ML053360562

Request for Hearing and Petition to Intervene by M. Donato

ML053360562
Person / Time
Site:	Oyster Creek
Issue date:	11/14/2005
From:	Donato M Grandmothers, Mothers & More for Energy Safety, Jersey Shore Nuclear Watch, New Jersey Environmental Federation, New Jersey Public Interest Research Group (NJPIRG), Nuclear Information & Resource Service (NIRS), Sierra Club, New Jersey Chapter
To:	Annette Vietti-Cook NRC/SECY
Julian E
References
50-219-LR, ASLBP 06-844-01-LR, RAS 10793
Download: ML053360562 (37)

Text

DOCKETED USNRC November 14,2005 (5:OOpm)

P. 0. Box 145 106 Grand Central Avenue Lavallctte, NJ 08735 Michele R. Donato A Professioiial Corporation Attorney at Law OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Phone: (732) 830-0777 Telefas: (732) 830-0778 Email: mdonato@.Micl~eleDonatoEsq.com November 1 4, 2005 V I A FEDERAL EXPRESS Annette L. Vietti-Cook, S e c r e t a r y U. S. Nuclear Regulatory Commission Washington, DC 20555-0001 S u b j e c t :

Request f o r Hearing and P e t i t i o n t o I n t e r v e n e

Dear Madam S e c r e t a r y :

On b e h a l f of Nuclear Information and Resource S e r v i c e, J e r s e y Shore Nuclear Watch, t h e New J e r s e y P u b l i c I n t e r e s t Research Group, t h e New J e r s e y Environmental Federation, Gramrnies, t h e New J e r s e y S i e r r a Club, I am e n c l o s i n g an o r i g i n a l and one copy o f t h e f o l l o w i n g :

1.

Request f o r h e a r i n g and p e t i t i o n t o i n t e r v e n e w i t h C e r t i f i c a t e of Service and Notices o f Appearance; 2.

D e c l a r a t i o n s f o r each of t h e P e t i t i o n e r s ;

3.

A f f i d a v i t of D r. Rudolf H. Hausler, P r e s i d e n t, Corro-Consulta; and The e x h i b i t s a r e being posted t h i s day and w i l l be d e l i v e r e d by s e p a r a t e cover.

I n a d d i t i o n, t h e s e documents a r e being f i l e d e l e c t r o n i c a l l y.

P l e a s e f i l e t h e s e documents and t a k e a p p r o p r i a t e s t e p s t o a s s u r e t h a t t h i s r e q u e s t f o r h e a r i n g and p e t i t i o n is processed i n accordance with t h e Code of Federal Regulations.

I f you have any q u e s t i o n s o r problems w i t h r e g a r d t o t h i s p e t i t i o n, p l e a s e a d v i s e immediately.

Otherwise, I a w a i t your c o n f i r m a t i o n a s t o t h e r e c e i p t of t h i s information and i t s f i l i n g.

Thank you.

Very t r u l y yours, I

J,'

.- L Michele R. Donato MRD : dp

Page 2 Encs.

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( b y V I A EMAIL TRANSMISSION ONLY)

Nuclear I n f o r m a t i o n and Resource S e r v i c e J e r s e y Shore Nuclear Watch N e w J e r s e y P u b l i c I n t e r e s t Research Group N e w J e r s e y Environmental F e d e r a t i o n ( w i t h e n c s. )

The New J e r s e y S i e r r a Club ( w i t h e n c s. )

C : \\ F \\ W ; X X S \\ O y s t e i Cre%:.:\\NRC Petition for Hearing\\NRC 1etter.doc

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY In the Matter of 1

Docket No. 50-0219 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN)

)

OYSTER CREEK NUCLEAR 1

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period 1

REQUEST FOR HEARING AND PETITION TO INTERVENE Now come Nuclear Information and Resource Service, Jersey Shore Nuclear Watch, Inc.

Grandmother, Mothers and More for Energy Safety, New Jersey Public Interest Research Group, New Jersey Sierra Club and the New Jersey Environmental Federation hereafter referred to as the Petitioners, hereby make their REQUEST FOR HEARING AND PETITION TO INTERVENE in the above captioned matter, pursuant to the Federal Register Notice of September 15, 2005 [Volume 70, Number 178, Page 54585-545861 and in accordance with the provisions of 10 CFR § 2.714 and § 2.309.

In support of their Request and Petition, said Petitioners as Intervenors further state as follows:

1. Nuclear Information and Resource Service (NIRS) is a nonprofit corporation with over 6000 members, a number of whom live within the State of New Jersey of whom make their residences and places of occupation and recreation within fifty (50) miles of Oyster Creek nuclear generating station (hereinafter referred to as "Oyster Creek"). The central ofice of NIRS is located at 1424 16"' Street NW Suite 404, Washington, DC 20036.

2. Jersey Shore Nuclear Watch, Inc. is a citizen organization located at 364 Costa Mesa

Drive. Toms River, New Jersey 08757 with more than 900 supporters who live within the fifty (50) mile radius of the Emergency Planning Zone of Oyster Creek.

3 Grandmothers, Mothers, and More for Energy Safety is an organization of concerned citizens within the emergency planning zone of the Oyster Creek nuclear generation station. There one hundred and fifty members who either reside, recreate or are employed within the 50 mile emergency planning zone. GRAMMIES is located in Ocean County at 747 Bay Avenue, Brick, New Jersey 08724

4. New Jersey Sierra Club is located at 139 West Hanover Street, Trenton New Jersey 08618. The New Jersey chapter has approximately 23,000 members statewide a number of reside, recreate and work within the 50 mile emergency planning zone for Oyster Creek.

5 New Jersey Environmental Federation is a non-profit organization that is part Clean Water Action with 110,000 members in New Jersey and 90 member groups.

The main oflice is at 1002 Ocean Avenue, Belmar, New Jersey 073 19.

6 New Jersey Public Interest Research Group (NJPIRG) is located at 11 N. Willow St, Trenton, NJ 08608. NJPIRG is a statewide, non-partisan, non-profit, public interest organization with a thirty-three year history of representing both environmental and consumer interests. NJPIRG has 25,000 citizen members, many of whom live within the 50-mile radius of the Oyster Creek nuclear power station.

7. The Declarations of members and supporters are annexed to this Request for a Hearing and Petition to Intervene, with each individual declarant identifying his or her affiliation with each of the petitioning organizations.

