Official Transcript of Proceedings

NUCLEAR REGULATORY COMMISSION

Title 10 CFR 2206 Petition Review Board RE BraidwoodByron

Docket Number (na)

Location teleconference

Date Wednesday May 162012

Work Order No NRC-1624 Pages 1-31

IORIGINALI

NEAL R GROSS AND CO INC Court Reporters and Transcribers 1323 Rhode Island Avenue NW _ Washington DC 20005w)

(202) 234-4433

5

10

15

20

25

1

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

+ + + + +

10 CFR 2206 PETITION REVIEW BOARD (PRB)

CONFERENCE CALL

RE

BRAIDWOODBYRON

+ + + + +

WEDNESDAY

MAY 16 1 2012

+ + + + +

The conference call was held Bill

Ruland Chairman of the Petition Review Board

l

ll

presiding

PETITIONER BARRY QUIGLEY

PETITION REVIEW BOARD MEMBERS

BILL RULAND I PRB Chairman and Director

NRRDSS

JOEL S WIEBE Petition Manager for 2206

Petition

LEE BANIC I PRB Coordinator NRRDPR

ERIC DUNCAN Region 1111 Branch Chief

Division of Reactor Projects

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwne~grosscom

5

10

15

20

25

1

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

UNITED STATES OF AMERICA

NUCLEAR REGULATORY COMMISSION

+ + + + +

10 CFR 2206 PETITION REVIEW BOARD (PRB)

CONFERENCE CALL

RE

BRAIDWOODBYRON

+ + + + +

WEDNESDAY

MAY 16 1 2012

+ + + + +

The conference call was held Bill

Ruland Chairman of the Petition Review Board

l

ll

presiding

PETITIONER BARRY QUIGLEY

PETITION REVIEW BOARD MEMBERS

BILL RULAND I PRB Chairman and Director

NRRDSS

JOEL S WIEBE Petition Manager for 2206

Petition

LEE BANIC I PRB Coordinator NRRDPR

ERIC DUNCAN Region 1111 Branch Chief

Division of Reactor Projects

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwne~grosscom

5

10

15

20

25

2

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

ED SMITH NRRDSS Balance of Plant Branch

PREM SAHAY NRRDE ectrical Engineering

Branch

AHSAN SALLMAN NRRDSS Containment and

Ventilation Branch

ALEXANDER TSIRIGOTIS NRRDE Mechanical and

Structural Engineering Branch

NRC HEADQUARTERS STAFF

MICHELLE ALBERT Office of General Counsel

LAUREN CASEY Office of Enforcement

NICOLE COLEMAN Office of Enforcement

KIMYATA MORGAN BUTLER NRRDPRGeneric

Communications Branch

JAKE ZIMMERMAN NRRDORL

NRC REGION III STAFF

BRUCE BARTLETT Senior Resident Inspector

Byron Generating Station

TRAVIS DAUN Resident Inspectors Office

Byron Generating Station

RAYMOND NG Project Engineer

JOHN ROBBINS Resident Inspector Byron

Generating Station

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW (202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

3

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

JAMIE BENJAMIN Senior Resident Inspector

Braidwood Generating Station

ALEX GARMOE Resident Inspector Braidwood

Generating Station

ALSO PRESENT

TOM COLE Braidwood Generating Station

Engineering Staff

DAN ENRIGHT Braidwood Generating Station

Site Vice President

AMY FERKO Braidwood Generating Station Site

Engineering Director

MARK KANAVOS Braidwood Generating Station

ant Manager

CHRIS VANDENBURGH Braidwood Generat

Station Regulatory Assurance Manager

DAVE GUDGER Byron Generating Station

Regulatory Assurance Manager

TRACY HULBERT Byron Generating Station

Regulatory Assurance

CHUCK KELLER Byron Generating Station Acting

Design Manager

DAVE GULLOTT Exelon Corporate censing

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

4

MIKE

2

3

4

1

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

(202) 234-4433

PERRY Illinois Management

Agency Resident Inspector for Braidwood

Generating Station

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

5

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

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

(1005 am)

