ML16350A327

Transcript of Advisory Committee on Reactor Safeguards Plant License Renewal Subcommittee Meeting - November 17, 2016

ML16350A327
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Site:	South Texas
Issue date:	11/17/2016
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NRC-2739
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Advisory Committee on Reactor Safeguards Plant License Renewal Subcommittee Docket Number: (n/a)

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

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

Washington, D.C. 20005 (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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

-3701 www.nealrgross.com 1 1 2 3 DISCLAIMER 4 5 6 UNITED STATES NUCLEAR REGULATORY COMMISSION'S 7 ADVISORY COMMITTE E ON REACTOR SAFEGUARDS 8 9 10 The contents of this transcript of the 11 proceeding of the United States Nuclear Regulatory 12 Commission Advisory Committee on Reactor Safeguards, 13 as reported herein, is a record of the discussions 14 recorded at the meeting.

15 16 This t ranscript has not been reviewed, 17 corrected, and edited, and it may contain 18 inaccuracies.

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-3 701 (202) 234-4433 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

+ + + + + ADVISORY C OMMITTEE ON REACTOR SAFEGUARDS (ACRS) + + + + + PLANT LICENSE RENEWAL SUBCOMMITTEE

+ + + + + THURSDAY NOVEMBER 17, 2016

+ + + + + ROCKVILLE, MARYLAND

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

Skillman, Chairman, presiding.

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-3701 (202) 234-4433 COMMITTEE MEMBERS:

GORDON R. SKILLMAN, Chairman PETER RICCARDELLA, Member

-at-Large RONALD G. BALLINGER, Member WALTER L. KIRCHNER, Member DANA A. POWERS, Member JOHN W. STET KAR, Member MATTHEW W. SUNSERI, Member ACRS CONSULTANT:

STEPHEN SCHULTZ DESIGNATED FEDERAL OFFICIAL:

KENT HOWARD ALSO PRESENT:

ARDEN ALDRIDGE, STP NOC MIKE BERG, STP NOC

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

DAVE GERBER, SIA RON GIBBS, STP RAFAEL GONZALES, STP NOC ALLEN HISER, NRR/DLR

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-3701 (202) 234-4433 WILLIAM HOLSTON, NRR MATTHEW HOMIACK, NRR LOIS JAMES, NRR/DLR RAIHAN KHONDKER, STP NOC BRET LYNCH, WP JANE MARSHALL, NRR TODD MAXEY, ST P JAMES MEDOFF, NRR/DLR

MIKE MURRAY, STP NOC CHANCEY PENCE, STP NOC GREG PICK, Region IV DAVE RENCURREL, STP BILL ROGERS, NRR/DLR DAN SICKING, STP NOC RICK STARK, STP NOC DAVID STUHLER, STP NOC MIKE SVETLIK, STP MARK WALES, STP NOC GARY WARNER, WP DAVE WI EGAND, STP NOC JAMES WILLIAMS, STP NOC PRESTON WILLIAMS, STP NOC JAMES C. YOUNGER, STP NOC KEVIN REGIS, STP NOC

• Present via telephone

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-3701 (202) 234-4433 C-O-N-T-E-N-T-S Call to Order and Opening Remarks

..................

5 Staff Introduction

................................

.6 South Texas Project Nuclear Operating

..............

7 Company (STPNOC) - South Texas Project, Units 1 and 2 (STP)

NRC Staff Presentation SER with Open

..............

80 Items Overview Opportunity for Public Comment

...................

133 (None) Committee Discussion

.............................

134 Adjourn

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-3701 (202) 234-4433 P R O C E E D I N G S 1 8:29 a.m. 2 CHAIRMAN SKILLMAN: (presid ing) Ladies 3 and gentlemen, good morning. This meeting will now 4 come to order.

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

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

2. 10 ACRS members in attendance today are 11 Dana Powers, John Stetkar, Ron Ballinger, Peter 12 Riccardella, Walt Kirchner, and Matt Sunseri. Our 13 ACRS consultant Dr. Stephen Schultz is also in 14 attendance. Kent Howard of the ACRS is the 15 Designated Federal Offici al for this meeting.

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

24 The rules for participation in today's 25 6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 meeting have been announced as part of the notice 1 of this meeting published in The Federal Register.

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

6 There will be a phone bridge line. To 7 preclude interrupti on of the meeting, the phone 8 will be placed in a listen

-in mode during the 9 presentations and Committee discussion.

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

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

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

23 Thank you, Chairman Skillman.

24 As stated, I am Jane Marshall. I'm the 25 7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Acting Director for the Division of License Renewal 1 in the Office of Nuclear Reactor Regulation. With 2 me here today are members of my management team and 3 several members of my staff. They will introduce 4 themselves as they answer questions today. Also 5 joining u s by phone is Greg Pick, who is the Lead 6 Inspector from Region IV.

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

13 At today's ACRS Subcommittee meeting, 14 the staff will present its review and resolution 15 path for the open item for the license renewal of 16 South Texas Project Units 1 and 2. The information 17 we will be presenting was documented in the Final 18 SER. 19 At this time, I would like to turn the 20 presentation over to South Texas Project Nuclear 21 Operating Company and Dave Rencurrel, Senior Vice 22 President for Operations, to introduce his team and 23 commence their presentation.

24 Thank you.

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-3701 (202) 234-4433 MR. RENCURREL: Good morning.

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

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

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

14 There it is. All right. As you can 15 see, here is an overview of the agenda, which we 16 will be presenting today. I would like to point 17 out that we are setting aside a really special time 18 or focused time to discuss the Safety Evaluation 19 Report open item for aluminum bronze selective 20 leaching. 21 With that, I would like to move into 22 the introductions of the team that we brought 23 today. I will start and, t hen, we will just move 24 to the left and move down our line.

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-3701 (202) 234-4433 Now my name, as I said, is David 1 Rencurrel. I'm the Senior Vice President of 2 Operations.

3 I began my career over 35 years ago, my 4 nuclear career over 35 years ago in 1981, when I 5 started in the Un ited States Navy as a nuclear 6 officer. In 1988, I joined the South Texas Project 7 and, since then, I have had many different jobs. I 8 got hired in as a young system engineer. I have 9 went through license class, spent time in the 10 control room as a shift technical advisor. I spent 11 time as a work control supervisor, worked in 12 maintenance, system engineering manager, design 13 manager. I was ops manager for a little bit over 14 four years, VP of Engineering and Projects, Site VP 15 for over four years. Now I am in my current role 16 where I am responsible for all projects here 17 onsite. 18 I would like to hand off to Mike 19 Murray. 20 CHAIRMAN SKILLMAN: Not so fast, Dave.

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

24 MR. RENCURREL: I think that is 25 10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 extremely important. 10 CFR 50 Appendix B is what 1 gives us that consistency and that credibility that 2 we all want. I think that is where that comes from 3 in that regard.

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

13 CHAIRMAN SKILLMAN:

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

18 MR. RENCURREL: So, what is

-- that is 19 the quality, right?

20 CHAIRMAN SKILLMAN: Yes, yes.

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

22 So, here's what we do in regards to independent 23 oversight of their station.

Independent oversight, 24 obviously, we have the right dedication and right 25 11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 resources assigned to that. They act independently 1 in that they report up to a company officer. All 2 right. We ensure that they have a very 3 professional relationship with the staff , that they 4 are honored by the staff and listened to by the 5 staff, that they have the capability to measure our 6 not just compliance, but also our drive towards 7 excellence.

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

17 And then, it subsequently goes to escalate, if that 18 doesn't get solved, where, depending upon the 19 level, it can actually go all the way up to an 20 officer or a vice president to b e accountably 21 resolved. 22 And then, you roll into the whole 23 concept of corrective actions and the idea of being 24 able to -- it is not just a corrective action 25 12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 program; it is more of a program to ensure that you 1 have proper problem identification and real 2 reso lutions that solve not just the symptom of the 3 problem, but the actual do the hard work of 4 understanding the cause of the problem. And I 5 believe that is extremely important, something we 6 measure very closely for.

7 I believe that in any organization you 8 ha ve to have governance, proper governance, which 9 is the rules, the regulations, the traditions, the 10 meetings that we all interact with, so that you can 11 have proper oversight, so the oversight can come up 12 and measure how your governance is actually 13 operating and working. I believe in all those 14 concepts. 15 I also know that the folks I work with, 16 my boss, our Chief Executive Officer Dennis Koehl, 17 our Chief Nuclear Officer Tim Powell, also believe 18 very strongly in the Appendix B, in the 50.B 19 program. They believe very strongly in the 20 corrective action program and independent 21 oversight.

22 And having said all those words, in 23 conclusion, I would say plants/stations that 24 perform well, stations that perform with 25 13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 excellence, stations that, quite frankly, meet the 1 business plan needs of the owners and the 2 shareholders have that healthy respect. Plants 3 that don't, they don't meet those; they don't have 4 that performance and they don't meet those business 5 goals. So, it all ties together.

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

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

-on in 16 how things are working.

17 My shadow is that I believe very, very 18 strongly in the indepen dence of QA, its 19 independence and conclusion, its independence in 20 their messaging, but we work closely with them in 21 ensuring that that message is presented in a way 22 that can be readily understood and accepted by the 23 staff. 24 I spend time; I go down and talk to the 25 14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 folks -- they actually sit down the hall from me.

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

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

5 CHAIRMAN SKILLMAN: Dave, thank you.

6 Please proceed.

7 MR. RENCURREL: Okay. Thank you.

8 MR. MURRAY: My name is Michael Murray.

9 I'm the Regulatory Affairs Manager at South Texas 10 Project. 11 I have been in the industry for 41 12 years, started as an I&C tech at the Bruns wick 13 Plant. I have had 31 years at South Texas Project.

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

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

23 MR. GIBBS: Good morning. I'm Ron 24 Gibbs. My current position is the Manager, 25 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Operations, Shift Operations. I'm the Senior 1 License at the South Texas Project now.

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

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

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

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

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-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Thank you.

1 MR. BERG: Good morning. I'm Michael 2 Berg. I'm the Engineering Manager of Design and 3 Programs. 4 I have got 38 years in the nuclear 5 ind ustry, 34 years at South Texas Project. I was 6 one of the original engineering supervisors that 7 took over design control from the architect 8 engineer. 9 I have had various manager roles over 10 the past 25 years and I was the manager over the 11 STP initial license renewal application submitted.

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

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

17 South Texas Project Nuclear Opera ting 18 Company is the licensed holder for the station.

19 The station is actually owned by three different 20 companies, Energy Texas, which is an investment

-21 owned utility; the City Public Services, San 22 Antonio, which is owned by the municipality San 23 Antonio, Texas, and Austin Energy, which is owned 24 by the City of Austin. So, we are owned by one 25 17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 investor and two municipalities. To put our 1 generation in context, over 25 percent of the 2 carbon-free electric generation in the State of 3 Texas is produced at South Texa

s. 4 CHAIRMAN SKILLMAN: And you get no 5 credit for that whatsoever.

6 (Laughter.)

7 MR. RENCURREL: Yes, sir.

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

-pressure turbines. We have 15 replaced both reactor vessel heads in both units.

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

19 Looking forward, we have main 20 transformers done on one unit, but we are replacing 21 the main transformers in the other unit in the next 22 outage, and we are working through the replacement 23 of our feedwater heaters that show that there is an 24 ongoing investment in the major improvements of the 25 18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 plant. Also, as you can see there, the non

-welded 1 stress improvement process is being put in place, 2 and that is going to go down in 2017 and 2019. 3 The way our governance works is that we 4 have a business plan. And the way that the owners 5 commit to the long

-term safe operation of the 6 station is via that business plan. This business 7 plan is approved annually for the next five years' 8 spend. 9 And so, in a sense, what goes on is the 10 money is allocated or set aside for the next five 11 years' worth of capital investments. However, our 12 plant investment plan itself goes out 20 years 13 where we have levelized out and put in all the 14 capital improvements and all the capital necessary 15 to move forward.

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

24 With that, I would like to turn it over 25 19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to Ron Gibbs, our ops manager.

1 MR. GIBBS: Good. Thank you , Dave. 2 This morning I will be giving a brief 3 description of the South Texas Project site and 4 station design.

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

14 The large body of water here in the 15 center is our main cooling reservoir. Makeup from 16 our main cooling reservoir is the Colorado River 17 you can see here

-- that is the main source

-- and, 18 also, rainwater.

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

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

24 Makeup to this is from well water as a primary 25 20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 means of makeup and rainwater.

1 Just to the right here you can see our 2 switchyard. We have nine 345

-KV lines coming into 3 and out of the switchyard. And the units here are 4 in the center of the pictures. We have two 5 Westinghouse four

-loop PWRs, P ressurized Water 6 Reactors. Our thermal rate of power is 3853 7 megawatts thermal with a design output of 1250 8 megawatts electric.

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

-- 12 MR. G IBBS: Yes.

13 CHAIRMAN SKILLMAN:

-- compared with 14 brackish water?

15 MR. GIBBS: That's correct.

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

19 MR. GIBBS: Okay.

20 CHAIRMAN SKILLMAN:

Okay. 21 MR. GIBBS: Operators are licensed on 22 both units. So, we can operate either unit, and we 23 utilize common operating procedures.

24 Both containment structures are post

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-3701 (202) 234-4433 tensioned concrete cylinders with steel liner 1 plates, hemispherical tops, and flat bottoms. 2 Each unit has three independent safety 3 trains, including piping, valves, pumps, and diesel 4 generators, our emergency supply for emergency 5 power. And each unit has four safety

-related 6 auxiliary feedwater trains, three electric pumps, 7 and one steam

-driven pump.

