ML050870619
| ML050870619 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 03/04/2005 |
| From: | NRC/EDO |
| To: | |
| Dick G F, NRR/DLPM,415-3019 | |
| Shared Package | |
| ML050870621 | List: |
| References | |
| 2.206, G20050160, NRC-272, TAC MC6311 | |
| Download: ML050870619 (21) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Petition Review Board Docket Number: (not applicable)
Location: (telephone conference)
Date: Friday, March 4, 2005 Work Order No.: NRC-272 Pages 1-21 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 PETITION REVIEW BOARD (PRB) 5 CONFERENCE CALL 6 + + + + +
7 FRIDAY 8 MARCH 4, 2005 9 + + + + +
10 The conference call was held, JIM LYONS, 11 Petition Review Board Chairman, presiding.
12 13 PETITION REVIEW BOARD:
14 JIM LYONS, Chairman, Deputy Director, 15 Division of Licensing, Project Mgmt/NRR 16 HERBERT N. BERKOW, Project Director, DLPM/NRR 17 DONNA M. SKAY, 2.206 Petition Coordinator 18 GEORGE DICK, 2.206 Petition Manager and 19 Project Manager, Byron Station 20 PETITIONER:
21 BARRY QUIGLEY, Exelon 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 NRC HEADQUARTERS STAFF:
2 ABY MOHSENI, NRR 3 GENE SUH, Section Chief, NRR 4 MELISSA DUFFY, Office of General Counsel 5 TOM SCARBOROUGH, Mechanical Engineering 6 Branch, NRR 7 FRANK ORR, Reactor Systems Branch, NRR 8 NRC STAFF PRESENT FROM REGION III:
9 KEN O'BRIEN, Enforcement Director 10 DAVE PASSEHL, Branch Chief 11 JIM HELLER, Allegation Coordinator 12 RICHARD A. SKOKOWSKI, Senior Resident Inspector 13 PRESENT FROM BYRON STATION:
14 BRAD ADAMS, Director of Site Engineering 15 STEVE KOZINSKI, Site Vice President 16 PRESENT FROM EXELON CORPORATION:
17 KEITH JURY 18 JOE BOWER 19 TOM O'NEILL 20 DEAN LARK 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 P-R-O-C-E-E-D-I-N-G-S 2 MR. DICK: Let me just start off by saying 3 I'm George Dick. I'm the Project Manager for Byron.
4 And for this particular activity, I'm also the PRB 5 manager, Petition Manager.
6 What I would like to do initially, we got 7 the organization. So I'd like just within those 8 organizations for everyone to identify themselves.
9 And as far as the people here at headquarters, if 10 others are interested, we can provide a written list 11 of who all is participating. So, with that, why don't 12 we just ask people to identify themselves?
13 MR. BERKOW: Okay. Yeah. Herb Berkow.
14 I'm a PRB member.
15 CHAIRMAN LYONS: Jim Lyons. I'm the PRB 16 chairman.
17 (Inaudible.)
18 MS. DUFFY: Melissa Duffy, Office of 19 General Counsel.
20 MR. SCARBOROUGH: Tom Scarborough, 21 Mechanical Engineering Branch, NRR.
22 MS. SKAY: Donna Skay, NRC 2.206 23 Coordinator.
24 MR. DICK: Region III?
25 MR. O'BRIEN: Is Ken O'Brien. I'm the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 Enforcement Director.
2 MR. PASSEHL: I'm Dave Passehl. I'm the 3 Branch Chief.
4 MR. HELLER: Jim Heller, the Allegation 5 Coordinator.
6 MR. SKOKOWSKI: Rick Skokowski, Senior 7 Resident Inspector.
8 MR. DICK: Okay. Thank you. Exelon 9 environ site?
10 MR. ADAMS: This is Brad Adams, Director 11 of Site Engineering.
12 MR. KOZINSKI: Steve Kozinski, Site Vice 13 President.
14 MR. DICK: Okay. Thank you. Exelon 15 corporate?
16 MR. JURY: Yes. Here we have Keith Jury, 17 Joe Bower, Tom O'Neill, and Dean Lark.
18 MR. DICK: Okay. And, Mr. Quigley, you 19 identified yourself?
20 MR. QUIGLEY: That's correct.
21 MR. DICK: And Frank Orr?
22 MR. ORR: Frank Orr, Reactor Systems 23 Branch, NRC.
24 MR. DICK: Great. I think we have 25 everybody. And, with that, I'll just turn it over to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 Jim Lyons, who is the PRB Chairman for this activity.
