ML110840219
| ML110840219 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point, Oyster Creek |
| Issue date: | 04/04/2011 |
| From: | Geoffrey Miller Plant Licensing Branch 1 |
| To: | Chernoff H Plant Licensing Branch 1 |
| Miller G, NRR/DORL/LPL1-2, 415-2481 | |
| References | |
| NRC-652 | |
| Download: ML110840219 (91) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 4, 2011 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch 1-2 1.
Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: G. Edward Miller, Project Manager ~.
Plant Licensing Branch 1-2 Division of Operating Reactor liCenSing! d bt)16 lad\.
Office of Nuclear Reactor Regulation U
SUBJECT:
MEMORANDUM TO FILE: TRANSCRIPTS FOR 10 CFR 2.206 PETITION REGARDING OYSTER CREEK AND NINE MILE POINT, UNIT NO.1, PEAK CLADDING TEMPERATURE AND ECCS PERFORMANCE The Purpose of this memorandum is to provide and make publically available, the transcripts associated with the petition submitted by Mr. Mark E. Leyse regarding the Oyster Creek Nuclear Generating Station and Nine Mile Point, Unit NO.1. The petition was submitted pursuant to Title 10 of the Code of Federal Regulations, Section 2.206. Enclosure 1 contains the transcript from the petitioner's first opportunity to address the petition review board (PRB) which occurred on January 13, 2011. Enclosure 2 contains the transcript from the petitioner's second opportunity to address the PRB which occurred on February 17, 2011. Both transcripts have been corrected based upon review by the NRC staff and the petitioner, as supported by the audio recording of the call. Changes made to the petitions are marked in square brackets.
Docket Nos. 50-219 and 50-220
Enclosure:
As stated
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board Oyster Creek and Nine Mile Point Docket Number: (n/a)
Location: (conference call)
Date: Thursday, January 13, 2011
- Transcript Corrections marked in [square brackets]
Work Order No.: NRC-652 Pages 1-55 NEAL R. GROSS AND CO., INC. Encolsure 1 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
+ + + + +
10 CFR 2.206 PETITION REVIEW BOARD (PRB)
CONFERENCE CALL ON 7 OYSTER CREEK AND NINE MILE POINT 8 + + + + +
THURSDAY 10 JANUARY 13, 2011 11 + + + + +
12 The conference call was held, Theodore 1 Quay, Chairperson of the Petition Review Board, presiding.
1 1 PETITIONER: MARK LEYSE 1 PETITION REVIEW BOARD MEMBERS 1 THEODORE QUAY, Deputy Director, 20 Division of Policy and Rulemaking 21 TANYA MENSAH, Petition Coordinator, 22 Office of Nuclear Materials Safety and 2 Safeguards ED MILLER, Petition Manager for 2.206 petition 2
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2 NRC HEADQUARTERS STAFF BRETT KLUKAN, Attorney, Off of General Counsel JOYCE TOMLINSON, Region 1, Division of Reactor Safety SHIH-LIANG NU, Office of Nuclear Reactor Regulation, Nuclear Performance and Code Review Branch 1
11 12 1
1 1
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3 1 On Behalf of Exelon:
DONALD FERRARO, ESQ.
3 200 Exelon Way 4 Kennett Square, PA 19348 5 Tel: ( 610) 765-5381 7
8 1
11 12 1
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4 1 TABLE OF CONTENTS 2 Opening - Mr. Miller. .5 Introductions .6 Background and Overview - Chairman Quay .8 Mr. Leyse 13 Closing Chairman Quay 55 1
11 12 13 14 1
1 17 18 1
2 21 22 23 24 2
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5 1 P-R-O-C-E-E-D-I-N-G-S 2 1:01 p.m.
3 MR. MILLER: Okay. So, we're re today 4 to allow the Petitioner, Mr. Mark Leyse, to address the Peti on Review Board regarding the 2.206 Petition dated December 10, 2010.
I'm the Petition Manager for the petition 8 and the Petition Review Board Chairman is Ted Quay.
As part of the Petition Review Board's 1 review of the petition, Mr. Leyse has requested the 11 opportunity to address the PRB.
12 This meeting is scheduled to go from 1:00 1 to 3:00 p.m. Eastern Time.
The meeting is being recorded by the NRC 1 Operations Center and will be transcribed by a court 1 reporter. The transcript will become available later 17 and be attached as a supplement to the petition. It 18 will also be made publicly available.
1 I'd like to open this meeting with 20 introductions. We'll start here. We'll go around the 21 room.
22 As I said, myself, I'm Ed Miller.
MR. DUDLEY: I'm Richard Dudley from the NRR Rulemaking Branch.
MS. ROSENBERG: Stacey Rosenberg. I'm a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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6 1 Branch Chief in the Division of Policy and Rulemaking 2 in Office of Nuclear Reactor Regulations.
MS. MENSAH: Tanya Mensah. I'm the 2.206 Coordinator in the Office of Nuclear Reactor Regulations.
CHAIRMAN QUAY: Ted Quay, Division of Policy and Rulemaking, NRR.
MR. KLUKAN: Brett Klukan. I'm the Attorney Representative from the Office of the General 10 Counsel.
11 MR. WU: Shih-Liang Wu, Nuclear 12 Performance and Code Review Branch, NRR.
MR. GUZMAN: ch Guzman, ect Manager in the Office of Nuclear Reactor Regulation or NRR.
MS. SANDERS: Carleen Sander, Project Manager, Office of NRR.
MR. WHITED: Jeff Whited, ect Manager also in NRR.
MR. MILLER: Okay. That's the 20 introductions for NRC Headquarters. At this time, I'd 21 like to ask for anybody from the NRC not with us in 22 person to identify themselves if they could.
MR. KULP: Hi. This is Jeff Kulp. I'm up at Region 1. Also, Senior at Oyster.
MR. MILLER: Anyone else from the NRC?
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7 1 Okay.
2 Do we have any representatives from the Licensee on the phone?
MR. WALKER: Yes, there's a number of people from Exelon here. I'll go through the names.
I think we've given them to the court reporter 7 already, but -
8 MR. MILLER: Yes, I know we went through them before, but for the record, if you could. So.
1 MR. WALKER: And if I miss anybody, please 11 speak up. I have Dean Galanis, Andy Olson, Hossein 12 Youssefnia, Anthony Giancatarino, Don Ferraro, Chase 13 McDaniel, Dave Helker, Doug Walker. Did I miss 14 anybody?
1 MR. THOMPSON: Rick Thompson.
1 MR. WALKER: Rick Thompson.
17 MR. FLEMING: From Constellation Energy 18 Nuclear Group Headquarters, this is Carey Fleming C-A 1 R-E-Y and Fleming with one M.
2 MR. DOSA: And John Dosa from the site.
21 MR. MILLER: Anybody else from the 22 Licensee's side? Okay. Mr. Leyse, for record, 2 could you please introduce yourself as well?
MR. LEYSE: Sure. Mark 1'm 2 Petitioner.
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8 1 MR. MILLER: Okay. And I thought I heard 2 somebody speak up just about the same time. Did somebody else want to introduce themselves?
MR. LOCHBAUM: This is David Lochbaum with the Union of Concerned Scientists.
MR. MILLER: Okay. Any other members of the public? Okay. We'll move forward then.
I'd like the emphasize today that everybody when they speak please do so loudly and 10 clearly. It will ass our court reporter in 11 accurately transcribing meeting.
12 If you do have something you'd like to 1 say, also please state your name before you speak.
Again, to help him attribute that to the appropriate 1 person.
1 For those dialing into the meeting, if you would please put your phone on mute when you're not 1 speaking to minimize any background noises and 1 distractions. If you don't have a mute button, you 20 can so press *6 and that will through the conference 21 line, mute your phone. Again, that's *6 to mute your 22 phone if you don't have an mute feature.
23 At this time, I'd like to turn it over to 24 the PRB Chairman, Mr. Quay.
2 CHAIRMAN QUAY: Good afternoon. Welcome NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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9 1 to this meeting regarding the 2.206 Petition submitted 2 by Mr. Leyse.
3 I'd like to first share some background on 4 our process. Section 2.206 of Title 10 of the Code of Federal Regulations describes the ition process, the primary mechanism for the public to request enforcement action by the NRC in a public process.
This process permits anyone to petition the NRC to take enforcement-type action related to NRC licensees 10 or licensed activities.
11 Depending on the results of its 12 evaluation, NRC could modify, suspend or revoke an 1 NRC-issued license or take any other appropriate enforcement action to resolve a problem.
1 The NRC staff's guidance on a disposition 1 for 2.206 ition requests in Management Direct 17 8.11 which is publicly available.
18 The purpose of today's meeting is to 1 the petitioner an opportunity to provide any 20 additional explanation or support for the petition 21 before the Petition Review Board's initial 22 consideration and recommendation. This meeting is not 2 a hearing nor is it an opportunity for the Petitioner to question or examine the PRB on the merits or the 2 issues presented in the petition request.
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10 1 No sion regarding the merits of this 2 ition will be made at this meeting.
Following this meeting, the Petition 4 Review Board will conduct its rnal deliberations.
5 The outcome of s internal will be discussed with the Petitioner.
7 The Petition Review Board typically 8 consists of a Chairman, usually a manager at senior executive service level at the NRC and has a 10 Petition Manager and a Petition Review Board 11 Coordinator. Other members of the Board are 12 determined by the NRC staff based on the content of 1 the information in a petition request.
At this time, I'd like to introduce the 1 Petition Board. I am Ted Quay, the Petition Review 1 Board Chairman. Ed Miller is the Petition Manager for 17 the petition under discussion today. Tanya Mensah is 18 Office of Petition Review Board Coordinator. Our 1 technical staff includes Shih-Liang Wu from the Office 20 of Nuclear Reactor Regulations, Nuclear Performance 21 and Code Review Branch. Joyce Tomlinson from NRC's 22 Region 1 Division of Reactor Safety. We also obtain advice from our General Coun represented by Brett Klukan.
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11 1 may ask clarifying questions in order to better 2 understand the Petitioner's presentation and to reach a reasoned decision whether to accept or reject the tioner's request for review under the 2.206 process.
I would like to summarize the scope of the 7 pet ion under consideration and the NRC activities to 8 date.
On December 10th, 2010, Mr. Leyse 10 submitted to the NRC a petition under 2.206 regarding 11 the licensing basis peak-cladding temperatures of 12 Oyster Creek Nuclear Generating Station and Nine Mile 13 Point Unit 1 and the Licensee's ability to quench fuel 14 cladding using emergency core cooling systems in the 1 event of a loss of coolant accident or known as a 1 LOCA.
17 In this ition request, Mr. Leyse 18 identified the following areas of concern.
1 Experimental data indicates that Oyster Creek and Nine 20 Mile Unit 1 licensing basis peak-cladding temperatures 21 of 2150 and 2149 respectively do not provide necessary 22 margins of safety against partial or complete meltdown 2 in the event of LOCAs. Such data indicate that Oyster Creek and Nine Mile 1 licensing basis peak-cladding 2 temperatures must be decreased to temperatures lower NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NoW.
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12 1 than 1832 degrees Fahrenheit in order to provide 2 necessary margins of 3 Experimental data indicates that Oyster 4 Creek and Nine Mile 1 emergency core cooling systems would not effectively quench the fuel cladding in the event of LOCAs if the fuel cladding reached Oyster 7 Creek and Nine Mile 1 1 ing bas peak-cladding 8 temperatures of 2150 degrees Fahrenheit and 2149 degrees Fahrenheit respectively.