MR WIEBE My name is Joel Wiebe I am

the Braidwood and Byron Stations Project Manager

This is the Petition Review Board

discussion with the Petitioner of the 2206 petition

dated April 20 2012

The Petition Manager for the petition shy

the Petition Review Board Chairman is 11 Ruland

And one thing could I ask the ones who

arent talking to go on mute and then go off mute

when you want to say something

As part of the Petition Review Boards

review of this petition the Petitioner Barry

Quigley has requested this opportunity to address the

PRB The meeting is scheduled from 1000 to 1100

Eastern Time The meeting is being recorded by the

NRC Operations Center and is also being transcribed by

a Court Reporter

The transcript itself will become a

supplement to the petition and the transcript will be

made publicly available

I would like to open this meeting with

introductions and we will go around the room in

headquarters first I would 1 ike to ask you to

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE Nw (202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

6

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

clearly state your name your posi tion and the office

you work for within the NRC

I will start off My name again is Joel

Wiebe I am a Project Manager with NRR

MR SALLMAN My name is Sallman I work

with the Containment - my position is Reactor Systems

Engineer and I work for the Division of Safety

Systems in the Containment and Ventilation Branch

MS BUTLER Kimyata Morgan Butler in the

Division of Policy and Rulemaking in NRR Im the

Acting Branch Chief of the Generic Communications

Branch

MS COLEMAN Im Nicole Coleman an

Enforcement Specialist in the Office of Enforcement

MS CASEY Im Lauren Casey an

Enforcement Specialist in the Office of Enforcement

MR SAHAY 11m Prem Sahay P-R-E-M S-Ashy

H-A-Y Im an Electrical Engineer work for NRR

Electrical Engineering Branch

MR TSIRIGOTIS Alexander Tsirigotis

Division of Engineering l Mechanical and Structural

Engineering Branch

MR DUNCAN And in Region III my name is

Eric Duncan I am the Branch Chief for Branch III BRP

for Byron and Braidwood And also Raymond Ng is

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

I

5

10

15

20

25

7

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

here and he is the Project Engineer for Branch III

MR BARTLETT This is Byron Resident

fice Weve got Bruce Bartlett Im the Senior

Resident Weve got John Robbins he is the Resident

And we have Travis Daun

MR BENJAMIN At the Braidwood resident

inspector office we have Jamie Benjamin the Senior

Residenti Alex Garmoe the Resident Inspector and we

also have Mike Perry with the Illinois Emergency

Management Agency He is the Resident Inspector of

Braidwood

MR SMITH Here at headquarters this is

Ed Smith DSS Balance of plant Branch

MR ZIMMERMAN Jake Zimmerman Branch

Chief Division of Operating Reactor Licensing

MS ALBERT Michelle Albert At torney in

the Office of General Counsel

MS BANIC Lee Banic 2206 Petition

Coordinator NRR

MR RULAND 11 Ruland Director of the

Division of Safety Systems in NRR and the PRB Chair

MR WIEBE Okay That completes the

introductions at NRC headquarters and the other NRC

participants Is there any other NRC participants

that have not introduced themselves

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

8

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

(No response)

Okay Are there any representatives from

the licensee on the phone

MR ENRIGHT Yes This is Dan Enright at

Braidwood Station Im the site Vice President With

me are Mark Kanavos Plant Manager i Chris Vandenburgh

Regulatory Assurance Manager i Amy Ferko Site

Engineering rectorj and Tom Cole of our engineering

organization

MR GUDGER This is Dave Gudger at the

Byron Nuclear Station Im the Regulatory Assurance

Manager I have with me Chuck Keller Acting Design

Manager and Tracy Hulbert Regulatory Assurance

MR GULLOTT This is Dave Gullott Exelon

Corporate Licensing

MR WIEBE Okay Mr Quigley would you

introduce yourself for the record

MR QUI GLEY Yes My name is Barry

Quigley Q U-I G-L-E Y

MR WIEBE Okay Thanks It is not

required for members of the public who may be on the

phone to introduce themselves for the call However

if there are any members of the public on the phone

who do wish to introduce themselves please do so at

this time

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

9

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

(No response)

