ML12250A714
| ML12250A714 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 08/27/2012 |
| From: | Lynnea Wilkins Plant Licensing Branch IV |
| To: | |
| Wilkins L | |
| References | |
| G20120458, TAC ME8973, NRC-1836, OEDO-2012-0390 | |
| Download: ML12250A714 (43) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition RE Fort Calhoun Nuclear Station Docket Number: (n/a)
Location: (teleconference)
Date: Monday, August 27, 2012 Work Order No.: NRC-1836 Pages 1-42 Corrected Transcript: Corrections denoted within brackets [ ]
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 5 CONFERENCE CALL 6 RE 7 FORT CALHOUN NUCLEAR GENERATING STATION 8 + + + + +
9 MONDAY 10 AUGUST 27, 2012 11 + + + + +
12 13 The conference call was held, Timothy McGinty, 14 Chairperson of the Petition Review Board, presiding.
15 16 PETITIONER: WALLACE TAYLOR 17 CO-PETITIONER: LYNN MOORER 18 19 PETITION REVIEW BOARD MEMBERS 20 TIMOTHY McGINTY, Office of Nuclear Reactor Regulation, 21 Division of Policy and Rulemaking 22 LYNNEA WILKINS, Petition Manager for 2.206 petition 23 ANDREA RUSSELL, PRB Coordinator 24 CHRISTOPHER CAUFFMAN, Office of Nuclear Reactor 25 Regulation, Reactor Inspection Branch NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 MICHAEL BALAZIK, Office of Nuclear Reactor Regulation, 2 Performance Assessment Branch 3 JOHN KIRKLAND, Senior Resident Inspector at Fort 4 Calhoun Station, NRC Region 4 Division of 5 Reactor Projects Branch 6 PATRICIA JEHLE, Office of the General Counsel 7
8 NRC HEADQUARTERS STAFF 9 JENNIVINE RANKIN, Division of Operating Reactor 10 Licensing 11 MIKE MARKLEY, Division of Operating Reactor Licensing 12 13 ALSO PRESENT:
14 PAMELA DALY 15 MIKE CARBERRY 16 MIKE RYAN 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 TABLE OF CONTENTS 2 Welcome and Introductions 4 3 Statement by Timothy McGinty, Chairman 4 Petition Review Board 8 5 Presentation by Wallace Taylor, Petitioner 12,35 6 Presentation by Lynn Moorer, Co-Petitioner 24 7 Questions of Petitioner 39 8 Adjourn 42 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., N.W.
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4 1 P R O C E E D I N G S 2 2:01 P.M.
3 MS. WILKINS: First, I would like to thank 4 everyone for attending this meeting. My name is Lynnea 5 Wilkins and I am the Project Manager for 6 Fort Calhoun Station.
7 We are here today to allow the Petitioner, 8 Mr. Wallace Taylor, to address the PRB, the Petition 9 Review Board, regarding the 2.206 petition dated June 21, 10 2012.
11 I'm getting a little feedback. Could 12 everyone mute their phones?
13 PETITIONER TAYLOR: There is feedback 14 here, too.
15 MS. WILKINS: The Petition Review Board 16 Chairman is Tim McGinty. As far as the PRB's review of 17 the petition, Mr. Wallace Taylor has requested this 18 opportunity to address the PRB.
19 This meeting is scheduled from 2 to 3 20 o'clock p.m. Eastern. The meeting is being recorded by 21 the NRC Op Center and will be transcribed by a court 22 reporter. The transcript will become a supplement to 23 the petition. The transcript will also be made publicly 24 available.
25 I'd like to open this meeting with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 introductions. As you go around the room here, please 2 make sure to clearly state your name, your position, and 3 the office that you work for within the NRC for the 4 record.
5 Again, I'm Lynnea Wilkins and I am in the 6 Division of Operating Reactor Licensing.
7 CHAIR McGINTY: I am Tim McGinty. I'm in 8 NRR, the Division of Policy and Rulemaking. I'm the 9 Director of that.
10 MR. CAUFFMAN: Chris Cauffman, Nuclear 11 Reactor Regulation, Reactor Inspection Branch.
12 MR. BALAZIK: My name is Mike Balazik, 13 Office of Nuclear Reactor Regulation from the 14 Performance Assessment Branch.
15 MS. RUSSELL: Andrea Russell, 2.206 16 Coordinator in NRR.
17 MS. JEHLE: Patricia Jehle, attorney with 18 the Office of the General Counsel.
19 MS. RANKIN: Jennivine Rankin, Division of 20 Operating Reactor Licensing.
21 MS. WILKINS: We have completed 22 introductions here at the NRC Headquarters. At this 23 time are there any NRC participants from Headquarters on 24 the phone?
25 Hearing none, are there any NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 participants from the Regional Office on the phone?
2 MR. KIRKLAND: This is John Kirkland. I'm 3 the Senior Resident Inspector with the NRC in Region 4, 4 stationed at Fort Calhoun.
5 MS. WILKINS: Thanks, John. Are there any 6 representatives for the licensee on the phone?
7 MS. BAUGHN: This is Susan Baughn, Fort 8 Calhoun, Station Manager of Licensing.
9 MS. WILKINS: Mr. Taylor, would you please 10 introduce yourself and any other presenters for the 11 record?
12 Mr. Taylor?
13 PETITIONER TAYLOR: I forgot to unmute.
14 This is Wallace Taylor. I'm legal counsel for the Iowa 15 Chapter of the Sierra Club. With me is Lynn Moorer, an 16 attorney from Lincoln, Nebraska who will be making 17 comments also.
