ML052150443

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E-Mail from Lyman to Power Uprate Et Al., VY News, Thursday May 22, 2003
ML052150443
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 05/22/2003
From: Layman P
Entergy Nuclear
To: Pulsifer R
NRC/NRR/DLPM/LPD1
References
FOIA/PA-2005-0031
Download: ML052150443 (16)


Text

From:

"Lyman, Pat" <PLYMA90@entergy.com>

To:

"_Power Uprate" <_PowerUprate@prod.entergy.com>, "Al Chesley" al.chesley@netzero.net>, "Al Parker" <AI.Parker@vynpc.com>, "Alan Haumann"

<Alan.Haumann @vynpc.com>, "Alan Robertshaw" <arober6@prod.entergy.com>, "Amelia Scharrer" <AScharr@prod.entergy.com>, "Art Wiese" <awiese@entergy.com>, "Audra Williams" <Audra.Williams@vynpc.com>, "B. Cosgrove" <brendan@vermont.org>, "Barbara Williams" <Barbara.Williams@vynpc.com>, "Bernard Buteau" <Bernard.Buteau@vynpc.com>,

"Bernie Jwaszewski" <Bernie.Jwaszewski @ vynpc.com>, "Beth Sienel"

<bsien9O@prod.entergy.com>, "Bill Lynch" <Bill.Lynch@vynpc.com>, "Bob DeAngelo"

<deangrj @ nu.com>, "Bob Pulisifer" <rmp3 @ nrc.gov>, OBoguslawski"

<john.boguslawski @adelphiabusiness.net>, "Bonnie Notte" <bnotte @ prod.entergy.com>,

"Bonnie O'Rourke" <borourk@cvps.com>, "Brian Cosgrove" <Brian.Cosgrove@vynpc.com>,

"Brian Finn" <Brian.Finn@vynpc.com>, "Bryan Croke" <bcroke@prod.entergy.com>, "Candy Sak" <Candy.Sak @ vynpc.com>, "Carl Crawford" <ccrawfo@entergy.com>, "Charles Edwards"

<Charles.Edwards@vynpc.com>, "Chris Hansen" <Chris.Hansen@vynpc.com>, "Chris Wamser" <Chris.Wamser@vynpc.com>, "Christina Canty" <Christine.Canty@vynpc.com>,

"Christina Strubbe" <cstrubbe @ ctel.net>, "CONNIE WELLS' <CWELLS @ entergy.com>, 'Craig Nichols" <Craig.Nichols @vynpc.com>, "David Andrews" <David.Andrews @vynpc.com>, "David Mannai" <David.Mannai@vynpc.com>, "David McElwee" <David.McElwee@vynpc.com>,

"David Pelton" <dpelt9O@prod.entergy.com>, "DEBORAH WAGLEY"

<DWAGLEY@entergy.com>, "Diane McCue" <Diane.McCue~vynpc.com>, "Dolord DeForge"

<Dj.DeForge@vynpc.com>, "Don Leach" <Don.Leach@vynpc.com>, "Dorothy Schnure 2"

<schnure @ greenmountainpower.biz>, "Duncan Higgins" <dhiggins @dps.state.vt.us>, 'Dutton Christopher" <dutton@gmpvt.com>, "Ed Matson" <Ed.Matson@vynpc.com>, "Eve Finkenstadt"

<Eve.Finkenstadt@vynpc.com>, "F. Greenman" <greenman@yankee.com>, "Frank Lipinski"

<Frank.Lipinski@vynpc.com>, "Fred Marcussen" <Fred.Marcussen@vynpc.com>, "G Franklin"

<gfranklin @ ecvtlaw.com>, "George Thomas" <gthomas @ prod.entergy.com>, "George Wierzbowski" <George.Wierzbowski@vynpc.com>, "Greg Brede <Greg.Brede@vynpc.com>,

"Harry Sutton" <Harry.Sutton~vynpc.com>, "Howard C Shaffer" <howardmariann@juno.com>,

"Kent Brown" <kbrown@cvps.com>, "James Callaghan" <James.Callaghan~vynpc.com>,

"James Kritzer" <jkritze@prod.entergy.com>, "James Rogers" <James.Rogers@vynpc.com>,

"Jan Bennett" <Jan.Bennett@vynpc.com>, "Jay Thayer" <jthayer@entergy.com>, "Jeff Meyer"

<Jeff.Meyer~vynpc.com>, "Jill Smith" <jsmit43@entergy.com>, "Jim Devincentis"

<Jim.Devincentis @vynpc.com>, 'Jim Muckerheide" <jim.muckerheide @ mema.state.ma.us>,

"John Hoffman" <John.Hoffman~vynpc.com>, "John Lampron" <damp44@aol.com>, 'John Moriarty" <John.Moriarty@vynpc.com>, "John OConnor" <John.OConnor@vynpc.com>, "John Patrick" <JPATRIC@prod.entergy.com>, "Karen Mego" <Karen.Mego@vynpc.com>, 'Kevin Bronson" <Kevin.Bronson @vynpc.com>, "Kilburn" <bobbi.kilburn @adelphiabusiness.net>,

