ML13030A486
| ML13030A486 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/20/2012 |
| From: | Pickett D Plant Licensing Branch 1 |
| To: | |
| Pickett D NRR/DORL/LPL1-1 301-415-1364 | |
| References | |
| NRC-2081, G20120875 | |
| Download: ML13030A486 (35) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board RE: Indian Point Energy Center Docket Nos.:
50-247, 50-286 Location:
Rockville, MD Date:
Thursday, December 20, 2012 Work Order No.:
NRC-2081 Pages 1-35 Edited by Douglas Pickett NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1
UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 4 CONFERENCE CALL 5
RE:
6 INDIAN POINT ENERGY CENTER 7
+ + + + +
8 THURSDAY 9
DECEMBER 20, 2012 10
+ + + + +
11 The conference call was held, John 12 Lubinski, Chairperson of the Petition Review Board, 13 presiding.
14 PETITIONERS: MARK LEYSE and DEBORAH BRANCATO, 15 Riverkeeper 16 PETITION REVIEW BOARD MEMBERS:
17 JOHN LUBINSKI, PRB Chairperson 18 DOUGLAS PICKETT, Petition Manager for 2.206 petition 19 ANDREA RUSSELL, 2.206 Petition Coordinator 20 AHSAN SALLMAN, NRR/DSS 21 ASIMIOS MALLIAKOS, FSME 22 FARHAD FARZAM, NRR/DE 23 24 25
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1 NRC HEADQUARTERS STAFF:
2 CHRISTOPHER HAIR, OGC 3
AL NOTAFRANCESCO, RES/DSA 4
BRETT TITUS, NRR/DSS 5
6 NRC REGION I STAFF:
7 BRICE BICKETT, Senior Project Engineer 8
ART BURRITT, Division of Reactor Projects 9
LARRY DOERFLEIN, Chief, Engineering Branch 2 10 11 ALSO PRESENT:
12 ARDESAR IRANI, Entergy Nuclear 13 14 15 16 17 18 19 20 21 22 23 24 25
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P R O C E E D I N G S 1
1:03 p.m.
2 MR. PICKETT: Welcome and good afternoon.
3 I would like to thank everybody for attending this 4
meeting. My name is Douglas Pickett. And I am the 5
Indian Point Project Manager for the Office of Nuclear 6
Reactor Regulation.
7 We are here today to allow the Petitioner, 8
Riverkeeper, and Mark Leyse, to address the Petition 9
Review Board known as the PRB regarding the 2.206 10 Petition dated November 14, 2012. I am the Petition 11 Manager for the Petition. The Petition Review Board 12 Chairman is Mr. John Lubinski.
13 As part of the PRB's review of this 14 petition, Riverkeeper has requested this opportunity to 15 address the PRB. Today's meeting is scheduled for one 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> from 1:00 p.m. to 2:00 p.m. Eastern Time.
17 The meeting is being recorded by the NRC 18 Operations Center and will be transcribed by a court 19 reporter. The transcript will become a supplement to 20 the Petition. The transcript will also be made publicly 21 available.
22 I'd like to open this meeting with 23 introductions. As we go around the room, please be sure 24 to clearly state your name, your position and the office 25
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that you work for within the NRC for the record.
1 I'll start with myself. Douglas Pickett.
2 I'm the Petition Manager.
3 MR. MALLIAKOS: I'm Asimios Malliakos from 4
the Office of Federal and State Materials and 5
Environmental Management Programs.
6 MR. SALLMAN: My name is Ahsan Sallman from 7
the Containment and Ventilation Branch in NRR.
8 MR. TITUS: My name is Brett Titus. I'm a 9
technical reviewer in the Division of Safety Systems, 10 NRR.
11 CHAIRMAN LUBINSKI: I'm John Lubinski.
12 I'm the Director of the Division of License Renewal in 13 the Office of Nuclear Reactor Regulation.
14 MR. HAIR: Chris Hair of the Office of 15 General Counsel.
16 MS. RUSSELL: Andrea Russell, 2.206 17 coordinator, NRR.
18 MR. FARZAM: Farhad Farzam, Mechanical 19 Civil Engineer Branch, NRR.
20 MR.
PICKETT:
We've completed 21 introductions of NRC Headquarters. I understand we had 22 someone from the Office of Research.
23 MR.
NOTAFRANCESCO:
I'm Allen 24 Notafrancesco, RES Fuel and Containment Development 25
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Branch.
1 MR. PICKETT: Okay. Would the Regional 2
Office identify yourself please?
3 MR. DOERFLEIN: Yes, this is Larry 4
Doerflein. I'm the Chief of Engineering Branch 2, NRC 5
Region I.