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

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

12 MR. GIBBS: That's correct.

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

15 Is that what you've got down there?

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

18 CHAIRMAN SKILLMAN: That's 5

-6,000 19 acres, 10,000 acres, something like that?

20 MR. GIBBS: It itself, yes

. 21 CHAIRMAN SKILLMAN: Yes. Thank you.

22 Okay. Okay.

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

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-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Right.

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

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

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

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

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-3701 (202) 234-4433 will talk to later in the applic ation. 1 On the next slide, just a description 2 of the programs, of how they have rolled out. We 3 had 41 aging management programs, of which 33 of 4 them were existing programs and eight new ones. On 5 that slide you will see in GALL consistency we said 6 we were 90-percent consistent with the standard 7 notes alpha through echo of GALL Rev. 1. However, 8 with the enhancements of GALL Rev. 2, that 9 consistency with GALL Rev. 2 is 95 percent against 10 the standard notes. As just a reminder, on the 11 bottom there, reinforcem ent, we did get reviewed 12 against standard review plan for GALL Rev. 2 and 13 those requirements.

14 On the next page, STP's program's 15 consistency with the GALL is we were consistent 16 with GALL Rev.

-- the consistency table is against 17 GALL Rev. 1, but it is just an accounting 18 perspective. We had 21 aging management programs 19 that are consistent with GALL. We have 16 aging 20 management programs that are consistent with 21 exceptions, and we have four plant

-specific aging 22 management programs.

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

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-3701 (202) 234-4433 addition of the requirements of GALL Rev. 2 and the 1 lessons learned that we incorporated. The 2 remaining exceptions would be alternate methods of 3 managing the aging effects specifically for the 4 progr ams that we developed.

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

15 We have an implementation plan, a 16 schedule, and the budget that Dave mentioned to 17 complete these remaining open commitments prior to 18 their scheduled due dates in preparation for 19 entering the period of extended operation in 2027 20 and 2028. 21 CHAIRMAN SKILLMAN: Before you change 22 that slide, would you give us a little tutorial on 23 your i nspections? The Unit 1 refueling water 24 storage tank welds you had some leaking, outside 25 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 tanks? 1 MR. ALDRIDGE: Yes.

2 CHAIRMAN SKILLMAN: You repaired those.

3 MR. ALDRIDGE: Yes.

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

n. 11 Please tell us more about this.

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

13 We did have a plant

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

23 So, the concern for the aging effect of 24 internal stress corrosion cracking was not a 25 26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 concern. When we did our aging management program, 1 we were committed to performing a confirmatory that 2 the repairs, confirmed that they were effe ctive and 3 that there is no aging degradation going on on the 4 internal side of the tank. In addition, we, then, 5 every refueling outage, we look at the exterior of 6 the tank for external indications of cracking or 7 leakage. 8 CHAIRMAN SKILLMAN: What is your fu el 9 cycle length, please? Fuel cycle length?

10 MR. ALDRIDGE: Yes, 18 months.

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

13 MR. ALDRIDGE: Okay.

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

21 So, my question for you is, are you an 22 upflow or downflow plant? What has your experience 23 with the baffle bolts been? And what are you doing 24 to track the issue from an aging management 25 27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 perspective?

1 MR. BERG: I will go ahead and answer 2 that question. Certainly, we have been involved 3 with the EPRI Materials Reliability Project and 4 compliance with MRPG

-27. We are an upflow design, 5 and our baffle bolts are 3/16 material. So, when 6 you look at the susceptibility, we are in the 7 lowest susceptibility associated with that.

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

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

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

-- 16 MEMBER SUNSERI: So, you have it right?

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

18 MEMBER KIRCHNER: Dick, may I ask a 19 question? 20 CHAIRMAN SKILLMAN: Please.

21 MEMBER KIRCHNER: From this long list, 22 what are the long poles in the tent? Not all these 23 are equal in terms of effort and commitment and 24 difficulty. Could you just highlight those that 25 28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 are -- we know we have one more coming, but

-- 1 MR. ALDRIDGE: Right.

2 MEMBER KIRCHNER:

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

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

-plant inspections, 18 whether they are one

-time inspections or the 19 beginning of a periodic.

20 And then, from an analysis perspective, 21 we have already performed the screening on the 22 NUREG-6260 central locations. We just have to go 23 through and upgrade the program to continue to 24 monitor those new locations. So, that would be the 25 29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 main areas.

1 MEMBER KIRCHNER: Thank you.

2 CHAIRMAN SKILLMAN: Please proceed.

3 MR. ALDRIDGE: Thank you.

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

11 There are two processes that control those, and 12 they are being tracked for completion under those 13 programs. 14 All right. At this time, I would like 15 to transfer to Mike Berg.

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

20 The open item focuses on wells 21 themselves. But, prior to getting into the 22 specifics of the open item, I would just like to 23 give a brief overview of the selective leaching 24 process. So, from a high

-level background for 25 30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 selective leaching of our low

-pressure essential 1 cooling water system, which is commonly referred to 2 in the industry as service water system, as Ron 3 stated earlier, the material is aluminum bronze, 4 which is a copper aluminum alloy. Selective 5 leaching is a corrosion process where the aluminum 6 in the transformed phase can selectively leach out 7 when you have aluminum that is greater than 8 8 percent and exposed to wetted surfaces. Selective 9 leaching of aluminum leaves micro

-voids along the 10 grain boundaries and, when progressed through a 11 wall, leakage/seepage will become visible on the 12 outside surface of the material.

13 So now, I would like to refer to the 14 slide here. So, what we are looking at here, this 15 is a section of pipe. We have a weld and, then, we 16 have got a weld

-neck flange. So, the piping itself 17 -- there we go

-- the piping itself is made out of 18 wrought material. It has less than 8

-percent 19 aluminum, and we have not seen, nor is it 20 vulnerable to, selective leaching.

21 I want to talk about the casting

-- 22 MEMBER KIRCHNER: Just for perspective 23 -- 24 MR. BERG: Yes.

25 31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER KIRCHNER:

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

3 I can see nuts on the side. So, it looks like it 4 is now 4-inch or -- 5 MR. BERG: I'm thinking it is 4

- or 6-6 inch diameter pipe that we are looking at here. 7 So, let's talk about the casting 8 materials themselves. They are susceptible to the 9 alloying. We first saw the alloying or cast 10 materials on our small

-bore piping back in 1988.

11 All of those were replaced.

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

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

23 Just over a period of time, on these 24 large-bore castings we were somewh ere between five 25 32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 or ten first initial startup. Over the years, we 1 currently run somewhere between zero or two of 2 these per year, is what we see.

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

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

9 CHAIRMAN SKILLMAN: Okay.

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

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

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

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

24 MEMBER KIRCHNER: Have you cut any of 25 33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 these castings out and done an evaluation?

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

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

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

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

16 MR. BERG: We will go with, if we stay 17 with aluminum bronze material, then we will have 18 material probably a wrought

-type material that has 19 less tha n 8-percent aluminum.

20 MEMBER BALLINGER: Yes, wrought 21 material, it is a two

-phase thing where they get 22 something called the gamma

-2 phase which is rich in 23 aluminum. It is like dezincification.

24 MR. BERG: Right.

25 34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER BALLINGER: So, you get 1 electrochemic al cell buildup and you selectively 2 leach out the aluminum. It is like 3 dezincification. And so, you end up with sort of 4 like a porous structure.

5 MR. BERG: Right.

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

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

15 MEMBER KIRCHNER: With the current 16 material? 17 MEMBER BALLINGER: With the cast 18 material. 19 MEMBER KIRCHNER: With the casting?

20 MEMBER BALLINGER: With the cast 21 material. 22 MEMBER KIRCHNER: Right. And what is 23 th e differential with the wrought?

24 MEMBER BALLINGER: You get rid of this 25 35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 gamma phase. And so, you don't have the same kind 1 of problem at all for de

-aluminization. So, 2 wrought materials are generally not susceptible to 3 the material. And if you are less th an -- you said 4 8 or 9 percent

-- 5 MR. BERG: Yes, 8 percent.

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

9 MEMBER KIRCHNER: Yes. Thank you.

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

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

13 So, with the welds, we have seen

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

24 So, we have seen 10 welds with 25 36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 cracking. The cracking has some de

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

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

? 9 MR. BERG: We would cut it out and 10 replace it. When we talk about the open item, 11 there are 10 issues associated with that. When I 12 go through that, I will talk about the specifics we 13 do on how do we do the inspection, acceptance 14 criteria, and then, we will talk about corrective 15 actions. 16 MEMBER RICCARDELLA: So, is a 17 significant percentage of this piping underground?

18 MR. BERG: Not percentage

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

23 MEMBER SUNSERI: So, maybe you are 24 going to talk about this when you get to the 25 37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 inspections, but is there an NDE technique for this 1 or? 2 MR. BERG: This really gets into our 3 corrective action. But we have been working over 4 the last few years with an NDE technique. So, 5 obviously, if it is a cracking

-type phenomena that 6 is occurring, ultrasonic NDE will detect that 7 condition.

8 MEMBER SUNSERI: And are you doing i t 9 any? 10 MR. BERG: So, we would do it if we 11 found a condition where we were seeing cracks at 12 the surface type of thing. Then, we would follow 13 the code requirements and we would have to go 14 characterize that, and we would go do an NDE 15 inspection.

16 MEMBER SUNS ERI: Okay. Because I 17 thought I heard you say you see the misting and all 18 that stuff. So, I mean, it is a safety

-related 19 system. I guess that puts you in a tech

-spec 20 action statement.

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

-- 23 MEMBER SUNSERI: The active mode 24 versus -- 25 38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. BERG: It would be an operability 1 determination associated with that, which Ron would 2 request, and we would go do the characterizations 3 in accordance with code.

4 And we are going to talk a little bit 5 later on, the proactive piece is prior to the 6 period of extended operation. I will just get to 7 it briefly now. It is that we will do an 8 inspection of

-- I'm going to get this wrong

-- 20 9 percent with 25 welds with backing rings and 10 without backing rings prior to the period of 11 extended operation. We will actually go in and 12 come apart and look at it.

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

20 MEMBER SUNSERI: Okay.

21 CHAIRMAN SKILLMAN: Mike, let me ask 22 this: from the inspection report, the 71002 23 inspection report, the comment is, "The team noted 24 the experience regarding the loss of material 25 39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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

-3701 (202) 234-4433 caused by selective leaching in aluminum bronze 1 components in the essential service water system is 2 an ongoing aging mechanism." That is from the 3 71002 inspection.

4 MR. BERG: Yes.

5 C HAIRMAN SKILLMAN: The text appears to 6 point only to the essential service water system.

7 Is th is phenomenon anywhere else in any other 8 systems? 9 MR. BERG: The answer to that is no 10 because we only use aluminum bronze in our 11 essential -- 12 CHAIRMAN SKILLMAN:

Let me ask you one 13 more. Your cathodic protection system is not in 14 scope. At least it isn't in the document that I 15 read. What connection have you made between this 16 phenomenon and the inoperability of your cathodic 17 protection system for what appears to be 10 to 15 18 years? 19 MR. BERG: Do you want to answer from 20 the TLA perspective?

21 MR. ALDRIDGE: Yes. Yes, sir. Let me 22 answer from the perspective of the cathodic 23 protection. The piping at South Texas is 24 cathodically protected as part of the buried piping 25 40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 aging management program, and aluminum bronze is 1 one of the systems that is protected by the 2 cathodic protection.

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

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

-- 11 MEMBER STETKAR: Let's get specific.

12 What has the historic availability over the life 13 of the plant of your cathodic protection system 14 been? 15 MR. ALDRIDGE: Thank you, sir. We have 16 the subject matter expert present, and he can give 17 you the numbers.

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

20 MR. KHONDKER: My name is

-- can you 21 hear me? 22 CHAIRMAN SKILLMAN: Yes.

23 MR. KHONDKER: Okay. So, my name is 24 Raihan Khondker. I am the Cathodic Protection 25 41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 System Engineer at South Texas.

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

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

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

19 MEMBER STETKAR: I'm not sure that I 20 got a straight answer to my question. Over the 21 life of the plant, I would like to know what the 22 historic percentage availability has been if I take 23 the time up divided by the total time the plant has 24 been operating as a percentage. You have told me 25 42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 that you had corrective action programs and things 1 were out of service for a long time. But what is 2 the average historical availability over the life 3 of the plant?

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

6 MEMBER STETKAR: Great. Thank you.

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

9 MEMBER STETKAR: Thanks.

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

12 MEMBER STETKAR: Okay. Thanks.

13 MEMBER RICCARDELLA: Does cathodic 14 protection have any influence on this selective 15 leaching p rocess? 16 MR. BERG: The answer is, no, it does 17 not, but our very piping is coated and it is 18 protected from that standpoint.

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

-protected area.

23 MEMBER BALLINGER: It is very difficult 24 to use cathodic protection for this problem, yes, 25 43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 because it is a very local system.

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

7 And again, our focus on our open item 8 is associ ated with welds or weld repairs with 9 susceptible weld filler material. It will be 10 managed. That includes piping butt

-welds and, 11 also, weld preparers on extruded tees.

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

14 MR. BERG: Per the site.

15 MEMBER STETKAR: Thanks.

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

20 So, you have had that problem?

21 MR. BERG:

Yes. 22 MEMBER BALLINGER: But, with the 23 welding, how are you going to get around the 24 problem with welding? Because you still have the 25 44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 solidification issue. Are you going to post

-weld 1 heat-treat? What are you going to do to get rid of 2 that problem?

