ML15181A127

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Transcript of 10 CFR 2.206 Petition Review Board Teleconference with Petitioner, Michael Mulligan, Citizen, 2.206 - Emergency Ultrasonic Inspection Test or Best Available Flaw Detection Technology for USA Reactor Plants Similar to the Thous
ML15181A127
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Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 05/19/2015
From: Stephen Koenick
Plant Licensing Branch IV
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Koenick S
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

10 CFR 2.206 Petition Review Board Teleconference with Petitioner, Michael Mulligan, Citizen, re: 2.206 - Emergency Ultrasonic Inspection Test or Best Available Flaw Detection Technology for USA Reactor Plants Similar to the Thousands of Cracks Discovered in Belgium Nuclear Power Plants.

Docket Number: 50-271 Location: teleconference Date: Tuesday, May 19, 2015 Work Order No.: NRC-1581 Pages 1-32 NEAL R. GROSS AND CO., INC.

Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.

Washington, D.C. 20005 (202) 234-4433

1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

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10 CFR 2.206 PETITION REVIEW BOARD (PRB)

CONFERENCE CALL RE BELGIUM NUCLEAR PLANT VESSEL CRACKS IN USA PLANTS

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TUESDAY, MAY 19, 2015

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The conference call was held, Rob Taylor, Chairperson of the Petition Review Board, presiding.

PETITIONER: MICHAEL MULLIGAN PETITION REVIEW BOARD MEMBERS ROB TAYLOR, Petition Review Board Chairman STEPHEN KOENICK, Petition Manager BOB HARDIES, Senior Technical Advisor MERRILEE BANIC, 2.206 Petition Coordinator PATRICIA JEHLE, Office of the General Counsel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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2 NRC HEADQUARTERS STAFF ROBERT CARPENTER, Office of Enforcement MEENA KHANNA, Branch Chief REGIONAL OFFICE PARTICIPANTS STEPHEN HAMMANN, Region 1 VIJAY MEGHANI, Region 3 JOON PARK, Region 3 REPRESENTATIVES FOR THE LICENSEE PHILIP COUTURE, Entergy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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3 C O N T E N T S Page Welcome and Introductions..........................4 PRB Chair for Introductory Remarks.................7 Petitioner's Presentation.........................11 Staff Questions of Petitioner.....................30 PRB Chair Closing Remarks.........................31 Adjourn...........................................32 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 2:05 p.m.

3 MR. KOENICK: I'd like to thank everyone 4 for attending this meeting. My name is Stephen 5 Koenick. I'm a Project Manager in the Division of 6 Reactor Licensing.

7 And we're here today to allow the 8 Petitioner, Michael Mulligan to address the Petition 9 Review Board regarding his 2.206 Petition dated March 10 25, 2015[sic] submitted by email on March 26, 2015.

11 I'm also the Petitioner Manager for this 12 Petition. And the Petition Review Board Chairman is 13 Robert Taylor.

14 As part of the Petition Review Board's 15 review of this Petition, that can now be found in Adams 16 under accession number ML15090A487. Michael Mulligan 17 has requested this opportunity to address the Petition 18 Review Board.

19 The meeting is scheduled from 2:00 to 3:00 20 p.m. eastern time. The meeting is being recorded by the 21 NRC Operations Center. And will be transcribed by a 22 Court Reporter.

23 The transcript will become a supplement to 24 the Petition. And the Transcript will also be made 25 publicly available.

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5 1 So I'd like to open this up with 2 introductions. I'd like the rest of the Petition 3 Review Board to introduce themselves. What we'll do is 4 we'll go around the room here at Headquarters. And then 5 we'll figure out how to get everybody on the phone.

6 So first, I'd like to turn it over to Rob.

7 CHAIRMAN TAYLOR: Hi, this is Rob Taylor, 8 Chair of the PRB.

9 MR. HARDIES: I'm Bob Hardies, Senior 10 Level Advisor, Office of Nuclear Reactor Regulations, 11 Division of Engineering.

12 MS. BANIC: Lee Banic, 2.206 Petition 13 Coordinator, NRR.

14 MS. JEHLE: Patricia Jehle, Office of the 15 General Counsel.

16 MS. KHANNA: Meena Khanna, Branch Chief in 17 the Division of Operating Reactor Licensing.

18 MR. KOENICK: Excellent. So that's here 19 with us at Headquarters. Can we go through any other 20 NRC participants from Headquarters on the phone?

