ML14114A293
| ML14114A293 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/17/2014 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Regner L | |
| Shared Package | |
| ML14071A025 | List: |
| References | |
| LTR-14-0142, NRC-735, OEDO-14-00146 | |
| Download: ML14114A293 (47) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
10 CFR 2.206 Petition Review Board RE St. Lucie Unit 2 Docket Number:
50-328 Location:
teleconference Date:
Thursday, April 17, 2014 Work Order No.:
NRC-735 Pages 1-45 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
1 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION 2
+ + + + +
3 10 CFR 2.206 PETITION REVIEW BOARD (PRB) 4 CONFERENCE CALL 5
RE 6
ST. LUCIE UNIT 2 7
+ + + + +
8 THURSDAY 9
APRIL 17, 2014 10
+ + + + +
11 The conference call was held, Samson Lee, 12 Chairperson of the Petition Review Board, presiding.
13 PETITIONER: THOMAS SAPORITO 14 PETITION REVIEW BOARD MEMBERS 15 SAMSON LEE, Deputy Director, Division of Risk 16 Assessment, NRR 17 LISA REGNER, Petition Manager for 2.206 18 petition, NRR 19 20 NRC HEADQUARTERS STAFF 21 MERRILEE J. BANIC, 2.206 Petition Coordinator, 22 NRR 23 DAVID CYLKOWSKI, Office of General Counsel, 24 USNRC 25
2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 GLORIA KULESA, Chief Engineer, Tube Integrity 1
and Chemical Engineering Branch, NRR 2
EMMETT MURPHY, Steam Generator and Chemical 3
Engineering Branch, USNRC 4
NRC REGION II OFFICE 5
MARK MILLER, USNRC Region II 6
DANIEL W. RICH, Chief, Reactor Projects Branch 7
3, USNRC Region II 8
ALSO PRESENT:
9 DOUG ANDREWS, St. Lucie Nuclear Power Plant 10 WILLIAM BLAIR, Florida Power & Light 11 ERIC KATZMAN, Florida Power & Light 12 J.R. KELLY, Florida Office of Public Counsel 13 MARK LAUX, Florida Public Service Commission 14 IVAN PENN, Tampa Bay Times 15 CHARLES REHWINKEL, Florida Office of Public 16 Counsel 17 ERIK SAYLER, Florida Office of Public Counsel 18 SUSAN SALISBURY, Palm Beach Post 19 20 21 22 23 24
3 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 P-R-O-C-E-E-D-I-N-G-S 1
(2:05 p.m.)
2 MS. REGNER: I believe we will go ahead and 3
get started.
4 My name is Lisa Regner. I am the project 5
manager and the petition manager, actually. The 6
purpose of today's call is to provide the Petitioner, 7
Mr. Thomas Saporito, the opportunity to address the 8
Petition Review Board.
9 We will also refer to the Petition Review 10 Board as the PRB. And this is related to his 10 CFR, 11 Code of Federal Regulations, Section 2.206 Petition 12 related to the steam generators design changes for St.
13 Lucie Plant, Unit 2.
14 So, I will go through some welcome and 15 introductions and then I will turn it over to the 16 Petition Review Board Chairman for his introduction, 17 and a little bit of background.
18 We will then go right into Mr. Saporitos, 19 the Petitioner's, presentation. We have scheduled an 20 hour2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> and then we will lose our bridge line for Mr.
21 Saporito's presentation, so I will try to gently remind 22 the people -- some timing reminders, if that is okay, 23 Mr. Saporito.
24
4 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MR. SAPORITO: Yes. That is fine.
1 MS. REGNER: Then the PRB Chairman will 2
make some closing remarks. So, again, I would like to 3
thank everybody for your interest and for attending this 4
meeting.
5 I am the project manager, as well, for the 6
St. Lucie Plant, Units 1 and 2, and I -- by virtue of 7
that, I am the petition manager for this petition 8
submitted on March 11th, 2014 by Mr. Saporito.
9 I talked about why we are here today, to 10 allow him to address the PRB so he can present any 11 relevant additional explanation and support for his 12 request in advance of the PRB's evaluation of the 13 petition.
14 The meeting started at two p.m., Eastern 15 Daylight time on April 17th, 2014, and it is being 16 recorded by the NRC Operations Center. It will be 17 transcribed by a court reporter and the transcript will 18 be publicly available and will become a supplement, in 19 addition to Mr. Saporito's handouts.
20 Those will both become supplements to the petition.
21 So, with that, I would like to remind anyone 22 that speaks, the court reporter is actually on the 23 phone, so it is especially important that anyone that 24
5 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 speaks, identify themselves for the court reporter.
1 And, I apologize ahead of time for 2
interrupting anybody, but I will -- I will try to make 3
sure that, if you forget to introduce yourself, that I 4
will gently remind you.
5 The Petition Review Board Chairman is Dr.
6 Samson Lee. I would like the rest of just the Petition 7
Review Board to introduce themselves. As we go around 8
-- as we go around the room, please be sure to clearly 9
state your name, your position and the office that you 10 work for within the NRC for the record.
11 So, we will start here at Headquarters.
12 MR. CYLKOWSKI: I am David Cylkowski, an 13 attorney in the Office of General Counsel, here at NRC.
14 MR. MURPHY: I am Emmett Murphy with the 15 Steam Generator and Chemical Engineering Branch at the 16 NRC.
17 MS. BANIC: Lee Banic, Office of Nuclear 18 Reactor Regulations, 2.206, Petition Coordinator.
19 CHAIR LEE: I am Samson Lee. I am the PRB 20 Chair for -- for this Petition. I am the Deputy 21 Division Director, Division of Risk Assessments.
22 MS. KULESA: Gloria Kulesa, Chief, Tube 23 Integrity and Chemical Engineering Branch.
24
6 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 MS. REGNER: Okay. That is it for the PRB 1
Members here at Headquarters.
2 Dan, would you go ahead and introduce 3
yourself as well, please.
4 MR. RICH: Yes. I guess, Lisa, Dan Rich.
5 I am Chief of Branch 3, Division of Reactor Projects, 6
Region II.
