ML24132A002
| ML24132A002 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/29/2024 |
| From: | NRC/NRR/DORL/LPL2-2 |
| To: | |
| Jordan N | |
| References | |
| OEDO-23-00350-NRR, NRC-2805, 2.206 | |
| Download: ML24132A002 (1) | |
Text
Official Transcript of Proceedings
NUCLEAR REGULATORY COMMISSION
Title:
2.206 Petition Review Board RE Diablo Canyon Power Plant Unit 1
Docket Number: (n/a)
Location: teleconference
Date: Monday, April 29, 2024
Work Order No.: NRC-2805 Pages 1-39
NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1716 14th Street, N.W.
Washington, D.C. 20009 (202) 234-4433 1
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
+ + + + +
MEETING BETWEEN THE U.S. NUCLEAR REGULATORY
COMMISSION PETITION REVIEW BOARD AND THE SAN LUIS
OBISPO MOTHERS FOR PEACE AND FRIENDS OF THE EARTH
REGARDING A 2.206 PETITION
SUBMITTED ON SEPTEMBER 14, 2023
+ + + + +
MONDAY, APRIL 29, 2024
+ + + + +
The meeting was convened via Video-
Teleconference, at 3:00 p.m. EST, Lynn Ronewicz,
Facilitator, presiding.
PRESENT:
LYNN RONEWICZ, NSIR/DSO/ISB, Facilitator
NATREON JORDAN, NRR/DORL/LPL2-2
JAMIE PELTON, NRR/DORL
ON YEE, NRR/DNRL/NVIB
JOHN TSAO, NRR/DNRL/NVIB
JOHN WISE, NRR/DNRL
JAMES KIM, NRR/DORL/LPL1
DANIEL KING, NRR/DORL/LLPB
PERRY BUCKBERG, NRR/DORL/LPL2-2
ROBERT CARPENTER, OGC/LHE/SE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 2
ALSO PRESENT:
DIANE CURRAN, Counsel to San Luis Obispo Mothers
for Peace
HALLIE TEMPLETON, Counsel to Friends of the Earth
DIGBY MACDONALD, Professor in Residence,
Departments of Nuclear Engineering and
Materials Science and Engineering, University
of California at Berkeley
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 3
C-O-N-T-E-N-T-S
Introduction
Lynn Ronewicz.....................................4
Nate Jordan.......................................6
Jamie Pelton......................................9
Petitioner Presentation
Diane Curran.....................................14
Digby Macdonald..................................16
Public Interaction
Robert Budnitz...................................36
Kevin Kamps......................................37
Adjourn...........................................39
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 4
P-R-O-C-E-E-D-I-N-G-S
3:00 p.m.
MS. RONEWICZ: Good afternoon. Welcome to
this virtual public meeting and thank you for
attending. My name is Lynn Ronewicz. I am an NRC
employee and I will be assisting with meeting
facilitation.
The purpose of this meeting is to provide
the Petitioners Diane Curran and Dr. Digby Macdonald
an opportunity to address the Petition Review Board,
or PRB, and clarify or supplement the September 14th,
2023 petition regarding reactor pressure vessel
embrittlement at Diablo Canyon Power Plant Unit 1
based on the results of the PRB's initial assessment
of the petition. The PRB will then consider
information obtained today in its final assessment of
the petition's acceptability for further review.
The Petitioners may present information to
the PRB, but this meeting will not include a
discussion regarding the PRB's evaluation of the
subject petition as this would be outside the scope of
this meeting. I will provide a gentle reminder if we
get outside the scope of the meeting. After the
presentation members of the public and others may ask
questions about the 2.206 process which will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 5
answered by the NRC staff.
As a general note please keep yourself
muted unless you have been called on to speak or have
the speaking role and please do not turn your camera
on unless you are speaking, and then remember to turn
your camera off. This will save bandwidth and allow
the focus of the meeting to be on the specific
individual who is presenting or speaking.
After introductions are made a
presentation will follow after which time the
opportunity for questions and comments within the
scope of this meeting will occur.
Please keep yourself muted in Teams and if
you dialed in on the bridge line, use the mute icon or
dial star-6. Please only un-mute if you are in a
speaking role. For phone --
(Simultaneous speaking.)
MS. RONEWICZ: -- unmute using star-5.
Yes, hello. Everyone please mute your phones if you
are not speaking.
Attendees will be called in order of hands
raised at the appropriate time. At that time,
speaking clearly and loudly, please state your name.
And if you are affiliated with an entity, please state
the entity.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 6
A court reporter is transcribing this
meeting. All questions, comments are to be made
verbally for the court reporter to transcribe, and
thus the Teams chat has been disabled. The transcript
will become a supplement to the petition. The
transcript will also be made publicly available.
Is the court reporter present and able to
record the meeting?
COURT REPORTER: Yes, I am.
