ML102090391
| ML102090391 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/15/2010 |
| From: | Farideh Saba Plant Licensing Branch II |
| To: | Farzam F, Tanya Mensah, George Thomas NRC/NRR/DE/EMCB, Division of Policy and Rulemaking |
| References | |
| FOIA/PA-2010-0116 | |
| Download: ML102090391 (39) | |
Text
Lake, Louis From:
Sent:
To:
Cc:
Subject:
Attachments:
Saba, Farideh Friday, January 15, 2010 11:22 AM Mensah, Tanya; Thomas, George; Farzam, Farhad; Franke, Mark; Sykes, Marvin; Rezai, Ali; Blount, Tom; Lake, Louis; Clark, Michael Mozafari, Brenda; Boyce, Tom (NRR); Khanna, Meena; Rosenberg, Stacey; Lupold, Timothy; Carrion, Robert; Hardage, David; Chou, Rich Crystal River 2.206 regarding Mr. Thomas Saporito petition request for Containment Issue at CR-3 G20090690_Crystal River Containment Issue_ 01-07-10 meeting transcript_ corrected.doc; G20090690_Crystal River Containment Issue_ PRB Notes for Internal meeting.doc Attached are corrected transcript for the January 07, 2010 meeting/conference call with Mr. Saporito and notes that I have prepared for the PRB internal meeting on January 21. Please let me know if you have any questions or comments.
- Regards, Farideh Farideh E. Saba, P.E.
Senior Project Manager NRC/ADRO/NRR/DORL 301-415-1447 Mail Stop O-8G9A Farideh.Saba@NRC.GOV
("9 32
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Crystal River Unit 3 2.206 Petition
Title:
Docket Number:
(n/a)
Location:
(telephone conference)
Date:
Thursday, January 7, 2010 Work Order No.:
NRC-01 8 Pages 1-32 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433 m
L-)OD96 %
0'0ý( P q6fl(TleIk
1 1
UNITED STATES OF AMERICA 2
+++++
3 NUCLEAR REGULATORY COMMISSION 4
+++++
5 THOMAS SAPORITO 10 CFR 2.206 PETITION FOR 6
CRYSTAL RIVER UNIT 3 7
8 TELECONFERENCE 9
+++++
10 THURSDAY 11 JANUARY 7, 2010 12
+++++
13 The teleconference convened at 14 10:30 a.m.,
Thomas Blount, Petition Review Board 15 Chair, presiding.
16 NRC STAFF PRESENT:
17 THOMAS BLOUNT, NRR/ADRO/DPR, Petition Review Board 18 Chair 19 THOMAS BOYCE, NRR/ADRO/DORL/LP[L2-2]
20 RICH CHOU, Region II 21 MICHAEL CLARK, OGC/GCHEA/AGCMLE 22 BOB CARRION, Region II 23 FARHAD FARZAM, NRR/DE/EMCB 24 MARK FRANKE, Region II 25 DAVID HARDAGE, Region II NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE,, N.W.
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2 LOUIS LAKE, Region II 2
TANYA MENSAH, NRR/ADRO/PSP[B],
Petition Review Board 3
Coordinator 4
BRENDA MOZAFARI, NRR/ADRO/DORL/LP[L2-2]
5 ALI REZAI, NRR/DCI/CPNB 6
STACEY ROSENBERG, NRR/ADRO/DPR/
PSP[B]
7 FARIDEH SABA, NRR/ADRO/DORL/LP, Crystal River Unit 3 8
Project Manager 9
MARVIN SYKES, Region II 10 GEORGE THOMAS, Region II 11 12 PETITIONER:
13 THOMAS SAPORITO 14 15 PROGRESS ENERGY REPRESENTATIVES PRESENT:
16 BRIAN McCABE 17 JOHN FRANKE 18 GARRY MILLER 19 JOHN O'NEILL 20 21 22 23 24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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P-R-O-C-E-E-D-I-N-G-S 2
(10:34 a.m.)
3 MS.
SABA:
Good morning.
I would like to 4
welcome to thank everybody for attending this 5
meeting.
6 My name is Farideh Saba, and I
am the 7
Crystal River Nuclear Generating Plant Unit 3 Project 8
Manager.
9 We are here today to allow the Petitioner, 10 Mr.
Thomas Saporito, to address the Petition Review 11 Board regarding the 2.206 petition dated December 5,
12 2009.
13 I
am the Petition Manager for this 14 petition.
The Petition Review Board Chairman is Tom 15 Blount.
As part of the Petition Review Board, or PRB, 16 review of this petition, Thomas Saporito has requested 17 this opportunity to address the PRB.
18 This meeting is scheduled from 10:30 a.m.
19 to 12:00 p.m.
Eastern Time.
The meeting is being 20 recorded by the NRC Operations Center and will be 21 transcribed by a Court Reporter.
The transcript will 22 become a supplement to the petition.
The transcript 23 will also be made publicly available.
24 I would like to open this meeting with 25 introductions.
As we go around the room, please be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4
sure to clearly state your name, your position, and the office that you work for within the NRC for the record.
I'll start off.
Farideh Saba, Senior Project
- Manager, Office of Nuclear Reactor Regulation,
- NRR, Division of Operating Reactor Licensing.
MR.
REZAI:
Ali Rezai, Piping and NDE Branch, Materials Engineer.
MR.
FARZAM:
Farhad Farzam, Mechanical and Civil Engineering Branch, NRR Office.
MR.
CLARK:
I'm an attorney with the Office of the General Counsel.
MS.
MOZAFARI:
Brenda
- Mozafari, Senior Project Manager, NRR.
MR.
BOYCE:
Tom Boyce.
I'm a Licensing Branch Chief in the Office of
- NRR, Division of Operating Reactor Licensing.
MS.
MENSAH:
I'm the 2.206 coordinator in the office of NRR.
[GHAI-Tom]
BLOUNT:
Tom
- Blount, NRR, Deputy Director in the Division of Policy and Rulemaking.