18 MS. WILKINS: Thank you. We've had 19 another addition here in the room. Would you like to 20 introduce yourself?
21 MR. MARKLEY: Mike Markley, I'm the Chief 22 of Plant Licensing Branch in the Division of Operating 23 Reactor Licensing, NRR.
24 MS. WILKINS: Thank you. It is not 25 required for members of the public to introduce NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 themselves for this call. However, if there are any 2 members of the public on the phone that wish to do so at 3 this time, please state your name for the record?
4 MS. DALY: Pamela Daly.
5 MS. WILKINS: I'm sorry, could you repeat 6 that?
7 MS. DALY: Pamela Daly.
8 MS. WILKINS: Thank you.
9 MR. CARBERRY: Mike Carberry, Iowa Sierra 10 Club.
11 MR. RYAN: Mike Ryan, Omaha, Nebraska with 12 Clean Citizens Leading Environmental Action in Nebraska.
13 MS. WILKINS: Is there anyone else? Okay, 14 thank you.
15 I'd like to emphasize that we each need to 16 speak clearly and loudly to make sure that the court 17 reporter can accurately transcribe this meeting. If you 18 do have something that you would like to say, please first 19 state your name for the record. For those dialing into 20 the meeting, please remember to mute your phones to 21 minimize any background noise or distractions.
22 If you do not have a mute button, this can 23 be done by pressing the *6 key and to unmute, press the 24 *6 key again. Thank you.
25 At this time, I'll turn it over to the PRB NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 Chairman, Tim McGinty.
2 CHAIR McGINTY: Thanks, Lynnea. Good 3 afternoon. Welcome to this meeting regarding the 2.206 4 petition submitted by Mr. Taylor.
5 I'd like to first share some background on 6 our process. Section 2.206 of Title 10 of the Code of 7 Federal Regulations describes the petition process, the 8 primary mechanism for the public to request enforcement 9 action by the NRC in a public process.
10 This process permits anyone to petition NRC to take 11 enforcement-type action related to NRC licensees or 12 license activities.
13 Depending on the results of its evaluation, 14 NRC could modify, suspend, or revoke an NRC-issued 15 license or take any other appropriate enforcement action 16 to resolve a problem. The NRC staff's guidance for the 17 disposition of 2.206 petition requests in Management 18 Director 8.11 which is publicly available.
19 The purpose of today's meeting is to give 20 the Petitioner an opportunity to provide any additional 21 explanation or support for the petitions before the 22 Petition Review Board's initial consideration and 23 recommendations.
24 This meeting is not a hearing, nor is it an 25 opportunity for the Petitioner to request -- excuse me, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 to question or examine the PRB on the merits or the issues 2 presented in the petition request. No 3 decisions regarding the merits of these petitions will 4 be made at this meeting.
5 Following this meeting, the Petition Review 6 Board will conduct its internal deliberations. The 7 outcome of this internal meeting will be discussed with 8 the Petitioner.
9 The Petition Review Board typically 10 consists of a chairman, usually a manager at the Senior 11 Executive Service Level at the NRC. It has a Petition 12 Manager and a PRB Coordinator. Other members of the 13 Board are determined by the NRC's staff, based on the 14 content of the information in the petition request.
15 At this time, I'd like to introduce the 16 Board. I am Tim McGinty, the Petition Review Board 17 Chairman. Lynnea Wilkins is the Petition Manager for 18 the petition under discussion today. Andrea Russell is 19 the Office's PRB Coordinator. Our technical staff 20 includes Christopher Cauffman from the Office of Nuclear 21 Reactor Regulations, Reactor Inspection Branch; Michael 22 Balazik from the Office of Nuclear Reactor Regulations, 23 Performance Assessment Branch; John Kirkland, Senior 24 Resident Inspector at Fort Calhoun Station, NRC's Region 25 4, Division of Reactor Projects Branch. We also obtain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 advice from the Office of the General Counsel represented 2 by Patricia Jehle.
3 As described in our process, the NRC staff 4 may ask clarifying questions in order to better 5 understand the Petitioner's presentation and to reach a 6 reasoned decision whether to accept or reject the 7 Petitioner's request for review under the 2.206 process.
8 I'd like to summarize the scope of the 9 petitions under consideration and the NRC activities to 10 date. On June 21, 2012, Mr. Taylor submitted to the NRC 11 a petition under 2.206 regarding his concerns with the 12 adequacy of the management and operation of Fort Calhoun 13 Station. In this petition request, Mr. Taylor 14 identified the following areas of concern: Mr. Taylor 15 requested that the NRC revoke Omaha Public Power 16 District's license to operate Fort Calhoun Station. As 17 the basis for this request, Mr. Taylor states, in short, 18 that since at least 1992, Omaha Public Power District has 19 been unable and unwilling to operate Fort Calhoun 20 properly and safely. It states that "OPPD" which is an 21 acronym for Omaha Public Power District "has failed to 22 correct problems that were identified years ago and has 23 resisted directives from the NRC regarding safety 24 violations."
25 The Petitioner is concerned that there is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 no likelihood that OPPD will ever be able to or willing 2 to operate Fort Calhoun properly and safely.
3 Allow me to discuss the NRC activities to date.
4 On July 12, 2012, the Petition Manager contacted the 5 Petitioner to discuss the 10 CFR 2.206 process and to 6 offer the Petitioner an opportunity to address the PRB 7 by phone or in person. The Petitioner requested to 8 address the PRB by phone which is the purpose of today's 9 call, prior to the PRB internal meeting to make the 10 initial recommendations to accept or reject the 11 petitions for review.
12 As a reminder for the phone participants, 13 please identify yourself if you make any remarks as this 14 will help us in the preparation of the meeting's 15 transcript that will be made publicly available. Thank 16 you.
