ML12349A123
| ML12349A123 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 12/03/2012 |
| From: | Advisory Committee on Reactor Safeguards |
| To: | |
| References | |
| NRC-2039, 2.206 | |
| Download: ML12349A123 (1) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board RE Peach Bottom Units 2 and 3 Docket Number: (n/a)
Location: (telephone conference)
Date: Monday, December 3, 2012 Work Order No.: NRC-2039 Pages 1-39
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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 PEACH BOTTOM 2 and 3 8 . . . . .
9 MONDAY 10 DECEMBER 3, 2012 11 12 The conference call came to order at 11:00 13 a.m., Michele Evans, Chairperson of the Petition 14 Review Board, presiding.
15 16 PETITIONER: MICHAEL MULLIGAN 17 PETITION REVIEW BOARD MEMBERS 18 MICHELE EVANS, Director, Division of Operating 19 Reactor Licensing, NRR, Office of Nuclear Reactor 20 Regulation.
21 MERILEE BANIC, PRB Coordinator 22 JAMES KIM, Petition Manager 23 SAM HANSEL, SR., Resident Inspector 24 DAVID PELTON, Branch Chief, Process Owner, 2.206 25 Process, NRR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 ADAM ZIEDONIS, Resident Inspector, Peach Bottom 2 Station 3 MOHAMMAD RAZZAQUE, Reactor Systems Branch, NRR 4 GEORGE WILSON, Branch Chief, Division of Operating 5 Reactor Licensing, NRR 6
7 NRC STAFF 8 JOE DeMARSHALL, Operations Examiner in Training, 9 Peach Bottom Resident Office 10 11 LICENSEE STAFF 12 DAN DULLUM, Regulatory Assurance Division, Exelon, 13 Peach Bottom 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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3 1 P R O C E E D I NG S 2 11:00 a.m.
3 MR. KIM: On the record. Good morning.
4 I would like to thank everybody for attending this 5 meeting. My name is Jim Kim. And I am a project 6 manager in NRR.
7 We are here to today to allow the 8 Petitioner Michael Mulligan to address the Petition 9 Review Board (PRB) regarding 2.206 Petition dated 10 October 15, 2012. I am the Petition Manager for the 11 Petition. The Petition Review Board Chairman is 12 Michele Evans. As a part of the Petition Review 13 Board's review of this Petition, Michael Mulligan has 14 requested this opportunity to address the Petition 15 Review Board.
16 This meeting is schedule from 11:00 a.m.
17 to 12:00 p.m. The meeting is being recorded by the 18 NRC Operations Center and will be transcribed by a 19 court reporter. The transcript will become a 20 supplement to the Petition. The transcript will also 21 be made publicly available.
22 I would like to open this meeting with 23 introductions. As we go around the room, please be 24 sure to clearly state your name, your position and the 25 office that you work for within the NRC for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4 1 record.
2 I'll start off. This is James Kim. I'm 3 a project manager for the Division of Operating 4 Reactor Licensing in NRR.
5 MR. RAZZAQUE: This is Mohammad Razzaque 6 from the Reactor Systems Branch, NRR.
7 CHAIRPERSON EVANS: And this is Michele 8 Evans. I'm the Director in the Division of Operator 9 Reactor Licensing in NRR. And I'm also the PRB 10 Chairman.
11 MR. PELTON: This is David Pelton, Branch 12 Chief, Process owner of the 2.206 Process in NRR.
13 MR. WILSON: And this is George Wilson.
14 I'm a Branch Chief in the Division of Operating 15 Reactor Licensing in NRR.
16 MR. KIM: We have completed introductions 17 at the NRC Headquarters. At this time, are there any 18 other NRC participants from Headquarters or regional 19 office on the phone?
20 MR. HANSEL: Peach Bottom Residents are 21 here. I'm Sam Hansel. I'm the Peach Bottom Senior 22 Resident from Region I.
23 MR. ZIEDONIS: Adam Ziedonis. I'm the 24 Resident Inspector at Peach Bottom. And we also have 25 Joe DeMarshall in the Peach Bottom Resident Office.
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5 1 He's the Operations Examiner In Training.
2 MR. KIM: Okay. Are there any 3 representatives for the Licensee on the phone?
4 MR. DULLUM: Yes, this is Dan Dullum from 5 Peach Bottom. I'm the Engineer in the Regulatory 6 Assurance Division.
7 MR. KIM: Okay. Mr. Mulligan, would you 8 please introduce yourself for the record?
9 MR. MULLIGAN: Hi. I'm Mike Mulligan.
10 I'm a whistleblower. I worked in the industry for a 11 number of years. I've had a lot of interactions with 12 the NRC and many utilities throughout the recent 13 years. Thank you.
14 MR. KIM: Thank you. It is not required 15 for the members of the public to introduce themselves 16 for this call. However, if there are any members of 17 the public on the phone that wish to do so at this 18 time, please speak your name for the record.
19 (No verbal response.)
20 As there is. none, I would like to 21 emphasize that we each need to speak clearly and 22 loudly to make sure that the court reporter can 23 accurately transcribe this meeting. If you do have 24 something that you'd like to say, please first state 25 your name for the record.