6 MR. BURRITT: Art Burritt, Region I, 7
Division of Reactor Projects responsible for inspections 8
at Indian Point.
9 MR. BICKETT: Brice Bickett, NRC Region I, 10 Senior Project Engineer.
11 MR. PICKETT: Is that all from the Regional 12 Office?
13 (No verbal response.)
14 I guess it is. Would the licensee like to 15 introduce themselves?
16 MR. IRANI: This is Ardy Irani from Indian 17 Point.
18 MR. PICKETT: Is there anyone more from the 19 licensee?
20 (No verbal response.)
21 Okay. Ms. Brancato, would you please 22 introduce yourself for the record?
23 MS. BRANCATO: This is Deborah Brancato.
24 I'm a staff attorney for Riverkeeper.
25
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MR. PICKETT: And, Mr. Leyse, would you 1
please introduce yourself for the record?
2 MR. LEYSE: Sure. Mark Leyse, Consultant 3
for Riverkeeper.
4 MR. PICKETT: It is not required for 5
members of the public to introduce themselves for this 6
call. However, if there are members of the public on the 7
phone that wish to do so at this time, please state your 8
name for the record.
9 (No verbal response.)
10 I would like to emphasize that we each need 11 to speak clearly and loudly to make sure that the court 12 reporter can accurately transcribe this meeting. If you 13 do have something that you would like to say please first 14 state your name for the record. For those dialing into 15 the meeting, please remember to mute your phones to 16 minimize any background noise or distractions. If you 17 do not have a mute button, this can be done by pressing 18 the keys *6. To unmute press the *6 keys again. Thank 19 you.
20 At this time, I'll turn it over to the PRB 21 Chairman John Lubinski.
22 CHAIRMAN LUBINSKI:
Good afternoon, 23 everyone. Welcome to this meeting regarding the 2.206 24 Petition submitted by Riverkeeper. I'd like to first 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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share some background on our process.
1 Section 2.206 of Title 10 of the Code of 2
Federal Regulations describes the petition process, the 3
primary mechanism for the public to request enforcement 4
action by NRC in a public process. This process permits 5
anyone to petition NRC to take enforcement type action 6
related to NRC licensees or licensed activities.
7 Depending on the results of its evaluation, 8
NRC could modify, suspend or revoke an NRC issued license 9
or take any other appropriate enforcement actions to 10 resolve a problem. The NRC staff's guidance on the 11 disposition of 2.206 petition request is in NRC 12 Management Directive 8.11 which is publicly available.
13 The purpose of today's meeting is to give 14 the Petitioner an opportunity to provide any additional 15 explanation or support for the Petition before the 16 Petition Review Board's initial consideration and 17 recommendation. This is not a hearing nor is it an 18 opportunity for the Petitioner to question or examine the 19 PRB on the merits or the issues presented in the petition 20 request. No decisions regarding the merits of this 21 Petition will be made at this meeting.
22 Following this meeting, the Petition Review 23 Board will conduct its internal deliberations. The 24 outcome of this meeting will be discussed with the 25
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Petitioner.
1 The Petition Review Board typically 2
consists of a chair, usually a manager at the senior 3
executive service level at the NRC. It has a petition 4
manager and a Petition Review Board coordinator. Other 5
members of the Board are determined by the NRC staff based 6
on the content of the information in the petition 7
request.
8 At this time, I would like to ask the 9
Petition Review Board members to introduce themselves.
10 I'll start by restating that I'm John Lubinski, the 11 Petition Review Board Chair. Our Petition Manager is.
12 MR. PICKETT: Doug Pickett.
13 CHAIRMAN LUBINSKI:
And our PRB 14 coordinator.
15 MS. RUSSELL: Andrea Russell.
16 CHAIRMAN LUBINSKI: Members of the Board.
17 We'll start here at Headquarters.
18 MR. SALLMAN: Ahsan Sallman.
19 MR. MALLIAKOS: Asimios Malliakos.
20 Mr. Farzam: Farhad Farzam 21 CHAIRMAN LUBINSKI: And from our Regional 22 Office we have two additional Board members. If we could 23 start with Larry.
24 MR. DOERFLEIN: Larry Doerflein.
25
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CHAIRMAN LUBINSKI: And Brice.
1 MR. BICKETT: Brice Bickett.
2 CHAIRMAN LUBINSKI: We also obtained 3
advice from our Office of General Counsel who today is 4
represented by Christopher Hair.
5 As described in our process, the NRC staff 6
may ask clarifying questions in order to better 7
understand the Petitioner's presentation and to reach a 8
reasoned decision whether to accept or reject the 9
Petitioner's request for review under the 2.026 process.