17 Mr. Taylor, at this point, I'll turn it over 18 to you to allow you to provide any information you believe 19 the PRB should consider as part of these petitions. Ms.
20 Moorer can present her information after you have 21 completed your presentation.
22 PETITIONER TAYLOR: Thank you very much.
23 I appreciate the opportunity to make this presentation 24 to you in support of the petition.
25 As you mentioned, the petition was filed on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 June 21st asking to revoke the Fort Calhoun license 2 because of a long history of problems at the plant. A 3 few points of background that might get us off to a good 4 start, Fort Calhoun is a 478.6 megawatt Pressurized Water 5 Reactor licensed in 1973 and operated by OPPD. The 6 license was renewed in 2003.
7 Fort Calhoun was initially shut down on 8 April 9th of 2011 for scheduled refueling. Then while 9 the plant was shut down for refueling, the Missouri river 10 on June 6, 2011 flooded and surrounded the plant with 11 flood water and OPPD issued a Notification of Unusual 12 Event due to that flooding.
13 Then the next day, June 7th, while the plant 14 was shut down and surrounded by flood water, they had a 15 catastrophic fire in the west switchgear room. We'll 16 talk more in detail about that as we go along.
17 Then after the flood waters receded and 18 inspection was accomplished or at least started, the NRC 19 issued a Confirmatory Action Letter to OPPD on September 20 2, 2011. The plant remained shut down because further 21 inspection led the NRC to place Fort Calhoun on the 0350 22 status for further investigation and monitoring. And 23 that's the status in which it still remains.
24 As I said, Fort Calhoun came to public 25 attention in June of 2011 when it was surrounded by flood NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 water from the Missouri River. The plant sits right on 2 the edge of the river across the river from Missouri 3 Valley, Iowa. The Iowa Sierra Club felt that this 4 situation affected the safety of the plant and the people 5 in western Iowa. So we decided to take a look at the 6 situation. As I attended meetings conducted by the NRC 7 in the Omaha area and did more investigation, it became 8 obvious that there were significant problems at Fort 9 Calhoun in addition to the flooding.
10 As set out in our petition, there's a 11 history of violations and unwillingness by OPPD to 12 operate the plant properly. These are not just isolated 13 incidents, but rather they show a pattern and practice 14 by OPPD of ignoring or even refusing in some cases to 15 address these violations. We submitted a summary of the 16 more serious problems through the years at Fort Calhoun 17 to Ms. Wilkins last week. I understand that the Board 18 members have that summary for your review and I hope you 19 do take a look at that and look at the problems that the 20 plant has had over the years.
21 Although this hearing is about OPPD's 22 operation of the Fort Calhoun plant, I want to make clear 23 that the recent proposal by OPPD to hire Exelon to operate 24 the plant does not eliminate our concerns. Our concerns 25 about Exelon will be documented and discussed in an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 additional hearing later as I have discussed with Ms.
2 Wilkins.
3 I had asked that this hearing be postponed 4 so we could further find out exactly what the agreement 5 is between Exelon and OPPD and to research Exelon's 6 history a little more and Ms. Wilkins indicated to me that 7 since this hearing had been set up, we would proceed, 8 focused on OPPD, but that we could have a hearing later 9 on regarding the recent development regarding Exelon.
10 Preliminary investigation reveals that 11 Exelon does have a history of problems in operating its 12 fleet of nuclear plants. Also, the public information 13 about the agreement between OPPD and Exelon is that OPPD 14 would still own and be responsible for operation of the 15 plant and would still be calling the shots, so to speak.
16 It would just be turning the day-to-day management over 17 to Exelon.
18 Now regarding OPPD's history of operating 19 the plant, we note that as early as 1992 there were 20 problems. At that time, an electrical malfunction led 21 to the loss of 25,000 gallons of reactor coolant. An 22 OPPD employee who was writing in the company newsletter 23 at that time, who was apparently an engineer or some sort 24 of management employee, wrote that "the Fort Calhoun 25 Station had hit the other side of the bathtub curve."
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15 1 And I'm sure you're aware, the bathtub curve is a graph 2 that's used to show that a nuclear plant in its first 3 years has some problems to work out and the reliability 4 goes down. That's the near side of the bathtub curve 5 going down. And then for a period of time it flattens 6 out and is fairly static, that's the bottom of the 7 bathtub. And then as it goes on and has more problems 8 and reaches the end of its life, the bathtub curve goes 9 up again with more reliability problems. Even back in 10 1992, OPPD was saying that the plant had reached that far 11 side of the bathtub curve and that was 20 years ago.
12 Regarding the flood aspect, prior to the 13 flood, OPPD had received repeated warnings about 14 inadequate flood protection at the plant. In 2003, the 15 Corps of Engineers warned OPPD of the dangers of flooding 16 to the Fort Calhoun plant and that the plant was not ready 17 for such an event. OPPD apparently did nothing 18 in response to that warning.
19 In 2010, the NRC cited OPPD for a violation 20 of inadequate flood protection procedures. This 21 resulted in a yellow significance determination, yellow 22 being the second highest degree of seriousness for safety 23 and reliability problems. And this is discussed in our 24 summary of incidents in a little more detail.
25 Then in 2011, the NRC again determined that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 OPPD had not adequately prepared Fort Calhoun for flood 2 events. This was in very early 2011. OPPD's response 3 in a letter dated March 4, 2011 was that "flooding at Fort 4 Calhoun was highly unlikely" and therefore requested 5 that the NRC not impose flood safety requirements. OPPD 6 just sort of ignored the warnings it had been given by 7 the Corps of Engineers and by the NRC and in fact, 8 resisted doing anything about them. Finally, OPPD 9 backed down and began to do some flood protection work.