3 MR. BE RG: Okay. So, we will talk 4 about that when we go through the open issue, but 5 it is really with the one

-time inspections and with 6 the periodic inspection, particularly the welds 7 with the backing rings.

8 What we do to address that is we would 9 use a weld fil ler material with nickel in it.

10 MEMBER BALLINGER: Yes, okay.

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

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

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

20 Just to talk a little, we do have a 21 comprehensive aging management program that 22 addresses selective leaching. That program 23 includes inspections of walkdowns, replacements 24 prior to the period of extended operation. Then, I 25 45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 am going to talk specifically associated with the 1 welds. It includes one

-time volumetric exams, 2 periodic volumetric examination, defines acceptance 3 criteria, and has additional testing elements in 4 it. 5 The specific open item is related to 6 welds, and the Safety Evaluation Report does 7 contain 10 specific issues, which I will discuss 8 further on the following three slides.

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

13 But, in this year, you put together a 14 fully-revised, well, I will call it a fully

-revised 15 program because there were many issues associ ated 16 with Rev. 1 of the program. And now, this Rev. 2 17 program was submitted to the staff in June of this 18 year. 19 And my question is general, in that, 20 once that was submitted, then there were many 21 questions from the staff related to the new and 22 revised program. So, my general question is, why 23 did that happen? You had a lot of experience with 24 the program moving forward. You had the 25 46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 opportunity or made the choice to put in a fully

-1 developed to address a number of concerns that the 2 staff had had over the year s really. And yet, 3 there were a number of issues that were not, if you 4 will, fully addressed in the new program where you 5 had the opportunity to really set yourself up for 6 full success. And yet, there has been a number of 7 issues in many different areas that the staff found 8 needed additional attention. So, my question is 9 that: why did that happen? Can you give me some 10 perspective on that or give us some perspective on 11 that? 12 MR. BERG: So, there are several phases 13 that I think we have gone through here.

First, our 14 first focus was on the casting

-type material. I 15 said before we have got about 400 to 450 of those.

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

21 Our real focus was on the casting

-type 22 area. We did a lot of research, testing, did bin 23 testing and strength tied to the de

-alloying of our 24 casting materials. Lots of correspondence and 25 47 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 interaction took place between us and the Nuclear 1 Regulatory Commission, and we just ended up in the 2 point of all of that to go to that reasonable 3 assurance to the level that was expected for that; 4 that the easiest answer to that was just to go 5 ahead and replace the castings. And we were doing 6 selective replacements just to do testing anyway.

7 So, that was a change in the program.

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

10 Again, that assurance that, from a welding 11 standpoint, that we would not expect to see any 12 cracks in the future or, even more important, that 13 we don't see anything that would impact the 14 structural integrity of our essential cooling water 15 system. 16 We think we have had that, but there 17 were a series of questions that we had to go 18 through to answer and to come up with some 19 additional research or evaluation of the welding 20 itself just to demonstrate that.

21 DR. SCHULTZ: So, as you revamped the 22 program, you really went broader in terms of those 23 specific areas that you determined you needed to 24 address? So, the scope of the program grew 25 48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 dramatically

-- 1 MR. BERG: Correct.

2 DR. SCHULTZ:

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

7 MR. BERG: That is correct.

8 DR. SCHULTZ: Thank you.

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

11 So, the first one

-- and I am going to do this at a 12 high level

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

24 No. 2 is clarify the parameters 25 49 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 monitored to address. First is loss of material 1 due to selective leaching, which is monitored 2 through our system walkdowns and destructive 3 examinations. Crackin g associated with selective 4 leaching is monitored through volumetric 5 examination of destructive evaluation. And the 6 third area is our root passes phase distribution is 7 verified to be discontinuous phase during our 8 destructive inspections.

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

19 Four, clarify the thresh

-- 20 MEMBER RICCARDELLA: E xcuse me. Is 21 that different weld, a different 25 percent for the 22 initial inspection versus the subsequent, the 23 periodic? 24 MR. BERG: An answer would be yes to 25 50 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 that because, when we do the destructive 1 examination, we will

-- 2 MEMBER RICCARDELLA: Oh, it is a 3 destructive?

4 MR. BERG: It is a destructive

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

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

10 MEMBER RICCARDELLA: Okay. And you 11 said there is only about 100 of these welds out 12 there? 13 MR. BERG: There is actually about 3300 14 welds in the plant.

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

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

21 So, we have got about 3300 welds total.

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

24 Sir, did you get your question 25 51 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 answered? 1 M EMBER RICCARDELLA: I thought I heard 2 you say a one

-time inspection of 20 percent which 3 is about 25 welds. And I don't understand how that 4 fits with 3300 welds total.

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

7 MEMBER RICCARDELLA: Oh, oh, oh, oh.

8 Okay. Yes.

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

11 MEMBER RICCARDELLA: Okay. All right.

12 All right.

13 MEMBER BALLINGER: Is that a rational 14 choice? 15 (Laughter.)

16 I mean, I can un derstand sticking with 17 the letter of the law, okay, but you have a known 18 issue which you think you are going to have solved, 19 which you might have. And so, to just arbitrarily 20 say we're just going to do 25 and get it over with 21 and move on just doesn't seem to me -- I mean, is 22 there a way, is there some kind of rapid expansion 23 that would occur if you see an issue that is also 24 different from the GALL requirements? You know, 25 52 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 this is a unique set of cases, I think.

1 MR. BERG: So, that does get into the 2 next i tem here. Okay? So, let me try to answer 3 your question a little bit more basic to start 4 with. 5 So, again, this condition, we have not 6 seen any crack in the welding since 1994. We have 7 done some research and testing that we believe that 8 we understand why that is the case. We do believe 9 it is a preexisting flaw that seems to be there.

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

21 If we do find one that doesn't meet the 22 criteria, we would go back to the Generic Letter 23 90-05 criteria. And for every one that we would 24 find that doesn't meet our predictions, we would 25 53 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 increase that sample size by five until we had no 1 welds that had issues on them. So, we will follow 2 the Generic Letter

-- 3 MEMBER BALLINGER: By five or a factor 4 of five? 5 MR. BERG: By five.

6 MEMBER BALLINGER: By five.

7 MEMBER RICCARDELL A: How are the 25 8 samples selected?

9 MR. BERG: Okay. So, that is No. 5 on 10 the bottom of the page, and those will be randomly 11 selected from the total population of above

-ground 12 welds, considering construction and size 13 distributions. We will use ASME Code criteria to 14 do that. 15 MEMBER BALLINGER: Okay. Randomly 16 selection, with this kind of phenomenon, can't you 17 get a little bit less random? Because when you do 18 welding and stuff like that, you can record heat 19 input and all those kinds of things. So, is the re 20 another set of criteria which you can overlay on 21 this that says we'll do this random 22 characterization, but this particular weld and this 23 particular weld, in our judgment, may be a little 24 bit more susceptible? Can you modify the 25 54 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 randomness a little bit?

1 MR. BERG: I don't know.

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

-- 4 MR. BERG: Yes. I mean

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

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

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

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

-- 24 MEMBER BALLINGER: But nickel aluminum 25 55 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 bronze weld material is going to be better, much 1 better. 2 MR. BERG: Absolutely.

3 MEMBER BALLINGER: But right at the 4 interface between the weld and the heat

-affected 5 zone there is going to be a wrought material which 6 is not going to be wrought anymore.

7 MR. BERG: Yes.

8 MEMBER BALLINGER: It is going to be at 9 the me lting point and, then, it is going to be 10 requenched. And so, I am wondering whether or not 11 the welds will be fine, but right, you know, 12 adjacent to the weld where that thermal transient 13 has happened, you don't get gamma phase in the 14 piping itself and now get yourself in an issue 15 there. 16 MR. BERG: So, again, you start off 17 with less than 8 percent. So, if you look at the 18 phase diagram for the wrought material, you know, 19 being less than 8 percent, you would not expect to 20 go through a transformed region.

21 MEMB ER BALLINGER: I agree.

22 MR. BERG: And

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

25 56 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. BERG: Right.

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

5 MR. BERG: Okay.

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

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

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

-- 16 MEMBER BALLINGER: Okay.

17 MR. BERG:

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

-2 phase, you are at the beta phase.

24 ME MBER BALLINGER: Okay. I'm just 25 57 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 saying usually

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

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

6 MR. BERG: Yes.

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

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

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

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

17 MEMBER RICCARDELLA: Yes.

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

23 MEMBER RICCARDELLA: And it was in the 24 weld, not in the heat

-affected zone?

25 58 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. BERG: In the weld, correct.

1 MEMBER RICCARDELLA: Okay.

2 MEMBER BALLINGER: But do n't you have 3 two issues, cracking and de

-aluminization?

4 MR. BERG: Yes.

5 MEMBER BALLINGER: So, I'm talking 6 about the de

-aluminization part, not the cracking 7 part. 8 MR. BERG: So, the de

-- I will try to 9 get there.

10 MEMBER BALLINGER: It is too many 11 syllable s. 12 (Laughter.)

13 MR. BERG: Yes. So, the de

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

-- 17 MEMBER BALLINGER: Okay.

18 MR. BERG:

-- flaws or anything else.

19 When we get into the welds, we do see 20 some de-alloying in the weld surfaces, but 21 everything is telling us it is due to that 22 preexisting flaw. Probably just created an 23 environment because of the type crack and the 24 aqueous condition in there, it has created an 25 59 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 e nvironment that did allow anything in the 1 transformed region to show that de

-alloying 2 occurred, maybe weakened the material a little bit, 3 and then, allowed cracking and, then, de

-alloying 4 and cracking as it propagates through. We don't 5 really know that for a fact, but what we do know is 6 all of our OE tells us there had to be a 7 preexisting flaw there for this condition to occur.

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

12 MR. BERG: That is correct.

13 MEMBER RICCARDELLA: Thank you.

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

21 MR. BERG: That is correct.

22 CHAIRMAN SKILLMAN: And with that , I 23 believe we

-- 24 MEMBER STETKAR: Hold on.

25 60 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Go ahead, John.

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

4 CHAIRMAN SKILLMAN: No, no.

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

9 In many other of these programs that we 10 have seen, not this particular one, throughout the 11 course of license renewal, where you do have a 12 large population to se lect from, people establish 13 what they call a risk

-informed sampling program.

14 And I don't want to get into the nuances of risk, 15 but they look at places where they would be more 16 likely to find a problem, whether that is a fatigue 17 issue or whether it is crac king of small

-bore 18 piping welds, or whatever, and then, sample from 19 those locations.

20 So, I'm asking you, given what we have 21 heard here, is there a more, I'll call it risk

-22 informed approach that could be used, rather than 23 just randomly selecting 25 out of 3300, in your 24 opinion? 25 61 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER BALLINGER: See, I am not a risk 1 guy. So, I hesitate to use the word "risk," but I 2 will use it anyway.

3 That is what I was trying to get at.

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

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

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

21 MR. BERG: Correct.

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

25 62 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. BERG: Correct.

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

3 MEMBER STETKAR: Okay. Thanks.

4 MEMBER BALLINGER: Thanks.

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

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

-- 15 MEMBER RICCARDELLA: Yes, yes.

16 MEMBER STETKAR:

-- because they wrote 17 the guidance and they are following the guidance.

18 MEMBER RICCARDELLA: Right.

19 Understood, yes.

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

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

24 MR. BERG: Okay. Item No. 6, we did 25 63 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 determine that there was no impact of the external 1 coatings regarding detecting buried piping leaks at 2 the surface.

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

5 I would like to focus a little bit more 6 on Item No. 8, define the acceptance criteria for 7 the weld defects. For visual exams, the acceptance 8 criteria is no detectable leakage. For volumetric 9 examination, it would be no detected twiner 10 indication that is subsurface

-connected unless the 11 depth of the indication is contained within the 80 12 percent of the weld root pass. And for destructive 13 examinat ions, no selective leaching penetrating 80 14 percent of the root pass region, and any found 15 selective leaching is non

-propagating. So, it is 16 surrounded by a non

-continuous resistant phase 17 distribution.

18 And then, the microstructure of the 19 weld root region wi ll exhibit a non

-continuous 20 phase distribution, which is consistent with all of 21 our metallurgical evaluation or metallurgical 22 reports that we have done so far. So, we see a 23 non-continuous phase distribution. So, if you had 24 a little localized de

-alloying, it is not going to 25 64 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 have any depth associated with that, being a non

-1 continuous.

2 Item No. 9, identify the threshold for 3 increased inspections when adverse inspection 4 results are detected. We talked about that a 5 little bit earlier. That is tied back to Ge neric 6 Letter 90-05. 7 And the last item is to identify the 8 corrective actions to address all potential 9 inspection results. We will remove any leaking 10 welds and destructively exam to determine the 11 extent of the cracks, the extent of the selective 12 leaching, and the microstructure phase 13 distribution, perform five additional volumetric 14 exams, and perform a structural integrity 15 evaluation to confirm the load

-carrying capacity.

16 Move on to the next slide. So, this 17 brings us into one remaining open issue associate d 18 with the corrective actions. This remaining issue 19 concerns how to address the extended condition in 20 the unlikely condition that structural integrity 21 evaluation does not support the load

-carrying 22 capability or capacity.

23 A method and acceptance criteria t o 24 bound the extended condition is being defined. We 25 65 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 have had some initial communications with the NRC 1 staff, and we do feel comfortable that we can 2 address that concern, and it does support a pathway 3 forward and timely response and resolution.

4 DR. SCHULTZ

Mike -- 5 MR. BERG: Yes?

