ML11242A014

G20110365/EDATS: OEDO-2011-0357 - Transcript of 10 CFR 2.206 Petition Re St. Lucie, July 7, 2011, Pages 1-38

ML11242A014
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Site:	Saint Lucie
Issue date:	07/07/2011
From:	NRC/OCM
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References
2.206, G20110365, OEDO-2011-0357, NRC-1014
Download: ML11242A014 (39)

Text

Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION

Title:

10 CFR 2.206 Petition RE St. Lucie Docket Number: (n/a)

Location:

(teleconference)

Date:

Thursday, July 7, 2011 Work Order No.:

NRC-1014 Pages 1-38 NEAL R. GROSS AND CO., INC.

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

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

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 1

UNITED STATES OF AMERICA 1

NUCLEAR REGULATORY COMMISSION 2

+ + + + +

3 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 4 CONFERENCE CALL 5

RE 6

ST. LUCIE PLANT 7

+ + + + +

8 THURSDAY 9

JULY 7, 2011 10

+ + + + +

11 The conference call was held, Sam Lee 12 Chairperson of the Petition Review Board, presiding.

13 14 PETITIONER: THOMAS SAPORITO 15 16 PETITION REVIEW BOARD MEMBERS 17 SAMSON LEE, Deputy Division Director, Division of Risk 18 Assessment, NRR 19 MARILEE BANIC, PRB Coordinator, NRR 20 TRACY ORF, Project Manager for St. Lucie Plant, NRR 21 22 23 24 NRC HEADQUARTERS STAFF 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 2

DOUG BROADDUS, Branch Chief, NRR 1

GERALD PURCIARELLO, Balance-of-Plant Branch, NRR 2

DAN RICH, Branch Chief 3

STEVEN ROSE, Senior Project Engineer 4

MARCIA SIMON, Office of General Counsel 5

6 ON BEHALF OF THE LICENSEE 7

STEVEN HAMRICK, Florida Power and Light 8

ERIC KATZMAN, Florida Power and Light 9

10 11 12 13 14 15 16 17 18 19 20 21 22 23

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 3

P R O C E E D I N G S 1

2:30 p.m.

2 MR. ORF: I would like to thank everybody 3

for attending this meeting. My name is Tracy Orf, and 4

I'm the St. Lucie Project Manager. We are here today 5

to allow the petitioner, Thomas Saporito, to address 6

the Petition Review Board regarding the 10 CFR 2.206 7

petition dated May 12, 2011. I am the Petition 8

Manager for the petition, and the Petition Review 9

Board Chairman is Sam Lee.

10 As part of the Petition Review Board's, or 11 PRB's review of this petition, Thomas Saporito has 12 requested this opportunity to address the PRB. This 13 meeting is scheduled from 2:30 to 3:30 p.m. Eastern 14 Time. The meeting is being recorded by the NRC 15 Operations Center, and will be transcribed by a court 16 reporter. The transcript will become a supplement to 17 the petition. The transcript will also be made 18 publicly available.

19 I'd like to open this meeting with 20 introductions, and as we go around the room, please be 21 sure to clearly state your name, your position, and 22 the office that you work for within the NRC for the 23 record. I'll start it off; my name is Tracy Orf, I'm 24 the Project Manager for St. Lucie in the Office of 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 4

Nuclear Reactor Regulations.

1 MR. PURCIARELLO: Jerry Purciarello, in 2

the Balance-of-Plant Branch in NRR.

3 MS. SIMON: Marcia Simon, from the Office 4

of General Counsel.

5 MR. LEE: Samsom Lee, I'm the Deputy 6

Division Director, Division of Risk Assessment, NRR.

7 MS. BANIC: Lee Banic, back up Petition 8

Coordinator, NRR.

9 MR. BROADDUS: Doug Broaddus, Branch Chief 10 in NRR.

11 MR.

ORF:

Okay, we've completed 12 introductions at the NRC Headquarters. At this time, 13 are there any NRC participants from Headquarters on 14 the phone? Are there any NRC participants from the 15 Regional Office on the phone?

16 MR. ROSE: Yes, this is Steven Rose, I'm 17 the Senior Project Engineer for the Southern Nuclear 18 Company sites, and I was the Lead Inspector for the 19 Component Design Basis Inspection at St. Lucie.

20 MR. RICH: And I'm Dan Rich, Branch Chief 21 for the Florida sites.

22 MR. ORF: Are there any representatives 23 for the licensee on the phone?

24 MR. HAMRICK: Yes, this is Steven Hamrick 25

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with Florida Power and Light.

1 MR. KATZMAN: And this is Eric Katzman 2

from Florida Power and Light.

3 MR. ORF: Okay. Mr. Saporito, would you 4

please introduce yourself for the record?

5 MR. SAPORITO: Yes, my name is Thomas 6

Saporito, I'm the Senior Consulting Associates with 7

Saprodani Associates in Jupiter, Florida; I'm the 8

petitioner in this proceeding.

9 MR. ORF: Okay, it is not required for 10 members of the public to introduce themselves for this 11 call; however, if there are any members of the public 12 on the phone who wish to do so at this time, please 13 state your name for the record. I'd like to emphasize 14 that we each need to speak clearly and loudly to 15 ensure the court reporter can accurately transcribe 16 this meeting. If you do have something that you would 17 like to say, please first state your name for the 18 record. For those dialing into the meeting, please 19 remember to mute your phones to minimize any 20 background noise or distractions. If you do not have 21 a mute button, this can be done by pressing the keys 22 star, six. To un-mute, press the star, six keys 23 again. Thank you. At this time, I'll turn it over to 24 the PRB Chairman, Samson Lee.

