ML14259A135
| ML14259A135 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/03/2014 |
| From: | Division of Operating Reactor Licensing |
| To: | |
| Jennivine Rankin, NRR/DORL, 415-1530 | |
| References | |
| 2.206, NRC-1044 | |
| Download: ML14259A135 (26) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board RE Palisades Nuclear Plant Docket Number:
50-255 Location:
teleconference Date:
Wednesday, September 3, 2014 Work Order No.:
NRC-1044 Pages 1-25 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 4 CONFERENCE CALL 5
RE 6
PALISADES NUCLEAR PLANT 7
+ + + + +
8 WEDNESDAY 9
SEPTEMBER 3, 2014 10
+ + + + +
11 The conference call was held, Louise Lund, 12 Chairperson of the Petition Review Board, presiding.
13 14 PETITIONER: MICHAEL MULLIGAN 15 16 PETITION REVIEW BOARD MEMBERS 17 LOUISE LUND, Chair, Deputy Division Director 18 Division of Reactor Licensing, NRR 19 DAVID ALLEY, Branch Chief, Component 20 Performance, NDE, and Testing Branch, Division 21 of Engineering, NRR 22 REED ANZALONE, General Engineer, Nuclear 23 Performance & Code Review Branch 24 MERRILEE BANIC, Petition Coordinator, NRR 25
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MAHESH CHAWLA, Project Manager, NRR 1
JOSHUA KAIZER, Reactor Systems Engineer, NRR 2
WARREN LYON, Senior Reactor Systems Engineer, 3
Reactor Systems Branch, NRR 4
DAVID PELTON, Chief of Licensing, Branch 3-1, NRR 5
JENNIE RANKIN, Project Manager, NRR 6
ROBERT WOLFGANG, Senior Mechanical Engineer, 7
Division of Engineering, NRR 8
9 REGION III STAFF 10 ALEX GARMOE, Senior Resident Inspector 11 CHRISTOPHER HUNT, Reactor Engineer 12 JAY LENNARTZ, Project Engineer, Palisades Site 13 APRIL SCARBEARY, Resident Inspector 14 15 LICENSEE STAFF 16 BARBARA DOTSON 17 18 19 20 21 22
3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P R O C E E D I N G S 1
10:02 a.m.
2 MS. RANKIN: So I'd like to thank 3
everybody for attending this meeting. My name is 4
Jennie Rankin, and I am the NRC Project Manager for the 5
Palisades Nuclear Plant.
6 We are here today to allow the petitioner, 7
Mr. Michael Mulligan, to address the Petition Review 8
Board regarding the 2.206 petition dated March 5th, 9
2014. I am also the petition manager for this 10 petition. The Petition Review Board Chairman is 11 Louise Lund.
12 As part of the Petition Review Board or 13 PRB's review of this petition, Mr. Mulligan has 14 requested this opportunity to address the PRB. This 15 meeting is scheduled from 10 a.m. to 11 a.m. The 16 meeting is being recorded by the NRC Operations Center 17 and will be transcribed by a court reporter. The 18 transcript will become a supplement to this petition.
19 The transcript will also be made publicly available.
20 I'd like to open this meeting with 21 introductions. As we go around the room, please be 22 sure to clearly state your name, your position, and the 23 office that you work for within the NRC for the record.
24 I'll start. My name is Jennie Rankin, 25
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Project Manager in the Office of Nuclear Reactor 1
Regulation.
2 MS. LUND: Louise Lund. I'm the Acting 3
Division Director for the Division of Operating Reactor 4
Licensing and NRR, and I'm also the PRB Chair.
5 MR. ALLEY: Dave Alley. I'm the Branch 6
Chief for the Component Performance, NDE, and Testing 7
Branch, Division of Engineering, Office of NRR.
8 MR. WOLFGANG: Bob Wolfgang, Senior 9
Mechanical Engineer, Component Performance, NDE, and 10 Testing Branch, Division of Engineering and NRR.