8. Petitioners, as organization intervenors, believe that their members' interests will not be adequately represented without this action to intervene, and without the opportunity to participate as full parties in this proceeding. If the Oyster Creek license is extended

without first resolving the Petitioners7-Intervenors' safety concern, this nuclear generating station may operate unsafely and pose an unacceptable risk to the environment and jeopardize the health, safety and welfare of the respective Petitioners' members who live, recreate, and conduct business within the vicinity of the nuclear power station.

Contention of the Petitioners regarding the drywell liner corrosion management propram for the 20-year license extension of the Oyster Creek nuclear generating station The Petitioners contend that the licensee's application is significantly deficient by failing to adequately and reasonably assure the continued integrity for the requested twenty (20) year license extension for the safety-related containment component, the drywell liner or drywell shell, by providing confirmatory ultrasonic testing (UT) measurements at all critical areas of the known degraded component to determine the actual remaining wall thickness of the vitally important containment component. Petitioners contend that failing to due so unreasonably jeopardizes the health and safety of the Petitioners' members. The Petitioners therefore contend that as part of this licensing proceeding that the applicant be required to conduct an adequate number of confirmatory UT measurements using state of the art equipment at 4 levels of the drywell liner, including multiple measurements at the area formerly known as the "sand bed region" and also be required to submit the results to the United States Nuclear Regulatory Commission as publicly available documents as part of this license extension proceeding for the Petitioners' independent review and analysis. The Petitioners further contend that the applicant's new UT measurements at all critical areas, the NRC and the Petitioners' independent analysis shall concur with ASME standards governing the safety limitations of the known degraded drywell liner. The Petitioners further contend that the UT measurements be taken periodically for the life of the reactor at all critical levels of the drywell liner including the area formerly known as the "sand bed region" to include the requested 20-year extension to confirm that the actual corrosion measurements are as projected and that additional UT measurements be greatly expanded into areas not

previously inspected The General Electric Mark I Boiling Water Reactor's (GE Mark I BWR) primary containment system design consists of three large components; 1) the drywell liner; 2) the downcomer vent system and; 3) the torus or wet well. The downcomer vents are large diameter pipes connecting the drywell and the torus which is designed as a large pressure suppression chamber filled with approximately one million gallons of water. The drywell liner is a steel pressure vessel fabricated of ASTM A212 Grade B carbon plate steel in the shape of an inverted light bulb, with a spherical bottom section and an upper cylindrical section. The spherical section is partially embedded in reinforced concrete and transitions into the non-embedded section. The entire non-embedded portion of the drywell liner is enclosed by a reinforced concrete shield wall, separated by a gap or annulus of three inches which is designed to allow for expansion of the drywell liner. The drywell liner is painted on the interior with inorganic zinc and on the exterior with "red lead" identified as TT-P-86 C Type 1.

Both the United States Nuclear Regulatory Commission (NRC) and the applicant have identified the drywell liner as a safety-related structure to be maintained both as a pressure-related boundary and for structural support. It is required to contain and control the release of fission products to the Reactor Building in the event of a Design Basis Accident including a Loss-Of-Coolant-Accident (LOCA) so that the offsite radiation dose consequences to surrounding populations would be within the postulated acceptable limits.' Oyster Creek is the first licensed and oldest operating GE Mark I BWR in the United States. The drywell liner is therefore a primary structure where the assured integrity and design performance is vital to the protection of the health, safety and welfare of the Petitioners members.

On December 8, 1986, NRC Information Notice 86-99: Degradation of Steel Containments (IN 86-99) identified to the nuclear industry that the potential for corrosion of the drywell liner was first recognized in the United States at Oyster Creek in 1980 after

' Oyster Creek Generating Station License Renewal Application, July 2005

water leakage was identified in the gap between the boiling water reactor's drywell liner and the concrete shield

[Petitioners' Exhibit I] The operator began investigation in 1983. The NRC information notice states that the water leakage was identified to be as much as 2 gallons per minute during reheling outages. Ultrasonic testing (UT) was 1

performed on the drywell liner to determine if the leakage had caused damage to the steel containment. IN 86-99 states that investigations to identify the source of the water, at least from one source, observed leakage from the region above the drywell, which is flooded during reheling, to be coming from around bellows and a gasket located at the top of the drywell. There first appeared a loss of metal in a bathtub shaped ring of corrosion at the 11 -foot 3-inch level on the gap side immediately above the concrete floor. In this area, the gap or annulus had been packed with sand and contained five equally spaced drain pipes. A trench was excavated in the concrete floor to reach the inside of the drywell liner. The operator made a total of 143 UT measurements at this level where 60 measurements indicated localized corrosion (pitting) with a reduction in the liner wall thickness of more than %I inch from the drawing thickness of 1.154 inches.

On February 19, 1991, NRC issued Information Notice 86-99, Supplement 1 that determined "Siwce drywell corrosion was detected ill 1986, the licensee instituted periodic wall thickness nleasrtrements by the ultrasoiric testing (UT) techniqrie to determine coi-rosioil rates. The most severe corrosion was found in the sand bed region at a nonzinal elevation of 11 '-3". The highest corrosion rate determined was 35.2-/-6.8 mils per year. To n~itigate the corrosioii in the sand bed region, water was dra~ned.frorn the sand bed and cathodic protectioi~ (CP) was installed in the bays with the greatest wall thinnrlzg in early 1989. Subsequent UT thickness nzeasurenlents in these bays indicated that CP was ineffectzve... In the spherical portion of the drywell above the sam bed, the highest corrosion rate deternmed was 3.6 +/- I. 6 mils per year at a non~iml elei?ation of 51 '. In the cylmdrical portioi? of the drywell above the spherical portion, where minor corrosion was discovered and thought to have originnted nzostly during constritctioi~, no signijcawt wall thinni~lg was detected (at a nominal elevation of 87 7.

However, this 1s the region in which the nominal thickness of wall thickr~ess has the least

' IN 86-99: Degradation of Steel Containments, US NRC. December 8, 1986

margin, thus requiring periodic monitori~rg of actual thickne~s."~

[PETITIONERS' EXHIBIT 21 lnformation Notice 86-99 Sup 1 hrther states, "The licemee believes that a thoi20ugh program has been established for managing leakage that could crfSect dryell integrity due to corrosion from moistwe ingress illto the drywell gap. Recent sriz.veilla~~ce ofthe sand bed drains indicates that the.mid bed ispee of water.