10 Based on the stated concerns, Mr.
11 requested the NRC order the Licensees of Oyster Creek 12 and Nine Mile 1 to lower the licensing basis peak-13 cladding temperature of Oyster Creek and Nine Mile 1 14 in order to provide necessary margins of safety to 1 help prevent partial or complete meltdown in the event 1 of LOCAs, order the censees of Oyster Creek and Nine 17 Mile 1 to demonstrate the Oyster Creek and Nine Mile 18 1 BWR/2 emergency core cooling systems would 1 effectively quench the fuel cladding in the event of 20 LOCAs and prevent partial or complete meltdowns.
21 The activities, to date, regarding this 22 petition have included on December 10th, 2010, the 2 petition was received by the NRC. On December 17th, 2010, the Petitioner requested to address the Petition 2 Review Board prior to his initial meeting to further NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW (202) 234-4433 WASHINGTON, D.C. 20005*3701 www.nealrgross.oom
13 1 clarify the provided information for the Board's 2 consideration. On January 13th, 2010, today, we are providing the requested opportunity to address the Petition Review Board.
As a reminder for the phone participants, please identify yourself if you make any remarks as 7 this will help in the preparation of the meeting 8 transcript that will be made public available.
Thank you and at this point, I'm going to turn it over to you, Mr. Leyse.
MR. LEYSE: Okay. Yes. Yes, Mark 12 speaking. I would first like to bring up a couple of 13 things. Just that this ition is very similar to an 14 enforcement action petition I filed regarding Vermont 1 Yankee that it has additional information that 1 the peti regarding Vermont Yankee did not have and 17 one additional thing is that I've placed information 18 in about the - how the presence of inconel spacer 1 grids would affect the cladding in the event of a loss 20 of coolant accident and that's something that I did 21 not cover in the Vermont Yankee petition.
22 So, that basically on pages 69 through 2 roughly -- let me see. Sixty-nine through 72 of the petition, it talks about chemical interactions between 2 zircaloy and stainless steel and between zircaloy and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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14 1 inconel at "low temperatures." So, I think that's 2 something important to look at just -- and it even actually has a quote from Dan Ford of Union of Concerned Scientists from 1971 regarding zircaloy inconel eutectics and just how this is not considered.
So, you know, when you see that this was an issue raised back in 1971, it really kind of means that, you know, it's about time that we look at it.
And then, of course, the petition how it 10 differs from the Vermont Yankee petition is that I 11 talk about BWR thermal hydrau experiments and, of 12 course, [spray] cooling and also kind of point out 13 that there there really has not been many 14 experiments conducted with zircaloy bundles and that 1 the heat transfer coe that are used in the 1 computer codes are derived the appendix [K ones]
17 that are used both at Oyster Creek and Nine Mile Point 18 Unit Number 1 are actually from sta s steel 1 [tests] where they used stainless steel fuel rod 2 simulators and they're not from z bundled 21 [tests] and I think that's a big problem that is -
22 just really to be addressed.
2 And I also did want to see - I can 24 continue, but I just wanted to see if Mr. Lochbaum 25 wanted to discuss BWR systems and how the BWR/2 system NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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15 1 is different from other ECCS systems. But, I'm not 2 you know, I just -- because I -- I'm not sure what his schedule is like and two hours -- I'm not sure if this will -- if we have enough to cont this until 3:00.
I had actually asked for 90 minutes. I Appreciate the extra time, but I just wanted to see if he wanted to say something.
MR. LOCHBAUM: Yes, this is Dave Lochbaum.
Thanks, Mark.
1 I just wanted to re what Mark has 11 in the pet ion he submit The Oyster Creek 12 reactor, the BWR/2 product, the emergency core ing 13 systems for the Oyster Creek reactor are different 14 from those systems on the later versions of the 1 boiling water reactor. The Dresden -- introduced at 1 Dresden and later expanded the BWR/4 and BWR/5 and 6 1 lines. In that the Oyster Creek emergency core cool ing systems aren't quite as diverse and redun,dant 1 as the latter product lines in terms of core spray and 2 [LPCI (Low Pressure Coolant Injection)] and all the 21 other stream-driven, electric-dr diverse systems, 22 number pumps and capabilities. Oyster is 2 different from those and that.
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16 1 are probably as small at Oyster Creek as anywhere.
2 In that regard, seems that his petition the safety concerns about cladding rate in Mark
's petition are as relevant at Oyster Creek as anywhere. more so because of the minimal safety margins that exist there.
And that's about as much as I wanted to say. I appreciate the opportunity. Thanks.
MR. LEYSE: This is Mark Leyse speaking.
10 Yes. Yes, thank you and I appreciate your input on 11 this and I think that this does make -- this is -
12 obviously, this petition is addressing generic issues 13 where the metal water reaction is indeed a 14 issue and, in , it's a issue to say that 1 there are problems with these tests that are all based 1 on stainless tests.
17 However, there is some part that is plant 18 specific which is what Mr. Lochbaum just mentioned.
1 Was the fact that Oyster Creek and Nine Mile Point 20 Unit Number 1 are the only two reactors that are 21 licensed by NRC that do have the BWR/2 ECCS. So, 22 that makes this issue regarding those plants, you 2 know, plant 2 So, I think that is something to take into 2 consideration -- for the Petition Review Board to take NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE" NW (202) 2344433 WASHINGTON, D,C, 20005-3701 www,nealrgross,com
17 1 into consideration how this is unique to these two 2 plants and would not apply to other BWR systems or PWRs. Where the tion that was filed with Vermont Yankee, the Petition Review Board decided that it was a gene c issue because that was focusing primarily on the metal water reaction. That that would apply to 7 all plants even PWRs and as you know, that was 8 actually even turned into a rulemaking petition PRM
[50-95] .
10 But, in this case, I think there is 11 something that's plant specific for these two plants.
12 And I also think that there is a -- as I 13 repeated -- I'm repeating what I before. Just 14 with Appendix K which is what is used at Oyster Creek 1 and Nine Mile Point Unit Number 1, the heat transfer 1 coefficients that are used in the ECCS evaluation 17 calculations, they're derived from stainless steel 18 tests and that is discussed in the petition. Let me 1 see. I think that's page 74 to page 78 and that's 2 just I think there's definitely a problem where I 21 -- admittedly, what I'm going to say now more of a 22 generic sue. I think the NRC needs to have tests 2 conducted with zircaloy bundles, zircaloy fuel rod simulators and bundles for heat transfer tests and for 2 deriving heat transfer coefficients.
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18 1 There's actually a statement from the PWR 2 [FLECHT] reports that Westinghouse did [,] where they state that heat transfer coefficients are not directly measurable quantit s. They must be calculated from measured temperatures, known heat sources and known thermal propert s and I would add that, you know, in 7 line with that, the heat transfer coefficients that 8 would be used in LOCA analysis for real reactor cores with zircaloy fuel assemblies, they must also be 1 calculated from thermal hydraulic experiments that are 11 conducted with multi-rod zircaloy bundles.
12 And basically, in recent years, most of 13 the primary facilities that have -- testing facilities 14 for BWR thermal hydraul tests, they've been 1 conducted with inconel 600 bundles and the behavior of 1 that regarding oxidation is just different than it is 17 with zircaloy when you get up to temperatures above 18 1800 degrees Fahrenheit.
1 And I wanted to point out that even today 2 there's a test facility at Purdue and oddly enough 21 papers that are talking about this facility. It's the 22 [PUMA] Facility. They don't mention what the cladding 2 material is. I'm assuming that the cladding material would be inconel 600 since that has been used at a lot 2 of other test lities. But, this paper you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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19 1 know, I've looked at over a dozen papers from this 2 test facility and none of them even state what the cladding material is.
And just recent lities like the two
[loop] -- well, not recent, but just past facil like the two [loop] test apparatus, the TLTA facility that General Electric had that had electrically heated inconel 600 fuel rod simulators, for example, and there was another facility that General Electric had 1 the FIST facility. That also had inconel 600 fuel rod 11 simulators. The Rosa facility in Japan also had 12 inconel 600 fuel rod simulators.
1 And as I mentioned before, General Electric, what appendix K is based off of are the BWR 1 [FLECRT] tests that were conducted by General Electric 1 in the y 1970s and they did, I believe, five tests 17 with zircaloy, but those tests, they did not use the 18 results of those tests and they actually used those 1 tests to compare them to the results of the stainless 2 steel tests and what are used as appendix K heat 2 transfer coefficients actually come from some of the stainless steel tests that General E conducted.
2 That's for BWR ECCS evaluation calculations.
And then some of the results actually of 2 the -- one of the, in particular, zircaloy tests was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW (202) 2344433 WASHINGTON, D.C. 20005*3701 www.nealrgross.com
20 1 very problematic. It really did not demonstrate that 2 the core spray systems would work and there were a number of criti sms of this test including criticisms from Roger Griebe who worked with Aerojet who kind of oversaw the -- I don't know the exact role that he had, but I believe it was with the Atomic Energy 7 Commission. He was in the role of overseeing the test 8 that General Electric was conducting and he wasn't so convinced that one of these tests didn't turn out so 1 well and that would be the ZR2 test.
11 And there is a quote that I have in the 12 Oyster Creek/Nine Mile Point Unit 1 tion. It's on 1 page 72 and 73. It's from J.W. McConnell who also worked at Aerojet and that just kind of shows that he 1 wasn't so convinced that the top -- the top spray ECCS 1 systems would be very effective. He actually said 17 from a licensing viewpoint, the effectiveness of top 18 spray emergency core cooling systems that it has not 1 been demonstrated nor has it been proven ineffective 2 and he also questioned the accuracy of predicting the 21 heat transfer coefficients for the metal water 22 reactions and how they could be -- in terms of 2 separating them and just showing that they did, in fact, have proper heat transfer coefficients that had 2 been derived from the s less steel tests.
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21 1 So, that's something -- these are things 2 to consider. Admittedly, what I've just discussed are more generic sues.
4 And I did want to also mention that there 5 was an issue in the early '80s regarding I be it was generic issue A16, stearn affects on BWR core spray 7 distribution and apparently, they wanted to show that 8 the BWR ECCS systems would actually be effective terms of core spray distribution.
10 And there were a number of tests that were 11 conducted by General Electric and these tests were 12 actually conducted by the two [loop] test apparatus, 1 the TLTA Ii ty and again, as I mentioned before, they had inconel 600 fuel rod simulators and they also 1 conducted some tests with the 30 percent stearn sector 1 test facility. That's the SSTF facility and I'm not 17 sure what the cladding material was at that facil 18 I haven't been able to locate information on that.
1 But, one thing that indicates the temperatures may not 20 have been very high is that I believe they used stearn 21 injection to simulate core heat and the maximum 22 temperature the stearn was 800 degrees Fahrenheit.
2 Anyway, these generic issues -- this issue that was concern A16 stearn affects on BWR core 2 spray distribution was decided -- after these tests, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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22 1 they concluded that this issue had been resolved and I think that's something to also look at. That, you know, this sue -- it was concluded that this issue was resolved with tests that were at least at the TLTA and most likely the other test facility the SSTF.
That this issue was resolved for tests conducted with 7 inconel 600 rods[,] not resolved with tests conducted 8 with zircaloy fuel rods or fuel rod simulators.