25

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MR. LEE: Good afternoon. Welcome to this 1

teleconference, regarding the 2.206 petition submitted 2

by Mr. Saporito. I would like to first share some 3

background on our process. Section 2.206 of Title 10 4

of the Code of Federal Regulations describes the 5

petition process--the primary mechanism for the public 6

to request enforcement actions by the NRC in a public 7

process. This process permits anyone to petition NRC 8

to take enforcement-type action related to NRC 9

licensees or licensed activities. Depending on the 10 results of its evaluation, NRC could modify, suspend 11 or revoke an NRC-issued license or take any other 12 appropriate enforcement action to resolve a problem.

13 The NRC staff's guidance for the disposition of 2.206 14 petition requests is in Management Directive 8.11, 15 which is publicly available.

16 The purpose of today's teleconference is 17 to give the petitioner an opportunity to provide any 18 additional explanation or support for the petition 19 before the Petition Review Board's initial 20 consideration and recommendation. This teleconference 21 is not a hearing, nor is it an opportunity for the 22 petitioner to question or examine the PRB on the 23 merits or the issues presented in the petition 24 request. No decisions regarding the merits of this 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 7

petition will be made at this teleconference.

1 Following this teleconference, the Petition Review 2

Board will conduct its initial deliberations. The 3

outcome of this internal meeting will be discussed 4

with the petitioner.

5 The Petition Review Board typically 6

consists of a Chairman, usually a manager at the 7

senior executive service level at NRC. It has a 8

Petition Manager and a PRB Coordinator. Other members 9

of the Board are determined by the NRC staff based on 10 the content of the information in the petition 11 request. At this time, I would like to introduce the 12 Petition Review Board. I'm Sam Lee, the Petition 13 Review Board Chairman. Tracy Orf is the Petition 14 Manager for the petition under discussion today. Lee 15 Banic is filling in as the office PRB Coordinator, and 16 our technical staff includes Jerry Purciarello from 17 the Office of Nuclear Reactor Regulation's Balance-of-18 Plant Branch; Steven Rose from NRC's Region II 19 Division of Reactor Projects.

20 As described in our process, the NRC staff 21 may ask clarifying questions in order to better 22 understand the petitioner's presentation and to reach 23 a reasoned decision whether to accept or reject the 24 petitioner's request for review under the 2.206 25

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process. I would like to summarize the scope of the 1

petition under consideration, and the NRC activities 2

to date.

3 On May 12, 2011, Mr. Saporito submitted to 4

the NRC a petition under 2.206 regarding the St. Lucie 5

Plant. In this petition request, Mr. Saporito's area 6

of concern was with the design of the component 7

cooling water system at St. Lucie Plant, Units 1 and 8

2. Mr. Saporito requests that the NRC suspend or 9

revoke the NRC licenses granted to the licensee for 10 operation of the St. Lucie Plant, Units 1 and 2; issue 11 a notice of violation with a proposed civil penalty 12 against the licensee; and order the immediate shutdown 13 of St. Lucie Plant, Units 1 and 2.

14 Please allow me to discuss the NRC 15 activities to date. On May 25, the Petition Manager 16 contacted you to discuss the 10 CFR 2.206 process and 17 to offer the opportunity to address the PRB by phone 18 or in person. You requested to address the PRB by 19 phone prior to its internal meeting to make the 20 initial recommendation to accept or reject the 21 petition for review. Because you requested the 22 immediate shutdown of the St. Lucie plant, the PRB met 23 on June 2 to discuss those actions to determine if 24 immediate actions were required. The PRB denied the 25

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request for immediate action because there was no 1

immediate safety concerns to the plant and to the 2

health and safety of the public. The Petition Manager 3

informed you of this decision on June 8.

4 As a reminder for the phone participants, 5

please identify yourself if you make any remarks, as 6

this will help us in the preparation of the meeting 7

transcript that will be made publicly available.

8 Thank you. Mr. Saporito, I will turn it over to you 9

now to allow you to provide what you believe the PRB 10 should consider as part of this petition.

11 MR. SAPORITO: All right. Thank you, 12 Chairman, and good afternoon to everyone. Again, my 13 name is Thomas Saporito, I'm a Senior Consulting 14 Associate with Saprodani Associates in

Jupiter, 15 Florida, and we're the petitioner in this proceeding 16 today, and we maintain a website at saprodani-17 associates.com; there's a hyphen between those two 18 words. Before I get into the substance of these 19 issues today, I would like to first correct this 20 public record. The NRC has several times this 21 afternoon stated on this record that the petition 22 filed in this matter was dated May 12, 2011. The fact 23 of the matter is the petition was filed on April 3, 24 2011. So let the record be corrected in that respect; 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 10 that brings a concern to me of exactly which documents 1

the NRC Petition Review Board has reviewed in these 2

circumstances, in the fact that they have the wrong 3

dated document.

4 Anyway, continuing on, I have several 5

years' experience working in the nuclear industry, and 6

I've been following the actions of the NRC over the 7

better part of 22 years; in fact, I was actually an 8

employee of the Florida Power and Light Company, St.