,A Petitioners contend that this of course is nonsensical (as stated) because water will be retained in the pores of the sand bed by capillary forces and continued to support corrosion even though no drainage from the sand bed is observed]

However, the Petitioners note that contrary to the licensee's assertions neither the leakage nor the corrosion was in fact arrested.

The Petitioners submit that NRC stated in its 1992 Safety Evaluation of Oyster Creek's Drywell Integrity, "In I986 the steel diywell liner at Oyster Creek Nuclear Gemrating Station (OCGS) was found to be extensively corroded in the area of the shell which is in coi~tact with sand cushion arorind the bottom of the diywell. Since then GPU Nnclear.

(GPUN, the licensee of OCNGS), has instituted a program of periodic inspection of the drywell shell sand cushion area through zrltrasonic testing ((IT) thickiess measr~rements.

The inspection has bee?? extended to other areas of the d y e l l and some areas above the sandbed region is continzring. In an attempt to eliminate corrosion or reduce the corrosion rate, the licensee tried cathodic protection and fol~zid to be of no m~ail. An exanmation of the results of consecutive UT measruements, corrfirmed that the corrosion is continuing. There is concern that the str~ictural integrity of the drywell can?rot be asswed. Since the root came of the cormsion in the sand bed region is the presence qf w3ater in the sanU: the licensee has considered sand removal to be 01 intportant element in it isprogran~ to eliminate the corrosion threat to the diywell integrity. "'

Information Notice No. 86-99 Supplement 1: Degradation of Steel Containments, US NRC, February 14.

1991 Ibid.

5 Safety Evaluation by the Office of Nuclear Reactor Regulation. Drywell Structural IntegriQ. Oyster Creek Nuclear Generating Station, GPU Nuclear Corporation, United States Nuclear Regulatory Co~ii~nissio~i, April 24, 1992, Introduction.

[PETITIONERS' EXHIBIT 31 The NRC Safety Evaluation noted on completion of their safety review and evaluation

Be stresses obtained for the case of reduced thickness can only he interpreted to represent those 111 the corroded areas and their adjncent regions of the drywell shell. In view of these observations, it is essential that GPtJN continue UT thickness measur.enients at refueling outages and at outages of opportunity for the llfe of the plant.

The nteasurenrents shonld cover not only the areas previously inspected but include accessible areus which have not been inspected so as to confirn~ that the thickness of the corroded areas are as predicted and the corroded areas are localized. "6 The Petitioners contend that the emphasis in the staff finding, and its recommendation, that it is "essential" that GPUN continue UT testing "jor the Ilfe of the plant" at not only previously inspected areas such as areas in the bathtub ring of severe corrosion around the sandbed region of the drywell, but other areas never inspected "so as to conJirm that the thickness of the corroded areas are as projected", be followed.

The Oyster Creek license extension application states at Section 3.5 1 - 13 that ASME Section XI Subsection IWE and 10 CFR 50 Appendix J will be used to manage loss of material for steel elements of the containment including the drywell liner The application identifies that loss of material is considered in a Time Limited Aging Analysis (TLAA) and evaluated in accordance with 10 CFR 54.21(c). The application notes that 'Zo.ss of material in the sand bed regron and on the exterior surfaces of the lipper region of the drywell was ideiitfied as a potential concern in the early 1980 's. As a result the sand was removed from the sand bed region aud a protective coating was applied to the drywell exterior surfaces in that region. The upper regions of the drywell are examined by ultrasonic testing (UT) measurements and evaluated to ensure that the act~lal thickness meets ASME ~.e~~iimnents."~

Ibid, page 5.

7 Oyster Creek Generating Station License Renewal Application, July 2005

The Petitioners are concerned that the protective coating needed to be applied to the bathtub ring of corrosion area over the entire periphery of the outside of the drywell liner or only to the areas where in fact corrosion had been observed or accessible.

The applicant fbrther states in Subsection 3.5.2.2.1.4 that the current normal operating temperature for the drywell varies from 139" F at the lower Elevation Level of 55 feet to 250" F at the higher Elevation Level of 95 feet.

The applicant states that the sand bed region was originally filled with dry sand per ASME 633. The purpose of the sand was to act as a cushion and allow expansion of the drywell during operation. The Petitioners note that the sand was originally installed to prevent buckling of the drywell liner at the transition from the free standing portion of the large and heavy steel component and the embedded portion at the base of the component.

The application states that leakage was observed from the sand bed drains as early as 1980 with mitigation efforts beginning in 1983. The application fbrther states that it was concluded that the optimal method for arresting the corrosion was (1) removal of the sand to break up the galvanic cell; (2) removal of the corrosion from the drywell liner at the sand bed region and; (3) application of a protective coating. Removal of sand was started in 1988 by cutting access holes in the concrete shield wall and completed in 1992. The application states that core samples taken in seven locations of the dry well liner validated UT measurements and confirmed that the corrosion of the drywell liner was due to the presence of oxygenated wet sand and exacerbated by the presence of chloride and sulfate in the sand bed region. The application states that corrective actions taken at this time included cleaning loose rust from the drywell shell followed by an application of a coating of an epoxy material. The application then states that UT measurements were taken after cleaning. The application notes that "There were, however, some areas thimer than projected" but were still within ASME code requirements.

The Petitioners submit that in fact the margins of safety left by severe corrosion damage and compliance are extremely narrow. UT measurements were conducted by GPUN in

1993 on the remaining thickness of the drywell liner at selected elevations According to UT thickness measurements taken from inside of the Oyster Creek drywell and reported in a NRC summary of a meeting with GPUN dated May 05, 1993 several areas were experiencing corrosion, particularly severe in the Sand Bed region of the steel drywell liner:

Drwell Region As Designed Minimum Required Current Thinnest Previous Thinnest 12/92 07/9 1 Cylinder 0.640" 0.580" 0.614" 0.612" Upper Sphere 0.722" 0.650" 0.69 1" 0.695" (Elv. 5 1' to 65')

Middle Sphere 0.770" 0.670" 0.743" 0.745" (Elv. 23 ' to 5 1 ')

Sand Bed 1.154" 0.736" 0.800" 0.803" (Lowest Region)

(Source: US NRC)'

[PETITIONERS' EXHIl3IT 41 The Petitioners submit that in 1992, UT measurements indicated that as little as.064 inches remained between as found and minimum required.