You know, I think the results of the tests 10 could have been entirely different just with the BWR 11 [FLECHT] tests. How there were problems with the 12 zircaloy bundles. You're going to get different 13 results if you actually use the material that's used 14 reactor cores and not a stand-in that doesn't have 1 [the] oxidation rates that zircaloy does.
1 And 's kind of interesting just to touch on the fact that this BWR core spray distribution 1 problem, it was resolved and there is a cover letter 1 regarding that from Roger Mattson, the final report 2 and that's in [ADAMS] Online, but the attachment to 21 that is actually nonpublicly available. It's a - and 22 again, this is not in particular, you know - I mean 2 it relates 24 COURT REPORTER: Excuse me. This is the 25 court reporter. Could you hold on for a second? I'm NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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23 1 having a technical problem.
2 MR. LEYSE: Sure.
3 COURT REPORTER: Okay. You can go ahead.
4 Sorry about that.
MR. LEYSE: Oh, no problem. Yes, this is a actually, it's in "[ADAMS] Legacy" and this is -
7 I haven't been able to look at it because as I said, 8 it's nonpublicly available and the [accession] number is 8304130488 and it has like an estimated page count 10 of ten. The date is 1983 and it says that it 11 recommends closure of task plan A16, steam affects on 12 BWR core spray distribution and this is nonpublicly available. So, I actually haven't been able to look at that and that might be something to consider just for rulemaking branch. The fact that it seems like this should be publicly available. It's a resolution 17 of this core spray problem, this generic sue and 18 yet, can't look at it.
1 And another thing that's interesting is 20 what I just mentioned. This is for BWR/1, 3, 4, 5 and 21 6 type reactors. It actually is not for BWR/2 22 reactors and the cover letter that's actually in 23 ADAMS online I can give you the ML number for that.
24 That's ML993370214. It's the same -- the cover letter 25 from Roger Mattson.
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24 1 It says that they are going to be 2 reviewing this core spray issue for BWR/2 reactors and that they will provide a separate SER to document the evaluation results for each plant, but that's actually a separate issue. I haven't been able to [locate]
that SER and I'm not sure if that would also be nonpublicly available.
8 Also, that kind of brings up another issue which is kind of related to this in just kind of 1 shifting gears to talk about the metal water reaction 11 and the limits of 50.46b number 1 and 2 in terms of 12 the 2200 limit and the 17 percent oxidation limit.
13 Those are actually -- those come largely 14 from research done by David Hobson and Philip 1 Rittenhouse and there's actually a paper that they 1 wrote. I don't have the title in front of me, but 17 that's actually also nonpublicly available and that's 18 just a side issue that I thought I would mention.
1 [It] just seems odd that the primary 20 research paper that the 2200 limit and also the 1700 21 oxidation limit are based off of that that's 22 nonpublicly available. We're talking about a paper 23 from the early 1970s.
24 So, that's kind of -- actually, I think I 2 -- yes, I do have the title. It's Enbrittlement of 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 1 Zircaloy-Clad Fuel Rods by Steam During LOCA 2 Transients. That's a paper from Rittenhouse and 3 Hobson from 1972. It's located at ML082410413 and 4 it's nonpublicly available.
5 So, anyway, just since there are some people from Rulemaking Branch who are listening to 7 that. If there anyway to make these documents 8 publicly available, I think that would be great and I think it would be appropriate.
10 So, anyway, sorry. That's sort of an 11 aside.
12 MR. MILLER: Well, actually, could I get 13 you to repeat that last ML number just so we can get 14 down here?
1 MR. LEYSE: Oh, sure. I would be happy 1 to. Yes, this is for the Hobson-Rittenhouse paper and 17 the ML number is ML082410413.
18 MR. MILLER: Thank you.
1 MR. LEYSE: Yes, I have actually written 20 to the Public Document Room and that's how I know that 21 these papers are nonpublicly available. So, but yes.
22 And just sort of back to the ition, as 2 I mentioned, what I just was talking about generic issue, steam affects on BWR core spray 2 distribution, I mean 's sort of -- it's related to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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26 1 this problem obviously and I think it is just 2 interesting that, you know, here you had this -- what was brought up in the late '70s I guess, early '80s.
4 This generic safety issue for BWRs and they did 5 conduct the tests for at least the BWR types 6, 5 and 4 and I guess they also did the other ones.
7 As I said, these -- this generic safety 8 issue was resolved with the results of tests conducted with inconel 600 fuel rod simulators and here you 10 have, you know, appendix K. To this day, it's st 11 based off of the tests that were done with stainless 12 steel bundles by General Electric in the early 1970s.
1 That's where the heat transfer coefficients are coming from and I think that that's definitely something that 1 as Dave Lochbaum pointed out there are limitations of 1 the BWR/2 ECCS that they do not have the redundancy as 17 he had mentioned that the more advanced systems have.
18 So, that's something I think that really 1 should be considered for these two plants with this 20 petition and that's -- just mentioning in the -- just 21 kind of regarding the problems with recent tests and 22 inconel 600 fuel rod simulators. On page 93 through 2 page 96 of the petition, I mention a number of different test facil that the primary BWR test 2 facilities for heat transfer tests or thermal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE., N.w.
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27 1 hydraulic experiments and how they're all using these 2 inconel 600 fuel rod simulators and it just seems that
-- well, not seems. It's just this is just not -- if you were going to be basing your interpretations of what's going to occur in the reactor core in the event of a real loss of coolant accident off of these tests 7 conducted with inconel 600, that's a real big problem 8 because that's just not the reality.
The oxidation rates are different. I have 10 some information on that on page 95. Just talking 11 about the different oxidation rates of inconel 600.
12 So, you're going to have different test results.
1 If the bundles would be heated up to temperatures between say 1,000 s Celsius and 1 1200 Celsius. They are going to -- if they 1 were zircaloy, they would with high probabili incur 17 autocatalytic oxidation. You'd have runaway 18 oxidation. Where this very same counterpart bundles 1 inconel 600, you're not going to have that.
20 And I realize the Oyster Creek and Nine 21 Mile Po Unit 1, the heat transfer coefficients that 22 are used are not based on inconel 600, but you have 2 the same problem with them. They're based on stainless steel.
2 It's a situation where [aJ counterpart*
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28 1 bundle that would be zircaloy, you know, counterpart 2 to a stainless steel bundle, you could heat the stainless steel bundles between, you know, 1,000 degrees Cels and 1200 degrees Celsius and you would not have a problem. However, with zircaloy with high probability, you would incur runaway oxidation at 7 those temperatures.
8 So, clearly, there's a big problem with the licensing basis [peak cladding] temperatures of 10 Oyster Creek and Nine Mile Point Unit Number 1 being 11 [set] at 2150 and 2149 Fahrenheit respectively. So, 12 that's obviously, a big problem because these -- it's 1 all based off of, you know -- well, that's based off largely from tests that were conducted with single 1 rod tests that were conducted for the metal' water 1 reaction.
17 In the case of appendix K, they're using 18 the Baker-Just data. So, that would -- you're going 1 to have different oxidation rates with 20 MR. MILLER: Are you 1 there? It 21 sounds like phone might have cutoff. We'll go 22 ahead and him a minute here to to rejoin.
(Whereupon, at 1:44 p.m., a recess was taken until 1:45 p.m.)
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29 1 sorry. I was disconnected somehow.
2 MR. MILLER: Yes, we were just giving you
-- just taking a break here to give you a minute to reconnect.
MR. LEYSE: Okay. Yes, I appreciate that.
MR. MILLER: Okay.
7 MR. LEYSE: I'm not sure what happened.
8 MR. MILLER: Neither are we.
MR. LEYSE: Yes. Anyway, as I was saying, 1 with appendix K, that's based off of Baker-Just which 11 is basically for the metal water reaction. It's 12 coming from single rod tests conducted with zircaloy 13 and there's plenty of information in the petition 14 where I talk about how the metal water reaction is 1 different when you have bundles and then oddly enough, 1 with the heat transfer coefficients and also 17 demonstrating that the system, that the emergency core 18 cooling systems at Oyster Creek and Nine Mile Point 1 Unit Number 1, you know, here you do have [bundle]
20 tests, but instead of using zircaloy to demonstrate 21 that these systems would work and also for the heat 22 transfer code coefficients that are used in the 23 calculations, the ECCS evaluations, those come from, 24 you know, stainless steel bundles.
25 So, it's kind of -- I think you have two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE" NW (202) 234-4433 WASHINGTON, D,C. 20005-3701 www,nealrgross,com
30 1 problems here with these appendix K, the metal water 2 based on a single zircaloy rod not a bundle and then 3 heat transfer coefficients based off of stai s 4 steel bundles and not z bundles.
And I bel there's also information in the ition that just kind of shows that a lot of this way of thinking about this is just kind of based 8 in what people were thinking back in the early '70s.
There are statements from the Atomic Energy 10 Commissioners that the heat that was generated from 11 oxidation that it would all go back into the rod and 12 there really wouldn't be a problem with sta s 1 steel being a stand in for the zircaloy.
And, in fact, I think there's a quote that 1 I have on page 77 from the Atomic Energy 1 Commissioners. They say the Commission sees no basis 17 for concluding that the heat transfer mechanism is 18 different for zircaloy and stainless steel and 1 believes that the heat transfer correlations derived from stainless steel clad heater rods are suitable for 2 use th zircaloy clad fuel rods and so, I mean it's 2 just kind of interesting. There's a lot of -- I try 2 to in those pages in area map out the history and show kind of just how the Commissioners that made 2 these sions.
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31 1 And also the fact that Henry Kendall and 2 Dan Ford of Union of Concerned Scientists, they criticized the fact -- during the rulemaking hearings, they were very cal of the fact that the heat transfer coefficients that they were based off of stainless steel bundles and not from zircaloy bundles 7 and they criticized the fact that in the BWR [FLECHT]
8 tests that they -- out of over 100 tests, that they had only conducted five with the zircaloy bundles and 1 that's obviously in that area where there's a lot of detail where they're also criticizing, you know, just 1 the [FLECHT] tests in general and there are quotes 13 from some of the people that were experts. Aerojet's 14 Robert Griebe and McConnell who I mentioned earlier 1 and what they had to say about these issues.
1 And it just seems to me that this [has]
17 kind of somehow fallen through cracks and these 18 issues really need to be addressed and let me see just 1 to make sure I'm covering things.
2 Yes, I actually -- you know, I realize that I had initially asked for 90 minutes. It was 2 very friendly that more time was offered than one hour, but Mr. Miller had this was a couple of weeks ago. He had said that I could have longer than one 2 hour's time regarding s issue and I thought 90 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, NW.
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1 minutes would be in order.
But, I think I'm pretty much concluded, but there might be things that other people want to say and also I would be [happy] to answer any questions that anyone may have.
CHAIRMAN QUAY: Okay. Thank you, Mr.
Leyse. Is there anyone else that wants to comment?
Okay.
Before I conclude this meeting, members of the public may provide comments regarding the petition 1 and ask questions about the 2.206 Petition process.
However, as stated at the opening, the 1 purpose of this meeting is not to provide an 14 opportunity for the Petitioner or the public to 15 question or examine the Petition Review Board 1 regarding the merits of the petition request.
