ML062850109
| ML062850109 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 09/14/2006 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| Byrdsong A T | |
| References | |
| 50-271-OLA, ASLBP 04-832-02-OLA, NRC-1247, RAS 12354 | |
| Download: ML062850109 (178) | |
Text
R~AS /;2,3q Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Hearing ITMO Entergy Nuclear Docket Number: 50-27 1-OLA; ASLBP No.: 04-832-02-OLA DOCKETED USNRC Location: Newfane, Vermont bctqber 11, 2006 (4:07pm)
OFFIC'E OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Date: Thursday, September.14, 2006 Work Order No.: NRC-1247 Pages 1438-1578/1608-1614 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433 Ft 3(CteC -esf -- 3P Sc-O - -0 )
1438 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL HEARING
-- - - - - - - - - - - - -x In the Matter of:
ENTERGY NUCLEAR VERMONT YANKEE L.L.C. and :Docket No. 50-271-OLA NUCLEAR OPERATIONS INC., :ASLBP No. 04-832-02-OLA (Vermont Yankee Nuclear Power Station)
-- - - - - - - - - - - - -x Thursday.- September 14, 2006 The above-entitled hearing was convened, pursuant to notice, at 9: 00 a.m. at the Windham County Superior Court, 2nd floor Courtroom, 7 Court Street, Newfane, Vermont.
BEFORE:
ALEX S. KARLIN, Chair ANTHONY J. BARATTA Administrative Judge LESTER S. RUBENSTEIN Administrative Judge NEAL R. GROSS COURT REPORTERS AND TS M4'SCRIB::S 1323 RHODE ISLAND AVE.. N.W.
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1439 APPEARANCES:
on Behalf of the Licensee:
MATIAS E. TRAVIESO-DIAZ, ESQ.
SCOTT VANCE, ESQ.
of: Pillsbury Winthrop Shaw Pittman 2300 N Street, N.W.
Washington, DC 20037 (202) 663-8142 on Behalf of the Intervenor, New England Coalition:
RAYMOND SHADIS, ESQ.
New England Coalition P.O. Box 98 Edgecornb, Maine 04556 (202) 882-7801 on Behalf of the Nuclear Regulatory Commission:
SHERWIN E. TURK, ESQ.
STEVEN C. HAMRICK, ESQ.
of: office of the General Counsel U.S. Nuclear Regulatory Commission Mail Stop 0-15D21 Washington, DC 20555 (301) 415-1533 NEAL R. GROSS
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1440 ALSO PRESENT:
MARCIA CARPENTIER, ESQ., ASLBP Staff RICK ENNIS, Project Manager, NRC CRAIG NICHOLS, Project Manager, Entergy KAREN VALLOCH, ASLBP Staff DR. JORAM HOPENFELD NEAL R. GROSS
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1441 I -N-D-E-X EXAMINATION EXAMINATION BY THE LICENSING BOARD PANEL OF:
RICHARD B. ENNIS, STEVEN R. JONES, ROBERT L. PETTIS, GEORGE THOMAS, ZENA ABDULLAHI 1444 PREFILED DIRECT TESTIMONY OF DR. JORAM HOPENFELD 1509 EXAMINATION BY THE LICENSING BOARD PANEL OF DR. J.ORAM HOPENFELD 1511 EXAMINATION BY THE LICENSING BOARD PANEL OF JOSE CASILLAS AND CRAIG NICHOLS 1571
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1442 EXHIBIT INDEX KEY I-Identified A-Admitted into evidence R-Rej ected W-Withdrawn TUA-Taken under advisement official Hearing Document Disposition!
Exhibit 1#/letter Title Page (None.)
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1443 P ROC EE DI NG S 2 9:01 a.m.
3 CHAIR KARLIN: Good morning. We are back 4 on the record this morning. We intend to proceeding 5 with the-~witnesses presented by the Staff. And then 6 we will have the witness for New England Coalition 7 come up.
8 And at that point, as I said yesterday, we 9 will take a break, 15 minutes, 10 minutes, something 10 like that, where you can then submit to us, at the end 11 of that time frame, questions that you might, 12 supplemental questions you might suggest that we ask 13 of any of the witnesses who have appeared.
14 We will then consider those and decide 15 whether to ask either those questions, or any 16 supplemental questions we may have thought of after 17 having heard from the various panels.
18 And then we will proceed to the 19 proprietary session. And pursue the same format, 20 approach.
21 So with that, Mr. Hamrick, Mr. Turk, if 22 you would bring your witnesses forward, we are going 23 to just proceed with that. And thanks to whoever put 24 the signs up in terms of the names. That is helpful.
25 Good morning. Let me remind you all that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1444 1 you are still under oath, and to testify to the truth, 2 and I'm sure you will remember that.
3 Whereupon, 4 RICHARD B. ENNIS 5 STEVEN R. JONES 6 ROBERT L. PETTIS 7 GEORGE THOMAS 8 ZENA ABDULLAHI 9 were recalled as witnesses by Counsel for the Staff 10 and, having been previously duly sworn, assumed the 11 witness stand, were examined and testified as follows:
12 CHAIR KARLIN: I think I may start with a 13 few questions here. I would like to ask a f ew 14 questions about the standard review plan, which is 15 Entergy exhibit 4, I believe.
16 And walk and talk about the factors and 17 criteria, this sort of thing, that appear at page 18 14.2.1-7. May I ask, Mr. Ennis, who do you think, who 19 is the best person to talk about those factors?
20 WITNESS ENNIS: It would be a combination 21 of Mr. Jones and Mr. Pettis.
22 CHAIR KARLIN: All right, Mr. Jones and 23 Mr. Pettis.
24 WITNESS JONES: Okay, thank you.
25 CHAIR KARLIN: And I will focus my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1445 1 questions to Mr. Jones and Mr. Pettis, and then if 2 someone has some great additional point to make, you 3 know, I would be glad to hear that, too. But I don't 4 think it is really going to go that way.
5 So let's start with Mr. Jones. On 14..-2.1-6 7 it has use of evaluation to justify elimination of 7 power ascension test, right?
8 WITNESS JONES: Yes.
9 CHAIR KARLIN: And this is what we are 10 talking about here, and what Entergy submitted, a 11 justification to do that.
12 Now, as I understand the fourth and fifth 13 lines of the general discussion, it says that the 14 licensee shall provide an adequate justification for 15 each of these normally required tests.
16 So these tests are normally required, the 17 MSIV closure test is normally required? Is it a 18 normally required -- that is what it says, doesn't it?
19 WITNESS JONES: It is referenced in REG 20 Guide 1.68, it would normally be part of a startup 21 test program. And it is listed in table 2 of the 22 standard review plan, as a transient test applicable 23 to power uprate, in that sense, yes.
24 CHAIR MARLIN: So the REG Guide, I'm 25 sorry, not the REG Guide, the standard review plan NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS .9 1323 RHODE ISLAND AVE., N.W.
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1446 1 ref ers to the MSIV closure test and the generator load 2 rejection test as normally required power ascension 3 tests.
4 Attached to this is an attachment 2 which 5 has that as one of the tests,..doesn't it?
6 WITNESS JONES: Yes.
7 CHAIR KARLIN: Okay. Let me go to C-2.
8 It says, specific acceptance criteria. Now we get 9 into the criteria. It is on the same page, C-2.
10 WITNESS JONES: All right.
11 CHAIR KARLIN: The reviewer should 12 consider the following factors when assessing the 13 adequacy of the licensee's justification, all right?
14 And then it goes through factors A, 15 previous operating experience; B, introduction of new 16 thermal hydraulic phenomena; C, D, E, F, and G, right?
17 And these are the factors to be considered by the 18 Staff, I guess, when making a decision on this?
19 WITNESS JONES: Yes.
20 CHAIR KARLIN: I just want to -- once you 21 have considered those factors, what are the criteria 22 for deciding whether to grant the elimination of these 23 tests?
24 These are factors, what is the criterion 25 that you use? After you have considered all these NEAL R. GROSS COURT REPORTERS AND TRAN3CRIBERS .-
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1447 factors, how do you make your decision?
2 WITNESS JONES: As I mentioned yesterday, 3 in REG Guide 1.68 it describes how the scope of the 4 testing should be - applied relative to the safety 5 significance of the equipment. And I think that 6 continues to be applied through all these criteria, 7 depending on how important a particular system, or 8 component, is to safe operation of the plant.
9 It would determine to what extent these 10 criterion would be applied. Safety related equipment 11 would need to conform to all the elements of Appendix 12 B. Important to safety equipment, or like most of the 13 balance of plant systems, would be somewhat of a lower 14 threshold of review.
15 In that we are not looking for, when it 16 mentions code application, we wouldn't be looking for 17 a code that had been implemented, fully, in accordance 18 to the quality assurance program, but had just been 19 merely benchmarked to the plant.
20 CHAIR KARLIN: Okay. Well, let me just 21 stop you there. I'm just trying to get to a very 22 simple question which is, we have factors that are 23 listed here, but what I'm looking for is, after you 24 have considered the factors, is there something in the 25 standard review plan which tells you, now that I have NEAL R. GROSS I TARD TRn3CFIID7FI
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1448 1 considered these factors, if it meets 3 out of 8, out 2 of 10, they win; for 5, 6 out of 10, or the majority, 3 or what is the criterion by which you end up deciding 4 whether or not, having considered all these factors, 5 to grant it?
6 WITNESS JONES: The standard review plan 7 provides merely a guidance statement that states, on 8 page 14.2.1-10, if the licensee provides adequate 9 justification for not performing certain power 10 ascension tests, the Staff may conclude that the EPU 11 test program is acceptable without the performance of 12 these tests.
13 The final finding is --
14 CHAIR KARLIN: Show me where that is, 15 4.2.1.10?
16 WITNESS JONES: Right.
17 CHAIR KARLIN: Where are we now?
18 WITNESS JONES: Below paragraph G.
19 CHAIR KARLIN: G, yes. If the licensee 20 provides adequate justification for not performing, 21 the Staff m~ay conclude that the EPU test is 22 acceptable.
23 Okay, that is what I'm trying to ask, what 24 is adequate justification? We just went through a 25 bunch of factors, what is your criterion for deciding NEAL R. GROSS
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1449 1 what is adequate?
2 WITNESS JONES: I mentioned that it 3 depends on the safety significance, once you have data 4 we are looking for --
5 CHAIR KARLIN: Is there something in the 6 standard review plan that answers this question?
7 WITNESS JONES: Nothing beyond the 8 references to the reg guide 1.68 and appendix B, part 9 50.
10 CHAIR KARLIN: Does this section, on this 11 subject, C, refer to reg guide 1.68?
12 WITNESS JONES: And in the -- let's see.
13 CHAIR KARLIN: Maybe it does. I mean, I 14 don't know.
15 WITNESS JONES: On page 14.2.1-3, going on 16 to page 4, it lists the acceptance criteria.
17 CHAIR KARLIN: Okay.
18 WITNESS JONES: Intended to be satisfied.
19 CHAIR KARLIN: Well, I thought these were 20 the specific acceptance criteria that were listed 21 here. That is a different section?
22 WITNESS JONES: That is the review 23 procedures. I think -- excuse me?
24 CHAIR KARLIN: That is a different 25 section? I mean, the subsection C use evaluation to NEAL R. GROSS
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1450 1 justify elimination of power ascension tests. I'm 2 looking in that section. You are --
3 WITNESS JONES: Right, it doesn't contain 4 specific --
5 CHAIR KARLIN: -- referring to a different 6 section?
7 WITNESS JONES: That section indicates 8 what the Staff reviews and what we look for. But the 9 ultimate acceptance criteria are the regulations that 10 are cited under section 2, and --
11 CHAIR KARLIN: Right.
12 WITNESS JONES: -- as the standard review 13 plan has, on the front page of each section, they are 14 prepared for guidance, and they are an acceptable way 15 of implementing the regulations, but are not 16 requirements in and of themselves.
17 CHAIR KARLIN: Well, I understand. But it 18 is guidance to the Staff to how to make a decision.
19 And I just don't see any criteria in this provision 20 that says how you make that decision, consider factors 21 and --
22 WITNESS JONES: Right.
23 CHAIR KARLIN: I do understand that what 24 criterion 11, in appendix B, is the ultimate criteria, 25 and that you should be using. I just wanted to find NEAL R. GROSS
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1451 1 out more about that.
2 Now, let me ask about this standard review 3 plan. What, as a background, as I understand it, 4 General Electric came in and asked for a generic 5 *exemption for MSIV closure testing and generator load 6 closure testing? Who should I direct this question 7 to?
8 WITNESS PETTIS: Maybe I can address those 9 questions.
10 CHAIR KARLIN: Did you work on any of the 11 requests from General Electric about this, or --
12 WITNESS PETTIS: With respect to the 13 standard review plan I was involved in some of the 14 initial development along --
15 CHAIR KARLIN: Okay.
16 WITNESS PETTIS: -- along with others, of 17 course. But to set the stage for the questions that 18 you have on the standard review plan, it might be 19 helpful to go back and introduce the review standard, 20 which --
21 CHAIR KARLIN: No, I would just like to 22 focus on my question, which is, did General Electric 23 originally ask for a generic exemption from these 24 tests?
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1452 1 because the documentation in the ELTR-1 is where the K)2 original large transient testing information was 3 referenced.
4 And when they had changed the approach to 5 the CPPU the Staff's position was we could not grant 6 an exemption across the Board for every facility that 7 might be coming in with a CPPU application, due to the 8 uniqueness of the plants.
9 CHAIR KARLIN: So they requested a generic 10 exemption, and you said, no we are going to do it on 11 a -- can't do it across the board, we are going to do 12 it case by case?
13 WITNESS PETTIS: Right. That is the final 14 Staff conclusion on the CPPU, basically it states that 15 we would look at it on a case by basis. Each 16 application would come in, would make its case for 17 exemption of the testing, and then the Staff would 18 review it based on those merits.
19 CHAIR KARLIN: And on a case by case basis 20 how many EPUs have been requested?
21 CHAIR KARLIN: Well, if you go back and 22 look at the total EPU inventory of applications they 23 break down into applications that were filed prior to 24 the Staff's -
25 CHAIR KARLIN: Well, subsequent to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1453 1 issuance of this draft standard review plan how many?
2 WITNESS PETTIS: This draft standard 3 review plan covered, primarily, about four plants, 4 because this came out in draft form in 2002.. And 5 since then we have applied, Waterford was.one, Brown's 6 Ferry is the second one.
7 CHAIR KARLIN: What is this reference to 8 11 plants that I have seen?
9 WITNESS PETTIS: Earlier, in yesterday's 10 testimony there was a reference made to the NRC review 11 standard, which is RS-001. And that plays an 12 important role only because it defines a point in time 13 in which the Staff's review of the EPUs followed a 14 more prescribed programmatic process for evaluation.
15 CHAIR KARLIN: Okay. Well, are there 16 four, or are there 11?
17 WITNESS PETTIS: There is a total of about 18 15. Eleven were done prior to the risk development 19 and four or so plants were done after that-20 development.
21 CHAIR KARLIN: And how many of those have 22 you required, on a case by case basis, large transient 23 testing of the MSIV and the generator load rejection?
24 WITNESS PETTIS: Well, in a more --
25 CHAIR KARLIN: Is the answer none?
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1454 1 WITNESS PETTIS: No, none.
2 CHAIR KARLIN: None. So case by case, 3 although you didn't grant a generic exemption, you 4 granted 15 in a row exemptions?
5 WITNESS PETTIS: Fifteen to 16.
6 CHAIR KARLIN: Sixteen, okay.
7 WITNESS PETTIS: With the Duane Arnold 8 probably being one in which the Staff had imposed a 9 requirement.
10 CHAIR KARLIN: So why not just do the 11 generic exemption like General Electric asked?
12 WITNESS JONES: We have a case, right now, 13 with Brown's Ferry,. where we proposed a license 14 condition for a large transient test for Brown's Ferry 15 1 that would require both the MSIV closure test and 16 the generator load rejection test within a short time 17 after restart, achieving a full uprated power.
18 CHAIR KARLIN: Good, good.
19 ADMINISTRATIVE JUDGE RUBENSTEIN: You said 20 the review standard formalized the experience of the 21 review that had been ongoing in a previous large 22 number of plants.
23 Was the substance of the review the same, 24 was this just a standardization, and a good recording 25 of the history of what the Staff'Is review was when you NEAL R. GROSS COURT REPORTERS AND V~ NSCr.!SC-IS--
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1455 1 wrote the requirements in the review standard?
2 WITNESS PETTIS: I would say, after the 3 development of the review standard, the Staff had a 4 more proceduralized-road map that they could use to 5 evaluate future EPU applications.
6 Prior to that most of the reviews were 7 performed by, say, the more experienced reviewers 8 within the Staff that had more of a command of the 9 information.
10 However, as the agency is growing we 11 needed some type of historical document that could be 12 left behind once those experienced reviewers left the 13 agency.
14 So there was an attempt made to collect 15 all of the information that the agency has, and put it 16 under the umbrella of the review standard. And there 17 were also recommendations made by the Advisory 18 Committee on Reactor Safeguards, in meetings that we 19 had with them, regarding CPPU and, also, the EPU 20 process in general, to develop some type of guidance 21 for the Staff.
22 Because prior to that it was, more or 23 less, each EPEJ application was assigned to a specific 24 branch, and those experts, in those particular areas, 25 took that EPU application and, based upon existing NEAL R. GROSS
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1456 1 procedures, and their own experience, would review the 2 application.
3 So that is where the 11 or so EPt~s came 4 from, which -were --in *the pre-risk era. Af ter the 5 review standard was developed we processed, and--like 6 I said, maybe four to six EPUs from that.
7 And the standard review plan, 14.2. 1, this 8 is a little background information, was developed as 9 a new standard review plan. This standard review plan 10 did not exist prior to the development of the review 11 standard.
12 The task that the Staff had was to develop 13 a guidance document that would cut across all of the 14 review disciplines and basically reference, and 15 embody, all of the existing regulations, and all of 16 the existing procedures, and processes that the Staff 17 has to review applications.
18 So if you look at the review standards, 19 broken down into about 12 to 15 dif ferent areas, 20 structural, mechanical areas, INC, testing, and each 21 of those disciplines reviews the EPU using the 22 guidance that is in the review standard.
23 My particular area, or branch, needed a 24 supplemental document to specifically address the 25 power ascension portion of the review.
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1457 We did not have that written in the 2 documentation, other than reg guide 168, which has 3 been on the books since 1972. But reg guide 168 is 4 for initial..test programs of initial plants that the 5 NRC was giving an operating license.
6 So for a brand new reactor in 1972 they 7 would be using the power ascension guidance that was 8 contained in reg guide 168. But for EPUs, for plants 9 that had already been operating, and were coming in 10 for an EPU, we had to develop new guidance.
11 The standard review plan 14.2.1 was 12 developed, it became part of the review standard. And 13 to further answer your question regarding the specific Q
4~ 14 guidance, the standard review plans, and the reg 15 guides,- and all- of these other Staff documents, 16 provide guidance to the Staff.
17 And they also provide guidance to the 18 applicants, because the applicants read the standard 19 review plans, they see what the Staff is looking for, 20 and they put that information in the application.
21 But the specific how-to-do cookbook, so to 22 speak, really does not exist with respect to 23 performing an EPU exemption. It is, basically, the 24 standard review plan is used for guidance, and then 25 each individual review branch follows their own NEAL R. GROSS
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1458 existing procedures, standard review plans, 2 information notices, generic communications, whatever 3 they have developed in their branch, plus the, I hate 4 to use the term skill of the craf t, but there is a 5 certain amount of expertise involved in doing these 6 reviews.
7 And that is why most of them are given to 8 the more senior reviewers. So the specific guidance is 9 not in the standard review plan, and you won't find 10 it.
11 ADMINISTRATIVE JUDGE RUBENSTEIN: However, 12 in the case of all the reviews, they met the 13 regulations. And this is sort of an internal document 14 for guidance of the reviewer.
15 But the quality of reviews probably 16 changed over the course of all the reviews. Is this 17 true?
18 WITNESS PETTIS: Yes, they have. And 19 simply because prior to the review standard --
20 ADMINISTRATIVE JUDGE RUB ENSTE IN: I 21 understand why.
22 WITNESS PETTIS: -- we didn't have the
- 23 type of guidance --
24 ADMINISTRATIVE JUDGE RUBENSTEIN: The 25 second question is, and there are some differences in NEAL R. GROSS 3UTREPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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1459 1 how an individual reviewer may, earlier on, before 2 getting the guidance, would apply how the regulations 3 were satisfied.
4 Is that accurate? So this is a learning process which was culminated, for efficiency, in the 6 writing, finally of the standard review plan section?
7 WITNESS PETTIS: Yes, I would say that is 8 accurate.
9 ADMINISTRATIVE JUDGE RUBENSTEIN: Okay.
10 WITNESS PETTIS: But, again, I think the 11 real reason was to make sure that the Staff had a 12 living document that could be passed on throughout the 13 review period, and anyone could pick up the review 14 standard, whether they were a senior person, or 15 whether they were a junior person, to EPU.
16 An-d they could get into the review 17 standard and they could, at least, look at the types 18 of documents, the types of processes and procedures, 19 and the references made, to the regulations, like 20 IOCFR50 Appendix B.
21 CHAIR KARLIN: But if someone gets into 22 it, anyone gets into the review standard, and I just 23 got into it, and we went through the factors. And if 24 they discussed the factors it wouldn't -
25 WITNESS PETTIS: No, that is the standard NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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1460 1 review plan.
2 CHAIR KARLIN: Okay, the standard review 3 plan. It wouldn't tell me what the decision was.
4 These factors have been discussed and considered, and 5 I would still be uninformed as to how I should decide 6 this matter. It would be just a judgement call based 7 upon criterion 11.
8 I see a nod f rom Mr. No-Name, sorry.
9 Please if you would address that, that is correct, is 10 it not? Yes, Mr. Ennis?
11 WITNESS ENNIS: In the review standard one 12 of the most important things in there is the template 13 safety evaluation. And within that template safety 14 evaluation it contains, for each review section, the 15 regulatory evaluation section.
16 That is the first part of each section 17 that tells the regulatory criteria that we are 18 concerned about. For example, for this, it would be 19 section, it is in the NRC Staff's --
20 CHAIR KARLIN: Well, why don't we take --
21 can I get that exhibit, what exhibit is it?
22 WITNESS ENNIS: Exhibit 2.
23 CHAIR KARLIN: Exhibit 2. Yes, give me 2.
24 I don't have the whole thing. Are you referring to 25 page -- what page is it?
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1461 1 WITNESS ENNIS: Page 260.
2 CHAIR KARLIN: I'm with you, 260 of 3 exhibit 2.
4 WITNESS ENNIS: Right in the middle of the 5 page, under section 2.12. 1, the -first subsection there 6 is regulatory evaluation.
7 CHAIR KARLIN: Right.
8 WITNESS ENNIS: That paragraph, for the 9 most part, depending on the design basis of the plant, 10 the licensing basis of the plant, is almost, word for 11 word, out of the review standard.
12 And that tells you the regulatory criteria 13 that we are interested, in this particular section of 14 the safety evaluation, and it puts into context, for 15 that regulatory criteria, what aspects of, *for 16 example, the appendix B criterion 11 that we are 17 concerned about.
18 And it also gives the reviewer a reference 19 to, you know, what additional guidance we should be 20 looking at in making our decision. In this case it 21 references specific review criteria contained in 22 standard review plan section 14.2.1.
23 CHAIR KARLIN: Right, okay. Well, let me 24 ask you about that. Certainly criterion 11, referred 25 to there, is the standard, the legal standard, that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1462 1 all must use. You used, the Applicant used, and we 2 would use, in trying to decide this matter, I guess.
3 And specific review criteria are contained 4 in standard review plan 14.2. 1.- That was my question, 5 the criteria are not in there. There are factors.
6 WITNESS ENNIS: Right.
7 CHAIR KARLIN: They just discuss consider 8 factors, but it doesn't provide a criteria, or 9 criterion. This is the criterion, what you referred 10 to, attachment criterion 11, that is the criterion.