11 MS.
BANIC:
Lee
- Banic, Petition 12 Coordinator, NRR.
13 MR. KAISER: Joshua Kaiser, Nuclear 14 Performance and Code Review, NRR.
15 MR. ANZALONE: Reed Anzalone, Nuclear 16 Performance and Code Review, Division of Safety 17 Systems, NRR.
18 MR. PELTON: David Pelton, Chief of 19 Licensing Branch III-1 in NRR.
20 MR. CHAWLA: Mac Chawla. I'm the Project 21 Manager in Division of Licensing, NRR.
22 MS. RANKIN: Okay. We've completed 23 introductions here at headquarters. We'll go to the 24 bridge line for the NRC participants from headquarters 25
5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 on the phone.
1 MR. LYON: Warren Lyon, Reactor Systems, 2
NRR.
3 MS. RANKIN: And then the participants 4
from the NRC from the regional office on the phone, 5
please introduce yourself.
6 MR. LENNARTZ: Jay Lennartz. I'm the 7
Project Engineer for Palisades site, Region III.
8 MR. HUNT: Christopher Hunt. I'm the 9
Reactor Engineer for Palisades site, Region III.
10 MR. GARMOE: Alex Garmoe and April 11 Scarbeary, NRC Resident Inspectors at Palisades.
12 MS. RANKIN: Okay. And then are there any 13 representatives for the licensee on the phone?
14 MS. DOTSON: Barb Dotson, Palisades, 15 Licensing.
16 MS. RANKIN: Mr. Mulligan, would you 17 please introduce yourself for the record?
18 MR. MULLIGAN: I'm Mike Mulligan. I live 19 in Hinsdale, New Hampshire. I have been interested in 20 Palisades for a number of years, and I've had a number 21 of failed 2.206's. I'm a whistleblower, and I was in 22 the nuclear industry for a while. Thank you.
23 MS. RANKIN: Thank you, Mr. Mulligan. It 24 is not required for members of the public to introduce 25
6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 themselves for the call. However, if there are any 1
members of the public on the phone that wish to do so 2
at this time, please state your name for the record.
3 Okay. Moving on, hearing none, I'd like 4
to emphasize that we each need to speak clearly and 5
loudly to make sure that the court reporter can 6
accurately transcribe this meeting. If you do have 7
something that you would like to say, please state your 8
name for the record.
9 Court reporter, did you hear everybody 10 okay so far?
11 COURT REPORTER: Yes, I have.
12 MS. RANKIN: Okay. Thank you. For those 13 dialing into the meeting, please remember to mute your 14 phones to minimize any background noise or 15 distractions. If you do not have a mute button, this 16 can be done by pressing the keys *6. To unmute, press 17 the *6 key again. Thank you.
18 At this time, I'd like to turn it over to 19 the PRB Chairman, Louise Lund.
20 MS. LUND: Okay. Thank you. Good 21 morning. Welcome to this meeting regarding the 2.206 22 petition submitted by Mr. Mulligan. I'd like to first 23 share some background on our progress, our process.
24 Section 2.206 of Title 10 of the Code of 25
7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Federal Regulations describes the petition process, 1
the primary mechanism for the public to request 2
enforcement action by the NRC in a public process.
3 This process permits anyone to petition NRC to take 4
enforcement-type action related to NRC licensees or 5
licensed activities.
6 Depending on the result of its evaluation, 7
NRC could modify, suspend, or revoke an NRC-issued 8
license or take any other appropriate enforcement 9
action to resolve a problem. The NRC staff guidance 10 for the disposition of 2.206 petition requests is in 11 Management Directive 8.11 and is publicly available.
12 The purpose of today's meeting is to give 13 the petitioner an opportunity to provide any additional 14 explanation or support for the petition following the 15 Petition Review Board's initial consideration and 16 recommendation. This meeting is not a hearing, nor is 17 it an opportunity for the petitioner to question or 18 examine the PRB on the merits or the issues presented 19 in the petition request. No decisions regarding the 20 merits of this petition will be made at this meeting.
