ML17111A774
| ML17111A774 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 04/13/2017 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| References | |
| NRC-3007 | |
| Download: ML17111A774 (47) | |
Text
I ::: ', ' ,I, ,' Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION Title: Docket Number: Location:
Date: Work Order No.: 10 CFR 2.206 Petition Review Board RE Braidwood and Byron NGS (n/a) teleconference
- Thursday, April 13, 2017 NRC-3007 loRIGINALI NEAL R. GROSS AND CO., INC. Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W. Washington, D.C. 20005 (202) 234-4433
(' Pages 1-45 1 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 5 CONFERENCE CALL 6 RE 7 BRAIDWOOD AND BYRON NUCLEAR GENERATION STATIONS 8 + + + + +
9 THURSDAY 10 APRIL 13, 2017 11 + + + + +
12 The conference call was held, Christopher 13 Miller, Chairperson of the Petition Review Board, 14 presiding.
15 16 PETITIONER:
BARRY QUIGLEY 17 18 PETITION REVIEW BOARD MEMBERS 19 CHRISTOPHER MILLER, Director 20 Division of Inspection and Regional 21 Support, Office of Nuclear Reactor 22 Regulation 23 JOEL WIEBE, Petition Manager for 2.206 24 petition, Division of Operator and 25 Reactor Licensing (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 2 1 KAIHWA (ROBERT)
HSU, Senior Mechanical 2 Engineer, Division of Engineering 3 STEVEN JONES, Senior Reactor Systems Engineer, 4 Off ice of Nuclear Reactor Regulation 5 MOLLY Human Factors Specialist, 6 Division of Inspection and Regional 7 Suppqrt, Office of Nuclear Reactor Regulation 8 EMILY MONTEITH,
- Attorney, Office of the 9 General Counsel 10 ERIC OESTERLE, Chief, Reactor Systems Branch, 11 Off ice of Nuclear Reactor Regulation 12 AHSAN SALLMAN, Senior Reactor Systems 13 Engineer, Office of Nuclear Reactor 14 Regulation 15 16 NRC HEADQUARTERS STAFF 17 MERRILEE BANIC, Petition Coordinator, 18 Off ice of Nuclear Reactor Regulation 19 20 21 22 23 24 25 NEAL R. GROSS (202) 234-4433 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. :20005-3701 (202) 234-4433 3 1 ALSO PRESENT 2 RUSSELL ARRIGHI, Office of Enforcement 3 BRUCE BARTLETT, Project Engineer, Region III 4 JOHN FREEMAN, Corporate Licensing, Exelon 5 Corporation 6 DAVID GULLOTT, Corporate Licensing, Exelon 7 Corporation 8 JAMES HELLER, Allegation Coordinator, Region 9 III 10 MARK JEFFERS, Engineering Branch Chief, 11 Division of Reactor Safety, Region III 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS (202) 234-4433 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, O.C. 20005-3701 (202) 234-4433 4 1 P R 0 C E E 0 I N G S 2 (1:34 p.m.) 3 MR. WIEBE: Okay, this is Joel Wiebe at 4 NRC Headquarters.
You are on the telephone call to 5 discuss the Barry Quigley 2.206 Petition dated 6 February 8, 2017. 7 Just want to check to make sure, Barry, 8 are you on the line? 9 MR. QUIGLEY:
Yes, I am, Joel. 10 MR. WIEBE: Okay, okay, thanks. 11 We' 11 continue here. My name is Joel 12 Wiebe. I am the NRC Petition Manager for this 13 Petition.
14 We are here today to allow the Petitioner, 15 Barry Quigley, to address the Petition Review Board 16 regarding his 2.206 Petition dated February 8, 2017. 17 As part of the PRB' s review of this 18 Petition, Mr. Quigley has requested this opportunity 19 to address the PRB. 2 0 The meeting is scheduled from 1: 3 0 to 3: 3 0 21 Eastern Time. The meeting is being recorded by the 22 NRC Operations Center and will be transcribed by a 23 court reporter.
The transcript will become a 24 supplement to the Petition.
The transcript will also 25 be made publically available.
(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 5 1 I'd iike to open this meeting with 2 introductions.
3 The Petition Review Board Chair is 4 Christopher Miller. And Chris is the Director of the 5 Division of Inspection and Regional Support in the 6 Office of Nuclear Reactor Regulation.
7 I'd like the rest of the Petition Review 8 Board to introduce themselves.
As we go around the 9 room, please be sure to clearly state your name, your 10 position and the office that you work for within the 11 NRC for the record. 12 I'll start off, I'm Joel Wiebe, I'm the 13 Petition Manager for this Petition and I work in the 14 Division of Operator Reactor Licensing.
15 MR. MILLER: And I'm Chris Miller. I'm 16 the Petition Chair. I'm the Director of the Division 17 of Inspection Regional Support in the Off ice of 18 Nuclear Reactor Regulations.
19 MS. KEEFE-FORSYTH:
I'm Molly Keefe-20 Forsyth.
I'm a Human Factor Specialist Subject Matter 21 Expect for Safety Culture and Safety Conscious Work 22 Environment.
I work in the Division of Inspection and 23 Regional Support in the Off ice of Nuclear Reactor 24 Regulations.
25 MS. MONTEITH:
I'm Emily I'm an (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 6 1 attorney in the Office of General Counsel.
2 MR. HSU: I 'm Robert Hsu and I 'm the 3 Senior Mechanical Engineer in the Division of 4 Engineering.
5 MS. BANIC: Lee Banic, 2.206 Petition 6 Coordinator in the Office of Nuclear Reactor 7 Regulation.
8 MR. SALLMAN:
My name is Ahsan Sallman.
9 I'm the Senior Reactor Systems Engineer in the NRR. 10 MR. JONES: Steven Jones, Senior Reactor 11 Systems Engineer and Develop Plan Branch, Off ice of 12 Nuclear Reactor Regulation.
13 MR. WIEBE: And we've completed the 14 introductions of NRC staff at the NRC Headquarters.
15 Do we have any regional personnel on the 16 line? 17 MR. JEFFERS:
Yes, this is Mark Jeffers, 18 the Engineer Branch Chief in the Division of Reactor 19 Safety from Region III. 20 MR. BARTLETT:
This is Bruce Bartlett, 21 Project Engineer, Region III. 22 23 Coordinator.