11 WITNESS ENNIS: And is consider these 12 factors and make your best judgement.
13 WITNESS ENNIS: Right. And then also from 14 the review standard, it is part of the safety 15 evaluation. The other main part of that is the 16 conclusion section and after you go through this 17 review, you look and see, can I make this conclusion?
18 That is the final that we want to be able 19 to look at -
20 CHAIR KARLIN: Right, and I want to get to 21 that next. I'm ready to get to that, unless you have 22 further questions?
23 ADMINISTRATIVE JUDGE RUBENSTEIN: Well, I 24 want a little clarification. The standard review plan 25 is review guidance for the Staff. It def ines the K) NEAL R.GROSS COURT REPORTERS AND TRANSCRSaERS*
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1463 areas of review which should be covered, as a minimum.
2 I want an affirmation, or negative, or a correction.
3 For the industry it says, this is how the 4 Staff will look at -these .. various topics, please 5 address these topics in the safety assessment report.
6 And they really don't accept, for their 7 source, in the beginning sentence of any given section 8 of the standard review plan, give the regulatory 9 origin of the basis for addressing these sections. Is 10 this correct?
11 WITNESS PETTIS: Yes, that is correct.
12 The acceptance --
13 ADMINISTRATIVE JUDGE RUBENSTEIN: That is 14 all.
15 WITNESS PETTIS: -- criteria is the 16 regulation.
17 ADMINISTRATIVE JUDGE RUBENSTEIN: Let's 18 move on. The adequacy of the information submitted, 19 in accord with what is potentially about to be 20 reviewed, according to the review standard 001, or the 21 standard review plan, stands and fails on its own, on 22 whether or not it meets the regulations, and whether 23 they use code, pardon me, licensing topical reports, 24 or other documentation which had been previously 25 accepted, and it allowed them to reference these NEAL R. GROSS 1323 RHODE ISLAND AVE.. N.W.
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1464 1 documents. Is this correct?
2 WITNESS PETTIS: Yes.
3 ADMINISTRATIVE JUDGE RUBENSTEIN: In other 4 words, you . review. -the SAR and you look for 5 completeness in the SAR, did they address all these 6 topics in the review standard, but you have to make 7 your judgements based on your technical knowledge, and 8 the conformance with the regulations? Please.
9 WITNESS ABDULLAHI: If I can just bring 10 one issue?
11 ADMINISTRATIVE JUDGE RUBENSTEIN: Please.
12 WITNESS ABDtJLLAHI: It is not only person 13 dependent, reviewer dependent, only like you stated.
14 But there is also the fact that there was a task force 15 and the first, the second licensee that requested an 16 exemption to the -- the first licensee that requested 17 an exemption to the large transient test, and I think 18 that is one of our exhibits.
19 They came up with and said we would like 20 to get exemption from the requirement of ELTRi and 2.
21 And at that point there was a task force, there was a 22 review done. And when these reviews, they went 23 through it, and then acceptance criteria, and 24 eventually --
25 CHAIR KARLIN: May I ask a question? Is Y~v NEAL R.GROSS
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1465 1 that the task force that dealt with the generic 2 request for a generic exemption?
3 WITNESS ABDULLAHI: That is after that 4 piece, - the CPPU was a generic request, which is 5 another licensing topical report.
6 CHAIR KARLIN: Okay.
7 WITNESS ABDULLAHI: So there is an 8 exhibit, the one from Exelon.
9 CHAIR KARLIN: Can I ask this question?
10 We were talking about the standard review plan calls 11 for the factors to be discussed. Reviewers should 12 consider the following factors when assessing the 13 adequacy of the licensee's justification.
14 And then there is a list of factors that 15 need to *be discussed, and the Applicant needs to 16 discuss those factors.
17 Let's say factor B, introduction of new 18 thermal hydraulic phenomena or identified system 19 interactions. Let's say the Applicant had a 20 wonderful, deep, discussion of those and said, there 21 are many new thermal hydraulic phenomena being 22 introduced by this change.
23 There is a tremendous amount of change, 24 and he went into great detail. Then there is factor 25 C, the facility conformance to limitations associated NEAL R. GROSS
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1466 with analytical analysis methods.
2 He had a great discussion of that factor 3 and he said, our facility doesn't conform at all, it 4 is totally different, there are a lot of differences, 5 I~t was a great discussion, it was an adequate 6 discussion.
7 So the Applicant would have adequately 8 discussed every factor. If they adequately discuss 9 every factor does that mean you grant it?
10 WITNESS JONES: No.
11 CHAIR KARLIN: No.
12 WITNESS JONES: Because C --
13 CHAIR KARLIN: The adequate discussion is 14 not the criterion for whether this is some judgement 15 call.
16 WITNESS JONES: The standard is --
17 CHAIR KARLIN: That is all I want.
18 ADMINISTRATIVE JUDGE BARATTA: Let me ask 19 Mr. Jones a question. You said that in the case of 20 Brown's Ferry you made a license condition that they 21 do the testing.
22 Looking at the factors that you are.
23 supposed to consider, which ones led you to that 24 decision? I'm not questioning that decision, I'm just 25 trying to get a comparison and, again, get --
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1467 1 WITNESS JONES: This is not a final K) 2 decision. What the Staff has proposed is the license 3 condition specific to Brown's Ferry unit 1, which has 4 an operating license, but has not operated for in.
5 excess of 25 years.
6 And then, clearly --
7 CHAIR KARLIN: So that is an initial test, 8 or is that an EPU? That is not an EPU, is it, that is 9 the initial test?
10 WITNESS JONES: It is both.
11 CHAIR KARLIN: Okay, different category.
12 WITNESS JONES: Well, from the aspect of 13 an operating license, if they decided to, since they 14 hold an operating license, if they elected to return
-15 the power to one hundred percent, and there are no 16 changes to the plant design, there is no requirement 17 to do any testing.
18 CHAIR KARLjIN: There is no requirement to 19 do an initial large transient test, MSIV?
20 WITNESS JONES: Unless there is a change.
21 If there is a change, new equipment, or new --
22 CHAIR KARLIN: So has one ever been 23 performed on it before?
24 WITNESS JONES: Yes.
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1468 had one?
2 WITNESS JONES: Right.
3 WITNESS ABDULLAHI: I think the key thing 4 there was that because they shut down for some time --
5 CHAIR KARLIN: For 25 years. -
6 WITNESS ABDULLAHI: Right. So you don't 7 have operating experience in a planned integral 8 testing. And then on top of it you are increasing the 9 dome pressure.
10 So there was this consideration. Reviews 11 were done, I don't know whether we should discuss it 12 but, roughly --
13 ADMINISTRATIVE JUDGE BARATTA: That is 14 fine. I suspected that it was the lack of operating 15 experience, that was probably one of the main 16 considerations.
17 WITNESS PETTIS: There were other factors, 18 including that. And just on a generic basis, without 19 getting into too much detail, since the review is 20 still under -- or since the application and exemption 21 is still under review, there were other arguments that 22 were made by the licensee, following the standard 23 review plan, in the area.
24 To give an example, of similarity, between
- 25 Units 2 and 3, which are operating units, have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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1469 1 operating history, have experienced transients 2 throughout their operating life.
3 And the licensee tried to make a 4 correlation between the operating experience for those 5 units versus unit 1, .which is of the same design, 6 although severely modified due to the 20 years of 7 inoperation.
8 So the Staff had an opportunity to review that. The Staff had an opportunity to have extensive 10 RAI discussions with the Applicant, and as a result 11 came to the conclusion that Steve mentioned.
12 ADMINISTRATIVE JUDGE BARATTA: That 13 actually leads me to my next question. I appreciate 14 you providing that opening.
15 Yesterday, as Abdullahi, and I hope-.I 16 pronounced your name properly, I apologize if I 17 didn't.
18 WITNESS ABDULLAHI: That is okay, you did 19 f ine.
20 ADMINISTRATIVE JUDGE BARATTA: You made a 21 very interesting, some very interesting statements 22 with regards to comparing Vermont Yankee to other 23 plants, and talking about power densities and such.
24 And you may recall that there was a 25 summary,. that was exhibit 38, I believe, from Entergy, NEAL R.GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1470 1 which --
2 CHAIR KARLIN: It was 39.
3 ADMINISTRATIVE JUDGE BARATTA: -- tried to 4 do that comparison, I think,, with Brunswick, if I 5 recall correctly. It was 38 or 39, I'm sorry.
6 Could you maybe give me some suggestions 7 on what I should look at relative -- you know, you've 8 said we've had this type of a transient on this plant, 9 which is a high power density plant, and this type of 10 transient on that plant.
11 If I were to try to do some similarity 12 that TVA was arguing with respect to units 3 and 4, if 13 I were to try to do that, what should I be looking at, 14 Vermont Yankee relative to plants that have experience 15 16 WITNESS ABDULLAHI: I don't really have 17 that exhibit in front of me. But, roughly, one thing 18 you would look at in MSIV is SRV capacity. Because --
19 ADMINISTRATIVE JUDGE RUBENSTEIN: I didn't 20 hear that, ma'am.
21 WITNESS ABDULLAHI: Excuse me?
22 ADMINISTRATIVE JUDGE RUBENSTEIN: I didn't 23 hear that.
24 WITNESS ABDULLAHI: One thing you would 25 look at, I don't have the exhibit, but -
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1471 1 ADMINISTRATIVE JUDGE RUBENSTEIN: No, I 2 don't care about that.
3 WITNESS ABDULLAHI: So one thing you would 4 look for is when you -close -the. MSIV the power will 5 peak, right? So you would want to look at SRV 6 capacity.
7 So if you have two plants, and the amount 8 of SRV capacity that plant has would mean how fast it 9 will depressurize and reduce the peak, while the scram 10 is also being affected.
11 So if you look at these two plants, and I 12 have to confirm this, the SRV capacity for Vermont 13 Yankee, at EPU power level, they used to have one 14 hundred percent, I think, is 60 percent.
15 CHAIR KARLIN: I think Mr. Hamrick found 16 the exhibit, that would be great. This is exhibit 38, 17 this appeared at page 7 in the testimony?
18 MR. HAMRICK: Correct, Your Honor.
19 CHAIR KARLIN: Yes.
20 WITNESS ABDULLAHI: So the SRV capacity 21 for Vermont is 60 percent, and Brunswick is 56.
22 ADMINISTRATIVE JUDGE BARATTA: And 23 Brunswick is what?
24 WITNESS ABDULLAHI: It is 56, EPU power 25 level. So they are relatively, they have similar NEAL R. GROSS
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1472 capacity. The interesting thing to also look for, K) 2 actually, is that Vermont, I believe, has done its 3 analysis with one SRV out of service, and met their 4 criteria. -
.5 Assuming one of their SRVs is out of 6 service. Therefore that means that they have 7 sufficient capacity to handle for ASME overpressure 8 purposes, and MSIV closure case to handle the excess 9 steam, 24 percent extreme flow increase through the 10 EPU.
11 And this is also with a conservative 12 assumption of the flux scram. So putting all of these 13 together, if you are the reviewer you would say that 14 the plant, analytically, it has been demonstrated that 15 the plant can handle SRV, can handle ASME.
16 Now, looking at that, what you also want 17 to look at is, I guess, the power density, which means 18 the power over the number of bundles you have in the 19 core. So it is power to bundle conditions.
20 And the power density, when your EPU goes 21 out. So if you have a smaller core, and you uprate, 22 you put more hot bundles, then your power density will 23 go up, and so that is one thing you check, whether the 24 similarity of the power distribution would be power 25 levels.
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1473 1 I would also, if you are looking at K) 2 turbine trip, of course, you would look at the bypass 3 capacity. In which case you have here, VY has 86 4 capacity, Brunswick unit 2, I believe, had 69.
5 -So they seem to have a sufficient 6 capacity. Now, other parameters, such as the MSIV 7 closure times, these are more tech spec values, so all 8 plants have to meet those specific values. I wouldn't 9 really worry about that.
10 But for ASME overpressure you would, more 11 or less, look at are they similar, do they have a 12 similar capacity, do they have similar power 13 distribution, hopefully, and how relevant are they to K) 14 each other?
15 And in some cases you will actually, would 16 be able to, depending on what you are concerned with, 17 you can look at individual core parameters that were 18 calculated and compare them.
19 ADMINISTRATIVE JUDGE RUBENSTEIN: I have 20 a question.
21 ADMINISTRATIVE JUDGE BARATTA: Let me just 22 follow-up with one and I -- you know, I forget whether 23 Brunswick has experienced an MSIV closure, or turbine 24 trip at uprate conditions. Do you know if they have?
25 WITNESS ABDULLAIHI: I believe that was NEAL R. GROSS
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1474 1 Hatch. Again, I'm only referring to my notes. Hatch 2 did. Do you want to ask a question, or do you want me 3 to explain that comparison with Hatch?
4 CHAIR KARLIN: I believe the testimony you all presented indicates that four -- that there were 6 four transients that occurred, well, at uprated power, 7 but not all of them -- it is in the testimony.
8 WITNESS ABDULLAHI: Yes.
9 ADMINISTRATIVE JUDGE BARATTA: Could you 10 do a comparison with Hatch, do you have that, a 11 similar comparison?
12 ADMINISTRATIVE JUDGE RUBENSTEIN: Same way 13 you just did the other one.
14 ADMINISTRATIVE JUDGE BARATTA: Yes, with 15 Brunswick-.-
16 WITNESS ABDULLAHI: Compare with Hatch, 17 okay. Again, I would need an exhibit number.
18 ADMINISTRATIVE JUDGE BARATTA: Probably 19 39.
20 CHAIR KARLIN: No.
21 MR. TURK: Can we go off the record for a 22 moment?
23 CHAIR KARLIN: Yes.
24 (Whereupon, the above-entitled matter 25 went off the record at 9:44 a.m. and NEAL R. GROSS
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1475 1 went back on the record at 9:47 a.m.)
2 CHAIR KARLIN: We are back on the record 3 now. And I understand the question that was just
-- 4 asked has been withdrawn, or pending to be answered, 5 perhaps later, if you can locate the exhibit?
6 ADMINISTRATIVE JUDGE BARATTA: Yes, that 7 is correct.
8 ADMINISTRATIVE JUDGE RUBENSTEIN: I want 9 to call your attention to the upper dome pressure, and 10 the criteria is boiling pressure vessel code. And it 11 has been testified, by Entergy, and your opinion, that 12 the pressure increase is nominal.
13 Is the pressure increase nominal?
14 WITNESS ABDULLAHI: Nominal?
15 ADMINISTRATIVE JUDGE RUBENSTEIN: Small?
16 WITNESS ABDtJLLAI{I: In the dome pressure.
17 And there won't be pressure increase, but once you 18 close the MSIVs there will be a momentary spike of the 19 .pressure before you scram and SRV is depressurized.
20 ADMINISTRATIVE JUDGE RUBENSTEIN: The rest 21 of my question is, in comparing, in achieving 22 conformance that the pressure is well within the 23 limits of the boiler and pressure vessel code, one can 24 come at it with the calculation, one can come at it 25 through measurements, past experience, and the KY ~
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1476 1 pressure in the plants.
2 So give me an indication, was this a close 3 call, was there a very large amount margin, along 4 those lines, give me a sense of where you are-at.
5 WITNESS THOMAS: When Vermont Yankee did 6 the over-pressure analysis for ASME, the calculated 7 percent was 499PS1G, and the limit is 1375PS1G. So 8 there was a margin there.
9 WITNESS ABDULLAHI: And this is with 10 assumption when SRV is out of service.
11 ADMINISTRATIVE JUDGE RUBENSTEIN: That 12 code calculated?
13 WITNESS THOMAS: Yes.
14 CHAIR KARLIN: What about actual pressure 15 measurements?
16 WITNESS ABDULLAIHI: The actual steady 17 state pressure measurements?
18 ADMINISTRATIVE JUDGE RUBENSTEIN: Yes.
19 WITNESS ABDULLAHI: Yes, they know what 20 the dome pressure is and there are some sort of DP 21 measure, or something.
22 ADMINISTRATIVE JUDGE RUBENSTEIN: And 23 during these kinds of transients --
24 WITNESS ABDtJLLAHI: It can be seen.
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1477 1 were well within their limit, they were marginally 2 within their limit?
3 WITNESS ABDULLAHI: You means the plants 4 that experience EPU?
5 ADMINISTRATIVE JUDGE RUBENSTEIN: Yes.
6 WITNESS ABDULLAHI: The plants that 7 experience EPU, there were some data taken. There is 8 a data telling you where the pressure increase of the 9 vessel is. And that dome pressure increase, the 10 prediction always bounds the actual plant --
11 ADMINISTRATIVE JUDGE RUBENSTEIN: That is 12 a regulatory answer.
13 WITNESS ABDULLAHI: -- conservatism that 14 has been --
- . 15 ADMINISTRATIVE JUDGE RUBENSTEIN: But in 16 your professional opinion was it well below, or 17 approaching, was it calculated, and the actual value, 18 were they anywhere near the ASI4E boiler pressure 19 vessel code stress limits?
20 WITNESS ABDULLAHI: Maybe for Vermont, or 21 the plants that experience EPU. Sir, I would have to 22 go plant by plant, because it depends on the core, the 23 core reactivity, the amount of SRV capacity, you know, 24 you would have to look at that plant, whether it is 25 close to the margin.
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1478 1 However, in terms of the code prediction, 2 1 professionally, from what I have seen, am 3 comfortable with ODYN's peak pressure calculations.
4 I'm very comfortable with that.
5-- ADMINISTRATIVE JUDGE BARATTA: Just one 6 point of clarification. There is, NEC has suggested 7 that the process that was used did not identify the 8 stress levels in the components at EPU conditions.
9 And particularly during these transients.
10 Now, from what I believe you are saying is the plant 11 was analyzed to be able to withstand a 1375, I mean, 12 does that mean, then, that these higher pressures, 13 which are still below 1375, would therefore produce 14 acceptable stresses, is that the answer to their 15 concern, or -
16 WITNESS ABDULLAHI: In terms of structure, 17 and structural stresses, I think I will pass on to 18 Rick Ennis. I'm more the reactor side.
19 WITNESS ENNIS: I'd like to point back at 20 the SRP 14.2.1. And if you look in the back, at the 21 two attachments on there, and in making a decision on 22 whether testing is adequate, you are not just talk 23 about transient testing, you are also talking about 24 steady state testing.
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1479 1 or structural integrity, our guidance does not show us 2 to look into transient testing, it is a steady state 3 condition that you are concerned about.
4 If you -look at page 14.2.1-14, the 5 standard review plan -
6 CHAIR KARLIN: Is that part of the section 7 that deals with justification for not doing the large 8 transient tests?
9 WITNESS ENNIS: No.
10 CHAIR KARLIN: No, okay. I didn't think 11 SO.
12 WITNESS ENNIS: Section 2 of the SE, that 13 is the mechanical and civil engineering analysis of 14 the vessel, and reactor cooling pressure boundary 15 piping.
16 But if you look at page 14.2.1-14, in the 17 standard review plan --
18 ADMINISTRATIVE JUDGE RUBENSTEIN: would 19 you speak up? I'm having difficulty, and I'm sure the 20 lawyers --
21 WITNESS ENNIS: Page 14 of the standard 22 review plan, which is attachment 1, which is steady 23 state power exemption testing, the very first item on 24 that table says, conduct vibration testing and 25 monitoring of reactor vessel internals, and reactor NEAL R. GROSS
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1480 1 coolant systems containments.
2 And it says, the recommended initial 3 conditions of the lowest practicable power level, it 4 also, in the -fourth column there, it references the 5 NRC information noti-ce 2002-26, and that is the 6 information that was discussed along with these 7 vibration problems that happened in Quad Cities, with 8 the steam driers.
9 So our guidance is telling us, as far as 10 stress and structural integrity issues go, any testing 11 that we deem would be necessary, would be under steady 12 state conditions, not transient conditions.
13 ADMINISTRATIVE JUDGE BARATTA: But that Q 14 doesn't quote answer my question. I wasn't asking 15 what the regulatory requirements were, as --
16 CHAIR KARLIN: Well, that is not the 17 regulatory requirement, anyway. Criterion 11 doesn't 18 miake the distinction between steady state and non-19 steady state.
20 ADMINISTRATIVE JUDGE BARATTA: I was 21 asking from a topical analysis standpoint, at one time 22 somebody did a stress analysis at the plant?
23 WITNESS ENNIS: That is correct.
24 ADMINISTRATIVE JUDGE BARATTA: And it was 25 done fo r the ASME boiler pressure vessel code, and it NEAL R. GROSS 1323 RHODE ISLAND AVE., N.W.
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1481 1 concluded that appropriate pressure was 1375, that 2 that was the limit.
3 And the implication named that if you are 4 below-that pressure your stresses are okay. If you are 5 above that pressure, they are not.
6 WITNESS ENNIS: Right.
7 ADMINISTRATIVE JUDGE BARATTA: Now, what 8 occurred is that in plants that have had EPU under 9 constant pressure, the pressures have remained below 10 1375.
11 WITNESS ABDULLAIII: Yes, that is a 12 requirement.
13 ADMINISTRATIVE JUDGE BARATTA: Number one.
14 Number two the code predictions also say that the 15 pressures would be-below 1375. So am I to conclude, 16 then, that the concerns expressed by NEC have been 17 addressed?
18 Namely the pressure, as long' as the 19 pressure remains below 1375 the stress levels are 20 acceptable?
21 WITNESS ABDULLAHI: For ASME over-pressure 22 purposes -they do meet the ASME over-pressure 23 requirement, which ensure vessel integrity.
24 WITNESS ENNIS: I think it is a bigger 25 issue than just over-pressure. If you look at the NEAL R. GROSS 76-tN TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1482 CCPU topical report, and our safety evaluation report,
& 2 I believe it is sections 3.2 and 3.4 of that safety 3 evaluation, it discusses an acceptable methodology for 4 calculating the stresses, for EPU conditions, on 5 various components.
6 And I believe it points back to some 7 specific appendices in the ELTRi topical report.
8 Using that specific methodology they calculated the 9 stresses for the ASME based load cases, and those load 10 cases include things, you know, such as transient 11 conditions, as well as other conditions like seismic 12 conditions.
13 And the Staff'I SC, and this is in various 14 subsections of section 2.2 of our safety evaluation, 15 we reviewed the methodology they used, we believe that 16 the methodology they used was consistent with the CPPU 17 topical report, and that the stresses would remain 18 within acceptable limits, and structural integrity 19 would be -maintained under EPU conditions, including 20 transients.
21 ADMINISTRATIVE JUDGE BARATTA: So what you 22 are saying is that when NEC said that ODYN would not 23 do a stress analysis. This is true but stress 24 analysis was done using other acceptable methods, as 25 outlined in the CPPU topical, or -
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1483 1 WITNESS ENNIS: Yes.
2 ADMINISTRATIVE JUDGE BARATTA: That is 3 basically where I wanted to get to, was -- thank you.
-. 4 CHAIR KARLIN: I have some questions about 5 the --
6 ADMINISTRATIVE JUDGE RUBENSTEIN: Let me 7 go a little bit further on that.
8 CHAIR KARLIN: Okay.
9 ADMINISTRATIVE JUDGE RUBENSTEIN: Give me 10 a second here to pull up -- I believe you wrote, in 11 your Safety Evaluation Report, the methodology used to 12 evaluate mechanical stresses on various components, 13 subject to increased loading of the EPU conditions, is 14 included in your safety evaluation for the CPPU 15 topical report, dated March 31st, 2003.
16 Specifically section 3.2 of the CPPU 17 safety evaluation discusses reactor pressure vessel, 18 and its internals, and section 3.4, discusses piping 19 systems and associated components.
20 CHAIR KARLIN: Do we know where that was 21 in the report?
22 ADMINISTRATIVE JUDGE RUBENSTEIN: Yes, it 23 is -- I will give it to you in a minute.
24 CHAIR KARLIN: Yes, so we can all --
25 ADMINISTRATIVE JUDGE RUBENSTEIN: Section NEAL R. GROSS
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1484 1 3.2 of the CPPtJ.