21 MR. CARPENTER: This is Rob Carpenter, OE.

22 MR. KOENICK: Okay. Any other 23 Headquarters participants?

24 (No response) 25 MR. KOENICK: Hearing none, are there any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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6 1 Regional Office -- participants from Regional Offices?

2 We can start from Region I?

3 MR. HAMMANN: This is Steve Hammann from 4 the Region I, Decommissioning and Technical Support 5 Branch.

6 MR. KOENICK: Okay. Region II? We 7 probably don't have anybody from Region II.

8 (No response) 9 MR. KOENICK: Region III?

10 MR. MEGHANI: This is Vijay Meghani and 11 Joon Park from Region III, Division of Reactor Safety.

12 MR. KOENICK: Excellent. And Region IV, I 13 don't believe we have anyone?

14 (No response) 15 MR. KOENICK: Okay. Are there any 16 representatives for the licensee on the phone?

17 MR. COUTURE: Phil Couture with Entergy.

18 MR. KOENICK: And the Court Reporter is on 19 the line?

20 COURT REPORTER: Yes, Sir. Dylan Stroman 21 with Neal R. Gross Court Reporters.

22 MR. KOENICK: Thank you. Okay. Is there 23 any -- are there any other members on the call that have 24 not been identified? With the exception of our 25 Petitioner? We'll get to you last.

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7 1 (No response) 2 MR. KOENICK: Okay. Hearing none, 3 Michael Mulligan, would you please introduce yourself 4 for the record?

5 MR. MULLIGAN: Hello. I'm Michael 6 Mulligan. I live in Hinsdale, New Hampshire. I'm a 7 whistle blower. I worked at a nuclear plant, for 8 Vermont Yankee for ten years or so.

9 I was in the Navy on a submarine, on a 10 nuclear submarine. And that's it.

11 MR. KOENICK: Okay. Thank you. I'd like 12 to emphasize that we need to speak clearly and loudly 13 to make sure that the Court Reporter can accurately 14 transcribe this meeting.

15 If you do have something that you would like 16 to say, please first state your name for the record.

17 And for those dialing into the meeting, please remember 18 to mute your phones to minimize any background noise or 19 distractions.

20 At this time I'd like to turn it over to the 21 PRB Chairman, Robert Taylor.

22 CHAIRMAN TAYLOR: Thanks, Steve. This is 23 Rob Taylor from the Deputy Director of NRR's Division 24 of Safety Systems. And I'll be serving as the PRB 25 Chairman for Mr. Mulligan's Petition that we're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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8 1 discussing today.

2 Mr. Mulligan, thank you for submitting your 3 Petition. I think you're familiar with the process.

4 But there are some aspects that I do want to go through 5 at the beginning here before we get into your discussion 6 and presentation.

7 Just for some background on the process.

8 Section 2.206 of Title 10 of the Code of Federal 9 Regulations describes the Petition process. The 10 primary mechanism for the public to request enforcement 11 action by the NRC in a public process.

12 This process permits anyone to petition NRC 13 to take enforcement type action related to NRC licensees 14 or licensed activity. Depending on the results of this 15 evaluation, NRC could modify, suspend or revoke an NRC 16 issued license or take any other appropriate 17 enforcement action to resolve the problem.

18 The NRC staff guidance for this position of 19 2.206 Petition Request is in management directive 8.11, 20 which is publically available.

21 The purpose of today's meeting is to give 22 the Petitioner, Mr. Mulligan, an opportunity to provide 23 any additional explanation or support for the Petition 24 before the Petition Review Board's initial 25 consideration and recommendation.

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9 1 I want to be clear that this meeting is not 2 a hearing. Nor is it an opportunity for the Petitioner 3 to either question or examine the PRB on the merits of 4 the issues presented in the Petition Request.

5 No decisions regarding the merits of this 6 Petition will be made at this meeting. Following this 7 meeting the Petition Review Board will conduct its 8 internal deliberations. The outcome of this internal 9 meeting will be discussed with the Petitioner.