I am the PRB Chair.
MS.
ROSENBERG:
Stacey Rosenberg,
- NRR, Branch Chief in the Division of Policy and Rulemaking.
MS.
SABA:
Okay.
Are there any representatives for the licensee on the phone?
Please NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 I
introduce yourself.
2 MR.
McCABE:
- Yes, thanks, Farideh.
This 3
is good morning to everyone.
This is Brian McCabe.
4 I'm the Regulatory Affairs Manager for Progress 5
Energy.
With me on the call-today are John Franke, 6
the Crystal River 3 Vice President; Garry Miller, the 7
General Manager responsible for the Crystal River 3 8
containment project; and John O'Neill, who is serving 9
as counsel to Progress Energy.
10 We appreciate the opportunity to 11 participate in the call today.
We understand that, 12 per Management Directive 8.11, this is a call between 13 the NRC and the Petitioner, and that the purpose is to 14 afford the Petitioner an opportunity to provide the 15 NRC with additional information relative to the 16 petition.
17 So, as such, we understand and respect our 18 role on this call is not to be an active participant, 19 but to, rather, listen to the discussions,
- and, if 2
necessary, ask clarifying questions, so that we 21 understand the issues that have been raised.
22 So,
- again, Farideh, we appreciate the 23 opportunity to listen in on the discussions today.
24 And with that, I will turn it back to you.
25 MS.
SABA:
Okay.
We would like also to --
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NRC employees from the region or anybody else on the 2
line please introduce yourself.
3 MR.
FRANKE:
From Region II, this is Mark 4
- Franke, Chief of Engineering Branch T,-I-[31, Division 5
of Reactor Safety.
6 MR.
CARRION:
This is Bob Carron also from 7
Region II, Senior Project Engineer --
Senior Reactor 8
Engineer with Engineering !-!-![3].
9 MR.
CHOU:
Rich
- Chou, C-H-O-U, I0 Region II 11 THE COURT REPORTER:
Pardon me.
This is 12 the transcriber.
I am not getting a good recording.
13 Somebody doesn't have their phone on mute.
I'm 14 getting interference.
15 MR.
McCABE:
- Hey, Mark
- Franke, this is 16 Brian McCabe.
It seems like when the region is 17 speaking there is a lot of interference in what is 18 coming over the speaker.
19 MR.
FRANKE:
Okay.
So only when we're 20 speaking, Brian?
21 MR.
McCABE:
- Yes, now it's clear.
But it 22 seemed like there was some shuffling associated with 23 the speaker that might have been interfering in the 24 communication.
25 MR.
FRANKE:
Okay.
Thank you.
What was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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the last name that the transcriber was able to get?
2 THE COURT REPORTER:
I couldn't get the 3
names from whenever that region started to 4
introduce themselves, the interference started, so I 5
couldn't get the names.
They were --
there were only 6
two names.
7 MR.
FRANKE:
We'll have the same person 8
basically introduce all of us.
9 MR.
SYKES:
Okay.
So here in Region II we 10 have Mark Franke, Chief of Engineering Branch 1-11[3]
11 in the Division of Reactor Safety; we have Bob 12 Carrion, Senior Inspector, Division of Reactor Safety; 13 we have Rich Chou, Senior[reactor] Inspector, Division 14 of Reactor Safety; we have David
- Hardage, Reactor.
15 Inspector, Division of Reactor Projects; and Marvin 16
- Sykes, Chief, Division of Reactor Projects, Branch 17 1-11[3].
And that's all from here in Region II.
18 And onsite at Crystal River we have I
19 think Lou Lake, Louis Lake, Senior Inspector,
- DRS, 20 Branch 1-1[3],
Engineering Branch 1-1-[31; and Mr.
21 George Thomas from our Office of Nuclear Reactor 22 Regulation in Washington.
23 MS.
SABA:
Okay.
Mr.
Saporito, would you 24 please introduce yourself for the record?
25 MR.
SAPORITO:
Yes.
My name is Thomas NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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Saporito.
I'm a United States citizen.
I reside in 2
Jupiter, Florida.
3 MS.
SABA:
Are there any others, such as 4
members of the public, on the phone?
5 MR.
DANIELSON:
My name is Rick Danielson.
6 I'm a reporter with the St. Petersburg Times.
7 MS.
SABA:
Could you please spell your 8
name?
9 MR.
DANIELSON:
Yes.
First name Richard, 10 R-I-C-H-A-R-D, last name Danielson, D-A-N-I-E-L-S-O-N.
11 MS.
SABA:
And would you please repeat 12 your association?
13 MR.
DANIELSON:
I'm a reporter with the 14 St. Petersburg Times in Florida.
15 MS.
SABA:
Thank you.
16 MR.
DANIELSON:
You're welcome.
17 PARTICIPANT:
This is the headquarters 18 operations officer.
Just for your information, if you 19 do not have a mute on your phone, you can mute it 20 through our system by hitting star 6.
And then, when 21 you want to unmute, you can hit star 6 again.
22 MS.
SABA:
Thank you.
23 I would like to emphasize that we each 24 need to speak clearly and loudly to make sure that the 25 Court Reporter can accurately transcribe this meeting.
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If you do have something that you would like to say, 2
please first state your name for the record.
3 At this time, I will turn it over to the 4
PRB Chairman, Mr.
Tom Blount.
5 CHAIR BLOUNT:
This is Tom Blount.
Good 6
morning.
Welcome to the meeting regarding the 2.206 7
petition submitted by Mr.
Saporito.
I would like to 8
first share some background on our process.
9 Section 2.206 of Title -[10]
of the Code 10 of Federal Regulations describes the petition process 11 the primary mechanism for the public to request 12 enforcement action by the NRC in a public process.
13 This process permits anyone to petition the NRC to 14 take enforcement-type action related to NRC licensees 15 or licensed activity.
