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Transcript for Advisory Committee on Reactor Safeguards - License Renewal Subcommittee (Duane Arnold), Pages 1-186
	ML101720552
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Site:	Saint Lucie, Point Beach, Seabrook, Turkey Point, Duane Arnold
Issue date:	06/08/2010
From:	Kathy Weaver; Advisory Committee on Reactor Safeguards
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	NRC-288
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

Advisory Committee on Reactor Safeguards License Renewal Subcommittee Docket Number:

(n/a)

Location:

Rockville, Maryland Date:

Tuesday, June 8, 2010 Work Order No.:

NRC-288 Pages 1-134 NEAL R. GROSS AND CO., INC.

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

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

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1 2

4 DISCLAIMER 3

5 UNITED STATES NUCLEAR REGULATORY COMMISSIONS 6

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 7

8 9

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

14 15 This transcript has not been reviewed, 16 corrected, and edited, and it may contain 17 inaccuracies.

18 19 20 21 22 23

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UNITED STATES OF AMERICA 1

NUCLEAR REGULATORY COMMISSION 2

+ + + + +

3 ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 4

(ACRS) 5

+ + + + +

6 LICENSE RENEWAL SUBCOMMITTEE 7

+ + + + +

8

TUESDAY, 9

JUNE 8, 2010 10

+ + + + +

11 ROCKVILLE, MARYLAND 12

+ + + + +

13 The Subcommittee convened at the Nuclear 14 Regulatory Commission, Two White Flint North, Room 15 T2B1, 11545 Rockville Pike, Rockville, Maryland at 16 8:30 a.m., Dr. Dennis Bley, Chairman, presiding.

17 SUBCOMMITTEE MEMBERS PRESENT DENNIS C. BLEY, Chair 19 18 J. SAM ARMIJO 20 MARIO V. BONACA 21 HAROLD B. RAY 22 WILLIAM J. SHACK 23 JOHN D. SIEBER 24 JOHN W. STETKAR 25

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1 CONSULTANTS TO THE SUBCOMMITTEE PRESENT JOHN J. BARTON 3

2 4

NRC STAFF PRESENT KATHY D. WEAVER, Designated Federal Official 6

5 BRIAN HOLIAN 7

BRIAN HARRIS 8

BENNY JOSE 9

CLIFF DOUTT 10 ABDUL SHEIKH 11 12 ALSO PRESENT CHRIS COSTANZO 14 13 KEN PUTNAM 15 MIKE FAIRCHILD 16 CURT BOCK 17 CLARA RUSHWORTH 18 ERIC SORENSON 19 AL THOMAS 20 21 22 23 24 25 26

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T-A-B-L-E O-F C-O-N-T-E-N-T-S 1

WELCOME/OPENING REMARKS Dennis Bley, Chair........................... 4 3

2 STAFF INTRODUCTION/REMARKS Brian Holian, NRR............................ 5 5

4 DUANE ARNOLD ENERGY CENTER PRESENTATION Chris Costanzo, DAEC......................... 8 7

6 Ken Kleinheinz, DAEC........................ 16 8

Ken Putnam, DAEC......................... 32/44 9

Mike Fairchild, DAEC........................ 39 10 NRC STAFF PRESENTATION, SER OVERVIEW Brian Holian, NRR........................... 99 12 11 Brian Harris, Region III.................... 99 13 Benny Jose, Region III..................... 102 14 SUBCOMMITTEE COMMENTS/DISCUSSION:................ 130 15 ADJOURN Dennis Bley................................ 134 17 16 18 19 20 21 22 23 24

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P-R-O-C-E-E-D-I-N-G-S 1

8:27 a.m.

2 CHAIR BLEY: Good morning. The meeting 3

will now come to order. This is a meeting of the 4

Plant License Renewal Subcommittee. I'm Dennis Bley, 5

Chairman of this Subcommittee meeting.

6 ACRS Members in attendance are: John 7

Stetkar, William Shack, Harold Ray, Mario Bonaca, Jack 8

Sieber, Sam Armijo.

9 I said Harold, right? Harold Ray.

10 MEMBER SHACK: You said William.

11 CHAIR BLEY: I did. I read it. John 12 Barton our consultant is also present.

13 Cathy Weaver of the ACRS staff is the 14 Designated Federal Official for this meeting.

15 The Subcommittee will review the license 16 renewal application for the Duane Arnold Energy Center 17 and the Associated Draft Safety Evaluation Report with 18 Open Items.

19 We will hear presentations from NRC staff 20 and FPL energy, Duane Arnold, LLC representative and 21 other interested persons regarding this matter.

22 We have received no written comments or 23 requests for time to make oral statements from members 24 of the public regarding today's meeting.

25

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This meeting will be open to public 1

attendants.

2 The Subcommittee will gather information, 3

analyze relevant issues and facts and formulate 4

proposed positions and actions as appropriate for 5

deliberation by the full Committee.

6 The rules for participation in today's 7

meeting have been announced as part of the notice of 8

this meeting, previously published in the Federal 9

Register A transcript of the meeting is being kept 11 and will be made available as stated in the 10 Federal 12 Register The participants should first identify 17 themselves and speak with sufficient clarity and 18 volume so that they may be readily heard.

19 notice.

Therefore, we request the 13 participants in this meeting to use the microphones 14 located throughout the meeting room when addressing 15 the Subcommittee.

16 We will now proceed with the meeting. I 20 call upon Brian Holian of the NRC staff to begin.

21 Brian?

22 MR. HOLIAN: Good morning and thank you 23 Chairman. My name is Brian Holian. I'm the Director 24 of the Division of License Renewal. The agenda for 25

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today's meeting is just brief introductions by myself 1

of the NRC staff and then I'll turn it over to Duane 2

Arnold's staff for their morning presentation which 3

will be followed by the staff's presentation.

4 To my immediate left is Bo Pham, the 5

Branch Chief that is responsible for Duane Arnold. To 6

my immediate right we have Benny Jose, Senior Reactor 7

Inspector from Region III and the Project Manager from 8

the Division of License Renewal, Brian Harris. You 9

will be hearing from both of them at the NRC 10 presentation.

11 In the audience I have Dr. Allen Hiser, 12 Senior Level Advisor, several DLR Branch Chiefs, 13 technical staff on both license renewal and some of 14 the technical divisions at NRR and they will be 15 available for questions during the staff presentation.

16 I did want to just take a short minute, 17 half a minute here to recognize to my immediate right 18 Dr. Sam Lee. Sam, if you would stand up? Sam is 19 moving on from license renewal. He has been a long 20 time license renewal reviewer, branch chief and deputy 21 division director. He has been my deputy for the last 22 two years and of P.T. Kuo before that.

23 Sam is swapping over. He is still staying 24 at NRR, but just broadening himself over to the 25

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Division of Risk Assessment and he will be swapping 1

with Melanie Galloway. You will meet her at next 2

month's session.

3 And yesterday was Sam's last day in 4

license renewal and I just wanted to highlight his, 5

you know, participation in license renewal. He 6

clearly is probably the single person with the most 7

longevity in license renewal. He dates himself back 8

to Calvert Cliffs and the rule before that, he has 9

been, I didn't count up all the ACRS Subcommittee and 10 Committee meetings that he has attended, but, to quite 11 a few.

12 He has been involved in almost all of the 13 59 plants that have been renewed. He did take a stint 14 in there when he went through his SES CDP and had a 15 rotation away from license renewal for a couple of 16 years, but then came back.

17 To cite his technical accomplishments, you 18 know, Dr. lee from MIT, he has been involved in all 19 our technical reviewers issues. You can ask the 20 branch chiefs the level of detail he gets into.

21 Besides that, which I know these are recognized, Sam 22 has also been a key hirer, not only for license 23 renewal, but for NRR.

24 And just within the last six months, he 25

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

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has received a couple of awards from the Federal 1

Advisory Committee for his hiring efforts. In the 2

last 15 months, he has hired over 25 people at NRR.

3 And part of that aspect is really 4

increasing the diversity of NRR. He has done just a 5

super job. You know, he is already starting to talk 6

risk assessment talk. He has repeated 10-7 if only a 7

couple of times yesterday. And he is asking me to put 8

a little more risk into license renewal, so we'll get 9

that view from him and you will be seeing him from 10 that side of the house.

11 But I did want to recognize him today in 12 this setting. He, like all of us, think very highly 13 of the ACRS. He uses these sessions to scare our 14 staff to death at presentations and prepare them well.

15 So he has always used that. But I wanted to 16 highlight him today in this setting and thank him.

17 (Applause) 18 MR. HOLIAN: With that, I'll turn it over 19 to Duane Arnold and Chris Costanzo, the site Vice 20 President.

21 MR. COSTANZO: Thank you, Brian. And 22 congratulations, Dr. Lee, and I wish you the best in 23 your new endeavor.

24 Good morning and welcome, Mr. Chairman and 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 10 the Committee, and welcome everybody in the back. I 1

think I can see everybody in the back.

2 I certainly appreciate the opportunity to 3

discuss our safety evaluation report with this 4

Committee and as well as the process reviews and 5

license renewal, our future plans at Duane Arnold and 6

the current plat status as well.

7 I have brought with me a great team. To 8

my left is Ken Putnam from the License Renewal 9

Project. He is the Project Manager. I have Ken 10 Kleinheinz, who is the Director of Engineering at 11 Duane Arnold. And Mike Fairchild who is the License 12 Renewal Electrical Lead.

13 And in the back row, if you guys wouldn't 14 mind, just raise your hand when I call you, Curt Bock.

15 Curt Bock is our License Renewal Mechanical Lead.

16 Ken Chew, which is our License Renewal Civil Lead, 17 Clara Rushworth, which is our License Renewal 18 Licensing Lead, Herb Giorgio, Environmental Lead, Eric 19 Sorenson, our Program Engineer, and Al Thomas, who as 20 well is a Program Engineer.

21 Today's agenda, we will be talking about a 22 background of the site. We will be talking about an 23 operation history and I'm going to have Ken Kleinheinz 24 do that, our Engineering Director. And Ken Putnam 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 11 will do our License Renewal Project overview. He will 1

include scoping discussions, our time-limiting aging 2

analysis. He will go through the generic aging 3

lessons learned and our commitment process.

4 As well, Ken will touch on our technical 5

items of interest. In particular, we will be talking 6

about the torus coatings, our buried piping system and 7

our small bore piping system, which are open items.

8 The next slide that may seem odd that we 9

are showing a picture, but I think it's a very good 10 picture to depict where Duane Arnold is. And what 11 this represents is what we call our excellence model, 12 as Duane Arnold knows well, at our fleet.

13 And this shows, and it's no optical 14 illusion, that both the prevention and the detection 15 parts of the circles are slightly bigger than the 16 correction model, because that depicts exactly how 17 Duane Arnold operates. We tried to attempt to stay 18 more in our prevention mode as well as our detection 19 mode to be better prepared to not react to things and 20 spend less time in correction.

21 And the reason I thought this is just one 22 of those values that we use in our excellence plan.

23 And this has been a journey that we have been on since 24 2008 and there is a series of values. But we picked 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 12 this slide in prevention correction detection, because 1

I think it most accurately represents what we do in 2

this license renewal process.

3 And when you look at our aging mechanisms 4

and establishing goals and trying to get a head of the 5

different aging issues that come up at Duane Arnold, 6

it depicts exactly where we are at.

7 We set those goals. We establish a 8

process to make those commitments and we go ahead and 9

effect those changes before they become a correction 10 mode.

11 And the next slide. Just a little bit of 12 background from the site. We are, approximately, six 13 miles northwest of Cedar Rapids in Iowa. We are a 14 general electric plant. Bechtel was our constructor.

15 We are a BWR. We are a Mark I containment. We have 16 just upgraded to 1912 megawatts thermal power and, 17 approximately, 630 megawatts electric.

18 The Cedar River is an ultimate heat sink 19 and a water makeup source with forced draft cooling 20 towers for condenser cooling. And our staff right now 21 consists of, approximately, 650 people.

22 MEMBER SIEBER: What was your original 23 licensed electrical output?

24 MR. PUTNAM: It's about 515.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 13 MEMBER SIEBER: 515, okay.

1 CONSULTANT BARTON: Why did you have a 2

restriction on your original license? Your original 3

license, you didn't have -- you weren't licensed for 4

your full power.

5 MR. PUTNAM: Yes, you license it to 1658 6

was the license and then the tech specs are restricted 7

to 1593.

8 CONSULTANT BARTON:

What was the 9

restriction all about?

10 MR. PUTNAM: You know, I think that was 11 for testing and power density. Duane Arnold has a 12 small core, so there is a -- they wanted some 13 operating time there on that before they allowed us to 14 go up.

15 CONSULTANT BARTON: Okay.

16 MR. PUTNAM: And we did that in 1985.

17 CONSULTANT BARTON: Thank you.

18 MR. COSTANZO: Earlier in the slide that I 19 used with prevention, detection and correction, I 20 spoke of a fleet. And so just as a little bit of 21 background, as we are a plant of five in our fleet, we 22 do have Point Beach in Wisconsin, Seabrook in New 23 Hampshire and we have the two southern plants, both 24 St. Lucie and as well Turkey Point down in Miami.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 14 And since 1974, and the reason I mention 1

that is, when we were first connected to the grid, 2

Duane Arnold has become a member of, you know, the 3

third largest fleet for very small plant in Palo, Iowa 4

just outside of Cedar Rapids. And with the inception 5

of that fleet and the strength of that fleet comes a 6

tremendous amount of governance and oversight.

7 So I just kind of wanted to mention that 8

with regards to we are not that small plant in Palo, 9

Iowa. We are actually a member of a much larger fleet 10 with a good bit of governance and oversight.

11 MEMBER SIEBER: Is this a merchant plant?

12 MR. COSTANZO: Yes, it is. There is a 13 portion. We do work with a PPA, which is a Power 14 Purchase Agreement, with the State of Iowa, but yes, 15 there is a portion of it that is a merchant.

16 MEMBER SIEBER: Okay. Thank you.

17 MR. COSTANZO: A little background on 18 plant status. We did start-up from the refueling 19 outage 21 and that was in March of 2009. The current 20 plant status is it's operating very well. We are at 21 100 percent power. And I just will mention, I'm 22 certain that the Committee is familiar with the 23 Institute for Nuclear Power Operations, we were just 24 rated as an excellence rating back in December, and we 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 15 are operating the licensee response column with the 1

NRC.

2 We did have a mid-cycle outage that we 3

concluded in May. We did have an issue with a drywell 4

cooler leak. It was one of the last remaining copper-5 tubed coolers, which did have a very small leak. We 6

did also identify that we did have -- actually, there 7

was a small plug in one of our circuit-setter valves, 8

which is the throttle valve on the outlet of the those 9

coolers that did have some erosion that also caused 10 that leak and it got up to almost 3.5 to 4 gallons a 11 minute. And we did take the unit off and made those 12 repairs.

13 And as well, there were several other, not 14 several, but there were some other issues that we did 15 take care of during that mid-cycle outage to get us 16 ready for our outage this year.

17 MEMBER SIEBER: I take it you didn't 18 replace the heat exchanger?

19 MR. COSTANZO: Actually, we did. I'm 20 sorry.

21 MEMBER SIEBER: Okay.

22 MR. COSTANZO: Yes, we did. It was 23 actually a job that was going to be done in this 24 upcoming refueling outage, however, we did take the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 16 opportunity to put a stainless steel cooler in, which 1

is a much nicer design and much more reliable.

2 MEMBER SIEBER: So is that the end of the 3

copper in that kind of application?

4 MR. COSTANZO: There is actually one set 5

of coolers that still remain copper, but they are much 6

different design. They are not like a U-tube type 7

heat exchanger. They are a full flow with a tube 8

sheet that haven't experienced that same type of 9

corrosion on those coolers that we have had excellent 10 reliability on. So with those two, there is no more 11 remaining copper-tubed coolers in containment.

12 MEMBER SIEBER: Okay.

13 MR. COSTANZO: Our next refueling outage 14 is in October of 2010.

15 CONSULTANT BARTON: You have what kind of 16 cycle refueling cycle?

17 MR. PUTNAM: Variable.

18 CONSULTANT BARTON: Variable?

19 MR. PUTNAM: Yes, it's two years is the 20 nominal, you know, like the tech spec surveillance 21 frequency, but fuel loading decides exactly what it 22 is, so we are a little under probably this year.

23 MR. KLEINHEINZ: We are averaging about 21 24 month cycles.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 17 CONSULTANT BARTON: Okay. Okay.

1 MR. COSTANZO: And I'll turn it over to 2

Ken to talk a little bit about the operating history.

3 MR. KLEINHEINZ: All right. Good morning.

4 Again, my name is Ken Kleinheinz.

I'm the 5

Engineering Director at the plant. I'll be presenting 6

slides 7 through 9. We'll go to slide 7 there.

7 On 7, we show a brief time line of the 8

operating history of the plant with regard to its 9

license. That history starts in 1970 when the Atomic 10 Energy Commission granted a construction permit to 11 Iowa Electric Light & Power and its two minority 12 owners. And then four years later they issued License 13 DPR-49, the operating license. And then just about 14 one year after that, the plant went fully commercial 15 in 1975.

16 In 1985, back to the question that Mr.

17 Burton asked, we were approved for an uprate of, 18 approximately, 5 percent in our tech spec to get us 19 from that 1593 up to 1658.

20 And then in November of 2001, we were the 21 first plant approved for extended power uprate. And 22 that was to go to a full 120 percent of original rated 23 thermal power.

24 The plant used a very deliberate phased 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 18 approach to implementing the extended power uprate.

1 We implemented mods to equipment over several cycles.

2 I'm going to describe some of those uprates in the 3

next two slides, so I'll hold off on that now.

4 But as Chris mentioned, the final phase 5

was completed at our last outage in the spring of 2009 6

and we did reach full extended power in March of 2009.

7 Let's

see, in

2006, the plant was 8

purchased by FPL Group, NextEra Energy and the license 9

was transferred at that time. And then September 10 2008, we submitted our application for license renewal 11 and that's what will extend our current license, which 12 expires, as it states, in February of 2014.

13 Are there any questions on Slide 7 before 14 I move on?

15 CONSULTANT BARTON: What kind of equipment 16 did you have to change out for that large increase?

17 MR. KLEINHEINZ: I'm going to cover that--

18 CONSULTANT BARTON: Okay.

19 MR. KLEINHEINZ: -- on the next two 20 slides.

21 CONSULTANT BARTON: Gotcha. All right.

22 MR. KLEINHEINZ: And if there is any 23 questions after that, I'll --

24 CONSULTANT BARTON: All right. Thank you.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 19 MR. KLEINHEINZ: Okay. On Slide 8, I 1

mentioned a moment ago that the plant has implemented 2

several upgrades to achieve power uprate. We have 3

also made several upgrades in recent years to support 4

long-term asset health of the plant and also to 5

address several reliability and performance issues, 6

such as the coolers we just mentioned.

7 I used the word deliberate earlier also in 8

describing our approach to power uprate. I think that 9

best characterizes how the plant operates in 10 developing long-term life cycle management plans for 11 the equipment and taken a very conservative approach 12 implementing equipment upgrades and in achieving 13 initiatives like the license renewal, which is one of 14 extended power uprate.

15 Okay. So on Slide 8, the first two 16 bullets list improvements the plant made to ensure the 17 long-term health of the recirculation system piping, 18 stainless steel piping. In 1987, the plant was the 19 pilot for boiling water reactor, hydrogen water 20 chemistry.

21 And since 1987, we have been injecting 6 22 standard cubic feet per minute of hydrogen 23 continuously into our feedwater system to protect that 24 piping.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 20 In order to stay in the detection phase 1

and monitor the effectiveness of that hydrogen water 2

chemistry, we also installed, at that time, a rather 3

unique system called a crack arrest verification 4

system, so I can point on my slide and you can read 5

through yourself.