All drywell liner bays showed presence of a "Bathtub Ringn-an 8 to 18 inch wide band about 30 to 40 inches long-containing similarly heavily corroded areas. At that time GPUN management made the comment to NRC "The integrity of the Oyster Creek Drywell remains a priority concern of GPUN management, we will continue UT thickness n~easurements.for the life of the plant (emphasis added)"g

[PETITIONERS' EXHmIT 51 8 Sununary of May 05, 1993 Meeting with GPU Nuclear (GPUN) To Discuss Matters Related to the Oyster Creek Drywell Corrosion mtigation Program, US NRC, May 17, 1993, Enclosure 2, Summan of 14R UT Thickness Measurements (Taken froin Inside Drywell).

Ibid. May 05, 1093, GPUN Conclusions

Oyster Creek's 15"' Reheling Outage in September 1994 was the last time that UT measurements were taken at the sandbed region of the drywell liner. The UT measured minimums at the sand bed region were recorded at 0.806 inches while the Code required 3 736 inches as determined by buckling calculations for the drywell liner.'"

[PETITIONERS EXHIBIT 61 At that time the operator submitted that there was 2vidence of ongoing corrosion in the upper regions and sand bed region of the dry well liner which was cleaned of sand and rust and coated in December 1992. At that time, GPU Nuclear stated that "after 21 months of service, the coating is performing

,,I 1 satisfactory ~ ' i t h no signs of deteriorntiol~ such as blisters,.flakes, discolomtio~~,

etc.

GPU in their letter of 9/15/95 estimated that the life of the epoxy coating would be 8-10 years, bringing it to the end of its life between December 2000 and December 2002.

The Petitioners contend that the applicant does not indicate whether visual coating inspections since the original application have been made specifically for pinhole leaks in the coating which could allow for water seepage behind the epoxy coating resulting in corrosion behind the coating on the exterior surface of the already degraded component.

Because the remaining measured margin of,064 inches in an unknown number of locations within the severely corroded sand bed region is so extremely narrow, Petitioners contend that the described observable blisters, flakes and discoloration do not need to occur before the component is in fact outside of safety tolerances due to ongoing corrosion behind the coating. In fact, the applicant's reliance upon only visual examinations may not actually be able to observe corrosion of the exterior liner to below tolerances at such narrow margins. The Petitioners have consulted their expert, Dr.

Rudolph Hausler of Corro-Consulta (See attached Affidavit), on this matter of fact, who supports this contention.

The application states at Page 3-5-20 that the Protective Coating Monitoring Program 10 Oyster Creek Dry Well Corrosion Monitoring Program, GPUN, September 15, 1995. Tablc 1.

I I Ibid.. Oyster Creek Monitoring Program 1995

was revised to include monitoring of the coating at the former sand bed region. The application does not specify the degree of inspection, other than visual, merely stating.

"The coated szq$aces were inspected during refireling outages of 1996, 2000 and 2004.

The inspections showed no coating failure 01. signs of deterioration. It is therefore concluded that corrosion in the sand bed region has been arrested and no flirther loss of nraterial is expected. "

However, the Petitioners point out that the application does not indicate that the coated areas were ever inspected specifically for pinhole leaks in the coating at any time since the application in 1992. As such, the Petitioners fiirther contend that wet conditions occurring over the past 12 years behind the epoxy coating can reasonably contribute to corrosion. For this reason, the Petitioners contend that confirmatory UT inspections with state of the art equipment must be employed so as to ascertain the actual remaining wall thicknesses of this safety structure.

As is stated in the Oyster Creek Inservice Inspection Report dated February 16, 2005 inspections of the drywell liner were conducted between October 28, 2004 and November 22, 2004 during the 20"' Refueling Outage. I 2 [PETITIONERS EXHIBIT 71 The IS1 includes Attachment 1 "NIS-1 Owner's Data Report for Inservice Inspections performed in accordance with ASME Code,Section XI, 1995 Edition with Addenda.

In Attachment 1 entitled Oyster Creek Generating Station IS1 Post 1R20 Outage Summary Report under "Abstract of Examinations and Tests" of the submittal AmerGen states: '7n addition, vi.mal and UT exan~inations were completed 011 the dyvell and torus 117 accordance with ASME Section IWE (Containnrent Pi.ogranl). In smrnzary, ah' excmrinations Icere conpleted successfzrlly. '"' Form NIS-1 for Containment IS1 Program-IWE "Abstract of Examinations and Tests" states: "Oyster Creek is at the end of the secondperiod of the first inspection 12 Oyster Creek Generating Station Refueling Outage 20 (1R20) Inservice Inspection Report (ISI)

Sumrnary Report, Amergen, February 16, 2005.

13 Ibid, Attachment 1; p. 3.

irrternal for containmerlt inspections. These examirzatiorzs were performed to fillfill the requrrements of ASME Sectiorl XI, 1 992 Edition with the 1 992 Addenda. Examinations were performed on all accessible areas of the interior mid exterior of the dryr~ell and torzrs sz~ppression chamber. The algmented exanlirmtiorl of the drpvell liner and exterior sarrd bed area was perjornled. "' '

The Petitioners submit that close examination of TABLE I-Contaiment IS1 Program pages 1-17 and particularly in regard to all documented inspections of the drywell and drywell liner, the only identified "Method" provided by AmerGen was "VT-G or Visual Testing. There are no designations or indications that any "UT" or Ultrasonic Testing was specifically conducted on the drywell liner. In fact, there are no values for drywell liner wall thicknesses assigned or provided at any levels of the containment component including the Upper Sphere, Middle Sphere and Sand Bed Region in the 2005 report for the 2004 inspections.

The Petitioners hrther submit the NRC meeting summary of May 12, 2005 covering the Annual Assessment with AmerGen which states "The licensee has wsually irrspected the coating applied to the liner in the sandbed region in 1996, 2000 and 2004. The viszral inspectiori determined the coating repair is iri very good conditior I. For I-egions above the sandbed, ultrasonic inspections have been periodically completed for the areas that exhibited the worst corrosion in 1992, 199 6, 2000, and 2004. No signrficant degradation has been identrfied.for the regions above the sandbed. " l5

[PETITIONERS EXHIBIT 81 Petitioners hrther submit NRC document "Changes in the Oyster Creek Drywell Monitoring Program" (TAC No. M93658) dated November 1, 1995. I 6 [PETITIONERS' EXHIBIT 91. As is stated, in a letter dated September 15, 1995, GPU Nuclear stated that they had assessed the condition of the drywell and that they remained committed to 14 bid, Attachment 2, p. 4 15 Summary of May 12. 2005, Annual Meeting Assessment Meeting with AmerGen. Oyster Creek Generating Station. United States Nuclear Regulatory Commission, June 21, 2005, page 6.

