ML13176A429
| ML13176A429 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 05/29/2013 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Pickett D | |
| Shared Package | |
| ML13176A398 | List: |
| References | |
| G20120875, NRC-4235 | |
| Download: ML13176A429 (27) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board Riverkeeper Indian Point Nuclear Generating Unit Nos. 2 and 3 Docket Numbers: (50-247, 50-286)
Location:
Rockville, MD Date:
Wednesday, May 29, 2013 Edited by:
Douglas Pickett Work Order No.:
NRC-4235 Pages 1-26 ML13176A429 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.
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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 WEDNESDAY 9
MAY 29, 2012 10
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11 The conference call was held, John 12 Lubinski, Chairperson of the Petition Review Board, 13 presiding.
14 15 PETITIONER: RIVERKEEPER 16 PETITION REVIEW BOARD MEMBERS 17 JOHN
- LUBINSKI, Office of Nuclear Reactor 18 Regulation, Division of License Renewal 19 DOUGLAS PICKETT, PRB Petition Manager, Office of 20 Nuclear Reactor Regulation, Division of Operating 21 Reactor Licensing 22 ANDREA RUSSELL, PRB Coordinator, Office of 23 Nuclear Reactor Regulation, Generic Communications 24 Branch 25
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1 NRC HEADQUARTERS STAFF 2
RAJENDAR
- AULUCK, Japan Lessons Learned 3
Directorate 4
RICHARD DUDLEY, Office of Nuclear Reactor 5
Regulation, Rulemaking Branch 6
FARHAD
- FARZAM, Office of Nuclear Reactor 7
Regulation, Mechanical and Civil Engineering Branch 8
CHRISTOPHER HAIR, Office of General Counsel 9
ASIMIOS MALLIAKOS, Office of Federal and State 10 Materials and Environmental Management Programs 11 ALLEN NOTAFRANCESCO, Office of Research 12 AHSAN
- SALLMAN, Office of Nuclear Reactor 13 Regulation, Containment and Ventilation Branch 14 15 NRC REGIONAL STAFF 16 BRICE BICKETT, Region 1 Division of Reactor 17 Projects 18 PAUL KROHN, Region 1 Division of Reactor Safety 19 20 REPRESENTATIVES OF PETITIONER 21 DEBRA BRANCATO 22 MARK LEYSE 23 ALSO PRESENT 24 STEVEN PRUSSMAN, ENTERGY 25
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1 2
T-A-B-L-E O-F C-O-N-T-E-N-T-S 3
Welcome and Introductions, Doug Pickett............ 4 4
Opening Statement, Chair John Lubinski............. 7 5
Debra Brancato and Mark Leyse, Representatives for the 6
Petitioner........................................ 14 7
Q&A.............................................. 23 8
Adjourn 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24
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P-R-O-C-E-E-D-I-N-G-S 1
10:04 a.m.
2 MR. PICKETT: Welcome and good morning. I 3
would like to thank everybody for attending this meeting.
4 My name is Douglas Pickett and I am the Indian Point 5
project manager for the Office of Nuclear Reactor 6
Regulation.
7 We are here today to allow the petitioner, 8
Riverkeeper, assisted by Mr. Mark Leyse, to address the 9
Petition Review Board, known as the PRB, regarding 10 Riverkeeper's 2.206 petition dated November 14, 2012 11 concerning Indian Point Nuclear Generating Units 2 and 12
- 3. I am the petition manager for the petition. The 13 Petition Review Board Chairman is Mr. John Lubinski.
14 As part of the PRB's review of this petition 15 Riverkeeper has requested this opportunity to address 16 the PRB. Today's meeting is scheduled for one hour from 17 10:00 to 11:00 a.m. Eastern Time. The meeting is being 18 recorded by the NRC Operations Center and will be 19 transcribed by a court reporter. The transcript will 20 become a supplement to the petition. The transcript 21 will also be made publicly available.
22 I would 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. I'm Douglas 2
Pickett.
3 MR. SALLMAN: My name is Ahsan Sallman. I 4
work in the Containment and Ventilation Branch of NRR.
