ML12145A633
| ML12145A633 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 05/16/2012 |
| From: | Joel Wiebe Plant Licensing Branch III |
| To: | |
| Joel Wiebe | |
| References | |
| 2.206, NRC-1624 | |
| Download: ML12145A633 (33) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board RE Braidwood/Byron Docket Number: (n/a)
Location: teleconference Date: Wednesday, May 16,2012 Work Order No.: NRC-1624 Pages 1-31 IORIGINALI NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
\.w) Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 5 CONFERENCE CALL 6 RE:
7 BRAIDWOOD/BYRON 8 + + + + +
9 WEDNESDAY 10 MAY 16 1 2012 11 + + + + +
12 The conference call was held l Bill 13 Ruland l Chairman of the Petition Review Board l 14 presiding.
15 16 PETITIONER: BARRY QUIGLEY 17 18 PETITION REVIEW BOARD MEMBERS:
19 BILL RULAND I PRB Chairman and Director, 20 NRR/DSS 21 JOEL S. WIEBE, Petition Manager for 2.206 22 Petition 23 LEE BANIC I PRB Coordinator, NRR/DPR 24 ERIC DUNCAN, Region 1111 Branch Chief, 25 Division of Reactor Projects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 ED SMITH, NRR/DSS, Balance of Plant Branch 2 PREM SAHAY, NRR/DE, ectrical Engineering 3 Branch 4 AHSAN SALLMAN, NRR/DSS, Containment and 5 Ventilation Branch 6 ALEXANDER TSIRIGOTIS, NRR/DE, Mechanical and 7 Structural Engineering Branch 8
9 NRC HEADQUARTERS STAFF:
10 MICHELLE ALBERT, Office of General Counsel 11 LAUREN CASEY, Office of Enforcement 12 NICOLE COLEMAN, Office of Enforcement 13 KIMYATA MORGAN BUTLER, NRR/DPR/Generic 14 Communications Branch 15 JAKE ZIMMERMAN, NRR/DORL 16 17 NRC REGION III STAFF:
18 BRUCE BARTLETT, Senior Resident Inspector, 19 Byron Generating Station 20 TRAVIS DAUN, Resident Inspector's Office, 21 Byron Generating Station 22 RAYMOND NG, Project Engineer 23 JOHN ROBBINS, Resident Inspector, Byron 24 Generating Station 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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3 1 JAMIE BENJAMIN, Senior Resident Inspector, 2 Braidwood Generating Station 3 ALEX GARMOE, Resident Inspector, Braidwood 4 Generating Station 5
6 ALSO PRESENT:
7 TOM COLE, Braidwood Generating Station, 8 Engineering Staff 9 DAN ENRIGHT, Braidwood Generating Station, 10 Site Vice President 11 AMY FERKO, Braidwood Generating Station, Site 12 Engineering Director 13 MARK KANAVOS, Braidwood Generating Station, 14 ant Manager 15 CHRIS VANDENBURGH, Braidwood Generat 16 Station, Regulatory Assurance Manager 17 DAVE GUDGER, Byron Generating Station, 18 Regulatory Assurance Manager 19 TRACY HULBERT, Byron Generating Station, 20 Regulatory Assurance 21 CHUCK KELLER, Byron Generating Station, Acting 22 Design Manager 23 DAVE GULLOTT, Exelon Corporate censing 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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4 1 MIKE PERRY, Illinois Management 2 Agency, Resident Inspector for Braidwood 3 Generating Station 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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5 1 P-R-O-C-E-E D-I-N G S 2 (10:05 a.m.)
3 MR. WIEBE: My name is Joel Wiebe. I am 4 the Braidwood and Byron Stations Project Manager.
5 This is the Petition Review Board 6 discussion with the Petitioner of the 2.206 petition 7 dated April 20, 2012.
8 The Petition Manager for the petition 9 the Petition Review Board Chairman is 11 Ruland.
10 And one thing, could I ask the ones who 11 aren't talking to go on mute, and then go off mute 12 when you want to say something?
