens, we have 12 the ubiquitous Dr. Hausler.13. CHAIRMAN HAWKENS: Thank you. The 14 witnesses are reminded they were sworn yesterday and 15 they do remain under oath or affirmation for the 16 testimony they will provide today.17 For the benefit of members of the audience 18 who were not with us yesterday, and as a reminder to 19 counsel, under the informal hearing procedures, it is 20 the Judges who are tasked with doing the questioning.
21 We've had the benefit of written suggested questions 22 by the counsel and we do appreciate that. We've also 23 had the benefit, as I indicated earlier, of the very 24 thorough briefing and reams of documents and expert 25 testimony already. So this is the Board's opportunity NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 619 1 really to pursue the line of questioning where issues 2 remain in their own mind.3 And regulations do provide that no party 4 may submit proposed questions to the Board except upon 5 request by and at its sole discretion of the Board.6 So they're reminded that interjections should be few.7 To the extent counsel does raise a question and is not 8 interrupted by a Judge and requested to refrain from 9 questioning, the other counsel may assume, by 10 inference, that the Board is permitting that 11 individual, that counsel to raise a question.
So I 12 would expect questioning to be rare and objections to 13 be even rarer. With that in mind, let's proceed.14 JUDGE BARATTA: In response to the Board's 15 questions, there was a statement or there was a 16 question concerning providing a table which showed the 17 95 percent confidence interval for all the data.18 AmerGen, I believe, responded that they had not only 19 calculated that interval for the 2006 data, however, 20 in the discussion yesterday, it was mention of 21 projections to determine the thickness in the future.22 That's how you came up with that .736 thickness and 23 that was based on a 95 percent confidence estimate.24 I wasn't sure what the 95 percent referred to.25 Could somebody respond to that as the --NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 620 1 were there other data, earlier data like the 1980s 2 data that was analyzed to obtain a confidence 3 interval?4 MR. TAMBURRO:
This is Peter Tamburro.5 Prior to 1992, when we removed the sand, we did apply 6 a 95 percent confidence interval on the curve fit of 7 the mean over time. The averages of each grids were 8 trended over time. We then established a curve fit of 9 those averages over time. We performed statistical 10 tests on the curve fit to ensure that the curve meets 11 the data with 95 percent confidence.
Then we 12 calculated a lower, 95 percent confidence interval.13 This is a curve that bounds the original curve fit 14 with 95 percent confidence, Your Honor.15 JUDGE BARATTA: And is that provided any 16 place in any of the exhibits?17 MR. TAMBURRO:
In the ACRS testimony there 18 is a--19 JUDGE BARATTA: It's Exhibit 40, I think, 20 is that correct?21 (Pause.)22 MR. WEBSTER: I think page 79 gives a 23 schematic.
24 MR. TAMBURRO:
That's AmerGen Exhibit 40 25 which is the January 18th ACR presentation.
Starting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 621 1 at page 77, Your Honor.2 JUDGE BARATTA: Seventy-seven?
3 MR. TAMBURRO:
Page 77 provides a 4 schematic on the trending.
The points represent the 5 average of the grids and the Y axis is the thickness.
6 If you go to page 78.7 MR. POLONSKY:
Mr. Tamburro, hang on.8 Just a clarification.
9 Judge Baratta, are you looking for how 95 10 percent confidence interval was applied prior to 1992?11 JUDGE BARATTA: Well, I was curious as to 12 -- in response to the Board's questions, there was a 13 statement made that the confidence interval was not 14 calculated.
And it appears that that was done, taking 15 this curve, at least, that that's what I'm trying to 16 get at is was it or was it not calculated and if so, 17 what did it show?18 MR. POLONSKY:
And I was just trying to 19 clarify so that you get an answer in the proper time 20 frame of what you're looking for, that's all.21 MR. TAMBURRO:
Prior to 1992, we 22 calculated confidence intervals on the corrosion rate 23 because there was a large corrosion rate. After 1992, 24 with respect to the corrosion rate,' we did not 25 calculate the confidence interval because we could not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 622 1 establish corrosion rate.2 JUDGE BARATTA: To obtain that 95, 3 specifically, how was the confidence interval 4 calculated and what was it calculated on? Could you 5 go through the details of that?6 MR. TAMBURRO:
I would like to. I was 7 going to, if I could continue with the --8 JUDGE BARATTA: Sure, yes. Please. I 9 thought you were done, sorry. Didn't mean to cut you 10 off.11 MR. TAMBURRO:
Again, I apologize.
Again, 12 on page 78 of Exhibit 40, it's a schematic.
The round 13 circles are the mean. The squares around the round 14 circles are the standard error and then the line is a 15 curve fit using least squares fit. We then performed 16 a test on that curve fit using the f-test to 95 17 percent confidence.
If the curve fit met the data 18 with 95 percent confidence, prior to 1992, the staff we then concluded that the slope of that curve was 20 the corrosion rate.21 Once that slope was established as being 22 indicative of corrosion, we went, if you look at page 23 79, we calculated the lower 95 percent confidence 24 interval on the curve fit. That confidence interval 25 takes into account how many data points, how many NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 623 1 means the standard error and the duration that the 2 data was collected.
3 The projections prior to 1992 when we had 4 corrosion were then the intersect of the 95 percent 5 confidence interval with the time of interest or the 6 minimum thickness.
7 JUDGE BARATTA: The more recent data that 8 you've obtained, have you done a detailed analysis of 9 variance to see whether or not the means are in fact 10 the same..- In other words, there's no corrosion rate 11 occurring?
12 MR. TAMBURRO:
Yes, sir.13 JUDGE BARATTA: Where is that document?14 MR. TAMBURRO:
Exhibit 20, AmerGen Exhibit 15 20 is a calculation which evaluated all of the 16 internal grids.17 JUDGE BARATTA: Do you have any comments 18 that you want to make about it?19 MR. TAMBURRO:
Yes, sir. The exhibit, 20 this calculation concludes that there is no 21 statistical observable corrosion.
We only had four 22 data points since 1992. Although the data is fairly 23 well behaved, the variance on the data is large enough 24 to where we cannot pick up the corrosion rates we 25 would have expected, which would be less than the mil NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.,N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 624 1 per year, if any. Therefore, we did not have enough 2 data to confirm an observable corrosion rate.3 JUDGE BARATTA: Did you get an estimate of 4 what the minimum observable corrosion rate would be 5 based upon the variance, did you not?6 MR. TAMBURRO:
Yes, sir.. We performed a 7 study based on a Monte Carlo simulation using the 8 bounding area, grid 19A, using the mean of that 9 bounding area, 1992, and the variance as measured by 10 the standard area. That simulation told us that a 11 rate of 6.9 mils per year would have been observable 12 with only four observations from 1992 to 2006. Any 13 rate less than 6.9 mils per year would have not be 14 observed and would have been within the scatter of the 15 data.16 Therefore, we have based our next 17 inspection based on that 6.9 mils per year as if this 18 hypothetical rate, as if it were really there and-we 19 are inspecting prior to any hypothetical degradation 20 in the dry well. We will inspect prior to that time.21 JUDGE BARATTA: Now how did you obtain the 22 four year? You say it was based on the hypothetical 23 rate of 6.9 mils? How was the four year obtained, the 24 four year interval obtained?25 MR. POLONSKY:
I think maybe there's some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 625 1 confusion, Your Honor. The four year UT frequency is 2 for the license renewal period. Mr. Tamburro I think 3 is talking about the next inspectionin 2008, which 4 would have been two years later.5 MR. TAMBURRO:
Independent of our 6 commitments, this calculation was performed and at the 7 limiting location with this highly conservative 8 corrosion rate, we would have not violated 736 9 criteria until, I believe, 2014. I need to review 10 this to give you a better date.11 JUDGE BARATTA: Go ahead. Feel free to go 12 ahead and do that. Let me just ask while you're doing 13 that Dr. Hausler, do you have any comments on what you 14 heard?15 DR. HAUSLER: I have a question.
I have 16 a question.
I was wondering if in the correlation 17 calculation of the old data, the means were used for 18 the correlation or the means of the individual 19 averages or the lower 95 percent confidence limit?20 JUDGE ABRAMSON:
Before we go too far down 21 that path and spend a lot of time, let's all remember 22 that those calculations were only used to develop the 23 .736 criteria, that they have no other meaning. Is 24 that right, Mr. Tamburro?
That slope was used to come 25 up with a .736, which was your estimate of where you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 626 1 would be in the worst case?2 MR. TAMBURRO:
Yes, sir. And that was the 3 lower curve, the lower 95 percent confidence, so not 4 the curve fit.5 JUDGE ABRAMSON:
And that has no 6 significance here other than it is the number that 7 they use to come up with a guidance to General 8 Electric, tell them what to use for a fully, a 9 uniformly degraded shell. So while it is nice to have 10 this academic discussion, we're spinning wheels.11 MR. WEBSTER: Judge Abramson, I think it 12 was, maybe I'm wrong, but I thought it was also used 13 to calculate the measurement interval.14 MR. POLASKI: This is Fred Polaski. I 15 think we need to be clear, like Judge Abramson is 16 saying, is what went on before 1992 is totally 17 different than what happened after 1992. Before 1992, 18 there was corrosion occurring and the previous owner 19 was doing calculations of projecting corrosion rates 20 based on actual data and things that were going on and 21 that's how they projected with the lower 95 percent 22 confidence of 736 mils.23 After 1992, the data radically changes 24 because there is no corrosion occurring and so the 25 analysis takes on a totally different approach because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 627 1 you're getting essentially zero corrosion rate when 2 you look at the actual measurement data that was 3 taken. But AmerGen does do conservative calculations 4 to project forward a, you know, 95 percent lower 5 corrosion rate that could occur to look at what would 6 the interval be that we could'go to before we would 7 exceed 736 if corrosion was occurring.
8 JUDGE ABRAMSON:
And that was the Monte 9 Carlo calculations and the statistics had indicated 10 that you couldn't detect anything less than 6.9 mils, 11 do you just used the worst case scenario assuming it 12 would be as bad as you could not detect. Is that --13 MR. TAMBURRO:
Yes.14 MR. POLASKI: That's correct.15 MR. TAMBURRO:
Exhibit 40, page 86, 16 provides, which was the ACRS presentation, provides 17 the results of that study. And in the most limiting 18 locations were 19A and 17D. If one were to project 19 forward that this very high, hypothetical, unrealistic 20 corrosion rate from 2006, we would not reach the 21 minimum required thickness of .736 until 2016.22 JUDGE BARATTA: The technique that was 23 used there was a Monte Carlo sampling from the 24 distributions of the mean of each data point.25 MR. TAMBURRO:
Yes, sir.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
.1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 628 1 JUDGE BARATTA: That's how you did that as 2 opposed to just a curve fit like you did previously, 3 correct?4 MR. TAMBURRO:
Yes, sir.5 MR. POLASKI: I'd also like to point out 6 that that in that analysis when we did that, we did 7 that for 19A, is that the correct one, Pete?8 MR. TAMBURRO:
We did them for all. The 9 two bounding grids are 19A and 17Do 10 MR. POLASKI: 17D. But when you look at 11 the overall data, I mean this is very hypothetical.
12 Is that corrosion would be going on on only that 13 location and not show up. You've got 19 locations 14 we're monitoring and we're not seeing any corrosion on 15 any of those locations in the sand bed region. That's 16 why we believe, you know, as Mr. Tamburro said, this 17 is hypothetical and it's very conservative bounding 18 type analysis.19 JUDGE BARATTA: Would you say -- I think 20 you said already that if you, in fact, do statistical 21 tests on the means, there is no statistically 22 significant difference between those, is that correct?23 MR. TAMBURRO:
Yes, 'sir.24 JUDGE BARATTA: So that basically backs up 25 what you've said.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 3323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 629 1 MR. TAMBURRO:
Yes, that's correct.2 JUDGE BARATTA: Dr. Hausler, do you have 3 any comments on that?4 DR. HAUSLER: I would just like to add 5 that these data and the 6.6 NPY actually refer to the 6 grid measurements.
And I believe we have established 7 yesterday that that is not likely the place where the 8 most corrosion will occur in the future.9 JUDGE ABRAMSON:
I have three. Actually, 10 my first question is in the nature of a request of 11 Citizens.
Yesterday, Dr. Hausler mentioned briefly 12 and I think, you, Mr. Webster, supported it, that 13 Citizens has raised an issue of how much remaining 14 margin there is for the pressure failure. Would you can you provide for us where in the testimony you 16 have raised this? You don't need to do it right away, 17 just give it to us by noon today or something like 18 that. We would just like to know where in the 19 prefiled testimony you've raised this so we can take 20 a closer look at it.21 MR. WEBSTER: Certainly.
I think it was 22 in response to the Board's request on extreme value 23 statistics.
24 JUDGE ABRAMSON:
Thank you. That's my 25 first request. My second request is Dr. Mehta, once NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 630 1 again, would you come up, please?2 Dr. Mehta, we heard yesterday a lot about 3 the GE calculations.
As I understand it, so the 4 record is perfectly clear, GE did two types of 5 calculations, one assuming that the entire drywell 6 shell was degraded to .736 and looked to see what 7 safety margin that would provide. Is that correct?8 DR. MEHTA: Yes, Your Honor.9 JUDGE ABRAMSON:
And the other was that 10 and superimposed on top of that this tray of 11 additional erosion at the midpoint between the 12 downcomers.
Is that correct?13 DR. MEHTA: Yes, Your Honor.14 JUDGE ABRAMSON:
Okay, and those are the 15 only calculations you've done. You have not, GE has 16 not been asked to analyze anything that looks like --17 -- estimates the current configuration, i.e., one 18 inch, 1.15 inch most everywhere with degradation as 19 measured.
Is that correct?20 DR. MEHTA: That is correct, sir.21 JUDGE ABRAMSON:
You've calculated for the 22 uniform degradation of .736 that the safety margin 23 would be 2.0. And I think you said yesterday you 24 would expect if you did the as measured or current 25 configuration, you'd get -- you, would get a higher NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
* ° 631 1 safety margin. Am I accurately remembering that?2 DR. MEHTA: Yes, sir. That is my 3 engineering judgment.
That's what I stated.4 JUDGE ABRAMSON:
Well, you're the only one 5 here who's done this sort of work, so we're sort of 6 stuck asking you or stuck -- we're happy to have you 7 here to answer the question.8 But okay, that's -- I just wanted to make 9 sure we were all on the same page, that in fact, 10 you've done two very hypothetical calculations which 11 are being used by the Applicant and the staff as 12 bounds for when this shell would reach certain 13 criteria that are called the current licensing basis.14 But we've never analyzed, nobody has analyzed what the 15 buckling 'safety factor would be for the actual 16 configuration.
Is that correct?17 DR. MEHTA: That is correct, sir.18 JUDGE ABRAMSON:
Thank you. The next one 19 is for Dr. Harlow who is not related to the famous 20 Harlow from Los Alamos National Lab, I'm told.21 Dr. Harlow, we heard a lot of testimony 22 yesterday about the sparseness of this data. And yet 23 we're using this data, the Agency is using the data to 24 try to confirm and the Applicant is using the data to 25 establish that this drywell shell is not approaching NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 632 1 either of these failure criteria.2 Can you just take a few minutes and give 3 us your view on how statistically one can or should 4 use this data and whether the approach taken by the 5 Applicant of looking at a few points and seeing 6 whether they fit under the tray. Is there a rational 7' approach when there's a limited amount of data?8 DR. HARLOW: So I'm assuming you're 9 talking about the external data or the internal or 10 both?11 JUDGE ABRAMSON:
Let's talk about -- well, 12 first of all, the internal data is what -- let me come 13 back to Mr. Tamburro.14 Which data is being used to determine 15 whether you're approaching the --either of these 16 buckling criteria?17 MR. TAMBURRO:
The internal data is being 18 used for comparison to the uniform thickness.
19 JUDGE ABRAMSON:
Okay.20 MR. TAMBURRO:
And is being used to 21 demonstrate margin.22 JUDGE ABRAMSON:
It's being used to 23 demonstrate margin vis-a-vis the uniform degradation?
24 MR. TAMBURRO:
Yes, sir.25 JUDGE ABRAMSON:
And what data is being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 633 1 used to demonstrate compliance?
2 MR. TAMBURRO:
The external data was used 3 to demonstrate compliance with the local buckling 4 criteria.5 JUDGE ABRAMSON:
So let's focus on the 6 external data because I think we understand that it is 7 not uniformly degraded,'
the .736. There's what, 90 8 percent, 95-percent of this shell is not degraded at 9 all? Give me a ballpark estimate, Mr. Tamburro.
What 10 percentage is not corroded?11 MR. TAMBURRO:
A large percentage, Your 12 Honor, greater than 80 percent.13 MR. WEBSTER: Not corroded?
Does that 14 mean not corroded at all, no wall thickness loss 15 whatsoever?
16 JUDGE ABRAMSON:
We've taken -- you've 17 taken measurements in some areas, right?18 MR. TAMBURRO:
Yes, sir.19 JUDGE ABRAMSON:
And in those areas where 20 in the sand bed region you observed material 21 corrosion?
22 MR. TAMBURRO:
Yes, sir.23 JUDGE ABRAMSON:
Perhaps I can rephrase 24 this question.
What percentage of the shell does not 25 show material degradation?
What percentage is still NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 634 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 over an inch thick, let's say?MR. TAMBURRO:
'In my estimation, over 80 percent.within the MR. WEBSTER: Judge, could we clarify that sand bed region?JUDGE ABRAMSON:
No, no. The entire shell.MR. WEBSTER: Okay.JUDGE ABRAMSON:
And the reason I'm interested is because the uniform degradation calculation, as soon as the entire shell is thinned.I'm just trying to get a handle on it.MR. TAMBURRO:
Your Honor, I misunderstood the question.
I thought you were only talking about the sand bed.JUDGE ABRAMSON:
No.MR. TAMBURRO:
If you're talking about the entire drywell, then 95 percent would be more appropriate in my opinion, a more appropriate
--MR. WEBSTER: Judge, I think maybe there is also some misunderstanding.
I think the GE analysis does it, assumes .736 in the sand bed region, not over the whole shell.JUDGE ABRAMSON:
Dr. Mehta, which way is it?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.WASHINGTON, D.C. 20005-3701 (202) 234-4433 www.nealrgross.com 635 1 DR. MEHTA: Your Honor, in the sand bed 2 region, we used 736 mils. The rest of the other areas 3 were different thicknesses.
4 JUDGE ABRAMSON:
Okay, I'm glad we got 5 that clarified.
So the uniform degradation is not the 6 whole shell, it's just in the sand bed region.7 DR. MEHTA: That is correct, sir.8 JUDGE ABRAMSON:
So in any case, so let's 9 come back and let's address what you think is the 10 situation of degradation in the sand bed region. What 11 percent, and now I can see why Mr. Webster said wait 12 a minute, it's not such a big number. What percentage 13 of the sand bed region does the Applicant estimate is 14 not materially degraded, say still remains greater 15 than an inch?16 MR. TAMBURRO:
Okay, my previous 80 17 percent. I was assuming that you were talking about 18 within the 800 to 900 hundred mil range. If you're 19 saying what percentage of the sand bed is still at its 20 nominal thickness
--21 JUDGE ABRAMSON:
Or near., 22 MR. TAMBURRO:
Or near its nominal 23 thickness then there are four bays which have evidence 24 of no wastage at all. So 50 percent would have no 25 wastage.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 636 1 JUDGE ABRAMSON:
And other bays have a 2 variation of ways of degradation, and we've heard 3 about that.4 MR. TAMBURRO:
Yes, sir. That's why I 5 originally said 80 percent.6 JUDGE ABRAMSON:
So anyway, the point I 7 would like to clarify for the record is I don't, it 8 seems to me that nobody, and I thought I heard 9 Citizens say' this, nobody argues we're really 10 approaching the uniform degradation barrier at this 11 point. Is that correct?12 MR. WEBSTER: We have in pre-trial 13 testimony, we have actually put in testimony that 14 shows for the external data, the 95 percent confidence 15 limits do approach or in some cases go below the 16 uniform.17 JUDGE ABRAMSON:
Based on the external 18 data?19 MR. WEBSTER: Based on the 95 percent 20 confidence limits, the lower 95 percent confidence 21 limits.22 JUDGE ABRAMSON:
From the external?23 MR. WEBSTER: For the external, that would 24 be, yes.25 JUDGE ABRAMSON:
And your calculations are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 637 1 based on the internal data. Is that correct, Mr.2 Tamburro?3 MR. TAMBURRO:
Yes.4 JUDGE ABRAMSON:
Okay, I think I 5 understand that. So now to come back to what I want 6 to hear from Dr. Harlow. The big focus yesterday was 7 on the, why can I never remember this, the small area 8 criteria.9 MR. POLONSKY:
Local buckling criteria.10 JUDGE ABRAMSON:
The local buckling 11 criteria, which is being computed on a basis of the 12 external data. So talk to us for a few minutes about 13 the statistical significance, the fact that there is 14 limited data and how that should affect our 15 interpretation of the meaningfulness of that data.16 DR. HARLOW: Well, it's my understanding 17 --18 JUDGE ABRAMSON:
Get a little closer to 19 the mic, please?20 DR. HARLOW: It's my understanding that 21 all of that data, the way it is being used by AmerGen 22 is to look at each point individually.
So as a 23 result, you're looking at the pressure criterion or 24 membrane criterion, or you're using this local 25 buckling criterion.
So as a result, statistics, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
* o v 638 1 way you normally think of it doesn't really come into 2 play.3 However, if you were to assume that the 4 106 data points were representative of thin areas, so 5 they're biased thin, you could do statistics on that 6 amount of data and 106 data points is a reasonably 7 fair number of points. But again, the distribution 8 and the statistics that you would do would be a 9 conditional distribution, conditioned on the fact that 10 you're looking at thin areas. It is not 11 representative of the whole region or any bay or the 12 whole sand bed region. So you would have to keep that 13 'caveat there.14 JUDGE ABRAMSON:
Okay, but I am 15 particularly struck by your first comment that we're 16 looking at it point by point and we're using the, each 17 particular measurement to make a comparison to the 18 local buckling criteria or to the pressure criteria.19 Is there any information that you can gain 20 from the fact that there are 106 instances of that 21 measurement that helps you understand the accuracy of 22 any one measurement?
23 DR. HARLOW: I actually did sort of to 24 satisfy my own curiosity, I did do statistical 25 analysis on those data comparing the 1992 measurements NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701*
www.nealrgross.com 639 1 with the 2006 measurements.
Turns out that you have 2 a couple of options. You can use a Gaussian or normal 3 distribution, and it represents that data quite well.4 Or you can actually use extreme value statistics to 5 characterize that data.6 In both cases, if you do that, just 7 looking again at these conditioned on being thin data, 8 you really are not close to the 736 or the 490 for the 9 pressure criterion.
10 JUDGE ABRAMSON:
530? What's a -- oh, the 11 pressure criterion.
Okay.12 (Pause.)13 MR. WEBSTER: Just as a point. If that 14 analysis hasn't been disclosed, we would like 15 disclosure of that analysis.16 JUDGE ABRAMSON:
Well, I am asking, I'm 17 asking Dr. Harlow to describe what one could learn 18 from this so if there is any written -- is there a 19 written product anywhere?20 DR. HARLOW: Not with me.21 MR. WEBSTER: Sorry, but is there written 22 product at your office?23 DR. HARLOW: Yes.24 JUDGE ABRAMSON:
Is it written in a way 25 that it can be usefully understood by us or is it a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 640 1 set of notes?2 DR. HARLOW: it is primarily a set of 3 notes and it is a figure. It is a graph.4 JUDGE ABRAMSON:
I think what I'm trying 5 to understand is we had a lot of arguments yesterday 6 about whether this external data is accurate.
Can you 7 tell us, if I looked at one particular, let's take one 8 particular point. Let's say we took the point where 9 this was closest to the local buckling criteria and we 10 took that measurement.
Does the fact that you have 11 all these other measurements give you some idea of the 12 uncertainty in that particular local measurement, 13 which is what I thought I heard. I'm not sure what I 14 heard now.15 Your first answer was, well, you're 16 looking at each point locally and so you can't tell 17 much from the fact that there are other measurements.
18 Maybe what I should ask is this: do you have any 19 information that tells you about what uncertainties 20 associated with each individual measurement?
21 Obviously, this is what we're worried 22 about, right? They measure one point. They're using 23 that to compare it to a certain criteria.
What can we 24 tell?25 From one measurement, there is whatever is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 641 1 the instrument of uncertainty and what they did by 2 noodling around with where the probe was.3 DR. HARLOW: Yes, so as a result if you 4 are only looking at one exterior point, I don't think 5 you would be able to hone in on that very well.6 However, because again, it is my limited 7 understanding, the way that they do the measurements 8 internally, there are roughly 49 measurements in a 9 small grid, you can. better assess what that 10 uncertainty is and for internal measurements on those 11 grids, the amount of scatter is relatively small so --12 JUDGE ABRAMSON:
The internal measurements 13 are fine. But if the calculations for whether we're 14 approaching, what this panel is all about is how much 15 margin do we have left before we get to the local 16 buckling criteria, because that's going to be used in 17 combination with a corrosion rate, whatever that is, 18 to compute what's an appropriate frequency of 19 measurement.
20 So we need to have this first value tied 21 down reasonably well. It is our starting point, and 22 the starting point is current condition which is based 23 on these measurements and as I understand it, Mr.24 Tamburro, correct me if I've got this wrong, but as I 25 understand it, our starting point for local buckling NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 642 1 criteria is these external data point measurements 2 only. Is that right?3 MR. TAMBURRO:
And their spatial 4 relationship where they are located, where they are 5 located from each other.6 JUDGE ABRAMSON:
Right, because you used 7 several sometimes to determine.
Okay, we understand 8 that part pretty well.19 So what information do we have? Is it 10 each of these points is in a different location and 11 each of these points, we don't, yes, you said if you 12 make the assumption they're in locally thinned areas 13 and they were all ground down to be able to put the, 14 is that right? These were all ground down, the 15 surface was ground to be able to put the probe in and 16 that creates, what's the right word, it biases the 17 data toward a thin site because you took some material 18 off, but it also, Mr. Tamburro, is there any way to, 19 do we know whether the grinding is uniform from spot 20 to spot?21 MR. TAMBURRO:
No, sir.22 JUDGE ABRAMSON:
So there is a huge 23 variation in the grinding which could account for 24 variation in the data from point to point. So if we 25 tried to use these data, these thickness measurements NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 643 1 from point to point, what information would we be 2 gaining about any individual point when we don't know 3 how much was ground off to begin with?.4 DR. HARLOW: I think you would have to 5 trust the UT measurement and the operator to try to 6 estimate how much variability there is in the true 7 measurement.
And like I said, the only way that I 8 know to check that would be to compare it with 9 internal measurements where you have a sufficiently 10 large number to hone in on that.11 JUDGE ABRAMSON:
So what you're suggesting 12 is that for an individual measurement, we can get some 13 information about how accurate that is by looking at 14 how accurate the external thickness measurement was by 15 looking at the internal measurements where there were 16 a lot of points close together, so we can estimate 17 what actually was going on in a measurement itself.18 DR. HARLOW: Yes, sir.19 JUDGE ABRAMSON:
So that leaves us now 20 with 106 external points, each measured in area that 21 was ground down and ground in a way that we don't know 22 how much material was taken off in any point. And 23 we're talking mils here, so I think I heard yesterday 24 that the grinding was somewhere between 100 and 200 25 mils based on testimony from Mr. Hawkens or somebody NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross~com 644 1 who had done the measurements.
Is that correct?2 MR. TAMBURRO:
That was my testimony.
3 JUDGE ABRAMSON:
Your testimony?
4 MR. TAMBURRO:
Yes, sir.5 MR. WEBSTER: Judge, could just clarify.6 The foundation of the testimony was from measurements 7 taken around the grinding spot, but I don't think it 8 shows that the thinnest spot was ground by one to two 9 hundred mils.10 JUDGE ABRAMSON:
No, it doesn't. What I'm 11 trying to get a handle on is how much variation is 12 there in the amount of-grinding from point to point, 13 because we're trying to get some statistical 14 information out of 106 measurements which are trying 15 to measure the thickness of something down to mils and 16 we've got a variation of something like a 100 mils in 17 the amount of grinding.18 If I told you I had 100 points and I 19 didn't know any of them to within a 100 mils, Mr.20 Harlow, what would it tell you about the statistics 21 that I could gather from that? I would have to put in 22 100 mils uncertainty on each point. Isn't that 23 right?24 DR. HARLOW: Yes, if you were trying to 25 compare the thickness to the original thickness.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 645 1 JUDGE ABRAMSON:
Or if I'm trying to get 2 statistical information about the actual thickness of 3 the nearby unground material, which is what this is 4 being used for. Right? We're trying to estimate the 5 actual remaining thickness of the liner, and it is not 6 what's been, it's not what's left after you grind 100 7 mils off or 200 mils off. It's what is there. They 8 had to grind it to get this. So now we're being told 9 that you get 100 points and they ground off between 10 100 and 200 mils to get the surface flat enough to 11 make a measurement.
12 MR. WEBSTER: Judge, could I just clarify?13 I don't think that's, maybe you can clarify. I don't 14 think the testimony is that they grind the thinnest 15 point thinner by 100 to 200 mils.16 JUDGE ABRAMSON:
The testimony is that 17 they don't know how much they ground off at any point.18 Is that --19 MR. POLONSKY:
I think that's correct, 20 Your Honor. I just want to make sure we're all clear, 21 because I think you just mentioned it. But the Carbon 22 UT measurements were taken after the grinding, so the 23 measurements currently taking already take into 24 account the removal of whatever metal was removed, 25 even though we don't know the amount at each spot that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 646 1 was removed.2 JUDGE ABRAMSON:
Yes, that's the point.3 The point I'm making is we've got 106 measurements and 4 they vary, they vary from each other because the 5 thicknesses, the original thickness varied and because 6 there was 100 to 200 mils ground off and we don't know 7 how much.8 MR. WEBSTER: Judge, I guess I would 9 characterize the testimony that it is between 0 and 10 100 mils ground off.11 JUDGE ABRAMSON:
I think it may be between 12 0 and 200.13 MR. WEBSTER: Well, okay.14 MR. POLASKI: Your Honor, just to try to 15 elucidate on this a little more. In 1992, when they 16 took the original readings, there were 19 or 20 of 17 those external-readings that measured less than 736.18 Those were --19 JUDGE ABRAMSON:
Those were 736 after some 20 grinding.21 MR. POLASKI: After some grinding, because 22 they had to grind and then they took the UT readings.23 JUDGE ABRAMSON:
I'm sorry, let me 24 interrupt one more time. Do we know how much they 25 ground off?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 647 1 MR. POLASKI: Those that were less than 2 736 were measured in 1992 were, micrometer readings 3 were taken of the depth of the depression and those 4 were the ones that we discussed yesterday and the 5 numbers range from 100 to 200 mils and specifically 6 Mr. Tamburro has the information in Calc 24?7 MR. TAMBURRO:
Exhibit 16, Your Honor.8 That's the Calc 24, revision 2.9 JUDGE ABRAMSON:
Okay, and those numbers 10 indicate that the amount, this is based on micrometer 11 readings of the depth. Now, let's all remember that 12 you've got a rough surface to begin with and you're 13 putting a ruler basically against the rough surface 14 and then you're pushing a probe into the hole and 15 you're trying to measure how deep that probe goes in.16 Well, a lot of that depends on how well you get it on 17 the surface too and how rough the surface is.18 So what we're finding is numbers that vary 19 between 100 and 200 mils from that. Maybe you ground 20 off 200 mils from the highest point on the rough 21 surface and maybe you only ground off 20 mils from the 22 lowest point on the rough surface because you're 23 laying a ruler on the rough surface.24 So what I'm trying to understand is we've 25 got 100 data points and I'm trying to get a handle on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 648 1 whether there's any statistically meaningful way to 2 compare these things when we've introduced error of 3 something like 0 to 200 mils on these points to begin 4 with and whether statistical analysis of these points 5 will have any meaning at all for us.6 I guess that's my real question, Dr.7 Harlow, and I think you sort of said that in your 8 first comment and then you came back and said well, 9 you've done some statistical analysis, but 'what I'm 10' wondering is it useful?11 DR. HARLOW: No, not relative to what's 12 remaining in the dry well thickness.
What that data 13 tells you, and what you can do is to measure what 14 exists today which means it has been ground and 15 etcetera, etcetera.16 JUDGE ABRAMSON:
So you can use it to look 17 at continuing degradation or something, but to compare 18 these 106 points you'd have to' get meaningful 19 comparison, you'd have to know how much was ground off 20 of each one. But' let me come at it at another way.21 If I asked you how much variation there was between 22 these 106 points in thickness, can you give me a 23 ballpark number which led you to try to do statistical 24 analysis?
Was there variation by more than 100 mils?25 DR. HARLOW: No.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 649 1 JUDGE ABRAMSON:
So there's variation 2 among these 106 points by less than 100 mils, and yet 3 we ground off 100 to 200 mils to begin with and we 4 don't know how much. So the variation among the 5 points could well be caused by differences in the 6 grinding and not by differences in remaining thickness 7 at all.8 MR. WEBSTER: Just to give you a range on 9 the external measurements, I *think the maximum 10 external measurements are around the nominal thickness 11 and the minimum measured data is around .06..12 JUDGE ABRAMSON:
Is that accurate?13 MR. POLASKI: Yes, that's accurate.
The 14 thinnest point was about 602 mils and the thickest, 15 there were some readings taken at the higher 16 elevations in the sand bed region where corrosion had 17 not occurred, just to check thickness.
So --18. JUDGE ABRAMSON:
Let's talk about the 19 corroded region which is where we're trying to do.20 Okay, I appreciate that. If you include the non-21 degraded areas in the non-degraded
-- the measurements 22 in the non-degraded areas when you do this 23 calculation, then you introduce additional what do you 24 want to call it, additional variability in data which 25 is intended to look at thinned areas.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 650 1 MR. WEBSTER: I think that's another 2 misapprehension is that some of this -data is taken 3 deliberately at the nominal thickness areas.4 JUDGE ABRAMSON:
It makes sense because 5 you want to know where --6 MR. WEBSTER: That's right. I'm not 7 saying it doesn't make any sense. I'm saying that 8 it's important when you look at these 104 points or 9 whatever they are to remember they're not all in the 10 thin spots. Some of them are designed to be in the 11 thick spots and some of them are designed to be in the 12 thin spots.13 JUDGE ABRAMSON:
I think that's good. So 14 in the end what it sounds like is we really can't get 15 any statistically meaningful information out of the 16 fact that we have a data set because the variation 17 introduced in individual measurements is quite 18 significant.