24 25 on the line? (202) 234-4433 MR. HELLER: And Jim Heller, Allegation MR. WIEBE: Okay. Is the Court Reporter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 7 1 COURT REPORTER:
Yes, the Court Reporter 2 is on the lirte. 3 MR. WIEBE: Okay. If there are any 4 licensee personnel on the line, I would like eacp of 5 you to email me your name, position and organization 6 and likewise for any public people on the iine: 7 It is not required for members of the 8 public to themselves, but if there any on 9 the phone that wish to do so, email me your name and 10 organization if it's applicable.
11 My email is joel.wiebe@nrc.gov.
12 Mr. Quigley, would you introduce yourself 13 for the record? 14 MR. QUIGLEY:
Yes. Barry Quigley.
I'm an 15 employee of Exelon Generation and I'm in Rockford, 16 Illinois.
17 MR. WIEBE: Okay. I'd like to emphasize 18 that we each need to speak clearly and loudly to make 19 sure the Court Reporter can accurately transcribe the 20 meeting.
21 If you do have something you would like to 22 say, please first state your name for the record. 23 We also ask you to minimize any side 24 conversations during the meeting.
We will try to have 25 only one speaker at a time. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433
,---8 1 For those dialing in to the meeting, 2 please remember to mute your phones to minimize any 3 background noise or distractions.
If you do not have 4 a mute button, you can mute by pressing the keys star 5 six. To unmute, you press the star six keys again. 6 At this time, I will turn it over to the 7 PRB Chairman.
8 MR. MILLER: This is Chris Miller and we 9 have one more joining us at the Headquarters Office. 10 MR. OESTERLE:
Yes, thanks, Chris. This 11 is Eric Chief at Reactor Systems Branch in 12 NRR. 13 MR.
Thank you, Eric. 14 Did anybody else join us on the phone that 15 we haven't identified or that wishes to have their 16 name on the record here? 17 MR. ARRIGHI : Yes, this is Russell 18 Arrighi, Office of Enforcement.
19 MR. MILLER: Thank you, Russ . Okay, thank 20 you. 21 Again, my name is Chris Miller and I want 22 to welcome you and thank you, Mr. Quigley, for 23 bringing us --bringing these issues to our attention.
24 And thank you for all the participants 25 that are here and to help us work through these (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 9 1 issues. I appreciate it. These are issues that are 2 important issues. But, you've got a lot of other 3 important issues, so I appreciate your time and the 4 use of it and we'll try to work through this process 5 efficiently and get to the details as best we can in 6 an efficient manner. 7 First, let me share some background on the 8 process.
9 Section 2. 206, that's Title 10 of the Code 10 Federal Regulations, describes the Petition process.
11 And, I think, Mr. Quigley, you're aware of the way of 12 it. Let me just cover in very short order. 13 It's a primary mechanism for the public to 14 request enforcement action by the NRC in a public 15 process.
This process permits anyone to Petition NRC 16 to take enforcement type action related to NRC 17 licensees or license activities.
18 Depending on the results of the 19 evaluation, NRC could modify, suspend or revoke an NRC 2 O issued license or take any other appropriate 21 enforcement action to resolve a problem.
22 Tpe NRC staff's guidance for the 23 disposition of 2.206 process is located in our 24 Management Directives, that's Management Directive 25 8.11, which is also publically available.
(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433
- l. 10 1 The purpose of today's meeting is to give 2 you, Mr. Quigley, the Petitioner, an opportunity to 3 provide any additional explanation or support for the 4 Petition before us, the Petition Review Board's 5 initial considerations and recommendations.
6 A couple things that merit mentioning, 7 this is not a hearing nor is it an opportunity for the 8 Petition to question or examine the PRB on the merits 9 of the issues presented in the Petition Request.
10 No decisions regarding the merits of this 11 Petition will be made at this particular meeting.
12 Following the meeting, the Petition Review 13 Board will conduct its internal deliberations.
So, 14 we're really just trying to get the best information 15 that we can with your help, Mr. Quigley, to be able to 16 conduct those internal deliberations.
17 The outcome of this internal meeting will 18 be discussed with you, Mr. Quigley, the Petitioner.
19 The Petition Review Board consists of 20 myself as Chairman, usually the Manager at the Senior 21 Executive Service level of the NRC. 22 We help the Petition Manger who has been 23 identified as Petition Review Board Coordinator, and 24 you've heard both of them identify themselves.
25 Other Members of the Board are determined (202) 234-4433 NEAL R. GROSS COURT REPORTERS ANO TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 11 1 by the NRC staff based on the content of the 2 information in the Petition Request.
The Members have 3 already introduced themselves.
4 .And so we try to bring, you know, the best 5 knowledgeable people on the specific issues that are 6 brought up together.
They're experts in their areas 7 to be able to render decisions there. 8 As described in our process, the NRC staff 9 may ask clarifying questions in order to better 10 understand, Mr. Quigley, your presentation and to 11 reach a reasoned decision whether to accept or reject 12 the Petitioner's request for review under the 2.206 13 process.
14 Also, as described in that process, the 15 licensee has been invited to participate in today's 16 meeting to ensure they understand the concerns about 17 their facility or activities completely.
18 Have any other members besides the ones 19 identified members for the licensee staff? 20 MR. WIEBE: There may be some on here. 21 MR. MILLER: Okay, we have none that have 22 identified themselves, let's put it that way. 23 Also, as described in our --okay --while 24 the licensee may ask questions to clarify the issues 25 raised by the Petitioner, I want to stress that (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 12 1 licensee is not part of the PRB' s decision making 2 process.
3 When we talk about an internal
- meeting, 4 we' re talking about the NRC experts and the Board 5 Members getting together and having that discussion 6 and there are no other members of the public or 7 members of the licensee staff that participate in 8 that. 9 So, I want to summarize the scope that --10 with those kind of background
- comments, the next area 11 I want to summarize the scope of the Petition under 12 consideration.