6 DR. SCHULTZ:

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

15 MR. BERG: Yes, an additional question 16 is what we are working with the staff on to 17 add ress. 18 DR. SCHULTZ: Okay.

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

-- 21 DR. SCHULTZ: On Item No. 10?

22 MR. BERG:

-- item, yes.

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

-- 25 66 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 DR. SCH ULTZ: Okay.

1 MR. MURRAY:

-- with the understanding 2 of the strategy.

3 DR. SCHULTZ: Thank you.

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

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

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

13 (Laughter.)

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

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

18 MEMBER KIRCHNER: Sure.

19 MR. BERG: I would say I am really 20 giving you kind of an estimate, just based on where 21 our essential cooling water intake structure is to 22 our Class 1E structures

-- you can choose a little 23 bit further away

-- so, I would say about 3,000 24 foot underground would be my estimate associated 25 67 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 with that.

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

-ground 5 equipment?

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

9 MEMBER KIRCHNER: Okay. Thank you.

10 Thank you.

11 MEMBER RICCARDELLA: But, then, above 12 grou nd -- there's 3,000 feet below underground

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

17 MR. BERG: Yes, there's several 18 thousand feet.

We have 30

-inch pipe; we have 4

-19 inch pipe, 10

-inch pipe through the plant. I'm 20 thinking in the several thousands, 13,000

-ish. 21 Kevin or Rick?

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

24 Buried underground piping, be tween the 25 68 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 two units, supply and return, is just over 24,000 1 feet. 2 MEMBER RICCARDELLA: Buried? Buried?

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

5 MR. STARK: That is correct. That is 6 all essential cooling water piping. There is 6

-7 inch, 10-in ch, and 30

-inch. 8 MR. BERG: I was off by a factor of 9 eight. 10 Thanks, Rick. Thank you.

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

17 MR. BERG: Right.

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

24 MR. BERG: A metallurgy examination.

25 69 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER SUNSERI: So, essentially, you 1 are replacing 25 every inspection period then, 2 right? 3 MR. BERG: That is corre ct. 4 MEMBER SUNSERI: Okay. Thank you.

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

12 MEMBER BALLINGER: Can I get one thing?

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

16 MR. BERG: That is correct.

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

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

24 MEMBER BALLINGER: Okay. So, you would 25 70 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 replace the castings?

1 MR. BERG: And when we replace that 2 weld, we will use the nickel

-based material. So, 3 it won't be vulnerable to it.

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

10 MR. BERG: For the underground? So, 11 the underground piping is only wrought material 12 already. That is what exists now. So, we will use 13 -- so, from a stress standpoint, the above

-ground 14 welds are higher

-stress conditions; they are mor e 15 vulnerable

-- so, we will use our operating 16 experience from the above

-ground welds for any 17 decisions associated with expansion of scope. And 18 this really ties back in the corrective action, 19 depending on what we see.

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

24 Our aging management program will demonstrate that.

25 71 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER BALLINGER: Thank you.

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

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

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

16 MR. ALDRIDGE: Arden Aldridge.

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

-- 19 CHAIRMAN SKILLMAN: Please do.

20 MR. ALDRIDGE:

-- who can provide some 21 clari fication. 22 CHAIRMAN SKILLMAN: Okay.

23 MR. WARNER: Yes, my name is Gary 24 Warner. I'm the Senior Project Manager for License 25 72 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Renewal. 1 Cathodic protection is not in the scope 2 of license renewal because it is not one of those 3 systems that performs an intended function for 4 license renewal. It is a support system that is 5 used to allow you to protect your buried piping.

6 But, in the absence of cathodic protection, you are 7 required to inspect a lot more buried piping than 8 you would if you have adequate cathodic pr otection. 9 So, based on the other plants in the 10 country plus the way the rule is written, cathodic 11 protection does not perform a license

-renewal-12 intended function.

13 CHAIRMAN SKILLMAN: Thank you for that 14 explanation.

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

22 MR. ALDRIDGE: Yes, sir.

23 CHAIRMAN SKILLMAN: Another question

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-3701 (202) 234-4433 you a followup on the operating experience of the 1 cathodic protection system?

2 CHAIRMAN SKILLMAN: That's correct, as 3 a p ercentage of time, yes.

4 On your license renewal application, 5 page 112, the statement is

-- it is actually 6 2.3-27, but it is on PDF page 112

-- "The essential 7 cooling pond is included with the evaluation of the 8 essential cooling water structures in Section 9 2.4.9." Please tell us about the actions that you 10 have taken to confirm that the pond is good for 11 your projected PEO.

12 MR. ALDRIDGE: Arden Aldridge.

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

18 CHAIRMAN SKILLMAN: Please do.

19 MR. ALDRIDGE: Okay. Mark Wales.

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

22 The pond, it is an underground pond.

23 That is the first thing you need to understand.

24 And it is surrounded by a berm which keeps debris 25 74 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 out of the pond. But, as far as maintenance of the 1 pond, there's not really any maintenance that is 2 required. We do period ically inspect it and use 3 biocides to prevent things from growing in it and 4 in the concrete, and we inspect it as part of the 5 structures monitoring program periodically. But, 6 other than that, there is no specific maintenance.

7 CHAIRMAN SKILLMAN: Now you s tated it 8 is underground. Is it really a surface pond or an 9 underground pond?

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

13 CHAIRMAN SKILLMAN: Okay.

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

21 So, it is managed there from that perspective.

22 CHAIRMAN SKILLMAN: Okay. Thank you.

23 Let me bring your attention to page 9

-24 12 in your license renewal application. This is 25 75 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 under TLAAs. The subject is your studs, nu ts, 1 flanges. But, in this particular section, you are 2 silent on inserts. And the table that you show 3 shows inserts with cumulative usage factor greater 4 than one. So, do you have someone here who can 5 explain the relationship between studs, nuts, 6 flanges, and inserts? I understand the CUF for the 7 studs, nuts, and flanges, but I do not understand 8 CUF greater than one for inserts.

9 MR. LYNCH: My name is Bret Lynch. I 10 worked on the time

-limiting aging analyses.

11 For standard practice, when we were 12 developing the South Texas application, we took a 13 40-year CUF, Cumulative Usage Factor, and 14 multiplied it by 1.5 to get an estimate of what the 15 CUF would be. On that criteria, we decided either 16 the current CUF was projected to the end of the 17 period of extended oper ation, which was one of the 18 disposition criterias. If it was over one in this 19 case, we would have to justify managing the usage 20 factor to ensure that the 40

-year one would be good 21 for 60 years. So, we were keeping the same number, 22 the design transients, from 40 years for 60 years.

23 CHAIRMAN SKILLMAN: Okay. Now hold 24 that thought. That suggests in this case, and in 25 76 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 other texts in your application, your TLAA depends 1 upon your cycle

-counting program.

2 MR. LYNCH: That is correct.

3 CHAIRMAN SKILLMAN: Okay. What is the 4 pedigree of that cycle

-counting program and how 5 does the plant manage that program? What is the 6 pedigree and how do you manage it?

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

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

12 Really, it is procedurally

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

16 CHAIRMAN SKILLMAN: Okay. Thank you.

17 Let me see if I have any more here.

18 (Pause.) 19 I'll ask my colleagues, any comments 20 for the Applicant relative to this matter?

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

25 77 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Inaccessible underground cables, I 1 understand and I read back in 2011

-2012, as the 2 program was evolving, there were a lot of RAIs. I 3 understand that your program is now consistent w ith 4 GALL Rev. 2, is that correct?

5 MR. ALDRIDGE: That is correct.

6 MEMBER STETKAR: Okay. Thank you.

7 I noticed that, as I read through 8 things, you have manholes that have solar

-powered 9 sump pumps in them. And as best I can tell, you 10 have committed to what is in GALL Rev. 2, which is 11 an annual inspection of manholes or I would 12 categorize it as an episodic inspection if you 13 have, you know, a typical

-- I used to do 14 consulting work down at South Texas and they used 15 to call them South Texas frog floaters.

16 (Lau ghter.) 17 So, you had a particularly heavy rain.

18 As best as I can tell, it is says that, 19 if an inspection determines that a sump pump is 20 inoperable, you will put it into your corrective 21 action program and fix it. Are those sump pumps 22 alarmed? I mean, is th ere a better indication of 23 whether they are operating or inoperable than just 24 simply finding that there is water in the manhole 25 78 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 and the sump pump wasn't working?

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

3 MEMBER STETKAR: Okay.

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

8 MEMBER STETKAR: Okay.

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

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

14 MR. ALDRIDGE: Correct.

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

-- 17 MR. ALDRIDGE: Yes.

18 MEMBER STETKAR:

-- and groundwater 19 intrusion is pretty pervasive.

20 MR. ALD RIDGE: Right.

21 MEMBER STETKAR: So, I was curious.

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

24 MR. KHONDKER: My name is Raihan 25 79 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Khondker. I'm the cable program owner at South 1 Texas Project.

2 The question is regarding the su mp 3 pumps in our manholes at STP and what we are doing 4 about it. At present, we have solar pumps designed 5 in all the manholes where we have seen water 6 submergence issues. The solar pump design that we 7 have, we have been maintaining them through our 8 prevent ive maintenance program. We have, depending 9 on what kind of manhole it is and how often, we 10 have seen the trend showing how often the 11 groundwater incurs. We have frequencies from four 12 weeks all the way to annually, depending on which 13 manhole it is, and w e go in and inspect the pumps 14 on them. 15 And if we see that a float switch or a 16 pump or any of the control mechanisms are not 17 working, we replace it as a part of the PM. I will 18 say, if there is any water at the floor level, we 19 pump it out.

20 At present, also, what we are doing as 21 a corrective action is that we have redesigned all 22 our pumps. We have a new approved design change 23 package which is allowing me to go and replace all 24 the pumps we have. We are putting higher

-duty 25 80 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 pumps. Like we have in the higher o nes we are 1 putting 2,000 gallons per hour. In some of them we 2 are putting 1500 gallons per hour, and some of them 3 are below 1,00 gallons per hour.

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

8 MEMBER STETKAR: Good. That is 9 encouraging.

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

-- 12 MEMBER STETKAR: Ninety

-six, wow. 13 MR. KHONDKER: Nin ety-six solar pumps 14 are going in manholes because we have 155 manholes, 15 and out of them, 96 have seen historic

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

-- 18 MR. KHONDKER: Yes.

19 MEMBER STETKAR:

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

22 MR. KHONDKER: No, they are not all in 23 scope. 24 MEMBER STETKAR: Yes.

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-3701 (202) 234-4433 MR. KHONDKER: It is a combination 1 because we are looking at manholes, so we look at 2 them all as similar, yes.

3 MEMBER STETKAR: Sure, sure , sure, 4 sure. 5 MR. KHONDKER: Not just in scope, no.

6 MEMBER STETKAR: Great. Thank you.

7 MR. KHONDKER: No problem, sir.

8 MR. MURRAY: This is Mike Murray.

9 I do want to point out that you talked 10 about the frog floaters. We have also improved the 11 sealing, the external sealing of those manholes as 12 well. 13 MEMBER STETKAR: Yes, I have read some 14 of the operating experience. Thank you.

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

17 MEMBER RICCARDELLA: Yes, you indicate 18 you have your plant

-specific program for nickel 19 alloys. As I recall, South Texas is somewhat 20 unique in having had a cracking of the bottom head 21 instrument nozzles. Is that part of your plant

-22 specific program or is there anything special you 23 are doing on that top ic? 24 MR. ALDRIDGE: Mike Garner, do you have 25 82 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 a specific on the nickel alloy program, on the 1 scope? Is that what it is for?

2 MR. ALDRIDGE: In regards to VMI, 3 right? 4 MEMBER RICCARDELLA: Yes, yes.

5 MR. GARNER: Are you referring to VMI?

6 MEMBER RICCARDELLA: U h-hum. 7 CHAIRMAN SKILLMAN: Please identify 8 yourself. 9 MR. GARNER: My name is Michael Garner.

10 I'm the Site Metallurgist for STP.

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

19 MEMBER RICCARDELLA: Okay. Thank you.

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

22 (No response.)

23 Dave, to you, please, sir?

24 MR. RENCURREL: Thank you very much, 25 83 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 and we would like to thank the ACRS for your 1 questioning.

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

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

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

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

18 With that, ladies and gentlemen, we 19 will take a 16

-minute break and we will resume at 20 quarter after 10:00 on that clock.

21 We are i n recess. 22 (Whereupon, the foregoing matter went 23 off the record at 9:57 a.m. and went back on the 24 record at 10:15 a.m.)

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-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Ladies and 1 gentlemen, we are back in session.

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

5 (Laughter.)

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

10 Als o, Greg Pick, are you there, please?

11 MR. PICK: Yes, I am.

12 CHAIRMAN SKILLMAN: Thank you.

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

15 With that, let's begin. Lois, to you, 16 please. 17 MS. JAMES: Thank you.

18 Good mornin g, Chairman Skillman and 19 Members of the License Renewal Subcommittee.

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

23 We are here today to discuss the review 24 of the STP license renewal application, or LRA, as 25 85 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 documented in the Safety Evaluation Report with 1 open items which was issued in October.

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

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

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

20 Next slide, please. STP Nuclear 21 Operating Company, or Applicant , submitted an 22 application for the renewal of STP Units 1 and 2 23 operating licenses for an additional 20 years. The 24 staff conducted onsite audits, offsite audits here 25 86 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 in Maryland, and onsite inspections. As you can 1 see, the staff performed additional audits of the 2 open item for selective leaching of aluminum 3 bronze, AMP.

