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.
Washington, D.C. 20005
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(202) 234-4433
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11 12 13 14 16 17 18 19 21 22 23 24 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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10 CFR 2.206 PETITION REVIEW BOARD (PRB)
CONFERENCE CALL RE:
BRAIDWOOD/BYRON
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WEDNESDAY MAY 16 1 2012
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The conference call was held Bill Ruland Chairman of the Petition Review Board l
l l
presiding.
PETITIONER: BARRY QUIGLEY PETITION REVIEW BOARD MEMBERS:
BILL RULAND I PRB Chairman and Director, NRR/DSS JOEL S. WIEBE, Petition Manager for 2.206 Petition LEE BANIC I PRB Coordinator, NRR/DPR ERIC DUNCAN, Region 1111 Branch Chief, Division of Reactor Projects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 12 13 14 16 17 18 19 21 22 23 24 ED SMITH, NRR/DSS, Balance of Plant Branch PREM SAHAY, NRR/DE, ectrical Engineering Branch AHSAN SALLMAN, NRR/DSS, Containment and Ventilation Branch ALEXANDER TSIRIGOTIS, NRR/DE, Mechanical and Structural Engineering Branch NRC HEADQUARTERS STAFF:
MICHELLE ALBERT, Office of General Counsel LAUREN CASEY, Office of Enforcement NICOLE COLEMAN, Office of Enforcement KIMYATA MORGAN BUTLER, NRR/DPR/Generic Communications Branch JAKE ZIMMERMAN, NRR/DORL NRC REGION III STAFF:
BRUCE BARTLETT, Senior Resident Inspector, Byron Generating Station TRAVIS DAUN, Resident Inspector's Office, Byron Generating Station RAYMOND NG, Project Engineer JOHN ROBBINS, Resident Inspector, Byron Generating Station NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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11 12 13 14 16 17 18 19 21 22 23 24 JAMIE BENJAMIN, Senior Resident Inspector, Braidwood Generating Station ALEX GARMOE, Resident Inspector, Braidwood Generating Station ALSO PRESENT:
TOM COLE, Braidwood Generating Station, Engineering Staff DAN ENRIGHT, Braidwood Generating Station, Site Vice President AMY FERKO, Braidwood Generating Station, Site Engineering Director MARK KANAVOS, Braidwood Generating Station, ant Manager CHRIS VANDENBURGH, Braidwood Generat Station, Regulatory Assurance Manager DAVE GUDGER, Byron Generating Station, Regulatory Assurance Manager TRACY HULBERT, Byron Generating Station, Regulatory Assurance CHUCK KELLER, Byron Generating Station, Acting Design Manager DAVE GULLOTT, Exelon Corporate censing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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MIKE 2
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9 11 12 13 14 16 17 18 19 21 22 23 24 (202) 234-4433 PERRY, Illinois Management Agency, Resident Inspector for Braidwood Generating Station NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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11 12 13 14 16 17 18 19 21 22 23 24 P-R-O-C-E-E D-I-N G S (10:05 a.m.)
MR. WIEBE:
My name is Joel Wiebe.
I am the Braidwood and Byron Stations Project Manager.
This is the Petition Review Board discussion with the Petitioner of the 2.206 petition dated April 20, 2012.
The Petition Manager for the petition the Petition Review Board Chairman is 11 Ruland.
And one thing, could I ask the ones who aren't talking to go on mute, and then go off mute when you want to say something?
As part of the Petition Review Board's review of this petition, the Petitioner, Barry Quigley, has requested this opportunity to address the PRB.
The meeting is scheduled from 10:00 to 11:00 Eastern Time.
The meeting is being recorded by the NRC Operations Center and is also being transcribed by a Court Reporter.
The transcript itself will become a
supplement to the petition, and the transcript will be made publicly available.
I would like to open this meeting with introductions, and we will go around the room in headquarters first.
I would 1ike to ask you to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.w.
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11 12 13 14 16 17 18 19 21 22 23 24 clearly state your name, your position, and the office you work for within the NRC.