7 MS. REGNER: All right. And Mr. Saporito, 8
if you wouldn't mind -- oh, actually, let's -- are there 9
any other Headquarters -- we already went through the 10 Headquarter participants on the phone. I don't want to 11 redo that.
12 Let's see. And representatives for the 13 Licensee, why don't you go ahead and introduce 14 yourselves again.
15 MR. KATZMAN: This is Eric Katzman, 16 Station Licensing Manager, Florida Power & Light.
17 MR. BLAIR: This is William Blair, 18 Managing Attorney, Florida Power & Light.
19 MR.
ANDREWS:
Doug
- Andrews, Site 20 Communications, St. Lucie.
21 MS. REGNER: Okay. And, Mr. Saporito, 22 would you please introduce yourself for the record.
23 MR.
SAPORITO:
Yes.
This Thomas 24
7 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Saporito, Saprodani Associates. I am the Petitioner in 1
this matter. Thank you.
2 MS. REGNER: Thanks. And I would like to 3
again emphasize that we each need to speak clearly and 4
loudly to ensure the court reporter can accurately 5
transcribe the meeting.
6 And, for those of you that are dialing into 7
the meeting, especially while Mr. Saporito is speaking, 8
if you would kindly mute your phones to minimize any 9
background noise or distractions.
10 If you don't have a mute button, this can 11 be done by pressing the keys "Star 6." If you do want 12 to speak at any point, you do need to press star 6 again 13 to unmute your phones.
14 At this point, as this is not a public 15 meeting, I do want to stress that the public is invited 16 to participate as observers only, and there will be a 17 point in time where we ask if any members of the public 18 would like to inquire of the NRC how the 2.206 process 19 works.
20 Other than that, this is Mr. Saporito's 21 opportunity and I would like to at this point turn it 22 over to our Petition Review Board Chairman, Dr. Samson 23 Lee, for opening remarks.
24
8 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 CHAIR LEE: Welcome to the meeting 1
regarding the 2.206 Petition. I would like to first 2
share some background on our process.
3 Section 2.206 of Title 10 of the Code of 4
Federal Regulations describes the petition process, the 5
primary mechanism for the public to request enforcement 6
action by the NRC in a public process.
7 This process permits anyone to petition NRC 8
to take enforcement-type action relating -- related to 9
NRC licensees or licensed activities.
10 Depending on the results of its evaluation, 11 the NRC could modify, suspend or revoke an NRC-issued 12 license or take any other appropriate enforcement 13 action to resolve a problem.
14 The NRC Staff's guidance for the 15 disposition of 2.206 Petition Requests is in Management 16 Directive 8.11, "Review Process for 10 CFR 2.206 17 Petitions," which is publicly-available.
18 The purpose of today's meeting is to give 19 the Petitioner an opportunity to provide any additional 20 explanations or support for the Petition before the 21 Petition Review Board's initial consideration and 22 recommendation.
23 This meeting is not a hearing, nor is it an 24
9 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 opportunity for the Petitioner to question or examine 1
the Petition Review Board on the merits of the issues 2
presented in the Petition Request.
3 This meeting is not a public meeting, 4
although members of the public have been invited to 5
participate as observers.
6 No decision regarding the merits of this 7
Petition will be made at this meeting.
8 Following this meeting, the Petition 9
Review Board will evaluate the Petition to determine if 10 it meets the criteria for review. The outcome of this 11 internal meeting will be discussed with the Petitioner.
12 The Petition Review Board typically 13 consists of a Chairman, usually a manager at the senior 14 executive service level at the NRC. It has a Petition 15 Manager and a Petition Review Board Coordinator.
16 Other members of the Board are determined 17 by the NRC Staff, based on the content of the Petition 18 Request. The Members have already introduced 19 themselves for this Petition.
20 As describe in our process, the NRC Staff 21 may ask clarifying questions in order to better 22 understand the Petitioner's presentation and to reach 23 a reasoned decision whether to accept or reject the 24
10 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Petitioner's request for review under the 2.206 1
process.
2 I would like to summarize the scope of the 3
Petition and the consideration and the NRC activities 4
to date.
5 On March 11th, Mr. Saporito submitted a 6
Petition to the NRC under 10 CFR 2.206 regarding St.
7 Lucie Plant Unit 2, in which you requested a number of 8
actions.
9 You requested the following enforcement 10 actions: to suspend or revoke the license of St. Lucie 11 2; to issue a violation with a civil penalty of $10 12 million dollars; to issue a "Confirmatory order" that 13 will keep the plant shutdown or cooled down until the 14 licensee completes an independent assessment of the 15 steam generator wear, completes a comprehensive 16 evaluation of safety-related and components modified or 17 affected by the steam generator design modifications, 18 identifies and removes any damaged or unauthorized 19 safety-related components, and completes an 20 independent assessment through a third party to review 21 all safety-related components to ensure safety and NRC 22 regulations are met.
23 As a basis for this request, you stated that 24
11 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the licensee incorrectly used the 10 CFR 50.59 process 1
instead of submitting a license amendment request to the 2
NRC.
3 You believe that the licensee should have 4
used the amendment process since significant design 5
changes were made to the replacement steam generators.
6 You provide a list of significant design 7
changes between the original and the replacement steam 8
generators. You state that, since a significant number 9
of new tubes were added to the steam generator, there 10 are many more holes in the center of the tube support 11 plate challenging its integrity.
12 Also, since the stay cylinder, a support 13 structure for the tubesheet in previous steam generator 14 designs, was removed, you state this calls into question 15 the structural integrity of the tubesheets.
16 You are concerned that the licensee did not 17 adequately address the "weakened tubesheet" which 18 "raises concerns about the safety and integrity of Unit 19 2's pressure boundary in the event of a steam line break 20 accident."
21 On March 21st, the Petition Manager 22 contacted you by phone and email, providing information 23 on the 10 CFR 2.206 process and asking if you would like 24
12 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to address the Petition Review Board. You responded 1
that you would like to address the Petition Review Board 2
by teleconference. A mutually agreed-upon date was set 3
up for April 17th.
