ML14050A356
| ML14050A356 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/04/2014 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Lyon C | |
| Shared Package | |
| ML14050A357 | List: |
| References | |
| G20130776, LTR-13-0866, NRC-573, TAC MF3031 | |
| Download: ML14050A356 (34) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
2.206 Petition Review Board Docket Number: G20130776 Location: teleconference Date: Friday, February 4, 2014 Work Order No.: NRC-573 Pages 1-33 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 SEISMIC CONCERNS AT COLUMBIA GENERATING STATION 8 (G20130776) 9 +++++
10 TUESDAY 11 FEBRUARY 4, 2014 12 + + + + +
13 The conference call was held, Joe Giitter, 14 Chairperson of the Petition Review Board, presiding.
15 16 PETITIONER: CHARLES K. JOHNSON 17 PETITION REVIEW BOARD MEMBERS 18 JOE GliTTER, Director, Division of Risk 19 Assessment, NRR 20 FRED LYON, Petition Manager for 2.206 petition 21 MERRILEE BANIC, Petition Coordinator 22 YONG LI, NRR/DE/EMCB 23 MICHAEL MARKLEY, NRR 24 SERITA SANDERS, NRR 25 DAVID SULKOWSKY, OGC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 FACILITATOR:
2 BOB HAGAR 3
4 NRC REGION IV 5 DAN BRADLEY, Resident Inspector 6 JEREMY GROOM, Senior Resident Inspector 7
8 ALSO PRESENT:
9 DON GREGOIRE, Energy Northwest 10 NANCY MATE:.LA , Alliance for Democracy 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 P R 0 C E E D I N G S 2 1:09 p.m.
3 MR. HAGAR: Let's get started. And we've 4 done a few introductions to get started, but we'll do 5 more complete introductions in just a moment. Again, 6 my name is Bob Hagar, and I'm the facilitator for this 7 meeting. And my role is to ensure the meeting goes 8 smoothly and to make sure that everybody who has 9 something to say in this meeting has an opportunity to 10 say it without being interrupted.
11 And I want to remind everybody and want to 12 emphasize that the purpose of today's meeting is to 13 allow the petitioners from the Oregon and Washington 14 Physicians for Social Responsibility to address the 15 NRC's Petition Review Board regarding 10 CFR 2. 206 16 petition that was dated October 31st, 2013. And in 17 that petition, there was actually a letter. The 18 petitioners asked the NRC to take enforcement-related 19 action against Energy Northwest, the licensee for the 20 Columbia Generating Station.
21 Now, when I talk about the Petition Review 22 Board in this meeting, I may mention the PRB and other 23 speakers may do the same. So if we do that, and we 24 say PRB, we're just talking about the Petition Review 25 Board.
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4 1 Now, this meeting is scheduled for one 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, and it's being recorded, I think as everybody 3 recognizes, by the NRC Operations Center. And it will 4 be transcribed by a court reporter, and the resulting 5 transcript will become a supplement to the petition.
6 And before they file the transcript in ADAMS, which is 7 the NRC's document library, the Petition Review Board 8 wi 11 review it to ensure it doesn't contain any 9 allegations or sensitive information.
10 But, now, in order to produce a complete 11 and accurate transcript of this meeting, we have to 12 set some ground rules. First, everyone, please turn 13 off or mute your electronic devices if you're going to 14 speak. And everyone who is not speaking should mute 15 their phones, so we don't hear background noise on the 16 line. And if your phone doesn't have a mute button, 17 then you can mute it by pressing the key *6 and then 18 you can unmute it by pressing *6 again.
19 Another ground rule is that, when you do 20 speak, let's ensure that only one person speaks at a 21 time. And you've got to be close enough to the phone 22 and speak clearly and loudly to ensure that your voice 23 is recorded. And, also, the first time you speak, 24 please again state your name for the record so that 25 the person producing the transcript will have no doubt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W.
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5 1 about who's speaking.
2 So now let's take a minute and introduce 3 the meeting participants. Early on, we went through 4 the speakers for the court reporter. But now I want 5 to make sure we introduce all of the participants that 6 are on the line, and we'll do it in turn. And I've 7 introduced myself twice already, so I don't need to do 8 it again. But let's do, first, the NRC participants 9 that are at Headquarters in the room with Fred and 10 Joe. Could you please, let's introduce everybody, 11 even if they're not going to speak. And what I'd like 12 is your name, your position, and the organization you 13 represent.
14 MR. GIITTER: Okay. My name is Joseph 15 Giitter. I'm the Chairman of the PRB, and my position 16 is Division Director for the Division of Risk 17 Assessment in the Office of Nuclear Reactor Regulation 18 at the NRC.