I will start off.
My name again is Joel Wiebe.
I am a Project Manager with NRR.
MR. SALLMAN:
My name is Sallman.
I work with the Containment
- my position is Reactor Systems
- Engineer, and I work for the Division of Safety Systems in the Containment and Ventilation Branch.
MS. BUTLER:
Kimyata Morgan Butler in the Division of Policy and Rulemaking in NRR.
I'm the Acting Branch Chief of the Generic Communications Branch.
MS.
COLEMAN :
I'm Nicole Coleman, an Enforcement Specialist in the Office of Enforcement.
MS.
CASEY:
I'm Lauren
- Casey, an Enforcement Specialist in the Office of Enforcement.
MR. SAHAY:
11m Prem Sahay, P-R-E-M, S-A H-A-Y.
I'm an Electrical Engineer, work for NRR, Electrical Engineering Branch.
MR.
TSIRIGOTIS:
Alexander Tsirigotis, Division of Engineering l Mechanical and Structural Engineering Branch.
MR. DUNCAN:
And in Region III my name is Eric Duncan.
I am the Branch Chief for Branch III BRP 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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11 12 13 14 16 17 18 19 21 22 23 24 here, and he is the Project Engineer for Branch III.
MR.
BARTLETT:
This is Byron Resident fice.
We've got Bruce Bartlett; I'm the Senior Resident. We've got John Robbins; he is the Resident.
And we have Travis Daun.
MR. BENJAMIN:
At the Braidwood resident inspector office we have Jamie Benjamin, the Senior Residenti Alex Garmoe, the Resident Inspector; and we also have Mike Perry with the Illinois Emergency Management Agency.
He is the Resident Inspector of Braidwood.
MR. SMITH:
Here at headquarters, this is Ed Smith, DSS, Balance of plant Branch.
MR.
ZIMMERMAN:
Jake Zimmerman, Branch Chief, Division of Operating Reactor Licensing.
MS. ALBERT:
Michelle Albert, At torney in the Office of General Counsel.
MS.
BANIC:
Lee Banic, 2.206 Petition Coordinator, NRR.
MR. RULAND:
11 Ruland, Director of the Division of Safety Systems in NRR, and the PRB Chair.
MR.
WIEBE:
Okay.
That completes the introductions at NRC headquarters and the other NRC participants.
Is there any other NRC participants that have not introduced themselves?
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11 12 13 14 16 17 18 19 21 22 23 24 (No response.)
Okay.
Are there any representatives from the licensee on the phone?
MR. ENRIGHT:
Yes. This is Dan Enright at Braidwood Station. I'm the site Vice President. With me are Mark Kanavos, Plant Manager i Chris Vandenburgh, Regulatory Assurance Manager i Amy
- Ferko, Site Engineering rectorj and Tom Cole of our engineering organization.
MR. GUDGER:
This is Dave Gudger at the Byron Nuclear Station.
I'm the Regulatory Assurance Manager.
I have with me Chuck Keller, Acting Design Manager; and Tracy Hulbert, Regulatory Assurance.
MR. GULLOTT: This is Dave Gullott, Exelon Corporate Licensing.
MR. WIEBE:
Okay.
Mr. Quigley, would you introduce yourself for the record?
MR. QUIGLEY :
Yes.
My name is Barry Quigley, Q U-I G-L-E Y.
MR. WIEBE:
Okay.
Thanks.
It is not required for members of the public who may be on the phone to introduce themselves for the call.
- However, if there are any members of the public on the phone who do wish to introduce themselves, please do so at this time.
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11 12 13 14 16 17 18 19 21 22 23 24 (No response.)
Okay.
Hearing none t I
would like to emphasize that we each need to speak clearly and loudly to make sure the Court Reporter can hear you and accurat y transcribe the meeting.
Also t first state your name before you say something.
That way the Court Reporter knows who to attribute the comment to.
For those who are dialing into the meeting please remember to mute your phones to t
minimize the background noise.
If you do not have a mute button t you can mute by pressing the keys star and then six.