13 And from our read, we think the Petition 14 identifies four concerns, the analysis of for 15 the main steam isolation valve room pressurization 16 following the high energy line break is deficient.
17 Next one of the concerns is the that the 18 corrective action to resolve an issue in the analysis 19 of record are long overdue, eight years and improperly 20 tracked.
21 Number three is a proposed revision to the 22 analysis of record shows that the MSIV room slabs will 23 be injected by the high pressures in the MSIV rooms 24 becoming potential missiles.
25 And number four is engineering management (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 13 1 is dismissive of dissenting views such that 2 opera:Pili ty issues are not promptly addressed and 3 safety conscious work environment is not assured.
4 As a reminder for the phone participants, 5 please identify yourself if you make any remarks and 6 this will help us in preparation of the transcript 7 which we noted earlier that will be made publically 8 available.
9 Since this is a public meeting, I would 10 like to remind the PRB Members, licensees, the 11 Petitioner and other meeting participants of the need 12 to refrain from discussing any NRC sensitive or 13 proprietary information during today's meeting.
14 And now, Mr. Quigley, I'll turn the 15 discussion over to you to allow you the opportunity to 16 provide any information you believe the Petition 17 Review Board should consider as part of this Petition.
18 MR. QUIGLEY:
All right, thank you. 19 I would like this to be interactive.
As 20 we go through the points, if any of the staff have 21 questions, I'll be happy to address them. 22 I would note that the supporting 23 documentation for this Petition runs through several 24 thousand pages, so I may not be able to properly 25 answer a question, but I will be able to get back with (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 14 1 the staff. 2 MR. MILLER: Okay, I appreciate that. 3 MR. QUIGLEY:
Okay. I do believe this 4 Petition introduces new and significant information 5 that the NRC has not been aware of. 6 And just going through each of the points, 7 the analysis of record is deficient in a couple of 8 points. 9 I sent the FSAR sections to the staff as 10 part of the Petition and the analysis that supports 11 that FSAR is deficient for two reasons.
12 In 1996 when we did our steam generator 13 replacement
- project, we had a vendor calculate new 14 massive energy releases for the new steam generators.
15 And in doing so, they improperly extracted 16 from the RELAP probe the internal energy instead of 17 the enthalpy.
And, the internal energy is about 13 18 percent less than the enthalpy.
And, that is a 19 significant defect in the calculations.
20 Another one with the analysis of record is 21 the failure to use a secondary side volume of the main 22 steam piping. 23 It may come as a surprise, but there's 24 roughly 11,000 to 12,000 cubic feet of steam in the 25 steam lines whereas the individual generator has a (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 15 1 volume of 5, 000 cubic feet or so. So, it's very 2 significant.
3 And when we did the steam line break 4 inside the containment
- analysis, that volume was 5 included.
6 When the reanalysis was redone in 2013, we 7 contracted with another company to provide the mass 8 energy releases and they did use the volume in tpe 9 piping which caused the room pressurization rates to 10 go up a fair amount. 11 So, those are the two significant things 12 with the analysis of record. 13 MR. MILLER: I'm sorry, could I just ask 14 you a clarifying question there? 15 MR. QUIGLEY:
Who's speaking, please? 16 MR. MILLER: I'm sorry, this is Chris 17 Miller asking a clarifying question.
18 So, what you' re saying in --you' re saying 19 it was previously used the volume in the secondary 20 side and then in 2013, it was also used but then 21 eventually that got taken out or help me out with that 22 second part about 2013. 23 MR. QUIGLEY:
Well, the inside containment 24 steam line break, for the inside containment steam 25 line break, we used the volume of the external (202) 234c4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 16 1 secondary piping because it will feedback in in the 2 containment.
So, it was used properly there. 3 However, in our original analysis of 4 record, it was not used for the outside containment 5 break. 6 MR. MILLER: Okay. 7 MR. QUIGLEY:
And then we had a contractor 8 in 2012 that calculated new mass end releases and when 9 they did that, they did properly use, in my view, 10 properly, the external secondary piping. 11 And when they did so, that additional 12 energy of the pressure in the rooms to go up 13 substantially.
14 Does that clarify your question?
15 MR. MILLER: Yes. So, you believe that 16 the calculations that were done ip '12 and '13 were 17 done properly?
18 MR. QUIGLEY:
With regards 19 (Simultaneous speaking.)
20 MR. QUIGLEY:
It was done better. 21 MR. MILLER: Okay, okay. 22 MR. QUIGLEY:
There's some other minor --23 MR. MILLER: Okay, got it. Thank you, 24 that's all I was just tryirig to --I was just trying 25 to get that clarification.
Thank you. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 17 1 Go ahead, I'm sorry, I'm just trying to 2 MR. QUIGLEY:
No, this is a very, very 3 complicated issue. We have four vendors involved.
It 4 spans, you know, 20 years so it's very difficult to 5 follow. So, questions are not a problem at all. 6 MR. MILLER: Thank you. 7 MR. SALLMAN:
Excuse me, this is Ahsan 8 Sallman.
9 Is this calculation that was done a 10 revised calculation became the analysis of record or 11 not? 12 MR. MILLER: You' re talking about the 13 2013? 14 MR. SALLMAN:
Yes, the new calculations 15 that was done? 16 MR. QUIGLEY:
That is not the analysis of 17 record. The one that shows was just last looking, not 18 the analysis of record. 19 MR. SALLMAN:
It did not become the 20 analysis of record? Okay. 21 MR. QUIGLEY:
Basically, Exelon did not 22 like the results and kind of didn't do a whole lot 23 with it. 24 25 for that? (202) 234-4433 MR. SALLMAN:
So, what was their rationale NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS
. 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 18 1 MR. QUIGLEY:
The rationale for that was 2 that they didn't believe a double-ended guillotine 3 break in tl;le MSIV room was part of the current 4 licensing basis. 5 In my --in concern number four I I explain 6 that a little bit more about their basis. 7 MR. SALLMAN:
But the break in the --I'm 8 sorry, this is Ahsan Sallman again. Was the break 9 assumed inside the main steam valve room or outside?