16 "Changes In The Oyslcr Creek Drywcll Monitoring Program" (TAC No. M93658). US NRC, dited Novmeber 1, 1995.

continue taking drywell thickness measurements for the life of the plant.

GPUN had also requested a reduction in the monitoring program to discontinue UT measurements at the former sand bed region based on UT examinations during the 15"'

refbeling outage. The document states that NRC accepted the GPUN proposed examination reduction and GPUN's commitment to additional inspection at the sand bed region within approximately 3 months after discovery of water leakage from the pools above the reactor cavity.

Petitioners submit and contend that this NRC staff evaluation was based on the 40-year license and did not contemplate and analyze a twenty-year license extension. Petitioners submit that lesser spills of water which could also include corrosive borated water from the refbeling canal or leaks in the spent fbel pool could be taking place and therefore justifies the Petitioners' reasonable request that confirmatory inspections be made at the level of the component which was found to be the most severely corroded area and subjected only to visual exams of the coating since 1994.

Therefore, the Petitioners submit that no UT measurements have been made at the severely corroded sandbed region, which in fact experienced the most severe known corrosion, and at present still has the closest remaining margins (0.064 inches or less) on this safety-related structure since the epoxy coating was originally applied in 1992. The Petitioners fbrther submit that the applicant has not provided reasonable assurance that the epoxy coating has been adequately monitored for all possible methods of leakage behind the coating including pinhole leaks that could provide a pathway for water intrusion and subsequent corrosion.

It is clear to the Petitioners that the epoxy coating in and of itself is not the structural load bearing or pressure boundary on this safety-related structure but in fact the remaining dry well wall thickness that is of paramount concern to the Petitioners. The Petitioners therefore contend that it is unreasonable to rely on solely on visual inspections of the condition of the coating for expectations of containment performance for an additional twenty years.

The Petitioners contend that the burden of proof is now on the applicant with its request for an additional 20-year license extension to provide the reasonable assurance with physical measurements as evidence that the actual remaining drywell wall thickness have enough margin to meet the applicable ASME requirements through confirmatory state-of-the-art UT measurements which in the discovery of the degree of the severe corrosion both NRC and the operator of Oyster Creek had previously deemed necessary "$or the Ife qf the plant" in order to assure public safety. Arguably, the Petitioners contend that this must certainly apply to a re-licensing proceeding for the 20-extension of "the Ife of the plant. "

The Petitioners hrther provide the affidavit of Dr. Rudolph Hausler, Corro-Consulta, in support of their contention in the matter of American Energy Company, LLC application to extend the operation license of Oyster Creek nuclear power station by twenty years.

Signed,

/

Michele Donato November 14,2005

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY

)

In the Matter of 1

Docket No. 50-0219 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN)

)

OYSTER CREEK NUCLEAR

)

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period

)

CERTIFICATE OF SERVICE I hereby certify that the foregoing Request for Hearing and Petition to Intervene was sent this 14"' day of November, 2005 via email and U.S. Postal Service as designated to each of the following:

Secretary of the Commission (Email and 2 copies via U.S Postal Service)

United States Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemaking and Adjudications Staff Email: HEARINGDOCKET@,NRC.GOV Office of General Counsel (Email and U.S. Postal Service)

United States Nuclear Regulatory Commission Washington, DC 20555-0001 Email :.~G.~.~~ilC.ee!!~er@nrc1g~.v Kathryn Sutton, Esq. (U.S. Postal Service)

Morgan, Lewis, & Boikus LLP 11 11 Pennsylvania Avenue, NW Washington, DC 20004 Paul Gunter (Email and U.S. Postal Service)

Nuclear Information and Resource Service 1424 16th St. NW Suite 404 Washington, DC 20036 Email: pgunter@nirs.org

Certificate of Service (continued)

Edith Gbur (Email and U.S. Postal Service)

Jersey Shore Nuclear Watch, Inc.

364 Costa Mesa Drive. Toms River, New Jersey 08757 Email: gburl @&omcast.net Paula Gotsch GRAMMIES 205 6"'Avenue Normandy Beach, New Jersey 08723 Kelly McNicholas New Jersey Sierra Club 139 West Hanover Street Trenton New Jersey 086 18 Email: Kelly.McNicholas@sierraclub.org Suzanne Leta New Jersey Public Interest Research Group 11 N. Willow St, Trenton, NJ 08608.

Email: sletaanj pirg.org Peggy Sturmfels New Jersey Environmental Federation 1002 Ocean Avenue Belmar, New Jersey 073 19 Email: psturmfels@cleanwater.org Michele Donato, Esq.

PO Box 145 Lavalette, NJ 08735 Email: mdonato@micheledonatoesq.com Signed Michele Donato, Esq.

Novmeber 14, 2005

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY 1

In the Matter of

)

Docket No. 50-02 19 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN)

)

OYSTER CREEK NUCLEAR 1

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period

)

NOTICE OF APPEARANCE FOR MICHELE DONATO, ESQ Pursuant to 1 0 CFR 2.7 133(b), Michele Donato, Esquire, hereby enters an appearance on behalf of Nuclear Information and Resource Service (NIRS), Jersey Shore Nuclear Watch, Inc. (JSNW), Grandmothers, Mothers and More for Energy Safety (GRAMMIES), New Jersey Public Interest Research Group, New Jersey Sierra Club, and New Jersey Environmental Federation provides the following information:

1. I am an attorney licensed to practice law in New Jersey. My offices are located at 106 Grand Central Avenue, Lavallette, N.J.

2. 1 have been appointed by the petitioners to jointly represent these organizations in this proceeding.

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- L Michele Donato, Esq 1 1/14/2004 Date

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY 1

In the Matter of

)

Docket No. 50-02 19 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN)

)

OYSTER CREEK NUCLEAR

)

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period

)

NOTICE OF APPEARANCE OF PAUL GUNTER Pursuant to 10 CFR 2.7133(b), Paul Gunter hereby enters an appearance on behalf of Nuclear Information and Resource Service (NIRS) and provides the following information:

1. I am Director of the Reactor Watchdog Project at Nuclear Information and Resource Service at 1424 16"' Street NW Suite 404, Washington, DC 20036, Tel. 202 328 0002.