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

9 The scoping and screening methodology audit results 10 were documented in a report dated September 6th, 11 2011. 12 During the AMP audit, the team examined 13 the Applicant's aging management programs and 14 related documentation to verify that the 15 Applicant's programs are consistent with those 16 described in the GALL Report and with the plant 17 conditions and operating experience. The staff 18 reviewed the initial 40 AMPs and documented the 19 results in a report dated September 22nd, 2011.

20 I n January of 2016, the Applicant 21 informed the staff of significant changes to the 22 Aluminum Bronze Selective Leaching AMP. These 23 changes redirected the staff's review such that the 24 topic-specific audits conducted in 2012 and 2015 25 87 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 were no longer applicable.

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

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

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

16 Next slide, please. The staff 17 performed its review of the STP LRA and documented 18 its results in two Safety Evaluation Reports with 19 open items. In February of 2013, the staff issued 20 an SER with four open items. We did not come to an 21 ACRS meeting because the staff continued its review 22 of the selective leaching of the Aging Aluminum 23 Bronze AMP. We were unce rtain about where the 24 review was going and we thought it was premature to 25 88 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 come to the ACRS at that time.

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

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

12 Mr. Pick. 13 MR. PICK: Thank you, Lois.

14 Good morning, Members of the 15 Subcommittee.

16 CHAIRMAN SKILLMAN: Good morning, Greg.

17 We can hear you loudly and clearly.

18 MR. PICK: Thank you.

19 So, in our inspection we verif ied that 20 STP had properly identified those structures, 21 systems, and components included in scope and made 22 appropriate determinations of non

-safety-related 23 systems and components affecting safety

-related 24 components.

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-3701 (202) 234-4433 STP had established adequate programs 1 to manage aging of in

-scope structures systems and 2 components, as specified in our regulations and 3 their Applicant's license renewal program.

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

9 During our two

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

17 These walkdowns enabled us to assess 18 and evaluate whether the existing aging management 19 programs would be successful at managing aging 20 effects for in

-scope structure systems and 21 components.

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

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-3701 (202) 234-4433 They added susceptibility considerations when using 1 the online fact manager, and they developed 2 guidance in the structures monitoring program to 3 allow for noting changes and trending. This 4 included things such as taking measurements, 5 providing more detailed descriptions, and the use 6 of photographs.

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

-voltage cables.

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

18 They changed five application 19 commitments and the related aging management 20 programs. They changed their sampling criteria for 21 selecting fire water piping to flow tests. They 22 will need a flow tes t 20 percent of the piping up 23 to a maximum of 25 components during their flow 24 testing. They will look at 20 percent or a maximum 25 91 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 of 25. 1 They are going to clarify selecting the 2 representative samples frequency inspection 3 requirements for the structures. They changed the 4 frequency for inside containment to five years, as 5 an example.

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

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

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

21 From our reviews, we verified that 22 existing programs effectively manage d the aging 23 effects. We verified that the Applicant tracked 24 the completion of enhancements and development of 25 92 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 new programs and a database, as they have already 1 described.

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

10 CHAIRMAN SKILLMAN:

Greg, yes, I do. I 11 want to push back a little bit on the broadness of 12 your findings. I am referring to page 54 in the 13 PDF file of the SER. And here it is written, 14 "However, upon further review, subsequent to 15 submittal of the LRA, the Applicant determined that 16 the method used did not identify all non

-safety 17 SSCs with the potential to impact the performance 18 of safety-related SSCs." This goes on to read, 19 "Following this determination, the Applicant 20 performed walkdowns of the applicable MAB and FHB 21 spaces and identified additional non

-safety SSCs 22 with the potential to impact safety

-related SSCs, 23 and provided this additional information to the 24 staff in response to RAI 2.1

-3." 25 93 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Then, that paragraph concludes the 1 staff's concerns are resolved. What gives you 2 comfort that walking down the MAB and the FHB is 3 sufficient for thoroughness in this regard?

4 MR. PICK: When the team members walked 5 down the areas and did our reviews, what we saw 6 from using the drawings and looking at the safety

-7 related components, the things that they said were 8 in scope were in scope. So, during our individual 9 samples, we did not identify anything that they had 10 not previously identified. So, that was the basis 11 of our statement on the sample we took.

12 CHAIRMAN SKILLMAN: Thank you. No 13 f urther question on that issue, Greg.

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

16 MEMBER STETKAR: Yes, I had one. And I 17 think I understand, but I wasn't quite sure from 18 your oral presentation what they are doing 19 regarding the fire protection system. Are they 20 doing flow tests according to the

-- I don't know 21 if they are NFPA requirements

-- they are probably 22 NFPA requirements

-- for flow testing.

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

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-3701 (202) 234-4433 MEMBER STETKAR: Okay. Because you 1 mentioned -- 2 MR. PICK: That is something we look at 3 during our triannual fire protection inspections.

4 MEMBER STETKAR: Okay. Good.

5 You did mention something about 20

-6 percent sampling or 25 items. What's that? That 7 is not related to flow testing, though?

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

9 MEMBER STETKAR: Okay.

10 MR. PICK: In the report under fire 11 water system, they had identified they were going 12 to take 10 samples for volumetric examination to 13 see if there were any issues during their 14 enhancement for blockage. What they are really 15 going to do is take a 20

-percent sample of the 16 piping or a maximum of 25 samples, because that is 17 what ends up statistically being the maximum they 18 would need to take of the fire water pipe 19 locations. And they are, again, going to base it 20 on location and pipe size.

21 MEMBER STETKAR: Okay. Thank you.

22 That helps clarify. Thank you.

23 CHAIRMAN SKILLMAN: Greg, this is Dick 24 Skillman. I have a question, a little different 25 95 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 topic. 1 I'm reading from our Status Report that 2 "The staff determined that the Applicant has a 3 quality Class QC4 that was not addressed in the 4 application." What can you tell us about QC4 and 5 its applicability to our deliberations today, 6 please? 7 MR. PICK: I have no knowledge of that 8 classification and I would have to defer th at to 9 the licensee.

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

14 MR. PICK: Thank you, Lois.

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

17 So, we looked at that when we were 18 doing the scope

-instituting methodology audit.

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

24 In this particular case, there was one 25 96 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 classification, QC4, that it wasn't clear how that 1 related to the determination of safety

-related as 2 it would be applied in the implementation of the 3 rule. So, we dis cussed that.

4 And the answer that was provided to us 5 during discussion and, then, in the followup RAI 6 was QC4 could actually refer to both non

-safety-7 related and safety

-related components. So, the 8 Applicant had reviewed all of the QC4 components 9 and deter mined those which are identified, those 10 which were safety

-related, and include them within 11 the scope of license renewal for A1, identified 12 those which were non

-safety-related, and they would 13 have been included only if they were in scope for 14 A2, non-safety affecting safety; otherwise, they 15 would have been excluded. And we determined that 16 as an acceptable response and it resolved the 17 question. 18 CHAIRMAN SKILLMAN: Thank you. Thank 19 you. 20 Please proceed.

21 DR. SCHULTZ: I have one general 22 question, Dick. I would like to ask the question, 23 as one reads through the Inspection Report

-- and 24 this is to be expected

-- but, as we look at 25 97 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 license renewal and aging management, as you did 1 the inspection, you had the opportunity or the 2 need, of course, to look at the corrective action 3 program, the program health reports, surveillances, 4 as you did your investigations.

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

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

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

22 MR. PICK: We do.

23 DR. SCHULTZ: Thank you.

24 MR. PICK: Any other questions before I 25 98 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 turn it back over to Lois?

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

4 (No response.)

5 Hearing none, Lois, please proceed.

6 Thank you, Greg.

7 MR. PICK: Thank you.

8 MS. JAMES: Thank you, Greg.

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

17 The staff also reviewed the various 18 summaries of the safety

-related systems, 19 structures, and components, non

-safety-related 20 systems, structures, and components affecting 21 safety-related functions, and s ystems, structures, 22 and components relied upon to perform functions in 23 compliance with the Commission's regulations for 24 fire protection, environmental qualification, 25 99 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 station blackout, pressurized thermal shock, and 1 anticipated transients without a scram.

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

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

24 Next slide, p lease. The LRA identified 25 100 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 40 AMPs, and the Applicant subsequently added an 1 existing program in response to License Renewal 2 Interim Staff Guidance ISG

-2013-01, aging 3 management of loss of coating or lining integrity 4 for internal coatings/linings or on in

-s cope 5 piping, piping components, heat exchangers, and 6 tanks issued in November of 2014.

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

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

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

17 The first open item. In reviewing the 18 open-cycle cooling water system AMP, the staff 19 found that the LRA did not describe the protective 20 coatings used in the essential cooling water 21 system, nor discuss site

-specific operating 22 experie nce which would provide objective evidence 23 supporting the conclusion that the effects of aging 24 will be adequately managed during the period of 25 101 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 extended operation.

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

-2013-01 which encompassed these 7 issues. 8 After reviewing the RAI responses and 9 changes in response to the ISG, the staff 10 determined that the open cycle cooling water system 11 AMP is consistent with the GALL Report and meets 12 the requirements of 10 CFR Part 54.

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

20 In response to RAIs, STP detailed its 21 activities to characterize the cracking on the Unit 22 1 RWST and its proposed methods to manage the aging 23 effects with both one

-time and periodic 24 inspections. Based on the staff's review of the 25 102 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Applicant's response, the concerns regarding the 1 cracking in the Unit 1 RWST were resolved and the 2 corresponding open item is closed.

3 DR. SCHULTZ: Lois, did you have an 4 expectation that that might be extended to other 5 tanks? 6 MS. JAMES: Yes, the program extends to 7 other stainless steel tanks.

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

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

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

-- 17 DR. SCHULTZ:

-- applying it to all 18 tanks? 19 MS. JAMES: Yes. Yes, sir.

20 DR. SCHULTZ: Thank you.

21 CHAIRMAN SKILLMAN: Lois, thank you.

22 Before you leave this section on open 23 items closed

-- thank you, John

-- before you leave 24 this slide on open items closed, there is another 25 103 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 open item that has been closed. It is open item 1 4.3.2.11-1, the Effects of Thermal Aging on Cast 2 Austenitic Stainless Steel.

3 MS. JAMES: Yes, sir.

4 CHAIRMAN SKILLMAN: And written in the 5 documentation is this statement: "Use of minimum 6 material properties do not provide adequate 7 protection in light of information from the past 29 8 years." This item was then closed. Would you 9 please provide an explanation of how this 10 determination was made that this open item can be 11 closed? 12 MS. JAMES: Can I defer that to Section 13 4? 14 CHAIRMAN SKILLMAN: Sure.

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

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

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

22 MR. HOLSTON: So, the aluminum bronze 23 open item, as you heard the Applicant discussing, 24 initially, the aluminum bronze program was focused 25 104 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 on about 450 cast components that were susceptible 1 to selective leaching. And in January of last 2 year, they came in and said, well, we are going to 3 replace all of those castings because we had 4 questions related to what is the real strength of 5 the component when you de-alloy part of it. When 6 you saw the picture that they showed on the slide 7 with that little area of external de

-alloying or 8 the indication you could see, well, how do you 9 really project what is going on inside the pipe to 10 do your operability evaluati ons? 11 So, those are all being replaced.

12 That, however, left, as was discussed, about 3300 13 welds. Of course, that number will be lower when 14 castings are cut out and replaced, so you are still 15 talking about 2,000 welds, somewhere in that 16 ballpark, that are susceptible to selective 17 leaching. 18 As a result of our review of the 19 changes to the program, you heard we had about a 20 10-part open item, of which nine of those were 21 closed by a submittal that changed the program. It 22 came in in September of 2016. So, I am going to 23 focus that point forward on this.

24 So, one of the key aspects that the 25 105 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Applicant was looking at is they had not had any 1 leaks due to selective leaching in these welds, 2 these susceptible welds, since 1994. So, they did 3 some metallurgical testing.

They did some 4 calculations on cooldown rates on welds and all 5 sorts of things, and then, came to postulate that 6 the root pass is less susceptible, and it is less 7 susceptible because the dilution, the higher rate 8 of dilution that occurs in the root pass and the 9 cooldown rate being higher than in subsequent 10 passes. 11 So, in effect, what would happen is 12 they have reduced the susceptibility of the overall 13 weld to selective leaching of this aluminum bronze 14 because the root pass acts as a barrier. I mean, 15 you can almost kind of think of it as, well, it is 16 kind of like a coating and it is isolating the more 17 susceptible passes of the weld from the 18 environment. If you isolate it from the 19 environment, you are not going to have selective 20 leaching occur.

21 And some, tha t is dependent upon not 22 having a construction

-related or an in

-service flaw 23 that penetrates through the root pass and, then, 24 unless you can get the environment in the 25 106 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 subsequent passes that are most likely more 1 susceptible. That is where it is postulated they 2 had the through

-wall de-alloying up to 1994, was in 3 welds that had, you know, construction

-related 4 flaws. 5 So, as the staff and Lois talked about 6 audits we did on site, technical data we reviewed, 7 testing results we reviewed, the root pass as a 8 barrier seemed very plausible to us. However, 9 there wasn't enough testing done. The Applicant 10 had cross-sectioned, you know, about six welds.

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

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

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

24 If you look at the cross

-section of one 25 107 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 of these welds or any material that is susceptible, 1 you basically have a front of de

-alloying that goes 2 through. On one side of that front it is 100

-3 percent de

-alloyed; on the other side of the front 4 it is not de

-alloyed. Now, of course, if yo u can 5 keep exposing the environment as you pass through 6 those grains, those are going to become de

-alloyed 7 eventually. However, that is what it is.