MS. RONEWICZ: Great. Thank you. I will
now turn the meeting over to Nate Jordan, but again I
just want to remind everybody please keep your cameras
off if you are not in a speaking role and your phones
muted. Thank you.
MR. JORDAN: Thank you, facilitator.
I'd like to thank everybody for attending
today's meeting. My name is Natreon "Nate" Jordan,
and I'm a project manager in the U.S. Nuclear
Regulatory Commission, and also a member of the NRC's
2.206 Petition Core Team.
On September 14th, the Petitioners
submitted a petition to the NRC seeking immediate
closure of the Diablo Canyon Unit 1 due to concerns
that the reactor pressure vessel could reach an
unacceptable level of embrittlement well before NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 7
expected. This petition was referred to the Title 10
of the Code of Federal Regulations, 10 CFR Section
2.206 petition process.
The purpose of today's meeting is to
provide the Petitioners an opportunity to address the
Petition Review Board, or PRB as it's called, and
clarify or supplement the petition based on the
results of the PRB's initial assessment of the
petition. The PRB will then consider any information
obtained today in its final assessment of the
petition's acceptability for further review.
Welcome, Ms. Diane Curran, Hallie
Templeton, and Dr. Digby Macdonald.
PRB is a symbol for certain 2.206
petitions and typically consists of a petition
manager, myself; a chair who is usually a senior
executive service manager; and members of the NRC
staff based on the content of the information given in
the petition. The PRB chair for this petition is
Jamie Pelton, Deputy Director of the NRC Division of
Operating Reactor Licensing in the Office of Nuclear
Reactor Regulation within the NRC. PRB members
will introduce themselves shortly.
In addition I'd like to open this meeting
with introductions. To better facilitate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 8
introductions virtually I will read attendees' names.
Again, my name is Nate Jordan and I'm a
petition manager for DORL. The list of the PRB
members on the line: Jamie Pelton, On Yee, John Tsao,
John Wise. Next NRC participants who are also
involved may be James Kim, Daniel King, Dave Rudland,
who is not on -- who wasn't able to make the call.
Perry Buckberg as well, who is the primary 2.206
Petition Core Team member, as well as Robert
Carpenter.
And so at this point I want to ask first
of all are there any Licensee staff in attendance for
this meeting?
(No audible response.)
MR. JORDAN: Okay. Hearing none, I also
want to make known too that it is not required that
members of the public introduce themselves as part of
this meeting, however, if there are any members of the
public attending this meeting and they would like to
introduce themselves at this time, please feel free to
do so.
(No audible response.)
MR. JORDAN: All right. Hearing none, at
this time I will turn it over to the PRB chair, Jamie
Pelton.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 9
MS. PELTON: Hi. Good afternoon. As Nate
said, my name is Jamie Pelton and I'm the Deputy
Director of the Division of Operating Reactor
Licensing in NRR.
Welcome to this meeting regarding the
2.206 petition submitted by Diane Curran and Hallie
Templeton.
I'd first like to share some background on
our process. Section 2.206 of Title 10 of the Code of
Federal Regulations describes the petition process,
the primary mechanism for the public to request an
enforcement action by the NRC in a public process.
This process permits anyone to petition the NRC to
take enforcement-type actions related to NRC licensees
or license activities. Depending on the results of
its evaluation NRC could modify, suspend, or revoke an
NRC-issued license or take any other appropriate
enforcement action.
The NRC staff's guidance for the
disposition of 2.206 petition requests is Management
Directive 8.11, which is publicly available.
The purpose of today's meeting is to give
the Petitioners an opportunity to provide any relevant
additional explanation and support for the petition
after having received the Petition Review Board's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 10
initial assessment.
This meeting is not a hearing, nor is it
an opportunity for the Petitioners or other members of
the public to question or examine the PRB on the
merits or the issues presented in the petition
request.
During the question and answer phase the
NRC staff may ask clarifying questions of the
Petitioners and the Licensee. The Licensee may ask
PRB questions related to the issues raised in the
petition. And then the Petitioners and the Licensee
may ask the PRB questions related to the 2.206
petition process in general. This is consistent
with Management Directive 8.11,Section III.F.
No decisions regarding the merits of this
petition will be made at this meeting.
Following this meeting the PRB will
conduct its internal deliberations. The outcome of
these internal meetings will be provided to the
Petitioner in a letter.
I would like to summarize the scope of the
petition under consideration and the NRC activities to
date.
Diane Curran and Hallie Templeton
submitted a petition to the NRC on September 14th, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 11
2023, which was referred to the 2.206 petition
process. The petition requested that the NRC
immediately close Diablo Canyon Unit 1 and require the
completion of tests and inspections of the pressure
vessel, require the public disclosure of the results,
require a public hearing and a determination by the
Commission that Diablo Canyon Unit 1 can safely resume
operation.