21 Following this meeting, the Petition 22 Review Board will conduct its internal deliberations.
23 The outcome of this internal meeting will be discussed 24 with the petitioner.
25
8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 The Petition Review Board typically 1
consists of a chairman, usually a manager at the Senior 2
Executive Service level at the NRC. It has a petition 3
manager and a PRB coordinator. Other members of the 4
board are determined by the NRC staff based on the 5
content of the information in the petition request.
6 The members have already introduced themselves.
7 As described in our process, the NRC staff 8
may ask clarifying questions in order to better 9
understand the petitioner's presentation and to reach 10 a reasoned decision whether to accept or reject the 11 petitioner's request for review under the 2.206 12 process.
13 I would like to summarize the scope of the 14 petition under consideration and the NRC activities to 15 date. On March 5th, you submitted to the NRC a petition 16 under 2.206 regarding Palisades Nuclear Plant in which 17 you requested a number of actions. The major ones 18 concern operating with a broken impeller and flawed 19 control rod drive mechanism housing.
20 Allow me to discuss the NRC activities to 21 date. On March 14th, 2014, the PRB reviewed your 22 request for immediate action to prevent Palisades' 23 restart and determine that there were no 24 safety-significant concerns to prevent the plant from 25
9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 restarting as scheduled. The NRC has reviewed the 1
licensee's evaluation of the impeller piece fragment 2
within the reactor vessel and concluded that it does 3
not pose a threat to the reactor and other plant 4
components. Additionally, the licensee has replaced 5
all of the 45 control rod drive mechanism housings prior 6
to plant startup.
7 Based on the review of the licensee's 8
evaluation related to the stuck impeller piece and 9
replacement of all CRDM housings during the refueling 10 outage, there were no immediate safety-significant 11 concerns to prevent the plant from restarting as 12 scheduled. Your request for the immediate action of 13 shutdown of Palisades and other Entergy plants did not 14 have the adequate basis. Therefore, your request to 15 prevent Palisades from restarting was denied.
16 You were informed on March 19th, 2014 of 17 the PRB's decision to deny your request for immediate 18 action. On March 24th, the petition manager contacted 19 you to discuss the 10 CFR 2.206 process and to offer 20 you an opportunity to address the PRB. You requested 21 to address the PRB by phone prior to its internal 22 meeting to make the initial recommendation to accept 23 or reject the petition for review.
24 On April 8th, 2014, you addressed the PRB 25
10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 by teleconference. The teleconference was recorded 1
and transcribed and has become a supplement to this 2
petition.
3 On May 19th and July 28th, 2014, the PRB 4
met to discuss your petition, as supplemented and in 5
accordance with the criteria for review and rejection 6
described in Management Directive 8.11. The PRB 7
determined that the following requests from your 8
petition meet the criteria for review in accordance 9
with MD 8.11: Number one, request for PNP to open every 10 PCP for inspection and clear up all flaws. Number two, 11 request for PNP to replace the PCPs with a design for 12 their intended duty. Number three, request an Office 13 of Inspector General inspection on why there are 14 different analysis criteria for similar PCP events 15 between the NRC regions. Four, request a $10 million 16 fine over these events. And number five, request for 17 PNP to return to yellow or red status and intensify NRC 18 monitoring of PNP.
19 You were informed of the PRB's initial 20 recommendation to accept your petition, in part, by 21 email dated August 15th, 2014. In addition, you were 22 informed of the basis for not accepting the remaining 23 parts of the petition. The petition manager also 24 offered you an opportunity to address the PRB. You 25
11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 requested to address the PRB by phone following 1
notification of the PRB's initial recommendations.
2 As a reminder for the phone participants, 3
please identify yourself if you make any remarks, as 4
this will help us in the preparation of the meeting 5
transcript that will be made publicly available.