10 Is there a --is that a part of the room, inside the 11 room or outside?
12 MR. QUIGLEY:
The analysis of record that 13 licensed us in the days assumed a double-ended 14 break inside the room. 15 MR. SALLMAN:
Okay, that was the new 16 analysis, okay. 17 MR. QUIGLEY:
And then that was also used 18 for the new analysis.
And then we --Exelon did not 19 like the results so they began questioning whether a 20 double-ended break was required or not. 21 22 23 Okay, since 24 25 (202) 234-4433 MR. SALLMAN:
Thank you. MR. HSU: Also, can I ask you a question?
MR. QUIGLEY:
What's your name? MR. HSU: Robert Hsu. Okay, so --and in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 19 1 the --at the UFSAR analysis, there's an assumption at 2 the doors and the HAV chamber in the upper chamber of 3 the barred room are initially assumed the cones are 4 intact. At the differential pressure equal to 1. 5 psi 5 where flow opened the door and the panel to --6 So, if this applies to you, and then, how 7 could the room be pressurized to 1185 psi? Because, 8 they say if the differential pressure it just equals 9 1. 5 psi. Your panel is compromised.
Your door is 10 open completely to that ATM. 11 So, if that apply to this calculation?
12 MR. QUIGLEY:
The fact that the 13 MR. HSU: This is at 3616-3S.
14 MR. QUIGLEY:
The blow out panels do blow 15 out, but the area provided is not sufficient to fully 16 vent, therefore, the pressure of the room keeps going 17 up to be around, you know, 25 pounds or* so. 18 MR. MILLER: Does that answer your 19 question?
20 MR. HSU: Yes, but this answers the 21 question, but this creates another thing. Okay? He 22 already has a vent, so are you --but, so, given your 23 calculation, okay, did not consider this vent? 24 25 (202) 234-4433 MR. QUIGLEY:
It does consider the vent. MR. HSU: They did consider or they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, O.C. 20005-3701 (202) 234-4433 20 1 didn't? 2 MR. QUIGµEY:
Yes, they did. 3 MR. HSU: The new analysis or record 4 was discarded the Exelon did consider the vent to be 5 open during this transient, right? Is that correct?
6 MR. QUIGLEY:
Yes. 7 MR. HSU: Okay, okay, thank you. 8 MR. MILLER: Okay, please continue.
We'll 9 keep on asking the questions when we need a little bit 10 more clarity, but I appreciate your helping us get 11 through it. 12 MR. QUIGLEY:
Yes, like I said, it's very 13 difficult.
So, that's why I'm saying that the 14 analysis of record is deficient.
15 Moving on to the second one, it's 16 relatively simple. In 2008, it was recognized that 17 the internal energy instead of the enthalpy was used 18 in .the analysis of record at that time. 19 And, so, an IR was written,
- however, no 20 corrective action was made to resolve the issue and 21 the analysis of record still contains the non-22 conservative break. 23 MR. MILLER: Just back up, you said 24 something was written, what was written?
25 (202) 2344433 MR. QUIGLEY:
A condition NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 21 1 MR. MILLER: Oh, okay. 2 MR. QUIGLEY:
Yes. 3 MR. MILLER: Thank you. 4 So, they recognized the problem back in 5 2008, documented it in a CR and they have not taken 6 action to correct that? 7 MR. QUIGLEY:
Correct.
8 MS. KEEFE-FORSYTH:
This is Molly Keefe-9 Forsyth.
Have they --did they close that CR? 10 MR. QUIGLEY:
It got closed to another 11 action and I diq not follow it. I did not follow the 12 trail completely, I simply based my statement on, I 13 can look at the analysis today and see that's it's not 14 been corrected.
15 MR. MILLER: Got it. So, you're haven't 16 followed the CR trail, but between 2008 and now, the 17 same error still exists in the --or the analysis of 18 record? 19 MR. QUIGLEY:
Yes. 20 MR. KEEFE-FORSYTH:
This is Molly, again. 21 Have there been anymore CRs written on 22 this issue? 23 MR. QUIGLEY:
There have been --on the 24 exact issue of using the internal energy instead of 25 enthalpy, there have been no new IRs. There have been (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 22 1 other issues related to high energy line breaks, but 2 nothing directly related to this. 3 MS. KEEFE-FORSYTH:
Okay, thank you. 4 MR. QUIGLEY:
Yes. All right --5 MR. MILLER: Go ahead. 6 MR. QUIGLEY:
moving on to --yes, yes.
7 MR. MILLER: Yes, no, I think that's all 8 the questions we have from here on those two issues. 9 MR. QUIGLEY:
That's a hard one to argue. 10 MR. MILLER: Yes, yes. 11 MR. QUIGLEY:
I don't mean it that way, 12 like an argument.
I'm just saying it's very, in my 13 view, it's what it is. 14 So, the next one is the main steam 15 isolation valve roof slab injections.
16 Vendor one, which was Sargent & Lundy, was 17 contracted in late 2013, early 2014 to revise the 18 analysis of record. And they used massive energy 19 releases that were provided by Fauske & Associates.
20 When they put those --well, let me back 21 up. So, that's what they did. And then Sargent & 22 Lundy had done some work for us in 2005 or 2008 with 23 tornados and the ability for the roof slabs to be 24 lifted by a tornado.
25 They turned out that that wasn't the case, (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 23 1 but that did make Sargent & Lundy sensitive to the 2 fact that the roof slabs exist and they can move. 3 So, when they did their analysis on this 4 one, they used RELAP4 to do the pressurization 5 analysis.
And, when they did that, they determined 6 that the pressure in the room, even including the vent 7 area of the blowout panels was enough to cause the 8 slabs to lift out of their openings.
9 Basically, they're just set in, they're 10 not bolted down, they just rely on gravity.
11 And, then, they determined that the 5,000 12 pound slabs would be ejected with a velocity of 32 13 feet per second. And, in our FSAR, it clearly states 14 there are no credible secondary missiles flown from 15 the postulated break of piping. And, the vendor found 16 one. 17 There was quite a bit of disagreement 18 within Exelon as to the validity of these results.
19 And, the main point of contention was that Sargent & 20 Lundy had used a break location in the main steam 21 isolation room because that is what the analysis of 22 record had also used. 23 And, you know, I was in agreement that 24 Sargent & Lundy had indeed used the correct break 25 location.