19 MR. LYON: This is Fred Lyon. I am the 20 Petition Manager, and I am also a Project Manager in 21 the Division of Operating Reactor Licensing in the 22 Office of Nuclear Reactor Regulation of the NRC.
23 MS. BANIC: Lee Banic, Petition 24 Coordinator, NRR.
25 MR. CYLKOWSKI: This is David Cylkowski.
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6 1 I'm an attorney with the Office of General Counsel in 2 the NRC and serving as legal advisor to the PRB.
3 MR. MARKLEY: Mike Markley. I'm the Chief 4 of Licensing in the Division of Operator Reactor 5 Licensing for the Columbia Station, also with Nuclear 6 Reactor Regulation.
7 MR. LI: My name is Yong Li. I'm an NRC 8 seismologist.
9 MR. LYON: And that' s everyone here, Bob.
10 MR. HAGAR: Thank you. Now could we have 11 the NRC participants in the Columbia resident 12 inspector office introduce themselves?
13 MR. GROOM: Yes. This is Jeremy Groom.
14 I'm from NRC Region IV. I'm the Senior Resident 15 Inspector at Columbia Generating Station.
16 MR. BRADLEY: I'm Dan Bradley, Resident 17 Inspector, NRC, at Columbia Generating Station.
18 MR. HAGAR: All right. Next, are there 19 any other participants in the Region IV office or 20 elsewhere? Please speak up now.
21 MS. SANDERS: What do you mean by 22 elsewhere? Region IV participants outside of the 23 Region IV office or NRC 24 MR. HAGAR: NRC personnel that are not 25 with Fred and Joe and that group or are not at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
7 1 Columbia resident inspector office, and that would be 2 you, Serita.
3 MS. SANDERS: Okay. Serita Sanders. I'm 4 the back up to petition coordinator in the Generic 5 Communications Branch.
6 MR. HAGAR: All right. And are there any 7 other NRC participants who have not yet introduced 8 themselves? All right. Then now could we have the 9 representatives for Entergy Northwest, the licensee 10 for Columbia Generating Station, introduce yourselves, 11 please?
12 MR. GREGOIRE: Let's just be clear. It's 13 Energy, not Entergy, Northwest. And I am Don 14 Gregoire. I'm the Reg Affairs Manager here at 15 Columbia Station.
16 MR. JAVORIK: Alex Javorik, Engineering 17 Vice President, Columbia.
18 MR. DONOVAN: Paul Donovan, Design Stress 19 Supervisor at Columbia.
20 MR. TRAUTVETTER: JR Trautvetter, 21 Compliance Supervisor, Columbia.
22 MR. DOBKEN: Public affairs.
23 MR. LANGDON : Andy Langdon, Fukushima 24 flooding hazard project.
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8 1 engineer.
2 MR. GREGOIRE: And that's it from Energy 3 Northwest.
4 MR. HAGAR: All right, gentlemen. And I 5 apologize for the slip of my tongue there. I know 6 that you guys are Energy Northwest and not Entergy.
7 I apologize for even making that suggestion that you 8 were. So, now, Mr. Johnson, would you and the other 9 petitioners or the representatives of your 10 organizations please introduce yourselves?
11 MR. JOHNSON: Okay. I'm Charles K.
12 Johnson, and I'm the Director of the Joint Tasks Force 13 on Nuclear Power for Oregon and Washington Physicians 14 for Social Responsibility.
15 MS . Mf\TE.i..A I'm Nancy Mo..t(t)c:r..
16 I'm with Alliance for Democracy, co-petitioner with 17 Oregon and Washington Physicians for Social 18 Responsibility. I'm also the head of the Nuclear 19 Energy and Waste Committee of Alliance for Democracy.
20 MR. HAGAR: All right. Now, we don't 21 require members of the public to introduce themselves.
22 But if there's any member of the public on the phone 23 that wants to introduce himself or herself, right now 24 would be a good time to do that. Please state your 25 name. All right. It sounds like no members of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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9 1 public are on the line. Is there anyone listening 2 that has not been introduced? All right.
3 Then before we actually get started, I 4 want to review some general information about the 10 5 CFR 2.206 process and make sure we're all starting 6 from the same place. Section 2.206 of Title 10 of the 7 Code of Federal Regulations describes the petition 8 process. It's the primary mechanism for the public to 9 ask the NRC to take enforcement action. And this 10 process permits anyone to petition the NRC to take 11 enforcement action related to NRC licensees or 12 licensed activities. And depending on the results of 13 the evaluation, the NRC could modify, suspend, or 14 revoke an NRC-issued license or take any other 15 appropriate enforcement action to resolve the problem.