9 Lucie Nuclear Power Plant. I worked with both units, 10 but I was actively involved in the start up on Unit 2.

11 So I am pretty familiar with the overall plant and its 12 operation.

13 Alright. So, on April 3, 2011, an 14 enforcement petition was filed with the U.S. Nuclear 15 Regulatory Commission, or NRC, requesting that the 16 Agency take escalated enforcement action against the 17 Florida Power and Light Company, or FP&L, St. Lucie 18 Nuclear Plant, in connection with a very serious 19 safety violation that occurred at the nuclear plant, 20 resulting in a notice of violation and a yellow 21 finding by the NRC against FPL on April 19, 2010. The 22 yellow finding by the NRC identified an issue with 23 substantial safety significance which will require 24 additional NRC inspections, and was determined to have 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 11 a

cross-cutting aspect in the area of human 1

performance.

2 Specifically, in October

2008, air 3

intrusion from the containment instrument air system 4

to the component cooling water system occurred, which 5

affected both redundant trains of the component 6

cooling water system.

The troubleshooting and 7

subsequent corrective actions that were implemented by 8

the licensee failed to identify the source of the air 9

in-leakage, and ensure that the component cooling 10 water system maintained--excuse me--remained capable 11 of delivering adequate cooling to essential equipment 12 used to mitigate design basis accidents which 13 contributed to a similar air intrusion event into the 14 component cooling water system in November 2009. The 15 petitioner references NRC EA-09-321--it's an 16 enforcement action--for the record.

17 On November 3, 2010, the NRC issued a 18 letter to Florida Power and Light Company's Executive 19 Vice President, Mano Nazar, M-A-N-O, N as in Nancy, A-20 Z-A-R, which stated in relevant part that "on 21 September 30,

2010, the United States Nuclear 22 Regulatory Commission's staff completed a supplemental 23 inspection at your St. Lucie Nuclear Plant, Unit 1.

24 The objectives of the supplemental inspection were to 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 12 provide assurance that 1) the root causes and the 1

contributing causes for the risk-significant issues 2

were understood; 2) the extent of condition and extent 3

of cause of the issues were identified; and 3) 4 corrective actions were or will be sufficient to 5

address and preclude repetition of the root and 6

contributing causes." The inspection also included an 7

independent NRC review of the extent of condition and 8

extent of cause, so the Yellow finding, and an 9

assessment of whether any safety culture component 10 caused or significantly contributed to the issue.

11 Florida Power and Light Company's staff 12 evaluation identified root causes of the issue to be:

13

1) decision-making by the organization was 14 insufficient due to inadequate knowledge and skills 15 related to risk-significant decisions, conservative 16 assumptions, and timely communication between 17 departments; and 2) the organization missed several 18 opportunities to promptly identify, fully analyze and 19 resolve in a timely manner the air intrusion event; 20 and 3) inadequate fleet site procedures resulted in 21 the failure to recognize the condition and 22 significance of the event in a timely manner; and 4) 23 management did not effectively implement policies and 24 procedures, which resulted in a

reluctance to 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 13 challenge issues and recognize the significance of the 1

2008 event, and a repeat of the event in 2009; and 5) 2 less than adequate design of the containment air 3

compressor system resulted in recurrent air intrusion 4

events; and 6) less than adequate maintenance resulted 5

in a similar 2009 component cooling water system air 6

intrusion event.

7 The NRC inspection team further determined 8

that FP&L's organization failed to recognize or 9

understand the significance of the 2008 gas intrusion 10 event and its impact on the component cooling water 11 system, and that there were inadequacies in operating, 12 alarm response, maintenance, operability determination 13 and corrective action procedures. Overall, the NRC 14 inspectors determined that the components of safety 15 culture at the St. Lucie nuclear plant contributed to 16 the Yellow finding associated with the licensee's 17 failure to implement adequate corrective actions 18 associated with the 2008 component cooling water air 19 intrusion event. Petitioners reference NRC's November 20 3, 2010 letter to FP&L Executive Vice President Mano 21 Nazar in connection with EA-09-321 for the record.

22 Now before I

continue with further 23 discussion, let this public record reflect the 24 following issues, which should be of grave concern to 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 14 the NRC Office of the Inspector General. Issue number 1

1, what are the root causes and the contributing 2

causes for the NRC's failure to timely require the 3

licensee, FP&L, to affirmatively and definitively 4

identify and resolve the 2008 air in-leak event 5

associated with the St. Lucie Nuclear Plant component 6

cooling water system in 2008, which resulted in a 7

repetitive violation of NRC safety regulations for the 8

very same issue in 2009? Issue number 2, what 9

corrective actions will be sufficient to address and 10 preclude repetition of the root cause and contributing 11 causes of the NRC's failure, in these circumstances, 12 and when will they be implemented to protect public 13 health and safety?

14 Issue number 3, why did the NRC wait until 15 April 19, 2010, to take any enforcement action against 16 FPL and the St. Lucie Nuclear Plant for a serious 17 nuclear safety violation that initially occurred in 18 2008? Next issue, what role, if any, did the NRC 19 resident inspectors at the St. Lucie Nuclear Plant 20 play to identify the air in-leak intrusion event in 21

2008, and to oversee the licensee's corrective 22 actions, if any, at that time? And finally, why 23 didn't the NRC inspect the St. Lucie Nuclear Plant, 24 Unit 2, for a similar design problem associated with 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 15 its component cooling water systems?

