ML14143A212
| ML14143A212 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 04/08/2014 |
| From: | Division of Operating Reactor Licensing |
| To: | |
| M. Chawla, NRR/DORL | |
| References | |
| NRC-693 | |
| Download: ML14143A212 (41) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board RE Palisades Nuclear Plant Docket Number: (n/a)
Location: teleconference Date: Tuesday, April 8, 2014 Work Order No.: NRC-693 Pages 1-41 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 PALISADES NUCLEAR PLANT 8 + + + + +
9 TUESDAY 10 APRIL 8, 2014 11 + + + + +
12 The conference call was held, Louise Lund, 13 Chairperson of the Petition Review Board, presiding.
14 15 PETITIONER: MICHAEL MULLIGAN 16 17 PETITION REVIEW BOARD MEMBERS 18 LOUISE LUND, Chair, Deputy Division Director 19 Division of Reactor Licensing, NRR 20 DAVID ALLEY, Senior Materials Engineer, 21 Division of Engineering 22 REED ANZALONE, General Engineer, Nuclear 23 Performance & Code Review Branch 24 LEE BANIC, Petition Coordinator, NRR 25 BOB CARLSON, Branch Chief, Division of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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2 1 Operating Reactor Licensing 2 MAC CHAWLA, Petition Manager for 2.206 3 Petition 4 GANESH CHERUVENKI, Materials Engineer, 5 Division of Engineering 6 RUSS HASKELL, Operating Experience Branch, 7 NRR 8 JOSHUA KAIZER, Reactor Systems Engineer, NRR 9 WARREN LYON, Senior Reactor Systems Engineer, 10 Reactor Systems Branch 11 BOB WOLFGANG, Senior Mechanical Engineer, 12 Division of Engineering 13 14 NRC HEADQUARTERS STAFF 15 JEREMY DEAN, Branch Chief, Nuclear Performance 16 & Code Review Branch 17 LINDSAY ROBINSON, Project Manager, Division of 18 License Renewal 19 SHELDON STUCHELL, Branch Chief, Generic 20 Communications 21 22 REGION III STAFF 23 BRENT BOSTON, Reactor Engineer, Division of 24 Reactor Projects 25 ERIC DUNCAN, Branch Chief, Reactor Projects NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3 1 Branch 3 2 ALEX GARMOE, Senior Resident Inspector 3 JAY LENNARTZ, Project Engineer, Division of 4 Reactor Projects 5
6 LICENSEE STAFF 7 BARBARA DOTSON 8 LINDSAY ROSE 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 11:00 3 a.m.
4 MR. CHAWLA: Okay, all right. Id like to 5 thank everybody for attending this meeting. My name is 6 Mac Chawla, and Im the Project Manager for the 7 Palisades Nuclear Plant. We are here to allow the 8 petitioner, Mike Mulligan, to address the Petition 9 Review Board regarding the 2.206 petition dated March 10 5, 2014.
11 Im also the petition manager for the 12 petition. The Petition Review Board Chairman is Louise 13 Lund. As part of the Petition Review Boards, or PRBs, 14 review of this petition, Mike Mulligan has requested 15 this opportunity to address the PRB.
16 This meeting is scheduled from 11 a.m. to 17 12 p.m. Eastern time. The meeting is being recorded by 18 the NRC Operations Center and will be transcribed by a 19 court reporter. The transcripts will become a 20 supplement to this petition. The transcript will also 21 be made publicly available.
22 I would like to open this meeting with 23 introductions. As we go around the room, please be sure 24 to clearly state your name, your position, and the 25 office that you work for within the NRC for the record.
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5 1 Ill start off. My name again is Mac 2 Chawla. Im the petition manager. Ill go around the 3 table here.
4 CHAIR LUND: Im Louise Lund. Im the 5 deputy division director for the Division of Operating 6 Reactor Licensing in the Office of Nuclear Reactor 7 Regulation.
8 MR. WOLFGANG: Bob Wolfgang. Im a senior 9 mechanical engineer in the Division of Engineering.
10 MR. LYON: Warren Lyon, senior reactor 11 systems engineer with the Reactor Systems Branch.
12 Hello, Mike. I grew up in Peterborough. I just wanted 13 to say hello to a fellow person from New Hampshire.
14 MR. MULLIGAN: The snow is all gone 15 finally.
16 MS. BANIC: Lee Banic, petition 17 coordinator, Office of Nuclear Reactor Regulation.
18 MR. HASKELL: Russ Haskell with the Office 19 of Nuclear Reactor Regulation in the Operating 20 Experience Branch.
21 MR. ALLEY: Dave Alley, senior materials 22 engineer, Division of Engineering.
23 MR. CHERUVENKI: Ganesh Cheruvenki, 24 materials engineer, Division of Engineering.
25 MR. KAIZER: Joshua Kaizer, reactor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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6 1 systems engineer, Nuclear Regulation, NRR.
2 MR. CARLSON: Bob Carlson, branch chief, 3 Division of Operating Reactor Licensing.
4 MR. ANZALONE: Reed Anzalone, general 5 engineer, Nuclear Performance and Code Review Branch, 6 Division of Safety.
7 MS. ROBINSON: Lindsay Robinson, Division 8 of License Renewal, project manager.
9 MR. CHAWLA: Okay. We have completed the 10 introductions at the NRC Headquarters. At this time, 11 are there any other people from Headquarters on the 12 phone?
13 (No response.)