13 As part of the Petition Review Board's 14 review of this petition, the Petitioner, Barry 15 Quigley, has requested this opportunity to address the 16 PRB. The meeting is scheduled from 10:00 to 11:00 17 Eastern Time. The meeting is being recorded by the 18 NRC Operations Center and is also being transcribed by 19 a Court Reporter.
20 The transcript itself will become a 21 supplement to the petition, and the transcript will be 22 made publicly available.
23 I would like to open this meeting with 24 introductions, and we will go around the room in 25 headquarters first. I would 1 ike to ask you to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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6 1 clearly state your name, your posi tion, and the office 2 you work for within the NRC.
3 I will start off. My name again is Joel 4 Wiebe. I am a Project Manager with NRR.
5 MR. SALLMAN: My name is Sallman. I work 6 with the Containment - my position is Reactor Systems 7 Engineer, and I work for the Division of Safety 8 Systems in the Containment and Ventilation Branch.
9 MS. BUTLER: Kimyata Morgan Butler in the 10 Division of Policy and Rulemaking in NRR. I'm the 11 Acting Branch Chief of the Generic Communications 12 Branch.
13 MS . COLEMAN : I'm Nicole Coleman, an 14 Enforcement Specialist in the Office of Enforcement.
15 MS. CASEY: I'm Lauren Casey, an 16 Enforcement Specialist in the Office of Enforcement.
17 MR. SAHAY: 11m Prem Sahay, P-R-E-M, S-A 18 H-A-Y. I'm an Electrical Engineer, work for NRR, 19 Electrical Engineering Branch.
20 MR. TSIRIGOTIS: Alexander Tsirigotis, 21 Division of Engineering l Mechanical and Structural 22 Engineering Branch.
23 MR. DUNCAN: And in Region III I my name is 24 Eric Duncan. I am the Branch Chief for Branch III BRP 25 for Byron and Braidwood. And also, Raymond Ng is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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7 1 here, and he is the Project Engineer for Branch III.
2 MR. BARTLETT: This is Byron Resident 3 fice. We've got Bruce Bartlett; I'm the Senior 4 Resident. We've got John Robbins; he is the Resident.
5 And we have Travis Daun.
6 MR. BENJAMIN: At the Braidwood resident 7 inspector office we have Jamie Benjamin, the Senior 8 Residenti Alex Garmoe, the Resident Inspector; and we 9 also have Mike Perry with the Illinois Emergency 10 Management Agency. He is the Resident Inspector of 11 Braidwood.
12 MR. SMITH: Here at headquarters, this is 13 Ed Smith, DSS, Balance of plant Branch.
14 MR. ZIMMERMAN: Jake Zimmerman, Branch 15 Chief, Division of Operating Reactor Licensing.
16 MS. ALBERT: Michelle Albert, At torney in 17 the Office of General Counsel.
18 MS. BANIC: Lee Banic, 2.206 Petition 19 Coordinator, NRR.
20 MR. RULAND: 11 Ruland, Director of the 21 Division of Safety Systems in NRR, and the PRB Chair.
22 MR. WIEBE: Okay. That completes the 23 introductions at NRC headquarters and the other NRC 24 participants. Is there any other NRC participants 25 that have not introduced themselves?
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8 1 (No response.)
2 Okay. Are there any representatives from 3 the licensee on the phone?
4 MR. ENRIGHT: Yes. This is Dan Enright at 5 Braidwood Station. I'm the site Vice President. With 6 me are Mark Kanavos, Plant Manager i Chris Vandenburgh, 7 Regulatory Assurance Manager i Amy Ferko, Site 8 Engineering rectorj and Tom Cole of our engineering 9 organization.
10 MR. GUDGER: This is Dave Gudger at the 11 Byron Nuclear Station. I'm the Regulatory Assurance 12 Manager. I have with me Chuck Keller, Acting Design 13 Manager; and Tracy Hulbert, Regulatory Assurance.