17 Is there any member of the public that has 18 any comments?
1 MR. WEBSTER: Yes, I'll comment. Richard 20 Webster.
21 CHAIRMAN QUAY: Okay.
22 MR. WEBSTER: I think there are a couple 2 of comments. One is that obviously this is an extremely important safety issue. It's one that I 2 hope the Board will take extremely seriously and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE, NW, (202) 234-4433 WASHINGTON, D,C. 20005-3701 V/WW,nealrgross.com
33 1 [ensure] that it is addre very expeditiously.
2 I think one thing to perhaps consider is whether it's appropriate to -- whether reasonable assurance currently exists on safety when these kind of issues are being sed. I remind the Board that the essence of reasonable assurance is that is up to the applicant, it is up to the reactor operator to demonstrate reasonable assurance. It is not up to the public to demonstrate the lack thereof and I think 1 with the very serious question Mr. Leyse's raised, I 11 questioned whether the operator actually has been able 12 to demonstrate reasonable assurance.
13 That being said, I think there's the 14 second issue or there's two other issues really. One 1 issue is it's kind of amazing to me that this issue 1 could have lurked for so long and not been adequately 17 dealt with by the staff in the past. I think this is 18 something which the NRC really needs to look at more 1 systemically to see why these kind of very fundamental 2 safety issues are coming to the fore decades after the 1 se was issued and especially after the reactor's 2 supposedly gone through a comprehensive safety review 2 process in re-licensing.
And finally, I'd just like to give my 2 thanks to Mr. Leyse for spending so much and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE" NW, (202) 234-4433 WASHINGTON, D.C, 20005-3701 www,nealrgross.com
34 1 energy working on this when he actually isn't 2 receiving any compensation whatsoever and there no 3 funding at all or funding for these kind of things and 4 I think what this really shows is that there should be.
The publ play a very useful role in 7 finding and highlighting safety issues and I think 8 where they do find and highlight a safety issue, I think there should be some ability for the public to 1 recover the time spent in doing what is difficult and 11 technical work.
12 Thank you.
1 MR. LEYSE: Mark Leyse. I really appreciate your comments, Mr. Webster and especially 1 what you said at the last point regarding spending a 1 lot of time.
17 And some of your other comments just -- I 18 mean I do find that -- I don't know how to [phrase]
1 this, but as I pointed out, I think some of these 20 issues were raised, you know, 40 years ago during the 21 -- almost 40 years ago during the rulemaking hearings 22 and I like I said, why should the heat transfer 2 coefficients that are used in the ECCS evaluation culations be based on tests that were done with 2 stainless steel bundles as opposed to zircaloy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE" NW, (202) 2344433 WASHINGTON, D.C 20005-3701 www.nealrgross.com
35 1 bundles. It just doesn't make sense.
And then you had the BWR [FLECHT] test.
3 The ZR2 test which actually seemed to incur runaway 4 oxidation. Just looking at the graphs on that, seemed to take off. You know, incur runaway oxidation around 2100 degrees Fahrenheit. Maybe between 21 and 7 22. Maybe it was even above. You know, it's hard to 8 see from the graph.
But, I mean why after such -- and this 1 test was such an issue of contention. Henry Kendall and Dan Ford spent a great deal of their time focusing 1 on this test.
1 The people from Aerojet, they said -
14 Roger Griebe said that most like -- he said that 15 runaway oxidation [maybe] it did occur in this test.
1 He wasn't sure. He seemed to think that -- he said 17 that General Electric's interpretation of the results, 18 I quote him, "Were tremendously slanted" and yet after 1 that, why not just say okay, maybe General -- you 2 know, even if you think there's something wrong with 21 that conclusion, why not conduct more tests? Why not 22 figure out[,] is this, in fact, a real problem? Would 2 you have runaway oxidation in this situation or not?
And then if you look at the history, you 2 can just read this in "The [Cult] of the Atom" by Dan NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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36 1 Ford. The people at Aerojet like Roger Griebe, he was 2 basically -- he lost his job in reactor safety. He was basically because of his testimony, what he said during the rulemaking hearings, he was told to go look for another job from Aerojet or basically, transferred. I don't know the details, but they were 7 -- basically him and I think George Brocket, he was 8 also at Aerojet, they were basically not allowed to keep the jobs that they had had.
10 And you had a similar situation with 11 lip Rittenhouse at Oak Ridge National Labs and, you 12 know, I can go on and on. Even Alvin Weinberg lost 13 his position as the rector of Oak Ridge.
14 I think that's something important to look 1 at. Only if it's primarily just the fact that more 1 tests were not conducted and the people who had 17 ti zed the tests were basically told to take a 18 walk and, you know, it's just something that I think 1 is pretty important.
20 Are you still there? Am I still 21 connected?
22 CHAIRMAN QUAY: You are still connected.
23 MR. LEYSE: Okay. I'm sorry. I heard 24 things that it sounded like I may have been 25 disconnected a second time. So.
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37 1 CHAIRMAN QUAY: I don't know if somebody 2 joined us, Mr. or somebody dropped off.
MR. LEYSE: Okay. Sure. But, I just wanted to say that I really appreciate Richard Webster's comments and also, just, I guess, personally what he said about fiscal compensation.
7 I do feel kind of that -- you know, I 8 don't know what to say. It's like I think that I shouldn't have to really be spending as much time on 10 this. You know, telling the NRC to conduct more 11 tests. I think 's pretty obvious that more tests 12 should be conducted and I think it's pretty obvious 13 that with Oyster Creek and Nine Mile Point Un Number 14 1 that there should be a demonstration that 1 you know, it's plant specific for two plants. That 1 their ECCS systems would indeed work in the event of 17 a loss of coolant accident if the zircaloy peak you 18 know, the cladding rature would indeed 1 approach temperatures that they say are the licensing 20 peak cladding temperature for both of those plants.
21 And I also just want to state again that 22 I really appreciate Dave Lochbaum's input on this 23 from, you know I the [Union of] Concerned Scientists 24 and again, I would be if anyone else wants to 2 comment or if you have any ques s for me, I would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISlAND AVE., NW.
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38 1 be happy to answer them.
2 CHAIRMAN QUAY: At this time, does the here in headquarters have any questions for Mr.
Leyse?
MR. DUDLEY: Yes. Yes, Mr. Leyse, this is Richard Dudley.
7 Because we have such a large amount of 8 information in-house that you've submitted to us on various petitions for rulemaking and comments 10 on other rulemakings, well over a thousand pages, 11 would you please identi in your 2.206 petition the 12 pages that you believe contain new technical 1 information or new issues or additional information regarding issues that you've already sed with us 1 and fy those pages in this petition so that we 1 are sure that we do not overlook or miss some new 17 information as we review the information you've 18 submitted?
1 MR. LEYSE: Sure. I think that in this case because of PRM [50-95] which was the Vermont 2 Yankee 2.206, you reopened the public comment period 22 and I think there is actually - I'm quite sure that I 23 have not really added any new information in this 24 particular 2.206 regarding Oyster Creek and Nine Mile 2 Point Unit Number 1. Because a lot of the issues like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW, (202) 2344433 WASHINGTON, D,C. 20005-3701 www,nealrgross.com
39 1 discussing zircaloy and stainless steel and inconel 2 600 for example, I submitted that information in the 3 recent comments that I made in that comment period.
4 So, I can't really -- I do not think that there would be anything in this particular case just because the second comment period was opened.
7 However, one thing is that as I said there 8 are some -- just with this petition, particular, like I said, you know, this is plant specific for two 1 plants since they are the only two plants with the 11 BWR!2 ECCS emergency core cooling systems and I have 12 perhaps focused on that a little more than I did in 13 the comments that I made. But, I don't think there's 14 anything necessarily too different.
1 And actually, I did make a third comment 1 and I'm sorry. This is sort of a side issue. NEI 1 made a comment in the recent comment period and I submitted a response to NEI that has not been placed 1 in the docket folder yet.
20 But, there is some information actually in 21 my response to NEI that is pertinent to this petition 22 and actually, you kind of reminded me of it. NEI 23 points out something that I real didn't clarify when 24 I talk about the control rods or BWR cruciform control 2 elements. Say when the cladding would be around 2150, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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40 1 the peak cladding temperature, the control elements 2 would actually be roughly say 400 degrees or almost 400 degrees Fahrenheit cooler than the fuel rods and this was demonstrated in some of the experiments that were conducted at the [CORA] test facility.
And actually, in those comments, my third group of comments, I think 're dated December 27th, 2010, I actually have two graphs in there, you know, that I placed for the CORA-16 experiments and 1 they show that the control rods would basically be 11 about 400 degrees Fahrenheit lower than the fuel rod 12 cladding and that's something I really didn't clarify 13 in this Oyster Creek Petition.
14 But, what I responded to NEI is that 1 basically if you're going to incur runaway oxidation 1 between 1832 degrees Fahrenheit and 2200 degrees 17 Fahrenheit which you could[,] with a high probability 18 according to this data, what's going to happen is 1 suddenly the fuel rod temperatures, the maximum fuel 2 rod temperatures, are going to start increasing at a rate of tens of degrees Fahrenheit per second and so, 2 within say 30 seconds, you're going to probably be up 2 I mean this you're going to have it's 24 different case by case, but so, you incur runaway 25 oxidation at say around 2,000 degrees Fahrenheit.
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41 1 Thirty seconds later, you could be up around 2500 or 2 say 2600 degrees Fahrenheit.
Let's say you're up around 2600 degrees 4 Fahrenhe The, you know, data has shown that this 5 could be the case. In such case, then your control rods or control elements they're going to up around 7 2200 degrees Fahrenheit or around 1200 degrees 8 centigrade and according to [the CORA] data, that's when you start to have eutectic liquefaction when the 10 -- you can have the I think the boron [carbide] in 11 the stainless steel start having eutectic reactions 12 and there can be problems with that.
1 So, that's -- even though at say 2150, you're going to be -- the control rod element or 1 control elements are going to be lower, if you do, in 1 fact, incur runaway oxidation at say around 2150 or, 17 you know, within about 30 seconds, the BWR control 18 elements will be up at a temperature where you're 1 going to have these eutectic reactions.
20 I'm sorry. That's rather a long answer to 21 your question, Mr. Dudley, but 22 CHAIRMAN QUAY: There apparently are no 2 other questions here at headquarters.
MR. KLUKAN: I actually have a couple.
2 CHAIRMAN QUAY: Okay.
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42 1 MR. KLUKAN: I'm sorry. This is Brett 2 Klukan, the OGe Representative.
3 Mr. Leyse, I just wanted to clarify. Have 4 you filed a FOIA request for those nonpublic 5 documents?
MR. LEYSE: Have I done what? I'm sorry.
MR. KLUKAN: Filed a Freedom of Information MR. LEYSE: No, I'm sorry. I have not.
1 MR. KLUKAN: Okay. That's generally the 11 process by which the public can either seek the 12 redaction of otherwise nonpublic information or 1 challenge the agency's designation as such.
MR. LEYSE: Okay.
1 MR. KLUKAN: And then my -- just to 1 understand what it is that you're asking in layman's 17 terms, so, while you're saying th is plant specific 18 and thus, different from what you've previously 1 submitted, the information is different. Is not 2 neces ly contained in this - is based on prior 21 comments to other itions' rulemaking. That's where 22 this new information has come in or that's where this 23 new source of information regarding your plant 24 specific allegation is located or first located.
2 MR. LEYSE: Let me see. I'm sorry. Are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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43 1 you responding -- when you say comments on rulemaking, 2 are you responding some to what I just answered?