2 CHAIR KARLIN: Of the CPPU.
3 ADMINISTRATIVE JUDGE RUBENSTEIN: Of the Safety Evaluation Report. Discusses details regarding 5 how stresses were analyzed for the reactor pressure 6 vessel, and its internals, other than the steam dryer.
7 In section 2.2.3, for the steam dryer, in 8 section 2.26 for piping systems and components. Now, 9 -- and your finding was?
10 WITNESS ENNIS: The finding was that 11 structural integrity would be maintained under 12 repeated conditions.
13 ADMINISTRATIVE JUDGE RUBENSTEIN: And this 14 is based on a review of independent calculations, or 15 based on a review of Entergy's submittal?
16 WITNESS ENNIS: Review based on Entergy's 17 submittal, and in some cases it might have been under 18 a request for additional information. It might have 19 been calculations submitted.
20 We did, specially with the steam dryer, we 21 did several audits.
22 ADMINISTRATIVE JUDGE RUBENSTEIN: I 23 thought the steam dryer was a little separate --
4..
24 WITNESS ENNIS: Based on its submission of 25 information on the docket.
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1485 1 ADMINISTRATIVE JUDGE RUBENSTEIN: I think, 2 and I can't recall exactly where, but Entergy, in 3 discussing, in response to some questions by me, about 4 the steam dryer, and the potential loads arising from 5 the subject of interest, which are the two transients, 6 testified that the time period of the load imposition 7 was exceptionally short.
8 So are your steam dryer concerns from the 9 MSIC, or the turbine generator loads, or are they from 10 a long time steady state, either thermal or mechanical 11 fatigue considerations?
12 WITNESS ENNIS: May I have a minute to 13 take a look at the SE for a second?
14 (Pause.)
15 WITNESS ENNIS: I believe it is more of a 16 long term fatigue related stresses, rather than 17 impulse loads to the transient.
18 ADMINISTRATIVE JUDGE RUJBENSTEIN: Did you 19 consider this degradation which may or may not have 20 occurred? And I think Entergy testified that they had 21 strengthened the baf fle where the incoming lines were, 22 that this might be a concern in doing a transient 23 calculation, considering that the initial conditions 24 may have been degraded?
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1486 1 question, please?
2 CHAIR KARLIN: Could you speak up? Try to 3 speak up because everyone needs to hear. Thank you.
4 ADMINISTRATIVE JUDGE RUBENSTEIN: Very 5 simply put there is a potential for long time steady 6 state degradation of the mechanical integrity of the 7 steam dryer.
8 Would this be a concern going into this 9 transient, and how do you deal with it?
10 MR. ENNIS: The analysis that was done 11 even for the steam dryer, even though it's not an ASME 12 component, they used ASME load cases to do the 13 analysis.
14 And those load cases did include transient 15 conditions.
16 ADMINISTRATIVE JUDGE RUBENSTEIN: Okay.
17 Thank you. Just for the record, get out of the 18 jargon, please state what an ASME condition is.
19 MR. ENNIS: Well the -- they have loading 20 conditions that they would include --
21 ADMINISTRATIVE JUDGE RUBENSTEIN: The 22 American Society of Mechanical Engineers standard?
23 MR. ENNIS: Right.
24 ADMINISTRATIVE JUDGE RUBENSTEIN: Okay.
25 I'll do the testifying on that. Thank you.
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1487 1 CHAIR KARLIN: I had a couple of questions 2 related to the safety evaluation section that deals 3 with SRP 14.2. 1. And it starts on page 266 with Staff 4 Exhibit 2. Who is most responsible for drafting and 5 developing that?
6 MR. PETTIS: Probably me.
7 CHAIR KARLIN: Mr. Pettis?
8 MR. PETTIS: I think so. If it's the same 9 page numbering I think that I have.
10 CHAIR KARLIN: I believe it's the page 11 numbering from your exhibit number 2. Page 266, are 12 you with me?
13 MR. PETTIS: Yes.
14 CHAIR KARLIN: Okay, great, because all I 15 am is a lawyer, and words -- I focus on words and I 16 try to understand what they mean. And to me what they 17 say are important.
18 Words are important. So this section is 19 in the middle of page 266, SRP 14.2.1 Section 3C, use 20 of evaluation to justify elimination of power 21 ascension tests.
22 That's what I'm focusing on. And the 23 Staff evaluation refers to the draft SRP and says 24 then, first paragraph, the following factors should be 25 considered, and lists bullets, factors that need to be NEAL R. GROSS
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1488 considered.
2 Right. Then we go to the next page 267.
3 The NRC Staff reviewed the licensee's justification.
4 The following-factors were applied by the licensee.
5 And then there's some bullets.
6 All right. And then the following is a 7 brief justification provided by the licensee and some 8 more bullets. Page 268, more bullets. Now at the 9 bottom of page 268 there's a statement in that full 10 paragraph, the licensee, it's the third line down, and 11 I'm trying to understand what that means.
12 The licensee cited industry experience at 13 ten other domestic BWRs, EPE~s up to 120 percent OLTP 14 in which the EPU demonstrated that plant performance 15 was adequately predicted under EPU conditions.
16 Now that sentence starts with a 17 proposition, the licensee cited industry experience, 18 blah, blah, blah. Now the phrase plant performance 19 was adequately predicted under EPU conditions, in that 20 sentence is that simply a reiteration of what the 21 Applicant said or is that what you're saying?
22 MR. PETTIS: That's a combination of 23 information supplied by the Applicant in addition to 24 our review of LER information.
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1489 1 made the judgment call right there in that sentence.
2 The Staff is saying that in those ten other domestic 3 BWRs the EPU demonstrated that plant performance was 4 adequately predicted.
.5 That'Is the Staf f'Is judgment or is that the 6 citation of what the Applicant said?
7 MR. PETTIS: That may in fact be a statement that was submitted by the Applicant and its 9 review of those --
10 CHAIR KARLIN: Right.
11 MR. PETTIS: -- events --
12 CHAIR MARLIN: So it's more --
13 MR. PETTIS: -- in their application.
14 CHAIR KARLIN: That's the way I took it.
15 It was something the Applicant said to you.
16 MR. PETTIS: Right, because I can rest 17 assured that I personally did not do a exhaustive 18 review --
19 CHAIR MARLIN: Right.
20 MR. PETTIS: -- of all of this external 21 information to come up with that.
22 CHAIR MARLIN: Right.
23 MR. PETTIS: But again --
24 CHAIR MARLIN: Okay. So I think the way 25 I read that sentence, it's your -- the writer is NEAL R. GROSS
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1490 1 telling us that the licensee cited certain experience 2 in which certain, you know, demonstrated plant 3 performance.
4 So you weren'It making that conclusion, you 5 were just saying that the licensee said this. The 6 next sentence. The licensee stated that one such 7 plant, Hatch units 1 and 2 is granted blah, blah, 8 blah, blah.
9 Again, you're repeating what the licensee 10 said to you?
11 MR. PETTIS: Yes.
12 CHAIR KARLIN: Right. The next paragraph 13 on 269. The licensee also provided information 14 regarding transient testing for the livestock 15 facility. This is the one facility in the world, I 16 guess, where they've done it, or at least they have 17 done it somewhere.
18 And the one, two, three, four, five lines 19 down, there is at the end of that line, the testing 20 demonstrated the performance of the equipment that was 21 modified in preparation for the higher power levels.
22 And you saying that? Is that something 23 the licensee told you and put in his application or is 24 that some conclusion that the Staff is making here?
25 MR. PETTIS: It was most likely a NEAL R. GROSS
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1491 1 statement from the licensee in their application --
2 CHAIR KARLIN: That's --
3 MR. PETTIS: -- since they've done, you 4 .know, quite an exhaustive review -
5 CHAIR KARLIN: Right. -
6 MR. PETTIS: -- of all of these events.
7 CHAIR MARLIN: Okay. In the last sentence 8 in that paragraph, additionally the licensee indicated 9 that in transient experience for a wide range of power 10 levels at operating BWRs has shown a close correlation 11 of plant transient data to the predicted response.
12 Now that is not a Staff conclusion, it's 13 just what the licensee told you?
14 MR. PETTIS: Most likely.
15 CHAIR KARLIN: Okay.
16 MR. PETTIS: But I like to put something 17 in context with respect to --
18 CHAIR MARLIN: Sure.
19 MR. PETTIS: -- this particular individual 20 section. And basically we are looking in this section 21 at the licensee's compliance to the SRP with respect 22 to --
23 CHAIR MARLIN: Right.
24 MR. PETTIS: -- the elements of their 25 power ascension and test plan and how it conforms with NEAL R. GROSS
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1492 1 the guidance in the SRP.
2 CHAIR KARLIN: And whether they adequately 3 discussed these factors?
4 MR. PETTIS: Yes. In addition to that my 5 group's review .- is basically an overall coordinated 6 review of the other technical branches. So what 7 happens is in the safety evaluation, in the template 8 safety evaluation section which has ten, twelve 9 different disciplines, the disciplines that have input 10 into the overall power ascension test plan we discuss, 11 like plant systems, balance of plant and reactor 12 systems. And collectively --
13 CHAIR KARLIN: Right.
14 MR. PETTIS: -- we use this section as a 15 depository of the overall conclusion --
16 CHAIR KARLIN: Okay.
17 MR. PETTIS: -- with respect --
18 CHAIR KARLIN: All right.
19 MR. PETTIS: -- to the power upright.
20 CHAIR KARLIN: What I see so far is what -
21 - in this is a recitation of the SRP and a recitation 22 of things that the Applicant said to the NRC. Now 23 let's go to the bottom of page 269 where we were 24 before, and that SRP 114 specifies that, and it goes 25 on, blah, blah.
flA~.
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1493 1 Top of 270, the SRP provides guidance on 2 that. Next paragraph, the NRC Staf f review is 3 intended to insure that performance -- so this is sort 4 of what your intent is and what you want to do.
5 Next paragraph, energies test program 6 primarily includes steady state. They sent a letter 7 December 21, '04. Finally at the bottom of page 270 8 we get to what seems to be where the Staff's 9 conclusion is stated for the first time.
10 Based on its review of the information 11 provided by the licensee as describe above, the NRC 12 Staff concludes that in justifying the test 13 limitations, deviations, blah, blah, blah, the 14 licensee adequately addressed the factors.
15 And we talked about before you could 16 adequately address the factors very thoroughly and 17 find out we just totally should not be granted this 18 thing. Right? So an adequate discussion is not your 19 criterion for granting this.
20 So there was an adequate discussion. Then 21 there's a sentence in the middle, and this I think as 22 far as I can tell, this is the only judgmental 23 sentence you all put in this whole thing, which is 24 from the EPU experience referenced by the licensee it 25 can be concluded, can be I guess it means you are NEAL R. GROSS
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1494 1 concluding, that large transients either planned or 2 unplanned have not provided any significant new 3 information about transient modeling or actual plant 4 response.
5 All right. Let me ask about that, can be 6 concluded large transients either planned or 7 unplanned. Now with regard to MSIVs have there been 8 any planned MSIV closure tests at EPU by any facility 9 that you all have regulated, planned MSIV closure jo tests? I think the answer is no.
11 MR. PETTIS: I Im not aware of any, but I'Im 12 not in that area of the Staff that would refer me to 13 that --
14 CHAIR KARLIN: Well didn't we just hear 15 there were -
16 MR. PETTIS: -- information anyway.
17 CHAIR KARLIN: -- 16 EPt~s granted and no 18 one ever required a large transient test?
19 MR. PETTIS: No.
20 CHAIR KARLIN: Okay. So there aren'It any 21 planned, at least in the United States, at MSIVs, at 22 EPU, or generator load. Let's -- it can be concluded 23 that large transients either planned or unplanned have 24 not provided any significant new information about 25 transient modeling or actual plant response.
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1495 1 Is that true only with regard to this 2 plant, or is it true generally? Is that conclusion 3 based upon this plant, the Vermont Yankee plant?
4 MR. PETTIS: Well that conclusion is based 5 on Vermont Yankee, however there is a body of 6 information that exists within the General Electric 7 boiling water reactor fleet, and in the CPPEJ topical, 8 and in the ELTR documents--
9 CHAIR KARLIN: Right.
10 MR. PETTIS: -- that seems to carry over 11 from application to application to application.
12 CHAIR KARLIN: Right.
13 MR. PETTIS: You will find in most 14 applications references made to a lot of the KKL and 15 the KKM testing, and the CPPU topical, and the fact 16 that there's no increase in dome pressure, and the 17 analysis is simplified, and --
18 CHAIR KARLIN: All right.
19 MR. PETTIS: So a lot of that gets carried 20 over in the GE BWR process. So --
21 CHAIR KARLIN: So that conclusion is not 22 unique to --
23 MR. PETTIS: That conclusion is not unique 24 to Vermont Yankee.
25 CHAIR KARLIN: It's sort of a generic NEAL R. GROSS COURT REPORTER3,z'.qD TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1496 1 conclusion about experiences, planned, unplanned large 2 transient?
3 MR. PETTIS: Yes.
4 CHAIR KARLIN: So it's a generic 5 contlusion, it can be concluded that large transients 6 either planned or unplanned have not provided any 7 significant new information about transient modeling 8 or actual plant response.
9 I thought this was supposed to be a plant 10 specific exclusion. It sounds like a generic 11 exclusion.
12 MR. PETTIS: Well it's plant specific.
13 CHAIR KARLIN: Is that true generally?
0' 14 MR. PETTIS: It's plant specific to 15 Vermont Yankee. It just so happens that if you look 16 back at all of the --
17 CHAIR MARLIN: But what is plant specific 18 about that statement to Vermont Yankee? What -- look 19 at that statement. What is specific about that 20 statement to Vermont Yankee?
21 MR. PETTIS: Well Vermont Yankee in its 22 application cites in references operating experience 23 of other similar --
24 CHAIR MARLIN: They provided you the data.
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1497 1 transients, although at the time of application, you 2 know, VY did not experience --
3 CHAIR KARLIN: Right.
4 - MR. PETTIS: -- that.
5 CHAIR KARLIN: So the unique part about 6 this is simply that Vermont Yankee is the one that 7 provided you the information?
8 MR. PETTIS: Well we're right --
9 CHAIR KARLIN: But the information applies 10 generally to all -- is generic information?
11 MR. PETTIS: Pretty much.
12 CHAIR KARLIN: So and that -- is that the 13 basis for the Staff's conclusion that this exemption 14 should be granted? I mean that's -- let me just read 15 this paragraph.
16 Show me someplace else within this SER --
17 I mean the report where you say the reason why you've 18 reached this conclusion to grant this exemption.
19 MR. PETTIS: On page --
20 CHAIR KARLIN: No. I'mI sorry. Mr. Jones, 21 did you have something?
22 MR. JONES: Yes, on page 273.
23 CHAIR KARLIN: Oh, wait a second, 273 is
- 24 not part of the justification for exemption of this, 25 is it? That's a different section.
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1498 1 MR. JONES: No, it's within the same 2 section. It's not -- it's highlighted BOP systems.
3 CHAIR KARLIN: Well let me -- let's go to 4 -that then. Let's start with 271, SRP 14.2.1 Section 5 3D, different section. Evaluate the adequacy of 6 proposed transient testing plans.
7 Is that focused on -- well if you're going 8 to do a transient testing plan you've got to make sure 9 it's an adequate one. You've already decided not to 10 do the transient tests.
11 You just did that in the prior section, so 12 how does this section apply? You're evaluating the 13 adequacy - -
14 MR. JONES: Well --
15 'CHAIR KAR.LIN: -- because you've already 16 decided not to do it. That was what the paragraph 17 just said.
18 MR. JONES: There's a separate heading on
-19 the top of page 273.
20 CHAIR KARLIN: Two seventy-three, okay.
21 MR. JONES: It kind of separates it from -
22 23 CHAIR KARLIN: But you've already 24 concluded not to do the large transient test on page 25 270 it seems. Okay. What are we doing in 273? This NEAL R. GROSS
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1499 1 is balance of plant.
2 I just want to go back to page 270 for a 3 minute and say is that the basis -- was there anything else in that section, than that one sentence, as to-5 your reason, conclusion,- explanation of why you 6 decided to grant this exemption, Mr. Pettis?
7 MR. PETTIS: Well that section there 8 represents a compilation of inputs.
9 CHAIR KARLIN: Right. I know it's a 10 compilation, but I'm looking for the final judgment 11 call my the Staf f articulated in this report that says 12 here's why we decided to grant this exemption.
13 MR. PETTIS: That'Is pretty much where it'Is 14 located.
15 CHAIR KARLIN: Is that it?
16 MR. PETTIS: That's pretty much where it'Is 17 located. It's in that Section 212 which is the power 18 ascension and test plan.
19 CHAIR KARLIN: OKAY.
20 MR. PETTIS: And again, that would embody 21 the collective inputs of other technical branch 22 reviews, if they felt that they needed to provide 23 input with respect to the justification.
24 ADMINISTRATIVE JUDGE RUBENSTEIN: Does 25 each section specify in this area that it meets the
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1500 1 applicable regulation, so this summary paragraph 2 really is saying we have met the regulations?
3 MR. PETTIS: Well yes, there's a --
.4 ADMINISTRATIVE JUDGE RUBENSTEIN: Each 5 section in the SER?
6 CHAIR KARLIN: Well, yes, sure. That's 7 what they're saying. I'm just trying to find out why.
8 MR. PETTIS: Each section of the SRP --
9 ADMINISTRATIVE JUDGE RUBENSTEIN: SER.
10 MR. PETTIS: -- excuse me, SER provides 11 its own conclusion at the end with respect to their 12 technical -
13 ADMINISTRATIVE JUDGE RUBENSTEIN: And it 14 says basically we meet the regulation. So this --
15 MR. PETTIS: Ultimately yes.
16 ADMINISTRATIVE JUDGE RUBENSTEIN: So this 17 paragraph --
18 MR. PETTIS: Well we have another -- we 19 have another paragraph that's part of the template 20 safety evaluation.
21 CHAIR KARLIN: So we're at 270. This is 22 the conclusion paragraph of the analysis of whether 23 they've justified not having to do this test. And the 24 only sentence I find that provides such justification 25 is the one we've been focusing on.
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1501 1 And that's not a site specific analysis, 2 that's a generic statement. Why not just give them 3 the generic exemption that GE asked for the first 4 time? Yes, Mr. Ennis?
5 MR. ENNIS: I agree that it doesn't go' 6 explicitly into details, but I think --
7 CHAIR KARLIN: Well we who pay attention 8 to these things find this important. What I want to 9 understand, why, what's your judgment call on?
10 MR. ENNIS: The intro of the first 11 sentence is based on review of the information 12 provided by the licensee. And in the course of the 13 review we *had several rounds of requests for 14 additional information.
15 I believe we provided those as Entergy 16 Exhibits -- I mean our Staff Exhibits 9, 10, and 11, 17 where we said that SRP says we should address all 18 these criteria, we don't think you've provided enough 19 for Vermont Yankee.
20 And they provided a lot more information 21 there that we did review.
22 CHAIR KARLIN: Okay. They provided 23 information, you all asked for more information, they 24 gave you more information, you reviewed it. And all 25 I was looking for is why you concluded that it was -
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1502 1 should be exempt.
2 And that's the one sentence that seems to 3 tell me the answer.
4 MR. ENNIS: As I think Mr. Jones was 5 starting to state, is if you go all1 the way to the end 6 of the section, based on the template safety 7 evaluation we have the overall conclusion that it 8 meets criterion 11 in --CHAIR KARLIN: Right. That's 9 ultimately -- it's a judgment call. You've made that 10 judgment that it is --
11 MR. ENNIS: Right.
12 CHAIR KARLIN: -- meets criteria.
13 MS. ABDULLAHI: I think --
14 CHAIR KARLjIN: Ms. Abdullahi?
15 MS. ABDULLAHI: I just wanted to say, like 16 Steve's section on input, Steve Jones, --
17 CHAIR KARLIN: Yes?
18 MS. ABDULLAHI: -- on the inputs on 19 whether to require the generated load reject, one of 20 his inputs and plant specific condition was all the 21 plant modifications were already done. They 22 experienced two transient --
23 CHAIR KARLIN: I understand, Ms.
24 Abdullahi.
25 MS. ABDULLAHI: -- after the model. So NEAL R. GROSS COURT REPORTERS AND TRANSCMiBERS -
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1503 1 these go into --
2 CHAIR KARLIN: Ms. Abdullahi, I understand 3 that. All I was asking for is when I read these words 4 I'm trying to find out what the Staff's reason was, 5 and that's not in there.
6 MS. ABDULLAH-I: Oh, maybe it'Is not written 7 there.
8 CHAIR KARLIN: Yes. This is an important 9 document. This is a Safety Evaluation Report by the 10 Staff. It's a key document that tells us why you've 11 reached the conclusion you did.
12 ADMINISTRATIVE JUDGE BARATTA: I think -
13 CHAIR KARLIN: And the conclusion in here 14 is a generic reason.
15 ADMINISTRATIVE JUDGE BARATTA: I think the 16 problem that we all had in reading this document, at 17 least I did, is that it really does not provide that 18 much insight into the thought processes that you went 19 through in that it has, as Judge Karlin has adequately 20 pointed out, a generalization based on what's there.
21 And that'Is what we'Ire trying to get at, is 22 what is -- what was the rationale? You know, where --
23 how did you get to where you got?
24 CHAIR KARLIN: Well, I'm not -- and I 25 think we've already gone over that ground several NEAL R. GROSS COURT REPORTERS-AND RANSCRIRSSS 1323 RHODE ISLAND AVE.. N.W.
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1504 1 times.
2 ADMINISTRATIVE JUDGE BARATTA: Yes.
3 CHAIR KARLIN: But I -- when I look at the 4 -- so we've understood and..we've heard your testimony 5 -. as to what your rationale was in terms of the written 6 testimony and here today and yesterday.
7 I just -- I'm troubled by the fact it's 8 not articulated.
9 ADMINISTRATIVE JUDGE BARATTA: Right.
10 CHAIR KARLIN: And here in fact a 11 different reason is given in here than what you've 12 spoken to in a sense. And it's a generic reason, not 13 a site specific one.
14 MS. ABDULLAHI: So is the SE content.
15 CHAIR MARLIN: Yes. How it's written.
16 And I rely on that as an important document, how 17 you've cited it in your exhibits. Okay. That's all 18 I have. Any more questions for -- now we did have a 19 follow-up question for the Staff.
20 Perhaps you have that before we -- yes, 21 Ms. Abdullahi?
22 MS. ABDULLAHI: After the break I will --
23 CHAIR MARLIN: Do you have that?
24 MS. ABDULLAHI: -- give you. I just need 25 to maybe -
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1505 1 CHAIR KARLIN: Well we might not have to 2 call you back on the stand if --
3 MS. ABDULLAHI: Oh, I don' t want to do 4 that then. Let-rne. -- Okay.
5 CHAIR KARLIN: All right. We'll take a 6 ten recess --
7 MS. ABDULLAHI: Let me give you --
8 CHAIR KARLIN: Why don't we do this?
9 We'll take a ten minute recess and then if you've got 10 something you can -- we won't necessarily call 11 everybody back but maybe you could just address that, 12 whatever that question was.
13 MS. ABDULLAHjI: Okay.
14 CHAIR KARLIN: And then give us an answer.
15 MS. ABDULLAHI: Okay.
16 CHAIR KARLIN: All right. We'll break for 17 ten minutes, 10:30.
18 (Whereupon, the above-entitled matter 19 went off the record at 10:29 a.m. and 20 went back on the record at 10:30 a.m.)
21 CHAIR KARLIN: On the record.
22 (Audience interruption.)
23 CHAIR KARLIN: We will take another break, 24 everyone gets a few more minutes while we remove this 25 lady. Thank you.
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1506 (Whereupon, the above-entitled matter K> 2 went off the record at 10:31 a.m. and 3 went back on the record at 10:39 a.m.)
4 - CHAIR KARLIN: I think we only need Ms.