4 On March 28, the Petition Review Board 5
reviewed your request for immediate action to prevent 6
St. Lucie Plant Unit 2 restart, and determined that 7
there were no safety-significant concerns to prevent 8
the plant from restarting as scheduled.
9 This decision was based on, the pressure 10 boundary components of the replacement steam 11 generators, including the tube sheets were designed in 12 accordance with 20 CFR Part 50, including the American 13 Society of Mechanical Engineers Boiler and Pressure 14 Vessel Code,Section III, thus ensuring their 15 structural integrity.
16 The NRC's Reactor Oversight Process 17 verifies that St. Lucie, Unit 2 is operated in 18 accordance with the Steam Generator Program to ensure 19 tube integrity is maintained.
20 NRC Resident Inspectors are on-site to 21 verify compliance with the Steam Generator Program.
22 23 St. Lucie, Unit 2 has been operating 24
13 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 acceptably for seven years since the steam generators 1
were replaced with no findings of significance in the 2
past three NRC inspections.
3 There is no indication that this licensee 4
used the 10 CFR 50.59 process improperly based on 5
verification by NRC regional inspectors.
6 On March 31st, the Petition Manager 7
informed you by email, at your request, of the Petition 8
Review Board's decision on the immediate actions, 9
including the basis for the NRC staff's decision that 10 immediate actions would not be taken.
11 Again, as a reminder for the participants, 12 please identify yourselves, as this will help us in the 13 preparation of the meeting transcript that will be made 14 publicly-available.
15 Thank you. At this time, Mr. Saporito, I 16 will turn it over to you to allow you the opportunity 17 to provide any information you believe the Petition 18 Review Board should consider as part of this Petition.
19 Thank you.
20 MR. SAPORITO: Thank you, Mr. Chairman.
21 Before I get into this -- into the 22 presentation, I will note for the record, it is 2:21 now 23 and I specifically asked the Project Manager, Lisa 24
14 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Regner, that I be allocated one hour.
1 So, I have got till 3:21, till I have 2
completed my presentation, just so the record is clear.
3 So, for the record, my name is Thomas 4
Saporito. I am the senior consultant with Saprodani 5
Associates in Jupiter, Florida. I am the Petitioner 6
currently before the NRC Petition Review Board.
7 In addition to the 2.206 enforcement 8
petition filed with the NRC, or Nuclear Regulatory 9
Commission in this matter, I have provided the PRB, or 10 the Petition Review Board with six attachments in 11 support of the 2.206 Petition.
12 I will refer the PRB Members to those 13 specific attachments in my presentation today, and I 14 respectfully request that the attachments be 15 incorporated in today's record transcripts, including 16 a copy of today's presentation, which is identified for 17 the record as Attachment 7, which I will email to Lisa 18 Regner, NRC Project Manager at the conclusion of today's 19 meeting.
20 If any member of the public would like a 21 copy of the attachments, please send me an email request 22 at saprodani@gmail.com.
23 To the extent that this meeting is for the 24
15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 public -- excuse me. To the extent that this meeting 1
is -- this is a meeting for which the public is permitted 2
to attend, I will briefly describe the overall operation 3
of a typical pressure water reactor or PWR, to enlighten 4
members of the public who may later read the meeting 5
transcripts, or who are attending this meeting in person 6
via telephone.
7 I will now refer the PRB Members to 8, which is identified for the record as a 9
diagram of a typical pressurized water reactor.
10 The steam generators are heat exchangers, 11 used to convert water into steam from heat produced in 12 a nuclear reactor core. They are used in pressurized 13 water reactor between primary and secondary coolant 14 loops.
15 In commercial power
- plants, steam 16 generators can measure up to 70 feet in height and weigh 17 as much as 800 tons. Each steam generator can contain 18 anywhere from 3,000 to 16,000 tubes, each about three 19 quarters of an inch in diameter.
20 The coolant or treated water is maintained 21 a high pressure to prevent boiling and is pumped through 22 the nuclear reactor core.
23 Heat transfer takes place between the 24
16 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 reactor core and the circulating water and the coolant 1
is then pumped through the primary side of the steam 2
generator by coolant pumps before returning to the 3
reactor core.
4 This is referred to as the primary loop, and 5
is shown as the orange-colored dash lines in the reactor 6
vessel and the tubes in the steam generator, as depicted 7
in Attachment 5.
8 It is noted here that the primary loop water 9
is highly radioactive as it travels through the 10 thousands of tubes inside the steam generator.
11 The water flowing through the steam 12 generator boils -- excuse me. The water flowing 13 through the steam generator boils water on the shell 14 side to produce steam in the secondary loop, and it is 15 delivered to the turbines to make electricity.
16 It is noted here that the secondary loop 17 water is not radioactive and simply acts as a heat sync 18 to transfer the heat energy from the primary loop to the 19 secondary loop as depicted in Attachment 5 by the dark 20 blue-colored water in the steam generator.
21 The steam is subsequently condensed via 22 cooled water from the tertiary loop and returned to the 23 steam generator to be heated once again. The tertiary 24
17 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 cooling water may be recirculated to cooling towers 1
where it sheds its waste heat before returning to 2
condense more steam.
3 Alternatively, once through tertiary 4
cooling, may also be provided by a river, a lake or an 5
ocean. This primary/secondary tertiary cooling scheme 6
is the most common way to extract useable energy from 7
a controlled nuclear reaction.
8 I note here that in all cases, the heat 9
energy generated in the nuclear reactor core must be 10 constantly removed to prevent a core meltdown similar 11 to the ongoing Fukushima nuclear disaster.
12 These water cooling loops also have an 13 important safety role because they constitute one of the 14 primary boundaries between the radioactive and 15 nonradioactive sides of the plant, as the primary 16 coolant becomes radioactive from its exposure to the 17 core.
18 For this reason, the integrity of the steam 19 generator tubing is essential in minimizing the leakage 20 of water between the two sides of the plant.