1 Considering that the NRC first issued an 2

operating license for the St. Lucie Nuclear Plant Unit 3

1 on March 1, 1976, it strains the mind of a 4

reasonable person that the NRC continues to allow FP&L 5

to operate their nuclear reactors at full power with 6

so many broad-based failures in management, training, 7

worker knowledge, failed plant procedures, system 8

design based

flaws, inadequate safety

culture, 9

repetitive serious violations for the very same 10 problem, et cetera.

11 It is reasonable to believe that after 12 some 31 years of operating the St. Lucie Nuclear 13 Plant, that FP&L management would have excellent 14 station procedures and accurate station procedures, 15 and seasoned managers who take personal responsibility 16 for plant operations and an impeccable work safety 17 culture, where all nuclear workers are free, and feel 18 free, to raise nuclear safety concerns to anyone, and 19 a corrective action program of sufficient use and 20 design to prevent repetitive, serious safety 21 violations of NRC requirements, and proper supervision 22 of craft workers effecting repairs and conducting 23 surveillance maintenance activities, and a viable 24 training program, et cetera.

25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 16 Clearly, the record of evidence to date 1

shows exactly the opposite at the St. Lucie Nuclear 2

Plant, a nuclear plant that the NRC issued a 20-year 3

license extension, allowing operation of the nuclear 4

reactor until March 1, 2036. In consideration of 5

these grave concerns in connection with the NRC's 6

oversight and inspection activities and enforcement 7

activities associated with the St. Lucie Nuclear 8

Plant, the petitioner requests that a copy of the 9

record transcripts be provided to the NRC Office of 10 the Inspector General to enable that agency to make an 11 informed decision as to whether the NRC should be 12 investigated for improper activities in these 13 circumstances, and whether public health and safety 14 was at any time jeopardized in connection with 15 licensed activities at the St. Lucie Nuclear Plant in 16 connection with the events outlined in NRC EA-09-321, 17 dated November 3, 2010.

18 With respect to the instant enforcement 19 petition, the licensee apparently admitted to the NRC 20 that when the St. Lucie Nuclear Plant, Unit 1 was 21 licensed, the facility was not required to incorporate 22 a single failure design capability for a non-safety 23 system. And FPL concluded that a violation of 10 CFR, 24 Part 50, Appendix B, Criterion 3 did not occur as 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 17 found by NRC inspectors. Petitioners contend here 1

that the licensee's admission supports a finding that 2

the licensee is operating the St. Lucie Nuclear Plant 3

well outside the NRC's nuclear safety regulations 4

under 10 CFR, Part 50, and that the component cooling 5

water system employed at the St. Lucie Nuclear Plant, 6

Unit 1 and Unit 2 is a nuclear safety-related system 7

to the extent that it serves to remove heat from the 8

reactor core in various manners and modes of 9

operation.

10 Petitioner further contends that since the 11 licensee admitted to the NRC that the St. Lucie 12 Nuclear Plant, Unit 1 was licensed by the NRC for 13 operations not requiring the incorporation of a single 14 failure design capability for the component cooling 15 water system, that the licensee's NRC operational 16 licenses for Unit 1 and Unit 2 are invalid, and that 17 the NRC should order the licensee to immediately bring 18 the St. Lucie Nuclear Plant, Unit 1 and Unit 2 to a 19 cold shut down mode of operation to protect public 20 health and safety in these circumstances.

21 Petitioner further contends that the metal 22 in the nuclear reactor vessels at the St. Lucie 23 Nuclear Plant, Unit 1 and Unit 2 have become 24 dangerously brittle from bombardment of high-level 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 18 neutron radiation during normal operations over years 1

and years of operation, and that neither the licensee 2

nor the NRC has any accurate and meaningful data 3

measurements of just how brittle the nuclear reactor 4

vessels have become at the St. Lucie Nuclear Plant.

5 Petitioners are concerned that should one or both of 6

the nuclear vessels at the St. Lucie Nuclear Plant 7

crack or shatter, that a full core melt down would 8

immediately occur, similar to the ongoing melt down of 9

three nuclear reactors in Japan. Such an event at the 10 St. Lucie Nuclear Plant would rapidly release an 11 abundant amount of hydrogen, which would inundate any 12 action mitigation systems designed to dissipate such 13 gaseous buildup, and that a dangerous explosion of the 14 St. Lucie Nuclear Plant containment buildings would 15 occur and spew high level nuclear particles directly 16 into the environment and adversely affect public 17 health and safety, just like what happened in Japan.

18 Petitioners further contend that the NRC 19 improperly granted FP&L and the St. Lucie Nuclear 20 Plant, Unit 1 and Unit 2 a 20-year license extension 21 under the Atomic Energy Act of 1954, as amended, and 22 its relevant subsections, where such authority to 23 grant license extensions by the NRC was misinterpreted 24 by the NRC, as the language contained in the Act was 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 19 meant to deal with NRC licensed activities at medical 1

facilities or at medical research facilities, and not 2

at commercial nuclear

reactors, such as those 3

operating at the St. Lucie Nuclear Power Plant.