5 MR. AULUCK: I'm Rajendar Auluck. I'm in 6
the Japan Lessons Learned Directorate within the Office 7
of Nuclear Reactor Regulation.
8 MR. FARZAM: Farhad Farzam, Mechanical 9
Civil Engineering Branch, Office of Nuclear Reactor 10 Regulations.
11 MR. DUDLEY: Richard Dudley, Rulemaking 12 Project Manager in the Rulemaking Branch in the Office 13 of Nuclear Reactor Regulation.
14 MR. NOTAFRANCESCO: Allen Notafrancesco, 15 Office of Research involved in a number of hydrogen 16 related issues.
17 CHAIR LUBINSKI: John Lubinski. I'm the 18 Director of the Division of License Renewal in NRR and 19 I'm the Petition Review Board Chairman.
20 MR.
PICKETT:
We have completed 21 introductions at NRC headquarters. At this time are 22 there any NRC participants from headquarters on the 23 phone?
24 MS. RUSSELL: Yes. This is Andrea 25
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Russell, the PRB Coordinator in the Office of Nuclear 1
Reactor Regulation.
2 MR.
PICKETT:
Are there any NRC 3
participants from the regional office on the phone?
4 Are there any representatives for the 5
licensee on the phone?
6 MR. PRUSSMAN: Steven Prussman, Entergy.
7 MR. PICKETT: Ms. Brancato, would you 8
please introduce yourself for the record.
9 MS. BRANCATO: Yes. This is Debra 10 Brancato. I'm a staff attorney with Riverkeeper.
11 MR. PICKETT: And Mr. Mark Leyse, would you 12 please introduce yourself for the record?
13 MR. M. LEYSE: Sure. Mark Leyse.
14 MR. PICKETT: Mr. Robert Leyse, would you 15 introduce yourself for the record?
16 MR. R. LEYSE: No.
17 MR. PICKETT: It is not required for 18 members of the public to introduce themselves for this 19 call. However, if there are any members of the public 20 on the phone that wish to do so at this time, please state 21 your name for the record.
22 I would like to emphasize that we each need 23 to speak clearly and loudly to make sure that the court 24 reporter can accurately transcribe this meeting. If you 25
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do have something that you would like to say, please first 1
state your name for the record.
2 For those dialing into the meeting, please 3
remember to mute your phones to minimize any background 4
noise or distractions. If you do not have a mute button, 5
this can be done by pressing the keys
- 6. To unmute 6
press the
- 6 key again.
7 At this time I'll turn it over to the PRB 8
chairman John Lubinski.
9 CHAIR LUBINSKI: Good morning. Welcome to 10 this meeting regarding the 2.206 petition submitted by 11 Riverkeeper. 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, the 15 primary mechanism for the public to request enforcement 16 action by the NRC in a public process. This process 17 permits anyone to petition NRC to take enforcement type 18 action related to NRC licensees or licensed activities.
19 Depending on the results of this 20 evaluation, NRC could modify, suspend, or revoke an 21 NRC-issued license or take any other appropriate 22 enforcement actions to resolve a problem.
23 The NRC staff's guidance for the 24 disposition of 2.206 petition request is in Management 25
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Directive 8.11 which is publicly available. The purpose 1
of today's meeting is to provide the petitioner an 2
opportunity to comment on the initial recommendation of 3
the PRB to reject the Riverkeeper petition because it 4
asserts deficiencies within the Commission's 5
regulations on combustible gas control.
6 The PRB also recommends referring 7
Riverkeeper petition for rulemaking with regard to the 8
October 14, 2011 petition for rulemaking submitted by 9
NRDC. This meeting is not a hearing. Nor is it an 10 opportunity for the petitioner to question or examine the 11 PRB on the merits or the issues presented in the petition 12 request. No decision regarding the merits of the 13 petition will be made at this meeting.
14 Following this meeting the Petition Review 15 Board will conduct its internal deliberations. The 16 outcome of this internal meeting will be discussed with 17 the petitioner.