21 Steam generator tubes often degrade over 22 time, and if a steam generator tube bursts while a plant 23 is operating, contaminated steam could escape directly 24
18 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 to the secondary cooling loops.
1 This is the reason that during scheduled 2
maintenance outages or shutdowns, some or all of the 3
steam generator tubes are inspected by eddy testing, and 4
individual tubes can be plugged to remove them from 5
operation.
6 As can be seen in the diagram, and through 7
my brief description of how a PWR operates, the steam 8
generators employed at the St. Lucie Unit 2 Nuclear 9
Plant act as a heat sync in removing heat from the 10 highly-radioactive primary water, drawing from the core 11 of the nuclear reactor.
12 This process allows the nuclear reactor at 13 the St. Lucie Unit 2 to maintain full power operation 14 without causing nuclear fuel rods inside the reactor to 15 melt down.
16 Therefore, the integrity of the St. Lucie 17 Unit 2 steam generator tubes is absolutely critical to 18 nuclear safety and to protect public health and safety.
19 For this reason, standing alone, the 2.206 20 Enforcement Petition requests that the NRC issue a 21 confirmatory order to the licensee requiring the 22 licensee to maintain the St. Lucie Nuclear Unit 2 in a 23 cold shutdown mode of operation until such time as, one, 24
19 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the licensee completes an independent assessment to 1
fully understand and to correct the potential and/or 2
realized damage to the Unit 2 steam generators and the 3
modifications made to the Unit 2 steam generators.
4 And, two, the licensee completes a 5
comprehensive evaluation of all nuclear safety-related 6
plant equipment and components which may have been 7
otherwise modified and/or affected as a direct or 8
indirect result of the modifications made to the Unit 9
10 And, three, the licensee completed, 11 identified and removes any and all damaged and/or 12 unauthorized nuclear safety-related plant equipment 13 and/or components.
14 And finally, four, the licensee completes 15 an independent safety assessment to a third-party 16 contractor to review all plant nuclear safety-related 17 equipment and/or components to ensure that such nuclear 18 safety-related systems and/or components will properly 19 function to protect public health and safety under all 20 NRC regulations and requirements under 10 CFR Part 50, 21 and under other NRC regulations and requirements.
22 I would now refer the PRB Members to 23, which is identified for the record as a 24
20 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 November 8th, 2014 email correspondence from Lisa 1
Regner, NRC Project Manager, to me.
2 The email details six specific reasons that 3
the NRC PRB decided not to take immediate actions 4
requested in the instant 2.206 petition. At this time 5
I will briefly respond to each of the PRB's stated 6
reasons as follows.
7 First reason. The staff is not aware of 8
any safety issue related to the design and operation of 9
the St. Lucie Unit 2 replacement steam generators. The 10 pressure boundary components of replacement steam 11 generators, including the tubesheets were designed in 12 accordance with 10 CFR 50, including the American 13 Society of Mechanical Engineers Boiler and Pressure 14 Vessel Code, Section 3, thus ensuring their structural 15 integrity.
16 The broached-hole, support plates for the 17 replacement steam generators are fabricated from 18 stainless steel, significantly reducing any potential 19 for denting, compared to carbon steel support plates.
20 Concerns for denting were the motivating 21 factor cited in the final safety analysis report with 22 the use of egg-crate design of the carbon steel supports 23 in the original steam generators, both broached-hole 24
21 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 support and egg-crate designs have been used 1
successfully in both the original and replacement steam 2
generators.
3 Petitioner's response. Although the St.
4 Lucie Unit 2 replacement steam generator pressure 5
boundary components, including the tubesheets appear to 6
have been designed in accordance with 10 CFR 50.
7 The licensee cannot affirm structural 8
integrity to the NRC because the stay cylinder was 9
apparently removed from the bottom of the steam 10 generators.
11 Notably, the stay cylinder was apparently 12 incorporated into the licensee's original final safety 13 analysis report to ensure that the steam generator 14 tubesheet was not subject to flexing during power --
15 reactor power operation.
16 To the extent that the stay cylinders have 17 apparently been removed by the licensee, the NRC cannot 18 have any measurable assurance that the licensee will 19 operate the St. Lucie Nuclear Reactor in full compliance 20 of NRC regulations and requirements under 10 CFR 50 and 21 under other NRC authority.
22 Moreover, the licensee apparently added 23 588 additional tubes to the St. Lucie Unit 2 steam 24
22 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 generators, thus it is reasonable to conclude that 1
additional tube sheet penetrations were made to 2
accommodate the additional tubes.
3 Thus, to the extent that additional tube 4
sheet penetrations were made in the steam generator tube 5
sheets, the now existed and -- they are now existent 6
increase likelihood that the tubesheet will flex to a 7
greater extent under full-power operations, in 8
violation of safety margins set out under 10 CFR 50, and 9
significantly increase the probability of a nuclear 10 accident, which could result in a loss of coolant 11 accident, and a significant release of radioactive 12 material and particles into the surrounding environment 13 and adversely affect public health and safety.
14 Therefore, the NRC cannot have any measure 15 of reasonable assurance that the licensee will operate 16 St. Lucie Nuclear Reactor in full compliance of NRC 17 regulations and requirements under 10 CFR 50 and under 18 other NRC authority.
19 Reason number two by the PRB. The reactor 20 oversight process verifies that St. Lucie Unit 2 is 21 operated in accordance with the technical 22 specifications. Technical specifications require 23 implementation of a
- program, 24
23 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 inspections, tube wear limits for removing tubes from 1
service, tube integrity assessments, to ensure tube 2
integrity is maintained.
3 Petitioner's response. Although the 4
licensee steam generator program may implement 5
inspections, tube wear limits for removing tubes from 6
service, and tube integrity assessments, the licensee 7
installed replacement steam generators which were not 8
specifically designed for the combustion engineering 9
pressurized water reactor employed at the St. Lucie, 10 Unit 2.
11 Moreover, the licensee had additionally 12 implemented a power uprate program at the St. Lucie Unit 13 2, which caused a significantly greater amount of stress 14 on the reactor cooling system which is likely to result 15 in the loss of coolant nuclear accident as described 16 earlier.