(202) 234-4433 And not a whole lot was done with this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 24 1 issue. Basically, it just gqt tabled. There was 2 nothing driving it and so, it just sat. 3 In August 2015, I began FMLA to deal with 4 a medical issue and then in September, Exelon started 5 moving again and they contracted Enercon to perform a 6 new analysis for the main steam isolation valve room 7 to be --8 MR. MILLER: This was September of '15? 9 MR. QUIGLEY:
Yes. 10 MR. MILLER: Okay. 11 MR. QUIGLEY:
- So, the harsh view of this 12 is that Sargent & Lundy gave them results they didn't 13 like so they went to somebody else. 14 And then Enercon, you know, questioned 15 what break location to be used and Exelon directed 16 them to use a break location outside the main steam 17 isolation room. 18 And this break location and also a much 19 smaller break size. And, of course, when you use a 20 break outside the room with a smaller break, the --21 low and behold, the roof slabs did not lift. That 22 analysis has not been finalized yet, either. 23 MR. SALLMAN:
This is Ahsan Sallman.
24 You' re saying Enercon, right, is that the vep,dor three 25 that you --that's in your questions?
(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 25 1 MR. QUIGLEY:
Yes, and Enercon, yes. 2 MR. SALLMAN:
Enercon; okay. 3 MR. QUIGLEY:
Yes. 4 MR. SALLMAN:
So, they used smaller break 5 area? 6 MR. QUIGLEY:
Yes. 7 MR. SALLMAN:
How did they come up with a 8 smaller break area? Because the break area should be 9 the limiter times four, I guess, is that the limiter 10 break area times four? 11 MR. QUIGLEY:
That's correct.
12 MR. SALLMAN:
How did they --13 MR. QUIGLEY:
That's what I used. 14 MR. SALLMAN:
That is your --okay. And, 15 how did they come with the break area? 16 MR. QUIGLEY:
Exelon told them what to 17 use. And, Exelon basically picked the smaller break 18 area based on a question that came up during our 19 licensing and that's part of the Petition and they 20 interpreted that question to mean that no breaks were 21 required in the main steam isolation valve room. 22 MR. SALLMAN:
So, the two things you 23 mentioned, the break area was smaller and the other 24 thing is the user break outside the MSIV room so that, 25 obviously, that would not lift up any roof or (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 26 1 anything.
2 MR. QUIGLEY:
That's correct.
3 MR. BALLMAN:
Okay. Please go ahead, 4 thank you. 5 MR. MILLER: And can I just ask one thing 6 regarding the question that came up during licensing, 7 this was the Request for Additional Information from 8 the NRC I'm thinking, is that what you're saying? 9 MR. QUIGLEY:
Yes, that's correct.
10 MR. MILLER: And do you --did you provide 11 that in your information we have? Okay, yes, my 12 staff's telling me yes. 13 MR. QUIGLEY:
Yes. 14 MR. MILLER: Or the staff 1s telling me 15 yes. Okay, thanks. 16 MR. QUIGLEY:
Yes. 17 MR. HSU: Can I ask you a question?
This 18 is Robert Hsu from Division of Engineering.
19 Okay, you' re talking about a slab. In the 20 whole slab is solid, okay, during this pressurization.
21 And, so, you're talking about 510, okay, the roof, 22 okay, all together going to be ejected.
23 But, however, usually this was to be the 24 concrete, is that right? And, the concrete has a 25 corner collection.
Okay, it's --according to the ACI (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, O.C. 20005-3701 (202) 234-4433 27 1 code, okay, there's a special co+ner steel, okay, to 2 reinforce the corners.
3 And, so, when you reinforce the corners 4 and they if you pressurize this thing, okay, 5 basically, there's no way, okay, you cap say this 6 thing is going to be, okay, completely blown off, as 7 completely intact, okay. Because when you pressurize 8 that, okay, the weak point, okay, definitely going to 9 crack. The weak point is not this solid, okay, slab 10 according to the fact, it's going to crack first and 11 then concrete blow out. 12 MR. QUIGLEY:
Okay. I understand what 13 you're saying and I recognize that when I wrote this, 14 I was not as clear as I should have been. 15 When I say the roof slab, I'm not talking 16 about the entire roof. There are access points so --17 for the room. Basically, the --a portion of the roof 18 is removable.
You can come in with a crane, lift 19 these slabs and then access the room. 20 So, what I'm talking about :j_s not the 21 entire roof coming off, but one of the access slabs 22 that are just sitting there by gravity.
23 MR. HSU: Yes, because my point is, okay, 24 if this is a cracking open, actually, that's relieved 25 the pressure already.
And, so, the only thing like (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433
28 1 you say, okay, concrete, okay, blow up, okay, but 2 concrete blow out, okay, on the --as a missile.
But, 3 that's just small piece of concrete.
Okay? 4 It's blown up to the sky. As long as, 5 okay, which is nothing to hit the containment 6 building.
That's no safety issue at all. 7 MR. QUIGLEY:
This is 8 MR. HSU: If based on your calculations.
9 MR. QUIGLEY:
This is not the concrete 10 cracking, this is not a structural failure of the 11 concrete due to over pressurization.
12 What this is is, like I said, the roof has 13 basically, the roof has a big hole in it by design. 14 And, that hole is filled with a concrete slab, a 15 concrete plug, if you will, a plug, maybe that's a 16 better word to use. 17 And, when the room pressurizes, this plug 18 is what's being ejected.
19 MR. MILLER: Yes, I think we understand 20 that and maybe --this is Chris Miller and we may 21 be talking by each other, but I think we understand.
22 MR. QUIGLEY:
Okay. 23 MR. MILLER: And we can evaluate, you 24 know, our thoughts on that separately.
But, I guess 25 we understand.
(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 29 1 I thought I heard you say 5, 000 pounds and 2 then I heard 5,000 tons. 3 MR. QUIGLEY:
Yes, yes, I got that, too. 4 It's 5,000 pounds. 5 MR. MIJ;.iLER:
Five thousand pounds, so it 1 s 6 --these concrete plugs that are plugging the hole in 7 the roof are 5,000 pound each one is 5,000 8 pounds of concrete?