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6 1 For those dialing into the meeting, please 2 remember to mute your phones to minimize any 3 background noise or distractions. If you do not have 4 a mute button, it can be done by pressing the keys 5 star-6. To unmute, press the star-6 keys again.
6 Thank you.
7 At this time, I'll turn it over to the PRB 8 Chairman Michele Evans.
9 CHAIRPERSON EVANS: Good morning. Welcome 10 to this meeting regarding the 2.206 Petition submitted 11 by Mr. Mulligan. I would like to first share some 12 background on our process.
13 Section 2.206 of Title 10 of the Code of 14 Federal Regulations describes the petition process, 15 the primary mechanism for the public to request 16 enforcement action by the NRC in a public process.
17 The process permits anyone to petition NRC to take 18 enforcement type actions related to NRC licensees or 19 licensed activities.
20 Depending on the results of its 21 evaluation, NRC can modify, suspend or revoke an NRC 22 issued license or take any other appropriate 23 enforcement action to resolve a problem. The NRC 24 staff's guidance for the disposition of the 2.206 25 petition request is a management directive 8.11 which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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7 1 is publicly available.
2 The purpose of today's meeting is to give 3 the Petitioner an opportunity to provide any 4 additional explanation or support for the Petition 5 before the Petition Review Board's initial 6 consideration and recommendation. The meeting is not 7 a hearing nor is it an opportunity for the Petitioner, 8 to question the PRB on the merits or the issues 9 presented in the Petition request.
10 No decisions regarding the merits of this 11 Petition will be made at this meeting. And following 12 this meeting the Petition Review Board will conduct 13 its internal deliberations. The outcome of this 14 internal meeting will be discussed with the 15 Petitioner.
16 The Petition Review Board typically 17 consists of a chairman, usually a manager at the 18 senior executive service level of the NRC, and has a 19 petition manager and a PRB coordinator. Other members 20 of the board are determined by the NRC staff based on 21 the content of the information in the petition 22 request.
23 At this time I would like to introduce the 24 Board. Again, I'm Michele Evans, the Petition Review 25 Board Chairman. James Kim is the Petition Manager for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 the Petition under discussion today. Marilee Banic 2 is the Office's PRB Coordinator. And our technical 3 staff includes Sam Hansel, Senior Resident Inspector, 4 and Adam Ziedonis, Resident Inspector for the Peach 5 Bottom Station, Mohammad Razzaque from the Reactor 6 Systems Division, Andrew Rosebrook from NRC Region I 7 Division of Reactor Projects. We also obtain advice 8 from our Office of General Counsel represented today 9 by Chris Hair.
10 As described in our process, the NRC staff 11 may ask clarifying questions in order to better 12 understand the petitioner's presentation and to reach 13 a reasoned decision whether to accept or reject the 14 petitioner's request for review under the 2.206 15 process.
16 I'd like to summarize the scope of the 17 Petition under consideration and the NRC activities to 18 date. On October 15, 2012, Mr. Mulligan submitted to 19 the NRC a petition under 2.206 regarding the Peach 20 Bottom Unit 2 and Unit 3 reactors which requested a 21 number of actions:
22 (1) requested immediate shutdown of Peach 23 Bottom 2 and 3 for safety reasons based on the common 24 mode failure of the SRV actuators not being qualified 25 for the accident containment max temperature and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 radiation conditions; 2 (2) request that Peach Bottom be fine $10 3 million for not declaring a 10 CFR 50.73(a) (2) (v) (D) 4 on their SRV actuators. They do not warn the other 5 plants of these problems; 6 (3) request the Department of Justice FBI 7 investigation of these events; 8 (4) request an investigation nationwide 9 with equipment and components not be accident 10 qualified in any nuclear plant containments, 11 especially accident temperatures and radiation; 12 (5) request the formation of a local 13 public oversight panel around every plant; 14 (6) request formation of an emergency NRC 15 senior official oversight panel with the aims of 16 reforming the reactor oversight process; 17 (7) request formation of a national NRC 18 oversight panel of outsiders; 19 (8) request massive reforms within the 20 2.206 system and their directives. The system doesn't 21 serve the public and their communities; and 22 (9) request a $10 million fine to Peach 23 Bottom as they failed to submit and comply with Part 24 10 CFR 50.73.
25 Allow me to discuss the NRC activities to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 date. On November 16, 2012, Mr. Mulligan requested an 2 opportunity to address the PRB by telephone which is 3 the purpose of today's call.
4 And on November 1, 2012, the PRB met 5 internally to discuss the request for immediate action 6 of a shutdown of Peach Bottom Units 2 and 3. The PRB 7 denied the request for immediate action because there 8 was no immediate safety concern to the plant or to the 9 health and safety of the public.
10 On November 6, 2012, Mr. Mulligan was 11 informed of the PRB's decisions on the immediate 12 action.
13 And on November 8, 2012, Mr. Mulligan 14 submitted supplemental information in support of his 15 petition.
16 As a reminder for the phone participants, 17 please identify yourself if you make any remarks as 18 this will help us in the preparation of the meeting 19 transcript that will be made publicly available.
20 Thank you.
21 Mr. Mulligan, I'll turn it over to you to 22 allow you to provide any information you believe the 23 PRB should consider as part of this petition.