10 The Petition Review Board typically 11 consists of a Chairman, myself, usually a manager at the 12 senior executive service level at the NRC. It has a 13 Petitioner Manager and a PRB coordinator, who have 14 introduced themselves during the opening of this 15 meeting.

16 Other members of the Board are determined 17 by the NRC staff based on the content of the information 18 in the Petition Request. The members have already gone 19 around and introduced themselves, including the subject 20 matter experts that will weigh in or evaluate Mr.

21 Mulligan's Petition.

22 As described in our process, the NRC staff 23 may ask clarifying questions in order to better 24 understand the Petitioner's presentation and to reach 25 a reasoned decision whether to accept or reject the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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10 1 Petitioner's request for review under the 2.206 2 process.

3 I'd like to summarize the scope of the 4 Petition under consideration and the NRC activities to 5 date. On March 26, 2015, Mr. Mulligan submitted to the 6 NRC, a Petition under 2.206 regarding Kewaunee Nuclear 7 Power Plant and Vermont Yankee Nuclear Plant. And the 8 operating U.S. Nuclear Plants in which he requested a 9 number of actions.

10 The major ones are as follows. He 11 requested immediate full scale ultrasonic inspections 12 similar or with better technology on Vermont Yankee and 13 Kewaunee. He requested large bore hole samples be cut 14 out of both vessels and transport the vessel specimens 15 to a respected metallurgical laboratory for 16 comprehensive offsite testing.

17 He requested an immediate NRC report and 18 public meeting on the vulnerabilities with U.S. reactor 19 cracking and these weakened vessels. He requested all 20 U.S. plants be ultrasonically tested within six months 21 if distressed and unsafe results are discovered.

22 Now, let me take a moment to discuss the NRC 23 activities to date. On May 4 of this year, the 24 Petitioner Manager contacted you to discuss the 10 CFR 25 2.206 process. And to offer you an opportunity to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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11 1 address the PRB.

2 Mr. Mulligan requested to address the PRB 3 by phone prior to its internal meeting to make the 4 initial recommendation to accept or reject the Petition 5 or review it.

6 On May 13 of this year, the Petition Manager 7 arranged a courtesy call with the NRC technical expert, 8 Robert (Bob) Hardies to discuss the Petition. The call 9 between Mr. Mulligan, Mr. Hardies and the Petitioner 10 Manager took place last week.

11 As a reminder for the phone participants, 12 please identify yourself if you make any remarks. As 13 this will help us in preparation of the meeting 14 transcript that will be made publically available.

15 Thank you.

16 Mr. Mulligan, with that, I'd like to turn 17 it over to you, to allow you an opportunity to provide 18 information you believe the PRB should consider as part 19 of this position. We've allocated 40 minutes for your 20 presentation.

21 MR. MULLIGAN: I'm Mike Mulligan. Thank 22 you very much for this opportunity. I generally know 23 that I'm very lucky to be living in the United States 24 of America.

25 I know that if this was -- I mean, if I had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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12 1 this concern in another country, say Russia or China or 2 something like that, you know, they'd probably find me 3 on the side of the road dead.

4 So, I know that we live in the greatest 5 nation on the planet. And I'm thankful to be living 6 here. I thank the NRC for this opportunity.

7 I really thank them for talking -- for 8 allowing me to talk with Mr. Hardies. He was a -- he 9 just -- he was extraordinary as far as his abilities.

10 As far as you talked about, as far as for 11 Vermont Yankee and Kewaunee, I essentially wanted 12 either ultrasonic testing or the best technology or 13 similar to what they did over in Belgium or over in 14 Europe and stuff like that. So, I don't know if I said 15 that right in the way you just got done talking about 16 it.

17 We know with any crack in the vessel, none 18 have been discovered so far in that. In the worst case, 19 if a crack happened and it was large enough, and it would 20 basically bypass a lot of designs of the facility.

21 And so it would be a particularly nasty 22 accident. The most likely result would be a small leak 23 or -- but you never know. And the systems will be able 24 to handle it.

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13 1 then the worst case. Because it would bring terrible 2 repercussions to the nuclear industry.

3 Even if we -- even if, you know, we went 4 through this and we did a lot of investigations on the 5 vessels we're testing, even finding a core crack would 6 be pretty dramatic as far as what it would do to the 7 industry.