5 Abdullahi to come up because our question is directed 6 to her, so you all can step down at this point. Thank 7 you for your testimony and your time. We may end up 8 recalling you at some point.
9 MS. ABDULLAHI: Okay. I looked --
10 CHAIR KARLIN: Well let's just ask --
11 ADMINISTRATIVE JUDGE BARATTA: I think 12 previously you said that for am MSIV closure the 13 important comparison was the SRV capacity. So could 14 you compare the SRV capacity for Vermont Yankee to 15 that of Hatch?
16 MS. ABDULLAHI: I looked at the data right 17 now here for -- there's the data comparing Hatch and 18 some other plants at rated condition, not EPU.
19 However the data contained everything you need but the 20 SRV capacity. So I tried to go through the 21 licensing document, G-STAR-2, which all BWRs with GE 22 have. I couldn't find it. But what I did notice 23 though is that Hatch would be a larger BWR.
24 It would probably have a higher power 25 density, and so relative, Vermont would be much on the NEAL R. GROSS 41 Ak=TR AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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1507 1 smaller side, so Hatch would probably have more SRVs, 2 but then it's a larger core.
3 So you just have to compare the two. I 4 can't do that right now.
5 ADMINISTRATIVE JUDGE BARATTA: You don't 6 have enough information to do that?
7 MS. ABDULLAHI: I do not have -- however 8 I -- I just thought, I also thought you asked about 9 the turbine trip case. In Brunswick that's covered.
10 We did have a turbine trip case.
11 ADMINISTRATIVE JUDGE BARATTA: Oh, okay.
12 MS. ABDULLAHI: And so --
13 ADMINISTRATIVE JUDGE BARATTA: So the data 14 that's in that chart is --
15 MS. ABDULLAHI: Is a similarity between 16 Brunswick and Vermont Yankee, which are much closer 17 than Hatch and Vermont. But -- and --
18 CHAIR KARLIN: And the chart being?
19 ADMINISTRATIVE JUDGE BARATTA: Yes, the 20 chart --
21 CHAIR KARLIN: Exhibit 38?
22 ADMINISTRATIVE JUDGE BARATTA We were 23 referring to it as Exhibit 38.
24 MS. ABDULLAHI: Thirty-eight.
25 CHAIR KARLIN: Yes, okay.
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1508 1 MS. ABDULiLAHI: The one that was added.
2 ADMINISTRATIVE JUDGE BARATTA: Thank you.
3 CHAIR KARLIN: Yes. Is that it?
ADMINISTRATIVE JUDGE RUBENSTEIN: Just to 5 summarize, the dominant factors were SRV capacity, 6 energy density, power density, and peak water flow 7 capacity?
8 MS. ABDULLAHI: Yes.
9 ADMINISTRATIVE JUDGE RUBENSTEIN: Well, I 10 thank you.
11 CHAIR KARLIN: All right. Thank you, Ms 12 Abdullahi. You may step down. Thank you for your 13 attention. At this point the New England Coalition 14 has a witness.
15 You have no exhibits that you have 16 presented, Mr. Shadis.
17 MR. SHADIS: That's correct.
18 CHAIR KARLIN: So we will just go 19 directly.
20 MR. SHADIS: I'll be relying on Entergy 21 and NRC exhibits.
22 CHAIR KARLIN: All right, fine. So let's 23 have Dr. Hopenfeld --
24 DR. HOPENFELD: Yes, I'm Dr. Joram 25 Hopenfeld.
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1509 1 CHAIR KARLIN: Dr. Hopenfeld would you 2 please take a seat over there behind the -- in the 3 jury box, or stand over there. That's where -- Thank 4 you.
5 Whereupon, 6 DR. JORAM HOPENFELD 7 was called as a witness by Counsel for NEC and, having 8 been duly sworn, assumed the witness stand, was 9 examined and testified as follows:
10 CHAIR KARLIN: Thank you. Please sit 11 down.
12 MR. SHADIS: Dr. Hopenf eld, would you open 13 your materials to your testimony, please? Dr.
14 Hopenfeld, do you before you a prefiled, written 15 testimony of Dr. Joram Hopenf eld, regarding Contention 16 3, and do you have before you a declaration of Dr.
17 Joram Hopenfeld in support of New England Coalition's 18 response to the statements of position of Entergy and 19 Staff?
20 WITNESS HOPENFELD: I believe I do, yes.
21 MR. SHADIS: I'm sorry?
22 WITNESS HOPENFELD: Yes.
23 MR. SHADIS: Did you prepare this 24 testimony for submission in this proceeding?
25 WITNESS HOPENFELD: Did I what?
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1510 1 MR. SHADIS: Did you prepare this 2 testimony for submission in this proceeding?
3 WITNESS HOPENFELD: Yes, I did.
4 MR. SHADIS: Have you prepared a statement 5 of your professional qua-lifications?
6 WITNESS HOPENFELD: Yes, I did.
7 MR. SHADIS: Is your statement of 8 professional qualifications included in your prefiled 9 testimony?
10 WITNESS HOPENFELD: Yes, indeed.
11 MR. SHADIS: Have you any corrections or 12 revisions to that testimony at this time?
13 WITNESS HOPENFELD: I do not.
14 MR. SHADIS: Do you adopt this written 15 testimony as your sworn testimony in this proceeding?
16 WITNESS HOPENFELD: I do.
17 MR. SHADIS: I now move to have this 18 direct testimony admitted into this proceeding.
19 CHAIR KARLIN: Are there any objections?
20 Hearing none the testimony will be 21 admitted into this proceeding and entered into the 22 transcript as if read.
23 (Whereupon, the direct prefiled testimony 24 of Dr. Joram Hopenfeld was bound into the record as if 25 having bee n read.)
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UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THlE ATOMIC SAFETY AND LICENSING BOARD IMthe matter Of My1,20 ENTERGY NUCLEAR VERMONT YANKEE, LLC My1,20 and ENTERGY NUCLEAR OPERATIONS, INC. Docket No. 50-271 (Vermont Yankee Nuclear Powver Station) ASLBP No. 04-832-02-OLA AFFIDAVIT OF DR. JORAM JIOPENFELD REGARDING HIS PREFILED TESTIMONY IN SUPPORT OF NEW ENGLAND COALITION'S CONTENTION 3 I, Dr. Jorain Hopenfeld, declare as follows:
- 1. My name is Dr. Joramn Hopenfeld, I reside at 1724 Yale Place, Rock-Ville, Maryland.
- 2. The Newv England Coalition has retained me as an expert witness in -the above captioned matter.
- 3. I declare under penalty of perjury that the testimony that I have offiered in the above captioned proceeding as PREFILED WRITT1EN TESTIMONY OF DR. JORAM HOPENFELD IN SUPPORT OF NEW ENGLAND COALITION CONTENTION 3, is true and correct.
Executed this day, April 17, 2006 at Rockville, Maryland.
Joram Hopenfeld, PhDL*
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the ATOMIC SAFETY AN]) LICENSING BOARD In the Matter of Entergy Nuclear Vermont Yankee, LLC May 17,2006 and Entergy Nuclear Operations, Inc. (Vermont Yankee DoktN.5271OL Nuclear Power Station) (Technical SpecificationDoktN.5-7OL Proposed Change No. 362) ASLBP No. 04-832-02-OLA PREFILED WRITTEN TESTIMONY OF DR. JORAM TIOPENFELD REGARDING CONTENTION 3 On behalf of New England Coalition, Dr. Jorarn Hopenfeld hereby submits the following testimony regarding New England Coalition's Contention 3.
Q.1. Please state your name and address.
A.I. My name is Dr. Joram. Hopenfeld and my business address is 1724 Yale Place, Rockville, MD, 20850.
Q.2. What is your educational and professional background?
A.2. I have received the following degrees in engineering from the University of California at Los Angeles: BS 1960, MS 1962, and PhD 1967.
My major fields were in Fluids Flow, Heat Transfer and Electrochemistty.
I ani an expert in the development of thermal hydraulic computer codes and models as they relate to the assessment of nuclear safety issues.
My resume' has been provided to the Board and to the parties as an attachment to a Declaration Of Dr. Jorain Hopefeld Supporting New England Coalition's Response To Envy's Motion For Summary Disposition. December 21, 2005.
During a professional career spanning over 44 years I have:
" conceived, designed and conducted tests as well as managed national and international -research programs in the areas relating to thermal hydraulics, materialscoolant compatibility and reactor safety,
- managed a major international program on steam generator performance during accidents, and
" funded research and development work at the Engineering Department of the University of Virginia, which resulted in the development of a computer code in support of measurements of pipe wall thinning from erosion/corrosion.
Q.3. Can you cite specific examples of recognition by the scientific community?
A.3.
" As described in Attachment One. PUBLICATION IN PEER REVIEWED JOURNALS ONL 1 have published 14 papers in peer-reviewed technical journals in the above areas.
" I hold eight U.S. patents and I am listed in the Engineers of Distinction published by the Engineers Joint Council and in American Men and Women in Science.
" I was a reviewer for the "A.I.A.A. Journal of Energy."
" I was the U.S. representative to the 1976 International Conference on Cavitation in Fast Breeder Reactors. I am a recipient of the ASME Blackall Machine Tool Gage Award Q.4. Please discuss your experience as it relates to transient testing?
A.4. While working for the NRC I was responsible for a major, international transient test program, MB-2, which was designed to benchmark thermal hydraulic codes for PW;R
steam generators. This program required intimate knowledge of scaling laws and the understanding of instrumentation and data acquisition systems. The results were published in NUREG 1CR-4751 -andare being used (9, 11) to validate computer codes.
Q.5. The above studies appear to be related to- Pressure Water Reactor (PWR) issues, why is this experience applicable to thermal hydraulic issues in a Boiling Water Reactor (BWR)?
A.5. The thermal hydraulic issues are comnmon to many components both in PWRs and BWRs. For example both PWRs and I3WRs use dryers to separate moisture from steam.
Differences in geometry and the operating conditions would require different modeling; nevertheless the concepts of the governing equations are similar. My broad experience in various areas of thermal hydraulics qualifies me as an expert in evaluating thermal hydraulic issues in BWRs.
Q.6 Could you please list the areas where you had hands-on experience with modeling?
A.6 I have hands-on experience with modeling in these areas:
" Transient Boiling,
- Fire propagation,
" Stratified flow,
" Natural Circulation,
" Jet mixing,
" Plenum Mixing,
- Fuel mixing in fuel bundles,
- Cavitation,
0 Water - Molten Metal Interaction,
- Boundary Layer/Shock Interaction, 0 Reentry Heat Transfer, 0 Two Phase pressuie drop in undeveloped pipe flows and
- NOx Emissions from coal fired plants.
Q.7. What materials have you reviewed in preparation for your testimony?
A.7 I have reviewed Entergy and NRC documents, published papers, and certain chapters in two classic textbooks. A list of these references is provided in the Attachment Two, LIST of REFERENCES..
Q.8. What is the purpose of your testimony A.8 My purpose is to discuss why Entergy rationale for seeking exemptions from transient testing is technically unsound. This rationale is essentially based on the following unsubstantiated three propositions:
a) "None of the plant modifications that have been or will be made for the EPU will introduce new thermal-hydraulic phenomena, nor will there be any new system interaction during or as the result of analyzed transients introduced."
b) "There is every reason to anticipate that the transient analysis will accurately predict the plant response to large transient events without need to perform actual tests" c) "The transient analysis for VY are performed using the NRC approved code ODYN" With regard to item (a) above, Entergy provides no substantiation of this assertion. For example the steam dryer has been modified; its structural integrity could be affected by
the EPU. The 20% increase in flow velocity at EPU conditions increases turbulence and vortex shedding frequencies and loads on the dryer.
With regard to item (b), this statement is too general to deserve comment. Entergy must provide a discussion showing why their analysis can be used as a substitute for transient testing; a mere assertion to that effect is simply not acceptable. The public must be provided with the proper documentation to evaluate the risk from forgoing transient testing.
With regard to item (c) Entergy does not state that the ODYN code was bencbmarked for pressurized transients nor does it discuss how the ODYN code was bcnchmarked for steady state operations.
In summary Entergy must provide the public an analysis of the key assumptions, which underlie their assertions that transient tests are not needed.
Q.9. Please explain why it is important to show benchmarking of ODYN.
A.9. Thermal-Hydraulics (T-H) computer codes attempt to represent complex physical processes during various reactor operations.
An example of such a process is two-phase flow that occurs in the reactor core where water is converted to steam. The theoretical basis for describing two-phase flow phenomena is not complete; T-H1 codes must therefore rely heavily on experimental data to reduce uncertainties. As shown in Reference 9, unless the T-1I codes are validated with data from well-instrumented prototype components, the predictions of the codes may result in significant errors in calculating heat transfer parameters. For certain components, knowledge of this uncertainty is critical because otherwise some components may fail, especially under transient conditions.
The need to reduce code uncertainties during transient conditions is well recognized, for example, Peach-lBottom-2 transient experimental data has recently been used to validate best estimate T-H codes (16).
The coolant flow rate under EPU conditions is higher than the flow rate under 100%
power. Since the core void fraction, the power generation rate and the coolant flow rate are interdependent, accurate predictions of void fractions are essential. This ability depends on the two-phase model that a particular code has adopted. Different computer codes use different models (homogeneous, drift flux) having different accuracies. If the ODYN computer code employs inaccurate models, the predicted behavior of the VY reactor during transients will include large uncertainties. For example, closure of the MSIVs, due to operator error or LOCA redirects the flow of steam into the containment suppression pool. The uncertainties in predicting loads under these conditions must be quantified at EPU flow rates.
Q.10 Do you have concerns with regards to a specific component in particular?
A. 10 Yes, the steam dryer. Because of the increase in flow velocity at EPU conditions, steady state temperature and pressure fluctuations will increase the fatigue usage factor of the steam dryer. This increase in fatigue together with the increase in fatigue during transients must be taken into account to show that the cumulative fatigue factor at EPU conditions will remain below A.S.M.E. allowable limits.
A computer code of unknown accuracy, such as the ODYN, can not be used reliably for the above purpose.
Q.11. Please discuss what Entergy should do to demonstrate that the fatigue usage factor of critical components will remain below the relevant A.S.M.E. code limits.
A.1 1. In my opinion Entergy should proceed as follows.
I . Walk around the plant and identify those components that are most susceptible to failure by flow-induced vibrations.
- 2. Identify the parameters (pressure, neutronic response) that can be used to compare plant behavior during MSIVs closure and load rejections to ODYN predictions under VY- EPU conditions.
- 3. Compare ODYN predictions with Peach Bottom data
- 4. If a good agreement is not obtained in 3 above, show that transient tests are not required in spite of the differences between Peach Bottom and VY.
Q.12 Have you previously filed testimony in support of New England Coalition Contention 3?
A.12 Yes, On December 21, 2005, 1 provided testimony in the form of my a declaration supporting New England Coalition Contention 3 and responding to an Entergy Motion for Summary Disposition.
Q.13 Do you now wish to incorporate that testimony in this, your prefiled written testimony?
A. 13 Yes.
Q.14. Please summarize your conclusions?
A.14. I have concluded that Entergy's assertion that there is no need for transient testing is severely wanting.
A lack of demonstrated ability to predict loads on structural components during transients can have a major impact on public health and safety. Entergy's description of the ODYN code is blatantly general; it is impossible to scrutinize generalities.
Acceptance of the Entergy unsubstantiated statements that the transient test is not needed would in essence shut the door to the public for evaluating Entergy analysis.
Q.15. Please state what would you believe the Board should do?
A.115. I believe that the Board should direct the NRC to discontinue Entergy operation above I00% power untilI the issues discussed in A.1I I are satisfactory resolved.
Q.16. Does that conclude your testimony?
A. 17. Yes.
Attachment One: PUBLICATION IN PEER REVIEWED JOURNALS ONLY
- 1. Distributed Fiber Optic Sensors for Leak Detection In Landfills, Proceeding
- ofSP[E Vol 3541 (1998)
- 2. Continuous Automatic Detection of Pipe Wall Thinning, ASME Proceedings of the 9th, International Conference on Offshore Mechanics and Arctic Engineering. Feb. 1990 3 Iodine Speciation and Partitioning in PWR Steam Generators, Nuclear Technology, March 1990
- 4. Comments on "Assessment of Steamn Explosion Induced Containment Failures"' Letter to the Editor, Nuclear Science and Engineering, Vol. 103, Sept. 1989
- 5. Experience and Modeling of Radioactivity Transport Following Steam Generator Tube Rupture, Nuclear Safety, 26,286, 1985
- 6. Simplified Correlations for the Predictions of Nox Emissions from Power Plants. AIAA Journal of Energy, Nov.-Dec., 1979
- 7. Grain Boundary Grooving of Type 304 Stainless Steel in Armco Iron Due to Liquid Sodium Corrosion, Corrosion, 27, No.1 1, 428, 1971
- 8. Corrosion of Type 316 Stainless Steel with Surface Heat Flux in 1200 Flowing Sodium, Nuclear Engineering and Design, 12; 167-169, 1970 9 Prediction of the One Dimensional Cutting Gap in Electrochemical Machining, ASME Transaction, J. of Engineering for Industry, p1 00 (1969)
- 10. Electrochemical Machining- Prediction and Correlation of Process Variables, ASME Transactions, J. of Engineering for Industry, 88:455-461, (1966)
- 11. Laminar Two-Phase Boundary Layers in Subcooled Liquids, J. of Applied Mathematics and Physics (ZAMP), 15,388-399 (1964)
- 12. Onset of Stable Film Boiling and the Foam Limit, International j. of Heat Transfer and Mass Transfer, 6; 987-989 (1963) ) (co-author) 13 Operating Conditions of Bubble Chamber Liquids, The Review of Scientific Instruments, 34, 308-309. (1963); co-author
- 14. Similar Solutions of the Turbulent Free Convention Boundary Layer for an Electrically Conducting Fluid in the Presence of a Magnetic Field, AIAA J. 1:718-719 (1965)
Kit
Attachment Two: LIST OF REFERENCES
- 1. Entergy's Motion for Summary Disposition of New England Coalition Contention
- 3. ASLB-No.04-832-02-OLA
- 2. Nureg-0800, SRP 14.2.1
- 3. VYNP Technical Specification Proposal Change No. 263 Supplement No 3 "Justification for Exception to Large Transient Testing"
- 4. Same Title Docket 50-271, BVY 03-80
- 5. Petlon to Anderson, Regarding Draft Press Release Regarding VY Dryer Cracking. ML052790448 2004-04-16
- 6. Transcript of 512f" ACRS Meeting, May 7, 2004 Rockville, MD ML041470049 2004-05-07
- 7. 2005/03/31 Vermont Yankee TSP Change No-263, Supplement No. 26 "Extended Power Uprate Steam Dryer Analysis and Monitoring ML050960047 - 2005 31
- 9. Yassin A.llassan et.al. "U-Tube Steam Generator Predictions: New Tube Bundle Convective Heat Transfer Correlations NUCLEAR TECHNOLOGY, Vol. 94, June 1991
- 10. Prototypical Steamn Generator ( MB-2) Transient Testing Program, NIJREG/CR-3661
- 11. A Sawyer et. al "RELAP5-3D Validation Study Using MB-2 Prototypical Steam Generator Steady State Data" NUCLE AR TECHNOLOGY Vol. 151 Sep. 2005
- 12. Yoshiro Asahi et. al. Analysis of BWR Turbine Trip Experiment by Entire Plant Simulation with Spatial Kinetics. NUCLEAR SCIENCE AND ENGINEERING, 152 219-235 (2006)
- 13. E. Uspuras et. al. 'RELAPS-3D Code Validation in the Neutron-Dynamic Analysis of Transient Processes Taking Place in RBMK-1500 Reactors. Nuclear Engineering and Design 224 (2003) 2937300
- 14. Hasna. J. Khan. ct. al " Mitigation of Anticipated Transient Without Scram Event in A Simplified Boling Water Reactor By the Insertion of Fine-Motion Control Rods" NUCLEAR TECHNOLOGY, Vol 112 Nov.1995
- 15. EE. Lee and EIN-CHIJN WýU "Term Analysi MAAP 3.013 Analysis of A Severe Anticipate Transient Without Sciram" NUCLEAT TECHNOLOGY, VOL. 100 OCT. 1992
- 16. Lainsu Kao et.al. "Peach Bottom Turbine Trio Simulations with RETRAN Using INERIITC BWR Transient Analysis Method" NUCLEAT TECHNOLOGY Vol.
149, Mar. 2005
- 17. Vermont Yankee Safety Evaluation for Amendment 229 regarding Extended Power Uprate ML060050028
- 18. 1H. Schlichting. Boundary Layer Theory, Fourth Edition, McGraw-Hill Book Co 1 Inc New York, June 1962. (PP.216-228 and 457-472)
- 19. H.W. Liepmann, A. Roshko, Elements of Gasdynamics , John Wiley & Sons, Inc, Fifth Printing, 1963. (Chapter 3)
UNITE D STATE S OF AMERICA NUCLEAR REGULATORY COMMISSION Before the ATOMIC SAFETY AND LICENSING BOARD In the Matter2 of Entergy Nuclear Vermont Yankee, LLC June 14, 2006 and Entergy Nuclear Operations, Inc. (Vermont Yankee DoktN.5271OL Nuclear Power Station) (Technical SpecificationDoktN.527-L Proposed Change No. 362) ASLBP No. 04-832-02-OLA DECLARATION OF DR. JORAM HOPENFELD IN SUPPORT OF NEW ENGLAND COALITION'S RESPONSE TO THlE STATEMENTS OF POSITION OF ENTERGY AND NRC STAFF Dr. Joram Hopenfeld submits the following declaration in support of New England Coalition's Response to the Statements of Position of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc (herein, "Entergy or ENVY") and U.S.
Nuclear Regulatory Commission Staff (herein, "NRC Staff').
At the request of New England Coalition, I have performed a technical assessment of the May 17, 2006 Statements of Position of ENVY and NRC Staff.
Dr. Hopenfeld addresseZs and rebuts key points in the ENVY and NRC Staff Statements of Position while providing a critical discussion of the technical aspects of the proposed exemption from full-transient testing.
Dr. Hopenfeld relies upon ample qualifications as an expert in the pertinent scientific and technical fields and on evidence provided by ENVY and NRC Staff to assess ENVY's proposed exemption from full-transient testing.
A list of the references drawn from ENVY and NRC Staff filings cited by Dr. Hopenfeld in his testimony precedes his Declaration.
References
- 1. New England Coalition's Answer to Entergy's Statement of Material Facts Regarding NEC Contention 3 - Docket No 50-271, ASLB No.04-832 OLA
- 3. Entergy's motion for summary Disposition of New England coalition on 3, December 2, 2005.- Docket No 50-27 1, ASLB No.04-832 OLA
- 4. Entergy's Initial Statement of Position on New England Coalition Contention 3.
May 17, 2006 -Docket No 50-27 1, ASLB No.04-832 OLA
- 5. Testimony of Craig J. Nichols and Jose L. Cassillas on NRC Contention 3- Large Transient Testing, May 17, 2006- Docket No 50-27 1, ASLB No.04-832 OLA
- 6. NRC Staff's Initial Statement of Position Concerning NEC Contention 3 - May 17, 2006- Docket No 50-27 1, ASLB No. 04-83 2 OLA
- 7. NRC Staff Testimony of Richard 13. Ennis, Steven R.Jones, Robert L. Pettits Jr.,
A George Thomas, and Zeynab Abdullahi, Concerning NEC Contention 3 -17, 2006-Docket No 50-27 1, ASLB No.04-832 OL 2
UNITE D STATE S OF AMERICA NUCLEAR REGULATORY COMMISSION Before the ATOMIC SAFETY AND LICENSING BOARD In the Matter of Entergy Nuclear Vermont Yankee, LLC June 14, 2006 and Entergy Nuclear Operations,Inc. (Vermont Yankee Dce o 021-L Nuclear Power Station) (Technical Specification D~e o 021-L Proposed Change No. 362) ASLBP No. 04-832-02-OLA DECLARATION OF DR. JORAM IJOPENFELD IN SUPPORT OF NEW ENGLAND COALITION'S RESPONSE TO THE STATEMENTS OF POSITION OF ENTERGY AND NRC STAFF On behalf of New England Coalition, Dr. Joram Hopenfeld hereby submits the following declaration in support of New England Coalition's Response to the Statements of Position of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc (herein, "Entergy or ENVY") and U.S. Nuclear Regulatory Commission Staff (herein, "NRC Staff').