14 MR. CHAWLA: Hearing none, are there any 15 NRC participants from regional office on the phone?
16 MR. DUNCAN: Yes, Mac. This is Eric 17 Duncan. Im the branch chief for Palisades here at 18 Region 3, and theres a couple of others here, as well.
19 Theyll introduce themselves.
20 MR. LENNARTZ: This is Jay Lennartz. Im 21 the project engineer for Palisades.
22 MR. BOSTON: Good morning. This is Brent 23 Boston. Im a reactor engineer in DRP here at Region 24 3.
25 MR. DUNCAN: Thats it, Mac.
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7 1 MR. CHAWLA: Is there any representatives 2 for the licensee on the phone? Please introduce 3 yourself.
4 MS. DOTSON: Barb Dotson, Regulatory 5 Assurance.
6 MS. ROSE: Lindsay Rose, communications 7 specialist.
8 MR. CHAWLA: We do have a couple more folks 9 from Headquarters who have joined. Please introduce 10 yourself.
11 MR. STUCHELL: Sheldon Stuchell, branch 12 chief, Generic Communications.
13 MR. DEAN: Jeremy Dean, branch chief, 14 Nuclear Performance and Codes.
15 MR. CHAWLA: Mr. Mulligan, would you 16 please introduce yourself for the record?
17 MR. MULLIGAN: Hi. Im Mike Mulligan and 18 -- Im sorry?
19 MR. DUNCAN: Sorry, Mike. We need to get 20 the residents, as well, and anybody else --
21 MR. CHAWLA: Sorry. I thought you said 22 everybody was . . .
23 MR. GARMOE: Yes, Mac, its Alex Garmoe, 24 NRC, senior resident inspector.
25 MR. CHAWLA: Okay. Then thats everybody NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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8 1 from NRC. So back to Mr. Mulligan. Mr. Mulligan, 2 would you please introduce yourself for the record?
3 MR. MULLIGAN: Im Mike Mulligan. I was 4 on a fast-attack submarine many years ago as a nuke. It 5 was an experimental sub anyways. I worked at Vermont 6 Yankee for a number of years. I was, for a number of 7 years, I was a reactor operator at the plant. And now 8 Im, more or less, a general whistleblower. Thank you.
9 MR. CHAWLA: It is not required for members 10 of the public to introduce themselves on the call.
11 However, if there are any members of the public on the 12 phone that wish to do so at this time, please state your 13 name for the record. Any members of the public?
14 (No response.)
15 MR. CHAWLA: Okay. Hearing none, I would 16 like to emphasize that we each need to speak clearly and 17 loudly to make sure that the court reporter can 18 accurately transcribe this meeting. If you do have 19 something that you would like to say, please first state 20 your name for the record.
21 All those dialing into the meeting, please 22 remember to mute your phone to minimize any background 23 noise or distraction. If you do not have a mute button, 24 this can be done by pressing the keys *6. To unmute, 25 press *6 keys again. Thank you.
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9 1 At this time, I will turn it over to the PRB 2 Chairman, Louise Lund.
3 CHAIR LUND: Good morning. Welcome to 4 this meeting regarding the 2.206 petition submitted by 5 Mr. Mulligan. Id like to first share some background 6 on our process.
7 Section 2.206 of Title 10 of the Code of 8 Federal Regulations describes the petition process, the 9 primary mechanism for the public to request enforcement 10 action by the NRC in a public process.
11 This process permits anyone to petition NRC 12 to take enforcement-type action related to NRC 13 licensees or licensed activities. Depending on the 14 results of its evaluation, NRC could modify, suspend, 15 or revoke an NRC-issued license or take any other 16 appropriate enforcement action to resolve the problem.
17 The NRC staffs guidance for the disposition of 2.206 18 petition requests is in Management Directive 8.11, 19 which is publicly available.
20 The purpose of todays meeting is to give 21 the petitioner, Mr. Mulligan, an opportunity to provide 22 any additional explanation or support for the petition 23 before the Petition Review Boards initial 24 consideration and recommendation. This meeting is not 25 a hearing, nor is it an opportunity for the petitioner NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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10 1 to question or examine the PRB on the merits or the 2 issues presented in the petition request. No decisions 3 regarding the merits of this petition will be made at 4 this meeting.
5 Following this meeting, the Petition 6 Review Board will conduct its internal deliberations.
7 The outcome of this internal meeting will be discussed 8 with the petitioner.
9 The Petition Review Board typically 10 consists of a chairman, usually a manager at the Senior 11 Executive Service level at the NRC. It has a petition 12 manager and a PRB coordinator. Other members of the 13 Board are determined by the NRC staff based on the 14 content of the information in the petition request.
15 The members have already introduced themselves.
16 As described in our process, the NRC staff 17 may ask clarifying questions in order to better 18 understand the petitioners presentation and to reach 19 a reasoned decision whether to accept or reject the 20 petitioners request for review under the 2.206 21 process.
22 I would like to summarize the scope of the 23 petition under consideration and the NRC activities to 24 date. On March 5th, 2014, you submitted to the NRC a 25 petition under 2.206 regarding Palisades Nuclear Plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11 1 in which you requested a number of actions. The major 2 ones concern operating with a broken impeller and flawed 3 control rod drive mechanism housing.
4 Allow me to discuss the NRCs activities to 5 date. On March 14th, 2014, the PRB reviewed your 6 request for immediate action to prevent Palisades 7 restart and determined that there were no 8 safety-significant concerns to prevent the plant from 9 restarting as scheduled. The NRC has reviewed the 10 licensees evaluation of the impeller piece fragment 11 within the reactor vessel and concluded that it does not 12 pose a threat to the reactor and other plant components.