10 Then, of course, the June 2011 flood came 11 and we saw all the problems resulting from that.
12 In a post-flood Event Report submitted by 13 OPPD on March 1, 2012, OPPD identified inadequate 14 flooding protection due to ineffective oversight which 15 is what everybody was telling them to begin with.
16 Specifically, the root causes of the inadequate flood 17 protection were, number one, a weak procedure revision 18 process. In other words, they had no plans or process 19 to revise their flood protection procedures. It just 20 wasn't on their radar.
21 Number two, insufficient oversight of work 22 activities associated with external flood matters. So 23 they weren't paying attention. There was no oversight 24 of any work regarding external flood matters.
25 Number three, ineffective identification, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 evaluation, and resolution of performance deficiencies 2 related to external flooding. Again, they weren't 3 paying any attention. They weren't looking for any 4 problems. In fact, as we've seen, they were ignoring or 5 resisting any problems.
6 And finally, four, and this really tells a 7 story that OPPD had a quote, safe as is, quote, mindset 8 relative to external flooding events. So as far as they 9 were concerned it was safe as is and that was their 10 mindset. That was their culture. And we see what 11 happened.
12 Then while Fort Calhoun was surrounded by 13 flood water in June of 2011, a fire occurred inside the 14 plant. The fire was caused by a short circuit in a 15 circuit breaker in the plant and this was described as 16 an catastrophic event. According to a letter from David 17 Bannister of OPPD to the NRC on May 24, 2012, he said "the 18 cause of the fire was that when new circuit breakers were 19 installed in 2009, the new circuit breakers did not fit 20 the receptacles that they were supposed to go into." But 21 in complete defiance of the situation, OPPD workers 22 shoved the new circuit breakers into the receptacles 23 anyway, even though they didn't fit. And because of 24 that, the contacts of the circuit breakers did not line 25 up or they did not touch and the fire was not an accident.
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18 1 It was caused by what can fairly be described as gross 2 negligence by OPPD.
3 Then because of the increased and 4 intensified inspection by the NRC after the flood, the 5 two inspection reports, well, more than that but two that 6 I want to focus on, one on November 14, 2011, several 7 violations of NRC regulations were found. There was a 8 failure to incorporate design information into the 9 procedures for operation of the component cooling water 10 system. And also failure to have adequate instructions, 11 procedures, or drawings including appropriate 12 quantitative or qualitative acceptance criteria to 13 ensure they can detect reactor coolant leakage. This 14 violation occurred from November 21, 2008 until April 14, 15 2009, but was not corrected by OPPD prior to the 16 post-flood inspection.
17 And finally, failure to identify or correct 18 a condition adverse to quality, specifically the 19 calibration of the load weighing system for a crane prior 20 to its use in lifting the spent fuel transfer cask loaded 21 with spent fuel out of the fuel pool. This apparently 22 occurred on July 7, 2009, but was not reported by OPPD 23 and was not discovered by the NRC until the post-flood 24 inspection. This situation adversely impacted the 25 spent fuel pool and handling attributes of the barrier NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 integrity cornerstone objective of providing reasonable 2 assurance that physical design barriers protect the 3 public from radionuclide releases caused by accidents or 4 events. So that was a real safety problem.
5 Then the next inspection report I want to 6 pinpoint is on February 14, 2012, several more violations 7 were discovered. Failure to follow a procedure for 8 placing a reactor coolant system level monitors into 9 service, this failure resulted in the draining of 10 approximately 1800 gallons of reactant coolant through 11 the reactor coolant drain tank. This problem could have 12 led to a complete loss of reactor coolant inventory.
13 Next, failure to perform testing and 14 evaluation of safety-related heat exchangers in 15 accordance with written procedures. This affected the 16 ability of systems to respond to initiating events to 17 prevent core damage.
18 Next, failure to follow procedures 19 requiring workers to comply with radiological work 20 permit instructions. This violation affected the 21 objective of ensuring adequate protection of worker 22 health and safety from exposure to radiation during 23 routine operations.
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20 1 during an emergency that implemented federal guidance.
2 This failure allowed the subsequent removal of 3 recommendations to evacuate members of the public during 4 a radiological emergency.
5 These inspections show in the entire 0350 6 process, as demonstrated, that there were many failures 7 by OPPD in operating Fort Calhoun that came very close 8 to causing serious problems. In fact, if the plant had 9 been shut down, I really wonder what the implications 10 would have been. It is only by sheer luck that nothing 11 tragic did happen. OPPD should not be allowed to 12 gamble with public safety and the environment.
13 And as further post-flood inspection is 14 performed, more long-standing problems that OPPD has 15 failed to address are revealed. Some of these problems 16 go back as far as 39 years, virtually as long as Fort 17 Calhoun has been in operation. Lynn Moorer 18 will follow my presentation with a more detailed 19 discussion of some of these long-standing problems.
20 So I want to emphasize that our petition is 21 not just about the flood of June 2011. It is about OPPD's 22 long history of inability and unwillingness to operate 23 Fort Calhoun safely and properly. I also want to 24 emphasize again that the proposed transfer of operation 25 of Fort Calhoun to Exelon does not solve the problem. It NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 does, however, clearly prove that OPPD admits that it 2 cannot operate Fort Calhoun. In fact, OPPD Board member 3 John Green stated publicly that "OPPD was not going to 4 be able to open the plant without transferring operation 5 to Exelon." OPPD by its own admission, has 6 substantiated the basis of our petition that they are not 7 able or willing to continue to operate Fort Calhoun.