4 For these reasons, Petitioner supplements 5

the Original Petition filed in the instant action to 6

request that the NRC order FP&L and the St. Lucie 7

Nuclear Plant to immediately, or within a reasonably 8

short period of time, bring the Unit 1 and Unit 2 9

nuclear reactors to a cold shut down mode of 10 operation, until such time as the licensee can have 11 the Unit 1 and Unit 2 nuclear reactor vessel metal 12 tested to determine exactly how brittle the metal has 13 become, and to determine how many years, if any, that 14 the nuclear reactors can be safely operated.

15 To the extent that the Petitioner is 16 engaging the United States Nuclear Regulatory 17 Commission Petition Review Board with respect to 18 issues initially brought up on April 3, 2011 in a 19 written petition to the Executive Director for 20 Operations for the NRC, all the comments made today on 21 this public record are to be considered and to be 22 construed and to be implemented as a supplement to the 23 Original Petition dated April 3, 2011, just the same 24 as if they were placed in writing and submitted to the 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 20 NRC along with the initial petition.

1 With respect to the previously stated 2

concerns encompassed in the instant enforcement 3

petition, Petitioner states that, in general, the 4

major secondary systems of a pressurized water reactor 5

are the main steam system and the condensate feed 6

water system. Since the primary and secondary systems 7

are physically separated from each other by the steam 8

generator tubes, the secondary system should contain 9

little or no radioactive material. During normal 10 operation at the St. Lucie Nuclear Plant, the heat 11 produced by the fission process is removed by the 12 reactor coolants, and transferred to the secondary 13 coolant in the steam generators. The secondary 14 coolant is boiled into steam and sent to the main 15 turbine.

16 Even after the nuclear reactor has been 17 brought to a cold shut down mode of operation, there 18 is a significant amount of heat produced by the decay 19 of fission products, which is called decay heat. The 20 amount of heat produced by decay heat is sufficient to 21 cause fuel damage if not removed. Thus, nuclear and 22 safety related systems must be designed and installed 23 in the plant to remove the decay heat from the nuclear 24 reactor

core, and transfer that heat to the 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 21 environment. The very same concerns for decay heat 1

removal are relevant when performing maintenance 2

activities on a reactor coolant system component at 3

the St. Lucie Nuclear Plant, where the temperature and 4

pressure of the reactor coolant system must be reduced 5

low enough to allow personnel access to the equipment.

6 The auxiliary feed water system and the 7

steam dump system or turbine bypass valves work 8

together to allow the plant operators at the St. Lucie 9

Nuclear Power Plant to remove the decay heat from the 10 nuclear reactor. The auxiliary feed water system 11 pumps water from the condensate storage tank to the 12 steam generators, where the water boils to make steam.

13 The steam can then be dumped to the main condenser 14 though the steam dump's valves. The circulating water 15 will then condense the steam--excuse me--the 16 circulating water will then condense the steam and 17 take the heat to the environment. If the steam dump 18 system is not available, the steam can be dumped 19 directly to the atmosphere through the atmospheric 20 release valves. By using either method, the heat is 21 being removed from the nuclear reactor coolant system, 22 and the temperature of the reactor coolant system can 23 be reduced to the desired level.

24 At some point, the decay heat being 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 22 produced will not be sufficient to generate enough 1

steam in the steam generators to continue the cool 2

down. When the reactor coolant system pressure and 3

temperature have been reduced to within the 4

operational limits, the residual heat removal system, 5

or RHR, will be used to continue the cool down by 6

removing heat from the core and transferring it to the 7

environment. This is accomplished by routing some of 8

the reactor coolant through the residual heat removal 9

system heat exchanger, which is cooled by the 10 component cooling water system, or CCW.

11 The heat removed by the component cooling 12 water system is then transferred to the service water 13 system in the component cooling water heat exchanger.

14 The heat picked up by the service water system will be 15 transferred directly to the environment from the 16 service water system. The residual heat removal 17 system can be used to cool the plant down to a low 18 enough temperature that personnel can perform any 19 maintenance activities and refueling activities.

20 For the reasons stated, it is abundantly 21 clear that the component cooling water system at the 22 St. Lucie Nuclear Power Plant serves to remove heat 23 from the nuclear reactor core, and is therefore a 24 nuclear safety-related system. Thus, to the extent 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 23 that the component cooling water system at the St.

1 Lucie Nuclear Plant is a nuclear safety-related 2

system, the operating licenses issued by the NRC to 3

Florida Power and Light Company and the St. Lucie 4

Nuclear Plant are required to incorporate a single 5

failure design capability for the component cooling 6

water system at Unit 1 and at Unit 2.

7 To the extent that the licensee has 8

apparently admitted to the NRC that the St. Lucie 9

Nuclear Plant Unit 1 was licensed by the NRC, not 10 requiring the incorporation of a single failure design 11 capability for the component cooling water system, 12 the NRC must find that the licensee's operation of the 13 nuclear reactors at the St. Lucie Plant is in 14 violation of NRC federal safety regulations, standards 15 and requirements under 10 CFR Part 50, and issue a 16 confirmatory order requiring the licensee to bring the 17 St. Lucie Nuclear Plant Unit 1 and Unit 2 to a cold 18 shut down mode of operation to protect public health 19 and safety in these circumstances.

20 Petitioners further request that the NRC 21 issue a notice of violation and a civil penalty in a 22 monetary amount of $500,000 to insure for the 23 protection of public health and safety by emphasizing 24 the severity of the licensee's violation and need for 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 24 prompt remedial corrective action, and long-lasting 1

corrective action to prevent a repetitive violation 2

with respect to the component cooling water system.