13 Additionally, the licensee replaced all of the 45 14 control rod drive mechanism housings prior to plant 15 startup.
16 Based on the review of the licensees 17 evaluation related to the stuck impeller piece and 18 replacement of all CRDM housings during the refueling 19 outage, there were no immediate safety-significant 20 concerns to prevent the plant from restarting as 21 scheduled. Your request for the immediate action of 22 shutdown of Palisades and other Entergy plants did not 23 have adequate bases. Therefore, your request to 24 prevent Palisades from restarting was denied.
25 You were informed on March 19th, 2014, of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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12 1 the PRBs decision to deny your request for immediate 2 action. On March 24, 2014, the petition manager 3 contacted you to discuss the 10 CFR 2.206 process and 4 to offer you an opportunity to address the PRB. You 5 requested to address the PRB by phone prior to its 6 internal meeting to make the initial recommendation to 7 accept or reject the petition for review.
8 As a reminder for the phone participants, 9 please identify yourself if you make any remarks, as 10 this will help us in the preparation of the meeting 11 transcript that will be made publicly available. Thank 12 you.
13 Mr. Mulligan, Ill turn it over to you to 14 allow you the opportunity to provide any information you 15 believe the PRB should consider as part of this 16 petition.
17 MR. MULLIGAN: Good morning. Good job on 18 the CRDMs, although there was reports in the media that, 19 you know, you were going to replace a proportion of them, 20 and then you came back and replaced a larger proportion 21 of them, and then you came back and said you replaced 22 them all. So that is a, that is a good job you did.
23 You know, as far as, I guess, I mean, 24 everything associated with these broken impellers tells 25 us that Palisades is confused. They dont understand NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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13 1 the limitations of their equipment, and they dont 2 understand how serious an issue is as far as these broken 3 impellers are.
4 And theres a lot of them. Heres a short 5 list. In 1983, they had issues with impellers, PCP 6 impellers. 1984, they had severe damage, and I contend 7 its the same issue that caused the 2011 incident.
8 2001, theres a segment of cracked impellers that were 9 found. 2007, I originally put down 2012, but thats 10 inaccurate because you never, they never found the 11 impeller in 2012.
12 And, you know, theres reports out in the 13 media that they replaced an impeller, and Im not sure 14 what the nature of, what they found to replace that 15 impeller in this recent outage and stuff like that. And 16 so, you know, that big question Id like answered 17 eventually.
18 And so beyond this whole thing is, you know, 19 well, how does the NRC maintain credibility with the 20 public? And out of TMI, we discovered that there was 21 a lot of miscommunication and withholding information 22 and all sorts of rationalizations about withholding 23 information and picking and choosing the information 24 you release and stuff like that. And then once -- it 25 didnt happen.
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14 1 And everybody was disillusioned with the 2 agency and stuff. They had reorganization. And out of 3 it came, essentially, this system that these utilities 4 are required to disclose information, an assortment of 5 information, partially to appease and make the public 6 feel better and, more importantly, to notify, to put 7 their problems on a piece of paper so all of the 8 utilities could take a look at it and see if they have 9 the same problems so, you know, there wouldnt be 10 repeated problems and that type of stuff.
11 And out of this issue with Palisades, its 12 just amazing what theyre allowed to not report about.
13 Like I said, all these incidences with the broken 14 impellers would require the LER. You know, Palisades 15 could have, theres nothing prohibiting them from 16 throwing in an LER and stuff like that. You know, they 17 could have voluntarily submitted a bunch of these LERs 18 to document the issues and to maintain credibility with 19 the public and NRC itself and to keep track of these 20 problems.
21 You know, its interesting. The 22 Information Notice 1985 is curious. Theres different 23 vibration levels, you know. In the 1985 one, the pump 24 vibration level, according to the IN, reached the danger 25 level of 10 mils. In 2012, inspection report 2012, on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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15 1 October 11th, the operators noted a steep change of 2 approximately 1 mil on the pump monitor. Vibration 3 values were trending around 10.5 mils prior to the 4 perturbation, remaining steady state for around 25 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and then spiked up to 22 mils for less than three 6 seconds. So, you know, I dont know why is it 10 mils 7 in the danger level and, you know, up to 25 mils during 8 this recent event and stuff?
9 It was interesting. Donald Rumsfeld 10 talked a little bit about unknowns, unknown unknowns, 11 and that was essentially about him trying to obscure the 12 fact that they didnt have any information about weapons 13 of mass destruction in Iraq. You know ..And The New 14 York Times, by the way, has a whole, the whole history 15 on Donald Rumsfeld and his unknown unknowns. They have 16 three articles. Its pretty interesting, you know, the 17 history. I like the history of everything, actually.
18 So the issue in 2001 was, and I guess up to 19 the present time, fatigue-related effects from the 20 operation of the pump in a condition beyond the maximum 21 flow rate and below the minimum net positive suction 22 head recommendations described at UFSAR and other 23 design documentation.
24 So, I mean, how is a plant allowed to run 25 outside of its designs? I mean, you guys, theres tons NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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16 1 of you guys in the NRC and they got tons of people, 2 licensed people and highly-skilled people and stuff 3 like that. How does a plant, how is a plant allowed to 4 run outside of its designs for so many years with so much 5 damage and stuff? How come they didnt immediately see 6 what was going on here and make it so that they wouldnt 7 have anymore problems with their PCP pump impellers and 8 stuff? I mean, thats basic competence. And if you 9 cant, you know, if you cant keep up with your 10 information and your reports and stuff arent accurate, 11 and then you run outside your plant designs, I mean, 12 youre asking for a lot of problems down the road with 13 the competence of site employees and the NRC itself that 14 they cant figure out a way to cause a plant to fix their 15 PCPs early and not consume so much agency resources and 16 their own internal resources, you know, researching 17 these issues over and over again.