8 As far, you know, if you -- generally, most 9 of the vessels have been immune to inspections. I know 10 they do ten year inspections on, thanks to Mr. Hardies, 11 on the weld areas and that type of stuff.

12 But it would be terrible repercussions.

13 Because it would, you know, question the NRC. It would 14 question the utilities. You know, how come, you know, 15 how come the reactor vessels weren't fully inspected and 16 have ultrasonic testing or better.

17 It's interesting, the Belgium nuclear 18 regulator, the FANC, the Federal Agency for Nuclear 19 Control, here's a quote. This is how they discovered 20 it. In 1912 -- in 2012, a new type of in-surfaced ISI 21 inspection of the reactor vessel by ultrasonic testing 22 was introduced in the Belgium nuclear plants.

23 These inspections were introduced in 24 France in order -- and to search for underclad cracks 25 that may be presented in the base metal directly below NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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14 1 the interface to the cladding. These underclad cracks 2 if present, have particular orientations at a surface 3 and were created by the welding process of the 4 austenitic strip cladding and to the ferric base metal.

5 The underclad is like, I imagine is, it's 6 like our cladding in our domestic vessels that are 7 inside the -- that are on the outside -- inside the --

8 on the surface of inside the vessel.

9 So, I -- in talking with Mr. Hardies, we 10 talked about taking samples of some shutdown reactor 11 vessels similar to the Belgium reactors. And I know 12 what Mr. Hardies wants for Christmas next year. And 13 that there would be samples taken from an assortment of 14 reactor vessels.

15 That would be to cut out a piece of the 16 reactor vessel. And then bring it into a laboratory and 17 to, you know, to go wild with the testing and stuff like 18 that.

19 And as far as my understanding that would 20 be a wonderful idea as far as the verified and knowledge 21 that we have. And as far as what happens, what a reactor 22 vessel during its life.

23 And it would help us, you know, to do a lot 24 of testing that might discover some other flaws in the 25 reactor. And just like with the Belgium reactors, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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15 1 know, they went on a journey looking for one type of flaw 2 and they discovered a completely different flaw.

3 One thing should be noted, is that they had 4 a discover -- they had to institute a special kind of 5 ultrasonic test. It sounds like it was more sensitive 6 then normal.

7 And then as this thing went on, they decided 8 that they even need a more sensitive type of ultrasonic 9 test. And I think there's a lot of limitations with 10 ultrasonic tests.

11 You should get it in -- if you could get some 12 of these, you know, these specimens into the -- into a 13 laboratory, you know, you could be -- you could have more 14 confidence that this type of accident would never happen 15 in the United States fleet.

16 AREVA recently had troubles -- well, 17 basically, it's my -- I've become educated with this 18 kind of problem. And I made a set of poor assumptions 19 whenever I started this.

20 But today it's generally, it's a forging 21 issue. And either did a state of the art type of thing.

22 They didn't think about it or there was a shortcoming.

23 And forging -- and during the forging process, water was 24 inside the forging as they were pouring it. And as it 25 was cooling down.

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16 1 And in this process, hydrogen was released 2 from the water. And it's this hydrogen business that's 3 causing hydrogen flaking, as far as I think, was going 4 on.

5 But I'm no expert. I do have a little 6 better understanding of what's going on here. And 7 there's uncertainty. You know, like there's 8 uncertainty if we can see everything in the vessel as 9 it sits right now.

10 Especially when we don't do a lot of 11 testing. We only test a small part of the vessel. And 12 there is uncertainty with the forging process. And 13 there's even uncertainty with the forging today, what's 14 going on. Which is really astounding.

15 With AREVA, they had lower then their 16 expected mechanical toughness properties. In other 17 words, it's weaker and probably it would -- cracks would 18 proliferate more easily.

19 It revolves generally around high carbon 20 contact. It's a -- that's what's the mechanism that 21 makes the metal weaker. And it is a simple forging 22 problem that everybody's astonished that they didn't 23 detect.

24 And you notice that. And even with all the 25 -- even if there is no radiation on it in the vessel or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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17 1 because the vessels are quite radioactive. AREVA still 2 didn't discover the flaws until much like they even got 3 one and the reactor plant just, you know, almost it's 4 all buttoned up and stuff. And they're going to have 5 to take it apart, take it out or something.