16 Now, the NRC staff guidance, 2.206 17 petition request, is in Management Directive 8 .11, and 18 that directive is publically available through the NRC 19 website.
20 So that's about the process. Now, this 21 specific meeting, in a letter dated October 31st, 22 2013, the petitioners provided the initial information 23 that the NRC staff was considering under the 2.206 24 process. Within that process, the Petition Review 25 Board, or PRB, has been formed and is preparing to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 consider the subject information and develop a 2 recommendation for responding to the petition. The 3 purpose of today's meeting is to give the petitioners 4 an opportunity to provide additional support for the 5 petition before the Petition Review Board develops 6 that recommendation.
7 I want to emphasize that today's meeting 8 is not a hearing. It is also not an opportunity for 9 anyone to question or examine the Petition Review 10 Board on the merits of the issues presented in a 11 petition request. While the NRC staff may ask 12 clarifying questions, their primary role in this 13 meeting is to listen to the petitioners.
14 I want to emphasize no decision regarding 15 the merits of the issues will be made at this meeting.
16 And following this meeting, the Petition Review Board 17 will conduct its internal deliberations. And after 18 they've completed those deliberations, they will 19 discuss the outcome with the petitioners.
20 Now, the 2. 2 06 process allows the NRC 21 staff to ask clarifying questions in order to better 22 understand the petitioner's presentation. The process 23 also allows the NRC to invite the licensee to 24 participate in the meeting to ensure that they 25 understand the concerns being raised about their NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 facility order activities.
2 Now, in this meeting, the licensees may 3 ask questions to clarify issues raised by the 4 petitioners. But I want to stress that the licensees 5 are not part of the 2. 206 or the Petition Review 6 Board's decision-making process.
7 Does anybody have any questions about any 8 of the topics I've covered and background information?
9 All right. Then let's move on. I'll turn the meeting 10 now over to Joe Giitter, who is the Chair of the 11 Petition Review Board, to discuss the specific 12 petition that's under consideration. Go ahead, Joe.
13 MR. GliTTER: Okay. Thank you, Bob. I'd 14 like to begin by summarizing the PRB's understanding 15 of the scope of the petition under consideration and 16 then talk about what the NRC activities have been to 17 date.
18 On October 31st of 2013, Dr. Pearson and 19 Dr. Gilbert, representing the Oregon and Washington 20 Physicians for Social Responsibility, responded to a 21 letter from Chairman McFarlane concerning new 22 information about seismic hazards to the Columbia 23 Generating Station. After reviewing the letter, the 24 NRC staff decided that it should be put into a 2.206 25 petition process, as Bob described, because it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 specifically requested that the Columbia Generating 2 Station be shut down.
3 To be specific, the petitioners requested 4 that the NRC provide the data used by the NRC to 5 continue to conclude that the Columbia Generating 6 Station has been designed, built, and operated to 7 safely withstand earthquakes likely to occur in the 8 region, and that the shut down of the Columbia 9 Generating Station Nuclear Power Plant take place 10 immediately until it can be shown that the plant meets 11 adequate earthquake standards.
12 As the basis for the request, the 13 petitioners provide evidence that, to their knowledge, 14 it is more current and has not been considered by the 15 NRC in its seismic evaluation of the Columbia 16 Generating Station. Then on December 17th of last 17 year, the PRB discussed the petitioner's request for 18 immediate action, and what the PRB decided was to deny 19 the request because the petitioners provided no new 20 information demonstrating an immediate safety concern 21 to the plant or to the health and safety of the 22 public, as documented in the evaluation.
23 The plant is already undergoing a seismic 24 hazard review, and the issues raised by the 25 petitioners are encompassed by the NRC letter dated NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 March 12th, 2012, the request for information under 2 50.54(f), what we call a 50.54(f) letter, regarding 3 recommendations 2.1, 2.3, and 9.3 have been near-term 4 task force review of advice from the Fukushima Daiichi 5 accident.
6 The PRB's determination was approved by 7 the Deputy Director of the NRC Office of Nuclear 8 Reactor Regulation, Jennifer Uhle, on December 23rd, 9 2013. And Mr. Johnson was informed of the PRB' s 10 determination on January 6th of 2014.
11 Then on January 14th, Mr. Johnson asked 12 for an opportunity to address the PRB on a telecon, 13 which is the purpose of today's meeting.
14 As a reminder for the meeting 15 participants, please identify yourself if you make any 16 remarks, as this will help in the preparation of the 17 meeting transcript that will be made publically 18 available at a future date. In addition, the NRC 19 staff verified that no sensitive or proprietary 20 information is contained within the petition.