3 As everyone at this meeting is surely 4

aware, there are currently three nuclear reactors in a 5

full melt down scenario in the country of Japan, where 6

the containment buildings have exploded and various 7

levels of nuclear radiation and radioactive particles 8

have spewed into the environment, and continue to spew 9

into the environment, where the reactor fuel--fuel 10 inside the reactor core has melted through the 11 containing pipes, the fuel assemblies, through the 12 bottom of the reactor vessel, and through the 13 containment structure itself into the environment, 14 contaminating drinking water in the country of Japan, 15 and spreading the contamination by air, land and sea 16 throughout the world.

17 There's been radioactive iodine-131 18 monitored here in various states within the 19 continental United

States, and by some expert 20 accounts, there is actual radioactive contamination on 21 food products. The events in Japan cannot be 22 understated, and it is doubtful that the government 23 and the plant operator will ever gain control of those 24 nuclear reactor vessels to bring them to a cold shut 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 25 down mode of operation, and I fear that the situation 1

was out of control within hours of the earthquake and 2

tsunami, and that it continues to be completely out of 3

control, and the severity of that accident is only 4

going to grow and become greater, and harm more and 5

more people, not only in the country of Japan, but 6

around the United States.

7 Here, in our country, we have 104 nuclear 8

reactors that are licensed for operation by the United 9

States NRC, and are operating in this country. Two of 10 those reactors are at the St. Lucie Nuclear Power 11 Plant. A recent media release by Associated Press, it 12 spoke very broad, encompassing and pervasive terms 13 about how the NRC as a regulator is failing to protect 14 public health and safety over the years concerning the 15 commercial operation of these nuclear reactors. And I 16 won't go into any length of discussing that report, 17 because it's a matter of public record. The video 18 part of that is posted on our website if anyone wants 19 to view it. But it shows time and time again that the 20 NRC has relaxed their safety margins, their safety 21 requirements and their safety standards to allow these 22 nuclear reactors to continue in operation.

23 And my concern here is that the NRC over 24 the years and over the life span of the two nuclear 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 26 reactors operating at the St. Lucie Nuclear Power 1

Plant, that the NRC has relaxed its safety margins 2

with respect to the degree of embrittlement that those 3

nuclear reactor vessels are allowed to have and 4

continue to operate. So what was once a safety 5

standard early on when the reactors were licensed by 6

the NRC, it is my belief and understanding, and fully 7

supported by the Associated Press investigative 8

findings, that the NRC over the years has relaxed 9

those safety requirements with respect to 10 embrittlement of the reactor vessels, and that those 11 reactor vessels are dangerously brittle and could 12 shatter, and if that event occurred, that would be a 13 LOCA, what's called a loss of coolant accident.

14 There is no way to recover from that 15 accident, and I don't care how many fire trucks you 16 back up to the St. Lucie Plant; I don't care how much 17 sea water you dump in there; those reactors are going 18 to melt down because the water is not going to be 19 cooling the core of that reactor; that fuel will melt 20 immediately and the containment buildings will explode 21 because it'll be such huge amount of hydrogen released 22 from the heat generated in that melt down, they will 23 explode. And the public will be harmed exactly the 24 same way as the public in Japan is being harmed from 25

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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 27 those three reactors that are still melting down and 1

still spewing high level radiation in the environment.

2 The public has no alternative but to turn 3

to the Nuclear Regulatory Commission in this country 4

to bring these issues to light, to get them resolved, 5

and to insure for public protection from a nuclear 6

disaster comparable to what's going on in Japan. We 7

the public have no other agency to turn to. NRC is 8

that--Congress in

1974, through the Energy 9

Organization Act, the NRC is responsible; in fact, it 10 is their mandate to protect public health and safety 11 in the environment with respect to commercial nuclear 12 plant operations and with respect to medical radiation 13 usage also.

14 So that's why we're here today. That's 15 why myself, as a member of the public, filed an 16 enforcement petition under NRC's own regulations, to 17 get the attention of the NRC that there's something 18 very, very wrong going on at the Florida Power and 19 Light Nuclear Power Plant. And apparently, the NRC 20 has some very experienced and very qualified people 21 who went in on these special inspection teams and made 22 the determinations that they did in their enforcement 23 documents. But that's not enough. You know, the 24 public should have had the benefit of those inspection 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 28 findings back in 2008, and the corrective actions 1

should have been taken then.

2 When I worked at the St. Lucie Nuclear 3

Plant years

ago, believe me, it was a

very 4

professional attitude, high-quality managers there, 5

high-quality technicians; I was an instrument control 6

technician; I even went to Reactor Operator School for 7

a short time there. And we had station procedures to 8

work with to do our maintenance activities, to do our 9

surveillance

testing, to do refueling outage 10 activities and the like, and to operate the power 11 plant. And with the skill level of the instrument 12 control people and the maintenance electricians and 13 other craft in the plant, the mechanics and such, was 14 such a high level that we weren't required by the NRC 15 to have what's called verbatim compliance to 16 procedures, meaning if you had a procedure that had 20 17 steps in it, you had to go from step one, step two, 18 step three, all the way down, verbatim, word for word, 19 you had to accomplish what that written procedure said 20 on whatever maintenance activity you were working on.