To unmute t you can press the star six key again.
Thanks.
At this timet I will turn it over to the PRB Chairman t Bill Ruland.
MR.
RULAND:
Thank you t Joel.
Good morning.
Welcome to this meeting regarding the 2.206 petition submitted by Mr. Quigley.
I would like to first share some background for our process.
Section 2.206 Title X of the Code Federal Regulations describes the petition process tithe primary mechanism for the public to request enforcement action by the NRC. II It is a public process.
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9 11 12 13 14 16 17 18 19 21 22 23 24 This process permits anyone to petition NRC to take enforcement type action related to NRC licensees or licensed activities.
Depending on the results of this evaluation, NRC could modify, suspend, or revoke an NRC-issued license, or take any other appropriate enforcement action to resolve a problem.
The NRC staff's guidance for the disposition of a
2.206 petition request is in Management Directive 8.11, which is publicly available.
The purpose of today's meeting is to give the Petitioner an opportunity to provide any additional explanation or support for the petition before the Petition Review Board's initial consideration and recommendation. This meeting is not a hearing, nor is it an opportunity for the Petitioner to question or examine the PRB on the merits of the issues presented in the petition request.
No decisions regarding the merits of this petition will be made at this meeting. Following this meeting, the Petition Review Board will conduct its internal deliberations.
The outcome of this internal meeting will be discussed with the Petitioner subsequently.
The Petition Review Board typically NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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9 11 12 13 14 16 17 18 19 21 22 23 24 consists of a Chairman l usually a manager at the senior executive level at the NRC.
It has a Petition Manager and a PRB Coordinator I who already have introduced themselves. Other members of the Board are determined by the NRC staff based on the content of the information in the petition request.
First l I
would like to introduce the Board.
Of course I myself I Bill Ruland l I
am the Petition Review Board Chairman. Joel Wiebe I who is who gave us the introduction l is the Petition Manager the petition under discussion today.
Lee Banic is the fice/s PRB Coordinator.
Our technical staff includes l but is not limited tOI Ed Smith, who is in the Balance of ant Branch in the Division of Safety Systems in NRRi Prem
- Sahay, who is in the Division of Engineering in Electrical Engineering Branch; exander Tsirigotis, who is in the'Division Engineering, Mechanical and Civil Engineering Branch; Ahsan Sallman, who is in the Containment and ventilation Branch in NRR; and Eric Duncan, who is a Branch Chief in Region III in the Division of Reactor Projects.
We also obtained advice from the Office of General Counsel, represented by Michelle Alberti and 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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9 11 12 13 14 16 17 18 19 21 22 23 24 12 Coleman.
As described in our process, the NRC staff may ask clarifying questions to better understand the Peti tioner' s presentation and to reach a reasoned decision whether to accept or reject the Petitioner's request for review under the 2.206 process.
Now, I would like to summarize the scope of the petition under consideration and the NRC's activities to date.
On April 20, 2012, Mr. Quigley submitted to the NRC a petition under 2.206 regarding Braidwood Units 1 and 2 and Byron Units 1 and 2.
In this petition, Mr. Quigley identified the following areas of concern.
He requested that the NRC require Braidwood Units 1 and 2, and Byron Units 1 and 2, to be immediately shut down until all turbine building high energy line break concerns are identified, and those important to safety are corrected.
As the basis for this request, Mr. Quigley states that the physical layout of the Byron and Braidwood plants exposed both trains of emergency electric power generation, alternating current distribution, ESF batteries, and a direct current -
and direct current distribution to the effects of non-safety-related piping failures.
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9 11 12 13 14 16 17 18 19 21 22 23 24 Mr. Quigley states that the design flaw was missed during initial licensing, and the potential to disable mul tiple trains of safety related equipment was first identified in 1991.
He states that some analysis was performed, but work stopped short of a comprehensive review of the HELB, or high-energy line break, regulatory requirements.
Mr. Quigley identified the following major issues.