"Larry Smith" <Larry.Smith@vynpc.com>, "Liliane Schor" <Liliane.Schor@vynpc.com>, "Lori Tkaczyk" <Lori.Tkaczyk @ vynpc.com>, "Lynn DeWald" <Idewald @ prod.entergy.com>, "MEMA"

<tanyia.gosselin@mema.state.ma.us>, "Mike Desilets" <Mike.Desilets@vynpc.com>, "Mike Empey" <Mike.Empey@vynpc.com>, "Mike McKenney" <Mike.McKenney@vynpc.com>, "Mike Metell" <Mike.Metell@vynpc.com>, "Milton Eaton" <maeshe@sover.net>, "MYRA NORVILLE'

<MNORVIL @entergy.com>, 'Nancy Blake" <Nancy.Blake @vynpc.com>, "NEI' <sck @ nei.org>,

"Pat Corbett" <Pat.Corbett@vynpc.com>, "Pat McKenney' <Pat.McKenney@vynpc.com>,

"Paul Rainey" <Paul.Rainey@vynpc.com>, "Pedro Perez" <Pedro.Perez@vynpc.com>, "Peri Hall" <perihall @ compuserve.com>, "Poulin Gerald" <geraldcpoulin @ aol.com>, "R. Barkhurst"

<siverkingjr @ earthlink.com>, "Richard Bargeron" <Richard.Bargeron @vynpc.com>, "Richard January" <Richard.January@vynpc.com>, "Rick McCullough" <Rick.McCullough@vynpc.com>,

"Rob Williams" <Rob.Williams@vynpc.com>, "Robert H. Young" <byoung@cvps.com>, "Robert Martin" <robertmartin@nstaronline.com>, "Robert Smith" <Robert.Smith@vynpc.com>,

"Robert Sojka" <Robert.Sojka@vynpc.com>

Date:

5/22/03 8:27AM

Subject:

VY News, Thursday, May 22, 2003.doc

1. Lawmakers reach deal on renewable energy - Rutland Herald
2. not found in the Reformer Guilford Selectboard Mtg/Pat Lyman - evacuationplans.org
3. Oyster Creek nuclear plant shut down after power interruption
4. Partial Transcript of Regional Commission - VY Meeting - ibrattleboro.com VY Daily News Thursday, May 22, 2003 If you have news items to contribute contact Pat Lyman - plyma90@entergy.com Rutland Herald, Thursday, May 22, 2003 Lawmakers reach deal on renewable energy By TRACY SCHMALER Vermont Press Bureau MONTPELIER - House and Senate leaders reached a compromise Wednesday on a bill designed to increase Vermont's energy independence by promoting the use of environmentally friendly power.

The measure was thought to be dead for weeks because the two chambers were at an impasse over a controversial provision in the Senate-backed bill. The provison would have mandated utilities to buy a percentage of their power from renewable energy sources such as wind and solar.

The House opposed the controversial "renewable portfolio standard" provision, arguing that the mandate on utilities would increase costs for all ratepayers.

The Senate's bill would have required utilities to buy 1 percent of their power from green sources in 2004, 2 percent in 2005, 3 percent in 2006 and then at a percentage set by the Public Service Board.

Senate President Pro Tem Peter Welch, D-Windsor, agreed to take that provision out.

"Our choice was a bill making it voluntary for utilities or no bill at all. We chose voluntary,"

Welch said. "We know how to say yes."

Instead of that provision, the bill calls for a study of the costs of such power and promotes a "green pricing" program where customers could ask to buy electricity that comes from renewable or clean sources.

If that power costs more than regular electricity, those customers alone would bear the added expense.

"Everybody wins with this bill," said John Sales, deputy commissioner of the Department of Public Service.

Some utilities, including Green Mountain Power Corp., already offer consumers a choice. But the bill would set clear parameters for that company and others that want to offer customers the option without having to increase rates for all.

The program is contingent upon approval from the Public Service Board, Sales said.

We give the House and Senate a lot of credit for moving forward with this," said Patrick Berry of the Vermont Natural Resources Council, an environmental advocacy group. "We'd rather see a baby step moving forward with renewable energy than no step at all."

The bill would also:

u Give the board the authority to try alternative regulation schemes allowing utilities to make greater profits if they meet standards for encouraging efficiency and using renewable energy, and reduce their profits if they don't.

u Spend $750,000 from penalties collected from oil companies to support local projects that use alternative energy systems.

u Provide customers with the opportunity to invest in the development of new technology and facilities such as wind turbines.

u Allow utilities to purchase tradable renewable energy credits that they can in turn sell.

The bill still has to clear hurdles in the House, but leaders said Wednesday that the agreement with the Senate all but secured its passage.

The compromise signaled some progress for the Legislature as it tries to meet its goal of adjourning later this week.