To provide some process background the PRB
first evaluates petitions using MD 8.11, Section
III.C.1., criteria for accepting petitions to assess
whether or not further review is warranted. A
petition must basically provide facts not previously
reviewed and/or resolved by the NRC to warrant further
review.
On March 8th, 2024, Nate, the petition
manager, contacted Diane Curran and Hallie Templeton
via email to inform you of the PRB's initial
assessment that the petition did not meet the MD 8.11,
Section III.C.1(b)(2) criteria for accepting
petitions. The PRB's initial assessment was not to
accept your petition for further review.
The concerns that were stated, or that
were evaluated from your petition --there were four
primary. One, that the license amendment issued by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 12
NRC staff to Pacific Gas and Electric, PG&E, by letter
dated July 20th, 2023, extending the schedule for
conducting surveillance of the Diablo Canyon 1
pressure vessel until 2025 poses an unreasonable risk
to public health and safety.
The second concern was that the Licensee
committed violations by not properly monitoring the
condition of the Diablo Canyon Unit 1 RPV, reactor
pressure vessel.
Three, that PG&E has repeatedly postponed
additional surveillance and testing of the pressure
vessel.
And four, that the Licensee should
implement Dr. Macdonald's independent analysis-based
recommendations regarding reactor pressure vessel
integrity.
In the email the petition manager informed
you that these concerns have previously been the
subject of facility-specific or generic NRC staff
review and that the petition does not provide
significant new information that the staff did not
consider in prior reviews.
The March 8th response also included that
Diablo Canyon Unit 1 reactor pressure vessel will not
reach the pressurized thermal shock screening criteria NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 13
in 10 CFR 50.61 until approximately the year 2032.
Also that the Licensee's current pressure
temperature limits documented in Revision 16(a) of its
pressure temperature limit report, or PTLR, are
applicable beyond the current 40-year operating
license period.
Three, that the final capsule required for
the current operating license period, Capsule V, was
withdrawn and tested which provided surveillance data
representative of the reactor vessel beyond the end of
its current 40-year operating license period.
And finally, while the PRB recognizes the
efforts by Dr. Macdonald highlighted in the petition,
the merits of the recommendations do not justify a
change to the NRC's already conservative approach to
assessing the integrity of the reactor pressure
vessel.
The petition manager offered you an
opportunity to address the PRB to clarify or
supplement your petition in response to this
assessment and you requested to address the PRB in
this forum.
As a reminder for all participants, please
identify yourself if you make any remarks as this will
help us in the preparation of the meeting transcript NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 14
that will be made publicly available. Thank you.
Diane Curran and Hallie Templeton, I will
now turn it over to you to provide any information you
believe the PRB should consider as part of this
petition. You have 50 minutes for your presentation.
Thank you.
MS. CURRAN: Thank you, Ms. Pelton. I am
Diane Curran. I represent San Luis Obispo Mothers for
Peace. And on the phone with us today is Hallie
Templeton, but I will be the attorney speaking for the
Petitioners. With me today also is Dr. Digby
Macdonald, who is our expert.
As you know, we are very concerned that
the pressure vessel for Diablo Canyon Unit 1 does not
meet NRC requirements for integrity and therefore we
asked the Commissioners to order the shutdown of the
facility pending testing of Capsule B. And that
petition was referred to the staff for consideration.
We still hold that view and we primarily wanted to
give Dr. Macdonald a chance to address you on our
technical concerns because of his great level of
expertise on these issues.
At the bottom we have legal concerns here.
As you know, we're in the Ninth Circuit challenging
the NRC's failure to treat the 2006 license amendment NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 15
as having effect in the -- on PG&E, that we believe
that license amendment which allowed PG&E to operate
Diablo Canyon for an extra three years to recapture,
quote/unquote, the term of low-power testing included
in it a requirement to remove Capsule B within the
current license term and included a finding by the NRC
that the data that has been collected so far,
including Capsule V, was credible and showed that the
reactor would approach the reference temperature
limits at or before the end of its operating license.
We've got that issue in the Ninth Circuit.
I don't think -- I don't see a point in discussing
the legal issues here, but there are six points that
Dr. Macdonald is going to discuss with you today. I
know we have 50 minutes. We would also like to leave
time for you to ask questions of Dr. Macdonald, so
we're going to try to keep it to a half an hour.
In brief, his six points are -- they
relate to: (A) the creditability of the data that has
already been -- from the capsules that have already
been removed; (2) the inappropriateness of relying on
the so-called sister data from Palisades; (3) that the
extension of the ultrasound testing deadline was in
fact significant and has an adverse effect on the
NRC's ability to assess the condition of the pressure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 16
vessel with respect to embrittlement; (4) that we
disagree with the PRB about the relevance of the
experience of the Belgian reactors; (5) the
possibility that hydrogen-caused embrittlement is a
factor affecting the integrity of the Diablo Canyon
pressure vessels; and then that Dr. Macdonald's own
calculations show that NRC and PG&E have not done an
adequate job of assessing embrittlement of the Unit 1
pressure vessel.