One, the emergency diesel generators are affected by H-E L-B -
I'll use those initi s from now on, or HELB because steam can enter the emergency diesel generator rooms, the emergency diesel generator room ventilation, and the emergency diesel generator air intakes.
Engineered safety
- features, or ESF switchgear rooms
- this is the second item are af ed because of the potential of high temperature to alter protective relay set points.
Three, the current method of analysis for turbine building HELB uses a lumped volume approach, which substantially reduces energy effects and does not always give conservative results.
Preliminary assessment using GOTHIC subdivided volume features shows structural limits substantially exceeded on the block wall between the ESF switchgear rooms.
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9 11 12 13 14 16 17 18 19 21 22 23 24 Four, there has been no structured and detailed review of the licensing requirements regarding impacts on equipment operability for turbine building high energy line break or HELB.
Next, I will discuss NRC activities to date.
On April 26,
- 2012, the Petition Manager contacted the Petitioner to discuss the 10 CFR 2.206 process and to offer him an opportunity to address the PRB by phone or in person.
The Petitioner requested to address the PRB by phone prior to its internal meeting to make the initial recommendation to accept or reject the petition for review.
On May 4th, also of this year, the PRB met internally to discuss the request for immediate action.
The PRB denied the request for immediate action of shutdown
- excuse me.
The PRB denied the request for immediate shutdown of the fected plants, because the licensee had completed an operability determination finding the equipment was operable but degraded.
Instead, based on the potential hazardous conditions presented in the petition, we determined that a 10 CFR Section 2.204 demand for information would be initiated for the purposes of determining 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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The PRB may stop or continue the processing of the Section 2.204 demand for information based on further internal meetings accordance with the 2.206 process.
On May 14,
- 2012, the Petitioner was informed of the PRB's decision to deny the request for immediate action.
As a reminder for the phone participants, please identify yourself if you make any remarks, as this will help us in the preparation of the meeting transcript that will be made publicly available.
Thank you.
Mr. Quigley, I will ask you now to provide any information that you believe the. PRB should consider as part of its petition.
Mr. Quigley?
MR.
QUIGLEY:
Thank you.
I will be pausing as I go through to allow for questions, first talking a little bit about the physical layout.
At Byron and Braidwood, the turbine building shares a wall with the safety-related aux building. The diesel generators and ectrical equipment rooms are located the aux building, but they have ventilation and personal access openings in a shared wall with the turbine building.
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9 11 12 13 14 16 17 18 19 21 22 23 24 The ventilation for these areas is relatively simple consisting of using fans to blow outside air through areas. Al though the source of the air is a safety-related intake air shaft, the exhaust openings are simply holes in the turbine building wall.
As far as the history of HELB, the NRC asked several questions related to HELB outside containment during initial licensing.
Additional analyses were
- done, but neither the NRC or Commonwealth Edison noticed the large openings approximately five foot by five foot between the turbine building and the dies generator and switchgear rooms.
In 1991, the NRC partially noted the potential for a turbine building HELB to effect the diesel generator switchgear and diesel generator.
However, the NRC only allowed Commonwealth Edison 90 days to reply.
Therefore, the analysis done was limited.
Basical the analysis took credit for fire dampers in the turbine building exhaust openings to drop and isolate the areas from the fects of the high energy line break.
Credit was also taken 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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9 11 12 13 14 16 17 18 19 21 22 23 24 pressure In the turbine building.
Additional work was done in 1996 related to piping break locations.
Stress calculations were done to eliminate some locations.
In 2011, it was noted that the assumed fire damper drop time was substantially in error. An operability evaluation was completed, which showed acceptable temperatures based on more thermal hydraulic analyses that were done.
I note that Mr. Ruland stated that the immediate request was denied in part on the presence of the op eval.
I did not have that information prior to today.
BasicallYt I wrote the op eval.
The only thing that the Byron op eval addresses is fire dampers taking too long to drop.
MR.
RULAND:
Mr.
- Quigley, I've got a question for you.
MR. QUIGLEY:
Certainly.