But lawmakers still have significant bills to work out before they can leave for the year. Most significant are the state budget, changing the way the state pays for education, and reforming the state's environmental permitting process.

House and Senate negotiators on the state budget appear to be close to a deal, with both sides agreeing on a general fund budget of roughly $900 million.

Members of the committee trying to polish off a mutually acceptable budget were optimistic that a compromise could be reached on some of the lingering line items in the next day or so.

Meanwhile, lawmakers working to find common ground on the competing proposals to change the state's environmental permit process couldn't have been farther from a resolution Wednesday.

"I think we're quite a ways apart between the House and the Senate,' said Sen. Phil Scott, R-Washington. 'I think it would be very difficult to bridge the gap between the House and Senate plans."

Scott is on the joint House and Senate conference committee that has been meeting for days, trying to settle the differences in the two bills.

On Wednesday, the future looked dim when senators offered a counterproposal to House negotiators that opposed consolidating all permit appeals before a single Environmental Court.

Welch said the Senate supported the goal of consolidating appeals and would review that option comprehensively when the Legislature returned next year, but could not pass off on that provision in the House bill.

Instead, the Senate asked the House to pass off on provisions in the two bills that were similar, including changes to local and regional zoning regulations and consolidating some citizen boards that review permit appeals.

But House leaders and Gov. James Douglas have been clear that a bill that does not include consolidated appeals would not be considered "comprehensive permit reform."

NThe bill doesn't work without consolidated appeals," said Rep. William Johnson, R-Canaan, chairman of the House Natural Resources Committee.

Johnson was reluctant to say there was no chance of a compromise, but was not optimistic.

"There's always divine intervention... lightning does strike," he said.

Evacuationplans.org, Wednesday, May 21, 2003 ofeund4n the Reformer:

Pat LyriA-f Guilford sent a letter to the Brattleboro Reformer on May 15 giving details of the GtieSutbctboard meeting held on May 12th at the Guilford School cafeteria. It is presented (here) <http://www.evacuationplans.org/lyman_letter.htm> in its entirety. (5/21/03)

I was at this meeting as a Guilford resident and a participant of the Guilford Neighbor Project and felt that despite the diverse group in the room, helpful information was given and in no way was a hostile crowd. Information as you can see was given to the community to strengthen and let them know that Vermont Emergency Management has a plan and was at the meeting to give and receive inforrrmi-aon.

My.n is PAttu tind one of at least two in the crowd at the Guilford Selectboard meeting

-on 5/12, helda e G ford School cafeteria that supported the evacuation plan as a process that is constantly being maintained and tested by VEMA and Vermont Yankee and area volunteers.

This is my observation of the meeting and my thoughts, which are quite different from Eesha's headline and article in the Brattleboro Reformer on Tuesday, May 13, 2003.

The selectwoman Anne Rider laid out that this was a selectboard meeting and that Albie Lewis of Vermont Emergency Management was invited to answer questions of the selectboard and the community. Anne laid out the requests of the town for funding and why items were needed and gave copies to Albie for his review. The meeting continued with questions and comments.

As a community, we have been given the tools by VEMA and Vermont Yankee, we need to use them. That is why John Kristensen as a former selectboard member, in March, 2001 proposed starting a group to create community awareness. John as a Selectboard member passionately felt a responsibility to make his town safe and as a result created a network of 13 districts with a phone chain plus creating an awareness of neighbors that have needs. As a Guilford resident I volunteered with many others setting up the Guilford Neighbor Project to create an awareness that a plan is in place, we delivered weather alert radios, calendars and met with our neighbors to create an awareness of the local emergency plans for any type of disaster. The group did run out of steam but, the goal of creating an awareness was effective and data was collected. This would have been a great story to expand on for Eesha.

Albie said, "we don't have unlimited funding." 'We need to change the process, set-up a budget committee, include in that committee the recipient's of the funding and Vermont Yankee.

This committee will review the requests and determine who will get the funding. So, you see a plan is in place by VEMA to organize and take care of Windham County. This was not even mentioned in Eesha's story.

ir I

Anne Rider also made the comment that the reason Patty O'Donnell would not sign for more RERP funds as she wanted accountability and more RERP funds coming locally to Windham County. Also, not mentioned in Eesha's story.

Anne explained the budget request to RERP and gave copies to Albie. Information was collected and neighbor helping neighbor network was established. However, all needs to be put in a database and that was part of the funding request.

Albie responded that the RERP is a voluntary system; private information can be secured and not shared concerning the information collected and creating a database. Emergency Planning is a priority for Windham County. Albie also explained the process to get funding through the Department of Justice grant moneys and the timeline. I saw Mr. Albie giving vital information to the community and helping to create an atmosphere of workability. Eesha again did not mention the process of getting funding from the Department of Justice and the time frame to apply.