In fact, it's -- it could be as much as 19 a third of the threshold that you were worried about, 20 right? Two hundred mils out of 700. It's almost a 21 third. Certainly more than a quarter. Two hundred 22 out of 800 would be a quarter. So 200 out of 700 is 23 more than a quarter. So in the end-when we're trying 24 to understand the meaningness of the external data, it 25 comes back up to Harlow to looking at individual data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 651 1 points and trying to understand the error in that 2 data.3 DR. HARLOW: Yes, sir.4 'JUDGE ABRAMSON:
By comparing it to the 5 error in measurements from clustered internal data 6 which tells us something about how accurate the 7 instrument is and how accurate the instrument user is.8 DR. HARLOW: Yes, sir.9 JUDGE ABRAMSON:
Okay, that's very 10 helpful. Thank you. I'm sorry for this long ii diversion, but Dr. Hausler, do you want to add 12 anything to this? Does this all make some sense to 13 you? It seems to me to be consistent with what you 14 were talking about yesterday about the paucity of data 15 and the difficulty of interpreting it?16 DR. HAUSLER: Yes, sir. Your Honor, what 17 I would like to add is this, that.I think we did talk 18 yesterday I think with Judge Baratta about the 19 reproduceability of the measurement.
We do have an 20 idea as to what the variability of a single 21 measurement point might be. We do not know, however, 22 as you clearly pointed out, that we have no idea how 23 much was ground off.24 The other thing that I would like to add 25 is that again, we talk about the 106 points or 109 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 652 1 points, not all of them have been ground. That's the 2 first comment I would like to make.3 The second point is that they represent a 4 relatively small area, 'again, of the entire bay. Just 5 to put this in perspective, Mr. Tamburro has 6 calculated that the internal grids represent roughly, 7 I believe, a half of a percent of total sand bed area 8 and that the external areas that have been explored by 9 UT measurements are not more than five percent. I 10 think it's perhaps of the order of two percent.11 So when we talk about trying to project 12 maybe maximum damage from a relatively small area of 13 exploration, we may be, able to use extreme value 14 statistics as Dr. Harlow pointed out, but again, we 15 would have to use it with some caution. In that 16 context, I would like to perhaps, this is the moment 17 to do it, to bring to your attention an example of 18 extreme value statistics.
19 JUDGE ABRAMSON:
I think you've provided 20 some examples in your written testimony.
21 DR. HAUSLER: That's correct.22 JUDGE ABRAMSON:
So if you just want to 23 repeat that, that's not necessary.
We have it in 24 writing.25 DR. HARLOW: Okay.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 653 1 MR. WEBSTER: Would you like to know where 2 that is, Judge?3 JUDGE ABRAMSON:
Yes, if you want to show 4 us where that is in your testimony, you can just give 5 us the reference and we can look at it. But I 6 remember seeing it --7 DR. 1AUSLER: No, I have it in front of 8 me. It is Exhibit C, Attachment, I believe 2.9 JUDGE ABRAMSON:
Okay, thank you very 10 much.11 DR. HAUSLER: We probably might be able to 12 project --13 JUDGE ABRAMSON:
That's okay. We don't 14 need to go through it again. We have it in writing.15 The purpose here is to try to fill in some gaps in our 16 understanding, not to repeat what we've already seen 17 in writing.18 DR. HAUSLER: I think there is perhaps a 19 point that I might make and that is how one comes from 20 a relatively small amount of data to a project that 21 would indicate that -- I mean an estimate that would 22 indicate a value if one had, in fact, made more 23 measurements.
24 JUDGE ABRAMSON:
We're familiar with that 25 technique, Dr. Hausler, but I would ask is how NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 654 1 affected would those projections be by an uncertainty 2 of 200 mils in each data point caused by the grinding, 3 the variability in grinding?
In other words, what 4 would it do to the projections?
5 DR. HAUSLER: Well, that is something that 6 we have explored in the statistical calculations, but 7 my estimate is by that very same amount, which seems 8 like a good first guess.9 JUDGE ABRAMSON:
Okay, thank you very 10 much.11 MS. BATY: Judge Abramson, if I may, you 12 were asked about whether there was a finite element 13 analysis of the current condition of the drywell 14 shell. Would you like the staff to address that issue 15 and how it was treated during the license renewal 16 review?17 JUDGE ABRAMSON:
Yes, that might be very 18 useful to us. Is Mr. Ashar who has done that?19 MR. ASHAR: Hansraj Ashar. Yes, sir.20 JUDGE ABRAMSON:
Do you want to --21 MR. ASHAR: Yes, I had a contract with 22 Sandia National Lab which did the independent study, 23 it was a confirmatory study.24 JUDGE ABRAMSON:
Okay, we've seen the 25 Sandia study.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 655 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 MR. ASHAR: oh, you have seen it.JUDGE ABRAMSON:
So that's --MR. ASHAR: If you want to know something more about it, I can --JUDGE ABRAMSON:
I think we've read the report and we've had comments about it and we appreciate the comments that Sandia made about it, so MS. YOUNG: Judge, may I hand the staff's SER to Mr. Ashar to refer to?JUDGE ABRAMSON:
For what purpose?MS. YOUNG: To refresh his recollection, because I don't believe he answered the question correctly.
JUDGE ABRAMSON:
Okay.(Pause.)MR. ASHAR: I think, Mitzi, you are thinking about the feature performed by --is that what you are --MS. YOUNG: Yes.JUDGE ABRAMSON:
That's not where we're going.MR. ASHAR: That's not where we are going.JUDGE ABRAMSON:
We're only interested in did somebody look at the -- in the current condition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 656 1 and I understand that Sandia did that.2 MS. YOUNG: I don't believe this is on.3 I don't know if you can hear me.4 JUDGE ABRAMSON:
I hear you., 5 MR. ASHAR: And if you read the Sandia -6 MS. YOUNG: There's a commitment by the 7 licensee that they made during the review to do a 8 future analysis.
And as part of the ACRS report, the 9 ACRS specifically asked the staff to include a license 10 condition, asking the licensee to do that future 11 finite element analysis using the current condition of 12 the -13 JUDGE ABRAMSON:
Oh, I see.14 MS. YOUNG: That's the only -15 JUDGE ABRAMSON:
When is the -16 MS., YOUNG: I'm not trying to testify, I'm 17 trying to --18 JUDGE ABRAMSON:
That's okay, because in 19 the ACRS report -- is that okay, Mr. Webster?20 MR. WEBSTER: Absolutely.
That's 21 absolutely a license condition that requires a fire 22 element analysis.23 JUDGE ABRAMSON:
Does anybody recall when 24 that is to be done? Is that before the renewal?25 MS. YOUNG: The condition is summarized NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 657 1 very succinctly on page 1-18 of the SER. And the ACRS 2 report is Exhibit 3 of the staff.3 JUDGE ABRAMSON:
Thank you.4 MR. GALLAGHER:
Judge Abramson, this is 5 Mike Gallagher from AmerGen. Yes, that analysis --6 our commitment is to complete that analysis before the 7 period of extended operation.
8 JUDGE ABRAMSON:
Before the commencement 9 of the extended operation.
10 MR. GALLAGHER:
That's correct.11 JUDGE ABRAMSON:
Okay. Thank you. That's 12 very helpful.13 I assume that somebody is going to have to 14 do a lot of measuring to be able to do that, right?15 Wasn't one of Sandia's comments that a lot of unknown 16 information in order to do the calculation, is that --17 MR. GALLAGHER:
Well, we're going to use 18 the existing measurements we have. We feel we have --19 JUDGE ABRAMSON:
For that degradation.
20 You have enough other measurements about the rest of 21 the shell and the loads and such?22 MR. GALLAGHER:
Yes, we have all that. So 23 it will be a complete 3D model.24 JUDGE ABRAMSON:
Great.25 CHAIRMAN HAWKENS: Could you please NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 658 1 explain to a layman, I am familiar with that 2 commitment and I've been curious as to what exactly a 3 three dimensional analysis is and if you would explain 4 to me what, after performing it, and this will be done 5 before the renewal period, what you'll have and what 6 that will tell you?7 MR. GALLAGHER:
Yes, Judge. Our 8 expectation is, and if you looked at the -- if you can 9 look at the ACRS transcript, it's very clear that our 10 expectation is that it would show in the current 11 condition that we have more margin than a safety 12 factor of two.13 MR. WEBSTER: Judge, I object to this. I 14 think this is speculative.
15 JUDGE ABRAMSON:
It is.16 MR. WEBSTER: It is speculative.
17 JUDGE ABRAMSON:
We' agree that it's 18 speculative.
Nobody knows what will be the result.19 It will give you -- it will computer a safety margin.20 MR. GALLAGHER:
It's not inspeculative 21 because just as we've been testifying here, the 22 current model which is conservative, is a uniform 23 thickness of 736 mils in the sand bed region. This 24 would take account of the thicknesses that we actually 25 have.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.II (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 659 1 MR. WEBSTER: I'll object to that 2 characterization.
3 MR. GALLAGHER:
If you have above the area 4 of corrosion
--5 CHAIRMAN HAWKENS: Objection is overruled.
6 What I'm looking for I want to know exactly what 7 you're going to use to create this three-dimensional 8 model. Are they additional data points you're going 9 to get or are the data points from the prior points 10 you've already taken them which you'll take again in 11 2008 to create this 3D model?12 MR. GALLAGHER:
The inputs are the 13 thicknesses we've already measured.14 CHAIRMAN HAWKENS: Which you'll retake in 15 2008.16 MR. GALLAGHER:
We will retake those in 17 2008.18 CHAIRMAN HAWKENS: To create this model.19 JUDGE ABRAMSON:
Well, and also there are 20 a lot of other measurements they'll need to use.21 MR. GALLAGHER:
There's other factors they 22 need and Dr. Mehta can go into that. GE is not doing 23 the analysis, but a 3D model, it's all the things you 24 need in there. You need the thicknesses of all the 25 other plates in the drywell. You need the loads that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www~nealrgross.com 660 1 are on all the penetrations and things like that. The 2 actual geometries and it's a 360 degree model so that 3 we don't have to make asymmetry assumptions.
We can 4 model it exactly and it will have a finer mesh because 5 the computers today are able to do that better.6 JUDGE ABRAMSON:
Just let me comment Mr.7 Webster. Part of the reason we're all comfortable 8 with letting this kind of information in in addition 9 to the fact that it gives us some information is as we 10 have said in numerous of our written orders, we give 11 testimony the weight we think it deserves and we.12 understand what this is saying to us, so did you get 13 what you needed, Judge Hawkens, about a 3D model?14 Okay,, thank you. Thank you, Mr. Gallagher.
15 CHAIRMAN HAWKENS: I have a question for 16 AmerGen regarding Dr. Hausler's testimony that in his 17 opinion there's at least one area in the drywell shell 18 that will exceed the pressure criteria.
Can you 19 address that? Are you aware of any locations that 20 approach that limiting criteria?21 MR. TAMBURRO:
This is Peter Tamburro.22 None of the data even comes close to or approaches the 23 490 mil criteria.24 CHAIRMAN HAWKENS: And can you tell me why 25 -- what problem then do you see in Dr. Hausler's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
.1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 661 1 analysis?2 MR. TAMBURRO:
This is Peter Tamburro 3 again. He extrapolates data. He uses improper 4 statistics to look at only the lowest hypothetical 5 measurements and that's not supported by the data.6 CHAIRMAN HAWKENS: Did you provide written 7 testimony to that effect or can AmerGen point to where 8 in their written testimony, so we can have easy access 9 to that?10 MR. POLONSKY:
Are you asking us 11 specifically about the 490?12 CHAIRMAN HAWKENS: Yes.13 MR. POLONSKY:
We'd have to look at the 14 Exhibit C, attachment
: 2. I don't think we were given 15 a page reference and then look where we responded to 16 in our testimony.
17 JUDGE ABRAMSON:
What we're interested in 18 is we asked Dr. Hausler and his counsel to advise us 19 where they raised this question.20 MR. POLONSKY:
Yes.21 JUDGE ABRAMSON:
And rather than go in 22 depth into it in this proceeding, unless there's some 23 specific questions we have, if you've already 24 addressed that -- those assertions by Dr. Hausler, 25 we'd like to just know where and if it takes you some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 662 1 time, you can tell us at noon.2 MR. POLONSKY:
We can provide that. I 3 think Mr. Tamburro in pretrial testimony certainly has 4 said that the thinnest measured point in 2006 was 5 somewhere above 600. We don't have any single point 6 below that. So that's, I think --7 MR. TAMBURRO:
The thinnest point measured 8 in 2006 was in bay.13.7 and it was measured at 602 ,9 mils.10 MR. WEBSTER: I don't think that was your 11 question, was it, Judge? /12 JUDGE ABRAMSON:
I'm not sure --13 MR. POLONSKY:
That's in the testimony.
14 So that's the response to 490, then that's the 15 response.
We can identify that answer for you.16 MS. BATY: Your Honors --17 CHAIRMAN HAWKENS: It would be helpful if 18 there's anything additional that he wants to provide 19 a reference to later on in this hearing, we'd 20 entertain that. Thank you.21 MS. BATY: Your Honors, may I interject 22 that it could be that the issue of the .490, the 23 challenging of the -- whether they meet the pressure 24 criteria might have been addressed in a motion in 25- limine as well as exceeding the scope of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com w
663 1 contention, of the admitted contention which was 2 buckling, the buckling criteria.
So that might be 3 just another -- I just wanted to interject that that 4 might be a place to look for --5 JUDGE ABRAMSON:
Unfortunately, looking at 6 motions in limine isn't going to answer a technical 7 question, if a technical question was raised earlier 8 and that's why I'm looking to see whether the'record 9 has, what we're hearing from Citizens now is that 10 they've raised this question and the question for us 11 is has it been technically addressed.
12 I understand that part of the answer is 13 that there are -- that part of the reason that Dr.14 Hausler got that number is the statistical approach he 15 took to analyzing the data and that I understand is in 16 the record. Is that correct or is it not? Is it only 17 in motions in limine because motions in limine to 18 exclude testimony don't help us understand if it's a 19 technical question that's been addressed, then we need 20 to deal with it. And if what you're saying is we've 21 already excluded that, then show us where we've 22 already excluded it or if it's one of those things 23 that we said we'll give it the weight we think it's 24 worth, which seems -- which I believe is our general 25 approach to things, since we think we can understand NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 664 1 technical matters reasonably well.2 MR. WEBSTER: Well, let me -- this is part 3 of the record. It was not one of the elements on the 4 few elements that was redacted from Dr. Hausler's memo 5 so it's definitely raised in the record.6 JUDGE ABRAMSON:
Okay, and so if it's been 7 addressed
--8 MR. POLONSKY:
At a break or lunch we will 9 provide --10 JUDGE ABRAMSON:
Why don't you see what 11 you can find and then we'll move from there. Thank 12 you.13 MS. BATY: Yes, because Your Honors, it 14 may be a matter of an argument that it was outside the 15 scope of the admitted contention.
16 JUDGE ABRAMSON:
We understand.
We 17 understand, Ms. Baty.18 MS. BATY: That's why we would like to get 19 back to you on that. Thank you.20 JUDGE BARATTA: I think we've found it.21 If you look at our order of August 27th, there's a 22 reference
-- I'm sorry AmerGen's motion of August 23 27th, there's a reference there, although it looks 24 like the cite might be incorrect on page 7. Citizens'25 argument that there's likely to be a spot thinner than NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 665 1 0.49 is impermissible.
And it goes on to discuss why 2 and the .49 appears to come from his analysis of 3 extreme value, using the extreme value statistics 4 where you project out.5 Answer 17.6 MR. WEBSTER: To be clear, AmerGen moved 7 to strike this testimony and that motion was denied.8 So the testimony is therefore admitted.9 JUDGE ABRAMSON:
That's the way it usually 10 works.11 MS. BATY: Your Honor, we would like the 12 opportunity to verify that it was ,- you said you'd 13 give it due weight. Because I think that might be a 14 more accurate reflection of what the Board's decision 15 was.16 JUDGE ABRAMSON:
Ms. Baty, let's let the 17 parties move on. As we said, let's at a break or by 18 lunch, let's ese what there is in the record and then 19 we'll come to grips with it from there.20 JUDGE BARATTA: For Dr. Harlow, have you 21 had a chance to look at his -- Dr. Hausler's analysis 22 that was done using extreme value statistics?
23 DR. HARLOW: The answer to that is no, 24 because although there has been repeated mentions of 25 extreme value statistics, it was never really NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 666 1 explained what that meant statistically.
So I don't 2 have any idea what they mean when they say extreme 3 value statistics.
4 MR. WEBSTER: Well, could I refer Dr.5 Harlow to the record? Again, it's Exhibit C, 6 attachment 2, page 12 provides the graph. And that 7 tells you precisely what is meant by --8 JUDGE ABRAMSON:
And Dr. Harlow's answer 9 was crystal clear. He hasn't looked at it.10 MR. POLONSKY:
Could I follow, up with a 11 question with Dr. Harlow, Mr. Abramson?12 JUDGE ABRAMSON:
You may. Judge Abramson.13 MR. POLONSKY:
I'm sorry, Judge Abramson.14 JUDGE ABRAMSON:
Or Dr. Abramson.15 Or Your Honor, not Mister.16 MR. POLONSKY:
My apologies.
Dr. Harlow, 17 is the question that you don't know what distribution 18 he used in his extreme value statistics?
Is that the 19 question that you had?20 DR. HARLOW: The qudstion is -- there is 21 a well-documented old area of statistics called 22 extreme value statistics.
It was started in 1928 by 23 Fischer and Tippit. There are three classical 24 distributions for maxima. There are three classical 25 distributions for minima. None of those had been used NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 667 1 that I have seen in any of the written record, so when 2 you talk about doing extreme value statistics, those 3 just have not been used.4 / JUDGE BARATTA: Dr. Hausler, would you 5 care to explain how you obtained the curve that 6 appears in Exhibit C2?7 DR. HAUSLER: From my understanding, the 8 extreme value statistics approach that has been used 9 in the oil field, for instance, in order to correlate 10 pitting are based on the double logarithmic 11 distribution.
This is described in the literature.
12 We have discussed it in the expos6 that we wrote for 13 the panel of Judges with respect to question about 14 statistics.
We've mentioned in there. We've 15 presented a graph here that can easily be -- well, 16 it's not easily explained because the parameters are 17 although they're mathematical correlations, to put it 18 in layman's terms is not an easy thing to do.19 JUDGE ABRAMSON:
Did you provide a 20 reference where in your testimony, is there a 21 reference to the analytical techniques so that -- in-22 a way that could be understand by somebody?23 DR. HAUSLER: I believe we did.24 DR. HARLOW: Your Honor, I'm looking at --25 this is Figure 4. It's called extreme value NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS i323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 668 1 statistics for external UT measurements in bay 13.2 This is their Exhibit 3B.3 MR. WEBSTER: It's also -- it occurs 4 twice. It's Exhibit 38.5 DR. HARLOW: Yes. On the screen there.6 If you notice on the horizontal axis, there's no 7 indication of what that is. Also, on the vertical 8 axis, there's no indication of what that is. There's 9 a linear least square regression put through points, 10 but you don't know where those points came from. So 11 typically in corrosion, the two extreme valued 12 distributions that are most popular are the Gumbel 13 distribution for maxima and the Weibull distribution 14 for minima. So I'm not quite sure looking at that how 15 you could determine which of those has been used.16 There are no double logarithmic 17 distributions.
Gumbull distribution has two 18 exponentials in it. So again, I'm not sure what has 19 been done at this point.20 JUDGE ABRAMSON:
Mr. Webster, did you say 21 there was a reference to the technique or the 22 methodology somewhere in this report?23 MR. WEBSTER: Yes, on page 7 of this 24 report, there's a description of the methodology.
25 DR. HARLOW: Well, again, there's no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 669 1 equation there, so it's kind of hard to tell what 2 distribution is being used. There's a lot of verbiage 3 again about extreme value statistics, but again, we 4 don't know whether we're talking about maxima or 5 minima and if so, which of those distributions are 6 being used.7 MR. WEBSTER: Perhaps we can ask. Dr.8 Harlow did say he did some extreme value statistics 9 'himself earlier.10 JUDGE ABRAMSON:
Let's go back to Dr.11 Baratta who -- or Judge Baratta who has been pursuing 12 this line of inquiry and see whether he's got what he 13 wanted or needs some more.14 MS. BATY: Your Honor, could I -- do you 15 want to hear from the staff on this --16 JUDGE ABRAMSON:
Let's have Judge Baratta 17 pursue this. This is his issue.18 JUDGE BARATTA: I'd like to hear from the 19 staff because I'm still as confused as I was when I 20 asked the question.21 MR. SALOMON: I'm Art Salomon with the 22 staff. Your Honors, I believe either in a response to 23 your Board questions or in some previous testimony 24 regarding extreme value statistics we provided a 25 response that essentially agrees with what Dr. Harlow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 670 1 said, although I never heard of him or met him until 2 today, so this was developed independently.
3 The Weibull distribution was essentially 4 one of the first limiting it's a limiting value of 5 the minimum of a sample which was what would be used 6 in this case and I also agree with him that I saw no 7 evidence of the Weibull distribution used in it.8 That's the typical extreme value distribution used 9 when you're talking about the minimum and I assume 10 that in this case since they're referring to 11 thickness, they would be looking at the minimum of a 12 distribution.
13 JUDGE BARATTA: I am familiar with Weibull 14 distribution and it looks -- it should give you a 15 straight line when you do plot it on the Weibull graph 16 paper. But I was confused by your double logarithmic 17 as well. Are you referring to either the 18 distributions that were mentioned like Dr. Harlow?19 DR. HAUSLER: I believe the procedure we 20 used is based on the Weibull distribution.
21 JUDGE BARATTA: Based on it.22 DR. HAUSLER: Yes, I believe so.23 JUDGE BARATTA: You're shaking your head.24 DR. HARLOW: Well, if it is based on the 25 Weibull distribution, this is not the way you present NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com w
671 1 that data. Typically, a Weibull distribution on 2 Weibull graph paper, the slope is positive.
And 3 again, you would label the coordinates and if it's 4 Weibull probability paper, the horizontal axis would 5 be a log scale and the vertical axis would not be a 6 linear scale. So again, on this figure 4 you've got 7 a linear vertical scale, a linear horizontal scale and 8 neither one of those would be appropriate unless there 9 has been some transformation of the data and again, 10 there's no indication of what that transformation is.11 DR. HAUSLER: The transformation is in 12 what's called the reduced variant. And whether the 13 slope is positive or negative, simply depends on how 14 you position the vertical axis, The vertical axis and 15 the graph is pretty clear. It is, in fact, the 16 residual wall thickness.
The horizontal axis is what 17 is called the reduced variant. It is a double 18 logarithmic expression for the ranking of the data 19 which in the end comes out exactly the same thing as 20 what you described as Weibull graph paper. We haven't 21 used the graph paper. We have used Excel in order to 22 perform the calculations necessary to (a) ranking the 23 data; and (b) calculating what is called the reduced 24 variant.25 It was my understanding that these are in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 672 1 the statistical community pretty standard procedures.
2 JUDGE BARATTA: Any comment from the staff 3 or from AmerGen on that?4 DR. HARLOW: Well, my only comment is 5 there's a variety of distributions that you can do 6 this kind of analysis with. You have to specify which 7 distribution you're applying when you do this kind of 8 analysis.9 JUDGE BARATTA: It appears that he has, 10 namely used the Weibull distribution.
11 JUDGE ABRAMSON:
As I recall, he says he 12 thinks it's the Weibull distribution or to his 13 recollection it's the Weibull distribution.
14 MR. WEBSTER: I think that's appropriate.
15 I mean I think if we would like Dr. Hausler to confirm 16 that, I think he can revisit his calculations perhaps.17 I'll discuss it with him at the break whether we can 18 actually look at the calculations and double check.19 JUDGE BARATTA: That would be helpful if 20 you could do that at the break.21 I believe staff had -- and I apologize.
22 Would you give me your name? I have a terrible memory 23 for names.24 MR. SALOMON: Art Salomon. Salomon is the 25 last name.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 673 1 I just wanted to say that this notion of 2 the reduced variant at a minimum, the formula or 3 expression that was used to compute that should have 4 been presented.
Reduce variant can mean any number of 5 things, depending on the particular distribution and 6 when I saw it I had no idea what he was talking about 7 and I've used the Weibull distribution for perhaps 25 8 years or so and didn't recognize it from his --9 MR. WEBSTER: Judge, I can provide some 10 clarification.
I think what's happened is that we 11 presented this information at an earlier time and then 12 there was some issue about whether it was or wasn't 13 within the scope of the contention.
And then we 14 revived this work when the Board asked us about 15 extreme value statistics.
So I think if we on the 16 break, we can probably go back to the earlier more 17 full explanation of this material and then move on.18 Perhaps we might --I admit that was an additional 19 exhibit, if it's not admitted as an exhibit already, 20 then that would provide us a basis to go forward on 21 this.22 CHAIRMAN HAWKENS: Thank you. We're going 23 to go off the record for one moment.24 (Off the record.).25 CHAIRMAN HAWKENS: We are back on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 674 1 record.2 DR. HARLOW: Your Honor, if I could 3 please. This is Gary Harlow. I would just like to 4 clarify something that I may have given you the wrong 5 impression about. When I said I had not seen Dr.6 Hausler's work, I meant the underlying computations.
7 I have read his testimony and their exhibits.
I had 8 seen that, but I had not seen the underlying work that 9 he performed.
10 JUDGE BARATTA: Thank you for that 11 clarification.
12 I would like to leave this topic now and 13 go back to something we heard yesterday relative to 14 the inclusions that were apparently observed during 15 the UT measurements.
I know this was discussed 16 somewhat yesterday, but again, what we're trying to 17 determine was what is the margin, hence the questions 18 about the statistics that were used in predictions and 19 such.20 I think Dr. Hausler, you mentioned that 21 some of the UT measurements were discarded because of 22 some inclusions that were encountered.
23 DR. HAUSLER: That is what I understood, 24 yes.25 JUDGE BARATTA: Are you at all familiar NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 675 1 with any of. the standards as to whether, I mean, 2 typically I think this is the case. We'll have to ask 3 the Staff and the Applicant to confirm this, you know, 4 inclusions are expected..
Are you at all familiar with 5 any of the specs on that or anything like that?6 DR. HAUSLER: I'm not sure I understood 7 your statement.
Your conclusions are what?8 JUDGE BARATTA: You seem rather surprised 9 that there were some inclusions in there, and I was 10 just curious as to how familiar you are with the ASTM 11 specs that are used to purchase the material.
In 12 other words, did they, do you know if they allow for 13 inclusions or not?14 DR. HAUSLER: I can't comment on that. I 15 was surprised.
I think my comment was that I was 16. surprised at the frequency of inclusions, but I do not 17 know what the standard is for purchasing the material.18 No, sir, I don't.19 JUDGE BARATTA: Is there somebody on the 20 staff or the Applicant can maybe shed some light on 21 that?22 MR. McALLISTER:
This is Martin.23 McAllister.
I'm not a metallurgist, but I have done 24 ultrasonic inspections on rolled plate for laminations 25 and typically, that spec is like a three-inch circle.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 676 1 A lamination is allowed a not exceed.2 JUDGE BARATTA: Three inch diameter.3 MR. McALLISTER:
Yes.4 JUDGE BARATTA: Do you have any idea, 5 though, on the number that are allowed or anything 6 like that?7 MR. McALLISTER:
No, I'm only aware of the 8 one criteria.9 JUDGE ABRAMSON:
Let me follow this up for 10 a second.11 As I understand it, when a plant is being 12 designed and built there are specifications provided 13 for the materials, and the materials have to meet 14 those specifications when they are delivered.
Is that 15 correct?16 MR. POLASKI: Yes, that's correct.17 JUDGE ABRAMSON:
And do those 18 specifications include a specification on the maximum 19 number and size and distribution on inclusions to your 20 knowledge?
Does anybody know that?21 There are very specific kinds of 22 specifications for nuclear power plant components and 23 materials.
Let me have somebody who can speak to 24 that.25 MR. WEBSTER: Judge, to be clear, are we NEAL R..GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
.° 677 1 talking about in 1969 or --2 JUDGE ABRAMSON:
We can talk about the 3 time this was purchased.
That's when it is relevant.4 We should probably talk about that.5 MR. OUAOU: Your Honor, my name is Ahmed 6 Ouaou, and typically the specifications do not call 7 for inclusions.
When you specify is the material you 8 want to use.9 In this case, the drywell is SA212o It's 10 a type of material and you would expect inclusions if 11 you do not want inclusions in the material.
You 12 specifically
-- then you would have to specify I 13 believe a vacuum de-gas type of a plate which is not 14 this material.15 JUDGE BARATTA: Okay, so in other words, 16 you would expect to see some?17 MR. OUAOU: That is correct.18 JUDGE BARATTA: That's what I was trying 19 to get at.20 MR. OUAOU: Yes, sir.21 MR. DAVIS: This is Jim Davis from the 22 staff. The material was probably ordered in the '60s 23 and the standard steelmaking practice in that time you 24 would expect to see inclusions.
What the 25 specifications normally would be, these are ASTM NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 678 1 specifications.
Now we use SA which are ASTM 2 specifications in Section 2 of the code and they're 3 very similar to the ASTM standards.
But what you'd 4 normally specify as minimally yield strength, tensile 5 strength, elongation, a lack of cracks or laps, lack 6 of delamiantions, things of that type. But you 7 normally would not specify the number of inclusions.
8 But that would be normal in steelmaking.
9 JUDGE ABRAMSON:
And if the inclusions 10 were of a character to affect the physical strength 11 that then the material would be out of spec, right?12 You have specs that require that certain physical 13 properties of this material, right?14 MR. DAVIS: That's right. But they would 15 be -- you would expect to have these inclusions in 16 there and you would still meet the specifications.
17 You'd have to meet the --18 JUDGE ABRAMSON:
Physical strength, its 19 ability to withstand a membrane stress, its ability to 20 withstand buckling load. Those properties, the 21 physical properties are part of the specifications and 22 if the material, if the number of inclusions caused it 23 to be nonconforming from those specs, then it wouldn't 24 be accepted.
Is that correct?25 MR. DAVIS: That's correct, it would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 679 1 rejected.2 MR. WEBSTER: Just to be clear, Judge, I 3 think Dr. Hausler's testimony is going primarily to 4 the reason why the ASME code has a safety factor of 5 two which is partly taken account of these inclusions 6 and other defects in the material.7 CHAIRMAN HAWKENS: Thank you to Panel 3.8 We'll now sit Panel 4.9 Panel 4 is dealing with sources of water.10 MR. POLONSKY:
Judge Hawkens, I noticed 11 that Judge Abramson has stepped away, but there was a 12 follow-up that we had before we move off of Panel 3 to 13 specifically address a question that Judge Abramson 14 had asked. So if we could wait until he returns and 15 then we could quickly dispense with that, addressing 16 that question, we could then move to Panel 4.17 CHAIRMAN HAWKENS: That would be fine. It 18 will be somebody, an individual on Panel 3?19 MR. POLONSKY:
Yes, Fred Polaski and 20 potentially Pete Tamburro, if there is follow up.21 MR. WEBSTER: Judge Hawkens, may we have 22 a moment? We had said that we believe there's some 23 work from Dr. Hausler that Wasn't submitted as an 24 exhibit, but was submitted during the course of the 25 proceedings.
I haven't actually been able to find NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 680 1 that work in the break.2 Would you be interested in having that 3 submitted later or are you happy with the state of the 4 record as it is.5 CHAIRMAN HAWKENS: You say you have not 6 found it in the record yet?7 MR. WEBSTER: It is definitely
--8 CHAIRMAN HAWKENS: You believe it's in the 9 administrative record, but you haven't located it yet?10 MR. WEBSTER: I believe it's not in the 11 record as an admitted exhibit.12 CHAIRMAN HAWKENS: I understand.
13 MR. WEBSTER: But it is probably part of 14 the administrative proceedings.
15 CHAIRMAN HAWKENS: When you locate it, 16 just bring it to the Board's attention, please, some 17 time during today's proceeding.
18 MR. POLONSKY:
Judge Abramson, we have one 19 further thing to follow up with you, if we could, 20 regarding Panel 3 before we move to Panel 4.21 You had asked specifically whether there 22 was any information about the thickness of the drywell 23 shell near the bottom of the'sand bed region because 24 you were investigating what the margin, available 25 margin would be at that location?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 681 1 JUDGE ABRAMSON:
Yes, if you have 2 information that would be helpful.3 MR. POLONSKY:
Yes, Mr. Fred Polaski -- I 4 would just want him to address that before he ends his 5 participation in Panel 3.6 MR. POLASKI: This is Fred Polaski, Your 7 Honor. We looked at the availability of thickness 8 measurement data in the lower elevations of the sand 9 bed region near the floor and if you remember we had 10 shown in Exhibit 28 a map of all of the UT thickness 11 data taken. This is the one with the green rectangles 12 and yellow spots. And there was very few data points 13 in the lower elevations.
14 However, there are two areas where there 15 is UT information down at those lower elevations.
16 This is the trench data taken from the inside. And in 17 bay 17 which is the trench data that was more -- in 18 the area that was more severely corroded compared to 19 bay 5, we took a look at the lowest 6 inches of data, 20 the 6 by 6 grid at the bottom of that trench. And we 21 were able, in the calculations that have been 22 performed, and they're AmerGen's Exhibit 19 which is 23 eval 09, that the average thickness of the 6 by 6 grid 24 at the bottom of that trend was 965 mils average 25 w thickness, which comparing to the general buckling NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 682 1 criteria 736. gives you 229 mils of margin at that 2 elevation.
3 We'll note that the bottom of that trench 4 is at elevation 9 feet 3 inches. The floor is 8 feet 5 11. So it's close to the bottom. It's not exactly at 6 the floor level. But those are the lowest readings 7 we've got elevation-wise.
They're representative of 8 the corrosion in the most severely corroded bays.9 JUDGE ABRAMSON:
When we talk about 10 measurements that are in those trenches, that then is 11 a region where the drywell shell is supported on one 12 side by concrete except for the trench. Is that 13 correct?14 MR. POLASKI: Yes, that correct. It's 15 filled with -- actually during the construction, the 16 steel was welded in place and then the floor was 17 poured on the inside.18 JUDGE ABRAMSON:
So from a structural 19 point of view, let me ask Dr. Mehta, where the drywell 20 shell is supported on one side by concrete, what is 21 the effect of that concrete on the propensity to 22 buckle in that location, iLeo, is this a relevant 23 failure location?24 DR. MEHTA: Your Honor, we have bonding 25 conditions of the floor and as you can see in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgoss.com 683 1 buckling evaluation, the way it forms where the fixed 2 bonding condition, that's one point in that --3 JUDGE ABRAMSON:
So we have a floor on one 4 side of the shell in this region, but am I correct 5 that one side is not -- that the concrete level on one 6 side of the shell is lower than the concrete level on 7 the other side. Is that correct?8 Both of you stay up there, because we've 9 got to see if we can --10 MR. POLASKI: You are correct, Judge 11 Abramson.
The drywell has concrete on the inside up 12 to elevation 10.3 inches which is the floor level on 13 the inside.14 JUDGE ABRAMSON:
Okay.15 MR. POLASKI: On the outside, the concrete 16 only comes up to elevation 11 feet -- 8 feet 11 17 inches.18 JUDGE ABRAMSON:
And the trench was below, 19 it was down below, into that area, right?20 MR. POLASKI: It goes close to the bottom, 21 the bottom of the trench in bay 17 is elevation 9 feet 22 3 inches. So it's a couple inches above the floor in 23 the external surface.24 JUDGE ABRAMSON:
So now Dr. Mehta, when 25 you did the calculation, where was the fixed boundary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.-! (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 684 1 condition?