MR. RULAND:
Since you wrote the original operabilityevaluation t and apparently determined that the equipment was operable but degraded, what has changed from the time you wrote and signed off on that operability evaluation and the present time?
MR. QUIGLEY:
The operability evaluation only dealt with the fact that the fire dampers take 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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9 11 12 13 14 16 17 18 19 21 22 23 24 18 this information at the time, but I could not show operabil MR. RULAND:
So you didn't include this other information in the op eval, nor did you write a non-conformance or a condition report, whatever you call it at those stations, at that time?
MR. QUIGLEY:
I made my management aware of - - my engineering management aware of the technical concerns I had.
MR. RULAND:
Okay.
Thanks.
MR. QUIGLEY:
Yep.
Talk a little more of the history and a little bit more the structural layout.
So the basic high energy line break concern is that we have a non-safety-related steam or feedline rupture in the turbine building, pressurized within the turbine building.
And since these diesel rooms and switchgear rooms are connected, the adverse environment for the turbine building can propagate into the safety-related areas.
So we had recognized that at some point.
However, as I looked at it more detail, that's where these additional issues under the basis request come from.
Well, the first one I want to t k about 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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simple.
For temperature control I it relies on a recirculation mode.
BasicallYI when it is hot air outside or hot in the diesel room l it draws air in through the intake sha through a fan l and out through a hole in the turbine building wall.
If the temperatures are cooler/ there is a recirculation damper that opens up.
And what that recirculation damper does is allows the fan to basically isolate the outside air path and just recirculate air through the room.
It is that recirculation path that is of concern for combustion air.
When the turbine building pressuri zes / and then the pressure comes in and steam comes into the diesel generator room l the damper configuration can be such that steam flows back into the intake air shaft.
The diesel generator combustion air supply is located approximately eight feet from that point.
So the concern would be that the diesel l when it is either trying to start or already running l could draw in some steam that is coming through this other path.
Now/ that is very difficult to visualize perhaps.
So if there is any questions on how that is laid out/ I will take them right now.
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9 11 12 13 14 16 17 18 19 21 22 23 24 (No response.)
Okay.
Hearing none, I will move on.
So potentially, instead of having 100 percent air, the diesel generator could be trying to run or start on a steam air mixture. And we have not undertaken to find out the capability of the engine to do so, nor have we undertaken to find out how much steam will actually get to that location.
Also, as I
was thinking further about this, the turbocharger on the diesel engine could also be at risk, because now we have a pressurized air intake, if you will.
So that could raise concerns with the ability of the turbocharger to carry that additional bus load.
The next item I had was that the effects of high temperature in the switchgear rooms on the protected relay has not been evaluated.
We did look at motor control centers.
However, the four kv switchgear was not rigorously looked at.
So the concern would be that the temperature effects could cause the relays to fail to actuate when desired or the relays could actuate earlier than desired.
We have not fully considered the environment in the switchgear room, including the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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9 11 12 13 14 16 17 18 19 21 22 23 24 ssurization effects.
These reI have glass covers on them.
If the pres zation breaks the glass, it follows the relay.
We not considered any of that.
The next item is reI to the modeling.
The way that a
high energy I
break outside containment has been modeled the past, both at Byron and other utilities, is wi a lumped volume approach.
I paused when I d
because there is no NRC approved methodology for culating pressures and temperatures for HELB's fsite containment.
So as I was looking at the lumped volume approach, I created a side model, if you will, and started looking at the effects of subdivided volumes, where the area is divided up 0 a much finer mesh.
When I did that, I got results were contrary to those in the model currently progress.
What I was focusing on was the switchgear rooms.
Our switchgear rooms Alpha and Bravo Divisions -- are located adjacent to each other and are separated by a block wall.
on in the HELB reconstitution we noted that block wall had very little margin in it, and there were concerns that we could exceed the structural limits on the wall.
We resolved that in the rna part of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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9 11 12 13 14 16 17 18 19 21 22 23 24 proj ect separately.
However, when I looked at it under a subdivided approach, we would exceed the structural capability on that wall by about a factor of three.