Q.1. Please state your name and address.
A.1. My name is Dr. Joram Hopenfeld and my business address is 1724 Yale Place, Rockville, MD, 20850.
Q.2. What is your educational and professional background?
A.2. I have received the following degrees in engineering from the University of California at Los Angeles: BS 1960, MS 1962, and PhD 1967.
My major fields were in Fluids Flow, Heat Transfer and Electrochemistry.
I am an expert in the development of thermal hydraulic computer codes and models as they relate to the assessment of nuclear safety issues. I have 45 years of professional experience in the fields of instrumentation, design, project management, and 3
nuclear safety; including 18 years in the employ of the U.S. Nuclear Regulatory Commission.
My resume' has been provided to the Board and to the parties as an attachment to a Declaration Of Dr. J6ram Hopenfeld Suppor-ting New England Coalition's Resnonse To Envy's Motion For Summar Disposition. December 21, 2005.
Q.3. What is the purpose of your declaration?
A.3. At the request of New England Coalition, I have performed a technical assessment of the May 17, 2006 Statements of Position of ENVY and NRC Staff. The purpose of this declaration is to provide a critical discussion of the technical aspects of the statements of position and to provide my conclusions regarding them.
Q.4. Please summarize your findings.
A.4. I have examined the Statements of Position of ENVY and NRC Staff Entergy and have concluded that ENVY's position that the ODYN computer code can be used as a replacement to transient testing is completely void of any technical justification. In my*
professional opinion ENVY should be required to reduce power to original licensed thermal power ("OLTP or 100%") until it can demonstrate by transient testing or by a valid analysis that it is safe to operate the plant at 120% power.
In ENVY's most recent communication, a Statement of Position, May 17,2006, ENVY averred that the ODYN code can predict only the maximum pressure in the reactor vessel and not the stresses of reactor components during transients. (Ref. 5, A 39)
This represents a considerable change from ENVY's December 2, 2005 Motion for Summary Disposition in which they claimed that the ODYN code is capable of predicting plant performance during transients, 4
- 1. The analytical tools used by Entergy will accurately predict plant performance in large transient events under EPU conditions The transient analyses for VY are performed using the NRC-approved code ODYN, which models the behavior of the safety- and non-safety-related systems of the plant during operational events... [Page 5]
In discussing the benchmarking of the ODYN code, ENVY provided no comparison of experimental data with code predictions nor did ENVY describe in sufficient details how the code was qualified.
In discussing industry experience, ENVY referenced several BWR reactors that have undergone transients and for which it claimed that no new phenomenon have been exhibited. However, ENVY has not provided any analysis to indicate why the above results are applicable to the VY plant at the EPU conditions.
ENVY provides no direct justification for using the ODYN code. ENVY seems Q to be saying that the code can predict transient behavior because they say so.
Review of the May 17, 2006 NRC Staff Statement of Position seems to indicate that the NRC basically accepts ENVY's contentions without apparent scrutiny.
The purpose of transient tests is to verify that the performance of a given plant is consistent with its design. Wh~en ENVY seeks to forgo transient testing by using analyses instead, ENVY must demonstrate that the analyses include sufficient details so that it is representative of the actual tests that are being excluded. As part of this requirement, ENVY should provide material that permits the public to quantify the effects of key assumptions. ENVY has not done so.
Q.5. Please provide a discussion of your review of ENVY and NRC Statements of Position and your findings with respect to the issues raised in NEC Contention 3.
5
A.5. In previous communications to the ASLB (references 1, 2) NEC stated that Vermont Yankee, VY, should not be allowed to operate at the 120% of OLTP without a complete revalidation of the plant ability through analysis, and both individual component and full transient testing to operate at these power levels. Entergy Nuclear Vermont Yankee -
(ENVY) claimed (3, 4, 5) that full transient testing is not required largely because the ODYN computer code is capable of predicting plant behavior during transients.
Since ENVY did not discuss benchmarking, I have raised the question (reference]I) of how the ODYN code was benchmarked (or not) for the type of transients that ENVY claimed to have analyzed for the EPU.
In a reply to the board regarding this issue, ENVY and the NRC stated (4, 5, 6) that the ODYN code was benchmarked against Peach Bottom and other transient data.
Neither ENVY nor the NRC provided a comparison between ODYN predictions and experimental data. Both the ENVY and the NRC state that ODYN provide conservative predictions. Review of ENVY's latest submittals (4 and 5) reveals some new information regarding ODYN, which is discussed below.
In Reference 3 ENVY stated that the ODYN code would accurately predict plant performance during large transients under EPU conditions.
.From the latest ENVY submittals, we are now discovering (Ref. 5, A 39) that the ODYN code was used only to predict the peak pressure rather than stresses on various components during transients.
It is not clear to me why ENVY is referring to "plant performance" while the ODYN code is capable of predicting only the maximum pressure. On page 5 of Reference 3, ENVY stated:
6
I. The analytical tools used by Entergy will accurately predict plant performance in large transient events under EPU conditions.
The transient analyses for VY are performed using NRC- approved code ODYN, which models the behavior of the safety-and non-safety-related systems of the plant during operational events.
Since ENVY did not define "plant performance"~ one can reasonably assume that "plant performance" refers the performance of structures, systems and components as defined in Appendix B to 10 C.F.R. Part 50 for exemptions from transient testing.
A test program shall be established to assure that all testing required to demonstrate that structures, systems, and components ("SSCs") will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The test program shall include, as appropriate, proof tests prior to installation, preoperational tests, and operational tests during nuclear power plant or fuel reprocessing plant operation, of structures, systems, and components. Test procedures shall include provisions for assuring that all prerequisites for the given test have been met, that adequate test instrumentation is available and used, and that the test is performed under suitable environmental conditions. Test results shall be documented and evaluated to assure that test requirements have been satisfied.
If ODYN were able to predict system performance during transient then its output would have been consistent with the requirements for exemptions from transient testing.
However, since ODYN can potentially predict only the maximum pressure its output is not consistent with Appendix B to 10 C.F.R. Part 50. Since plant safety depends on the structural integrity of key vessel components the integrity of these components must be addressed as part of system performance. The applied structural stresses and the allowable stresses, would ultimately determine whether a given component would perform satisfactorily in service. Knowledge of the maximum pressure alone is not a sufficient to assure system performnance. The frequency and amplitude of the vibrations as well as the component's natural frequency, which is affected by 7
temperature and temperature gradients, for example, govern failure of components from vibrations.
With the newly provided -understanding that ODYN can predict only maximum pressure, ENVY must in addition to describing the benchmarking of ODYN address the issues of how the stresses of SSC were calculated during transient in order to assure compliance with Appendix B3 1 CFR Part 50. These two issues are further discussed below.
- a. Peak pressure during transients According to ENVY the ODYN code is a one-dimensional code.
This characterization of the ODYN code is confirmed in the NRC Staff Statement of Position at Page 11, As part of its justification for not performing large transient testing, Entergy
~ stated that the MSIV closure pressurization transient analysis (that bounds the load reject without bypass pressurization event) had been performed at Vermont Yankee for the EPU conditions using the ODYN code. The results of this analysis showed the response of the plant to this bounding transient to be acceptable. Id. at 18. The One Dimensional DYNamic Core Transient model
("ODYN") code has been qualified by comparing its predicted response to actual data.Id. at 18-20. [NVRC Staffr Testimony NRC Staff Testimony Of Richard B.
Ennis, Steven R?.Jones, Robert L Pettis Jr., George Thomas, And Zeynab Abdullahi Concerning NIEC Contention 3, May 17. 2006]
Such codes incorporate certain simplifications that describe transient behavior therefore; their validity is limited to the cases where the code was benclimarked. For this reason, I disagree with ENVY and the NRC that the observation that the code is conservative or that it over predicts pressure also means that the code is suitable to predict all transients.
It is important to understand that a code can predict certain quantities very accurately under a certain set of boundary conditions yet it will be very inaccurate in 8
predicting the same parameters under different boundary conditions. It is not the amount of conservatism that is important, it the understanding of the reasons for the discrepancy between the experimental data and code predictions. Neither Envy nor the NRC discusses the specific Peach Bottom test data that was compared to ODYN predictions nor do they explain why the predicted peak pressure exceeded the experimental data.
Perhaps the lack of transparency on part of ENVY and the NRC is due to the fact that some data may be proprietary. If that is the case, it is my opinion that ENVY and the NRC should not be allowed to hide behind a veil of "proprietary information" instead of being required to present a straightforward comparison of the experimental data with ODYN predictions.
We need not review nor need we be interested in the specific mathematical techniques or proprietary data. Instead, it would serve the record to be able to determine from information that ENVY should be supplying, for example, how accurately ODYN can predict the core exit pressure rise and pressure oscillations, and water levels during the turbine trip tests at Peach Bottom It would also be appropriate to be able to determine from information provided by ENVY the basic assumptions regarding the coupling between neutronics and thermal hydraulic and the flow through the moisture separator.
Such information is essential in assessing the ability of the code to provide meaningful information for different transients and boundary conditions.
The board should require that ENVY list and make public all key assumptions and models that were used in ODYN. ENVY should also compare key VY plant 9
parameters such as flow velocities vs the parameters that were used to benchmark ODYN.
- b. Loads on key components during transients Transients can introduce large stresses on vessel components due to induced vibration. The EPU involves an increase of 20% in the flow velocity; this change in velocity increases the potential for flow-induced vibration both under steady state and transient conditions.
When during a transient, the frequency of the induced vibrations is close to the natural frequency of a component, that component can fail catastrophically.
This is the reason why key components such as the dryer must undergo an integrity assessment to assure that the applied stresses remain within the design limits.
Q.6. Please provide any additional, specific comments on ENVY's Statement of Position to which you wish to draw the Board's attention.
A.6. Referenced by page number and topic, Iprovide the following few specific comments:
- a. Page 5 - Expertise ENVY stated that unlike Mr. Nicholas, BSEE and Mr. Casillas, BSME, Dr. Hopenfeld has no expertise in the issues that were raised by Contention 3 because he has no operational experience at VY with large transients and other BWR plants.
Reply Since ENVY relies on the ODYN code as a replacement to transient testing, the main expertise that is required in this regard is an in depth knowledge of thermal 10
hydraulic (T-11) modeling and code verification. Dr. Hopenfeld has experience and knowledge in this area.
Scientists who are familiar with the various T-H theories and numerical schemes write T-1H codes. Experience with transients at VY, or other BWR plants, does not appear to be a prerequisite for the development of T-H codes. Very few if any, of the code developers have been project managers at nuclear facilities also the field of thermal hydraulics is not subdivided into PWR or BWR branches.
Although Dr. Ilopenfeld has not been working at VY, he has published in peer reviewed journals several papers on complex problems in T-1H and material coolant interaction, his experience include, Hand on modeling T-H phenomena and testing o two phase flow in channels,
" transient boiling,
" fire behaviour and propagation.
o Radioactivity transport following SG tube rupture o Steam Explosions
" A US representative to an International Conference on Cavitation,
" Project Manager for the development of major (T-H) computer codes such as COBRA.
" Project Manage for a major international program on transient testing of prototypical steamn generators (MB-2).
" Supervised the use of the RELAP code for the calculations of temperatures during PW~R transients.
I1I
The above background qualifies Dr. Hopenfeld to address the issues, which relate to the assessment of the ODYN code as a substitute for transient testing.
In contrast, Mr. Nicholas and Mr. Casillas have not demonstrated in depth knowledge of T-11 by any publication in the open literature. Their resumes give no indication that they have been involved in code development or code verifications. Mr.
Nicholas does not even appear to have any significant educational background in T-H since his degree is in electrical engineering.
It may be that Mr. Nichols and Mr. Casillas have some experience with T-H analysis but the level and complexity of that experience is not specified. Mr. Nichols' and Mr. Casillas' resumes do not reflect an in-depth knowledge of T-H modeling development or testing. T-H computer codes validation is a complex task. Mr. Nichols' and Mr. Casillas' training and discipline do not appear to meet professional standards for assessing T-11 computer codes.
- b. Page 8 - Generalities Item 8 ENVY states that, ODYN code has been benchmiarked against all significant plant transients including turbine trip (equivalent in its effects to generator load rejection test) and MSIV closure events.
The turbine data were obtained from Peach Bottom and KKM and the MSIV data were obtained from the Hatch plant Item 9 ENVY states, 12
The results of the ODYN's bench mark assessment demonstrate the ability of the code to accurately predict plant performance during transients The current version of the ODYN code continues to accurately predict the over power magnitude and slightly over predict the overpressure magnitude.
Item 10 Envy states.
..t is reasonable to assume the ODYN code of VY behavior during large transients at I3PU operations accurately predict the actual plant response to those transients because the ODYN model is qualified for the analysis of this type of a transient.
Reply The above information is too general as to be of any use in evaluating ]ENVY's analysis or determining if ENVY is qualified exemption to the requirement for transient testing.
It is my professional opinion that, at a minimum, Energy should be required to plot the measured plant parameters such as pressure and flow velocities vs. code predictions and explain the reasons for any differences between code predictions and experimental data.
ENVY should be required to explain in detail how the code was qualified for transients under EPU conditions.
- c. Pages 9 -10, Items 12-32 - Industry Experience ENVY discusses several I3WR reactors, Hatch 1&2, Brunswick 2, Dresden 3 and KKL where transient have occurred at various power level and the ODYN code was used to compare system performance. Since it is claimed that no new related phenomena were observed at these plants, ENVY concluded without analyses that the same results would be obtained at VY.
Reply 13
System performance can only be predicted by considering the stresses on key reactor components during the transients.
To make a valid comparison between the above reactor experience and what is expected to occur at VY under transient conditions, ENVY must show by actual analysis, including stresses on key components, that the above reactor experience is sufficient relevant to forgo transient testing.
If ENVY chooses to use statistical consideration alone, (which apparently appeared to be their approach) to conclude that based on reactor experience one can eliminate transient testing than ENVY should elaborate on the validity of their statistical sampling.
Q.7. Please provide any additional, specific comments on NRC Staff's Statement of Position to which you wish to draw the Board's attention.
A.7. NRC Staff's position regarding the use of ODYN and its benchmarking can be summarized by referring to pages I1I and 12 of Reference 6.
Page 11I As part of its justification for not performing large transient testing, Entergy stated that the MS1V closure pressurization transient analysis (that bounds the load reject without bypass pressurization event) had been performed at Vermont Yankee for the EPU conditions using the ODYN code.
The results of this analysis showed the response of the plant to this bounding transient to be acceptable. Id. at 18. The One Dimensional Dynamic Core Transient model ("ODYN") code has been qualified by comparing its predicted response to actual data. Id. at 18-20.
Page 12 The facts show that the ODYN code has been properly benchmarked for modeling EPU operations and is appropriate for use in demonstrating reasonable assurance that SSCs will perform satisfactorily in service.
Reply 14
There is nothing that links even remotely the NRC conclusions on page 12 with thie discussion of Reference 7 a on pages-18-20.
First, the NRC has not reviewed the benchmarking of ODYN for the Hatch and the KKL plants.-
Secondly, The staff has not demonstrated the comparison of ODYN with Peach Bottom and with RELAP-3B data.
From the discussion provided by the NRC one must conclude that the NRC evaluation was limited to the ability of the ODYN code to predict general system performance, like maximum system pressure for example. NRC is silent about the ability of ODYN to such parameters which are required to asses stresses and integrity of SSCs.
during transients.
As already discussed above, overall predictions of system performance is not sufficient to assure that SSCs will perform satisfactory one must ensure that the applied stresses do not exceed allowables. The purpose of transient testing is to do just that:
provide confirmation that the system will perform as designed.
When one seeks to substitute actual integral testing with analytical tools he must use analytical tools that can predict those parameters that are relevant to the stress of the SSSc. Pressure, temperature and flow variations with time are required for such analyses.
NRC has not demonstrated (and therefore it is only speculating) that that the ODYN code has properly been benchinarked to ensure that the " SSCs will perform satisfactory in service" and comply with Appendix B to 10 C.F.R.. Part 50.
Q.8. Hlave you anything further?
A.8 I offer the following conclusion:
K-I 15
Based upon my examination and professional assessment of the ENVY and NRC Staff Statements of Position, I conclude that ENVY has yet to provide technically defensible justification for avoiding full transient testing; and that the sum total of information to be gained from consideration of ENVY's proposed computer code-(s),
individual component testing, and very limited applicable industry experience is insufficient to displace the information to be gained from full transient testing.
Therefore, it remains my professional opinion that adequate assurance of public health safety cannot be determined from the license application in this case.
Nothing in the ENVY and NRC Staff Statements of Position has altered my professional opinion that Atomic Safety and Licensing Board should examine the issue of full transient testing (per NEC Contention 3) in the context of a full hearing before making a final decision on the Vermont Yankee EPU application.
I declare under penalty of perjury that the foregoing is true and correct.
Executed this day, June 12, 2006, at Rockville, Maryland.
K-pM 16
1511 1 CHAIR KARLIN: Dr. Hopenfeld, good 2 morning, we are going to ask you some questions.
3 WITNESS HOPENFELD: Good morning.
4 CHAIR KARLIN: And if there is a question 5 which is unclear, you don' t. understand, please let us 6 know and we will try to rephrase it or speak more 7 clearly.
8 If there is a point where you need a break 9 let us know that as well.
10 WITNESS HOPENFELD: Thank you.
11 CHAIR KARLIN: And, again, if there is an 12 exhibit that you think would help your testimony by 13 referring to it, please let us know, or access that 14 exhibit, so that would focus your testimony and our 15 understanding of this matter.
16 We ask, if we ask for your opinion, that 17 is fine. But otherwise we are looking for what you 18 can testify to, factually. We understand you are a 19 PHD, so we would appreciate your testimony.
20 And, with that, I turn it over to my 21 colleagues for asking you some questions.
22 ADMINISTRATIVE JUDGE RUBENSTEIN: Good 23 morning, Dr. Hopenfeld. In your May 17th testimony 24 you focused on three areas where you felt concern that 25 inadequate analysis had not been done.
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1512 1 You focused on new thermal hydraulic 2 phenomena, transient analysis, and its accurate 3 prediction of plant response to large transient 4 events, and transient analysis for Vermont -Yankee 5 using the code ODYN.
6 CHAIR KARLIN: Please speak up, Dr.
7 Hopenfeld, we --
8 WITNESS HOPENFELD: I'm sorry, can you 9 hear me now better?
10 CHAIR KARLIN: Yes.
11 ADMINISTRATIVE JUDGE RUBENSTEIN: Yes. In 12 establishing the basis for the contention Mr.
13 Gunderson also cited a number of other items. Are we 14 going to discuss those items, or should we stick to 15 the three items that you preferred in your testimony?
16 WITNESS HOPENFELD: Three items are fine, 17 but I don't quite understand which other items you are 18 referring to.
19 ADMINISTRATIVE JUDGE RUBENSTEIN: Well, he 20 had four items.
21 WITNESS HOPENFELD: Who had, I'm sorry?
22 ADMINISTRATIVE JUDGE RUBENSTEIN: Mr.
23 Gunderson. But, okay, we will stick to yours.
24 WITNESS HOPENFELD: Who had four items?
25 ADMINISTRATIVE JUDGE RUBENSTEIN: Mr.
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1513 1 Gunderson, in the original proffering of the 2 contention for admission.
3 WITNESS HOPENFELD: I'm not familiar with 4 that. Oh, I see what you are saying. No, I'm not, I 5 skimmed through them, but I'm not familiar with them.
6 ADMINISTRATIVE JUDGE RUBENSTEIN: I won't 7 question you on those items.
8 WITNESS HOPENFELD: Please do not, I'm not 9 prepared to talk about that.
10 ADMINISTRATIVE JUDGE RUBENSTEIN: Of the 11 three items, let me first address thermal hydraulic 12 phenomena. We've heard testimony, yesterday, and 13 perhaps today also, on the alleged thermal hydraulic 14 phenomena which might take place during one of the two 15 transients. Do you have any observational basis for 16 your concern for new thermal hydraulic phenomena? Can 17 you cite a plant where this was observed?
18 DR. HOPENFELD: I cannot cite the plant 19 that this has been observed, but I can cite my 20 reasoning for why - -
21 ADMINISTRATIVE JUDGE RUBENSTEIN: No, 22 please. We'll get to that.
23 DR. HOPENFELD: Okay.
- 24 ADMINISTRATIVE JUDGE RUBENSTEIN: And we
- -*.25 have read your testimony in that regard.
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1514 1 DR. HOPENFELD: Yes.
2 ADMINISTRATIVE JUDGE RUBENSTEIN: And I 3 feel fully satisfied. Perhaps one of the other Judges 4
5 DR. HOPENFELD: The answer is no. I 6 cannot cite a plant where this has been observed.
7 ADMINISTRATIVE JUDGE RUBENSTEIN: Are you 8 aware of any calculations which would support your 9 concern, specific calculations from thermal hydraulic 10 or mass loads?
11 DR. HOPENFELD: Not calculations, but 12 general observations, yes.
13 ADMINISTRATIVE JUDGE RUBENSTEIN: No --
14 DR. HOPENFELD: No calculations.
15 ADMINISTRATIVE JUDGE RUBENSTEIN: By 16 observations you mean --
17 DR. HOPENFELD: General, from the physics of the problem.
19 ADMINISTRATIVE JUDGE RUBENSTEIN: Not in 20 a specific sense?
21 DR. HOPENFELD: Correct.
22 ADMINISTRATIVE JUDGE RUBENSTEIN: And in 23 any plants? Remember I asked Entergy specifically 24 based on the instrumentation in their plant or in all 25 the other plants anywhere were any of the phenomena NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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1515 observed.
K) 2 And that's what I was getting at. Do you 3 have any knowledge of any abnormal thermal-hydraulic 4 phenomena which would have compromised the limiting 5 conditions for operations or the other safety limits 6 for the plants?
7 DR. HOPENFELiD: There's a potential for 8 it. I don't have a knowledge that it had happened.
9 This is a new situation.
10 ADMINISTRATIVE JUDGE RUBENSTEIN: So what 11 we have before us is your hypothesis, and -- but 12 you're not offering any experimental or calculation in 13 support?
K) 14 DR. HOPENFELaD: I did not do experimental 15 or calculation.
16 ADMINISTRATIVE JUDGE RUBENSTEIN: I think 17 I'm going to move on to the steam dryer structural 18 integrity question. And you asserted that the steam 19 dryer structural integrity could be affected by the 20 EPU because of the increased flow velocity at EPU 21 conditions, increased turbulence, and vortex shedding 22 frequency and loads on the dryer.
23 DR. HOPENFELD: Correct.
24 ADMINISTRATIVE JUDGE RUBENSTEIN: You 25 think -- is this a stead state concern?
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1516 I DR. HOPENFELD: Correct. That's a steady 2 state and a transient concern, both.
3 ADMINISTRATIVE JUDGE RUBENSTEIN: And what 4 is the transient concern?
DR. HOPENFELD: okay. The steady state 6 concern is --
7 ADMINISTRATIVE JUDGE RUBENSTEIN: No, the 8 transient concern. I understand the steady state 9 concern.
10 DR. HOPENFELaD: I want to give the base.
11 The steady state -- the transient concern that you 12 would excite resonance vibrations of high amplitude 13 through this very, very short period of time, which if 14 the component's already weakened, they have used up 15 their fatigue cycle, they already at their endurance 16 limit or there was stress corrosion and the components 17 are cracked already, that resonant vibration would 18 cause potential problem or it would not fulfill the 19 requirement that SSSCs are -- meet their design 20 requirement.