Okay Hearing none t I would like to

emphasize that we each need to speak clearly and

loudly to make sure the Court Reporter can hear you

and accurat y transcribe the meeting Also t first

state your name before you say something That way

the Court Reporter knows who to attribute the comment

to

For those who are dialing into the

meeting please remember to mute your phones tot

minimize the background noise If you do not have a

mute button t you can mute by pressing the keys star

and then six To unmute t you can press the star six

key again Thanks

At this timet I will turn it over to the

PRB Chairman t Bill Ruland

MR RULAND Thank you t Joel Good

morning Welcome to this meeting regarding the 2206

petition submitted by Mr Quigley

I would like to first share some

background for our process Section 2206 Title X

of the Code Federal Regulations describes the

petition process tithe primary mechanism for the public

to request enforcement action by the NRC II It is a

public process

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

10

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

This process permits anyone to petition

NRC to take enforcement type action related to NRC

licensees or licensed activities Depending on the

results of this evaluation NRC could modify suspend

or revoke an NRC-issued license or take any other

appropriate enforcement action to resolve a problem

The NRC staffs guidance for the

disposition of a 2206 petition request is in

Management Directive 811 which is publicly

available

The purpose of todays meeting is to give

the Petitioner an opportunity to provide any

additional explanation or support for the petition

before the Petition Review Boards initial

consideration and recommendation This meeting is not

a hearing nor is it an opportunity for the Petitioner

to question or examine the PRB on the merits of the

issues presented in the petition request

No decisions regarding the merits of this

petition will be made at this meeting Following this

meeting the Petition Review Board will conduct its

internal deliberations The outcome of this internal

meeting will be discussed with the Petitioner

subsequently

The Petition Review Board typically

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

11

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

consists of a Chairman l usually a manager at the

senior executive level at the NRC It has a Petition

Manager and a PRB Coordinator I who already have

introduced themselves Other members of the Board are

determined by the NRC staff based on the content of

the information in the petition request

First l I would like to introduce the

Board Of course I myself I Bill Ruland l I am the

Peti tion Review Board Chairman Joel Wiebe I who is

who gave us the introduction l is the Petition Manager

the petition under discussion today Lee Banic is

the fices PRB Coordinator

Our technical staff includes l but is not

limited tOI Ed Smith who is in the Balance of ant

Branch in the Division of Safety Systems in NRRi Prem

Sahay who is in the Division of Engineering in

Electrical Engineering Branch exander Tsirigotis

who is in theDivision Engineering Mechanical and

Civil Engineering Branch Ahsan Sallman who is in the

Containment and ventilation Branch in NRR and Eric

Duncan who is a Branch Chief in Region III in the

Division of Reactor Projects

We also obtained advice from the Office of

General Counsel represented by Michelle Alberti and

the Office of Enforcement I represented by Nicole

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE Nw

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

12

Coleman

As described in our process the NRC staff

may ask clarifying questions to better understand the

Peti tioner s presentation and to reach a reasoned

decision whether to accept or reject the Petitioners

request for review under the 2206 process

Now I would like to summarize the scope

of the petition under consideration and the NRCs

activities to date On April 20 2012 Mr Quigley

submitted to the NRC a petition under 2206 regarding

Braidwood Units 1 and 2 and Byron Units 1 and 2

In this petition Mr Quigley identified

the following areas of concern He requested that the

NRC require Braidwood Uni ts 1 and 2 and Byron Uni ts 1

and 2 to be immediately shut down until all turbine

building high energy line break concerns are

identified and those important to safety are

corrected

As the basis for this request Mr Quigley

states that the physical layout of the Byron and

Braidwood plants exposed both trains of emergency

electric power generation alternating current

distribution ESF batteries and a direct current -shy

and direct current distribution to the effects of non-

safety-related piping failures

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW (202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