Was it at the top of the inside concrete 2 or was it at the top of the outside concrete?3 DR. MEHTA: Your Honor, I think it was 8 4 feet 3 inch which is at the lower level.5 JUDGE ABRAMSON:
Okay. Thank you. Okay, 6 so now come back to that. Sorry, come back to that.7 So the fixed boundary condition is that the bottom 8 where both sides are embedded, right? The inside has 9 cement, and we've got some measurements on the inside 10 below the top of the inside cement, but above the 11 fixed boundary condition.
Is that an area where 12 buckling failure is where the shell is likely or less 13 likely, more or less likely to fail in bucking than 14 say a midplane area where it's not supported?
15 DR. MEHTA: Your Honor, when we looked at 16 the lowest buckling mode, which is the lowest single 17 wave, that is -- that forms at the top of the sand bed 18 and then one complete wave coming back to the bottom.19 So essentially
--20 JUDGE ABRAMSON:
So the maximum amplitude 21 is several feet off that floor, is that right?22 DR. MEHTA: Several inches. Because the 23 height is about 40 inches, so 40 inches or so forms 24 one wave.25 JUDGE ABRAMSON:
A full wave. So a half NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com I
685 1 wave is 20 inches and to the peak amp is like 10 2 inches off the floor. And these measurements were 3 where, how high off the floor?4 MR. POLASKI: These measurements were from 5 four inches off the floor to ten inches off the floor.6 JUDGE ABRAMSON:
Okay, so it's in an area 7 where there is a peak.8 So it is relevant from a buckling point of 9 view and the numbers are -- this is -- how many 10 measurements to get this number?11 MR. POLASKI: Well, this was a six by six 12 inch grid, so there's --13 JUDGE ABRAMSON:
So there's 49 14 measurements.
15 MR. POLASKI: With an average of 965.16 JUDGE ABRAMSON:'
Thank you very much.17 That's very helpful.18 MR. WEBSTER: To be clear, Judge, the bays 19 where the external measurements show the lower 95 20 percentile confidence limit at or below the general 21 buckling criteria is not at bay 17.22 CHAIRMAN HAWKENS: Will counsel please 23 introduce the expert witnesses on topic four, sources 24 of water?25 MR. POLONSKY:
Yes, Your Honor, this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 686 1 Mr. Polonsky for AmerGen. For Panel 4, seated to my 2 right is Mr. John O'Rourke.
Seated to his right is 3 Francis H. or Howie Ray. Seated to his right is Jon 4 C. or Chris Hawkins. Seated to his right is Scott 5 Erickson.
And behind them is Mr. Ahmed Ouaouo 6 CHAIRMAN HAWKENS: Thank you.7 MS. BATY: For the NRC staff we have Mr.8 Hansraj Ashar, Dr. James Davis, and Timothy O'Hara.9 CHAIRMAN HAWKENS: Thank you.10 MR. WEBSTER: And for Citizens, we have 11 Dr. Hausler, who will be wearing disguises so it makes 12 it look like we have more witnesses.
13 CHAIRMAN HAWKENS: Thank you, Mr. Webster.14 Once again the witnesses are reminded they 15 were sworn yesterday and remain under oath or 16 affirmation for the testimony they are about to 17 provide.18 (Pause.)19 I'd like to hear from Dr. Hausler in what, 20 in his view, the most likely source of water would be 21 and the duration of it.22 DR. HAUSLER: Well --23 CHAIRMAN HAWKENS: And we have all of your 24 -- the testimony you've previously provided, so if you 25 could summarize it, that would be great.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 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 687 DR. HAUSLER: Well, I don't think, Judge, that they can go very much beyond as to what has been already stipulated by AmerGen as to where the water comes from.I have nothing further to add than that the water comes from the refueling bay.MR. WEBSTER: The other element in the prefile is condensation.
Perhaps I could ask for comment.DR. HAUSLER: There are two things. When we talk about condensation, there may be condensation on the inside of the drywell shell. I am not sure that we can really speculate a great deal about condensation on the outside.In other words, I don't think that'condensation on the outside is really a source of water that we might have to worry about.CHAIRMAN HAWKENS: So condensation on the outside is not a real problem?DR. HAUSLER: I don't think so.CHAIRMAN HAWKENS: For a source of corrosion in your judgment.DR. HAUSLER: That's correct.CHAIRMAN HAWKENS: Thank you.JUDGE ABRAMSON:
Let me ask AmerGen folks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 688 1 and this not so much source of water as to what water 2 was there for how long in the old days when you had 3 corrosion.
AS we understand it, the sand bed was 4 holding water that got there'during refueling.
Is 5 that correct?6 MR. O'ROURKE:
Yes, it is. This is John 7 O'Rourke.8 JUDGE ABRAMSON:
Thank you, Mr. O'Rourke.9 And in your estimate, was that water there 10 continuously once- it got there and not just 11 evaporating and as a source of corrosion, do we have 12 any evidence once way or the other?13 MR. O'ROURKE:
We don't have specific 14 evidence, but our best guess is that the sand held the 15 water against the shell and that whatever evaporated 16 the next time there was a refueling outage would have 17 been replenished until the issue was resolved.18 JUDGE ABRAMSON:
So your best engineering 19 judgment is that there was a kind of--- more or less 20 continuous source of corrosion from the beginning of 21 the leak until it was -- until the situation was 22 corrected?
23 MR. O'ROURKE:
Until the sand was removed 24 in 1992.25 JUDGE ABRAMSON:
1992, okay. And during NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 689 1 a normal -- during normal operation of the plant 2 today, since the sand bed has been removed, how long 3 does a refueling outage take on average?4 MR. O'ROURKE:
On average, refueling 5 outages at Oyster Creek, the last two have averaged 26 6 days.7 JUDGE ABRAMSON:
And they occur every 8 other year?9 MR. O'ROURKE:
Every other year, that's 10 correct.11 JUDGE ABRAMSON:
And are there any other 12 ordinary operational conditions during which there 13 would be water in the refueling bay?14 MR. O'ROURKE:
None that we're aware of.15 JUDGE ABRAMSON:
So the maximum time there 16 could be any source of water, whether or not it gets 17 down to this liner would be 30 days every two years?18 MR. O'ROURKE:
It would be less than 26 19 days because the cavity is not filled during the 20 entire time that the plant is off-line.21 JUDGE ABRAMSON:
Okay, thank you.22 JUDGE BARATTA: There was discussion about 23 forced outages where if you had to go in and replace maybe it wasn't manufactured correctly or something 25 like that. That has occurred in the industry, has it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 690 1 not?2 MR. O'ROURKE:
Yes, it has.3 JUDGE BARATTA: It is a rare event though, 4 as well?5 MR. O'ROURKE:
Absolutely rare event.6 JUDGE BARATTA: Can you give us a 7 guesstimate on over the life of the plant how many 8 times that might occur, based on industry experience?
9 MR. O'ROURKE:
I reviewed the outages at 10 Oyster Creek since 1990 and the reasons for them.11 None of those reasons required the reactor cavity to 12 be filled. And none of them involved removal of 13 damaged fuel bundles or any reason why we would have 14 to go into the reactor.15 I can't speak to the periods prior to 16 1990. I had no data on that. I was at Limerick for 17 a number of years and I recollect one time where we 18 took the reactor down to replace a damaged fuel 19 bundle.20 JUDGE BARATTA: So maybe, would it be your 21 22 MR. O'ROURKE:
Once or twice over the 23 lifetime of a plant would be my best guess.24 JUDGE BARATTA: And the time that would be 25 required to do that -- that would be 30 days, 25 days, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 691 1 10 days or --2 MR. O'ROURKE:
If the plant were being 3 removed for the sole purpose of removing a failed fuel 4 bundle, and the plant does testing, prior to removing 5 the plant from operation to try to pinpoint the 6 location of the failed fuel bundle, it would be on the 7 order of five to six days.8 You would come off and remove the bundle 9 and replace it with a fresh bundle and come back up 10 again.11 JUDGE BARATTA: So in other words, at 12 most, let's -- if we had a failed fuel bundle, we 13 might have had maybe five or six days to the --14 MR. O'ROURKE:
At most and keeping in mind 15 that the cavity is not again, is not filled. You have 16 to take shield blocks off and get down to the cavity 17 before you can put the strippable coating on and then 18 fill it.19 JUDGE BARATTA: Really, it's almost an 20 insignificant amount of time, then.21 MR. O'ROURKE:
I would say so.22 JUDGE BARATTA: An insignificant amount of 23 time in an extremely unlikely event.24 MR. O'ROURKE:
That's correct.25. JUDGE BARATTA: Okay, and spread -- and if NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 692 1 you look at the statistics, spread over the life of 2 the plant, not every year.3 MR. O'ROURKE:
That's correct.4 MS. BATY: Yes, Your Honor, if you mind, 5 would the Board like to ask AmerGen how long on 6 average the reactor refueling cavity is filled with 7 water? They said 26 days outage, but how many days 8 it's actually filled with water.9 JUDGE ABRAMSON:
So asked.10 MR. O'ROURKE:
Thank you for that 11 question.
We have Mr. Howie Ray will -- has the data 12 from the most recent refueling outage.13 MR. RAY: Yes, this is Howie Ray and the 14 cavity was filled October 18, 2006 and it was emptied 15 November 3, 2006. So it was less than 30 days.16 JUDGE BARATTA: You mentioned in one of 17 the testimony that you do observe a light, I think it 18 was referred to something like a light skin film of 19 rust on the inside of the drywell. Am I correct in my 20 recollection?
21 MR. POLONSKY:
I am just going to consult 22 with my witness to see if this is the correct panel to 23 answer that.24 JUDGE BARATTA: Okay. Well, I was trying 25 to get to the source of the water for,that light film.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 693 1 MR. POLONSKY:
Judge Baratta, if you'd 2 like to understand whether there is water and what the 3 source of water on the inside is?4 JUDGE BARATTA: Yes.5 MR. POLONSKY:
We can clearly address 6 that.7 JUDGE BARATTA: That's what I was trying 8 to get at, that there was a statement that someone 9 made that there's a light film of rust that were 10 adequately formed. So what's the source of water for 11 that that might cause that?12 MR. O'ROURKE:
The source of water was 13 leakage inside the drywell during operation from any 14 number of sources that drips on to the floor. And 15 this light film of rust was in one of the trenches.16 When the filler material was removed from the 17 trenches, they observed alight film of rust that was 18 brushed off very easily.19 CHAIRMAN HAWKENS: When you say any 20 sources of water are we talking about reactor coolant, 21 nonreactor coolant and what volume?22 MR. O'ROURKE:
I don't have an estimate of 23 the volume. It could be either reactor coolant from 24 leakage or it could be other water inside. I don't 25 have numbers on those.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 wNw.nealrgross.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 694 MR. RAY: This is Howie Ray, if I may add to that, in 2006 outage we did go in and investigate some of this water source. We did find a defect in the trough that runs underneath the subpile room.Some of the water was getting down into the concrete and we did repair that and validated that it significantly reduced any source of water into the concrete.JUDGE BARATTA: Where was this trough? Do you have that model or would that be helpful to look at that?MR. O'ROURKE: troughs that were cut into JUDGE BARATTA: MR. POLONSKY: trenches, the two trenchesýMR. O'ROURKE: I am referring to the the concrete.Oh, okay.Do you mean trough or the The bay 5 and bay 17 trenches that --JUDGE BARATTA: You had a filler material that was to project those to keep any water from getting into there, is that what that water was?MR. O'ROURKE:
Yes. And there was some water that was found when the filler material was removed in -- it was bay 5.And there was an observation of wetness in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 695 1 bay 17, but no standing water.2 JUDGE BARATTA: And what you've done now 3 is try to seal that water so that when any 4 condensation or whatever, whatever the source of that 5 water was --6 MR. O'ROURKE:
That's correct. In the 7 2006 outage, not only was the concrete around the 8 periphery to the shell seal, but also the concrete to 9 the trenches was sealed. It was totally sealed to 10 prevent any water from getting into those trenches.11 JUDGE BARATTA: Did you put like a caulk 12 between the concrete and the steel like you have on 13. the outside, is that what you did as well?14 MR. O'ROURKE:
I can't say that it was the 15 exact -- it was caulk, yews.16 JUDGE BARATTA: Similar.17 MR. O'ROURKE:
Similar. I can't say it was 18 the exact material that was used on the outside, since 19 that material was placed in 1992.2,0 JUDGE BARATTA: And the amount of leakage 21 that you see as you account for make up and such into 22 the primary system or into the feed system as such, 23 it's not something that's significant from operational 24 standpoint?
25 MR. O'ROURKE:
That's correct. The plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVE., N.W.
696 1 tech specs allow for certain unidentified and 2 identified leakage. There are some leaks that are 3 designed from the recirculation pumps, for instance, 4 are design leakage. Unidentified leakage is limited 5 to an amount that once we exceed that amount we would 6 have to go in and find where that was coming from.7 MR. POLONSKY:
Your Honor, for the record, 8 Panel 6 will be testifying and they will be assuming 9 that the interior shell that is embedded in concrete 10 on the inside is saturated, that there's water 11 continually present there as a normal condition.
Just 12 if that helps to put this in perspective.
13 JUDGE BARATTA: I was more interested in 14 that film that was-- in what the origins might be of 15 that, just to confirm.16 CHAIRMAN HAWKENS: Is it AmerGen's view 17 that its commitment regarding the application of 18 strippable coating and tape to the reactor cavity 19 applies not only to refueling outages, but to forced 20 outages also?21 MR. O'ROURKE:
Yes, it is.22 CHAIRMAN HAWKENS: Does the NRC staff 23 share that understanding of the commitment?
24 MS. BATY: Could you repeat the question 25 and I think then we can get someone to address it.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 697 1 CHAIRMAN HAWKENS: AmerGen said that it 2 understood and would apply its commitment to apply the 3 strippable coating and tape to the reactor cavity both 4 to refueling outages as well as forced outages.5 MR. O'ROURKE:
And to clarify, Judge, 6 that's forced outages where we would need to flood the 7 cavity in order to get into the vessel?8 CHAIRMAN HAWKENS: Yes, correct.9 MR. ASHAR: Hansraj Ashar. Yes, I have 10 seen the commitment as part of our appendix A and SER.11 CHAIRMAN HAWKENS: Thank you.12 MS. BATY: Your Honors, would you -- there 13 are additional commitments.
Would you like to hear 14 from the staff about additional commitments related to 15 water and sources of water?16 JUDGE BARATTA: I have no questions.
17 We're familiar with them. Thank you. We need not 18 hear further on that.19 MS. BATY: It is a license condition
-- a 20 proposed license condition in Appendix A.21 And discussed in our testimony.
Not Appendix A, 22 excuse me. 1.7.23 CHAIRMAN HAWKENS: Thank you. Citizens, 24 you've heard the questions we've posed to the NRC 25 staff and to AmerGen regarding sources of water. Do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 698 1 you have anything to add or to rebut regarding what 2 they've said, regarding our questions?
3 DR. HAUSLER: Not with respect to what 4 they have said, but there are some -- it appears to us 5 there are some open questions.
And particularly with 6 respect to the frequency of the water, whether it's 7 always there on the outside of the drywell. For one, 8 we're wondering about on-going corrosion that has been 9 apparently documented yesterday.
You do need water 10 for that. So where does the water come from.11 CHAIRMAN HAWKENS: May I ask you a 12 question?
Do you have any evidence that a source 13 other than the reactor cavity when it's filled would 14 be the source of water on the external shell?15 DR. HAUSLER: No, I don't have the p 16 evidence.
I have the question where it comes from.17 CHAIRMAN HAWKENS: Do you have the answer 18 where it comes from?19 DR. HAUSLER: No, no --20 CHAIRMAN HAWKENS: You say you just wonder 21 where it comes from?22 DR. HAUSLER: I just wonder where it comes 23 from.24 JUDGE ABRAMSON:
Did I understand you 25 correctly, Dr. Hausler, that you believe we heard NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 699 1 yesterday that there is on-going corrosion on the 2 outside and you --3 MR. WEBSTER: Can i just clarify this? I 4 think, Dr. Hausler, that the testimony was there's 5 ongoing corrosion, the upper drywell on the outside.6 JUDGE ABRAMSON:
The upper drywell, not in 7 the--8 MR. WEBSTER: And Dr. Hausler's point is 9 that the upper drywell is hotter than the bottom and 10 if there's ongoing corrosion, there must be water 11 there.12 JUDGE ABRAMSON:
Let's ask the Applicant, 13 what's the source of the water? Is there on-going 14 corrosion in the upper drywell and if so, what's the 15 source of the water? That's a straightforward 16 question.17 MR. POLONSKY:
Judge Abramson, I think we 18 had detailed questions and answers on this primarily 19 with Judge Baratta yesterday, and we went through the 20 extremely low hypothetical and only statistically 21 based corrosion rate. I think it was .66 mils in the 22 one point in the upper region.23 We don't believe that that was real --24 that there's actually corrosion ongoing. The 25 testimony walked through what the actual measurements NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 700 1 are from those -- that, I think it was location --2 JUDGE ABRAMSON:
Let's rather than have 3 the lawyer -- let's put on the individual who did this 4 analysis and let's refresh everybody's memory on it 5 and be done with it. Let's get the information right 6 back. I don't think it's going to take all that long.7 MR. GALLAGHER:
Yes, this is Mike 8 Gallagher.
AmerGen.9 JUDGE ABRAMSON:
Mr. Gallagher, what I 10 think your counsel is trying to tell us is that we 11 discussed yesterday what sort of analysis one could do 12 with the measurements and from those measurements 13 because of the uncertainty, the worst case within the.14 bounds of the uncertainty would lead one to project 15 6.6 mils. Can you tell me, have we got this right?16 MR. WEBSTER: Judge, I think the analysis 17 you're referring to is the analysis of the external 18 measurements in the sand bed. That wasn't the 19 analysis of the -- these are grid measurements in the 20 upper drywell.21 JUDGE ABRAMSON:
Let's talk about it.22 MR. GALLAGHER:
I believe we did discuss 23 this yesterday, but this was a question that Dr.24 Baratta had about the upper drywell. Okay, which is.25 outside the scope of what we're talking about.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 701 1 JUDGE ABRAMSON:
Right.2 MR. GALLAGHER:
What we have there, we 3 have a grid system we measure. There's 13 grids we 4 measure. And we do -- if you look at the data, and 5 see the exhibit, Exhibit 3, what page, John?6 JUDGE ABRAMSON:
We went through this 7 yesterday.
8 MR. GALLAGHER:
I'll just summarize.
All 9 the data is flat lined. It's the same situation.
10 There's a grid system. We take the average, the mean.11 It's all flatlined, meaning there's no on-going 12 corrosion.
13 -In one area, we -- and we have data since 14 the late 1980s, and in one area we conservatively 15 called a corrosion rate, based on statistics, okay?16 And that was .66 mils per year. It's basically flat 17 lined.18 JUDGE ABRAMSON:
But that estimate of 19 corrosion was based purely on statistics, not on 20 observation of any actual corrosion?
21 MR. GALLAGHER:
That's correct. And it's 22 uncoded, the upper drywell is uncoded and the other 23 thing I said yesterday is the original water source, 24 which we're monitoring for, was from the reactor 25 activity, would come from the reactor cavity, a leak NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 702 1 behind the plate and then go into the gap. So it 2 passes through the upper drywell area.3 So what I said yesterday, it was the 4 source would have been the same source, but there is 5 no onrgoing source since we control that leakage now.6 It goes in the trough and goes down the drain into the 7 rad waste system.8 MR. WEBSTER: Judge, could I just --9 MR. GALLAGHER:
That's what I said 10 yesterday.
11 JUDGE ABRAMSON:
Quiet, please.12 MR. WEBSTER: Okay, fine.13 MR. GALLAGHER:
That's what I had said 14 yesterday and that's --15 JUDGE BARATTA: And that's what you said.16 MR. GALLAGHER:
Yes, that's correct.17 JUDGE BARATTA: I pulled up the transcript 18 and that's exactly what you have. For future 19 reference, it's on page 108.20 JUDGE ABRAMSON:
Mr. Webster, is there 21 something you want to add?22 MR. WEBSTER: Well, a couple of things.23 One is I think it would be useful to know the level of 24 statistical significance with which this corrosion has, 25 been observed.
The second thing is the reason there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 703 1 no visual measurement, no visual observations of 2 corrosion at this point I think is because there's an 3 insulating material and there's a three-inch gap. And 4 so these measurements are taken on the inside of the 5 upper drywell. It's not possible to do visual as far 6 as I understand.
7 JUDGE ABRAMSON:
Thank you. We understand 8 where you're coming from. I don't have any further 9 questions.
Do you, Dr. Baratta?10 JUDGE BARATTA: Nothing more.11 CHAIRMAN HAWKENS: We will take a 10-12 minute break and hear from the next panel.13 (Off the record.)14 CHAIRMAN HAWKENS: You are missing a 15 critical partner, Mr. Webster, we will wait for him to 16 return.17 MR. WEBSTER: I am and actually I was just 18 going to say that he does have one thing to add to the 19 last panel, if he could, which is not in his file 20 testimony.
21 CHAIRMAN HAWKENS: We will hear from him 22 first.23 MR. WEBSTER: Thank you very much.24 CHAIRMAN HAWKENS: Let's go back on the 25 record. While we are awaiting Dr. Hausler, let's have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 704 1 the counsel, please, introduce the witnesses for Panel 2 5, which deals with the epoxy coating.3 MR. POLONSKY:
This is Mr. Polonsky for 4 AmerGen. Panel 5 consists of Jon Cavallo, sitting to 5 my right. To his right is Mr. Ahmed Ouaou. To his 6 right is Jon C. or Chris Hawkins. To his right is 7 Scott Erickson.
And behind that panel in the second 8 row is Mr. Martin McAllister.
9 CHAIRMAN HAWKENS: Thank you.10 MS. BATY: For the staff we have Mr.11 Hansraj Ashar, Dr. Davis and Mr. Tim O'Hara.12 CHAIRMAN HAWKENS: Thank you.13 MR. WEBSTER: And for Citizens yet to be 14 disguised is Dr. Hartzman.15 CHAIRMAN HAWKENS: Thank you. The 16 witnesses once again are reminded they are sworn and 17 they remain under oath or affirmation for the 18 testimony they are about to present. Before asking 19 questions on the -- regarding the topic of the epoxy 20 coating, Dr. Hausler would like to say something 21 regarding the prior topic, sources of water.22 MR. HAUSLER: Well, there has been, you 23 know, comments and I believe it was in a document that 24 had been generated by Mr. Tamburro about the plugging 25 of the drains. In the latest outage, the drains from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 705 1 the drywell area have been plugged, at least three of 2 them. My question was how did they get plugged?.
You 3 know, we do know that due to vibration the concrete, 4 you know, in that area has a tendency to degrade, you 5 know, chunks of concrete have been found in that area 6 before.7 Now, my question, of course, is how does 8 that get into the drains?9 MR. POLONSKY:
Now, for the record, just 10 could we get an exhibit number, so we can accurately 11 respond?12 MR. WEBSTER: We are having trouble 13 finding the exhibit number. Maybe Mr. Tamburro can 14 confirm with Dr. Hausler's recollection is correct?15 MR. POLONSKY:
Perhaps we could come back 16 to this after this panel is over, so after Mr.17 Tamburro has an opportunity to review the exhibit that 18 you are alleging he wrote.19 CHAIRMAN HAWKENS: That would be fine.20 Let's do that and that question will remain on the 21 table. We will not only address it, but find out the 22 corrective actions that have been done. and the 23 commitments that are in the record to prevent its 24 recurrence..
Let's now proceed to Topic 5, the Epoxy 25 Coating, with a question for AmerGen.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 706 1 Is there a possibility that some portion 2 of the exterior area in the drywell region has not 3 been coated with the epoxy?4 MR. HAWKINS: This is Jon Hawkins. The 5 sand bed region, the elevation goes from 8 foot 11 to 6 12 foot 3 inches, which is a total of 3 feet 4 inches.7 That entire area is completely coated. There are 8 areas above that where the gap gets smaller to the 3 9 inches where they could not reach or could not access.10 CHAIRMAN HAWKENS: Thank you. No, my 11 concern was the sand bed region. Thank you.12 MR. HAWKINS: That's completely coated.13 CHAIRMAN HAWKENS: Thank you.14 JUDGE ABRAMSON:
All the way down to the 15 floor?16 MR. HAWKINS: That'.s correct.17 MR. HAUSLER: Could we perhaps revert to 18 Citizen's Exhibit 63, which is a diagram of that.19 particular region? And we have a question with 20 respect to how far the coating actually goes.21 MR. WEBSTER: Actually, it's an 22 administrative matter that is now referred to damage 23 in Exhibit 7. It's the same figure.24 CHAIRMAN HAWKENS: Yes, we'll consider 25 that. Again, what exhibit is it?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 707 1 MR. WEBSTER: It's AmerGen Exhibit 7.2 JUDGE ABRAMSON:
Is there something about 3 what we just heard from AmerGen that you dispute or 4 that's unclear?5 CHAIRMAN HAWKENS: What I think we heard 6 was that the entire sand bed region from the floor up 7 to a certain elevation was coated period.8 MR. HAUSLER: Yes, and there is a gap 9 between the vent pipe and the concrete.
There is a 10 gap there and we're wondering that is subject to, of 11 course, accumulation of water that was also subject to 12 accumulation of sand there, you know, when the sand 13 bed was poured and we don't know whether, in fact, the 14 sand has been removed from there or whether in fact 15 that area, the rust has been removed from that area 16 and whether, in fact, it was coated.17 That area would be severely subject to 18 corrosion if, in fact, you know water comes down the 19 outside of the drywell.20 JUDGE ABRAMSON:
So let's ask AmerGen. A)21 is there sand remaining in that gap region?22 JUDGE BARATTA: Could we get that up, if 23 you don't mind, before we ask that?24 MR. WEBSTER: Yes, it would be helpful.25 JUDGE BARATTA: Because I'm not sure what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W: (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 708 1 region you are talking about.2 MR. WEBSTER: It's AmerGen Exhibit 7.3 JUDGE BARATTA: I have it here, but I 4 don't know exactly where you're talking about on 5 the--6 MR. POLONSKY:
Your Honor, if we could 7 also just renew our objection on this. We don't know 8 what this has to do with UT frequency., even if we 9 took UT frequency at the points that currently are 10 designated every single second, it would not relate to 11 an area that is on the side.12 JUDGE BARATTA: I can tell you're not an 13 engineer then. If you would, continue, please.14 Sorry.15 MR. POLONSKY:
I agree. I am not.16 JUDGE BARATTA: Could you --17 MR. POLONSKY:
The area I'm talking about 18 is that gap just immediately to the right of No. 6.19 That is between the concrete and the vent pipe, that's 20 the area, that's exactly right.21 MR. HAUSLER: Is that the area, the 22 drywell?23 UNIDENTIFIED SPEAKER: The drywell shell 24 is this piece, right?25 ALL: No.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 709 1 UNIDENTIFIED SPEAKER: No? Where is the 2 drywell shell?3 MR. OUAOU: The dark black line, Your 4 Honor, that's correct, yes.5 JUDGE BARATTA: And what is this?6 MR. OUAOU: That's -- this is on the --7 MR. POLONSKY:
On this figure, the drywell 8 shell is the dark line running diagonally up from the 9 6.10 MR. OUAOU: Your Honor, that's the drywell 11 shell and as Mr. Hawkins stated that we consider the 12 sand bed region from this level, that's 8 foot 11 to 13 12 foot 3, that's the elevation here. That's all 14 coated. This gets into the gap and it is accessible 15 for coating. This is a gap between the vent pipe and 16 the concrete and the vent pipe is not part of the dry 17 well shell itself. Ordinarily, there is no sand in 18 this gap. This is all clear.19 JUDGE ABRAMSON:
And it is not structural 20 for the -- from the perspective of adding to the 21 ability of the drywell shell to withstand buckling.22 Is that correct? It's just a vent pipe.23- MR. OUAOU: The vent pipe was modeled as 24 part of the model that GE did, but it's -- my belief 25 is it's not all they credit it.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 710 1 MR. WEBSTER: Well, I would like Dr.2 Mehta. I had thought that the structure to the vent 3 pipe was created for buckling.4 JUDGE ABRAMSON:
Dr. Mehta, once again, 5 when you modeled the drywell shell for buckling, how 6 did you treat the vent pipes?7 DR. MEHTA: In the vent pipes nominal 8 thicknesses were used to include in this model.9 JUDGE ABRAMSON:
Okay. And how do they --10 how are they susceptible to the buckling loads you 11 were looking at? Are they relevant to considering 12 buckling of the drywell shell or does it take much 13 greater loads to cause the vent pipes themselves to 14 buckle? What's the relative relationship?
15 DR. MEHTA: Your Honor, they are somewhat 16 relevant, but given that the buckled wave is in the 17 middle between the two bays, it will have some 18 insignificant effect or a very small effect if there 19 is any.20 JUDGE ABRAMSON:
An effect on the buckling 21 of the drywell shell itself, but are the pipes 22 themselves susceptible to buckling prior to buckling 23 of the drywell shell? Which is going to fail first?24 DR. MEHTA: Your Honori the vent pipes are 25 very thick, so they are not susceptible to buckling.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 711 1 JUDGE ABRAMSON:
Thank you.2 MR. POLONSKY:
Your Honor, if we can put 3 on the record an objection that the contention is 4 about the drywell shell and UT of the drywell shell 5 and we believe Citizens are trying to expand this to 6 an area outside of the drywell shell.7 CHAIRMAN HAWKENS: Thank you. We 8 understand the contention is limited to the 'drywell 9 shell. NRC staff?10 MS. BATY: We justwanted to join in with 11 AmerGen's objection.
12 MR. WEBSTER: May I respond to that 13 objection, which is the reason this area is relevant 14 is twofold. One is that those vent pipes are in 15 regard to structural in the model for buckling the 16 drywell shell. There is a boundary condition put on 17 which does -- is -- assumes that those vent pipes have 18 normal thickness.
19 Second, AmerGen has claimed air flow 20 through this gap contributing to evaporation.
So it's 21 relevant when this gap is full of corrosion products 22 or not.23 JUDGE ABRAMSON:
Okay. So let's come back 24 to I think we heard from AmerGen that there is no sand 25 in this gap. Is that correct?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com v
712.1 MR. OUAOU: Yes, Your Honor.2 JUDGE ABRAMSON:
And that the drywell 3 shell is coated up to this gap, but can you show us 4 with a pointer where it is not coated?5 MR. HAWKINS: It's coated from the floor 6 up the drywell shell, the bottom of the vent header, 7 approximately, up to here on both sides of the vent 8 header coming up each side. So it goes up much higher 9 than the 12.3.10 JUDGE BARATTA: Here is a photograph in 11 Exhibit 40. It's on page 91. I don't know whether it 12 shows any of this region, but if you could just grant 13 me, because on that photograph, I would appreciate it, 14 because it looks like we are actually looking -- it's 15 labeled Bay 13, Drywell Shell. And it is --16 MR. POLONSKY:
That's page 91, Your Honor?17 JUDGE BARATTA: Yes, yes. I think it 18 looks like there is something in the background there.19 I was wondering whether that was a vent header or not.20 MR. HAWKINS: Yeah, the vent header is out 21 of the picture, but the support ring that surrounds 22 the vent header, it's an 18 inch -- from the vent 23 header itself to the bottom of the support ring is 18 24 inches.25 JUDGE BARATTA: Um-hum.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 713 1 MR. HAWKINS: That is like I said above 2 the --3 JUDGE BARATTA: Is that what is visible in 4 the background there, that?5 MR. HAWKINS: This is a weld that welds 6 the support ring to the vent header and the vent 7 header to the drywell shell.8 JUDGE BARATTA: So you can see that that's 9 coated there.10 MR. HAWKINS: Yes, all the way up here.11 JUDGE BARATTA: And there is also no 12 evidence of any corrosion.
In fact, that looks like 13 it is in good condition.
Is that correct?14 MR. HAWKINS: It appeared to me to be a 15 red painted surface, not a corroded rusty surface.16 JUDGE BARATTA: Right. There's no -- like 17 the area that's below 'that where the external UT 18 inspection location is.19 MR. HAWKINS: In this picture here?20 JUDGE BARATTA: No, further down. It's 21 clearly corroded.22 MR. HAWKINS: Yes.23 JUDGE BARATTA: And that looks almost like 24 it's an as-built condition above that.25 MR. HAWKINS: Correct.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE IS LAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 714 1 JUDGE BARATTA: Is that correct?2 MR. HAWKINS: Yes, that's the bathtub ring 3 right here. So above that we did take some thickness 4 readings there also and that was -- there was no 5 corrosion and we also have these areas here, which are 6 the prepped areas that we performed the UT.7 inspections.
8 JUDGE BARATTA: And is this photograph 9 fairly typical of -- this is for one bay. Are the 10 other bays --11 MR. HAWKINS: Yes.12 JUDGE BARATTA: Are they typical of that?13 MR. HAWKINS: Very typical, if not more 14 coating up even higher.15 MS. BATY: For clarification of the 16 record, can we put in where the witness was pointing 17 to on that photograph, as far as like the upper right 18 hand corner, to point out how high theepoxy coating 19 goes and where the vent line, support ring -- the 20 support ring and the vent line attaching to the 21 drywell shell? If we could put that in the record?22 CHAIRMAN HAWKENS: You go ahead and 23 describe it again and verbally describe where you're 24 placing the pointer on the picture.25 MR. HAWKINS: Okay. This is the drywell NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 715 1 shell. This is the weld that attaches --2 CHAIRMAN HAWKENS: Right. If you are the 3 -- the laser is in the top right hand corner.4 MR. HAWKINS: Oh, okay. The laser is 5 pointing to the top right hand corner of the screen 6 and that is the vent header penetration.
Just below 7 that into the gray painted surface is the vent header 8 support ring, which is attached by a weld to the 9 drywell shell which is just 'below it. And I'm 10 pointing to a flat surface on the screen, which is the 11 drywell shell above the bathtub ring, near the top of 12 the screen or the picture.13 JUDGE ABRAMSON:
Let the record reflect 14 that the witness has been describing the upper right 15 hand corner of this picture where there are weldments, 16 one running apparently circumferentially across the 17 upper right hand corner of the picture and describing 18 it in an arc. And below that arc there is what 19 appears to be a relatively shiny flat area. And then 20 coming down to the left, lower left from that, one 21 sees a rough surface. I think that ought to be enough 22 to get this in the record.23 MS. BATY: Thank you. I also pointed --24 I believe the witness also pointed to the one area/25 that is located on -- that's pointed to on the caption NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 716 1 of the picture saying external UT inspection location.2 That was also described.
3 JUDGE ABRAMSON:
We have enough 4 information.
It's in the record.5 MS. BATY: Okay. Thank you.6 MR. WEBSTER: Judge, I think I have a 7 comment on this photograph.
If you can't see a 8 feature on the projection, but in the original 9 photograph there is a feature which has it coming.10 MR. HAUSLER: There appears to be an area 11 just below the B as in bed and R as in reach, and in 12 other words, in the center of the photograph on the 13 upper boundary.
There appears to be a region that is 14 corroded or is full of corrosion products and it has 15 not been identified as being coated.16 MR. WEBSTER: Just a clarification.