6 And so there you go again. Some of this 7 stuff is hard to detect. And there's uncertainty of the 8 bureaucracy. Are they capable of discovering these 9 things? It's like I said, that accented so bad. You 10 know, you can imagine if they -- or could be so bad.

11 You could imagine if it was, like I said, 12 a small crack was discovered and the repercussions would 13 be so dock and dire. You know, that would be hard to 14 stay to yourself. We've got to disclose this.

15 There would be a lot of pressure to not 16 disclose things. You know, maybe you get -- the higher 17 ups might not know about it. But the lower guys would 18 sit there and say holy smokes, you know, maybe the best 19 thing to do is keep this quiet.

20 Mr. Hardies is a Chief of Component 21 Integrity Branch of the Division of Engineering in the 22 Office of Nuclear Regulatory Research. He gave me a 23 pretty neat phrase. He said, you never know what is 24 discussed be -- you never know what is discussed 25 privately between the licensee and a regulator.

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18 1 He was talking about the Belgium guys. And 2 all I know is it was an interesting comment.

3 What is most interesting to me is the 4 Belgium regulator, they, you know, they went back and 5 then said they've got to do some more testing. They 6 tested hydrogen flakes in a test reactor.

7 And they put a lot -- put these pieces of 8 metal in a heavy radiation field. And the preliminary 9 results, the material properties, fracture test 10 toughness, is more strongly affected by radiation then 11 predicted in theoretical models.

12 And that, you know, I've talked to a few 13 people. And they basically say we -- between us and the 14 Europeans, we all generally got only a few of these 15 companies that do these kind of testings, contractors 16 or whatever have you.

17 And they're generally more alike then not 18 alike. And that type of thing. And they're all 19 intermixed and the information is kind of shared between 20 them and all that sort of stuff.

21 So, you know, we're -- like I said, we're 22 more alike then not. And so, you know, and so to have 23 -- the big thing is this testing of this metallic flake, 24 you know, is raising questions of their modeling of the 25 metal and how it responds.

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19 1 And that's a, you know, that's a -- the 2 regulators are usually looking for proof. You know, 3 everything they do is they look for proof. And they, 4 you know, they want everybody to have evidence and all 5 that sort of stuff.

6 And I think the harder things a lot of 7 times, because there's nothing there. And so a lot of 8 times it only really revolves around what's in your 9 head. And that is the idea of what are the 10 uncertainties associated with say the reactor vessel?

11 And that's the things that, you know, you 12 can't prove. And that is very worrisome. So, and you 13 know, I think the United States of America, you know, 14 the greater public would say, you know, we don't want 15 to push on the reactor vessel inspected or tested.

16 We want the vessel tested with the best 17 technology available. We're the greatest nation on the 18 planet. And we understand that it's probably an action 19 that's very infrequent. But if you had one, there would 20 be a tremendous amount of consequences to it.

21 And so I think the public would say, we want 22 to know the absolute current best technology type of 23 condition that the reactor vessels are in now. And we 24 want proof that, you know, that this terrible event 25 wouldn't occur.

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20 1 So like I said, I was told that, you know, 2 the ultrasonic testing on the welds happen every ten 3 years. It's from the insides and that. And the most 4 worrisome aspect about that is that Mr. Hardies told me 5 that there was never any flaw discovered in it.

6 And we look around and now once I talked 7 about the reactor heads, you know, once those were 8 considered a perfect barrier. And there was a lot of 9 margin of safety there. And the fact that barrier 10 should not -- should not, you know, there's no evidence 11 that the reactor heads could have a flaw in it.

12 Of course, now we know. Even as the 13 evidence and leaks were building up, the Agency and the 14 FirstEnergy failed to prevent that kind of an accident.

15 And stuff and we know that most of the Agency and 16 FirstEnergy had terribly flawed bureaucracies.

17 And I think if we could have seen a lot of 18 that, you know, if it was disclosed to the outsiders, 19 you know, and people would have rebelled. And we would 20 have fixed you. If we could see the flaw, the 21 bureaucratic flaws in both the agency and the utility 22 and stuff.