14 MR. GULLOTT: This is Dave Gullott, Exelon 15 Corporate Licensing.
16 MR. WIEBE: Okay. Mr. Quigley, would you 17 introduce yourself for the record?
18 MR . QUI GLEY : Yes. My name is Barry 19 Quigley, Q U-I G-L-E Y.
20 MR. WIEBE: Okay. Thanks. It is not 21 required for members of the public who may be on the 22 phone to introduce themselves for the call. However, 23 if there are any members of the public on the phone 24 who do wish to introduce themselves, please do so at 25 this time.
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9 1 (No response.)
2 Okay. Hearing none t I would like to 3 emphasize that we each need to speak clearly and 4 loudly to make sure the Court Reporter can hear you 5 and accurat y transcribe the meeting. Also t first 6 state your name before you say something. That way 7 the Court Reporter knows who to attribute the comment 8 to.
9 For those who are dialing into the 10 meeting t please remember to mute your phones to 11 minimize the background noise. If you do not have a 12 mute button t you can mute by pressing the keys star 13 and then six. To unmute t you can press the star six 14 key again. Thanks.
15 At this timet I will turn it over to the 16 PRB Chairman t Bill Ruland.
17 MR. RULAND: Thank you t Joel. Good 18 morning. Welcome to this meeting regarding the 2.206 19 petition submitted by Mr. Quigley.
20 I would like to first share some 21 background for our process. Section 2.206 Title X 22 of the Code Federal Regulations describes the 23 petition process tithe primary mechanism for the public 24 to request enforcement action by the NRC. II It is a 25 public process.
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10 1 This process permits anyone to petition 2 NRC to take enforcement type action related to NRC 3 licensees or licensed activities. Depending on the 4 results of this evaluation, NRC could modify, suspend, 5 or revoke an NRC-issued license, or take any other 6 appropriate enforcement action to resolve a problem.
7 The NRC staff's guidance for the 8 disposition of a 2.206 petition request is in 9 Management Directive 8.11, which is publicly 10 available.
11 The purpose of today's meeting is to give 12 the Petitioner an opportunity to provide any 13 additional explanation or support for the petition 14 before the Petition Review Board's initial 15 consideration and recommendation. This meeting is not 16 a hearing, nor is it an opportunity for the Petitioner 17 to question or examine the PRB on the merits of the 18 issues presented in the petition request.
19 No decisions regarding the merits of this 20 petition will be made at this meeting. Following this 21 meeting, the Petition Review Board will conduct its 22 internal deliberations. The outcome of this internal 23 meeting will be discussed with the Petitioner 24 subsequently.
25 The Petition Review Board typically NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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11 1 consists of a Chairman l usually a manager at the 2 senior executive level at the NRC. It has a Petition 3 Manager and a PRB Coordinator I who already have 4 introduced themselves. Other members of the Board are 5 determined by the NRC staff based on the content of 6 the information in the petition request.
7 First l I would like to introduce the 8 Board. Of course I myself I Bill Ruland l I am the 9 Peti tion Review Board Chairman. Joel Wiebe I who is 10 who gave us the introduction l is the Petition Manager 11 the petition under discussion today. Lee Banic is 12 the fice/s PRB Coordinator.
13 Our technical staff includes l but is not 14 limited tOI Ed Smith, who is in the Balance of ant 15 Branch in the Division of Safety Systems in NRRi Prem 16 Sahay, who is in the Division of Engineering in 17 Electrical Engineering Branch; exander Tsirigotis, 18 who is in the'Division Engineering, Mechanical and 19 Civil Engineering Branch; Ahsan Sallman, who is in the 20 Containment and ventilation Branch in NRR; and Eric 21 Duncan, who is a Branch Chief in Region III in the 22 Division of Reactor Projects.
23 We also obtained advice from the Office of 24 General Counsel, represented by Michelle Alberti and 25 the Office of Enforcement I represented by Nicole NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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12 1 Coleman.
2 As described in our process, the NRC staff 3 may ask clarifying questions to better understand the 4 Peti tioner' s presentation and to reach a reasoned 5 decision whether to accept or reject the Petitioner's 6 request for review under the 2.206 process.