21 Since this is a public meeting, I would 22 like to remind the PRB members, the licensee, the 23 petitioner, as well as other meeting participants, of 24 the need to refrain from discussing any NRC sensitive 25 or proprietary information during today's public NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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14 1 meeting.
2 Mr. Johnson, I'll turn the meeting over to 3 you to allow you to provide any additional information 4 you believe the PRB should consider as part of the 5 petition. And starting now, you'll have one hour to 6 make your presentation.
7 MR. JOHNSON: Thank you very much, Mr.
8 Chairman. My name is Charles K. Johnson. I'm the 9 Director of the Joint Task Force on Nuclear Power for 10 the Oregon and Washington Physicians for Social 11 Responsibility.
12 I want to start first by introducing Nancy 13 from the Alliance for Democracy and 14 indicate that the Alliance for Democracy has decided 15 that they would like to join us as petitioners in this 16 proceeding. I understand that they will need to be 17 sending a written, some sort of written 18 correspondence, but perhaps you'd like to say a couple 19 of words, Nancy, before I go on.
20 MS. ,f\TELA Yes. Thank you, Charles.
21 Alliance for Democracy, among other things, works for 22 sustainable economies that also sustain the 23 environment. And the new news about the earthquake 24 faults that lie under and around CGS and are connected 25 to the Puget major fault is very disturbing to us.
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15 1 Very few people realize that that 2 southeast corner of Washington is upriver from over a 3 million people, including Portland, Oregon. It is 4 upwind from many thousands of people in Idaho, and 5 there's 300,000 people within the 50-mile radius of 6 CGS alone. That would be the lives that would be in 7 jeopardy if an earthquake happens on or near the 8 reservation. It would also destroy industries, such 9 as the ag industry, which is over a billion dollars.
10 So in terms of economy and environment, 11 we're deeply disturbed by the apparent increased risk 12 that has come to our attention. And that's why we are 13 co-petitioners. I'll turn it back to you, Charles.
14 MR. JOHNSON: Thank you, Nancy. I have 15 sent Fred a list of additional documents that I'd like 16 you to consider with regard to this petition. The 17 first is actually a question. We had hoped to ask 18 this question informally, but we were told we needed 19 to ask it formally. So we'll go ahead and take this 20 opportunity to do it now. It's from Terry Tolan, who 21 is the geologist that we hired to review the USGS and 22 other seismic studies that have been done in the 23 Hanford Nuclear Reservation and the vicinity around 24 it.
25 The question is, and this is regarding the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 internal determination, the NRC memo that rejected our 2 call for an immediate shutdown of the Columbia 3 Generating Station. This question is directed to the 4 author of that memo. I understand Yong Li is there 5 today. Perhaps he could answer this question now, or 6 perhaps he could answer it later in writing. Either 7 way is fine.
8 The question is is it the case that the 9 maximum vibratory ground motion, FSE, for the Columbia 10 Generating Station is 0.25 G to 0.60 Gin the 2 to 10 11 hertz range on figure one, as stated in the attached 12 letter? If so, can you explain the statement on page 13 two of the letter highlighted in yellow that cites 20 14 hertz? Should it state 2 hertz and greater?
15 MR. HAGAR: This is Bob Hagar. Let me 16 interrupt for just a moment here because it's my 17 understanding that this meeting is not set up to 18 enable or to provide you an opportunity to interrogate 19 the NRC staff. Instead, it's an opportunity for you 20 to present the evidence that you want the PRB to 21 consider. I'd like to --
22 MR. JOHNSON: Would it be possible to get 23 an answer to this question at some point? And if so, 24 how would I go about doing that? We were hoping to 25 actually ask the authors of the study in some way. We NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W.
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17 1 were told that we, that -- I mean, you instruct me as 2 to how to get the answer to that. Is there some way 3 to get an answer to that, or is there no way to get an 4 answer to that question?
5 MR. HAGAR: Let's ask the Headquarters 6 staff to say how you can, how you can have a dialogue 7 with the NRC staff. But I'm suggesting that this 8 meeting is not the forum for that.
9 MR. JOHNSON: If you'll pardon me for a 10 moment, it seems to be a typo in the memo. If that's 11 the case, could you tell us that, or what's it going 12 to take to find out?
13 MR. LYON: Chuck, this is Fred Lyon. What 14 we're going to do is take your question, and you are 15 absolutely right. We will look at it. We will verify 16 that what we've written is correct. And if we have a 17 typo, then you are correct, we need to fix it and 18 we'll address it, and we will let you know as part of 19 our follow-on response to you. So the answer is, yes, 20 you will get an answer to the question.