23 And so that was a -- that was one of the 24 lessons learned, is how much we don't know about what 25 these bureaucracies do behind our backs and stuff. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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21 1 so, the reactor heads, we know that have flaws.

2 And we know a lot of different nozzles and 3 piping right next to the reactor have a -- they 4 discovered flaws in it or cracks in it and they dig them 5 out -- dig out the flaw and reweld it and stuff like that.

6 What is surprising is that in all this 7 testing in all these reactors, they never found one flaw 8 in it, in the weld area and stuff. It just doesn't make 9 sense. To me it doesn't.

10 And you know, they might have found a couple 11 of flaws that were there, you know kind of, or a couple 12 of indications that looked like a flaw. And then go in 13 there and did we report about it? We thought there was 14 a flaw in the core.

15 We discovered a flaw and we fixed it and all 16 that sort of stuff. But to never discover a flaw in the 17 welding -- in the components that were welded together 18 of a vessel is kind of a -- doesn't -- it's nonsensical 19 to me if you really want to know.

20 And the implications are that, you know, 21 you're not using the best technology and the most 22 sensitive technology available. And like I said, you 23 know, with the Belgium guys, they went in hunting for 24 one thing with sensitive gear. And that's how they 25 discovered the metallic flakes.

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22 1 So that kind of raises -- then they jacked 2 it up again. And you know, they found tens and 3 thousands of them and stuff. So, that just -- there's 4 a question of whether we're using the right sensitivity 5 for detecting these flaws.

6 You know, there's questions if we're 7 looking -- not looking at the whole vessel also. I 8 think, I don't know. You know, maybe when it was new, 9 it was -- we couldn't -- we, you know, we used the best 10 technology to look for flaws in these vessels.

11 And you know, and then decided, you know, 12 and then we're all busy with new construction and all 13 that sort of stuff. And we just couldn't conceive of 14 the ideas that these vessels could develop a flaw later 15 in life.

16 I know you have coupon testing. And I know 17 you have a lot of secondary I'd call it of theoretical 18 models of what radiation does to these vessels and stuff 19 like that. You have a lot of that.

20 But that's not -- that's not -- that's, you 21 know, that's that better theoretical stuff that I talked 22 about that is placed in question. Are your models all 23 accurate and stuff.

24 And I think there's a lot of uncertainty 25 there to be truthful. And I think, you know, the United NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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23 1 States deserves to have proof with the best technology 2 available that these vessels are safe.

3 You know, like I said, maybe if we go in and 4 take the worst case PWR and take a couple of samples out 5 of there. Do a couple of ultrasonic tests of a dead 6 vessel and stuff, then you have like a, you know, you 7 would have a more sense of what might be going on there.

8 And then of course if you did find flaws in 9 the vessel, then you'd have to, you know, just like 10 jacking it up as far as going to all the rest of the 11 plants and demanding that they do similar kind of 12 testing. That would be the kind of things that I am --

13 I'm asking for in this.

14 It's been noted, this is sound -- this is 15 going to sound like, you know, not another issue. But 16 the flipping the Palisades primary cooling pump power 17 went out. One official told me that, you know, that 18 basically these components sit in the bottom of the 19 core.

20 That the blades break off and they found one 21 between the core shroud and stuck in the core. And then 22 there was a lot of other parts in different areas.

23 There was Salem 2 was the same problem.

24 But one official told me, NRC official said 25 -- basically implied that these guys sit in the bottom NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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24 1 of the thing and they stay there the whole cycle.

2 And I had a recent -- a different official 3 tell me that oh no, those, there's a lot of flow in --

4 and now I'm paraphrasing, there's a lot of flow inside 5 these vessel -- the bottom of the core. And these 6 things are banging around.

7 And we just discovered cladding damage 8 caused by components being in the bottom of the vessel 9 and stuff. And you hear, you know, there's never no 10 pictures of what kind of cladding damage there was.

11 And again, you know, I worry about the 12 missing cladding. And what the vessel metal behind it, 13 you know, would do in a reactor vessel.

14 I know that there is oxygen. Somebody said 15 that there might be oxygen -- there was oxygen missing 16 in the vessel. But on the other hand, I know that oxygen 17 gets disassociated in water and a radiation field and 18 there is oxygen in there.