You 17 cannot see. it on the projection.
You have to look at 18 the original photograph,.
which is reproduced on the 19 AmerGen Exhibit 40, page 91.20 MR. HAWKINS: He is talking about an area 21 on the original picture that's in this area over here 22 in the upper left hand'side of the picture.23 MR. WEBSTER: Well, it's in the center 24 below the B in bed as Dr. Hausler described.
25 MR. HAWKINS: This was below the D in bed?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 717 1 JUDGE ABRAMSON:
Yes, it's right in there.2 Right there. If you look at the picture, the actual 3 photograph there is some odd geometry in there or 4 irregular geometry which we can't tell what it is.5 MR. HAWKINS: In my opinion, that is the 6 concrete wall beyond the shell. Because we are 7 looking at an arc surface as you get off to the --8 now, you are seeing the concrete wall that's behind 9 you.10 MR. POLONSKY:
Can we have one moment, 11 please, Your Honor?12 CHAIRMAN HAWKENS: Yes.13 MR. POLONSKY:
Your Honor, Mr. Tamburro 14 previously testified that he physically was in Bay 13 15 during the 2006 outage, so I thought you might want to 16 hear, you know, as opposed to a picture, what he saw.17 CHAIRMAN HAWKENS: All right. Bring Mr.18 Tamburro forward.19 MR. TAMBURRO:
This is Peter Tamburro.
I 20 was in Bay 13. I was able to look up in those areas 21 and I did not see any evidence of corrosion on the 22 drywell vessel. There were different colors, 23 different discolorations on the concrete areas on the 24 interface between the drywell and the concrete, but 25 there was no evidence of corrosion in that area.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 718 1 MR. WEBSTER: I think the question was 2 what was the feature that's on the photograph?
3 JUDGE ABRAMSON:
Yes, and I think the 4 answer we heard from the expert who was describing it 5 is that he thinks that feature is, he thinks, the 6 concrete behind in the background.
And one can't 7 tell. And so I think the answer is one can't tell and 8 we'll leave it at that. That's his expert opinion.9 MR. HAWKINS: I can clarify my statement 10 by saying that no where on the drywell shell in the 11 area of examination looked like that.12 MR. WEBSTER: Well, I mean, I guess the 13 question is when we're talking about the drywell 14 shell, what about this area Dr. Hausler is pointing 15 out between the vent header and the concrete.16 MS. BATY: Your Honor, the staff has 17 something.
One of our inspectors was there and has 18 something that they would like to share on this.19 MR. O'HARA: Tim O'Hara, Your Honor.20 During the outage in the fall of '06, I entered Bay 13 21 and Bay 11, physically looked at the drywell. All the 22 regions on the outside of the drywell were coated.23 Conditions like that exist on the shield wall opposite 24 the drywell shell itself. And all those conditions 25 were documented by AmerGen and they are taking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 719 1 corrective actions as needed on those conditions.
But 2 the drywell shell was completely coated.3 I also examined all the records both 4 visual and the video records that AmerGen made and 5 everything that we looked at on the external of the 6 drywell was coated.7 JUDGE ABRAMSON:
Mr. O'Hara, did you 8 observe any sand remaining in any of these gaps that 9 are in question here?10 MR. O'HARA: No, I didn't, Judge.11 JUDGE BARATTA: Did you see any corrosion 12 products in any of those gaps or anything like that?13 MR. O'HARA: There was no corrosion 14 products visible on the outside of the drywell. On 15 the shield wall and the tendons running through there, 16 there was light rust. There was no visible signs of 17 any moisture in the -- in any part of the sand bed 18 area.19 JUDGE BARATTA: Are those tendons concrete 20 or are they steel?21 MR. O'HARA: Steel, I believe.22 JUDGE BARATTA: The shield wall, is that 23 concrete?24 MR. O'HARA: That's concrete.25 JUDGE BARATTA: So what we're probably --NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 720 1 it's difficult seeing is one of the tendons?2 MR. O'HARA: That would be my guess. But 3 it is not on the drywell shell, in this particular 4 bay, which I did look at.5 JUDGE BARATTA: Thank you.6 CHAIRMAN HAWKENS: Dr. Hausler, you have 7 expressed concerns about pin holes in the epoxy 8 coating.9 MR. HAUSLER: Well, the area that we're 10 pointing to on the vent pipe, on the down comer, you 11 know, in that gap, is, in fact, the pressure boundary 12 and we have been concerned about pressure boundaries 13 on the drywell shell. I believe that is, you know, 14 just, you know, the same area, the same problem with 15 the, you know, 49 or 490 mil limiting --16 CHAIRMAN HAWKENS: Well, I'm talking about 17 pin holes in epoxy coating. Is that what you are 18 addressing right now?19 MR. HAUSLER: No, I'm not.20 CHAIRMAN HAWKENS: We're in the epoxy 21 coating topic. Here is my question.22 MR. HAUSLER: I'm sorry.23 CHAIRMAN HAWKENS: In your testimony you 24 expressed concerns about the possibility of corrosion 25 in the sand bed region which would occur at pin holes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 wvw.nealrgross.com 721 1 in the epoxy coating.2 MR. HAUSLER: Yes, sir. The studies that 3 have been made prior to the application of the epoxy 4 took for qualification of the application procedure 5 and so on have clearly shown that there is a 6 possibility of pin holes forming, thus inclusions as 7 well as, you know, hairs from brushes and things of 8 that nature.9 It is my understanding, you know, from 10 reading of the report that had been prepared by the 11 applicator of the epoxy that on the mark-up where the 12 panels were, you know, prepared, you know, for future 13 study, examinations have been done, you know, for the 14 detection of pin holes by, you know, electrical 15 methodology, you know, the way painters, in fact, you 16 know, do detect pin holes.17 However, when the coating was applied in 18 the sand bed area, no such examinations or quality 19 control procedures have been applied. As a 20 consequence, you know, I think it is reasonable to 21 postulate that if pin holes, you know, can, in fact, 22 occur during the study of the coating procedure, it is ,23 even more likely that pin holes occur in the actual 24 application, simply because you have more dust and it 25 is not as sanitary environment in the sand bed when NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 722 1 you apply the coating as it is, you know, when you. do 2 it on the mark-up.3 CHAIRMAN HAWKENS: I understand now. I 4 understand that theory. Is there any evidence, based 5 on the record you have seen provided by AmerGen, that 6 pin holes actually exist?7 MR. HAUSLER: No, there isn't, because 8 they haven't looked for them.9 CHAIRMAN HAWKENS: Thank you. AmerGen,/10 could you respond to that?11 MR. CAVALLO: I would be glad to, Your 12 Honor. Jon Cavallo. In all deference to Dr.13 Hausler's observations, there is no evidence of any 14 pin holes after 14 years of service in this coating.15 Pin holes would be evidenced by visual rust staining 16 in the area of the pin hole. In order to bet 17 corrosion and bear with me just a sec and also Barry 18 Gordon will testify on corrosion, we need anodes, 19 cathodes and an electrolyte as we discussed in the 20 previous panel and a path for that electrolyte to get 21 to the steel. That would be a pin hole or one to 22 occur.23 In the years of experience I have and 24 probably personal observation in over 40 -- over 50 25 nuclear power plants in the U.S., plus China, plus NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 723 1 Korea, plus Europe, when we have a pin hole in 2 atmospheric service, such as what we have here, and we 3 expose it to moisture, we would first see a rust 4 bleeding.
Very similar to what you would see on your 5 lawn furniture in your home. You would see a rust 6 stain, which would be very large, very visible.7 And I have had the opportunity to review 8 the visual inspection records done by the gentleman to 9 my right and there is absolutely no indication of any 10 visual indications of pin holes. So that allows me to 11 state unequivocally we do not have pin holes in the 12 coatings applied to the drywell in 1992.13 CHAIRMAN HAWKENS: I would like to hear 14 from the gentleman on your right, who you said 15 actually performed them?16 MR. CAVALLO: Please.17 CHAIRMAN HAWKENS: The visuals.-18 MRo HAWKINS: That would be Mr. Erickson 19 and myself performed the majority of the examinations 20 on the drywell shell in those areas and we saw .no 21 evidence of the rust seepage from anything at all. No 22 rust at all.23 MR. ERICKSON:
Scott Erickson and I concur 24 with Mr. Hawkins. I saw no evidence of any rust 25 seepage or any pin hole evidence of rust going on.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
% I 724 1 JUDGE ABRAMSON:
Mr. Cavallo, is there 2 anything unique about the epoxy that was used in 3 Oyster Creek that would make it less likely or more 4 difficult for the rust to show through, to be visible 5 compared to other -- these many other plants you have 6 looked at?7 MR. CAVALLO: No, this epoxy is unique in 8 ways that would actually help us to prevent pin holes.9 One reason is that all three coats that were applied 10 are 100 percent solvent free. Pin holes occur during 11 the application process or during the curing process.12 Typically it has to do with solvent migration leaving 13 very small holes in the coating or --14 JUDGE ABRAMSON:
What's the relevance of 15 dust in the atmosphere when you are applying this?16 MR. CAVALLO: None.17 JUDGE ABRAMSON:
Thank you.18 MR. CAVALLO: These coatings are 100 19 percent solid, so we have no solvents in any one of 20 the three-coats.
That's a very common cause of pin 21 holes in epoxy coatings.22 JUDGE ABRAMSON:
And to come back to what 23 I asked, because what we are concerned about is 24 whether you would actually physically be able to see 25 the rust. Is there anything unique about this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
.o 725 1 particular coating that would make it more difficult 2 to visually observe rust underneath if it were 3 occurring?
4 MR. CAVALLO: No actually, just the 5 opposite.
The selection of the top coat color, which 6 is a grayish white would give you a very good visual 7 contrast to, in this case it would be, iron oxide or 8 red rust, so the staining would be very visible to, 9 particularly, trained UT-I inspectors.
10 JUDGE ABRAMSON:
And in your experience 11 when you have -- in cases where you have seen pin 12 holes, what -- can you describe the character of the 13 rust corrosion that was underneath the epoxy when you 14 have seen it? How big an area was it? How much was 15 being corroded?
What was the relationship to the size 16 of the pin hole? Can you tell us anything about the 17 rate?18 MR. CAVALLO: I'll speak to --I won't 19 speak to the rate. I'll ask my colleague, Barry 20 Gordon, to address that in the next panel if you can 21 bear with me.22 JUDGE ABRAMSON:
Okay. That's fine.23 That's fine.24 MR. CAVALLO: As far as what we would find 25 were we to excavate the coating in the area of a pin NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 726 1 hole, typically with a three coat epoxy such as the 2 one used in the Oyster Creek dry well. We would find 3 if there were no -- there was no carbuncle present, a 4 large swelling of the rust, we would find very 5 localized, very minimal corrosion at that point..6 JUDGE ABRAMSON:
And that would be at the 7 point where you'had seen the color, but not had any 8 swelling underneath.
Is that right?9 MR. CAVALLO: That's correct, sir.10 JUDGE ABRAMSON:
Okay. And if it went so 11 far as to building a carbuncle as you call it, what 12 would be typical then?. Give me an idea the diameter 13 of a carbuncle, how deep would it eat in?14 MR. CAVALLO: The consensus in the i5 corrosion industry is that that carbuncle, the iron 16 oxide or oxide products form would occupy a volume and 17 actually swell and occupy a volume 7 to 10 times the 18 .size of the steel that it was replacing.
So we would 19 see an irregularly shaped fairly circular rough 20 surfaced deformation of the coating that would be 21 centered on the area of the pin hole.22 JUDGE ABRAMSON:
Okay. Now, we're mindful 23 that you are saying that there is no evidence of any 24 of these in Oyster Creek, but in the worst cases that 25 you have seen where things have been let go, how big NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 727 1 carbuncles have you seen and how much did it eat in?2 MR. CAVALLO: In a benign environment, 3 such as the Oyster Creek drywell, we have very low 4 temperature, air conditioned conditions.
We have no 5 extensive moisture exposure as we saw in the previous 6 panel. I wouldn't expect to see carbuncles.
I would 7 expect to see over a period of three or four years, 8 which is the frequency of inspection, staining only.9 I would not anticipate seeing carbuncles.
10 CHAIRMAN HAWKENS: Does the NRC staff have 11 anything to add to that?12 DR. DAVIS: Jim Davis with the staff. I 13 agree with what Jon says. That has been my 14 experience, too, with a lot of years of working with 15 coatings.16 CHAIRMAN HAWKENS: Thank you.17 JUDGE BARATTA: One thing that has 18 confused me about that is there was a discussion about 19 the environment that the coating is in and the 20 mechanisms that would degrade the coating. It was 21 mentioned that ultraviolet light degrades epoxy 22 coatings.
Is that correct?23 MR. CAVALLO: That's correct, sir.24 JUDGE BARATTA: This area does have a not 25 tremendously, but some gamma radiation in it. Is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 728 1 also correct?2 MR. CAVALLO: That's correct.3 JUDGE BARATTA: How come it doesn't 4 degrade the epoxy coating?5 MR. CAVALLO: That's a good question.
I 6 can testify that it does not in the doses that we are 7 talking about in the Oyster Creek drywell, based on 8 the plant numbers and I'll let AmerGen testify to 9 those numbers, if you would like. What we have found 10 in probably 50 years of testing is the epoxies are 11 quite resistent to gamma radiation, such as we see in 12 the Oyster Creek drywell. We would see some slight 13 chalking of the epoxy on the surface, but that's a 14 matter of surface oxidation.
15 There are a number of studies going on 16 right now to actually quantify that number, but we're 17 looking at fractions of a mil and it tends to be 18 surface oriented.
It's a radio oxidation phenomena.
19 There is a study going on sponsored by Electrocar 20 Power Research Institute and Electricitas de France, 21 which is going to quantify that, but we're two years 22 away from that. But basically, it's a surface 23 oxidation phenomena.
24 MR. POLONSKY:
Your Honor, if we could 25 just perhaps refresh Mr. Cavallo's memory? We do have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 729 1 specific testimony on this in AmerGen's direct 2 testimony on Part 5. It was part of the answer to A7, 3 which went from -- started on page 7 of 17.4 MR. CAVALLO: What I would like to add is 5 the actual dose rates that were estimated in the 6 drywell, based on measurements that with a dose rate, 7 this is in the section that was just quoted by 8 counsel. 5.6 rads per hour and since the 1992 outage 9 when the coating was installed, we would have 10 estimated a dose of 1.1 x 1 0 6th rads. Most of our 11 epoxy or all of our epoxy coatings used in nuclear 12 power today have been tested to 1 x 1 0 9th rads per 13 hour. So we are three orders of magnitude higher.14 JUDGE BARATTA: That was the number that 15 was missing-was the 1 0 9th-o 16 MR. CAVALLO: Exactly.17 JUDGE BARATTA: Thank you.18 MR. CAVALLO: You're welcome.19 CHAIRMAN HAWKENS: Dr. Hausler, you have 20 heard the testimony of AmerGen and the NRC staff. Is 21 there anything that they said that was error?22 MR. HAUSLER: No. I haven't, you know, 23 seen anything that is in error. I am wondering how 50 24 years experience with a coating actually relates to 25 specifically to the coating life. You know, we're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 730 1 talking about a coating life here of, you know, 18 to 2 20 years. I expect it to last another 40 years. And 3 my question is, you know, how much experience do we 4 really have with respect to this coating going to last 5 for another 20 years?6 CHAIRMAN HAWKENS: AmerGen, could you/7 respond to that, please?8 MR. CAVALLO: Okay. Could you possibly 9 play the question, Judge Hawkens, to help me out with 10 answering, because AmerGen will answer part of this.11 CHAIRMAN HAWKENS: Let me see if I can 12 rephrase it. Citizens are concerned because they 13 recall earlier in the record, it was suggested that 14 this epoxy life may have had a coating between 10 and 15 15 years. Given that that has expired, we're seeking 16 an extension of 20 years. How does past experience 17 with epoxy coatings give assurance that this epoxy 18 coating which arguably is at a very late stage in life 19 will maintain its integrity during the renewal period?20 MR. HAUSLER: Thank you, Judge. You have 21 done better than I could..22 MR. CAVALLO: Let us answer that in two 23 parts. One, could we first address the 18 to 20 year 24 question?
And I would like Mr. Ouaou to address that 25 with AmerGen.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 731 1 MR. OUAOU: Your Honor, I think if we can 2 refer to Exhibit 16 which I believe that it says in 3 Exhibit 16, which I believe Dr. Hausler was referring 4 to, Citizens exhibit, Citizens, yes. This is a 5 transcript of our testimony before the ACRS. Citizens 6 Exhibit 16. I just want to refresh Dr. Hausler's 7 memory on what I said in the meeting.8 What I said in the meeting is that there 9 were some original estimates initially when the 10 coating was specified that the expected life of the 11 coating was 8 to 20 years, something less than 20 12 years. And what I found out is that I spoke to the 13 supplier or the vendor of the coating is that the 14 vendor cannot really guarantee a life of any coating 15 beyond 8 years or something less.16 However, the vendor suggested that the 17 setting, the environment the coating is in, we should 18 not expect it to last for a long time. And as far as 19 the life, the only way you would determine that is by 20 doing inspections and do repairs if you see anything 21 that comes up. And if you do that, the coating we 22 have will last for a long time. And this is reflected 23 in the --24 JUDGE ABRAMSON:
Do you have any 25 information that would lead you to believe there would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 732 1 be a relatively rapid-'deterioration at some point or 2 that therefore in between inspections there might be 3 some rapid deterioration and you might miss it?4 MR. OUAOU: No, Your Honor, no.5 JUDGE ABRAMSON:
Nothing in your 6 experience with the vendor. How about Mr. Cavallo in 7 your experience, have you ever seen rapid 8 deterioration of epoxy coatings?9 MR. CAVALLO: Not applied properly with 10 the degree of care and inspection that these coatings 11 were applied to. We have not seen end of life failure 12 in epoxy coatings in nuclear power plants due to age.13 JUDGE ABRAMSON:
Okay. Now, let me ask 14 the staff. If there were some deterioration observed 15 in the coating at some point and it got so severe that 16 the coating needed replacing, how would the staff 17 handle that sort of an incident?18 DR. DAVIS: Well, through the inspections 19 they would have to replace it if they saw 20 deterioration in the coating.21 JUDGE ABRAMSON:
Thank you.22 DR. DAVIS: But in -- to just add to what 23 Jon said, primarily the reason coatings fail is 24 because of poor surface finish. And then the second 25 factor is the application of the first layer and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com l * *v 733 1 failure normally occurs very quickly within the first 2 few years if it's going to occur. Once it gets past 3 the first few years, then it goes on to five or six 4 years. Then it is much likely to get a rapid failure 5 of the coating. It's much less likely to see a rapid 6 failure.7 MR. WEBSTER: Judge, could Dr. Hausler 8 comment on this?9 CHAIRMAN HAWKENS: Please, go ahead.I0 MR. HAUSLER: Well, I think this is, you 11 know, pretty much one opinion against another opinion.12 I think it is well-known that the epoxy in particular 13 are, you know, subject to, you know, continued 14 hardening with life, particularly, if the temperature 15 is elevated, that is one thing. Another --16 JUDGE ABRAMSON:
Well, what constitutes 17 elevated, in your view?18 MR. HAUSLER: You know, about 150 degrees.19 JUDGE ABRAMSON:
And have you seen this 20 type of epoxy in use, the type -- this three coat type 21 of this particular chemical composition in use in your 22 experience?
23 MR. HAUSLER: No, sir, I haven't seen it.24 I know it from the literature, but this kind of thing 25 happens. I also know it from understanding of basic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 734 1 chemistry that is involved in forming it.2 JUDGE ABRAMSON:
Are you a chemist?3 MR. HAUSLER: Yes, sir.4 JUDGE ABRAMSON:
Okay. You have 5 experience in the chemistry of epoxy coatings?6 MR. HAUSLER: We did study the nature of 7 epoxy, you know, quite extensively, you know, along 8 with other, you know, polymers, you know, in -- you 9 know, during the, you know, education, that's right.10 CHAIRMAN HAWKENS: Carry on.11 MR. HAUSLER: Well, the point I wanted to 12 make is that embrittlement of a coating does, in fact, 13 occur. You know, that is known. It does depend on 14 the formulation of the specific epoxy, you know, that 15 there is no question about that. You know, you can 16 avoid the embrittlement with age by choosing the 17 different, you know, components, either, you know, the 18 epoxide itself or the hardener.19 JUDGE ABRAMSON:
And what can you tell us 20 about the chemical composition of this particular 21 epoxy that tells us whether, in your view, this is the 22 kind of epoxy composition that is subject or is not 23 subject to such embrittlement?
24 MR. HAUSLER: I cannot tell you anything 25 about that. I'm not familiar with this specific NEAL R. GROSS COURT REPORTERS AND. TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
.o 735 1 composition.
2 MR. WEBSTER: Perhaps Dr. Hausler can do 3 two things. One thing is he can identify something 4 where he positively knows something, but he also can 5 identify data gaps, where, in fact, a certain fact is 6 not known and I think there is a danger here that we 7 don't. get to those data gaps if we just keep 8 positively asking do you know this. I could suggest 9 to him are you happy, Dr. Hausler, that the data that 10 we have leads to a reasonable certainty that it won't 11 be a rapid end of life failure of this coating?12 MR. HAUSLER: I don't think that the data 13 will indicate that. I am particularly concerned about 14 the fact that this particular area is subject to not 15 only temperature variations, but, in fact, to 16 vibrations.
We know that the floor, the sand bed 17 floor that was heavily coated with this epoxy has 18 broken up several times and had to be, you know, 19 repaired.
We also know that concrete, parts of the 20 concrete from the, you know, concrete wall around the 21 drywell shell do come lose due to vibration and 22 temperature changes.23 JUDGE ABRAMSON:
So you are comparing the 24 epoxy that was applied to a concrete surface, the 25 floor, to the concrete that was applied to the carbon NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 736 1 steel liner? Is that what --2 MR. HAUSLER: No, I mentioned the-example 3 in order to illustrate that, in fact, there are 4 vibrations and there are stresses.5 MR. POLONSKY:
Objection.
Foundation for 6 vibration.
7 JUDGE ABRAMSON:
Well, we understand.
8 Let's carry on.9 MR. HAUSLER: And that can, in fact, you 10 know, with age of the epoxy, in my opinion, lead to, 11 you know, possible, you know, crack formation.
12 JUDGE ABRAMSON:
And would you expect the 13 crack formation to be a function of how the material 14 to which the epoxy is applied responds to these 15 vibrations and stresses and would you expect there to 16 be a difference in the response of a steel vessel from 17 that of a concrete?18 MR. HAUSLER: The process may be slower, 19 but in principle, I think, that if, in fact, the steel 20 has different coefficient of expansion around the 21 epoxy and-the steel does expand with temperature and, 22 you know, on top of it we know that there are 23 vibrations there. We understand that. In fact, yes, 24 it can happen either on concrete or on steel.25 JUDGE ABRAMSON:
And would you expect NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 737 1 there to be a difference in the response of the two 2 kinds of materials to vibrations?
I mean, are you 3 familiar with how concrete in these circumstances in 4 this plant behaves? How it decomposes?
How it 5 responds to vibration?
6 MR. HAUSLER: Let me answer the question, 7 counselor.
8 MR. WEBSTER: No, I'm very happy to answer 9 the question.
I'm just going to suggest that, 10 obviously, Dr. Hausler is not as familiar with the 11 specific details of the plant as AmerGen's witnesses.
12 JUDGE ABRAMSON:
We understand.
He is 13 trying to draw an analogy between the way epoxy 14 coating on the cement floor might behave and how the 15 epoxy coating on this stainless
-- on this carbon 16 steel membrane might behave. And I'm trying to 17 understand what the foundation is for that analogy or 18 comparison.
19 MR. HAUSLER: So just to clarify, Judge, 20 then you're asking in principle, rather than that 21 specific plant?22 JUDGE ABRAMSON:
Yeah. I'm asking in 23 principle, but I want to understand what his 24 understanding is of how concrete behaves under these 25 circumstances versus- how carbon steel behaves under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.neairgross.com v
738 1 it, 1 inch thick carbon steel behaves under these 2 circumstances.
3 MR. HAUSLER: Okay. Well, you know, the 4 analogy is -- you know, was brought forth because, you 5 know, we know that the concrete floor has broken up.6 And when we know that there is this sort of --7 MR. WEBSTER: Does that leave epoxy 8 coating to the concrete floor?9 MR. HAUSLER: The epoxy coated concrete 10 floor has broken up. We know that.11 JUDGE ABRAMSON:
And I'm saying, you think 12 that has broken up because of what happened to the 13 concrete or that has broken up because of the flaws in 14 the epoxy? What are you suggesting?
15 MR. HAUSLER: Actually, we don't know 16 that.17 MR. WEBSTER: Judge, let's just say what 18 you are saying is that Dr. Hausler can testify to 19 things we don't know as well as things he does know?20 And I think the things he doesn't know, since we don't 21 bear the burden of proof, things he doesn't know need 22 to be addressed.
23 JUDGE BARATTA: Could I ask if--- let's 24 say that for whatever reason that the epoxy cracked.25 Would that be visible in such a way that it could be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 739 1 detected by a visual inspection, which is conducted 2 periodically?
3 MR. HAUSLER: It would eventually become 4 visible. There's no question about that, of course.5 What we have suggested early on is that the inspection 6 could be much more effectively carried out by tools 7 that are specified, for instance, by name. These are 8 very simple and don't laugh now, but electric and 9 sponge type surface examinations.
10 MR. SILVERMAN:
Your Honor, this does go 11 to the monitoring of the coating, which is outside the 12 scope of the proceeding.
13 CHAIRMAN HAWKENS: I do agree it's outside 14 the scope. I'll just let him finish his thought.15 MR. HAUSLER: Well, I think, you know, any 16 damage to the coating could very easily be detected, 17 you know, prior to actually prior to serious damage 18 happening.
That's what we have, you know, suggested 19 early on that, you know, the coating should undergo 20 rigorous quality control and not just a visual 21 examination.
Such examination should be, you know, 22 more frequent than, you know, every 4 or 10 years.23 MR. WEBSTER: Can I just clarify here that 24 I think Dr. Hausler -- can I just clarify, Dr.25 Hausler? When you say it could be detected, do you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 740 1 mean by methods other than visual inspection?
2 MR. HAUSLER: That's correct.3 CHAIRMAN HAWKENS: We understand that 4 argument and as AmerGen correctly said, this is 5 outside the scope.6 MR. WEBSTER: I think it goes to the issue 7 of frequency of monitoring.
If there is a danger that 8 the coating floors will not be identified through 9 visual inspection, then it effectively means that the 10 longer period where corrosion could occur.11 JUDGE BARATTA: Thank you.12 MR. SILVERMAN:
Your Honor, could AmerGen 13 just follow-up on the issue of temperature effects, 14 which Dr. Hausler testified to?15 CHAIRMAN HAWKENS: Please. Let's hear 16 from AmerGen on how the thermal -- how temperature 17 might affect the behavior of this concrete and its 18 embrittlement.
I'm sorry, this epoxy coating.19 MR. CAVALLO: Now, I'll address that 20 question, sir. Dr. Hausler mentioned a number of 150 21 degrees fahrenheit.
In fact, the maximum exposure 22 temperature, which is in our direct testimony, is 130.23 So this coating will never see anything about 130 plus 24 a little ever.25 JUDGE ABRAMSON:
And in your experience NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 741 1 with epoxies, is his number of 150 a reasonable number 2 of where it might start to become embrittled or is it.3 4 MR. CAVALLO: No, no. The surface --5 JUDGE ABRAMSON:
-- that's a number out of 6 the air?7 MR. CAVALLO: Excuse me, sir. I didn't 8 mean to interrupt you.9 JUDGE ABRAMSON:
That's okay.10 MR. CAVALLO: The surface condition of 11 this coating, as in most of our epoxy polymers, is 250 12 F continuous.
13 JUDGE ABRAMSON:
So it is designed to 14 handle 250 without embrittling?
15 MR. CAVALLO: Yes, sir. This coating was 16 originally intended for a tank lining, continuous 17 immersion, aggressive service at temperature up to and 18 including 250 F. So it's a much more robust coating 19 than would be needed under normal circumstances in the 20 sand bed region. This was selected to give an extra 21 order of confidence to the performance.
22 JUDGE BARATTA: And the only situation 23 that you could even approach those would have to be in 24 an accident condition or maybe you're not -- you can't 25 comment on that.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 742 1 MR. CAVALLO: I am not aware what the 2 temperature would be in an accident situation.
3 JUDGE BARATTA: Yeah.4 MR. OUAOU: The temperature in an accident 5 condition, I believe, is around 281 degrees to 340.6 JUDGE BARATTA: And that would be an 7 extreme?8 MR. OUAOU: That's an extreme, yes.9 MR. CAVALLO: But I believe, correct me if 10 I'm wrong, Mr. Ouaou, that temperature is inside the 11 drywell, so we may not -- the coating on the outside 12 might not see that.13 MR. OUAOU: That is correct.14 JUDGE BARATTA: And even under those 15 circumstances, you would probably--
would you do an 16 inspection?
You would have to do an inspection on the 17 whole system.18 MR. OUAOU: That inspection is required 19 after that.20 MR. WEBSTER: Could we just clarify the 21 record a little bit? The testimony where the pre-fire 22 was 130, where was that?23 MR. OUAOU: That is -- oh, I'm sorry.24 MR. POLONSKY:
That can be addressed in 25 Part 1 of the testimony, the temperatures, and it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 743 1 also incorporated in Part 6 which we will hear from 2 next.3 MR. WEBSTER: Okay. Well, I think Dr.4 Hausler, do you have another comment on that?5 MR. HAUSLER: Yes, I do.6 MS. BATY: Excuse me, before we move on, 7 oh, sorry.8 MR. WEBSTER: We're not moving on. We're 9 keeping -- there is no intention to move on. The 10 intention
*is to stick precisely with this question.11 MS. BATY: Excuse me, can I ask my 12 witnesses if they have anything to --13 JUDGE ABRAMSON:
Not yet.14 MS. BATY: -- add about --15 JUDGE ABRAMSON:
Not yet, counselor.
16 MS. BATY: -- epoxy coating on -- the 17 difference of epoxy coating on carbon steel versus on 18 the concrete floor?19 JUDGE ABRAMSON:
Yes, that's where I want 20 to go with AmerGen and with the staff.21 MS. BATY: Okay. Thank you.22 JUDGE ABRAMSON:
AmerGen, do any of your 23 witnesses have experience or knowledge that might help 24 us understand the difference of the behavior of 25 concrete and carbon steel to the kind of vibration NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 744 1 environment and how concrete can break up and what it 2 does to the epoxy? We would like to know whether this 3 analogy to -- of knowing that epoxy has appeared to 4 have broken up when the concrete broke up makes -- is 5 relevant.6 MR. CAVALLO: I'll attempt to address that 7 properly.
Two things to realize about the coating 8 system applied to the concrete versus applied to the 9 steel. The steel was pre-primed using a penetrating 10 epoxy seal, again 100 percent solid. That sealer was 11 not applied to the concrete.
The second thing to 12 realize is this coating material can be applied, since 13 it is solvent free up to a quarter of an inch thick, 14 as recommended by the manufacturer.
15 The coating was applied to the concrete 16 less as a preventive measure, but more to slope the 17 coating, as you heard yesterday, towards the drains.18 It was actually used as a surfacer to change -- to 19 correct the contours.
When --20 JUDGE ABRAMSON:
So it was not designed to 21 prevent moisture penetration into the concrete.
It 22 was designed to guide the water into the drains? Is 23 that --24 MR. CAVALLO: That's my understanding.
25 But let me let AmerGen address that directly.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.,*N.W.
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745 1 MR. OUAOU: That is correct, Your Honor.2 We--3 CHAIRMAN HAWKENS: Please, identify 4 yourself.5 MR. OUAOU: Ahmed Ouaou. The epoxy on the 6 floor is actually a putty that was used to fill in the 7 irregularities that were identified in the floor and 8 sent that back in in the late '80s, '90s time frame.9 It's not just a coating. Actually, it's about -- in 10 some cases before to 8 inches thick. And it is not a 11 coating as we know it.12 If I may just add, I'm not sure the source 13 of the vibration that, you know, Dr. Hausler was 14 talking about. I think in our testimony we indicated 15 that the irregularities or the defects in the floor of 16 the sand bed is actually-a result of not having 17 finished during construction.
It was never -- the 18 sand bed floor was never finished and it's, in my 19 opinion, not a result of live --20 MR. WEBSTER: Might I clarify the record 21 with that. I think there's some confusion about what 22 the sand bed floor is, whether it is the concrete or 23 whether it's the epoxy. Dr. Hausler's testimony did 24 not relate to the concrete floor. It related -- which 25 is I think what Mr. Ouaou's testimony relates to. It NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 746 1 relates to the epoxy.2 JUDGE ABRAMSON:
Yeah, we understand that.3 Thank you, counselor.
4 MR. CAVALLO: And I think that again, the 5 thing to keep in mind is that the coating on the floor 6 has no connection with the coating on the corrosion 7 preventive coating on the concrete or the steel liner.8 JUDGE ABRAMSON:
When you say no 9 connection, you don't mean that there's no physical 10 connection?
11 MR. CAVALLO: No, no.12 JUDGE ABRAMSON:
You mean it's an entirely 13 different purpose and entire different material?14 MR. CAVALLO: Thank you. Philosophical 15 connection, right.16 JUDGE ABRAMSON:
All right. Staff has an 17 expert who can add some information to this that I 18 understand?
19 DR. DAVIS: Jim Davis. I don't have 20 anything else to add. I agree with what they have r 21 said.22 MS. BATY: They who?23 DR. DAVIS: AmerGen.24 MR. WEBSTER: Judge, I do think Dr.25 Hausler has another comment, if you have time.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 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 747 CHAIRMAN HAWKENS: Is it directly related to what we just asked of the staff and AmerGen? And if it's not, if you can be very brief, go ahead.JUDGE ABRAMSON:
And not get on your sand box.MR. HAUSLER: Let me just let it go at that.CHAIRMAN HAWKENS: I'm sorry, I didn't hear you, Dr. Hausler?MR. HAUSLER: I said let it just go at that, since Judge Abramson doesn't like my sand box, I think I'll just shut up.JUDGE ABRAMSON:
If you have technical information to add that we haven't already seen in written testimony and we haven't already heard, we welcome it, but if it's just repetitive, we don't need it.MR. HAUSLER: There is --MR. WEBSTER: I think perhaps the point is --MR. HAUSLER: -- a concern. There is a lot of confusion about, you know, what the product really is. The difference between the epoxy on the floor and the epoxy on the shelf. It had not been specifically, you know, pointed out. However, what I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 748 1 do want to point out is that I was not previously 2 aware of the fact that this is not a solvent 3 containing epoxy. That really makes it all the more 4 difficult.
5 It is more highly viscous epoxy and it 6 makes it more difficult for air bubbles to escape.7 And I think that would have made it all the more 8 important and imperative to apply good quality control 9 to the epoxy coating after it had been applied in the 10 sense that -- in the same sense that this quality 11 control was applied to the test panels that, you know, 12 had been epoxy coated in the mark-up.13 MR. WEBSTER: Could I also -- but I also 14 think it's useful to clarify the difference in 100 --15 these various temperatures.