24 MR. MULLIGAN: I -- Yes, I just want to 25 say that containment and the components in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 containment especially all the electrical components, 2 the valve actuators, motors, valve motors, actuators 3 and stuff like that. The worst case situation we're 4 talking about is containment overheat and melts all 5 their electronic and electrical stuff in the 6 containment and stuff like that.
7 Then you have what you call a irreversible 8 core meltdown. All of the electrical stuff would be 9 melted. You then couldn't see what you were doing and 10 you couldn't respond to -- You couldn't respond. You 11 couldn't see. You couldn't respond to anything. You 12 wouldn't know what's going on there and that's 13 Fukushima and stuff. And that's what we're talking 14 about the worst case.
15 I'm looking at Fort Calhoun license in 16 2012-017. These guys have a lot of LERs I'll tell 17 you. The event date is July 26, 2012. The report 18 date is September 9. While performing an extent of 19 condition review associated with the adequacy of air 20 operating climate inside the containment to withstand 21 containment main steam line break and loss of coolant 22 temperatures in which it was discovered in three 23 valves. Have a nitro plastomer and rubber like part 24 where the air regulator and actuator might not be able 25 to withstand a containment main steam line break and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 LOCA temperatures.
2 The air filter regulator and actuator, the 3 design temperature limit for the nitro plastomer used 4 in the valves is 180 degrees which is an acceptable 5 normal operating condition inside containment.
6 However, the main steam line and LOCA containment 7 temperatures reached 360 and 270 degrees.
8 This guy's -- They backed into this 9 because they didn't mix -- They had troubles with the 10 main steam line break accident, you know, modeling, 11 San Onofre. You know modeling issues with incorrect 12 modeling, stuff like that. And we see this modeling 13 business. And so they have problems with modeling, 14 having an accurate model of the main steam line break.
15 And so they backed into this with a spin of condition.
16 Be sure they have that adequate quality to all our 17 actuators. So that's how they backed into this.
18 And then they spent a lot of time talking 19 about the maximum, you know, the accident you'd have 20 balancing the containment with high temperatures and 21 stuff like that.
22 Peach Bottom and Vermont Yankee backed 23 into it because they had leakage problems with an 24 inappropriate part, an unqualified part, that they 25 stuck in their safety relief valve and stuff. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 there seems to be two regimes here. There's one 2 regime that they interpret -- the NRC interprets the 3 regulations between two regimes.
4 If you're a non-operating plant, they more 5 or less tell the truth. And they get down to the 6 dirty business of figuring out what's going on.
7 If you're an operating plant, the NRC is 8 terrified as to making a utility comply with 9 regulations. So they play around and play shadow 10 games and play investigations and all that sort of 11 stuff.
12 And they wait until a plant becomes upon 13 a convenient time to shut the plant down. And they 14 may or may not fix it during that outage. And they 15 wait until the next outage and stuff like that.
16 These kinds of issues where everybody has 17 this kind of shadow game of enforcing regulations and 18 stuff like that is terrible for the employees. The 19 little guy sitting there saying, "I see something that 20 my managers are doing this wrong. But I've seen this 21 shadow game and I understand it. And if I say 22 something, then the big boys, the big dogs, can come 23 out and everybody will key off their credibility and 24 apparent integrity" and stuff like that.
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14 1 know gets squashed. And the guys that are hiding or 2 being tricky and all that sort of stuff they get to 3 play God and they get to intimidate employees.
4 These kinds of issues we're talking about 5 besides the component problem and how they're 6 responding to an accident, these kind of issues are 7 also the historic culture of the plant. And the 8 communication, integrity and trust and stuff like 9 that, I think that's more important than any safety 10 system you've got there.
11 Communications, the integrity of 12 communications, the integrity of your documents and 13 the stuff, you're putting information on the documents 14 as fast as you can so that everybody in the 15 organization and everybody outside the organization.
16 Those are the things that have called safety when you 17 really get down to it.
18 You're going to have safety in a plant.
19 But you also have to have safety in the system. The 20 system comes back. You notify the system. And then 21 it notifies all the players in the system and it makes 22 everybody safe, that kind of thing. That kind of 23 safety. A lot of times, risk regulations, we don't 24 even talk about that kind of safety.
25 But, anyways, the basic outline of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 issue with Vermont Yankee, January 2010, Vermont 2 Yankee had energy piping leaks and tritium got into 3 the ground and stuff like that.
4 February 4th they found 775,000 picocuries 5 per meter of tritium and junk in the soils and stuff 6 like that. And at that time the Republican Governor 7 went crazy because you couldn't trust Entergy and the 8 NRC. And the Senate and the House went into a frenzy 9 and voting this down for Vermont Yankee. Everybody is 10 still trying to shut down Vermont Yankee and stuff.
11 And then April 26, they came upon a 12 shutdown. They got out of the shutdown May 26th.
13 Somewhere in this outage this is when the SRV actuator 14 seals began leaking. They spit out their first LER 15 for Vermont Yankee, LER 2010-002-00 inoperability of 16 the main steam safety release valve through the 17 degraded thread seal.
18 Interesting, the NRC just did a new 19 inspection in Target Rock. I'll talk about this later 20 a little bit. Reports for embrittlement began 21 somewhere after the Vermont Yankee, the first LER.