21 ADMINISTRATIVE JUDGE RUBENSTEIN: Is this 22 based on your experience and expert opinion?
23 DR. HOPENFELD: Yes, it is.
- 24 ADMINISTRATIVE JUDGE RUBENSTEIN: But is
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1517 1 these have been exacerbated or these occurred?
2 DR. HOPENFELD: There is evidence that 3 oscillation that could excite resonant vibration exist 4 during the transient, yes.
5 ADMINISTRATIVE JUDGE RUBENSTEIN: Okay.
6 The operative word being could.
7 DR. HOPENFELD: If you ask me whether 8 actual vibrations were there, I don't know. And EPU 9 I don't know who measured that.
10 ADMINISTRATIVE JUDGE RUBENSTEIN: Now on 11 the value of doing a large transient test, you 12 *included in your testimony an excerpt from the 13 advisory committee on reactor safety, Mr. Seibert, and 14 I'm going to ask you at the end, I'll read it first, 15 if you adopt this as part of your own understanding of 16 the phenomena.
17 Mr. Seibert's comment on hangers and 18 stubbers strikes home in as much as while Entergy 19 Nuclear's Vermont Yankee is running at 120 percent of 20 original thermal license power without benefit of full 21 transient testing.
22 And you go on a little bit in this area.
23 And what he says is that the value of the test would 24 be not to challenge the reactor control system because 25 the reactor control system is often challenged and in NEAL R. GROSS
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1518 1 all cases it's been shown to perform, in other words 2 the plant scrams, the pressure relief valves are --
3 can be opened.
.4 While the spring safety relief valves have 5 not been challenged it is likely they-would perform.
6 So he says the value would be to walk down the plant 7 after the transient and see if there had been any structural response damage to the balance of the plant.
10 He basically says there's no concern for 11 the reactor cooling system and the only potential 12 concern would be a little mechanical response damage.
13 Is -- how do you deal with that in adopting his 14 information from the ACRS?
15 DR. HOPENFELD: Okay. I do not agree that 16 that'Is the only consideration. I think there is 17 another consideration, and that has to do with the 18 ability of the ODYN code to predict the decreasing 19 margins that the EPU provides.
20 By increasing the power you decrease the 21 margins to our safety. And that --
22 ADMINISTRATIVE JUDGE RUBENSTEIN: So --
23 DR. HOPENFELD: -- has to be predicted and 24 you have to have a code to do that.
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1519 1 going to get into ODYN's capabilities.
2 DR. HOPENFELD: Well you asked me, I just 3 gave you an answer to your question.
4 ADMINISTRATIVE JUDGE RUBENSTEIN: You 5 knocked me a little off track. So if one stays on 6 that, we have three components of the value of the 7 test. One would be to determine structural damage.
8 The second component would be to determine 9 if the reactor control systems continue to work. And 10 the third component would be a holistic integral 11 thing, did everything work as planned.
12 In doing the test, one comes now to the 13 ODYN code, and you have some concerns with the code's 14 capability to calculate.
15 How do you contrast with the testimony of 16 Entergy and the Staff where they say they relied very 17 lightly, if at all, on the ODYN code., but they look --
18 we just had testimony that the cogent factors are the 19 three parameters we just. discussed, SRV capacity, 20 power density, and free water flow capacity.
21 So what role do you see the ODYN code in 22 the licensing decision basis? And we'll get to the 23 deficiencies, or -- that you point out for the code, 24 and I'll let -- be happy to let Judge Baratta explore 25 those areas.
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1520 1 DR. HOPENFELD: First of all you quoted 2 three items. I would like to add another one. And 3 that is observations, not just of general damage, but 4 during the transient.
5 There may be no damage, but during the 6 transient you may experience violent resonance 7 vibrations. Now there is experience in power plants, 8 but this reactor, but there has been experience.
9 And it's not in evidence, but it has been 10 experienced that during an event it's possible and it 11 happens that you can get into a resonant situation 12 where you have violent vibrations.
13 And that's what is the fourth option. And 14 again, if you had a plant that is brand new, and we 15 all know it doesn't experience any stress corrosion, 16 it doesn't experience any flowing use vibrations, well 17 then I don't think, you know, it's throughout it's 18 life, throughout the design life, these phenomena are 19 not going to be there.
20 Each component will be just perfect just 21 the way it was put in, then I don't care about -- that 22 much about the vibration.
23 ADMINISTRATIVE JUDGE RUBENSTEIN: And the 24 valve observation, did that --
25 DR. HOPENFELD: I'm sorry.
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1521 1 ADMINISTRATIVE JUDGE RUBENSTEIN: Was the 2 valve back oscillations, were they specific to any 3 component --
4 DR. HOPENFELD: That, which valve?-
5 ADMINISTRATIVE JUDGE RUBENSTEIN: -- or 6 was damage, specific damage observed on a given 7 component?
8 DR. HOPENFELD: In which one are you 9 talking about?
10 ADMINISTRATIVE JUDGE RUBENSTEIN: The 11 valve back that you just cited.
12 DR. HOPENFELD: I didn't say valve back.
13 I said there is -- generally there have been 14 observations in power plants where during an event, 15 and it has nothing to do with BWRs even, where during 16 the accident, during the event the plant had 17 experienced very severe vibrations.
18 ADMINISTRATIVE JUDGE RUBENSTEIN: okay.
19 Give me a second to look at your testimony a minute.
20 I think I'mI done. Judge Baratta, Judge Karlin?
21 Whoever.
22 CHAIR KARLIN: Well, just a couple of 23 questions, Dr. Hopenfeld. Yesterday we asked some 24 questions of the Staff and of the Entergy witnesses.
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1522 1 for you. There is this thing called a 2 MSIV test, closure test. And then there's also 3 something called an MSIV unplanned transient.
4 DR. HOPENFELD: Yes.
5 CHAIR KARLIN: And during an unplanned 6 transient, as I understand it, the reactor, the 7 company will gather data about what happened during 8 that unplanned transient --
DR. HOPENFELjD: Yes.
10 CHAIR KARLIN: -- afterwards, and they 11 will study it and they will assess whether things went 12 according to H-oyle and that sort of thing. So in an 13 unplanned transient, MSIV closure, there's data 14 gathered.
15 DR. HOPENFELD: Yes.*
16 CHAIR KARLIN: Now you're asking, and NEC 17 is asking that a transient test be performed --
18 DR. HOPENFELD: Yes.
19 CHAIR KARLIN: -- a MSIV closure test be 20 performed. And my question is was there any 21 additional data gathered when you do a test planned 22 versus what you would gather in a unplanned event?
23 MR. SHADIS: I think I would like to 24 answer, if I may, in two parts of your question. If 25 I understand it correctly, one question is why do the NEAL R. GROSS COURT REPOqTERS AND TRANSC8iIS2RS 1323 RHODE ISLAND AVE., N.W.
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1523 test? We know that somewhere down the line there's 2 going to be an event.
3 And we're going to get data. And then 4 we're going to take-that data and we're going to see 5 what our -- go to our toolbox and see whether this 6 computer, this computer works.
7 Well I spent some time at sea, and we 8 would once a week or whatever, go and lower the 9 lifeboats just to make sure they work. Now each time 10 you lower a lifeboat you will, you know, you stress 11 the cables a little bit, not much, but you stress 12 them.
13 I never heard a captain say well look,
'4/ 14 let's not do that, let's not do this thing. When 15 there's going to be a fire aboard we're going to get 16 those boats down anyway.
17 Now I realize, sir, that knowledges are 18 very, very dangerous in this environment, and I'm not 19 good at them. My point is if the issue -- and that is 20 the question, if it's a trade off, if the issue is of 21 sufficient importance, if there is a safety concern, 22 then the answer is I'm not going to wait to some 23 unspecified event which I haven't defined.
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1524 1 case, this experience that we have, that doesn't K) 2 justify us to wait for an event to happen and then go 3 and get the data and say well, go in our toolbox and 4 say well everything's okay. Now that's -- sorry.
5 CHAIR KARLIN: Okay.
6 DR. HOPENFELD: It's only part to your 7 question. The other part of your question, just 8 refresh my memory, I appreciate it.
9 CHAIR KARLIN: Well my question would 10 focus on this. Is there any additional data gathered 11 when a planned test is performed versus an unplanned 12 transient, and if so what additional data is gathered 13 in a planned test?
14 DR. HOPENFELD: It depends on the 15 instrumentation. , otherwise with the present 16 instrumentation, you're really limited what you can 17 measure, you can measure power, you can measure level, 18 you can measure pressure, and I think now they've 19 installed some transducers in the steam line and some 20 might have been somewhere else.
21 Basically that's what you have. And I 22 would say to answer your question, would be no, you 23 probably get the same information. The question 24 really is the severity of the event.
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1525 1 a very mild event you're not going to get anything 2 anyway.
3 CHAIR KARLIN: Okay. Let me ask -- focus 4 on.-this question. We heard testimony from Entergy and 5 the Staff that one reason -- why shouldn't we do this 6 test? Well, one of the answers is it will be an 7 undesirable transient cycle. Can you tell me what 8 that is?
9 DR. HOPENFELD: Well, obviously I mean I 10 can see their concern, and I would be -- I equally 11 would concerned. It's a question of trade off. What 12 are you trading off?
13 It's better not to run a test, if I had my 14 choice, but the concern is we have introduced 15 something new. As you said before we don't have many 16 -- a lot of experience with MSIV events at EPIJ level.
17 We have very little if any. And I hope I 18 can get -- give me the opportunity to talk about that 19 too. But the answer is, to this, it's better not to 20 perform it, but given the situation we are -- we have 21 it in front us, what's before the bar here, you should 22 perform, definitely.
23 CHAIR KARLIN: What is the risk of not 24 performing the test?
25 DR. HOPENFELD: I think I would -- can I NEAL R. GROSS
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1526 give you a little bit lengthy answer to this?
2 CHAIR KARLIN: Well, keep it as short as 3 possible.
4 DR. HOPENFELD: Okay. Let me say it 5 short. It can be done. The -- we rely to a large 6 degree on a computer -- on computer codes. We can 7 measure very few things.
8 We don't have x-rays to tell us what the 9 thermal hydraulics doing in those channels. We don't 10 know what it is. We calculate it. So now we have 11 done something to the plant which reduces the margin 12 of safety.
13 It maybe reduces very, very little, maybe 14 itsy-bitsy, but it may reduce more. And the only tool 15 *we have is some kind of a computer code that will tell 16 us that. And that would be the value of running the 17 test.
18 CHAIR KARLIN: I'm sorry. The value of 19 running the test is?
20 DR. HOPENFELD: The value of running the 21 test, and maybe I would consult my notes, one, it 22 would be the --
23 CHAIR KARLIN: To validate the computer --
24 DR. HOPENFELD: One --
25 CHAIR KARLIN: -- model and to test the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1527 1 system as a whole against unexpected phenomena?
2 DR. HOPENFELD: Let me just list those 3 because I would like to be -- one would be to meet 4 regulations. The regulations is one.
5 CHAIR KARLIN: Okay.
6 DR. HOPENFELD: The 10-CFR Part 50, 7 Appendix B, going by memory, I think it's criteria --
8 CHAIR KARLIN: Are you referring to a 9 document that's in an exhibit?
10 DR. HOPENFELD: No, I'm referring to 11 10CFR, Part 50, criteria 19, which you have mentioned 12 this morning.
13 CHAIR KARLIN: Criteria in 11, you mean?
14 DR. HOPENFELD: Yes, 11, correct.
15 CHAIR KARLIN: Yes, okay.
16 DR. HOPENFELD: That's what -- and this is 17 not in order of importance. Two, to validate the 18 computer code, the ODYN computer code, because we 19 rely, that's what we're using.
20 This is the bread and butter. Each time 21 you go to a reload you use this.
22 CHAIR KARLIN: Right.
23 DR. HOPENFELD: So this is what we have.
24 Now if we for some reason had really good 25 instrumentation and we knew what happens in all these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1528 1 channels, I don't think you would have to do that 2 because --
3 CHAIR KARLIN: Okay.
4 DR. HOPENFELD: -- you may have a.-notice 5 in advance. You want to. verify that the maximum 6 pressure does not exceed 1,230 because that was the 7 original criteria.
8 CHAIR KARLIN: Okay.
9 DR. HOPENFELD: You want to determine 10 whether transients can initiate severe component 11 vibration. You're not going to -- I'm not interested 12 in putting strain gauges, acoustics, or everything to 13 see whether I'm getting any cracking.
14 I'd just like to know whether the 15 transient induces vibration, resonance vibration in 16 the pipes, in the hangers, --
17 CHAIR KARLIN: Okay.
18 DR. HOPENFELD: -- all that.
19 CHAIR KARLIN: Got you.
20 DR. HOPENFELD: And the fifth one is what 21 was discussed here yesterday, and that is general 22 component functionality, and that is, is my actuator 23 working, I believe that that, by itself would not be 24 a justification for the test.
25 I mean, I'm sure that you have tested the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS-' -'-
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1529 1 control rods, you have confidence, I hope you do. So 2 that would not be the justification. Actuations, 3 sensors, hard to operate, it is not the 4 justifications.
5 But ODYN code is the problem here.
6 CHAIR KARLIN: Could you give us a bit of 7 your reasoning about the thermal hydraulic of why you 8 were concerned about that?
9 WITNESS HOPENFELD: Okay.
10 CHAIR KARLIN: I know you don'It have 11 observational or experimental data.
12 WITNESS HOPENFELD: Correct.
13 CHAIR KARLIN: I didn't ask, but what is 14 your reasoning?
15 WITNESS HOPENFELD: Okay, that is good, 16 thank you very much for the --
17 CHAIR KARLIN: Sure, sure.
18 WITNESS HOPENFELD: In order to get the 19 EPU, what was done, the number of maximum power, 20 bundles, has been increased. Also the averaGe power 21 has been increased.
22 What that did, it increased the void 23 fraction that you operate with. I don't know by how 24 much. The bottom line is that it decreased the margin 25 towards getting into transition boiling during the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS -- ~ ~
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1530 1 transient.
2 It decreased that. And that is what you 3 want to avoid. You don't want to get into transition 4 boiling, no matter what you, the trickle power ratio, 5 that is what- is of main concern, and that is part of 6 the thermal design basis.
7 You have to assure yourself that no more 8 than .1 percent, or whatever, I don't remember, I 9 think it is .1 percent, a number of pins get into that 10 transition boiling.
11 Now, you have done something. And, again, 12 please I cannot quantify it, I haven't seen it, hardly 13 anybody has. These are all calculations. So you have 14 done something that here we are operating today. And 15 by going to EPU you went a little-bit away from the 16 safety.
17 Now, if you had gone the other way you 18 wouldn't need the test. But they haven't shown that.
19 CHAIR KARLIN: All right. Are you 20 familiar with the standard review plan 14.2.1 that the 21 Staff uses to review these requests for justification 22 to not have to do the test?
23 WITNESS HOPENFELD: I reviewed it, I 24 honestly don't have that standard review plan in front 25 of me.
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1531 1 CHAIR KARLIN: okay, well. one of the 2 factors in that is factor E, margin reduction and 3 safety analysis results for anticipated operational 4 occurrences. Do you know whether Entergy discussed
..5 that in its request for this?
6 WITNESS HOPENFELD: okay. The SER, the 7 answer is yes but not in the context of the large 8 transient test. It was discussed in the context of 9 the reactivity coefficient.
10 CHAIR KARLIN: Okay.
11 WITNESS HOPENFELD: And the question came 12 up because of that issue. Also it was a little more 13 complicated, it had to do with the void of the bypass, 14 too.
15 But the -question came up, and 16 surprisingly, it didn't come up in the context of 17 testing, of the MSIV and the turbine trip testing. It 18 came up in an entirely different section part of the 19 SER.
20 CHAIR KARLIN: Okay.
21 WITNESS HOPENFELD: Different people 22 probably.
23 CHAIR KARLIN: Thank you.
24 ADMINISTRATIVE JUDGE BARATTA: I think 25 what we have learned from the Staff is that they Qo) NEAL R. GROSS
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1532 1 appear to have placed less emphasis on the computer K)2 results than on past experience. And I do understand 3 what you are saying about getting closer to CHF and 4 boiling, and such.
5 However, looking at exhibit 38, which is 6 that chart that compares Vermont Yankee to Brunswick -
7-8 CHAIR KARLIN: Mr. Shadis, do you have 9 that exhibit, can we give Dr. Hopenfeld -- Ms.
10 Carpentier, do you have that?
11 WITNESS HOPENFELD: If you could just 12 please refresh my memory I should be able to minimize 13 the --
14 (Pause.)
15 CHAIR KARLIN: Yes, Ms. Carpentier has a 16 copy.
17 WITNESS HOPENFELD: You are talking about 18 the ODYN code prediction of --
19 ADMINISTRATIVE JUDGE BARATTA: No. What 20 I'm leading up to is that the Staff appears to place 21 more emphasis with the experience with actual 22 transients under operating conditions at other 23 facilities.
24 And in that table, exhibit 38, which gave 25 you -- if you notice, at the top of that, it has a NEAL R. GROSS
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1533 1 comparison for the power density, which is the energy 2 per assembly, or megawatts per assembly for Vermont 3 Yankee versus Brunswick.
4 -. And we just heard, a few minutes ago that 5 Brunswick did, in fact, experience turbine trip at 6 uprate conditions. And the power density, I think, is 7 one of the parameters that tells you something about 8 the potential for going to transition boiling.
9 And the two are identical. Does that 10 address any of your concern about the possibility of -
11 - since apparently there was no fuel damage --
12 WITNESS HOPENFEILD: I think it is a very 13 good question. It partially, yes, but very, very 14 partially. I tell you why. Just the fact that power 15 density is identical to what it is at Vermont Yankee 16 that, by itself, is not sufficient to answer that 17 question.
18 However, I have not seen any discussion of 19 a detailed uncertainty study of the differences 20 between these two plants. What you really should be 21 doing, what you should take is a computer code, it 22 doesn't have to be ODYN, something, do the analysis on 23 Brunswick.
24 Taking that 5.2, I don't know the 25 distribution was the same, it is not only the average, NEAL R. GROSS
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1534 1 it is also the fuel design, how many spaces you have 2 there, that affects the transition boiling.
3 There are other parameters in there. And
-4 if you look at the basic equation you can see what we 5 are talking about..- I mean, a lot of things come into 6 play here. The difference in the dryer, for example, 7 that affects the heat balance, too.
8 So all these things, if you take all of 9 these major ones, I'm not taking every little, put it 10 in that ODYN code, after you made sure that it is 11 applicable, that you benchmark, and you make sure that 12 it is self-consistent with other plants that you have 7 13 tested at, and you apply that to Brunswick, and the 14 computer code predicts what happened there with, under 15 these conditions.
16 And then you make an assessment with 17 regard to Vermont Yankee. And you say, that 18 assessment falls within that uncertainty bank. Then 19 you have a confidence that what happened at Brunswick 20 is directly applicable.
21 But I haven't seen that done. All I -- I 22 was sitting here yesterday, I heard the NRC says, 23 basically they said, we have accepted whatever Entergy 24 provided us, and we agree to it.
25 I didn't see any analysis. They said that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1535 1 is what they said, we agree.
2 ADMINISTRATIVE JUDGE BARATTA: All right.
3 What would be your criteria, considering that it did, 4 in fact, adequately, the ODYN code adequately 5 represented what occurred?
6 We have heard that it has some 7 conservatisms in it, and we have seen, already, 8 comparisons with Peach Bottom turbine trip analysis, 9 that it overpredicts the pressure, at least for that 10 case.
11 WITNESS HOPENFELD: Can I answer now?
12 ADMINISTRATIVE JUDGE BARATTA: Yes, 13 please.
14 WITNESS HOPENFELD: Please refer to table 15 1. It is item O4NEC3. NED 241 --
16 CHAIR KARLIN: Dr. Hopenfeld, table 1?
17 WITNESS HOPENFELD: Table 1. I'm reading 18 the documents where that table is.
19 CHAIR KARLIN: All right.
20 WITNESS HOPENFELD: It is marked item 01.
21 First of all the title of my -- Entergy index document 22 provided in response to the Board request.
23 CHAIR KARLIN: What are you reading from?
24 WITNESS HOPENFELD: RAI. I'Im reading from 25 -- what was provided by Entergy, the summary of those Q NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS --
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1536 1 documents, and the numbering was item 04, and then I 2 think they changed that thing to number 26 yesterday.
3 It is table 1 that was discussed yesterday.
4 CHAIR KARLIN: I have, attached to-their 5 testimony, at the end of their testimony.; Entergy's 6 testimony, a document called table 1, Vermont Yankee 7 equipment modifications implemented at EPU. That is 8 not what you are referring to?
9 WITNESS HOPENFELD: No, that is not the 10 document.
11 ADMINISTRATIVE JUDGE RUBENSTEIN: Is this 12 in the RAI?
13 WITNESS H-OPENFELD: The document that I'm 14 talking about, that Entergy provided in response to 15 your request. They provided us a set of documents.
16 There are two documents which summarize the ODYN code.
17 CHAIR KARLIN: These are the supplemental 18 exhibits?
19 WITNESS HOPENFELD: It is in the 20 supplemental, correct.
21 CHAIR KARLIN: That we requested. Okay.
22 WITNESS HOPENFELD: And I'm reading what 23 was provided in that supplemental, and I believe it 24 was provided on June 14th.
25 CHAIR KARLIN: Well, just wait for a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS '
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1537 1 second so that we can see if we understand what 2 document that is. Please just hold for a moment, Dr.
3 Hopenfeld.
4 MR. SHADIS: It looks like it is Entergy 5 24.
6 CHAIR KARLIN: Entergy exhibit 24?
7 MR. SHADIS: I believe that is what it is.
8 WITNESS HOPENFELD: Item 04, and the 9 counsel yesterday referred to the same table I'm 10 talking about. I believe it is the same table I'm 11 talking about.
12 CHAIR KARLIN: Mr. Shadis, why don't you 13 go over and see if you can verify what Dr. Hopenfeld Nw14 is referring to?
15 MR. SHADIS: Thank you.
16 CHAIR KARLIN: It would help us, for the 17 record.
18 (Pause.)
19 MR. SHADIS: Yes, this is NEDO 24 --
20 CHAIR KARLIN: That is Entergy 26, 1 21 believe, was what we must be referring to. All right, 22 so I think you are referring to Entergy exhibit number 23 26?
24 WITNESS HOPENFELD: Yes, that is exactly 25 what it is. Let me read the title of that document.
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1538 1 It is page 1, table 1, and it is rebuttal testimony of
4 And I would like~to answer the question, 5 first, in the context of this table.
6 MR. TRAVIESO-DIAZ: In the interest of 7 expediting matters, I believe that he is referring to 8 what has been introduced into evidence as Entergy 9 exhibit 23, which was the exhibit 1 to the rebuttal 10 testimony of Mr. Nichols and Mr. Casillas. It is the 11 same document, like this.
12 CHAIR KARLIN: I think he is referring to 13 rebuttal testimony, exhibit 1? So it is 23.
14 MR. TRAVIESQ-DIAZ: Exhibit 23.
15 CHAIR KARLIN: All right.
16 WITNESS HOPENFELD: In the --
17 CHAIR KARLIN: Thank you.
18 WITNESS HOPENFELD: -- middle of the page 19 there is a statement by Entergy that the table below, 20 table 1, which is -- which I will discuss later, is 21 the justification for using the ODYN code for Vermont 22 Yankee at EPIJ conditions.
23 What they are saying, that these 24 parameters that you see in this table, cover the EPU 25 operational parameters. That is what this statement NEAL R.GROSS COUJRT-REPORTERS AND TP.UAH3CJR!BEF-1S 1323 RHODE ISLAND AVE., N.W.
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1539 1 says.
Kg 2 So now, if this is true, they do not 3 provide any backup to this, this is an extremely 4 important statement. There is no backup to this. I 5 believe they are mistaken. And I would like to point 6 out to you why they are mistaken.
7 But before I go into this table and 8 discuss the parameters that they are talking about, 9 and what the outcome of the table, I would like to 10 give you, if I may, a little bit feel for the actual 11 data in person.