18 I had a list of all the different -- sorry.
19 They had, between Information Notice 85-03 -- oh, here 20 it is -- 85-03 and its supplement and, you know, all the 21 issues associated with these impellers and there were 22 so many different things that, you know, first they 23 talked about cap screws and the cap screws werent 24 torqued appropriately by the site. And then theres 25 the cap screws, the threads are defective. And then the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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17 1 cap screws were torqued appropriately by the site, but 2 it was, they werent torqued right when they put the pump 3 together back at the -- then they talk about, in >83, 4 theres impeller damage of some sort thats so-called 5 not related.
6 So its, you know, fatigue brought on by 7 preload at the bolts. Thats the supplement. And by 8 the way, the site had not followed assembling that pump 9 back up.
10 And so then First Energy, you aint got a 11 -- their docket, you know, there was a combination of 12 residents, residential stresses caused by improper heat 13 treatment, poor fabrication practices, stress 14 associated with starting and stopping the pumps and 15 stuff. And so we get through this thing, and everybody 16 has got, you know, theres so many rationalizations or 17 theres so many different things wrong with this pump, 18 and how can you trust, how can you trust these guys to 19 throw out an accurate report with this kind of record 20 with these impellers and stuff?
21 And so then it comes out in 2012 that its, 22 theyve missed operating the pump. How does that 23 happen? How do you prevent a plant from operating 24 outside of its USFAR? How do you change the behavior 25 of that? How do you make sure all the other plants, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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18 1 know, take that seriously? If they cant keep track of 2 the limitations and the requirements of their safety 3 equipment, that is -- we cant identify the exact 4 accident thats going to happen in the future, but 5 theres going to be a bad one and a lot of people arent 6 going to know whats going on and theres going to be 7 a lot of confusion.
8 And Ive seen that where, you know, 9 something happens and people are caught with their pants 10 down and they dont know whats going on and their 11 panicking and stuff like that. I mean, thats not going 12 to be good if this kind of thing happens with an example 13 of a plant being operated with such a record.
14 The latest thing that I discovered is 15 something about an appendix of a report, there was 16 something about they put in a wrong sized impeller.
17 Theres a, theres an operability and a functionality 18 thing. It sounds like they actually put a wrong sized 19 impeller inside there, and I dont know the nature of, 20 you know, Im not sure if they purchased impellers and 21 they were wrong size and they kept them out of the plant 22 or -- it sounds like to me that they actually put them 23 in the plant. You know, it talks about, in 2012, at the 24 end of 2012, this report came out. Evidently, the NRC 25 looked at it and stuff. But, you know, I cant see it.
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19 1 I dont know what its about.
2 And so, you know, like I said to the 3 inspectors yesterday, the inspectors and the branch 4 chief or whatever, you know, they were really nice 5 people and stuff. They didnt talk about, you know, we 6 went over what was the factors involved with the pumps 7 having issues and stuff like that. And the inspectors 8 didnt talk about the wrong sized pump impellers in the 9 PCP pump.
10 And so, you know, from outside, its hard 11 to get, you know -- reading a lot of this stuff, and its 12 helter skelter, a lot of this information. And, you 13 know, its just not right. It should be a complete 14 documentation. And safety, you know, is scrutinized 15 ability. Its the ability of outsiders, the ability of 16 you know that people are looking over your shoulders and 17 whether we catch you or just the idea that somebody might 18 catch you is an enormous safety barrier for people, you 19 know, doing the right thing.
20 Heres the 2012 003 August 8th and response 21 to the discovery of the two pieces that resembled the 22 PCP impeller. You know, when you get into this thing 23 and resembled and apparent impeller thing, how come 24 people cant -- what is going on here with people saying, 25 oh, it could be a possibility of an impeller or it might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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20 1 be an impeller. Well, its either an impeller or its 2 not. It doesnt seem to be that hard of an issue to 3 identify. I mean, thats the first responsibility of 4 a licensee to know if its an impeller or not an 5 impeller, to know that, you know, resembled a PCP 6 impeller, you know.
7 So why do people do that, put these weasley 8 words in here? Well, you know, if something happens and 9 that impeller is loose and we get into big problems, you 10 know, somebody cant go back and look and say we said 11 it was an -- plausible deniability. It resembled. We 12 didnt really know if it was a PCP impeller or what have 13 you.
14 So during the reactor vessel inspections of 15 2007, the licensee conducted an apparent root cause 16 analysis. The conclusion was that the pieces were most 17 likely from the DPCP. Well, whats going on? Most 18 likely from the DPCP? I mean, you could only run these 19 things knowing the facts of the condition and the 20 situations and what are the limitations of your 21 equipment. So most likely from the DPCP? Why havent 22 they gotten it down to its either an impeller or its 23 not an impeller? We will be damn certain we know what 24 pump that the impeller, the piece that broke away from 25 the impeller and stuff.
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21 1 Additionally, the analysis explored the 2 history of the Palisades PCP impeller conditions, which 3 included repeated occurrences of cracking which have 4 been identified and instances of heavy re-circulation 5 damage. Okay. So youre playing big words with me.
