ML12300A412
| ML12300A412 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 06/14/2012 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Pickett D | |
| References | |
| G20120253, NRC-1678, OEDO-2012-0208, TAC ME8439 | |
| Download: ML12300A412 (30) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board Natural Resources Defense Council RE: Indian Point Nuclear Generating Unit No. 2 Docket Number: 05000247 Location: teleconference Date: Thursday, June 14, 2012 Edited by Douglas Pickett Work Order No.: NRC-1678 Pages 1-30 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 PRESENTATION 6 BY 7 NATURAL RESOURCES DEFENSE COUNCIL, INC.
8 + + + + +
9 THURSDAY 10 JUNE 14, 2012 11 + + + + +
12 The conference call was held, John Lubinski, 13 Chairperson of the Petition Review Board, presiding.
14 15 PETITIONER: NATIONAL RESOURCES DEFENSE COUNCIL 16 17 PETITION REVIEW BOARD MEMBERS 18 JOHN LUBINSKI, Deputy Director 19 Division of Inspection and Regional Support 20 Office of Nuclear Reactor Regulation 21 DOUGLAS PICKETT, Petition Manager for 2.206 petition 22 23 CHRISTOPHER HAIR, Office of General Counsel 24 25 NRC HEADQUARTERS STAFF NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 ANDREA RUSSELL, Petition Coordinator 2 ANHSAN [AHSAN] SALLMAN, Containment and Ventilation 3 Branch, NRR 4 FARHAD FARZAM, Mechanical and Civil Engineering Branch, 5 NRR 6
7 NRC REGION I STAFF 8 BRICE BICKETT 9 LAWRENCE DOERFLEIN 10 11 ON BEHALF OF THE PETITIONER 12 JORDAN WEAVER, Natural Resources Defense Council 13 THOMAS COCHRAN 14 MARK LEYSE, Consultant 15 16 ON BEHALF OF THE LICENSEE 17 STEVE PRUSSMAN, Entergy 18 BILL DENNIS, Entergy 19 20 21 22 23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 P R O C E E D I N G S 2 10:03 a.m.
3 MR. WEAVER: All right. So, my name is 4 Jordan Weaver. I'm with the National Resources Defense 5 Council. And I just wanted to quickly thank the NRC for 6 providing us with the opportunity to speak with the 7 Petition Review Board this morning regarding our 8 petition.
9 MR. PICKETT: Mr. Weaver, if I could 10 interrupt you, we have a script we want to run through 11 first.
12 MR. WEAVER: Sure, no problem.
13 MR. PICKETT: And then we will open the 14 floor for you in a few moments.
15 MR. WEAVER: Sounds great. Sorry about 16 that.
17 MR. PICKETT: No problem. Good morning.
18 My name is Doug Pickett. I'd like to welcome everybody 19 here. I am the Indian Point Project Manager. We are 20 here today to allow the petitioner, Mr. Jordan Weaver, 21 of the National Resources Defense Council, assisted by 22 Mr. Mark Leyse. The Petition Review Board also referred 23 to as PRB -
24 MR. WEAVER [LUBINSKI]: If we could ask, 25 when people are not speaking, if they could put their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 phone on mute.
2 MR. PICKETT: Okay, we'll start again.
3 I'd like to thank everybody for attending this meeting.
4 My name is Doug Pickett, and I am the Indian Point Project 5 Manager. We are here today to allow the petitioner, Mr.
6 Jordan Weaver, of the National Resources Defense 7 Council, assisted by Mr. Mark Leyse, to address the 8 Petition Review Board, also referred to as the PRB, 9 regarding the 2.206 petition dated April 16, 2012.
10 I am the Petition Manager for the petition.
11 The PRB chairman is Mr. John Lubinski. As part of the 12 PRB's review of this petition, Jordan Weaver has 13 requested this opportunity to address the PRB. This 14 meeting is scheduled from 10 to 11 a.m. eastern time.
15 The meeting is being recorded by the NRC Operations 16 Center, and will be transcribed by a court reporter. The 17 transcript will become a supplement to the petition.