6 But basically, that's a continuous monitor 7

using precracked, stressed metal specimens typical 8

alloys like Alloy 600, 304 stainless steel and A182 9

filler material, so we can measure the effectiveness 10 and verify that our cracks are not growing.

11 Also at that time, we installed another 12

system, an electrochemical potential monitor 13 monitoring system. And basically, that's also a 14 continuous system monitoring reactor coolant to make 15 sure the electrochemical potential stays below the 16 value that assures that cracks won't grow. So that 17 has been in place since that time also.

18 MEMBER SHACK: What percent of the time is 19 that operable?

20 MR. KLEINHEINZ: Well, it's got to be --

21 MEMBER SIEBER: Good question.

22 MR. KLEINHEINZ: It is operable more than 23 98 percent of the time.

24 MEMBER SHACK: Oh, that's good.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 21 MR. KLEINHEINZ: It is very rare for that 1

system to come out of service.

2 MEMBER SHACK: This is the electrochemical 3

potential monitor?

4 MR. KLEINHEINZ: Oh, I'm sorry.

5 MEMBER SHACK: Not the hydrogen water 6

chemistry.

7 MR. KLEINHEINZ: Oh, I'm sorry. I don't 8

have -- I can't say I have a percentage of time.

9 MEMBER SHACK: Is it something that is 10 reliable or as I suspect it takes a lot of coaxing and 11 care?

12 MR. KLEINHEINZ: Not a lot of coaxing and 13 care when the electrodes wear out, we do have to go in 14 and replace, which is no small evolution because of 15 dose concerns mostly.

16 What we have shown is there are other 17 monitoring systems like dissolve hydrogen and oxygen, 18 which are kind of backups to that, so that's not the 19 only system that kind of tells us, you know, based on 20 our start-up test and we know as long as we have a 21 certain result, load of dissolved oxygen, dissolved 22 hydrogen, these --

23 MEMBER SHACK:

The hydrogen water 24 chemistry is 98 percent?

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 22 MR. KLEINHEINZ: That system is in service 1

greater than 98 percent of the time.

2 MEMBER SHACK: Okay.

3 MR. KLEINHEINZ: That was one of the 4

conditions for our risk-informed ISI Program.

5 MR. COSTANZO: Actually, we were one of 6

the first plants to put hydrogen water chemistry in 7

their very reduced power and actually, we are looking 8

to do that even further down in the reduction of power 9

as you start to come up to increase the effectiveness 10 of the hydrogen water chemistry. It was recognized by 11 INPO as one of our strengths.

12 MEMBER ARMIJO: Do you still have the 13 original stainless steel piping in your recirc system 14 in coarse braids or have you changed that out?

15 MR. KLEINHEINZ: No, we have the original.

16 MEMBER ARMIJO: You are protecting that 17 with the water chemistry?

18 MR. KLEINHEINZ: That's correct.

19 MEMBER ARMIJO: Okay.

20 MR. KLEINHEINZ: And that's a good 21 question. The purpose of hydrogen water chemistry is 22 to mitigate intergranular stress corrosion cracking of 23 the piping.

24 Now, in 1996, we implemented another 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 23 process, noble metals application.

1 MEMBER SIEBER: Right.

2 MR. KLEINHEINZ: Because hydrogen water 3

chemistry only provides mitigation for the piping 4

itself. No metals is applied to the piping and to the 5

reactor internals. So that extends the coverage of 6

IGSCC protection into the vessel internals. So we 7

first injected platinum and rhodium in 1996 during 8

that outage and our last application was in the 2005 9

refueling outage.

10 Starting next year, 2011, we will be doing 11 on-line noble metals application, which is now the 12 industry standard. It reduces outage time. It can be 13 performed with the plant at full power. So we look 14 forward to that next year.

15 MEMBER SHACK: Did you do some residual 16 stress improvements? Since you have risk-informed 17 inspections, you somehow got out of the 03-13 enhanced 18 inspections, but you needed two methods.

19 MR. PUTNAM: We did induction heat 20 stressing improvement.

21 MEMBER SHACK: Okay.

22 MR. PUTNAM: And --

23 MR. KLEINHEINZ: Certain welds.

24 MR. PUTNAM: -- in '86 or so. I don't 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 24 recall.

1 MR. KLEINHEINZ: Roughly, yes. In the 2

mid-'80s, yes.

3 MEMBER SHACK: So it is two methods. SO 4

you have some welds that you did the heating.

5 MR. KLEINHEINZ: There are some welds we 6

did the heating, not all.

7 MEMBER SHACK: Yes.

8 MEMBER ARMIJO: And your shroud, did you 9

have any cracking of your shrouds and did you have to, 10 you know, clamp them, since some plants did?

11 MR. KLEINHEINZ: No. We have had no 12 incidents of cracking in our core shroud to date.

13 MEMBER ARMIJO: Okay.

14 MR. KLEINHEINZ: We will be doing another 15 inspection in our next outage.

16 MEMBER ARMIJO: Good.

17 MR. KLEINHEINZ: Back to the noble metals 18 application. Are there any questions on that, I mean, 19 any further questions?

20 Okay. Just again, back to the monitoring 21 phase. Along with the noble metal application, we did 22 install a coupon system also in that crack arrest 23 verification, the sampling

system, we installed 24 coupons that are treated with noble metals, so we can 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 track the wear rates. Make sure the metals are still 1

present protecting our vessel.

2 So we have a routine sampling program 3

where we remove those coupons. And every time we 4

apply, we install new coupons.

5 Okay. Moving on to 19 --

6 MEMBER SHACK: Did you sign up for 7

continuous injection?

8 MR. KLEINHEINZ: Of noble metals?

9 MEMBER SHACK: Yes.

10 MR. KLEINHEINZ: That's platinum and 11 rhodium are not inexpensive, but no, I know of no 12 continuous injections.

13 MEMBER ARMIJO: It lasts a long time 14 though.

15 MR. KLEINHEINZ: They do last a long time, 16 that's right.

17 MEMBER ARMIJO: Yes.

18 MEMBER SIEBER: Need a stimulus program.

19 MR. KLEINHEINZ: In 1998, the plant did 20 install larger emergency core cooling system suction 21 strainers on our low pressure ECCS system that is 22 inside of our torus. We did that to increase our 23 margin in the case there is a pipe break inside our 24 containment that blows debris into the containment and 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 26 that gets washed to our torus. So that increased the 1

surface area of those strainers significantly. That 2

was a preemptive measure.

3 In

2001, we implemented the first 4

component upgrades.

5 MEMBER SHACK: When you did that, did you 6

replace --

7 MR. KLEINHEINZ: Okay.

8 MEMBER SHACK: How much fiber insulation 9

is left?

10 MR. KLEINHEINZ: We did not replace the 11 fiber insulation in our drywell, at least not at this 12 point. Now, the BWR Owner's Group is taking a 13 significant look at that and we are a part of that 14 group. As a matter of fact, we'll be doing some 15 significant walk-downs of our containment next outage 16 to, basically, get a feel for how much fibrous 17 insulation is in our containment.

18 MEMBER SHACK: Okay. On the piping you 19 have got reflective metal?

20 MR. KLEINHEINZ: Jacketing on some of it.

21 I don't know if anyone wants to add to that over 22 there, but it is fibrous insulation.

23 MEMBER SHACK: Oh, okay. So it's the 24 packaged kind of fibrous insulation that you can take 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 27 off to inspect?

1 MR. KLEINHEINZ: Right.

2 MEMBER SHACK: Right.

3 MR. COSTANZO: But as Ken mentioned, we 4

are on the BWR Owner's Group Committee. We are going 5

to stay ahead of that in prevention, so that we don't 6

have to react to that. And as the other Ken had 7

mentioned, we are doing some walk-downs to this outage 8

to be able to better understand that, so that when we 9

do have to take some actions, that we would be better 10 poised to do that.

11 MEMBER SHACK: Okay.

12 MR. KLEINHEINZ: In 2001, we implemented 13 the first round of upgrades to support our Phase I of 14 power uprate and that included new high pressure 15 turbine internals, new moisture separator heater 16 internals and then two new circulating water pumps.

17 In 2003, we mentioned, we replaced 10 out 18 of 12 of our copper drywell coolers, those were the 19 original coolers.

20 CONSULTANT BARTON: So one of the two that 21 are remaining leaked?

22 MR. KLEINHEINZ: Yes. We had replaced 23 those in 2001, like-for-like, they were the first ones 24 that caused us an issue and, at that time, we were 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 28 replacing like-for-like. So we had planned for a 1

later replacement of them, an upgrade, and --

2 CONSULTANT BARTON: It gotcha though.

3 MR. KLEINHEINZ: -- it got me. It got us, 4

yes, sir.

5 MR. COSTANZO: Really, the leaks were very 6

minimal --

7 MR. KLEINHEINZ: As it turned out.

8 MR. COSTANZO: -- on those coolers 9

themselves. We had anticipated that it was going to 10 come from those, because of the history of those 11 coolers. But as I had mentioned, it was actually in 12 the downstream circuit setter valves that had a 13 quarter inch plug that actually caused some turbulent 14 erosion on that plug and it was a hollow plug that 15 actually caused the leak.

16 MR. KLEINHEINZ: So it was the same 17 system, different component that actually affected --

18 MR. COSTANZO: And we did do an extensive 19 condition and root cause analysis and did some 20 mitigating, put some solid plugs in and we will take a 21 look at any other extent of condition we have to do 22 this outage.

23 MEMBER SHACK: Okay.

24 MEMBER ARMIJO: Do you still have the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 29 original condenser? Did you have stainless steel 1

condensers or did you have --

2 MR. KLEINHEINZ: Yes, we have stainless 3

steel condensers.

4 MEMBER ARMIJO: So you never had the 5

copper Admiralty-brass problem?

6 MR. KLEINHEINZ: No, that's right. We had 7

stainless steel, three or four stainless steel since 8

we began.

9 MEMBER BONACA: In your extended power 10 uprate, did you need credit for accident pressure?

11 MR. KLEINHEINZ: Yes.

12 MEMBER BONACA: Okay.

13 MR. KLEINHEINZ: I don't recall the 14 number.

15 MR. PUTNAM: But as a matter of fact, you 16 know, we credited over pressure in the original 17 license for the plant, you know, in power uprate the 18 number changed a pound or two, and we continued to 19 credit over -- containment over-pressure.

20 MEMBER BONACA: All right.

21 MR. KLEINHEINZ: Okay. I'll move on to 22 Slide 9. 2005 included equipment upgrades to support 23 the second phase of power uprate. 6 of 12 of our 24 feedwater heaters replaced in that outage. We 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 30 replaced both of our condensate pumps with new pumps 1

and motors. And then we installed condenser isolation 2

valves on our circulating water system and that allows 3

us to isolate individual trains of these circ water 4

going into our condensers and do repairs or cleaning 5

of the tubes on-line, if necessary, at lower power.

6 Previously, we had had to shut down any 7

time we had an issue with condenser leaks or fouling.

8 In 2007, we replaced a significant number 9

of the instrumentation and power cables inside our 10 heater bay. We hadn't encountered any failures of 11 these non-safety

cables, but it's a

higher 12 temperature, ambient temperature in that area and had 13 noted some cracking and brittleness of those cables.

14 So in the prevention mode, we went in and 15 replaced about a third of all the cables in that area 16 to ensure continued reliability.

17 CONSULTANT BARTON: With different cable 18 insulation?

19 MR. KLEINHEINZ: Well, I'll ask Mike. I 20 don't believe there is anything significantly 21 different than what we had.

22 MR. FAIRCHILD: This is Mike Fairchild.

23 No, it was basically the same type of cable, XLPE 24 installation.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 31 MR. KLEINHEINZ: Okay. In our 2009 1

outage, our last refueling outage in the spring of 2

'09, we implemented several upgrades to our emergency 3

diesel generators, replaced the governor on the Bravo 4

Generator. We will replace the Alpha Governor in this 5

coming fall outage. Then we also replaced both 6

regulating systems on those engines for reliability 7

purposes.

8 MEMBER SIEBER: What kind of governors 9

were originally on and what did you replace them with?

10 MR. KLEINHEINZ: Woodward.

11 MEMBER SIEBER: Okay.

12 MR. KLEINHEINZ: Both.

13 MEMBER SIEBER: So it's --

14 MR. KLEINHEINZ: An upgrade.

15 MEMBER SIEBER: -- the new one is an 16 upgrade or just a replacement?

17 MR. KLEINHEINZ: No, it is an upgrade. It 18 makes the engines a little more responsive.

19 MEMBER SIEBER: Okay.

20 MR. KLEINHEINZ: Then we installed the 21 last large upgrade to achieve full power uprate and 22 that was a replacement of our main transformers.

23 And then just a couple more enhancements 24 we did during that outage. We put new more reliable 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 32 Jordan positioners on our recirc pump MG Set Scoop 1

Tube Positioners. And then lastly, replaced our 2

ultrasonic feedwater flow measuring system during that 3

outage to get us a little more accurate calorimetric 4

for measuring reactor power.

5 CONSULTANT BARTON: Transformer upgrade 6

was just because of power uprate? It wasn't because 7

of transformer failures?

8 MR. KLEINHEINZ: The transformers are not 9

failed. We had basically four individual phases. One 10 was a spare and any time could be swapped out.

11 CONSULTANT BARTON: Okay.

12 MR. KLEINHEINZ: So they were all operable 13 at the time of the change out.

14 CONSULTANT BARTON: All right.

15 MR. KLEINHEINZ: The one showed some signs 16 of gasing, I think, so early signs of degradation.

17 MR. COSTANZO: Now, Mr. Barton, one of 18 your questions was, you know, we talked a little bit 19 about the power upgrade and what were those 20 modifications we did. The list is not, obviously, all 21 due to those modifications required for power uprate, 22 but they do represent a lot of our life cycle 23 management, our system health reporting systems for 24 obsolescence and some, unfortunately, for instance the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 33 tube position upgrade we did in correction, because we 1

did have some issues and some problems with the 2

previous ones with regard to reactivity control.

3 But it does represent a little bit about 4

the slide that I was trying to show you earlier, our 5

value with regard to prevention and protection.

6 CONSULTANT BARTON: Thank you.

7 MR. KLEINHEINZ: Any other questions on 8

Slides 7 through 9? Okay. Hearing none, then I'm 9

going to turn the presentation over to our License 10 Renewal Project Manager, Ken Putnam who will cover the 11 remaining slides.

12 MR. PUTNAM: All right. Thanks. I'll 13 give a brief overview of our License Renewal Project 14 for Duane Arnold and then cover the three technical 15 items of interest, including two open items we have 16 with the staff.

17 Shortly after FPL purchased Duane Arnold, 18 we kicked off the project to renew the operating 19 license. The decision was made then that we wanted 20 the bulk of the work done on-site at Duane Arnold, 21 that would allow us to have good site ownership and 22 oversight to support both the quality of the project 23 as well as ensure we had site ownership of the 24 programs as we went forward in implementing license 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 34 renewal.

1 We staffed the project with a very 2

experienced team. It included people who had been 3

long-term employees at Duane Arnold. We also had 4

several people who had been involved from corporate at 5

St. Lucie and Turkey Points License Renewal, so we had 6

their experience and then we augmented that with 7

contract staff, who had been at an awful lot of the 8

plants that have renewed their license in the past.

9 To ensure we tapped into the most current 10 experience with respect to renewing the license for a 11 BWR, we sent our team up to Monticello who was just 12 wrapping up their License Renewal Project, at that 13 time, to do benchmarking for a week there, that was a 14 great leaning experience for us. We picked up a lot 15 of things from them.

16 And we have continued to be engaged with 17 the industry throughout the project, sending team 18 members to observe audits at other sites during -- who 19 were slightly in front of us. And we have also 20 participated in industry working groups throughout the 21 period.

22 We did have peer reviews of both the 23 technical products being produced by our individual 24 disciplines. And we also had a peer review of the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 35 integrated application at the end. We did also use 1

our QA folks to perform independent audits midstream 2

as we were developing our analysis to check us to make 3

sure we were following our own processes.

4 Next slide. The scoping process is pretty 5

standard. We followed NEI 95-10. We categorized the 6

entire plant in terms of major system structures and 7

components and we tried to stay as close as practical 8

to the existing plant system nomenclature.

9 We went through each of the systems and 10 cataloged the system level functions then evaluated 11 these functions against the scope and criteria 12 specified in 10 CFR 54.4(a)(1) for safety-related 13 (a)(2) for non-safety-related equipment that could 14 affect safety-related and (a)(3) for the regulated 15 events of EQ fire protection at loss, ATWs and station 16 blackout.

17 Then we went down to the component level 18 and identified those components supporting an intended 19 function under the license renewal.

20 Next slide.

21 MEMBER STETKAR: Ken, on that, I don't 22 think you are going to cover it later, so stop me if 23 you are. But I noticed there was some discussion 24 about the intake trash racks and the rakes on the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 36 trash racks. And they are currently not in scope.

1 They do provide protection for safety-2 related service water intake traveling screens. The 3

discussion seemed to focus on the fact that failures 4

of the trash racks themselves would not block the 5

intake, because the trash racks would collapse down 6

into the intake. Well, I can buy that, they are steel 7

or whatever they are made out of.

8 On the other hand, what they do is they 9

keep large debris from coming in and jamming up the 10 traveling screens which then causes smaller debris to 11 collect on the screens, which then plugs the intake.

12 So I was curious why the maintenance of 13 the function of those trash racks is excluded from the 14 scoping.

15 And also the second question is it 16 probably gets pretty cold in Palo in the wintertime.

17 Do they block ice from coming in from the river?

18 MR. PUTNAM: I'll let Curt Bock, our 19 mechanical lead, maybe answer that.

20 MR. BOCK: Yes. This is Curt Bock for the 21 applicant. Our main reasoning there was that the flow 22 that is the inner velocity through those racks is so 23 small that we felt that the racks would fall directly 24 down and would not impact our safety-related equipment 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 37 that is in our intake structure.

1 MEMBER STETKAR: I understand that. As I 2

said, they are steel. They will go down.

3 MR. BOCK: Right.

4 MEMBER STETKAR: The stuff that is 5

floating in the river will not go down. So I'm 6

curious about if the trash racks disappear, what 7

protection does your safety-related intake have from 8

debris in the river? Large debris.

9 MR. BOCK: Well, if we no longer have the 10 trash racks, then larger debris would be able to --

11 you are assuming a failure of the trash racks?

12 MEMBER STETKAR: Yes.

13 MR. BOCK: Which would then -- the 14 material could then enter that area in the intake 15 structure.

16 MR. PUTNAM: That configuration though at 17 the intake rake, Curt, the screen flow pulls the stuff 18 away. You know, it is kind of angled toward the 19 downstream, so that debris tends to not sweep into 20 that intake. And then, you know, our operating 21 experience certainly is we don't get trash on those 22 trash racks oddly enough. We have a trash grate there 23 that is intended to like remove that. It was never 24 getting used. We had to put a PM in place to cycle 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 38 the motors, because it was never used.

1 MEMBER STETKAR: That's good experience.

2 I mean, that's odd, but that's good experience.

3 MEMBER SIEBER: Well, usually the screen 4

house is built with the outer shell submerged, so the 5

trash actually stays out in the river.

6 MR. PUTNAM: Right.

7 MEMBER SIEBER: While the water flows in, 8

that's why it doesn't freeze in there provided you 9

heat the building, which is the other question, I 10 think, you asked.