6 So what does heavy circulation damage mean? Is that a 7 safe -- is a heavy re-circulation damage, is that 8 unsafe?
9 And then it goes on and says, well, which 10 rendered the impeller unfit for continued use. Is it 11 safe? Is it an unfit impeller for continued use, is 12 that a safe impeller? Is that a safe condition when 13 theres something going on there that they dont 14 understand is causing all these impellers to break off 15 and they lose pieces in there?
16 This is really interesting. When the DPCP 17 was later inspected after removal during the 2009 18 refueling outage, it did not have any pieces of impeller 19 missing. Inspections of the PCP were recommended in 20 the apparent cause and had been planned to be executed 21 and the DPCP was not the source of the 2007 pieces, was 22 canceled. The cancellation was based, in part, on 23 thoughts that the piece may have originated elsewhere.
24 So here you go. You know, it resembled a 25 PC, most likely was from the DPCP. It might have been NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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22 1 an impeller. It could have been an impeller and stuff.
2 And it sets you up where these guys can say, oh, well, 3 we thought that it came from the DPCP, but we popped it 4 open and there was no damage in there, so it had to be 5 from the steam generators or wherever the hell it comes 6 from and stuff like that.
7 And so, you know, how come that engineering 8 is, you know, you know whats going on. You know the 9 conditions of your equipment. You know these defective 10 parts and these parts that are floating around in the 11 system, you know what they are. You get with facts and 12 evidence.
13 You know, somebody with a Ph.D., I mean, I 14 have to have triplicate evidence or proof of an 15 assertion. A Ph.D. can get there and, you know, they 16 can guess on a lot of these things. And the engineers.
17 You know, most of this is not about evidence and proof, 18 its all about guesswork, and it irks me.
19 So a piece, I mean, they didnt hunt down 20 and figure out what these pieces were in 2009. Then 21 that leads up to the inspection of 2012, 03. So that 22 was in August 2012. The event happened seven months 23 before that, October 11th, 2011. It was safe to operate 24 until the April 12th, 2012 outage and stuff.
25 So here today were sitting in not this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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23 1 outage but the outage before it. They knew that it was 2 a piece of an impeller. I mean, everybody admits that 3 it was the October 11th event of 2011, thats the 4 impeller thats in the core right now and stuff.
5 You know, the idea that -- and that prior 6 outage, you know, after they were given such leeway by 7 the NRC and stuff like that, I dont think they should 8 have been operated. Like I said, you know, the impeller 9 was unfit for continued use, and they talk about heavy 10 re-circulation damage and stuff like that. So what is 11 safe or what is unsafe? You know, everybody bandies 12 around about being safe and stuff like that, and, you 13 know, theres very little information on what is safe.
14 Theres a lot of -- outside people can 15 understand, Im telling you. Youve got a reactor 16 coolant pump and its flinging impellers, thats 17 unsafe. They dont have to go through a whole 18 calculation and stuff like that. They know thats not 19 right, and it stinks to high heaven that a plant like 20 that would be allowed to operate in such an unfit 21 condition, in such a discombobulated, confused 22 condition and stuff.
23 And so, like I was saying, and, again, so 24 here we sit in 2014. We know that an impeller got stuck 25 between the vessel and the flow skirt. That comes from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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24 1 2011 and stuff. So, you know, what Im trying to get 2 at, from that 2012 inspection report, I mean, everybody 3 knows that theres an attitude of, you know, broken 4 impellers and, wink-wink, were not going to -- you 5 know, theyre apparent impellers or theyre almost 6 impellers or, you know, they might be impellers, but we 7 really havent looked close enough to be positive that 8 they are impellers and stuff like that.
9 So they have a long history of having 10 impellers, knowing we have impeller damage and not 11 saying, not stopping and saying were going to, number 12 one, before we start up, were going to know what pump 13 that came from, we will never allow a PCP pump to 14 operate, knowingly operate with any cracks of any sort 15 or any degradation and stuff like that, and were going 16 to hunt down that impeller and yank it out of the core 17 and stuff like that.
18 So, I mean, you know, that impeller thats 19 sitting next to the core or the vessel or the core skirt 20 and stuff like that, theres a long history of Palisades 21 losing impellers and knowingly losing impellers and 22 dancing around with the NRC saying theyre, you know, 23 talking language like it resembled a PCP impeller, you 24 know, kind of playing with words, you know, we think its 25 an impeller, but if we get in trouble we can deny that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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25 1 or, especially if we do a search like we did in 2012 and 2 we cant find the impeller, well, maybe there was never 3 an impeller blade that was missing, or, you know, if the 4 NRC doesnt ask us then we wont have to tell them and 5 then we get started back up.
6 Everything about that 2012 inspection 7 report is, its making that information inscrutable to 8 the public. So make sure that you dont discuss it 9 until not only way after the event, its only publicly 10 discussed after the next outage and when that plant is 11 back in operation. All the dirty little linen and all 12 that sort of stuff is engineered so its on the other 13 side of the plant operational threat, and the agency has 14 a habit of doing this all the time, you know, not 15 discussing the dirty deeds until everybody is safe or 16 youre already back up at power and it cant be 17 contested, theres no way it can be contested. Its not 18 fair. Its not allowing the public to see whats going 19 on and giving somebody a shot to ask a question and that 20 type of thing.