13

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

Mr Quigley states that the design flaw

was missed during initial licensing and the potential

to disable mul tiple trains of safety related equipment

was first identified in 1991 He states that some

analysis was performed but work stopped short

of a comprehensive review of the HELB or high-energy

line break regulatory requirements

Mr Quigley identified the following major

issues One the emergency diesel generators are

affected by H-E L-B - Ill use those initi s from

now on or HELB because steam can enter the

emergency diesel generator rooms the emergency diesel

generator room ventilation and the emergency diesel

generator air intakes

Engineered safety features or ESF

switchgear rooms - this is the second item - are

af ed because of the potential of high temperature

to alter protective relay set points

Three the current method of analysis for

turbine building HELB uses a lumped volume approach

which substantially reduces energy effects and does

not always give conservative results Preliminary

assessment using GOTHIC subdivided volume features

shows structural limits substantially exceeded on the

block wall between the ESF switchgear rooms

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE Nw

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

14

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

Four there has been no structured and

detailed review of the licensing requirements

regarding impacts on equipment operability for turbine

building high energy line break or HELB

Next I will discuss NRC activi ties to

date On April 26 2012 the Petition Manager

contacted the Petitioner to discuss the 10 CFR 2206

process and to offer him an opportunity to address the

PRB by phone or in person The Petitioner requested

to address the PRB by phone prior to its internal

meeting to make the initial recommendation to accept

or reject the petition for review

On May 4th also of this year the PRB met

internally to discuss the request for immediate

action The PRB denied the request for immediate

action of shutdown - excuse me The PRB denied the

request for immediate shutdown of the fected plants

because the licensee had completed an operability

determination finding the equipment was operable but

degraded

Instead based on the potential hazardous

conditions presented in the petition we determined

that a 10 CFR Section 2204 demand for information

would be initiated for the purposes of determining

whether an order under 2202 should be issued or

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW (202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