18 The transcript will also be made publicly available.
19 I'd like to open this meeting with 20 introductions. As we go around the room here in 21 headquarters, please be sure to clearly state your name, 22 your position, and the office that you work for within 23 the NRC, for the record. I'll start with myself, Douglas 24 Pickett. I'm the Indian Point Project Manager in the 25 Office of Nuclear Reactor Regulations, and I'm also the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5 1 Petition Manager.
2 MR. SALLMAN: My name is Ahsan Sallman. I 3 am the [a] Reactor Systems Engineer in the Containment 4 and Ventilation Branch, in the Office of Nuclear Reactor 5 Regulations.
6 MR. HAIR: I'm Christopher Hair from the 7 Office of General Council.
8 MS. RUSSELL: Andrea Russell, 2.206 9 Coordinator for the NRC.
10 CHAIR LUBINSKI: John Lubinski. I'm the 11 Deputy Director of the Division of Inspection and 12 Regional Support, and I will serve as the chair for this 13 petition review board.
14 MR. PICKETT: We've completed the 15 introductions of the NRC Headquarters. At this time, 16 are there any NRC participants from Headquarters on the 17 phone?
18 MR. FARZAM: Yes, this is Farhad Farzam.
19 I'm a Senior Structural Engineer, Mechanical and Civil 20 Engineering Branch, Office of Nuclear Reactor 21 Regulations.
22 MR. PICKETT: Are there any NRC 23 participants from the regional office on the phone?
24 MR. DOERFLEIN: Yes, this is Larry 25 Doerflein. I'm Chief Engineering Branch 2, in NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 Region 1.
2 MR. BICKETT: And this is Brice Bickett, 3 NRC Region 1, Senior Project Engineer for Branch 2.
4 MR. PICKETT: Are there any 5 representatives for the licensee on the phone?
6 MR. PRUSSMAN: Steve Prussman, Entergy.
7 MR. DENNIS: Bill Dennis, Entergy.
8 MR. PICKETT: Mr. Weaver, would you please 9 introduce yourself, and anyone assisting you, for the 10 record?
11 MR. WEAVER: Yes, my name is Jordan Weaver.
12 I am a Nuclear Program Scientist at the Natural Resources 13 Defense Council. And with me, I have Dr. Tom Cochran, 14 who is also a scientist at the Natural Resources Defense 15 Council. And I believe also on the line is Mark Leyse, 16 who I'll let introduce himself.
17 MR. LEYSE: Sure. Mark Leyse.
18 MR. PICKETT: All right, thank you. It is 19 not required for members of the public to introduce 20 themselves for this call. However, if there are any 21 members of the public on the phone that wish to do so at 22 this time, please state your name for the record. The 23 hearing then will go on.
24 I'd like to emphasize that we each need to 25 speak clearly and loudly, to make sure that the court NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 reporter can accurately transcribe this meeting. If you 2 do have something that you would like to say, please first 3 state your name for the record.
4 For those dialing in to the meeting, please 5 remember to mute your phones to minimize any background 6 noise or distractions. If you do not have a mute button, 7 this can be done by pressing the keys *6. To unmute, 8 press *6 keys again. Thank you.
9 At this time, I'll turn it over to the PRB 10 Chairman, John Lubinski.
11 CHAIR LUBINSKI: Good morning. Welcome to 12 this meeting regarding the 2.206 petition submitted by 13 Mr. Weaver of the National Resources Defense Council.
14 I'd like to first share some background on our process.
15 Section 2.206 of Title 10 of the Code of Federal 16 Regulations describes the petition process - the primary 17 mechanism for the public to request enforcement action 18 by the NRC in a public process. This 19 process permits anyone to petition the NRC to take 20 enforcement-type action related to NRC licensees or 21 licensed activities. Depending on the results of its 22 evaluation, NRC could modify, suspend or revoke an 23 NRC-issued license, or take any other appropriate 24 enforcement action to resolve a problem. The NRC 25 staff's guidance for the disposition of 2.206 petition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 requests is in Management Directive 8.1[8.11], which is 2 publicly available.
3 The purpose of today's meeting is to give 4 the petitioner an opportunity to provide additional 5 explanation or support for the petition before the 6 Petition Review Board's initial consideration and 7 recommendation.