2. I have been appointed by NIRS to represent the organization and its New Jersey members in this proceeding.

IS/ Paul Gunter Paul Gunter 11/14/2004 Date

N O V - 1 4 - 2 0 0 5 11:55 Frorn:SRVE ERRNEGRT ERY 732F306670 UNITED STATES OF AMERICA BKFOKE '1'Hk; N LICLEAK KEC;ULA'l'OKY COMMISSION OFFICE OF 'I'HE SEC'lUC'l'AHY

)

111 the Matter of

)

Docket No. 50-0219 AMERICAN ENERGY COMPANY, T T,C (ALSO KNOWN AS AMERGEN)

)

OYS 1gK C'lUEK NUCLEAR

)

GENERATING STATION

)

NOVT;.MRER 14,2005 Rcga rdi ng the Renewnl of Facility Opel-ating Liccnsc No. DPR-16 for a,&Year Period 1

T)EC,'I,ARATION OF WILLIAM cleCAMP,TR.

IN SUPPORT OF PETITION TO REQUEST A HEARING AND LEAVE TO TNTERVENE ON

'I'HE OYSTER CREEK LICENSE RENEWAL APPLICATION 1.) My name is William decamp Jr. 1 am a member oSNuclear InSurmr-llion and Kcso~u+ce Service.

2. ) 1 haw a rcsidcncc at I 223 Bay Avenue, Mmtoloking, NJ. My honlc lies within eigh1et.n miles 01'~hc Oystcr Crcck nuclear povwcr station sitc in 'l'oms Kivcr Ncw Jcrscy, OCVIIL'~ by A.mei-Oen. The applicanl, A~iiericiin Energy Company, LLC a. subsidiary 01' Exdurn Nuclear Cnrpnrntion, has npplied ro rhe 7J.S. Nuclear Regulnrnry C ~ l l ~ ~ i i i ~ s i ~ ~ l

3) I bclieve thdt the application for a license extension of the (Iyster Creek nuclear generaling skativrl is sufiicicntly imdcquatc as w~ittcn and 1ny intcrcsts will not bc adcquntely represenied wih)ul Lhis action lo inlcrver~t: arid wi~houl [he opporlunily ol'

VIRS LO parlicipalc as a lit11 party in this procccdi~lg on m y bchalf. If thc Oystcr C'rcck Nuclear Generaling S~nlion licenst-is rt.ncwtd without resolving the I'ctitiunrrs' salt~y conccrn, this nuclear generating slalion may oprrale unsulkly and pose a11 unacceptnhle risk tu 111~ cnvirorltncnt, tllcrcby jeopardizing rile health and welfare of r11e respective Petitioners'-Intervenors' rnembcrs who live. rccrcatc and ha-vc busincsscs within thc vicinity of the nuclear power reactor. J an1 concerned ihal if an accident were l o occur a1

[he Oystcr Crcck nuclcnr generating stntion I mighr be IiilIed, serioudy injured or sickened 17y lie I-adiortc~ivc releases.

Dare

IJNI'I'ED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY 1

In the Matter of 1

Docket No. 50-02 19 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMEGEN) 1 OYSTER CREEK NUCLEAR

)

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period

)

DECLARATlON OF EDITH GBUR IN SUPPORT OF PETITION TO REQUEST A HEARING AND LEAVE TO INTERVENE ON THE OYSTER CREEK LICENSE RENEWAL APPLICATION The following statemenls are true under the penalty of perjury.

I.) My name is Edith Gbur. I am President of Jersey Shore Nuclear Watch, Inc. (JSNW).

3.) I have a residcnce at 364 Costa Mesa Drive, 'I'oms River New Jersey. My home lies within 10 miles of the Oyster Creek nuclear power station site in Toms River New Jersey, owned by AmerGen. Thc applicant, American Energy Company, L I E a subsidiary of Exelon Nuclear Corporation. has applied to the U.S. Nuclear Regulatory Commission

("NRC") for a twenty (20) year license extension.

3) I believe that the application for a license extension of the Oyster Creck nuclear gcncrating station is sufficiently inadequate as written and my interests will not be adequately represented without this action to intervene and without the opportunity of the Petitioner to participate as a full party in this proceeding on my behaIf. If the Oyster

Creek Nuclear Gcnerating Station license is renewed without resolving the Petitioners' stated safety concern, this nuclear generating station may operate unsafely and pose an unacceptable risk to the environment. thereby jeopardizing the health and welfare of the respective Petitioners'-Intervenors' members who live, recreate and have businesses within the vicinity of the nuclear power reactor.

UNITED STATES OF AMERICA BEFORE THE NUCLEAR IiEGULATORY COMMISSION OFFICE OF THE SECRETARY 1

In the Matter of 1

Docket No.50-021 9 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN)

)

OYSTER CREEK NUCLEAR

)

GENERATING STATION

)

NOVEMBER14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period 1

DECLARATION OF NEW JERSEY PUBLIC INTEREST RESEARCH GROUP IN SUPPORT OF PETITION TO REQUEST A HEARING AND LEAVE TO INTERVENE ON THE OYSTER CREEK LICENSE RENEWAL APPLICATION The following statements are true under the penalty of pe jury.

1.) My name is Suzanne Leta. I am a member of New Jersey Public Interest Research Group.

2.) My work address is 11 N. Willow St, Trenton, New Jersey 08608 and my home address is 60 Paterson St, Apt 701, New Brunswick, NJ 08901. My home and my workplace are within 50 miles of the Oyster Creek nuclear power station site in Lacey

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New Jersey, owned by ArnerCcn. The applicant, American Energy Company, LLC a subsidiary of Exelon Nuclear Corporation, has applied to the U.S. Nuclear Regulatory Commission ("NRC") for a twenty (20) year license extension.

3) I believe that the application for a license extension of the Oyster Creek nuclear generating station is sufficiently inadequate as written and my interests will not be

adequately represented without this action to intervene and without the opportunity of the Petitioner to participate as a full party in this proceeding on my behalf. If the Oyster Creek Nuclear Generating Station license is renewed without resolving the Petitioners' stated gfety concern, this nuclear generating station may operate unsafely and pose an unacceptable risk to the environment, thereby jeopardizing the health and welfare of the respective Petitioners'-Intervenors' members who live, recreate and have businesses within the vicinity of the nuclear power reactor. My concerns focus on the possibility that if Oyster Creek's liccnsc is renewed without resolving the stated safety issues a nuclear accident could result that causes the death or sickening of myself and my family.