8 The final issue I want to address is the 9 implications of revoking the license for Fort Calhoun.
10 Although it's not specifically in your focus to think 11 about what are the consequences if it's closed, I'm sure 12 that we all do have that in the back of our minds. And 13 I want to assure the Board that OPPD's customers will not 14 be without power if the plant ceases to operate. OPPD 15 has excess capacity. For over a year and a half, Fort 16 Calhoun has been shut down with no adverse consequences.
17 At the July 17th hearing, in Omaha, 18 conducted by the NRC, Gary Gates, OPPD president said 19 they have been able to supply all of the needed power to 20 their customers with no adverse effect on rate payers.
21 But more importantly, OPPD can and should transition to 22 clean and renewable energy, primarily wind power.
23 Nebraska is the fourth-best state in the country for wind 24 resources, but Nebraska has practically no wind 25 generation. Wind energy would be a much better source NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 of energy for OPPD on several levels than try to depend 2 on a troubled nuclear plant.
3 As we've seen, this plant has had numerous 4 troubles over the years, whether or not even the NRC 5 inspection and guidance under the 0350 process, whether 6 it can really be started again with the assurance that 7 it can be operated safely and properly. It seems a much 8 better proposal to look at alternative sources of energy 9 for OPPD.
10 The 2.206 petition can be revoked by the NRC 11 under its enforcement policy for a number of reasons, 12 including when a licensee is unable or unwilling to 13 comply with NRC requirements, or when a licensee refuses 14 to correct a violation. I think we've seen from the 15 facts in this case that that's exactly what the situation 16 here is at Fort Calhoun. And as I've said, we think 17 Exelon is not the answer and we certainly appreciate your 18 willingness to let us have a further hearing on those 19 issues after we develop the facts.
20 I want to thank the Board for allowing us 21 to discuss our petition with you. As I said, we do want 22 the opportunity for a further hearing to discuss the 23 issues presented by the recent agreement between OPPD and 24 Exelon.
25 With respect to the record of this hearing, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 we request that the summary of incidents we submitted 2 last week be a part of the record and that all of the 3 documents referenced in that summary be part of the 4 record.
5 We also request that the record of this 6 hearing be kept open until September 4th so we can 7 document any matters that have come up at this hearing 8 or that you may have questions about that we can supply 9 answers for.
10 At this point, I'll turn it over to Ms.
11 Moorer and then perhaps I can have a couple of minutes 12 after she finishes to make some final comments.
13 CO-PETITIONER MOORER: This is Lynn 14 Moorer. Thank you for this opportunity to present 15 evidence.
16 When looking at the bigger picture of OPPD's 17 operation at Fort Calhoun, a pattern and practice 18 emerges. What is evident is both poor decision making, 19 as well as deep-seated cluelessness, to use non-legal 20 terms. This is demonstrated by an extensive record of 21 long-standing failure to take appropriate corrective 22 actions to address known problems. It's also 23 demonstrated by a clear record of failure to establish 24 and use inspection and other investigative procedures to 25 discover long-standing potentially significant issues.
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24 1 In short, the employees running Fort 2 Calhoun lack a questioning attitude and instead 3 repeatedly act as those operations are good enough as is.
4 This occurs throughout the plant in all areas. Whether 5 through negligence or intentional decisions, OPPD has 6 demonstrated incompetence at many levels and in many 7 areas in operating Fort Calhoun. This troubling lack of 8 confidence runs deep throughout OPPD.
9 In addition, OPPD has also demonstrated a 10 pattern and practice of very slow response to safety 11 issues at Fort Calhoun. A large backlog of safety 12 problems exist. Many of them have not yet had root cause 13 analyses performed, but less conclusions reached and 14 bottom-line causes identified. Documentation also 15 contains instances noted by NRC personnel that when OPPD 16 conducts root cause analyses, they are less than 17 adequate.
18 Of the long-standing violations, I want to 19 focus first on the inadequate fire protection at Fort 20 Calhoun and the catastrophic fire that occurred June 7, 21 2011. Before I get into this, I need to note for you that 22 two references related to the fire were inadvertently 23 omitted from your summary. Immediately after the 24 hearing, I'll email those references to Ms. Wilkins for 25 distribution to all of you if that will be acceptable?
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25 1 MS. WILKINS: Yes, that will be acceptable.
2 CO-PETITIONER MOORER: That is? All 3 right, thank you.
4 To begin from a more long-term perspective, 5 Fort Calhoun Station has had inadequate fire protection 6 procedures since November 1997. This is noted in a 7 triennial fire inspection report, dated June 13, 2012.
8 That's included on your summary. That's 14 and a half 9 years that fire protection procedures at Fort Calhoun 10 have not been adequate.
11 Then, moving to the specifics leading up to 12 the fire, when the NRC issued its red significance 13 determination process finding and Notice of Violation on 14 April 10th of this year, the NRC, noted among other 15 things, that from May 2008 to June 2011 or for about three 16 years, Fort Calhoun failed to ensure that its preventive 17 maintenance program for the safety-related 480 back 18 electrical power distribution system was adequate to 19 ensure proper cleaning of conductors, proper torquing of 20 voltage conductor or bus bar connections, and adequate 21 inspection guidance for abnormal connection 22 temperatures.
23 According to the latest documentation, 24 there were in addition to failure to maintain and inspect 25 all provisions of the approved fire protection program, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 at least two contributing causes for the breaker fire 2 that resulted in a loss of power, the six of nine 3 safety-related 480 back buses, two of four 4 safety-related 4160 back buses, and the resulting 5 declaration of an alert on June 7, 2011.