So the subdivided approach yields more accurate results and unacceptable results.
MR. RULAND:
Just hold on a second, Mr.
Quigley.
MR. QUIGLEY:
Yep.
MR. SALLMAN:
This is Ahsan Sallman from the Containment and Ventilation Branch.
I understand that you did a subdivided approach. Could you explain more about this?
How many divisions for the lumped model, and what was the outcome of that?
MR. QUIGLEY:
For the model that Exelon is currently working on, the 426 elevation is about 1.3 million cubic feet.
I divided that up into six smaller lumped volumes, and then the area in front of the switchgear rooms is approximately 110 feet by 45 feet.
I divided that up into about 800 sub-volumes.
And then, I also modeled the switchgear rooms as subdivided volumes, with connections into the turbine building.
So what I saw there was, if I put a break outside of that subdivided volume, as the pressure -
as the whole model pressurizes, the pressure moves NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 11 12 13 14 16 17 18 19 21 22 23 24 into the subdivided volume I and it reaches one of the switchgear rooms before it reaches the other and then I
it starts to pressurize that room.
And then l several milliseconds later l the other room starts to pressurize.
And then l after a period of timel the pressures in the rooms switchgear rooms stabilized.
And then I when the turbine building siding blows off I and the model depressurizes l the rooms do not depressurize at the same rate.
SOl againl there is depressurization of the building.
We get another excessive differential pressure across the switchgear room wall.
MR. SALLMAN :
You said there were six smaller lumped volumes for -
which building was that?
MR. QUIGLEY:
For the 426 elevation of the turbine building.
MR. BARTLETT:
HeYI BarrYI this is Bruce Bartlett.
MR. QUIGLEY:
Yes.
MR. BARTLETT:
Wouldn/t that so work if the dampers in one of the switchgear rooms worked and the dampers in the other switchgear room had your single failure and didn/t work?
You can generate a differential pressure across the wall that way also?
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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QUIGLEY:
Yes.
With that --
those other dampers that we are considering putting in.
MR. BARTLETT:
Thank you.
MR. QUIGLEY:
Right.
That is one of the problems that we are trying to work through on the dampers we're putting in.
The scenario that I am talking about right now exists today independent any damper installation.
- Now, again, this is the first thing I looked at with the subdivided model.
So I would anticipate that a further subdivided model would uncover further non-conservatisms.
I have looked at this particular one enough to be confident that modeling-wise there is not a whole lot that can be done to make it better.
Were there any other questions on the modeling aspects?
MR.
BARTLETT:
No, not from here, from headquarters.
MR. QUIGLEY:
Thank you.
MR. RULAND:
Mr. Quigley, why don't we because I you know, we -
I would like to see if we can finish this meeting today on time.
And if we need further time, we will have to just reschedule and have another phone call.
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9 11 12 13 14 16 17 18 19 21 22 23 24 But so why don't you just kind of go through your entire list right now, and then we will come back and ask questions.
How does that sound?
MR. QUIGLEY:
Well, that's fine. But I've only got one more item on the list.
MR.
RULAND:
Oh.
Then, I guess that's easy.
MR. QUIGLEY:
Right. The next one is that there has been no structured and detailed review of the licensing requirements for HELB.
As I
said earlier, HELB got missed during initial licensing.
When the issue was identified by the NRC in 1991, the company responded.
The NRC's followup inspection was not a licensing type of review.
It just looked at the response and accepted the response.
So in 1991 we had a chance and didn't get there.
In '96, it was looked at a little bit further, but only for piping stresses.
In 2001, we looked at the HELB issue again, and that is when we found out that the fire damper assumption the fire damper drop time assumption was in error.
We did a lot of work, but we have still not done a structured review of HELB.
We have not picked up the standard review plan, gone through it line by line, and found all of the problems.
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RULAND:
Mr. Quigl could you would it be possible, since it might help us expedite our actions on this, to provide those references? You talked about '91 and MR. QUIGLEY:
Yes.
MR.
