ML121660040
| ML121660040 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/12/2012 |
| From: | Mulligan M - No Known Affiliation |
| To: | John Hughey Plant Licensing Branch 1 |
| John Hughey - 415-3204 | |
| References | |
| Download: ML121660040 (3) | |
Text
From:
Michael Mulligan [steamshovel2002@yahoo.com]
Sent:
Tuesday, June 12, 2012 3:25 PM To:
Hughey, John
Subject:
Re: Peach Bottom 2.206 Petition Request John, You encapsulated my conversation with you today perfectly.
Thanks!
Mike
- John, As I spoken, it my feeling that the NRC engineer's language...picks and chooses engineering rationales and issues...indeed picks specific terms of a petitioner to meet a agenda. What is going on is not pure science, its mocking science and the public process. I am not talking about you, you were a nice guy trying to listen to me...but as the agency talks to me. I have no beef with you.
Basically the agency has been trying like hell not to get the material deficiencies of the Vermont Yankee buna-n SRC seals written down in the pubic record...how this led to the Buna-n not being able to withstand normal operational and accident worst case heat environments.
Operating through a normal cycle or through leak rate testing doesn't cut the needs of public safety. It should be noted they normally get leak rate tested and they have failed in as little as a year. And these aren't the extreme environment of accident conditions in containment. So big deal it doesn't fail in a normal environment, and that is a extremely dangerous NRC position.
I like somebody to give me a written assurance that all the material deficiencies of the Buna-n SRV seal at VY are fully understood and these deficiencies will not show up at other plant. That the failed SRV buna-n seal at Peach Bottom is not related systemically to VY. It is passing strange that the NRC doesn't want to get this down on the written record.
Prove to me that the buna-n properties characteristics can meet the regulatory intent of primary containment. Prove to me through QA and proper testing that the seals new parts production stream can meet the design intent. If the regulations allow this kind of behavior, then the regulations are not safe for nuclear power.
It is something in the vendors or the way these utilities stores these rubber compounds seals?
It is beyond suspicious where one day these rubber compound can't withstand 165 degrees and then VY purchase new Viton or vitron seals that can withstand 400 or 700 degrees.
Could this message be placed on the Peach Bottom docket thus becoming part of my 2.206.
Thank you for being so timely and kind to me today during out conversation.
- Thanks, Mike Mulligan Hinsdale, NH From: "Hughey, John" <John.Hughey@nrc.gov>
To: 'Michael Mulligan' <steamshovel2002@yahoo.com>
Sent: Tuesday, June 12, 2012 3:10 PM
Subject:
RE: Peach Bottom 2.206 Petition Request
Forwarded Message -----
Mr. Mulligan, It was a pleasure speaking with you this afternoon. As we discussed, I am forwarding my e-mail to you dated February 10, 2012, regarding the safety determination made by the NRC staff regarding the failure of the Peach Bottom Unit 3, 71B Automatic Depressurization System Safety Relief Valve on 9/25/2011 Licensee Event Report (LER) 3-11-03 (ADAMS Accession No. ML11325A383). However, the LER evaluation includes enforcement considerations in addition to the safety determination. While the safety evaluation associated with the LER was completed prior to the issuance of the 1st quarter Peach Bottom Integrated Inspection Report, issued May 7, 2012, (ADAMS Accession No. ML12129A016), the enforcement evaluation was not.
Therefore, the completed LER evaluation will be included in the 2nd quarter Integrated Inspection report that will be issued by September 2012.
I also want to acknowledge that you related that the safety determination the NRC staff has provided does not satisfy your concerns related to the Buna-N threaded seal failure at Peach Bottom or your concerns with the use of Buna-N seals in general. You expressed that the material facts of the seal (the temperature duration in radiation for example) had not been established through testing. Therefore, the NRC staff could not prove to you that the Buna-N threaded seal material is adequate for accident conditions as well as normal operating conditions. You also expressed that you felt that the NRC staffs safety determination was merely throwing engineering language at you instead of addressing your concerns.
You also inquired about the reasons that the enforcement consideration had not yet been completed. I explained that I was not able to discuss any aspects of the enforcement consideration since this determination has not yet been finalized by NRC staff and is, therefore, pre-decisional information.
Thank you again for taking the time to speak with me today.
John Hughey, Project Manager
NRR / Division of Operating Reactor Licensing Phone: 301-415-3204 e-mail: John.Hughey@nrc.gov From: Michael Mulligan [1]
Sent: Monday, June 11, 2012 5:05 PM To: Hughey, John
Subject:
Re: Peach Bottom 2.206 Petition Request Mr Hughey, So you are saying you don't have enough evidence that PB is safe until Sept?
Can we have a talk about this?