19 And I know that oxygen sometimes collects 20 up at the top of patrol light mechanisms in the housing.

21 And that causes hydrogen and oxygen and causes all sorts 22 of corrosion problems. And well, at least it did on one 23 plant. I don't know, I can't say for certainty if they 24 did.

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25 1 me just -- I'm talking about this. Mr. Hardies sent me 2 this, the metallurgical sent me this document.

3 metallurgical -- metallurgical, what am I talking 4 about?

5 Nope, I was going to give it to him or --

6 well, anyways, the metallurgical aspects influence had 7 a potential for hydrogen flakes and forging for reactor 8 pressure components. You know, in the Belgium, seeing 9 all of their dockets, I never seen any blackouts or 10 security or hidden information.

11 So, you know, I count -- so this document 12 is filled with blacked out pieces, information missing.

13 That you know, either is privacy issues or I don't know 14 what, you know, security issues.

15 And so, you know, there's 16 huge chunks of 16 this document missing information because the NRC 17 refuses to release it. One of the most interesting 18 pieces of blacked out or redacted information is, you 19 know, the -- at the bottom of this document, there's the 20 references. And three of the references are blacked 21 out.

22 I mean, it's just, you know, the labels or 23 the headings or the titles of the documents are too 24 classified. Or, you know, might give secrets away or 25 something.

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26 1 I mean, it's just ridiculous. So this goes 2 to kind of like what I'm saying about bureaucracies.

3 You never know what they -- you never know the reasons 4 why they're hiding things.

5 They say they might have one reason. And 6 all that sort of stuff. But there's never -- there is 7 not an independent outside person or an organization 8 looking and say for the NRC, is this legitimate that all 9 this information is missing and stuff?

10 Or should the public, you know, it might be 11 private information or competitive information. But 12 there's countervailing public interests in releasing 13 this information. And that is, you know, like I said, 14 would be to have an outsider have, maybe have the power 15 to, you know, straighten out our bureaucracy like 16 Davis-Besse or the situation in that incident there and 17 stuff.

18 And so we would never have a Davis-Besse 19 accident and stuff. So we debate these issues and fully 20 as the problem is developing. And you know, because 21 everybody afterwards, Davis-Besse said, you know, we 22 all had flaws. We had terrible flaws. And letting 23 this plant, you know, run away from us and stuff.

24 And you know, part of that would be that you 25 disclose all your flaws and you let the outsiders help NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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27 1 you -- help you -- and it would probably be painful. But 2 it would help you clean up your bureaucracies.

3 And you know, that's always been my hope 4 that we'd have a strong industry and a strong NRC.

5 Where a lot of this stuff, this nonsense doesn't emerge 6 and is corrected before it happens.

7 And so there would be less negative 8 information out there that people use. And well, use 9 in a wrong way. So, you know, it seems to be, to me I've 10 seen a lot of the incidences that I've read about, 11 inability to anticipate cracks and corrosions.

12 I wish, you know, as far as taking them 13 samples, I wish the Agency would get, you know, move 14 heaven and earth as far as getting these samples from 15 some of these reactor vessels.

16 And I know that there's a radiation versus 17 an altruism or doing good type of conflict here and 18 stuff. But, you know, I don't know, is that an excuse 19 not to do it?

20 I know -- I can't think of -- Yankee Atomic 21 over in -- when they were shutting down and their 22 controversy after they were shut down. And that was the 23 question, what are you going to do with the core?

24 And the idea of taking samples of the core 25 came up. And basically, they said that there was more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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28 1 -- they were afraid of more negative information to the 2 industry then that might do finding information that 3 would be positive information.

4 In other words, they thought it was a risk 5 releasing -- doing any samples on their reactor vessel.

6 They thought it was a public relations risk and stuff.

7 Instead of, you know, saying, you know, we want the 8 honest truth.

9 We want all fundamental aspects of what 10 we're going out there in front of us. We want nothing 11 hidden. We want to see it all and then, you know, we 12 trust people to make the right decisions and stuff like 13 that.

14 It's only certain segments of a bureaucracy 15 decide on their own that hey, this is not good. I'm 16 going to hide this information and the rest of the 17 bureaucracy doesn't see that. That's when we lose 18 faith in the institution and all that sort of stuff.