I think it's useful for 16 Dr. Hausler to clarify whether these temperatures are 17 threshold temperatures, so there is no effect below a 18 certain temperature or whether they relate to the 19 right situation.
20 MR. HAUSLER: Well, you know, we are 21 talking about chemistry.
And chemistry doesn't start 22 at 250 degrees or not. Chemistry is depending on 23 kinetics and, you know, kinetics are accelerated with 24 temperature.
But that doesn't mean that the kinetics, 25 you know, are not prevalent at 130 or 150 degrees.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 2 3 4 5 6 7 8 9 10 11 12 13.14 15 16 17 18 19 20 21 22 23 24 25 749 And we have all the time in the world, you know, for things to happen in the reactor over the next 20 years. And that, in my opinion, is a concern.CHAIRMAN HAWKENS: I do want to give the AmerGen and opportunity to respond, if it wishes to, to the two points that he made about temperature and about his concern about the epoxy did not contain a solvent may have made it more susceptible to problems at the application.
MR. WEBSTER: Let the record reflect that counsel is consulting with the witness. He was supposed to do that --MR. POLONSKY:
I'll do it on the record.MR. WEBSTER: Thank you.MR. POLONSKY:
If your pre-file testimony you believe already covers this, the Board has this in front of them. If you think this is somehow something new, you should address it.MR. CAVALLO: There is a -- just one point of clarification, one point of technical clarification.
One, the technical data sheets are in the pre-file testimony and have been available since the -- it's our -- AmerGen's Exhibit 35, I believe, and I hate trusting my memory, but I believe it's 35.Both the pre-prime and the epoxy have been available NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com.
750 1 since the start of these proceedings.
2 Second, the use of a 100 percent solid 3 epoxy is preferable in that in Dr. Hausler's pre-file 4 testimony, he refers to things like shrinkage.
There 5 is no shrinkage and equate that to cracking with 100 6 percent solid epoxy. That' -- in reviewing this after 7 the fact, the selection, I applauded, because it was 8 the proper way to go, because we eliminated shrinkage 9 as a potential defect producer.10 I think that's all the clarification I 11 need to add.12 MS. BATY: Your Honor, can I --13 CHAIRMAN HAWKENS: Thank you.14 MS. BATY: Could I ask that the Board as 15 both AmerGen and Dr. Hausler about Dr. Hausler 16. suggested that 20 -- things could happen over the next 17 20 years and then AmerGen did not respond. I'm 18 wondering the frequency is 4 years between inspections 19 and I wonder if there would be any effect on their --20 on Dr. Hausler's testimony if he knew -- if he was 21 thinking in terms of the 4 year interval of 22 inspection.
23 MR. WEBSTER: Can I just clarify for the 24 record? I do believe Dr. Hausler said something that 25 reflects that he thinks that the coating end of life NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com v
751 1 could occur during the next 20 years and, therefore, 2 it's relevant to try to understand.
3 MS. BATY: Could AmerGen address the 20 4 years and how likely it is to fail between inspection 5 intervals?
6 JUDGE ABRAMSON:
Counselor, let me pick 7 this one up. First of all, we have asked the parties 8 about rapid deterioration.
And the real question is 9 is there going to be deterioration that would occur so 10 rapidly that it wouldn't be detected in between 11 inspections?
I don't see the need for any further 12 testimony on that from anybody. While we appreciate 13 your concern and your interest in our obtaining proper 14 knowledge, I think we have enough knowledge on this 15 point. If my colleagues disagree, they will certainly 16 speak up.17 JUDGE BARATTA: No further questions.
18 CHAIRMAN HAWKENS: Thank you. We are done 19 with that Panel 5. We do have before we go to Panel 20 6 and we may hold off on Panel 6 until lunch, but Dr.21 Baratta had a few questions for Dr. Hartzman.
He is 22 an NRC staff witness.23 JUDGE BARATTA: I want to go back and 24 revisit this ASME Code requirement for design.25 CHAIRMAN HAWKENS: May I interrupt?
Dr.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 752 1 Hartzman; as always, when you are testifying today, 2 you remain under oath.3 DR. HARTZMAN:
Yes, sir.4 CHAIRMAN HAWKENS: Thank you.5 JUDGE BARATTA: Okay. We're at the design 6 phase. The ASME Code requires a factor of 2. Is that 7 correct?8 DR. HARTZMAN:
That is correct.9 JUDGE BARATTA: Now, for subsequent 10 modifications to the plant, what is required for a 11 factor of safety?12 DR. HARTZMAN:
The same factor of safety.13 JUDGE BARATTA: Okay. When you are 14 dealing with modifications, does it also cover 15 resolution of discrepancies that they have occurred 16 due to-construction errors or due to other factors?17 DR. HARTZMAN:
Any kind of physical 18 modification would require meeting the cold case, the 19 cold case specified factor of safety.20 JUDGE BARATTA: All right. So if there 21 were a deviation that occurred due to construction 22 error, would that then have to be analyzed to 23 determine if that factor of safety would be met?24 DR. HARTZMAN:
It would have to be 25 checked, yes.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 753 1 JUDGE BARATTA: And what would be done if 2 it did not?3 DR. HARTZMAN:
It would have to be 4 submitted to the staff for review and for -- for 5 review and approval.6 JUDGE BARATTA: And what would the staff 7 usually require in order to make an assessment?
8 DR. HARTZMAN:
A thorough review of 9 whatever analytical evaluation was done of this 10 deviation.
11 JUDGE BARATTA: Would they require an 12 analytical evaluation typically?
Would an analytical 13 evaluation be typically required?14 DR. HARTZMAN:
Yes, I would think so, yes.15 JUDGE BARATTA: Okay. Thank you.16 CHAIRMAN HAWKENS: We are going to take a 17 break before we sit the final panel, which will be on 18 future corrosion.
We're going to make it an hour and 19 15 minutes, so we will reconvene at 12:45. During.20 that time, the parties will have another opportunity 21 to present this Board with any proposed questions 22 they may wish the Board to ask regarding the topics we 23 have just covered. And again, the proposed questions 24 should be linked to the line of questioning that were 2'5 asked by the Board Members.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com v
754 1 MR. WEBSTER: Judge?2 CHAIRMAN HAWKENS: I meant 12:45 we will 3 reconvene.
4 MR. WEBSTER: Judge, I think we are making 5 good progress today, but I think we do have quite a 6 lot of loose ends to wrap up during the break. I 7 think it would be helpful rather than taking another 8 break to wrap those loose ends up if we try to find 9 all the things that we said we would find and provide 10 the --11 CHAIRMAN HAWKENS: Are you saying an hour 12 and 15 minutes is not enough?13 MR. WEBSTER: An hour and a half I would 14 be happier with if that's possible.15 CHAIRMAN HAWKENS: NRC staff and AmerGen, 16 do you require an hour and a half also?17 MR. SILVERMAN:
We don't require that much 18 time, Your Honor. I guess we wouldn't have a strong 19 objection.
20 MS. BATY: I don't think --21 CHAIRMAN HAWKENS: You are accommodating 22 as always NRC staff.23 MS. BATY: Yes.24 CHAIRMAN HAWKENS: Given the limited 25 manpower that's available to Citizens, I think that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 755 1 not an unreasonable request. We will go with an hour 2 and a half.3 MR. WEBSTER: Thank you, Judge. We will 4 do our best to wrap up.5 CHAIRMAN HAWKENS: And we'll march 6 through. Let's try to make sure we do have all loose 7 ends wrapped up in that time.8 MR. WEBSTER: We will absolutely do our 9 best to do that.10 CHAIRMAN HAWKENS: Thank you very much.11 MS. BATY: Oh, Your Honor, there is --12 CHAIRMAN HAWKENS: One second, please.13 MS. BATY: -- a limitation of being able 14 to provide additional questions in writing or at least 15 in typed format.16 MS. WOLF: I never said you need to type 17 one up. Just be clear it has to go into the docket, 18 so it has to be legible. My knowledge is that we 19 don't have a typed requirement, it has to go into the 20 docket. I never said it had to be printed.21 CHAIRMAN HAWKENS: That is good. If it 22 can be typed up, great. If it is handwritten to the 23 extent it's legible, that would be fine. I am advised 24 the library does have a printer available.
So we're 25 in recess.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 756 1 (Whereupon, at 11:34 a.m. the hearing was 2 adjourned, to reconvene at 1:04 p.m. this same date 3 CHAIRMAN HAWKENS: We are back on the 4 record.5 Good afternoon.
Before seating the final 6 panel, could we get Dr. Hartzman back up to the 7 microphone.
A couple of questions we would like to 8 ask him.9 Good afternoon, Dr. Hartzman.
As a 10 reminder, you remain under oath.11 DR. HARTZMAN:
Good afternoon, sir.12 CHAIRMAN HAWKENS: Prior to. the recess, 13 Dr. Baratta was asking you some questions about the 14 safety margin required.
Were you required to comply 15 with the ASME code of 2.0 at the- design phase, at the 16 modification phase, and --17 DR. HARTZMAN:
And at the modification 18 phase.19 CHAIRMAN HAWKENS: And you indicated that, 20 yes, you would be required to comply with that. That 21 would be part of the CLB?22 DR. HARTZMAN:
Yes.23 CHAIRMAN HAWKENS: He also inquired 24 whether -- if there was a deviation
-- deviation as 25 opposed to a modification?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 757 1 JUDGE BARATTA: Either a deviation or a 2 discrepancy.
3 CHAIRMAN HAWKENS: If there were a 4 discrepancy, whether you would be required to comply 5 with the code as part of the CLB, and I believe you 6 answered that in the affirmative as well. Is that 7 correct?8 DR. HARTZMAN:
It depends what kind of a 9 deviation you are referring to.10 CHAIRMAN HAWKENS: Okay.11 DR. HARTZMAN:
What are you referring to?12 CHAIRMAN HAWKENS: Here is my question.13 Do you view the degradation in the sand bed region of 14 the drywell shell as a deviation or discrepancy that 15 would require compliance with the ASME code?16 DR. HARTZMAN:
It is -- You could consider 17 it as a deviation, yes.18 CHAIRMAN HAWKENS: And to follow up with 19 that, do you as a representative of the NRC staff view 20 that as a deviation that requires compliance with the 21 ASME code which requires a safety margin of 2, and 22 that is viewed as part of the CLB?23 DR. HARTZMAN:
We have examined the way 24 the licensee has approached this deviation, and we 25 have concluded that in this case the factor of safety NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www~nealrgross.com v
758 1 of the code case would not be required to be met.2 JUDGE ABRAMSON:
Let me pursue this for a 3 moment, because it seems like we are getting some 4 variation in the responses to our questions.
5 If it were a regular deviation, you would 6 require the 2.0 safety factor?7 DR. HARTZMAN:
You see, again -- Again, 8 what exactly is meant by deviation?
Are you referring 9 to the corrosion that is --10 JUDGE ABRAMSON:
Yes.11 DR. HARTZMAN:
-- that has been measured?12 JUDGE ABRAMSON:
Yes.13 DR. HARTZMAN:
Okay. Ordinarily, the 14 licensee would be advising us that the -- a corrosion 15 situation has existed, and they would provide 16 analytical recommendation for us to review; and if the 17 basis for the analytical recommendation is acceptable, 18 we would say we will accept the deviation
-- a 19 deviation would not -- and the factor of safety of 2 20 would not be required to be met.21 JUDGE ABRAMSON:
Okay. let's pursue this 22 a little further, because we have a lot of additional 23 information about the analysis that the applicant 24 provided to you -- licensee provided to you in this 25 case.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS , 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 759 1 They provided you with analysis that 2 indicated, if the entire sand bed region were degraded 3 to .736 --4 DR. HARTZMAN:
That is correct.5 JUDGE ABRAMSON:
If -- then that would 6 produce a safety factor of 2, but they also provided 7 the staff with information that the entire sand bed 8 region is not degraded to .736. Did that enter into 9 your thinking?10 DR. HARTZMAN:
That was part of it, yes.11 JUDGE ABRAMSON:
And they also provided 12 you with analysis-that indicated, if the entire sand 13 bed region were degraded to .736 and there were 14 additional tray degraded along the lines of the -- oh, 15 why can't I -- What is the right phrase?16 MR. POLONSKY:
Local buckling criteria.17 JUDGE ABRAMSON:
Local buckling -- local 18 buckling criteria degradation
-- Why is that a blank 19 in my brain? I don't know -- that that would produce 20 a somewhat lower safety factor, but that there was 21 evidence to indicate that the liner was not degraded 22 to that condition.
So that was another piece of 23 information they gave you.24 Did that enter into your thinking?25 DR. HARTZMAN:
That would be one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 760 1 consideration.
2 JUDGE ABRAMSON:
Okay. So you've got two 3 sets of analyses that the applicant provided to the 4 staff, both of them based on hypotheticals, neither 5 representing the actual conditions, both of which 6 indicate -- one of which indicated that it would 7 produce a safety factor of 2, and one which indicated 8 it would produce a safety factor of something like 9 1.9, a little more than 1.9.10 Those entered into your accepting this 11 configuration.
Do you view yourselves as having 12 accepted a safety factor of less than 2 or not; and if 13 so, why do you believe there is a safety factor of 14 less than 2 when you don't have any analysis of the 15 current configuration?
16 DR. HARTZMAN:
No. The licensee provided 17 an analysis of what you call the local buckling 18 criteria.
We examined that analysis fairly 19 thoroughly.
We came to the conclusion that that 20 analysis was detailed enough, was refined enough. The 21 basic assumptions on which that analysis is based is 22 refined and conservative
-- and conservative to admit 23 the possibility that the factor of safety was indeed that analytically, the factor of safety -- it was 25 less than 2, analytically.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 761 1 JUDGE ABRAMSON:
The computed safety 2 factor, but even though it was less than two, as -- I 3 don't want to put words in your mouth, but to me there 4 is--5 MR. HARTZMAN:
The basis The basis for 6 the criteria -- The basis for the criteria, which is 7 that analysis that G.E. provided, and other 8 information, supported a lower factor of safety. In 9 addition to that --10 JUDGE ABRAMSON:
You mean the theoretical 11 lower safety factor?12 MR. HARTZMAN:
Yes, theoretical, This is 13 an analytical factor of safety. the actual factor of 14 safety of the as built structure is higher than the 15 factor of safety corresponding to the acceptance 16 criteria, for the simple reason that the actual 17 thickness, the wall thickness, is greater than what 18 was chosen for the acceptance criteria.19 So, yes, it is very possible that the true 20 factor of safety may be as high as 2 or greater, even 21 today, even with degraded areas.22 MR. WEBSTER: Judge, I don't think the 23 witness has quite answered the question of what is the 24 acceptable level factor of safety.25 JUDGE ABRAMSON:'
We haven't answered it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 762 1 sufficient for our purposes.2 CHAIRMAN HAWKENS: Thank you, Dr.3 Hartzman.4 Would AmerGen please introduce the 5 witnesses for the final panel.6 MR. POLONSKY:
Yes, Your Honor. This is 7 Mr. Polonsky.
For Panel 6, seated to my right is --8 MR. WEBSTER: Sorry. Before Mr. Polonsky, 9 just remind the panel that we do have a few loose ends 10 to sweep up from this morning with regards to debris 11 in the concrete -- concrete debris in the drains, and 12 a couple of other issues.13 CHAIRMAN HAWKENS: Thank you for bringing 14 that to my attention.
Why don't we tie up those loose 15 ends first before going to the final word.16 MR. POLONSKY:
If we could, AmerGen's 17 preference would be to get Panel Six out of the way 18 and then go back to the loose ends. Frankly, some of 19 the things we thought were going to be provided to us, 20 like specific citations, you know, we are still 21 looking at. So we would not be prepared to wrap up 22 those loose ends at this time.23 CHAIRMAN HAWKENS: All right. If you are I 24 not prepared to wrap them up, we will proceed with the 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 763 1 MR. WEBSTER: Judge, I think we are 2 prepared to do at least. the concrete debris in the 3 sand bed drains. That's very easy, and it will be 4 cogent with the testimony we had this morning.5 JUDGE ABRAMSON:
Why don't you let Judge 6 Hawkens run this proceeding.
7 MR. WEBSTER: Well, I am merely offering 8 a suggestion.
9 CHAIRMAN HAWKENS: And I appreciate that.10 Let's go ahead and introduce the members of the final 11 panel and go forward with that.12 MR. POLONSKY:
Seated to my right is Mr.13 Michael Gallagher.
Seated to his right is Barry 14 Gordon. Seated to his right is Mr. Edwin Hosterman.
15 Mr. Gordon and Mr. Hosterman have not been on a 16 previous panel. So I guess I would just like to add 17 that Mr. Gordon is with Structural Integrity 18 Associates and is our proffered corrosion expert, and 19 seated to his right, Edwin Hosterman is with Exelon's 20 corporate group out of Kennett Square, Pennsylvania, ,21 and he is more of a heat transfer evaporation expert.22 CHAIRMAN HAWKENS: Thank you.23 MS. BATY: For the NRC staff, we have Mr.24 Hans Ashar, Dr. Jim -- James Davis, Dr. Mark Hartzman, 25 and Dr. -- excuse me, Mr. Timothy O'Hara and Mr.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 764 1 Arthur Salamon.2 CHAIRMAN HAWKENS: Thank you.3 MR. WEBSTER: And for Citizens, 4 metaphorically wearing his spandex and cape, we have 5 Dr. Hausler.6 CHAIRMAN HAWKENS: Thank you very much.7 For the record, the witnesses were sworn yesterday, 8 and the witnesses are reminded, those who have not 9 been empaneled yet today, that they remain under oath 10 or affirmation.
11 JUDGE ABRAMSON:
I have no questions for 12 this panel. The beauty of being a Judge is you don't 13 have to be an expert. It's up to the experts to 14 educate us.15 CHAIRMAN HAWKENS: Let me ask a question 16 to AmerGen. If the coating fails, and if there is 17 water in the sand bed region, what would the rate of 18 corrosion be?19 MR. POLONSKY:
Mr. Gordon is best to 20 answer that.21 MR. GORDON: Assuming that situation, the 22 water -- source of water would be very high purity 23 water, and there have been studies performed, 24 corrosion rate as a function of temperature over this 25 range where the sand bed region is exposed to.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 765 1 Typically, at the temperatures of about, at the lower 2 end where the flaw is, where you would expect to have 3 the most amount of possible water, which is 93 degrees 4 Fahrenheit, the corrosion rate would be about 3 mils 5 per year.6 JUDGE ABRAMSON:
That's assuming no 7 coating?8 MR. GORDON: No coating, fresh surface, 9 shiny steel where the corrosion rate would be at its 10 highest.11 JUDGE ABRAMSON:
And continuous exposure 12 to water?13 MR. GORDON: Continuous exposure over that 14 period.15 JUDGE ABRAMSON:
Refresh my recollection.
16 In the old days when you had the sand bed, what was 17 the computed average corrosion rate over the period?18 MR. GORDON: the highest identified 19 corrosion rate was about 39 mils per year. This is 20 water, saturated sand against bare carbon steel.21 JUDGE ABRAMSON:
What made that so much 22 greater than the situation you are suggesting here?23 MR. GORDON: Well, it's a number of 24 things. You have a higher conductivity water.25 JUDGE ABRAMSON:
Because?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
* .v 766 1 MR. GORDON: You have chlorides present 2 and other impurities and stuff like that, but the only 3 water that would come down now will be very low 4 conductivity water.5 JUDGE ABRAMSON:
Why was that other water 6 -- Why did the water in the old days have chlorides 7 and such in it, and the water that one might expect 8 today to get down there be different?
9 MR. GORDON: Well, it traveled along the 10 shell. It traveled through the sand. The sand is 11 stored in a marine atmosphere outside the plant while 12 the plant was being constructed, and it was basically 13 sort of like marine sand. So it had a lot of 14 impurities in it, and so the conductivity was higher.15 MR. GALLAGHER:
I would like to add, Judge 16 Abramson, as far as that 39 mils per year, it is an 17 early-on corrosion rate before the corrective action.18 If I can just point-you to a graph that 19 shows the long term before the corrective action, look 20 at Exhibit 3, AmerGen Exhibit 3. And I'm sorry, there 21 doesn't seem to be page numbers. Let me see if I can 22 point you to it.23 If you look at -- there is a page 6-22, 24 which is a title page.25 CHAIRMAN HAWKENS: Are we able to put that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 767 1 on the screen? Let's see if we can get it up on the 2 screen.3 MR. WEBSTER: Sorry. Which page?4 MS. YOUNG: 6-22.5 MR. POLONSKY:
We are going to be going to 6 6-22, which is the beginning of Attachment 1, but then 7 there are a number of unnumbered graphs that are 8 within Attachment 1, and once we get to 6-22, we can 9 direct the projector to go to the specific page we are 10 trying to get to.11 MR. GALLAGHER:
So this is -- Go 15 --12 This section has all the graphs. Go 15 slides 13 forward, 15 pages forward, and just -- I just wanted 14 to point out the biggest rate, which is -- It's Figure 15 18. It is labeled Figure 18 at the top. Okay.16 That's it.17 On the lefthand side where it has the 18 corrosion rate of negative-18.mils per year. So that 19 was the rate that was sustained through that period of 20 time before the corrective action was put in place.21 JUDGE ABRAMSON:
What is the relationship 22 between that 18 mils corrosion rate and the 39 you 23 gave me earlier? I'm lost.24 MR. GALLAGHER:
The 39 was an early 25 projection based on a few data points, and it would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealmross.com
* °v ,
768 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 have been, you know, a --MR. WEBSTER: Objection, Judge. That witness didn't testify to the 39. So I don't know how he knows what basis it was.MR. POLONSKY:
Mr. Gordon, can you please respond to that?MR. GORDON: If you can look at AmerGen Exhibit 23, the second page, you will see a table of corrosion rates, and you will see the 39 was the highest rate on that page.MR. POLONSKY:
But, Mr. Gordon, could you address why -- I mean, you started talking previously about a shiny surface and why the corrosion would be higher earlier. Could you address, I guess, that question?MR. GORDON: Yes, certainly.
When you put fresh metal into an environment, the iron wants to go into solution, and if there is nothing there, no film on the surface, it will go in very readily. As film builds up, as rust builds up on the surface, it becomes more and more difficult.
So the initial corrosion rates of fresh metal in a solution is always the highest.JUDGE ABRAMSON:
So these corrosion rates were indicated in the sand bed region when sand was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
* o v 769 1 there holding this water that had a lot of impurities 2 that could cause corrosion?
3 MR. GORDON: , That is correct.4 JUDGE ABRAMSON:
And it was continuously 5 there. What is AmerGen's expectation for the presence 6 of water in the bottom of the sand bed region going 7 forward from today?8 MR. GALLAGHER:
Well, our expectation is 9 there wouldn't be. We have corrected the situation, 10 and we have the leak-off from the trough that handles 11 the water. We have also made commitments that, if 12 water was detected in there, we would take corrective 13 action.14 JUDGE ABRAMSON:
And as we understood from 15 the earlier panel's testimony, the maximum number of 16 days there would be water in the reactor cavity is 17 something like 15 days a year.18 MR. WEBSTER: Objection, Judge. That is 19 not established.
20 JUDGE ABRAMSON:
We were told that the 21 water in the reactor During refueling, the reactor 22 cavity -- Refueling took 26 days, and I think what we 23 heard was that it took something like -- and refueling 24 occurs every other year, and if you take 26 days and 25 divide it by two, you come up with 13. Is that where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 770 1 that comes from?2 So I said 15. I'm sorry if I 3 overestimated it. In fact, we heard information that 4 the water in the reactor cavity is there for less than 5 26 days. It is there for something like three weeks 6 or less. So, in fact, it is a lower number than that.7 So that is where that is coming from. Sorry if I am 8 able to do some of these calculations in my head.9 MR. WEBSTER: I misheard you. MY 10 apologies, Judge.11 JUDGE ABRAMSON:
If there were water there 12 and it were to leak during those 15 days, what would 13 happen to it in the bottom of the sand bed region, 14 once it got there?15 MR. GALLAGHER:
It would drain off into 16 the sand bed drains, and as we testified before, the 17 floor on the sand bed is shaped so that it goes away 18 from the shell and into the drains.19 The other thing I would mention, is we 20 daily -- During refueling outages, because there is 21 water in the reactor cavity at the time, we check 22 those drains daily, the sand bed drains, the five sand 23 bed drains. We check those daily.24 JUDGE ABRAMSON:
Oh, you check them daily.25 MR. GALLAGHER:
For leakage.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 771 1 JUDGE ABRAMSON:
So if it drained off, 2 while there might be some residual, one could expect 3 some evaporation of the residual, and if there were no 4 protective coating on the drywell shell, then that 5 would be the time that there could'be some corrosion.
6 Is that correct?7 MR. GALLAGHER:
Yes. As we testified, the 8 time that the water could be on the shell is only 9 during the refueling outage and when the plant starts 10 up, the shell is heated up and --11 MR. WEBSTER: I object on foundation for 12 that.13 MR. GALLAGHER:
-- would quickly evaporate 14 off.15 CHAIRMAN HAWKENS: Objection is overruled.
16 Please continue.17 MR. GALLAGHER:
I'm sorry. And one of the 18 things I do want to point out from Dr. Hausler's 19 testimony, he had indicated that there is no air flow 20 in this region.21 MR. WEBSTER: Objection.
This witness 22 doesn't have expertise in air flow.23 MR. GALLAGHER:
Yes, I do.24 CHAIRMAN HAWKENS: Objection is overruled.
25 Please continue.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 772 1 MR. GALLAGHER:
Between the bioshield and 2 the drywell shell, there is a one-inch air gap. Okay?3 And so there is continuous air exchange between that 4 volume and the exterior, and also from the bioshield 5 is not airtight, because there are various 6 penetrations through the bioshield for the piping that 7 penetrates for the primary containment.
8 JUDGE ABRAMSON:
Natural circulation air 9 flow?10 MR. GALLAGHER:
Yes.11 CHAIRMAN HAWKENS: Does the 3 mil per year 12 include interior corrosion?
13 MR. GORDON: No, that's just based on the 14 exterior corrosion.
15 CHAIRMAN HAWKENS: Do you have any 16 estimate for interior corrosion?
17 MR. GORDON: It would- be very low, 18 probably a value lower than that. You have -- Any 19 water that is present will be high pH concrete pour 20 water, which produces a protective film on the steel, 21 and the corrosion rate is essentially negligible.
22 CHAIRMAN HAWKENS: NRC staff, do you have 23 anything to add to that discussion?
24 MR. ASHAR: I am Hansraj Ashar. I wanted 25 to find out when you ask question that is it internal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 773 1 -- do you mean the corrosion on the inside surface or 2 the measurement is taken from inside?3 CHAIRMAN HAWKENS: My latter question, I 4 was asking whether it be 3 mil per year included a 5 figure for corrosion on the interior.6 MR. ASHAR: Interior.
Thank you, sir.7 CHAIRMAN HAWKENS: Thank you. Nothing 8 more from the NRC staff?9 Dr. Hausler, could we hear from you your 10 response to AmerGen?11 DR. HAUSLER: Yes. I have just a few 12 minor comments, really. With respect to the 3 mils, 13 I would like to comment that that was specified for 93 14 degrees Fahrenheit, and of course, we do know that 15 the corrosion rate is dependent on temperature.
That 16 is the, first thing.17 The second thing is that the high 18 corrosion rate --19 CHAIRMAN HAWKENS: Excuse me, Dr. Hausler.20 So it is your view that it would be slightly higher 21 than 3 mil per year?22 DR. HAUSLER: Well, specifically, the 23 corrosion rate is set to increase -- to double as the 24 temperature increases 10 degrees Centigrade.
That is 25 more or less correct..NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE;, N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 774 1 So in other words, you know, if we go up 2 40 degrees Fahrenheit, you know, we can assume that 3 the corrosion rate more or less quadrupled.
4 JUDGE ABRAMSON:
Mr. Gordon, is that 5 accurate?6 MR. WEBSTER: Excuse me.7 JUDGE ABRAMSON:'
This is our style, and if 8 you will just allow me to get answers to my questions.
9 Dr. Hausler has made an assertion about what the 10 corrosion rate -- what the effect of temperature is on 11 'corrosion rate. I'd like to have an answer --12 MR. WEBSTER: I object. My witness did 13 not have a chance to respond in full to AmerGen.14 AmerGen had a chance to put their case in full, and I 15 think it would really be one-sided if AmerGen rebuts 16 each point, point by point, while we have to wade 17 through it in an interrupted fashion.18 CHAIRMAN HAWKENS: As we informed you at 19 the. beginning before we started this session, the 20 purpose of this session is for us to ask questions and 21 to get answers. We advised you in a telephone 22 conference, and we have advised you on numerous other 23 occasions, that our style is to get various experts 24 and to ask experts what they think of what other 25 people are saying.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1.323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 775 1 We've done that. We are doing it now, and 2 please, Mr. Gordon, just give us your view of whether 3 it is reasonable to expect the corrosion rate to 4 increase with temperature of this kind of magnitude 5 that we are --6 MR. GORDON: Certainly, below a certain 7 temperature
-- The corrosion rate goes through, a 8 maximum. At about 160 Fahrenheit, you reach a maximum 9 corrosion rate in this environment of about 8 mils per 10 year. At 130 degrees Fahrenheit, it is about 5 mils 11 per year. So it does go up, but it doesn't go up by 12 10 degrees. It depends on the activation energy.13 So it's close. It's like 15 degrees, 16 14 degrees, carbon steel.15 JUDGE ABRAMSON:
So now, Dr. Hausler, you 16 have what he has to say about this. What is your view 17 of this?18 DR. HAUSLER: It's a number -- The 19 doubling of the corrosion rate or 10 degrees 20 Centigrade is a number that is quoted in practically 21 all textbooks on corrosion.
I don't think we have to 22 go and establish that in great detail now.23 CHAIRMAN HAWKENS: Fine. Carry on.24 MS. BATY: Would you like to hear from the 25 staff?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202);234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 776 1 MR. WEBSTER: Well, again I would ask if 2 my witness could --3 CHAIRMAN HAWKENS: We have asked who we 4 wanted to ask. Let's have Dr. Hausler keep -- If my 5 colleagues want more information, they will ask. This 6 is our style. This is our hearing. This is our 7 inquisition, if you will.8 MS. BATY: Your Honor, it was just if you 9 wanted to hear from us on the -- our expert on the 10 corrosion rates for the temperature.
11 JUDGE ABRAMSON:
We may.12 MS. BATY: Okay.13 JUDGE ABRAMSON:
Please, Dr. Hausler.14 DR. HAUSLER: Thank you very much. I do 15 appreciate it.16 Let's also consider that the corrosion 17 rate -- you know, whether it is in oxygen or in acid 18 or another environment
-- is highly dependent on the 19 nature of the metal. And in fact, there are different 20 types of steels. For instance, 533A which is a high 21 tensile strength steel, or there is, I think it is 210 22 or 218 that is being here is lower. There are 23 different alloys in these steels to achieve the 24 tensile strength of them. There are different heat 25 treatments, and all of these affect, in fact, the NEAL R. GROSS* COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 777 1 corrosion rate.2 I don't need to go into the detail. I 3 don't need to, I think, give you a lecture on the 4 effects various parameters
--5 JUDGE ABRAMSON:
Did I ask you if we need 6 it?7 DR. HAUSLER: -- that affect the corrosion 8 rate. However, I would like to touch on a different 9 subject, and that is the nature of the water.10 We have seen, in fact, a number of 11 analyses for the water, and that was drained out of 12 the sand bed, and it was accused for the corrosion 13 rates that were --14 JUDGE ABRAMSON:
This was during the --15 before the sand was removed or after the sand was 16 removed? You say drained out of the sand bed.17 DR. HAUSLER: Actually, those were before 18 the sand bed, because the corrosion rates that were 19 quoted of 39 mpy, 18 mpy and so on, were in fact 20 corrosion rates that were established in the sand bed.21 JUDGE ABRAMSON:
Okay. So you really 22 meant the water that was there at the time they had 23 the --24 DR. HAUSLER: Yes. Your question was why 25 39 versus 3, you know, why 18, why the spread. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 778 1 answer was from Mr. Gordon, I believe, because of the 2 amount of chloride that was in there.3 Now it is a fact, of course, that chloride 4 does accelerate the corrosion under these -- corrosion 5 rate under these conditions.
However, the numbers 6 that we have seen for chloride recently were of the 7 order of .04 ppm, and that is too low a number, too 8 low, in fact, a concentration to affect the corrosion.
9 JUDGE ABRAMSON:
Was that water that was 10 taken out late, you know, in recent years as opposed 11 to water that was taken out in the early days when the 12 sand was pretty fresh? What I'm wondering is: These 13 chlorides come from salt in the sand, I assume.14 DR. HAUSLER: Your Honor, we have seen 15 quite a number of water analyses that were, in fact, 16 passed on from AmerGen in the discovery process. Now 17 these --18 MR. WEBSTER: Judge, can I just interrupt 19 my witness a little bit. I think we have to be 20 careful here to distinguish between chlorides on the 21 interior and chlorides on the exterior.
I think the 22 record reflects that water was found that drained from 23 the sand bed region. After years of monitoring, water 24 was found in 1996, but I think the record reflects 25 that AmerGen threw that water away before they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 779 1 analyzed it.2 JUDGE ABRAMSON:
But we are talking about 3 the difference between the corrosion rate 20-some 4 years ago and the corrosion
--5 MR. WEBSTER: No, I understand that, but 6 what I'm saying is I don't think there are recent 7 measurements of the chlorides in the water that 8 drained from the sand bed region.9 JUDGE ABRAMSON:
That is-- But that is not 10 what we were asking. Dr. Hausler, I think, is 11 advising us what he thinks the 'chloride concentrate 12 was in the water that was coming through the sand.13 DR. HAUSLER: Actually, I am trying to 14 advise you that we don't know what the chloride 15 concentration was for the very simple reason that the 16 analytical reports that presumably came out of the 17 laboratory from AmerGen did not indicate the 18 concentration associated with the numbers that were 19 presented there.20 So there is a confusion whether this is 21 actually 48 parts per billion or 48 parts per million, 22 because, you know, at times we have seen in the 23 documentation ppm, and at times we have seen parts per 24 billion.25 Nevertheless, the water that even was 40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 780 1 parts per million would be reasonably fresh, so that 2 we would not expect a great acceleration of the 3 corrosion rate.4 JUDGE ABRAMSON:
So to what do you think 5 one might attribute this higher corrosion rate when 6 the sand was there as opposed to what we are hearing 7 might be expected today?8 DR. HAUSLER: I think it depends on where 9 you measure.10 MR. WEBSTER: Judge, could I just help my 11 witness one second? I just remind the witness about 12 the 5rd material in the gap between the sand bed, and 13 whether that could be a source of chlorides.
14 DR. HAUSLER: Well, that was another sort 15 of confusion.
I didn't want to touch on that, because 16 of the uncertainty there. But the 5rd at one point in 17 the testimony was, in fact, identified.
