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