Eesha choose to only capture the anti-sentiment in the room. The meeting was about sharing information and coming up with a plan that works. Evacuation plans are to be improved on and reviewed and that is why we have drills and used as a source not an absolute. We need to use our own common sense, plan and create an awareness of our surroundings and create an individual action plan.

Comments were made concerning the dirt roads of Guilford. As a town, we need to plan and take care of those trouble spots. We need to ask our Road Commissioner what he needs to make the roads passable. Do we need more funding? How and where can we get those funds? We need to plan, that is our responsibility for any emergency. What if a house was on fire, how does the fire department get there? Your have to have a plan and improvise in the case of the unknowns that can happen. As Albie stated the plan is a guide and a tool.

The Halifax Selectman (Ray White) suggested an alternate site west of location for evacuation and have that corner of Guilford part of that plan and mentioned funding was slow coming to this area, awareness and education was important.

Albie assured that they were looking into the Bennington area for a westerly evacuation. As far as education, Steve Goldsmith has been hired for the education process and could be reached at 251-2172, in Brattleboro. Dave Hannum was another source. Albie also stated that if he felt the plans were 100% he would not be here. Albie also reported that there is progress on the community notification system that Fred Humphrey had asked about. The system has some quirks and has to be tested, said Albie. The system would not work with a zapper and stops calls. This would have been great information for Eesha to report to the community. This type of information shows that VEMA and Vermont Yankee care about the community and are working to create a plan that works.

Eesha and the Brattleboro Reformer missed the real opportunity to draw the community together and work for the good of all people. After being at this meeting and seeing what really happened at this meeting I will hesitate in the future to believe what is printed. I will choose to attend meetings of interest and form my own opinions and I hope others will do the same.

As you can see from my observations, Albie Lewis of Vermont Emergency Management answered all questions and laid out goals, which Eesha choose not to mention. It appears that Eesha chooses to scare and keep people concerned that VEMA and Vermont Yankee are not giving information to the community.

Eesha and the Brattleboro Reformer reporting will only continue to create hate and discontent among neighbors and the area communities. Monday's Guilford Selecboard meeting was a

prime exa eo4he half - truths reporting.

,atricia Lyman A

nUarMYzmrriit 05301 Oyster Creek nuclear plant shut down after power interruption By Associated Press, 5/21/2003 02:53 LACEY, N.J. (AP) The Oyster Creek nuclear power plant will remain closed while officials try to determine what caused a power interruption at the facility.

The Lacey plant was manually shutdown around 12:30 a.m. Tuesday after an electrical bus malfunctioned, said Neil Sheehan, a spokesman for the federal Nuclear Regulatory Commission. The outage caused the plant to lose power for half of its vital equipment, but did not cause any safety or environmental problems.

"Our operators identified the problem and made the decision to take the plant off line and repair the problem," Ernest Harkness, a plant vice president, told the Asbury Park Press of Neptune for Wednesday's editions. He declined to estimate how long the plant would be closed.

The shutdown was the first unscheduled outage at the Ocean County facility since another equipment failure caused it to be closed for a week in November 2001.

http://www.ibrattleboro.com/article.php?story=20030425134500914 Partial Transcript of Windham Regional Commission-VY Meeting Friday, April 25 2003 @ 01:45 PM EDT Contributed by: gfv Use This to Inform Yourself About VY Now..Your Help is Needed 4/29/03 Hey Y'all. I am putting this here because if we are all informed we can speak more knowledgably. The nuke is trying to jack up their power using ways they haven't even figured out. This Tues 4/29 please come speak out to the Public Service Board to stop the increase power output at VY. They can

charge top $ for the power from the uprate. It is not in our best interest. It is in the interest of profit... This was hours of work... and I apologize for the length.. please print it to read... gfv Preface from the transcriber...

I hope this info is helpful to bring us all the clearest data possible on the issue of the uprate in Yankee's own words and in the words of two concerned people. Please remember to attend the PSN public hearing in Vernon 4/29/03 at 7 pm in the elementary school. Contact the Psb with your concerns clerk psb.state.vt.us.The Windham regional commission is receiving public comment until the close of business on 4/29.

For more information: 257-4003 Thanks, Gary (please excuse the typos if you want to fine tooth comb it feel free to.. and know this is only the 40 minutes not the 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of questions... if you want to transcribe those feel free to call) if you are interested in my questions based on the vy part of this talk feel free to call or email garyfromvermont~yahoo.com Partial Transcript of Windham Regional Commission-VY Meeting April 21, 2003 at the Brattleboro Retreat This portion of a full transcript is of the first several speakers of the event.

Hendrik Vandloo-moderator David Mcelwee Sr Liaison Entergy for ENVY... role to introduce the distinguished presenters...

Don Leach-Dir. of Engineering, Craig Nichols - power uprate project manager, George SR project manager Don Leach:

Dir of engineering 5.years. Before that 17 years with Stone Webster engineering corp. 17 years of construction startup and ops of new facilities. Graduate of Tufts with BA.