6 Mr. Mulligan, I'll turn it over to you to 7
allow you the opportunity to provide additional 8
explanation and support for your petition in light of 9
the PRB's initial recommendation. You have about 40 10 minutes for your presentation.
11 MR. MULLIGAN: Thank you. Deterrents.
12 You know, we look at deterrents as far as the NRC's 13 activities associated with a nuclear power plant, and 14 we see that the NRC doesn't have any, very little 15 deterrents on the bad behaviors of other plants.
16 As far as all of the issues with Palisades 17 over the years, a recent newspaper wrote up an 18 interesting set of articles about Palisades and all the 19 troubles they had. And what you see over this thing 20 is there is, one thing, the NRC doesn't have any 21 horsepower to, you know, put fear in the eyes of these 22 guys. And that's, basically, you know, if you go 23 one-by-one with these regulations and stuff like that, 24 you're going to consume all the NRC's resources and 25
12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 stuff like that.
1 And so there's the deterrence part of the 2
NRC's activities. You know, the utilities are going 3
to exhaust the agency with all the nickel and dime stuff 4
if there's not a deterrence part of this deal, if they 5
don't fear the NRC and that type of thing.
6 We also know that -- I believe that, 7
generally, in the last five years, as shown by the 8
articles in the newspaper, that with all of our 9
troubles, Palisades had better capacity factor than 10 they had in the early years and stuff. And this is all, 11 essentially, because of risk perspectives and 12 reductions of regulations and all that sort of stuff.
13 And so in spite of all their troubles and that type of 14 thing, Palisades has been allowed to continue on in the 15 way they've always done.
16 Palisades did a relatively good job on the 17 control rod drive mechanisms of recent, but they had 18 a horrible history of CRDM problems and that type of 19 stuff. Palisades has had numerous issues of 20 falsifying documents, intimidating employees, lying to 21 inspectors over the recent years and that type of stuff.
22 And, you know, like the recent issue with the security 23 guards, they had a similar incident four or five years 24 ago, basically the same thing: lying and falsifying 25
13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 documents to the NRC. And I know the NRC basically says 1
after two or three years, well just make believe that 2
it never happened, you know, the history never really 3
is caught up together. And you don't have enough 4
influence and power to keep a plant like Palisades 5
straight.
6 What's happened here is really ugly.
7 What's happened with the impellers is ugly. It's 8
unprofessional. It makes our nation a laughing stock 9
to all the other nations that are desperately trying 10 to, you know, maintain their fleet safely and stuff like 11 that.
12 And I've heard from numerous professional 13 people in the industry basically saying they cannot 14 believe that we allowed the Palisades plants to operate 15 for so many years with these reactor coolant pumps and 16 all these different kind of warnings we've had over the 17 years and stuff and all these indications. And we're 18 only getting, the outsiders are only getting the bits 19 and pieces of what really went on with these impellers 20 and stuff. You know, a lot of nations think of this 21 as irresponsible and not worthy of a great nation when 22 you get down to these impellers and stuff.
23 And then you've got Salem, like I talked 24 about, the recent issues with a horrendous, all their 25
14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 bolts being loose and stuff like that, prior, you know, 1
prior warnings and that type of stuff that were ignored, 2
and the NRC really hasn't stepped in there and done what 3
the public wants. They don't want to have a Salem.
4 You know, a crack starts somewhere in a reactor coolant 5
pump. They want that crack fixed. They don't want to 6
have to deal with these problems for years and years 7
and deal with the broken bolts and fallen down 8
components and the pumps and stuff. That's ugly. The 9
amount of cracked and broken impellers, it's ugly.
10 It's unprofessional. It's an essence of an indicator, 11 you know. If they can't keep these impellers, you 12 know, if they don't have to spend so much resources on 13 these broken components, impellers, the tank that 14 recently leaked, the control rod drive mechanisms, and 15 stuff like that. You know, they're just consuming 16 plant resources, and we fear that other safety problems 17 aren't being dealt with adequately.