In fact, I 18 think it is. in the SER identified as magnesium 19 oxychloride, which I think is utterly impossible, but 20 that was the designation there.21 In the beginning, I thought, yes, indeed, 22 you know, thatý's where the chloride comes from, but 23 later I think it was identified as different type of 24 fibrous material.25 JUDGE ABRAMSON:
Is it only chlorides that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 781 1 could cause this differential in the corrosion rate?2 DR. HAUSLER: Well, you know, it is 3 halites, but the most abundant halite, of course, is 4 chloride.
Chloride will not have the same effect, but 5 iodide and bromide would, but the most abundant is, in 6 fact, chloride.7 So I don't think we can take these numbers 8 on face value. They do vary, and we don't really know 9 exactly what the parameters are -- the level of the 10 parameters are that affect the numbers that we are 11 talking about.12 There was a thought that just escaped my 13 brain. I am sorry.14 JUDGE ABRAMSON:
You're not alone.15 DR. HAUSLER: I do have a senior moment as 16 well.17 Of course, you know, we also realize that 18 all of these corrosion rates were, as has been pointed 19 out, before corrective action was taken. So, you 20 know, they don't necessarily
-- are not necessarily 21 valid anymore.22 Judge Abramson, you asked why we would 23 expect a difference between -- a difference of 39 24 versus maybe 10 or 18 or whatever.
I indicated that 25 that was most likely because of where the measurement NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 782 1 was taken.2 The sand is not uniform, as I have 3 indicated earlier. It is not necessarily level, and 4 in this particular case of corrosion that we identify 5 is crevice corrosion or under deposit corrosion.
6 It is very important to, in fact, specify 7 the location where the measurement was taken with 8 respect to the surface of the deposit, and the depths 9 that you go into the deposit to properly characterize 10 *the measurement that has been taken.11 Of course, we don't know that, really, 12 because when the measurements were taken, we assumed 13 that there was a sand bed there, but we didn't know 14 how high it was, what the surface at the sand bed was, 15 and *so on. I think that should explain the 16 differences in these numbers.17 MR. WEBSTER: I think I want to make sure 18 that AmerGen testified that because the epoxy on the 19 floor is there that the water would go to the drains.20 Is that necessarily true?21 DR. HAUSLER: Well, the floor was shaped.22 I haven't been there. So I really can't testify 23 effectively as to what the slope of the floor really 24 was. However, I think I do want to come back to the 25 question of water being there in 2006.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www:nealrgross.com 783 1 Some drains had, in fact, been found 2 plugged. Now if drains are plugged, you don't find 3 any water coming out from the sand bed, but that 4 doesn't mean that there is no water there. That is 5 the first point I wanted to make.6 The second point is that the plugging had 7 been indicated by material -- and this, by the way, is 8 AmerGen's
-- No, it is our Exhibit 52, on the third 9 page. The deposits or the plugging material had been 10 identified as most likely being cement.11 Again, I do ask the same question I asked 12 this morning. How does the cement get into the 13 drains? There has to be water there to sweep it 14 there. Otherwise, we cannot assume that (just 15 fortuitously cement falls off the bioshield right into 16 the drain.17 MR. WEBSTER: One other question.
If 18 there were cracks in the floor, would that have an 19 effect on how the water flows?20 DR. HAUSLER: Yes, of course, it would.21 You know, there was a concern about -- as we had 22 indicated earlier, that the floor cracked. Now we do 23 know that in '92 the floor wasn't finished, etcetera, 24 and then it was built up.25 We also know that more recently the floor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 784 1 had to be repaired again, because there were cracks 2 there. Now in my mind, those cracks would actually 3 cause the water to flow toward -- or could cause the 4 water to flow toward the shield rather than away from 5 it. But we get into an area that may not necessarily 6 be within the scope of this hearing, and so I don't 7 want to pursue it unless you urge me to do that.8 CHAIRMAN HAWKENS: I'd like to hear from 9 the NRC staff on the correlation between temperature 10 and corrosion, please.11 'DR. DAVIS: Hi. This is Jim Davis from 12 the staff.13 It is a little bit more complicated than 14 Dr. Hausler stated. It is very true that the 15 Arrhenius equation applies to all kinetic reaction, 16 and ,that's for every 10 degrees C increase in 17 temperature you get a tenfold increase in reaction 18 rate.19 That assumes that all reactants are 20 constant.21 JUDGE ABRAMSON:
Tenfold?22 DR. DAVIS: Or twofold. I'm sorry, 23 twofold.24 What actually happens is, when you heat 25 water, of course, the oxygen solubility drops. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 785 1 that Arrhenius equation does not hold in water, and 2 also you have to be extremely careful when you are 3 looking at a situation like this, because you may 4 actually be going from corrosion in an immersed 5 condition to atmospheric corrosion, which is a total 6 different ball game.7 I think you would be more likely, although 8 I doubt if you would get much atmospheric corrosion 9 under the conditions, because the humidity is not high 10 enough in this area. So you would see very little 11 corrosion unless you were immersed in water, but it is 12 a little bit more complicated than what Dr. Hausler 13 expressed.
14 That's why you go through a maximum, 15 because -- and you even drop more, like I've done a 16 lot of experiments at higher temperatures where, when.17 you go above about 200 degrees in just a laboratory 18 experiment, your corrosion rate drops dramatically, 19 because your oxygen is almost insoluble.
You no 20 longer have the oxygen driving force for the reaction 21 to occur.22 So you have to make sure that nothing 23 changes when you are applying an Arrhenius equation, 24 none of the reactants change.25 MS. BATY: May I ask the staff's witness NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 786 1 to spell the name of the equation for the record?2 DR. DAVIS: A-r-r-e-n-i-o-u-s, I believe.3 JUDGE ABRAMSON:
I think it is u-s.4 MS. BATY: Someone spell it for the 5 record, please.6 DR. HAUSLER: Well, it is A-r-r-h-e-n-i-u-7 S.8 MR. POLONSKY:
If AmerGen could address 9 two issues, when the Judges are ready.10 DR. HAUSLER: May I respond to the comment 11 from --12 CHAIRMAN HAWKENS: Please, Dr. Hausler.13 Go ahead.14 DR. HAUSLER: What the witness just said 15 is entirely correct. I did not want to bother Judge 16 Abramson with a lecture on the kinetics of corrosion.
17 However, there is another --18 CHAIRMAN HAWKENS: A quick interruption.
19 You have three Judges up here. One is not legally 20 trained. So please, don't hesitate to share your 21 knowledge with us.22 DR. HAUSLER: I am perfectly prepared to 23 that, if you are willing to listen for the next 15 24 minutes.25 CHAIRMAN HAWKENS: Well, that is a little NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 787 1 bit long, but go ahead and summarize what you wanted 2 to say.3 DR. HAUSLER: It is quite correct, of 4 course, that the oxygen eventually now will get out of 5 the water, and so you have competing effects. You 6 have less oxygen, but higher corrosion rate, and you 7 get into questions of mass transfer, how fast can you 8 get the oxygen to the surface of the metal. And so 9 you get into questions of flow rate or stagnant 10 si.tuations and so on.11 If you get to higher temperatures, 12 however, the water can, in fact, take the place of 13 oxygen, and the water can react with iron, you know, 14 forming hydrogen and hydroxide irons, in essence iron 15 hydroxide.
That is why we often find magnetite on the 16 surface of corroded metals or magnetite-type corrosion 17 product.18 So, yes, the witness was quite correct.19 The situation is a lot more complicated than what I 20 ventured to explain in the first part of the 21 testimony.
22 CHAIRMAN HAWKENS: Based on your review of 23 the record, during the time the reactor cavity is 24 filled, what would the temperature range be during 25 that several week period?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 788 1 DR. HAUSLER: I am really confused on 2 that, Your Honor.3 CHAIRMAN HAWKENS: Okay. Should I address 4 that to AmerGen or are you prepared to provide an 5 answer based on the record?6 DR. HAUSLER: Let me tell you what it is 7 that I know. Originally, that there was a pressure 8 specification of 66 psi and the temperature 9 specification for the operation of the reactor 10 environment, the reactor housing of, I believe, 173 or 11 something like that. Later on, the pressure had been 12 lowered to 44 psi, and the temperature had been 13 increased to 273. This is actually in the record.14 Now I just want to mention that I am kind 15 of confused as to what the temperature in that sand 16 bed region really was. I'mh not sure anybody really 17 knows what the temperature there is during normal 18 operation.
19 MR. WEBSTER: Can I just clarify, Judge?20 There are two questions:
What's the temperature 21 during normal operation, and what the temperature 22 during the refueling outage?23 CHAIRMAN HAWKENS: My principal concern 24 was during the refueling outage, because my 25 understanding is that's when the likelihood of water -NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 789 1 -Well, if there is to be water, it is coming from the 2 reactor cavity, and that's when the water would be 3 expected to be there.4 So my question was limited to during that 5 time period, what would you expect the range of 6 temperatures to be?7 DR. HAUSLER: I don't know. I haven't 8 been around. I'm sorry.9 CHAIRMAN HAWKENS: Well, that's all right.10 DR. HAUSLER: I can't answer the question.11 CHAIRMAN HAWKENS: Thank you. Let me see 12 if AmerGen can eliminate the confusion.
13 MR. POLONSKY:
Your Honor, that was one of 14 the two points that I was hoping to get to. If we 15 could hand the mic, I guess, over to Mr. Edwin 16 Hosterman on heat transfer, I believe he has done 17 calculations about what the temperature would be 18 during refueling outages. And you are talking about 19 the exterior where the water would be present?20 CHAIRMAN HAWKENS: That is correct.21 MR. POLONSKY:
Okay.22 MR. HOSTERMAN:
Well, just to be clear, 23 the calculation I did is normal --24 CHAIRMAN HAWKENS: Can you identify where 25 in the record?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 790 1 MR. HOSTERMAN:
Excuse me. Edwin 2 Hosterman, Exelon.3 Just to clarify the record, the 4 calculation that I did for the purposes of calculating 5 evaporation rates was based on normal operation.
,6 However, the starting point for that calculation would 7 be the expected temperature in the air space that 8 would occur during a refueling outage, and those would 9 be roughly the same temperatures that we would see in l0 the torus room, which can range up toabout 90 degrees 11 Fahrenheit, which can range up to about 90 degrees 12 Fahrenheit, and that will vary, depending on when we 13 start the refueling outage and what the outside air 14 temperatures are at the time. But 90 degrees is 15 probably pretty typical for the upper rahge of 16 temperaturesl in that room during an outage.17 CHAIRMAN HAWKENS: Thank you. And is that 18 in testimony in the record or otherwise in a record 19 exhibit?20 MR. POLONSKY:
Let me just quickly look 21 through the rebuttal and surrebuttal testimony.
22 CHAIRMAN HAWKENS: While you are looking, 23 Mr. Polonsky, is there another area you wanted to have 24 a witness address?25 MR. POLONSKY:
Yes. It was the allegation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 791 1 that the drains were plugged, which I guess we 2 interpret as no water could go through, since Dr.3 Hausler suggested we wouldn't see the water. So I 4 thought I would have an AmerGen person answer that 5 question.6 CHAIRMAN HAWKENS: All right.7 MR. POLONSKY:
Pete Tamburro.8 JUDGE ABRAMSON:
Almost as ubiquitous as 9 Dr. Hausler, Mr. Tamburro.10 MR.. TAMBURRO:
I am not sure how to take 11 that. Pete Tamburro..12 I have looked at Exhibit -- Citizens 13 Exhibit 52. This is an issue report that was issued 14 by myself during the 2006 outage.15 During the 2006 outage, we inspected the 16 five sand bed drains. The way we inspected them was 17 by inserting the boroscopic device, and we snaked it 18 through the entire drains.19 Three of the drains were completely empty 20 and had no debris in it. A fourth drain had some 21 debris in it, but we were able to push the boroscope  minor debris in it, and we were able to push the 23 boroscope through, completely through it.24 The fourth one had some blockage, and I 25 described the debris as -- and I am reading from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
.o 792 1 Exhibit -- Citizens Exhibit 52: Debris looks like 2 loose --3 CHAIRMAN HAWKENS: What page?4 MR. TAMBURRO:
Page 3 of 5: Debris looks 5 like loose concrete.6 CHAIRMAN HAWKENS: I'm sorry, what page?7 MR. TAMBURRO:
I apologize.
It is.8 Citizens Exhibit 52, page 3.9 MR. GALLAGHER:
Upper righthand corner.10 This is a corrective action report from AmerGen.11 MR. TAMBURRO:
Can I continue?
Okay.12 So in summary, one of the five drains was 13 blocked, and we could not pass our boroscope through.14 I entered this corrective action, and we corrected the 15 situation by removing the blockage and clearing the 16 two drains that had any debris in it.17 My opinion of this one drain that was 18 blocked physically so that the boroscope could not 19 pass through was that it was not clogged. There were 20 plenty of spaces between the loose pieces of what I 21 termed concrete that would have allowed flow.. There.22 was no water in that line or any of the five lines, 23 and we have since resolved that and cleared the two 24 lines.25 JUDGE ABRAMSON:
Mr. Tamburro, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 793 1 unfortunately, I'm having trouble finding the right 2 page in the exhibits that we have.3 MR. GALLAGHER:
It's Citizens Exhibit 52.4 JUDGE ABRAMSON:
Citizens 52? Okay. I'm 5 sorry. We were looking at your exhibit. Thank you.6 CHAIRMAN HAWKENS: Mr. Tamburro, does 7 AmerGen have a practice in place for the future to 8 ensure the drains do not become clogged?9 MR. TAMBURRO:
Yes.10 CHAIRMAN HAWKENS: Can you explain that to 11 me, please?12 MR. TAMBURRO:
We will perform the same 13 inspection periodically.
In addition, we have looked 14 inside the sand beds for loose material that could end 15 up in the drains, and there was none. None was 16 reported in any of the inspections.
17 CHAIRMAN HAWKENS: Is that part of your 18 commitment, the drain inspection part of AmerGen's 19 commitment for, the renewal period, or is that an 20 internal procedure?
21 MR. TAMBURRO:
I'm not sure. I could ask 22 Mr. Gallagher to answer that.23 MR. GALLAGHER:
It's an internal 24 procedure.
25 CHAIRMAN HAWKENS: Thank you.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 794 1 MR. POLONSKY:
Your Honor, I have 2 identified the page in the testimony, if I could just 3 confer to this with Mr. Hosterman.
4 CHAIRMAN HAWKENS: Please.5 MR. POLONSKY:
We may have to bring on one 6 other witness after this as well.7 MR. HOSTERMAN:
As I had specified, the 8 original calculations that I had done for the sand bed 9 region were for normal operations, and this is for an 10 internal drywell temperature of 130 degrees.11 I calculated an air temperature in the 12 sand bed region of approximately 109-110 degrees, 13 109.5, to be precise, but that would be during normal 14 operations.
Refueling outages would be lower 15 temperatures, because we do not have the heat sources 16 in the drywell.17 MR. WEBSTER: What are we referring to 18 here?19 MR. POLONSKY:
I'm sorry. My apologies.
20 This is AmerGen's direct testimony, and it is Part 6, 21 and Mr. Hosterman was reading or referring to 22 refreshing his memory from answering 19, which is on 23 page 12 of 15.24 CHAIRMAN HAWKENS: Does the NRC staff have 25 anything to add to that?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
* o w 795 1 MR. O'HARA: Yes, Your Honor. Tim O'Hara, 2 Region 1 inspector.
3 During the fall outage in 2006, I did note 4 that condition along with Mr. Tamburro.
It is our --5 my opinion that the drains did have debris in them, 6 but were not blocked, and we agreed with their 7 summation of handling it and cleaning it out.8 CHAIRMAN HAWKENS: Thank you.9 JUDGE ABRAMSON:
Do you have any idea 10 where the debris came from, how it got there?11 MR. O'HARA: My guess would be that it 12 came from the shield wall, spalled off the shield wall 13 inside the sand bed region.14 JUDGE ABRAMSON:
Is a swelling normal 15 under these circumstances, these physical conditions?
16 MR. O'HARA: It's not abnormal.17 JUDGE ABRAMSON:
Does AmerGen want to 18 comment on how the debris got there? Does that sound 19 like a sensible guess?20 MR. GALLAGHER:
Our analysis was that it 21 was historical, and it was probably from --22 JUDGE ABRAMSON:
That it had been there 23 for some while?24 MR. GALLAGHER:
It was just not cleared 25 out when the original drains were cleared out, and as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
.° 796 1 we testified, it did not impact actual flow area.2 MR. O'HARA: I would like to add, as we 3 had said before, we didn't see any evidence that there 4 had been water in there that had swept this into the 5 drain.6 DR. HAUSLER: -Let me just comment that, 7 when the floor in 1992 was repaired, so were the 8 drains. I think'it is bit disingenuous to indicate 9 that the debris in those drains was historical.
It's 10 the one point.11 The other point said here in the 12 conclusions:
Sand bed drains from elbow to sand bed 13 were agglomerated, thus preventing water from 14 draining, and have been cleared. That's the 15 conclusion on page --16 MR. WEBSTER: Just to be-clear, that is 17 Citizens Exhibit 25.18 DR. HAUSLER: That is the conclusion on 19 the same page that we just looked at. I mean on the 20 same exhibit that we just looked at. That would be 21 page 4.22 MR. WEBSTER: That's Exhibit -- Could you 23 just verify, Dr. Hausler, which exhibit that is.24 DR. HAUSLER: That's Exhibit 22, I 25 believe.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2 3 4 5 6 7 8 9 10 Ii 12 13 14 15 16 17 18 19 20 21 22 23 24 25 797 MR. WEBSTER: I'm.sorry.
My apologies.
That is Citizens Exhibit 22.DR. HAUSLER: And that would be on page 2 that I just read from.MR. WEBSTER: No, it's not the same.DR. HAUSLER: Exhibit 22, and it is page 2 that I read from.MR. TAMBURRO:
May respond, Your Honor?JUDGE ABRAMSON:
Yes, please.MR. TAMBURRO:
Exhibit 22 is a report that was performed prior to 1992 when we discovered these drains were clogged and we repaired them then. This was not -- This is not a report describing the 2006 condition.
MR. WEBSTER: Can I just say that Mr.Tamburro is entirely correct. The witness is providing response to the suggestion that these concretes were historic.JUDGE ABRAMSON:
So the point is that this debris was cleared out in 1988.MR. WEBSTER: Ninety-two, I think.JUDGE ABRAMSON:
I thought this report said 1988. The debris was there in '88. Right? Am I reading this wrong?MR. WEBSTER: Dr. Hausler, what date is on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.WASHINGTON, D.C. 20005-3701 (202) 234-4433 www.nealrgross.com 798 1 that exhibit?2 DR. HAUSLER: The date is '89, I believe, 3 March 3, '89.4 JUDGE BARATTA: Now, Dr. Hausler, what you 5 are saying is that there was debris in there in 1988, 6 which was cleaned out in 1989, based on that report.7 DR. HAUSLER: Right.8 JUDGE BARATTA: And that any subsequent 9 debris that was found, such as what was found later, 10 was not, therefore, historical?
11 DR. HAUSLER: Well, again, you know, the 12 sand bed floor was build up. The drains were repaired 13 in '92 as well, and I would be highly surprised if the 14 drains at that time were not cleaned up for the water 15 to flow.16 I believe subsequently it has alsobeen 17 observed that -- well, in fact, it was in 2006 that 18 water did flow out the sand bed drains and had been 19 collected in water botties that subsequently were 20 discarded prior to an inspection by NRC. That has 21 also pretty well established, I believe.22 JUDGE BARATTA: Thank you.23 CHAIRMAN HAWKENS: AmerGen, do you have 24 any response,'
or the NRC staff? If not, I have a 25 question for AmerGen.NEAL R. GROSS COURT REPORTERS'AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 799 1 How often during'shutdown and how often 2 during operations are these drains checked for water?3 MR. GALLAGHER:
For the sand bed drains, 4 the sand bed drains are checked daily when there is 5 water in the refueling cavity, and quarterly during 6 other times.7 CHAIRMAN HAWKENS: Again, I am non-8 technically..
trained. Why only quarterly during 9 operations?
10 MR. GALLAGHER:
There really is no source 11 of water to come into the sand bed region, because the 12 source is the refueling cavity when we fill that with 13 Water during refueling outages. So what we did is, 14 again, as a belt and suspenders check, is to quarterly 15 look for the possibility of anything else going on.16 We have done those inspections, and 17 there's no water.18 CHAIRMAN HAWKENS: Do other factors 19 contribute to that? For example, is it a radiation 20 area that you want to keep people out of or is it 21 purely driven by the fact that, in your judgment, 22 there is no source of water that would contribute?
23 MR. GALLAGHER:
In our judgment, there is 24 no source of water. Quarterly is fine. It is an area 25 that the operators would have to dress out in. It is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 800 1 a contaminated area.2 CHAIRMAN HAWKENS: NRC staff?3 MS. BATY: The NRC staff, if the Board 4 would like to hear about the commitments that AmerGen 5 has made regarding water, monitoring for water --6 CHAIRMAN HAWKENS: I would like to hear 7 them, please.8 MR. ASHAR: This is Hansraj Ashar. I just 9 want to point out that in the number of commitments 10 that are made and which are in the Appendix A of SER,.11 there is a line item 3 under commitment
: 27. Second 12 bullet says, "The sand bed region drains will be 13 monitored quarterly during the plant operating cycle.14 If leakage is identified, the source of water will be 15 investigated." Otherwise, the following items will be 16 performed, and there is a lot of things that they will 17 do if they find water.18 So what I am saying is -- I will get a 19 clarification from AmerGen as to what they are going 20 to do, because I heard the word periodically and not 21 the quarterly test.22 CHAIRMAN HAWKENS: All right. Thank you., 23 MS. BATY: And just for the record, the 24 SER is Staff Exhibit 1.ý25 MR. WEBSTER: I believe Dr. Hausler has a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 801 1 comment.2 CHAIRMAN HAWKENS: Dr. Hausler.3 DR. HAUSLER: You asked the question, you 4 know, why the investigation, the monitoring of the 5 water, was quarterly, and you asked whether this was 6 because of radiation.
7 I just wanted to add to this, and perhaps 8 this is not in scope. But monitoring of water can be 9 done differently than having to send persons into 10 areas that are contaminated.
11 CHAIRMAN HAWKENS: Thank you. My 12 understanding from his answer was that, although it 13 would require them to dress out because it is a 14 contaminated area, that was not the driving factor.15 It was their judgment there was no source of water.16 DR. HAUSLER: I don't think I want to 17 comment on that, but there is no certainty that there 18 is no water in 45 days, in three months. In fact --19 I am sorry -- 90 days, in three months. There is 20 indeed a possibility during normal operation that, if 21 water is there, damage could be done.22 This goes toward how well do we know 23 things, and how certain are we that things are under 24 control. The-water could be monitored electronically, 25 and this has been done in other places as well.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 802 1 CHAIRMAN HAWKENS: Thank you.2 That concludes the Board's questions for 3 this panel. I do have a couple of questions I would 4 like to pose to AmerGen and have the staff weigh in 5 on. And, AmerGen, I'll let you determine which 6 witness is most appropriate to respond.7 In the absence of a corrosive environment, 8 could statistically significant corrosion in the upper 9 drywell occur?10 MR. POLONSKY:
We are a bit caught off 11 guard, Your Honor, because I thought the upper drywell 12 was outside the scope of the proceeding.
13 CHAIRMAN HAWKENS: We have discussed it 14 earlier, though, and you said there was minimal 15 corrosion.
It was not -- It was significantly
--16 statistically significant, and the question is: In 17 the absence of a corrosive environment.
18 MR. POLONSKY:
We can have Pete Tamburro 19 give an answer, I think, consistent with what he 20 testified before, but I think you may be 21 mischaracterizing.
But, obviously, Mr. Tamburro can 22 address that. Pete?23 MR. TAMBURRO:
To be honest with you, I'm 24 not sure I understand the question.
In the absence of 25 a corrosive environment
-- which would indicate to me NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 803 1 that --2 JUDGE ABRAMSON:
Let's see if I can 3 clarify that, to put it a little more directly.
It 4 was a nice indirect question from a lawyer. To put it 5 as a scientist, I'll put my other hat on for a moment, 6 Your Honor.7 How could there have been statistically 8 significant corrosion in the upper drywell, if there 9 was no corrosive environment?
10 That's the inverse of the question that 11 had been posed.12 MR. TAMBURRO:
The inspections of the 13 upper drywell started in the mid-Eighties prior to 14 many of the corrective actions that occurred, which 15 was the strippable coatings and monitoring water.16 That series of inspections occurred from the mid-17 Eighties until 2006, and as we do know, there were 18 outages where we did have water early on that were in 19 this environment.
20 The small corrosion rate, .6 mils per 21 year, is an indication, in my mind, that that occurred 22 early on and is a conservative judgment of what is a 23 rate in one location, using statistics.
24 MR. WEBSTER: Could I just clarify? The 25 record states this has been ongoing corrosion there.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 804 1 Is that incorrect?
2 CHAIRMAN HAWKENS: We would have to take 3 a look at the exhibit. Is that correct, AmerGen?4 Does the exhibit indicate there is ongoing corrosion?
5 JUDGE ABRAMSON:
We discussed this earlier 6 today ad nauseam.7 CHAIRMAN HAWKENS: Well, if there is 8 ongoing corrosion
-- Go ahead.9 MR. POLONSKY:
Mr. Tamburro, if the title 10 of that slide may have said statistically significant 11 observable corrosion, what is your answer to that?12 MR. TAMBURRO:
The rate of .66 mils per 13 year was, from a statistical standpoint, observable.
14 It met the f-test. However, that rate was measured 15 over a long duration, from the mid-Eighties to 2006.16 MR. POLONSKY:
Does that mean that there 17 is actually any ongoing corrosion?
18 MR. TAMBURRO:
In my opinion, there is no 19 ongoing corrosion at this time.20 CHAIRMAN HAWKENS: Thank you. That 21 answers my question.22 DR. HAUSLER: Could I perhaps ask a 23 clarifying question?
Over what period of time was 24 that corrosion rate of .6 mpy determined?
25 CHAIRMAN HAWKENS: Mr. Tamburro, could we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com v
805 1 hear from you again, please?2 MR. TAMBURRO:
That period of time was 3 from the late Eighties until 2006. We included all 4 data.5 JUDGE ABRAMSON:
So if the corrosion took 6 place over, say, the first 10 years, then can we 7 assume that the rate would have been higher than .6 8 mils per year, because you are dividing it by less 9 years?10 MR. TAMBURRO:
Yes, sir.11 JUDGE ABRAMSON:
Thank you. I think 12 that's where that goes. Thank you very much.13 DR. HAUSLER: Well, the point, I think, is 14 -- You are looking at me questionably, Your Honor. So 15 I 'feel like maybe I have to add something.
16 JUDGE ABRAMSON:
Not unless you think we 17 need more information on this.18 DR. HAUSLER: No. The corrosion could 19 have occurred anytime, and it could have occurred at 20 a fairly high rate over a short period of time.21 JUDGE ABRAMSON:
Yes.22 DR. HAUSLER: Or a-very low rate over a 23 long period of time.24 JUDGE ABRAMSON:
Yes.25 DR. HAUSLER: And I think that is perhaps-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 806 1-2 JUDGE ABRAMSON:
We understand.
Thank you 3 very much. We don't know when it occurred or how long 4 it took.5 CHAIRMAN HAWKENS: Do the parties at this 6 point have any -- I think Mr. Webster mentioned 7 earlier that -- Oh, excuse me.8 JUDGE BARATTA: I just was looking at the 9 SER, and under ---On page A-28, Ttem number 13, it 10 uses the term reactor cavity trough drain. Is that 11 the same as the sand bed trough drain?12 MR. GALLAGHER:
No. There is -- Did you 13 want me to show you in exhibit what drain that is?14 JUDGE BARATTA: If you don't mind, yes.15 Please.16 MR. GALLAGHER:
Okay. If you go to 17 AmerGen Exhibit 4.18 JUDGE BARATTA: Is that those lines that 19 come in underneath the vent pipes on either side? Is 20 that what you are --21 MR. GALLAGHER:
No. If I can just point 22 it out to you. So this is AmerGen Exhibit 4. The 23 sand bed drains are in Detail C, down here, these 24 little lines here -- okay? -- coming off of Detail C.25 MS. BATY: Can you indicate more precisely NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 807 1 for the record?2 MR. GALLAGHER:
I am pointing at Detail C.3 CHAIRMAN HAWKENS: It is identified on the 4 diagram.5 MS. BATY: Okay.6 MR. GALLAGHER:
Now the trough drain we 7 are talking about, Judge Baratta, is up here in Detail 8 B, and if I can take you to that exhibit, which is --9 JUDGE BARATTA: Okay. So that is in 10 connection with the refueling cavity.11 MR. GALLAGHER:
Yes. Exhibit 8. Exhibit 12 8 shows the trough drain at the bottom of that bellow 13 seal, which is --14 JUDGE BARATTA: A line labeled "drain for 15 concrete trough"?16 MR. GALLAGHER:
That's correct.17 JUDGE BARATTA: Thank you. I have a-18 question for the staff.19 Item Number -- Again referring to Appendix 20 A of the SER, page A-30, Item 18. This refers to 21 AmerGen will perform a 3-D finite element structural 22 analysis.
What is meant by the last section -- I 23 guess it's the last sentence.24 It says, "If the analysis determines that 25 the drywell shell does not meet required thickness NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 808 1 values" -- What are the required thickness values? --.2 "the NRC will be notified in accordance with 10 CFR 50 3 requirements." 4 What are the required thickness values we 5 are .referring to there?6 MR. ASHAR: This is Hansraj Ashar. The 7 whole thing about the new analysis was to -- Your 8 question was what is required thickness.
Correct?9 JUDGE BARATTA: Yes, that's correct. I 10 think I understand the previous part, but it depends 11 upon what your answer is to this. I may not have.12 MR. ASHAR: It was the thickness which was 13 being used during all the evaluations and thickness 14 which is required to meet the criterion that had been 15 placed together.16 JUDGE BARATTA: Well, that is where I got 17 a little confused, because it says in the beginning of 18 this, AmerGen will perform a 3-D finite element 19 structural analysis of the primary containment drywell 20 shell using modern methods and current drywell shell 21 thickness data to better quantify the margins that 22 exist above the code required in minimum for 23 buffering.
24 In light of that, I didn't understand that 25 last sentence.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 809 1 MR. ASHAR: As you know, in GE analysis 2 they used .736 as the uniformly corroded surface in 3 the sand bed area. Now it is possible that in the 3-D 4 analysis they might use the true depth at various 5 places in various ways to do the analysis.6 So this is what they mean to say -- not 7 meaning to say, at least. Applicant is the one who 8 proposed it, and we accepted.
So in that sense, that 9 is what we understand, that it does not meet 10 requirement, NRC would be notified in accordance.
11 So there the whole idea as to which 12 thicknesses they will meet, which thicknesses that are 13 existing, you know, and that is what we understand, 14 that true thickness are existing at present time.15 JUDGE BARATTA: So you are taking the 16 required thickness values as the .736. Is that what 17 I understand?
18 MR. ASHAR: No. See, in the front that 19 you read, it stated that they might use the true 20 thicknesses in various ways to analyze the shell.21 What we mean by required thickness means, if the 22 required thickness
-- if they come out with a 23 conclusion that they cannot meet all the design 24 criteria that have been established for it, then it 25 could be sent to us for review.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 810 1 JUDGE ABRAMSON:
So let's see if we can 2 clarify this with the applicant.
Thank you, Mr.3 Ashar.4 As I understood what we heard aboutthis 5 analysis, you are going to do a 3-D analysis using the 6 current configuration as best you can understand.
Is 7 that correct?8 MR. GALLAGHER:
That's correct.9 JUDGE ABRAMSON:
And out of that analysis 10 will come buckling load safety factor?11 MR. GALLAGHER:
That's correct. If I 12 could just tell you what our intention was here, 13 obviously, the currently analysis is our current 14 licensing basis, and that is what we judge everything 15 to. This 3-D analysis we are performing, as I stated 16 earlier, our expectation is that it will show we have 17 more margin than we have in our current analysis.
But 18 we put in here the flip side.19 If we did this analysis and it showed a 20 problem with our current condition, then we are 21 obligated by Part 50 to notify the NRC, and that's all 22 we are saying here.23 JUDGE ABRAMSON:
And let me pursue this 24 for arminute, because I'm trying to understand how 25 this all fits together with some rather confusing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 811 1 testimony we have heard about how the safety factor 2 fits into the current licensing basis.3 The design safety factor, we understand, 4 is 2.0. Is that correct? For buckling.5 MR. GALLAGHER:
That is correct.6 JUDGE ABRAMSON:
Okay. So let's talk 7 hypothetically.
You do the analysis.
You get a new 8 safety factor. The new safety factor is less than 2.0 9 with the existing thicknesses; you report to NRC. If 10 it's greater than 2.0, you don't need to. Is that 11 kind of the gist of this?12 MR. GALLAGHER:
That essentially it, yes.13 JUDGE ABRAMSON:
Okay. And therefore, one 14 might expect that that will leadinto a review of the 15 frequency of your inspection of corrosion.
Let's say 16 it turns out you have a safety factor of greater than 17 2.0. That would support the frequency of inspection 18 as proposed?19 I am trying to understand sort of how this 20 fits together, what the agency could expect to happen 21 as a result of this analysis, other than just 22 reporting.
23 MR. GALLAGHER:
Well, if i can back up to 24 say what was the intent. The intent of performing 25 this analysis was -- and you would have to look at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 812 1 transcript of the ACRS meeting. It was really a 2 discussion of the current model, and the current 3 analysis you have now is very, very conservative.
You 4 know, the uniform thickness in the sand bed -- you 5 don't have that. All the things that you --6 MR. WEBSTER: Objection.
Mischaracterizes 7 the ACRS.8 JUDGE ABRAMSON:
Well, we can read the 9 ACRS transcript.
10 MR. WEBSTER: Well, it is not entirely in 11 the record, Judge.12 JUDGE ABRAMSON:
The ACRS transcript is 13 not in the record?14 MR. WEBSTER: The whole transcript is not 15 in the record.16 JUDGE ABRAMSON:
Is part of the transcript 17 in the record?18 MR. GALLAGHER:
It's a public record.19 JUDGE ABRAMSON:
We will access it and 20 look at it. Thank you.21 MR. GALLAGHER:
And the discussion that we 22 had with the ACRS was you are being very conservative 23 here; what are your real margins? And we said, we'll 24 explore that, and we will do this 3-D, find that out 25 in the analysis.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 813 1 JUDGE ABRAMSON:
That was the origin.2 MR. GALLAGHER:
That was the origin, and 3 you know, we are very confident in our current 4 licensing basis that it is conservative and we can-use 5 that as acceptance criteria, and this particular is 6 really a comfort level to show that there is much more 7 margin than we have.8 So our expectation, it will -show more 9 margin. But we put the flip side of it in this.10 JUDGE ABRAMSON:
So the flip side is, if 11 it shows less margin than you have, that it might well 12 lead to a shortening of the inspection frequency.