8 This meeting is not a hearing, not [nor]is 9 it an opportunity for the petitioner to question or 10 examine the PRB on the merits or the issues presented in 11 the petitioner request. No decisions regarding the 12 merits of the petition will be made at this meeting.
13 Following this meeting, the Petition Review 14 Board will conduct its internal deliberations. The 15 outcome of this internal meeting will be discussed with 16 the petitioner.
17 The Petition Review Board typically 18 consists of a Chairman, usually a manager at the senior 19 executive service level at the NRC. It has a Petition 20 Manager and a PRB Coordinator. Other members of the 21 Board are determined by the NRC staff based on the content 22 of the information in the petition request. At this 23 time, I would like to introduce the Board.
24 I am John Lubinski, the Petition Review 25 Board Chairman. Doug Pickett is the Petition Manager NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 for the petition under discussion today. Andrea Russell 2 is the office's PRB Coordinator.
3 Our technical staff includes: Ahsan Sallman 4 of NRR's Containment and Ventilation Branch, Farhad 5 Farzam from NRR's Mechanical and Civil Engineering 6 Branch, and Brice Bickett and Larry Doerflein from NRC's 7 Region 1 Office. We also obtain advice from our Office 8 of General Counsel, represented today by Chris Hair.
9 As described in our process, the NRC staff 10 may ask clarifying questions in order to better 11 understand the petitioner's presentation, and to reach 12 a reasoned decision whether to accept or reject the 13 petitioner's requests for review under the 2.206 14 process.
15 I would like to summarize the scope of the 16 petition under consideration, and the NRC activities to 17 date. On April 16, 2012, Mr. Weaver submitted to the NRC 18 a petition, prepared by Mr. Leyse, acting as a consultant 19 to the Natural Resources Defense Council, under 2.206, 20 regarding the use of passive autocatalytic recombiners, 21 hereafter referred to as PARs, at the Indian Point 22 Nuclear Generating Unit 2.
23 In this petition, Mr. Leyse requests that 24 the NRC order the licensee of Indian Point Unit 2 to 25 remove the PAR system from the reactor containment, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 because the PAR system could have unintended ignitions 2 in the event of a severe accident which, in turn, could 3 cause a hydrogen detonation and ultimate failure of the 4 reactor containment structure.
5 As the basis for this request, the 6 petitioner describes the PAR system as simple devices 7 consisting of catalyst surfaces arranged in an 8 open-ended enclosure. In the presence of hydrogen, a 9 catalytic reaction occurs spontaneously with oxygen at 10 the catalyst surface. PARs do not need external power 11 or operator action to function, and once installed, they 12 cannot be stopped or turned off by control room operators 13 following an accident.
14 The petitioner does not question the use of 15 the PAR system during the design basis accident.
16 However, the petitioner believes that the nearby Ramapo 17 seismic zone could create a seismic event that exceeds 18 the Indian Point design, thus inducing a severe reactor 19 accident.
20 Once a severe reactor accident occurs, the 21 petitioner believes that the PAR system will be 22 overwhelmed by local concentrations of hydrogen gas, and 23 effectively become ignition sources leading to the 24 hydrogen detonation as described above.
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11 1 date. On April 17, 2012, the petition manager contacted 2 the petitioner to discuss the 10 CFR 2.206 process, and 3 to offer the petitioner an opportunity to address the PRB 4 by phone or in person. The petitioner requested to 5 address the PRB by phone prior to its initial meeting to 6 make the initial recommendation to accept or reject the 7 petition for review.
8 As a reminder for the phone participants, 9 please identify yourself if you make any remarks, as this 10 will help us in the preparation of the meeting transcript 11 that will be made publicly available. Thank you. At 12 this point, Mr. Weaver, I would like to turn the meeting 13 over to you and Mr. Leyse, to provide any information you 14 believe the PRB should consider as part of this petition.
15 MR. WEAVER: Thank you. And I want to 16 thank, generally, the NRC for providing us with the 17 opportunity to speak today. So, just a little 18 background, for over a year now, NRDC's nuclear program 19 has become increasing involved with the assessment of 20 reactor safety, especially as it pertains to severe 21 accident mitigation, and the plans of associated safety 22 systems.