Therefore, we continue to advocate for the
immediate shutdown of the reactors and testing of the
samples from Capsule B.
With that, I will turn the discussion over
to Dr. Macdonald.
DR. MACDONALD: Good afternoon. My name
is Digby Macdonald. I was born and bred in New
Zealand, no nuclear reactors, and I came to the United
States after having worked at the Atomic Energy of
Canada Limited developing CANDU reactors. That was in
1977. I've held a variety of university positions at
Ohio State University, Penn State University, and
University of California at Berkeley from which I just
retired at the age of 80.
My involvement in nuclear energy has been
extensive for more than 50 years and it included the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 17
development of the CANDU nuclear reactor and the
issues related to activity transport and mass
transport of those reactors. And then when I came to
the United States I concentrated a lot on describing
the electrochemistry of the coolant in the boiling
water reactor and in pressurized water reactors.
And I just want to make sure that
everybody understands that in a pressurized reactor
you have a pressure vessel of a ferritic steel that is
clad with a very thin layer, seven millimeters
approximately of stainless steel. And that's in
contact with an aqueous solution which contains a lot
of hydrogen, 35 CCs per kilogram added to the
pressurizer. And not only that, that hydrogen is
radialized by both the gamma radiation and the neutron
radiation, and in the case of PWR the alpha radiation
from the boron reaction with neutrons. And those
processes result in very high concentration of atomic
Now hydrogen can enter the steel only in
the atomic form. And so under normal corrosion
conditions if you have a cathodic reaction that
produces what is called nascent hydrogen, that's
atomic hydrogen on the surface on the steel, part of
that hydrogen enters the surface of the steel and will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 18
cause hydrogen-induced cracking and hydrogen
embrittlement. And this has been a major concern and
still is a major concern in the oil and gas industry,
for example. In that industry they call that sulfide
stress corrosion cracking, but it's all the same
phenomenon of hydrogen-induced cracking.
I've worked on the theory of hydrogen-
induced cracking and the data derived models that are
quite capable of accurately calculating crack growth
rate under subcritical conditions. That is when the
stress intensity is lower than the fracture toughness
of the steel.
In the normal nuclear energy field, which
is dominated by mechanical engineers that tend to
concentrate a lot on the fracture toughness of the
material, but cracks grow at sub-fracture subcritical
conditions with a stress intensity factor of about 11
K1c. And that should always be taken into account
because those cracks eventually become long cracks and
if they have sufficient loading, K1 will exceed K1c and
you'll get sudden failure.
But what I've done really is to introduce
electrochemistry into nuclear reactor materials
concerns, and for that I was nominated this year for
the Fermi Award. I haven't heard whether I won it or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 19
not. I was nominated in 2011 for the Nobel Prize for
my development of the theory of passivity which
explains why we can use metals in contact with an
oxidizing environment. So I've taken a different tack
to describing phenomena that occur in nuclear reactors
and it seems to work very well.
I was retained by Mothers for Peace, San
Luis Obispo Mothers for Peace via Diane Curran to
provide some expert background on what was happening
in Diablo Canyon. And the literature is voluminous of
course and I must congratulate people such as Dr. Kirk
for the magnificent job that they've done in
describing fracture in these reactors.
I'd just like to add some additional
comments that I think should be considered. So let me
just pull up my -- so the first one relates to -- the
danger from Capsules S, Y and V were determined
credible by the NRC in 2006 license amendment
decisions and show that Unit 1 would approach or reach
an unsafe level of embrittlement at the end of the
current operating license term. And in fact that can
be found in Reg Guide 1.99, Revision 2. There's an
addendum to that revision written by Dr. Kirk which
lists the various reactors in the PWR fleet in the
United States and gives the values for the RTNDT, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 20
so-called reference temperature, in relationship to
the critical value of the RTPTS. And Diablo Canyon,
after the end of the 40-year operating period, is at
269 or so degrees, whereas the critical condition is
270 degrees.
Now let me say a word about these critical
conditions in the RTNDT. As shown by Easton,
Mitchell, and Odette in CF 6551, these quantities are
distributed quantities. In other words, if you had
somebody make measurement -- 100 measurements of each
at the same time, you'd get 100 different answers.
And if you were to plot those data, they would be
described by a normal distribution. Well, that is
what they claim. They don't actually demonstrate that
it's a normal distribution.
Anyhow, normal distribution is
characterized by a mean value, which is the average,
which is the value that's quoted in the literature and
in reports, and a standard deviation. And what is
missing from and puzzling me -- so what is missing
from all of this analysis is recognition that it's a
probability problem that is described by a standard
deviation in the mean. In fact two standard
deviations in two means, one for RTNDT and the other
for RTPTS. And so you can have RTNDT less than RTPTS, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 21
but the wings of the normal distribution will overlap.