Let me start with a little discussion of the economic and reliable supply currently at VY. We are 34% of Vermont's demand and we represent 3/4 of the states in state generation. Economically

that's an attractive source of electricity,VY energy costs less than the hydro Quebec imports and many of the alternative forms of generation. Lets take a look at the past 8 months of operation since the sale of VY to Entergy. If you compare our prices to the average market clearing price, you save the VT customers in excess of 8 million dollars.

The next slide is just a pictorial of the energy mix. You see about 50% imported and 50 % in state generation. VY dominates the instate generation. Our contribution is favorably priced when compared to the other alternatives.

And at VY we always start with the safe and reliable performance. That is our mission. day to day and as well as long range plans.... Power uprate-that is one of our long range plans. And our performance continues to improve. Noteworthy is VY's position in the first quartile or top 25% of national performance goals. These are goals that are established to focus on nuclear safety and plant safety performance. We continually upgrade the facility. We have an 18 month operating cycle where we do on line work and outage work. Part of that work involves considerable maintenance where our preventative maintenance activities also provide insight to us on how to continually improve the facility.

We are subject of frequent inspection and analysis both internal and now as part of Entergy group, of corporate inspection and external, namely the Nuclear Regulatory Commission.

We have a highly experienced plant staff. Frequently the results of audits and inspections we go through a positive comment is the dedication oaf our staff as well as the dedication and significant experience they bring to the running of our facility.

Essentially the uprate optimizes VY's generating capacity. The uprate will provide up to 20%

more electricity without your seeing a new smokestack, without new power plant construction and no additional greenhouse gases. If you were to look at that additional 1 00mw of electricity, that's enough to provide enough electricity for 1 00,000 homes. I should mention that that is a base load stable source available 24/7.

This is an overview of the VY station. This is just to show that there will be no external change to the physical station as you see it here.

Let's talk of the benefit to VT consumers We see many but two major benefits include the additional electrical supply would help drive down the overall regional price of electricity.

Furthermore, this change does not require construction for additional high voltage transmission lines. Again I'll reiterate that other forms of construction to install new facilities would require infrastructure to tie the new constructions in to the existing grid. And the states two utilities CVPS and GMP do have the first opportunity to negotiate for the new electricity. It is important to note that power uprate is a proven process. Currently there are uprates at approximately 30 BWRS, just like our design have been completed in Us. 8 of em very similar to the VY design where they are looking to increase power by about 20%. Provides us a substantial opportunity to build on the successes of others it's a great learning opportunity for us we have been engaging in for the past year and a half as

the project has been active.

I am going to touch briefly on how the electricity is generated. We will have more discussion on that in a moment.. But essentially we will increase water flow which helps us bring more steam to our turbine generator and also the electro generator reactor pressure and temperature remain the same.

There will be some modifications on existing in plant equipment At the core of an uprate is the comprehensive analysis and a rigorous regulatory review is undertaken. Currently we have a team of 20 engineers that are preparing our analysis located in Vernon. That is the core team. When you expand it to other pros contracted experts etc, it s on the order of 100 personnel. The NRC conducts an extensive review; this focuses on the nuclear safety aspect of the project. They have a specialized team of engineers and inspectors that must approve VY's analysis and approve the uprate request.

Once again they have been through this many times. So their opportunity is to build on success and learn from previous projects.

Also there are 2 full time resident inspectors on site at VY and once we work forward to implementing the change, revising procedures, and implementing modifications they will be observing our in plant processes to see that we are in compliance. On top of that the VT PSB does a full regulatory review which many of you may have heard is called a Certificate of Public Good. It examines the benefit to ratepayers it makes the determination of common good is in fact served.

Furthermore the VT state Dept of Public Service will be a full participant in the review process and the VT state nuclear engineer will also be involved in technical reviews. If you look at both of these there is significant investment of resources of both of these regulatory bodies and they are among the order of about a year review and approval cycle from the very beginning to the final acceptance.

It has been our experience that as we discuss this project that there are some frequently asked questions and we thought we would touch on a few of those right now.

1. Will there be an increase in spent fuel?
Yes, there will and our existing plans are designed to cover that. That is going to be in an order 4.of about 20% increase going forward.
2. Will the temperature of the CT river be impacted?

The answer is no. There is no temperature increase in water that we would discharge back into the CT river.

3)Will there be any change to the existing Emergency plans?

No change. The existing e plan covers a power uprate condition both from the VY efforts and from the community response.

Finally to reiterate, It s a proven process with definite benefits Our first and foremost mission at VY is to maintain the facility safely and reliably. The power uprate process ensures that that mission stays intact. There have been many plants that have uprated similar to Vermont Yankee's and those have been successfully completed. The Process, the regulated

process requires rigorous review by the NRC and the VT PSB. And this does introduce and additional supply of economic electricity that will be available to Vermonters without greenhouse gasses This concludes my remarks.. and I'd like introduce Craig Nichols a project manager who works for me running the show.