23 We believe this petition highlights the 24 vulnerability in the passive autocatalytic recombiner 25 system, or PAR system, currently installed in Indian NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 Point Unit 2. The petition describes the problem 2 thoroughly, and sites[cites] numerous studies that have 3 analyzed the behavior of PAR systems in a range of 4 environments and scenarios.
5 And of a particular concern, is that which 6 is the result of a design basis accident or severe 7 accident, and how the transition into this environment 8 plays the risk of the PAR system, being its ability to 9 mitigate any possible quantities of hydrogen produced.
10 NRC [NRDC] consultant Mark Leyse is a 11 principal researcher and author of this petition, and so 12 at this time, I will turn it over to Mr. Leyse to provide 13 the remainder of our comments. And if there are any 14 questions, either now or at the end, I'm more than happy 15 to answer them. Thank you.
16 CHAIR LUBINSKI: Okay, thank you, Mr.
17 Weaver. Mr. Leyse?
18 MR. LEYSE: Sorry, Mark Leyse speaking. I 19 forgot that I was on mute there. Sorry about that. You 20 can hear me now?
21 CHAIR LUBINSKI: Yes, we can, thank you.
22 MR. LEYSE: Okay, great, thanks. Okay.
23 First, I'd like to cover some of the points that have been 24 made in the petition. On pages six and seven, there is 25 information about the fact that passive autocatalytic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 recombiners, which I will now call PARs, would operate 2 automatically.
3 You covered this in your introduction, but 4 just to reiterate, they would commence operation when 5 there was enough hydrogen and oxygen available, and then 6 there would be a reaction on their catalytic surfaces, 7 and they would commence operation without operator 8 action. And so, Unit Number 2 operators would not be 9 able to turn PARs off, or stop PARs from operating.
10 Now, Unit 3, as is mentioned in the 11 petition, has electrical-powered thermal recombiners.
12 So, that is not a problem with the Unit Number 3. Okay, 13 now on page 10 of the petition, there is a quote from -
14 CHAIR LUBINSKI: Excuse me, Mr. Leyse?
15 MR. LEYSE: Yes?
16 CHAIR LUBINSKI: Would you like us to ask 17 questions along the way, or -
18 MR. LEYSE: Feel free to, please.
19 CHAIR LUBINSKI: Okay, can you just clarify 20 please, for me, when you say that it is not an issue for 21 Unit 3, your position on why it's not?
22 MR. LEYSE: Oh, of course. Basically, 23 Unit 3 has two electrically-powered thermal hydrogen 24 recombiners. It's a different type of recombiner than 25 the passive autocatalytic recombiners that are in Unit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 2. And so, the thermal hydrogen recombiners that are in 2 Unit 3, which actually used to be in Unit 2, operators 3 would be able to control the operation of those two 4 electrically-powered thermal hydrogen recombiners, of 5 course if they were functioning properly.
6 But, the important thing is that if they 7 weren't functioning properly, they wouldn't even be able 8 to be actuated, and that's the problem that we have, is 9 with the PAR system that's in Unit 2, it does not need 10 any electrical power, so it's something that cannot be 11 shut off if a detonable concentration of hydrogen were 12 to build up in Unit 2's containment. So, that's the 13 problem we have with that.
14 CHAIR LUBINSKI: Thank you for that 15 clarification.
16 MR. LEYSE: You're welcome. Okay, just to 17 continue, I'm just going through and highlighting 18 certain things in the petition. On page 10 of the 19 petition, there's a quote from an OECD Nuclear Energy 20 Agency report from 2000. It states that quote, "A rapid 21 initial hydrogen source occurs in practically all severe 22 accident scenarios, because of the large chemical heat 23 release of the zirconium steam reaction, that it causes 24 a fast self-accelerating temperature excursion, which 25 initially large surfaces and masses of reaction partners NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 are available."
2 So, basically, in the event of a severe 3 accident also, if there were a scenario in which there 4 was the reflooding of an overheated core, up to 300 5 kilograms of hydrogen could be produced in 1 minute, and 6 that's information from a Nuclear Engineering and Design 7 paper from 2003. That's on page 10.