Depending on the results of 16 this evaluation, NRC could modify, suspend, or revoke 17 an NRC-issued license, or take any other appropriate 18 enforcement action to resolve a problem.
19 The NRC staff guidance for the disposition 20 of a
2.206 petition request is in Management 21 Directive 8.11, which is publicly available.
22 The purpose of today's meeting is to give 23 the Petitioner an opportunity to provide any 24 additional explanation or support for the petition 25 before the Petition Review Board's initial NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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consideration and recommendation.
2 This meeting is not a hearing, nor is it 3
an opportunity for the Petitioner to question or 4
examine the PRB on the merits or the issues presented 5
in the petition request.
No decisions regarding the 6
merits of this petition will be made at this meeting.
7 Following this
- meeting, the Petition 8
Review Board will conduct its internal deliberation.
9 The outcomes of this internal meeting will be 10 discussed with the Petitioner.
11 The Petition Review Board typically 12 consists of a chairman, usually a manager at the 13 senior executive
- level, senior executive service 14 level, at the NRC.
It has a petition manager and a 15 PRB coordinator.
Other members of the Board are 16 determined by the NRC staff based on the content of 17 the information and the petition request.
18 At this time, I would like to introduce 19 the Board.
I am Tom Blount, the Petition Review Board 20 Chairman.
Farideh Saba is the Petition Manager for 21 the petition under discussion today.
Tanya Mensah is 22 the office's PRB coordinator.
23 Our technical staff includes Farhad Farzam 24 and George Thomas from the Office of NRR, Mechanical 25 and Civil Engineering Branch; Ali Rezai from
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Piping and NDE Branch; Marvin Sykes and Mark Franke, 2
Branch Chiefs from Region II.
We also obtain advice 3
from our Office of General Counsel represented by Mike 4
Clark.
5 As described in our process, the NRC staff 6
may ask clarifying questions in order to better 7
understand the Petitioner's presentation and to reach 8
a reasoned decision whether to accept or reject the 9
Petitioner's request for review under the 2.206 10 process.
11 I would like to summarize the scope of the 12 petition under consideration and the NRC's activities 13 to date.
On December 5,
- 2009, Mr. Saporito submitted 14 to the NRC a petition under 2.206 against Progress 15 Energy Corporation at Crystal River Nuclear Generating 16 Station Unit 3.
17 In this petition request, Mr.
Saporito 18 identified the following areas of concern.
Physically 19 remove the --
Mr.
Saporito requests that the NRC take 20 enforcement action against the licensee and issue a 21 confirmatory order requiring that the licensee:
- one, 22 physically remove the outer 10 inches of concrete 23 surrounding the Crystal River Nuclear Containment 24 Building from the top of the Containment Building to 25 the bottom of the Containment Building and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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encompassing 360 degrees around the entire Containment 2
Building.
3 Two, test samples of the concrete removed 4
from the Crystal River Nuclear Containment Building 5
for composition and compare the test results to a 6
sample of concrete from a similarly-designed facility 7
like the Florida Power & Light Company Turkey Point 8
Nuclear Plant.
9
- And, three, maintain the Crystal River 10 Nuclear Station in cold shutdown mode until such time 11 as the licensee can demonstrate full compliance with 12 its NRC operating license for Crystal River, within 13 the safety margins delineated in the licensee's final 14 safety analysis report and within the Crystal River 15 Nuclear Station's site-specific technical 16 specification.
17
- And, four, provide the public with an 18 opportunity to intervene at a public hearing before 19 the NRC Atomic Safety and Licensing Board to challenge 20 any certification made by the licensee to the NRC that 21 it has reestablished full compliance with 10 CFR 50 22 and the safety margins delineated in its FSAR and 23 technical specification.
24 Allow me to discuss the NRC activity to 25 date.
On December 9,
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to address the PRB prior to its initial meeting, and 2
requested time to prepare supplemental information for 3
the Board's consideration.
And that is the meeting 4
that we are having today.
5 As a reminder for the phone participants, 6
please identify yourself if you make any remarks, as 7
this will help us in the preparation of the meeting 8
transcript that will be made publicly available.
9 Thank you.
10 Mr. Saporito, I will turn the meeting over 11 to you to allow you to provide any information you 12 believe the PRB should consider as part of this 13 petition.
You will have one hour, as you requested, 14 to provide additional information to the PRB.
15 MR.
SAPORITO:
All right.
Thank you very 16 much.
I appreciate the opportunity to engage the NRC 17 in this manner.
18 First of all, good morning to everyone.
19 As I stated earlier for the record, my name is Thomas
,20 Saporito.
That's S as in Sam, A-P-O-R-I-T-O.
And I 2
am the Petitioner in this matter.
22 As a result of the licensee's discovery of 23 a structural defect in the Crystal River Nuclear Plant 24 Containment Building, I filed a formal request through 25 the NRC 2.206 process.
The specific request was for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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confirmatory order to take enforcement action, which 2
the Chairman has addressed very adequately.
3 For the benefit of those members of the 4
public who may be attending this meeting today, I will 5
provide a brief background of the events of the 6
Crystal River Nuclear Plant for which this petition 7
arose.
During the maintenance activity performed 8
under the direction and authorization of the licensee 9
to cut an opening in the Containment Building to gain 1
access to replace steam generator
- units, it was 11 discovered that the there were separations or 12 delaminations in the concrete perimeter of the 13 Containment Building.
14
- Now, the licensee has been engaged in 15 various testing methods to determine the root cause of 16 the separations with the delaminations.
So before I 17
- continue, let me --
let me just state that in a prior 18 teleconference call attended by the NRC, and by the 19
- licensee, myself, and others, the licensee made a
20 verbal commitment -t-e[through] Mr.
Jim Scarola, if I'm 21 not mistaken, to determine the root cause of the 22 delamination of the Containment Building structure 23 prior to the restart of the Crystal River nuclear 24 reactor.