18 The Petition Review Board typically 19 consists of the Chairman, usually a manager at the senior 20 executive level at the NRC. It has a petition manager 21 and a PRB coordinator. Other members of the Board are 22 determined by the NRC staff based on the content of the 23 information in the petition request.
24 At this time I would like to introduce the 25
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Board. I am John Lubinski, the Petition Review Board 1
chairman. Doug Pickett is the petition manager for the 2
petition under discussion today. Andrea Russell is the 3
office's PRB coordinator.
4 Our technical staff includes Ahsan 5
Sallman of the Office of Nuclear Reactor Regulation, 6
Containment and Ventilation Branch; Farhad Farzam from 7
the Office of Nuclear Reactor Regulation, Mechanical and 8
Civil Engineering Branch; Asimios Malliakos, Office of 9
Federal and State Materials and Environmental Management 10 Programs; Brice Bickett from NRC's Region I Division of 11 Reactor Projects; and Paul Krohn from NRC's Region 1 12 Division of Reactor Safety.
13 We also obtain advice from our Office of General Counsel 14 represented by Christopher Hair.
15 As described in our process the NRC may ask 16 clarifying questions in order to better understand the 17 petitioner's presentation and to reach a reasoned 18 decision whether to modify the PRB's initial 19 recommendation.
20 I would like to summarize the scope of the 21 petition under consideration and the NRC activities to 22 date. On November 14, 2012 Riverkeeper submitted to the 23 NRC a 2.206 petition regarding Indian Point Units 2 and 24
- 3.
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 The petition was prepared by Mr. Mark Leyse.
1 The petitioner requested the permanent shutdown of 2
Indian Point Units 2 and 3 because fast hydrogen 3
deflagrations or detonations could breech the 4
containment following a severe accident exposing the 5
public to a large radiological release.
6 The petitioner states that there is no 7
assurance that Entergy, the licensee, could control the 8
total quantity of hydrogen that would be generated in the 9
event of a severe reactor accident at Indian Point. It 10 is highly likely that there would be hydrogen combustion 11 in the containment either in the form of a deflagration 12 or detonation.
13 As the basis for this request, the petition 14 states the following:
15 The Indian Point site is located within one 16 or two miles of the Ramapo seismic zone. Research 17 suggests the site is susceptible to an earthquake of 7.0 18 magnitude on the Richter scale and the petitioner 19 indicates the site was only designed for a 6.0 magnitude 20 earthquake. As a result, the sites are susceptible to 21 a severe reactor accident.
22 A population of nearly 17 million people 23 reside within a 50-mile radius of the site and they would 24 be adversely impacted by a large radiological release.
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 The NRC's resolution of combustible gas control issues 1
for large dry containment such as Indian Point did not 2
assume hydrogen deflagrations or detonations.
3 Indian Point 2 has passive autocatalytic 4
recombiners, or PARs, which could be overwhelmed by the 5
production of hydrogen during a severe reactor accident.
6 PARs have been observed to have unintended ignitions 7
during experiments with high initial concentrations of 8
hydrogen. These ignitions could lead to a deflagration 9
or detonation.
10 Indian Point 3 has electrically powered 11 thermal hydrogen recombiners that, according to the 12 petitioner, could also have unintended ignitions 13 following a severe reactor accident. While the Indian 14 Point containment design pressure is 47 psi, the 15 petitioner acknowledges that the ultimate containment 16 failure is estimated to be approximately 126 psi.
17 The petitioner notes that due to an overall 18 lack of data, estimated containment failure pressures 19 are questionable. It states that the Indian Point 20 containments could fail from the maximum possible 21 combustion load.
22 Finally, the petitioner states that the 23 containment integrity and essential system could be 24 compromised by internally generated missiles caused by 25
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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the licensee's severe accident mitigation alternatives, 2
known as SAMA, do not address internally generated 3
missiles resulting from hydrogen combustion.