And where they overlap that determines the
probability of failure. Or the probability of an
unacceptable condition, let me put it that way. But
it will.
So I've just done the calculation. In
fact, finished this morning in the wee hours. And
what I find is that for a Diablo Canyon 1 look-alike,
where I took as much of the data as I could from
Diablo Canyon 1 -- but I had to guesstimate some data
because some data were not available. At least I
couldn't find it. If you use data up to 30 years, the
measurement of RTNDT every 10 years, then you would
project to come within -- you'd be less than RTPTS,
but the wings of the distributions would go to that
and you calculate that the so-called failure
probability is 0.22.
And how this would be interpreted is as
follows: If you have a weld that is 100 centimeters
long in about 22 centimeters of that weld the RTNDT
equals or exceeds the RTPTS. So even though the
average value of RTNDT is less than the average value
for RTPTS. So it's a question of probability. And
that's not unusual. That phenomenon occurs all the
time in natural systems and in corrosion and in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 22
failure analysis and so forth. So I'm not introducing
any new concepts here. It's well-described
methodology in the literature. I just happened to
apply it to this particular problem.
So that's first, but there's some other
troubling things. When PG&E published the report on
the Capsule V, they declared all their data to be not
credible. And that allowed them to attempt to seek
further licensing via 10 CFR 50.61, I believe it is.
And so that's what they attempted to do. And what
they sought to do was to use data from a so-called
sister plant like Palisades.
But let me come back before I go onto the
Palisades issue and just point out that they declared
the data to be non-critical. Then in 2009, when they
wanted to get a 37-month extension, as Diane Curran
pointed out, the data became suddenly credible. Now
NRC had declared the data to be -- or deemed the data
to be credible in 2006, but I can find nothing that
PG&E did would have caused them to change their mind.
So this is somewhat troubling that an organization
would declare a set of data non-critical and then
later have it declared credible, want to use it argue
for a life extension. So that to me is somewhat
troubling personally.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 23
But now let's go to the sister plant.
They chose Palisades. Now if you look in the document
by Dr. Kirk, the RG 1.99, Revision 2, table 4 -- or 3
-- table 3, I think it is -- where he lists all the
reactors that have -- and gives the RTNDT and RTPTSs,
the RTPTS of Diablo Canyon, as I said before, was 269
degrees, 1 degree less than the critical condition.
But Diablo Canyon -- I'm sorry, Palisades had a value
of 322 degrees Fahrenheit, well over 100 degrees over
the -- well almost 100 degrees over the limit, the
critical limit.
And so in terms of the existing
embrittlement, in my opinion Palisades is much more
embrittled than is Diablo Canyon. As you know,
Palisades was shut down. Then it was bought by Holtec
International and nobody seems to know what Holtec is
going to do with it, whether they want to restart it,
maybe get the pressure vessel a thermal anneal and
then restart it. Nobody seems to know at this point.
So it was --it's not a very good sister
plant. For example, the plants are of completely
different design. The Diablo Canyon plant is a
Westinghouse PWR on a four loop design, which has four
heat exchangers for the one reactor core, whereas
Palisades has only two. So they operate quite NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 24
differently. And if you look at the operating
histories, which we've done by digging up data from
the International Atomic Energy Agency and
International Energy Agency and various other sources,
Diablo Canyon has been run more as the baseload-type
plant, whereas Palisades' startup/shutdown history is
chaotic, to say the least. And they had many, many
shutdowns to zero power, whereas Diablo Canyon has --
tends to have shutdowns to zero power only during
refueling. So they're quite different in their
operating histories. In their energy availability
they're quite different. So I've put together a lot
of data to show that.
I had in fact intended to have some
slides, but I just didn't have the time from when I
stopped working on doing the calculations on the
probability of failure until this morning.
So we would argue that Palisades is in no
way a sister plant, but there's also something other
-- something else which is a bit troubling. The way I
read the regulations PG&E was supposed to first of all
deal with the outliers according to letter GL 9201.
And if there's a good excuse for excluding any of the
outliers, they would -- they were to quantify what
that excuse was. Well, this is a normal procedure in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 25
science, by the way. And this was what the NRC was
insisting that they do. But we find no evidence that
they ever did that. Okay?
Now secondly, when they chose the sister
plant, they were supposed to make the case to NRC as
to why that plant was -- should be considered as a
sister plant, but we can't find an analysis of where
that was done. Now perhaps it was done and not
published publicly, which I would argue would be
improper, but it's certainly nothing that we can find.