17 Therefore, the NRC cannot have any measure 18 of reasonable assurance that the licensee will operate 19 St. Lucie nuclear reactor in full compliance of NRC 20 regulations and requirements under 10 CFR 50, and under 21 other NRC authority.
22 The PRB's reason number three. The steam 23 generator program requires the licensee to perform 24
24 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 inspections to evaluate tube safety margins for all 1
tubes against regulatory requirements to confirm that 2
the steam generators continue to be operated safely.
3 These inspections are also used to 4
determine what tubes need to be removed from service and 5
what other actions may be needed to ensure continued 6
safe operation of St. Lucie Unit 2 until the next 7
scheduled inspection.
8 Resident inspectors are on-site to verify 9
compliance with the inspection with the in-service 10 inspection program. The steam generator program 11 inspections are part of the licensee's ISI or in-service 12 inspections.
13 Petitioner's response. Although the 14 licensee has conducted inspections under the steam 15 generator program to determine what tubes need to be 16 removed from service, the licensee has failed to date 17 to determine the root cause of the excessive degradation 18 of the steam generator tubes.
19 To the extent that the licensee has failed 20 to determine the root cause of the continued degradation 21 of the steam generator tubes, the NRC cannot have any 22 measure of reasonable assurance that the licensee will 23 operate the St. Lucie Nuclear Reactor in full compliance 24
25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 with NRC regulations and requirements under 10 CFR 50 1
and under other NRC authority.
2 PRB's stated reason number four. The 3
plant has been operating acceptably for seven years 4
since the steam generators were replaced in 2007.
5 There have been no findings of significance 6
in the past three NRC inspections conducted to provide 7
oversight of the licensee's shutdown ISI inspections.
8 Only a very small percentage of tubes have 9
needed to be plugged. There is no measurable primary 10 or secondary leakage.
11 Petitioner's response.
Since the 12 licensee replaced the steam generator, St. Lucie's Unit 13 2 steam generators in 2007, there has been a 14 significant, an increasing number of steam generator 15 tube wear indications.
16 Notably, to date, the St. Lucie Unit 2 steam 17 generators have significantly more tube wear 18 indications and the number of tube wear indications is 19 much greater than at other units with AREVA steam 20 generators.
21 Notably, it is not the number of tubes that 22 the licensee continues to plug, which should be the --
23 should be the NRC's only focus, rather, it should be the 24
26 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 significantly increasing number of tube wear 1
indications which have the potential to cause the tubes 2
to burst and result in a loss of coolant accident, as 3
previously-described.
4 Once again, the licensee has failed, to 5
date, to determine the root cause of the significantly 6
and increasing number of tube wear indications and to 7
correct the problem.
8 The PRB's stated reason number five.
9 There is no indication that the licensee used 10 CFR 10 50.59 process improperly. The Region II resident 11 inspections reviewed the 2007 Unit 2 steam generator 12 replacement project, including the Florida Power &
13 Light 10 CFR 50.59 evaluations. The NRC inspectors 14 identified no findings of significance.
15 Petitioner's response. My research as to 16 whether licensee used the 10 CFR 50.59 process indicates 17 that the licensee apparently did improperly use the 10 18 CFR 50.59 process with respect to installation of the 19 St. Lucie Unit 2 steam generators.
20 This subject matter will be discussed in 21 greater detail during the remainder of this 22 presentation.
23 And finally, the Petition Review Board 24
27 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 stated reason number six. In February, 2011 FPL 1
submitted a license amendment request for a power 2
uprate.
3 The amendment request provided evaluations 4
of the steam generator replacements, with respect to 5
thermal-hydraulics, structural integrity and tube 6
wear.
7 The NRC staff reviewed the amendment, 8
including the effects of the steam generators, 9
replacement steam generators and ultimately approved 10 the amendment.
11 Petitioner's response. Although the NRC 12 staff reviewed the amendment, including the effects of 13 the replacement steam generators, and ultimately 14 approved the amendment, there appear to be significant 15 nuclear safety concerns for which the staff may not have 16 considered or may not have properly considered in 17 approving the amendment.
18 This subject matter will be discussed in 19 greater detail during the remainder of this 20 presentation.
21 At this time I will very briefly discuss 22 important background information related to the St.
23 Lucie Unit 2 Nuclear Plant to provide the PRB Members 24
28 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 with a complete understanding about the critical and 1
ongoing nuclear safety issues surrounding the steam 2
generator tubes for which the licensee has apparently 3
failed to specifically identify the root cause and for 4
which the licensee has apparently failed to correct to 5
date.
6 I would now refer the PRB Members to 7
Attachment One, which is identified for the record, the 8
November 24th, 2004 notice by the Nuclear Regulatory 9
Commission related to a proposed license amendment for 10 the St. Lucie Unit 2 Nuclear Plant.
11 I have highlighted the text of interest in 12 the document. At page two, enumerated number one 13 paragraph, it states, in part, that FPL proposes to 14 modify the definitions of steam generator plugging 15 limit and tube inspection as contained in the St. Lucie 16 Unit 2 technical specifications, IM 4.4.5.4.A56 and 17 4.4.5.4.A8, respectively.
18 And then, in the next paragraph it states, 19 in part, tube bursts is precluded for tube -- with the 20 tube defects within the tubesheet region because of the 21 constraint provided by the tubesheet.
22 As such, the tube pull-out resulting from 23 the actual forces induced by a primary-to-secondary 24
29 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 differential pressures would be a prerequisite for tube 1
bursts to occur.
2 Petitioner refers here that the NRC 3
ultimately approved the proposed license amendment and 4
that the licensee replaced the original steam 5
generators at the St. Lucie Nuclear Plant Unit 2, 6
however, based on information and belief, it appears 7
that the licensee made certain and specific 8
modifications to the St. Lucie Unit 2 steam generators 9
in removal of the stay cylinder, the perforation of the 10 essentially region of the tube sheet, and the addition 11 of 588 tubes in the central region of the tubesheet.