7 Now, I would like to summarize the scope 8 of the petition under consideration and the NRC's 9 activities to date. On April 20, 2012, Mr. Quigley 10 submitted to the NRC a petition under 2.206 regarding 11 Braidwood Units 1 and 2 and Byron Units 1 and 2.
12 In this petition, Mr. Quigley identified 13 the following areas of concern. He requested that the 14 NRC require Braidwood Uni ts 1 and 2, and Byron Uni ts 1 15 and 2, to be immediately shut down until all turbine 16 building high energy line break concerns are 17 identified, and those important to safety are 18 corrected.
19 As the basis for this request, Mr. Quigley 20 states that the physical layout of the Byron and 21 Braidwood plants exposed both trains of emergency 22 electric power generation, alternating current 23 distribution, ESF batteries, and a direct current -
24 and direct current distribution to the effects of non-25 safety-related piping failures.
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13 1 Mr. Quigley states that the design flaw 2 was missed during initial licensing, and the potential 3 to disable mul tiple trains of safety related equipment 4 was first identified in 1991. He states that some 5 analysis was performed, but work stopped short 6 of a comprehensive review of the HELB, or high-energy 7 line break, regulatory requirements.
8 Mr. Quigley identified the following major 9 issues. One, the emergency diesel generators are 10 affected by H-E L-B - I'll use those initi s from 11 now on, or HELB because steam can enter the 12 emergency diesel generator rooms, the emergency diesel 13 generator room ventilation, and the emergency diesel 14 generator air intakes.
15 Engineered safety features, or ESF 16 switchgear rooms - this is the second item - are 17 af ed because of the potential of high temperature 18 to alter protective relay set points.
19 Three, the current method of analysis for 20 turbine building HELB uses a lumped volume approach, 21 which substantially reduces energy effects and does 22 not always give conservative results. Preliminary 23 assessment using GOTHIC subdivided volume features 24 shows structural limits substantially exceeded on the 25 block wall between the ESF switchgear rooms.
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14 1 Four, there has been no structured and 2 detailed review of the licensing requirements 3 regarding impacts on equipment operability for turbine 4 building high energy line break or HELB.
5 Next, I will discuss NRC activi ties to 6 date. On April 26, 2012, the Petition Manager 7 contacted the Petitioner to discuss the 10 CFR 2.206 8 process and to offer him an opportunity to address the 9 PRB by phone or in person. The Petitioner requested 10 to address the PRB by phone prior to its internal 11 meeting to make the initial recommendation to accept 12 or reject the petition for review.
13 On May 4th, also of this year, the PRB met 14 internally to discuss the request for immediate 15 action. The PRB denied the request for immediate 16 action of shutdown - excuse me. The PRB denied the 17 request for immediate shutdown of the fected plants, 18 because the licensee had completed an operability 19 determination finding the equipment was operable but 20 degraded.
21 Instead, based on the potential hazardous 22 conditions presented in the petition, we determined 23 that a 10 CFR Section 2.204 demand for information 24 would be initiated for the purposes of determining 25 whether an order under 2.202 should be issued, or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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15 1 whether other action should be taken.
2 The PRB may stop or continue the 3 processing of the Section 2.204 demand for information 4 based on further internal meetings accordance with 5 the 2.206 process.
6 On May 14, 2012, the Petitioner was 7 informed of the PRB's decision to deny the request for 8 immediate action.
9 As a reminder for the phone participants, 10 please identify yourself if you make any remarks, as 11 this will help us in the preparation of the meeting 12 transcript that will be made publicly available.
13 Thank you.
14 Mr. Quigley, I will ask you now to provide 15 any information that you believe the. PRB should 16 consider as part of its petition. Mr. Quigley?
17 MR. QUIGLEY: Thank you. I will be 18 pausing as I go through to allow for questions, first 19 talking a little bit about the physical layout. At 20 Byron and Braidwood, the turbine building shares a 21 wall with the safety-related aux building. The diesel 22 generators and ectrical equipment rooms are located 23 the aux building, but they have ventilation and 24 personal access openings in a shared wall with the 25 turbine building.