I stand to be corrected if somebody knows where that
was published and done. I'd be more than happy to
have a look at it. But as things stand at the moment,
we're unable to find any case made by PG&E to NRC and
NRC's approval that Palisades should be considered a
sister plant of Diablo Canyon.
It's like the human race: I regard
Palisades perhaps at best as a (audio interference) or
a second cousin, but I don't consider it to be a twin.
And even if it was a twin, just as human twins have
the same genetic material, they grow up quite
differently and they lead quite different lives.
My wife for example is a twin and she
excelled and became a professor of nuclear physics in
France and then a professor of engineering science and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 26
mechanics at Penn State University when we were there,
yet her sister did not excel in anything that she
tried. And so the operating experience, both in human
beings and in complex systems like nuclear reactors,
say that you have to be very careful in choosing what
you believe to be a sister plant, okay, because the
operating history essentially determines the
properties of the system. And the operating histories
of those two plants are quite different and therefore
they should not be regarded as being twins.
Now we believe that UT inspections, as
they were scheduled over 10 years and not carried
about by PG&E for 20 years, are very valuable
inspections to have because what they detect is the
formation of voids, fissures in the belt line region
due to embrittlement. So the embrittling process
itself involves knocking metal atoms out of their
normal atomic positions, and those metal atoms are
hot. That is, they have a lot of energy and they move
through the lattice like a bull in a china shop.
And they knock other atoms out of position
and so forth and you get a cascade of atoms produced
and you also --a cascade of vacancies. Now some of
these vacancies are annihilated by the atoms jumping
back into the vacancy to become an atom in a normal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 27
atomic position from there being an institution. But
many of the vacancies will diffuse quite rapidly
through the lattice until they find a free surface.
And the free surface may be at some metallic
inclusion, for example, such as a manganese sulfide or
maybe an intermetallic compound, a nickel/copper or a
nickel/iron, or copper/iron, which by the way explains
a lot, the debilitating effect of copper and nickel in
Anyhow, they combine and they form voids.
And if these voids are platelet shaped, as they
usually are, they have a sharp edge at the periphery.
Like a flying saucer they have a sharp edge around
the periphery. And if they are then loaded with a
thermal stress or a load due to a thermal stress
resulting from a loss of coolant accident, for example
with cold water suddenly being pumped into the reactor
so that you get the pressurized thermal shock problem,
because once you've got pressure being applied, then
you can exceed 0K1sec, the stress intensity factor for
slow crack growth.
And these cracks will grow slowly and
their size, where the K1 equals K1c fracture toughness,
then the crack will grow unstable. In fact, it may
lead to failure and you get a characteristic bang, as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 28
we all must have heard if you drop a glass on the
floor. And that is caused by the shockwave of a
fracture moving through the material. That is
significant fraction at the speed of sound. So
these events, these platelets form in a very
embrittled material, that is a material that is
approaching the RTPTS limit. And so it's very, very
important that we in fact are able to detect these.
Now I bring up the Belgian experience, what
Professor Walter Bogaerts at the University of Leuven
in Belgian -- he's an old friend of mine. He asked me
to team with him to look into the Doel 3 and Tihange 2
issue.
Now many of you may know that these
reactors were built -- the pressure vessels were
fabricated by a Dutch company, and I won't attempt to
pronounce the name, that has since gone out of
business. But the argument is that they forged the
ingots into the rings for the reactor pressure vessel
in a very humid environment. The moisture, HDO,
reacted with iron to give you hydrogen plus iron
oxide, and that hydrogen was retained by the steel.
And it diffused to where the manganese sulfide
inclusions had been smeared out by rolling the ingot
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along with smeared manganese sulfide inclusions.
And that is a characteristic form of
cracking, but it's also very characteristic of
hydrogen embrittlement. But nobody in Belgium, in
FANC, which is the equivalent of NRC -- they didn't
want to hear any of this. Okay? And neither did
Electrabel, the operator. They just didn't want to
hear. Not interested. Didn't want to hear.
But we did get the ultrasound examinations
and we found that not only the population of
indications increase with time, but also the maximum
size of the indications increase with time. To us
that meant growing cracks.
Now, they immediately responded to us by
saying, oh, no, no, no, no, no. Said the people are
using better UT examination. Now all of a sudden
they're finding more cracks. Well, maybe, but that --
they should be finding small cracks, not large or
larger cracks. Okay? Not large cracks that are
becoming even larger. They were characterized quite
well by previous examination.
So we wrote all this up and made our case.
They didn't even read it. Okay? They weren't
interested. They just wanted to produce electricity.
Well, they hired SCK CEN to carry out some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 30
experiments for them and that's the Belgian National
Laboratory, if you like. And the Belgian National
Laboratory people contacted the reactor operator and
said, you know, there's something really funny about
this steel. And it seems that they found evidence
that what we had concluded was probably quite true.
But nobody published it. It was never put into a
report, certainly not the report that they ended up
with the NRC and was disseminated to reactor operators
in the United States.