22 That's when Target Rock got a wind of this 23 embrittlement problem with Buna-N and their SRV.
24 And I'll tell right from that point right 25 there, when Target Rock got it, everybody knew what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 the thing was from the opening moment. Everybody knew 2 that there was wrong material in there, inappropriate, 3 dangerous material, corrupt material, inside Vermont 4 Yankee's SRV valve. And then it was a matter of 5 structuring inspection reports and structuring 6 internal and NRC inspection.
7 The whole game of the structuring business 8 is just that that is a coverup. You kind of delay 9 reporting until the heat of the fire is over with and 10 stuff like that. And not everybody knew what's going 11 on extemporaneously or immediately and stuff like 12 that.
13 And that's safety. And that's integrity 14 for the employees when you get to see the reports 15 immediately and stuff like that and everybody stops 16 playing this vendor-contractor investigative kind of 17 games that go on here. I figure big bucks to do this 18 big investigation for us, but you've got to delay for 19 two years, that kind of game.
20 Those kind of games destroy integrity of 21 an enormous amount of people because it's useless.
22 And the guys know what's going on and they see that 23 kind of stuff.
24 Then we pop into May 1st. Again, a 25 nuclear power plant, PhDs and advanced degreed people, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 engineers and stuff, highly educated people. And 2 spending millions of dollars on these investigations 3 and stuff like that.
4 How does this come out March 1, 2011?
5 Material testing determined that the apparent cause of 6 the thread conditions was thermal degradation. We 7 know that's an absolute lie. It wasn't thermal 8 degradation at all. Absolutely an accurate lie.
9 You people are supposed to be educated and 10 you're supposed to have the systems available that you 11 immediately know what kind of condition these 12 materials are in your plant. You're supposed to be 13 able to pull up that information with one key stroke, 14 do the key stroke.
15 And the information is supposed to be 16 available to everybody. Everybody knows where 17 everybody sits. And then those are the things that 18 change behaviors.
19 Honestly and integrity and full disclosure 20 and immediate disclosure, those are the kinds of 21 things that drive integrity. Acceptance of nuclear 22 power plants.
23 I could get into the ASME and basically a 24 lot of these codes are purchased from the nuclear 25 utilities. I'll just say there's not a lot of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 integrity there. There's not an independent authority 2 that's not owned by the money of the nuclear industry.
3 And that's a big problem.
4 The big issue with Vermont Yankee and 5 Peach Bottom, where were these people? Where were all 6 these highly educated people in engineering problems, 7 highly educated, PhDs, advanced degrees, experience 8 and skills up the yin yang? Where was Peach Bottom 9 when the first problem came out?
10 I don't see anywhere there of an extended 11 condition or an extended investigation. What were 12 those materials? By the way, we have unqualified 13 materials in containment that apparently withstand 220 14 degree temperatures when they should be 400 degrees.
15 Peach Bottom -- Where am I? Everybody 16 remembers the Peach Bottom 2003 LOOP, loss of all 17 oversight power, dual plant trip. They -- Here we go.
18 It challenged a number of -- I mean this is the kind 19 of accident that operators are terrified of.
20 A simple cascading event. You know 21 lightning strikes 20 miles away at the plant. And it 22 trips the plant. And then it trips -- And then 23 because of craziness at the plant and with the NRC by 24 allowing this business of some regulations really need 25 some regulations to be enforced and other regulations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 don't need to be reinforced. We'll turn a blind eye 2 if it's really going to affect your profits and your 3 capacity factor.
4 There was diesel generator gaskets that 5 were leaking and stuff like that. You know you've got 6 two SRVs, three SRVs. Erratic indication on CSRV, 7 failure of the DSRV to close, failure of the ESRV to 8 open.
9 And that's an interesting one. The thing 10 failed to open because right around this time there 11 was a realization that there are asbestos fields in 12 the actuators. The ones that we're generally talking 13 about, they're not being supplied by the vendor of the 14 actuator anymore because it was asbestos. That's when 15 they shifted over to this Buna-N stuff evidently.
16 Safety release valves are one of the most 17 dangerous components in a nuclear plant outside of 18 what kind of accident. You know the engineering 19 models tell us that that could happen.
20 The reason why that is is because on the 21 whole they're a simple valve. They're a simple 22 component. You put it on a table if it wasn't cracked 23 up and it's really kind of a simple mechanical device.
24 What makes it dangerous is in a 25 containment. It's in an area that it's inaccessible.
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20 1 It's inaccessible for years at a time, maybe even 2 outages at a time or cycles at a time depending upon 3 the surveillance cycle and stuff. So you can't see 4 what's going on in there. There's no magic button to 5 push. How are you doing today, Mr. SRV?
6 And we know everything going on about that 7 SRV. You can't see what's going on and stuff. And 8 that makes it extraordinarily dangerous. And the 9 danger isn't that the device itself is going to melt 10 down the core and traumatize our nation.
11 Historically, the SRVs or especially FRVs 12 or release valves misoperation and core maintenance 13 bums up the operator. They put a bunch of information 14 in their head that's crap. They're either leaking or 15 they're not working or they failed to work and stuff.