12 Because as it was -- okay. If you go, now 13 please, to the exhibit which, again, on my 14 nomenclature here, it is item 03, NED241454-A, volume 15 2. Please take a look-at-pages 327, 330, 325, 331, 16 360. I will summarize it to you.
17 CHAIR KARLIN: Please stop for a minute.
18 I believe that is exhibit --
19 MR. TRAVIESO-DIAZ: I believe that is 20 exhibit 27 he is talking about now.
21 CHAIR KARLIN: That is what I have, okay.
22 WITNESS HOPENFELD: It is item 03 on my --
23 CHAIR KARLIN: Yes, okay.
24 WITNESS HOPENFELD: If you look at this, 25 this is an example, a snapshot of the comparison of NEAL R. GROSS
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1540 the data. The data does not compare very well with K) 2 the actual test at Peach Bottom. But that is not very 3 important.
4 What is important is to understand what is 5 the difference and you mentioned conservatism.-. The 6 fact that something is higher doesn't mean that it is 7 conservative.
8 So the word conservative is kind of very 9 touchy. originally General Electric, and I'm going 10 back to 1979 or something, or '80, General Electric 11 claimed that the ODYN code was conservative.
12 NRC looked, and there was a bunch of very, 13 very professional technical people, because I happen 14 to know some of them, and their names, that evaluated 15 the code, and they -madean assessment. And they said, 16 this is not conservative. These differences are in 17 error. This is not a conservative code.
18 Forty five years later we get a statement, 19 from the NRC, where they say this code, or they 20 implied, they don't say exactly, they were told by a 21 reactor operator, that the code is very, very 22 conservative, and it predicted some few data, a few 23 power plants, conservatively.
24 So the word conservative, I'm bringing it 25 up because one has to be conservative, you have to be NEAL R. GROSS ZRT'-iV1ND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1541 1 careful. The important thing, when you don't have an 2 agreement, first of all, define what are the 3 parameters we are interested.
4 They, in those graphs that I mentioned to 5 you, compared the pressure, and you can see the dome 6 pressure, the pressure, they compared the steam line 7 pressure, they compared the power, and in all cases 8 ODYN provides higher values.
Well, that is okay if you can explain it.
10 It doesn't matter, it doesn't have to agree. But if 11 you can explain it by a good uncertainty analysis, and 12 they can put confidence on X number of signals on the 13 confidence of the data, then if you take that, and 14 apply it to another plant, I would have confidence in 15 it.
16 CHAIR KARLIN: So essentially what you are 17 saying is that, you would like, you question the large 18 deviation that occurred, and the pressure is higher, and they could be getting the right answer for the 20 wrong reason?
21 WITNESS HOPENFELD: That is part of it.
22 But I say, I'm not that much concerned about that, 23 because they have done a good analysis, and they told 24 me where and how I can use the code. Arnd I would like 25 to go back to table 1, if I may?
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1542 If you look at the table 1, you have two 2 predictions. One of comparison. This is uncertainty 3 that was done on all the data. Now, the parameters 4 that they are talking about, in this table, and that 5 was the o~riginal intent of the code, to predict that 6 parameter, is the CPR, or the delta critical power.
7 Critical power ratio for those that may be 8 of interest, its a power at which one point, at some 9 point of the bundle you get into transition boiling, 10 divided by the average power of the bundle.
11 It is a calculated value. As I said, it 12 is not something that you measure, but it is a very 13 important criteria. Now, why is it important?
14 Because once you get into that transition boiling, you 15 want to stay away from it, like away from cancer.
16 Because once you get there you will have 17 potential for a melt. So it is important, and it is 18 a safety, and what we have done here, we have 19 decreased the margin, towards getting to that 20 transition boil.
21 So if you look at this table it has only 22 one criteria at this point. We are interested in 23 other criteria. We are interested in the pressure.
24 And, as I said before, we also are interested in the 25 frequency of oscillations of that pressure, because NEAL R. GROSS
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1543 1 that is a potential excitation force for resonance 2 vibration.
3 Now, if you look at the comparison nowhere 4 is ODYN code even getting close of predicting the
.5 vibration frequency. So as far as the vibration 6 frequency, it doesn't predict it.
7 Now, it does predict pressures, it also, 8 is my understanding, but I understand that it is some 9 proprietary information which we haven't seen, and I 10 don't understand why, there is a comparison with the 11 level.
12 Now, level is a very important parameter.
13 And --
14 CHAIR KARLIN: Well, let me stop you 15 there, Dr. Hopenfeld. In terms of the proprietary 16 information. You were entitled to see that 17 proprietary information if you just signed a non-18 disclosure agreement.
19 So when you say you don't understand why, 20 I think you should understand why, which is you are 21 entitled to see it, and you declined to -
22 WITNESS HOPENFELD: Well, sir, I don't 23 know if it is proper for me, and you know everybody 24 has his own life experiences. And I don't know if it 25 is appropriate for me to go and reflect on my own NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1544 1 experience. And I used to work for NRC.
2 CHAIR KARLIN: No, I don't want to hear 3 that. I just want to say, you were entitled to see it 4 if you had just signed a non-disclosure agreement.
5 WITNESS HOPENFELD: I cannot sign that.
6 CHAIR KARLIN: All right. You are 7 entitled not to sign it.
8 ADMINISTRATIVE JUDGE BARATTA: I 9 understand your concerns about the, I'm trying to 10 think how to say this nicely. I understand your 11 concerns about disagreement between the predictions 12 and I also understand your concerns about lack of an 13 explanation of why that is, okay?
14 However, I'm also looking at what appears 15 to be another principled reason for not doing the 16 testing, at least in the minds of, I believe, the 17 Staf f and also based on some of the testimony of 18 Entergy, at least, is that -- okay, putting the ODYN 19 code aside, we have to have a number of events at 20 other plants which in a variety of ways are 21 comparable.
22 And we have not seen any behavior that 23 deviates from what was anticipated. I mean, just 24 looking at the events on a very, just fundamental 25 physics and such, could you comment on that argument?
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1545 WITNESS HOPENFELD: I was going there, 2 sir. But I would like to complete my explanation.
3 Because the heart to your question sits in this table, 4 as I see it.
5 And I would like to, so I could 6 communicate properly and explain what my concerns, 7 explain some of those terms. You can see here, you 8 see here that there are two parameters. One is called 9 C, and one is the velocity.
10 And you can see they are bound by 11 uncertainty. It is important to understand what those 12 parameters are. One represents the distribution, the 13 void distribution in a channel, when you have a two-14 phased flow there is a distribution.
15 The other one, VJ, represents the drift 16 velocity. It is not the same velocity that was 17 changed at Entergy. Because when they say, well, that 18 is within these parameters, I don't know, maybe they 19 mean it is within this velocity.
20 This velocity is not the velocity they 21 have changed. This is a drift velocity, it is an 22 experimental parameter. But that C parameter, and 23 that subzero are experimental parameters which GE 24 spent a lot of money to generate those, for conditions 25 which they believe are relevant.
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1546 1 There are a lot of those numbers in the K.'2 literature. They were obtained under steady state 3 conditions. What we have here, we don't have a steady 4 state condition, we have a transient situation, the 5- temperature rise on the surface of the clad, is going 6 to be affected by the heat generation.
7 So it is going to be different under EPU 8 than it is under normal operating conditions. The 9 temperature rise, if you go back to your boiling curve 10 and, especially transient kind of information, you 11 will find that that temperature rise would affect, 12 could affect the mechanism void, it could affect the 13 heat transfer mechanism.
14 So you have to analyze, you have to see 15 whether these things are the same. Now, they lump 16 everything in here and they say, well that covers 17 everything.
18 So to answer your -- to go back now, 19 partially, I'm not done-with this table because for 20 the following reason. This table only showed one 21 parameter. Later on, a year or two after this table 22 was generated, NRC said well, they've done some 23 calculations that say, well we can also use this for 24 pressure.
25 And they put some numbers in there. But NEAL R. GROSS COURT REPORTMflS AND TRP41,0)G.IBEPS.
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1547 1 they have not provided their rationale for doing that.
Ka~' 2 They just said we can also use it for pressure. So 3 that is the justification.
4 Now, going-back to taking this experience 5 in different plants, the only way I know to make the 6 thing, to formalize this experience, is to take a 7 computer, and these are complex, if these plants were 8 simple, if they were just like a fuel tank sitting 9 here, you don't need a computer code, I can tell you 10 how fast the fuel go down.
11 But these are complex animals. And each 12 one has differences. It is not the same design. So 13 you have to do, analyze the case, you have to do the 14 analysis in each case.
15 And in order- -to do the analysis in each 16 case you have to use the computer, some kind of a 17 computer code. Now, we heard testimony, yesterday, 18 that observations from all these plants show that 19 there are not abnormalities between these plants.
20 Well, first, when you say there are no 21 abnormalities, and I'm talking about the observation 22 from different plants, you have to define what it is, 23 what abnormality is.
24 Then you have to describe how it was 25 measured. For example if, an abnormality for me, for NEAL R. GROSS 1323 RHODE ISLAND AVE.. N.W.
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1548 1 example a normal situation would be if an enormous one 2 hundred percent power, only one fuel pin goes in 3 transition boiling, and under EPU conditions ten fuel 4 pins go into. transition boiling, that would be an 5 abnormality.
6 So first you have to define what you are 7 talking about. Because, otherwise, such a general 8 statement to say, I haven't seen anything here, and 9 anything here, therefor it is okay. I don't know how 10 to address that.
11 An engineer would look at, would have some 12 kind of a model, and would put an uncertainty study on 13 each one. Now, let me say something about the model,
- 14 about how you take a model and make sure that --
15 CHAIR KARLIN: Can we stop for just a 16 minute, Dr. Hopenfeld?
17 WITNESS HOPENFELD: Yes.
18 CHAIR KARLIN: I have forgotten what the 19 question was. Could we have an understanding of what 20 the question is, is there any question you have 21 remaining?
22 WITNESS HOPENFELD: I was answering how do 23 you --
24 CHAIR KARLIN: Well, we want to know what 25 the question was.
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1549 1 ADMINISTRATIVE JUDGE BARATTA: I 2 understand what you are saying, because the drift flux 3 model, both of those are parametric fits. And they 4 are done under limited conditions, and it is -veryý 5 difficult to do transient heat transfer studies.
6 So you take these with a grain of salt, so 7 to speak. Now, that said, though, that the truth, to 8 me, and I believe Staff, was in the other cases where 9 this has occurred. And they haven't seen any fuel 10 failure, they haven't seen any component damage.
11 And that seems to indicate, at least, 12 apparently they have had four or five of these 13 occurrences, that under similar uprate conditions 14 there isn't a problem. That is what I'm really trying 15 to focus on here.
16 WITNESS HOPENFELD: I understand, that is 17 why I'm trying to answer the question, abnormality, 18 they haven't seen any problem. That is why I'm using 19 the word abnormality.
20 You see abnormality, and what is the 21 problem? I mean, you don't measure fuel boiling.
22 ADMINISTRATIVE JUDGE BARATTA: No, but you 23 do measure fuel damage, right?
24 WITNESS HOPENFELD: Well, you do, but 25 there was no des~cription in our presentation, anywhere Kfi *- -
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1550 1 in here, whether there was, and what the degree of 2 fuel damage was. And what are the differences between 3 this plant and that plant.
4 - ~Just, as I said before, just -the- energy 5 density is not, by itself, sufficient. There are 6 other parameters.
7 ADMINISTRATIVE JUDGE BARATTA: There are 8 other parameters, that is quite true, I agree, that 9 you need to look at.
10 WITNESS HOPENFELD: I will give you an 11 example, maybe this plant is different. I don't know, 12 I haven't gone to each one. Plus there is a 13 difference in vibration, because maybe they haven't 14 gotten any resonance vibration over there, but maybe 15 you will get it here.
16 Now, let me tell you why. Because maybe 17 the natural frequency of the dryer at Brunswick, of 18 the stiffness of the dryer, divided by its mass is 19 entirely-different than the one at Vermont Yankee.
20 So if these two are different you are 21 going to have a dif ferent resonance vibration. So you 22 have to take a look at each case. Now, I don't know, 23 I haven't done the calculations. But you can't say, 24 just because this has a dryer, plus the dryer at 25 Vermont has been modified. And I think they modified NEAL R.GROSS
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1551 for the EPU.
klý 2 I don't know, but they increased the 3 diameter, I guess. And the dryer does come in, in the 4 heat balance calculation -
5 ADMINISTRATIVE JUDGE RUBENSTEIN: To 6 follow-up on Judge Baratta'Is question on the potential 7 of an OPWR type, I won't call it DNV, I will call it 8 CPR, critical power ratio exceedence. Is there any 9 evidence, anywhere, have you looked at Licensee Event 10 Reports, the analysis of the transients in all the 11 other BWRs which are operating at EPU?
12 WITNESS HOPENFELD: I have'. I have seen -
13 14 ADMINISTRATIVE JUDGE RUBENSTEIN: Have you 15 seen any evidence of fuel failure?
16 WITNESS HOPENFELD: No.
17 ADMINISTRATIVE JUDGE RUBENSTEIN: Not in 18 the LERs, they don't talk about -- no xenon, nothing
- 19 like that?
20 WITNESS HOPENFELD: No.
21 ADMINISTRATIVE JUDGE RUBENSTEIN: So in a 22 physical sense the thermal hydraulic ef fects have not 23 resulted in fuel damage?
24 WITNESS HOPENFELD: They have not resulted 25 in those plants. It is not sufficient to say that it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS -
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1552 1 is not going to result --
2 ADMINISTRATIVE JUDGE RUBENSTEIN: Well, 3 these are multiple BWRs, which are operating at EPU 4 conlditions5, multiple numbers of transients. I don't 5 know what the number of plants times the number of 6 transients are, the transients of concern in this 7 hearing.
8 But there has been no evidence of fuel 9 damage and no reporting of the safety limit, minimum 10 critical power ratios exceedences. Is that true?
11 WITNESS HOPENFELD: Well, I said, each 12 plant is different.
13 ADMINISTRATIVE JUDGE RUBENSTEIN: I'm 14 talking about observations.
15 WITNESS HOPENFELD: You are talking about 16 the observation that there was no plant, there was no 17 fuel melt. The fact that there wasn't fuel melt here, 18 I don't know how to take --
19 ADMINISTRATIVE JUDGE RUBENSTEIN: No, I 20 didn't say anything about fuel melt --
21 WITNESS HOPENFELD: -- Vermont Yankee.
22 ADMINISTRATIVE JUDGE RUBENSTEIN: I could 23 ask you, have you seen xenon ratios in the coolant, 24 but I'm not going to do that kind of stuff.
25 WITNESS HOPENFELD: No.
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1553 1 ADMINISTRATIVE JUDGE RUBENSTEIN: But 2 there is no evidence of perforation in the fuel rods.
3 WITNESS HOPENFELD: No.
4 ADMINISTRATIVE JUDGE RUBENSTEIN: Judge 5 Baratta?
6 CHAIR KARLIN: Any more questions?
7 ADMINISTRATIVE JUDGE BARATTA: No.
8 CHAIR KARLIN: All right, thank you Dr.
9 H-openfeld. You may step down. Thank you, sir. At 10 this point it is about 20 of, by my official clock 11 back there.
12 We are going to proceed, as we discussed 13 earlier, which is we will take a 15 minute break. At Ka~) 14 the stroke of noon we will reconvene. And at that 15 point I will hear from you, if any of the counsel, or 16 pro se representatives have any suggested supplemental 17 questions we should, you think we might ask of any 18 party, any witness I'm sorry, the witnesses that have 19 appeared here.
20 We will be following, essentially, the 21 same rule as 1QCFR2.1207, there is a process for doing 22 this sort of thing. And you, obviously, previously 23 submitted questions to us, suggestions for us to 24 propound to witnesses.
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1554 1 it in a written form, which the other parties won't 2 see until after this proceeding is over with, and then 3 it will be put into the record for everyone to see.
4 Or you can just tell us in open-court, and stand up 5 and say, we think you ought to enqui~re into the 6 following areas.
7 Either way I understand it won't be a nice 8 pretty piece of paper if you want to do it in writing.
9 It might be handwritten, but put your name on top of 10 it, and your party identification, and your signature 11 at the bottom of it as whoever is submitting this.
12 I prefer them to be just orally presented 13 on the transcript. But if you want to do it in 14 writing, fine. And then we will break for lunch, we 15 will think about the questions you have asked, or 16 suggested, we will think about any further questions 17 we have, and then if appropriate, and we think it is 18 necessary, we will reconvene such witnesses as we want 19 to ask some follow-up questions to.
20 Thank you. We will be adjourned until 21 noon.
22 (Whereupon, the above-entitled matter 23 went off the record at 11:45 a.m. and 24 went back on the record at 12:00 p.m.)
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1555 1 start with you. Do you have any suggested 2 supplemental questions?
3 MR. TRAVIESO-DIAZ: Well, Mr. Chairman, I 4 have-..two items. First item is a question for Mr.
5 Nichols that was left pending yesterday, as to the 6 details, I think it was your question, time and 7 details of the startup testing initially at the plant.
8 And I believe that question should be asked as a 9 follow-up.
10 CHAIR KARLIN: All right.
11 MR. TRAVIESO-DIAZ: My second item is a 12 question to the Board. I understand there is going to 13 be a proprietary session after lunch?
14 CHAIR KARLIN: Yes.
15 -MR. TRAVIESO-DIAZ: I would like to 16 reserve the opportunity to propose additional 17 questions after the proprietary session, to the 18 witnesses that testify in that session, if 19 appropriate.
20 CHAIR KARLIN: Well, we are going to go 21 through the same procedure in the proprietary session, 22 which will be, we will hear the witnesses, and then we 23 will stop and decide whether we want to ask them any 24 further questions. So the same process will occur in 25 the proprietary.
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1556 1 MR. TRAVIESO-DIAZ: That is fine, then.
2 ADMINISTRATIVE JUDGE BARATTA: Have you 3 written out your question that you are recommending 4 for Mr. Nichols,.or --
5 MR. TRAVIESQ-DIAZ: No, it is only one 6 question, and I --
7 CHAIR KARLIN: Okay, so your question is 8 that we ask him to address the startup transient 9 testing?
10 MR. TRAVIESO-DIAZ: Yes, because it was 11 left open yesterday.
12 CHAIR KARLIN: Yes, all right, thank you 13 Mr. Travieso-Diaz. Staff, Mr. Hamnrick, Mr. Turk any 14 questions you suggest?
15 MR. TURK: I think we do have two 16 questions, Your Honor, that we have identified so far.
17 Let me preface, normally under subpart G, when we go 18 to hearings, every night we meet with witnesses, and 19 we talk about any redirect that is necessary, or any 20 questions to ask of the witnesses.
21 I know this is the first informal hearing 22 that is being held at NRC.
23 CHAIR KARLIN: Right.
24 MR. TURK: I think it is useful if we are 25 allowed to have a little more time to discuss K> -
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1557 1 testimony than just a little short 15 minute session.
2 Because when you get into a room with ten people there 3 is a lot of talk that doesn't get you to the bottom 4 line of let's identify the question.
5 So for future reference if it is possible 6 to get more time?
7 CHAIR KARLIN: Right. I think in addition 8 NEC has the shortest turnaround, because they just 9 finished their witness. You had maybe an hour before 10 it, so I understand that. So we just need to proceed, 11 so -
12 MR. TURK: At this point, Your Honor, the 13 only questions we would suggest would be to Staff 14 witnesses. And the first would be whether they agree 15 that -- with-the suggestion that all they did here was 16 simply review what the Applicant gave them, and 17 reached the one line conclusion that appears in the 18 SE. Do they agree with that characterization of what 19 the review consisted of.
20 CHAIR KARLIN: Okay.
21 MR. TURK: And the second question we 22 have, again it would be for a staff witness, would be 23 to explain the justification for requiring condensate 24 feedwater testing here, as distinct from deciding not 25 to require testing of the MSIV closure and load K) I _-0*-
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1558 1 rejection.
2 CHAIR KARLIN: okay. Did we get those 3 questions? Okay. Any other questions that you would 4 propose that we consider asking? -
5 MR. TURK: Not at this time.
6 CHAIR KAIRLIN: All right, thank you. Mr.
7 Shadis, for New England Coalition?
8 MR. SHADIS: Thank you, Your Honor. I 9 have a list of 15 questions, and then one additional 10 question which I have not translated into readable 11 type, but only have it as a note.
12 And I don't know if you would, because of 13 the number of questions, if you would now prefer to 14 simply have them written, and the one question stated 15 orally? or shall I go through them and give them all 16 to you orally?
17 CHAIR KARLIN: Well, it is somewhat of 18 your call. I mean, you can -- I think it would be 19 preferable for us if you just told us verbally, here, 20 what your questions were, and we will try to take them 21 down slowly, or whatever, and alternatively, if you 22 don't want to state them in open court, you can give 23 us the piece of paper, handwritten as it is.
24 MR. SHADIS: That is not an issue in terms 25 of stating. I would be pleased either way.
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1559 1 CHAIR KARLIN: Yes, please, would you do 2 it? And tell us who the question is addressed to, 3 this panel, that sort of thing.
4 MR. SHADIS: Thank you. The first 11, 5 actually, are for the Entergy-- panel, for the 6 Applicant's panel.
7 And I will just read them. And if the 8 prose is too dense, maybe you can --
9 CHAIR KARLIN: We probably won'It use your 10 exact words, anyway.
11 MR. SHADIS: Thank you. Can you describe, 12 in quantitative terms, how the so-called mild 13 transient tests, with all relief valves open, would 14 vary as to pressure versus time, power changes versus 15 time, and level changes versus time?
16 CHAIR KARLIN: Pressure, power, and level 17 changes versus time?
18 MR. SHADIS: Versus time. And the second 19 part of that is the other extreme.
20 CHAIR KARLIN: Wait a second, is this 21 another part of the question?
22 MR. SHADIS: Well, it is the second part 23 of that question.
24 CHAIR KARLIN: Okay.
25 MR. SHADIS: It is really a -
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1560 1 CHAIR KARLIN: Just read that one again, 2 one time, for us.
3 MR. SHADIS: Thank you. Can you describe, 4 in quantitative terms, how' so-called mild transient 5 tests, with all relief valves open, would vary as to 6 pressure versus time, power changes versus time, and 7 level changes versus time?
8 CHAIR KARLIN: Okay.
9 MR. SHADIS: And the flip side of that, if 10 you will, have you done any studies, and could you 11 please describe or provide them, of how the above 12 parameters would vary as a factor of scram delay?
13 CHAIR KARLIN: Would you repeat that one 14 again?
15 MR. SHADIS: Yes, I think I can. Have you 16 done any studies, and could you describe or provide 17 them, of how the above parameters would vary as a 18 factor of scram delay.
19 ADMINISTRATIVE JUDGE RUBENSTEIN: Scram 20 delay time?
21 MR. SHADIS: Scram delay, yes.
22 ADMINISTRATIVE JUDGE RUBENSTEIN: Thank 23 you.
24 MR. SHADIS: If I understand on what you 25 are looking for in clarification. Yesterday we heard-
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1561 2 CHAIR KARLIN: okay, keep going, question 3 number 2. No, that was a two-part number one.
4 MR. SHADIS: -*Yes, it is a two-part number 5 one. And actually I had listed them here 1 and 2, but-6 I'm not --
7 CHAIR KARLIN: All right, whatever.
8 MR. SHADIS: For the General Electric 9 representative, General Electric wrote full transient 10 testing into the licensing topical report. And after 11 that report was accepted, in a several year process, 12 GE asked for generic exemption.
13 What rationale did GE offer for placing 14 the requirement for large transient testing in the 15 topical report in the first place?
16 CHAIR KARLIN: Okay.
17 MAR. SHADIS: If the licensing basis, or 18 safety analysis assumes, as a matter of conservation, 19 transients near the end of core life, why not perform 20 the large transient testing at the end of the fuel 21 cycle, with resulting outage concurrent with the 22 refueling outage? To address the concern for losing 23 a couple of days of power generation, why not do it on 24 the eve of shutting down anyway?