8 And also on page 10, it states that the 9 hydrogen removal capacity for each PAR unit is several 10 grams per second of hydrogen. So clearly, Unit 2's two 11 PAR units would not be able to handle the quantity of 12 hydrogen that could be produced in a severe accident, 13 within a time frame that would prevent the buildup of 14 hydrogen to concentrations at which there could be either 15 a deflagration or detonation.
16 They would be completely overwhelmed by the 17 quantity of hydrogen produced in a severe accident. So, 18 that's something that, you know, clearly they could help 19 in a design-basis accident, but in a severe accident, 20 they're not going to be effective. So, that's one of the 21 main points that we're making.
22 And then, pages 14 to 16 of the petition, 23 there's information about the fact that PARs have had 24 unintended ignitions in three different experimental 25 investigations. On page 15, there's a quote from a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 Nuclear Engineering and Design paper from 2004, which 2 states that during the operation of PARs, "at a hydrogen 3 concentration of 4 percent volume, maximum temperatures 4 reach the ignition limits, which according to reports is 5 in region of about 560 degrees Celsius, or 1,040 degrees 6 Fahrenheit. Any further increase in the inlet hydrogen 7 concentration would lead to catalyst temperatures above 8 the ignition limit, and hence increase the risk of an 9 unintended ignition."
10 And on pages 16 and 17 of the petition, there 11 are quotes from recent reports that have discussed the 12 fact that PARs behave like igniters in elevated 13 concentrations. So, that would be the type of 14 concentrations one would expect to have in the event of 15 a severe accident.
16 On pages 18 and 19 of the petition, there 17 is information about the fact that, "An unintended 18 ignition of a PAR unit could cause a hydrogen detonation, 19 in the event of a severe accident." That's a quote from 20 a Nuclear Engineering and Design paper from 2003.
21 Clearly, safety issues regarding igniters 22 pertain to PARs, because PARs would be likely to have 23 unintended ignitions, and behave like igniters in the 24 event of a severe accident.
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17 1 quotes from recent reports that have questioned the 2 safety of using igniters to mitigate hydrogen at certain 3 times in some severe accident scenarios, or without 4 having conducted a thorough safety analysis with 5 computer codes.
6 So, basically, that's the highlights of 7 some of the things - information that is in the petition, 8 and the reason why NRDC has submitted this petition 9 requested that the two passive autocatalytic recombiners 10 be removed from Unit number 2.
11 And now, I'd like to make a suggestion for 12 Entergy, and in this, I'm going to reiterate some of the 13 information I said in answering your question earlier.
14 Basically, if Entergy would really like to have two 15 hydrogen recombiner units at Indian Point Unit number 2, 16 to handle the quantity of hydrogen that would be produced 17 in a design-basis accident, NRDC has no objection to 18 that.
19 We would - I should say, NRDC, again I am 20 a consultant for them - So, NRDC would recommend that 21 Entergy replace Indian Point Unit 2's two passive 22 autocatalytic recombiners with two electrically powered 23 thermal hydrogen recombiners, which is the type of 24 recombiners that are currently in Indian Point Unit 3, 25 and used to be in Unit 2.
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18 1 In the event of a severe accident, operators 2 would be able to control the operation of the two 3 electrically powered thermal hydrogen recombiners, if 4 they were functioning properly. But, the main thing is, 5 if they were not functioning properly, they would not be 6 able to be actuated, which obviously, the PARs would turn 7 on once a high enough concentration of hydrogen 8 developed, and they would not be able to be shut off.
9 So, operators would be able to turn off 10 electrically powered thermal hydrogen recombiners if an 11 accident transitioned into a severe accident, in which 12 there would be higher hydrogen concentrations. This is 13 important, because thermal hydrogen recombiners are also 14 prone to ignitions in the elevated hydrogen 15 concentrations which would occur in severe accidents.
16 On this issue, a Sandia National 17 Laboratories report, the title is Light Water Reactor 18 Hydrogen Manual states that thermal recombiners, "Use is 19 limited to containment atmospheres, that are not within 20 the flammability limits," and that, "Thermal recombiners 21 could be an ignition source for a flammable mixture in 22 the containment."