Date

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY In the Matter of 1

Docket No. 50-0219 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN) 1 OYSTER CREEK NUCLEAR 1

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Y ear Period

)

DECLARATION OF A m

GOLDSlMITH AS A MEMBER OF THE NEW JERSEY EhWIRONMENTAL FEDERATION TSV SUPPORT OF PETITION TO REQUEST A HEARING AND LEAVE TO INTERVENE ON TBE OYSTER CREEK LlCENSE RENEWAL APPLICATION The following statements are true under the penalty of perjury.

1.) My name is Amy Goldsmith. I am a member of the New Jersey Environmental Federation.

2.) 1 have a residence at 16 Locust Avenue, Red Bank, New Jersey 0770 1. My home lies within 50 miles of the Oyster Creek nuclear power station site in Lacey Tomuship, New Jersey, owned by AmerGen. The applicant, American Energy Company, LLC a subsidiary of Exelon Corporation, has applied to the U. S. Nuclear Regulatory Commission ("NRC") for a twenty (20) year license extension.

3) I believe that the application for a license extension of the Oyster Creek nuclear generating station is sufficiently inadequate as written and my interests will not be adequately represented without this action to intervene and without the opportunity of thc OEEE 13fd3SHl dH t2:St SO02 tt fiON

Petitioner to participate as a full party in this proceeding on my behalf. If the Oyster Creek Nuclear Generating Station license is renewed without resolving the Petitioners' stated safety concern, this nuclear generating station may operate unsafely and pose an unacceptable risk to the environment, thereby jeopardizing the health and welfare of the respective Petitionersy-Intervenors' members who live, recreate and have businesses within the vicinity of the nuclear power reactor. My concerns focus on the possibility that if Oyster Creek's license is renewed without resolving the stated safety issues a nuclear accident could result that causes the death or sickening of myself and my family.

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY 1

In the Matter of

)

Docket No. 50-0219 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN) 1 OYSTER CREEK NUCLEAR 1

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period 1

DECLARATION OF PAULA GOTSCH IN SUPPORT OF PETITION TO REQUEST A HEARING AND LEAVE TO INTERVENE ON THE OYSTER CREEK LICENSE RENEWAL APPLICATION The following statements are true under the penalty of perjury.

1.) My name is Paula Gotsch. I am a member of Grandmothers, Mothers and More for Energy Safety (GRAMMIES).

2.) I have a residence at 205 Sixth Avenue, Normandy Beach, New Jearsey. My home lies within 50 miles of the Oyster Creek nuclear power station site in Lacey Township, New Jersey, owned by AmerGen. The applicant, American Energy Company, LLC a subsidiary of Exelon Nuclear Corporation, has applied to the U.S. Nuclear Regulatory Commission ("NRC") for a twenty (20) year license extension

3) I believe that the application for a license extension of the Oyster Creek nuclear generating station is sufficiently inadequate as written and my interests will not be adequately represented without this action to intervene and without the opportunity of the

Petitioner to participate as a full party in this proceeding on my behalf. If the Oyster Creek Nuclear Generating Station license is renewed without resolving the Petitioners' stated safety concern, this nuclear generating station may operate unsafely and pose an unacceptable risk to the environment, thereby jeopardizing the health and welfare of the respective Petitioners'-Intervenors' members who live, recreate and have businesses within the vicinity of the nuclear power reactor. My concerns focus on the possibility that if Oyster Creek's license is renewed without resolving the stated safety issues a nuclear accident could result that causes the death or sickening of myself and my family x9

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signature Date

UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY 1

In the Matter of 1

Docket No. 50-02 19 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN)

)

OYSTER CREEK NUCLEAR 1

GENERATING STATION

)

NOVEMBER 14,2005 Regarding the Renewal of Facility Operating License No. DPR-16 for a 20-Year Period DECLARATION OF JANET TAURO IN SUPPORT OF PETITlON TO REQUEST A HEARING AND LEAVE TO INTERVENE ON THE OYSTER CREEK LICENSE RENEWAL APPLlCATION The following statements are true under the penalty of perjury.

1.) My name is Janet Tauro. I am a member of Grandmothers, Mothers and More for Energy Safety (GRAMMIES).

2.) 1 have a residence at 747 Bay Avenue, Brick, NJ. My home lies within 50 miles of the Oyster Creek nuclear power station site in Toms River New Jersey, owned by ArnerGen. The applicant, American Energy Company, LLC a subsidiary of Exelon Nuclear Corporation, has applied to the U.S. Nuclear Regulatory Commission ("NRC")

for a twenty (20) year license extension

3) I believe that the application for a license extension of the Oyster Creek nuclear generating station is sufficiently inadequate as written and my interests will not be adequately represented without this action to intervene and without the opportunity of the

Petitioner to participate as a full party in this proceeding on my behalf. If the Oyster Creek Nuclear Generating Station license is renewed without resolving the Petitioners' stated safety concern, this nuclear generating station may operate unsafely and pose an unacceptable risk to the environment, thereby jeopardizing the health and welfare of the respective Petitioners'-Intervenors' members who live, recreate and have businesses within the vicinity of the nuclear power reactor. My concerns focus on the possibility that if Oyster Creek's license is renewed without resolving the stated safety issues a nuclear accident could result that causes the death or sickening of myself and my family.

NJSIERRA NJbltW UNlTED STATES OF AMERICA BEPORE T m NVmEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY J

In the Matter of Docket No. 50-02 19 AMERICAN ENERGY COMPANY,LLC (ALSO KNOWN AS AMERGEN) 1 OYSTER WEK NUCLEAR OENETtATRJG STATION 1

)

NOVEMBER 14,2085 Regarding rlzc Rbntwd of 'Facility L~oQ~%B No. DPR-16 for a 2 0. Y ~

Petid 1

PAGE 02 r

UI)L DECLARATION OF GW!23 AUWE.WHA IN 3UPPoRT OF PETITION TO REQUEST A ~~G AND LEAVE TO MTERVJ?NE ON THE OYSTER CREEK LICXNSE RENEWAL APPLICATION 2.) 1 havF a m i h e st SO KETTLE CREEK DRIVE, BRTCK, NEW JERSEY, 08723, My home lies within 50 miles of the Oyster Creek nuclew power trtation sitt in Lacey U C a subsidiary of Exdun Nucleru Corporation, has applied to the U.