16 And it fills up their head.
17 And these guys can't think straight with 18 this device sitting behind a barrier. And they do 19 crazy stuff.
20 And TMI was an example of that where they 21 had operational problems and they had one tagged on or 22 don't operate. And the valve had a simple resin 23 condiment trip and the miscascaded the plant into 24 melting down. And bummed them was the trip happened, 25 the relief valve opened up and didn't shut. The tag NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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21 1 on the console hid the indication of the valve and 2 that's PMI and stuff like that.
3 So relief valve was fundamental to the TMI 4 accident. The relief valve, but it actually did the 5 accident and then the set-up for it with all the 6 maintenance problems and the craziness and the 7 utilities not fixing things immediately and stuff.
8 That's TMI for what happened.
9 They discussed the same thing when you 10 really get down to it. A cascade. A lightning at a 11 plant. A lightning bolt 30 miles from Peach Bottom.
12 That sets up a simple plant trip. It turns into with 13 this craziness going on a terrible adventure of plant 14 maintenance problems showing up in an accident.
15 Davis-Besse a pressurizer, a relief valve 16 was notorious for leaking for~years. Davis-Besse was 17 one of the best children, you know, the better child 18 for the NRC. They had pretty good grades and stuff 19 like that.
20 And then they had this pressurizer relief 21 valve leaking and stuff like that. And then they had 22 the head starting to leak. And the operators used the 23 rationale that it's that old leaking pressurizer 24 safety valve that is causing the leak.
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22 1 in there and clogging up containment air filters and 2 stacks and stuff like that. And people used that 3 justification of where it's at. Made the data.
4 Modified the output of the relief valve and stuff like 5 that. And that bummed them up.
6 The operators you know. It's that false 7 idea that it's that safety valve that's leaking as an 8 excuse. And they couldn't even get past the idea it 9 might be something else. It might be a drive 10 mechanism or something like that that's leaking.
11 And so I mean that's how dangerous these 12 valves are. It's nothing to be joking about. Nothing 13 to be sneezing about these things. They're dangerous 14 because we can't see what's going on there.
15 At Peach Bottom with the latest LER 2012-16 001. The NRC last year dinged them on SRV actuator 17 set point. You usually get one or two. Here they got 18 six that were passed outside of regulation.
19 And the problem with these guys are after 20 one of two of these SRVs are inopt or not functioning, 21 they're behind the area. You can't see what's going 22 on. You can't see their inaccurate or misfunctioning 23 and stuff like that. So you have no idea.
24 You should -- There's a requirement to 25 shut down when you get to these thresholds of leaks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 from the relief valves, the limits, the set point 2 limits and stuff like that. And they should be shut 3 down immediately.
4 But you've got that barrier in there and 5 you should find these things years after they should 6 have been shut down. And it's taking care of this in 7 a really sloppy manner.
8 And the idea that you have a requirement 9 to shut down, but everybody blinks and they find it in 10 the outage when it should have been shut down six 11 months ago. It's one after another with these safety 12 relief valves.
13 And I'll tell you another thing. From the 14 beginning of early 2000 to within the last couple of 15 years, there's been a 300 percent increase in LERs for 16 safety relief valves. We don't know what the PWRs are 17 doing. I haven't had time to play around with them.
18 But 300 percent increase in LERs or problems with 19 safety relief valves. It's kind of amazing.
20 And you know nothing ever matters. We've 21 got backup to the backup safety systems. We've got 22 redundant and diverse safety systems. We've got so 23 many safety systems they're coming out of our yin 24 yang. But nothing ever matters.
25 One problem doesn't matter. And that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 the wrong philosophy. It should be that that's a 2 misuse of diverse and redundant safety systems.
3 Every safety system, every component, 4 should be thought of in the same way. Does it meet 5 their regular regulatory requirements? Are there any 6 defects in it? And it should be pristine. For the 7 most part, pristine. In pristine condition.
8 There should be no excuses that it doesn't 9 really matter because you've got backups to the 10 backups. That's the wrong way of thinking in your 11 head of how these things work.
12 Back to Peach Bottom, dual plant trip, AIG 13 and thing and stuff like that. Okay. You had all 14 these kind of surveillances and stuff. How come you 15 guys didn't know that those three safety valves were 16 in such terrible condition and stuff like that before 17 the trip? How do we know that's not going to happen 18 again and stuff?
19 Three units. Three safety valves jumping 20 all around and -- operating and the NRC made a comment 21 about a very hard site with a lot of stuff going on 22 and stuff like that. Those are the kinds of things 23 that lead to a meltdown. It's not a component 24 failing. It's not a lightning bolt 30 miles from the 25 plant that causes everybody to go nuts and stuff like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 that. It's an organization one on top of each other 2 all thinking alike. All saying to ourselves "Okay.
3 Rules and regulations."
4 What do we use rules and regulations for?
5 Rules and regulations are supposed to allow us to see 6 more, to communicate more, to improve our situations 7 in life. And when you miss a usual, when 8 organizations go crazy, they start bucking these rules 9 around as an excuse to blind each other, to blind 10 yourself and to bind the regular organization and the 11 agency itself.