21 MR. JOHNSON: Okay. That's all I wanted.
22 That's why I put it into the record. Okay, thank you.
23 The second document that I sent to Mr. Lyon is Terry 24 Tolan's response letter to me regarding the NRC's 25 internal determination memo to reject Oregon and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 Washington PSR's call for the immediate shut down of 2 the CGS pending the earthquake assessment, and I'm 3 going to read from that. Hang on just a moment.
4 Okay. Some comments on the Columbia 5 Generating Station's seismic hazard considerations 6 determination of immediate safety concerns letter.
7 G2 013 0776. "
Dear Mr. Johnson,
I've had an opportunity 8 to read this response letter cited above. I would 9 first like to respond to the background information 10 set out by the NRC staff. The NRC staff states that 11 each nuclear power plant was designed to a ground 12 motion level that is appropriate for the geology and 13 tectonics in the region surrounding the plant 14 location. In my two letter reports referenced at the 15 end of the letter, it has been clearly shown that the 16 CGS was designed at a time when much of the geology 17 and tectonics of this region was not well known and 18 was not well understood.
19 For example, the CGS was designed based on 20 the flawed decision that the epicenter of the largest 21 historical earthquake in this region was 180 miles 22 away, as compared to a recent study that places the 23 epicenter approximately 99 miles away from the CGS 24 site, which is a significant change that needs to be 25 assessed. Second, when the CGS was designed, only six NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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19 1 faults were considered within the Yakima fold and 2 thrust belt as part of the seismic risk assessment.
3 Subsequent studies have more than doubled this number 4 of Yakima fold and thrust belt faults. The design of 5 the CGS was based on a thin-skinned uncoupled fault 6 modeled for Yakima fold and thrust belt. Published 7 work by the U.S. Geological Survey, Blaekly et al 8 2011, shows that the Yakima fold and thrust belt is 9 best characterized by a thick-skinned coupled fault 10 model, which means that the faulting extends into the 11 basement rock below the salt layers and can give rise 12 to larger-magnitude earthquakes and subsequent high 13 vibratory ground motion at the CGS site. When 14 designed, the CGS seismic risk assessment was based on 15 the Yakima fold and thrust belt faults that had 16 relatively short lengths. Based on the published U.S.
17 Geological Survey work, Blaekly et al 2011, it appears 18 that these faults are substantially longer and likely 19 capable of producing much larger magnitude earthquakes 20 than previously believed.
21 Five, when the CGS was designed, it was 22 thought that movement on the Yakima fold and thrust 23 belt faults was old due to the lack of evidence of 24 offsets. This assumption is also questionable based 25 on the published work by Blaekly et al 2011. Six, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N W.
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20 1 when the CGS was designed, it was not known that there 2 was an active fault just 2. 3 miles away from the 3 reactor.
4 Thus, I question the NRC staff assumption 5 that the design of CGS is appropriate for the geology 6 and tectonics in the region, given all the fundamental 7 revisions in our knowledge that have occurred since 8 the last time the CGS seismic risk was assessed in the 9 early 1990s. These advances in understanding the 10 structural geology of the Yakima fold and thrust belt 11 fundamentally change the basic assumptions previously 12 used to assess seismic hazard and risk at the CGS 13 site.
14 Concerning the 'evaluation,' I note that 15 they stayed on page two, first bullet, third item, 16 that OWPSR mistakenly compared the 3 to 5 hertz 17 spectral acceleration levels of 0.8 G for the waste 18 treatment plant, WTP, 2005 seismic design with the CGS 19 SSB 20 hertz and greater spectral acceleration value 20 of 0.25 G. Indeed, I should have compared the CGS 21 spectral acceleration to that of the revised WTP 22 spectral response developed by Young 2007, which is 23 0.6 G.
24 However, it still doesn't change the fact 25 that the maximum vibratory ground motion for this area NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
21 1 has been dramatically increased based on the WTP 2 studies. As shown in their figure H-3 of the letter, 3 the revised WTP response spectrum is very similar to 4 that developed for the CGS. This is interesting given 5 that Energy Northwest previously implied, letter to 6 the NRC dated 17 December, 2010, response 3-A, second 7 paragraph, that differences in the --" oh, hang on a 8 second. God, I just messed up what I was reading 9 here. Hang on just a moment.
10 Let me start that sentence again. Well, 11 I'll just continue where I left it. "The differences 12 in the site factors, e.g. difference from the active 13 fault's physical soil properties and thicknesses 14 amplification/deamplification, etcetera, between the 15 CGS and WTP sites does not allow one to apply any of 16 the recent WTP seismic ground motion findings, Rohay 17 and Reidel 2005, Rohay and Brouns 2007, Young 2007, to 18 the CGS site.