25 First, let me say that I have personally NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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worked with Mr.
Scarola during the startup of the 2
Florida Power
& Light Company St.
Lucie Nuclear 3
Reactor Number 2, and I can assure everyone attending 4
this teleconference today that Mr.
Scarola is a very 5
competent and knowledgeable individual who always 6
places safety ahead of economics.
7 With respect to the Crystal River 8
Containment Building, the actual root cause of the 9
structural failure may never be fully known.
During 10 the last telephone conference
- call, the licensee 11 stated that they were investigating a
number of 12 reasons that may have contributed to the root cause of 13 the Containment Building delamination, and that they 14 were engaged in a process of eliminating this area of 15 suspected reason in an attempt to determine the root 16 cause of the Containment Building delamination.
17
- However, because of the nature of this 18 particular structural failure, the actual root cause 19 may never really be discovered.
- And, instead, the 20
- licensee, through the process of elimination, may 21 arrive at what I call a best guess determination of 22 the root cause.
23 Nonetheless, the NRC's focus should not be 24 solely on what the root cause of the containment 25 structure failure was, but instead I would suggest NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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that the agency should focus its attention on whether 2
the licensee at some time in the future will be able 3
to return the Crystal River Containment Building's 4
safety design basis, the safety margins required in a
5 licensee's
- FSAR, and site-specific technical 6
specifications.
7 In other words, the licensee need not be 8
required to state for certain the root cause of the 9
containment structural failure to be allowed to 10 restart the nuclear reactor, so long as the licensee 11 can demonstrate reasonable assurance that the Crystal 12 River Containment Building can function to meet its
- 13.
safety design basis after repairs are completed.
14 And I think that is the focus that the NRC 15 should be engaged, because there is, you know --
I am 16 not a rocket scientist or a degreed engineer, but I 17 can tell you just, you know, common sense looking at 18 this particular failure, there is a number of reasons 19 that could have caused this failure --
the tensioning 20 of the peripheral tendons prior to making the cut, the 21 manner in which the cut was
- made, the vibrations, 22 there have been a number of reactor SCRAMs that caused 23 the pressure within the containment structure to vary 24 and caused that failure --
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material against concrete.
2 There are just so many reasons that to be 3
certain of any one particular reason that caused this, 4
I don't as a reasonable-minded
- person, I
don't 5
think it's possible, especially because there was no 6
in my research no similar failure to this degree 7
and this extent over the course of the operation of 8
the 104 reactors operating in this country.
9 For the benefit of the NRC, I refer --
I 10 have done some research on this topic, and I refer you 11 to a document that's entitled "Detection of Aging [of]
12 Nuclear Power[
]pPlant Structures."
This was 13 apparently authored by D.J. Naus --
that's spelled N-14 A-U-S from the Oak Ridge National Laboratory, Oak 15 Ridge, Tennessee, and also by H.L. Graves, G-R-A-V-E-16 S,
- III, the U.S.
Nuclear Regulatory Commission, 17 Washington, D.C.
18 And specific to this article, which drew 19 my attention, it speaks at one point in this article 20 about the --
from a safety standpoint, speaking from a 21 safety standpoint, that the containment is
-- hello?
22 MS.
SABA:
We can hear you.
23 MR.
SAPORITO:
Oh, okay.
I thought 24 someone was okay.
From a safety standpoint, the 25 containment is one of the most important components of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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a nuclear power[
]plant, because it serves as the 2
final barrier to the release of fission products or 3
radioactive particles to the outside environment under 4
postulated accident conditions.
5 So that --
that sums it up.
That sums up 6
the importance of the of the failure of this 7
Containment
- Building, why it is so important the 8
licensee's repairs are such that the licensee return 9
this building to its original design basis, because 10 this is we are talking about containing nuclear 11 materials from entering the environment and harming 12 the public.
13 The article goes on.
It talks about that 14 such physical damage occurs when the geometry of a 15 component is altered by the formation of
- cracks, 16 fissures, or voids, or its dimensions change due to 17
- overload, buckling, corrosion,
- erosion, or formation 18 of other types of surface flaws.
You know, changes in 19 the component geometry can affect structural capacity 2
by reducing the net section available to resist 21 applied loads.
22 So, in
- essence, the failure or the 23 delamination of the containment structure, and 24 specifically the Crystal River Containment Building, 25 is very significant because it in its current state NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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it can no longer meet its safety design basis.
It 2
can't function sufficiently to protect public health 3
and safety should there be a nuclear accident within 4
that containment structure, and similar to Three Mile 5
Island where you had, you know, a major portion of the 6
core actually melt down.
7 Fortunately, that containment structure 8
served its design basis, and it functioned to protect 9
the public and the environment by containing those --
10 the majority of that nuclear material, although some 11 was eventually released.
12 So also what caught my attention in this 13 article was it
- says, "Where concrete degradation 14 incidents have occurred, they have generally done so 15 early in the life of the structure and were corrected.
16 Causes were primarily related to improper material 17 selection, construction/design deficiencies, or 18 environmental effects."
19 It says examples of some degradation 20 occurrences include cracking in basements -- base mats 21 (Waterford, Three Mile Island, North Anna, and Fermi);
22 and it says voids under the vertical tendon bearing 23 plates resulting from improper concrete placement as 24 in reference Calvert Cliffs plant; failure or pre-25 stressing wires, again Calvert Cliffs; cracking of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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post-tensioning tendon anchor heads due to the stress, 2
corrosion, or embrittlement they point to 3
Bellefonte, Byron, and Farley plants.
4
- And, finally, they talk about the 5
containment dome delaminations due to low quality 6
porous aggregate material and absence of r-a4de[radial]
7 reinforcement, and they specifically refer to the 8
Crystal River Nuclear Power[ ]pPlant.
9 So these --
this delamination event has 10 apparently occurred before, maybe not to the same 11 degree, but it has apparently occurred before at the 12 licensee's Crystal River Nuclear Plant.