21 And we didn't have to do that because the 22 NRC was so confident in our capabilities and our work 23 attitude, and the management at the time, that we 24 operated the plant in a safe manner. But since, over 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 29 the years, that--I am just shocked in my monitoring of 1

the inspection reports coming from the NRC, and how 2

the physical plant operations have degraded over the 3

years. I mean, they have degraded pervasively across 4

the board. You have poor management there, poor 5

management oversight of licensed activities at the St.

6 Lucie Nuclear Power Plant. You have a very poor 7

safety-conscious work environment.

8 Now the NRC--I read the investigative 9

findings by the NRC, and they said oh you know, we 10 talked to these number of people, and we asked them 11 these questions, and from our interviews, you know, we 12 feel that people believe they can raise nuclear safety 13 concerns without fear of retaliation. But that's a 14 subjective investigation, and it didn't go quite far 15 enough. You have to have your resident NRC inspectors 16 monitoring that plant more thoroughly on a daily 17 basis, and following up. You know, those inspectors 18 that wrote these reports should have went to the 19 corrective action program to follow through a number 20 of these instances where concerns were raised that had 21 some aspect of nuclear safety, and see how they were 22 dealt with. How timely were they dealt with? Were 23 they dealt it, were some ignored, or is there a 24 backlog of these type of--and who raised these 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 30 concerns, and what happened to these employees after 1

they raised these concerns?

2 There's none of that follow up. There was 3

no inspection activities in those areas whatsoever.

4 So, I've been complaining to the NRC for the better 5

part of 20 some years; there's a hostile work 6

environment, a poor safety culture at the St. Lucie 7

Nuclear Plant, and it's a Turkey Point nuclear power 8

plant, which Florida Power and Light Company also 9

operates. So over the years, the overall performance 10 has degraded in that area also, and it's degraded in 11 maintenance activities, where you have this air 12 intrusion event occur over two years ago, you know, 13 and the NRC has just now in 2010 taken enforcement 14 action, and even then, in the NRC's own inspection 15 activity reports say what measures the licensee plans 16 to take or will take, it doesn't mean--they haven't 17 even any corrective actions yet. And why, after all 18 these years of operation, is the NRC still finding 19 that there are significant problems with the 20 licensee's station procedures, which are part of their 21 technical specifications, which are encompassed in the 22 plant's license within the final safety analysis 23 review?

24 These are significant safety issues that 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 31 have a very far reach, and could cause a very 1

significant nuclear accident at the St. Lucie Nuclear 2

Power Plant. And obviously, you have a training issue 3

here, and you have a work force that isn't very 4

technically competent, and management which don't 5

properly oversee the work force. So you have to take 6

a broad look at these nuclear power plants, the St.

7 Lucie Nuclear Plant, and a broad look at the licensee, 8

and we need--the public needs to have more enforcement 9

action, more aggressive enforcement action.

10 A Yellow finding is great; but where's the 11 civil penalty? How do you get the licensee's 12 attention to change, to improve, to enhance and to 13 correct, and then correct in a timely manner these 14 serious safety violations? They were identified in 15 2008; no penalties, you know. We're just giving you 16 this little write up, this little warning; go ahead 17 and operate your nuclear reactors at full power 18 nonetheless. So they did. FPL went right ahead, 19 because they get $1 million a day per reactor, 20 approximately, for keeping those reactors on line.

21 And in 2009, same problem, same system, 22 same violation, and it's a safety-related system which 23 serves to mitigate a nuclear accident, like what 24 happened in Japan. And the NRC takes no enforcement 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 32 action in 2009; and it's only until 2010 before the 1

NRC gets around to issuing a Yellow finding, but no 2

enforcement. No monetary fine. So it's like me 3

driving my car down Interstate 95 here and speeding, 4

and the state trooper pulls me over, Mr. Saporito, you 5

know you were doing 100 miles an hour, and the speed 6

limit's 65. You know, I'm going to give you this 7

written warning, and don't let me catch you doing it 8

again. Do you think that's going to be a deterrent to 9

me for speeding? Of course not. I'm going to speed 10 again.

11 But if that state trooper would have said 12 Mr. Saporito, you were doing 100 miles an hour, and 13 the speed limits here are 65, I'm going to have to 14 suspend your license and I'm going to have to give you 15 a fine of $350, and you have to go to court. Guess 16 what? That police officer got my attention. I've got 17 to pay a $300 fine; I have to go to court; my license 18 is suspended; I've got to go ride a bike to get to 19 work now. I'm not going to speed again. Well that's 20 what the public wants the NRC to do. The public needs 21 to see the NRC show some teeth when it takes 22 enforcement action.

23 This Reactor Oversight Process is a sham, 24 because it's a haphazard way of inspecting a nuclear 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 33 power plant where you go in there on a quarterly basis 1

and only inspect certain systems and certain 2

processes. Prior to this process, there was a 3

systematic assessment of licensee performance, or the 4

SALP program, and that's the program that was in force 5

when I worked at the Florida Power and Light Company, 6

the St. Lucie Nuclear Plant. And that was a very 7

thorough inspection by the NRC. I've read those 8

reports, and you can be confident that every system, 9

operations, maintenance, procedures, health physics, 10 everything was looked at. And the NRC made some very 11 specific findings back then, and the NRC took 12 enforcement action back then; they issued hundreds of 13 thousands of dollars in fines.