3 MR. KLUKAN: I'm just trying to 4 understand. There was a question posed about you responded that there's nothing new in this petition.
MR. LEYSE: Right. Okay. I see. I got 7 it. Yes, let me explain that.
8 There would have been a great deal of new material in this petition, but it just so happened 10 that the 2.206 that I filed regarding Vermont Yankee, 11 s was something I could not have anticipated. That 12 the NRC, and, you know, I think it's laudable that 13 they did this, they decided to change the status of 14 that 2.206 into a rulemaking petition and that became 1 PRM [50-95 J . So, what NRC did was the Rulemaking 1 Branch reopened the comment od on both PRM [50-93J 17 and PRM, you know, [50-95J and so, you know, I 18 basically -- so, a lot of the "new information" that I 1 put into this Oyster Creek and Nine Mile Point Unit 20 Number 1 Petition, I actually ended up putting into 21 the rulemaking comments that I made during this 22 comment period.
2 So, Mr. Dudley had asked, you know, what additional information this petition may have and so, 2 I told them probably not much if any because they had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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44 1 reopened the comment period.
2 If they had not reopened the comment 3 period, there would be a lot of new information in 4 this petition.
But, just to continue with it, to answer your question, that still does not take away the fact that in this petition, I'm obvious talking about generic safety issues. The metal water reaction that I'm discussing, that would apply to all light-water 10 reactors that are licensed by the NRC. You're going 11 to have that same problem in all BWRs, PWRs.
12 And some of the problems that I'm 13 discussing with these tests, the heat transfer tests 1 or thermal hydraulic tests being conducted with stainless steel bundles and also inconel 600 bundles, 1 most of them now it's all inconel 600, that's a 17 generic issue that would apply to all BWRs.
18 However, the issue that is specific to 1 both Nine Mile Point Unit Number 1 and Oyster Creek is 20 the fact that they are the only two reactors licensed 21 by NRC that have the BWR/2 ECCS and as Dave Lochbaum 22 pointed out, that system does not have the redundancy 2 built in. You know, I'm not trying to summarize what 24 he said, but one thing, they're just not the same 25 system as the other systems, have the redundancy and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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45 1 other features. They don't have them.
2 So, I think that makes this, you know, 3 specific to that issue. So, in that sense, this is 4 like plant specific for those two plants.
MR. KLUKAN: Thank you for that, Mr.
Leyse. Just for my own clarification, what exactly, and again in layman's terms if possible, are you -
what actions are you asking the NRC to take in this petition? Specific to this pet ion, what actions 1 would you like the NRC to do? What do you want us to 11 do? Just in summary if you can.
12 MR. LEYSE: Now, you're really putting me 13 on the spot. I'm just kidding.
14 Like I - you know, it's just what does -
1 you know, it's like what is the rule of 2.206? What 1 can this pet ion do? You know, it could modify, 17 suspend or revoke the license or any action as may 18 seem proper.
1 You're the regulator. I'm not. So, I 2 would hope that you would know what to do in this 21 case, but I will try to answer your question.
22 One is that the power level of Oyster 23 Creek and also Nine Mile Point Unit Number 1, the 24 power level should be decreased so that - I mean ,s 2 fficult to say. Because here I'm criticizing the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE" NW, (202) 234-4433 WASHINGTON, D,C, 20005-3701 www,nealrgross,com
46 ECCS evaluation calculations. So, I think these calculations are so flawed that, one, you could maybe look at the results of the CORA-16 experiment just in the iminary to get your metal water reaction.
I discussed the CORA-16 experiment results in this -- let me see. I think that's around page 12.
Yes, it's -- yes, page 12. In that experiment, it said that the predicted and observed cladding thermal response that they were in excellent agreement until 1 application of the available zircaloy oxidation 11 kinetics models causes the low temperature, that's 900 12 degrees to 1200 Celsius, so that's 1652 to 2192 13 Fahrenheit, oxidation to be under predicted. So, 14 basically, they're talking about available kinetics 1 models and so, they're talking about Baker-Just, 1 Cathcart Powell.
1 So, I mean you could maybe look at the CORA-16 experiment just quick, your metal 1 water reaction from that and then maybe you could go 2 back and look at the results of the ZR, the BWR flect 21 ZR2 experiments and maybe just corne to the conclusion 22 that those results were perhaps not anomalous.
2 So, you know, General Electric basically said that the thermocouple readings were not valid.
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47 1 Dan Ford of Union of Concerned Scientists argued that 2 there was they actually said that it wasn't necessarily runaway -- that oxidation it almost incurred. That's how they phrased it at that time.
I would say it did incur runaway oxidation.
But, maybe to look at the results of the 7 BWR [FLECHT] ZR2 [test] and just to take them 8 seriously. Think well maybe these thermocouple readings were, in fact, real and so, based -- you 10 know, based off of that, just do maybe the best you 11 could to lower the power levels of both of those 12 plants so that your licens basis peak cladding temperature would be below, you know, 1832 degrees Fahrenheit or below 1000 degrees Celsius. I'm not sure how far below it would need to be.
So, that would be the first phase. So, I 17 said drop the power level and just we have some crude, 18 you know, metal water reaction from CORA-16. Maybe 1 look at the BWR [FLECHT] ZR2 test. Take it seriously 20 the thermocouple readings. Don't just say they're 21 erroneous and then immediately implement a situation 22 where you conduct BWR thermal hydraulic tests with 2 zircaloy bundles and you would conduct these tests with the zircaloy bundles to see -- you would have to 2 use temperatures say, you know, start at around -
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48 1 temperatures below 1832 degrees Fahrenheit. You know, 2 so that the peak cladding temperature would be between 1832 and 1200. Maybe try some other variations and vary the core spray rates and just investigate all kinds of parameters that would be within the possible, you know, reali c parameters that could occur in 7 the event of a loss of coolant accident.
8 That's kind of my answer. To first try to, you know, lower that 1 sing basis peak cladding 10 temperature and then follow that up by conducting 11 thermal hydraulic tests that would be particular to 12 the BWR/2 ECCS and, you know, use zircaloy fuel rods 1 for that, bundles, not inconel 600 bundles.
MR. KLUKAN: Thank you, Mr. Leyse. My 1 next question is based on your answer to the previous 1 question. If we were to engage those actions, 17 particularly your first point regarding [lowering the]
18 licensing temperature or the temperature, would that 1 necessarily result in your opinion into a changed NRC 20 regulation or would it have to result into a changed 21 NRC regulation?
22 MR. LEYSE: I see. Well, okay. I'm not 2 a lawyer as you know. So, I don't know the complete, you know, legal, you know, all the legal guidelines 2 for that. So, I would think that would certainly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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49 1 make sense to change the regulation, but here as I 2 said, it's a plant specific situation. I think that licensing basis peak cladding temperatures at all plants should definitely be below that. So, it would make sense to make that into a generic, you know, issue. You know, a regulation most certainly.
7 But, at the same time, you know, I still 8 nk a good place to start is, you know, maybe at Oyster Creek and Nine Mile Point Unit Number 1 and 10 just -- but, I think in general what you're saying is 11 true. That it would result in a change of regulation, 12 but I'm -- you know.
1 MR. KLUKAN: One final question, Mr.
Leyse, and , thank you for your response to these 1 thus far.
1 MR. LEYSE: Sure.
MR. KLUKAN: And again, this is Brett 1 Klukan. My final question is are you alleging in this 1 petition that either two plants you've particularly 20 identified the BWR/2s or any other s are 21 currently in violation of NRC requirement or of their 2 licenses?
23 MR. LEYSE: Yes, I would assert that these 24 two plants are in violation of 50.46b, the parameters.
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50 1 know, as things stand, obviously, the licensing basis 2 peak cladding temperature for these plants is roughly
-- well, you know, it's 2150 and then 2149 in the other. Let's just for convenience call them both 2150.
So, I mean that is obviously 50 7 Fahrenheit below the 2200 limit. So, I mean on paper, 8 obviously, it's not in violation. But -- and then I don't know what the oxidation layer would be in this 1 case. You know, I take it for granted that it's also 11 going to be below the 17 percent [limit) and 12 obviously, calculations are going to demonstrate that there's going to be core cooling and so, you're not going to incur a meltdown.
So, it's like on paper these are obviously not in violation of 50.46b. Just like the Vermont 17 Yankee 2.206, you know, I can't recall. I think that 18 that licensing basis peak cladding temperature was 1 1960 degrees Fahrenheit. So, on paper, obviously not.
20 But, I'm just saying the real of the 21 fact is that here you have these licensing basis peak 22 cladding temperatures and I'm not going to repeat, but 2 all through petition and what I've been discussing, they're based off of these calculations 2 that come from the single rods and then the stainless NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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51 1 steel bundle inputs from those experiments and so, I'm 2 arguing that 's just what's going to, in fact, happen in the event of a loss of coolant accident at Oyster Creek or Nine Mile Point Unit Number 1 if the fuel rods are going to reach a temperature say as low 6 as 1832 degrees Fahrenheit. With high probabil 7 they're going to incur, you know, runaway oxidation.
So, and just to , that's going to 9 then mean that temperature, the maximum in a local 10 area, the maximum fuel rod temperature is going to 11 start increasing by tens of degrees Fahrenheit per 12 second. So, within seconds, you know, within say, you 13 know, less than a minute's , you're going to be 14 above 2200 degrees Fahrenheit. So, in that sense, I 1 think that these plants are operating in violation of 1 50.46b.
1 So, yes, most certain they're and 1 they're not -- and you're going to not have you 1 know, you're not going -- you haven't demonstrated 20 that this core is going to be cooled and the fuel rods 21 will be quenched.
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52 1 stainless steel bundles, single rods, that, you know, 2 this -- but, the real, you know, real LOCA, you're going to have -- you are going to be over 2200 degrees Fahrenheit and then within, you know, less than two minutes time, you know, 's going to be different in different cases, you're going to have you're going 7 to get up to the point in a local area where the 8 zircaloy is going to -- it's going to be up around 3300 degrees Fahrenheit and it will start to melt in 1 the local area.
11 But, even at far lower temperatures as is 12 pointed out, the control elements are -- they're going 1 to be following. You know, they're going to be 14 increasing in temperature. Also albeit say around, 15 you know, based on looking at this CORA results maybe 1 400 degrees Fahrenheit [, approximately,] lower than 17 the fuel rods. They're going to start incurring 18 liquefaction at say around 2250 Fahrenheit or so or 1 maybe 2300. So, anyway, so, definitely in violation 20 of 50.46b.
21 MR. KLUKAN: So, just to clarify for my 22 own understanding, you're asserting that while they 2 would not currently be in violation of 50.46, if the 24 regulation were amended for the reasons that you've 25 iterated here today and for those documented in your NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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53 1 petition, then they would be in violation assuming 2 that we were to change the regulation for the reasons 3 that you've suggested. To limit the temperature.
4 MR. LEYSE: No, that's not really what I said. What I said is that, you know, clearly on paper right now, you know, the licensing basis peak cladding temperature for Oyster Creek, for example, that's 2150 degrees Fahrenheit. So, on paper, you know, that's 50 degrees Fahrenheit below, you know, 2200. So, that's 10 not in violation of 50.46b(1). You know, the 2200 11 limit. You know, that's just -- you know, that's on 12 paper. It's kind of like but what's the reality.