23 Additionally, in a 2011 IAEA report, this 24 is the title: Mitigation of Hydrogen Hazards in Severe 25 Accidents in Nuclear Power Plants states, "Below a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 hydrogen concentration of about 4 percent, thermal 2 recombiners may be used to reduce the hydrogen 3 concentration. Above this value, they can act as 4 igniters. Hence, their use is then only allowed if 5 ignition is allowed. Care is needed in using thermal 6 recombiners, as they may be damaged by the burn, and cause 7 radioactive releases."
8 It is clear that Entergy should not use the 9 two electrically powered thermal hydrogen recombiners in 10 the Unit 3 containment in the event of a severe accident.
11 I'm kind of going a bit off topic now, but just real 12 quickly. The same would apply, of course, if Entergy did 13 indeed decide to put those units back into Indian Point 14 Unit 2's containment.
15 But, it's clear that the NRC needs to 16 regulate severe accident training, so that plant 17 operators would be instructed to not run thermal hydrogen 18 recombiners in the event of a severe accident.
19 So, again, I just want to reiterate, if 20 Entergy really wants to have two hydrogen recombiners at 21 Indian Point Unit 2 to handle the quantity of hydrogen 22 that would be produced in a design-basis accident, NRDC 23 would recommend that Entergy replace Unit 2's two passive 24 autocatalytic recombiners with two electrically powered 25 thermal hydrogen recombiners, because operators would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 not be able to control the operation of passive 2 autocatalytic recombiners in a severe accident. And as 3 covered in the petition, they are prone to ignitions 4 which could, in turn, cause a detonation. Thank you, and 5 I would be happy to answer any more questions that you 6 may have.
7 CHAIR LUBINSKI: Thank you, Mr. Leyse.
8 Again, this is John Lubinski. And I'm going to start 9 with a couple questions here from NRC Headquarters, and 10 then go around the table here, and go around to all the 11 NRC folks to ask any clarifying questions.
12 Either Mr. Weaver, or Mr. Leyse, on page 5 13 of your petition, you state why you believe this is 14 applicable to Indian Point Unit 2. You have clarified 15 why it's not applicable to Indian Point Unit 3. Can I 16 ask you to clarify why you believe this is applicable to 17 Indian Point Unit 2, and not other nuclear power plants 18 that may use PARs?
19 MR. LEYSE: First, this is Mark Leyse 20 speaking. I would first like to give Jordan Weaver the 21 opportunity to answer this if he would like. Otherwise, 22 I'd be happy to answer that question.
23 MR. WEAVER: At the moment we don't have the 24 necessary information to kind of make that judgment with 25 regard to other plants. The issue was brought to us by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 Mr. Leyse that there was kind of a disparity between the 2 two units.
3 And so, the installation of PARs at the 4 level which they're currently installed, which is only 5 two units, implies that this would only be able to handle 6 the hydrogen during a design-basis accident, as Mr. Leyse 7 pointed out.
8 So, as to where it would apply to other 9 plants, if there are indeed other plants that employ the 10 use of passive autocatalytic recombiners in such a small 11 number that they're only qualified for a design-basis 12 accident, and the other mitigating measures don't apply, 13 that they would be able to handle the hydrogen produced 14 in a severe accident, then I suppose I could be possible 15 that it would apply to that plant. But, at this moment, 16 we didn't have the information to make that judgement.
17 CHAIR LUBINSKI: Thank you, Mr. Weaver.
18 MR. LEYSE: Mark Leyse speaking. Are 19 there other plants that you could list that have PAR units 20 that are licensed by the NRC?
21 CHAIR LUBINSKI: You're asking that 22 question of us?
23 MR. LEYSE: Yes.
24 CHAIR LUBINSKI: And that's where I'm 25 asking for a clarification from the standpoint of, this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 is our initial review, and looking at the scope of your 2 petition, you've made specific reasons why you felt it 3 was specific to Indian Point Unit 2.
4 So, I'm just asking for that clarification, 5 of whether you're asking it just because that's the only 6 plant you have knowledge of, of having PARs, or are you 7 saying that any plant that has PARs, this would have the 8 same - because when I read page five, I read it to be plant 9 specific because of the population around Indian Point, 10 as well as the seismic zone around Indian Point.