10 I would like to summarize the scope of the 11 Petition under consideration and the NRC activities to 12 date.
13 On November 14, 2012, Riverkeeper submitted 14 to the NRC a 2.206 Petition regarding Indian Point Units 15 2 and 3. The Petition was prepared by Mr. Mark Leyse.
16 The Petition requests the permanent 17 shutdown of Indian Point Units 2 and 3 because fast 18 hydrogen deflagration or detonation could breach the 19 containments following a severe reactor accident 20 exposing the public to a large radiological release.
21 The Petitioner states that there is no assurance that 22 Entergy, the Licensee, could control the total quantity 23 of hydrogen that would be generated in the event of a 24 severe reactor accident at Indian Point. And it is 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 10 highly likely that there would be hydrogen combustion in 1
the containment either in the form of a deflagration or 2
a detonation.
3 As the basis for this request, the 4
Petitioner states the following: The Indian Point site 5
is located within one or two miles of the Ramapo seismic 6
zone. Research suggests the site is susceptible to an 7
earthquake of 7.0 magnitude on the Richter scale. And 8
the Petition states the site was only designed for a 6.0 9
magnitude earthquake.
10 As a result, the sites are susceptible to 11 a severe reactor accident. A population of nearly 17 12 million people resides within a 50 mile radius of the site 13 and they would be adversely impacted by a large 14 radiological release.
15 The NRC's resolution of combustible gas 16 control issues for large, dry containments such as Indian 17 Point did not assume hydrogen deflagration or 18 detonation. Indian Point 2 has passive autocatalytic 19 recombiners or PARs, which could be overwhelmed by the 20 production of hydrogen during a severe reactor accident.
21 PARs have been observed to have unintended ignitions 22 during experiments with high initial concentrations of 23 hydrogen. These ignitions could lead to a deflagration 24 or detonation.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 11 Indian Point 3 has electrical powered, 1
thermal hydrogen recombiners that according to the 2
Petitioner could also have unintended ignitions 3
following a severe reactor accident. While the Indian 4
Point containment design pressure is 47 psi, the 5
Petitioner acknowledges that the ultimate containment 6
failure pressure is estimated to be approximately 126 7
psi.
8 For informational purposes, the Petitioner 9
refers to estimated peak containment pressures at three 10 large dry containments similar to Indian Point. The 11 Petitioner acknowledges the numbers for these other 12 plants cannot be directly applicable to Indian Point due 13 to factors such as the size of the reactor core which 14 dictates the volume of hydrogen that can be produced, the 15 containment volume that determines the hydrogen 16 concentration and the distribution of steel and concrete 17 masses that affect steam considerations.
18 The Petitioner notes that due to the overall 19 lack of data, estimated containment failure pressures 20 are questionable and states that the Indian Point 21 containments could fail from the maximum possible 22 combustion load.
23 Finally, the Petitioner states that the 24 containment integrity and essential systems could be 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 12 compromised by internally generated missiles caused by 1
flame acceleration or deflagration to detonation 2
transition. The Petitioner notes that the Licensee's 3
severe accident mitigation alternatives, also known as 4
SAMA, do not address internally generated missiles 5
resulting from hydrogen combustion.
6 I would now like to discuss the NRC 7
activities to date. On November 16, 2012, the Petition 8
Manager contacted the Petitioner to discuss the 10 CFR 9
2.206 process and to offer the Petitioner an opportunity 10 to address the PRB by phone or in person.
11 On November 19, 2012, the Petitioner 12 requested to address the PRB by phone prior to the PRB's 13 initial meeting to make the initial recommendation to 14 accept or reject the Petition for review. The 15 Petitioner and NRC agreed on this date and time for the 16 Petitioner to address the PRB.
17 As a reminder for the phone participants, 18 please identify yourselves if you make any remarks as 19 this will help us in preparation of the meeting 20 transcript that will be made publicly available. Thank 21 you.
22 At this time, I'd like to turn to Ms.
23 Brancato to allow you to provide any information you 24 believe the PRB should consider as part of this Petition.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 13 MS. BRANCATO: Thank you. This is Deborah 1
Brancato. As I indicated earlier, I'm the Staff 2
Attorney with Riverkeeper. I would like to first thank 3
you for convening and for the opportunity to address the 4
Petition Review Board in order to present additional 5
information on the Petition.
6 I would like to make a few brief opening 7
remarks and then I'll turn it over to Mark Leyse, the 8
author of the Petition, who can explain the technical 9
basis for the Petition and answer any questions that have 10 arisen to date.
11
- First, by way of some background, 12 Riverkeeper is a 501(c)(3) nonprofit membership 13 supported environmental organization. For about the 14 past 40 years, Riverkeeper's work has focused on 15 protecting the Hudson River from pollution in one form 16 or another.