11 MEMBER STETKAR: Yes.

12 MEMBER SIEBER: On the other hand, that 13 doesn't happen all the time.

14 MR. PUTNAM: Yes, we do have deicing out 15 there as well where we circulate circ water, I guess--

16 MR. BOCK: Yes.

17 MR. PUTNAM: -- back to the -- to spray on 18 those in that area.

19 MEMBER SIEBER: Screen wash pumps, right.

20 MR. PUTNAM: To keep things in place.

21 MEMBER STETKAR:

But basically your 22 operating experience is that you don't have periods of 23 large --

24 MR. PUTNAM: That's correct.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 39 MEMBER STETKAR: -- things coming in, tree 1

limbs.

2 MR. PUTNAM: No.

3 MEMBER SHACK: Even when you had Cedar 4

Rapid flooding?

5 MR. PUTNAM: We inspect them.

6 MEMBER STETKAR: I mean, you know, 7

riverine locations in northern climates tend to get 8

affected, you know, in the autumn we have severe 9

storms in the autumn and brings down tree limbs and 10 lots of debris in winter.

11 MR. PUTNAM: And as Curt said, the 12 approach velocity is really slow there. The river 13 speed is actually, I think, faster than the approach 14 velocity of the pumps pulling it in, so it's --

15 MEMBER STETKAR: Okay.

16 MR. PUTNAM: -- not competing with the 17 river in terms of flow over there.

18 MEMBER STETKAR: Thank you.

19 CONSULTANT BARTON: In the recent floods, 20 did any of that equipment at the intake get flooded?

21 MR. PUTNAM: You know, we had some backup 22 discussion of the flooding, if you would be interested 23 in jumping clear to that now?

24 CONSULTANT BARTON: Oh, if you are going 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 40 to cover it, that's fine.

1 MR. PUTNAM: Well, we intended. Mike, why 2

don't you pull that up and let's just jump to that 3

now.

4 MR. FAIRCHILD: Okay.

5 MR. PUTNAM: Go ahead, Mike.

6 MR. FAIRCHILD: This is Mike Fairchild for 7

Duane Arnold. This is a picture of the plant before 8

the flood. This is during the flood and this is 9

actually from the opposite direction. This is the 10 intake structure.

11 CHAIR BLEY: Could you go back to when the 12 orientation changed in it?

13 MR. FAIRCHILD: Yes, the orientation 14 changed.

15 MEMBER SIEBER: Oh, okay.

16 MR. FAIRCHILD: You can see the intake 17 structure is over here.

18 MEMBER SIEBER: So that was that little 19 island over there, right?

20 MR. FAIRCHILD: Yes.

21 MEMBER SIEBER: Okay. Got it.

22 MR. FAIRCHILD: None of the safety-related 23 components in the intake structure got water in it.

24 The level was above it and the next slide has the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 41 actual levels, one of the next slides.

1 MEMBER SIEBER: I take it that was 2

inaccessible, your intake structure, during the whole 3

period of the flood. So if you got debris, you 4

couldn't do anything about it anyway, right?

5 MR. FAIRCHILD: Right. There was --

6 MR. COSTANZO: Well, you would have had to 7

send some boats out there and mitigate by boat.

8 MEMBER SIEBER: Maybe you can go.

9 CONSULTANT BARTON: Yes, but could you 10 take big equipment to get the chicken coops and stuff 11 off the trash racks?

12 MR. FAIRCHILD: The river was actually 13 relatively debris free.

14 CONSULTANT BARTON: Was it?

15 MR. PUTNAM: At Duane Arnold.

16 MR. FAIRCHILD: Yes, at Duane Arnold.

17 MR. PUTNAM: Down the street at Cedar 18 Rapids --

19 MEMBER STETKAR: Before you flip to the 20 next one, is that your switchyard in the lower left 21 hand?

22 MR. FAIRCHILD: No, the switchyard is 23 actually right over here.

24 MEMBER STETKAR: Oh, back there? Okay.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 42 MR. FAIRCHILD: This is a parking lot.

1 MEMBER STETKAR: Oh, that's a parking lot.

2 Okay. I couldn't see.

3 MR. FAIRCHILD: Okay.

4 MEMBER STETKAR: Thank you.

5 MEMBER SIEBER: The insurance company 6

solves --

7 MR. FAIRCHILD: This is the flood levels 8

for Cedar Rapids. You can see the 2008 flood was 9

significantly higher than the previous records, over 10 11 feet.

11 MEMBER SIEBER: Yes.

12 MR. FAIRCHILD: So that was quite an 13 experience for us. The maximum probable flood is 14 764.1 and the intake structure floor level where the 15 safety-related equipment is is actually 767.

16 MEMBER STETKAR: Okay.

17 MR. FAIRCHILD: And that's what the plant 18 is designed to withstand. The main plant area 19 actually has stop logs and things to block entrances 20 up to that level.

21 CHAIR BLEY: What was the level in this 22 last part?

23 MEMBER SIEBER: 730 he said.

24 MR. FAIRCHILD: 751.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 43 MEMBER SIEBER: 751.

1 CHAIR BLEY: 751.

2 MEMBER STETKAR: It's right here.

3 CHAIR BLEY: The flood zone.

4 MR. FAIRCHILD: That was the highest flood 5

level.

6 CONSULTANT BARTON: So your flood design 7

is higher than what you experienced in this flood?

8 MR. FAIRCHILD: That is correct.

9 CONSULTANT BARTON: All right.

10 MR. FAIRCHILD: And then this is 15 plus 11 years of records, river level rev and you can see that 12 the 2008 was significantly higher than anything we had 13 had previously. The closest was like 2003. And our 14 records, computer records didn't go back that far.

15 This is just a trace of how it went up and the length 16 of time of the flood.

17 The purple line below is the average river 18 level and the green line on top is the plant floor 19 level.

20 CONSULTANT BARTON: Okay.

21 MR. FAIRCHILD: To show how much spare we 22 had, margin.

23 MEMBER SIEBER: 17 feet.

24 MR. COSTANZO: We had some renewed 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 44 advocacy by the entire Cedar Rapids area, because we 1

were one of the only stations that stayed on producing 2

electricity.

3 CONSULTANT BARTON: That's good for you.

4 MR. FAIRCHILD: We operated at 100 percent 5

power. If we had to back down it was because of lack 6

of load, not lack of any problems in the plant. And 7

only a couple of out buildings got water in them.

8 Just a little bit on the floor. Any further questions 9

on the flood?

10 CONSULTANT BARTON: Thank you.

11 MEMBER SIEBER: I think they have already 12 had their 100 year flood.

13 CONSULTANT BARTON: I think so.

14 MEMBER SIEBER: So they don't need it 15 inspected.

16 MR. PUTNAM: Yes, it was beyond the 100 17 year flood levels in Cedar Rapids. You know, it 18 certainly was a traumatic event for our community, I 19 think, more than for our plant.

20 MEMBER SIEBER: Yes.

21 MR. PUTNAM: A lot of people affected by 22 it.

23 MEMBER SIEBER: Right.

24 MR. PUTNAM: All right. Sorry, where was 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 45 I? On scoping, right? Let me think where I cut off 1

here.

2 MR. COSTANZO: At the fourth bullet down.

3 MR. PUTNAM: All right. Yes. We mapped 4

this stuff down to the individual component level.

5 Let's go to the next slide, Mike.

6 MEMBER STETKAR: I'm not going to let you 7

off the hook --

8 MR. PUTNAM: Okay.

9 MEMBER STETKAR: -- quite -- well, yes, I 10 am. Get to the next slide.

11 MR. PUTNAM: I've got one more slide of 12 scoping.

13 MEMBER STETKAR: Okay. I'll let you get 14 to the middle bullet on this one.

15 MR. PUTNAM: We use site component 16 databases and controlled drawings and all controlled 17 documents for performing the scoping reviews. For 18 safety-related and the regulated

events, those 19 databases they were easy, you know, it was one-to-one, 20 straightforward match-up on the definition of safety-21 related. That was pretty straightforward stuff.

22 They weren't really constructed to 23 evaluate non-safety affecting safety that is kind of a 24 different concept from our current licensing basis.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 46 So to compensate for that, we took a conservative 1

spaces approach. Like I said, we had good databases 2

on where our safety-related equipment is, so we took a 3

spaces approach where anything that had -- any area 4

that had safety-related equipment in it, we assumed 5

that the non-safety-related equipment located in that 6

same area could affect that safety-related equipment 7

and evaluated it for scope.

8 To confirm that there wasn't anything 9

unique about the physical location that doesn't show 10 up in the database or on a drawing, we did send our --

11 we have a couple of former shift managers on the team.

12 We sent them out to walk-down those areas we excluded 13 to make sure there wasn't something going on in the 14 plant where there was more interaction than we 15 realized from the drawings. And so that gave us a 16 good comfort that we had the right scope there on non-17 safety affecting safety.

18 For things like electrical really aren't--

19 isn't information so much down to the component and 20 tag number, level, so those we treated as commodity 21 groups in performing the evaluation at the commodity 22 group level, that's how we performed our scoping. I 23 assume you've got a question for me now?

24 MEMBER STETKAR: Yes, I do. And this is 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 47 the appropriate place to ask this one, I guess. There 1

was a question, I think, about scoping of the main 2

generator hydrogen coolers. And I'm assuming it was 3

under (a)(2). I didn't go back and check my notes 4

this morning.

5 MR. PUTNAM: Yes.

6 MEMBER STETKAR: But the response to the 7

staff's question said that the floor generator 8

hydrogen coolers are tube heat exchangers that are 9

entirely contained within the main generator shell.

10 MEMBER SIEBER: Right.

11 MEMBER STETKAR: Your hydrogen coolers are 12 inside the main generators?

13 MR. PUTNAM: Yes.

14 MEMBER STETKAR:

Inside the main 15 generator?

16 MR. PUTNAM: Yes.

17 MEMBER STETKAR: That's -- okay.

18 MEMBER SIEBER: It is water in.

19 MEMBER STETKAR: A lot of plants don't do 20 that though. They don't like service water --

21 MR. PUTNAM: Yes, you don't want them to 22 leak.

23 MEMBER STETKAR: You don't want them to 24 leak. Okay. But yours are inside. Okay. Thanks.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 48 CONSULTANT BARTON: It's a typical GE 1

design, if I remember correctly.

2 MEMBER STETKAR: Is it?

3 CONSULTANT BARTON: Yes.

4 MEMBER STETKAR: Okay.

5 CONSULTANT BARTON: I have seen GE plants 6

that have the hydrogen coolers down below.

7 MEMBER STETKAR: Okay.

8 CONSULTANT BARTON: Thanks.

9 MEMBER STETKAR: Is it these older GE 10 plans?

11 CONSULTANT BARTON: That could be, yes.

12 MEMBER STETKAR: Okay.

13 CONSULTANT BARTON: The ones I have seen 14 are newer ones.

15 MEMBER SIEBER: One thing, Westinghouse 16 had that, too, in some plants.

17 MEMBER STETKAR: Okay. Thanks. I just 18 hadn't seen one. Thank you.

19 CONSULTANT BARTON: Okay.

20 MEMBER STETKAR: Another question. This 21 is kind of scoping or -- I guess it is. You have 22 excluded monitoring of hot insulated piping that is 23 located indoors, because the argument that hot piping 24 will not have corrosion, because there is no way that 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 49 moisture can collect on that hot piping.

1 Although I

noticed your operating 2

experience said you had had some corrosion on the 3

external surfaces of the turbine stop-valve piping, 4

which is usually pretty hot.

5 So I was curious what the basis for 6

excluding hot piping --

7 MR. PUTNAM: No, we didn't exclude it from 8

scope. It is in scope.

9 MEMBER STETKAR: It is in scope, it's just 10 not part of the -- but I looked at forwarding your --

11 MR. PUTNAM: For one of the aging effects 12 there.

13 MEMBER STETKAR: Right.

14 MR. PUTNAM: Corrosion on the exterior 15 surface and I forget the details. If you remember 16 more, Curt, feel free to correct me. You know, so 17 that is really about evaluating one aging effect 18 there.

19 MEMBER STETKAR: Okay. I was looking 20 ahead and there wasn't a convenient place to ask you 21 about it in the next couple of slides.

22 MR. PUTNAM: I don't recall that operating 23 experience you are talking about off-hand, so I really 24

-- we can check into that, but I don't --

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 50 MEMBER STETKAR: I was just -- the main 1

question that I had, of course, is that if the piping 2

is always hot, above 212 degrees, 365 days a year, 3

there's no much chance to get water between the 4

insulation and the pipe.

5 On the other hand, if the pipe is cooled 6

down for extended periods of time, like during 7

outages, you might have some type of corrosive 8

effects. So I was curious. I was sort of interested 9

to know what systems or what piping sections are 10 excluded from that aging management program due to 11 that consideration?

12 MR. PUTNAM: Well, you know --

13 MEMBER STETKAR: It's probably something 14 you have to go back and take a look at.

15 MR. PUTNAM: Yes, we would have to look 16 that up.

17 MEMBER STETKAR: That's fine.

18 MR. PUTNAM: I'm sure it would be quite a 19 number of them.

20 MEMBER STETKAR: Yes, that's what I was --

21 MR. PUTNAM: That was in our methodology 22 as you work through evaluating each of the aging 23 effects, if it was above 212, and I don't remember if 24 there was a material restriction on that evaluation or 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 51 not, but if it was, if it fits the box that we defined 1

in our methodology using the EPRI tools, that's how we 2

treated it.

3 MEMBER SIEBER: But that's just the 4

external surface?

5 MR. PUTNAM: Correct.

6 MEMBER SIEBER: You still have the 7

corrosion taking place inside the piping.

8 MR. PUTNAM: That's correct.

9 MEMBER SIEBER: Which I'm sure you do 10 examine UT or whatever method you use. That is where 11 I would expect the most significant wall thinning from 12 the inside.

13 MR. PUTNAM: And that would depend on the 14 system again.

15 MEMBER SIEBER: Yes.

16 MR. PUTNAM: What we were doing on the 17 inside.

18 MEMBER SIEBER: Yes.

19 MR. PUTNAM: Next slide.

20 CONSULTANT BARTON: Let me ask you a 21 question on scoping. Can you explain to me what your 22 safety-related air system is? I was confused in your 23 application. The instrument air is not included. Do 24 you have a safety-related air system?

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 52 MR. PUTNAM: Yes.

1 CONSULTANT BARTON: What is it and what 2

are the components of it?

3 MR. PUTNAM: Curt, do you want to answer 4

that?

5 MR. BOCK: Yes. This is Curt Bock for the 6

applicant. Our safety-related air system, it's a 7

system designed to provide a reliable source of 8

compressed air to operate components in the standby 9

gas treatment system, control building standby filter 10 unit and the control building ventilation system and 11 other containment isolation valves.

12 We have two independent redundant motor-13 driven air compressors that are powered by the vital 14 buses. Dryers, receivers, instrumentation and the 15 distribution piping. The air receivers are normally 16 supplied by the plant instrument air system. And then 17 if, you know, air pressure falls below the set point, 18 they will kick on.

19 They are normally cooled by well water 20 with emergency service water backup. And the 21 compressors and dryers and receivers are located in a 22 portion of a standby gas treatment system room in our 23 reactor building on the second level.

24 CONSULTANT BARTON: Are some of the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 53 components in the instrument air system also part of 1

the safety-related system or is the safety-related air 2

system entirely separate?

3 MR. PUTNAM: You know, typically, you 4

know, most of the safety-related components that are 5

supplied by air are fail-safe.

6 CONSULTANT BARTON: I understand that.

7 MR. PUTNAM: If there is a loss of air, it 8

will fail to -- like an isolation valve, it will fail 9

to close. For a handful of equipment, that's not 10 true. You need active air to make it work right. And 11 that's the component that is supplied by that safety-12 related air.

13 CONSULTANT BARTON: But what is the air 14 source for that? Is it instrument air or is it 15 nitrogen bottles? You know, what is the source?

16 MR. PUTNAM: No, it's instrument air.

17 It's compressing atmospheric air and drying it. And 18 there is a, you know, redundant path with check valves 19 that your normal instrument air system is supplying it 20 99.9 percent of the time. If for some reason that 21 non-safety-related air went away, a check valve would 22 close and these compressors would start up and provide 23 air to that limited number of components.

24 CHAIR BLEY: So the safety-related air 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 54 system is a standby system that only supplies some of 1

the components supplied by instrument air?

2 MR. PUTNAM: Correct.

3 MR. BOCK: Correct.

4 CHAIR BLEY: Okay.

5 MR. PUTNAM: A very small subset.

6 CHAIR BLEY: Thanks.

7 CONSULTANT BARTON: Now I understand it.

8 All right.

9 MEMBER STETKAR: Does the safety-related 10 air system come into the instrument air head or 11 downstream from the outlet of the air receivers or 12 does the -- do the safety-related air compressors 13 charge the air receiver, the main air receiver from 14 the plant air system?

15 MR. PUTNAM: Downstream.

16 MEMBER STETKAR: They are downstream.

17 Okay. Okay. Now, you had problems with corrosion in 18 your instrument air system. Corrosion inside the air 19 receiver.

20 MR. PUTNAM: Yes.

21 MEMBER STETKAR: And apparently, corrosion 22 in the piping from the air compressor building --

23 MR. PUTNAM: Yes.

24 MEMBER STETKAR: -- wherever it is 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 55 located, because you replaced that.

1 MR. PUTNAM: Yes.

2 MEMBER STETKAR: When did that happen?

3 When was that all of that? When was the piping 4

replaced? And when did you -- you repaired the 5

corrosion on the inside of the air receivers with weld 6

grounded down and put weld overlays or something like 7

that. When did that happen?

8 MR.

PUTNAM:

I don't have that 9

information.

10 MR. BOCK: Approximately, 2007.

11 MEMBER STETKAR: 2007. So about three 12 years ago. Okay. I don't need a precise date. I was 13 looking for, you know, 1980 versus 2010. So a couple 14 of years ago.

15 MR. BOCK: Correct.

16 MR. PUTNAM: And that stuff, obviously, is 17 upstream of the dryers.

18 MEMBER STETKAR: That's right. But on the 19 other hand, you now, corrosion products and moisture 20 from those events can be carried through the system 21 and eventually deposit down in little solenoid 22 operated values. And having worked at a plant that 23 had a problem that way, your fail-safe valves don't 24 fail-safe if the solenoids don't move when they are 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 56 de-energized.

1 So I was curious whether you have had any 2

problems in the intervening three years with operation 3

of any of the air operated equipment or whether you 4

actually checked the eventual consumer lines, you 5

know, blew down the lines at the final endpoint to see 6

whether you had corrosion products and moisture out in 7

there?

8 MR. PUTNAM: We do routine periodic blow 9

downs.

10 MEMBER STETKAR: You do.

11 MR. PUTNAM: With the system in place and 12 check for exactly that.

13 MEMBER STETKAR: Good.

14 MR. PUTNAM: And we didn't -- we haven't 15 had any problem with the dryers.

16 MEMBER STETKAR: If you are doing the blow 17 downs --

18 MR. PUTNAM: Currently, you know, in the 19 way-back times we have had problems back in the early 20

'80s there with, I think it was, desiccant carrying 21 over and getting in there and causing problems. So 22 that, you know, we definitely know exactly what you 23 are talking about in terms of causing problems 24 downstream. And we do have -- we upgraded our dryers 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 57 to get rid of the desiccant moving downstream. And we 1

do do periodic blow downs --

2 MEMBER STETKAR: You do periodic blow 3

downs out at the end --

4 MR. PUTNAM: -- to check the quality of 5

that area.

6 MEMBER STETKAR: -- of consumers.

7 MR. COSTANZO: And part of the prevention 8

system is an operator can't go stroke a valve for an 9

IST. If it was an IST stroke, if he doesn't know the 10 history back two to three years and therefore can 11 monitor that, and if there is any change in that 12 prevention protection model, that gets incorporated 13 into the risk model and then you plan the work orders.

14 You get yourself prepared. And that feeds back to 15 the monitoring program. So we would have early 16 indication to be able to stand prevention in that.