11 MR. LEYSE: Right, that is definitely - it 12 is definitely plant specific for those reasons, because 13 of the location of Indian Point, and also the high 14 population density. So, there are many unique aspects 15 of Indian Point.
16 I just want to point out that the PARs that 17 were placed in Unit Number 2, were placed there in, I 18 believe, in the late `90s, and maybe even in 2000, but 19 I believe it was the late `90s. And in 2003, the NRC, 20 they got rid of the regulation that would require a 21 pressurized water reactor containment to have recombiner 22 units.
23 So, most pressurized water reactor 24 containments that still have hydrogen recombiners, have 25 the electrically powered thermal hydrogen recombiners.
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23 1 They have the older type of system installed, just as Unit 2 3 still has.
3 So, I think because, I know for a fact that 4 Unit Number 2 was the first American plant, or first plant 5 licensed by the NRC to have PAR units installed. And so 6 - and even before 2003, there was information available 7 to licensees that they were going to most likely stop 8 requiring hydrogen recombiners to be in containment 9 buildings.
10 So, there - it is quite possible that Unit 11 Number 2 is actually the only containment building by a 12 plant that is licensed by the NRC that has PAR units.
13 Now, it's also possible that there could be other plants 14 that have it, but as I say, the regulation was - it was 15 revoked in 2003, and prior to that, there was information 16 available that they were not going to require hydrogen 17 recombiner units anymore.
18 So, that - if indeed Unit Number 2 is the 19 only plant that has PAR units, that certainly think 20 that's plant specific. If not, if you want to say unit 21 specific, since Unit 3 does [not] have the PAR units.
22 CHAIR LUBINSKI: Thank you, Mr. Leyse, 23 appreciate it. What I'd like to do now, is go around the 24 room here at Headquarters, to see if anyone here in the 25 room has additional questions.
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24 1 MR. PICKETT: This is Doug Pickett. Mr.
2 Leyse, I'd like to say the Board here is not aware of other 3 plants with PAR systems. Are you aware of any plants in 4 the country that have the PAR system, other than Indian 5 Point 2?
6 MR. LEYSE: No, I am not. And as I just 7 said, it's possible that there are none besides Unit 8 Number 2, for the reasons I just gave.
9 MR. PICKETT: Thank you.
10 CHAIR LUBINSKI: Did you have other 11 questions, Doug?
12 MR. PICKETT: I guess I just wanted to 13 clarify your statements about the design-basis accident 14 versus severe accident. Reading the petition, it came 15 across to me that you did not have concerns about the 16 design-basis accident, which we (inaudible 10:36:02).
17 I wanted to clarify that.
18 MR. LEYSE: Okay, Mark Leyse, I'll answer 19 that. Yes, I believe that just - there is information, 20 I think it's in the petition, regarding the quantity of 21 hydrogen that would be produced in the event of a 22 design-basis accident, and that is the - yes, on page 8, 23 there is information about the quantity or the generation 24 rate of hydrogen that could be produced in a design-basis 25 accident. And that is from .001 to .05 of a kilogram per NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 second.
2 So, that is a - the type of generation rate 3 that a PAR unit, which has the capacity of several grams 4 per second, could handle. So, we're talking about a 5 situation where the PAR unit, it's a very reasonable 6 device for handling the type of hydrogen generation that 7 could occur in a design-basis accident.
8 However, we do have some additional 9 information that just says that there can be some other 10 - you know, it's a very complex issue, and that is also 11 discussed on page eight and nine of the petition.
12 So, that's why we have made the - NRDC has 13 made the recommendation of replacing the PAR units that 14 are in Indian Point Unit 2, with thermal hydrogen 15 recombiners, because recombiners can be an effective 16 tool for removing hydrogen in a design-basis accident.
17 Or just to clarify, we're talking about just 18 two units. So, it's not -
19 MR. WEAVER: If I could just interrupt 20 really quickly. This is Jordan Weaver at NRDC. It's 21 not necessarily that we don't have some concerns with 22 how, you know, a PAR system or a thermal recombiner system 23 could handle hydrogen produced during a design-basis 24 accident, that would all depend on, you know, a case by 25 case basis.