8 So, the material on either side of that 9 front that goes through the material is either in 10 its as-received material properties or it is in 11 fully de-alloyed material properties. We concluded 12 from the data that the Applicant had constructed on 13 testing of material properties for the de

-alloyed 14 material within the bulk component that there was 15 insufficient data to bound the mechanical 16 properties.

17 We are very fortunate to have a person 18 on staff, Chris Sevanick, who was involved in the 19 Navy Air Program, had actually been involved in 20 developing material properties from testing, and, 21 basically, had to go through all th at data. 22 So, based on the number, the size of 23 the population of tests they had, and based upon 24 some of the scatter within those results, we 25 108 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 basically came to a conclusion that you would not 1 give any credit or there would be no strength 2 credit, in other words, no tensile value, for de

-3 alloyed properties or fracture toughness credit.

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

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

17 But in the detection of aging effects 18 program element, the Applicant is going to do 19 volumetric inspections. These volumetric 20 inspections will look to see if there is weld 21 defects, weld defects that could be progressing 22 through the root pass, right? So, these are not 23 ultrasonic exams that are going to measure how much 24 de-alloying is going on. We are going to talk 25 109 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 about that maybe in a little bit, just as an 1 overview. 2 But those volumetric examinations will 3 provide information that, in fact, based upon a 4 representative sample, we aren't seeing, we haven't 5 seen from the last time they did these volumetric 6 examinations d uring the plant construction, that 7 there aren't weld defects that are propagating 8 through the root pass.

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

-sectioned.

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

-ground piping. 24 One of the pictures you saw or the 25 110 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 picture they showed you is very characteristic of 1 what you see if you see selective leaching. I 2 actually did a walkdown with one of the Applicant 3 staff members, and there was a fitting, you know, a 4 much smaller f itting. It was about a 3

-inch 5 fitting that showed that little fluorescent break 6 there. 7 Then, in addition, they look at yard 8 areas to detect if there is moisture that is 9 unusual that shouldn't be there. That would seem 10 odd. How do you that? Well, we explored that with 11 the Applicant. We looked at detailed calculations 12 that demonstrated that, if you have a 10

-gallon 13 permatted leak, it will get to the surface within 14 30 days. And they have a huge margin there. They 15 have about a margin of 1,000 gallons, I mean that 16 they can tolerate.

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

20 He reviewed those calculations and felt that they 21 were well-bounded and well

-founded.

So, albeit, 22 you can't look for leakage on the outside surface 23 of the components that are buried, we can observe 24 for an indirect effect and be convinced that there 25 111 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 is no leakage going on that would affect the 1 intended function.

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

8 So, that is basically what is going to 9 go on with detection of aging effects. Basically, 10 at the end of that, having done the volumetric 11 examinations to show that, yes, after that 12 representative sample, we don't see any defects 13 that are challenging the root pass, and we will 14 have 50 examinations that will actually not only 15 look at is there de

-alloying going on, but it will 16 look at the phase, the actual phases within that 17 cross-section that will be sufficient to 18 demonstrate that the theory, which we think is 19 true, is that root pass is more resistant to de

-20 alloying and protects the other layers of the weld.

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

23 Yes, sir? 24 MEMBER RICCARDELLA: How does the 25 112 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 presence of a backing bar affect this protection

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

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

11 The other thing is the backing ring 12 allows you to have a greater heat sink, which cools 13 it down quic ker. If you cool it down quicker, you 14 don't get the gamma

-2 or the beta phase that are 15 susceptible to selective leaching aluminum bronze.

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

-backing-ring population. We are 24 goin g to do 25 of those.

25 113 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER RICCARDELLA: Okay.

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

3 DR. SCHULTZ: Bill

-- 4 MR. HOLSTON: Yes?

5 DR. SCHULTZ:

-- one more question. We 6 have kind of bounced back and forth between a 7 representat ive sample and 25.

8 MR. HOLSTON: Uh

-hum. 9 DR. SCHULTZ: With regard to the 10 destructive examinations, what are the staff's 11 expectations if, when those are done, issues arise 12 as a result of the investigation? I mean, you 13 could hypothesize you do the destruct ive 14 examinations and you find issues.

15 MR. HOLSTON: Correct.

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

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

21 DR. SCHUL TZ: Sure.

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

24 DR. SCHULTZ: Thank you.

25 114 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. HOLSTON: So, yes, I will go 1 through acceptance criteria and, then, get to that 2 and I will answer your question I think directly.

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

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

11 MR. HOLSTON: The simple answer to the 12 question is no, because there is a huge

-- but the 13 answer to why is that there is a very large margin.

14 They can detect a 1 0-gallon-per-minute leak. They 15 can tolerate 1,000 gallons per minute. Now, 16 clearly, if they had a 1,000 gallons a minute, that 17 is going to be washing out soil. It could affect 18 structural integrity evaluations. But selective 19 leaching is not a rapidly

-propagating phenomenon.

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

-- 24 MEMBER SUNSERI: Yes. Thank you.

25 115 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MEMBER STETKAR: Bill, should I ask you 1 about the buried and underground piping program now 2 or should I ask you about it at all?

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

4 MEMBER STETKAR: Okay.

5 MR. HOLSTON: And why don't you go 6 ahead? 7 MEMBER STETKAR: Okay.

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

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

13 MR. HOLSTON: Sure.

14 MEMBER STETKAR: We heard earlier that 15 the license renewal application checked off a box 16 that said the cathodic protection system is not in 17 scope for license renewal. So, does that mean that 18 in their buried and underground piping inspection 19 program they are applying the

-- I don't know 20 whether it is Category E or Category F of their 21 inspe ctions. In other words, not taking credit at 22 all for cathodic protection? Or what are they 23 doing? 24 MR. HOLSTON: Yes, that doesn't mean 25 116 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 that. What it means is, when we say the cathodic 1 protection system is not within the scope, it is 2 the wires; it is the panels; it is the rectifiers 3 that aren't in scope.

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

10 MEMBER STETKAR: Yes.

11 MR. HOLSTON: So, the Applicant has to 12 measure the amount of time the current is turned 13 on. Somebody trips a breaker open for something 14 and it has been off for two months, th at is going 15 to be a problem, right? Because if you don't pull 16 the electricity, you are not going to get the 17 cathodic protection. So, there is a criteria for 18 that, and that is 85 percent of the time it has to 19 be on. 20 We also have a criteria, then, for the 21 effectiveness of it. And that is measured by the 22 annual cathodic protection surveys. You have to 23 demonstrate that you have negative 850 millivolts.

24 Now, with our new ISG we issued, we also accepted 25 117 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 in higher resistivity soils

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

-- 5 MEMBER STETKAR: Right.

6 MR. HOLSTON:

-- and do the additional 7 inspections.

8 And what demarcates between E and F is, 9 if your plant

-specific operating experience is good 10 and meets the criteria in the AMP, then your 11 cathodic protection is upright, up

-to-speed, you do 12 E, which is three every 10 years. But, if you also 13 have bad operating experience, then you have got to 14 go to six every 10 years.

15 MEMBER STETKAR: Right. So, I think 16 what I hear you saying is that they will

-- I 17 always hate to say "take credit" -- but they will 18 take credit for cathodic protection with all of 19 those caveats in determining the frequency and 20 extent of their piping inspections?

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

-- 24 MEMBER STETKAR: No, no.

25 118 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. HOLSTON:

-- rath er than checking 1 the wires, we performance monitor the effects of 2 the cathodic protection system with the 3 availability and the effectiveness.

4 MEMBER STETKAR: Yes. Thank you. That 5 helps. 6 MR. HOLSTON: Any other questions on 7 detection of aging effects?

8 (No response.)

9 Okay. For the acceptance criteria, 10 what they will do when they do the volumetric exams 11 is, obviously, they are looking for any plane or 12 flaw that would exceed 80 percent of the root pass 13 if it is connected

-- you know, you could have a 14 plane or flaw within. So, here's your water. And 15 so, your inside diameter of your pipe, and you have 16 your pipe, you know, your outer edge of your root 17 pass. If it is up here, we are not really worried 18 about it. We are here with an environment 19 connected plan e or flaw.

20 And with the destructive examinations, 21 the microstructure of the root region, we are 22 looking to see that we are reasonably certain they 23 are going to see some gamma

-2 in the welds, right?

24 It is not none whatsoever at all, right? But we 25 119 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 want to see that that is surrounded by the alpha 1 phase which is not susceptible to selective 2 leaching. And if the gamma

-2 or the beta phase 3 would exceed 80 percent of the depth of that root 4 pass, then we have an issue. And so, that is the 5 microstructure monitori ng. 6 And I did have a typo

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

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

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

19 CHAIRMAN SKILLMAN: Okay. Thank you.

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

22 (No response.)

23 Okay. Next slide, and this gets to the 24 corrective actions I was talking about before that 25 120 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Mr. Schultz was asking about.

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

15 Does that answer your question?

16 DR. SCHULTZ: Yes. Thank you.

17 MR. HOLSTON: Okay. Now another 18 aspect, though, which is structural integrity 19 calculations conducted with the as

-found 20 conditions, so, then, the question is, well, what 21 is a corrective action if you find an issue with 22 structural integrity?

23 So, the staff is concerned with that 24 because, if you find an issue with structural 25 121 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 integrity, you have an issue with the intended 1 function of the system. And so, that is where we 2 are right now with the Request for Additional 3 Information.

4 The licensee has worked with EPRI and 5 done some testing of a UT volumetric method that 6 should be able to actua lly take the weld and 7 measure the amount of de

-alloying that is going 8 inside, from the inside, from the ID to the OD.

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

15 We were aware of Vermont Yankee doing 16 the cast iron piping. We just hadn't been aware of 17 anybody doing it for aluminum bronze welding or 18 fittings. 19 And so, our RAI talks about, well, tell 20 us how you are going to demonstrate the method, how 21 you are going to quality people, what the 22 resolution of that process is, and several other 23 questions on sampling size and all of that. So, 24 that is the remaining open item, is, what are you 25 122 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 going to do for corrective actions if the 1 structural integrity evaluation isn't acceptable?

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

5 MR. HOLSTON: I don't

-- well -- 6 MS. JAMES: We have not issued the RAI 7 yet. So, we have to issue it. They have to have 8 their 30 days to respond and, then, we need at 9 least 30 days to look at what their respons e is. 10 And in this instance, we have to get 11 another division involved. So, we wanted to give 12 ourselves a little extra time to review what comes 13 in, which is why we are discussing delaying the 14 full Committee from February.

15 CHAIRMAN SKILLMAN: Thank you. I 16 understand.

17 MR. HOLSTON: The RAI has been peer

-18 reviewed. 19 CHAIRMAN SKILLMAN: Okay.

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

22 CHAIRMAN SKILLMAN: Thank you for the 23 explanation. We were trying to get clear on timing 24 and the workload for the Committee. And this gives 25 123 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 us an explanation of what is happening. Thank you.

1 Please proceed.

2 Go ahead, John.

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

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

-- 7 MEMBER STETKAR: Let me go back to the, 8 for lack of a better term, risk

-informed sampling 9 process. Is the staff good with taking a random 10 sample, you know, throwing a random number 11 generator in and taking a random sample of any 25 12 of the 3300, I think I wrote down here?

13 MR. HOLSTON: Yes, we are thinking 14 there is about 2,000. Once you cut out the 400

-15 some-odd fittings

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

18 (Laughter.)

19 MR. HOLSTON: It is a little bit less. 20 MEMBER STETKAR: But 25 out of a large 21 number -- 22 MR. HOLSTON: Right.

23 MEMBER STETKAR:

-- randomly 24 selected -- 25 124 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. HOLSTON: What we did was Matt 1 Homiack, who is back here in the room, he is in 2 Research now, did some calculations, finite element 3 hea t transfer calculations to determine how 4 sensitive that is. And he is coming up to the 5 microphone, and I would like to give him credit for 6 the great work he did in that regard. I think he 7 is going to have some positive answers for you.

8 MR. HOMIACK: Than k you, Bill.

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

-- 11 CHAIRMAN SKILLMAN: Excuse me, sir.

12 Identify yourself, please.

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

15 CHAIRMAN SKILLMAN: And, Matt, make 16 sure you s peak up in the microphone, so we can 17 hear. 18 MR. HOMIACK: Will do. Thank you. Is 19 this okay?

20 CHAIRMAN SKILLMAN: Yes.

21 MR. HOMIACK: So, there is actually two 22 -- it is a smart sample. There is two sample 23 populations, first of all. One, welds with backing 24 rings and one of welds without. And I believe, 25 125 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Bill, each will get 25 destructive examinations.

1 And so, the reason for looking at those 2 differently is the welds with the backing rings 3 have the operating experience, and the welds 4 without the backing rings are more susceptible root 5 pass to de

-alloying because they have a quicker 6 cooldown rate.

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

11 MR. HOLSTON: And Matt, in his 12 calculations, varied heat inputs, the exact 13 question you were asking. Because one of the 14 concerns we had was not so much some variation from 15 welder to welder, but if you are hanging upside

-16 down and trying to make that weld versus doing a 17 flat weld, doing a vertical weld, you know, as 18 well-controlled as weld procedures are, it is a 19 little tougher to make some of those welds. And 20 would they have a higher heat input or something?