4 Allow me to discuss the NRC activities to 5
date. On November 16, 2012, the petitioner manager 6
contacted the petitioner to discuss the NRC 2.206 process 7
and to offer the petitioner an opportunity to address the 8
PRB by phone or in person. On December 20, 2012 the 9
petition assisted by Mr. Mark Leyse addressed the PRB in 10 advance of the PRBs initial deliberations on the 11 petition. On January --
12 COURT REPORTER: This is the court 13 reporter. Can non-speakers please mute their phones at 14 this time.
15 CHAIR LUBINSKI: Thank you. On January 17 16 and February 20, 2013, the PRB met internally to discuss 17 the Riverkeeper petition and to make its initial 18 recommendation. The PRB concluded that the petitioner 19 asserted deficiencies in the Commission's regulations 20 regarding post-accident generation of hydrogen and the 21 subsequent modeling of combustion.
22 In accordance with NRC Management Directive 23 8.11 this finding supports rejecting the petition from 24 review under 10 CFR 2.206. The PRB also noted that Mr.
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 Mark Leyse, who prepared the Riverkeeper petition, also 1
prepared the October 2011 NRDC 2.802 petition for 2
rulemaking proposing rulemaking to revise the 3
Commission's regulations on combustible gas control.
4 The PRB also recommended that the Riverkeeper 2.206 5
petition be referred to the NRDC rulemaking petition.
6 On March 27, 2013 the PRB's initial 7
recommendation was submitted to senior NRR management 8
for approval. This approval was provided on March 29, 9
2013. On March 29, 2013 the petitioner was informed that 10 the PRB's initial recommendation was to reject the 11 petition because the petitioner asserted deficiencies 12 within existing NRC rules.
13 In addition, the PRB recommended referring 14 the Riverkeeper 2.206 petition to rulemaking under the 15 NRDC petition noted previously. At the time Riverkeeper 16 was offered an opportunity to address the PRB regarding 17 its initial recommendation. Finally, on April 23, 2013 18 Riverkeeper and NRC agreed upon today May 29th, for their 19 second petition before the PRB.
As a reminder 20 for the phone participants, please identify yourself if 21 you make any remarks as this will help us in the 22 preparation of the meeting transcript that will be made 23 publicly available. Thank you. Also, as a reminder, 24 when you're not talking please mute your phone so that 25
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1 Ms. Brancato, I will turn over to you to 2
allow you to provide any information you believe the PRB 3
should consider as part of this petition.
4 MS. BRANCATO: Thank you. This is Debra 5
Brancato. I'm a staff attorney with Riverkeeper.
6 First, I just wanted to thank you for the opportunity to 7
address the PRB in this follow-up conference call.
8 Riverkeeper disagrees with the PRB's initial 9
recommendation to reject Riverkeeper's 2.206 petition.
10 As Mr. Leyse will discuss in further detail, 11 the petition does present site-specific concerns for 12 which generic consideration and another form of 13 rulemaking proceeding is not appropriate and which 14 warrants the PRB's acceptance of the petition for further 15 review and consideration.
16 To the extent the PRB ultimately decides to 17 uphold this initial recommendation to reject 18 Riverkeeper's petition, then in the alternative only 19 does Riverkeeper support any recommendation that the 20 issues and concerns raised in our 2.206 petition be fully 21 considered in the context of petition for rulemaking 22 PRM-50-103.
23 With that very short introductory remark, 24 I'll turn it over to Mr. Leyse to discuss in further 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 detail why we disagree with the PRB's initial 1
recommendation. Thank you.
2 MR. M. LEYSE: Mark Leyse speaking. Thank 3
you. First, I would like to thank the Petition Review 4
Board, PRB, for this second meeting. In this second PRB 5
meeting I will respond to the PRB's initial decision to 6
not consider Riverkeeper's 2.206 petition.
7 In an email dated March 29, 2013, that Doug 8
Pickett, the PRB manager sent to Debra Brancato of 9
Riverkeeper, there is an explanation of the PRB's initial 10 decision. The email states that, "The PRB's initial 11 recommendation is to reject the petition because the 12 petitioner asserts deficiencies within existing NRC 13 rules.
14 In addition, the PRB recommends referring 15 the Riverkeeper petition to rulemaking under PRM-50-103.
16 I guess PRM-50-103 was just covered. That's the NRDC 17 rulemaking petition that is requesting revisions to the 18 NRC's regulations on combustible gas control.