6 Even though the extent of the fire damage 7 obliterated evidence needed to identify the precise 8 cause of the fire, the following two contributing causes 9 were identified. First, OPPD put in poorly-fitting 10 replacement parts. When it installed 12 new 480 back 11 load center breakers in 2009, OPPD failed to make sure 12 that the cradle assemblies as adapted to fit into the 13 older fixture bus cars fit properly and had a low 14 resistance connection.
15 A second contributing cause is OPPD's 16 inadequate inspection and cleaning of the conductors.
17 Among other things, the employees only inspected what was 18 readily accessible in the breaker cubicle and ignored the 19 areas that were hard to get to. They also only cleaned 20 the silver surfaces and ignored the copper surfaces which 21 allowed hardened grease and copper oxide to build up 22 which increased resistance of the electrical 23 connections.
24 A third opportunity missed to avoid the fire 25 was the failure of employees for three days prior to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 fire to adequately investigate an acrid odor in the west 2 switch gear room. The NRC special investigation report 3 notes that a proper investigation may have prevented the 4 fire. This report noted that the fire event resulted in 5 the loss of cooling for the spent fuel pool and also noted 6 that if the reactor had been at power, it could have 7 resulted in multiple failures in systems used to mitigate 8 an event.
9 Thus, OPPD could have prevented this 10 catastrophic fire in at least three ways. First, 11 adequate investigation of the acrid odor. Second, 12 installation of a breaker bus assembly that adequately 13 fit. Or third, an adequate maintenance program that 14 included inspecting the areas that were hard to get to.
15 As alluded to earlier, cooling of the spent 16 fuel pool was lost during this fire event for almost two 17 and a half hours because two breakers failed. The first 18 was destroyed by the fire. The second breaker intended 19 to provide independent redundancy also failed. Initial 20 analysis concluded that smoke and soot from the fire in 21 the first breaker caused the second breaker to trip.
22 However, more recent cause analysis reported by OPPD, May 23 24, 2012, concludes that the second circuit breaker and 24 cradle assembly had a wired jumper error which caused the 25 breaker to open.
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28 1 OPPD's report says the breaker had a feature 2 called a zone-selective interlock that should have been 3 disabled when received at Fort Calhoun. But that both 4 on inspection upon receipt and post-modification testing 5 failed to identify the wired jumper error. Thus, OPPD 6 failed five opportunities to prevent loss of spent fuel 7 cooling.
8 The three ways the fire could have been 9 prevented mentioned a moment ago, thus protecting the 10 first breaker from tripping. With respect to the second 11 breaker, discovering the wire jumper error either 12 through adequate inspection upon receipt or adequate 13 post-modification testing. Bottom line, OPPD failed 14 every one of these five opportunities resulting in the 15 breaker fire and two and a half loss of cooling for the 16 spent fuel pool. This is a clear example of OPPD's poor 17 decision making and deep-seated cluelessness in 18 operating Fort Calhoun Station that has led to unsafe 19 operation of the reactor.
20 It should also be noted that NRC inspectors 21 have identified problems in OPPD's repair activities 22 subsequent to the fire related to the electrical 23 equipment.
24 Now I'll discuss in less detail several of 25 Fort Calhoun's other long-standing problems. Fort NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 Calhoun Station has more than 530 primary containment 2 electrical penetrations that may not provide an adequate 3 seal during worst-case design basis accident conditions 4 as required. This is noted on your summary at July 18, 5 2012. These 530-plus penetrations first reported May 1, 6 2012, have existed since the plant was built. Fort 7 Calhoun began operation in 1973, thus, these 8 penetrations have remained undiscovered and unaddressed 9 for at least 39 years.
10 OPPD reported that during operating mode 11 under conditions of high radiation and high temperature, 12 the electric penetration seals which are Teflon could 13 degrade during a design-basis accident. After its 14 initial report, OPPD reported that under accident 15 testing, the Teflon field failed and water was noted 16 leaking from these penetrations. It also noted that 17 when the Teflon seal failed following a loss of coolant 18 accident, the highly-radioactive material, including 19 gas, could come into direct contact with outboard seals.
20 An update reported that penetrations are 21 also associated with the containment sump recirculation 22 isolation valve and the personnel airlock. OPPD says 23 it's continuing to investigate the extent of this 24 condition which has existed for at least 39 years at the 25 plant.
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30 1 Mr. Taylor detailed some of Fort Calhoun's 2 many deficiencies regarding flood protection which are 3 also long standing. I'll mention two that have existed 4 the longest. Looking at the item on your summary at 5 December 30, 2009, you can see that for 36 years OPPD 6 failed to have adequate procedures ensuring safe 7 shutdown at the probable maximum flood elevation at 8 1009.3 feet mean sea level. The notation on your summary 9 at October 6, 2010 shows that since 1978 or for about 32 10 years, OPPD has not maintained, as required, written 11 procedures for combating a significant external flood 12 related to the auxiliary building an intake structure.
13 As noted in your summary at March 1, 2012, 14 there are an unspecified number of unsealed through-wall 15 penetrations in various areas at Fort Calhoun through 16 which flood waters could seep or flow. These 17 penetrations which were created during installation of 18 the original plant security system were abandoned and 19 left unsealed in approximately 1985 when the security 20 system was replaced. Some of these penetrations that 21 have existed at Fort Calhoun for about 27 years were found 22 in rooms that housed safety-related electrical switch 23 gear.
24 In February of this year, OPPD identified 25 a problem noted in your summary at June 1, 2012 that has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 existed for about 22 years at Fort Calhoun. In this 2 case, the emergency diesel generator fuel oil transfer 3 pump had not been tested in accordance with the 4 requirements of technical specifications.