17 MEMBER STETKAR: Okay. Thank you.

18 Thanks.

19 MR. PUTNAM: Does that hit on where we are 20 at on scoping? Any other questions on that? All 21 right.

22 Time-limited aging analysis. We do have 23 to take a look at time-limited aging analysis under 24 the regulations in place that our analysis relies on 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 58 on a component of time to determine its adequacy. We 1

have a very good electronic file system of our 2

licensing basis for the facility. Every piece of 3

communication we ever had with the NRC is in a nicely 4

searchable format. We are able to do keyword searches 5

on that and definitely find anything in that realm 6

that mattered for licensing that depended on time.

7 We also went through all our calculations 8

and looked for anything there that was depending on 9

time and we also interviewed our engineers for 10 anything we might miss and compared ourselves against 11 similar plants to see what was in their time-limited 12 aging analysis.

13 So we think we have a good list of those 14 things where time matters in terms of 40 years of time 15 to take a look at.

16 Some of the things we did need to relook 17 at definitely neutron fluence, obviously, changes as 18 you go to 60 years, so we did reperform our analysis 19 for that. We went to the RAMA methodology. We hadn't 20 previously had that. That was a good improvement for 21 us, because it allowed us to do a lot better modeling 22 of our internals. We had good modeling, I think, of 23 the shell, not so good of the reactor vessel 24 internals. So by going to the RAMA methodology, I 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 59 think we improved quite a bit there.

1 We selected 54 effective full power years 2

as the endpoint for the analysis. That will take us 3

out several years past the 60 year life. We can't 4

quite get to 54 effective full power years yet. So we 5

picked a conservative value there.

6 And then using that neutron fluence value, 7

we did recalculate pressure-temperature curves for the 8

vessel and confirmed that we could get acceptable 9

results for those.

10 MEMBER SHACK: You mentioned that you 11 didn't have any cracking on your core shroud yet.

12 What's your fluence at those high fluence welds?

13 MR. PUTNAM: Clara, do you actually have 14 numbers for that? They are high.

15 MEMBER ARMIJO: I was going to add to 16 something, Bill. They did have, they mentioned, a 17 fluence of 5 times 1020th for the top guide.

18 MEMBER SHACK: Well, that's their trigger 19 for inspection.

20 MEMBER ARMIJO: That's their threshold for 21 IASCC.

22 MR. PUTNAM: That's written down.

23 MEMBER ARMIJO: But I believe that's a 24 threshold for conventional water chemistry, not a 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 60 threshold when you are doing hydrogen water chemistry.

1 Really, in a sense, that's my question. You are 2

going to have to do some additional inspection of that 3

top guide, because you are already there as far as 4

that threshold.

5 MEMBER SHACK: Right.

6 MEMBER ARMIJO: And then at 50 years or 54 7

years, you will be two orders of magnitude higher in 8

fluence. So my question is do you believe that the 9

threshold that you are using is valid for hydrogen 10 water chemistry plant?

11 MR. PUTNAM: Conservative.

12 MEMBER ARMIJO: Should you be doing 13 something else?

14 MR. PUTNAM: That is a question I don't 15 recall looking at. Clara, do you?

16 MS. RUSHWORTH: This is Clara Rushworth 17 for Duane Arnold. And no, I'll need to specifically 18 go back and see if I can get some more information for 19 you on the top guide. But as far as the core shroud, 20 I have the fluence numbers here. Is that what you 21 were asking?

22 MEMBER SHACK: Yes, that was. I was 23 curious.

24 MS. RUSHWORTH: Here we go. For 54 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 61 effective full power years, for example, for the H4 1

welds, there is a value of around 4 times 1021st 2

neutrons per centimeter squared. And did you want 3

more specific numbers?

4 MEMBER SHACK: No, that's fine.

5 MS. RUSHWORTH: Okay.

6 MEMBER SHACK: You know, so you, you know, 7

clearly have the fluence, so we can attribute some 8

benefit perhaps to the hydrogen water chemistry.

9 MEMBER ARMIJO: Well, that was the 10 original intent for that whole water chemistry change 11 is to protect the internals without having to replace 12 them. And I just wondered if the Owners Group or 13 someone else has come up with an IASCC threshold that 14 is appropriate for hydrogen water chemistry and noble 15 metals or whether you are just going to stick with the 16 conventional threshold, which I think is the 5 times 17 1020th?

18 MR. PUTNAM: The way we did the method, 19 that's what we compared it to.

20 MEMBER ARMIJO: Okay. So you will be 21 doing augmented inspections to look for any evidence 22 of cracking?

23 MR. PUTNAM: That's correct.

24 MEMBER ARMIJO: Okay.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 62 MEMBER SHACK: So since Sam brought this 1

up, I had a question on your Commitment No. 46.

2 MR. PUTNAM: Okay.

3 MEMBER SHACK: And since that's not in 4

your document, the only verbiage I have on it is in 5

the staff's SER. And the staff's text makes sense to 6

me, because it talks about BWR VIP-100 and fracture 7

toughness and reevaluating that fracture toughness for 8

higher fluences.

9 The actual commitment as it reads says 10 "Plant-specific inspection and rules we develop for 11 Duane Arnold core shroud welds that are exposed to a 12 neutron fluence equal or greater than a 1 times 1021 13 as needed."

14 So my question is are you still using the 15 5 times 1020 fluence threshold for inspection, and 16 this really only applies to the fracture toughness 17 evaluation, or have you changed the fluence threshold 18 for inspection?

19 MR. PUTNAM: I'm going to have to defer 20 over there to the --

21 MS. RUSHWORTH: This is Clara Rushworth 22 for Duane Arnold again. And in our administrative 23 document for the vessel internals and as we mentioned 24

before, we will be doing the core shroud UT 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 63 inspections this coming outage. And as you said, the 1

1E to the 21st, that's for the VIP-100, and the flaw 2

evaluation, should they

occur, and for the 3

reinspection role that is given in the VIP, that value 4

is still 5 times 1020th neutrons per centimeter 5

squared.

6 MEMBER SHACK: Okay.

7 MS. RUSHWORTH: Does that answer your 8

question?

9 MEMBER SHACK: That answers my question.

10 MR. PUTNAM: All right. Thermal cycle 11 projections. If we are done with fluence here.

12 Thermal cycle projections, we did update those for a 13 60 year life. We used where we were at at the time we 14 performed our analysis in terms of actual events we 15 had experienced to that point.

16 Then we projected forward to 60 years 17 using the current rate that we are accumulating 18 thermal cycles. For those events that are very 19 infrequent where we would have been projecting zero, 20 of course, we didn't project zero, we continued to 21 project that those will occur and kept the same number 22 for analysis purpose for those infrequent events.

23 And also for scrams, we had pretty good 24 performance in the period we used for projection. And 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 64 we were worried that that might be too optimistic, so 1

we added some cushion on there of about a little over 2

30 scrams to make sure that we didn't flirt with 3

problems there at some point downstream.

4 And regardless of the number selected for 5

projection, we will monitor those on an ongoing basis.

6 And if we approach one of those assumptions, in terms 7

of thermal cycles, we will take action before getting 8

there, not after getting there.

9 MEMBER STETKAR: Ken, on the thermal cycle 10 projections, I noticed that you have been monitoring 11 actual plant transients since 1998.

12 MR. PUTNAM: Yes.

13 MEMBER STETKAR: So you have, let's say, 14 real-time data since 1998.

15 MR. PUTNAM: Right.

16 MEMBER STETKAR: You went back and 17 reconstructed the operating history prior to 1998.

18 And I know that there was some discussions about 19 cycles that were used in the power uprate analyses 20 and, apparently, those have been reconciled for the 21 license renewal process.

22 Do you have any -- I know the staff asked 23 for it and I was curious whether you had any more 24 detailed information that shows how your trip history 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 65 or your transient history has changed over time?

1 I

mean, typically, you will see a

2 reduction from early years and improved performance in 3

later years. I'm curious where -- you typically find 4

a knee in that performance. So I'm curious about 5

where that knee is relative to the experience that you 6

use to project out into the future.

7 MR. PUTNAM: We didn't bring along a 8

histogram of scrams. You're really asking scrams --

9 MEMBER STETKAR: Yes, that's --

10 MR. PUTNAM: I think we do have one in the 11 background of shutdowns there. Our data gets a little 12 bit skewed because we had an extended outage in '78 13 and '79, so we got like a one year period there with 14 extraordinarily good performance and we were never 15 operating.

16 MEMBER STETKAR: Not many scrams, yes.

17 MR. PUTNAM: I don't think they thought it 18 was good at the time. You know, so it gets a little 19 bit flatter at the beginning of life than maybe --

20 MEMBER STETKAR: Than you would --

21 MR. PUTNAM: -- you would guess. But yes, 22 I think in the first --

23 MEMBER STETKAR: I would be curious.

24 MR. PUTNAM: -- 10 years, we had a high --

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 66 MEMBER STETKAR: Oh, yes, I mean, that's 1

typical performance.

2 MR. PUTNAM: Clearly, we had a high number 3

of scrams. We had extremely good performance in the 4

mid '80s out there.

5 MEMBER STETKAR: What particular period of 6

time for your operating history did you use as the 7

basis for your projection?

8 MR. PUTNAM: Yes.

9 MEMBER STETKAR: In other words, you know, 10 the years that you used to calculate your average 11 number of transients per year going forward.

12 MR. PUTNAM: I think that we used like '98 13 to 2005, something like that, you know, it was roughly 14 seven or eight years --

15 MEMBER STETKAR: About seven years.

16 MR. PUTNAM: -- there in the --

17 MEMBER STETKAR: Perhaps, you know, you 18 could put together or maybe the staff may have the 19 histogram and I can get it from them. We typically 20 don't get all of the RAIs.

21 MR. PUTNAM: If you want to pull up that 22 histogram on shutdown, I don't think we put a 23 histogram of scrams in there.

24 MEMBER SIEBER: Well, the interesting 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 67 thing about the curves of transients over the years is 1

that there is a knee in the beginning. There is also 2

a knee at the end, that's why they call it --

3 MEMBER STETKAR: Not in this one. There 4

is not a knee here.

5 CHAIR BLEY: Bending over gradually.

6 MEMBER STETKAR: I'm used to seeing kind 7

of an inverse of this, but --

8 MR. PUTNAM: Well, you know, in terms of 9

scrams, you know, that's the one thing -- that's the 10 main reason we added that.

11 MEMBER STETKAR: Your recent performance 12 really --

13 MR. PUTNAM: We had a bad year in 2003.

14 MEMBER STETKAR: Yes, I see a bad year in 15 2003. But, you know, on kind of a straight-line 16 averaging here, your recent performance is not 17 tremendously better.

18 MR. PUTNAM: Well, you know --

19 MEMBER STETKAR: In terms of accumulated 20 numbers.

21 MR. PUTNAM: -- I think you probably had 22 twice as many in the first -- or we had 47 in the 23 first 10 years and you have had roughly 60 since -- in 24 the preceding 25 years. So I think there is --

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 68 MEMBER STETKAR: There is improvement. I 1

mean, it's --

2 MR. PUTNAM: -- clearly improvement. And 3

I'll tell you, I think was it '84 to '88, some time in 4

there we had a string of 40 months without a scram.

5 Which at those days was --

6 MEMBER STETKAR: That's unusual.

7 MR. PUTNAM: -- pretty remarkable.

8 MEMBER STETKAR: That's unusual.

9 MEMBER SIEBER: That's remarkable.

10 MR. PUTNAM: That's freakishly low. We 11 had people coming up saying what are you doing out 12 there?

13 MEMBER STETKAR: I was mostly --

14 MR. PUTNAM: Then we immediately in '88 15 had a spike again of scrams and that's where I learned 16 the lesson that scrams aren't actually that 17 predictable. You need to leave some cushion in there 18 for the scram rates.

19 MEMBER STETKAR: Yes. And that's exactly 20 why I asked the question to see whether there was a 21 dramatic change in the operating history and this says 22 not as dramatic as some plants have recognized. And 23 to see the year-to-year variability in that transient 24 experience. And there is some, but not a huge amount.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 69 You said you used 1998 through 2005.

1 MR. PUTNAM: 2005, yes.

2 MEMBER STETKAR: So you saw a couple of 3

spikes in there. Okay.

4 MR. PUTNAM: Yes.

5 MEMBER STETKAR: The other question I had 6

in terms of projecting events, and this is in the 7

experience-base there were a couple of events in, I 8

think, 2006 where -- and I don't know the dynamics of 9

the process. I'm only reading from the experience 10 that apparently events occurred where you had an 11 unusual cool-down in the bottom head and experienced 12 an unusual cooling of the reactor coolant water, you 13 know, bottom head draining line. I'm assuming that is 14 what it was.

15 It is kind of interesting that you 16 experienced two of those kind of events in six years, 17 given your operating experience. You then go on to 18 say that that particular piping, although it is, you 19 know, an external piping from the vessel, has been 20 qualified for more severe transients and many more 21 cycles.

22 When you went back and reconstituted the 23 operating experience from day one up through 1998, did 24 you make any attempt at all to capture those types of 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 70 events that might have caused similar types of over-1 cooling down in the bottom head area?

2 MR. PUTNAM: Well, we definitely were 3

looking for that sort of thing. We didn't find a 4

whole lot of information there. And I guess, you 5

know, I think we put in the application as we came 6

across.

7 MEMBER ARMIJO: In your application you do 8

point out that the vessel shell and lower head will 9

have a

cumulative usage

factor, including 10 environmental effects, of.996 at the end of year, 11 which one comment is that's remarkably precise,.996.

12 MR. PUTNAM: Yes.

13 MEMBER ARMIJO: Which it's slightly lower 14 than one. But so I'm not sure you believe that number 15 to that --

16 MR. PUTNAM: Accuracy?

17 MEMBER ARMIJO: -- accuracy. But the 18 question is were those unusual cooling events the main 19 reason for that usage factor being so high? It's 20 surprisingly high.

21 MR. PUTNAM: They have a big environmental 22 penalty there. Those were actually ones with 23 relatively low cumulative usage factors before you 24 applied the environmental penalty, you know, so those, 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 71 I think, are unrefined calculations, because they had 1

such a low number initially and then they had a high 2

environmental penalty you put on there and that's how 3

we got up there as high as we were.

4 MEMBER ARMIJO:

Aren't these clad, 5

stainless steel-clad on the vessel at the bottom head?

6 And that's part of --

7 MR. PUTNAM: Clara is bending her head 8

there. I don't think that will make it into the 9

transcript, Clara.

10 MS. RUSHWORTH: Yes.

11 MEMBER ARMIJO: You have seen unusually 12 high, because there were a couple of other locations, 13 outlet nozzles and safe-ends for the same period of 14 time, including environmental effects, the usage 15 factors are like.19 or.2, but just the lower head 16 seems like unusually high. I still don't understand 17 what is going on there.

18 MR. PUTNAM: Well, Clara?

19 MS. RUSHWORTH: This is Clara Rushworth 20 for Duane Arnold again. As Ken said, the lower head, 21 those calculations were not refined. And the 22 calculations you are looking at, I believe, are for 23 the recirc outlet nozzle, feedwater nozzle and the 24 coarse spray nozzle. We had those calculations 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 72 refined ASME Code, the six stressors calculations 1

redone, finite element analysis by structural 2

integrity and environmental factors applied and with 3

those refinements, it shows much lower numbers.

4 MEMBER ARMIJO: So are you telling me that 5

the.996 is just very, very conservative?

6 MS. RUSHWORTH: That's correct.

7 MEMBER ARMIJO: And if you had applied 8

similar refinements, it would be less? You don't know 9

how much, but it should be less.

10 MR. PUTNAM: Correct.

11 MS. RUSHWORTH: That would be correct.

12 And we have not done, so, of course, we can't say for 13 sure, but that's based on the 40 year usage factor, 14 which was based on a lot of conservatisms and then 15 that adjusted for the cycles for 60 years and then the 16 environmental factors placed on.

17 So that was not using a finite element 18 analysis.

19 MEMBER ARMIJO: Okay. Thank you.

20 MR. PUTNAM: Mike, can you get us back to 21 the presentations here?

22 CHAIR BLEY: I'm going to interrupt you 23 for just a minute. We are running a bit behind. You 24 have a lot of slides left and we want to make sure we 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 73 get to your open item discussion at the end, so I'm 1

going to ask you to go ahead. Staff doesn't need 2

quite as much time as they have budgeted, so you can 3

go over, but let's aim for a quarter after or 20 4

after, something like that. See if we can get there.

5 MR. PUTNAM: Okay. We have already talked 6

about environmental fatigue adjustments. We made 7

those adjustments and we were asked by the staff about 8

new data on Alloy 600. We didn't reperform the 9

calculations using that new rate for new plants, but 10 we did check to see if the data in there, if we just 11 plugged that in in a conservative way, would it move 12 us above CUF < 1.0. And the conclusion was no, it 13 wouldn't alter the conclusions if we used that.

14 Environmental qualification calculations 15 are all updated to 60 year life without any real 16 problems here.

17 Next slide, Mike. Ultimately, our whole 18 point here, of course, is to get aging management 19 programs that make sure we manage aging in the plant 20 in the renewed term.

21 We tried to stay as close to the goal as 22 practical. We ended up with 43 aging management 23 programs. 19 of those are existing ones that just 24 will keep doing. They don't need enhancements.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 74 10 of the programs are existing, but they 1

do need enhancements. Typically, those are places 2

where we had to add more restrictive acceptance 3

criteria or we need to apply the program to more 4

pieces of equipment than we currently are.

5 And then we had 14 new programs, some of 6

which aren't entire new. We may be doing individual 7

maintenance tasks out in the field that are remarkably 8

similar, but they weren't organized in a programmatic 9

way, so we called those out as new programs.

10 In terms of GALL consistency, we ended up 11 with 28 programs consistent. 11 that were consistent 12 with exceptions and four that were plant-specific. A 13 couple of those are ones that could become issues with 14 ISGs that were consistent with and a couple are unique 15 to us.

16 Next slide. We did a number of industry 17 issues during our project. Station blackout boundary, 18 for some plants that's kind of a hard one if their 19 switchyards are a long way away from the plant. For 20 us, it's easy. During that flood part of the show 21 there, the switchyard is right next to our power 22 plant, so that wasn't a problem for us to go out to 23 the breakers in the switchyard.

24 Clara mentioned that we did any 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 75 refinements to calculations.

We didn't use 1

simplifying assumptions. We did full bore ASME 2

calculations for those.

3 Generic Letter 2007-01 came along during 4

our project where we were a lot more focused on the 5

status of power cables underground. We thought we 6

were in pretty good shape there, but we did find we 7

needed to do some improvements to our sump pumps to 8

make sure those were as reliable as we thought they 9

should be and we also had to add some inspections for 10 manholes without sump pumps to make sure even though 11 they are at higher elevations and shouldn't be as 12 likely to get water in them, we do need to inspect to 13 make sure we keep those in good shape.

14 CONSULTANT BARTON: Do you have any 15 experience of any cables that have failed as a result 16 of being submerged or wetted?

17 MR. PUTNAM: No power cables. Mike, do 18 you want to?

19 MR. FAIRCHILD: No, we have had some 20 inaccessible cables, 125-volt dc control cables.

21 CONSULTANT BARTON: Okay.

22 MR. FAIRCHILD: That have failed, but we 23 haven't pulled any of them out to do any recross 24 testing on them other than one that we could see and 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 76 that was an installation error.

1 CONSULTANT BARTON: Okay.

2 MR. FAIRCHILD: The bend radius was too 3

tight.

4 CONSULTANT BARTON: Okay.

5 MR. FAIRCHILD: But none of them have 6

failed coincident with water.