19 First, I would like to say that I think that 20 Riverkeeper's 2.206 petition does raise a number of 21 issues that are plant specific. For one thing, Indian 22 Point Unit 2 is the only unit licensed by the NRC that 23 has passive autocatalytic recombiners, PARs.
24 In the event of a severe accident, there is the 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 possibility that a PAR will malfunction by having an 1
ignition. Such an ignition could cause a detonation 2
that could potentially jeopardize Unit 2 containment.
3 That would most likely be in the form of a deflagration 4
that would transition to a detonation.
Then on 5
page 6 through 8 of the petition we cover plant specific 6
characteristics regarding the location of Indian Point.
7 On pages 8 and 9 of the petition we cover plant specific 8
characteristics regarding the particular volume of 9
Indian Point's containments as well as the particular 10 distribution of steel and concrete masses in the 11 containments.
12 Then, finally, the NRC itself in its 13 resolution of Generic Safety Issue 121 stated, "It was 14 believed that plant specific vulnerabilities may exist 15 mainly due to the effects of local hydrogen detonation 16 activities for estimating the likelihood of local 17 hydrogen detonation and accessing the consequences would 18 require plant specific information."
19 The second problem with the PRB's initial 20 recommendation to reject the petition and referring it 21 to the rulemaking branch is that the rulemaking process 22 take years, decades in some cases. It could take more 23 than 10 years for the NRC to correct the deficiencies in 24 its current regulations on combustible gas control.
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 Unfortunately the NRC has decided to 1
relegate combustible gas control safety issues to the 2
lowest priority of its response to the Fukushima Dai-ichi 3
accident. There is a very important reason that the PRB 4
should accept Riverkeeper's petition. I think there are 5
plenty of plant specific issues to justify the PRB 6
accepting the petition.
7 As discussed in the petition, Indian Plant 8
was built within a couple miles of the Ramapo seismic 9
zone. Research suggests that Indian Point is 10 susceptible to an earthquake of 7.0 in magnitude on the 11 Richter scale.
12 Hence, if there were a large earthquake, 13 there could be a severe accident at Indian Point. Severe 14 accidents can also occur without being caused by natural 15 disasters. Three Mile Island Unit 2 accident was not 16 caused by a natural disaster.
17 Or there could be perhaps a fire at Indian 18 Point that could cause a severe accident. Incidentally, 19 the NRC has allowed Indian Point to have lower fire 20 protection standards than are permitted at other 21 commercial buildings in New York.
22 Now I will discuss information that 23 indicates that Indian Point's large dry PWR containments 24 could be vulnerable to hydrogen combustion. The 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 Fukushima Dai-ichi accident demonstrated that the NRC's 1
hydrogen experiments, many of which were conducted at 2
Sandia National Laboratories, SNL, just did not 3
replicate what could occur in a severe accident.
4 In the September 8, 2011 ACRS meeting Dana 5
Powers of SNL said that, "It's extraordinarily hard to 6
get" detonations in experiments because of ignition 7
problems. He pointed out that there were detonations in 8
the Fukushima Dai-ichi accident. It seems to me that the 9
experiments that have been conducted just were not 10 realistic enough so conclusions from such experiments 11 could be non-conservative.
12 I want to point out that the NRC's 13 SECY-00-0198 states that, "A detonation would impose a 14 dynamic pressure on the containment structure that could 15 be more severe than the static load from an equivalent 16 deflagration." The point is that a dynamic pressure 17 load on the containment could be more severe than the 18 static load.
19 In a July 2011 IAEA report, Mitigation of 20 Hydrogen Hazards in Severe Accidents in Nuclear Power 21 Plants states, "Hydrogen deflagration can pose various 22 risks to the containment and other plant systems.
23 Combustion can give large pressure spikes varying 24 from relatively low pressure loads bound by AICC loads, 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 adiabatic isochoric complete combustion loads, up to 1
large loads from accelerated flames and detonations.
2 Such acceleration can already occur above 8 percent 3
hydrogen volume so that above that value the AICC load 4
may not always be the bounding value."