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26 1 But, as far as this petition goes, we didn't 2 actually speak to that problem. So, we are more 3 concerned, and this petition addresses the issue, of the 4 transition from a design-basis accident to a severe 5 accident, in terms of the amount of hydrogen produced.
6 So, it's just the inability to be able to 7 selectively use a mitigation system when you enter an 8 environment in which it is no longer applicable. So, and 9 that is what this petition speaks to, not necessarily how 10 it handles in operations for which it is likely qualified 11 how. That doesn't really concern us that much, because 12 there is reason enough to believe that they would operate 13 correctly in a design-basis accident.
14 CHAIR LUBINSKI: Thank you, both Mr. Leyse 15 and Mr. Weaver. There are no more questions here at the 16 Headquarters office where we're calling in from. I want 17 to turn next to Headquarters staff that are on the line.
18 Farhad, do you have any questions?
19 MR. FARZAM: No, John, I don't.
20 CHAIR LUBINSKI: Okay, thank you. Let me 21 turn to our regional staff. Brice and Larry, do you guys 22 have any questions?
23 MR. BICKETT: No, John, we don't.
24 CHAIR LUBINSKI: Thank you. I'd like to 25 now turn to the licensee. We have a couple licensee NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 representatives on the phone. Do you have any questions 2 at this point?
3 MR. PRUSSMAN: This is Steve Prussman.
4 No, I don't.
5 CHAIR LUBINSKI: Okay. As Doug mentioned 6 earlier, members of the public were allowed to call into 7 the meeting, and did not have to identify themselves.
8 Are there any members of the public right now, that would 9 like to provide any comments regarding the petitions, or 10 ask questions about the 2.206 petition process?
11 Okay. As hearing none, I assume there is 12 either no one from the public on the line, or they chose 13 not to ask any questions.
14 As stated at the opening of the meeting, the 15 purpose of this meeting is not to provide an opportunity 16 for the petitioner or the public to question or examine 17 the Petition Review Board regarding the merits of this 18 petition request. But, we did want to give members of 19 the public and the licensee an opportunity to ask any 20 questions.
21 Mr. Weaver and Mr. Leyse, I'd like to thank 22 you for taking the time to provide the NRC staff with 23 clarifying information on the petition you have 24 submitted. Before we close, does the court reporter 25 need any additional information for the meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 transcript?
2 MR. WEAVER: We have a quick question, 3 really quickly. I apologize for - this is Jordan Weaver.
4 MR. COCHRAN: And Mr. Cochran. I 5 recognize this isn't the proper time to ask the Review 6 Board, whether they could comment on the petition, but 7 I would like to ask whether any of the technical staff 8 or anybody at Entergy, in light of wherever they stand 9 with regard to the review of the petition, if they are 10 knowledgeable of any errors in the petition? Errors of 11 fact?
12 CHAIR LUBINSKI: Mr. Cochran, thank you.
13 As you said, the purpose of this Board today was for the 14 petitioners to present any additional information to the 15 NRC, and for us to ask clarifying questions. The 16 licensee and any member of the public is allowed to 17 participate in this call, and ask questions of the Review 18 Board. With respect to the licensee being on the call, 19 it's up to you if you want to respond to any of the 20 questions from the petitions.
21 MR. PRUSSMAN: We have no response.
22 CHAIR LUBINSKI: Okay, thank you.
23 MR. PRUSSMAN: Steve Prussman.
24 CHAIR LUBINSKI: Thank you, Mr. Prussman.
25 Okay. I don't believe I got a confirmation from the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 court reporter. Does the court reporter need any 2 additional information for the meeting transcript?
3 COURT REPORTER: If I could get a copy of 4 the service list, that would be great.
5 CHAIR LUBINSKI: Service list? Okay.
6 Andrea Russell will put that together for you, thank you.
7 Okay, with that, this meeting is concluded, and we will 8 be terminating the phone connection. Thank you all.
9 Have a great day.
10 (Whereupon, the meeting concluded at 10:43 11 a.m.)
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