21 So we dont know. You know, again, you had 22 a whole bunch of, you had a whole bunch of conditions 23 post that inspection report. And, basically, you 24 talked about the sequencing of the pumps. You know, how 25 do you, how do you know a pump is within its designs and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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26 1 the plant is running according to, you know, the FSARs 2 or whatever it is and stuff like that?
3 So, you know, you measure its suction 4 pressure, its discharge pressure, you know, you hit the 5 pump curves and all that sort of stuff, and thats how 6 you, you know, see the green or red. Its either 7 possible conditions that pump is going to be operated 8 according to its designs. You have verifiable 9 evidence. So, you know, you guys didnt show us. It 10 was kind of blurry as far as would them fixes really 11 protect the public and protect from any future issues 12 with broken impellers.
13 And we know that, you know, that that 14 inspection notice 85-03 or whatever it is, we know that 15 these things can lead to a severe accident. You could 16 destroy out of your four seals almost immediately, three 17 seals. And you could spew a lot of metal in the coolant 18 and have the potential of, a strong potential of 19 damaging fuel and stuff. You know, so theres a threat 20 to the pressure barrier right there that Palisades is 21 required to not have any, you know, to have their 22 pressure barrier within a certain set of quality type 23 of things and stuff. So, you know, I would think thats 24 a threat to the pressure barrier, you know, if, in the 25 future, theres other issues with the impellers NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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27 1 breaking off and stuff.
2 You know, well, you know, the question of 3 why would these guys not have new impellers on site?
4 What makes guys like this go into this thing of doing 5 weld repairs on reactor coolant pump impellers? And 6 especially you find that these weld repairs are, you 7 know, its the most threat to throwing blades and stuff 8 like that. I dont understand why the NRC wasnt in 9 there and saying you cant do that welding kind of stuff 10 on these impellers and stuff, you know. You cant have 11 a history of having broken impellers and stuff.
12 Wheres the NRC in this, in that thing, you know?
13 So I have questions whether Palisades is 14 competent to operate that plant, and I have issues in 15 this that the NRC is competent in knowing what the 16 conditions of culture is. And you know that theres a 17 lot of confusion going on, and youre not using the right 18 tools in order to straighten these guys out and stuff.
19 You know, Palisades has been in a lot of trouble, you 20 know. Entergy, the recent issues with the stator drop 21 accident. And now its a red finding and a yellow 22 finding.
23 When that event in 2011 was going on, 24 Palisades was starting up from their yellow finding with 25 their DC, they let their employees perform maintenance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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28 1 on a DC bus and it almost killed them, killed an employee 2 and stuff. And then you go into Palisades has issues 3 with the security department, their employees not 4 telling the truth. Their security employees across the 5 board for years have had issues with intimidation and 6 being afraid to speak up to their managers and stuff like 7 that. Back with that first incident with security and 8 now theres a new thing going on that we dont understand 9 really whats going on.
10 And so, you know, Entergy, site-wide, had 11 issues with, down south it had an engineer that was 12 raising issues and they tried to intimidate him and 13 stuff. So there was a lot of training about that 14 incident and stuff. They had employees in another 15 plant going on the internet in the control room and 16 stuff.
17 So Im just saying, you know, all of a 18 sudden, to treat Palisades like theyre a victim and, 19 you know, and give them all sorts of more breaks and 20 stuff like that, I just, I think thats heading in the 21 wrong direction and stuff.
22 The message here is that you can play word 23 games and you can call them apparent of almost impeller, 24 broken impeller blades and all that sort of stuff. And 25 every time you get a broken impeller, you wont be forced NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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29 1 to shut down and repair it and, number one, find it and 2 then figure out what the hell is broken or degraded and 3 replace it with a fully-qualified reactor coolant pump 4 and stuff that you wont have problems with for decades 5 and stuff like that.
6 So what youre signaling to Palisades is, 7 oh, you can have as many broken blades as you want and 8 well all play around with definitions and the words of 9 apparent impellers being stuck between the skirt and the 10 core and stuff. And, you know, you can keep this 11 behavior going on for infinite. You know, every time 12 a bad, you know, scares the pants out of the staff with 13 vibration problems and throwing blades and stuff like 14 that, you know, oh, dont worry about it, you will never 15 pay the price of a shutdown. As a matter of fact, you 16 dont even have to find out where that blade went. You 17 have repeated incidences of, like, a 2007 one, like the 18 most recent one in, I dont know, last August 2012, I 19 think its April 2012, where, you know, its really not 20 that important that you have a big incident where you 21 lose a 5 x 12 inch impeller in there.
22 And its really not that important that you 23 find that impeller. You can start it back up and two 24 years down the line by mistake you can find it, and then 25 youre heroes. Whats up with that? Besides the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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30 1 point, okay, you guys pick on me because I speculate and 2 I use my imagination. Well, so where are the reports 3 on broken impellers and stuff like that, you know?
4 Wheres the evidence that this kind of, this size 5 impeller is not going to lead to a 1984 event and this 6 size impeller break is going to lead to, you know, not 7 being an operational issue?
8 You know, with your recent, trying to yank 9 out that impeller piece this last outage, well, the 10 going theory is the flow, the large amount of flow pushed 11 that impeller against the skirt and the core and that 12 made it so that I guess they used 3,000 pounds to try 13 to yank it up from above and then they used some sort 14 of hammer to see if you could knock it up from below and 15 stuff. And so, you know, see, you know, why did Ph.D.s 16 get to make guesses on what caused that impeller to be 17 stuck versus wheres the evidence, you know -- on the 18 other end, youd have to say, well, youd have to have 19 a mockup maybe or something similar, and youd have to 20 have the same size impeller and stuff. Yes, I know this 21 is costly and ridiculous, but youre not supposed to 22 allow a PCP impeller to break in a nuclear power plant.