Craig Nichols:

Again I 'd like to thank you all for inviting us all here thisevening to prqvide the facts about the VT Yankee uprate project. Again Don said, my name is, Craig Nicholatand I am the VT Yankee uprate manager. I have a Bachelor of Science from No4heastern University. Also with us tonight we have George Thomas. George is a Sr. project manager on our team. George has a bachelor of science in mechanical engineering from UMass and masters in science in mechanical engineering from Northeastern University also an MBA from Robert Morse college. George has over thirty six years of nuclear power plant operation including initial start up at Vermont Yankee from 1969 to 1977. George was requested by Entergy to come back here to Vermont and use his extensive experience in support of the uprate project.

Don mentioned, I am going to talk about some of the engineering issues associated with this project. This project includes a rigorous review of the capability of the installed equipment vz the required capability at uprate condition as determined in our analysis. In most cases the installed capacity and capability of our equipment provide significant margin to the required capability at uprate condition and therefore those conditions do not require any modification. In those cases where the uprated capability requirement exceeds the installed capability or where there would not be sufficient excess capability remaining modifications and replacement.

For example the high pressure turbine and 4 of the feedwater heaters will be replaced and the main generator will undergo a rewind as part of the modification. I'll talk more about that in a few minutes Equipment analysis We are following the same detailed safety analysis process that other Boiling Water reactors have used in applying for the uprate. For BWRs, like VY this process is very well defined by both the NRC and General Electric the Original Equipment Manufacturer. And this has been used in the last 8 uprates that Don referred to that are very similar to VY. We evaluated all the impact of systems structures and components to assess their capability of the uprated condition. As I said, that assessment determined that in most instances we have excess capability and no modifications are required.

And a few components will require modification replacement as part of our plan.

I'd like to talk now about some of those modifications. The majority of the equipment mods will occur in the turbine building which is shown here as the long building with green siding. That bldg houses our main turbine, our main generator and the feedwater heater. Out in front of that building you see here the main transformer which converts the electricity produced by the power plant to a

.r

.r higher voltage for transmission and eventual use by our VT electricity customer.

This is the high pressure turbine actually this is the rotor of the high pressure turbine. It is being replaced due to the increased steam flow that it has to pass and in addition we will employ the latest technology to improve its efficiency. Steam is passed through a set of fixed and rotating blades. You see the rotating blades here to spin this rotor that in turn spins this generator which makes the electricity that we all use.

Everything u see here in this picture will be replaced to accommodate the increase steam flow and to employ the new technologies.

VY has 10 feedwater heaters that are used to preheat the water going to the reactor after it passes through the turbine and condenser. Four of these units will be replaced as part of this uprate. Those are the four that I said earlier require increased capability. The other six heaters were replaced within the last 10 years as part of our ongoing maintenance strategy for upgrades and improvements. For those who are not familiar with the feedwater heaters they operate very much like tankless hot water heaters in your home boiler that uses one set of water to heat another set of water. In the next picture, you will see a picture of a feedwater heater.

This is one of the 10, in fact it is one of the 10 that has already been replaced. Each of these feedwater heaters is approximately 35 to 40 feet in length approximately 5 ft in diameter made of stainless steel. It looks much larger in this picture due to the amount of insulation that we place around it to improve its performance I want to talk now about one of the modifications vs one of the replacements. The main generator as I said is the component that actually converts the mechanical energy of the turbine into the electrical energy we all use. It is identical to the generator used in fossil plants. We are going to perform a rewind to that generator which involves replacing the wiring inside the generator in fact it's the wiring that you can see in this picture. You're seeing the inside of the generator which is where the rewind will occur. If you can see this picture well enough you can see a gentleman performing an inspection similar to the ones that are performed routinely as part of our ongoing maintenance.

In fact, engineers like George and myself have been in there several times before doing similar types of inspections. In this picture you'll see again the main transformer I talked about. It operates on the same principle as the one on the pole out on the street that converts electricity down to a voltage you can use in your house. In this case it takes our generation and transforms it to a higher voltage so it can be put onto the transmission system. This actually is a picture of the new transformer that we installed in the fall of 2002 during our refueling outage. Following both application to and approval by the VY PSB which gave us permission to install that. In summary the VT Yankee uprate will continue the safe and reliable operation of VY. It includes extensive reviews.

Don alluded to that, to the significant investment of engineering time by both the company and our regulators for a review of that. It shows that most of the components in the plant are already designed with the excess capability that will operate in the uprated condition and we will perform the necessary replacements and modifications to insure that we continue to have that excess capability. And as always Entergy VY will operate in full compliance with all safety limits from the NRC and all regulations both in performing the uprate and in operation at uprated condition for future years.

Those are my comments again, thank you very much.

At this point I'd like to c (ll aaymond Shadis, 9consultant with the New England Coalition.

,Raymond Shadis: j I am staff advisor to the coalition. We use the Vietnam meaning of the term advisor.