9 MR. QUIGLEY:
Yes. 10 MR. MILLER: Thank you. 11 MR. WIEBE: This is Joel Wiebe and also, 12 I think your statement in your Petition here, and 13 you're not saying or commenting on the safety 14 significance of this effect, but you say it's contra+y 15 to the FSAR that says there are no credible secondary 16 missiles formed from the postulated break of piping? 17 MR. QUIGLEY:
That's correct, that's the 18 point. 19 MR. WIEBE: That's your point and you have 20 not evaluated the safety significance of that at this 21 point? 22 MR. QUIGLEY:
No, I have not. 23 MR. MILLER: And more than that --this is 24 Chris Miller --more than that, you believe that they 25 --that the licensee
--that Exelon has not gotten an (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 30 1 evaluation of that, is that right? 2 MR. QUIGLEY:
They have not got ten an 3 evaluation because they don't believe it credible.
4 MR. MILLER: Okay. 5 MR. QUIGLEY:
So they' re not going to 6 evaluate it. 7 MR. MILLER: Okay. 8 MR. JONES: This is Steve Jones. Getting 9 to that credible point, now, you mentioned your --in 10 the incoming Petition that the --there's a, you know, 11 break exclusion zone definition and there's 12 contradictions in the FSAR about where --how far that 13 extends.
14 MR. QUIGLEY:
Yes. 15 MR. JONES: If it extends to the --as one 16 of the statements goes, to the latter pipe restraint 1 7 downstream of the MSIV, that is at the boundary of the 18 valve room, correct?
19 MR. QUIGLEY:
Correct.
20 MR. JONES: Okay. So, if there is no 21 break in that area, there would not be any ejection of 22 the plug. It's if you take the alternate assumption 23 of the break exclusion zone terminating at the 24 downstream well from the MSIV, then, you have a break 25 in the room and then you ejected these plugs? (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 31 1 MR. QOIGLEY:
That's correct.
2 MR. JONES: That's what --okay. 3 MR. SALLMAN:
Orie more, this is Ahsan 4 Sallman.
+s the Sargent & Lundy analysis that said 32 5 feet per second, is that a quality record in the 6 system in Exelon? 7 MR. QUIGLEY:
In Exelon? No, it has been 8 prepared and reviewed by a competent vendor, in 9 Appendix B program.
But, like I said, Exelon has not 10 accepted it into the system because they didn't like 11 the results.
12 MR. SALLMAN:
Thank you. 13 MR. QUIGLEY:
All right, now we come to 14 the most difficult one of my concerns and that is the 15 fact that actually management does not want to deal 16 with this issue. 17 So, basically, in 2014, I was the only 18 person that felt that, you know , a break was required 19 in the main steam isolation valve room. 20 There was a lot of pointing to this FSAR 21 question which I did not accept and I provided a 22 rationale.
And then, you know, the issue kind of 23 died. I got assigned other work, then I went on FMLA. 24 One thing I really want to point out in 25 the Petition, there's a typographical error. It says (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 32 1 I returned to work in late April of 2016, that was 2 actually 2015. 3 When I say back in April 2015, I was 4 assigned a high priority task that didn't complete 5 until October and then I started looking into on my 6 own initiative, you know, what had happened with this 7 break in this concern.
And I tried to, you know, push 8 this through.
I tried in 2016, December 2016, and it 9 didn't go anywhere.
10 And, finally, on January 27th, sent an 11 email to entering management where I pretty much laid 12 it out and I said, you know, the analysis of record 13 that is in the FSAR that we were licensed to assumes 14 a double-ended break in the room. 15 I mean, my logic is there, my logic is 16 sound. Sargent & Lundy is the one that did the 17 analysis, they said it's a double-ended break in the 18 room. And so, I thought that this email would kind of . 19 move things along finally.
20 And then, on January 31st, there was a 21 conference call with Byron & Briarwood Engineering.
22 And, I presented my rationale again and the Byron 23 manager pulled out the FSAR question and said, no, we 24 don't have to take a break in the room because this 25 question says we don't. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 33 1 I tolO. them that the question was not part 2 of the current licensing basis because it had not been 3 incorporated into the FSAR. And then, I, again, 4 pointed out that something is in the FSAR, it does say 5 that the break is in the room. 6 And without looking at the FSAR, without 7 considering the point, the managers just stated that 8 the information in the FSAR was excessive detail and 9 they directed that we take it out of the FSAR. 10 And I told them I'm not going to take it 11 out FSAR because I don't think it's appropriate.
And 12 then, he just told the Briarwood personnel on the call 13 to take it out of the FSAR. 14 Also, during this conference call, I 15 pointed out the discrepancy in the FSAR about where 16 the break exclusion zone is at. And, you know, this 17 discrepancy was just dismissed by saying, well, the 18 FSAR needs to be cleaned up and to remove the 19 discrepancies.
20 So, there's really not a whole lot of 21 rigor going into these conclusions.
They' re very 22 dismissive.
23 And, also, this is not an isolated 24 incident with this manager.
Less than a month 25 earlier, there was an operability concern regarding a (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 34 1 seismic qualification of safety related relays. And 2 as we worked through the issue, we had a seismic 3 engineer with about 30 years of experience questioning 4 whether the relay was adequately tested. 5 And there was some back and forth and then 6 it was ultimately determined that there was no 7 problem.
The manager relied on the statement from 8 somebody else that was demonstrably irrelevant.
And, 9 just, you know, pretty much, that was the end of the 10 issue. 11 So, management is not really 12 interested in some engineering.
Management is not 13 really interested in resolving
- problems, they' re just 14 interested in making them go away. 15 What questions are there on this last one? 16 MR. JONES: Steve Jones. Just stepping 17 back a little bit, what's your understanding of the 18 reason for the break exclusion zone in this section of 19 piping? 20 MR. QUIGLEY:
Why I believe it's required?