12 The removal of the stay cylinder and the 13 additional 588 holes apparently made in the central 14 region of the tube sheet to accommodate 588 more tubes 15 appears to contradict the NRC's determination made with 16 respect to tube burst being precluded by constraint 17 provided by the tube sheet.
18 Indeed, the purpose of the stay cylinder 19 was to prevent tube sheet flexing. The steam 20 generators in St. Lucie Unit 2, apparently each have a 21 tube sheet with more holes in its center precisely where 22 more flexing is more likely to occur.
23 The weakened tube sheet raises concerns 24
30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 about the safety and integrity of Unit 2's pressure 1
boundary in the event of a steam line break accident.
2 I will now refer the PRB Members to 3
Attachment Two, which is identified for the record as 4
a November 30th, 2010 letter with enclosure from Tracy 5
J. Orf, O-r-f, NRC Project Manager, Plant Licensing 6
Branch, to Mano K. Nazar, Executive Vice President and 7
Chief Nuclear Officer at Florida Power & Light Company.
8 I have highlighted certain areas of 9
interest as follows. On page one of the enclosure, 10 which is the first page beyond the NRC letterhead, it 11 states that St. Lucie Unit 2 has two replacement steam 12 generators manufactured by AREVA.
13 Each steam generator has 8,999 14 thermally-treated allow 690 tubes with an outside 15 diameter of 0.75 inches and a wall thickness of 0.043 16 inches.
17 And then, at page two of the enclosure, it 18 states that approximately 5,800 indications of wear at 19 the antivibration bars were detected, 3,700 in steam 20 generator A, and 2,157 steam generator B.
21 And then, at the very bottom of page two of 22 the enclosure it states that, based on review of the 23 information provided, the NRC staff concludes that the 24
31 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 licensee provided the information required by the 1
technical specifications.
2 In addition, the staff concludes that there 3
were no technical issues that warrant follow-up action 4
at this time, since the inspections appear to be 5
consistent with the objective of detecting potential 6
tube degradation, and that the inspection results 7
appear to be consistent with industry operating 8
experience at similarly-designed and operating units.
9 And then in parentheses, the NRC says, 10 "Although the number of wear indications is much greater 11 than at other units with AREVA steam generators."
12 So, as of November 2010, the licensee and 13 the NRC were fully-aware that the St. Lucie Unit 2 AREVA 14 steam generator tubes were exhibiting a much greater 15 number of wear indications than were observed at other 16 nuclear units employing AREVA steam generators.
17 Nonetheless, as of November 2010, the 18 licensee failed to identify and failed to correct the 19 root cause of the problem causing the degradation of the 20 St. Lucie Unit 2 steam generator tubes. Despite the 21 significant and unresolved nuclear safety concern, the 22 NRC authorized the licensee to operate St. Lucie Nuclear 23 Reactor at full power.
24
32 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 I would now refer the PRB members to 1, which is identified for the record as a 2
March 9th, 2014 declaration of Arnold Gunderson. Mr.
3 Gunderson is a chief engineer at Fairewinds Associates 4
and a qualified nuclear engineer and expert witness.
5 I have highlighted specific areas of 6
interest for PRB Members. Specifically, at page three, 7
paragraph nine, Gunderson states that, "I have reviewed 8
FPL and NRC documents that discuss the safety of St.
9 Lucie Unit 2 steam generators with respect to 10 modifications that were made from the original steam 11 generator designs to the replacement steam generator 12 designs."
13 And then, at page five, and continuing on 14 page six at paragraph 16, Gunderson states that, "In 15 combustion engineering steam generators, including the 16 original St. Lucie steam generators, the tubesheet is 17 supported by a stay cylinder that is located in the 18 plenum.
19 "The stay cylinder is attached to the 20 bottom of the steam generator and the underside of the 21 tubesheet. Because the stay cylinder is designed to 22 relieve the weight in the middle of the tubesheet and 23 to prevent the tube sheet from flexing upward in the 24
33 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 event of an accident, the stay cylinder serves as a 1
passive safety-related role.
2 "As described by the NRC, the stay cylinder 3
in a steam generator serves an important safety function 4
in the event of a major accident as it supports a 5
tubesheet in the event of a steam line break and, 6
therefore, it lowers the tubesheet flexure."
7 And he referenced the letter from Alan B.
8 Wang to Harold B. Ray regarding the San Onofre Nuclear 9
Generating Station, Unit 2, dated September 23rd, 2002, 10 NRC Document M as in Mary, L as in Larry, 022540872.
11 He goes on to say that "The stay cylinder 12 is unique to the combustion engineering design because 13 the combustion engineering steam generators are twice 14 as large as the Westinghouse design.
15 "The larger diameter of the combustion 16 engineering steam generator would cause the tubesheet 17 to flex more in the event of a steam line break accident 18 at St. Lucie Unit 2, than at other reactors with smaller 19 steam generators."
20 And then, at page eight, paragraph 20, 21 21 and 22, Gunderson states that, "Unfortunately, a leak 22 or disintegration of one or more tubes would cause the 23 radioactive water to escape the containment. Because 24
34 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 there is a 1,000 pound per square inch pressure 1
difference between the high pressure radioactive side 2
of the tubes and the low pressure steam that then leaves 3
the containment, a leak will inevitably release 4
radioactivity to the environment.
5 "Additionally, gross failure of one or more 6
steam generator tubes could create a nuclear design 7
basis accident and cause the nuclear reactor core to 8
lose a portion of its cooling water.
9 "However, the unique concern regarding 10 degraded steam generator tubes is that the 11 out-of-control radiation releases from a tube break 12 will not remain inside the containment building and, 13 instead, leak out of the facility and into public areas 14 because it has a path to the environment via atmospheric 15 dump valves and steam generator blowdown.
16 "If a steam line break accident were to 17 occur, the depressurization of the steam generator 18 caused by the steam line break, coupled with the lack 19 of water at the top of the steam generators would cause 20 cascading tube failures involving dozens of tubes.