19 So, like I said, the specimens are 20 important. I'd like to, as far as to get some of the 21 most vulnerable plants. I know there's 31 that have 22 these forgings as Belgium. I think, or is it 61? In 23 that document.

24 And so, there's a vulnerability of these 25 having these metallic flakes in the United States fleet.

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29 1 And so, that specimen, collect a specimen and a quick 2 ultrasonic test of one of these dead vessels to make --

3 too just, you know with a high ability to detect flaws.

4 Probably much higher then we're currently 5 doing now. Similar to the Belgium regulatory agency.

6 And if we get nervous finding flaws, then I'd like to, 7 you know, I think that proper thing to do is start 8 testing vulnerable reactors on a, you know, within six 9 months type of thing.

10 Again, I'd like to thank you for attending 11 this opportunity to speak. Thank you. I'm all done.

12 CHAIRMAN TAYLOR: Mr. Mulligan, this is 13 Rob Taylor. Thank you for taking the time and providing 14 those additional perspectives and thoughts for our 15 consideration.

16 So at this time what I want to do is ask if 17 there are any questions from staff here at Headquarters 18 or our office enforcement representative who's on the 19 phone, for Mr. Mulligan?

20 MR. CARPENTER: Yes, this is Rob 21 Carpenter. I was going to say -- this is Rob Carpenter.

22 I don't have any comments. But thanks Mr. Mulligan.

23 MR. MULLIGAN: Thank you. Thank you for 24 being here.

25 CHAIRMAN TAYLOR: Let me ask now, if the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

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30 1 representatives from Region I and Region III have any 2 questions for Mr. Mulligan?

3 MR. HAMMANN: No questions from Region I.

4 MR. MEGHANI: No questions from Region 5 III.

6 CHAIRMAN TAYLOR: Thank you, Regions.

7 Lastly, I would like to ask if the Licensee 8 representative has any questions for Mr. Mulligan?

9 MR. CARPENTER: No questions.

10 CHAIRMAN TAYLOR: Thank you. With that, 11 Mr. Mulligan, the NRC would like to express its 12 appreciation for you taking the time to engage in the 13 2.206 process. And for taking the time today to provide 14 additional perspective and clarification on your 15 Petition.

16 We will move forward with our process and 17 evaluating your Petition to determine whether we need 18 to take any action.

19 With that I would like to ask the Court 20 Reporter if there is any additional information that you 21 need for the transcript?

22 COURT REPORTER: Yes. I was actually 23 wondering if I could get some spellings for a few of the 24 names of the participants on the call?

25 CHAIRMAN TAYLOR: Of course.

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31 1 COURT REPORTER: First, is it Ms. Khanna or 2 Connley? The Branch Chief of Operating Rental Agency?

3 Could you possibly spell your name?

4 MS. KHANNA: I'll provide you, but we can 5 do this offline if you'd like. I think we'll be happy 6 to get in touch with you if you'd like to do that.

7 CHAIRMAN TAYLOR: Is that acceptable?

8 We'll get you the spellings of all the participants.

9 COURT REPORTER: Oh, yes. That would be 10 very helpful.

11 CHAIRMAN TAYLOR: Okay.

12 COURT REPORTER: Aside from that, I only 13 had one question that was a technical term. Was it 14 potting damage or clotting damage?

15 CHAIRMAN TAYLOR: Cladding.

16 COURT REPORTER: Cladding damage. All 17 right, great. Okay, that was the only question aside 18 from the participants' names spellings.

19 CHAIRMAN TAYLOR: Okay. Well, we'll 20 reach out offline to get you those spellings.

21 COURT REPORTER: Excellent. Thank you.

22 CHAIRMAN TAYLOR: Thank you for your time 23 today. So with that, I'd like --

24 MR. MULLIGAN: Thank you.

25 CHAIRMAN TAYLOR: I'm sorry?

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32 1 MR. MULLIGAN: Thank you.

2 CHAIRMAN TAYLOR: All right. Thank you, 3 Mr. Mulligan. And we're going to conclude the meeting 4 now. Take care.

5 (Whereupon, the above-entitled matter went 6 off the record at 2:48 p.m.)

7 8

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