17 We've been involved with Indian Point 18 issues initially with environmental concerns when the 19 plant was first licensed in the 1970s. And subsequently 20 after the terrorists' attacks of September 11th, 21 Riverkeeper filed a 2.206 petition related to safety and 22 security issues at that time. And since that time 23 Riverkeeper has been involved in a range of safety and 24 Nuclear Regulatory Commission issues related to Indian 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 14 Point. Riverkeeper also currently is an admitted 1
Intervenor in the Indian Point license renewal 2
proceeding where we have raised and are adjudicating 3
various safety-related issues.
4 Riverkeeper has significant safety 5
concerns about the current and potential future 6
operation of Indian Point and in particular about the 7
ability of the plant to manage the build up of hydrogen 8
during severe accidents. I would like to thank Mr.
9 Lubinski for summarizing Riverkeeper's petition and 10 spelling out our request for relief.
11 But I would like to briefly elaborate on 12 some of the issues that Mr. Lubinski touched upon that 13 demonstrate why Riverkeeper believes that this petition 14 under Section 2.206 should be accepted and assessed 15 independently and not be combined with any other 16 petitions or proceedings that are currently before the 17 NRC.
18 The main concern here that we have is that 19 in the event of a severe accident and meltdown situation, 20 Entergy, the owner and operator of Indian Point, would 21 not be able to control the large amount of hydrogen that 22 could accumulate and avoid a breach of containment and 23 associated large scale radiological release to the 24 public surrounding the plant.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 15 The prospect of that kind of failure 1
implicates several significant site-specific concerns.
2 First, the risk of a large scale radiological release is 3
very concerning because of the location of Indian Point.
4 It is located just 25 miles away from the border of New 5
York City and 34 miles from Time Square which is roughly 6
midtown Manhattan and has an extremely high surrounding 7
population density.
8 Within 10 miles of the plant, there are 9
approximately 300,000 people and within 50 miles of the 10 plant, there are approximately 17 to 20 million people 11 either living or living and working. And Riverkeeper 12 continues to have ongoing concerns about the feasibility 13 of evacuating both the 10 mile emergency planning zone 14 surrounding the plant and the larger 50 mile zone around 15 Indian Point. This is, of course, a relevant 16 consideration in light of NRC's recommendation to 17 Americans living in Japan to evacuate 50 miles from the 18 Fukushima nuclear plant during that nuclear disaster.
19 In addition to the location of Indian Point, 20 the possibility of a large scale radiological release due 21 to uncontrollable hydrogen buildup during an accident 22 also necessitates site-specific consideration in light 23 of the recent information cited in the petition about the 24 enhanced seismic risk at the plant.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 16 To elaborate a little, in particular, 1
there's a 2008 study that was conducted by Lamont-Doherty 2
Earth Institute seismologist and he concluded that in 3
addition to the Ramapo Fault that was already known to 4
be near Indian Point, that an additional fault line 5
exists and intersects with the Ramapo Fault very close 6
to Indian Point. And this study concluded that Indian 7
Point was in fact at risk of an earthquake of up to 7.0 8
in magnitude on the Richter scale.
9 And in contrast the owner of the plant, 10 Entergy, has publicly indicated that Indian Point Units 11 2 and 3 could only withstand an earthquake of up to 6.1 12 on the Richter scale. And in addition the NRC has 13 conducted a seismic risk study in 2010 which indicated 14 that Indian Point Unit 3 is at an increased risk of core 15 damage under core damage frequency calculations from an 16 earthquake.
17 So Riverkeeper has significant concerns 18 that the plant may not be built or designed to withstand 19 a maximum earthquake that could be experienced in the 20 area surrounding the plant which places the plant at risk 21 for a severe accident meltdown scenario and the hydrogen 22 build-up situation that is of concern in the 2.206 23 petition.
24 And the information from Columbia to our 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 17 knowledge has never been assessed or considered by the 1
NRC. And the NRC's assessment of seismic risk has 2
likewise not been considered in any formal regulatory 3
process related to Indian Point that Riverkeeper is aware 4
of.
5 And lastly Riverkeeper is highly concerned 6
about the potential consequences of the large scale 7
radiological release that is possible as a result of 8
hydrogen build-up as discussed in the Petition.
9 Riverkeeper previously commissioned a report from the 10 Union of Concerned Scientists by a Dr. Ed Lyman which is 11 called "Chernobyl on the Hudson" and this report 12 describes the extremely catastrophic near-term and 13 long-term fatalities, economic consequences and 14 property damage that would occur in the region 15 surrounding Indian Point in the event of significant 16 radiological release from the plant.
17 And, so in sum, in light of the location of 18 Indian Point, the increased seismic risk near the plant 19 and the catastrophic consequences of a large scale 20 radiological release that would occur in the event of a 21 hydrogen induced explosion, there is a high degree of 22 site-specific concern raised in the Petition.