It goes on to 13 say that, on balancc[unbalanced],
pre-stressing forces 14 and they referenced the Turkey Point Nuclear Plant; 15 corrosion of steel reinforcement and water intake 16 structures
- again, Turkey Point and San Onofre; 17 leaching of tendon concrete
- again, Three Mile 18 Island.
And it goes on and on, and it is giving 19 reasons that these failures were likely to have 20 occurred in the past.
21 There is no definitive root cause found in 22 my research into any of these events.
But it is 23 noteworthy that Crystal River
- has, in the
- past, 24 experienced containment dome delamination due to the 25 quality of the porous aggregate materials.
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there was something wrong with the concrete apparently 2
that was poured in the formation of that structure 3
that has --
in the past that has caused delamination.
4 And the NRC does have regulations at 5
10 CFR Part 54 which states to licensees like Florida 6
Power or Florida excuse me, Progress Energy 7
Corporation, in its operation of the Crystal River 8
Nuclear Power[ IpPlant with respect to the structural 9
integrity of the Containment Building.
IC The article also references it says 11 here that the most significant information came from 12 inspections performed by the NRC staff of six plants 13 licensed before 1977.
And it says most of the 14 information on degraded conditions of the containment 15 structures was submitted by licensees under LERs, or 16 licensee event reports, under 10 CFR 50.73.
That went 17 to the inspections by licensees, voluntary 18 inspections, to try to do some type of long-term 19 surveillance of any type of corrosion or defects.
20 But the article says --
points out here 21 that --
this is very significant.
It says further, 22 "Based on the results of inspections and audits, the 23 NRC was concerned because many licensee containment 24 examination programs didn't appear to be adequate to 25 detect degradation that could potentially compromise NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1
the containment leak-tight integrity."
2 So what --
in other words, you know, the 3
status quo of the nuclear industry in their --
their 4
current surveillance programs doesn't appear to be 5
adequate to make detections, like the delamination 6
event we're talking about here at the Crystal River 7
Nuclear Power[ ]pPlant in its Containment Building.
8 NRC regulations at Appendix J,
under 9
10 CFR Part 50, requires a general inspection of the 10 accessible interior and exterior surface of 11 containment structures like that at Crystal River and 12 components to uncover any evidence of structural 13 deterioration that may affect either the containment 14 structural integrity or leak-tightness.
15 So, you know, how do you how do you 16 inspect a containment structure at a Crystal River 17 facility on a routine basis to make sure that you 18 don't have a delamination?
19 My concerns are that, you know, you --
the 20 current visual inspections are not satisfactory, 21 obviously, and the current inspection techniques being 22 used by the licensee for the remaining structure of 23 the containment facility at Crystal
- River, in my 24
- opinion, aren't sufficient to determine if there 25 exists more cracks, more fissures, more voids, more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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delaminations of the Crystal River Containment 2
Building.
3 So, you know, the -- this research article 4
that I've been pointing to here throughout this 5
discussion, they are talking about different 6
volumetric methods to make determinations of 7
delaminations and cracks and fissures and voids, and 8
they talk about ultrasonic
- testing, eddy current 9
testing, radiographic testing.
10 And it even points to some of the 11 standards that are defined in Article IWE-3000 of the 12 ASME Code, but all of these tests which this article 13 speaks to, and all of the tests that the licensee has 14 done to
- date, are more or less non-destructive 15 testing, meaning there is some means to inject some 16 certain type of signals and the resultant feedback to 17 make a reasonable determination whether or not other 18 delaminations exist at the Crystal River containment 19 structure.
And those determinations are not proof 20
- positive, in my view, that other fissures or cracks 21 are not present.
22
- Now, in my opinion, the only way to make 23 certain that there are no other delaminations, cracks, 24
- fissures, voids, or separations in the containment 25 structure itself is to remove 10 inches. of concrete NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1
from the perimeter of that facility, from the top to 2
the bottom, 360 degrees around.
3 And when I the reason I quote
[-i-rl0]
4 inches is because you have peripheral
- tendons, the 5
peripheral tendons that surround the Crystal River 6
containment structure from top to bottom.
They are 7
five and a
quarter inches in diameter.
The 8
containment wall itself containment wall itself is 9
42 inches thick from inside to the outside.
10 If you look at the pictures that are 11 already on record of these --
of the cut-away of the 12
- opening, you can see that the horizontal
- tendons, 13 which are five and a quarter inches in diameter, are 14 very near the outer edge of that 42-inch thick wall, 15 so much so, if you visually can place two of them side 16 by side, you could see that it is there is less 17 than a foot of concrete between the exposed tendon. and 18 that --
where the licensee has cut an opening in the 19 containment wall, you will see the exposed tendon.
20
- Well, that top [pereushorizontal]
tendon 21 is within 10 inches of the exterior of that 22 containment wall.
So that means there is a tremendous 23 amount of force being applied to a very small part of 24 that 42-inch thick wall.
It may or may not have 25 something to do with the delamination in this case.
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25 1
You know, I can't say.
2 But on the other hand, what we may have 3
here is a design --
design flaw, meaning the actual 4
design of this containment structure having those 5
tendons placed so close, within 10 inches of the 6
exterior part of that 42-inch thick concrete wall, 7
that design may itself be flawed and subject the 8
entire structure to other cracks and fissures and 9
- voids, which the licensee simply cannot detect with 10 any type of instrumentation to make certain that --
of 1
their non-existence.
12 Therefore, the only way to protect public 13 health and safety is to remove 10 inches of concrete 14 all around the building, from top to bottom, so you 15 would expose all of the tendons from top to bottom.
16 And with that concrete removed, you could reform that 17 structure, and in my view it should be reformed so 18 that you would add additional concrete when you repour 19 it, so that you would have --
so that you would have 20 those tendons, which are now within 10 inches of the 21 exterior perimeter of that concrete structure, you 22 should reform it so that when the new concrete is 23 poured that those tendons are in the middle of the 24 wall.