5 Consequently, the generators cannot be considered 6 operable.
7 As noted in your summary at August 12, 2008, 8 NRC inspectors noted that OPPD from 1990 to 2008 or for 9 about 18 years had failed to take adequate corrective 10 measures to address the potential that containment spray 11 pumps may run out and possibly fail. As noted in your 12 summary at December 30, 2009, NRC inspectors noted OPPD's 13 violation of failing from February 1992 to September 8, 14 2009 or for about 17 years, to adequately evaluate the 15 seismic qualification of the raw water pumps to ensure 16 that the pumps' anchor bolts embedded in the floor would 17 meet seismic Class 1 standards.
18 OPPD has for almost 14 years experienced a 19 significant amount of water intrusion into manholes 20 containing 41.60 bolt[4160 volt] cables at Fort Calhoun, 21 as noted in your summary at March 16, 2012. Yet, 22 according to NRC inspectors, OPPD has failed to address 23 this problem appropriately. From 2005 until 2011 or for 24 about six years, OPPD chose to postpone corrective 25 actions and failed to appropriately monitor water NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 intrusion into underground ducts and Manholes 5 and 31 2 for raw water, 41.80[4160] volt motor cables multiple 3 times. Even though OPPD has been aware for at least 16 4 months of almost 5.5 feet of water in Manhole 5, it failed 5 to perform any work to develop a permanent solution for 6 dewatering manholes that contain Maintenance Rule 7 cables.
8 There are numerous other examples of OPPD's 9 long-standing problems at Fort Calhoun, but there isn't 10 time to mention any more now. But in sum, the examples 11 of long-standing problems I've just mentioned are 12 problems OPPD either knew about or should have known 13 about. At this point, OPPD has not demonstrated the 14 requisite competence to assure that its safety problems, 15 long-standing or otherwise, will not continue at Fort 16 Calhoun.
17 I want to close by briefly addressing OPPD's 18 recent publicly stated plan to contract Exelon to manage 19 Fort Calhoun. This plan does not remove or temper our 20 concerns about OPPD's long history of poor decision 21 making and deep-seated cluelessness in operating Fort 22 Calhoun. We will address Exelon's operating record at 23 an additional hearing, but for now I want to mention two 24 things. First, as far as I know, OPPD hasn't actually 25 contracted with Exelon to manage Fort Calhoun day to day.
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33 1 At most, it has merely stated an intent to do so.
2 Second, OPPD, which in any event will remain 3 the owner and licensed operator, has announced that no 4 OPPD staff members will lose their job, that there will 5 be no housecleaning of Fort Calhoun's staff if Exelon 6 manages the reactor.
7 And I just wanted to clarify something that 8 Mr. Taylor said. He mentioned that the acknowledgement 9 by Mr. Green relates to OPPD's incapability to operate 10 Fort Calhoun. You should know that Mr. Green is the 11 Chair of the OPPD Board and as such, his views represent 12 those of the Board as a whole. And this Board is the 13 entity that is ultimately responsible for OPPD which is 14 the licensee of Fort Calhoun. So it's a public 15 acknowledgement by OPPD Board that they're not capable 16 of operating Fort Calhoun on their own.
17 That concludes my prepared remarks.
18 CHAIR McGINTY: Okay, thank you. This is 19 Tim McGinty, the PRB chair. Thank you both, Mr. Taylor 20 and Ms. Moorer.
21 Mr. Taylor, you had mentioned that you may 22 have like an opportunity after Ms. Moorer was complete 23 to add a couple of remarks?
24 PETITIONER TAYLOR: Yes, thank you. I 25 just wanted to emphasize and clarify that this petition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 is not about just one problem or just one incident. If 2 that were the case, we probably would not have filed this.
3 But as you've seen throughout here, this is about an 4 entire history of inability and unwillingness by OPPD to 5 operate Fort Calhoun properly. And so I just want to 6 emphasize that this is not like a lot of petitions you 7 might see where there's just one incident that brings it 8 about. This is really about the bare 9 ability to operate the plant and as shown by their long 10 history.
11 I guess I would also like maybe in your wrap 12 up to find out exactly what the process is for following 13 up, particularly with a further hearing regarding the 14 Exelon matter.
15 Thank you.
16 CHAIR McGINTY: Okay.
17 MS. RUSSELL: Hi, this is Andrea Russell 18 the 2.206 Coordinator. After this meeting, we will be 19 awaiting the transcript. It will be made publicly 20 available and then we'll be planning an internal PRB 21 meeting to make our initial recommendation. Once we 22 make that initial recommendation, you will be notified 23 as the Petitioner and will be offered a second 24 opportunity to address us.
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35 1 would bring up the Exelon matter then?
2 MS. RUSSELL: Correct, and you can always 3 file a supplement.
4 PETITIONER TAYLOR: Okay.
5 MS. RUSSELL: In hard copy form through the 6 EDO or directly to Lynnea and that can be entered into 7 our ticket process and be added to this as a supplement.
8 PETITIONER TAYLOR: Thank you. The reason 9 we haven't done that is this is a very recent occurrence 10 and so we haven't really had time to investigate it 11 thoroughly enough to feel comfortable filing anything.
12 CHAIR McGINTY: That's fine, Mr. Taylor.
13 This is Tim McGinty again. And by the same token, we'll 14 continue on with our process regarding the information 15 that's been both filed and presented today. And you'll 16 have an opportunity to either supplement or further 17 address the PRB another time.
18 PETITIONER TAYLOR: All right, thank you.
19 CHAIR McGINTY: Is that fair?
20 PETITIONER TAYLOR: Yes, and the record 21 will include the summary that we submitted to you and the 22 documents referenced therein?