7 CONSULTANT BARTON: Okay. Thank you.

8 MR. PUTNAM: Then Information Notice 2009-9 26 on degradation of neutron absorbers came out during 10 our review and we had to adjust our program there to 11 add a Boral Surveillance Program. We ended up with 50 12 commitments for license renewal, even though we are 13 numbered up to 51, I notice you counted our number 14 there. We have one of the commitments we ended up not 15 using as it changed during the course of the review.

16 The commitments are entered into our site 17 commitment tracking system, just like any other 18 commitment. We are relatively close to the end of our 19 period of extended -- or to our period of our license, 20 so we are moving straight into implementation 21 activities. We are not waiting on any of those. So 22 our goal is to be ready well in advance of the period 23 of extended operation.

24 We will retain a portion of our project 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 77 core team to support the implementation activities 1

with the program owners on the site. And for some of 2

the bigger commitments, we have set up specific 3

projects for running those and making that step change 4

for us to make sure those get the right oversight and 5

management attention for those hard ones to get 6

accomplished.

7 Any questions on that?

8 MEMBER STETKAR: Just one, sorry. Your 9

operating experience says you have had a leak in your 10 spent fuel pool since 1994. And you are confident 11 that you are currently collecting all of that leakage.

12 What are you doing to stop the leak? Do you know 13 where it is coming from?

14 MR. PUTNAM: No.

15 MEMBER STETKAR: And what's the leakage 16 rate?

17 MR. PUTNAM: The leakage rate is about 280 18 milliliters a day. And so about a little over a cup.

19 We have looked for it. We have not found a source 20 for that very, very small leakage.

21 CONSULTANT BARTON: Is it affecting any 22 equipment in the sortability?

23 MR. PUTNAM: No, no. It goes into a case 24 and then it goes to a series of drains that our 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 78 operators check every day. I think it's every day or 1

is it every week? Frequently.

2 CONSULTANT BARTON: Are you trending it?

3 MEMBER STETKAR: Is there any indication 4

that it is increasing?

5 MR. PUTNAM: No. It has been pretty 6

stable for years and years.

7 CONSULTANT BARTON: Okay.

8 MR. PUTNAM: Unchanged.

9 MEMBER STETKAR: Okay. Thank you.

10 MR. PUTNAM: There are two open items.

11 Buried piping and small bore piping. We will talk 12 about those later. And there were no confirmatory 13 items in the safety evaluation. Okay.

14 The first item here and it's not an open 15 item, but it is an item that has been of some interest 16 I know and a lot of interest to us, our torus 17 coatings. Our IWE Program has identified numerous 18 areas of zinc depletion on our torus coatings and 19 minor pitting.

20 I think the staff's main concern with it 21 is there is not really anything defined in the ASME 22 Code for when do you got to go replace those coatings 23 or restore those coatings. And so they were 24 interested in how we were going to manage that.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 79 Our torus was last coated in 1985. It is 1

a zinc oxide coating with a belly band of phenolic at 2

the water line. We do perform routine inspections, 3

obviously, under the IWE Program and we touch up any 4

areas of problems during the outage.

5 CONSULTANT BARTON: The original coating 6

only lasts about 10 years?

7 MR. PUTNAM: Correct.

8 CONSULTANT BARTON: Wow.

9 MEMBER ARMIJO: And it was replaced with 10 the same coating?

11 MR. PUTNAM: Yes.

12 MEMBER ARMIJO: Now, in the previous 13 review, somebody stated this was a zinc metal coating 14 in the phenolic. Is it zinc oxide or is it zinc 15 metal?

16 MR. PUTNAM: Eric, do you want to answer?

17 MR. SORENSON: The actual coating is a --

18 this is Eric Sorenson for Duane Arnold. The actual 19 coating is a carbo-zinc 11. It's a zinc oxide 20 coating.

21 MEMBER ARMIJO: Zinc oxide. In a 22 phenolic --

23 MR. PUTNAM: The phenolic is only at the 24 belly band, right?

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 80 MR. SORENSON: Yes, but there is a 2 foot 1

belly band that has a phenole-lined 386 WG. It's a 2

phenolic coating.

3 MEMBER ARMIJO: So that's plus or minus a 4

couple of feet?

5 MR. SORENSON: Right. That's plus or 6

minus a foot.

7 MEMBER ARMIJO: Okay.

8 MEMBER SIEBER: And you have only found 9

one pitting defect below mid-wall?

10 MR. PUTNAM: It was beyond 10 percent. It 11 wasn't below mid-wall.

12 MEMBER SIEBER: Okay.

13 MEMBER SHACK: The SER --

14 MEMBER SIEBER: Just one out of a 15 potential of thousands, right?

16 MR. PUTNAM: Yes, yes.

17 MEMBER SIEBER: Okay.

18 MEMBER SHACK: The SER says you are going 19 to replace the coating according to ANSI N101.2, which 20 is a 1972 standard that has been withdrawn so long ago 21 I can't find a copy of it in any of the databases.

22 I'm just wondering, I mean, I can understand why you 23 don't want to redesign your piping, but, you know, why 24 wouldn't you use a more modern standard for your 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 81 coating?

1 MEMBER SIEBER: You might have trouble 2

finding the coating.

3 MR. PUTNAM: Eric?

4 MEMBER SHACK: Is that the staff putting 5

words in your mouth here?

6 MR. SORENSON: This is Eric Sorenson 7

again. No. We are not committed to Reg Guide 1.154 8

Rev 0. And when we responded to Generic Letter 98.04 9

regarding our debris accumulation and how we were 10 treating our coatings, that was the standard that we 11 were using at the time and we still use. That's what 12 we were originally committed to.

13 MEMBER SHACK: Yes, I realize that it's 14 your original commitment.

15 MR. SORENSON: However, I will acknowledge 16 that we have -- our program does recognize the more 17 current standards for the ASTM, so our program is 18 built around more current ASTM Standards as sub-19 documents to 101.4.

20 MEMBER SHACK: Okay.

21 CONSULTANT BARTON: Do you do outage 22 sludge removal every outage? Get much man-rem out of 23 that?

24 MR. PUTNAM: Man-rem?

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 82 CONSULTANT BARTON: Yes. If you are 1

pumping your EMRVs in there occasionally and going and 2

cooling down those engine causants, you know.

3 MR. PUTNAM: Is this radioactive? I don't 4

recall that being a real --

5 CONSULTANT BARTON: Okay.

6 MR. PUTNAM: -- big dose.

7 MR. SORENSON: I don't believe. We don't 8

desludge necessarily for the man-, this is Eric 9

Sorenson again, rem exposure. We desludge to remove 10 the potential for the pit growth underneath the 11 sludge. We do the sludge removal every other outage 12 with divers with mechanical pumps underneath and with 13 brushes that they can remove it with. Otherwise the 14 other outage we use people from the catwalk with 15 extended vacuums doing it. So it's a much less 16 efficient desludge, but we do do a full desludge and 17 wall scrub basically every other outage.

18 And since we have this past outage when we 19 went in and we observed a significant change in the 20 amount of degradation we have seen in the torus due to 21 zinc, pure zinc depletion. So we have now changed our 22 program to an every other outage with divers going 23 into our torus, during every outage with divers, and 24 doing repairs to the torus that we find until we get 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 83 to a point where we do the full recoat.

1 CONSULTANT BARTON: So this is --

2 MEMBER ARMIJO: It seems to me for all the 3

money that is spent on divers, you could recoat the 4

torus.

5 MR. PUTNAM: I don't believe that math 6

works. I'm sure it's an extraordinarily large project 7

to recoat the torus. That is a major, major 8

commitment.

9 CONSULTANT BARTON: There was a plant that 10 did it.

11 MR. SORENSON: I would say we did. At 12 Duane Arnold we did recoat the torus in 1985 and our 13 cost back then was, approximately, $6 million. And we 14 expect that it is significantly, at least twice that 15 much --

16 MR. PUTNAM: Yes, double.

17 MR. SORENSON: -- or more to do it at this 18 point.

19 CONSULTANT BARTON: Okay.

20 MR. PUTNAM: And we are scheduling to do 21 that in the 2012 outage currently.

22 Recent industry events on buried piping, 23 unless there were other questions on torus?

24 Buried piping, the issue is that recent 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 84 industry events involving leakage from buried and 1

underground piping may warrant changes to the buried 2

piping tanks inspection program.

3 CONSULTANT BARTON: Do you have any 4

tritium issues at the site?

5 MEMBER SIEBER: If you're doing that kind 6

of work.

7 MR. PUTNAM: Certainly we produce tritium.

8 CONSULTANT BARTON: Do yo have any --

9 MR. PUTNAM: We have a tad tritium --

10 CONSULTANT BARTON: Have you found any?

11 MR. PUTNAM: We haven't had tritium above 12 the threshold reporting.

We haven't had any 13 indication of tritium for pipe leaks at this point.

14 CONSULTANT BARTON: Okay.

15 CHAIR BLEY: How much buried pipe do you 16 have?

17 MR. PUTNAM: Oh, a lot. Al?

18 MR. THOMAS: How much buried pipe do we 19 have? This is Al Thomas for Duane Arnold. I don't 20 know the exact number off the top of my head. The 21 vast -- a good piece of it is from the intake 22 structure to the pumphouse.

23 CONSULTANT BARTON: Sure.

24 MR. THOMAS: Which there is three 24 inch 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 85 diameter line and they are about 1,800 feet long.

1 MEMBER STETKAR: What kind of pipe is 2

that? Is it carbon steel? Normal steel, normal 3

carbon steel?

4 MR. THOMAS: It's A16, Grade B, 24 inch 5

diameter stain or scheduled 312.

6 MEMBER STETKAR: Coated and lined?

7 MR. THOMAS: It's externally coated. It's 8

not lined on the inside.

9 CHAIR BLEY: Go ahead.

10 MR. PUTNAM: All right. I guess before I 11 move on too far here, we talked about underground 12 piping and buried piping and I want to make sure there 13 is no miscommunication on that.

14 Underground piping is piping that is 15 exposed to air that happens to be below-grade 16 typically involves chases of some sort.

17 Buried piping is in contact with soil. We 18 do have a limited amount of underground piping at 19 Duane Arnold. Not very much. And all of that is 20 accessible. There is not stuff that is difficult to 21 get at and look at, so where appropriate in license 22 renewal process, that that piping would be typically 23 managed by external surface monitoring, not the buried 24 piping program.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 86 But I'll focus most of my discussion here 1

on the buried piping program. The industry certainly 2

recognizes that this is an important issue. So far, I 3

don't think there has really been so much safety 4

significance to the events, but certainly things that 5

matter to our stakeholders.

6 In response to that, there is an NEI 7

Initiative where they issued guidelines in January of 8

this year and we do support that and have actively 9

participated with them.

10 In

addition, EPRI has issued out 11 guidelines, kind of more technical guidelines on how 12 to control degradation of buried piping in the yard 13 following that.

14 CONSULTANT BARTON: So it is direct 15 buried, it's not in vaults, right?

16 MR. PUTNAM: That's correct.

17 CONSULTANT BARTON: Okay.

18 MR. PUTNAM: Yes, anything that is 19 underground for us, not in contact with soil is a 20 couple of vaults for cross-connecting pipes and some 21 manholes for the sump pump discharge piping and some 22 diesel fuel oil lines happen to run through an access 23 manway, where you can climb down to the top of the 24 tank. So it's very limited underground. Most of it 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 87 is buried.

1 Our fleet-issued guidance is -- our fleet 2

is participating actively with the industry in this.

3 And mid-course, our fleet elected to issue guidance 4

documents, upgrade our program with respect to buried 5

piping and then DAEC, out of that fleet guideline, 6

developed implementing procedures on-site where we are 7

really going above and beyond the minimum requirements 8

that are in the GALL or that had historically been out 9

there for how you manage buried piping. It mentions 10 underground is accessible.

11 Next slide.

12 CHAIR BLEY: Before you leave that one, 13 oh, no, you still have more buried pipe. Go ahead.

14 MR. PUTNAM: Got more buried piping, yes.

15 CHAIR BLEY: Okay.

16 MR. PUTNAM: We haven't had a history of 17 any leaks on our in-scope buried piping. We have had 18 leaks on our well water piping that is not in scope.

19 Those seem to be kind of unique to their material and 20 the physical location of those well water pipes, but, 21 you know, definitely one lesson that we can take from 22 that well water piping issue is that we are not immune 23 to problems on buried piping. It can happen to us and 24 it's something we do need to manage.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 88 We have had a fair bit of maintenance work 1

on fire protection piping in the last couple of years.

2 We took the opportunity to examine that piping when 3

it was excavated. We are happy to have found that 4

piping in very good condition, so that was a good 5

indicator.

6 We performed torsional guided wave exams 7

on our HR service water piping, emergency service 8

water piping and river water supply piping. Last year 9

on roughly 20 locations that identified -- and by the 10 way, I might comment here, that's really a screening 11 tool. It's not an absolute answer, but it gives you--

12 helps you pick what place do you want to go look 13 harder at.

14 And so out of that, we identified four 15 areas we wanted to go look at harder. We will be 16 excavating those this year or doing some sort of 17 examination, detailed examination of that piping this 18 year.

19 MR. COSTANZO: Yes, we have considerable 20 understanding of what this issue is, both at the fleet 21 level and at the site level. And actually, you know, 22 both the detection, the mitigation and the long-term 23 strategy has been budgeted, you know, at least through 24 2015, which we have just approved just recently. We 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 89 will commit those resources. We will commit the time 1

and effort to make sure that we stay ahead of this one 2

in prevention.

3 MEMBER SHACK: How long a run can you do 4

with the torsional guided wave?

5 MR. PUTNAM: It depends, I think. Al, 6

maybe you want to answer that?

7 MR. THOMAS: This is Al Thomas. Would you 8

repeat the question again, please?

9 MEMBER SHACK: How long a run can you do 10 with the guided wave? How far will it penetrate?

11 MR. THOMAS: Basically, with the guided 12 wave, it will basically go through two elbows. Okay.

13 It will go a long ways in straight pipe.

14 MEMBER SHACK: Pipe.

15 MR. THOMAS: But basically the second 16 elbow is about the end of your exam.

17 MEMBER SHACK: Okay.

18 MEMBER SIEBER: If you have a leak, a 19 small leak, in your buried piping, would you really 20 know it?

21 MR. PUTNAM: I don't know. It depends, I 22 think, is the answer. I think if you had a few drops 23 a minute coming out of an ESW pipe, you would never 24 know.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 90 MEMBER SIEBER: Would never know.

1 MR. PUTNAM: You would never know.

2 CHAIR BLEY: Use the mike.

3 MR. PUTNAM: Whoops, I'm sorry. Yes, I 4

don't think you would see a tiny leak like a few drops 5

a minute. I'm sure you would see a few gallons a 6

minute, because you would be coming up to the surface 7

floor area.

8 MEMBER SIEBER: Yes. On the other hand, 9

you really can't say for sure you have no leakage, 10 right?

11 MR. PUTNAM: That's correct.

12 MEMBER SIEBER: You really can't tell.

13 MR. PUTNAM: Yes. Well, what we have done 14 with the operating experience is looked back in time 15 of anything that we have seen in our Corrective Action 16 Program.

17 MEMBER SIEBER: Okay. Have you seen any 18 buildup of material inside of, for example, cooling 19 water piping? That refers to a lot of plants where 20 organisms from the river or where they are getting it 21 from gets inside lines that are ordinarily very low 22 flow, which during emergency testing provide much more 23 flow and tend to clog those lines? Have you seen any 24 evidence of that? That you know of.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 91 MR. PUTNAM: In these buried pipes? You 1

know, those pipes -- now, the river water supply, 2

those are normally operating. They are running at a 3

flow rate comparable to emergency conditions normally.

4 ESW and HR service water, those we do full flow tests 5

on routinely on a quarterly basis, so we would, you 6

know, see it. If there was a flow blockage, we would 7

definitely see that.

8 MEMBER SIEBER: But your detection of 9

blockage is by periodically measuring flow and the 10 flow is at full force as opposed to any kind of 11 inspection or other means to decide what is actually 12 inside the piping? Is that correct?

13 MR. PUTNAM: I believe that is correct, 14 unless somebody -- you know, there is a lot of 15 preventive maintenance out there on some of those 16 downstream components. But I think in terms of those 17 buried pipes we're talking about, definitely I would 18 say it's by flow.

19 MEMBER SIEBER: Some plants have found 20 that to be a problem. Some plants that I have worked 21 at have found it to be a problem. Thank you.

22 MR. PUTNAM: Okay.

23 MEMBER STETKAR:

Ken, you mentioned 24 earlier we discussed the instrument or the compressed 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 92 air systems. You replaced the piping from the air 1

compressor building wherever the air receivers are.

2 Was there evidence of corrosion in that piping?

3 MR. PUTNAM: No, not really. I would say 4

that piping was in pretty good condition.

5 MEMBER STETKAR: Okay.

6 MR. PUTNAM: It was a little different.

7 You know, it wasn't in-scope piping.

8 MEMBER STETKAR: No, that's --

9 MR. PUTNAM: It's a little different 10 coating, so I didn't include it on this slide.

11 MEMBER STETKAR: Yes, yes.

12 MR. PUTNAM: So it's --

13 MEMBER STETKAR: That's why I asked you 14 about it.

15 MR. PUTNAM: But it was in good condition.

16 MEMBER STETKAR: Okay. Thanks.

17 MR. PUTNAM: All right. And we have 18 checked the diesel fuel oil tank using UT and found 19 that in good condition, so that's another positive 20 indicator for us. And we will do another check of 21 that, I think, in 2012 as scheduled.

22 MEMBER SIEBER: Did you find a lot of 23 water or sludge in the bottom of the tank?

24 MR. PUTNAM: No. No, we check for water, 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 93 you know, routinely under that fuel oil. The program, 1

the whole objective is to keep that out of there. You 2

know, the withdraws they are a little bit above the 3

bottom. It's the only place you would be really very 4

worried about.

5 MEMBER SIEBER: Yes.

6 MR. PUTNAM: We are doing additional 7

torsional guided wave exams and we started those, I 8

guess, at the end of May there. We started doing some 9

additional pipes there next to the condensate storage 10 tank. And as I said, the ones we identified in 2009 11 for follow-up will be inspected yet this year.

12 You know, in terms of resolving the open 13 item, we did submit a response to the NRC's questions 14 on May 28th and we will work with the staff on 15 anything more that needs to be done there.

16 But fundamentally, you know, re recognize 17 that buried piping is something we need to continue to 18 move forward with the industry in doing the best job 19 we can with that component.

20 Next topic. Socket welds. The issue 21 really is --

22 CHAIR BLEY: Oh, on the buried pipe --

23 MR. PUTNAM: Yes.

24 CHAIR BLEY: -- have you now responded to 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 94 the RFI on that?

1 MR. PUTNAM: We did.

2 CHAIR BLEY: You think it should close?

3 You don't know, but you have submitted?

4 MR. PUTNAM: We have submitted it. You 5

know, clearly, it's our objective to do that. I don't 6

know whether some of the details will mean more. The 7

staff hasn't finished their review on it.

8 CHAIR BLEY: Okay. So we will hear from 9

them in a minute. But on your part, you have done 10 what you think you need to do?

11 MR. PUTNAM: We answered their question.

12 CHAIR BLEY: Okay. Go ahead.

13 MR. PUTNAM: Yes, socket welds. This is a 14 little more straightforward topic.

NUREG-1801 15 recommends a volumetric exam of small bore Class 1 16 piping using qualified techniques. And right now, 17 there is no qualified volumetric exam to technique for 18 socket welds.

19 Surface exams, obviously, don't detect 20 flaws coming from the inside out. And the staff is 21 interested in -- regardless of the qualification of 22 the examination, they feel that there are exams that 23 can be done that would provide meaningful information, 24 even if those socket weld configurations preclude a 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 95 perfectly qualified exam.

1 Since we have submitted our application, 2

there have been ongoing industry efforts to improve 3

those examination technologies and those seem to be 4

actually making a fair bit of progress there.