25 So you would have to add concrete so that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 I
the entire thickness of the wall places the steel 2
perimeter tendons exactly in the middle of that wall, 3
so that you won't have a repeat of this situation, 4
because you would have the extra structural support of 5
the concrete outside the tendons, and it wouldn't be 6
mere 10 inches.
7
- Now, the FSAR required licensee to build 8
this containment structure with a model with a thick 9
model model a thick perimeter wall, meaning it is 10 one one solid structure.
So this delamination 11 obviously violates the safety margins of the FSAR and 12 the site-specific technical specifications for 13 operation of a Crystal River nuclear reactor under its 14 current license.
15 So, therefore, what I would like the NRC 16 to focus on is the --
eventually, you know, we need to 17 get the plant back online, of course, because although 18 we have numerous avenues of renewable energy 19 available, or at our disposal in this current day, we 20 have a viable nuclear power[ ]plant here that should 21 be brought back into service as soon as possible with 22 safety foremost of course.
23 So to that extent, if we are going to 24 bring this reactor back online --
and we need to make 25 certain to protect public health and safety and to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1
protect the environment that this containment building 2
not only meets but exceeds its original design basis 3
which is delineated in the FSARs.
4 And the only way to do that is to make 5
certain there aren't any more flaws in that --
in that 6
building.
And you have --
and the only way you are 7
going to do that is through destructive removal of the 8
10 inches --
of the remaining 10 inches of concrete 9
around the entire building, top to bottom, until you 10 can visually inspect it.
11 And in addition to that, when the licensee 12 arrives at the point where repairs are actually going 13 to be made, it makes --
it is just common sense that 14 you reform the containment building with additional 15 concrete.
And with the existing --
with the existing 16 10 inches removed, as I
spoke to earlier, you are 17 going to have a higher degree of adhesion from the old 18 concrete to the new concrete, because it is going to 19 be uniform, you are going to --
you are going to have 20 a
you are going to form that put new forms 21 around the facility to pour the new concrete, and you 22 are going to have a higher degree of success and 23 reasonable assurance that the concrete perimeter wall 24 of the Containment Building has been restored to 25 monolithic status.
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Otherwise, if the NRC allows the licensee 2
to merely remove 20 or 30 feet around the existing 3
- defect, and to do a patch, there is no reasonable 4
assurance, number
- one, that that patch adequately 5
adhered to the existing concrete or that other 6
fissures and voids and delaminations do not exist.
7 So those are my concerns, and I have given 8
the NRC some direction through reference of this 9
document I spoke to earlier, which has covered a lot 1
of these areas.
But, you know, what the NRC should be 11 concerned with is that the containment building 12 eventually be returned to its original design basis, 13 if not better, and that the licensee has provided 14 reasonable assurance through removal of the perimeter 15 concrete that there are no more fissures or voids, and 16 that recurrence through the method of repair assures 17 that these defects won't again occur in the future.
18 And if there is any questions, I
will 19 certainly do my best to answer them at this time.
20 CHAIR BLOUNT:
Mr.
Saporito, this is Tom 21 Blount.
I do have a question.
Could you go back to 22 the title of the article that you were using as a 23 reference, please, and give me the --
24 MR.
SAPORITO:
Yes.
- Yes, it's entitled 25 "Detection of Aging
[of]
Nuclear Power[.] [pP]lant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1
Structures."
And underneath that it says "draft," and 2
underneath that it says D as in
- David, J as in
- Jack, 3
- Naus, N
as in
- Nancy, A-U-S, Oak Ridge National 4
Laboratory, Oak Ridge, Tennessee, and underneath that 5
it has H as in Henry, L as in Lucy, Graves, G-R-A-V-E-6 S,
- III, U.S.
Nuclear Regulatory Commission, 7
Washington, D.C.
8 CHAIR BLOUNT:
Does that this is Tom 9
Blount again.
Does that document have a
number 10 associated with it?
11 MR.
SAPORITO:
I don't I
don't see a 12 document number.
13 CHAIR BLOUNT:
Okay.
What I'm asking is, 14 is it an NRC document?
15 MR.
SAPORITO:
- Well, I
believe it I
16 believe it is.
It is well, there is a
going to 17 the very end of it here, it looks like it's 36 --
36, 18 37 pages.
It's
- well, I'm trying to find you a
19 reference.
Okay.
There is no --
I
- mean, there's a
20 bunch of NRC --
it references a bunch of NRC documents 21 at the very end of the document, but there is no --
22 there is no telling the NRC database number for this.
23 CHAIR BLOUNT:
Okay.
So it is the NUREG, 24 then.
That's what I'm asking you.
Is it 25 MR.
SAPORITO:
No, it's not a I
don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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believe it's a NUREG.
No, I think --
I believe this 2
is a
document that was drafted by these two 3
individuals for the benefit of the NRC.
And whether a 4
NUREG was developed from this I --
I can't say at this 5
point.
I haven't had enough time to do further 6
research.
7 CHAIR BLOUNT:
Okay.
All right.
That's 8
I was just trying to understand the genesis and the 9
basis of the
- document, and I
think you told me 10 somewhat that it is a draft document.
11 MR.
SAPORITO:
Yes.
12 CHAIR BLOUNT:
Okay.
And it was developed 13 by an NRC employee.
14 MR.
SAPORITO:
- Yes, it appears to be.
15 H.L. Graves, III, appears to be an NRC employee, and 16 D.J. Naus, appears to be an employee of the Oak Ridge 17 National Laboratory.
18 CHAIR BLOUNT:
Okay.
Gotcha.
I 19 appreciate that.
20 Let's see.
At this time, does anyone at 21 the headquarters staff have any questions for Mr.
22 Saporito?
23 (No response.)
24 Okay.
Looking around the table, seeing no 25 questions here, does anyone for the region have any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 questions for Mr. Saporito?