21 "The cascading tube failures would pop like 22 popcorn and cause excessive offsite radiation 23 exposures. Operators are not trained on procedures to 24
35 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 mitigate multiple tube failures and emergency core 1
cooling systems lack the capacity to mitigate an 2
accident if more than one tube were to fail.
3 "Hence, maintaining tube integrity is of 4
the utmost importance."
5 And then, at page 14 at paragraph 31, 6
Gunderson
- states, "A
careful review of the 7
subsequently-issued documents reveals, however, that 8
the Unit 2 replacement steam generators employed 9
significant design changes, while FPL claimed in the 10 Section 50.59 report that it had made no changes to 11 interfaces with the reactor coolant system and no 12 significant changes to major component supports or 13 piping supports, it is now clear from correspondence 14 related to the San Onofre steam generators that the 15 replacement steam generators no longer contained the 16 stay cylinders that were part of the original steam 17 generator design discussed in the final safety analysis 18 report, as structural support for the reactor coolant 19 system and included an aging management program."
20 And they reference an email from Ken --
21 Kenneth Karwoski, K-a-r-w-o-s-k-i to Greg Wemer and Art 22 Howell.
23 Then, at page 15, paragraph 31, Gunderson 24
36 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 states, "Documents related to subsequent inspections of 1
the St. Lucie two steam generators show that AREVA added 2
588 tubes -- new tubes to the original 8,411 tubes, now 3
totaling 8,999 tubes."
4 And further down in paragraph 31 Gunderson 5
states, "Finally, in order to accommodate the 588 new 6
tubes it is reasonable to infer that the region of the 7
tubesheet that had been directly above the stay cylinder 8
was now perforated with 588 new holes.
9 "As discussed in more detail below, the 10 purpose of the stay cylinder was to prevent tubesheet 11 flexing. The replacement steam generator in the St.
12 Lucie Unit 2 has a tubesheet with more holes in its 13 center precisely where more flexing is more likely to 14 occur."
15 And then, at page 17, paragraph 37, 16 Gunderson states, "While the replacement steam 17 generator tubes at the St. Lucie Unit 1 showed normal 18 wear over the past decade, an unusually high number of 19 tubes in the Unit 2 replacement steam generator 20 exhibited wear in 2009 during the very first inspection 21 after the replacement steam generators were installed.
22 "Demonstrations of tube wear continued to 23 increase in subsequent inspections in 2011 and 2012, and 24
37 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the latest inspection, September 2012 an astonishing 1
2,211 steam generator tubes, in Steam Generator A showed 2
7,646 wear indications, and 1,503 steam generator tubes 3
in Steam Generator B showed 3,988 wear indications.
4 "Of equal concern is the fact that the total 5
number of tubes exhibiting wear increased from 2,046 in 6
2009 to 3,714 in 2012, for an increase of 81 percent, 7
even before the extended power operating increase was 8
implemented." And then he provides a chart.
9 And then, at page 18, paragraph nine, 10 Gunderson states, "When St. Lucie was shut down for a 11 scheduled maintenance outage on March 3rd, 2014, FPL is 12 committed to inspect 100 percent of the steam 13 generators, as the NRC explained in a recent steam 14 generator update conference call.
15 "This will be the first outage following a 16 complete operating cycle under Unit 2's extended power 17 uprate. FPL has not committed to -- has not committed 18 to provide the results of the inspection before starting 19 the reactor again."
20 Before I move on to the next attachment, let 21 me restate the very last remark made by Mr. Gunderson 22 in which he stated, "FPL has not committed to provide 23 the results of the inspection before restarting the 24
38 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 reactor again."
1 At this time, and for the record, I am 2
incorporating supplemental requests into the instant 3
March 11th, 2014 enforcement petition submitted to the 4
NRC under Section 2.206.
5 The supplemental requests are that the NRC 6
require the licensee to maintain the St. Lucie Unit 2 7
Nuclear Reactor in a cold shutdown mode of operation 8
until, number one, the licensee provides the NRC the 9
results of the licensee's most recent inspection of the 10 St. Lucie Unit 2 steam generator tubes and components, 11 which is apparently completed during the current 12 refueling outage.
13 And, number two, the licensee identifies an 14 affirms exactly what the root cause of the steam 15 generator tube degradation and specifies exactly what 16 corrective actions will be taken and, three, completes 17 any and all specified corrective action to the St. Lucie 18 Unit 2 steam generators to prevent further tubes 19 degradation.
20 I would now refer to the PRB Members to 21, which is identified for the record as a 22 January 27th, 2014 letter from Siva P. Lingam, NRC 23 Project Manager, Plant Licensing Branch, to Mano Nazar, 24
39 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Executive Vice President and Chief Nuclear Officer at 1
Florida Power & Light Company. I have highlighted 2
points of interest in the document.
3 At page two, the document states that 4
approximately 11,518 indications of wear at the 5
antivibration bars were detected, 7,485 in Steam 6
Generator A, and 4,033 in Steam Generator B.
7 Of these indications, the number of new 8
indications was 1,623 in Steam Generator A and 1,070 in 9
Steam Generator B. The average growth rate for 10 effective full power year, 2.2 percent in Steam 11 Generator A and 0.6 percent in Steam Generator B 12 continues to decline.
13 The licensee is implementing a power uprate 14 in the next cycle of operation, cycle 20, incorporated 15 a wear rate increase of 24 percent in their operational 16 assessment to account for the effects of the power 17 upgrade.
18 So, based on -- based on a review of the 19 information provided -- this is me speaking now, not the 20
-- not the memo. Based on the review of information 21 provided, the NRC -- excuse me. This is still the memo.
22 IR. Based on a review of the information 23 provided, the NRC staff concludes that the licensee 24
40 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 provide the information required by the technical 1
specifications.
2 In addition, the NRC staff concluded there 3
are no technical issues that warrant follow-up actions 4
at this time, since the inspections appear to be 5
consistent with the objective of detecting potential 6
tube degradation and inspection results appear to be 7
consistent with industry operating experience at 8
similarly-designed and operating units.
9 The NRC staff notes, however, that the 10 number of wear indications is much greater than the 11 number of wear indications found at other AREVA steam 12 generators of similar age.