So that was my experience. I don't see
anything that changed my experience with that, and
conclusions. In fact, I was in contact with Walter
Bogaerts just a few days ago just to make sure that
nothing had changed as far as he was concerned. He
said no, nothing has changed, but the experience that
you and I had with the Belgian reactors showed
different that there are active cracks growing.
And that's what you would expect when you
have hydrogen that is under radiolysis conditions and
separated from ferritic steel by a thin layer of
stainless steel. Hydrogen atoms go through stainless
steel. Okay? And so that needs to be done.
I've done a lot of work on modeling the
radiolysis of the coolants of PWRs and BWRs. In fact, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 31
I finished about three years ago a DOE basic energy
sciences project where I calculated all the radiolitic
conditions in pressurized water reactors and boiling
water reactors. And so we know a lot about the
chemistry of these reactors, and also the
electrochemistry, which is the driver of cracks. And
we've been able to predict cracking in the stainless
steel -- in the sense of stainless steel components in
BWRs very accurately.
We've modeled something like seven or
eight operating nuclear reactors in great detail,
predicted where cracking occurred. And we were very
successful in predicting for example cracking in the
core barrel, in the welds, the upper welds in the core
barrel. (Audio interference.) And we also were very
successful in calculating crack growth rate and the
conditions for crack growth rate for alloy 600 and
cold work stainless steel bolts, alloy 182, and these
gave rise to --the cracking of 182 gave rise to the
Davis-Besse problem where there was leakage of coolant
into the annulus between the reactor head and the
control rod drive tube.
And as many of you know, that resulted in
corrosion of the pressure vessel. In fact there was
an 18-inch diameter hole where the coolant was being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 32
held only by the stainless steel liner. Okay?
MS. RONEWICZ: Excuse me, Dr. Macdonald.
I don't want to interrupt at all. This is the
facilitator. I just want to give a gentle time
reminder that we're at 3:46 and I think you roughly
have about 10 minutes for questions. So I apologize
for interrupting.
DR. MACDONALD: Thank you. Okay. I'll
finish very quickly.
Okay. My calculations indicate that the
NRC and PG&E, in my opinion, have not done an adequate
job of addressing embrittlement. You can only monitor
embrittlement by making the appropriate measurements,
and that's the purpose of these surveillance programs.
And that reactor head started off with being
initially a five capsule program that got reduced to a
four capsule program. Then it became a three capsule
program and then it became a four capsule program with
the addition of Capsule B.
But they say they couldn't remove Capsule
B, which is held in by its own weight, or at least the
plug was held in by its own weight. There's no
corrosion occurring in this system that would result
in a thick oxide that would jam the plug in place. So
I'm at a loss as to why they couldn't take it out.
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And I've asked people has this problem ever occurred
elsewhere and nobody has been able to point it out
where it has. So we'll leave that one at that.
And so I believe that it's not so much
what has been done at Diablo Canyon that concerns me.
It's what hasn't been done. They did not follow the
regulations as they were written down. Now they would
appeal to get relief for a regulation and the NRC
would grant that appeal.
But people who run these reactors are
there to make money and things like surveillance
programs and regulations and so forth, they're often
viewed as getting in the way of the primary purpose,
which is to make money. But that is contrary to a
good safety strategy. And so, Lord forbid, we don't
need another accident in a nuclear reactor in the
United States because if it happens, you can kiss much
of the nuclear industry goodbye.
So I will end with that. And if you have
any questions, I'd be more than happy to answer them.
MS. PELTON: Thank you, Dr. Macdonald.
So I'd like to thank you and Diane Curran
for your presentations and for taking the time to
raise your concerns.
Oh, go ahead, Diane.
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MS. CURRAN: Yes, hi. Thanks.
MS. PELTON: Sure.
MS. CURRAN: And thanks, Dr. Macdonald.
I just wanted to conclude with two things:
First of all, some --just a couple of really minor
clarifications of what Dr. Macdonald said.
I think he referred to PG&E asking in 2009
for a three-year extension. Just want to clarify it
was 2006.
And also Dr. Macdonald referred to a table
3 in Reg Guide 1.99. And it's the regulatory analysis
that accompanied that Reg Guide where you will find
that table. I just wanted to clarify that.
And then one more thing, which is that Dr.
Macdonald has been corresponding with the Diablo
Canyon Independent Safety Committee about his
concerns. That is an arm of the Public Utilities
Commission. And in the next few days we are going to
be sending them a report that will discuss some of the
things that he's discussed here and we will share it
with the PRB. Thank you.
MS. PELTON: Thank you very much.
So again, thank you, Diane, thank you, Dr.
Macdonald for your presentations and comments and for
taking the time to raise your concerns.