15

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

whether other action should be taken

The PRB may stop or continue the

processing of the Section 2204 demand for information

based on further internal meetings accordance with

the 2206 process

On May 14 2012 the Petitioner was

informed of the PRBs decision to deny the request for

immediate action

As a reminder for the phone participants

please identify yourself if you make any remarks as

this will help us in the preparation of the meeting

transcript that will be made publicly available

Thank you

Mr Quigley I will ask you now to provide

any information that you believe the PRB should

consider as part of its petition Mr Quigley

MR QUIGLEY Thank you I will be

pausing as I go through to allow for questions first

talking a little bit about the physical layout At

Byron and Braidwood the turbine building shares a

wall with the safety-related aux building The diesel

generators and ectrical equipment rooms are located

the aux building but they have ventilation and

personal access openings in a shared wall with the

turbine building

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

16

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

The ventilation for these areas is

relatively simple consisting of using fans to blow

outside air through areas Al though the source of

the air is a safety-related intake air shaft the

exhaust openings are simply holes in the turbine

building wall

As far as the history of HELB the NRC

asked several questions related to HELB outside

containment during initial licensing Additional

analyses were done but nei ther the NRC or

Commonwealth Edison noticed the large openings

approximately five foot by five foot between the

turbine building and the dies generator and

switchgear rooms

In 1991 the NRC partially noted the

potential for a turbine building HELB to effect the

diesel generator switchgear and diesel generator

However the NRC only allowed Commonwealth Edison 90

days to reply Therefore the analysis done was

limited

Basical the analysis took credit for

fire dampers in the turbine building exhaust openings

to drop and isolate the areas from the fects of the

high energy line break Credit was also taken

turbine building siding to blow off and relieve the

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE Nw

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

17

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

pressure In the turbine building

Additional work was done in 1996 related

to piping break locations Stress calculations were

done to eliminate some locations In 2011 it was

noted that the assumed fire damper drop time was

substantially in error An operability evaluation was

completed which showed acceptable temperatures based

on more thermal hydraulic analyses that were done

I note that Mr Ruland stated that the

immediate request was denied in part on the presence

of the op eval I did not have that information prior

to today BasicallYt I wrote the op eval The only

thing that the Byron op eval addresses is fire dampers

taking too long to drop

MR RULAND Mr Quigley Ive got a

question for you

MR QUIGLEY Certainly

MR RULAND Since you wrote the original

operabilityevaluation t and apparently determined that

the equipment was operable but degraded what has

changed from the time you wrote and signed off on that

operability evaluation and the present time

MR QUIGLEY The operability evaluation

only dealt with the fact that the fire dampers take

too long to drop Thats all it deals with I had

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

18

this information at the time but I could not show

operabil

MR RULAND So you didnt include this

other information in the op eval nor did you write a

non-conformance or a condition report whatever you

call it at those stations at that time

MR QUIGLEY I made my management aware

of - - my engineering management aware of the technical

concerns I had

MR RULAND Okay Thanks

MR QUIGLEY Yep Talk a little more of

the history and a little bit more the structural

layout So the basic high energy line break concern

is that we have a non-safety-related steam or feedline

rupture in the turbine building pressurized within

the turbine building And since these diesel rooms

and switchgear rooms are connected the adverse

environment for the turbine building can propagate

into the safety-related areas

So we had recognized that at some point

However as I looked at it more detail thats

where these additional issues under the basis

request come from

Well the first one I want to t k about

is the combustion air for the diesel generator As I

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

19

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

said the ventilation for this system is relativelyl

simple For temperature control I it relies on a

recirculation mode BasicallYI when it is hot air

outside or hot in the diesel room l it draws air in

through the intake sha through a fan l and out

through a hole in the turbine building wall

If the temperatures are cooler there is

a recirculation damper that opens up And what that

recirculation damper does is allows the fan to

basically isolate the outside air path and just

recirculate air through the room It is that

recirculation path that is of concern for combustion

air

When the turbine building pressuri zes and

then the pressure comes in and steam comes into the

diesel generator room l the damper configuration can be

such that steam flows back into the intake air shaft

The diesel generator combustion air supply is located

approximately eight feet from that point So the

concern would be that the diesel l when it is either

trying to start or already running l could draw in some

steam that is coming through this other path

Now that is very difficult to visualize

perhaps So if there is any questions on how that is

laid out I will take them right now

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW (202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

20

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

(No response)

Okay Hearing none I will move on So

potentially instead of having 100 percent air the

diesel generator could be trying to run or start on a

steam air mixture And we have not undertaken to find

out the capability of the engine to do so nor have we

undertaken to find out how much steam will actually

get to that location

Also as I was thinking further about

this the turbocharger on the diesel engine could also

be at risk because now we have a pressurized air

intake if you will So that could raise concerns

with the ability of the turbocharger to carry that

additional bus load

The next item I had was that the effects

of high temperature in the switchgear rooms on the

protected relay has not been evaluated

We did look at motor control centers

However the four kv switchgear was not rigorously

looked at So the concern would be that the

temperature effects could cause the relays to fail to

actuate when desired or the relays could actuate

earlier than desired

We have not fully considered the

environment in the switchgear room including the

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW (202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

21

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

ssurization effects These reI have glass

covers on them If the pres zation breaks the

glass it follows the relay We not considered

any of that

The next item is reI to the modeling

The way that a high energy I break outside

containment has been modeled the past both at

Byron and other utilities is wi a lumped volume

approach I paused when I d because there is

no NRC approved methodology for culating pressures

and temperatures for HELBs fsite containment

So as I was looking at the lumped volume

approach I created a side model if you will and

started looking at the effects of subdivided volumes

where the area is divided up 0 a much finer mesh

When I did that I got results were contrary to

those in the model currently progress

What I was focusing on was the switchgear

rooms Our switchgear rooms Alpha and Bravo

Divisions -- are located adjacent to each other and

are separated by a block wall on in the HELB

reconstitution we noted that block wall had very

little margin in it and there were concerns that we

could exceed the structural limits on the wall

We resolved that in the rna part of the

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

22

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

proj ect separately However when I looked at it

under a subdivided approach we would exceed the

structural capability on that wall by about a factor

of three So the subdivided approach yields more

accurate results and unacceptable results

MR RULAND Just hold on a second Mr

Quigley

MR QUIGLEY Yep

MR SALLMAN This is Ahsan Sallman from

the Containment and Ventilation Branch I understand

that you did a subdivided approach Could you explain

more about this How many divisions for the lumped

model and what was the outcome of that

MR QUIGLEY For the model that Exelon is

currently working on the 426 elevation is about 13

million cubic feet I divided that up into six

smaller lumped volumes and then the area in front of

the switchgear rooms is approximately 110 feet by 45

feet I divided that up into about 800 sub-volumes

And then I also modeled the switchgear rooms as

subdivided volumes with connections into the turbine

building

So what I saw there was if I put a break

outside of that subdivided volume as the pressure -shy

as the whole model pressurizes the pressure moves

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW (202) 234middot4433 WASHINGTON DC 20005middot3701 wwwnealrgrosscom