13 I'm stating that at the power level that 14 it's set now, the ty is that if you have a loss 1 of coolant accident and, you know, based on test 1 results, if the cladding were to, in fact, reach say 17 approximately 1832 or greater, you would - the 18 reality is that you would incur -- you know, with high 1 probability incur runaway oxidation. So, within a 20 matter of seconds, that's going to shoot above 2200 21 degrees Fahrenheit and that's going to boom, be a 22 violation of 50.46b(1), your 2200 limit.
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54 1 of 50.46b. Because if you had this loss of coolant 2 accident and the cladding reached, you know, temperatures approaching, you know, their licensing 4 basis peak cladding temperatures, they're going to 5 incur runaway oxidation and they're going to incur at least partial meltdowns or you know.
So, I'm saying that they are definitely in violation of this regulation, but I'm saying in terms of maybe legally speaking, bureaucratically speaking, 1 you know, at the moment, you know, on r, it says 11 that their -- that, you know, their maximum cladding 12 temperature, you know, going to be 2150. So, you 1 know, that's clearly -- you know, but I'm just saying that that's -- there's no foundation for that and 1 that's, you know, why the petition's over 90 pages 1 long. I try to document, you know, what's wrong with 17 that con in this 2150 degree Fahrenheit peak 18 cladding temperature and licensing basis peak cladding 1 temperature to say that everything is fine.
20 Has that clarified your question?
21 MR. KLUKAN: It has. Thank you.
22 MR. LEYSE: Okay. Sure.
2 CHAIRMAN QUAY: Okay. At this point, I'm going to ask are there any additional NRC questions 2 including the region?
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55 1 MR. KULP: Nothing from the region.
2 CHAIRMAN QUAY: Thank you. Hearing none, Mr. Leyse, I want to thank you for taking the time to provide the NRC staff with clarifying information on the petition you submitted.
Before we close, does the court reporter 7 need any additional information for the meeting 8 transcript?
Okay. Hearing none, this meeting is 1 concluded and we will terminate the phone connection.
11 MR. LEYSE: Yes. May I just add one 12 thing? Mark Leyse speaking.
13 CHAIRMAN QUAY: Yes.
14 MR. LEYSE: Yes. [I just] wanted to thank 1 the on Review Board for their time listening to 1 this and thank Ed Miller for the accommodations and also thank Mr. Webster and Mr. Lochbaum. So.
1 CHAIRMAN QUAY: Okay. With that, we're 1 going to conclude the phone connection. Thank you.
20 MR. LEYSE: Thank you.
21 (Whereupon, at 2:32 p.m., the conference 22 call was adjourned.)
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition RE Oyster Creek Docket Number: 50-[219] and 50-220 Location: (teleconference)
Date: Thursday, February 17, 2011
- Transcript corrections marked in [square brackets]
Work Order No.: NRC-715 Pages 1-31 NEAL R. GROSS AND CO., INC. Enclosure 2 Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
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1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 PETITION REVIEW BOARD DISCUSSION WITH PETITIONER
x IN THE MATTER OF:
10 CFR 2.206 PETITION Docket Nos.
OF MARK LEYSE 50 209 WITH RESPECT TO 50-220 1 OYSTER CREEK AND 11 NINE MILE POINT 12 ------x 13 Thursday, February 17, 2011 14 15 The above-entitled matter was convened via 1 econference, pursuant to notice, at 2:00 p.m.
Eastern Standard Time.
1 1 BEFORE:
2 THEODORE QUAY, Petition Review Board Chairman 21 sion Policy and Rulemaking 22 Office of Nuclear Reactor Regulation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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2 1
2 ALSO PRESENT:
ED MILLER, Project Manager for Oyster Creek Nuclear Generating Station.
MERRILEE BANIC, NRR Generic Communications Branch 7 RICHARD DUDLEY, NRR Rulemaking Branch 8 BRETT KLUKAN, ESQUIRE, Office of the General Counsel, Attorney/Advisor to Petition Review Board 1 TANYA MENSAH, NRR Generic Communications Branch 11 STACEY ROSENBERG, Branch Chief, NRR Generic 12 Communications Branch, Division of Policy and 13 Rulemaking 14 CARLEEN SANDERS, Reactor Licensing, NRR 1 RAYMOND SHADIS, New England Coalition 1 RICHARD WEBSTER, Publ Justice 17 JEFF WHITED, Reactor Licensing, NRR 18 SHIH-LIANG WU, Nuclear Performance and Code 1 Review Branch, NRR 2
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3 1
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4 1 P-R-O-C-E-E-D-I-N-G-S 2 (2:05 p.m.)
MR. MILLER: I'd Ii to thank everybody 4 here for attending this meeting. My name is Ed 5 Miller. I'm the Oyster Creek Nuclear Generating Station Project Manager.
7 We're here today to allow the Petitioner 8 Mark Leyse to address the Petition Review Board regarding the 2.206 Petition dated December 10, 2010.
1 The tion Manager for the Petition and the Petition 11 Review Board Chairman is Mr. Ted Quay.
12 The part of the PRB's review of this 1 petition has requested another opportunity to address PRB. Our meeting today is scheduled to go from 1 2:00 to 3:30 Eastern Time.
1 The meeting is being recorded by the NRC Operations Center and will be transcribed by a court 1 reporter. The transcript 1 become a supplement to 1 the Petition and will be made publicly available.
2 I would like to start the meeting out with 21 introductions. If we could go around the room first, 22 please be sure to state your name and position 2 in office within the NRC in which you work.
As I said, my name's Ed Miller. I'm in 2 Reactor Licensing.
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5 1 MR. WU: Shih-Lian Wu, Nuclear Performance 2 and Code Review Branch, NRR.
MR. KLUKAN: Brett Klukan. I'm from the Office of General Counsel and I'm the attorney/advisor to the Petition Review Board.
MS . SANDERS: Carleen Sanders, and I'm also part of Reactor Licensing Group.
MR. WHITED: Jeff Whited, Reactor Licensing.
1 CHAIRMAN QUAY: Ted Quay, Deputy Director, 11 Division of Policy and Rulemaking, NRR, and also the 12 Petition Review Board Chairman.
13 MR. DUDLEY: Richard Dudley. I'm from the 14 NRR Rulemaking Branch.
MS. BANIC: Merrilee Banic, NRR Generic Communications Branch.
MS. MENSAH: Tanya Mensah, NRR Generic Communications Branch. I'm the 2.206 Coordinator.
MS. ROSENBERG: Stacey Rosenberg. I'm the 20 Branch Chief of the Generic Communications Branch in 21 Division of Pol and Rulemaking, NRR.
22 MR. MILLER: Okay. Do we have anybody 2 from the Region on the phone that would like to identify themselves?
2 (No response.)
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6 1 MR. MILLER: Okay. Mr. Leyse, just for 2 the record, would you please introduce yourself.
MR. LEYSE: Sure. Mark Leyse.
MR. MILLER: Okay. Do we have any other members of the public that would like to identify themselves?
7 MR. SHADIS: This is Raymond Shadis with 8 New England Coalition.
MR. MILLER: Okay. Thank you.
10 Anyone else?
11 (No response.)
12 MR. MILLER: Okay. Before we get further, 1 I would like to emphasize that we each need to speak clearly and loudly to make sure that the court 1 reporter can accurately transcribe this meeting, and 1 if you do have something to say, please, for the 17 record, state your name first.
18 For anybody dialing in, please remember to 1 mute your phone to minimize background noise and 20 distractions. If you don't have a mute button on your 21 phone you can also press "star 6" and the system will 22 mute that line. Press "star 6" as well to unmute.
2 At this time I will turn it over to the 24 PRB Chairman, Mr. Quay.
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7 1 to this meeting regarding the 2.206 Pet ion submitted by Mr. Leyse.
I'd like to first share some background on our process. Section 2.206 of Title 10 of the Code of Federal Regulations describes the petition process, the primary mechanism for the public to request 7 enforcement action by the NRC in a public process 8 This process is open to anyone to petition NRC that take enforcement-type action related to 1 NRC licensees or licensed activi ties. Depending on 11 the results of this evaluation, NRC could modify, 12 suspend or revoke an NRC-issued license or take any 1 other appropriate enforcement on to resolve a problem.
1 The NRC staff guidance for the dispos ion 1 of 2.206 petition requests is in Management Directive 17 8.11, which is publicly-available.
18 The purpose of today's meeting is to give the Petitioner an opportunity to provide any additional explanation or support for their Petition before the Petition Review Board's initial consideration and recommendations.
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8 1 presented in the Petition Request.
2 No decisions regarding the merits of this Petition will be made at this meeting. Following s meeting, the Petition Review Board will conduct internal deliberation. The outcome of this internal meeting will be discussed with the Petitioner.
7 The Petition Review Board typically 8 consisted of a chairman, usually a manager at the senior executive service level at the NRC. It has a 1 Petition Manager and a Petition Review Board 11 Coordinator.
12 Other members of the Board are determined by the NRC staff based on the content of the information in the Petition Request.
At this time I would like to introduce the Board. I am Ted Quay, the Petition Review Board 17 Chairman. Ed Miller is the Pet ion Manager for the 18 ion under discussion today. Tanya Mensah is the 1 Of Petition Review Board Coordinator.
2 Our techni staff includes Shih-Liang Wu 21 from the Office of Nuclear Reactor Regulations, 22 Nuclear Performance and Code Review Branch. We also 2 obtain our advice from our Office of General Counsel, 24 represented by Bret Klukan.
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9 1 staff may ask clarifying questions in order to better 2 understand the Petitioner's presentation and to reach a reasoned decision whether to accept or reject the Petitioner's Request for Review under the 2.206 process.
I would like to summarize the scope of the Petition under consideration and the NRC activities to date.
On December 10th, 2010, Mr. Leyse 10 submitted to the NRC a Pet ion under 2.206 regarding 11 the licensing basis cladding temperatures of 12 Oyster Creek Nuclear Generating Station and Nine Mile 13 Point, Unit One, and the censee's lity to quench 14 the fuel cladding using their emergency core cooling 1 systems the event of a large cooling accident.
1 In this Request, Mr.
17 identified the following areas of concern: One, 18 experimental data indicates that Oyster Creek and Nine 1 Mile One's licensing basis peak cladding 20 temperatures of 2150 degrees Fahrenheit, and 2149 21 degrees Fahrenheit, respectively, do not provide 22 necessary margins of safety against partial or 2 complete melt-down' s in the event of loss of cooling accidents.
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10 1 Nuclear Generating Station and Nine Mile Point Unit 2 One's licensing basis peak cladding temperatures much 3 be decreased to temperatures lower than 1832 degrees 4 Fahrenhei t in order to provide necessary margins of safety.
Two, experimental data indicates that 7 Oyster Greek Nuclear Generation Station and Nine Mile 8 Point Un One's emergency core cooling systems would not effectively quench the fuel cladding in the event 10 of a LOCA if the fuel cladding reached Oyster Creek's 11 and Nine Mile One's -- Unit One's licensing basis of 12 21 degrees Fahrenheit -- 2150 degrees Fahrenheit, and 1 2149 degrees Fahrenheit respectively.
Did someone just join us?
1 MR. WEBSTER: Yes. This is Richard 1 Webster from Public Justice.
CHAIRMAN QUAY: Okay. Thank you.