19 It is curious that, if the site factors 20 are different between the CGS and WTP, as Energy 21 Northwest claimed, why are the vibratory ground motion 22 response spectrums so similar? As previously noted 23 and discussed, Energy Northwest needs to develop a CGS 24 site-specific model for ground motion response 25 spectrum based on blowhole vertical seismic profile NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 data from the ground surface to the top of the 2 Columbia River basalt. They then need to integrate 3 this data with the WTP shear wave velocity data for 4 the Columbia River basalt/Ellensburg formation 5 interbeds.
6 Energy Northwest also needs to reevaluate 7 the maximum credible earthquakes and overall seismic 8 hazards in light of the recently published U.S.
9 Geological Survey work, Blaekly et al 2011. They 10 would have to incorporate a coupled fault model, 11 extended active fault lengths, and reevaluate the 12 earthquake magnitude/frequency, etcetera, before the 13 CGS site-specific subsurface velocity data could be 14 used to help constrain estimates and vibratory ground 15 motion from various earthquake scenarios.
16 In the last bullet paragraph, page two, it 17 was stated that Energy Northwest, along with the U.S.
18 Department of Energy, is reevaluating the seismic 19 hazards for the region surrounding the Hanford site 20 and is using the latest data model and methods. They 21 also indicated that they are evaluating the issues we 22 have previously raised as part of this new seismic 23 hazard reevaluation and that this report is due to the 24 NRC in March 2015. I look forward to seeing this 25 report.
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23 1 In summary, since both the U.S. Department 2 of Energy's Young 2007, Rohay and Brouns 2007, Rohay 3 and Reidel 2005, and Energy Northwest seismic hazard 4 analyses rely on a flawed and outmoded seismic 5 assessment model developed by Geomatrix 1996, one 6 needs to question the basic adequacy of the existing 7 CGS seismic hazards analysis in light of the new and 8 recent data and findings presented by the U.S.
9 Geological Survey. Sincerely, Terry L. Tolan, LEG.u 10 And then there's citations at the end, which is in 11 this letter that I submitted to Fred already.
12 The third item that I submitted was an 13 issue brief that was done by Dave Lochbaum of the 14 Union of Concerned Scientists. The issue is boiling 15 water, it's entitled "Boiling Water Reactor Shutdown 16 System Problem,u and this is an additional issue that 17 I'd like you to consider in this petition. It's 18 related to the, to the danger of an earthquake. And 19 I'm going to go ahead and read it into the record.
20 Again, it's entitled "Boiling Water 21 Reactor Shutdown System Problem.u It's from David 22 Lochbaum, Union of Concerned Scientists. It's called 23 an issue brief. "GE Hitachi informed the Nuclear 24 Regulatory Commission, NRC, about a safety problem 25 related to the reactor shutdown system at its boiling NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 water reactors, BWRs, via a September 27, 2011 update 2 to NRC Event 46230, dated September 3, 3 2010." This is quoting from this. "GE Hitachi, GEH, 4 has determined that the scram capability of the 5 control rod drive mechanism in BWR/II-5 plants may not 6 be sufficient to ensure the control rod will fully 7 insert in a cell with channel control rod friction at 8 or below the friction limits specified in MFN 08-420 9 with concurrent safe shutdown earthquake, SSE. The 10 plant condition for which incomplete control rod 11 insertion might occur is when the reactor is below 12 normal operating pressure, less than 900 psig, and a 13 scram occurs concurrent with the SSE for Mark I 14 containment plants and for the SSE with concurrent 15 loss of coolant accident, LOCA, and safety release 16 valve events for Mark II containment plants.
17 In this scenario, a substantial safety 18 hazard results because the affected control rods might 19 not fully insert to perform the required safety 20 function. GEH has determined that when channel 21 control blade interference is present at reduced 22 reactor pressure and a friction level considered 23 acceptable in MFN 08-420, a simultaneously-occurring 24 safe shutdown earthquake, SSE, may result in control 25 rod friction that inhibits the full insertion of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
25 1 affected control rods during a reactor scram from 2 these conditions. This scenario was not explicitly 3 considered in MFN 08-420."
4 And back to the narrative from Mr.
5 Lochbaum. "This issue brief provides background 6 information about control rods at BWRs and the 7 specific safety problem. The reactor core of a BWR 8 consists of fuel pellets stacked within column metal 9 rods," and I'm actually not going to read all of that.
10 And I think I'll refrain from reading any of the rest 11 of this because this is background information that's 12 designed for people who don't understand nuclear power 13 plants, and I believe everyone on this call, with the 14 possible exception of myself and Ms. McCullough, did 15 understand this prior to, without having read Mr.