14 But something happened. When that program 15 ended, and the ROP program came into being, and the 16 enforcement actions, it just went off the chart.

17 There was no more enforcement actions. It went off 18 the radar, so to speak. Then, the NRC through a 19 change of politics in Washington, the new President 20 was elected, and Chairman Greg Jaczko got appointed 21 there as the Chairman, and his position is that you 22 know, well, we're just going to increase inspection 23 activities if we find a violation. That's not going 24 to serve the purpose; it's not going to protect public 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 34 health and safety; the NRC needs to wake up and start 1

issuing heavy monetary fines.

2 Just recently, the NRC issued a Red 3

finding for the Browns Ferry Plant; it was an improper 4

situation there where a valve wasn't working properly, 5

and the licensee should have picked it up on their 6

surveillance buzzers, and they didn't, and they denied 7

the violations, fought kicking and screaming at the 8

enforcement conference there should be no penalty 9

whatsoever. And it's just outrageous. But then--so 10 there's a Red finding, but there was no monetary fine 11 assessed against the licensee.

12 So while it's fine and dandy they got a 13 Red finding, because that's the highest level there 14 is, there has to be a fine attached to that to get 15 their attention, and it has to be six or seven 16 figures. In that situation, there should have been a 17 suspension of the license also. You want to get their 18 attention, escalate an enforcement action. And that's 19 why I'm here today. That's why I'm asking for 20 escalated enforcement actions. We're talking about 21 Florida Power and Light

Company, repetitive 22 violations, same violation occurred over more than one 23 year, a couple of years. And they admit they have 24 problems in management, they have problems with their 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 35 procedures. They have a design problem with the 1

system itself. There's a problem with the work 2

culture out there, there's a problem with training and 3

the maintenance activities that are going on out 4

there.

5 There's obviously a problem with the 6

performance of the NRC's site resident inspectors. I 7

mean, my goodness, what are these people doing out 8

there? Are they grabbing a cup of coffee and shooting 9

the breeze with the operators in the control room 10 every day? Is that the extent of their activities?

11 Aren't they going around with a note pad, taking 12 notes, looking at system line ups, looking at 13 equipment operations, watching maintenance workers as 14 they perform surveillance

testing, monitoring 15 activities during refueling outages. You know, where 16 is all of their reports?

17 You

know, if I

was a

regional 18 administrator Region II, and I understand there's a 19 new fellow there, Mr. McCree, and thank God that they 20 replaced the old fellow, and hopefully this new fellow 21 will take more aggressive enforcement action, but 22 McCree should be demanding that all resident 23 inspectors under his authority under Region II--

24 MR. ORF: Excuse me--

25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 36 MR. SAPORITO: --provide him a written 1

response of what the hell they're doing every--

2 MR. ORF: Mr. Saporito?

3 MR. SAPORITO: Yes sir?

4 MR. ORF: We're coming up on 3:30 if you'd 5

like to start summarizing.

6 MR. SAPORITO: Well okay, that's fine.

7 I'll just summarize in saying that we want enforcement 8

action from the NRC with respect to the license 9

activities that are going on at the St. Lucie Nuclear 10 Power Plant, where the licensee has, on more than one 11 occasion, been found to have violated NRC federal 12 safety standards and regulations under 10 CFR Part 50.

13 And we believe that the NRC's conduct in these 14 circumstances is outrageous and cannot be timely 15 corrected in the manner which will preserve and 16 protect public health and safety if these nuclear 17 reactors are allowed to continue operation at full 18 power, and that the NRC should order their immediate 19 shut down so the licensee can take the corrective 20 actions needed on the broad spectrum of problems that 21 have been identified by the Agency, and so those 22 reactor vessels can be properly tested to see how 23 brittle they are. And at this time, I'll stay on the 24 line to answer any questions from the NRC, the 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 37 licensee, or the public who may be attending this 1

conference.

2 MR. ORF: Thank you, Mr. Saporito.

3 MR. LEE: At this point, does the staff 4

here at headquarters have any questions for Mr.

5 Saporito? How about the Region?

6 MR. ROSE: No questions from the Region.

7 MR. LEE: Does the licensee have any 8

questions?

9 MR. HAMRICK: No.

10 MR. LEE: Mr. Saporito, thank you for 11 taking time to provide the NRC staff with clarifying 12 information on the petition you have submitted.

13 Before we close, does the court reporter need 14 additional information for the teleconference 15 transcript?

16 MR. SAPORITO: Mr. Chair, this is Mr.

17 Saporito, I'm sorry to interrupt, but I would ask if 18 you would please ask if there are any members of the 19 public who might want to ask a question.

20 MR. LEE: Okay, thank you for reminder.

21 Before I conclude the teleconference, members of the 22 public may provide comments regarding the petition and 23 ask questions about the 2.206 petition process.

24 However, as stated at the opening, the purpose of this 25

NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 38 teleconference is not to provide an opportunity for 1

the petitioner or the public to question or examine 2

the PRB regarding the merits of the petition request.

3 Is there any member of public that wants to ask a 4

question or make a comment? Okay, I think that's a 5

no. So with that, this teleconference is concluded, 6

and we will be terminating the telephone connection.

7 Thank you.

8 (The telephone conference was concluded at 9

3:26 p.m.)

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