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

25 126 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 Now the AMP does say, the aging management say that 1 they will take into effect construction

-related 2 fac tors. 3 MEMBER POWERS: If I just assume that 4 they have a random population

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

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

-percent chance 13 that I have covered 90 percent of the range of 14 things. 15 So, while the number looks small, it is 16 pretty powerful if you don't have systematic 17 effects. And that, coupled with your walkdown to 18 identify systematic vulnerabilities, it appears to 19 me, though, it is 25 of a large number, the fact is 20 random sampling is a pretty powerful technique for 21 id entifying outliers in that range.

22 MEMBER STETKAR: Well, except for how 23 frequently do they do this destructive examination 24 sampling. 25 127 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MR. HOLSTON: Well, if they are going 1 to do the destructive examinations, it is a one

-2 time destructive examination. Because you want to 3 demonstrate with adequate data that that root pass 4 is less susceptible.

5 MEMBER STETKAR: So, the sample is not 6 after three refuelings. It is a one

-time. It is 7 25. So, you have a little lower confidence.

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

-- 10 MEMBER STETKAR: Yes.

11 MEMBER POWERS:

-- that moves up 12 rapidly. 13 MR. HOLSTON: The actual numbers are 14 that the 25 is a 90/90 certainty. That is the 15 number. So, where we have adopted that throughout 16 the GALL Report and several aging man agement 17 programs is, where you are demonstrating that an 18 aging effect is not likely to cause a loss of 19 intended function, we use 90/90.

20 Now, for example, when talking about 21 structural integrity, there is a challenge to 22 structural integrity, the certainty n eeds to be 23 higher. So, for these welds that we are doing 24 where we have seen some cross

-sections, right, 25 128 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 about six welds that they cross

-sectioned that 1 support the theory, we want to have enough to say 2 that that is reasonable, that they are not going to 3 de-alloy through the root pass, go into the higher 4 susceptible weld passes, and then, de

-alloy 5 through-wall. And so, that is why we are very 6 comfortable with the 25 and the random at this 7 point. But the RAI addresses what happens if you 8 see more consequent ial results

-- 9 MEMBER STETKAR: Yes, I didn't read the 10 RAI. 11 MR. HOLSTON: Yes. Yes, we haven't 12 given that to you yet. It is not published yet.

13 MS. JAMES: It is not publicly

-14 available yet. So, it will be public and it will 15 issue in the next week or so.

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

24 MR. HOLSTON: That is correct, yes.

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-3701 (202) 234-4433 MEMBER BALLINGER: Okay.

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

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

-- 11 MEMBER RICCARDELLA: Bill, as you know, 12 the other side of risk

-informing this type of a 13 selection is to look at consequences. Is there any 14 abi lity to distinguish from different piping 15 locations based on the consequences of failure?

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

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

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

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

24 There are welds that directly supply maybe a cooler 25 130 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 for diesel, and those would be more. There are 1 welds that are downstream of the coolers. It has 2 already done its function as long as it doesn't 3 flood the room. All it is doing is going to the 4 bay, or not the bay, to the pond, right?

5 So, we didn't factor in in any 6 sel ection the consequential because we are 7 confident, based upon what we have seen with the 8 testing results, also with what Matt has done with 9 the backup analyses, that what you see in a weld 10 here that is a very critical weld would be the same 11 thing because the environment is the same here; the 12 weld processes are the same, and the sensitivity to 13 the amount of heat put in with the weld is 14 virtually, you know, it doesn't really affect the 15 potential for additional beta or gamma

-2. So, we 16 didn't say, make sure yo u do all your sampling of 17 your welds upstream or in the main header, or 18 anything like that.

19 MR. HOLSTON: Well, the consequence, 20 yes. Yes, as Allen is saying, the consequence 21 issue gets into whether what you see affects 22 structural integrity. And so, that is where we 23 have a four

-page RAI to address what

-- you know, 24 that is why the corrective actions for structural 25 131 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 integrity is still an open item. You know, we are 1 hopeful that this volumetric technique will be 2 something that we can accept it. Of course, with 3 the volumetric technique of that nature, they could 4 look at a lot of welds. They could zero into the 5 more consequential welds in that case. Because, to 6 date, of all the casting failures, castings are a 7 lot more susceptible than the welds are, and o n the 8 weld failure side, they have not had one that 9 failed structural integrity criteria.

10 MEMBER RICCARDELLA: Question. You 11 know, when you say "structural integrity criteria," 12 you say, well, the stresses are higher than the 13 allowable stress, or something like that. But is 14 there any concern at all about a rupture of one of 15 these or are we mainly just concerned about a leak?

16 MR. HOLSTON: Because of the very low 17 operating pressure at very low operating 18 temperatures, we are not too concerned. And they 19 have very low seismic loads, too. We looked at 20 their seismic analyses. There is nothing huge 21 there. 22 We would be more concerned with a leak 23 than we would be

-- but they have done a lot of 24 analyses on the leak rates, the allowable leak 25 132 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 rates versus detectabil ity of those leaks. And we 1 have reviewed all of that, and that is all 2 documented, that we feel they have the 3 detectability to see it before it could approach to 4 a leak that would starve the heat exchanger, or 5 whatever. 6 MEMBER RICCARDELLA: Thank you.

7 CHAI RMAN SKILLMAN: Let's proceed, 8 please. 9 Bill, thank you.

10 MR. HOLSTON: Yes, sir.

11 MS. JAMES: Okay. We are now on slide 12 16. SER Section 4 identifies the time

-limited 13 aging analysis, or TLAAs. Section 4.1 documents 14 the staff's evaluation of the Applicant's basis for 15 identifying plant

-specific or generic analysis that 16 need to be identified as TLAAs and determine that 17 the Applicant has provided an accurate list, as 18 required by 10 CFR 54.21(c)(1).

19 Sections 4.2 through 4.7 document the 20 staff's review of the ap plicable STP TLAAs as 21 shown. Based on its review and the information 22 provided by the Applicant, the staff concludes that 23 the TLAAs will remain valid for the period of 24 extended operation. The TLAAs have been projected 25 133 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 to the end of the period of extended operation or 1 the effects of aging on those intended functions 2 will be adequately managed for the period of 3 extended operations, as required by 10 CFR 4 54.21(c)(1).

5 Next slide, please. There is one TLAA 6 open item from the 2013 SER with open items that we 7 cl osed in this 2013 SER

-- or 2016 SER. In 8 reviewing the effects of thermal aging on CASS, the 9 staff was concerned that the Applicant's thermal 10 embrittlement evaluation of CASS material in the 11 leak-before-break piping relied upon an evaluation 12 and data from 1983. The staff issued RAIs between 13 April 2011 and November 2013 and documented its 14 concerns as an open item in the 2013 SER with open 15 items. 16 In response, the Applicant stated that 17 the referenced material, fractured toughness 18 properties, for their evaluations are shown to be 19 bounding. In addition, the Applicant revised its 20 LRA to identify the fracture mechanics evaluation 21 as a TLAA and dispositioned it in accordance with 22 10 CFR 51.21(c)(1) as an analysis that remains 23 valid for the period of extended oper ation. 24 The staff confirmed that the Applicant 25 134 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 used a bounding fractured toughness value for its 1 leak-before-break analysis, and that the fractured 2 toughness used is applicable to 60 years.

3 Therefore, the staff concluded that the revisions 4 to the LRA are acceptable, and the open item is 5 closed. 6 Mr. Skillman, do you have more 7 questions? We have our technical reviewer in the 8 audience. 9 CHAIRMAN SKILLMAN: No. You have 10 addressed the question that I raised earlier.

11 MS. JAMES: Okay.

12 CHAIRMAN SKILLMAN: I'm go od. Thank 13 you. 14 MS. JAMES: The next slide, please.

15 Pending the satisfactory resolution of the open 16 item, the staff will determine whether the 17 requirements of 10 CFR 29(a) have been met for the 18 license renewal for South Texas Project Units 1 and 19 2. 20 This c oncludes our staff presentation, 21 and we will now be available for any further 22 questions from the Subcommittee.

23 Thank you.

24 CHAIRMAN SKILLMAN: Lois, thank you.

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-3701 (202) 234-4433 Colleagues, I invite any questions you 1 might have for the staff at this time.

2 (No response.)

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

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

13 CHAIRMAN SKILLMAN: Aux feedwater 14 pumps. 15 MS. JAMES: Aux feedwater pumps have 16 vent valves and are they or are they not within the 17 scope of license renewal?

18 CHAIRMAN SKILLMAN: Yes, and it is page 19 127 in the PDR file of the SER. I don't need to 20 read the text. It just seems as though there was 21 an awful lot of traffic on this s ubject, and I 22 found it extremely confusing. And I said, oh, wait 23 a minute, most of these pumps do have some kind of 24 a vent valve. Most of them have some valves on 25 136 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 piping that is connected to the casing. So, it is 1 not a substance of issue, but I found th e text in 2 the SER very

-- 3 MS. JAMES: Confusing?

4 CHAIRMAN SKILLMAN:

-- confusing.

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

8 CHAIRMAN SKILLMAN: It is 127 in the 9 PDR file. 10 MS. JAMES: Is that Section 2 of the 11 SER? 12 CHAIRMAN SKILLMAN: This is.

13 MS. JAMES: It has got to be.

14 CHAIRMAN SKILLMAN: It's

-87. 15 MS. JAMES: 2

-, yes. 16 CHAIRMAN SKILLMAN: 2

-87 is the text 17 page. 18 MS. JAMES: Okay. I guess at this 19 point I'm going to have to t ake that as a takeaway.

20 CHAIRMAN SKILLMAN: If you would.

21 MS. JAMES: Yes.

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

25 137 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Yes.

1 MR. GIBBS: We have vent valves.

2 MEMBER STETKAR:

You actually have to 3 tell us on the record.

4 (Laughter.)

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

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

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

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

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

-87, please. 23 MS. JAMES: Okay.

24 CHAIRMAN SKILLMAN: Thank you. Sir, 25 138 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 thank you.

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

4 CHAIRMAN SKILLMAN: Okay. Thank you.

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

7 MS. JAMES: Restate the question?

8 MS. DIAZ: Yes.

9 MS. JAMES: Okay. I was asked to 10 restate the question. The question is, based on 11 the writeup on page 2

-87 of the SER, it was 12 confusi ng as to whether or not there were vent 13 valves on the aux feedwater pumps and were those 14 vent valves within scope of license renewal?

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

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

19 CHAIRMAN SK ILLMAN: Thank you.

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

23 MEMBER KIRCHNER: Dick, I have just a 24 question. I can't find it in the SER now. I 25 139 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 believe that tests were done on the baffle region 1 for vibration of reactor internals. Can you or the 2 Applicant report back on that? It is relevant to 3 Matt's earlier question about baffle bolts and what 4 you may have found as a result of that testing. I 5 think you did a scale model test of the conforming 6 region, the baffle conforming region. I just can't 7 find it. I know it is here in the SER and I can't 8 find it. 9 MS. JAMES: Okay. Jim Medoff is coming 10 to the microphone for the staff.

11 MR. MEDOFF: This is Jim Medoff of the 12 staff. I was the lead for the reactor internals 13 and I had some assistance with Mark Hughes of the 14 staff. 15 One of the things we check as part of 16 the identification of TLAAs in Chapter 4.1 is 17 whether the preopt testing for initial plant 18 operations, whether any analyses associated with 19 preopt testing are TLAAs. So, we did look at that 20 for the application. We usually would

-- in most 21 applications the vibrational analyses are below the 22 endurance limit for the components. So, vibrations 23 didn't come in as a TLAA for the i nternals. 24 That being said, we do rely on the 25 140 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 MRP-227 report and AMP XIM

-16(a) for the internal.

1 Originally, this plant was one that did it under 2 commitment, but due to the delays in the aluminum 3 rods, we did make them update the LRA, update their 4 AMRs and AMPs. So now, we have reviewed the entire 5 AMP, their inspection plan, to make sure it is 6 consistent with MRP

-227-A. That would include any 7 inspections of the baffle former region, including 8 the baffle formal bolts.

9 MEMBER KIRCHNER: Thank you.

10 MR. MEDOF F: Any more questions on 11 that? 12 CHAIRMAN SKILLMAN: No, sir. Thank 13 you. 14 Walt, thank you.

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

17 (No response.)

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

21 MR. HOWARD: The bridge is open.

22 CHAIRMAN SKILLMAN: The bridge is open.

23 Before we go to those who may be on the phone line, 24 I would like to ask if there are any individuals in 25 141 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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-3701 (202) 234-4433 the audience that would like to make a statement, 1 please. 2 (No response.)

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

7 MR. GAVULA: This is Jim Gavula.

8 CHAIRMAN SKILLMAN: Good morning, sir.

9 Thank you.

10 Anybody els e out there?

11 (No response.)

12 No? 13 For anyone that is on the line, would 14 you care to make a comment, please?

15 (No response.)

16 Hearing none, please close the bridge 17 line. 18 I would like to go around the room with 19 my colleagues to determine if there are any more 20 c omments that my colleagues may have.

21 Ron, may I start with you?

22 MEMBER BALLINGER: No further comments.

23 I think I have badgered them enough.

24 CHAIRMAN SKILLMAN: Thank you, Ron.

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-3701 (202) 234-4433 Pete? 1 MEMBER RICCARDELLA: Likewise.

2 CHAIRMAN SKILLMAN: Thank you.

3 Steve? 4 DR. SCHULTZ: I have no further 5 comments. I would like to thank the staff and the 6 Applicant for the discussions. Thank you.