16 Lochbaum's memo.
17 So, obviously, we're very interested in 18 knowing what measures, if any, have been taken to 19 address this situation at the Columbia Generating 20 Station, whether or not any modifications in the 21 control blades have been discussed or made, you know, 22 replacements of the control blades, and has this issue 23 been addressed either partially or fully; and, if not, 24 what is the time line in which it will be addressed?
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26 1 to item number five, which will introduce item number 2 four. I'll go back to number four of the documents 3 that I introduce after I discuss what the document 4 number five is, which is an email from Dave Lochbaum 5 from the Union of Concerned Scientists to me dated the 6 29th of January, 2014. It's a portion of an email.
7 It's regarding the implications of the D.C. Cook plant 8 fire event when considering the consequences of an SSE 9 magnitude quake on fire protection systems.
10 Here's what Mr. Lochbaum had to say to me 11 about this, and this came in the context of me asking 12 him questions about this problem with the control 13 blades. He said here's an additional thing you should 14 probably look at.
15 "Hello, Chuck. Attached is a November 16 2008 report to the NRC by the owner of the D.C. Cook 17 Nuclear Plant in Michigan. Some turbine blades came 18 apart. The turbine blades are very large pieces of 19 metal rotating at least 1,800 times per minute. When 20 they come apart, it ain't pretty. As the blades came 21 apart, they became missiles. Some missiles ripped 22 through piping, providing hydrogen gas to the 23 generator, starting a fire. Other missiles ripped 24 through piping containing lubricating oil for the 25 turbine bearings, starting another fire."
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27 1 No big deal, right? The turbine generator 2 is not a safety-related component, so let it burn.
3 But check out the paragraph on page three, and he's 4 referring to the NRC licensing event report, which is 5 item number four. The number is 315/2008-006-00.
6 "Manual reactor trip due to main turbine high 7 vibration' at the Donald C. Cook Nuclear Plant Unit 8 1."
9 Okay. Check out the paragraph on page 10 three of the Cook LER, beginning with, "At 2125 hours0.0246 days <br />0.59 hours <br />0.00351 weeks <br />8.085625e-4 months <br />, 11 the fire water headed, the vibrations caused when 12 heavy metal missiles struck concrete walls and floors 13 created a mini earthquake in the local area. As the 14 ground shook, a fire protection header pipe ruptured.
15 Water from the north fire water storage tank poured 16 from the ruptured header. I read other accounts where 17 security officers in the vicinity reported old 18 faithful as a geyser of water shot up from the ground.
19 Not good when an even triggering a fire also disables 20 the fire suppression system. Not good at all.
21 The NRC's regulations require plants be 22 designed to survive ground motion caus~d by the safe 23 shutdown earthquake. As you noted earlier, the SSE 24 value for CGS is suspect. But for the moment, let's 25 assume the SSE value is right. The NRC's regulations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE .. N.W.
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28 1 do not require the entire plant survive an SSE shake, 2 only the parts and components of the plant necessary 3 to shut down the reactor core and maintain a shutdown.
4 Control rod system, yes. Fire protection system, no.
5 There's a disconnect between fire 6 protection regulations and non-fire safety 7 regulations. I spoke about that disconnect in a 8 r e c e n t b l 0 g p 0 s t s e e 9 http://allthingsnuclear.org/fire-safety-OR-not.)
10 The Cook event was caused by a turbine 11 blade failure. An SSE magnitude quake could cause an 12 even greater ground motion at CGS. Would the SSE 13 cause fire or fires, would the SSE disable or degrade 14 the fire protection systems? Lubricating oil is not 15 only used for the turbine. CGS has two very large 16 recirculation pumps inside the drywell that use large 17 amounts of lubricating oil. There's ample combustible 18 material available in the reactor building. It would 19 be nice to know that the CGS can survive an SSE, even 20 if the SSE starts a fire. Thanks, and good luck."
21 So I did include the event report, and the 22 issues that are raised by Mr. Lochbaum in this memo I 23 think are germane to the issue of whether or not the 24 CGS is robust enough to withstand an SSE earthquake or 25 even a larger one, as we believe is possible to occur NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
29 1 there.
2 And with that, I think I've introduced all 3 of the elements that we'd like to have added. If you 4 have any questions about that or this isn't clear, 5 then please let me know.
6 MR. LYON: Chuck, this is Fred. Have you 7 already emailed the documents to me?
8 MR. JOHNSON: I emailed them to you at 9 9:16a.m., according to my email, yes.
10 MR. LYON: Okay.
11 MR. JOHNSON: You and Merrilee, also.
12 MR. LYON: Okay, great. We probably 13 missed them. We were already over here making sure 14 that the room was set up. But I will check my email 15 and those documents, and they will be entered into our 16 ADAMS document system, ad we will consider them as 17 part of our PRB evaluation. So thank you.