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16 1 The ventilation for these areas is 2 relatively simple consisting of using fans to blow 3 outside air through areas. Al though the source of 4 the air is a safety-related intake air shaft, the 5 exhaust openings are simply holes in the turbine 6 building wall.
7 As far as the history of HELB, the NRC 8 asked several questions related to HELB outside 9 containment during initial licensing. Additional 10 analyses were done, but nei ther the NRC or 11 Commonwealth Edison noticed the large openings 12 approximately five foot by five foot between the 13 turbine building and the dies generator and 14 switchgear rooms.
15 In 1991, the NRC partially noted the 16 potential for a turbine building HELB to effect the 17 diesel generator switchgear and diesel generator.
18 However, the NRC only allowed Commonwealth Edison 90 19 days to reply. Therefore, the analysis done was 20 limited.
21 Basical the analysis took credit for 22 fire dampers in the turbine building exhaust openings 23 to drop and isolate the areas from the fects of the 24 high energy line break. Credit was also taken 25 turbine building siding to blow off and relieve the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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17 1 pressure In the turbine building.
2 Additional work was done in 1996 related 3 to piping break locations. Stress calculations were 4 done to eliminate some locations. In 2011, it was 5 noted that the assumed fire damper drop time was 6 substantially in error. An operability evaluation was 7 completed, which showed acceptable temperatures based 8 on more thermal hydraulic analyses that were done.
9 I note that Mr. Ruland stated that the 10 immediate request was denied in part on the presence 11 of the op eval. I did not have that information prior 12 to today. BasicallYt I wrote the op eval. The only 13 thing that the Byron op eval addresses is fire dampers 14 taking too long to drop.
15 MR. RULAND: Mr. Quigley, I've got a 16 question for you.
17 MR. QUIGLEY: Certainly.
18 MR. RULAND: Since you wrote the original 19 operabilityevaluation t and apparently determined that 20 the equipment was operable but degraded, what has 21 changed from the time you wrote and signed off on that 22 operability evaluation and the present time?
23 MR. QUIGLEY: The operability evaluation 24 only dealt with the fact that the fire dampers take 25 too long to drop. That's all it deals with. I had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 this information at the time, but I could not show 2 operabil 3 MR. RULAND: So you didn't include this 4 other information in the op eval, nor did you write a 5 non-conformance or a condition report, whatever you 6 call it at those stations, at that time?
7 MR. QUIGLEY: I made my management aware 8 of - - my engineering management aware of the technical 9 concerns I had.
10 MR. RULAND: Okay. Thanks.
11 MR. QUIGLEY: Yep. Talk a little more of 12 the history and a little bit more the structural 13 layout. So the basic high energy line break concern 14 is that we have a non-safety-related steam or feedline 15 rupture in the turbine building, pressurized within 16 the turbine building. And since these diesel rooms 17 and switchgear rooms are connected, the adverse 18 environment for the turbine building can propagate 19 into the safety-related areas.
20 So we had recognized that at some point.
21 However, as I looked at it more detail, that's 22 where these additional issues under the basis 23 request come from.
24 Well, the first one I want to t k about 25 is the combustion air for the diesel generator. As I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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19 1 said l the ventilation for this system is relatively 2 simple. For temperature control I it relies on a 3 recirculation mode. BasicallYI when it is hot air 4 outside or hot in the diesel room l it draws air in 5 through the intake sha through a fan l and out 6 through a hole in the turbine building wall.
7 If the temperatures are cooler/ there is 8 a recirculation damper that opens up. And what that 9 recirculation damper does is allows the fan to 10 basically isolate the outside air path and just 11 recirculate air through the room. It is that 12 recirculation path that is of concern for combustion 13 air.
14 When the turbine building pressuri zes / and 15 then the pressure comes in and steam comes into the 16 diesel generator room l the damper configuration can be 17 such that steam flows back into the intake air shaft.
18 The diesel generator combustion air supply is located 19 approximately eight feet from that point. So the 20 concern would be that the diesel l when it is either 21 trying to start or already running l could draw in some 22 steam that is coming through this other path.