S. Nuclear

3) I bdiavr that the applkatian for a liccnst extension of the Oysta Creek nuclw d o t 1 io dcimtly inadequate kq written and my intsrests will not be adaquattly reprEstnttd without this actloo to intervene and without the opportuntty of the Fatitioner to parchipaw a8 a Pull MY in tb~s proceeding on my beMf If the Oyster

NJSIERRA NISIERRA PAGE 03 PAGE 83 Creek Nuoldar Otncruting Statjon liccnst ie renewed without rewlvlng the Petitioners' stand safety canctm, M a nuclcar generating station may operate &ely and pse an

@ve Petititioms'-lnts~lons' members who live m t

e and have businesses Mbiu the vicinity of the nwlorr pow reactor. My oancerns focus on th8 possibility that if @stm Ctcch'a license is renewed without resolving the ttated safety isawta n owla acddont could rc9Wt that c-the death ur skkenhg of myself sad my family

,,A-NOVEMBER 14, 2005 D*

8081 Diane Drive Tel: 972 962 8287 (oJke)

Tel: 972 824 5871 (mobile)

CORR~CONSULTA Rudolf H. Hausler rzrdyhau@nzs~~.

con2 To:

Mr. Paul Gunter, Director Reactor Watchdog Project Nuclear Information and Resource Service Washington DC 10036 Kaufinan, TX 75 142 Fax: 972 932 3947 November 10, 2005 From: Dr. Rudolf H. Hausler, President Corro-Consulta

Subject:

Oyster Creek Drywell Liner Corrosion A. Definition of the Problem Localized corrosion had been observed on the outside wall of the dry well containment vessel of the Oyster Creek nuclear reactor as early as 1986. The corrosion was localized in the "sand bed area" at an elevation of about 1 lft above the concrete floor. Detailed investigation in 1992 and 1994 determined a thinning of the wall from 1.154 inches to about 0.800 inches. (This calculates to an average local penetration rate - pitting rate - of about 15.4 mils per year). Structural integrity calculations indicated a minimum safe allowable remaining wall thickness in the corroded areas of 0.75 inches. In 1994 the sand bed was apparently removed and the corroded areas coated with an epoxy coating. At this time little is known about the nature of the coating, the manner in which it was applied, and its thickness.

Hence, the question arises whether in the period from 1994 to 2005 the coating prevented additional corrosion and whether the structure is still safe enough to be certified for an additional 20 years of operation. It has been proposed to verify this proposition by visual inspection, and use this methodology to ascertain that no additional corrosion has further impaired the integrity of the vessel.

B. The Apparent Operating Conditions It had been stated that the inside temperature of the dry well had been raised in 1994 from 175 OF to 292 OF. This latter temperature, which should have prevailed during normal operation of the reactor from 1994 to the present, would have been high enough to prevent the presence of liquid water in the corroded, coated, area on the outside wall of the dry well vessel. However, this temperature, even taking into account a lowering of the temperature on the outside of the vessel wall due to heat flux, would still be high enough to cause slow deterioration of the epoxy coating. Such deterioration in and of it self Oyster Creek D n Well Corrosion Corro-Consulta

would not have been a concern provided that no liquid water would ever be present in this area. This condition, however, could not ever be ascertained because, as has happened before (primary cause of corrosion), water could and can enter the space between the concrete containment and the dry well wall during refbeling and other non-planned outages. Deteriorated epoxy coating and the presence of liquid, oxygen containing, water would certainly lead to additional localized corrosion. (The drain channels, which had been added to drain the sand bed cannot possibly be effective enough to drain all water from the area and prevent condensation if conditions were right for such to occur).

It turns out, however, that newer information indicates that the conditions specified in 1994 were not strictly maintained. Apparently the temperatures inside the dry well vary from 135 OF at the 55 R elevation to 250 OF at 95 R. This temperature gradient would certainly allow for liquid water presence at the 11 ft elevation (Sandbed), i.e. in the annular space were previously the sandbed was located.

Epoxy resins in contact with water can, depending on the nature of the epoxy and the prevailing temperature, deteriorate over time. Furthermore, the application of epoxy resins on metal surfaces may result in holidays (pinholes) depending on surface preparation, the curing process, and general cleanliness. There is, therefore, no guarantee that the epoxy coating prevented fbrther growth of existing pits.

C. Direct Assessment of Additional Corrosion.

It has been proposed that visual observation of the damagedlcoated areas would be sufficient to verify that no additional corrosion had occurred. Additional severe corrosion would in deed manifest itself by the formation of rust, which would lead to blistering and cracking of the epoxy coating, and could be observed visually by means of fiberoptic devices. (Note that the epoxy may have thermally, or otherwise, deteriorated over time to a point where it is no longer transparent, if it ever was). However, the absence of such observations does not necessarily mean that no additional corrosion occurred in the pitted areas. As a consequence it would appear absolutely essential that at this point direct assessment of the integrity of the vessel is unavoidable. The last UT measurements in 1994 indicated a minimum wall thickness of 0.8 inches. The minimum allowable wall thickness for safe operation had been given as 0.75 inches. A fbrther deterioration of 0.05 inches over 11 years would mean an average local penetration rate of the order of 0.005 inches (5 mils per year). This small pitting rate is absolutely possible and would not necessarily lead to a visible deterioration of the epoxy coating. UT measurements through the epoxy coating are highly questionable and lack in accuracy. Therefore, the coating has to be removed and pit depth assessment has to be made with the best applicable methodology. UT measurements on the outside of the vessel wall are very difficult and have to be made by highly technically trained personnel. Optical pit depth measurements are no doubt more reliable.

Oyster Creek Dry Well Corrosion Corro-ConsultA

It is understood that it is impossible to examine the entire circumference of the dry well vessel at the elevation where the "bathtub ring" appeared. Since it is only possible to examine relative small areas through access channels bored into the concrete containment, it will be necessary not only to find and measure the deepest pit, as had been done before, but in fact to measure all accessible pit depths. This needs to be done through a number of access channels and the complement of all so measured pit depths needs to be evaluated by extreme value statistics in order to extract the deepest probable pit with some reasonable probability. This procedure of determining the most probable deepest pit with a probability of say 99.9% has not been done before and must, in the opinion of this writer, be done before this reactor, and in fact any other reactor with the same problem, can be handed over for an other 20 years of safe operation. (Note: previously it had been thought that a 95% confidence limit was sufficient. There is a real question whether that kind of probability limit is adequate for nuclear reactor operation).

Signed, Oyster Creek D n Well Corrosion Corro-Consulta