5

10

15

20

25

23

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

into the subdivided volume I and it reaches one of the

switchgear rooms before it reaches the other and thenI

it starts to pressurize that room

And then l several milliseconds later l the

other room starts to pressurize And then l after a

period of timel the pressures in the rooms

switchgear rooms stabilized And then I when the

turbine building siding blows off I and the model

depressurizes l the rooms do not depressurize at the

same rate

SOl againl there is depressurization of

the building We get another excessive differential

pressure across the switchgear room wall

MR SALLMAN You said there were six

smaller lumped volumes for - which building was that

MR QUIGLEY For the 426 elevation of the

turbine building

MR BARTLETT HeYI BarrYI this is Bruce

Bartlett

MR QUIGLEY Yes

MR BARTLETT Wouldnt that so work if

the dampers in one of the switchgear rooms worked and

the dampers in the other swi tchgear room had your

single failure and didnt work You can generate a

differential pressure across the wall that way also

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

24

MR QUIGLEY Yes With that -- those

other dampers that we are considering putting in

MR BARTLETT Thank you

MR QUIGLEY Right That is one of the

problems that we are trying to work through on the

dampers were putting in The scenario that I am

talking about right now exists today independent

any damper installation

Now again this is the first thing I

looked at with the subdivided model So I would

anticipate that a further subdivided model would

uncover further non-conservatisms I have looked at

this particular one enough to be confident that

modeling-wise there is not a whole lot that can be

done to make it better

Were there any other questions on the

modeling aspects

MR BARTLETT No not from here from

headquarters

MR QUIGLEY Thank you

MR RULAND Mr Quigley why dont we

because I you know we - I would like to see if we

can finish this meeting today on time And if we need

further time we will have to just reschedule and have

another phone call

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234middot4433 WASHINGTON DC 20005middot3701 wwwnealrgrosscom