12 In fact, using these rules as excuses to 13 turn everybody's vision off and perceptions and your 14 intelligence and stuff like that. That's how TMI, 15 that's how Davis-Besse and a host of other plants got 16 into trouble. It's not a component failing. It's 17 people failing. And that lightning bolt cascades a 18 plant into discovering a whole series of poor 19 maintenance issues and blind organizations and rules 20 that are not enforced on a level.
21 You know a lot of these organizations 22 after the event go around with a microscope And it's 23 astonishing the rules the NRC had to enforce, that 24 made the utilities enforce.
25 We'll start up on the -- I'm sorry. 1994 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 information notice, 1994-006, in January 1993 during 2 a review of components of the safety-related portion 3 of nitrogen supply system at Fitzpatrick Nuclear Power 4 Plant the licensee found that certain parts of the dry 5 well cooler air operated dampers and their associated 6 celluloid valves were made of -- material and 7 elasticifier that is not suitable for high temperature 8 conditions.
9 This is dangerous stuff. And there's been 10 a lot of indications. You guys are playing around 11 with nitro stuff. Somebody is talking about nitro 12 elastomers and other people are talking about just 13 gaskets and steel materials and stuff like that.
14 They're dangerous.
15 This stuff was dangerous stuff. The 16 industry has known it all along. And to be throwing 17 this into a safety system, you know there should be a 18 lot of people looking into that. In 1974, this guy 19 said it was dangerous material. And they should have 20 never been allowed at Vermont Yankee and Peach Bottom.
21 Now as far as I know Peach Bottom still 22 has that material in there. We don't know if the 23 actuator -- I asked. I asked the agency if the 24 actuators -- are they Type 1 or Type 2 actuator 25 valves? And NRC won't answer me. And that is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 suspicious.
2 Why can't they just say "Yeah, that 3 actuator was good to 400 degrees?" Why is just 4 everybody not answering these questions? You might 5 have an investigation going on for all I know. Or you 6 just might not know. You just might not -- You know, 7 nobody wants to really understand what's going on 8 here.
9 At Target Rock, the new NRC investigation 10 with the problem report for brittle unit in thread.
11 That was December 4, 2010 when the NRC doesn't go into 12 -- It doesn't get that report out, but that's another 13 thing. So went over the first daily -- it just talked 14 about manufactured in 2002 and it was a new actuator 15 in 2010 that was finally installed in 2010.
16 It fails the series of different tests.
17 I mean different seals and stuff like that. And it is 18 determined to be not a common failure mode. How can 19 it not be a common failure mode when there's 20 inappropriate error? When the material is only 21 qualified to 225 degrees.
22 You know, I'm trying to get down. There's 23 a lot of stuff. I could spit out a lot with the LERs 24 in the inspection report. But you see the shift. You 25 see the shift at Vermont Yankee from -- as you go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 through the years of inspection reports and stuff like 2 that. And they finally admit it many years afterwards 3 that.
4 And there's a lot of talk about certainty 5 as it was thermal degradation and the Type 1-Type 2 6 actuators and the Type 2 actuators weren't really 7 qualified to be in there and stuff. And nobody is 8 sitting there saying "My primary responsibility is not 9 keeping the plant." You know nuclear professionalism, 10 especially nuclear professionalism with the educated 11 people, the guys with the degrees, the engineers that 12 are formally educated. Advanced degrees. The PhDs 13 and stuff like that.
14 Their primary responsibility is how to 15 align that plant to run right, prepare it for the 16 operators in the worst possible case accident of 17 record and stuff like that. That's the primary 18 responsibility barring no other. That's the only way 19 the industry is going to survive.
20 Should put that in everybody's heads that 21 the primary responsibility of nuclear professionalism 22 is to prepare a plant for a bad accident, to have all 23 of their equipment in pristine condition and the 24 operators properly trained. And there are 25 expectations that we'll have no more Peach Bottom 2002 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 lightning bolt strike that challenges to 2 uncontrollable of two plants actually. Two plants 3 being almost uncontrollable with the accident and 4 stuff like that.
5 That's what I'm trying to say. It was a 6 coverup with Vermont Yankee not being in a positive 7 condition and stuff like that. They should have known 8 right in the beginning and they wanted to keep Vermont 9 Yankee because they were in the heat of the moment 10 with tritium issues. And you've got a governor 11 elected over with this tritium issue. The heat of the 12 moment. So everybody said "One more thing. We think 13 Vermont Yankee is dead. But it will certainly be dead 14 if everybody figures out that they had these bad 15 actuators in there.
16 So if the NRC allowed these actuators to 17 be put back -- well, not the actuators, the incorrect 18 material in -- and knowing. They probably never 19 discovered this until after the outage. Never thought 20 deeply about it. Maybe within a couple of months they 21 knew that those actuators would have -- the Buna-N 22 material was the wrong material and stuff.
23 And then have the courage to get the right 24 stuff in there, the 400 degree or 380, whatever in 25 that area. And shut down the plant and do the right NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 thing. Pay the price for having a chaotic 2 organization that doesn't know how to maintain order 3 in their parts training and within the organization as 4 far as complying with the regulations and policies and 5 stuff like that.
6 Peach Bottom is interesting. It's 7 interesting all the different words they use for the 8 same component evidently that broke or that was wrong.