5 CHAIR BLEY: Let me ask you a question.

6 As I read the things going back and forth on this, it 7

wasn't completely clear to me. Is your position on 8

this one about the no industry-accepted qualified exam 9

a, it's the wrong word, but, legal objection or is it 10 a technical one? Do you think there is no good 11 volumetric exam you can use that will give you good 12 information?

13 MR. PUTNAM: I think when we submitted, I 14 would say I would have been biased towards -- I don't 15 think there are good exams. If you looked at the 16 published data back in that time frame --

17 CHAIR BLEY: Yes.

18 MR.

PUTNAM:

they were very 19 questionable, in my opinion. As a matter of fact in 20 one study, I saw they had about -- and I'll mess up 21 the numbers here, but, when they looked at socket 22 welds with known flaws, they had about a third of the 23 flaws they found correctly.

24 CHAIR BLEY: Yes.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 96 MR. PUTNAM: About a third of the flaws 1

they didn't find. And a third of the flaws that they 2

couldn't distinguish them from other things going on 3

there, which for me I was kind of worried that might 4

be -- you might get false positives out of that.

5 CHAIR BLEY: Sure.

6 MR. PUTNAM: So I would say in 2008, I 7

wouldn't have been -- I would have been uncomfortable 8

sending people into the field to perform it or we 9

would have had to restrict what they looked at very 10 harshly.

11 CHAIR BLEY: Okay.

12 MR. PUTNAM: I think since then, and I'm 13 not a UT guy at all, but our NDE Level 3 tells me he 14 is pretty optimistic about some of the things that 15 they are doing lately and so he is real interested in 16 it and he thinks he can do good exams at some point 17 here in the future with the right planning and the 18 right equipment for it. So that's kind of where he is 19 at. You know, he hasn't done it yet.

20 CHAIR BLEY: Yes.

21 MR. PUTNAM: So --

22 CHAIR BLEY: I understand. Okay. Thanks.

23 Go ahead.

24 MR. PUTNAM: All right. Next slide, Mike.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 97 In terms of operating experience, we did have one pin 1

hole leak in 1989 on a Class 1 pipe. The apparent 2

cause for that was fatigue cracking due to vibration 3

and some apparent problems with initial fit-up. That 4

pike was, of course, replaced, refabricated and 5

replaced slightly differently and we verified that the 6

vibration problems weren't present after that and we 7

haven't experienced any further problems in Class 1 8

small bore piping since, in terms of socket welds, 9

then.

10 So at any rate, with the operating 11 experience, I'm directing we have to have a plant-12 specific program. We do have that.

13 Next slide, Mike. We did submit a 14 response to the NRC's open item. We are proposing 15 that we will do a volumetric exam of 10 percent of the 16 Class 1 socket welds. If a qualified technique is 17 available, we will use that, of course.

18 If one is not available, we will develop a 19 plant-specific procedure for performing it and we 20 will, you know, restrict the procedure to match the 21 technology that is available to us under that. So 22 that's socket welds. Unless there is more questions 23 on that?

24 Okay. Are there any questions?

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 98 CONSULTANT BARTON: I got a question. You 1

could tailor that, the story of years ago. And I know 2

it's for -- beyond design basis accidents. So it's 3

not included in your Aging Management Program.

4 The question I have is do you at least 5

have a preventive maintenance procedure? Can you at 6

least do something with that system on some periodic 7

basis?

8 MR. PUTNAM: Yes, some of the components 9

are actually in-scope. They happen to fall into, you 10 know, some of the other containment systems and so 11 those components out to the ruptured disk are in-12 scope. You know, how that sits once you have the 13 isolation valve and a ruptured disk that go at a 14 certain -- at a pressure above Pa but below the dent 15 you are intending to mitigate, below the design 16 pressure of the containment.

17 And there are PMs on those ruptured disks.

18 CONSULTANT BARTON: Okay.

19 MEMBER RAY: You have a turbine-driven 20 RCIC pump?

21 MR. PUTNAM: Yes.

22 MEMBER RAY: Does anybody know how often 23 it is surveilled?

24 MR. PUTNAM: Quarterly full blown test.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 99 MEMBER RAY: What's your experience with 1

that?

2 MR. PUTNAM: Recent experience has been 3

very good. You know, if you went back to the '80s not 4

so good.

5 MEMBER RAY: That's all I have.

6 MR. PUTNAM: No, I think recently it has 7

been very reliable. I think that system is agreeing.

8 CHAIR BLEY: Anything more from the 9

Committee? John, do you want to follow-up with 10 something?

11 CONSULTANT BARTON: You had this dollar 12 weld indication. I think it's on your vessel head 13 failed ASME acceptance standard, but you think it's 14 okay? What do you know about that? What can you tell 15 me about that?

16 MR. PUTNAM: Well, I'm going to pull up 17 another person from the background here.

18 MS. RUSHWORTH: This is Clara Rushworth 19 for Duane Arnold again. And we had identified on 20 indication in the dollar weld some years ago. We did 21 a flaw evaluation on it, submitted it to the staff for 22 approval and I believe we have an SE for that. And I 23 could look that information up if you would like.

24 CONSULTANT BARTON: Okay.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 100 CHAIR BLEY: Anything more? I think, at 1

this time, we will recess for 15 minutes until 10:30 2

and come back and then we will hear from the staff.

3 Thank you.

4 (Whereupon, at 10:12 a.m. a recess until 5

10:29 a.m.)

6 CHAIR BLEY: Okay. The meeting will come 7

back in session, please. And we will proceed with the 8

staff. I don't know who is starting this. Brian?

9 MR. HOLIAN: This is Brian Holian.

10 Introductions again, we have besides Benny Jose from 11 Region III, I just wanted to highlight he has had 12 seven years as an inspector in Region III, has 13 industry time at a couple of plants in Region III and 14 also some time in Sargent 1 before coming to the NRC.

15 Brian Harris has been the lead Project 16 Manager. His first project coming through license 17 renewal, so we're glad to have him present.

18 And also up there helping him just mainly 19 with the slides is John Daly. John has been with the 20 Kewanee Plant, which will come next month to ACRS.

21 And with that, Brian Harris.

22 MR. HARRIS: Okay. Good morning. Go 23 ahead, John.

24 CHAIR BLEY: Morning.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 101 MR. HARRIS: My name is Brian Harris. I'm 1

the Senior Project Manager for the Duane Arnold Energy 2

Center License Renewal Application.

3 So you have heard from Brian Holian, our 4

Director of the Division of License Renewal. Also we 5

have joining me today Bo Pham, Branch Chief of the 6

Reactor Project Branch 1, and Benny Jose, Region III 7

Inspection Team Leader.

8 Also seated in the audience are members of 9

the Technical Staff who participated in the review of 10 the license renewal application or in audits that were 11 conducted at the applicant's facility.

12 So I'll begin by providing an overview of 13 the LRA and the staff's review. Then we will discuss 14 Section 2 of the SER. And Mr. Benny Jose will discuss 15 the license renewal inspections and findings. And 16 then I'll discuss the staff's review of the Section 3 17 and 4 of the safety evaluation report.

18 CHAIR BLEY: Okay.

19 MR. HARRIS: The LRA was submitted by 20 letter dated September 30, 2008 and supplemented by 21 letter dated January 23, 2009. The unit is a GE 22 Boiling Water Reactor with a Mark 1 containment.

23 An extended power uprate was granted in 24 November of 2001.

And the operating license 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 102 expiration is in year 2014.

1 The plant is located near Cedar Rapids, 2

Iowa.

3 For the staff issues, the SER open items, 4

on May 7, 2010, there are two open items: The first 5

is Open Item 3.0.3.3.3 that's related to socket welds 6

in the small bore piping program and Open Item 7

3.0.3.1.7 is related to buried piping and Tanks 8

Inspection Program, which we will discuss later in 9

this presentation.

10 There are no confirmatory items.

11 So the NRC Review Team has conducted two 12 audits and one inspection at the Duane Arnold Energy 13 Center cited during the periods listed on the slide.

14 The staff started the on-site review with the aging 15 management audit in mid-August followed by a scoping 16 and screening methodology towards the end of August.

17 The Region III conducted its inspections 18 in November to review the applicant's scoping and 19 screening and aging management programs.

20 I'll now move on to Section 2 of the SER.

21 Section 2 discusses structures and components subject 22 to aging management review.

23 Within Section 2 we have scoping and 24 screening methodology; plant-level scoping results; 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 103 scoping and screening, excuse me, mechanical system; 1

structures; and electrical and instrumentation and 2

controls.

3 Based on review of the LRA and additional 4

information submitted as a result of requests for 5

additional information, the staff concluded that the 6

applicant's methodology is consistent with the 7

requirements of 10 CFR.54.4(a) and 54.21(a)(1).

8 Benny Jose, the Region III Inspection Team 9

leader will now discuss the results of his inspection.

10 MR. JOSE: Good morning again. I'm Benny 11 Jose. I'm the team lead for the regional inspection 12 of the 71002 inspection.

13 As Brian mentioned in the previous couple 14 of slides that we completed our inspection during 15 November of 2009 and the first part of the inspection 16 we concentrated on scoping and screening.

17 And we focused on the systems that -- non-18 safety-related systems that affected the safety 19 systems and also the four regulated events which are 20 fire protection, station blackout, ATWS and SBO.

21 During our review, we focused on, you 22 know, the system or the scoping boundary line, scoping 23 and screening reports. We did walk-downs of the 24 systems. And just to observe the general condition 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 104 for us to verify the scoping of all the components.

1 And during our review, we did identify a 2

few items that were not actually scoped in. Some of 3

it due to drying errors and some of it due to simple 4

mistakes by omitting.

5 One of the examples were the river screen 6

house, we did find two of the recent dampers which 7

were not scoped-in and due to our questioning, they 8

were scoped-in.

9 And as part of our inspection, the 10 licensee did send a

letter subsequent to our 11 inspection, which is NG-09-0823 and Enclosure 2 to 12 that letter actually lists all our findings in that.

13 And in general scoping and screening was found to be 14 acceptable.

15 And after the scoping and screening we 16 moved down to the Aging Management Program. They had 17 about a total of 43 Aging Management Programs and we 18 reviewed about 30 of them, which is roughly 70 19 percent, which is normally our norm. We couldn't 20 possibly look at all of them.

21 We chose those 30 Aging Management 22 Programs based on their safety significance. They 23 also had a 70/30 percent difference in new programs 24 versus existing programs. About 70 percent of them 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 105 were existing programs. And we chose the majority of 1

our 30 systems did include a good percentage of 2

existing systems and a small representation of the new 3

programs, because we found that looking at new 4

programs, we can't really add much value, because they 5

are all promises to be in accordance with GALL just 6

before the end of the -- just before the period of 7

operation.

8 CONSULTANT BARTON: Well, on the Aging 9

Management Program inspection, the Inaccessible Medium 10 Voltage Cable Program --

11 MR. JOSE: Yes, sir?

12 CONSULTANT BARTON: -- the applicant 13 stated that it is a new program using existing 14 inspection monitoring activities, consistent with 15 GALL. And they have done all the testing. Why is it 16 that this is an existing program versus a new program, 17 if they have already been -- they say they have been 18 doing this testing.

19 MR. JOSE: Well, they categorized that as 20 a

new program which uses existing monitoring 21 techniques or which uses existing monitoring in terms 22 of testing that is just MEGGER. I believe the type of 23 cables that they have are without -- what do you call 24 that, those cannot be. The only available test right 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 106 now is MEGGER test.

1 CONSULTANT BARTON: Right.

2 MR. JOSE: You know. They don't have that 3

shield. You require a uniform shield for our unit 4

from ground for doing standout and other things.

5 CONSULTANT BARTON: Right.

6 MR. JOSE: So they were doing some kind of 7

monitoring, but they took it as if it's a new program.

8 And hoping that will be a state of the art test just 9

before the --

10 CONSULTANT BARTON: Before the license 11 expires?

12 MR. JOSE: -- license expires. Plus, they 13 will have a one time test before the license expires 14 and 10 years thereafter.

15 CONSULTANT BARTON: Okay.

16 MR. JOSE: Yes, Cliff?

17 MR. DOUTT: Cliff Doutt. I have a 18 question as well.

19 CHAIR BLEY: Please, speak into the mike.

20 MR. DOUTT: Oh.

21 CHAIR BLEY: Just point it right at you.

22 MR. DOUTT: Is that better?

23 CHAIR BLEY: And give your name.

24 MR. DOUTT: Sorry. Cliff Doutt, License 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 107 Renewal. We asked the same question in an RAI. Our 1

concern was taking credit for a program that didn't 2

implement the AMP already.

3 CONSULTANT BARTON: Yes, that was my 4

problem.

5 MR. DOUTT: And so what they did is they 6

corrected the basis documents to remove that 7

statement. And they are not doing that. But in 8

reality, part of the issue was they wanted a credit 9

for current testing. And since we don't know what we 10 are going to do just yet, we've got four years to go, 11 then it's prior to, and we ask that question and it's 12 discussed in the SER as well. I think it is Section 13 3.0.3.1.1.9. There is a small paragraph on that.

14 There was another LRA revision, but the 15 basis documents are correct.

So that's more 16 background.

17 CONSULTANT BARTON: Thank you.

18 MR. DOUTT: Sure.

19 MR. JOSE: Again, for Aging Management 20 Program reviews, we did the program documentation. we 21 also performed walk-downs of the underground cable 22 vaults and switchyard and we also did -- interviewed 23 plant personnel.

24 Operating experience was another piece of 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 108 our review also just to make sure that they do account 1

for internalized industry operating experience. For 2

that, we did look at their Corrective Action Programs 3

and their reports on their Corrective Action Program, 4

as well as system health reports and the program 5

results.

6

Again, the Aging Management Program 7

inspection results. The licensee also did a specific 8

letter after our inspection called NG 10-009, which is 9

dated January 14, 2010. And Enclosure 1 to that 10 letter details all our findings.

11 And I did list a few here just for the 12 highlights here. Like the BWR vessel ID attachment 13 and BWR internal program, the licensee agreed to do 14 some clarification of the water chemistry. We did 15 have questions as to how increased sampling is going 16 to help or is used to verify effectiveness, things of 17 those nature and licensee has clarified they did take 18 corrective action to correct those.

19 And external surfaces monitoring, again 20 procedure enhancements that will include surface 21 conditions and document retention requirements, except 22 for those things that were not spelled out in their 23 program.

24 Structural monitoring was a bigger piece 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 109 here. And the bolting integrity took credit -- was 1

credited by several programs which also included 2

structural monitoring and this was not explicitly 3

stated in their program or their program procedures.

4 So licensee did agree to revise their plan procedures 5

to include inspection of bolting integrity.

6 And water chemistry program, we had a 7

question about how, because GALL has specific steps 8

and therefore monitoring hydrogen peroxide which was 9

not very explicit and the licensee did agree to 10 clarify to include this electrochemical potential 11 method that they are using.

12 Those were the highlights. Yes?

13 MEMBER ARMIJO: The hydrogen peroxide 14 monitoring, I'm not really familiar with that. Could 15 you explain what is going on there? Is this a 16 chemical additive that is in their system or is --

17 MR. JOSE: You know, I believe the water 18 chemistry, hydrogen peroxide comes in as a byproduct.

19 And again, this electrochemical potential is used to 20 measure the oxidizing power of oxygen and hydrogen 21 peroxide.

22 MEMBER SHACK: It's a radiolysis product, 23 Sam.

24 MR. JOSE: Right.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 110 MEMBER SHACK: It's just that oxygen isn't 1

the only thing that raises the electrochemical 2

potential. Hydrogen peroxide does, too.

3 MEMBER ARMIJO: But that is produced in 4

the core?

5 MEMBER SHACK: In the core.

6 MEMBER ARMIJO: Yes.

7 MEMBER SHACK: Okay. Okay.

8 MEMBER ARMIJO: And so they monitor or 9

track peroxide as well as --

10 MEMBER SHACK: Well, since they are 11 monitoring electrochemical potential, you

know, 12 whether the potential is coming from oxygen or from 13 hydrogen peroxide, it doesn't --

14 MEMBER ARMIJO: They don't care?

15 MEMBER SHACK: They don't care.

16 MEMBER ARMIJO: Right.

17 MEMBER SHACK: What they really worry 18 about is the potential. And, you know, if they were 19 just monitoring the oxygen, you would worry.

20 MEMBER ARMIJO: Yes.

21 MEMBER SHACK: Because they might be 22 getting a potential increase from the peroxide. But 23 since they are monitoring the potential, they got the 24 right thing.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 111 MEMBER ARMIJO: Okay. Thank you.

1 MR. JOSE: And with that, we concluded 2

that the scoping and screening as related to the Aging 3

Management Programs were appropriate.

And 4

documentation, you

know, was supporting.

The 5

application was auditable and retrievable and we found 6

the documentation to be to an acceptable level.

7 And our report was documented in 2009-10, 8

that was the report number. Any more questions for 9

me?

10 CHAIR BLEY: Okay. You can go ahead.

11 CONSULTANT BARTON: Oh, I'm sorry.

12 CHAIR BLEY: Go ahead. No, go ahead, 13 John, do you have one?

14 CONSULTANT BARTON: In your report you 15 noted material condition items during walk-down of the 16 plant and, apparently, you guys submitted or made sure 17 work orders were written as a result of some of your 18 observations on material conditions.

19 MR. JOSE: Yes.

20 CONSULTANT BARTON: Did the team get a 21 chance to go and look at the plants' list of the open 22 work items and look for material condition issues and 23 how long they may be open?

24 MR. JOSE: Yes. When we do the work, I 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 112 mean, we did the walk-downs. We identified like 1

corrosion, for example, some oil leaks here and there.

2 And the first reflection from the plant personnel to 3

us was to write a corrective work order.

4 CONSULTANT BARTON: Yes.

5 MR. JOSE: Okay. And we questioned that, 6

the threshold of writing CRs or IRs, corrective action 7

documents instead of work orders. And things that 8

they could repair with their team or whatnot, you 9

know, they would generally write a work order.

10 CONSULTANT BARTON: Right.

11 MR. JOSE: But during that process, we did 12 look at their work history.

13 CONSULTANT BARTON: Okay.

14 MR. JOSE: And their, I think, SAP-based 15 program and corrective action documents again, you 16 know, for system-based. And system health reports was 17 another avenue for looking at, you know, what their 18 standard problems were.

19 CONSULTANT BARTON: Okay.

20 MR. JOSE: And the focus was to get them 21 to start thinking in terms of license renewal, 22 basically. You know, something like corrosion or 23 pitting, it's not just to correct it immediately, but 24 you should be looking for long-term.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 113 CHAIR BLEY: Thank you.

1 MR. HARRIS: Okay. Moving on to Section 3 2

of the SER. Section 3 of the SER consists of the 3

following subsections: Aging Management Programs; 4

reactor vessel and internals; engineered safety 5

features; auxiliary systems; steam and power 6

conversion systems; containment, structures and 7

component supports; and electrical and instrumentation 8

and controls.

9 So I won't cover each section, subsection, 10 but will touch on those which either have an open item 11 or items of interest.

12 Section 3.0.3 contains the staff's review 13 of the applicant's Aging Management Program or AMPs.

14 43 AMPs were reviewed by the staff. 14 are new 15 programs. 29 are existing programs. 20 were 16 identified as consistent with the GALL Report. 8 were 17 consistent with enhancements. 9 consistent with 18 exceptions. 2 consistent with both enhancements and 19 exceptions. 4 were identified as plant-specific.

20 So during the staff's review, an open item 21 was identified related to the management of small bore 22 piping socket welds. During the review, the staff 23 indicated to the applicant our concern that a visual 24 inspection would be inadequate, as it would not detect 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 114 flaws initiating from the inside diameter.