23 At this
- point, that concludes my 24 preliminary comments and I will turn it over to Mark 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 18 Leyse. Thank you.
1 MR. LEYSE: Hello. This is Mark Leyse.
2 First, I would like to thank the Petition Review Board 3
for this meeting and giving us an opportunity to present 4
information pertinent to the Riverkeeper 2.206 Petition 5
regarding Indian Point dated November 14, 2012.
6 And, first, I just want to touch upon a 7
couple of things that Mr. Lubinski had said in his 8
introduction. Sorry to be pedantic, but I think that 9
when 10 CFR Section 50.44 was revised I think it did take 10 deflagrations into account. I think there have been 11 statements issued from the NRC basically saying that a 12 deflagration within a PWR large dry containment would be 13 lower than the design pressure of the containment.
14 But we are more concerned about fast 15 deflagrations and also detonations. So that's just 16 something, hydrogen explosion that occurred in Three 17 Mile Island in Unit 2 accident was there a deflagration.
18 And indeed that was lower than the design pressure of 19 Three Mile Island Containment. However, there are cases 20 where it could be a fast deflagration which would exceed 21 design pressure of the containment or detonation which 22 would also exceed the design pressure.
23 And then just the second thing I want to 24 point out is our concerns with internally generated 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 19 missiles. They could also be generated from direct 1
detonation. So that's just something I wanted to 2
clarify. But otherwise I thought your introduction was 3
quite good. I just wanted to address that.
4 Now, first, I would like to discuss an email 5
that Mr. Pickett, the Petition Review Boards Manager 6
sent to Deborah Brancato on December 4, 2012. Mr.
7 Pickett's email has some important questions for us which 8
I will answer shortly.
9 But I did want to point out that Mr.
10 Pickett's email states that he had requested that the 11 Riverkeeper 2.206 Petition be make publicly available 12 via ADAMS, Accession No.ML12321A317. However, I do not 13 believe that the Petition is publicly available yet. At 14 least it wasn't available when I searched for it last 15 night. I tried to find it in ADAMS and I also checked 16 with the Accession number directly. And it didn't come 17 up. So that's just something I wanted to mention.
18 CHAIRMAN LUBINSKI: Thank you very much, 19 Mr. Leyse. This is John Lubinski. Mr. Pickett will 20 follow up on that and send an email who is participating 21 in this call with what he finds. And if it is not public, 22 a determination of when it will be made public. Thank 23 you.
24 MR. LEYSE: Okay. Thank you. Yes. Mark 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 20 Leyse continuing.
1 Anyway, I would like to now address some of 2
the statements and questions that Mr. Pickett's email 3
asks and I'm now quoting. "The Petition says it is plant 4
specific for Indian Point. However, on page 14, it 5
states that the Indian Point Unit 3 electrically-powered 6
thermal hydrogen recombiners could experience 7
unintended ignition. This would imply that they could 8
also cause hydrogen deflagrations or detonations 9
following a severe reactor accident.
10 During your presentation, would you please 11 discuss whether there is something unique about the 12 Indian Point Unit 3's recombiners or whether the NRC 13 staff should consider this scenario generically for the 14 industry?"
15 Well, as Deborah Brancato said, the 16 Petition is plant-specific for Indian Point. And it 17 also covers many issues besides electrically-powered, 18 thermal hydrogen recombiners. But that being said, I do 19 think that the fact that the Indian Point Unit's thermal 20 hydrogen recombiners could have unintended ignitions, 21 that is not a plant-specific issue because other plants 22 in the United States also have thermal hydrogen 23 recombiners.
24 Electrically-powered thermal hydrogen 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 21 recombiners are prone to have ignitions in the elevated 1
hydrogen concentrations that would occur in severe 2
accidents. And I think that such ignitions could cause 3
either hydrogen deflagrations or detonations in a severe 4
accident.
5 On this issue, Sandia National Laboratory's 6
1983 report entitled "Light-Water Reactor Hydrogen 7
Annual" states that thermal recombiners "use is limited 8
to containment atmospheres that are not within the 9
flammability units." And that "thermal hydrogen 10 recombiners could be an ignition source for a flammable 11 mixture in the containment."
12 Additionally, discussions of thermal 13 hydrogen recombiners, a 2011 IAEA report titled 14 "Mitigation of Hydrogen Hazards in Severe Accidents in 15 Nuclear Power Plants" states "below a hydrogen 16 concentration of about four percent thermal recombiners 17 may be used to further reduce the hydrogen 18 concentrations. Above this value, they can act as 19 igniters. Hence, their use has been only allowed if 20 ignition is allowed. Care is needed in using thermal 21 recombiners as they may be damaged by the burn and can 22 cause radioactive releases."