RULAND:
, 96,
- and, you know, several inspection reports.
I f you could provide those references to us, it would be helpful.
MR. QUIGLEY:
I can do that.
MR.
RULAND:
And he would provide them through to you, Joel?
MR. WIEBE:
Yes, right.
MR. RULAND:
Okay.
Okay.
Continue.
MR. QUIGLEY:
I would also note that the licensee has entered the items of my petition into the corrective action process.
So basically the four bullets of the petition were entered into CAP.
I would note that the rationale for acceptability is weak, and at times I that the rationale is dismissive. In particular, when it talks about the GOTHIC analysis, it refers to the work I have done as preliminary informal, which is true, but Exelon is making no effort to resolve it.
So I feel that by saying it is informal, it is preliminary, that is dismiss NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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I don't see that.
What I see is an organization trying to resolve the minimum amount of possible with high energy line break, so that we can get our MUR approval.
So does anybody have any followup questions before I conclude?
MR. RULAND:
Hold on a second.
I've just got a question for the - - you're the Petition Manager, right, Joel?
Could you tell us what the status of those MUR approvals are?
MR. WIEBE:
We are in the latter stages of our review.
We have about three safety evaluation inputs left from the tech staff.
MR. RULAND:
Okay.
And they have been in house about
- what, about a year or so or MR. WIEBE:
For the application?
MR. RULAND:
Yes.
MR. WIEBE:
Yes, the year is up in June.
MR. RULAND:
Okay.
I just wanted to get a perspective on where they were.
Hold on a second.
I'm going to go on mute for a minute.
(Pause.)
Yes.
We were just trying to understand 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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But we understand your point.
MR. QUIGLEY:
Thank you.
MR. RULAND:
So any more questions for Mr.
Quigley from this room?
(No response.)
We have no more questions.
Any other NRC participants MR. QUIGLEY:
Well, I wasn't quite done yet.
MR. RULAND:
Oh, I'm sorry.
Go ahead.
MR. QUIGLEY:
That's fine.
I have been involved with the turbine building HELB analysis for 22 years now.
I have struggled to get Exelon to resolve it.
I have not been successful.
I performed the operability evaluation last year in the hope that that would move us along.
I focused the op eval solely on the fire damper delay times.
Then, when I was challenged by management to add additional information, I
told them that I
couldn't because I didn't know that it would support operability.
Based on what I know now --
I was an SRO for 15 years, I have been involved in this analysis for 21 years I I
have been doing operability evaluations for eight years -
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That concludes my remarks.
MR. RULAND:
Thank you, Mr. Quigl
- Now, let me ask again, is there any other questions in the room here?
(No response.)
Any other NRC participants have a
question?
(No response.)
Does the licensee have any questions?
(No response.)
Hearing
- none, did we ever establish whether or not there was a member of the public listening in?
MR. WIEBE:
No.
No member of the public spoke up.
MR.
RULAND:
Spoke up.
So I will just assume that there was, and I will are there -
before I conclude this meeting, members of the public may provide comments regarding the petition and ask questions about the 2.206 process.
However, as stated in the opening, the purpose of this meeting is not to provide an 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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So are there any members of the publ ic that have a question or comment about the petition process?
(No response.)
Having heard none, let me just ask a process question.
So anything else before we close the meeting?
Counsel, do we have anything else?
(No response.)
Okay. Mr. Quigley, I thank you for taking the time to provide the NRC staff with clarifying information on the petition you have submitted.
Before we close, does the Court Reporter need any additional information the meeting transcript?
THE COURT REPORTER; Hello.
This is the Court Reporter, and I am going to email Mr. Wiebe, if that is okay with him, to confirm the names of some the participants.
MR. WIEBE; Yes, that's good.
THE COURT REPORTER:
Thank you.
MR.
RULAND:
Okay.
With that, this meeting is concluded, and we will be terminating the phone connection.
Again, thank you, everyone, for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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(Whereupon, at 10:47
- a. m.,
the proceedings in the foregoing matter were conc1uded. )
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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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