2 CHAIRMAN LYONS: Thank you, George. The 3 subject of this teleconference is a 2.206 petition 4 submitted by Mr. Barry Quigley dated March 2nd, 2005.
5 The petitioners requested that the NRC 6 take enforcement action against Exelon for failure to 7 correct the longstanding problem on a reactor coolant 8 system cold leg loop stop isolation valve at Byron 9 Station.
10 The purpose of this teleconference is to 11 allow Mr. Quigley to address the Petition Review 12 Board. This is an opportunity to provide additional 13 explanation in support for this petition. This is 14 also an opportunity for the staff and licensee to ask 15 any clarifying questions about the petition. The 16 purpose of this teleconference, however, is not to 17 debate the merits of the petition.
18 Following this phone call, the Petition 19 Review Board will meet to determine whether the NRC 20 accepts the petition under the 2.206 process or 21 whether it will be dealt under another mechanism. The 22 PRB meeting today will not determine whether we agree 23 or disagree with the content of the petition.
24 This teleconference is being transcribed.
25 So it will help if anyone making a statement first NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 state their name clearly. The transcript will become 2 a supplement to the petition and will be made publicly 3 available.
4 If the PRB decides that the petition will 5 be considered under 2.206, then the NRC will issue an 6 acknowledgement letter to the petitioner. The 7 petition manager will keep the petitioner and licensee 8 periodically informed of the progress of the staff's 9 review.
10 So, with that introduction, I'd like to 11 turn it over to you, Mr. Quigley, to kind of go 12 through your request and provide any other additional 13 information you would like us to consider as part of 14 our deliberations.
15 MR. QUIGLEY: Well, in addition to the 16 petition, which I wrote relatively quickly due to time 17 constraints, -- I wanted to get this into the system 18 because I thought it was very important -- you can 19 kind of break the issues down into three areas.
20 There's a technical area, a procedural area, and a 21 cultural area.
22 The first one I want to deal with is the 23 technical area. The previous evaluations have not 24 completely addressed the loose parts that can be 25 (Inaudible.) valve. (Inaudible.) get into the hot leg NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 (Inaudible.) to get into the hot leg. The flow path 2 is to the head cooling nozzles, then down through the 3 (Inaudible.) tubes, then out the hot leg. So that's 4 (Inaudible.).
5 In the original Westinghouse 1999 safety 6 evaluation, which I wrote a paper on in 1999, the 7 response to it was relatively detailed except for one 8 part that did not address the concern I had raised.
9 I was questioning the amount of debris in the vessel 10 (Inaudible.).
11 PARTICIPANT: Mr. Quigley?
12 MR. QUIGLEY: Yes?
13 PARTICIPANT: Sorry to interrupt. You 14 seem to be breaking up quite a bit on the phone.
15 MR. QUIGLEY: Okay.
16 PARTICIPANT: So we may (Inaudible.) some 17 parts.
18 MR. QUIGLEY: Let me try something 19 different here.
20 PARTICIPANT: Okay. I'm going to call on 21 a different line. Give me a moment, please.
22 PARTICIPANT: Okay.
23 (Pause.)
24 MR. QUIGLEY: Okay. Is that better?
25 PARTICIPANT: We'll let you know when you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 start talking. We can hear you right now.
2 MR. QUIGLEY: Okay. How is that?
3 PARTICIPANT: It sounds good.
4 MR. QUIGLEY: All right. In the PIP in 5 1999, I raised the concern about the scope of the 6 5059. The scope of the 5059 was limited to loose 7 parts from the loop stop isolate valve. And in two 8 intervening outages, we have found loose parts that 9 have not been from the LSIV. So that to me might 10 invalidate the concerns that the only debris is from 11 the loop stop isolation valve.
12 Also, the 5059 does not address completely 13 all the piping valves in the loop stop isolation 14 valve. There are two tap-offs: the pressurizer spray 15 and the CVCS let-down system.
16 The 5059 acknowledges that the parts can 17 get in that area, but they do not fully address the 18 effects. For the CVCS line, the let-down line, it 19 says that it's possible that the debris could have 20 blocked the let-down orifice. That is acceptable 21 because we have the XF let-down system.
22 The CVCS let-down system is required to 23 perform a safety function for natural circulation 24 cool-down to provide let-down from the RCS. And, 25 therefore, the blocking of that line cannot be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 dismissed.