25 CHAIR KARLIN: Does everybody have that?
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1562 1 Okay. Which number are we on now, Mr. Shadis, do you 2 have the number?
3 MR. SHADIS: This would be number four 4 that we are moving-to.
5 CHAIR KARLIN: Okay.
6 MR. SHADIS: And number four, the question 7 goes to the reliability and dependence on turbine 8 bypass valves.
9 Can generator load shed, and failure of 10 bypass valves to open result from common mode 11 failures, and as example, electrical failures, either 12 power supply, or signal, or control?
13 CHAIR KARLIN: Is that a question that 14 arose from any of the questions we asked here in the 15 last two days?
16 MR. SHADIS: Yes.
17 CHAIR KARLIN: That is going to be a 18 criterion to apply.
19 MR. SHADIS: It rose from the answers that 20 were given to your questions. I don' t recall the 21 particular questions. But --
22 CHAIR KARLIN: Okay.
23 MR. SHADIS: -- there was a great deal of 24 discussion about the history of the reliability of the turbine bypass valves to --
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1563 1 CHAIR KARLIN: All right, I know.
2 MR. SHADIS: Thank you, Your Honor. Okay, 3 we were on four.
4 CHAIR KARLIN: Are you starting five?
5 MR:* SHADIS: Yes, we are starting five.
6 In the generator load shed failure, at Vermont Yankee 7 in 2004, what unanticipated events, if any, resulted 8 in the turbine hull and the reactor bin?
9 And we would presume those events, if any, 10 occurred, events that might result in difficulties in 11 restoring the plant balance. That was number five.
12 Number six, does fast shutdown analysis 13 assume feedwater pump trip, have feedwater pumps 14 failed to trip historically? That is, is there a 15 history?
16 CHAIR KARLIN: I really have some doubt 17 whether that question arises from anything we asked in 18 the last two days. But we will listen to it and take 19 consideration of it. Because this is limited to 20 supplemental questions, they are not something you 21 should have asked originally, but something that arose 22 directly out of what we asked.
23 And we will think about that, as we decide 24 whether to ask these questions.
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1564 1 the discussion not only with Entergy, but with the NRC K) 2 Staff yesterday, surrounded the timing of restoring 3 plant balance.
4 CHAIR KARLIN: Yes, I remember that.
5 MR. SHADIS: So if the feedwater pumps 6 fail to trip you have some issues. And there was a 7 great deal of emphasis placed upon the reliability of 8 individual components. So I think the question 9 follows on that.
10 CHAIR KARLIN: Okay.
11 MR. SHADIS: That was number six, was it?
12 Number seven, describe how core and fuel modifications 13 for EPU, at Vermont Yankee, affect scram parameters.
K) 14 CHAIR KARLIN: Okay.
15 MR. SHADIS: Entergy asked, answered a 16 question respecting a list of modifications done in 17 anticipation of extended power uprate. What 18 modifications were made to the steam dryer, and why 19 were these modifications not included in the list?
20 The issue of the cost of large transient 21 testing were raised, and there was a comparison 22 requested to the cost of unanticipated transients, as 23 well as how the company would follow on each of these.
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1565 1 analysis performed, and what is the range of cost of 2 the root cause analysis?
3 And the following question, then, if root 4 cause analysis would not have to be performed for a 5 large transient test, shouldn't that result in savings 6 be factored into the comparative costs?
7 This is a two part with respect to the 8 ODYN code, I think. Is the ODYN code predicted of 9 maximum pressure, is that what one is looking for in 10 employing an ODYN code?
11 And along with that, we would want to see 12 some considerations of level in responses. If, this 13 is going on to the next one, which I think we are now 14 on number 11, is that right?
15 We discussed very early plant startups and 16 the use of full transient testing. And then Entergy 17 responded on some question, remarking that there is a 18 history of latter day startups, such as Clinton and 19 Seabrook, where full transient testing was done.
20 And the question is, was ODYN used to 21 predict plant response in those plants? And if not 22 why was it not, or if it was, then why was it not 23 benchniarked against those plants?
24 We have benchniarking going back to Peach 25 Bottom and so on, but not on the latter day plants.
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1566 1 And since we are in pacman version number 9, it might 2 be good to apply it to those plants. And we want to 3 know why it wasn't.
4 - And I miscounted, so we now have a number 5 12. And I think it was answered, actually, and I may 6 just drop that. The question had to do with the 7 history of full transient testing in the original 8 licensing of Vermont Yankee. And I don't know that we 9 ever got an answer as to whether it was done at one 10 hundred percent or not.
11 But if we didn't I think that question 12 needs to be asked again. And now questions for NRC 13 panel. And this would be number 13 in a running list.
14 CHAIR KARLIN: All right.
15 - MR. SHADIS: But it is the first one for 16 the NRC panel. What mensara, including data, 17 calculations, screening criteria, etcetera, were used 18 to evaluate exemption considerations at Vermont
.19 Yankee?
20 CHAIR KARLIN: Could you repeat that?
21 MR. SHADIS: Yes, sir. What mensara --
22 CHAIR KARLIN: Mensara?
23 MR. SHADIS: What modes of measurement, 24 what kinds of measurements, and it would include such 25 things as data, calculations , screening criteria, NEAL R. GROSS
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1567 1 excuse me, data calculations, screening criteria --
2 CHAIR KARLIN: Like criteria, except it is 3 mensara? Go ahead. What mensara --
4 MR. SHADIS: What kind of criteria --
5 CHAIR KARLIN:.- All right.
6 MR. SHADIS: -- were used to evaluate 7 exemption considerations at Vermont Yankee? This is 8 the next question, 14. What were the standards of 9 review for exemption considerations at Vermont Yankee?
10 And I think by standards of review we 11 would mean, to what standards were the reviewing staff 12 held.
13 ADMINISTRATIVE JUDGE RUBENSTEIN: I don't 14 understand that.
15 MR. SHADIS: I'm sorry?
16 ADMINISTRATIVE JUDGE RUBENSTEIN: I don't 17 understand it.
1s MR. SHADIS: Well, let me try to explain -
19 20 ADMINISTRATIVE JUDGE RUBENSTEIN: -
21 satisfying the GDCs and the regulations, do you mean 22 more than that?
23 MR. SHADIS: Well, in listening to the 24 Staff'Is responses as to how they evaluated this, their 25 familiarity, or lack of familiarity with the Vermont NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1568 1 Yankee operational history, all the rest of it, one 2 could assume that it was very casual, off -the-shoulder 3 kind of approach with professional nonchalance, and 4 they said, yes it looks good to me.
5 Or did they have to actually get out a 6 checksheet and punch all the little boxes? I mean, 7 how strict are the standard of review held to when 8 they put out that SER? That is the question. it 9 looks to me like it is --
10 CHAIR KARLIN: Okay.
11 MR. SHADIS: I'm not going to testify.
12 CHAIR KARLIN: All right.
13 MR. SHADIS: And as a subpart to that 14 question, in reviewing the criteria for exemption, 15 what weight did they assign to each of those criteria?
16 And then I actually have two more.
17 Number 16. What characteristics of the 18 plant design, operational parameters, and so forth, of 19 individual plants, in the compared EPTJ transient 20 population were considered when applying industry 21 experience to the Vermont Yankee EPUJ?
22 We heard some of that, but there was very 23 little detail. So I guess the question goes, what was 24 the extent and detail of comparison.
25 And the final question for Dr. Hopenfeld, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.. N.W.
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1569 1 please discuss, in more detail, the ability of the 2 ODYN code to predict various aspects of a full 3 transient.
4 CH-AIR KARLIN: Okay.
5 MR. SHADIS: That is it, sir.
6 CHAIR KARLIN: All right, thank you. With 7 that I think what we will do is adjourn for lunch, and 8 reconvene at 1:30 by that clock. Thank you, we are 9 adjourned.
10 (Whereupon, at 12:28 p.m., the above-11 entitled matter was adjourned for lunch.)
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1570 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 1:31 p.m.
3 CHAIR KARLIN: Thank you. The Atomic 4 Safety and Licensing. Board is reconvening in the 5 Vermont Yankee uprate matter. We are now at a stage 6 where we, if we have any follow-up questions, we have 7 taken into consideration the questions that have been 8 posed, suggested by the parties, that we might ask.
9 In thinking about those questions we had 10 several factors to keep in mind. one is the parties 11 had an opportunity to ask questions, propose questions 12 to us on August 4th, on any and every subject they 13 chose, and wanted to suggest questions on.
14 And this was not a time to repeat that, or 15 redo that. Even if we asked some questions of a 16 similar vein, this is not an opportunity to revitalize 17 that set of questions.
18 Second, a lot of the questions we think 19 were already answered, asked and answered. And so, 20 you know, we are going to proceed with asking several 21 questions. We would like the Entergy witnesses to come 22 back up, and we would like to pose some questions for 23 them.
24 So, Mr. Nichols, Mr. Casillas, if you 25 would return to the witness stand, we would appreciate NEAL R. GROSS
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1571 1 it.
2 Whereupon, 3 CRAIG NICHOLS 4 JOSE CASILLAS 5 were recalled as witness by the Atomic Safety and 6 Licensing Board Panel and, having been previously duly 7 sworn, assumed the witness stand, were examined and 8 testified as follows:
9 CHAIR KARLIN: I don't know that we have 10 that many questions. You are loaded for bear.
11 Please be seated. I will remind you both 12 that you are still under oath, and if you would --
13 yes, I guess I will ask one question.
14 Earlier in the session we asked whether or 15 not the large~transient test, the main steam isolation 16 valve, and the generator load rejection tests had been 17 performed at the startup.
18 And could you perhaps address that, Mr.
19 Nichols, were they performed, were they performed at 20 one hundred percent, when were they performed?
21 MR. NICHOLS: And I checked my records and 22 this is actually in a public document that was 23 submitted to the NRC in response to what is referred 24 to as an RAI.
25 CHAIR KARLIN: Yes.
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1572 1 MR. NICHOLS: And as the Staff testified, 2 Vermont Yankee completed power ascension through 75 3 percent power, upon which there were problems with 4 fuel performance. Went through a period of reduction, 5 and then recommenced power operation and power 6 ascension testing in early 1974.
7 And they completed three large transient 8 tests. On January 24th of 1974, at 98 percent power, 9 Vermont Yankee performed a turbine trip test.
10 CHAIR KARLIN: Is that generator load 11 rejection test?
12 MR. NICHOLS: No, that is turbine trip.
13 CHAIR KARLIN: Okay.
14 MR. NICHOLS: obviously that took the 15 plant off line, returned to power. And on February 16 23rd, of 1974, at approximately 92.7 percent power, 17 Vermont Yankee completed the MSIV closure test.
18 And upon return to power on March 29th, 19 1974, Vermont Yankee performed the generator load 20 reject test.
21 CHAIR KARLIN: And at what power level was 22 that?
23 MR. NICHOLS: I apologize. That one was 24 at 93.7 percent power.
25 CHAIR KARLIN: At 93.7. Okay, thank you.
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1573 1 ADMINISTRATIVE JUDGE BARATTA: Mr.
2 Casillas, you indicated that as part of the process 3 for the constant pressure power uprate the void 4 fraction distribution was unchanged and you achieve 5 that by increasing the velocities through the core?
6 MR. CASILLAS: Yes.
7 ADMINISTRATIVE JUDGE BARATTA: That is 8 correct? Okay.
9 MR. CASILLAS: Well, you effectively 10 increase the core flow through the core. In effect, 11 actually, you decrease the flexibility that the plant 12 has to operate at low flow. So, correct.
13 ADMINISTRATIVE JUDGE BARATTA: Did -- you 14 are familiar with the real number and nissl number?
15 MR7. CASILLAS: Yes.
16 ADMINISTRATIVE JUDGE BARATTA: And those 17 are usually used to determine the flow regime, are 18 they not, or heat transfer regime?
19 MR. CASILLAS: Right, correct.
20 ADMINISTRATIVE JUDGE BARATTA: Did any of 21 the changes that were made, as a result of the 22 constant pressure power uprate result in any 23 significant changes in those quantities in the core?
24 MR. CASILLAS: There were no new, 25 certainly the average behavior of the average channel NEAL R. GROSS
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1574 1 changed, because it had a higher quality, higher void, 2 and so it was a higher distribution skewed towards the 3 maximum power.
4 But the maximum power assemblies, 5 actually, do not increase in power at all. Because 6 contrary to some discussions, the limit as to what is 7 the maximum power that the limiting element is allowed 8 to operate, whether it be at current power, or at the 9 EPU, is the same.
10 ADMINISTRATIVE JUDGE BARATTA: Right.
11 What I'm trying to get at is you didn't derive 12 anything in any new flow regime?
13 M4R. CASILLAS: Absolutely not, nothing 14 new.
15 ADMINISTRATIVE JUDGE BARATTA: Which would 16 be indicated by a change in the Reynolds number, or 17 new heat transfer regime, which would be --
18 MAR. CASILLAS: Yes, nothing would be.
19 ADMINISTRATIVE JUDGE BARATTA: -- by a 20 nissl number, is that correct?
21 MR. CASILLAS: That is correct, yes.
22 CHAIR KARLIN: What is the second number?
23 MR. NICHOLS: The nissl, heat transfer.
24 ADMINISTRATIVE JUDGE BARATTA: Do you have 25 any follow-up on that?
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1575 1 ADMINISTRATIVE JUDGE RUBENSTEIN: No.
2 ADMINISTRATIVE JUDGE BARATTA: Mr.
3 Nichols, you mentioned yesterday, and I tried to find 4.. the testimony where you said that I think a one-inch 5 plate was added to the steam dryer, and you mentioned 6 that it was done to be better able to resist the 7 pressure pulse that comes, I think, it was a turbine 8 trip, is that correct? Do you remember that 9 discussion?
10 MR. NICHOLS: I remember the discussion.
11 We did make modifications to the steam dryer, one of 12 which is strengthening the lower cover plate, the 13 front vertical plate was taken to one inch, as you 14 referred to. We added gussets for additional 15 strengthening of that front plate area.
16 It was not for the purpose of the turbine 17 trip. It was for normal steady state flow vibration, 18 that was the purpose of the modification, to resolve 19 the questions in the industry, the OE, but steady 20 state operation.
21 ADMINISTRATIVE JUDGE BARATTA: So it 22 wasn't based on any stress analysis that you did, or 23 that indicated a problem under EPU conditions?
24 MR. NICHOLS: No, it was really a 25 proactive modification to strengthen it. The NEAL R.GROSS 4-_ýii COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1576 1 subsequent testing that we did during power ascension, 2 and analysis that we talked about yesterday, at full 3 power, indicated that the stresses were very low.
4 ADMINISTRATIVE JUDGE RUBENSTEIN: Was this 5 recommended by the owner's group, or was this a GE, 6 was this an industry wide accommodation?
7 MR. NICHOLS: It was certainly, it is part 8 of the analysis for the extended power uprate. There 9 is a whole section of structural analysis performed 10 for the power uprate, steady state, transient, 11 accident loads.
12 And it came out of that, that steady state 13 load. Certainly the information gained throughout the 14 failures at other plants, and the data that they 15 gathered, was incorporated into that.
16 But we made the modification almost two 17 years before we uprated the plant.
18 ADMINISTRATIVE JUDGE RUBENSTEIN: But the 19 thrust of the question was, was this sort of an 20 individual Vermont Yankee action, or was it a result 21 of owner's group and GE SIL recommendation?
22 MR. NICHOLS: There is a GE SIL number 644 23 that relates to dryer effects. But it doesn't 24 necessarily talk to the modification. It talks to the 25 inspections you should do, etcetera. And the owner'Is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS -
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1577 1 group, there is an owner's group committee. But 2 that, again, did not drive the modification.
3 It was really the analysis done by General 4 Electric for the steam dryer, for the uprate that 5 resulted in that mod.
6 ADMINISTRATIVE JUDGE RUBENSTEIN: So they 7 called your attention that this is a potentially weak 8 area, and do the analysis and, therefore, as a 9 consequence of the analysis, make the certain 10 modifications would fit your case?
11 MR. NICHOLS: That is correct.
12 ADMINISTRATIVE JUDGE RUBENSTEIN: Thank 13 you.
14 CHAIR KARLIN: Anything more? okay, thank 15 you, gentlemen. You may sit down. You didn't need it.
16 Always better to be prepared.
17 With that we are going to adjourn this 18 session for ten minutes, so that we will reconvene.
19 Well, let's make it ten of the hour, and initiate the 20 proprietary session.
21 At that point only individuals who have 22 signed the non-disclosure agreement, prescribed in our 23 order of March 1st, 2005, will be able to sit in on 24 that session.
25 We will ask a few questions. We have done NEAL R. GROSS COURT REPORTERS AND TRANSC-RDERS 1323 RHODE ISLAND AVE., N.W.
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1578 1 our best to maximize the public hearing here. This 2 closed session for the proprietary questions will 3 probably last, maybe an hour. I don't know, maybe an 4 hour and a half or -15 minutes, that is what we are 5 thinking.
6 At which point we will then reconvene in 7 public session. So if you want to stay, hang around 8 for that time frame, please do. But that is our plan 9 so far. So right now we are adjourned until 10 of the 10 hour.
11 (Whereupon, at 1:43 p.m., the above-12 entitled matter was adjourned, to be reconvened after 13 the proprietary session.)
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1608 1 CHAIR KARLaIN: The Atomic Safety and 2 Licensing Board for this uprate request is now back in 3 session. We have now completed the questioning of all 4 the witnesses, and we -appreciate the time, and 5 attention, and preparation they have given to this.
6 It is helpful to us, in trying to reach a 7 decision in this matter. As the lawyers know this has 8 been a relatively unusual proceeding in the sense that 9 it is the first subpart L proceeding ever held in the 10 NRC.
11 Normally in courtroom setting you see the 12 lawyers doing the work, and asking the questions of 13 the witnesses, and the pro se representatives, they 14 would ask the questions, and we would sit back and 15 listen, and learn, and maybe ask a few questions of 16 our own.
17 Because of the new rules created by the 18 Commission, in an attempt to expedite the process, and 19 also to get the Board to take a-more active role in 20 pursuing questions, we have asked the questions over 21 the last two days.
22 I think we have asked some of the 23 questions that we think are right, that will help us 24 reach a decision, and these are all built upon the 25 written testimony that was filed by all the parties, NEAL R. GROSS 1323 RHODE ISLAND AVE.. N.W.
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1609 1 direct and rebuttal. And a lot of effort went into 2 that, and we appreciate that.
3 Where do we go from here? The court 4 reporter will generate a transcript of this 5 proceeding. And the parties are welcome to, and can 6 order a copy of it. And, obviously, I think all 7 parties should do so.
8 We are going to give you 20 days from 9 today's date to submit any transcript corrections, 10 errata, this sort of thing, that may be appropriate, 11 or necessary. At that same day, 20 days, the record 12 in this matter, the evidentiary record in this matter 13 will close.
14 Also if there are any corrections in terms 15 of the numbering of exhibits, and anything like that, 16 please get us that information before the 20th day, 17 because on that day the record, the evidentiary record 18 closes.
19 Next what happens is we have issued a 20 revised scheduling order, some time ago. And that 21 order lays out that 30 days after the close of the 22 evidentiary hearing, 30 days after today, the parties 23 are to submit proposed findings of fact, and
- 24 conclusions of law to us.
25 That is also set out in a regulation, in' NEAL R. GROSS 1323 RHODE ISLAND AVE., N.W.
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1610 1 the ubiquitous subpart L regulations, that we are 2 working under. And I think it is 2.1209, which says 3 each party shall file written post-hearing proposed 4 -findings of fact and conclusions of law, on the 5 contentions addressed at the oral hearing, within 30 6 days of the close of the hearing.
7 So that is what I would like you all to 8 do. And when you do that, and this will help us in 9 making our decision, and understanding your case, cite 10 chapter and verse of the transcript, the testimony, 11 and the exhibits that support what you contend are the 12 findings of fact and conclusions of law we should 13 reach.
14 I mean, if you don't help us in that way 15 we- are going to have a hard time following your 16 proposals. So please cite, as fully as you can, to 17 the record here, in your proposals.
18 Because when we arrive at a decision we 19 want to cite to the record, and the exhibits, and that 20 sort of thing, so we can support that decision. So 30 21 days from today please submit the proposed findings of 22 fact and conclusions of law.
23 At that point, you know, we will take what 24 we've heard, we will take the evidence that we have 25 seen, and submit it, we will take what you have NEAL R. GROSS
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1611 1 submitted, and then we will render our decision.
2 We will sit down, we will think it out, we 3 will work it out, and we will write a decision, and 4 then we will issue it.
5 I guess we are talking a month from now 6 when we get the proposed findings of fact and 7 conclusions of law. Undoubtedly it will be a month or 8 two later than that before you will see a decision 9 from us, but that is what we will be shooting for.
10 And with that, are there any questions, or 11 additional issues that any of the parties need to 12 raise? Mr. Shadis?
13 MR. SHADIS: Yes, if it is possible we 14 would greatly appreciate the production of a redacted 15 transcript of the proprietary session?
16 CHAIR KARLIN: Well, I think that might be 17 possible. Mr. Travieso-Diaz, any concerns about that?
18 MR. TRAVIESO-DIAZ: I'm not sure whether 19 it can be separated. The questions that were asked 20 here, whether they are proprietary and the non-21 proprietary portions can be separated.
22 For example, the question that Mr.
23 Casillas replied to, by drawing a diagram, and doing 24 an extensive discussion, I don't believe that that 25 could be separated between proprietary and non-K) NEAL R.GROSS
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1612 1 proprietary portions.
2 CHAIR KARLIN: Well, I think you may be 3 right. The questions we asked in the proprietary 4 session were relatively limited, in less than 45 5 minute session. And almost all of them were focused 6 on specific proprietary matters. A redaction might be 7 totally useless.
8 We will take that under consideration and 9 see if it can be done. But I don't know that that is 10 really going to work. Staff, do you have anything to 11 say about that?
12 HR. HAMRICK: Nothing further on that, no.
13 CHAIR KARLIN: We will take that under 14 consideration.
15 MR. SHADIS: Thank you, it would be 16 helpful to us even if it were portions of the 17 questions so that we had a general idea of --
18 CHAIR KARLIN: Well, that is one problem.
19 The questions actually refer to portions of the 20 proprietary data, and interposed to them. Almost all 21 of those questions are actually of that nature.
22 MR. SHADIS: Thank you.
23 CHAIR KARLIN: But we will think about it 24 and see if it might work.
25 MR. SHADIS: Thank you.
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1613 1 CHAIR KARLIN: Anything else?
2 MR. HAMRICK: One point, Your Honor.
3 2.1203 talks about the Staff's hearing obligations.
4 And it talks about our continuing obligation to update the hearing. Well, I just want to clarify for the 6 record that now that the hearing has occurred, that 7 the Staff is obligated --
8 CHAIR KARLIN: Yes, the hearing has 9 occurred. That obligation, as far as I would 10 understand it, is terminated. You have completed that 11 obligation. Thank you.
12 MR. TRAVIESO-DIAZ: And, likewise, I 13 believe we discussed that at one of the pre-hearing kj) 14 conferences. But the discovery obligations are also 15 terminated, right?
16 CHAIR KARLIN: That is right. The 17 discovery, duty to produce documents, it applies to 18 all the parties, is also terminated effective today.
19 That is a good point, thank you for that.
20 Anything else?
21 HR. TRAVIESO-DIAZ: One question. I 22 didn't hear you mention reply findings. I presume 23 that there is no provision for those?
24 CHAIR KARLIN: No. All right, they very 25 much, we are adjourned.
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1614 1 (Whereupon, at 3:01 p.m., the above-2 entitled matter was concluded.)
3 4
5 6
7 8
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CERTIFICATE This is to certify that the attached proceedings before the United.-States Nuclear Regulatory Commission in the matter of:
Name of Proceeding: Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc.
Hearing Docket Number: 50-271-OLA Location: Newfane, Vermont were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
-.1 Crissy Willis Official Reporter Neal R. Gross & Co., Inc.
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