21 MR. JONES: Well, why is it in the Byron 22 & Briarwood licensing basis to have a break exclusion 23 zone in this area? 24 MR. QUIGLEY:
Well, the break exclusion 25 zone comes out of the Standard Review Plan 361 and (202) 234-4433 NEAL R. GROSS COURT REPORTERS ANDTRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 35 1 362. And, we were licensed to those criteria and they 2 do specify that the break exclusion zone extends to 3 the downstream weld of the MSIV. 4 And then, you know, and that ' s how we 5 licensed the plant. They' re very, very original 6 analysis assumed a break at the downstream weld inside 7 the MSIV room. 8 MR. JONES: Okay, so you're saying the 9 initial licensing was consistent with the Standard 10 Review Plan, and the FSAR statement about going to the 11 downstream or stream was added some later point or 12 incorrectly added? 13 MR. QUIGLEY:
It was added at the later 14 point. So, you know, that introduced a conflict.
15 You know, so, the way I look at it is, you 16 know, I've got an FSAR one place it says, you don't 1 7 have to take a break here, in another part of the 18 FSAR, it says you have to take a break here. 19 But then, when you look at what we 20 analyzed, what we analyzed and what we submitted to 21 the NRC was a break in the room. 22 MR. JONES: And that original break, 23 though, did not determine any ejection because it was 24 non-conservative with respect to the energy release 25 rate? Is that --(202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 36 1 MR. QT,JIGLEY:
the pressures 2 would have lifted the slab, it's just nobody even 3 thought about the slab lifting at that time. 4 MR. JONES: Okay. 5 MS. KEEFE-FORSYTH:
This is Molly Keefe-6 Forsyth.
I know that you said that there had been the 7 one, I guess you call them IRs written for issue 8 number two. And then, you said that there hadn't been 9 any issued since then but you knew that the issue 10 hadn't been resolved.
11 Have there been IRs written about any of 12 these other issues? I'm trying to get a sense for how 13 much --how often this has been raised. 14 MR. QUIGLEY:
Well, it was raised by me 15 because I was involved in 2008 with the --I didn't 16 write the IR but I was involved with the using the 17 wrong enthalpy.
18 MS. KEEFE-FORSYTH:
Okay. 19 MR. QUIGLEY:
Then, when the slab ejection 20 issue came up in 2014, nobody wanted to write an IR 21 because it was an unapproved calculation.
But, then, 22 we never did anything to resolve it. We didn't do 23 anything timely to resolve it. 24 And as far as the stuff in January, you 25 know, when I sent out this email, you know, the (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 37 1 manager did tell me that, you know, I could write an 2 issue report on it if I wanted, but, you know, he's 3 the manager.
So, if I write an issue report, he's 4 just going to say, well, it doesn't apply because of 5 this FSAR question.
And, nobody else is going to 6 question it, so I really didn't bother. 7 You know, at that point, I just decided 8 to, you know, submit the Petition.
9 MS. KEEFE-FORSYTH:
Okay. So, there 10 haven't been IRs written on this but hasn't done due 1+ to formal corrective action process of being 12 prioritized and tracked and trended here. 13 What about raising the issue above the 14 engineering manager?
Has it gone up to the plant 15 mapager or to site VP level? 16 MR. QUIGLEY:
No, and the reason is, I 17 mean, this is hard to --but, you know, I lack faith. 18 You know, Jim Heller's on the line, he could provide 19 you some, you know, some background.
20 I don't have a lot of faith in Exelon 21 management to resolve issues. This is my fourth 2. 206 22 Petition with them. And, probably, you ](now, 30 or 40 23 allegations in the last 25 years. They are just not, 24 in my view, they just want this to go away. 25 (202) 234"4433 MS. KEEFE-FORSYTH:
Okay. Have you spoken NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 38 1 with any of your other colleagues about these issues? 2 Do they --do you get a sense that they feel the same 3 way? 4 MR. QUIGLEY:
Yes. In point number four 5 where I talk about a conversation that was held a 6 month earlier about safety related relays, basically, 7 we came out of that meeting, you know, one of the 8 engineers, you know, commented that, to me, you know, 9 well, thanks for sticking up him because basically the 10 engineering manager was kind of steam rolling the 11 other two people and I was also in the room and I kind 12 of tried to call him out on it. 13 So, you know, other people do recognize 14 this, yes. 15 MR. MILLER: So, this is Chris Miller. 16 Could I just ask a little bit more into that, the 17 managers?
- Because, you indicated that, you know, 18 various statements and I'm not quoting you directly, 19 but engineering management has just, you know, 20 concerned with getting these things to go away but not 21 necessarily resolving them in a technical manner. 22 Would that --at what level is it? Is it 23 basically just one person like the engineering manager 24 or is it many levels of engineering manager or 25 anything more you can tell us about that? (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 39 1 MR. QUIGLEY:
It is a very longstanding 2 culture with Exelon. I wasn't prepared to go into a 3 lot of detail on it right now because I'd have to go 4 back to my notes and stuff. But, you know, this is a 5 longstanding concern I've had with Exelon management.
6 I've been interviewed by attorneys I don't 7 know how many times for Exelon. And, the --they just 8 want to make things go away, they don't want to deal 9 with them. 10 MR. MILLER: Thank you. 11 MR. QUIGLEY:
Other questions that people 12 would like to ask at this point? 13 MR. HSU: This is Robert Hsu. Okay, I 14 just had the question, okay, I've been thinking about 15 it. This is a generic design problem because Byron 16 and Braidwood, okay, that's a very standard 17 Westinghouse design, okay, for those plants that same 18 stage at the same time. 19 They're also usually, okay, when it's a 20 Westinghouse design, it 1 s a plant design which is 21 going to our prior to the second plant design. 22 So, if they have this problem, it's 23 difficult, do you think just going back to generic 24 design problem?
That's one thing. 25 (202) 234-4433 The second thing I would like to ask you, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 40 1 you really think, okay, this is a really a big safety 2 significant problem?
3 MR. QUIGLEY:
Well, first of all, for the 4 generic, of course, it applied to Byron & Briarwood. 5 I did do some --searched ADAMS and looking at other 6 plants FSARs and the whole high energy line break 7 outside containment was very, well, let's call it 8 fluid. 9 It was changing a lot from 72 to 81. And, 10 so, it's really going to be a type specific kind of 1i thing. And, plus, you know, others may have, you 12 know, analyzed breaks in the relay. I really wasn't 13 able to get a feel to whether it was generic or not. 14 As far as the safety significance, a 15 double-ended rupture is a very low probability event. 16 The safety significance here is a licensee who ignores 17 contrary information.