23 MS. WILKINS: Yes, it's already been added 24 to the package.
25 PETITIONER TAYLOR: Thank you.
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36 1 CHAIR McGINTY: Okay, thanks. So this is 2 Tim McGinty again. So at this point I'd like to ask if 3 any of the staff that are here at headquarters for the 4 NRC have any questions of either Mr. Taylor or Ms. Moorer?
5 So I'm looking around the room and you've 6 provided a lot of information and it's very clearly 7 depicted. I'm getting a unanimous "I don't have any 8 additional questions from this portion of our audience" 9 here at the NRC.
10 I'd like to ask about folks that are out in 11 the region, in the region, whether they have any 12 questions of either Mr. Taylor or Ms. Moorer?
13 MS. DALY: This is Pam Daly. I have a 14 question. Can you hear me?
15 CHAIR McGINTY: Yes. Pam, if you'd be kind 16 enough I'm going to ask for questions from the public in 17 a second. Could you hold, please, on that?
18 MS. DALY: I'm sorry. I thought you were 19 asking that.
20 CHAIR McGINTY: That's perfectly all 21 right. I'm asking for NRC personnel out in the region.
22 I'll get to you in a second.
23 MS. DALY: I'm sorry.
24 CHAIR McGINTY: No problem. Anybody from 25 the region?
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37 1 MR. KIRKLAND: I don't. This is John 2 Kirkland. I do not.
3 CHAIR McGINTY: All right, thanks, John.
4 How about the licensee, do you have any questions?
5 MS. BAUGHN: No questions.
6 CHAIR McGINTY: Okay, so before I conclude 7 the meeting, members of the public may provide comments 8 regarding these petitions and ask questions about the 9 2.206 petition process. However, as stated at the 10 opening, the purpose of this meeting is not to provide 11 an opportunity for the Petitioner or the public to 12 question or examine the PRB regarding the merits of these 13 petition requests.
14 With that said, Ms. Daly, did you have a 15 question?
16 MS. DALY: Yes. I forgot to say before I 17 am a citizen of Washington County and I live very close 18 to the power plant. And I have talked with many people 19 who work there and they feel that a lot of the criticism 20 of the plant is just the Federal Government being 21 difficult and they basically have a cynical attitude.
22 My understanding is that that is a part of the culture 23 of the plant.
24 So when you say -- I'm wondering if you feel 25 in your petition that the culture can be changed by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 keeping the same people there. I'm afraid that it cannot 2 be changed and the staff, major staff who work there would 3 need to be looked at very carefully and not just some 4 supervising staff at top level come in. I don't think 5 they'd be able to change the culture, although I think 6 the culture initially is created by the leaders. I think 7 it's much harder to change it by simply bringing in a 8 different leader. I think you have to change many 9 staff-level positions.
10 Do you believe that as well? This question 11 is for Mr. Taylor.
12 PETITIONER TAYLOR: Thank you. Well, 13 you're right that the culture starts from the top and as 14 Ms. Moorer said, as far as we know right now, there will 15 be no changes as far as the management of OPPD and the 16 management of the plant. Exelon is simply providing 17 day-to-day operational services.
18 But again, we don't know exactly what is in 19 the agreement yet, and we haven't really had a chance to 20 look at that, but you're right that we have discovered 21 here a real culture, like I said, the safe-as-is culture 22 and we just -- from what I have seen from going to all 23 the meetings, and listening to the OPPD folks, I just am 24 not confident that that's going to be changed.
25 MS. DALY: Thank you.
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39 1 CHAIR McGINTY: Okay, and thank you, Ms.
2 Daly.
3 So any other members of the public have any 4 comments that they would like to provide or ask any 5 questions about the 2.206 petition process?
6 All right, with that said, Mr. Taylor, Ms.
7 Moorer, Ms. Daly, we'd like to thank you for taking the 8 time to provide -- actually just Mr. Taylor and Ms.
9 Moorer, thank you for taking the time to provide the staff 10 with clarifying information on the petitions you've 11 submitted.
12 Before we close we typically ask our court 13 reporter whether any additional information for the 14 meeting transcript is needed.
15 COURT REPORTER: This is the court 16 reporter. Do you want to continue on the record?
17 CHAIR McGINTY: Do I want to continue on the 18 record?
19 COURT REPORTER: Do you want to close the 20 record at this point? That is to say do you want this 21 discussion in the transcript?
22 CHAIR McGINTY: Yes, I'm on the verge of 23 concluding the meeting. I just wanted to see if you 24 needed any additional information that would help you 25 provide a clear record.
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40 1 COURT REPORTER: Yes, I do have a few 2 questions. Some of the participants I do not have 3 listed. There was a Mike Markley. I just need a correct 4 spelling for that name?
5 CHAIR McGINTY: Markley, M-A-R-K-L-E-Y.
6 COURT REPORTER: And then from the NRC, a 7 Ms. Rankin?
8 MS. RANKIN: R-A-N-K-I-N.
9 COURT REPORTER: Pamela Daly?
10 MS. DALY: Yes, P-A-M-E-L-A D-A-L-Y, just 11 four letters.
12 COURT REPORTER: Mike Carberry.
13 MR. CARBERRY: C-A-R-B-E-R-R-Y.
14 COURT REPORTER: And Mike Ryan.
15 MR. RYAN: Ryan, R-Y-A-N.
16 COURT REPORTER: Thank you. That's all I 17 have.
18 CHAIR McGINTY: Okay, and thank you.
19 With that said, I appreciate everybody's time and the 20 clarity of the information that you provided. The 21 meeting is concluded and we'll be terminating the phone 22 connections. Thank you.
23 (Whereupon, at 2:56 p.m., the 24 teleconference was concluded.)
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