23 Now/ that is very difficult to visualize 24 perhaps. So if there is any questions on how that is 25 laid out/ I will take them right now.
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20 1 (No response.)
2 Okay. Hearing none, I will move on. So 3 potentially, instead of having 100 percent air, the 4 diesel generator could be trying to run or start on a 5 steam air mixture. And we have not undertaken to find 6 out the capability of the engine to do so, nor have we 7 undertaken to find out how much steam will actually 8 get to that location.
9 Also, as I was thinking further about 10 this, the turbocharger on the diesel engine could also 11 be at risk, because now we have a pressurized air 12 intake, if you will. So that could raise concerns 13 with the ability of the turbocharger to carry that 14 additional bus load.
15 The next item I had was that the effects 16 of high temperature in the switchgear rooms on the 17 protected relay has not been evaluated.
18 We did look at motor control centers.
19 However, the four kv switchgear was not rigorously 20 looked at. So the concern would be that the 21 temperature effects could cause the relays to fail to 22 actuate when desired or the relays could actuate 23 earlier than desired.
24 We have not fully considered the 25 environment in the switchgear room, including the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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21 1 ssurization effects. These reI have glass 2 covers on them. If the pres zation breaks the 3 glass, it follows the relay. We not considered 4 any of that.
5 The next item is reI to the modeling.
6 The way that a high energy I break outside 7 containment has been modeled the past, both at 8 Byron and other utilities, is wi a lumped volume 9 approach. I paused when I d because there is 10 no NRC approved methodology for culating pressures 11 and temperatures for HELB's fsite containment.
12 So as I was looking at the lumped volume 13 approach, I created a side model, if you will, and 14 started looking at the effects of subdivided volumes, 15 where the area is divided up 0 a much finer mesh.
16 When I did that, I got results were contrary to 17 those in the model currently progress.
18 What I was focusing on was the switchgear 19 rooms. Our switchgear rooms Alpha and Bravo 20 Divisions -- are located adjacent to each other and 21 are separated by a block wall. on in the HELB 22 reconstitution we noted that block wall had very 23 little margin in it, and there were concerns that we 24 could exceed the structural limits on the wall.
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22 1 proj ect separately. However, when I looked at it 2 under a subdivided approach, we would exceed the 3 structural capability on that wall by about a factor 4 of three. So the subdivided approach yields more 5 accurate results and unacceptable results.
6 MR. RULAND: Just hold on a second, Mr.
7 Quigley.
8 MR. QUIGLEY: Yep.
9 MR. SALLMAN: This is Ahsan Sallman from 10 the Containment and Ventilation Branch. I understand 11 that you did a subdivided approach. Could you explain 12 more about this? How many divisions for the lumped 13 model, and what was the outcome of that?
14 MR. QUIGLEY: For the model that Exelon is 15 currently working on, the 426 elevation is about 1.3 16 million cubic feet. I divided that up into six 17 smaller lumped volumes, and then the area in front of 18 the switchgear rooms is approximately 110 feet by 45 19 feet. I divided that up into about 800 sub-volumes.
20 And then, I also modeled the switchgear rooms as 21 subdivided volumes, with connections into the turbine 22 building.
23 So what I saw there was, if I put a break 24 outside of that subdivided volume, as the pressure -
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23 1 into the subdivided volume I and it reaches one of the 2 switchgear rooms before it reaches the other I and then 3 it starts to pressurize that room.
4 And then l several milliseconds later l the 5 other room starts to pressurize. And then l after a 6 period of timel the pressures in the rooms 7 switchgear rooms stabilized. And then I when the 8 turbine building siding blows off I and the model 9 depressurizes l the rooms do not depressurize at the 10 same rate.
11 SOl againl there is depressurization of 12 the building. We get another excessive differential 13 pressure across the switchgear room wall.