I think that's the biggest 18 safety significant thing. 19 And if they're doing it for this, what 20 else are they doing it for? So, I think that's where 21 the safety significance lies. 22 MR. HSU: Yes, why I asked this question 23 is because that, high energy line breaks, okay, 24 actually, internally in the Division of Engineering, 25 mechanical
- engineer, people look at this, okay, (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 41 1 because which was set about 40 years. 2 So, people based on their point of view, 3 okay, conceptual point of view says, hey, I can't use 4 as a backup, okay, greater than .1 got to be 5 considered and allow for stress. Okay? 6 MR. QUIGLEY:
Right, oh, yes. 7 MR. HSU: Point eight, that becomes 8 compute at that, but in reality, up to 40 years later, 9 okay, we already know, okay, these things is not going 10 to happen based on the current criteria.
11 Current criteria is even the accumulation 12 --I say accumulation, you suspect that because 1.0, 13 the pipe is not going to break at all. Just it's the 14 only impact is 1.0 where the potential crack 15 initiation, not even cracked through.
And then to 16 allow for ASME itself has said that cracks up to 3.5 17 safety factor. 18 So, internally, okay, we understanding, 19 okay, the criteria we set also have a little bit of 20 problems since these were set up about 40 years ago. 21 So, we were talking about it in this area. 22 Okay, safety plus the high energy line breaks that you 23 assume is like a pipe, it's like suddenly, 24 immediately, okay, both rupture.
But, in reality, all 25 the steel has already demonstrated, okay, they have (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, O.C. 20005-3701 (202) 234-4433 42 1 the crack stability.
Even they have a crack, they 2 are not going to create immediately, okay, rupture.
3 That's the point I'm talking about it. 4 MR. QUIGLEY:
Well, there is something
--5 MR. HSU: Your problem is not really the 6 safety in those types, it's like a regulatory 7 paperwork consistency type, is that right? 8 MR. QUIGLEY:
Yes, there's a difference 9 between reality and licensing.
Byron is licensed to 10 a deterministic basis. And, I refer to those as thou 11 shalt. Thou shalt take a break in that power license.
12 I'm aware of the O . 8 and usage factors and 13 so on. I would also like to point out, yes, they are 14 40 years old, but they' re also being used for the 15 APlOOOs.
So, it hasn't gone away yet. 16 So, I would be uncomfortable with this 1 7 issue of not being addressed because it's a low 18 probability event. I would say, you know, large break 19 LOCAs are a low probability event, but they're still 20 part of the licensing basis, the deterministic 21 licensing basis. 22 MR. HSU: Yes, I'm talking about that 23 because like you mentioned, okay, APlOOO. APlOOO 24 actually is the first line, it's the first time we 25 grant leak-before-break to same lot. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433
43 1 And they demonstrate, okay, there 1 s no way 2 you can have the sudden break and then --because a 3 leak-before-break break already at those criteria, 4 okay, you've got to show the crack stability.
5 MR. MILLER: I think we have that. I 6 think we have the information that he's quoting which 7 is that your concern, because the licensing basis and 8 what the plant was analyzed to says that they've got 9 to deal with the break. 10 And your point is that, while I'm not 11 dealing with the break if they haven't addressed it 12 and they show the tendency to not want to address it. 13 I think that's what I'm getting.
14 This is Chris Miller, by t4e way. 15 MR. QUIGLEY:
Yes. 16 MR. MILLER: Okay, other questions for 17 folks around the table here or OE which is another 18 Headquarters bunch and anybody there and then I 111 get 19 to the region for questions.
20 (No response.)
21 MR. MILLER: Okay, not hearing any more 22 from the folks here, regions, any questions for Mr. 23 Quigley?
24 25 (202) 234-4433 MR. JEFFERS:
No questions.
MR. MILLER: Okay, thank you. NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISL,AND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 44 1 If there are any representatives of the 2 licensee listening, do any of those representatives 3 have any comments?
4 MR. GULLOTT:
We don't have any comments 5 at this point. 6 MR. MILLER: Okay. 7 MR. GULLOTT:
This is Dave GULLOTT, by the 8 way, from Corporate Licensing with John Freeman.
9 MR. MILLER: Dave Gullatt and John 10 Freeman?
11 MR. GULLOTT:
That is correct .. 12 MR. MILLER: Okay, thank you. 13 Okay, so let me just summarize.
I think 14 we have an understanding of your issues. You have 15 provided us more detailed information and we have that 16 in our possession for review. 17 I want to thank you, Mr. Quigley, for 18 taking your time. I acknowledge the staff for taking 19 their time, but you've also got a lot of things on 20 your plate and I want to you for taking your 21 time to bring these issues up for clarifying the 22 information for us related to the Petition that you've 23 provided to us. 24 Before I close the meeting, is there 25 anything that the Court Report needs for additional (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 45 1 information for the meeting transcript?
Anything you 2 didn't get or have a question about? 3 COURT REPORTER:
This is the court 4 reporter, I don't have any questions at this time. 5 Thank you. 6 MR. MILLER: Okay, thank you. 7 Okay, with that, this meeting is 8 adjourned.
We'll be terminating the phone connection 9 and we' 11 be providing more communication on this 10 issue as we described in the process earlier.
11 Thank you all for your time, I really 12 appreciate it. This is Chris Miller. 13 Thank you. 14 (Whereupon, the above-entitled matter went 15 off the record at 2:33 p.m.) 16 17 18 19 20 21 22 23 24 25 (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 (202) 234-4433 CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission Proceeding:
10 CFR 2.206 Petition Review Board RE Braidwood and Byron NGS Docket Number: N/a Location:
Teleconference were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken and thereafter reduced to typewriting under my direction and that said transcript is a true and accurate record of the proceedings.
Official Reporter Neal R. Gross & Co., Inc. (202) 234-4433 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. WASHINGTON, D.C. 20005-3701 www.nealrgross.com