5 The NRC may have determined that Generic 6
Safety Issue 121, hydrogen control for large dry PWR 7
containments, has been resolved. However, there are 8
calculations that indicate that hydrogen combustion 9
could cause a large dry PWR containment to fail.
10 Such calculations were done in 1982 in the 11 Indian Point probabilistic safety study by the power 12 authority of the State of New York and Con Edison. This 13 is covered in the petition on pages 23 and 24. Some of 14 the calculations found that the peak pressure could reach 15 160, 169, about 157, and 180 pounds per square inch.
16 17 Absolutes were greater. Such results 18 indicate that hydrogen combustion could, in fact, cause 19 Indian Point's containments to fail because the 20 estimated failure pressure of Indian Point's 21 containments is about 141 pounds per square inch 22 absolute.
23 Since these calculations were done back in 24 1982, it's very doubtful that these calculations modeled 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 loads from flame acceleration. Hence, they would have 1
been for static loads and not for dynamic loads so they 2
could be actually non-conservative in some ways.
3 Riverkeeper's petition does discuss the 4
fact that in a severe accident more hydrogen could be 5
produced than not produced from a reaction, a metal water 6
reaction of 100 percent of the active fuel cladding 7
length.
8 Despite that fact, the NRC does not seem to 9
be too worried about large concentrations of hydrogen 10 building up and exploding in a severe accident if it 11 occurs -- if it were to occur at a PWR with a large dry 12 containment.
13 In a recent proposed decision the NRC made 14 regarding 2.206 petition that NRDC, Natural Resources 15 Defense Council, submitted regarding Indian Point Unit 16 2, the NRC stated, "Hydrogen deflagrations are the most 17 likely mode of combustion in degraded core accidents.
18 The likelihood in nature of deflagrations inside 19 containments are influenced by gas mixture composition 20 and availability of ignition sources.
21 Due to the small amounts of energy needed 22 to ignite combustible mixtures, there are numerous 23 potential ignition sources such as sparks from 24 electrical equipment, electrostatic discharges, hot 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 jets, gases, hot surfaces including PARs, core-melt 1
particles, etc."
2 In that same decision the NRC concluded 3
that, "Multiple ignition sources would be present in the 4
containment to initiate combustion at lower flammability 5
limits which would be expected to maintain hydrogen 6
concentrations below detonable levels."
7 It is clear that the NRC has overlooked the 8
fact that a hydrogen deflagration could transition into 9
a detonation in a severe accident at a PWR with a large 10 dry containment. Of course, the NRC is correct that in 11 a severe accident hydrogen could randomly deflagrate 12 when its concentrations were low because only a small 13 quantity of energy is required for igniting hydrogen.
14 However, other scenarios could also occur.
15 In a severe accident the average hydrogen concentration 16 in the containment could reach 16 volume percent or 17 higher. Local concentrations could be much higher.
18 Hermit Karwat, K-A-R-W-A-T, a safety expert, in a paper 19 he wrote entitled, "Igniters to Mitigate the Risk of 20 Hydrogen Explosion: A Critical Review" he concluded, 21 "Within the large geometries of PWR containments, a slow 22 laminar deflagration would be very unlikely. In most 23 cases highly efficient combustion modes must be 24 expected."
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 Scenarios in which large quantities of 1
steam were present in the containment, the hydrogen gas 2
could reach high concentrations because of the inerting 3
effect of steam. That would prevent the hydrogen from 4
igniting at lower concentrations.
5 After the steam condensed, which is 6
inevitable at some point, a deflagration could 7
transition into a detonation. A detonation could cause 8
the containment to fail. It could also in particular 9
cause the containment to fail at containment 10 penetrations. PWRs typically have about 90 containment 11 penetrations.
12 To conclude, I think this is a very serious 13 safety issue regarding Indian Point. As discussed, 14 Riverkeeper's 2.206 petition raises issues that are 15 plant specific. I would be happy to answer any questions 16 that you may have regarding what I discovered. Thank 17 you.
18 CHAIR LUBINSKI: Thank you, Mr. Leyse and 19 Ms.
Brancato.