Is 13 that --14 MR. GALLAGHER:
Well, we would enter in 15 our corrective action program, and we would take the 16 appropriate corrective action. The first step would 17 be to notify the NRC, because that would be a Part 50 18 requirement, and then the second step would be, you 19 know, the evaluations we would have to do, and that 20 type of thing.21 JUDGE ABRAMSON:
And you would interact 22 with the staff in deciding what the implications of 23 that were.24 MR. GALLAGHER:
Of course. We would be 25 obligated under Part 50 to take corrective action and, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 2000573701 www.nealrgross.com 814 1 as appropriate, notify the NRC.2 CHAIRMAN HAWKENS:, Are there any 3 administrative matters or evidentiary matters that we 4 need to address now? Let's start with Mr. Webster.5 -MR. WEBSTER: I have a couple. We were in 6 the middle of discussing them with opposing counsel 7 and with NRC staff counsel. We can proceed with them 8 or we can take a short break. We could discuss them 9 further and see if we can reach --10 CHAIRMAN HAWKENS: Is it something you 11 need to discuss before we can resolve it?12 MR. WEBSTER: Well, let me go forward.13 One issue has to do with the extreme value statistics, 14 exactly how those were done. Dr. Hausler has now 15 refreshed his memory on precisely how those were done, 16 and he can offer testimony on that.17 The second issue is this what we are now 18 calling the Rosetta Stone, the translation between the 19 references for the internal buckling -- so the 20 internal grid locations and the exterior monitoring 21 locations.
22 We were provided an exhibit number by 23 AmerGen or a disclosure number by AmerGen. That 24 exhibit does not -- certainly does not enable us to 25 make this translation.
It may enable AmerGen to make NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 815 1 that translation.
2 CHAIRMAN HAWKENS: Why don't we proceed 3 with that right now. Let's start off with hearing 4 from Dr. Hausler.5 It is about 2:22. Let's take a recess 6 until 2:45. During that period, if the parties have 7 any additional questions on the final topic they would 8 like the Board to address, please submit them to Ms.9 Wolf.10 Additionally, counsel can prepare, to the 11 extent it is necessary, for their closing statements, 12 and we will reconvene at quarter !til. Thank you.13 (Whereupon, the foregoing matter went off 14 the record at 2:26 p.m. and went back on the record at 15 2:45 p.m.)16 CHAIRMAN HAWKENS: The Board is three 17 minutes late. I apologize for making the audience and 18 the parties wait. Did the parties provide Ms. Wolf 19 with any additional questions that they wish to have 20 asked?21 MR. WEBSTER: Citizens don't provide any 22 additional questions.
23 MS. BATY: No questions from the staff.24 MR. POLONSKY:
None from AmerGen.25 CHAIRMAN HAWKENS: Thank you. There are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 816 1 two administrative matters that Mr. Webster had 2 mentioned before we took the recess. One was what he 3 characterized as the Rosetta Stone which I think was 4 the data from AmerGen to make the internal grids 5 correspond to the external points. The other was some 6' of the underlying calculations for Dr. Hausler's 7 equations, the extreme value statistics.
8 One of the Board's significant concerns is 9 to allow additional data to come in from either party 10 at this point. It would expand the record. It would 11 open the door conceivably to additional briefings so 12 that the record could not be closed which would create 13 an extension as far as getting out a final decision.14 With that in mind, let me ask AmerGen what 15 are its views on this administrative matter letting in 16 additional exhibits into the record.17 MR. WEBSTER: Excuse me, Judge. If I 18 could just clarify. For the first issue, the extreme 19 value statistics, I don't think there is any need to 20 go beyond the record. I think we can do it by oral 21 testimony.
22 CHAIRMAN HAWKENS: All right. Thank you.23 MR. WEBSTER: The second issue I think is 24. slightly more thorny.25 JUDGE ABRAMSON:
Frankly, counselor, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 817 1 don't agree with you. If we get additional 2 information in that I don't believe that either the 3 applicant or the staff has had a chance to review in 4 depth all that information.
I, for one, am not 5 willing to make a ruling without hearing the parties 6 debate those at length.7 MR. WEBSTER: Well, Judge, we have just 8 showed the calculations, rather simple calculations 9 actually, to both AmerGen and the staff and they have 10 staff witnesses and they have had opportunity to look 11 at the spreadsheet that Dr. Hausler used to make the 12 calculations to produce the points that were in the 13 chart.14 MR. POLONSKY-v Your Honor, I think Judge 15 Abramson characterized it well. I thought he used the 16 words "in detail review." We may have had about two 17 minutes to have Dr. Harlow look at the spreadsheet.
18 MR. WEBSTER: We are very happy to submit 19 -- I just want to clarify we have no objection 20 whatsoever to submitting the spreadsheet and having 21 further hearings on the issue. I just thought that 22 was a desire by the Board to move forward quickly.23 MR. POLONSKY:
If we can discuss it orally 24 that would certainly be our preference, AmerGen's 25 preference on the issue of extreme value statistics.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 818 1 We frankly already have the extrapolation and 2 interpolation plots as exhibits.3 Dr. Hausler, I think, is just providing 4 what he believes is the underlying support for how 5 they generated some of those plots. AmerGen, I think, 6 is already on the record that the whole concept of 7 extrapolating and 'interpolating and treating the 8 internal/external data as representative of the shell 9 is improper.10 MR. WEBSTER: Objection to that 11 characterization.
Amergen's witness said he did do it 12 through value statistics on the data.13 MR. POLONSKY:
One moment, Your Honor. As 14 I said, I think limited oral testimony on the issue of 15 the underlying analysis of the extreme value 16 statistics is appropriate.
17 JUDGE ABRAMSON:
Staff have a view? Is 18 there some fruitful oral discussion we can have?19 MS.' BATY: Your Honors, our expert, 20 AmerGen's expert, had just two minutes to peruse Dr.21 Hausler's spreadsheet and so obviously we have not had 22 a chance to -- he's not had a chance to analyze the 23 material but we wouldn't object to an oral 24 conversation about the information.
25 JUDGE ABRAMSON:
So let me ask applicant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgrossxcom 819 1 and the staff this question.
Suppose that after this 2 oral discussion of what underlies Dr. Hausler's 3 information this particular Judge is not satisfied 4 that he has got adequate information to deal with it 5 and requires further briefing by all parties and 6 rebuttal of further briefing by all parties.7 Do you think that is a likelihood or do 8 you think you can actually get to the end of this in 9 a few minutes of oral discussion?
If you want to take 10 a couple minutes to discuss, do.11 MR. POLONSKY:
If we could have a couple 12 more minutes to discuss this. We-would still like to 13 proceed. This is Amergen, Judge Abramson.
We think 14 you won't have any follow-up required.
If I can, I x 15 think, remind us of why we came to this extreme value 16 statistics issue in the first place, I think --17 Richard, please correct me if I'm wrong -- there was 18 an assertion about the pressure criterion being 19 exceeded and that pressure criterion is 490.20 We were going to provide you with 21 citations where AmerGen had said in its testimony that 22 we thought there was no such location and Citizens 23 were identifying their use of extreme value statistics 24 to identify such a location.
I don't know if --25 JUDGE ABRAMSON:
Please. Let's hear what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 820 1 the lawyers say in response to my inquiry and then 2 we'll deal with it.3 MR. POLONSKY:
So, frankly, we think we 4 can supply you with those citations.
5 JUDGE ABRAMSON:
That's fine. I 6 understand.
You are okay with going forward. How 7 about staff? Staff shouldn't have the dog in this 8 fight. It's the licensee's application.
It will be 9 delayed if there is more information required.10 MS. BATY: Actually, Your Honor, we 11 conferred with our expert and he does have some 12 concern that he shares your concern that this 13 discussion could open doors and require -- there is a 14 chance that there would be a need for further briefing 15 in rebuttal as you had suggested depending on how 16 clear the discussion can be. He hasn't had a chance 17 to review this. What he saw he asked questions that 18 he would like to have answered in addition.19 I believe this -- correct me if I'm wrong 20 but the staff's understanding is the issue of extreme 21 value statistics arose at least partially out of the 22 Board's question in the August 9th order that you 23 asked us to address the use of extreme value 24 statistics and provide testimony.
25 MR. WEBSTER: Citizens also --NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON,.
D.C. 20005-3701 www.nealrgross.com 821 1 MS. BATY: So Citizens had an opportunity 2 at that point to provide the necessary information for 3 the foundation of their use of extreme value 4 statistics.
5 MR. WEBSTER: Well, we have -- excuse me.6 Citizens did provide --7 MS. BATY: And they had another 8 opportunity in surrebuttal as well.9 JUDGE ABRAMSON:
Let's not go into who had 10 an opportunity when. I think it's the applicant who 11 has a dog in this fight. Applicant said there would 12 go on and take the risk that this may lead to further 13 briefing.
I think, as far as I'm concerned, that 14 settles the question for me.15 CHAIRMAN HAWKENS: Although I will ask 16 this one question.
Citizens having had the 17 opportunity to address it and, in fact, did address 18 it, is there something material and new that you 19 didn't address in your prior submissions?
20 MR. WEBSTER: No. This is just a 21 clarification from the witnesses this morning. We are 22 saying they didn't quite understand what Dr. Hausler 23 said he used the log log distribution exactly what 24 that meant. Dr. Hausler is prepared to clarify 25 exactly what he means when he says he used the log log NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 822 1 distribution.
2 This is not new -- this is not anything 3 new; This is the result of prefindings.
In fact, the 4 problem is as a result of surrebuttal these questions 5 were not raised on surrebuttal.
They could have been 6 dealt with on surrebuttal and we wouldn't be in this 7 position.8 CHAIRMAN HAWKENS: We would like to hear 9 clarification from Citizens and a response by AmerGen 10 and the NRC staff, please.11 DR. HAUSLER: I would like to add that I 12 don't think at any point we have stipulated that there 13 are areas that are less than 490 mils. I think we 14 have said in a previous study as well as the extreme 15 value statistics that there is a finite probability 16 that such areas exist, that we have used extreme value 17 statistics to extrapolate from 37 points to 50 points 18 or to 100 points.19 Yes, that stipulation shows that there is 20 a finite probability that, in fact, such a point might 21 exist if enough measurements had been made. That is, 22 in fact, what the extreme value statistics are being 23 used for.24 The other thing that we did in an earlier 25 memorandum to counsel was to analyze some of the data, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 823 1 some of the external data that had also been analyzed 2 by experts for AmerGen to show that if one were to use 3 the standard deviation for certain means that the 4 external data could actually also be as low, or the 5 points in the external data could be as low as 490 6 mils depending on how one wants to accept the standard 7 deviation that we have defined at that point.8 We have extrapolated things. We have said 9 there is probabilities.
We have never said that such 10 points exist. I needed to clarify that because I 11 think counsel misrepresented
-- counsel for AmerGen 12 misrepresented what it is that we said. Thank you.13 CHAIRMAN HAWKENS: Thank you.14 JUDGE ABRAMSON:
Sorry. Did you want to 15 clarify something about your extreme value statistics 16 or is that all you wanted to say? That's it?17 DR. HAUSLER: The extreme value statistics 18 stand for themselves.
19 JUDGE ABRAMSON:
So there is nothing more 20 you want to offer on this? That's it?21 MR. WEBSTER: Actually, that's not quite 22 correct, Judge. There is something that Dr. Hausler 23 has to offer which is the equation that he's used or 24 the exact methodology that he's used to produce that 25 plot and he can go through that right now.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com v
824 1 JUDGE ABRAMSON:
' Has that been made 2 available to the parties?3 MR. WEBSTER: Yes, it has. It was made 4 available just now, Judge.5 JUDGE ABRAMSON:
This is the material that 6 the licensee and the staff have looked at for a couple 7 of minutes. Is that correct?8 MR. POLONSKY:
That's correct, Your Honor.9 MS. BATY: Yes. A two-minute perusal on 10 Dr. --11 DR. HAUSLER: Let me describe it very 12 briefly what was done. We have a number of data 13 points. We rank the data points from the highest to 14 the lowest. This gives us a ranking from 1 through 15 37. The number may not be quite accurate.
Anyway, 16 you know, we divide that ranking by the number of 17 observations plus 1 in order to get the relative 18 ranking.19 We then calculate the logarithm of the 20 negative logarithm of that relative ranking which is 21 standard procedure in the statistics.
We call that 22 the reduced variant. We plot the actual wall 23 thickness, or remaining wall thickness, against the 24 reduced variant in the linear plot. If we do get the 25 linear correlation, then that is an indication that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 825 1 extreme value statistics, as we just have defined 2 them, is applicable.
3 You get the correlation equation for that 4 straight line which is in our exhibit that we 5 mentioned earlier. You get the correlation equation 6 and you extrapolate that from 40 points, or 37 points, 7 to 90 points or 100 points or whatever.8 In this particular instance we 9 extrapolated it to 37 points -- from 22 to 37 points 10 and found the number at 488 mils residual wall 11 thickness.
Right? It's on that basis that we say if, 12 in fact, one had measured 37 points there is a very 13 good probability that one might have found a point 14 that is already at that limit.15 JUDGE ABRAMSON:
And all of those points 16 that you used for external measurements which had been 17 milled down to get a thickness.
Is that correct? You 18 said you started for 22 and you extrapolated
: 37. The 19 22opoints you used are external data points?20 DR. HAUSLER: Correct, for bay 13.21 MR. WEBSTER: Just to be clear, we don't 22 know if they were milled or not.23 JUDGE ABRAMSON:
Okay. I understand.
But 24 there is an uncertainty of up to 200 mils.25 MR. WEBSTER: There is plenty of NEAL R. GROSS'COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 826 1 uncertainty around here. There is no question.2 Could I just make one other point, Dr. Hausler? Could 3 you just give us a correlation coefficient or the 4 linear plot?5 DR. HAUSLER: The correlation coefficient 6 is .913. That is not a correlation coefficient.
7 Generally that is considered excellent but it is a 8 decent correlation coefficient.
That's all we have.9 CHAIRMAN HAWKENS: Thank you very much.10 AmerGen.11 MR. POLONSKY:
Can AmerGen take three 12 minutes to go caucus? Five minutes to go caucus?13 CHAIRMAN HAWKENS: Yes. Please do. We'll 14 reconvene at 10 after.15 MR. POLONSKY:
Thank you.16 (Whereupon, at 3:07 p.m. off the record 17 until 3:16 p.m.)18 CHAIRMAN HAWKENS: Back on the record.19 MR. POLONSKY:
Your Honor, AmerGen has no 20 testimony to provide in response.
In response we 21 would just like to identify as the Board had requested 22 before those locations in the prefile testimony where 23 we argue that there are no measurements below 490 in 24 AmerGen's direct testimony, Part 3.25 The answer to question 5 at the top of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 827 1 page 6 states what the thinnest UT measurement 2 obtained at any time between 1992 and the present and 3 it says it's 602 inches. Therefore, the pressure 4 criterion is also easily satisfied because there are 5 no single UT measurements below 490. I'm sorry, .602 6 inches or 602 mils.7 The second citation is to AmerGen's 8 prefiled rebuttal testimony also in Part 3 starting 9 with the answer to question 40 which starts at the 10 bottom of page 31 and encompasses answers 40, 41, and 11 42.12 CHA-IRMAN HAWKENS: Thank you. NRC staff, 13 anything you wish to add?14 MR. SALOMON: This is Art Salomon for the 15 NRC staff. Your Honors, not wanting to extend the 16 proceeding but if required to make a decision on the 17 applicability of the interveners exhibit or testimony, 18 I would prefer to have additional time and the 19 background equations and model and all the steps' in 20 the procedure to review before saying that the 21 procedure is applicable and used properly.22 CHAIRMAN HAWKENS: Thank you. So the NRC 23 staff does not endorse at this time this statement 24 made by Dr. Hausler.25 MR. SALOMON: That is correct.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433.
WASHINGTON, D.C. 20005-3701 www.nealrgross.com 828 1 CHAIRMAN HAWKENS: Thank you.2 MR. WEBSTER: It also does not negate it 3 either.4 JUDGE ABRAMSON:
That's correct.5 CHAIRMAN HAWKENS: Thank you.6 MR. POLONSKY:
Your Honor, that is 7 similarly the position for AmerGen.8 CHAIRMAN HAWKENS: Thank you. I think a 9 final admin. matter deals with data points underlying 10 some of the internal and external points that were 11 graphed by AmerGen in an exhibit. Is that correct?12 MR. POLONSKY:
Yes, Your Honor. I guess 13 it's Exhibit -- Amergen's Exhibit 28 is that lovely 14 chart of green triangles, yellow triangles and green 15 rectangles which is provided as part of an ACRS 16 presentation.
17 The underlying document, which was the 18 basis for this, although this was not to scale 19 horizontally, is the same document that is the 20 underlying basis for AmerGen's Exhibit 44. That 21 document was produced in discovery.
AmerGen provided 22 that OCLR Bates number to Mr. Webster at the break and 23 he now has that exhibit.24 CHAIRMAN HAWKENS: You have what you need, 25 Mr. Webster? You are satisfied with that?NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 829 1 MR. WEBSTER: Obviously not, Judge, or we 2 wouldn't be discussing it on the record here. While 3 it may be possible to translate from the document that 4 was disclosed to the coordinates that were used, in 5 fact, I think the sequence is that I asked Mr.6 Polonsky for the coordinates of the external points 7 and the internal -points all in the same relative 8 coordinate frame.9 JUDGE ABRAMSON:
When did you request 10 that?11 MR. WEBSTER: I don't recall exactly, 12 Judge.13 JUDGE ABRAMSON:
Was it in the last few 14 days or was it many, many months ago?15 MR. WEBSTER: It is subsequent to seeing 16 AmerGen plot. It's approximately two to three weeks 17 ago I would estimate.18 JUDGE ABRAMSON:
Does that sound accurate 19 to you, Mr. Polonsky?20 MR. POLONSKY:
I disagree with the 21 characterization but I'll let Mr. Webster continue 22 before I provide a reply.23 MR. WEBSTER: Okay. So as to those 24 coordinates you said that -- I don't recall too 25 precisely what you said. He said something along the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 830 1 lines of that there wasn't any coordinates but if they 2 had disclosed something from which one could deduce 3 the coordinates but didn't tell me exactly where in 4 the record. I do believe Ms. Young can corroborate 5 this.6 I complained to her at the time that it's 7 a pretty hard job looking at 40,000 sheets of paper to 8 try and find one document.
I think there is -- well, 9 I think that certainly didn't help Citizens develop 10 their record because obviously we have limited 11 manpower and plowing through 40,000 pages is a 12 significant task.13 Subsequently, AmerGen has produced Exhibit 14 44 on surrebuttal which attempts to do the same thing 15 again. It's actually to scale this time. Citizens 16 still have questions about whether these coordinates 17 are actually, properly overlaid.
We, therefore, 18 request AmerGen to provide the underlying coordinates 19 used for these plots and an explanation of how they 20 calculated those coordinates from the document that 21 was disclosed.
22 CHAIRMAN HAWKENS: Amergen.23 MR. POLONSKY:
First of all, the document 24 is not a new document.
The document was provided in 25 the mandatory disclosure process. It has a Bates NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C; 20005-3701 www.nealrgross.com 831 1 stamp and it obviously was produced before the close 2 of discovery.
When was that? In June.3 Secondly, the original document, which 4 should have raised this question in Citizens' mind was'5 provided as part of a presentation to the ACRS whether 6 it was in October or January or February.
Mr. Webster 7 attended that ACRS meeting. He never at that time 8 asked AmerGen why or what the underpinning of that 9 document was.10 In fact, my recollection of the first e-11 mail that he sent to me, which I would agree was about 12 three weeks ago, said, "Perhaps it's too late for me 13 to be asking this but where is this document or was it 14 produced?" We then did some diligence to confirm --15 CHAIRMAN HAWKENS: Excuse me, Mr.16 Polonsky.
The ACRS document you are referring to, is 17 that Exhibit 44?18 MR. POLONSKY:
No. The ACRS exhibit --19 I'm sorry. ACRS presentation is Exhibit 40 but the 20 slide from that exhibit we had previously attached as 21 Exhibit 28. Exhibit 28 should be duplicated somewhere 22 within one of the presentations.
It's Exhibit 40, 23 page 101. I believe it's in black and white there.24 That document was available.
He had a prior 25 opportunity, therefore, to raise the issue.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS I 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com I " "
832 1 Regardless of what transpired there is no 2 discovery allowed here now. There is no new document 3 that has been generated that Mr. Webster or Citizens 4 have not seen. In fact, what they would like us to do 5 is do the work for them it appears and we have given 6 them the document that my client spent weeks 7 correlating those coordinates and plotting them and 8 making various engineering adjustments.
9 This is not something that a lawyer can 10 do. This requires an engineer and QA and QC of that 11 internal and external correlation.
The grid 12 measurements for each of the internal grids and their 13 coordinates from known welds are shown on the figure 14 that I identified the OCLR document for to Citizens 15 today.16. CHAIRMAN HAWKENS: Thank you. Let me hear 17 from the NRC staff, please.18 MS. BATY: The NRC staff doesn't have a 19 position on this other than our understanding was that 20 the request for this document, or at least AmerGen's 21 promise to provide the document, was made yesterday.
22 There was a request to have a correlation and the OCLR 23 number was identified.
24 MR. WEBSTER: I think generally most of 25 these things are quite correct. There have been two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 833 1 requests.
One was made to Mr. Polonsky previously and 2 one was made yesterday for the specific OCLR number 3 since we did not have that previously.
I think what 4 Mr. Polonsky is saying is basically that AmerGen wants 5 take advantage of the fact that they have far more 6 resources than we do.7 Therefore, they want to hide the ball and 8 not identify where the locations were taken. They 9 criticized us for not putting the internal points upon 10 the contour plots. With a weld we could not do that.11 I think this Board in the interest of fundamental 12 fairness should require this document to be disclosed 13 to us and give us an opportunity to check whether 14 Exhibit 44 really reflects the appropriate 15 coordinates.
16 CHAIRMAN.*
HAWKENS: I want to for 17 clarification, AmerGen, you provided them with the 18 Bates number where the data is located. Is that 19 correct? Page numbers?20, MR. POLONSKY:
Essentially, yes. It's a 21 single figure and the figure has a depiction of the 22 entire drywell shell with weld locations, grid 23 locations, and then in the bottom left-hand it has 24 each, of the grid numbers and associated coordinates 25 up, down, left, right from those welds.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 834 1 MR. WEBSTER: Judge, just to be clear, Mr.2 Polonsky just said that it took weeks of work to go 3 from that figure to the actual coordinates of the use 4 for Exhibit 44.5 DR. HAUSLER: Could I --6 CHAIRMAN HAWKENS: No. I think I just 7 want to hear from the attorneys on this legal motion.8 The motion is denied. I think Citizens has had ample 9 time to request this data. In addition, there is 10 simply no reason to think -- no reason that you have 11 provided.12 You haven't had the data. You do have it 13 now but there has been no reason for this Board to 14 doubt the veracity of these charts to the extent once 15 you review this you determine that there is a problem 16 that may well provide a basis to reopen the record.17 You are to otherwise petition the Commission for 18 relief but the motion at this late date to receive 19 that into the record as an exhibit is denied.20 MR. WEBSTER: I would like to move for 21 reconsideration, Judge, and look at facts that will 22 led you to think about it some more.23 CHAIRMAN HAWKENS: No. Motion is denied.24 Thank you.25 MR. WEBSTER: You won't allow me to add 1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 835 1 any facts that may be relevant to the motion?2 CHAIRMAN HAWKENS: I gave you full 3 opportunity several times already.4 MR. WEBSTER: I didn't realize there are 5 some additional facts. The reasons that we believe 6 this figure may be mistaken is because that exhibit 7 that AmerGen provided to the ACRS at the time we 8 thought it was accurate.
What we find on the spectrum 9 is that it is not accurate.10 I think the Board yesterday reviewed the 11 comparison between Exhibit 44 and that diagram that 12 was provided to the ACRS, which I think is Exhibit 28 13 which noted the significant discrepancies between the 14 two diagrams.
Thus, I think'there is no confidence 15 that -- well, we certainly don't know which of these*16 exhibits.
One was not to scale and this one purports 17 to be at scale.18 Now, furthermore, with Mr. Tamburro's 19 analyst, which is revision to the 24 count, there were 20 likewise significant
-- maybe I wouldn't characterize 21 them as significant but there were errors in the 22 locations of the points and in the drawing .of the 23 areas. I think this is a fundamental point, the 24 overlap of this areas. I really think it would be in 25 the strong interest of this Board, of the agency, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
'1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 836 1 of nuclear safety to allow full discovery on this 2 point.3 MR. POLONSKY:
Your Honor, I think there 4 has been clearly full discovery on this point. The 5 Board cut off discovery and this document was produced 6 before that cutoff date. I believe the Commission has 7 a precedent although I cannot cite to you cases right 8 now which say the argument that we don't have enough 9 money or we don't have enough resources is not a 10 legitimate claim for a party in an NRC proceeding to 11 state that they cannot meet their burden. We don't 12 believe that is a convincing argument.
In addition --13 MR. WEBSTER: We have not --14 MR. POLONSKY:
I will finish., please. The 15 exhibit 28 I believe Mr. Webster is mischaracterizing 16 that. The footnote on the document explicitly states 17 that it is to scale in the vertical direction.
We 18 have already had testimony on that. It is not in the 19 horizontal direction nor really could it since each 20 bay is 15 feet wide and we are trying to put it all on 21 a single piece of paper.22 The mandatory disclosures have ended.23 This document was provided.
No discovery is allowed 24 in this proceeding.
I will just echo again they are 25 asking us to do their work for them and we think that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202i 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 837 1 is fundamentally unfair. Thank you.2 MR. WEBSTER: May I just, say, Judge, we 3 said yesterday that Exhibit 28 contains a mirror image 4 of some of the data locations on the horizontal scale.5 That is not really not to scale. It's in error.6 CHAIRMAN HAWKENS: Thank you. The motion 7 is denied. Are there any other administrative matters 8 the parties want to bring to the Board's attention?
9 MS. BATY: Your Honor, the date for 10 transcript correction submission, we need to set that 11 among the parties. I believe that was an item --12 administrative item left open. The parties, I think, 13 have discussed this and I don't have a date in my head 14 but I believe there is a consensus now, an agreement 15 to Friday, October 5. Is that correct, Mr. Silverman?
16 MR. SILVERMAN:
That is correct from 17 AmerGen's perspective.
18 CHAIRMAN HAWKENS: Citizens is October 19 5th?20 MR. WEBSTER: Provided the transcript is 21 available on Monday that will be fine. Citizens 22 request five business days.23 CHAIRMAN HAWKENS: If it is not available 24 to you at that time, please let us know.25 MR. WEBSTER: Thank you, Judge.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 838 1 MS. BATY: Another point of that is we 2 were expecting to have the corrections in hand by 3 close of business.
That was the deadline.
We believe 4 that was the agreement.
It wasn't close of business?5 MR. SILVERMAN:
That was what I understood 6 so I guess we are clear.7 MR. WEBSTER: Well, I have never heard 8 that before. What is the purpose of close of business 9 Friday? Presumably no business will occur if we have 10 it sent in by midnight on Friday.11 MR. POLONSKY:
The purpose we thought, 12 Your Honor, of getting a corrected transcript was so 13 that when we cite to the transcript in our findings of 14 fact and quote the transcript that we are actually 15 quoting things that parties have reviewed.
As long as 16 we can have them in our hands on close of business 17 midnight, whatever it is, on Friday, and only those 18 pages which have changes, could be sent to the 19 parties.20 CHAIRMAN HAWKENS: I understand.
Close of 21 business.
Mr. Webster, if that poses a problem 22 because you didn't receive it in time, please let us 23 know.24 MR. WEBSTER: Judge, my wife will be very 25 happy to hear that close of business is the deadline NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 839 1 actually.2 JUDGE ABRAMSON:
I think the implication 3 from all this is that' Morgan Lewis is going to work 4 over the weekend. I don't know about the staff.5 MR. WEBSTER: We have seen a lot of 6 weekend work already, Judge.7 CHAIRMAN HAWKENS: The Board's right hand 8 has brought to my attention that when they are 9 submitted the parties should have gotten together, 10 collaborated to make sure there is agreement on the 11 proposed revisions.
Does that pose a problem? Why is 12 that, Ms. Young?13 MS. YOUNG: Well, basically we have a very 14 abbreviated finding schedule in this proceeding and 15 I'm not sure we are going to be able to complete our 16 findings and do that but we will make an attempt to. to 17 the extent we can to share our proposed corrections 18 between the parties but have an agreement on any 19 changes that are made to the transcript is not likely.20 I believe you know the history of the participation 21 among the parties. There are areas which we have been 22 able to agree and there are many areas with which we 23 disagree.24 CHAIRMAN HAWKENS: Those have generally 25 been substantive matters. I want to emphasize this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 840 1 a motion for transcript corrections.
That is not a 2 motion for transcript enhancements.
3 MS. YOUNG: Absolutely.
Absolutely.
4 CHAIRMAN HAWKENS: And I think that is 5 very important.
I don't want Ms. Wolf to have to be 6 going through and refusing to, you know -- we don't 7 want to make her job harder.8 MS. YOUNG: Absolutely.
9 CHAIRMAN HAWKENS: So to the extent you 10 can make her job easier by simply insuring that any 11 suggested corrections you make are necessary endeavor 12 toget everybody's agreement and get the motions to/13 her by close of business on Friday I think we would 14 all be grateful.15 Mr. Webster.16 MR. WEBSTER: If I could give one possible 17 solution.
We all have been suffering from a very 18 abbreviated schedule so far. At the time we agreed to 19 that abbreviated schedule this proceeding was the 20 critical part for relicensing.
I believe that is no 21 longer the case because of the Coastal Zone Management 22 Act Consistency from New Jersey. I question whether 23 we need to adhere to this abbreviated schedule now 24 because this proceeding is no longer on the critical 25 path.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 841 1 CHAIRMAN HAWKENS: The Board is in favor 2 of going forward consistent with the schedule we have 3 already established.
Again, let's shoot for Friday 4 unless the Board is willing. If parties are willing 5 to get their draft motions to each other on Friday and 6 then submit them by close of business on Monday that 7 would be an alternative.
Monday is a federal holiday.8 That would be Tuesday. Is your wife willing to accept 9 that, Mr. Webster?10 MR. WEBSTER: Federal holidays do not have 11 an affect in my household I'm afraid.12 MS. YOUNG: The staff is amenable to that.13 MR. SILVERMAN:
And AmerGen is amenable to 14 that.15 CHAIRMAN HAWKENS: All right. Tuesday 16 close of business would be --17 MS. YOUNG: Which is the day before the 18 findings are due. The staff does have one small 19 administrative matter.20 MR. WEBSTER: Before we move on, I think 21 it's going to be very difficult for us to submit 22 proposed findings with' full references to the 23 transcript.
24 CHAIRMAN HAWKENS: That's why initially we 25 were going with Friday.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005.3701 www.nealrgross.com 842 1 MR. WEBSTER: I know. Perhaps one 2 approach would be to submit it in draft and then tidy 3 up the transcript references later when the transcript 4 is finalized.
5 CHAIRMAN HAWKENS: Let's go with having 6 the motion submitted on Tuesday by close of business, 7 again emphasizing this is just to ensure the court 8 reporter has not misconstrued words. It's not to make 9 the parties, the witnesses, or the Judges sound more 10 articulate than we actually are and not to include 11 punctuation.
12 And to the extent that you find the 13 proposed findings of fact, conclusions of law require 14 some corrections because the transcript page cites are 15 incorrect, you can provide them subsequently.
16 MR. WEBSTER: Thank you, Judge.17 CHAIRMAN HAWKENS: Ms. Young.18 MS. YOUNG: This is a separate issue, 19 small administrative matter. I just wanted to thank 20 Mr. Donnie Ashley, the plant project manager for 21 Oyster Creek for his willingness of taking the 22 responsibility and the fantastic job he did in 23 accessing exhibits during this hearing. It was a last 24 minute request on my part that caused him to be in 25 that position.
I just wanted to thank him definitely NEAL RA GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 843 1 on behalf of the staff and possibly the Board and the 2 parties.3 MR. WEBSTER: Absolutely.
Citizens 4 concur.5 CHAIRMAN HAWKENS: On behalf of the K 6  audience especially who wouldn't have had the benefit 7 of having the exhibits in front of them so bravo.8 Thank you very much. Anything else from the parties 9 before we go to closing statements?
The Board has a 10 couple of more items 11 Directed towards AmerGen, I think it was 12 Mr. Tamburro who had indicated that internal 13 procedures govern the periodic checking of the sandbed 14 drains.15 MR. POLONSKY:
I think Mr. Gallagher 16 provided the final testimony on that.17 CHAIRMAN HAWKENS: Okay. You testified 18 they were internal procedures as opposed to licensing 19 commitments.
20 MR. GALLAGHER:
That's correct.21 CHAIRMAN HAWKENS: The Board's question is 22 would AmerGen have any objection to making this a 23 commitment, to be done at least every -- consistent 24 with your internal procedures?
25 MR. GALLAGHER:
This is the sandbed --NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 844 1 verifying the sandbed drains are clear?2 CHAIRMAN HAWKENS: Correct.3 MR. GALLAGHER:
We would not oppose that.4 CHAIRMAN HAWKENS: All right. Thank you.5 JUDGE ABRAMSON:
Okay. And, 6 unfortunately, we have one final clarification which 7 comes back to the new 3D analysis and what is going to 8 happen with it. Let me see if I can phrase this in a 9 way that we can come to grips with it. Here is the 10 Board's concern. I think this envelopes everything 11 that has been going on here at the proceeding.
The 12 focus of this proceeding is, the ultrasonic testing 13 frequency sufficient to detect a problem before the 14 corrosion creates a problem.15 The purpose of the current condition full 16 3D analysis is to determine what the safety margin is.17 What the Board is not clear on is what will happen 18 with that result.19 First of all, we are not comfortable with 20 the way the language of the SER is stated and we would 21 like the staff and the applicant to rewrite that and 22 give us a draft rewrite so that it makes some sense to 23 us. We understand that the purpose of that is to 24 calculate a new safety -- to recalculate a safety 25 margin for the current configuration as degraded.
Is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 845 1 that correct?2 MR. GALLAGHER:
That's correct.3 JUDGE ABRAMSON:
Okay. And we understand 4 that what the applicant has committed to do is to 5 comply with the law which is if there is a problem 6 reported to the staff and then come to grips with it 7 with the staff under the regs. That is fully 8 appropriate.
We are wondering, however, how this 9 meshes with the issue at hand here which is what is 10 the ultrasonic frequency
-- ultrasonic testing 11 frequency and is it adequate.12 Here is the question we have and we're not 13 quite sure how to come to grips with it in the context 14 of 10 CFR 50 and the context of the regs and the SER 15 and the condition.
16 If you were to come up with a new current 17 condition safety margin that indicated you were on the 18 margin or right at the point where there could be a 19 problem, we presume you would then iterate with the 20 staff to figure out what that meant and that would 21 mean examining your -- since this whole thing is 22 brought about by corrosion, you would be examining 23 your look at the corrosion, your look at the epoxy and 24 your ongoing UT frequency.
Is that correct? Is that 25 what you would expect would happen if you were in that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 846 1 mode? You want to talk about it? We are trying to 2 understand.