1 Based upon the stated concerns, Mr. Leyse 1 requests that the NRC order the licensees of Oyster 2 Creek and Nine Mile Point Unit One to lower the 21 licensing basis peak cladding temperature of Oyster 22 Creek and Nine Mile Point Unit One in order to provide 2 necessary margins for to help prevent partial 24 or complete melt-downs in the event of LOCAs. Order 25 the licensees of Oyster Creek and Nine Mi Point Unit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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11 lOne to demonstrate that Oyster Creek and Nine Mile 2 Point Unit One BWR/2 emergency core cooling systems would effectively quench the fuel cladding in the event of LOCAs and prevent partial or complete melt downs.
The activities to date regarding this 7 Pet ion have included: On December 10th, 2010, the 8 Petition was received by the NRC; On December 17th, 2010, the Petitioner 1 requested to address the Petition Review Board prior 11 to its initial meeting to further clarify the provided 12 information for the Board's consideration; 13 On January 13th, 2011, the Petitioner 14 addressed the Petition Review Board to provide 1 additional clarifying information regarding the 1 Pet ion; 17 On January 31st, 2011, the Petitioner was 18 informed via email of the Petition Review Board's 1 initial recommendation to not accept the Petition for 20 review. On the same day that Petitioner requested 21 another opportunity to address the Petition Review 2 Board.
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12 1 cons idered in Petitions for Rulemaking 50-93 and 2 50-95.
3 For the second area of concern, the 4 ini tial recommendation was that the Petition did not meet the criteria for review because Pe tioner had no provided sufficient facts to warrant further 7 inquiry.
8 Specif ly, in the Petition and during the January 13th, 2011 teleconference, the Petitioner asserted that [BWR/2] , emergency core cooling systems 1 are different from other emergency core ing systems and potentially inadequate.
1 However, the Petitioner did not provide suffic information to the Petition Review Board to 1 warrant further inquiry.
1 On February 17th, 2011, today, we are 1 providing the requested opportunity to address the 1 Pet ion Review Board again.
1 As a reminder for the phone participants, 2 please identify yourself if you make any remarks, as 21 this will help in the preparation of the meeting 22 transcript that will be made publ ly-available.
23 Mr. Webster, if you would just introduce 24 yourself for the record and for the transcriber, and 2 then I will turn the phone call over to Mr. Leyse.
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13 1 MR. WEBSTER: Right. Thank you very much.
2 Yes. I r m Richard Webster. I'm the attorney who's 3 represented a number of groups in relicens 4 proceedings, and Mr. Leyse asked me to call to the cause and just make a couple of points, a couple of legal points which I would like to do fairly quickly, 7 if I may.
8 MR. LEYSE: Yes. I wanted to let Richard speak before I speak. This is Mark Leyse speaking.
1 So, I would like to turn it over to Mr. Webster.
CHAIRMAN QUAY: That I s fine. Go ahead, 1 Mr. Webster, and proceed.
13 MR. WEBSTER: Thank you very much. This 14 is Richard Webster, of Public Justice.
15 There's two issues I'd [like] to address.
1 One is about some - the interaction of relicensing 17 and 2.206 Petitions. I think it's very clear, and the 18 Seabrook decision yesterday confirms this, that 1 icensing covers [aging] management along with the 2 components during the period of extended operation.
21 And so, in a relicensing proceeding you 22 absolutely cannot make any allegations about the 23 current licensing basis, the adequacy of the current 24 licensing basis or about the [aging] management 2 programs in ace during the current period of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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14 1 operation.
2 And I do recall reading some logic somewhere in the Board's decision saying that because Mr. Leyse, because his issue might be raised in relicensing that might be a problem, however, that's certainly not the case.
7 In terms of generic issues, I think it's 8 probably reasonable for petitioners to seek both generic resolution and site-specific resolution. I 10 don't think -- I think it's actually unreasonable for 11 the Board to make a decision that says that because 12 Mr. Leyse is seeking both types of resolution, we 1 should therefore, not deal with -- with one or the other.
1 The reality is that Mr. Leyse has chosen 1 to pursue all angles, and I think he's to be commended 17 for that. Until - I remind the Board that the Atomic 18 Energy Act requires adequate assurance of safety at 1 all times.
20 It is not Mr. Leyse's burden to show lack 21 of sa It is the Applicant's burden to show on an 22 ongoing basis that there is safety.
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15 1 to make a determination on the merits as to whether 2 Mr. Leyse has raised an issue which causes reasonable assurance to be brought into question.
And therefore, I strongly urge this Board to resolve this Petition on the merits and address the issue of whether the facts that Mr. Leyse's put 7 forward, which are many, and which are extremely 8 detailed, e an issue which should be dealt with on the merits.
10 And if it does raise such an issue, then I 11 don't think the Board can punt by saying he's also 12 raised as a generic issue.
If this Board reaches a site-specific resolution in this particular proceeding, and then later the Commission reaches a slightly different decision, the generic proceeding, that's perfectly 17 fine.
18 There's absolutely no need to be afraid of 1 inconsistency in s subject. I'll any 20 questions from the Board right now.
21 MR. [MILLER]: Do you have any questions?
CHAIRMAN QUAY: Does anybody have any questions at this point?
(No response.)
MR. [LEYSE]: Hello.
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16 1 MR. MILLER: I'm sorry. I'm sorry. No, I 2 don't think there's any questions around the room 3 here.
4 MR. WEBSTER: Okay. Very well, if I may, I may take my leave, and thank you very much for the time.
7 MR. MILLER: Thank you, Mr. Webster.
8 MR. LEYSE: Yes. Thank you, Mr. Webster, for calling in.
10 MR. WEBSTER: All right. Good luck, Mr.
11 Leyse.
12 MR. LEYSE: Yes. Thank you.
1 MR. MILLER: The floor is to you, Mr.
14 Leyse.
15 MR. LEYSE: Okay. Yes. I just wanted to 1 follow up with what he had said, just in terms of not 17 the legal aspects, but I think I have definitely -
18 your number two reason for not wanting your initial 1 decision not to consider this, is that I have not 2 provided -- the 1, actually, that I received, says 21 that I haven't shown that the ECCS systems for both of 22 these plants are potentially inadequate, and I 2 disagree with that.
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17 1 of the Petition, I have a quote from J. W. McConnell, 2 and I think I had mentioned this in the last teleconference.
This was someone who worked for [Aerojet]
who was in charge of overseeing the BWR FLECHT program, and his conclusion was that from a licensing 7 viewpoint, the effectiveness of top spray ECC has not 8 been demonstrated, nor has it been proven ineffective.
And he and he also mentions that the 1 BWR FLECHT program being run by General Electric had 11 been done in a very, kind of -- with, you know, a 12 definite conflict of interest.
1 So, I - I think that just that, in itself I mean, we are talking about a nuclear reactor, 1 after all, and you're supposed to really ensure that 1 there's adequate public safety, and here's a statement 17 that says that hasn't necessarily been demonstrated 18 that this system would be effective.
1 And the system is the same, more or less, 20 as it was back when he made this observation. We're 21 talking about the BWR[/)2 system in this case, of 22 which there are just the ones at Oyster Creek and Nine 2 Mile Point Unit Number One, you know, under the NRC's control.
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18 1 shown, that there's -- to use your -- that the system 2 is "potentially inadequate," that the heat transfer coefficients that are used in the ECCS evaluation calculations, those come from data from the SS2N bundle and in SS2N, SS stands for stainless steel and the N stands for nichrome, but basically the point is, 7 this comes from a stainless steel bundle. It doesn't 8 come from a [Zircaloy] bundle, and I think that's another reason to show that the system is potentially 1 inadequate.
11 Those are facts and, as Richard Webster 12 kindly pointed out, you know, I've documented these 1 facts pretty thoroughly in the Petition. It's -- and the fact is, you know, these heat transfer 1 coefficients come from stainless steel, not from a 1 [Zircaloy] bundle.
17 And I also want to point out another thing 18 that is concrete, is the Oak Ridge National Labs 1 reports, and those are mentioned on page 11 and page 20 12.
21 They state - the first one is "In-Vessel 22 Phenomena, CORA, BWR, Core melt Progression Phenomena 2 Program, Oak Ridge National Laboratory.
24 It was presented in 1991. It explicitly 25 states "Cladding oxidation in the CORA-16 experiment,"
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19 1 that was a BWR severe fuel damage experiment. Anyway, "in the CORA-16 experiment the oxidation rates were not accurately predicted by available correlations."
So would be the Baker-Just Correlation and the Cathcart-[PawelJ Correlation.
Now, Oyster Creek is Appendix K, so that's 7 using the Baker-Just Correlation. So, this explicitly 8 states that there was an experiment. It had rapid oxidation, and it was not accurately predicted by the 1 Baker-Just Correlation, which is used for the ECCS.
It's used in the ECCS evaluation calculations for 1 Oyster Creek.
1 And then another paper, it's also an Oak Ridge National Lab document, it states 1 MR. DUDLEY: Mr. Leyse 1 MR. LEYSE: Yes.
MR. DUDLEY: This is Richard Dudley. I'd 1 like to ask you a question about your CORA-16 1 statement. Do you have any evidence to say that the 2 CORA test was made in under test conditions that were designed to be consistent with a loss of coolant 2 accident?
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20 have been performed under conditions consistent with a 2 loss of coolant accident.
3 Do you have any information regarding the 4 CORA test to show that that particular CORA-16 was done under conditions representative of a LOCA?
MR. LEYSE: Yes, I do, but let me rst 7 reply by saying do you think a single specimen in the 8 data in the Baker-Just Equation comes from a small specimen that would be, I think, an inch or so long, 1 maybe an inch, 1.2 inches long, I believe, 1 inductively-heated [zirconium] specimen that is held at isothermal conditions to measure the oxidation 1 rates, do you think that represents real LOCA conditions, inductively-heated?
1 MR. DUDLEY: Mr. Leyse, I am not a 1 [Zircaloy] oxidation specialist, and the purpose of 1 this call is not, I think, for you to ask us questions, but for us to ask you questions.
1 MR. LEYSE: Sure. Well, I would like to 2 point out that the - that in no way does a single rod 21 that is inductively-heated represents LOCA conditions, 22 and I would like to read something because, actually, 23 NEI stated that they did not believe that the CORA 24 experiments represented LOCA conditions in some of 25 their recent statements, and they had pointed out that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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21 1 it was a steam environment and that the purpose of the 2 experiments was to create an environment so that there would be oxidation, and then that would lead to fuel damage.
But I want to read one thing. This [is]
from Appendix K, and it regarding re 11 and 7 reflood heat transfer for pressurized water reactors, 8 now, that's not a BWR, but nonetheless, it speaks during refill and during reflood when reflood rates 1 are less than one inch per second, heat transfer 11 calculations shall be based on the assumption that 12 cooling is only by steam and shall take into account
- so, anyway, so that's a condition where cool is only by steam, and I believe there are counterpart conditions in BWRs, and that is essentially the conditions of the CORA experiments.
And the point is, anyway, here is a test where it was the you know, we're talking about oxidation rates, and the oxidation [rates] were 20 measured, and they were measured such that the 21 available correlations underpredicted them.
22 So, I think that's something that is very 2 important, and it was similar to conditions that can occur during a LOCA when there would be a steam 2 environment.
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22 1 50, that's kind of a long answer, but I 2 think it's pretty important to, you know, answer that thoroughly.