14 MR . SALLMAN : You said there were six 15 smaller lumped volumes for - which building was that?
16 MR. QUIGLEY: For the 426 elevation of the 17 turbine building.
18 MR. BARTLETT: HeYI BarrYI this is Bruce 19 Bartlett.
20 MR. QUIGLEY: Yes.
21 MR. BARTLETT: Wouldn/t that so work if 22 the dampers in one of the switchgear rooms worked and 23 the dampers in the other swi tchgear room had your 24 single failure and didn/t work? You can generate a 25 differential pressure across the wall that way also?
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24 1 MR. QUIGLEY: Yes. With that -- those 2 other dampers that we are considering putting in.
3 MR. BARTLETT: Thank you.
4 MR. QUIGLEY: Right. That is one of the 5 problems that we are trying to work through on the 6 dampers we're putting in. The scenario that I am 7 talking about right now exists today independent 8 any damper installation.
9 Now, again, this is the first thing I 10 looked at with the subdivided model. So I would 11 anticipate that a further subdivided model would 12 uncover further non-conservatisms. I have looked at 13 this particular one enough to be confident that 14 modeling-wise there is not a whole lot that can be 15 done to make it better.
16 Were there any other questions on the 17 modeling aspects?
18 MR. BARTLETT: No, not from here, from 19 headquarters.
20 MR. QUIGLEY: Thank you.
21 MR. RULAND: Mr. Quigley, why don't we 22 because I you know, we - I would like to see if we 23 can finish this meeting today on time. And if we need 24 further time, we will have to just reschedule and have 25 another phone call.
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25 1 But so why don't you just kind of go 2 through your entire list right now, and then we will 3 come back and ask questions. How does that sound?
4 MR. QUIGLEY: Well, that's fine. But I've 5 only got one more item on the list.
6 MR. RULAND: Oh. Then, I guess that's 7 easy.
8 MR. QUIGLEY: Right. The next one is that 9 there has been no structured and detailed review of 10 the licensing requirements for HELB. As I said 11 earlier, HELB got missed during initial licensing.
12 When the issue was identified by the NRC 13 in 1991, the company responded. The NRC's followup 14 inspection was not a licensing type of review. It 15 just looked at the response and accepted the response.
16 So in 1991 we had a chance and didn't get there.
17 In '96, it was looked at a little bit 18 further, but only for piping stresses. In 2001, we 19 looked at the HELB issue again, and that is when we 20 found out that the fire damper assumption the fire 21 damper drop time assumption was in error.
22 We did a lot of work, but we have still 23 not done a structured review of HELB. We have not 24 picked up the standard review plan, gone through it 25 line by line, and found all of the problems.
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26 1 MR. RULAND: Mr. Quigl could you 2 would it be possible, since it might help us expedite 3 our actions on this, to provide those references? You 4 talked about '91 and 5 MR. QUIGLEY: Yes.
6 MR. RULAND: , 96 , and, you know, 7 several inspection reports. If you could provide 8 those references to us, it would be helpful.
9 MR. QUIGLEY: I can do that.
10 MR. RULAND: And he would provide them 11 through to you, Joel?
12 MR. WIEBE: Yes, right.
13 MR. RULAND: Okay. Okay. Continue.
14 MR. QUIGLEY: I would also note that the 15 licensee has entered the items of my petition into the 16 corrective action process. So basically the four 17 bullets of the petition were entered into CAP.
18 I would note that the rationale for 19 acceptability is weak, and at times I that the 20 rationale is dismissive. In particular, when it talks 21 about the GOTHIC analysis, it refers to the work I 22 have done as preliminary informal, which is true, but 23 Exelon is making no effort to resolve it. So I feel 24 that by saying it is informal, it is preliminary, that 25 is dismiss NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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27 1 Also, the IR alludes to a HELB resolution 2 team and a HELB resolution effort. I don't see that.
3 What I see is an organization trying to resolve the 4 minimum amount of possible with high energy line 5 break, so that we can get our MUR approval.
6 So does anybody have any followup 7 questions before I conclude?
8 MR. RULAND: Hold on a second. I've just 9 got a question for the - - you're the Petition Manager, 10 right, Joel? Could you tell us what the status of 11 those MUR approvals are?