18 I'll let you know if, I'll let you know 19 if, for some reason, they got lost in electron land.
20 MR. JOHNSON: Okay. And I'd be happy to 21 send them again. I don't know if the procedure, now 22 that this is our formal, this is a formal pre-meeting, 23 I guess it's called, if you need additional 24 clarification, since I didn't give these to you, you 25 know, until 45 minutes, I tried to send them to you 45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 minutes before this hearing, if you have additional 2 questions, is it permissible for you to ask them after 3 this hearing is closed?
4 MR. LYON: Certainly it is. We're not 5 going to ignore information that might be pertinent to 6 the issues.
7 MR. JOHNSON: Okay. That's all I have at 8 this point. That's all I intend to present today.
9 MR. GliTTER: Okay. So at this time, I 10 just wanted to add a couple of things. This is not a 11 hearing. We'll take a look at the information that 12 you provide. At this time, since this is a public 13 meeting, I would like to remind the PRB members, the 14 licensees, and the petitioner, and other meeting 15 participants of the need to refrain from discussing 16 any sensitive or proprietary information from today's 17 meeting. I'm not sure there was any but just a good 18 reminder.
19 Does the staff from NRC Headquarters have 20 any questions for the petitioners at this time? Okay.
21 Does the staff from NRC Region IV have any questions 22 for the petitioners? Okay. Hearing none, I'd like to 23 turn the meeting back to Bob to allow questions from 24 any other participants.
25 MR. HAGAR: Thank you, Joe. Does the NRC NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 staff at the Columbia Generating Station have any 2 questions or comments? All right. Does the licensee 3 have any questions or comments for the petitioners?
4 MR. GREGOIRE: No questions. This is Don 5 Gregoire, again, Reg Affairs Manager at Columbia. We 6 do appreciate the previous consideration for our 7 station's safety. The NRC's assessment with regard to 8 immediate concern for safety, we agree with the 9 conclusion. We do recognize that there's some very 10 good questions raised from the petitioners, but, as 11 expressed previously, there's a pretty thorough study 12 going on right now with Pacific Northwest National 13 Laboratory, many of the peers of Mr. Tolan, that are 14 evaluating this type of information.
15 Energy Northwest will be implementing any 16 recommendations based on that thorough review of the 17 seismic hazards associated with this region. We'd 18 also like to say that many of the items that were 19 discussed that were brought up from Mr. Lochbaum, 20 those issues have been addressed and I think there's 21 information that can be found on the docket in 22 relation to that. But I do appreciate the opportunity 23 to make comments. That's it.
24 MR. HAGAR: All right, Don. Thank you.
25 Don, do you have any questions or comments about the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 petition process or the 2.206 process or the Petition 2 Review Board? Do you understand that process?
3 MR. GREGOIRE: Yes/ I do understand the 4 process. I don t 1 have any additional questions at 5 this time.
6 MR. HAGAR: All right. Then does any 7 member of the public/ anyone else who has joined this 8 call 1 have any questions either to the petitioners or 9 about the petition process? All right. I 1m not 10 hearing any response/ S0 1 Joe/ do you have any 11 concluding comments?
12 MR. GliTTER: Yes. I d just like to thank I
13 everybody/ Charles and Nancy/ for participating and 14 for sharing their views. We take safety very 15 seriously at the NRC. It 1 S our job. So I wanted to 16 thank Charles and Nancy for taking the time to provide 17 the NRC staff with clarifying information on the 18 petition they ve submitted.
1 And within a couple of 19 weeks 1 PRB plans to meet internally to discuss the 20 information that you ve provided and any additional 1
21 information that we haven t looked at yet and to make 1
22 its initial recommendation on the petition.
23 Following that meeting/ the petition 24 manager will inform you of the PRB 1 S initial 25 recommendation/ either accept or reject the 2. 206 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE, N.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
33 1 petition for review, in accordance with the criteria 2 in our management directive. And with that, I'll 3 return it back to you, Bob.
4 MR. HAGAR: All right. Before we close, 5 does the recorder for this meeting need any additional 6 information for the meeting transcript?
7 COURT REPORTER: I don't anticipate I 8 will. If I do, I'll call Mr. Lyon or I'll email Mr.
9 Lyon. But right now, in my first run over, I look 10 pretty good.
11 MR. HAGAR: All right, thank you. With 12 that then, this meeting is concluded. Thank everyone 13 for their time and attention. And we're now going to 14 terminate the telephone conversation. Thank you.
15 (Whereupon, the foregoing matter was 16 concluded at 1:58 p.m.)
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