5

10

15

20

25

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

But so why dont you just kind of go

through your entire list right now and then we will

come back and ask questions How does that sound

MR QUIGLEY Well thats fine But Ive

only got one more item on the list

MR RULAND Oh Then I guess thats

easy

MR QUIGLEY Right The next one is that

there has been no structured and detailed review of

the licensing requirements for HELB As I said

earlier HELB got missed during initial licensing

When the issue was identified by the NRC

in 1991 the company responded The NRCs followup

inspection was not a licensing type of review It

just looked at the response and accepted the response

So in 1991 we had a chance and didnt get there

In 96 it was looked at a little bit

further but only for piping stresses In 2001 we

looked at the HELB issue again and that is when we

found out that the fire damper assumption the fire

damper drop time assumption was in error

We did a lot of work but we have still

not done a structured review of HELB We have not

picked up the standard review plan gone through it

line by line and found all of the problems

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

MR RULAND Mr Quigl could you

would it be possible since it might help us expedite

our actions on this to provide those references You

talked about 91 and shy

MR QUIGLEY Yes

MR RULAND 96 and you know

several inspection reports I f you could provide

those references to us it would be helpful

MR QUIGLEY I can do that

MR RULAND And he would provide them

through to you Joel

MR WIEBE Yes right

MR RULAND Okay Okay Continue

MR QUIGLEY I would also note that the

licensee has entered the items of my petition into the

corrective action process So basically the four

bullets of the petition were entered into CAP

I would note that the rationale for

acceptability is weak and at times I that the

rationale is dismissive In particular when it talks

about the GOTHIC analysis it refers to the work I

have done as preliminary informal which is true but

Exelon is making no effort to resolve it So I feel

that by saying it is informal it is preliminary that

is dismiss

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

27

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

Also the IR alludes to a HELB resolution

team and a HELB resolution effort I dont see that

What I see is an organization trying to resolve the

minimum amount of possible with high energy line

break so that we can get our MUR approval

So does anybody have any followup

questions before I conclude

MR RULAND Hold on a second Ive just

got a question for the - - youre the Petition Manager

right Joel Could you tell us what the status of

those MUR approvals are

MR WIEBE We are in the latter stages of

our review We have about three safety evaluation

inputs left from the tech staff

MR RULAND Okay And they have been inshy

house about - what about a year or so or

MR WIEBE For the application

MR RULAND Yes

MR WIEBE Yes the year is up in June

MR RULAND Okay I just wanted to get

a perspective on where they were Hold on a second

Im going to go on mute for a minute

(Pause)

Yes We were just trying to understand

how this fit into MUR issue and you know at this

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW (202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

28

point it is uncertain But we understand your point

MR QUIGLEY Thank you

MR RULAND So any more questions for Mr

Quigley from this room

(No response)

We have no more questions

Any other NRC participants

MR QUIGLEY Well I wasnt quite done

yet

MR RULAND Oh Im sorry Go ahead

MR QUIGLEY Thats fine I have been

involved with the turbine building HELB analysis for

22 years now I have struggled to get Exelon to

resolve it I have not been successful

I performed the operability evaluation

last year in the hope that that would move us along

I focused the op eval solely on the fire damper delay

times Then when I was challenged by management to

add additional information I told them that I

couldnt because I didnt know that it would support

operability

Based on what I know now -- I was an SRO

for 15 years I have been involved in this analysis

for 21 years I I have been doing operability

evaluations for eight years - I see no rational basis

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

29

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

to conclude that the diesel generators and the ESF

switchgear rooms are operable

That concludes my remarks

MR RULAND Thank you Mr Quigl Now

let me ask again is there any other questions in the

room here

(No response)

Any other NRC participants have a

question

(No response)

Does the licensee have any questions

(No response)

Hearing none did we ever establish

whether or not there was a member of the public

listening in

MR WIEBE No No member of the public

spoke up

MR RULAND Spoke up So I will just

assume that there was and I will are there -shy

before I conclude this meeting members of the public

may provide comments regarding the petition and ask

questions about the 2206 process

However as stated in the opening the

purpose of this meeting is not to provide an

opportunity for the Petitioner or the public to

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

30

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

question or examine the PRB regarding the members

regarding the merits of the petition request

So are there any members of the publ ic

that have a question or comment about the petition

process

(No response)

Having heard none let me just ask a

process question So anything else before we close

the meeting Counsel do we have anything else

(No response)

Okay Mr Quigley I thank you for taking

the time to provide the NRC staff with clarifying

information on the petition you have submitted

Before we close does the Court Reporter

need any additional information the meeting

transcript

THE COURT REPORTER Hello This is the

Court Reporter and I am going to email Mr Wiebe if

that is okay with him to confirm the names of some

the participants

MR WIEBE Yes thats good

THE COURT REPORTER Thank you

MR RULAND Okay With that this

meeting is concluded and we will be terminating the

phone connection Again thank you everyone for

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTON DC 20005-3701 wwwnealrgrosscom

5

10

15

20

25

31

1

2

3

4

6

7

8

9

11

12

13

14

16

17

18

19

21

22

23

24

participating

(Whereupon at 1047 a m the

proceedings in the foregoing matter were

conc1uded )

(202) 234-4433

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW WASHINGTON DC 20005-3701 wwwnealrgrosscom

CERTIFICATE

This is to certify that the attached proceedings

before the United States Nuclear Regul

Commission

Proceeding 10 CFR 2206 Petition of BraidwoodByron by Barry Quigley

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 typewrit under my

direction and that said transcript is a true and

accurate record of the proceedings

Official er Neal R Gross amp Co Inc

NEAL R GROSS COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE NW

(202) 234-4433 WASHINGTONDC 20005middot3701 wwwnealrgrosscom