9 Two seconds. Vermont Yankee calls it a shaft to 10 piston thread seal. Peach Bottom calls it an SRV 11 actuator diagram thread seal. The NRC recently at 12 Vermont Yankee talks about some shaft methane seal.
13 You know, everybody is using different 14 words. I don't know if these are different 15 components. I suspect they're not. I highly suspect 16 they're not. I'd bet my credibility on it that 17 they're all the same thing.
18 So the bottom line with Peach Bottom, 19 Peach Bottom 2 like I said, these guys have known for 20 a number of years that that material was incorrect 21 material. Not thermally degraded or any of that 22 garbage that they talked about, that they first talked 23 about at Vermont Yankee and Peach Bottom. They knew 24 that was the wrong material. That material isn't 25 qualified to be in an SRV actuator.
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31 1 There should be this bi pole or 400 degree 2 material, whatever. It should be qualified to the 3 higher ends of their accident analysis types of 4 things.
5 It's mind-boggling that you guys don't 6 have the discipline to maintain the environmental 7 conditions in containment and stuff like that. That's 8 what nuclear professionalism is all about. It's 9 preparing for the accident. It's making sure all the 10 components will work perfectly in an accident.
11 The life of an operator up in those 12 control rooms is complicated enough. It's complicated 13 beyond -- All you bureaucrat guys, you work with 14 paperwork. You work in certainty, rules, regulations 15 and all that sort of stuff.
16 In the control room, there's a lot of gray 17 area. A lot of times if you just follow the rules, 18 you're going to end up getting in a lot of trouble.
19 So you don't want -- As an operator point of view who 20 sees a lot of shortcuts and equipment problems and 21 failures and how it throws your mind off, you don't 22 want a lightning bolt striking your plant and then a 23 lot of maintenance problems coming back and biting you 24 in the ass and confusing the hell out of you. That's 25 what you don't want.
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32 1 You want to go through a simple plant 2 trip. You want everything to work the first time.
3 You don't want a circa that's talked about in the 4 blackout. A Peach Bottom circa.
5 These SRVs are going to operate 400 times 6 in 10 hours. And it's worse than plant design and 7 stuff like that. And then the accumulators of Peach 8 Bottom and Vermont Yankee are in size for one or two 9 operations and stuff. That whole idea is that I think 10 shortcomings should be in the procedures.
11 I know from an operator's point of view I 12 don't care about what the engineers think. You know, 13 I want to be able to operate that SRV as many times as 14 it takes. And I don't really care about if it's in 15 accident models or stuff.
16 I want to be able to operate that as many 17 times as it takes for a week. I want to be so over 18 designed that there's no chance of it not opening when 19 I call it to be opened. An operator is supposed to be 20 --
21 And the NRC itself talks about the 22 automatic op function is still there. So there's no 23 accident. And I'll tell you that it is critically 24 important that an operator be at the station, have his 25 little fingers on that switch that opens it and shuts NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 it and communication with everybody else in that 2 control room. An SRV opening and closing on its own 3 is a runaway freight train. It confuses the hell out 4 of everybody. It disrupts the control room and 5 disrupts training that you trained over for years and 6 stuff like that. And it's a runaway freight train.
7 And anybody saying "Oh well, the automatic 8 function is going to be there." But you might not be 9 able to open it up for the low pressure cooling system 10 and stuff. Again, if you get into this mindset that 11 you don't have budgets to do everything. So we're 12 going to hack and slash 20 percent out of safety and 13 stuff like that. That's insanity. That's craziness.
14 That's insanity. And it drives people insane and then 15 you end up with a TMI, Davis-Besse, where in the 16 ruling you find out you had a real crazy organization 17 and nobody had the guts to stop them before the 18 accident.
19 And I see this with Peach Bottom and 20 Exelon and the trouble they're in as far as natural 21 gas fracking and their issues with green energy in the 22 new plants financing. There are big problems here.
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34 1 of the plant up as a corporation it's craziness.
2 These things can only come down from a 3 philosophy of the corporation. I've got to save my 4 rate payers money and I've got to save the stock 5 payers from -- You know I can thrown them a couple 6 pennies every quarter, but it's the long-term thing 7 that really matters. It's the long term investment in 8 a set of power plants that really make the difference, 9 that really gains the public trust and confidence in 10 the nuclear industry.
11 And the corporation at these plants, 12 Entergy, they've gotten too big. Have they gotten too 13 big where the NRC is afraid to squash regulations now?
14 They've got regulations on the books they can turn 15 their heads to and not enforce.
16 Have these utilities gained too much 17 political power? And is the agency just powerless and 18 they can't really enforce regulations to drive plant 19 employees' behaviors to do good and to report things 20 before they break and fix them before they break? Are 21 the employees too intimidated to push back at these 22 utilities because they've got all these things that 23 can squash a little guy at the power plant that he's 24 a liar and worries about the plant?
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35 1 a thought. I just can't understand why that wasn't 2 done at Vermont Yankee, especially at Vermont Yankee.
3 Peach Bottom they should have keyed in on Vermont 4 Yankee that that's appropriate. That's the idea.
5 Listen, we know what's there. But if it's 6 not in the paperwork, we can't see it. We can't say 7 anything. You know there is no proof that we've got 8 inappropriate materials and no seals and stuff like 9 that.