MR. DUDLEY: Mr. Leyse, this is Richard Dudley again. I just wanted to you know that under -- as part of our review of Petition [PRM] 50-93 7 and 50-95, our Office of Research is now looking into 8 the accident excuse me. the experiments you described, and we are trying to ascertain what were 10 the conditions of those tests, so that was why I was 11 asking the question.
12 If you don't know the answer, that's fine, 13 but we will we will go and figure out the answer 14 and that's how we're going to evaluate your technical 1 allegations as to whether or not we need to institute 1 rulemaking for a change to our ECCS rule.
MR. LEY5E: Okay. Yes. No, I appreciate 1 that, and I'm -- I just wanted to try to point out 1 that I think that's great that you're looking at that, 20 and I would also really recommend that you look at the 21 conditions of the tests that Baker-Just and Cathcart 22 [Pawel], that those correlations are based off of and 23 make a determination if you think that those replicate 24 actual LOCA conditions, and I think you'll find, when 2 you look at those tests, that they are far from it, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE" N,W.
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23 1 because we are talking about single specimens that, 2 where there are -- 's just not the same situation where you have interfacial rods and you'll have the hot spots at the center of interfacial rods, and you won't have the same amount of heat loss as you would with a single rod specimen.
7 So -- but I I appreciate that you're 8 concerned about that and that you're looking at that.
And I think I think you will also find 10 that I -- I don't know if I have this handy. I'll 11 look, but I think it's also mentioned in here that 12 there was the -- 's the compendium -- I forget the 1 - it's a compendium of ECCS research which I've cited a number of times.
1 If you give me one second, I'll be right 1 back. I'll find that.
17 Okay. It says, the compendium will 18 also talks about the situation where severe [fuel]
1 damage experiments can be used to show -- they claim 20 that severe fuel damage experiments can be used to 21 show that the 2200 limit is, in fact, conservative 22 where, you know, I've argued the opposite.
2 But have -- let me see. Yes, here 24 is. I'll read it. It's the Compendium of ECCS 25 Research for Realis LOCA Analysis, and they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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24 1 describe a method for assessing the conservatism of 2 the 2200 Fahrenheit PCT limit, and they say:
"[Assessment] of the conservatism in the PCT limit can be accomplished by comparison to [multi rod] bundle data for the autocatalytic temperature.
This type of comparison implicitly includes complex 7 heat transfer mechanisms and the effects of fuel rod 8 ballooning and rupture on coolability.
"Analysis of experiments performed in the 1 Power Burst Facility in the Annular Core Research 11 Reactor [,] and in the NEILS-CORA facilities in West 12 Germany Program have shown that temperatures above 1 2200 Fahrenheit are required before the [Zircaloy 14 steam] reaction becomes [sufficiently] rapid to 15 produce an autocatalytic temperature excursion.
1 "Another group of relevant experimental 17 data were produced in the [MT-6B]" -- that's material 18 I'm sorry. I can't it may be "materials 1 testing." Anyway, "6B and the FLHT LOCA and coolants 20 [Coolant Boilaway] and [Damage Progression] tests 21 conducted in the NRU reactor in Canada, Chalk River.
22 "Even though some severe accident research 2 shows lower thresholds for temperature excursion or a 24 cladding failure than previously-believed when design 25 basis heat transfer and decay heat are considered some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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25 margin above 2200 Fahrenheit exists."
So, the best experiment, I think, to look 3 at would be the LOFT LP I'm sorry, the LOFT FP2 4 experiment, and -- yes, FP. I hope I said instead of FB.
Anyway, that there's data from that 7 that shows that, in fact, runaway oxidation commenced 8 at 1400 Kelvin. So, that would be about 2060 degrees Fahrenheit, and in that experiment, you actually had 10 actual decay heat.
11 So, there you have [the] compendium and 1 they're really saying, you know, take a look at these 1 severe fuel damage experiments and you have your design basis heat transfer, and they just come to the 1 wrong conclusion because, you know, obviously, a lot 1 of these tests[,] runaway oxidation data shows it did, in fact, commence below 2200 degrees Fahrenheit.
1 So, I guess that's the continuation to 1 answer that, but I think that is extremely important.
2 So and just back to the situation with Oyster 21 Creek, just -- unless -- I'm sorry. Do you have any 22 other questions, Mr. Dudley?
23 MR. DUDLEY: Not at this point. We are 24 looking at all the information that you submitted in 2 your two petitions for rulemaking.
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26 1 MR. LEYSE: Okay. Okay. Yes. No, I 2 appreciate that, and I guess I yes. No, I appreciate your question and wanted to do the best answer, but since s is regarding also regarding Oyster Creek, and I think, as Richard Webster pointed out, I really do think that there is you know, I've 7 presented data and I understand that these are generic 8 issues.
The metal/water reaction is most certainly 1 a generic issue, and the way how that will affect the 11 peak cladding temperatures, you know, I believe is a 12 generic issue, so I'm not going to disagree with that.
1 But, at the same time I do think this is a 14 pretty important issue that should be addressed 15 concerning Oyster Creek and Nine Mile Point Unit 1 Number One, especially since they have the BWR[/]2 17 ECCS, and some of this like the quotes[,] like from 18 McConnell, from [Aerojet] and just some of these old 1 tests were done 40 years ago and things really haven't 20 changed. It's pretty much a very similar system to 21 what they had back then.
22 And another thing. I don't know if this 2 -- I actually -- I want to qualify this. I think the metal/water reaction is a generic issue, but I have 2 come across [a document] that was just placed in ADAMS NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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27 1 on January 27th of 2011, so it's actually placed in 2 ADAMS since our last teleconference.
3 It's a General Electric document and it 4 states, "Metal/water reaction is not important for most BWRs as PCTs are below 1200 Kelvin, 1700 degrees Fahrenheit. It is only significant for BWR[/]2 large 7 breaks."
8 Now, I find myself in an awkward position because I actually disagree with that statement.
10 However, at the same time I just want to submit 11 to -- this is a statement from General Electric, and I 12 think is it shows that, at least from their point 1 of view, from General Electric's point of view the metal/water reaction is plant-specific, you know, 1 for Oyster Creek and Nine Mile Point Unit Number One 1 s those are the only two BWRs that are under 17 regulation by the NRC.
18 So, at least from General Electric's point 1 of view, I doubt if they would want to -- I doubt if 2 they would want to, you know, go along with -- approve 21 I guess I should say I doubt they approve of 22 my petition, but at least from their point of view it 2 seems that the metal/water reaction is only something to be considered at BWR[/]2's.
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28 1 Number Two of it's the Track G Application for 2 Emergency Core Cooling Systems, Loss of Coolant 3 Accidents Analysis for BWR 2 6. So, that's two 4 through six.
That's a GE document, and I'll give you the ADAMS Accession Number. That's ML110280325, and the page number is 2-9, and it's Table 2.5-, and then it's a -- of that table, it's at 3.2.5 metal/water reaction rate.
1 Now, I also want to add that I believe 11 this is all based off of the Cathcart-[Pawel]
12 Correlation. They're talking about best estimate 1 models and again, you know, obvious that's something I say is [non-conservative], just everything 1 I've just said and what I've said about the CORA-16 1 [experiment] .
1 But at least from General Electric's point 1 of view this is an issue that is only specific to 1 Oyster Creek and Nine Mile Point Unit Number One, and 20 although I disagree with it, I do want to submit it to 21 you as something that may give you a reason to be able 22 to proceed with this.
2 It may be a reason for you to say that 2 this is actually [non-generic], because I think it's 25 very important that you do review this petition and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE .. N.w.
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29 1 and I'm just giving you an option for you to be able 2 to say, well, at least according to General Electric this is plant-specific, and maybe this is a reason we can say that this a [non-generic] safety issue, and that may be something you want to consider.
But, at the same time, you know, I think what Richard Webster said -- I can't duplicate what he said, but he basically said that there should be no reason why someone cannot pursue an issue both in the 10 rulemaking front and also in the enforcement action 11 [front] simultaneously.
12 And I think, unless you have any other 1 questions, that is pretty much all I have to say, and 14 I would like to turn things over to Ray Shadis unless 15 there are any questions.
1 CHAIRMAN QUAY: I see none here.
17 Mr. Shadis, are you still on the phone?
18 MR. SHADIS: Yes, I am. Yes, I am.
1 Thank you for the opportunity to comment.
20 I have in front of me the document that Mr. Leyse was 21 referring to that just appeared in ADAMS at the end of 22 January.
2 It appears to be a topical licensing report. It's NEDO-33005 Rev 0 and, yes, from all I 2 can make of the tables that he referenced, their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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30 1 concern with the metal/water reaction is limited to 2 the BWR [/ J 2 's and so therefore, with that particular aspect of the general topic of peak cladding temperature, with that particular aspect, it is site-specific, and in order to, you know, pass on assurance to our constituents, we would really like to see that 7 either addressed, that aspect alone, if necessary, 8 addressed through the 2.206 process so that it could be addressed expedi I Y or, you know, if we can't 1 see that, at least to have that section for those two 11 plants taken up particular the rulemaking 12 process.
13 But I don't know how you can find a safety 14 issue that is more plant-specific than a issue 1 in which the vendor says it really only applies to the 1 two plants named in the Petition.
17 So, I guess that's the that's the 18 extent of my comments and again, I do appreciate the 1 opportunity to make comment.
20 MR. LEYSE: And, yes, I want to thank Mr.
21 Shadis for his comments. Mark e speaking.
22 CHAIRMAN QUAY: Okay. At this time does 2 the staff here at headquarters have any ques ons for either Mr. Leyse or Mr. Shadis?
2 (No response.)
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31 1 CHAIRMAN QUAY: Seeing none, before I 2 conclude the meeting, members of the public may provide comments regarding the Petition and ask 4 ques ons about the 2.206 Petition process.
5 Remember, as stated in the opening, the purpose of this meet is not to provide an 7 opportunity for the or the public to 8 quest or examine at the Petition Board regarding the merits of the Petition Request.
1 Are there any members of the public that 11 wish to make comments?
12 MR. SHADIS: And Mr. Chairman, s is Ray 1 Shadis again. I guess I need to make clear, I'm probably the member of the public that you're speaking 1 of, and I really had no in preparing s 2.206, 1 the one that's currently before you, but I did want to 17 comment on it and comment on it as a member of the 18 public.
CHAIRMAN QUAY: Okay. Thank you. I understand that, but other members of the public may have joined us, so I just wanted to make sure.
Okay. At s point, Mr. I thank you for taking the time to provide the NRC staff with clarifying information on the Peti you've submitted.
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32 1 Before we close, does the court reporter 2 need any additional information for the meeting transcript?
COURT REPORTER: No, I do not.
CHAIRMAN QUAY: Okay. With that, we will conclude this phone call. Thank you.
7 MR. LEYSE: Yes. I just wanted to thank 8 Mr. Miller and the Petition Review Board and also Mr.
Dudley and the others from Rulemaking. Mark Leyse 1 speaking.
11 CHAIRMAN QUAY: Okay. Thank you, Mark.
12 MR. LEYSE: Thank you.
CHAIRMAN QUAY: Good afternoon, everyone.
(Whereupon, at 2:50 p.m. the above-entitled matter was concluded.)
17 18 1
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ML110840219 OFFICE DORLILPLI-2/PM DORLILPLI-2/BC NAME GEMilier HChernoff DATE 3/3/11 4/4/11