3 MR. GALLAGHER:
I'm not sure that the 4 analysis would necessarily factor back into a UT 5 frequency because what we would be calculating is the 6 current condition we' have now and the safety margin, 7 the safety factor.8 JUDGE ABRAMSON:
Suppose that safety 9 factor came in and let's say the current licensing 10 basis requires a safety factor of 2.0. Let's'assume 11 that is the case. I'm not absolutely clear that's the 12 case but let's assume that's the case. Suppose you 13 did a calculation and you came in at 1.99 or 2.01.14 I assume that even at 2.01 or 2.02 you 15 would feel some necessity to report to the staff given 16 their are some bounds of uncertainty in that kind of 17 analysis.
You reported to the staff that you were on 18 the edge of having a -- you are satisfied but you 19 would be on the edge or you nearly satisfied the 20 safety margin requirement of the CLB.21 The question is since that is what's at 22 issue here, i.e., the frequency of UT testing is being 23 driven by whether you are going to run into a problem 24 with the CLB or, to put it another way, the license 25 extension you have to demonstrate that you will meet NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 847 1 the CLB for the period of the license extension.
2 This analysis is being done before the 3 license extension is granted and we are wondering how 4 this would play out between the applicant and the 5 staff if you came in on the margin. Now, you don't 6 expect you will. I don't know but certainly we have 7 heard indications that the current analyses are very 8 conservative and the number is likely to be even 9 larger. If you came in on the margin, what would 10 happen?11 MR. GALLAGHER:
Well, let me first start 12 out with in 2008 we are doing the full scope of 13 inspections so we will have additional data at that 14 point. The same data points but we will have the 15 additional data.16 JUDGE ABRAMSON:
And it's about that same 17 time you are doing this analysis.
Is that right?18 MR. GALLAGHER:
We need to be done the 19 analysis by April of 2009. I think -- can I take a 20 minute to confer?21 JUDGE ABRAMSON:
Sure. Please.22 MR. GALLAGHER:
Okay, Judges. After 23 conferring with my colleagues here, let me talk about 24 both sides of the equation.
Our expectation is that 25 we are going to have a greater safety factor than our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 848 1 current analysis shows. If that is the case, that is 2 good information.
Just for clarity that doesn't 3 affect our CLB because if we wanted to change our CLB 4 with this new better case, this new model, we would 5 have to pursue that via staff review and approvals.
6 That is on the positive side.7 On the side that you're pointing out, if 8 we had a calculated safety factor less than 2, as we 9 said, we would notify the NRC and we would take 10 corrective actions, one of which would be enhancing 11 our inspection program, the locations of inspection, 12 because we could characterize to determine we have 13 more metal and then factor that back into the 14 analysis.
That's one possible solution.15 The other is obviously other corrective 16 actions, you know, that-we could pursue. The short 17 story of saying we put in a corrective action system 18 and pursue that. The staff we would obviously since 19 we notified the staff they would be involved in any 20 outcomes we come up with.21 JUDGE ABRAMSON:
Thank you. That is very 22 helpful. Does the staff have any comment?23 MS: BATY: The comment is that the license 24 condition and the commitment is that AmerGen is 25 supposed to perform this 3D analysis prior to the NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross'com v
849 1 period of extended operation which means that the 2 Board's decision, the Commission's decision about 3 license renewal, this analysis does not have to be 4 done prior to -- it doesn't have to be approved prior 5 to a Board decision, Commission decision on license 6 renewal the way it is written to say prior to the 7 period of. extended operation which means before the 8 current license.9 JUDGE ABRAMSON:
Which is long after our 10 decision hopefully and that is the idea. I understand 11 that.12 MS. BATY: Okay. We wanted to make it 13 clear. Also, this appears also as a proposed license 14 condition in the SER so that is the language.
The 15 language is not identical between those two. I guess 16 the staff is saying there is no basis to reword the 17 commitment because there is a proposed license 18 condition.
19 JUDGE ABRAMSON:
Right. It is the 20 proposed license commitment we would, like to see 21 clarified.
What's in the SER doesn't make any sense 22 to us so we would like to see that clarified to talk 23 about what the real result of this analysis which is 24 not going to be determination that you meet your 25 required thicknesses but that you meet your required NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 850 1 safety factor which would be a function of the 2 thicknesses which will indicate where you are on 3 thickness.
4 Just give us a draft of a revised proposed 5 licensing condition and the two of you can work on 6 that. We just want it to be clear what it really is 7 and it's not clear. If that means messing with your 8 commitment, then mess with the commitment, too. Get 9 it right. That's all.10 JUDGE BARATTA: One point of 11 clarification.
What we are talking about is a license 12 condition.
Not commitment, license condition.
13 JUDGE ABRAMSON:
I think what I hear the 14 staff saying is this will be done before the license 15 extension so it's the commitment that needs to be 16 clarified.
It becomes a condition in the SER that 17 this commitment is satisfied.
It will all be fait 18 accompli I assume by the time the license is actually 19 issued so it's not a condition of the license itself.20 It's a condition to issuance of the license.21 MS. BATY: Your Honor, can we -- I'm going 22 to read the condition as it currently is stated.23 JUDGE ABRAMSON:
We've read it in the SER.24 MS. BATY: We're confused about what is 25 unclear so we would like -- the staff would appreciate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 851 1 the Board's guidance in what we need to do to address 2 this. Right now it says, "The 7th license condition 3 requires the applicant to perform a 3D finite element 4 analysis of the drywell shell prior to entering the 5 period of extended operation." 6 JUDGE ABRAMSON:
That's appropriate.
7 There's another sentence.
Maybe it's in the condition 8 then that talks about to make sure that -- where was 9 that, Tony?10 MR. GALLAGHER:
It's in the commitment.
11 JUDGE ABRAMSON:
It's in the commitment.
12 Okay. Then let's just fix the commitment.
The 13 condition is fine.14 MS. BATY: Okay. Thank you.15 MR. GALLAGHER:
Judge Abramson, just one 16 point, of clarification.
I think you had said 17 something like it would be a condition to issue the 18 license. Our understanding of what this is it's a 19 license condition.
You are right the condition will 20 be satisfied before the period of extended operation 21 but it's not a condition to issue the license. It's 22 a condition within the license.23 JUDGE ABRAMSON:
I stand corrected.
24 That's fine. The license can be issued early but you 25 don't get your extension unless this condition is met.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 852 1 MR. GALLAGHER:
We have to comply with the 2 condition.
3 JUDGE ABRAMSON:
Okay. Thank you.4 CHAIRMAN HAWKENS: Does that conclude 5 administrative matters before hearing final 6 statements?
Citizens?7 JUDGE ABRAMSON:
Let me just plead with 8 the counsel who are going to give these closing 9 statements.
You are going to have plenty of chance to 10 spell this out in your proposed finding so please keep 11 it brief.12 CHAIRMAN HAWKENS: >NRC staff, no final 13 administrative matters?14 MS. BATY: No.15 CHAIRMAN HAWKENS: AmerGen?16 MR. POLONSKY:
No final other 17 administrative matters.18 CHAIRMAN HAWKENS: All right. Before 19 going into the closing statements, the Board would 20 just like to once again express its appreciation to 21 the Ocean County officials who allowed us to use this.22 and especially to Ms. Flynn back there. I wanted to 23 make sure I express my gratitude to you before you 24 stepped out. Thank you very much.25 We also express our gratitude to the Under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 853 1 Sheriff's Office for all the support they have given 2 us both during the limited appearance sessions and 3 during this session. Thank you very much.4 And to Rob. I don't know Rob's last name 5 but he's with Wolf Sound Company and he helped us out 6 with the sound system here today. We are very 7 grateful for that.8 Closing statements.
As per ordered, they 9 are limited to 20 minutes per party. The NRC staff 10 has declined the opportunity to provide a closing 11 statement.
We will hear first from Citizens.
The 12 parties need not use the full 20 minutes, although 13 they may.14 MR. WEBSTER: Was there a hint there 15 somewhere?
16 CHAIRMAN HAWKENS: No, it's a plea.17 MR. WEBSTER: Well, it's kind of hard to 18 be brief when so much has happened.
I will do my best 19 but also please remember this i's sort of an 20 extemporaneous'summary of what has occurred so I'll do 21 my best to sort of produce some sort of wonders or 22 oratorical
-- I lost the word already. Obviously I'm 23 going to fail at that. I'll try to keep it simple and 24 try to get it right.25 There are six groups here, Citizens NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 854 1 groups. These have been wrongly characterized as 2 anti-nuclear groups. In fact, they cover a very broad 3 range of interests.
We have mothers who have found 4 their children's teeth with high levels of radiation 5 in them. We have citizens who have genuine and 6 serious safety concerns.7 We have nuclear engineers who believe that 8 Oyster Creek is the first plant in the country and 9 should not be relicensed.
We have citizens who 10 believe that the NRC is fundamentally failing to 11 properly regulate nuclear safety. And we have 12 citizens who are anti-nuclear so there is a broad 13 range of motivations for this intervention.
14 I don't think the motivations matter that 15 much. This is an arduous process, as we've seen.16 Forty-four relicenses have been through with no 17 citizen intervention, no successful citizen 18 intervention.
Thus, without a valid scientific point 19 citizens simply are unable to get to this point.20 What we've heard over the last couple of 21 days I think has certainly troubled us and I think has 22 troubled people beyond this room. To use the 23 metaphor, the sea of uncertainty appears to have been 24 rising. I've got my snorkel out right-now.
25 What we've seen is that really we don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 855 1 know if the pressure criterion is met, we don't know 2 if the LOCA buckling criterion is met, and we don't 3 have 95 percent confidence that the generalized 4 corrosion criterion is met in every bay. I would call 5 that a pretty uncertain situation.
The question is 6 what do we do with that uncertainty?
7 We have tried repeatedly.
This is not a 8 situation where citizens have hid the ball here and 9 said AmerGen is springing on your this concern. We 10 have been to the ACRS with this issue and that is 11 where the requirement for the new final element 12 modeling came from. That was a commitment made at the 13 last minute by AmerGen to try to mollify the concerns 14 of the ACRS.15 Since then we have done more data 16 analysis.
We have finally managed to find coordinates 17 to scale. We have analyzed those. We have shown that 18 the characterizations of the measurements were 19 completely incorrect.
The measurements have been 20 characterized by showing only severe errors of 21 degradation near the vent header. That's completely 22 wrong.23 There are areas of very severe degradation 24 and that most -- well, it is most likely -- let's put 25 it this way. In a sea of uncertainty it's very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
.o 856 1 difficult to make definitive statements about this 2 drywell.3 If I phrase this as carefully as I can, 4 the best -interpretation of the data that we can 5 produce shows there is a probability that there are 6 very severe areas of corrosion that go beyond the CLB 7 in the most sensitive areas of the drywell. They are 8 at the edge of the base.9 AmerGen has never put the data for two 10 bays together and analyzed the two together and see 11 whether this nine square foot area actually extends 12 over the two bay. Each bay has been analyzed 13 completely separately from another.14 The level of analysis has been -- I'm 15 struggling for the right word here -- has been, I 16 think, poor. Let's put it this way. If this was' a 17 physics paper I think you would get a D, revision 2 of i8 the 24 Calc. I find that surprising because this was 19 a revision that was produced once this litigation had, 20 already started.21 If I was the largest nuclear company in 22 America, I might have taken some time to get that 23 calculation right but it appears that AmerGen didn't 24 do that. They put out a document that was riddled 25 with errors. It was simplistic and, at best, shows NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 857 1 marginal compliance.
At worst it shows they are 2 already by their own assessment beyond the CLB and 3 makes no attempt whatsoever to estimate margin.4 Let's say a few words about NRC. As you 5 might have gathered by now I wasn't born within these 6 shores. I'm going to use a soccer analogy here.7 Somebody said earlier this is like a baseball game.8 Well, I'm not too familiar with baseball so I'm going 9 to stick with a soccer analogy.10 As far as I'm concerned we have been 11 coming down the field here pretty strongly.
We have 12 been reaching the penalty box which, for those who 13 don't know, is 18 yards from the goal. Just as we are 14 moving into the penalty box NRC suddenly grabbed the 15 goal post and ran off down the field with it.16 The requirement to meet the ASME code 17 factor of 2 was acknowledged by the applicant 18 repeatedly and has been acknowledged again by the 19 applicant.
It is an 'amazing situation where the 20 regulator is suggesting a less stringent criterion is 21 appropriate than the applicant.
22 This is a situation that I have spent many 23 years as both an environmental consultant and a few 24 years as a lawyer. I have never seen a situation 25 where the regulator is saying, "Oh, we think we have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.ý202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 858 1 an exemption," or the applicant is saying they don't.2 How can citizens appropriate intervene in a hearing 3 like this when we don't even know what the 4 requirements are.5 The CLB is kind of like the Holy Grail.6 Everybody refers to it. .It can't be challenged.
The 7 only thing is none of us know what it is. There's no 8 statement of it. Even now this Board is struggling to 9 try to figure out what it is after a year and a half 10 of litigation.
That is an entirely ridiculous 11 situation.
12 How can you have public transparency of 13 nuclear regulation when citizens are unable to find 14 out without doing months of work on what the 15 requirements are? Even when citizens do figure out 16 what the requirements are, NRC staff then arbitrarily 17 changed them at the last minute.18 Why does NRC say they can change the rules 19 just as we start to win the game? They say they know 20 more now about the drywell than they knew when it was 21 built. That is entirely wrong. When it was built the 22 drywell had a nominal thickness.
There was presumably 23 some natural variation of nominal thickness but it was 24 very small.25 When it was built they hadn't thrown away NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 859 1 the files that they used to design it. When it was 2 built there was an allowance for inclusions and all 3 this other stuff. That was the safety _- well, the 4 safety factor 2 came in a little bit later. The 5 previous code actually required more analysis if a 6 thinning of 10 percent was observed.
When it was 7 built the safety factor was something around 3.85.8 Since then we have thrown away the files 9 and we've had severe corrosion.
We have heard that we 10 don't know where the severe corrosion is. We don't 11 know how thin it is. We know very little actually.12 I think that is the overriding theme. We know very 13 little about this drywell.14 We have 100 points from the exterior and 15 we have these tightly-spaced grids, 12 grids with a 16 quarter of a square foot and three square foot on the 17 outside, three square foot of a 700 square foot 18 vessel. We know very little. NRC's explanation, NRC 19 staff explanation for now we can now relax this safety 20 factor 2 makes no sense whatsoever.
If anything, NRC 21 should now require something greater than a factor of 22 two because the level of uncertainty has increased 23 since design, not decreased.
24 Likewise, this Board has characterized NRC 25 staff counsel in the role of amicus but at every stage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 860 1 -- not at every stage but more laterally NRC staff 2 counsel has more vigorously fought the citizens'3 attempt to add documents to the record, has cited more 4 reasons for to strike documents that citizens have 5 provided and has generally put itself in an 6 adversarial position to citizens.7 If the goal of the NRC in these 8 proceedings is to have issues fully aired, it's hard 9 to understand why NRC staff while spending their time 10 and Government money objecting to Citizens putting in 11 exhibits in a proceeding like this when the applicant 12 isn't objecting.
13 So now finally we reach the point, and I 14 think we are all very glad to be here, and certainly 15 my wife is very glad we are here, which is that we 16 know very little. AmerGen has to provide -- the legal 17 standard is AmerGen has the burden of showing that 18 they have reasonable assurance so they can meet the 19 requirement.
20 Now, there is a circuit court case out 21 there, I think it's North Anna, that interprets 22 reasonable assurance as a clear preponderance.
What 23 we have here, for instance, let's take an 6xample. On 24 the very LOCA pressure criterion
.49 we don't have a 25 clear preponderance.
We have Dr. Hausler's analysis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 861 1 saying there's a good chance that there are some areas 2 that are thinner than 4.9. We have no testimony from 3 the other parties. That's not a clear preponderance.
4 On the LOCA area criterion AmerGen hasn't 5 even sought to establish what the margin has been.6 There is no evidence -- the best evidence is that 7 there is no margins so you can't find a clear 8 preponderance in favor of compliance with the LOCA 9 area criterion.
10 Now, moving from a legal term to a 11 statistical term, we have shown that federal courts 12 regard the 95 percent competence interval as the basic 13 cornerstone of sound science. In 'federal court you 14 cannot show, for instance, causation to less than 85 15 percent competence.
The court will not allow you to 16 do that, 17 A single plaintiff cannot recover money 18 from a drug company, for instance, that cannot show to 19 95 percent competence.
There has been causation.
20 It's hard for me, and I think it will be hard for 21 everybody else, and I hope the Board will find it 22 impossible to find that when the safety of thousands 23 of people is at stake and billions of dollars that a 24 lower level of competence than 95 percent would be 25 appropriate.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 862 1 In fact, citizens assert that 95 percent 2 competence is the absolutely minimum that is supposed 3 to require it legally and require it technically.
4 Here perhaps we have a happy coincidence of more than 5 technicalities which don't always occur where it 6- appears that sound science and' the law are reasonably 7 coincident.
8 AmerGen has refused to plot these 95 9 percent competency rates. Again, it's hard to find a 10 clear preponderance that we know these margins are 95 11 percent competence when AmerGen has refused to even 12 evaluate the margins at 95 percent.13 So the sea of uncertainty has been rising.14 The Board is now faced with a question.
Does it 15 decide that AmerGen had plenty of chance to dispel 16 this sea of uncertainty and didn't bother to do it.17 Why didn't it both to do it? Presumably it figured 18 the NRC has exactly been the toughest agency in 19 nuclear the last few years.20 They figure no intervenor has ever managed 21 to get through the process of actually intervening and 22 getting a hearing so why dispel the uncertainty?
The 23 only danger if you dispel the uncertainty is you find 24 something you don't like. AmerGen adopted a don't 25 look, don't find policy. Amazingly NRC staff endorsed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 863.1 that policy.2 So now the Board has to decide -- well, 3 let's say this. Based on the record before the Board 4 because there is no clear preponderance of evidence 5 showing that the margins are met, we cannot move 6 forward with relicensing based on this record.7 Similarly because there is no showing what 8 the minimum margin is, it's impossible to determine 9 the ultimate question which is what is the appropriate 10 monitoring frequency.
We've had testimony that there 11 is corrosion, that AmerGen's expert is assuming there 12 is some degree of corrosion.
Therefore, what we have 13 to do, there is certainly corrosion on the interior.14 There is no argument about that. There's no coating.15 AmerGen's expert has assumed there is some 16 corrosion going on and that makes perfect sense. It 17 also makes sense to assume there is some corrosion 18 going on on the outside. We have some corrosion.
The 19 question is what is the minimum margin? We don't 20 know. We don't even know there is a margin.21 How am I doing, Judge Abramson on time?22 CHAIRMAN HAWKENS: You are doing well.23 You have another five minutes.24 MR. WEBSTER: Another five minutes. I 25 should wrap up early in that case.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 864 1 So the Board now has to decide. AmerGen'2 is struggling with this uncertainty.
Do you want to 3 throw them a life ring or do you want to let them 4 drown? It's our assertion that by now the biggest 5 nuclear company in America should have got this right.6 Their failure to get it right calls into question 7 their ability to operate this plant safely in the 8 future.9 It's our assertion, therefore, that the 10 Board should not throw them a life ring. The Board 11 should-decide that relicensing of Oyster Creek cannot 12 go forward. However, if as is the habit of the agency 13 the Board decides to throw them a life ring, then it 14 should lay down a number of conditions and it should 15 not close this proceeding.
It should keep the 16 proceeding open so the Citizens can see how the issues 17 that we have put forward are.18 What is required here are some 19 requirements.
We have this promise of more analysis.'20 Thie problem is we don't know what the requirement is.21 Dr. Hausler said, well, it could be 1.9, 1.8, 1.7. He 22 really doesn'tknow.
I don't understand then how this 23 analysis can be useful. How will we know whether the 24 analysis shows that the drywell meets the requirements 25 if NRC doesn't have any requirements?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 865 1 If the Board decides to throw AmerGen life 2 ring, which we believe it should not, the Board will 3 have to decide what standard should apply. At minimum 4 the Board should apply ASME code safety factor of 2.5 Actually because there is more uncertainty in this 6 case, well, we can go either way really but we have to 7 make sure there is also a known level of certainty 8 attached to either the condition of the drywell or to 9 the safety factor.10 Secondly, should the Board take this 11 nonrecommended route citizens should have the chance 12 to submit a new contention after the analysis is 13 complete because this analysis would be new 14 information.
Even AmerGen doesn't know what the 15 results are going to be.16 Finally, I think the Board needs to be 17 clear with the staff that the staff should not allow 18 SERs to go out without a staff being able to assign 19 competence in the mix to the parameters that they are 20 judging to be in compliance.
This is a fundamental 21 point. If you don't have 95 percent competence and 22 compliance, I don't know how many acceptance criterion 23 there are in a nuclear plant but I know there are more 24 than 40.25 On a statistical basis if we have 95 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS.
1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 866 1 percent competence and compliance, of two-tailed 2 distribution, that is, and then we have 40 parameters, 3 one of those parameters would be out of compliance.
4 We questioned for the Board whether that's enough but 5 at minimum we should know what the competence 6 intervals are. It's utterly inappropriate for the 7 staff to go forward with the safety assessment when 8 they don't know the competence intervals on the 9 parameters that they are judging to be in compliance.
10 In summary, we wish we could trust NRCo 11 We wish we could trust AmerGen. Unfortunately
-- NRC 12 staff, that is. Unfortunately, in the course of this 13 proceeding we found we cannot trust AmerGen, we can't 14 trust Exelon, and we have sadly lost trust in the NRC 15 staff.16 We now place our trust in you, this Board, 17 to salvage from this sea of. uncertainty some vestige 18 of legitimacy for this agency and make it clear that 19 the nuclear industry does not have the NRC in its 20 pocket, that NRC is a vigorous agency that will 21 vigorously uphold safety standards and safety 22 requirements and will not continually slip those 23 standards so that Oyster Creek today is a far less 24 safe plant than Oyster, Creek was 40 years ago.25 What that means is the NRC now is allowing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
.1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 867 1 a huge safety gap to emerge between new plants and 40-2 year-old plants. I know it's not this Board's 3 position to make policy but at minimum it must ensure 4 that the 40-year-old plants actually meet some 5 reasonable standards of safety.6 We put our trust in you, gentlemen.
We 7 know that you are very intelligent.
We know that you 8 are very inquiring.
We know that you have a lot of 9 training and we know that you have a lot of 10 experience.
We ask you to have a lot of courage.11 Thank you.12 CHAIRMAN HAWKENS: Thank you very much, 13 Mr. Webster.14 NRC staff. Excuse me, AmerGen.15 MR. POLONSKY:
Thank you, Your Honor.16 First and fundamentally, contrary to Mr. Webster's 17 statements, AmerGen's experts have acted 18 professionally, in good faith, and with a high degree 19 of technical competence, in particular Mr. Tamburro.20 We strongly disagree with Mr. Webster's aspersions on 21 their integrity and rigor of analysis.22 In our opening statement we described the 23 incredible assumptions the Board would have to make in 24 order to find that a four-year UT frequency was not 25 adequate.
Citizens' testimony over the past two days NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 868 1 did not make those assumptions any more credible.2 In fact, Citizens' testimony confirmed 3 that their arguments about the acceptance criterion, 4 available margins, sources of water, performance of 5 the epoxy coating and future corrosion rates are based 6 either on a misunderstand of the facts or an 7 inappropriate application of science. Let's go over 8 each of those areas.9 Acceptance criterion first. The general 10 buckling criterion and pressure criterion really never 11 were at issue in this proceeding and nothing over the 12 past two days called those criteria into question.13 Contrary to Mr. Webster's assertion we did provide the 14 citations which refute that there is no exceedance of 15 the LOCA buckling criterion
-- I'm sorry, the pressure 16 criterion.
17 As for the LOCA criterion, LOCA buckling 18 criterion, the current licensing basis is AmerGen's 19 description in Applicant's Exhibit 11, namely a one-20 foot square center 536 surrounded by a transition of 21 one foot to a uniform thickness of 736 mils. Dr. Har 22 Mehta from GE has demonstrated that Citizens misread 23 the GE analysis.
That was the basis for this LOCA-I 24 buckling criterion when they interpreted that 25 criterion to be half the size.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 869 1 Amergen then demonstrated that Citizens 2 also misread AmerGen's documents when they argued that 3 this LOCA buckling criterion has changed over time.4 In fact, Citizens' only expert could not addressthe 5 CLB because he was unfamiliar with it. Finally, the 6 staff concurred that the LOCA buckling criterion is 7 part of the CLB and that it has not changed over time.8 Two, available margin. As for identifying 9 the available margin, the testimony has demonstrated 10 that AmerGen's approach to use the average of the 11 internal UT grid data is adequate and is the standard 12 in the nuclear industry.13 Citizens would like a different standard 14 which would require AmerGen to use the lower 95 15 percent competence interval for the data. That 16 approach we believe would actually ignore data and 17 ignores the phenomenon that the ASME code is seeking 18 to present, namely buckling, which is a phenomenon 19 over large areas, not single points.20 In their opening statement Citizens cited 21 to federal courts and scientists who require each fact 22 to be proven to a 95 percent confidence.
Mr. Webster 23 alluded to that again in his closing. Reasonable 24 assurance, however, does not require a 95 percent 25 confidence.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 870 1 As for the bounding available margin, the 2 Board has made it abundantly clear that AmerGen has 3 the burden here but the record now makes clear that 4 AmerGen's bounding available margin estimate of 64 5 mils in a six-by-six inch area in bay 19 is extremely 6 conservative and that the likely available bounding 7 margin is considerably higher.8 We started with 64 mils in an area in bay 9 19 located in the upper sand bed region but it is now 10 clear from Dr. Hausler the likely future site of 11 corrosion, if any, will be near the sand bed region 12 floor because if there is any new water in the 13 exterior, it would accumulate on the floor because 14 there is no longer any sand to keep the water in 15 contact with the higher elevation in the sand bed 16 region. There is significantly more margin near the 17 sand bed floor. Bay 17 trench data show more than 200 18 mils of available margin in this elevation.
19 Moreover, the contour plots -- pardon me.20 There has also been quite a bit of discussion over the 21 past few days about whether the internal UT grid data 22 are representative of the bounding conditions from the 23 drywell shell when considering buckling.24 AmerGen unequivocally demonstrated that 25 the external UT measurements are biased thin because NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 871 1 (1) they were selected in 1992 to be the thinnest 2 locations as documented in historical reports; (2) the 3 internal grids when superimposed on external data 4 technically demonstrate that the external points are 5 thinner than surrounding areas; and (3) the photos and 6 personal observations of the exterior surface visually 7 show that they are.8 Accordingly, Citizens' contour plots of 9 the drywell shell which treat these data as randomly 10 selected and, therefore, representative of the drywell 11 shell, are meaningless.
Moreover, the contour of 12 other failings.
They are not based on actual UT 13 thickness measurements.
14 Approximately half of the points used on 15 the bay 13 contour plot in Citizens' Exhibit 61 were 16 manipulated by taking 1992 data and uniformly 17 subtracting 20 mils from each point. The contour 18 plots then extrapolate behind the known data. As Dr.19 Hausler stated, this is an exercise in speculation.
20 As for the sources of water, the testimony 21 is now conclusive that there is no potential for water 22 during normal operation and that only the refueling 23 cavity when it is filled with water could be the 24 source in the. future. This cavity is only filled 25 during refueling outages.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 872 1 It is only expected to be filled during 2 refueling outages. The time that the exterior shell, 3 therefore, could be wet is very short, less than 30 4 days every two years. All parties now agree that 5 condensation of the exterior, whether during normal 6 operation or an outage, is not an issue.7 As for the epoxy coating, Dr. Hausler 8 lacks the experience to provide a meaningful opinion 9 about the performance of that coating. The coating on 10 the exterior drywell shell is located in a benign 11 atmospheric environment.
It simply cannot suffer the 12 same untimely and rapid degradation as a coating in an 13 oil field which is located in a submerged, pressured, 14 and elevated temperature environment.
Dr. Hausler's 15 testimony on this issue, therefore, deserves little, 16 if any, weight.17 Finally, future corrosion, future 18 corrosion rate, for the external surface. Mr. Gordon 19 explained why 3 mils is a reasonable annual corrosion 20 rate assuming no coating, no sand, and the presence of 21 water. This is based on an outage temperature of 93 22 degrees F and Mr. Hosterman testified that this 23 temperature is reasonable considering temperatures in 24 the external sand bed region during normal operations, 25 which would be hotter, is around 109.5 degrees.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 873 1 For the interior surface Mr. Gordon 2 demonstrated why any future corrosion of that surface 3 of the drywell shell is of no engineering concern. He 4 also explained in his prefile testimony that the 5 chemistry of the water in contact with the internal 6 drywell surface that is embedded in. concrete meets the 7 NRC's goal and every guidelines for a noncorrosive 8 environment.
9 Citizens provided no evidence to the 10 contrary.
Thus, there is no, basis for Citizens 11 alleged annual'interior corrosion rate of 10 mils per 12 year and, frankly there never was a basis other than 13 an unsupported arguments that 2 mils of corrosion is 14 going on right now and that this rate might be 15 multiplied by five if new water reached the concrete 16 drywell floor and somehow came into contact with the 17 drywell shell before its pH was increased by the ever-18 present concrete.19 Mr. Gordon logically explained in his 20 prefile testimony that the pH of any new water would 21 quickly become basic from its contact with the 22 concrete.
Under no scenario would this rate be 23 sustained for an entire year. The Citizens contend 24 when they list 10 mils it's an annual corrosion rate.25 As for any rate of general corrosion on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 874 1 the exterior, that remains frankly outrageously 2 speculative.
To explain, to exceed the over 200 mils 3 of bounding margin near the base of the sandbed floor, 4 the Board would have to conclude that greater than 50 5 mils per year of corrosion would need to occur during 6 the four-year UT inspection interval.7 The Board would also need to find that the 8 coating, which is in excellent condition, would 9 degrade and that it would do so near the floor of the 10 sandbed region. Coating failure would have to be in 11 an area larger than 9 square feet because anything 12 smaller than that would be evaluated using LOCA 13 buckling criterion which, due to the bottom of its 14 tray of 536 allows significantly more metal to be 15 removed before exceeding that criterion and the LOCA 16 buckling criterion which is seven.17 The water would then have to come into 18 contact with the same large area of failed coating and 19 remain in contact with the underlying bare metal 20 surface for over four years without AmerGen detecting 21 the, water and taking corrective action. This is 22 despite fact that AmerGen has committed to check the 23 sandbed drains every three months.24 There is no known source of water during 25 operations and there is only speculation that water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 875 1 could reach the sandbed region during the 2 approximately 30-day long outages every other year.3 In addition, the floor of the sandbed is now sloped to 4 facilitate drainage away from the shell.5 For all these reasons there is reasonable 6 assurance that AmerGen will be able to manage the 7 effects of aging in the drywell shell during the 8 period of extended operation consistent with the 9 current licensing basis. Thank you.10 CHAIRMAN HAWKENS: Thank you, Mr.11 Polonsky.12 That concludes the presentation of the 13 parties for this hearing. Some administrative matters 14 I would like to address in closing. A reminder 15 parties that propose questions will be provided the 16 Sec'y. When the Board issues its written decision a 17 request for Citizens.
We did provide your handwritten 18 confidential questions.
If you would do us the favor 19 of providing Ms. Wolf with a typed copy of that by 20 Thursday, close of business.
Would that be possible?21 MR. WEBSTER: If I could get a copy of the 22 questions back, Judge, that would be fine.23 CHAIRMAN HAWKENS: You certainly may. As 24 a reminder, the parties have agreed they will submit 25 their motions for transcript corrections by October NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C7'20005-3701 www.nealrgross.com 876 1 9th. If Ms. Wolf has not done so already, she will 2 provide you with a format.3 MR. WEBSTER: Sorry, Judge. I'm sorry to 4 say that Dr. Hausler informed me, and he had been 5 wanting to inform the Board, that he has said that he 6 is over-committed for the next two weeks and cannot, 7 therefore, provide to me his transcript corrections.
8 I suggest that perhaps an approach might 9 be that I could certainly provide the corrections I 10 believe are appropriate by the deadline we had 11 discussed previously.
I think it is appropriate since 12 it is Dr. Hausler's testimony to allow him to correct 13 his own testimony at a later date.14 CHAIRMAN HAWKENS: What date can Dr.15 Hausler supply his transcript corrections?
16 DR. HAUSLER: Monday of the third week of 17 October. I'm committed through the 15.18 CHAIRMAN HAWKENS: October 22nd? That's 19 the date?20 DR. HAUSLER: That would be fine.21 CHAIRMAN HAWKENS: All right. We will 22 have then the parties submit their motion consistent 23 with our original understanding.
On October 9th they 24 will have the corrections agreed upon by the parties 25 with the exception of those corrections' by Dr.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 877 1 Hausler.2 You will provide your proposed findings of 3 fact and conclusions of law consistent with the 4 corrections-submitted.
To the extent there are 5 further corrections, you may provide a revised draft 6 of those proposed findings of fact and conclusions of 7 law.8 MR. WEBSTER: Sorry, Judge. I'm a little 9 slow by the end of the day.10 CHAIRMAN HAWKENS: Your proposed findings 11. of fact and conclusions of law are due on or before 12 October 10th.13 MR. WEBSTER: I understand that. Are 14 those going to be based on the draft transcript?
15 CHAIRMAN HAWKENS: Yes. Correct.16 MR. WEBSTER: Okay.17 CHAIRMAN HAWKENS: The party anticipates 18 issuing its decision sometime in November.
The Board 19 does. I'm sorry. I get a little slow also this time 20 of day. If a party wishes to challenge that decision, 21 it must file a petition for review within 15 days of 22 the service of that decision with the Commission.
23 If no petition for review is filed, if the 24 Commission does not initiate any review action, the 25 Board's decision is final Agency action 40 days after NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgrosscom 878 1 its date of issuance.
As a reminder to the parties, 2 under Commission regulations you must seek Commission 3 review as a prerequisite for seeking judicial review.4 Are there any other additional matters to 5 discuss before we close the record subject to the 6 motions for transcript corrections?
7 MR. POLONSKY:
Nothing for AmerGen, Your 8 Honor.9 MS. BATY: Nothing from the staff at this 10 time.11 MR. WEBSTER: Is there going to be another 12 time? Nothing for Citizens.13 CHAIRMAN HAWKENS:.
Thank you. Thank 14 counsel and their witnesses for the service they 15 provided for cooperation and the contributions to this 16 hearing, We express our gratitude to the audience for 17 their attendance.
The record is closed subject to the 18 motion for transcript corrections and the hearing is 19 closed. Thank you very much.20 (Whereupon, at 4:34 p.m. the hearing was 21 adjourned.)
22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com v
CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: Name of Proceeding:
Amergen Energy Company Oyster Creek Evidentiary Hearing Docket Number: 50-0219-LR Location:
Toms River, New Jersey were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting.
company, and that the transcript is a true and accurate record of the foregoing proceedings.
VJames Salan-dro Official Reporter Neal R. Gross & Co., Inc.NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com}}

Latest revision as of 21:09, 14 January 2025

Corrected Transcript of Evidentiary Hearing Held in Toms River, Nj; Pp. 610 - 878
ML073030157
Person / Time
Site: Oyster Creek
Issue date: 09/25/2007
From:
Atomic Safety and Licensing Board Panel
To:
SECY RAS
References
50-219-LR, ASLBP 06-844-01-LR, NRC-1780, RAS 14543
Download: ML073030157 (271)
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