7 CHAIRMAN SKILLMAN: Okay. Dana, 8 anything? 9 MEMBER POWERS: No.

10 CHAIRMAN SKILLMAN: Matt?

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

14 CHAIRMAN SKILLMAN: Thank you.

15 John? 16 MEMBER STETKAR: Nothing more. Thank 17 you. 18 CHAIRMAN SKILLMAN: Walt?

19 MEMBER KIRCHNER: Thank you to the 20 presenters.

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

24 MR. HOWARD: None.

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-3701 (202) 234-4433 CHAIRMAN SKILLMAN: Okay. To all who 1 have participated and traveled, thank you very 2 much. I wish you a safe journey home.

3 An d with that, this meeting is 4 concluded.

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

7 8 9 10 11 12 13 14 15 16 17 18 19 SOUTH TEXAS PROJECTAdvisory Committee on Reactor Safeguards License Renewal Subcommittee Meeting November 17, 2016 Dave RencurrelSenior Vice President Operations 2

• Introductions

• Station Ownership and Operation

• Site and Station Description

• License Renewal, GALL Consistency and Commitments

• Safety Evaluation Report Open Item oAluminum Bronze Selective Leaching

• Concluding RemarksSOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 3Agenda SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 4PERSONNEL IN ATTENDANCEDave Rencurrel Senior Vice President OperationsMichael Murray Manager Regulatory AffairsMike Berg Manager EngineeringRon GibbsManager Operations Arden Aldridge License Renewal Project LeadPlant StaffAMP Subject Matter Experts, Licensing, Chemistry, Systems Engineering, Design Engineering, andPrograms Engineering Specialty Consultants Introduction Operated by STP Nuclear Operating Company (STPNOC) STP Units 1 and 2 are owned by:*NRG South Texas LP*The City Public Service Board of San Antonio (CPS Energy

)*The City of Austin, Texas (COA

)SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 5Station Ownership and Operation SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 6Plant History & Major InvestmentsSouth TexasUnit 1Unit 2Initial License August 21, 1987Dec 16, 1988Steam Generator Replacement 2000 2002Low Pressure Turbine upgrade 2006 2004Replaced RX heads 2009 2010Main Generator Stator rewind 2014 2012Non-welded Stress Improvement Process (RPV) 2017 2019Expiration of current LicenseAugust 20, 2027Dec 15, 2028 Ron GibbsManager OperationsSite and Station Description 7

SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 8SITE DESCRIPTION SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 9STATION DESCRIPTION Arden AldridgeLicense Renewal Project LeadLicense Renewal Application10 SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 11License Renewal Application License Renewal Application (LRA) submitted to NUREG 1801 rev 110/2010NUREG 1800 and 1801 Revision 2 issued12/2010Scoping & Screening, AMP Audits completed 06/2011Scoping & Screening, AMP Inspection completed08/2011Annual Updates 2011, 2012, 2013 2011-2013Issued initial safety evaluation report (SER) with open item(s)02/2013Safety review paused2/2013-12/2013RAI's, LR-ISG incorporation into LRA1/2014-PresentAnnual Updates 2014, 2015, 2016 2014-2016Issued safety evaluation report (SER) with open item10/2016

• Total Aging Management Programs

-41*Existing Programs

-33 (3) plant specific

• New Programs

-8 (1) plant specific

• Plant Specific

-Nickel-Alloy -PWR Reactor Internals

-Protective Coating Monitoring and Maintenance

-Selective Leaching of Aluminum Bronze

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

• GALL Revision 2 lessons learned incorporated through license renewal application supplement and reviewed by the NRC using Standard Review Plan Rev 2.SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 12Aging Management Programs and GALL Consistency TableSOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 13GALL ConsistencyAMPSAMPS ConsistentAMPS Consistent with EnhancementsAMPS Consistent with Exception & EnhancementsAMPS with ExceptionsPlant SpecificNew (8)3 4 1Existing (33) 5 13 11 1 3Total AMPS (41)

License Renewal commitments

-46 total-Program Enhancements (4 complete, 26 open)

-Program Implementation (1 implemented , 9 open)

-Replace 6 Standby Emergency Diesel Generator bellows (open)

-Remove Safety Related Check Valve Seal Caps (complete)

-Review NUREG/CR

-6260 (Enhanced Fatigue Monitoring locations (open)-Take ground water samples for 24 consecutive months to assure non aggressive (complete)

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

-One time internal inspection of Unit 1 Refueling Water Storage Tank (RWST) bottom and side welds. (open)SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 14License Renewal Commitments License Renewal commitments are included in UFSAR Supplement (Appendix A to the LRA) and managed through the STP Condition Reporting and Licensing Commitment Management and Administration processes.SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 15License Renewal Commitments and Implementation Safety Evaluation ReportOpen ItemMike Berg Engineering Manager16 SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 17OI 3.0.3.3.3

-2 Aluminum Bronze Selective Leaching Wrought Material is non

-SusceptibleSusceptible Component Population

-Will be replaced with non-susceptible material prior to period of extended operation Welds or weld

-repairs with susceptible weld filler material will be managed

• piping butt

-welds *weld repairs on extruded teesSOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 18Selective Leaching of Aluminum Bronze Background STP responded to the NRC's open items related to Selective Leaching of Aluminum Bronze AMP by letter dated September 28, 2016, "NOC

-AE-16003403".

OI 3.0.3.3.3

-2 Identified ten open issues requiring closure. Nine of the ten open issues have been addressed. The final issue is still open but a pathway forward has been identified to assure timely resolution.SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 19Selective Leaching of Aluminum Bronze Aging Management Program (AMP

)

Addressed Issues:1. Added information to bound extruded piping tee repairs 2.Clarified the parameters monitored to address loss of material, cracking, and phase distribution.3. Clarified the sample size for volumetric inspectionsOne-time examination of weldsPeriodic examination of welds 4.Clarified the threshold for the number of defective welds resulting in further inspections 5.Identified selection criteria for weld inspectionsSOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 20Selective Leaching of Aluminum Bronze Aging Management Program (AMP

)

Addressed Issues:6. Determined there was no impact of the external coatings regarding detecting buried piping leaks at the surface. 7. Identified a method to monitor or trend results8. Defined the acceptance criteria for weld defectsVisual inspectionVolumetric examinationDestructive examination 9.Identified the threshold for increased inspections when adverse inspection results are detected10. Identified the corrective actions to address all potential inspection results.SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 21Selective Leaching of Aluminum Bronze Aging Management Program (AMP

)

Remaining Open Issue: 10. Corrective actions do not address all potential inspection results.Followupquestion is being developed by the NRC. Initial communication of the concern supports a pathway forward and timely response and resolution. SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 22Selective Leaching of Aluminum Bronze Aging Management Program (AMP

)

==

Conclusion:==

Following the resolution of the remaining issue related to corrective actions, the Selective Leaching of Aluminum Bronze Aging Management program will effectively manage aging of the Essential Cooling Water cast components and welds during the extended period of operation.SOUTH TEXAS PROJECT ACRS SUBCOMMITTEE November 17, 2016 23Selective Leaching of Aluminum Bronze Aging Management Program (AMP

)

Dave RencurrelSenior Vice President OperationsConcluding Remarks24 END25 Advisory Committee on Reactor Safeguards License Renewal Subcommittee South Texas ProjectSafety Evaluation Report (SER) with Open ItemsNovember 17, 2016Lois M. James, Senior Project ManagerOffice of Nuclear Reactor Regulation Presentation Outline

• Overview of South Texas Project (STP) license renewal review

• Region IV 71002 Inspection, License Renewal Inspection

• SER Section 2, Scoping and Screening Review*SER Section 3, Aging Management Review

• SER Section 4, Time-Limited Aging Analyses*Conclusion 2

License Renewal Review (Audits and Inspections)

• Scoping and Screening Methodology Audit-May 15 -19, 2011 (Onsite)*AgingManagement Program (AMP) Audit-June 13 -24, 2011 (Onsite)

• Aluminum Bronze Selective Leaching AMP Audits-February 29, 2012 (Rockville)-March 9 -13, 2015 (Onsite)

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

• Region IV 71002 Inspection (Scoping and Screening & AMPs)-August 8 -25, 2011 (Onsite) 3 SEROverview

• SER with Open Item (OIs) issued in 2013

• SER with OIs issued in 2016-Closed the OIs from 2013 -Opened OI 3.0.3.3.3-2 -Insufficient details provided regarding applicant's Selective Leaching of Aluminum Bronze AMP 4

71002 Inspection

• Scope*Non-Safety Systems affecting Safety Systems*Aging Management Programs

• Inspection *August 8 -August 25, 2011*Team Inspection on-site for 2 weeks 5

6*Results-Good material condition of structures, systems and components-Two implementing procedures changed

-Two Aging Management Programs Changed

-Revised Commitments and Corresponding Changes for five Aging Management Programs 71002 Inspection 71002 Inspection

• Conclusions-Scoping and screening performed in accordance with 10 CFR 54-Information easily retrievable and auditable

-Existing programs effectively managed aging effects

-Corrective and other actions being tracked for completion-Reasonable assurance that aging effects will be managed and intended functions maintained 7

SER Section 2

• Structures and Components Subject to Aging Management Review-Section 2.1, Scoping and Screening Methodology-Section 2.2, Plant-Level Scoping Results

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

SER Section 3

• Aging Management Review Results-Section 3.1, Aging Management of Reactor Vessel, Internals, and Reactor Coolant System-Section 3.2, Aging Management of Engineered Safety Features

-Section 3.3, Aging Management of Auxiliary Systems

-Section 3.4, Aging Management of Steam and Power Conversion Systems-Section 3.5, Aging Management of Containments, Structures and Component Supports -Section 3.6, Aging Management of Electrical Commodity Group 9

SER Section 3Applicant's Disposition of AMPs*8 new programs3 consistent4 consistent with exceptions1 plant specific*32 existing programs6 consistent13 consistent with enhancements3 consistent with exception8 consistent with enhancements and exceptions2 plant specific*1 existing program added1 plant specificFinal Disposition of AMPs in SER with OIs*8 new programs3 consistent 4consistent with exceptions1 plant specific*33 existing programs5 consistent14 consistent with enhancements1 consistent with exceptions10 consistent with enhancements and exceptions3 plant specificNote: The staff received and is reviewing the 2016 annual update. The final SER will be updated based on the staff's

review.10 3.0.3-AgingManagementPrograms SER Section 3 Open Items ClosedOI3.0.3.2.6-2: Management of fouling of downstream components due to coating degradations upstream

• Concern: AMP may be inadequate

• Resolution: AMP was revised in accordance with staff's guidance in ISG-2013-01, "Aging Management of Loss of Coating or Lining Integrity for Internal Coatings/Linings on In-Scope Piping, Piping

Components, Heat Exchangers, and Tanks."OI3.0.3.1.4-1: Cracking in Unit1 Reactor Water Storage Tank (RWST)*Concern: No AMP

• Resolution: Revised the One-Time Inspection AMP to include the internal surfaces of the Unit 1 RWST; and revised External Surfaces AMP to include visual inspections of the Unit 1 RWST every refueling cycle

.11 Aluminum Bronze Overview*Applicant revised AMP in September 2016.*Replacing all susceptible piping components that have exhibited leakage except for susceptible weld material joining nonsusceptible piping components.*Applicant proposed a basis for why butt welds have not experienced leakage since 1994.-Root pass less susceptible: dilution and cool down rate

-Root pass acts as a barrier

-No construction related or service induced flaws in root pass, barrier remains intact*Root pass as a barrier seemed plausible; however, basis lacked sufficient data to substantiate 12 Staff ConclusionsBased on review of tests and examinations conducted by the applicant, and the review of technical literature by the staff:*Microstructure level dealloying process is confined to a localized front that scales with the grain size. *Material on either side of the dealloying front is either in the as-received or fully dealloyed condition.*Insufficient data to establish lower bound mechanical properties for dealloyed aluminum bronze.*No strength or fracture toughness credit should be given to dealloyed material.

13 Program Element OverviewSeptember 2016, AMP revised to address most of the OI*Detection of aging effects:-Volumetric inspections and destructive examinations

-Visual inspections for leakage

-Opportunistic buried pipe coating inspections*Acceptance criteria:-Planar defect and dealloying

-Microstructure of the weld root region

-Monthly walkdowns 14 Program Element Overview, cont.

Corrective Actions:*Additional volumetric and destructive examinations

• Structural integrity calculations conducted with as-found conditions*Structural integrity analysis fails -additional inspections by ultrasonic testing (UT) technique capable of detecting loss of material due to selective leaching -Associated Request for Additional Information (RAI) for further information 15

• Time-Limited Aging Analyses-4.1, Identification of Time-Limited Aging Analyses (TLAA)-4.2, Reactor Vessel Neutron Embrittlement Analysis

-4.3, Metal Fatigue Analysis

-4.4, Environmental Qualification of Electric Equipment-4.5, Concrete Containment Tendon Prestress Analyses

-4.6, Containment Liner Plate, Metal Containment, and Penetrations Fatigue Analyses-4.7, Other Plant-Specific TLAAs SER Section 4 16 SER Section 4 Open Item ClosedOI4.3.2.11-1: Effects of thermal aging on cast austenitic stainless steel (CASS)

• Concern: L eak-Before-Break (LBB) TLAA may not be dispositioned correctly

• Resolution: Revised LRA Section4.3.2.11 to identify the fracture mechanics evaluation as a TLAA and disposition it in accordance with 10 CFR 54.21(c)(1)(i); and the material fracture toughness properties selected for use in the LBB analysis are sufficiently embrittled that they bound the amount of thermal embrittlement that will occur in 60years.

17 Conclusion Pending satisfactory resolution of the Open Item, the staff will determine whether the requirements of 10CFR54.29(a) have been

met for the license renewal of STP.

18