2 For the pressurizer spray, the evaluation 3 talks about getting lodged in a valve seat or lodged 4 in the nozzle. It does not clearly address the fact 5 that with a blocked pressurizer spray valve, the RCS 6 can depressurize and cause a safety injection.
7 The second part relates to procedural 8 issues. The decision-making process, OPAA 106, 101, 9 1006, the procedure is not followed completely. The 10 issue resolution documentation form that was done does 11 not address operating experience. In addition, the 12 procedure for the operational decision-making calls 13 out in several places whether or not an independent 14 review should be done for significant issues.
15 Now, we could argue about whether this is 16 significant or not. I believe it is. But more 17 detailed is a procedure called AQAA 1212. This is a 18 result of the AMAG event, where we developed a 19 procedure for technical issues. And basically the 20 decision-making procedure said it's for technical and 21 operational decisions and it produces a document.
22 The purpose of the AQAA 1212 is to provide 23 quality for technical work that produces some tangible 24 product, usually a document. So in that regard, the 25 AQAA 1212 procedure should have been used in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 decision-making process, which by my read of it would 2 have kicked it to an independent review, which we did 3 not get.
4 Also, the evaluations that the 5 decision-making is relying on are not complete. There 6 appears to be a hole in the procedures with loose 7 parts associated with the reactor coolant system, our 8 Nuclear Fuel Department does a loose parts evaluation.
9 And that has been done.
10 We also have a procedure for material in 11 general, which also requires an evaluation. The loose 12 parts procedure for the nuclear fuels area 13 specifically excludes things like valve-seat 14 interactions, flow blockages in other areas. And the 15 procedure for regular foreign material, if you will, 16 requires that those types of evaluations take place.
17 I was not able to find the second evaluation done 18 under the general foreign material procedure.
19 The third part is the cultural aspect of 20 this. When we attempt to close this value, it does 21 what is called torquing out. The motor torques out.
22 And what we are doing there is we are routinely 23 actuating a protective feature and then relying on 24 that feature.
25 As part of the communication from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 decision-making plan, we see that the performance of 2 this valve has improved over time. My contention is 3 it's improved because we're shaving the metal off and 4 we're putting it in CRS.
5 The decision-making plan also addresses an 6 organizational concern that this could be viewed as, 7 this decision to not repair the valve could be viewed 8 as, negatively by the organization.
9 The response to that concern was that Mr.
10 Kozinski issued a page and a half letter describing 11 the decision-making process and why the decision was 12 made.
13 That letter was not effective in 14 correcting any organizational concerns. There has 15 been a lot of concern among the station employees 16 about this issue. Their concern has ranged from they 17 probably shouldn't have done that to rather expressive 18 concerns using a fair amount of profanity. So the 19 letter was not effective in addressing that 20 organizational issue. That's my statement so far.
21 CHAIRMAN LYONS: All right. Thank you 22 very much. (Inaudible.)
23 With that, I look around the table here.
24 Are there any questions that we have, any additional 25 questions, on the issue? Yes. We've got a question NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 here.
2 MR. SCARBOROUGH: This is Tom Scarborough.
3 I'm with the Mechanical Engineering Branch with NRR.
4 You mentioned about the motor was 5 torquing out in terms of how it was operated. So I 6 assume what you're saying is it was operated on the 7 torque switch when it was closing?
8 MR. QUIGLEY: Yes.
9 MR. SCARBOROUGH: And when they operated 10 the valve, do you have any knowledge of how the torque 11 switch was set up, what was used as a basis for the 12 setup of the torque switch in terms of the weak link?
13 MR. QUIGLEY: No, I do not.
14 MR. SCARBOROUGH: Do you know if after 15 they operated it, they -- when they operated it a 16 second time -- you said they continued to operate it.
17 Did they leave the torque switch in the circuit for 18 the second try or did they bypass it?
19 MR. QUIGLEY: The torque switch was left 20 in the circuit.
21 MR. SCARBOROUGH: Okay. So it was 22 operated that way. Do you know of any other 23 diagnostics that they had on the motor operator valve 24 when they were running it?
25 MR. QUIGLEY: They were doing a current NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 trace on the motor.
2 MR. SCARBOROUGH: Okay. Do you have any 3 results of that, do you know?
4 MR. QUIGLEY: I've had the result 5 explained to me. And basically by looking at the 6 current trace, you can tell when the valve guide pops 7 back in by looking at the current trace. So what we 8 do is we run the motor until it torques out. And then 9 we back it up and try again in trying to get the valve 10 guide to pop back into the seat.