23 So what is your proof that the flow actually 24 wedged that impeller in that position? What is the 25 proof of that? Is it all guesses? You know, normally, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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31 1 youd kind of make a model, like I say, reenact it, and 2 then the proof is that, well, yes, shit, that thing did 3 get stuck in there with all that flow. And then you go 4 on real evidence and stuff like that and real proof and 5 studies and those kind of peer-approved reports to be 6 presented. And then wed have some sense of well, you 7 know, this is the truth and a lot of people looked at 8 it from different perspectives.
9 You know, like I say, you know, and even the 10 NRC in this, it might be true, its the cool down that 11 those parts contract at different rates, and thats what 12 putting the pressure on it. And, again, we dont know.
13 We dont know what kind of pressure is on that part right 14 now. We know what it is when the vessel is cooled down.
15 We dont know what it is when its heated up. Theres 16 no proof that, you know, that ten pounds wont move that 17 piece of impeller in the core today and stuff.
18 And so, you know, I dont know. I just see 19 a pattern of behavior of the issues of really not knowing 20 what gets broken in that plant. Yes, symptoms of a 21 coolant pump being thrown off impellers and nobody goes 22 searching for them blades and stuff. And so, you know, 23 whether were safe now with that impeller being stuck 24 in the core, I know that theres been a lot of impellers 25 broken and a lot of them have been found at the bottom NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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32 1 of the core. And this is really sloppy, unthoughtful 2 ways in which to operate a nuclear power plant.
3 And whens it going to stop? Like I say, 4 when its going to, whens Palisades going to realize 5 that theyre not allowed to operate with those kind of 6 degraded components in a nuclear power plant. They 7 should, a decade ago, the NRC should have come in there 8 and, you know, if they cant find the discipline in 9 themselves to do the right thing, then the agency is 10 supposed to behave in a way that the utility sees the 11 light and starts behaving the way theyre expected to.
12 I dont know whats in other PWRs, whats the -- and 13 this, again, theres a problem there because its not 14 documented.
15 I suspect theres a lot of plants out there 16 that dont have PCP problems as Palisades, just like 17 theres a lot of plants out there that dont have control 18 rod drive mechanisms, these kinds of repeated problems 19 over decades like Palisades and stuff like that. When 20 is Palisades going to be treated like a regular plant?
21 You know, and then they get all these 22 different kind of, theyve got flaws and stuff, and then 23 theyre getting all sorts of special permission from the 24 NRC to not go according to ASME. You know, again, you 25 know, its just -- oh, so here it is. When the fixes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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33 1 post 2012-003, you had a monitoring plan. A monitoring 2 plan? A monitoring plan? How about making sure that 3 that equipment is of a proper quality that those things 4 never happen again? So wheres that? Monitoring 5 plan? It boggles the mind.
6 Change the preferred sequence of starting 7 and stopping pumps during startup and shutdown, 8 corrective action to explore further procedure changes 9 regarding PCP and operations and result in other aspects 10 of other, result in impacts of other aspects of plant 11 operation.
12 CHAIR LUND: Okay, Mr. Mulligan. You have 13 about ten more minutes. This is Louise Lund.
14 MR. MULLIGAN: Oh, thank you, yes. Cyclic 15 pressures and stresses are created under reduced 16 pressure conditions. So I just dont get how the NRC 17 allows the plant to operate like that without -- I mean, 18 has PCP pumps been placed in a condition that theyre 19 in accordance to FSAR and other pump design documents?
20 I ask the inspectors and the branch chief yesterday, and 21 I got a kind of fuzzy answer. I didnt, I didnt -- and 22 another thing is that, well, why are they doing that?
23 Okay, that was a nice inspection report in 2012, 003, 24 but, you know, the agency doesnt explain why they were 25 doing that, you know. What were the motivations of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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34 1 operating outside the FSAR and the other -- for so long, 2 you know? Like I talked about, you know, how long is 3 the exposure rate? The NRC talks about it being limited 4 to 2007, and I think, like I talked about, I think the 5 1984 one and this most recent one are basically the same 6 incident and the exposure rate. Does the NRC get to 7 say, well, arbitrarily, its from 2007, you know, back 8 then?
9 How come the NRC didnt, you know, they 10 mentioned a 1984 event back in 2012. How come they 11 didnt explain in that inspection report to the 12 community, you know, they had a pretty terrible accident 13 in 1984. It wasnt just a blade letting loose. They 14 had serious damage to a pump. Why didnt they kind of 15 inform us of that more closely on that 1984 event and 16 stuff?
17 I mean, thats what Im saying. Does the 18 NRC get to pick and choose? You know, they got a list 19 of ten things that causes an event, and they can pick 20 the top five things to disclose to the public, the ones 21 that reflect well on Palisades? I mean, thats what it, 22 thats the issue. If you dont got your documents 23 straight and you dont report to us in a 24 straightforward, honest manner, instead of playing 25 these word games, how can you expect public confidence NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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35 1 and stuff?
2 And, you know, a plant like Palisades, say 3 theres another plant that acts in the same way. Do you 4 think that if they get into a big problem, if they get 5 into a big accident, and all of a sudden you have to 6 disclose all this sort of stuff, do you think its going 7 to end well? You think its going to reflect well on 8 the agency and the utility and all that sort of stuff?