Good evening I'd like to thank the commission for giving us a chance to share our concerns about this uprate. I work on a 12/96 last neutron generated at Me Yankee. And today there are 3/4 of the people who worked at the plant when the plant was open. It takes a lot of people to do decommissioning.

Demand for nuclear workers throughout the industry is very good and that when Maine Yankee announced it was going to be closing the Workers disappeared like snow on a hot day. Just out of town because there were places that wanted that expertise. In fact they instituted a program called golden handcuffs to keep the workers around that knew the plant history to help with decommissioning.

I want to tell you that our experience was there was no great economic dislocation and I want to express all sympathy for the workers and the families that were dislocated. We have a constant round of that in Maine as you do in VT where shoe plants or clothing factories or whatever they may be are changing ownership and workers are moving form one job to another. We ran a quick economic study and we found that within the state of Maine there was no discernible economic impact, statewide; not in unemployment, not in defaults on mortgages, not on increases in food stamps, not on any kinds of housing starts. No discernible economic impact statewide. When it came down to the county level we had a small economic impact in that the tax burden, towns there pay into the county's budget and the tax burden shifted to some of the towns surrounding the host town. And the host town's valuation went down when the plant closed.

Other than that I tried very hard over quite a long period of time to find any discernible overall impact. It is not there. I am not saying there wasn't an impact on those workers and their families but in terms of the state and the region; none. I might also add that for two years following the shutdown our electricity rates went down not up they went Down then leveled off and this year under de-regulation Maine consumers have the option to buy all renewable energy generated within the state of Maine at a premium of about 89 dollars a year. We were very glad to sign up for that. It's an option we had been looking for. I hope it's a token of the future.

I think the easiest lessons are those that come from someone else's experiences. You might want to take a look around. We have in New England 9 nuclear power reactors. Four of them

I are presently in decommissioning. Not a single one that is presently shut down reached the end of its licensed lifetime. Every one of them was shut down prematurely. Every one of them was shut down following an intensive examination of the plant. Yankee Rowe was embrittlement issues. Me Yankee CT Yankee steam generator issues. Millstone 1 which is down is practically a twin of Vermont Yankee. It s the same vintage, roughly the same size, BWR down and done.

What we have is VY surviving as the plant longest in commercial operation in New England. Its been run harder and longer than any other plant. Entergy also owns another BWR in New England, Pilgrim in Plymouth Ma, which is kind of a sister plant to VY very similar in size and design. There is no talk in eastern Ma of a power uprate of Pigrim. It is the home by the way, Tip O'Neill's old congressional district of 1400 colleges and universities.

It is also quite affluent. It is also a political powerhouse, as you may know as the kind of folks that have come out of eastern Massachusetts. Kennedys and the rest. Vermont is not. When we look at it we look at it in socioeconomic terms and we wonder why would Entergy choose an experimental procedure for VT and not for eastern Ma., which is slightly younger by a few months.

Experimental-yes it is. I think and I don't want to preach to you guys, I think Vermont Yankee would do well to level with people.

They have projected that this is a routine procedure. Well no it is not! 93 plants have had a power uprate but only a relative few have gone up anything near 20 %. In fact there's only two or three I see right now that have been approved for 20%. 2 Brunswick stations and the Clinton station and those by the way are newer than Vermont Yankee. Take that as a lesson because when plants get old plants get tired just like any other old piece of equipment. Of those plants that were granted 20% power uprates, all have occurred in the past 2 years. Those 3.this is not a procedure that has been around for a long time.

Of those plants have they had problems? Yes they have. Let's see if I can very quickly get to how VY describes... this is in their project description of their Certificate of Public Good application... "The main steam dryer will be structurally strengthened to mitigate the effects of flow induced vibration that was experienced at another facility,' Sounds relatively innocuous.

What are they talking about? They are talking about the Quad cities plant in which a large plate what would that be fellas what 10 12 feet diameter, the plate on top of the steam dryer. I think so. A large plate was also strengthened to resist what.. we are not increasing the pressure remember, we are not increasing the temperature, nonetheless the plate was strengthened by welds add-ons and they were not properly relieved and sometimes even relieving the welds with post heat treatment doesn't do the trick. The plate came apart and pieces of it went rattling down through the steam lines and they were mightily relieved that it did not hit the main steam isolation valves. If time allows I could give you a quick read on the Nrcs report on Duane Arnold. Information notice failure of steam dryer cover plate".due to recent power uprate In March 2002 Quad cities unit 2 completed a refueling outage to which included a modification to add baffle plates to steam dryer to reduce excessive moisture carryover as the result of extended

"', I I 1.

power uprate 17.8 % The unit began experiencing fluctuations in steam flow, reactor pressure and level and moisture carryover to the main steam lines." After another couple of months (June, July) and more fluctuations, the licensee conducted an engineering evaluation and concluded that steam flow irregularities could be caused by loose parts and that the loose parts could impair the proper functioning of safety systems.

Somehow back in Entergy's first description of we're going to strengthen this up to avoid some vibrations that were experienced in another plant sound way different. I think and this is my point to he Entergy folks.