1 So this concern stemmed from the staff's 2

review of industry operating experience for failures 3

in small weld piping socket welds and resulted in 4

unplanned shutdowns.

5 So we understand the applicant's initial 6

concerns regarding the lack of industry-endorsed 7

methodology for volumetric inspections. However, we 8

have also pointed to them several instances where 9

other applicants have been able to demonstrate flaw 10 detection using different plant specific techniques.

11 So the staff's position remains that 12 periodic volumetric examination is needed for small 13 bore socket welds in order to be consistent with the 14 recommendations of the GALL.

15 So as covered earlier, the applicant has 16 provided an RAI response subsequent for resolution.

17 And the staff has performed a preliminary review of 18 the response related to socket welds and will confirm 19 this item for the final SER.

20 Okay. Moving on to the next open item 21 here related to buried piping and the Tanks Inspection 22 Program. There has been a number of recent entry 23 events involving leakage from buried and underground 24 piping where the causes have included coating damaged 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 115 during backfill of piping; failure of fiberglass 1

piping; failure of buried piping in and around the 2

piping penetrations and failures of piping in 3

trenches.

4 The applicant's program is a new program, 5

which is aimed at managing the aging effect of piping 6

in the right contact with the soil. The program 7

credits incorporation of industry experience later 8

during the period of extended operation.

9 So the staff needed further information to 10 evaluate the impact that these recent industry events 11 might have on the buried piping program.

12 The staff issued an RAI in May to complete 13 its review. And the applicant has recently provided 14 an RAI response, supplement for this resolution. So 15 we are performing a preliminary review of this 16 information related to buried piping and will confirm 17 this item for the final SER review.

18 So I'm including the next set of slides, 19 because they are items of interest that have come up 20 in other reviews and I think that we are highlighting 21 here in our presentation today.

22 So the torus coating is an issue that was 23 also recently covered in the Cooper License renewal 24 review last month. Like Cooper, Duane Arnold has a 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 116 Mark 1 containment. And the staff reviewed the 1

applicant's operating experience and identified 2

concerns with more than the 15,000 coating repairs in 3

the torus, suppression pool documented since 1995.

4 One pit measured.25 inches in diameter 5

and.056 inches in depth or 10.5 percent of the 6

nominal thickness there. All other applications --

7 excuse me, all other locations of pit depths were less 8

than 10 percent of the nominal thickness.

9 MEMBER ARMIJO: What is the corrosion 10 allowance for that material?

11 MR. HARRIS: Corrosion allowance? I'll 12 have Abdul from the staff talk in more detail.

13 MR. SHEIKH: This is Abdul Sheikh, NRC 14 staff. As far as I know, there is no corrosion 15 allowance in this torus. But the way the applicant is 16 managing this torus is they are following the ASME 17 procedures and they are managing the program as in 18 regard with the ASME, the IWE Guidelines and GALL.

19 MEMBER ARMIJO: Well, that's kind of 20 strange. Maybe the applicant wants to clarify 21 something for me. If there is no corrosion allowance, 22 then there is some margin in the design, in the 23 structural design of the torus that is effectively a 24 corrosion allowance.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 117 You know, clearly, there has got to be 1

some margin against predictable things like corrosion.

2 So I wonder if the applicant can clarify that?

3 UNIDENTIFIED SPEAKER: Very little.

4 MR. SORENSON: Eric Sorenson for Duane 5

Arnold again. With regard to pitting, we do have 6

evaluations performed that are structural in nature 7

that since pit is a discrete defect, we can evaluate 8

the wall thickness with that discrete defect and 9

consider it acceptable. So we are talking about small 10 pits in a very -- you know, a single pit in a large 11 area not affecting the structural integrity of the 12 torus.

13 MEMBER ARMIJO: But that addresses other 14 questions, because it's a coated structure, you don't 15 really have a general corrosion allowance, do you?

16 MR. SORENSON: We do not have a general 17 corrosion allowance.

18 MEMBER SIEBER: All right.

19 MEMBER ARMIJO: The presumption is that 20 the coating protects you. Okay. I understand it now.

21 Thank you.

22 MEMBER BONACA: You refer to 15,000 23 coating repairs.

24 MEMBER ARMIJO: A lot of pits.

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 118 MEMBER BONACA: What is this? This simply 1

recoating?

2 MR. SORENSON: Yes, those 15,000 -- this 3

is Eric Sorenson again. Those 15,000 coating repairs 4

range from mechanical corrections to areas where we 5

just observe zinc depletion to areas that have had 6

actual pitting observed in there. And this is over 7

five exam periods. So we average -- I think it's 8

probably more exam periods in that. I have to look 9

exactly, but that's over a long period of time, 10 to 10 15, 15 or so years of inspection where we have 11 observed that many repairs.

12 MEMBER BONACA: Okay.

13 CONSULTANT BARTON: Does that mean there 14 is 15,000 pits or just 15,000 failures of the coating?

15 MR. SORENSON: 15,000 --

16 CONSULTANT BARTON: Some are repairs.

17 MR. SORENSON: Yes. There are not 15,000 18 pits.

19 CONSULTANT BARTON: That's a good thing.

20 UNIDENTIFIED SPEAKER: There's only 5,000 21 pits.

22 CHAIR BLEY: Go ahead. Let me ask one.

23 You said some of those weren't just touching up the 24 coating, you actually did mechanical repairs?

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 119 MR. SORENSON: No, no. This is Eric 1

Sorenson again. Some of those repairs that we had to 2

correct were mechanical things where somebody -- were 3

mechanical damage and we had to correct.

4 CHAIR BLEY: Oh, okay. I understand.

5 Okay.

6 MEMBER ARMIJO: But just to make sure I 7

understand, you never actually ground out the pit or 8

anything like that?

9 MR. SORENSON: No.

10 MEMBER ARMIJO: You just --

11 MEMBER SIEBER: Painted over it.

12 MEMBER ARMIJO: -- cleaned it up and 13 painted over it?

14 MR. SORENSON: That is -- this is Eric 15 Sorenson again. That is correct. The pit was not 16 deeper than the qualified coating thickness of the 17 coating that we were going to apply, so we could just 18 coat over the pit.

19 MEMBER ARMIJO: Okay.

20 CHAIR BLEY: Okay. Brian, go ahead.

21 MR. HARRIS: Okay. Yes. So basically, 22 from a cumulative effect, with respect to staff 23 concerns, the pitting corrosion rates are typically 24 much higher and less predictable than the general 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 120 corrosion rate.

1 So in resolution of this item of interest, 2

the IWE inspection procedure was revised to inspect 3

the torus coating during every outage until it is 4

recoated.

5 And a commitment was written to recoat the 6

torus underwater surface prior to start-up of the 7

first refueling outage during PEO.

8 An item of interest within Section 3.5 is 9

groundwater sampling. The applicant's groundwater is 10 non-aggressive as shown on the slide. All the 11 sampling markers meet acceptable limits. The staff 12 was concerned about the ten-year frequency of 13 groundwater sampling. And the applicant enhanced the 14 structures monitoring program to include groundwater--

15 sampling of groundwater on the five-year frequency 16 instead of the original ten-year frequency.

17 Moving on to Section 4 of the SER.

18 Section 4 contains the staff's review of the time-19 limited aging analysis or TLAA. TLAAs are certain 20 plant-specific safety analysis that involve time-21 limited assumptions defined by the current operating 22 term. It must be listed by section 54.21(c)(1). And 23 any plant-specific TLAA based assumptions per 24 54.21(c)(2).

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 121 The staff reviewed information in the LRA 1

to determine whether the applicant has provided 2

sufficient information pursuant to 54.21(c)(1) and 3

(c)(2).

4 In Section 4.2, the SER covers the reactor 5

vessel neutron embrittlement analysis. There were 6

three reviews performed to evaluate neutron 7

embrittlement as documented in the SER. Those three 8

were neutron fluence and adjusted reference 9

temperature review, upper shelf energy review and 10 pressure-temperature limits review.

11 The staff concluded that the reactor 12 neutron embrittlement analysis meet the review 13 criteria in the Standard Review Plan in accordance 14 with the rules.

15 In Section 4.3 of the SER, the staff 16 documents its review of the metal fatigue and piping 17 and the components TLAA. The 60-year environmentally 18 assisted fatigue analyses were performed for plant-19 specific locations identified in NUREG/CR-6260 for an 20 older vintage BWR plant.

The resulting 21 environmentally assisted fatigue cups were all less 22 than 1.0 for these locations.

23 The applicant manages fatigue of all 24 NUREG-6260 locations using the metal fatigue or 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 122 reactor coolant pressure boundary program in 1

accordance with 10 CFR 5421(c)(1)(iii).

2 So in conclusion, on the basis of its 3

review, the staff determines that pending resolution 4

of the open items discussed, the requirements of 10 5

CFR 5429(a) have been met for the license renewal of 6

the Duane Arnold Energy Center.

7 Staff conclusions regarding the LRA for 8

Duane Arnold will be provided in the final SER 9

scheduled to be issued on October 2010.

10 CHAIR BLEY: Okay. Thank you. Any 11 questions from the Committee?

12 MEMBER RAY: Can we go back to 16, please?

13 I did listen to the whole discussion. I got stuck 14 here and the discussion moved on. So there is an 15 average of 1,000 -- clearly, I'm getting confused 16 between coating problems and the pressure boundary 17 effects.

18 I take it that a pit or pitting corrosion 19 rates is something that affects the pressure boundary?

20 Is that right?

21 MR. HARRIS: Abdul?

22 MR. SHEIKH: This is Abdul Sheikh, NRC 23 staff. Let me just explain the issues. There are 24 15,000 total repairs. There is only one pit which is 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 123 bigger than 10 percent and that's just slightly bigger 1

than that.

2 MEMBER RAY: 10 percent of what?

3 MR. SHEIKH: 10 percent of about.553 of 4

an inch.

5 MEMBER RAY: Okay. Let's try it this way.

6 Is it 10 percent of the pressure boundary or 10 7

percent of the coating?

8 MR. SHEIKH: 10 percent of the pressure 9

boundary.

10 MEMBER RAY: Okay. Thank you. All right.

11 So but we repair the coating, we don't repair the 12 pressure boundary. Is that correct?

13 MR. SHEIKH: That is -- about this 15,000, 14 most of them are touch-ups of the coating. There are 15

-- I don't have the exact number where there has been 16 some loss of material. There is only one pit where 17 there is a loss of material that's more than 10 18 percent. And that was evaluated and found that the 19 structural integrity of the torus is maintained.

20 MEMBER RAY:

Okay.

Well, that's 21 information that isn't here, at least explicitly.

22 Maybe it is implicitly here. But the information on 23 this slide it's hard to puzzle out exactly what we are 24 talking about. But it sounds like most of the time 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 124 you are talking about repairs to the coatings, that's 1

what it says, coating repairs.

2 MR. SHEIKH: Right.

3 MEMBER RAY: And very occasionally, I 4

guess, you find there has been degradation of the 5

pressure boundary, but not enough to require repair of 6

the pressure boundary.

7 MR. SHEIKH: That is correct.

8 MEMBER RAY: Okay. Well, that's not 9

easily discerned from this slide, to be honest with 10 you.

11 MR. SHEIKH: Okay.

12 UNIDENTIFIED SPEAKER: It's not my slide.

13 MR. SHEIKH: We can -- I mean, at this 14 time, we can't correct it, but I --

15 MEMBER RAY: That's fine. But I'm just 16 telling you I can't -- it's hard to figure out what 17 you are talking about here.

18 MR. HOLIAN: This is Brian Holian. We 19 will take that comment. We are kind of following up 20 on last month's Cooper that had similar types of 21 coating repairs and probably more severe pitting in 22 that area. And Duane Arnold had had it coated once, 23 Cooper had not. So really, we were just shining a 24 little bit of a

spotlight on their operating 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 125 experience.

1 It hasn't been a significant issue for the 2

regions. The regions have been following it pretty 3

well. You know, we have even gone back to some plans 4

at Nine Mile Point that is already in license renewal 5

that had coated, but now, as a matter of fact, I think 6

they are coating this outage. So just following up on 7

operating experience and making sure they were long-8 range plan is really the message.

9 MEMBER RAY: Well, that's fine, Brian. I 10 appreciate the clarification.

I just think 11 distinguishing between fixing the coating and fixing 12 the pressure boundary is what I'm trying to get 13 straight here. And this has generic applicability as 14 you say. So I'm trying to figure out what information 15 are we being given. Thank you.

16 MR. HOLIAN: Okay.

17 MEMBER ARMIJO: Yes, well, I don't 18 disagree with the staff conclusion about the 19 consequences of pits on the structural integrity. I 20 just was looking to how much margin that the torus 21 really had. And just assume that you had lots of 22 pits, even though that's not the case, and if they 23 were 10 percent of the wall, would that be a 24 significant problem?

25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 126 And normally, in components like this, 1

there is often a corrosion allowance and so that's 2

throw away material. I just wondered if effectively 3

you have a corrosion allowance through some other 4

margin in the design? And my guess is you do, but I 5

don't know what it is. Maybe somebody can tell me.

6 MEMBER RAY: Well, I just accepted the 7

statement that it didn't affect structural integrity 8

and is consistent with what you are saying.

9 MEMBER ARMIJO: Yes, I'm sure that is the 10 way it will turn out. I'm just trying to get a number 11 of seeing how much could we have lost and still have 12 plenty of margin.

13 MR. SHEIKH: The staff hasn't calculated 14 that, but what we have looked, we have taken is that 15 they have only one small pit --

16 MEMBER ARMIJO: No, I understand one small 17 pit won't cause a problem.

18 MR. SHEIKH: Right, right.

19 MEMBER ARMIJO: Or even a lot of small 20 pits if they are spread out. But I'm just trying to 21 see how much margin that torus had in the original 22 design.

23 MR. SHEIKH: As far as I think, there is 24 plenty of margin in the torus, because the normal 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 127 corrosion, general corrosion rate in industry is about 1

2 to 4 millimeter, 2 to 4 mils per year. I'm sorry.

2 2 to 4 mils per year.

3 MEMBER ARMIJO: Okay.

4 MR. SHEIKH: So we have, you know, plenty 5

of margin there.

6 MEMBER BONACA: Just a question I had was 7

are the defects uniformly distributed on the torus or 8

are they look at it in certain specific areas?

9 MR. SHEIKH: I didn't get the question.

10 MEMBER BONACA: My question is if this 11 15,000 repairs are for defects that are uniformly 12 distributed over the torus area?

13 MR. SHEIKH: They are all in the area 14 underwater.

15 MEMBER BONACA: Yes, I understand that.

16 MR. SHEIKH: All of them. That's why they 17 are coating the bottom half of the torus.

18 MEMBER BONACA: But what are they? Are 19 they uniformly spaced?

20 MR. SHEIKH: Probably the applicant can 21 tell.

22 MR. SORENSON: This is Eric Sorenson 23 again. The pits and the defects, defined defects are 24 at every bay in our torus all the way underneath the 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 128 water line where we had -- those are areas we 1

typically would find general zinc depletion.

2 MEMBER BONACA: Okay.

3 MR. SORENSON: We do find heavier pittings 4

and damage in the bottom, in the actual bottom 12 5

inches of the ark of the torus where we would have the 6

heaviest sludge accumulation, so that would create 7

that pocket that we would have higher corrosion rates 8

in there.

9 MEMBER BONACA: Okay.

10 MR. SORENSON: But we do see it completely 11 around the torus, up on the walls.

12 MEMBER BONACA: Yes.

13 MR. SORENSON: Is where we would see all 14 the damage.

15 MEMBER BONACA: All right.

16 MEMBER RAY: But I'm sorry, I'm going to 17 pick at words again. You're talking about corrosion.

18 I don't know if that's the right word to apply to the 19 coating damage that you are seeing.

20 MEMBER SIEBER: Deterioration.

21 MEMBER RAY: Is that the correct term?

22 MR. SORENSON: This is Eric Sorenson 23 again. Corrosion is probably not the correct term in 24 here, because this is a sacrificial zinc coating that 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 129 is supposed to sacrifice. And when it does, you will 1

see surface rust and then immediately when we see, we 2

would go in and correct it.

3 There is a lot of cases where there is no 4

depth to that. It's just we have seen the coating 5

deplete.

6 MEMBER RAY: Okay.

7 CHAIR BLEY: Anything more? It looks like 8

you will be coming back to the Full Committee some 9

time around October?

10 MR. HARRIS: Yes, that's correct.

11 CHAIR BLEY: Okay.

12 MEMBER ARMIJO: How many open items do you 13 still have?

14 MR. SORENSON: We have two open items.

15 MEMBER ARMIJO: Two. Okay.

16 MR. HOLIAN: This is Brian Holian. Just a 17 comment on those open items. I could have stated that 18 earlier, but those are 12 or 13 applications that we 19 have in-house now. Both of those are current issues 20 that we are kind of upgrading to the new GALL, both of 21 them.

22 We just had a public meeting on the GALL 23 last week, the revised GALL coming out. Buried piping 24 is obviously one that we are increasing the amount of 25

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

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 130 sampling. A little push-back from the staff, you 1

know. Not the staff, I'm sorry, the industry on that.

2 The industry is worried a little bit about, you know, 3

the increased sampling that we might require and the 4

GALL will also then possibly cause opportunistic, you 5

know, degradations or backhoe damage to the piping.

6 But we are working towards a resolution as 7

is stated here. They stated they know they need to 8

increase their looks at what is unseen down there. So 9

not only are we picking those two up on these plans, 10 those two open items, but on all plants in-house kind 11 of finalizing and improving those commitments in the 12 commitment table.

13 MEMBER ARMIJO: Thanks.

14 CHAIR BLEY: Anything more? Well, I'm 15 going to go around the table, but I think before I get 16 the Committee

Members, I'm going to ask our 17 consultant, John Barton, to give us your comments, 18 please. John?

19 CONSULTANT BARTON: Well, I believe the 20 staff did a good job in their inspection report, 21 pretty thorough. The only issues I see is the 22 resolution to two open items. I'm sure that they can 23 give these out fairly easily. And the fact that they 24 have committed to finally recoat the torus, that's the 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 131 last issue I had. So I don't have any other issues 1

that would preclude license renewal in my opinion.

2 CHAIR BLEY: Okay. Great. Thank you.

3 And as we go around for the Committee, if you would 4

also mention anything, if there is anything here you 5

want to make sure we bring to the Full Committee, 6

please, do so.

7 Jack, why don't we go this way. Jack?

8 MEMBER SIEBER: Yes, I think that the 9

application was appropriate. And the staff's review 10 and their RAIs and resolutions are appropriate. But 11 we still have two open items, which I think should be 12 or must be resolved. And it is up to the staff to 13 resolve those in the appropriate fashion which we will 14 then review.

15 I think this plant compared to others of 16 this age is in pretty good condition. And so I really 17 don't have any issues that jump out at me that would 18 cause us to raise new issues with respect to this 19 application.

20 CHAIR BLEY: Thanks, Jack. Sam?

21 MEMBER ARMIJO: Yes, I share Jack's view.

22 I think the applicant was very good. I think the 23 staff has done a really good review. I think that the 24 plant has benefitted from a

very technically 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 132 aggressive program to deal with IASCC and IGSCC. I 1

think the plant has done a very good job being the 2

lead plant in the industry to apply hydrogen water 3

chemistry and noble metals.

4 I think that's one of the reasons why they 5

have such good experience with their core internals 6

and their piping. That being said, you still have to 7

monitor and you still have to inspect.

8 But

overall, I

think the plant's 9

presentation is very good. I would try in the 10 Committee, Full Committee, meeting try and just make 11 it easy for the Members who aren't here to understand 12 that this pitting corrosion of the torus is really a 13 very minor problem. And you don't get that from word 14 charts.