18 A lot of these kind of components breaking 19 and stuff like that, that has a tendency to make the 20 employees disillusioned and they know that it's wrong 21 and stuff like that. And they know that the NRC doesn't 22 back them. They know that, you know, we have to make 23
-- they'll be up in the control room and they'll have 24 the indications of a big blade being thrown off the 25
15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 pump, and everybody will sit back and not give what the 1
public really wants the Agency to force Palisades to 2
do, to shut down, pay a price, deterrence, deterrence, 3
and make them pay a price so that, you know, when they're 4
in their little rooms and they're making these 5
decisions about, you know, well, we've got some part 6
of the impeller cracked, we can either fix it right, 7
put in new parts so we don't have to deal with this in 8
the past, or the NRC is going to, down the road, if, 9
you know, bigger parts start falling off the pump or 10 it gets strewn about the plant, they're going to make 11 us pay a horrendous price.
12 Most of the people, you know, what is 13 safety related and all that sort of stuff, you know.
14 We think when you talk about Palisades is safe that 15 means that you are pretty sure that they won't have a, 16 you know, a type of severe core damage and off-site 17 relief where you'll have a fatality. That's what 18 you're saying when you say a plant is safe, and that's 19 just not an appropriate standard. We don't think 20 that's an appropriate -- we think this ugliness is a 21 pretty good indicator of the future and that it 22 shouldn't be tolerated. It should be nice and clean, 23 and the operation of the plant should be nice and clean, 24 and they're not all caught up with these degradations 25
16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 and broken components and all that sort of stuff. It's 1
a clean plant. The staff is not excessively busy or 2
the control room employees don't have all these 3
complicated procedures in place of, you know, a 4
well-engineered plant. And, you know, everybody is 5
diligently paying attention to the plant, not paying 6
attention, not worrying about the degradations.
7 Again, these kind of questions, you know, 8
what we know about what's going on in the wider nuclear 9
industry, how many other plants have bolts breaking off 10 on all their coolant pumps and stuff like that, other 11 blades that are getting thrown off the reactor coolant 12 pumps, the blades getting caught in the reactor core, 13 and that type of stuff? We have no confidence that we 14 know really, you know, that our nation is safe.
15 We worry about Palisades, but there's a 16 risk if a lot of plants have degradation mechanisms that 17 the NRC doesn't have under control and, you know, 18 necessarily what you can prove isn't the most unsafe.
19 It's a lot of the stuff that's behind the barrier that's 20 degradated, that's degrading in an unknown fashion, and 21 that's a threat to the nation and to a plant.
22 So that's kind of what we're worried about 23 with -- rules don't carry a lot of information and 24 stuff. You know, staying within the rules doesn't have 25
17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 a lot of information. Usually, human intelligence and 1
a brain can process a lot of information and that type 2
of thing, and so that's what I worry about is a lot of 3
these rules and stuff is designed to make us become more 4
stupider than we really are.
5 I think, like I said, we worry about what's 6
going on if regulations will tolerate this kind of ugly 7
behavior at Palisades, certain events in the industry 8
that are pretty concerning that are out there that kind 9
of questions whether it's a lot more uglier than what's 10 being portrayed by the NRC. The example of Cooper 11 plant, some other energy plant, and their issues with 12 training failures. And essentially, you know, I call 13 it cheating. There's a lot of cheating involved there, 14 as far as -- especially that they were simulating 15 booking hooking up the RCIC to the boron injection 16 system and they couldn't make that fire hose go through 17 the floors, the floor as, you know, as expected and 18 stuff. That's kind of cheating. That's the same kind 19 of thing that, you know, we're worried about as far as 20 at Palisades, this level of cheating.
21 You know, it almost gets to the point of, 22 you know, the NRC says, you know, well, cheating isn't 23 safety related, you know. We can't -- it doesn't, it's 24 un-safety related. It can be repaired, or it's not a 25
18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 big deal, or it's not modeled appropriately in all your 1
risk perspectives and stuff like that.