23 Clearly, if there were a severe accident at 24 Indian Point Unit 3, Entergy should not use the two 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 22 thermal hydrogen recombiners that are in the 1
containment. I do believe that the NRC should inform all 2
the licensees of plants that have thermal hydrogen 3
recombiners of the safety issue. It is an issue that 4
needs to be considered in severe accident management 5
guidelines.
6 Operators need to know that thermal 7
hydrogen recombiners can malfunction by having ignitions 8
in elevated hydrogen concentrations so that they know not 9
to run the recombiners in that environment. Or they know 10 that they should shut off recombiners if they have 11 actuated them earlier in an accident. But I do want to 12 point out that the safety issues with hydrogen 13 recombiners are not the main points of Riverkeeper's 14 petition.
15 Now, Mr. Pickett's December 4, 2012 email 16 also asked "Could you also discuss what sets this 17 petition apart from the Natural Resources Defense 18 Council petition dated April 16, 2012 and why shouldn't 19 the NRC simply combine the two petitions?"
20 Well, the NRDC petition simply asks that a 21 plant-specific type of hydrogen recombiner be removed 22 from IP2. IP2 is the only unit in the United States that 23 has passive auto-catalytic recombiners or PARs. IP2 has 24 two PARs which operators would not be able to control in 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 23 a severe accident. There is no way to turn them off.
1 The elevated hydrogen concentrations of the 2
severe accident, the PARs could malfunction by having 3
unintended ignition. In the event of a severe accident, 4
an ignition of a PAR could cause a hydrogen detonation 5
in IP2's containment.
6 Anyway, pointing out potential hazards of 7
PARs and asking that Entergy will move two PARs from IP2's 8
containment really has very little to do with the request 9
of the Riverkeeper petition which asks that Indian Point 10 be permanently shut down. So I do not think that the two 11 petitions should be combined.
12 Furthermore, NRDC's petition is not about 13 whether or not Indian Point's containment would 14 withstand detonations or not. However, Riverkeeper's 15 petition argues that the containments are vulnerable.
16 Before I proceed, I just wanted to see if 17 the Petition Review Board would have any questions 18 regarding what I just covered.
19 CHAIRMAN LUBINSKI: The members at 20 Headquarters have no questions. Region I, did you have 21 any questions with respect to those issues?
22 MR. DOERFLEIN: This is Larry Doerflein.
23 I don't.
24 MR. BICKETT: No questions here, John.
25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 24 This is Brice Pickett.
1 CHAIRMAN LUBINSKI: Okay. Thank you. No 2
questions. We'll turn it back to you, Mr. Leyse.
3 MR. LEYSE: Okay. Thank you. Mark Leyse.
4 Now I would like to highlight some of the 5
main issues Riverkeeper raised in the petition dated 6
November 14, 2012. In Sections 2A and 2B, the Petition 7
discusses plant-specific characteristics which Deborah 8
Brancato just discussed. And I want to point out that 9
on page nine there is a quote from NRC's resolution of 10 Generic Safety Issue 121 stating "It was believed that 11 plant-specific vulnerabilities may exist mainly due to 12 the effects of local hydrogen detonation activities.
13 For estimating the likelihood of local hydrogen 14 detonation and assessing the consequences would require 15 plant-specific information." So that's something from 16 the NRC's resolution of Issue 121.
17 I think just with that quote alone and other 18 information supplied in those sections I think it's 19 pretty clear that Riverkeeper's petition is 20 plant-specific. The Indian Point units have certain 21 specific characteristics that would affect the quantity 22 of hydrogen generated in the event of a severe accident 23 as well as the hydrogen distribution and combustion.
24 The Petition discusses information 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 indicating that Indian Point's large dry PWR 1
containments could be vulnerable to either hydrogen fast 2
deflagrations or detonations.
And Fukushima 3
demonstrated that the NRC's hydrogen experiments, many 4
of which were conducted at Sandia National Labs, just did 5
not replicate what would occur in a severe accident. So 6
I think a lot of the preparations at Indian Point are just 7
based on data that just may have perhaps been 8
unconservative.
9 I want to point out that in a September 8, 10 2011 ACRS meeting Dana Powers of Sandia National 11 Laboratories stated that "Not only do we have a hydrogen 12
-- We've got hydrogen detonations. And detonations are 13 just extremely hard to get. I mean even when you do them 14 in an experiment you have a tough time doing a detonation 15 because of the ignition problem. And we got them. And 16 it just strikes me that, gee, how much information do I 17 need to know about specifically Fukushima. I got 18 hydrogen. I see lots of ways of getting hydrogen. So 19 go take care of it."