9 Do you think, with all this kind of confusion, 10 engineering confusion running rampant, its going to 11 end in a good way?
12 Youre going to have an accident, and then 13 youre going to have an accident on top of it because 14 you didnt, you werent communicating for decades in an 15 appropriate manner. And you didnt have that bank 16 buildup of honesty in the public there. Well, I know 17 the NRC, and I know these guys, theyre particular as 18 hell and they make everybody document everything. You 19 know, out of this thing here, you can make the case that 20 is the exact opposite.
21 These guys, I dont know what kind of rules 22 they follow, but it ends up that an event like these 23 pumps are never documented, are arbitrarily put in an 24 inspection report because, you know, not because the 25 inspector sat there and says, boy, thats an interesting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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36 1 thing, you know. I looked at the suction pressures and 2 the discharge pressures and the pump curves, kind of we 3 expect that at the NRC. You know, it doesnt fit. And 4 so theyre not operating in accordance to the FSAR and 5 the procedures. And you throw up an inspection report 6 before the damage was shown. Thats what youd expect 7 out of the agency, you know, not have to have triplicate 8 proof that damage has occurred but to kind of, oh, well, 9 these guys arent operating in accordance to their FSARs 10 and were going to pick up that problem before the damage 11 shows and stuff like that.
12 Why cant the agency be proactive and ask 13 difficult questions, instead of waiting for, you know, 14 the evidence of multiple examples of broken impeller 15 blades to show up? And then they kind of get half honest 16 and stuff.
17 And so, I mean, Ive had issues. As an 18 example, with Pilgrim relief valves that Palisades 19 bought -- not Palisades. Pilgrim bought four brand new 20 relief valves, stuck them in there, and then for the next 21 operating cycle they had repeated power ups and power 22 downs because those guys were leaking. And, 23 essentially, the NRC and Pilgrim, you know, wink, wink, 24 wink, we dont have to report anymore. The crap out of 25 TMI, that doesnt matter anymore. Weve got rules in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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37 1 here that says that we dont have to make an LER report 2 that is accurate, that is detailed and stuff. And if 3 we write it up, its on the other side of the operability 4 issues or the threat of a plant being shut down. The 5 agency will never give outsiders the opportunity of 6 having information available that should prove that 7 that plant is unfit to be operating.
8 The bad stuff only comes out after the 9 operability issues are over with and stuff. So there.
10 Vermont Yankee had the same related issues with their 11 SRV valves and stuff like that. And weve had issues 12 in trying to follow it in the inspection reports and in 13 the LERs, and its really poor reporting.
14 You know, I know whats going on here.
15 Theyre saying these utilities and you guys are saying, 16 oh, well, weve put all this information in our 17 corrective actions and all these different kind of 18 internal reports. See, you shifted from the lessons of 19 TMI, of being honest, building up that bank of 20 credibility, and getting these documents -- Jesus, you 21 know, that was a miracle when they came out with LERs 22 and post TMI and stuff like that.
23 And, you know, it was quite detailed, a lot 24 of those reports, which they arent. Case after case 25 after case where, you know, the agency is just meeting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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38 1 its minimum requirements to document issues at these 2 plants. They dont have no sense of, as far as Im 3 concerned, professionalism or what really the public 4 wants and stuff like that. So theyre reporting this 5 crap at a minimum level or less, and we dont have any 6 really ways to, you know, present our side of the story 7 and stuff like that and see about these inspection 8 reports. You know, theres no open way to criticize, 9 oh, this is a skimpy inspection.
10 I hear this next one is going to be quite 11 thorough in justifying why that blade is stuck in the 12 core and stuff like that. But -- all right.
13 CHAIR LUND: Mr. Mulligan, let me go ahead 14 and move to the question period. So at this time, does 15 the staff here at Headquarters have any questions for 16 Mr. Mulligan?
17 (No response.)
18 CHAIR LUND: Okay. And what about the 19 region?
20 (No response.)
21 CHAIR LUND: Does the licensee have any 22 questions?
23 MS. DOTSON: We have no questions.
24 CHAIR LUND: Okay, thank you. And are 25 there any members of the public on the phone, besides NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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39 1 Mr. Mulligan?
2 (No response.)
3 CHAIR LUND: Okay. Before I conclude the 4 meeting, members of the public may provide comments 5 regarding the petition, ask questions about the 2.206 6 process. However, as stated in the opening, the 7 purpose of this meeting is not to provide an opportunity 8 for the petitioner or the public to question or examine 9 the PRB regarding the merits of the petition request.
10 So, again, is there anybody from the member 11 of the public who would like to ask a question?
12 (No response.)
13 CHAIR LUND: Okay. So in closing, Mr.
14 Mulligan, thank you for taking time to provide the NRC 15 staff with clarifying information on the petition you 16 have submitted. Before we close, does the court 17 reporter need any additional information for the 18 meeting transcript?
19 COURT REPORTER: Im okay for now. Thank 20 you.
21 MR. MULLIGAN: And I appreciate this 22 opportunity, and I appreciate the branch chief and the 23 two inspectors, I was talking with them yesterday, I 24 appreciate and thank the agency very much.
25 CHAIR LUND: Okay. Thank you for that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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40 1 feedback, Mr. Mulligan. And the court reporter, did 2 you need anything else?
3 COURT REPORTER: No, thanks.
4 CHAIR LUND: Okay. With that, the meeting 5 is concluded, and we will be terminating the phone 6 connection. Thank you.
7 (Whereupon, the above-referenced matter 8 was concluded at 12:02 p.m.)
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