2 Another issue we have is really you don't 3
have any proof, there's no engineering proof that those 4
reactor coolant pumps are safe. You don't have any, 5
I don't see any model of, you know, actual building a 6
plant, building, more or less, a prototype type of deal 7
where you're beating the hell out of the pumps and 8
you're getting those kind of blade failures and 9
everybody, you know, you're experimenting a lot on a 10 system like the Palisades pumps and its relationship 11 to its primary coolant system and stuff like that. You 12 don't have really any actual, I don't see any actual 13 engineering that those pumps are safe. Studies, 14 actual studies. It's all kind of, more or less, you 15 know, the fallback of the NRC, it's our opinion that 16 it's safe and stuff like that. That's the privilege 17 of the NRC. They get to say that, basically, the 18 professional people, they get to say, you know, a guy 19 like me needs triplicate proof that Palisades is 20 unsafe, even when it's all there. You guys get to say, 21 "It's my opinion that it's safe," and you don't have 22 any evidence to back it up.
23 So the evidence I'm talking about is, would 24 be some engineering document showing that, you know, 25
19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 we've gone through all of the, you know, not necessarily 1
intellectual kind of thing that the NRC likes to do, 2
but we really set up a system and we've repeated the 3
degradation mechanisms on Palisades with their PCP 4
pumps and stuff like that, and we actually seen the 5
results of the broken impellers and stuff like that.
6 We have a full engineering understanding of the 7
mechanisms of what potentially could go wrong in the 8
future with those pumps.
9 And, you know, and after all of this, after 10 all of these decades with this failure mechanism at 11 Palisades, if it's still not fixed, you know, they still 12 have issues with going outside their licensing as far 13 as certain pressures and stuff like that and creating, 14 you know, it's a poor design, probably poorly-designed 15 impeller that causes these, you know, cavitations and 16 all that sort of stuff. It's kind of amazing.
17 All these barriers, all these, you know, 18 proper design of the impeller, a NRC regulatory regime 19 that keeps a plant basically clean and very few 20 operational issues and stuff like that. Those are kind 21 of barriers, safety barriers, and things that the 22 public can see and stuff that gives indications that 23 a plant is safe, not these analysis that we'll never 24 have any proof until a plant gets into really deep 25
20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 trouble. And you can figure out, you know, was the risk 1
perspective analysis, was it accurate and that type of 2
thing.
3 And, again, another issue in the industry 4
is Millstone recently with their troubles with the 5
auxiliary feed pump, turbine-driven feed pump, and the 6
inability of the NRC to make a clean plant, to make sure 7
that the NRC forces a utility to pay attention to the 8
beginning stages of failure with their turbine pump, 9
turbine-driven pump, and to figure out why that 10 happened and then to say, well, do we got these kind 11 of failures any place else, and to have the NRC become 12 intrusive and to figure out these little things that 13 are going around. And if the utility doesn't want to 14 fix it or acknowledge it, then you come down with the 15 hammer and stuff like that; or, in the case of 16 Millstone, you know, the basic themes of broken 17 components and improperly-installed new components 18 nobody really catches, and then the degradation for 19 tube special inspection, inspection reports, and then 20 nobody really catches it until a plant trips and gets 21 into a loss offsite power. And then there's a host of 22 ugly issues that happened in the same transient and 23 stuff like that.
24 I don't think a lot of you guys really 25
21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 understand how difficult that is being in the control 1
room and, you know -- you guys all mostly get to see 2
a lot of this stuff in hindsight. Those guys in the 3
control room get to see those events when equipment 4
fails and they have no idea why it failed and why it's 5
behaving that way. Then they get stuck with procedures 6
that don't work. It's a terrifying situation and 7
unnerving situation in the control room.
8 And we think, you know, with this Palisades 9
deal being ugly and stuff, your inability to enforce 10 integrity and truth-telling -- Palisades is not afraid 11 to lie when they need to or be deceptive to the NRC.
12 That's the history of Palisades and stuff like that, 13 and we think actually that happens a lot throughout the 14 industry.