I think and I think you need to level with people This is a literary crowd.What's the combustion temperature of paper? Ignition temperature or combustion temperature, I don't remember, C'mon it's the title of a famous book???

Fahrenheit 451."

Entergy's been very clever in saying we're not going to raise the temperature or the pressure.

You understand temperatureis only one factor in talking about heat. If you burn a little bit of paper - temp 451. If you burn a whole schoolhouse of paper temp 451.

We're talking about volume we are talking about amount of heat available in a given time. It will be increased 20 %. It is plain mechanics...You do not get mechanical energy out of one end without putting heat energy in the other end and it's foolish almost to the point of being ludicrous to say we are not going to raise the temperature or the pressure just the steam flow.

You do not get there without putting in the heat energy. Steam flow is one of those issues. I'm running out of time I 'd love to tell you about the at one of these 4 plants at one of them the licensees uncertainty about under the conditions of a 20% uprate about the rate at which the erosion of the inside of their steam lines would be increased. They were talking about something on the order of 17 thousandths of an inch a year on a half inch thick plate.

But the advisory committee on reactor safety at the NRC said they were reminded of how one of the worst accidents happened due to a plant having a steam line blow out, so it's serious business. What you have at the end of the day is you have an application to slide a 100 megawatt reactor into a very old and very tired plant.

I am going to put some fact sheets out for people to take in the lobby explaining what kind of material degradation exists in old nuclear plants. What kinds of metal fatigue. People have to deal with, erosion and corrosion with stress corrosion cracking with radiation induced embitterment, all of the phenomena that you find with an older plant. These are not my words these are the words of the NRC.

II I 'd like to give my time over to Arnie Gunderson a nuclear engineer graduate of RPI.

AFN6iGunderson:

Thank You, My name i/A unni d&6s6 and l teachjhigh:school in Burlington and I have a bachelors and Masters H ear engife'ring. This year larfteaching math and next year I am teaching math and physics. I have a nuclear reactor operators license. For twenty years I was in the nuclear industry ultimately as a Sr. Vice President.

The issue is not should we shut the plant down. The issue is is the plant reliable enough to run at a higher power level. I was Supervisor of Reliability and Engineering in one of my positions up the corporate ladder. Reliability has something called a bathroom curve. Up on this curve is bad. And when you buy a new component, such as a car, it breaks down frequently and then as you get tall the rattles worked out, the unreliability drops. As a car gets older it gets less reliable. My car has 100,000 miles on it and I drove down here at 70 miles per hour. When it was new I would have driven down here at 90 miles per hour but I don't. That's because of the bathtub curve. We all know about it.

The engineering curve is the bathtub curve.The reason it's called the bathtub curve is because if you cut it in half it kinds of looks like a bathtub It drops sharply at the start and goes gradually up at the other end. As plants get old they become more unreliable. There's a thing called a P.R.A.

probabilistic risk assessment which includes new. The data they use for the PRAs for all the power plants and for an old plant like Vermont Yankee it has the advantage of having its unreliability watered down by the relative reliability of the newer plants.

If you do not believe me, the Union of Concerned Scientists has an excellent position paper on it. I sent it to the NRC two years ago about the unreliability of aging nuclear power stations as compared to the more modern ones. You can pull it off their website. I just found 7 reactors in the past two years that shut down because of unreliability aging related unreliability issues; nine mile 2 March 2000, Katabah 1, utility said the neoprene insert at the failure point on the connector exhibited signs of accelerated aging. Two months later Katabah2 had the same failure and was several years younger.

Other reports go on. I just think its obvious. It's hard. Anyone who owns a car knows that old things break faster than new things. We are stuck with the place till 2012 and I am not suggesting we do anything about it. I am suggesting we not run it at 20% faster. I didn't drive my car down here at 90 miles per hour.

The other thing is I was a nuclear whistle blower. I lost my home. I lost my house. I almost lost my marriage. I brought some concerns to the NRC which they did nothing about. This is a

Y.

w 1i report from the inspector general that talks about nuclear oversight of the nuclear industry. This is from the Inspector general to the chairman of the Nuclear regulatory commission talking about my allegations, Seabrook Allegations and Plymouth allegations, 3 plants right here in New England.

The common denominator among these 3 plants is that Region 1 personnel relied upon the representation of the licensee in each situation that were inaccurate or untrue.

The representations were not verified or reviewed until external influences forced an independent review. Again from the chairman, in another Inspector General report.

I'll leave with these guys: there is talk of inadequate inspections by region 1 personnel, umm, umm, right here in New England.

And a last report about graft: The NRC employees received a bribe from a public corporation.

All these involve my allegations. During the process of my allegations being approved the NRC did nothing to support me. In fact I was driven to bankruptcy. And finally there is a New York Times article about what my family and I went through.

When these guys talk about a rigorous safety inspection forget it!

The industry has the NRC in it's pocket.

CC:

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