20 Now I should point out -- end of quote, sorry 21
-- that most likely when he says, "Go take care of it" 22 is referring to BWR Mark 1s. However, I would venture 23 to say that this would be a problem at other containment 24 or other reactor designs. And the quote I just quoted 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 26 from Dana Power, that's from page 95 of the ACRS meeting 1
transcript. It's available in ADAMS at Accession No.
2 ML11256A117. And basically his point is that it's 3
difficult to get detonations in experiments because of 4
the ignition problems.
5 Yet of course there were detonations in the 6
Fukushima accident. So it seems that the experiment 7
were just not realistic. And that the conclusions from 8
such experiments could be nonconservative. Please keep 9
that in mind.
10 In Section 3C, the Petition discusses NRC 11 analyses which indicate that the pressure loads 12 resulting from combustion of the quantity of hydrogen 13 produced from a metal-water reaction of 100 percent of 14 the active fuel cladding link could cause either of 15 Indian Point's containments to fail. That's just the 16 results of those experiments which are -- not 17 experiments, I'm sorry -- analyses which are summed up 18 from inspections. It shows that a pressure that was 19 exerted on the containment wall exceeded that of the 20 design pressure. I think it exceeded it by about twice 21 the amount of the design pressure of those PWR large dry 22 containment.
23 As pointed out on page 21 of the Petition 24 and an NRC document from 2000 that is SECY-00-0198 states 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 27 that "more hydrogen could be produced in a severe 1
accident than would be produced from a metal-water 2
reaction of 100 percent of the active fuel cladding." So 3
that's something to keep in mind when reviewing the 4
results of the analyses that are discussed in Section 3C.
5 There could be scenarios where even more hydrogen would 6
be produced which could potentially explode.
7 And I want to point out that NRC 8
SECY-00-0198 also states that "a detonation would impose 9
a dynamic pressure load on the containment structure that 10 could be more severe than the static load from inadequate 11 deflagration."
12 I think the point there is just that you 13 could have a dynamic load that would be more severe than 14 a static load and this is significant because the NRC 15 analyses which are discussed in Section B-C for hydrogen 16 combustion of PWRs with large dry containments. They 17 were from pressure from adiabatic isochoric complete 18 hydrogen burns that the NRC's calculations do not take 19 into consideration flame acceleration resulting in 20 dynamic loads on the containment walls and dome.
21 The calculations are for adiabatic 22 isochoric complete combustion or AICC which is sometimes 23 termed constant volume explosion pressure. And there is 24 an IAEA report from 2011. The title again is "Mitigation 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 28 of Hydrogen Hazards in Severe Accidents in Nuclear Power 1
Plants." And that report states that "hydrogen 2
deflagration can pose various risks to the containment 3
and other plant systems. Combustion can have large 4
pressure spikes varying from relatively low pressure 5
loads bound by the AICC loads up to large loads from 6
accelerated flames and detonations." And such 7
acceleration can already occur above eight percent of 8
hydrogen if the containment has a concentration of 9
hydrogen that is eight percent of the volume. Okay.
10 Back to the quote "so that above that value the AICC load 11 may not always be the bounding value."
12 That sheds light on the fact that the 13 calculations that are discussed in B-C again were for 14 static loads and they were not for dynamic loads. So 15 that means that they kind of underestimated -- Well, 16 perhaps they were nonconservative at least in that aspect 17 of the calculations. They were nonconservative in that 18 they did not consider dynamic loads on the containment 19 walls.
20 Okay. In Section 3.2.2, the Petition 21 discusses analyses from the 1980s indicating that the 22 pressure loads resulting from the combustion of hydrogen 23 produced in a severe accident could cause either of 24 Indian Points' containments to fail. On pages 23 and 24 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 29 of the Petition, results of the analyses discussed in the 1
Power Authority of the State of New York in ConEdison's 2
title, "Indian Point Probabilistic Safety Study," are 3
mentioned. And those analyses are found at peak 4
pressures resulting from combustion exceeded the 5
estimated failure pressure of Indian Point's 6
containment.
7 And in Section 3D, the Petition discusses 8
analyses of the loss of offsite power accident for a 9
future nuclear power plant design. The analyses do not 10 directly apply to IndianPoint. However, they should be 11 instructive in that they provide a general idea of the 12 magnitude of the pressure loads that either containments 13 of Indian Point might be expected to occur if either a 14 hydrogen fast deflagration or detonation were to occur 15 in the event of a severe accident. The analyses model 16 future plant's containment which has a volume that is 17 about 20 percent larger than the volume of Indian Point's 18 containments.
19 And in Section 3E, the Petition discusses 20 reports that have stated that in the event of a severe 21 accident the containment integrity in the central safety 22 systems of a plant could be compromised by internally 23 generated missiles caused by other hydrogen deflagration 24 or detonation. And also that containment integrity 25
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 30 could be compromised by a global detonation.