15 And we worry that what we're seeing in 16 Palisades is similar to what we're seeing in Cooper with 17 their training program, which is terrifying in its own 18 manner. Only two passes out of nine attempted licenses 19 and all the associated problems, the ugliness of the 20 training program and stuff.
21 We think this is all kind of related to, 22 essentially, what our legislators and congressmen, you 23 know, the rules that enable the NRC, they're 24 insufficient and stuff. So Palisades, the Cooper 25
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 plant, Millstone, and San Onofre, Fort Calhoun, and 1
stuff like that. I mean, I was looking at the Swiss 2
cheese model as far as what's it take to cause an 3
accident, and it's, you know, a set of slices of Swiss 4
cheese with holes in it and they're usually all the 5
barriers to an accident. There's no clear hole through 6
the set of slices of cheese, but when the holes line 7
up that's when an accident happens. There's a lot of 8
holey Swiss cheese. The holes and, you know, maybe a 9
slice or two of the holes line up, maybe there's one 10 last barrier left, but we're uncomfortable with 11 actually having any holes in any slice of cheese. We 12 want these guys to operate a lot better than they have.
13 So there you go. You get my opinion of 14 what's wrong with Palisades, and you really don't have 15 any engineering to prove that those pumps won't cause 16 problems. You've still got the active mechanism on 17 there. You used to allow welding of those blades.
18 Now, you say it's [beep] blades that are welded in there 19 anymore. But there's been one assertion after another 20 that that's been proved false and stuff like that.
21 And then the general stated the nuclear 22 industry as a whole and incentives nowadays for a lot 23 of these utilities with their economic troubles to cut 24 back and stuff. You know, our fear is if we seen all 25
23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 that was going on there, we could foresee, and the NRC 1
could behave in a different way. But there's 2
tremendous barriers. A lot of rules are set up, you 3
know, like in this thing here. I can't see all the 4
documents and stuff like that.
5 And if we had all of the knowledge in front 6
of us of what was going on, outsiders could intervene, 7
just like if everybody seen what was going on in 8
Fukushima and the anti-nukes could have that kind of 9
ammunition, maybe that wouldn't have happened. Maybe 10 we could have captured a couple of minds and consciences 11 and not have such an ugly situation facing us in the 12 future.
13 Thank you very much. I appreciate -- by 14 the way, that response to me with this, even though the 15 2.206 failed, I appreciate that response. It was quite 16 thorough, the response to me, and I appreciate you 17 putting it all out on paper and I want to thank you for 18 doing that because at least it's B-well see how the 19 future plays out, if, you know, my concerns were 20 unaddressed and we have another terrible accident in 21 the United States with a reactor. Thank you.
22 MS. LUND: Okay. Thank you. At this 23 time, does the staff here at headquarters have any 24 questions for Mr. Mulligan? Okay, seeing none. What 25
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 about the region?
1 MR. LENNARTZ: No question from Region III 2
in the office.
3 MS. LUND: Okay. Any headquarters people 4
on the phone? Warren, do you have any question?
5 COURT REPORTER: I'm sorry. Who was the 6
gentleman who just spoke?
7 MR. LYON: No, there's no questions.
8 MS. LUND: Who was the person in the region 9
that spoke?
10 MR. LENNARTZ: That was Jay Lennartz.
11 MS. LUND: Okay. Thank you. And this is 12 Louise Lund, by the way. And does the licensee have 13 any questions?
14 MS.
DOTSON:
The licensee has no 15 questions.
16 MS. LUND: Okay. And do we end up with any 17 members of the public on the phone that want to ask any 18 questions? Okay. Hearing none, okay.
19 So, Mr. Mulligan, thank you for taking the 20 time to provide the NRC staff with clarifying 21 information on the petition you've submitted.
22 (Whereupon, the above-entitled matter 23 went off the record at 10:39 a.m.)
24 25
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 1
2 3
4 5
6 7
8 9
10 11 12 13 14 15