11 MR. SCARBOROUGH: Okay. So what you saw 12 during the trace was that the guide was not fully 13 attached and that it was being bent and then once it 14 got to a certain point, it popped back into its normal 15 alignment?
16 MR. QUIGLEY: It's a vertical guide that 17 is essentially hinged at the top and has a smaller pin 18 you pin at the bottom. And that's all that holds it 19 in.
20 What is happening is that the pin at the 21 bottom breaks and it allows the valve guide to 22 basically kick out a little bit at the bottom as the 23 pin that's up at the top. And when it does that, the 24 valve cannot fully close.
25 So closing the valve, repeated attempts to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 close the valve, will eventually cause that valve 2 guide to pop back into the body.
3 MR. SCARBOROUGH: Now, what type of valve 4 body is it?
5 MR. QUIGLEY: It's a stainless steel valve 6 body.
7 MR. SCARBOROUGH: Do you know what's the 8 manufacture?
9 MR. QUIGLEY: Westinghouse.
10 MR. SCARBOROUGH: During the operation, 11 are you familiar with any motor type of burnup issues 12 or problems of noise issues that accompanied when they 13 operated the valve?
14 MR. QUIGLEY: No, I'm not.
15 MR. SCARBOROUGH: Okay. Whenever you were 16 operating, did you notice any valve or stem 17 degradation or packing issues? Was there any 18 knowledge of that?
19 MR. QUIGLEY: I reviewed the condition 20 reports. And I was talking to some of the systems 21 engineers on this. And I have not heard that 22 information.
23 MR. SCARBOROUGH: Checking my notes here.
24 (Pause.)
25 MR. SCARBOROUGH: Yes. A question I had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 was, do you know what the actual -- the guide is 2 material, what is the guide material?
3 MR. QUIGLEY: I believe the guide is also 4 stainless steel.
5 MR. SCARBOROUGH: In terms of your 6 description, it talked about there was a plan for 7 resolution but then it was cancelled. Can you tell us 8 a little bit about what the plan for resolution was 9 that subsequently was cancelled?
10 MR. QUIGLEY: The longstanding plan to fix 11 this valve that had existed for basically a large 12 portion of the planning for B1R 13 was to install --
13 we were going to have the core barrel out. And that 14 will allow us ready access to the collate connection 15 to the reactor vessel.
16 The plug has been manufactured and 17 reviewed by engineering. And that plug is going to be 18 installed into the cold leg nozzle from the reactor 19 vessel side, inflated with a dual seal. And that 20 would have allowed work to proceed on the RCS cold leg 21 isolation valve.
22 That plan had been reviewed by the POR 23 Committee, Plant Oversight Review Committee, and 24 approved by the committee.
25 MR. SCARBOROUGH: And, again, can you talk NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 a little bit about what the actual operation on the 2 valve was planned to be in terms of what corrective 3 action was going to be taken?
4 MR. QUIGLEY: The bonnet was going to be 5 removed and a new type of valve guide installed that's 6 not acceptable to this type of failure.
7 MR. SCARBOROUGH: Okay. So they were 8 going to remove that guide itself and weld in a new 9 guide of some type or attach?
10 MR. QUIGLEY: I don't believe any welding 11 was involved. I think it was us placing it in.
12 MR. SCARBOROUGH: Okay. Anything else you 13 can think of that might be helpful in terms of the 14 technical issue?
15 MR. QUIGLEY: On the valve itself? No.
16 MR. SCARBOROUGH: Right. Okay. Thank 17 you.
18 CHAIRMAN LYONS: Any other questions here 19 in headquarters? Region or the residents, do you have 20 any questions that you have or would like to ask?
21 PARTICIPANT: Region III has nothing from 22 the office.
23 CHAIRMAN LYONS: Rick?
24 PARTICIPANT: And nothing from the site.
25 CHAIRMAN LYONS: Okay. Frank Orr, who is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 from headquarters, did you have any questions?
2 MR. ORR: I don't have any questions on 3 the equipment. I didn't know if we had been satisfied 4 in our yesterday's discussion that we had -- had we 5 concluded that we had enough technical information 6 about the function of the valve and its necessity?