15 CHAIR BLEY: Thanks. Harold?

16 MEMBER RAY: I would just echo what Sam 17 said and add nothing more.

18 CHAIR BLEY: Thank you. John?

19 MEMBER STETKAR: I don't have anything 20 more, other than to thank the staff for aggressive 21 reviews of operating experience and gaining a lot of 22 insight from that.

23 I think that that helped an awful lot in 24 their inspections and identifying potential issues.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 133 So I'm glad to see the staff is continuing to do that.

1 CHAIR BLEY: All right. Bill?

2 MEMBER SHACK: I am just glad to see the 3

torus is going to get recoated with a good modern 4

coating. The one thing that is new to me, and maybe 5

it has been here before, was the use of the torsional 6

guided waves to look at some very frightening -- I 7

mean, we have been sort of relying totally on 8

opportunistic inspections up until now, you know, and 9

if it isn't a perfect tool, at least any tool that 10 would help you to get some insight into degradation of 11 buried piping seems like a

helpful kind of 12 development.

13 And I hope other people will apply it and 14 sort of get along.

15 CHAIR BLEY: All right.

16 MR. HOLIAN: This is Brian Holian again.

17 Just a comment on that. I don't know if Bill Holston 18 was here. He is a Senior Engineer and spent 20 years 19 at Calvert. I know he is in the back, but I'll just 20 state it for him.

21 Several plants are, you know, using that 22 now and I guess we haven't highlighted as much, but 23 even the staff is going down to Charlotte in a couple 24 of weeks here to look at the latest techniques in 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 134 that.

1 And I know some Region I staff has already 2

gone there to look at what aspects, you know, we heard 3

that it can get out to the second bend or second 4

elbow. There is other indications sometimes that 5

external supports have also caused false issues, but 6

it is an area not only we are looking at license 7

renewal, but obviously the Division of Component 8

Integrity is looking at NEI's submittal on buried 9

piping and how far we can credit that.

10 MEMBER STETKAR: Brian, you said other 11 plants are actually implementing or have committed to 12 implement this?

13 MR. HOLIAN: Yes. I don't know if they 14 have committed in their applications yet.

15 MEMBER STETKAR: Because I was going to 16 say, I haven't seen it.

17 MR. HOLIAN: Yes.

18 MEMBER STETKAR: I think Bill is right, 19 this is the first one.

20 MR. HOLIAN: Yes, the committed -- the 21 word I might have used is verbally to us at times, but 22 we are looking at trying to get it in writing where 23 they are using it for their process.

24 MEMBER STETKAR: Good.

25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 135 CHAIR BLEY: Excellent. Mario?

1 MEMBER BONACA: No further comments.

2 CHAIR BLEY: Okay. And I would like to 3

thank staff and the applicant very much for very good 4

presentations and discussions.

5 And we will look forward to seeing you in 6

October.

7 At this point, the Subcommittee meeting is 8

-- well, I guess I should ask, are there any public 9

comments before we close the meeting?

10 Then we will close the Subcommittee 11 meeting. The Subcommittee is adjourned.

12 (Whereupon, the meeting was concluded at 13 11:12 a.m.)

14 15 16 17 18 19 20 21 22 23 24 25

Duane Arnold Energy Center ACRS License Renewal Subcommittee Presentation June 8, 2010

2 Personnel in Attendance Christopher Costanzo Site Vice President Ken Kleinheinz Engineering Director Ken Putnam License Renewal Project Manager Curt Bock License Renewal Mechanical Lead Ken Chew License Renewal Civil Lead Mike Fairchild License Renewal Electrical Lead Clara Rushworth License Renewal Licensing Lead Herb Giorgio Environmental Lead Eric Sorenson Program Engineering Al Thomas Program Engineering

3 Agenda

Background

Operating History License Renewal Project Overview

- Scoping Discussion

- Time Limited Aging Analysis

- Application of GALL

- Commitment Process Technical Items of Interest

- Torus Coatings

- Buried Piping

- Small Bore Piping

4 poe Maximize the time spent on Prevention and Detection to minimize leliminate Correction activities

5 Background - Site Approximately 6 miles NW of Cedar Rapids, Iowa General Electric (NSSS & Turbine Generator)

Bechtel (AE and Constructor)

BWR-Mark I Containment 1912 MWt Thermal Power; ~ 630 MWe Cedar River is ultimate heat sink and water makeup source. Forced draft cooling towers for condenser cooling Staff Complement: approximately 650

6 Background - Plant Status Startup from Refuel Outage 21 - March 2009 Current Plant Status Next Refuel Outage - October 2010

7 Operating History - Licensing Construction Permit June 17, 1970 Operating License February 22, 1974 Commercial Operation February 1, 1975 Uprated Power License (5%)

March 27, 1985 Extended Power Uprate License (15%)

November 6, 2001 Operating License Transfer to FPL (NextEra)

January 27, 2006 LR Application Submitted September 30, 2008 Operating License Expires February 21, 2014

8 Major Improvements 1987 Hydrogen Water Chemistry and Crack Arrest Verification System Electrochemical Potential Monitor 1996 Noble Metals Applied 1998 ECCS Suction Strainers Replaced 2001 High Pressure Turbine Upgrade Moisture Separator Reheaters Upgrade Replaced 2 Circulating Water Pumps 2003 Replaced Drywell Coolers

9 Major Improvements (continued) 2005 Replaced Feedwater Heaters Replaced Condensate Pumps Installed Condenser Isolation Valves 2007 Heater Bay Cable Replacement 2009 B Diesel Generator Governor Upgrade A & B Diesel Generator Voltage Regulator Upgrade Main Transformer Replacement Recirculation MG Set Scoop Tube Positioner Upgrade Feedwater Flow Correction System Replacement

10 License Renewal Project Overview Site Ownership and Oversight Experienced Team (DAEC, Corporate, Contract)

Benchmarking QA Audits Participation in industry working groups Industry Peer Review

11 Project Overview - Scoping Scoping process consistent with requirements of 10CFR 54 and the guidance of NEI 95-10 Categorized entire plant in terms of major SSCs Identified system level functions Evaluated all SSCs against Scoping Criteria 10CFR54.4 (a)(1), (a)(2) and (a)(3)

Identified SSCs that perform or support an intended function

12 Project Overview - Scoping Utilized site component database, controlled drawings, design and licensing documents Non-Safety Affecting Safety (a)(2)

- Reviewed safety related equipment locations

- Conservative spaces approach

- Performed walk-downs for verification Use of commodity groups used when evaluations were best performed by component type rather than SSC

13 Project Overview - TLAA Design and Licensing Basis reviewed for potential Time Limited Aging Analysis Neutron fluence was determined for DAEC operation out to 54 EFPY using RAMA methodology.

- Extended operation to 60 years will be bounded by 54 EFPY.

- Fluence determined for vessel and internals.

- Pressure/Temperature Curves created for 54 EFPY.

Thermal Cycle projections updated for 60 year life

- Used to evaluate fatigue for 60 year life.

14 Project Overview - TLAA Environmental Fatigue evaluated for locations identified in NUREG/CR-6260 using NUREG/CR-6583 and 5704

- All locations confirmed CUF < 1.0

- NUREG/CR-6909 for new plants has updated data for Nickel Alloys

- NUREG/CR-6909 can result in higher environmental fatigue factor but it would not alter the conclusion that CUF < 1.0 Environmental Qualification calculations updated to 60 year life

15 Project Overview - Application of GALL Programs 43 Aging Management Programs

- 19 Programs in place with out Enhancements

- 10 Programs will be Enhanced

- 14 New Programs GALL Consistency

- 28 Consistent

- 11 Consistent with Exceptions

- 4 Plant Specific Electrical Connections Program Electrical Penetration Assembly Program ASME Code Class 1 Small-bore Piping Inspection Program Boral Surveillance Program

16 Project Overview - Industry Issues Industry Issues During DAEC Project

- Station Black Out boundary - DAEC has included switchyard breakers, control circuits and associated structures within scope

- Methods for fatigue evaluation - DAEC eliminated use of simplifying methods (Greens Function) in fatigue calculations

- NRC GL 2007 Inaccessible or Underground Power Cables Sump pumps upgraded in three manholes New inspections for man-holes without sump pumps

- IN 2009-26 Degradation of Neutron Absorbing Materials in Spent Fuel Pool - DAEC Added Boral Surveillance Program

17 Project Overview - Commitment Process 50 Regulatory Commitments for License Renewal Commitments entered into site commitment tracking system Implementation activities underway to ensure completion well in advance of PEO Retain portion of project core team to support implementation activities with program owners Specific projects for larger items

18 Project Overview - Open Items Draft SER Summary Open Items - 2

- Buried Piping

- Small Bore Piping Confirmatory Items - None

19 Technical Items - Torus Coatings Issue

- IWE Program has identified numerous areas of zinc depletion on torus coatings and minor pitting

- ASME Code does not specify when coatings must be replaced DAEC Operating Experience

- Torus was last recoated in 1985

- Zinc Oxide Coating with Phenolic Coating band at the waterline

- Routine Inspections with touch up coating repairs

- Sludge deposits minimized during feed and bleed of torus using torus cooling and by outage sludge removal Resolution

- Recoat of underwater surfaces planned for 2012 Refuel Outage

20 Technical Items - Buried Piping Issue

- Recent industry events involving leakage from buried and underground piping may warrant changes to the Buried Piping and Tanks Inspection Program

Background

- In response to industry events, the Nuclear Energy Institute issued an initiative on buried piping titled Guideline for the Management of Buried Piping Integrity, NEI 09-14, in January, 2010.

- The Electric Power Research Institute issued buried component guidelines per EPRI 1016456, Recommendations for an Effective Program to Control the Degradation of Buried Piping in December, 2008.

21 Technical Items - Buried Piping DAEC Status

- NextEra Energy issued fleet guidance documents related to buried piping

- DAEC developed the DAEC implementing procedures in accordance with fleet guidance document. This document lists all buried piping at DAEC and performs a risk ranking to prioritize piping sections for inspection based on likelihood and consequence of failure.

- Underground piping is accessible and where applicable is managed by External Surfaces Monitoring Program

22 Technical Items - Buried Piping DAEC Operating Experience

- No history of leaks on in-scope piping.

- Buried piping leaks have occurred in well water piping sections constructed of gray cast iron.

- Opportunistic examinations of fire protection piping found the piping in good condition.

- Torsional Guided Wave exams have been performed on portions of the RHR Service Water, Emergency Service Water, and River Water Supply systems.

- UT examination of buried Diesel Fuel Oil Storage tank in 2001 found tank in good condition

23 Technical Items - Buried Piping 2010 Planned Examinations

- Torsional Guided Wave examinations of HPCI CST suction piping, Core Spray CST suction piping, Condensate system makeup and reject, and Demineralized Water pump suction and transfer piping are scheduled for 2010.

- Excavations to allow UT examinations of RHR Service Water and River Water Supply piping are also scheduled for 2010.

Proposed Resolution

- DAEC Buried Piping and Tanks Inspection Program has been updated to reflect recent industry operating experience.

24 Technical Items - Socket Welds Issue

- NUREG-1801 Recommends a volumetric examination of Small Bore Class 1 Piping using qualified techniques

- No industry accepted qualified volumetric exam technique for socket welds exists

- Surface examinations do not detect flaws originating on the interior surface until component fails

- NRC staff indicates volumetric examinations can provide meaningful information about many flaws even if the configuration precludes full qualification

- On going industry efforts appear to be improving potential examination technology

25 Technical Items - Socket Welds DAEC Operating Experience

- Pin Hole Leak in Recirculation Pump Drain Line Socket Weld in 1989 (Small Bore Class 1)

- Apparent Cause - Fatigue Cracking due to vibration and initial fit up

- NUREG-1801 Requires a plant specific program for Class 1 Small Bore Piping if plant has experienced cracking

- No additional Class 1 socket weld issues since 1989

26 Technical Items - Socket Welds Proposed Resolution

- Perform periodic volumetric exams of 10 percent of Class 1 socket welds using industry qualified exam technique if it is available at time of exam

- If no industry qualified examination technique is available at time of inspections a plant procedure for volumetric examination will be used

27 Questions?

1 Histogram for Cumulative Plant Startups Startup Histogram 0

20 40 60 80 100 120 1974 1975 1976 1977 1978 1979 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Advisory Committee on Reactor Safeguards License Renewal Subcommittee Duane Arnold Energy Center Safety Evaluation Report with Open Items June 8, 2010 Brian K. Harris, Project Manager Office of Nuclear Reactor Regulation

2 Introduction

Overview

Section 2: Scoping and Screening Review

License Renewal Inspections

Section 3: Aging Management Program and Review Results

Section 4: Time-Limited Aging Analyses (TLAAs)

3

LRA Submitted by letter dated Sept 30, 2008

GE Boiling Water Reactor (BWR), Mark I containment

Nov. 6, 2001 - Extended Power Uprate (EPU) was granted to DAEC to operate at 1912 MWth, 629 MWe

Operating license for NPR-49 expires February 21, 2014

Located approximately 8 miles NW of Cedar Rapids, IA Overview

4

Safety Evaluation Report with Open Items was issued May 2010

2 Open Items OI-3.0.3.3.3 Socket Welds OI-3.0.3.1.7 Buried Piping Overview

5

Aging Management Programs (AMP) Audit

- August 10 - 14, 2009

Scoping and Screening Methodology Audit

- August 24 - 28, 2009

Regional License Renewal Inspections

- November 2 - 6, 2009

- November 16 - 20, 2009 Overview

6 Section 2.1 - Scoping and Screening Methodology Section 2.2 - Plant-Level Scoping Results Section 2.3 - Scoping and Screening Results: Mechanical System Section 2.4 - Scoping and Screening Results: Structures Section 2.5 - Scoping and Screening Results: EI&C System Staff concludes that the applicant has appropriately identified the systems, structures, and components in accordance with 10 CFR 54.4(a), and those subject to an AMR in accordance with 10 CFR.54.21(a)(1)

Section 2: Structures and Components Subject to Aging Management Review

License Renewal Inspections Benny Jose Region III Inspection Team Leader

8 71002 Inspection Scope

54.4(a)(2) Scoping & Screening Non-Safety SSCs Non-Safety Affecting Safety was Acceptable

Reviewed 30 of 43 AMPs

- Program Documents & Procedures

- Walkdowns of Plant Areas including Cable Vaults and Switchyard.

- Interviewed Plant Personnel

Operating Experience Review

- System Health Reports and Program Results

- Corrective Action Reports for Prior SSC Problems, associated with the 30 AMPs reviewed License Renewal Inspections

9 71002 Inspection Results

Aging Management Program (AMP) Changes

- Buried Piping and Tanks Inspection Program (procedure revisions for opportunistic inspection of excavated pipes)

- BWR Vessel ID Attachment Welds Program (Water Chemistry clarifications)

- BWR Vessel Internals Program (Water Chemistry clarifications)

- External Surfaces Monitoring (procedure enhancements include surface conditions, document retention etc.)

License Renewal Inspections

10 Aging Management Program (AMP) Changes contd.

- Structural Monitoring Program (procedure revisions to include acceptance criteria, inspection of bolting materials and fasteners)

- Water Chemistry Program (LRA revision to clarify monitoring of H2O2)

License Renewal Inspections

11 Inspection Summary

Inspection results support a conclusion there is reasonable assurance that the effects of aging will be adequately managed

Scoping of non-safety systems was acceptable

Documentation supporting the application was auditable

& retrievable

Report 05000331/2009010 License Renewal Inspections

12

Section 3.0 - Aging Management Programs

Section 3.1 - Reactor Vessel & Internals

Section 3.2 - Engineered Safety Features

Section 3.3 - Auxiliary Systems

Section 3.4 - Steam and Power Conversion System

Section 3.5 - Containments, Structures and Component Supports

Section 3.6 - Electrical and Instrumentation and Controls System Section 3: Aging Management Review Results

13 Plant Specific Consistent with GALL With Exception With Enhancement With exception &

enhancement Existing 29 0

14 5

8 2

New 14 4

6 4

0 0

Section 3.0.3 - 43 AMPs evaluated in the SER, consistent with GALL Report Section 3: Aging Management Review Results

14 OI-3.0.3.3.3

DAEC proposed to use visual (VT-2) examination for socket welds

GALL AMP XI.M.35 recommends volumetric examination

Given previous operating experience of socket weld failures, GALL recommends that periodic volumetric examination is necessary for managing cracking in socket welds

In recently docketed responses, DAEC committed to perform periodic volumetric inspections Section 3.0.3.3.3 Small Bore Piping Section 3: Aging Management Review Results

15 OI-3.0.3.1.7:

Given recent industry OE related to leaks from buried and underground piping, staff is interested in efforts to incorporate OE into AMPs at DAEC

Staff issued an RAI on May 2, 2010, regarding buried and underground piping at DAEC

Recently docketed responses will be evaluated for acceptability in final SER Section 3.0.3.1.7 Buried Piping and Tanks Inspection Program Section 3: Aging Management Review Results

16

Staff Concern

- Over 15000 coating repairs (5% of the underwater torus area) performed since 1995

- One pit 0.25 inch diameter and 0.056 inch depth (10.5% of nominal thickness). All others less than 10%.

- Pitting corrosion rates are typically much higher and less predictable than general corrosion rate

Resolution

- IWE inspection procedure revised to inspect the torus coating during every outage until it is recoated

- Commitment to recoat the torus underwater surface prior to startup of first refueling outage during PEO Torus Coating Section 3: Aging Management Review Results

17 Item of Interest: Section 3.5

Groundwater sampling for pH, chloride, and sulfate concentrations will be performed on a 5-year periodicity.

DAEC Groundwater is non-aggressive Groundwater Monitoring Res ults from September 2007 Sample Des cription Shallow Wells Acceptance Criteria D111 D112 D113 D114 D115 D116 pH

>5.5 6.60 6.87 7.06 6.87 7.20 6.79 Chloride (ppm)

<500 ppm 77 62 124 48 14 110 Sulfate (ppm)

<1500 ppm 349 470 112 270 14 92 Section 3: Aging Management Review Results

18 4.1 Introduction 4.2 Reactor Vessel Neutron Embrittlement of the Reactor Pressure Vessel and Internals 4.3 Metal Fatigue 4.4 Environmental Qualification of Electrical Equipment 4.5 Concrete Containment Prestress 4.6 Fatigue of Primary Containment, Piping, and Components 4.7 Other Plant-Specific TLAA Section 4: Time-Limited Aging Analysis

19 Section 4.2 - Reactor Vessel Neutron Embrittlement Analysis Reactor Vessel Limiting Material Fluence at 54 EFPY Predicted USE Decrease (RG 1.99, Rev.2)

EOL USE Acceptance CriteriaMaximum Drop in USE value allowed per the BWRVIP-74-A Vessel Shell Ring #2, 1-20 Heat # B0436-2 5.74 X 1018 n/cm2 E > 1 MeV 21%

23.5%

Equivalent Margin Analysis (EMA)

Performed per BWRVIP-74-A Section 4: Time-Limited Aging Analysis

20 Section 4.3 - Metal Fatigue of Piping and Components

- NUREG-6260 locations

Eight plant-specific locations for DAEC

Environmentally adjusted CUF < 1.0 for all locations

Dispositioned in accordance with 10 CFR 54.21(c)(1)(iii)

Continued monitoring with The Metal Fatigue of Reactor Coolant Pressure Boundary Program for all NUREG-6260 locations during the period of extended operation Section 4: Time-Limited Aging Analysis

21

On the basis of its review, the staff determines that, pending resolution of the open items, the requirements of 10 CFR 54.29(a) have been met for the license renewal of Duane Arnold Energy Center

The staffs conclusion regarding the LRA for DAEC will be provided in the Final SER scheduled to be issued in October, 2010 Conclusion

22 United States Nuclear Regulatory Commission Protecting People,an,d the En,vironment

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