We appreciate the additional 20 information.
21 At this time does the staff here at 22 headquarters have any questions for either Mr. Leyse or 23 Ms. Brancato? Okay. We have no questions here at 24 headquarters.
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 Did anyone from our Region I office join us?
1 MR. KROHN: Yes. Paul Krohn. I joined 2
about five minutes ago. I have no other questions.
3 CHAIR LUBINSKI:
Thank
- you, Paul.
4 Appreciate it.
5 Does the licensee have any questions at this 6
time?
7 MR. PRUSSMAN: No, we do not.
8 CHAIR LUBINSKI: Okay. Before I conclude 9
the meeting, members of the public may provide comments 10 regarding the petition and ask questions about the 2.206 11 petition process.
12 However, as stated at the beginning of the 13 meeting, the purpose of this meeting is not to provide 14 an opportunity for the petitioner or the public to 15 question or examine the PRB regarding the merits of the 16 petition request. Are there any members of the public at 17 this time who have any comments or questions? Okay.
18 Hearing none, Ms. Brancato and Mr. Leyse, 19 thank you for taking the time to provide the NRC staff 20 with clarifying information on the petition you've 21 submitted.
22 Before we close, does the court reporter 23 need any additional information for the meeting 24 transcript?
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 COURT REPORTER: I'm all right. Thank 1
you, sir.
2 CHAIR LUBINSKI: Okay. With that this 3
meeting is concluded and --
4 MR. M. LEYSE: Actually, I'm sorry. This 5
is Mark Leyse speaking. May I just ask one question and 6
if the PRB does not want to answer it, would you please 7
consider the question?
8 CHAIR LUBINSKI: Yes.
9 MR. M. LEYSE: Sorry. It's just something 10 I thought of after I concluded. Senator Edward J.
11 Markey's office asked the NRC some questions regarding 12 statements that were made by the NRC on this petition.
13 The NRC responded on March 7, 2013.
14 In the attachment it said that the NRC said 15 that in a severe accident management in the SAMGs, severe 16 accident management guidelines, they provide advice, and 17 I quote, "Indian Point operators with multiple options 18 to control hydrogen including controlled burns in 19 containment by starting motors and initiating sparks."
20 Now, do you really think of turning motors on in the 21 containment? Do you really consider that a controlled 22 burn? It seems like a very random thing.
23 CHAIR LUBINSKI: Mr. Leyse, thank you for 24 that additional piece of information. If you requested 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 it, we weren't going to respond to that today. We would 1
consider that in our deliberation and we will consider 2
that question as well as the information that is in 3
response to Congressman Markey.
4 MR. M. LEYSE: Sure, sure. I just want to 5
add there is an IAEA report which I know I've referred 6
to it in Riverkeeper 2.206 petition. It was published 7
in 2011 and the title is Mitigation of Hydrogen Hazards 8
and Severe Accidents in Nuclear Power Plants. They 9
talked about that. Also about switching components on 10 and off. They qualify it. They say, "The operator may 11 try to generate sparks by switching components on an 12 off."
13 You know, they -- just like I say -- I 14 appreciate the fact that you will consider this. It just 15 really doesn't seem to me to really be a controlled burn.
16 If that's what we have up at Indian Point to save the day 17 in the event of a meltdown accident, I think that is not 18 going to really save the day. I think that is a real 19 problem.
20 Then there is also the option of containment 21 venting but that would not really solve the problem 22 because there would be no way you could vent a large PWR 23 dry containment in a timely fashion such that you would 24 be able to prevent hydrogen combustion.
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 Anyway, that is the last comment I have.
1 Thank you.
2 CHAIR LUBINSKI: Thank you, Mr. Leyse. We 3
will consider that information in making our final 4
deliberation.
5 MR. M. LEYSE: Okay. Thank you.
6 CHAIR LUBINSKI: Okay. Thank you for that 7
additional information. At this point we will conclude 8
the meeting and terminate the phone connection. Thank 9
you, everyone.
10 (Whereupon, at 10:41 a.m. the conference 11 call was adjourned.)
12 13 14 15 16 17 18 19 20 21 22 23