1 And Section 3F focuses on stating that the 2
containment integrity essential to safety systems of a 3
plant could be compromised by internally generated 4
missiles caused by either a hydrogen deflagration or 5
detonation. On page 33, it is mentioned that the IAEA 6
stated in July 2011 that no analyses has ever been made 7
on the damage potential of flying objects generated by 8
a hydrogen explosion which could occur in a severe 9
accident.
10 And on page 34 it is mentioned that over 30 11 years ago in 1980 the safety issue of the damage potential 12 of the internally generated missiles caused by hydrogen 13 explosions was addressed in a Sandia National Laboratory 14 slide presentation entitled "Hydrogen Behavior and 15 Control." This slide presentation states that one of 16 the concerns of hydrogen combustion is that "detonations 17 may produce missiles which could jeopardize equipment or 18 breach the containments."
19 In the Sandia National Laboratories 20 entitled "Light-Water Reactor Hydrogen Manual" 21 published in August 1983 states "This may be generated 22 when combustion deflagration or detonation occurs in an 23 confined region or when a propagating combustion front 24 produces dynamic pressure loads on equipment. Such 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 31 missiles may pose a threat to containment structure 1
itself as well as representing a potential threat to 2
safety and control equipment." And the NRC has not 3
required Entergy to perform any severe accident safety 4
analyses for Indian Point on a damage potential of 5
internally generated missiles which could be caused 6
either by hydrogen deflagrations or detonations.
7 And I think it would also be important to 8
point out that I do not believe that Entergy has ever done 9
any analyses where they would consider hydrogen 10 explosions where there would be dynamic loads on the 11 containment walls and dome.
12 That pretty much concludes what I have to 13 say. I just want to point out that just I think the 14 information I just provided, some of which I've 15 highlighted, items that are in the Petition and I've 16 provided a few extra things that are not in the Petition.
17 But I think that this information supports the 18 Riverkeeper request that the NRC revoke the operating 19 licenses of Indian Point Units 2 and 3 because either 20 hydrogen fast deflagrations or detonations could breach 21 either of Indian Point's containments in the event of a 22 severe accident. Thereby, it would expose the public to 23 a large radiological release.
24 Thank you and I would be happy to answer any 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 32 questions that you may have.
1 CHAIRMAN LUBINSKI: This is John Lubinski.
2 Thank you, Mr. Leyse. And, Ms. Brancato, I appreciate 3
your introductory remarks as well.
4 Does anyone in our room here at 5
Headquarters, have any questions?
6 (No verbal response.)
7 Okay. Hearing none, let's go to our PRB 8
members that are in the regions. Larry, Brice, do you 9
have any questions?
10 MR. DOERFLEIN: This is Larry. I don't 11 have any questions, John.
12 MR. BICKETT: This is Brice Bickett. No 13 questions from my end.
14 CHAIRMAN LUBINSKI: Okay. Thank you.
15 We have a representative from the Licensee 16 on the line. Do you have any questions?
17 MR. IRANI: This is Ardy Irani. No 18 questions.
19 CHAIRMAN LUBINSKI: Okay. Thank you. If 20 we have no additional questions, before I conclude the 21 meeting, members of the public may provide comments 22 regarding the Petition and ask questions about the 2.206 23 petition process. However, as stated at the opening, 24 the purpose of this meeting is not to provide an 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 33 opportunity for the Petitioner or the public to question 1
or examine the PRB regarding the merits of the petition 2
request. Are there any members of the public on the line 3
that would like to ask any questions or make any comments 4
at this time?
5 (No verbal response.)
6 Okay. Hearing none, Ms. Brancato and Mr.
7 Leyse, thank you for taking the time to provide the NRC 8
staff with clarifying information on the Petition you've 9
submitted. Before we close, does the court reporter 10 need any additional information for the meeting 11 transcript?
12 COURT REPORTER: Yes, this is the court 13 reporter. Could I ask the Licensee representative to 14 spell his name please?
15 MR. IRANI: Yes, the last name is Irani, 16 I-R-A-N-I.
17 COURT REPORTER: And the first name.
18 MR. IRANI: The first name is Ardesar, 19 A-R-D-E-S-A-R.
20 COURT REPORTER: Thank you very much.
21 CHAIRMAN LUBINSKI: Any other questions 22 from the court reporte4r?
23 COURT REPORTER: No thank you.
24 CHAIRMAN LUBINSKI: Thank you. With that, 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 34 this meeting is concluded. And we will be terminating 1
the phone connection. Thank you everyone. Off the 2
record.
3 (Whereupon, at 1:51 p.m., the above 4
entitled matter was concluded.)
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