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The regulations in 10 CFR 2.206 provide an
opportunity for the public to petition the NRC to take
enforcement-related action, and the NRC understands
that this process takes time and a lot of energy and
resources by the Petitioners.
With that, I will turn it over to our
facilitator for the question and comment portion of
this meeting.
Lynn?
MS. RONEWICZ: Okay. We will now go to
the question portion. First, we will ask if the PRB
has any questions for the Petitioner, then the
Licensee, if they are present, and then we will go to
members of the public. I will call on you by name in
order of hands raised. Please remember to speak
loudly and clearly, stating your name first. And if
you are affiliated with any entity, please state the
entity.
I you dialed in by phone, please raise
your hand by pressing star-5. And then once called
on, press star-6 to un-mute yourself.
So at this time does the PRB have any
questions for the Petitioner?
And we have a hand raised. Okay. Yes,
Robert Budnitz, please go ahead.
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MR. BUDNITZ: Hold on. Hello. Can you
hear me?
MS. RONEWICZ: Yes, we can.
MR. BUDNITZ: My name is Robert Budnitz.
I'm one of the three members of the Diablo Canyon
Independent Safety Committee that was just mentioned
three minutes ago and I want to make sure just to tell
you that I'm one of the members. I have listened to
this presentation. We have -- four of our consultants
are also listening to this presentation, too, and
we're trying to take it in so as to be sure we have as
much technical information as we can get. As we
interact, we -- as Digby Macdonald said, we intend to
be interacting with them sometime fairly soon on the
technical issues. Thank you.
MS. RONEWICZ: Okay. Do the PRB members
have any questions for the Petitioner?
(No audible response.)
MS. RONEWICZ: Okay. If not, if the
Licensee is present, does the Licensee have any
questions for the PRB related to the issues raised in
the petition?
(No audible response.)
MS. RONEWICZ: Okay. Does the Petitioner
or Licensee have any questions about the 2.206 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 37
petition process?
(No audible response.)
MS. RONEWICZ: Okay. And lastly, before
we conclude the meeting members of the public may
provide feedback regarding the 2.206 petition process,
however, as stated in the opening the purpose of this
meeting is not to provide an opportunity for the
Petitioner or the public to question or examine the
PRB regarding the merits of the petition request.
Please raise your hand if you have any
feedback or questions on the 2.206 process at this
time.
Okay. Yes, Kevin Kamps, please go ahead.
MR. KAMPS: Hello. Can you hear me?
MS. RONEWICZ: Yes.
MR. KAMPS: Okay. This is Kevin Kamps
with Beyond Nuclear and also Don't Waste Michigan, and
I just wanted to express our full support for the
efforts of Dr. Digby Macdonald and Diane Curran and
San Luis Obispo Mothers for Peace.
We've been watchdogging the embrittlement
of the reactor pressure vessel issue at Palisades in
Michigan for many decades and we finally got the
Nuclear Regulatory Commission to admit in writing in
April of 2013 that Palisades was the worst embrittled NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 38
reactor in the country. Diablo Canyon Unit 1 was
among the top five and now the top four because one of
those, Indian Point Unit 3, has permanently closed
thankfully.
And this is a tremendous safety risk and
we fully support the efforts that went into this
emergency enforcement petition. And I'd like to
express my gratitude to all those who have worked so
hard to bring it forward. Thank you.
MS. RONEWICZ: Thank you, Kevin.
DR. MACDONALD: Thank you.
MS. RONEWICZ: Are there any other
questions?
(No audible response.)
MS. RONEWICZ: Okay. Well, we'll give it
about 30 seconds just to see. And in the meantime --
so feel free to raise your hand if you have question
on the 2.206 process.
I would like to ask though at this time
does the court reporter need any additional
information for the meeting transcript?
COURT REPORTER: No, thank you.
MS. RONEWICZ: Okay. And I'd also like to
point out while we're waiting to see if there are any
other questions or comments that we encourage the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1716 14th STREET, N.W., SUITE 200 (202) 234 -4433 WASHINGTON, D.C. 20009-4309 www.nealrgross.com 39
participants outside the NRC to provide public meeting
feedback to the NRC staff via the NRC public meeting
web site. A link will be posted shortly after the
conclusion of this meeting.
So again, we're at five minutes to 4:00.
We do have a little time left. Are there any other
questions or comments?
(No audible response.)
MS. RONEWICZ: Well, it appears there are
not. So I believe we will go ahead and close out this
meeting and we appreciate everybody who joined.
DR. MACDONALD: Well, thank you very much
for giving me the opportunity.
MS. RONEWICZ: Thank you.
MS. PELTON: Thank you very much.
Appreciate it.
MR. JORDAN: Thanks so much and great job,
facilitator.
MS. RONEWICZ: Thank you.
MS. PELTON: Thank you.
(Whereupon, the above-entitled matter went
off the record at 3:56 p.m.)
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