MR.
SYKES:
No, we don't in Region II.
CHAIR BLOUNT:
And from Crystal River NRC staff?
MR.
LAKE:
No questions from Crystal River NRC staff.
CHAIR BLOUNT:
Thank you.
Does the licensee have any questions for Mr.
Saporito?
THE COURT REPORTER:
I'm sorry.
Who was that from the region, the Crystal River staff?
This is the transcriber.
MR.
SYKES:
This was Marvin Sykes in Region II.
MR.
LAKE:
This NRC, at Crystal River.
MR.
McCABE:
Tha McCabe from Progress Energy.
questions.
is Louis Lake down here,
- tnks, Tom.
This is Brian Progress Energy has no CHAIR BLOUNT:
I understand no questions.
Do we have any members of the public on the line?
(No response.)
Is the gentleman from the press still on the line?
MR.
DANIELSON:
- Yes, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1
Danielson with the St.
Pete[rsburg]
Times.
I don't 2
have any questions.
3 CHAIR BLOUNT:
Before I conclude, members 4
of the public may provide comments regarding the 5
petition and ask questions.
I understand you have no 6
questions at this time.
Do you have any comments?
7 (No response.)
8 Understanding that there are no questions 9
or comments, Mr.
- Saporito, thank you very much for 10 taking the time to provide the NRC staff with 11 clarifying information on the petition you submitted.
12 Before we close, does the Court Reporter 13 require or need any additional information for the 14 meeting transcript?
15 THE COURT REPORTER:
I do.
16 (Whereupon, some spellings and clarifications of 17 technical terms were provided by Mr.
18 Saporito.)
19 CHAIR BLOUNT:
Very good.
With that, the 20 meeting is concluded, and we will be terminating the 21 phone connection.
Thank you very much for your time, 22 everyone.
Have a nice day.
23 (Whereupon, at 11:21 a.m.,
the proceedings in the 24 foregoing matter were concluded.)
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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PETITION REVIEW BOARD MEETING January 21. 2010
SUBJECT:
PETITIONER:
DATE:
THOMAS SAPORITO 10 CFR 2.206 PETITION AGAINST THE PROGRESS ENERGY COMPANY, REGARDING CONTAINMENT CONCRETE DELAMINATION AT CRYSTAL RIVER NUCLEAR PLANT, UNIT 3 (G20090690)
Mr. Thomas Saporito December 5, 2009 PRB MEMBERS & ADVISORS Tom Blount Farideh Saba Tanya Mensah Farhad Farzam George Thomas Ali Rezai Marvin Sykes Mark Franke Michael Clark (PRB Chair - Deputy Director, NRR, Division of Policy and Rulemaking)
(Petition Manager - NRR, Division of Operating Reactor Licensing)
(Agency 2.206 Coordinator - NRR, Division of Policy and Rulemaking)
Technical Reviewer - NRR. Mechanical and Civil Engineering Branch Technical Reviewer - NRR. Mechanical and Civil Engineering Branch Technical Reviewer - NRR. Piping and NDE Branch Branch Chief-Region II Branch Chief-Region II Attorney - Office of General Counsel
SUMMARY
OF REQUEST FOR IMMEDIATE ACTIONS:
The petitioner requests that the NRC take enforcement action against the licensee and issue a Confirmatory Order requiring that the licensee take the following actions at Crystal River Nuclear Generating Plant, Unit 3 (CRN):
- 1. Physically remove the outer ten-inches of concrete surrounding the CRN containment building from the top of the containment building to the bottom of the containment building and encompassing 360-degrees around the entire containment building;
- 2. Test samples of the concrete removed from the CRN containment building for composition and compare the test results to a sample of concrete from a similarly designed facility like the Florida Power and Light Company (FPL), Turkey Point Nuclear Plant (TPN);
- 3. Maintain the CRN in cold-shutdown mode until such time as the licensee can demonstrate full compliance with its NRC operating license for CRN within the safety margins delineated in the licensee's Final Safety Analysis Report (FSAR) and within the CRN cite specific technical specifications; and
- 4. The petitioner in its December 5, 2009 petition -requests to provide the public with an opportunity to intervene at a public hearing before the NRC Atomic Safety and Licensing Board (ASLB) to challenge any certification made by the licensee to the NRC that it has reestablished full compliance with 10 CFR 50 and the safety margins delineated in its FSAR and technical specifications.
- 5.
From the January 7, 2010 conference call transcript - Reform the containment structure with adding additional concrete when it is repoured [rebuilt], so that those [horizontal] tendons, which are now within 10 inches of the exterior perimeter of that concrete structure, will be in the middle of the wall [containment concrete] after it is rebuilt BASIS FOR THE REQUEST
- 1. The petitioner stated that during a maintenance activity performed under the direction and authorization of the licensee to cut an opening in the CRN containment building for access to replace steam generator units, the CRN containment building was discovered to have one or more separations between the poured concrete perimeter wall of the containment building and the horizontally installed tendons placed from top to bottom around the containment building within 10-inches of the outer-most part of the 42-inch thick concrete perimeter wall of the containment building. To date, the licensee has not been able to determine the "root-cause" of this structural failure.
- 2. The petitioner stated that the licensee is currently engaged in conducting Impulse Testing of the remaining CRN containment building perimeter wall to determine if additional separations exist. However, the petitioner implies that the licensee's use of Impulse Testing is not sufficient to make such a determination. Notably, Impact Echo testing is used world-wide to determine concrete cracking and failures on public bridges and the like, but even this type of testing is not sufficient to fully validate the entirety of the CRN containment building.
Furthermore, the petitioner believes that even the use of destructive testing to make visual inspections of small areas of the CRN containment building is not sufficient to qualify the entirety of the containment building.
- 3. The petitioner believes that removal of ten-inches of concrete from the outer-part of the 42-inch containment building wall from top to bottom and 360-degrees around would effectively expose the entirety of the surrounding 5 1/4" tendons and allow visual inspection of the inner-side of the tendons to make certain that no separation between the tendons and the inner-part of the concrete wall exist.