13 Okay. So, Petitioner notes here again for 14 the record that the date of the NRC letter to the 15 licensee of January 27th, 2014. The letter from 16 January 27th, 2014, the licensee apparently failed to 17 identify the root cause and continuing steam generator 18 tube degradation, and the NRC noted that the number of 19 wear indications is much greater than the number of wear 20 indications found at other AREVA steam generators of 21 similar age.
22 At this time, and for the record, I am 23 incorporating another supplemental request into the 24
41 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 instant March 11th, 2014 enforcement petition submitted 1
to the NRC under Section 2.206.
2 The supplemental request is that the NRC 3
require the licensee to maintain the St. Lucie Unit 2 4
Nuclear Reactor in a cold shutdown mode of operation 5
until the licensee provides the NRC evidence, test 6
results and expert opinion affirming that the increased 7
wear rate of 24 percent resulting from the extended 8
power operated of the St. Lucie Unit 2 will not cause 9
further steam generator tube degradation or accelerate 10 the current rate of steam generator 2 degradation or 11 cause a steam generator to burst in light of extensive 12 tube degradation currently existing and in 13 consideration of any additional stress placed on the 14 steam generator tubes due to the licensee's plugging 15 activities.
16 Summary, comments and conclusions. Based 17 on the facts currently known to the NRC related to the 18 excessive number of St. Lucie Unit 2 steam generator 19 tube wear indications, and the modifications made to 20 certain and specific tubesheet and tube support 21 components and other components, such as removal of the 22 stay cylinder from the St. Lucie Unit 2 steam 23 generators, the licensee cannot demonstrate any measure 24
42 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 of reasonable assurance that the St. Lucie Unit 2 1
nuclear reactor will be operating in full compliance 2
with NRC regulations and requirements under 10 CFR Part 3
- 50.
4 Moreover, because the licensee has failed, 5
to date, to identify and to correct the root cause of 6
the continuing degradation of the St. Lucie Unit 2 steam 7
generator tubes, the licensee cannot demonstrate any 8
measure of reasonable assurance that the St. Lucie 9
Nuclear Reactor will be operating in full compliance 10 with the NRC's regulations and requirements under 10 CFR 11 Part 50.
12 Finally, to the extent that the licensee 13 has implemented an extended power uprate at the St.
14 Lucie Unit 2, and plugged numerous steam generator 15 tubes, increased stress will be exerted on the degraded 16 tubes in the Unit 2 steam generators, and significantly 17 increase the likelihood of a nuclear accident result in 18 unwarranted release of radionuclides into the 19 environment which will adversely affect public health 20 and safety.
21 For all these reasons, the NRC should grant 22 the requests delineated in the 2.206 enforcement 23
- petition, as supplemented
- today, and issue a 24
43 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 confirmatory order to the licensee, requiring the 1
licensee to maintain the St. Lucie Unit 2 -- Nuclear Unit 2
2 in a cold shutdown mode of operation until an 3
independent third-party contractor can make a full 4
assessment of the St. Lucie Nuclear Unit 2 steam 5
generators, including a root cause determination for 6
the degradation of the steam generator tubes, and until 7
the licensee completed any and all corrective action.
8 When this meeting concludes today, you NRC 9
folks will return to your homes in and about the Greater 10 Washington, D.C. Area and far away from the potential 11 dangers of the St. Lucie Unit 2 Nuclear Plant.
12 However, I live here in Florida close to 13 that nuclear plant, and I have family and friends who 14 also live here in Florida close to that nuclear plant.
15 Well, please think about our safety when 16 you folks are considering the requests made in the 2.206 17 petition to protect public health and safety.
18 Thank you, Mr. Chairman, and I will stay on 19 the line to respond to any questions that you folks might 20 have.
21 CHAIR LEE: And thank you very much for 22 your information. And at this time, does the NRC staff 23 here at Headquarters have any questions for Mr.
24
44 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 Saporito?
1 (No response.)
2 CHAIR LEE: How about NRC staff at the 3
region?
4 MR. RICH: No questions here. Thanks.
5 CHAIR LEE: Does the licensee have any 6
questions?
7 MR. KATZMAN: No. No, we don't. Thank 8
you.
9 CHAIR LEE: Before I concluded the 10 meeting, members of the public may ask questions about 11 the NRC's 2.206 Petition process.
12 However, as stated at the opening, the 13 purpose of this meeting is not to provide an opportunity 14 for the Petitioner or the public to question or examine 15 the Petition that you brought regarding the merits of 16 the Petition Request.
17 So, does the public have any questions 18 regarding the 2.206 process?
19 (No response.)
20 CHAIR LEE: Okay. Not -- not hearing any, 21 so I select "None."
22 So, Mr. Saporito, thank you for taking time 23 to provide the NRC staff the clarifying information in 24
45 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 the Petition you have submitted.
1 And, before we close, does the court 2
reporter need any additional information for the 3
meeting's transcript?
4 COURT REPORTER: I have spellings from the 5
-- that I got during the presentation, but afterwards 6
I can get the names of people from you, from Ms. Regner.
7 MS. REGNER: Yes. You can give me a call.
8 Thanks.
9 I do have one quick questions, though, for 10 Mr. Saporito. You referred to an Attachment 7 that you 11 will submit to me, hopefully today. Does that include 12 your supplemental requests?
13 MR. SAPORITO: (No response.)
14 MS. REGNER: Mr. Saporito, are you still 15 there?
16 MR. SAPORITO: Yes. Yes. I am sorry. I 17 had to -- I had the mute button on by error there.
18 Yes. I will send you that today and it 19 includes the supplemental request and all the 20 information that I explained on the record today.
21 MS. REGNER: All right. Thank you.
22 MR. SAPORITO: You are welcome.
23 CHAIR LEE: Okay. With that, this meeting 24
46 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433 is concluded, and we will be terminating the phone 1
connection.
2 MS.
REGNER:
Thanks for your 3
participation, all.
4 (Whereupon, the teleconference was 5
concluded at 3:02 p.m.)
6 7
8 9
10 11 12 13 14