10 Is that what integrity is? We'll just 11 engineer a set of reports and investigations to 12 essentially blind everybody. You don't have to send 13 a report for two years or six months. Why sit there 14 and say, "I want a contractor that's going to give me 15 an immediate correct report"? Or do I sit there and 16 say, "Oh, we're a little bit too hot down here. The 17 governor is going to get elected."
18 Do not submit this for a year and a half.
19 We're paying big bucks to not submit this for a year 20 and a half. We'll pay you big bucks to fumble around 21 and do the wrong analysis and to verify that it is a 22 thermally-degraded Buna-N, when the Buna-N material 23 wasn't even supposed to be there in the first place.
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36 1 like that to make visible, make transparent, allow 2 everybody to see what's going on here. And you know 3 some of us we have bad news things. I have bad news 4 things. I'll take a shortcut if you give me a chance.
5 But if I make my behaviors transparent and 6 do that now a lot more than I did when I was a young 7 man that's the key for me to change my behaviors if I 8 sabotage my bad instincts. And that's what you guys 9 have to start doing really.
10 It looks bad. They think I'm crazy 11 because I sabotaged my own bad behaviors which makes 12 you wonder about the world. That's what people have 13 to do. That's the hard work of life is to make 14 yourself to identify your shortcomings. Because you 15 know what? You probably don't only have that 16 shortcoming. Everybody else has it. And everybody 17 else is squeamish of talking about it and squeamish 18 that they come altogether and say "We can't be -- We 19 just can't be like that anymore. We're better than 20 that. We can be -- We can take on a philosophy of 21 excellence. We can be excellent."
22 "Always strive for the perfect. We can 23 always strive for -- The plant behaves like we think 24 it should be behave when the plant trips" and stuff 25 like that instead of coming back there and everybody NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 saying, "Nothing ever matters. Risk regulation says 2 that we're so safe that nothing ever matters. We can 3 tolerate three safety valves in two plants going belly 4 up" and stuff like that.
5 That's not how the world works. That's 6 not the way to excellence. That's not the way a great 7 utility should work. That's not the way a great 8 nation should be and stuff like that.
9 We ought to be better than that. We can 10 be better than that. And like I said, you start 11 sabotaging bad behaviors or start sabotaging our back 12 sides of our heads because we all have it. Nobody is 13 perfect.
14 And I don't care what kind of education.
15 I don't care if it's a gas attendant or President of 16 the United States, we've all got those black behaviors 17 in the back of our heads. And if we can't control 18 these things I'm telling you we're going to have a 19 terrible world.
20 And that should be our job to strive for 21 those kind of struggles to be better. Every day 22 struggle to be better than you are. Thank you very 23 much.
24 CHAIRPERSON EVANS: Okay. Thank you, Mr.
25 Mulligan.
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38 1 At this time, does the staff here at 2 Headquarters have any questions for Mr. Mulligan?
3 (No verbal response.)
4 How about the regional staff or the 5 resident inspectors?
6 MR. HANSEL: No questions from Peach 7 Bottom.
8 CHAIRPERSON EVANS: And the Licensee, do 9 you have any questions?
10 MR. DULLUM: No questions. Thank you.
11 CHAIRPERSON EVANS: Before I conclude the 12 meeting, members of the -- We don't have any members 13 of the public. Sorry about that.
14 Mr. Mulligan, thank you for taking time to 15 provide the NRC staff with clarifying information on 16 the Petition you've submitted. Before we close, does 17 the court reporter need any additional information for 18 the meeting transcript?
19 COURT REPORTER: I do. Who was 20 representing the Licensee?
21 MR. DULLUM: It's Dan Dullum, D-U-L-L-U-M.
22 COURT REPORTER: All right. And another 23 question, is Chris Hair actually on the line?
24 CHAIRPERSON EVANS: I don't think he was.
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39 1 line.
2 COURT REPORTER: Okay. And the actual 3 Board itself, it consisted of Ms. Evans, Mr. Kim. Is 4 it just the two of you?
5 CHAIRPERSON EVANS: The residents. So Sam 6 Hansel and Adam Ziedonis and also Mohammad Razzaque.
7 COURT REPORTER: Okay. So they are all 8 the actual Board itself.
9 CHAIRPERSON EVANS: Yes. Those are the 10 typical staff, yes.
11 COURT REPORTER: Okay. And all right.
12 That's all the questions I have. Thank you very much.
13 MR. KIM: Okay.
14 CHAIRPERSON EVANS: Okay.
15 MR. MULLIGAN: Thank you very much for 16 affording me this opportunity.
17 CHAIRPERSON EVANS: Yes. I was going to 18 say with that the meeting is concluded and we will be 19 terminating the phone connection. Thank you, Mr.
20 Mulligan.
21 MR. KIM: Thank you.
22 CHAIRPERSON EVANS: Off the record.
23 (Whereupon, at 11:58 a.m., the above 24 entitled matter was concluded.)
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CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission Proceeding: 10 CFR 2.206 Petition in re Peach Bottom by Michael Mulligan 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 typewriting under my direction and that said transcript is a true and accurate record of the proceedings.
Official Reporter Neal R. Gross & Co., Inc.
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