7 CHAIRMAN LYONS: Well, I guess that is one 8 of the questions (Inaudible.) is one of the questions 9 that we had had.
10 MR. QUIGLEY: The valve has a maintenance 11 function to close. It has a safety-related function 12 as a pressure boundary. And it has an implied safety 13 function to not put pieces of metal in the reactor 14 coolant system.
15 CHAIRMAN LYONS: Okay. (Inaudible.)
16 Exelon, do you have any questions from the site?
17 PARTICIPANT: None from the site.
18 CHAIRMAN LYONS: How about Exelon 19 headquarters?
20 PARTICIPANT: None from here, Jim.
21 CHAIRMAN LYONS: All right.
22 MS. SKAY: Mr. Quigley, this is Donna 23 Skay. Just an administrative question. I know you 24 are trying to fax in a signed copy of the petition.
25 MR. QUIGLEY: Yes.
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18 1 MS. SKAY: Were you ever able to get that 2 through or did you mail in a --
3 MR. QUIGLEY: I was not able to get it 4 through.
5 MS. SKAY: Okay. We will use the version 6 you e-mailed, then, as the sole copy.
7 MR. QUIGLEY: Okay.
8 MS. SKAY: Fine. Thank you.
9 CHAIRMAN LYONS: Okay. If there are no 10 other questions, I think we had mentioned that we need 11 to move forward with this. And I appreciate, Mr.
12 Quigley, your discussion of this. I thought it was 13 very good that you were able to run through it in an 14 orderly manner.
15 Sometimes we have people that tend to 16 stray on their discussions. And it's nice when we 17 have someone who can explain their issues clearly and 18 succinctly. So I appreciate that.
19 And hearing no other questions or comments 20 --
21 MR. QUIGLEY: Well, just one thing I 22 wanted to close with --
23 CHAIRMAN LYONS: Sure.
24 MR. QUIGLEY: -- is what I believe to be 25 the driver of this issue --
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19 1 CHAIRMAN LYONS: Okay.
2 MR. QUIGLEY: -- with the excessive 3 emphasis on dose reduction --
4 CHAIRMAN LYONS: Okay.
5 MR. QUIGLEY: -- and the fact that the 6 dose reduction plays such a large role in everyone's 7 bonus, including mine. Now, the same thing happened 8 at David Bessee with dose, and an engineer came in in 9 the morning. The scaffold was down because of dose.
10 They wouldn't let him look at it again because of 11 dose. Previous jobs they had cut the jobs due to 12 dose.
13 And their bonuses were tied to production.
14 Here it's a little bit closer tie where our bonuses 15 are tied directly to dose. Essentially the 16 (Inaudible.) has gone out the window because we don't 17 know what reasonable is because we don't know how much 18 we're willing to spend to save a millirem.
19 And that money had to come from somewhere 20 else. And we are diverting money from things that 21 could be better used for dose. You know, like I said 22 in the petition, you know, reducing dose sounds noble, 23 but when it starts compromising safety and you start 24 deferring maintenance, that becomes the issue.
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20 1 have another question here at headquarters.
2 PARTICIPANT: Can we go (Inaudible.)
3 CHAIRMAN LYONS: Yes. Hold on just one 4 second.
5 PARTICIPANT: Sure.
6 (Pause.)
7 PARTICIPANT: Mr. Quigley (Inaudible.)
8 just a question of clarification. Your letter states 9 that you're looking for enforcement action. Can you 10 provide any more specifics on what particular 11 enforcement action you had in mind?
12 MR. QUIGLEY: Criterion safety requires 13 that you correct conditions adverse to quality. This 14 condition has existed for at least six years and had 15 not been corrected. So it will be a violation of 16 criterion 16.
17 PARTICIPANT: So you're looking for a 18 notice of violation? Is that what you're requesting?
19 MR. QUIGLEY: Yes.
20 PARTICIPANT: Thank you.
21 CHAIRMAN LYONS: All right. Well, thank 22 you. And I guess hearing no other -- I guess I'll 23 give kind of a second chance for anybody else if they 24 have any other questions or comments.
25 (No response.)
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21 1 CHAIRMAN LYONS: Okay. Hearing none, 2 again, I appreciate everybody's time and attention on 3 this phone call. After the Petition Review Board 4 makes its determination, we will be getting back in 5 touch with you, Mr. Quigley.
6 MR. QUIGLEY: Thank you.
7 CHAIRMAN LYONS: Thank you very much.
8 MR. QUIGLEY: You're welcome.
9 PARTICIPANT: Thank you.
10 (Whereupon, the foregoing matter was 11 adjourned.)
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