- 4. The petitioner states that removal of 10-inches of concrete from the outer-part of the 42-inch containment building wall from top to bottom and 360-degrees around would ensure for the best possible adhesion of a new concrete pour to the existing inner concrete perimeter wall of the containment building.
- 5.
Furthermore, states that the licensee's FSAR requires that the CRN containment building be comprised of a monolithic concrete perimeter wall. The petitioner believes that the only way the licensee can fully achieve compliance with its FSAR is to remove ten-inches of concrete from the outer-part of the 42-inch containment building wall from top to bottom and 360-degrees around for proper visual inspect repair activities.
- 6. From the January 7, 2010 conference call transcript-The petitioner implies that there may have been a design flaw, meaning the actual design of this containment structure having those [horizontal] tendons placed within 10 inches of the exterior part of that 42-inch thick concrete wall, that design may itself be flawed and subject the entire structure to other cracks and fissures and voids, which the licensee simply cannot detect with any type of instrumentation to make certain that of their non-existence. Therefore, the petitioner requested that the CR-3 containment building not only meets but exceeds its original design basis which is delineated in the FSARs.
DOES IT MEET CRITERIA FOR REVIEW?
YES Criteria for Reviewing Petitions Under 10 CFR 2.206:
1.
The petition contains a request for enforcement-related action such as issuing an order modifying, suspending, or revoking a license, issuing a notice of violation, with or without a proposed civil penalty.
YES. The petitioner requests that the NRC take enforcement action against the Progress Energy at CRN and issue a Confirmatory Order requiring that the licensee actions 1, 2, 3, and 5 listed in the above "Summary of Request for Immediate Action."
- 2.
The facts that constitute the bases for taking the particular action are specified. The petitioner must provide some element of support beyond the bare essentials. The supporting facts must be credible and sufficient to warrant further inquiry.
YES. The petitioner has taken adequate lengths to present facts related to the need for the requested action.
- 3.
There is no NRC proceeding available in which the petitioner is or could be party and through which the petitioner's concerns could be addressed.
YES. There is no other NRC proceeding available. There is an on-going NRC proceeding (completion of the Special Inspection Team inspection report and public exit) where the petitioner could be a party and through which the petitioner's concerns could be addressed (public exit). However, the SIT process and Special Inspection Charter to Evaluate Crystal River Containment Building are not publicly available at this time.
Criteria for ReiectinQ Petitions Under 10 CFR 2.206:
1.
The incoming correspondence does not ask for an enforcement-related action or fails to provide sufficient facts to support the petition, but simply alleges wrongdoing, violations of NRC regulations, or existence of safety concerns.
NO.
- 2.
The petitioner raises issues that have already been the subject of NRC staff review and evaluation either on that facility, other similar facilities, or on a generic basis, for which a resolution has been achieved, the issues have been resolved, and the resolution is applicable to the facility in question.
NO. See item 3 above.
- 3.
The request is to deny a license application or amendment.
NO.
- 4.
The request addresses deficiencies within existing NRC rules.
NO. For Actions 1, 2, 3, and 5.
Yes. For Action 4 that the petitioner requests to provide the public with an opportunity to intervene at a public hearing before the NRC Atomic Safety and Licensing Board (ASLB) to challenge any certification made by the licensee to the NRC that it has reestablished full compliance with 10 CFR 50 and the safety margins delineated in its FSAR and technical specifications.
IS THERE A NEED FOR IMMEDIATE ACTION: (If Yes, describe)
NO.
CR3 has remained in a no-mode condition (defueled) since Friday, October 9, 2009 and core re-load has been suspended indefinitely. Therefore, there is no immediate safety concerns, and therefore no need for immediate action.
In addition, the NRR and Region II staffs are currently reviewing and the issues presented in this petition. Region II initiated a special inspection on October 13, 2009, to address the circumstances associated with the delamination identified in the CR3 containment structure. NRR is providing support to the SIT with George Thomas of the Division of Engineering (DE) traveling to CR3 and by contracting Dan Naus as an independent structural engineering contractor from the Department of Energy's (DOE) Oak Ridge National Laboratory (ORNL). The NRR staff is currently supporting the SIT's activities by assessing and evaluating the licensee's root cause analysis; design basis analyses; and repair strategy.
Also, the NRR staff is providing support for the review of the non-destructive examination techniques being used by the licensee to assess the extent of condition of the delamination extent of condition determination The SIT exit, which is a public meeting, is scheduled to take place following the licensee's completion of their root cause and design basis analyses.
IS THERE A NEED FOR OE. 01, OIG, or OGC INVOLVEMENT:
YES. The petitioner requests, Action 4, to provide the public with an opportunity to intervene at a public hearing before the NRC Atomic Safety and Licensing Board (ASLB) to challenge any certification made by the licensee to the NRC. This requested action is outside the NRC current process and addresses deficiencies within existing NRC rules.
Therefore, this action item may be rejected and the OGC legal review and advice is needed. There is no need to involve OE, 01, OIG, or the Allegations group.
RECOMMENDED APPROACH AND SCHEDULE (Next Steps):
ACCEPT THE PETITION FOR REVIEW In this petition, the staff is aware of the issue and is closely following the licensee's progress through the SIT activities and the NRR staff reviews. However, the issue had not been resolved. Therefore, the Petition Manager recommends that the PRB accept the petition for review, except action 4 which addresses the NRC's process and is not an enforcement action against the licensee.
The next steps would be to:
Internal PRB meeting is scheduled on January 21, 2010 to discuss/make the initial recommendation to accept or reject the petition for review under 10 CFR 2.206
" Ensure management agrees with the PRB recommendation Inform the petitioner of the PRB recommendations Determine if the petitioner would like a post-PRB meeting or telecon, and make the arrangements for an acceptable date and time