12 MR. WIEBE: We are in the latter stages of 13 our review. We have about three safety evaluation 14 inputs left from the tech staff.
15 MR. RULAND: Okay. And they have been in 16 house about - what, about a year or so or 17 MR. WIEBE: For the application?
18 MR. RULAND: Yes.
19 MR. WIEBE: Yes, the year is up in June.
20 MR. RULAND: Okay. I just wanted to get 21 a perspective on where they were. Hold on a second.
22 I'm going to go on mute for a minute.
23 (Pause.)
24 Yes. We were just trying to understand 25 how this fit into MUR issue, and, you know, at this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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28 1 point it is uncertain. But we understand your point.
2 MR. QUIGLEY: Thank you.
3 MR. RULAND: So any more questions for Mr.
4 Quigley from this room?
5 (No response.)
6 We have no more questions.
7 Any other NRC participants 8 MR. QUIGLEY: Well, I wasn't quite done 9 yet.
10 MR. RULAND: Oh, I'm sorry. Go ahead.
11 MR. QUIGLEY: That's fine. I have been 12 involved with the turbine building HELB analysis for 13 22 years now. I have struggled to get Exelon to 14 resolve it. I have not been successful.
15 I performed the operability evaluation 16 last year in the hope that that would move us along.
17 I focused the op eval solely on the fire damper delay 18 times. Then, when I was challenged by management to 19 add additional information, I told them that I 20 couldn't because I didn't know that it would support 21 operability.
22 Based on what I know now -- I was an SRO 23 for 15 years, I have been involved in this analysis 24 for 21 years I I have been doing operability 25 evaluations for eight years - I see no rational basis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW (202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com
29 1 to conclude that the diesel generators and the ESF 2 switchgear rooms are operable.
3 That concludes my remarks.
4 MR. RULAND: Thank you, Mr. Quigl Now, 5 let me ask again, is there any other questions in the 6 room here?
7 (No response.)
8 Any other NRC participants have a 9 question?
10 (No response.)
11 Does the licensee have any questions?
12 (No response.)
13 Hearing none, did we ever establish 14 whether or not there was a member of the public 15 listening in?
16 MR. WIEBE: No. No member of the public 17 spoke up.
18 MR. RULAND: Spoke up. So I will just 19 assume that there was, and I will are there -
20 before I conclude this meeting, members of the public 21 may provide comments regarding the petition and ask 22 questions about the 2.206 process.
23 However, as stated in the opening, the 24 purpose of this meeting is not to provide an 25 opportunity for the Petitioner or the public to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N,W.
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30 1 question or examine the PRB regarding the members 2 regarding the merits of the petition request.
3 So are there any members of the publ ic 4 that have a question or comment about the petition 5 process?
6 (No response.)
7 Having heard none, let me just ask a 8 process question. So anything else before we close 9 the meeting? Counsel, do we have anything else?
10 (No response.)
11 Okay. Mr. Quigley, I thank you for taking 12 the time to provide the NRC staff with clarifying 13 information on the petition you have submitted.
14 Before we close, does the Court Reporter 15 need any additional information the meeting 16 transcript?
17 THE COURT REPORTER; Hello. This is the 18 Court Reporter, and I am going to email Mr. Wiebe, if 19 that is okay with him, to confirm the names of some 20 the participants.
21 MR. WIEBE; Yes, that's good.
22 THE COURT REPORTER: Thank you.
23 MR. RULAND: Okay. With that, this 24 meeting is concluded, and we will be terminating the 25 phone connection. Again, thank you, everyone, for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 participating.
2 (Whereupon, at 10:47 a. m. , the 3 proceedings in the foregoing matter were 4 conc 1uded. )
5 6
7 8
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CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regul Commission Proceeding: 10 CFR 2.206 Petition of Braidwood/Byron by Barry Quigley Docket Number: n/ a Location: teleconference were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken and thereafter reduced to typewrit under my direction and that said transcript is a true and accurate record of the proceedings.
Official er Neal R. Gross & Co., Inc.
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