1 603 336 8320 From: "Hughey, John" <John.Hughey@nrc.gov>
To: 'Michael Mulligan' <steamshovel2002@yahoo.com>
Sent: Monday, June 11, 2012 2:36 PM
Subject:
Peach Bottom 2.206 Petition Request Mr. Mulligan, I have attached the transcripts from the teleconferences held with you on February 17, 2012, and April 10, 2012, associated with your petition request dated January 24, 2012, regarding Peach Bottom Atomic Generating Station. Per your request during the April 10, 2012, teleconference, a copy of the transcript of that teleconference has been forwarded to the NRC Office of Inspector General.
I also wanted to inform you that the NRC staff is continuing to consider your petition request and is in the process of completing the review of Licensee Event Report (LER) 3-11-03 (ADAMS Accession No. ML11325A383) associated with the failure of the Unit 3, 71B Automatic Depressurization System Safety Relief Valve on 9/25/2011. The NRC staff anticipates that the review of LER 3-11-03 will be completed and addressed in the Peach Bottom 2nd quarter Inspection Report by September of this year, which will be publicly available in ADAMS. Once this LER evaluation is issued, the NRC staff will be able to make a final determination regarding your petition request.
Thank you, John Hughey, Project Manager NRR / Division of Operating Reactor Licensing Phone: 301-415-3204 e-mail: John.Hughey@nrc.gov Mr. Mulligan,
We have arranged for a teleconference on February 17, 2012, from 11:00 am to 12:00 pm to provide you with an opportunity to address the Petition Review Board (PRB) concerning the 10 CFR 2.206 petition you submitted to the NRC on January 24, 2012, regarding Peach Bottom Atomic Power Station (PBAPS) Units 2 and 3. This will allow you approximately 45 minutes to provide any additional information to the PRB. The teleconference information is as follows:
Date: 2/17/2012 Time: 11:00 am - 12:00 pm Bridge Line: 1-800-772-3842 Pass Code 2206 I have also spoken with the Peach Bottom Resident Inspectors regarding your request to discuss the Peach Bottom safety relief valve (SRV) seal failure history with them prior to the PRB teleconference. The Senior Resident Inspector, Sam Hansell, and Resident Inspector, Adam Ziedonis, would be happy to speak with you. You can contact them directly at 717-456-7614.
The PRB met internally on February 3, 2012, and denied the request for immediate action to shutdown Peach Bottom Units 2 and 3, and replace the SRV pneumatic actuator threaded seals, because there was no immediate safety concern to the plant, or to the health and safety of the public. Specifically, the PRB determined that threaded seals with Buna-N material have been used in the PBAPS Unit 2 and 3 SRVs for 20 years with no seal failures until the subject failure in September 2011. The 3-ADS-SRV 71B seal had been in service for less than one year before its failure and the seals are replaced every 4 years. In addition, the insulation configuration on the Vermont Yankee SRVs that contributed to their 2 seal failures was confirmed to not be a contributing cause for the PBAPS Unit 3 ADS-SRV 71B failure. These facts support the conclusion that the failure of the 3-ADS-SRV 71B threaded seal was not a common mode failure, or an age related failure, but was isolated to the particular seal installed in the 3-ADS-SRV 71B actuator in November 2010. This information will be included in a future NRC Inspection Report regarding the subject SRV threaded seal failure.
Thank you, John Hughey Peach Bottom Project Manager NRR / Division of Operating Reactor Licensing Phone: 301-415-3204 e-mail: John.Hughey@nrc.gov From: Michael Mulligan [2]
Sent: Friday, February 03, 2012 10:07 AM To: Hughey, John
Subject:
Re: Peach Bottom 2.206 Petition Request
- John, Name the date and time, and i will be there. Give me a few days heads up if you can.
I had a nice talk with the VY inspectors about their SRVs yesterday...they were very gracious to me. Is your inspectors as nice and informed as VY's NRC inspectors? They said VY was all set with a new type seals already installed and they are qualified for much higher temperature. They gave me a lot of fascinating and interesting information.
Any chance I can get a brief from the Peach Bottom NRC inspectors before the 2.206 about their seal failure and history. Hey, it can't hurt just to ask. You never know?
- thanks, Mike From: "Hughey, John" <John.Hughey@nrc.gov>
To: 'Michael Mulligan' <steamshovel2002@yahoo.com>
Sent: Thursday, February 2, 2012 3:18 PM
Subject:
RE: Peach Bottom 2.206 Petition Request Mr. Mulligan, Please respond with your availability for the next two weeks (2/6 - 2/17) and I will forward the teleconference information to you to provide an opportunity to address the PRB. We will schedule the teleconference for a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> duration.
Thank you and please contact me should you have any questions.
John Hughey Peach Bottom Project Manager NRR / Division of Operating Reactor Licensing Phone: 301-415-3204 e-mail: John.Hughey@nrc.gov ith