ML072140013
| ML072140013 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 07/26/2007 |
| From: | Travieso-Diaz M Entergy Nuclear Operations, Entergy Nuclear Vermont Yankee, Pillsbury, Winthrop, Shaw, Pittman, LLP |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-271-LR, ASLBP 06-849-03-LR, RAS 13948 | |
| Download: ML072140013 (13) | |
Text
July 26, 2007 UNITED STATES OF AMERICA DO-KETED NUCLEAR REGULATORY COMMISSION USNRC July26, 2007 (10:47am)
Before the Atomic Safety and Licensing Board OFFICE OF SECRETARY RULEMAKMIGS AND In the Matter of ) ADJUDICATiONS STAFF
)
Entergy Nuclear Vermont Yankee, LLC ) Docket No. 50-271-LR and Entergy Nuclear Operations, Inc. ) ASLBP No. 06-849-03-LR
)
(Vermont Yankee Nuclear Power Station) )
ENTERGY'S RESPONSE TO NEW ENGLAND COALITION'S SUPPLEMENT TO OPPOSITION TO ENTERGY'S MOTION FOR
SUMMARY
DISPOSITION OF NEW ENGLAND COALITION CONTENTION 3 (STEAM DRYER)
Pursuant to the Atomic Safety and Licensing Board ("Board")'s July 13, 2007 Order (Granting Motion to Defer and Setting Schedule), Applicants Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. (collectively "Entergy") provide this response to "New England Coalition, Inc.'s (NEC) Supplement to Opposition to Entergy's Motion for Summary Disposition of New England Coalition Contention 3 (Steam Dryer)" ("NEC's Supplement"), dated July 19, 2007. NEC's Supplement provides no factual information or legal arguments that would render summary disposition inappropriate and provides no additional support for NEC's previous response in opposition to Entergy's April 19, 2007 Motion for Summary Disposition of New England Coalition's Contention 3 (Steam Dryer) ("Entergy's Summary Disposition Motion").' Because NEC's previous response provided no basis for denying summary disposition of this contention, Entergy's Summary Disposition Motion should be granted.
New England Coalition, Inc.'s (NEC) Opposition to Entergy's Motion for Summary Disposition of NEC's Contention 3 (Steam Dryer), dated May 9, 2007 ("NEC's Opposition to Summary Disposition Motion"). NEC also filed, on May 18, 2007, an unauthorized response to the NRC Staff's response to Entergy's Summary Disposition Motion. The Staff moved, on May 29, 2007, to strike NEC's unauthorized filing, and a ruling on that motion is pending.
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I. THE MAY 2007 STEAM DRYER INSPECTION RESULTS, WHILE REASSURING, ARE NOT RELEVANT TO THE ISSUES RAISED IN NEC CONTENTION 3 A. STEAM DRYER INSPECTIONS DURING THE CURRENT LICENSE PERIOD ARE IRRELEVANT TO CONTENTION 3 IN THIS PROCEEDING NEC Contention 3, as admitted by the Board, reads:
Entergy's License Renewal Application Does Not Include an Adequate Plan to Monitor and Manage Aging of the Steam Dryer During the Period of Extended Operation.
Memorandum and Order (Ruling on Standing, Contentions, Hearing Procedures, State Statutory Claim, and Contention Adoption), LBP-06-20, 64 N.R.C. 131, 187 (2006), ("LBP-06-20"),
emphasis added.
By its very terms, and because of the limited scope of this license renewal proceeding, NEC Contention 3 deals solely with the adequacy of the program that Entergy proposes to implement to manage aging of the steam dryer through a course of monitoring and inspections during the license renewal period after 2012. NEC's Supplement simply questions the favorable results of the recent steam dryer inspection during refueling outage 26 ("RF026") in May 2007, which identified no fatigue-induced cracks in the dryer, and does not address the programmatic adequacy of the measures that will be implemented during the period of extended operation.
Indeed, NEC's Supplement does not even mention the aging management program Entergy proposes to implement during the license renewal period, but simply seeks to litigate the current condition of the steam dryer.
However, in admitting NEC's Contention 3, the Board emphasized that arguments about dryer performance during the current licensing period are irrelevant to this proceeding:
[S]ince Entergy's existing license continues until 2012, its application for a license renewal necessarily only involves aging management matters after that date. Steam dryer monitoring and inspection plans for the time period prior to 2
2012 are not directly relevant to, nor dispositive of, our ruling on NEC Contention 3 except to the extent that Entergy's license renewal application, or other materials properly before this Board at this stage in the proceeding, indicates a commitment to continue existing programs.
Id. at 189, emphasis in original.
Also, under the terms of the existing license, Entergy is required to report to the NRC the results of its post-uprate steam dryer inspections starting with the recently completed inspection during RF026 in May 2007. See paragraph M.6 of VY license, included in Exhibit 2 to John R.
Hoffman's April 18, 2007 Declaration in support of Entergy's Summary Disposition Motion
("Hoffman Decl."). Therefore, if fatigue-induced cracks were identified during those inspections, 2 they would be subject to review by the Staff and would need to be addressed through appropriate corrective and preventive actions, so they would not remain a concern during the license renewal period. Without any discussion of the aging management program, NEC's questioning of dryer inspections under the current license has no relevance to NEC's Contention 3 and lends no support to NEC's contention.
B. THE ADEQUACY OF THE ANALYTICAL METHODS USED IN IMPLEMENTING THE VY EXTENDED POWER UPRATE IS NEITHER ESTABLISHED NOR DISPROVED BY THE RESULTS OF THE MAY 2007 STEAM DRYER INSPECTION In admitting NEC Contention 3, the Board found that the following statements in the Declaration of Dr. Joram Hopenfeld 3 submitted in support of NEC's petition to intervene "demonstrated a 'genuine dispute' under the standards of 10 C.F.R. § 2.309(f)(1)(vi)":
[T]he management of cracking at the steam dryer will be in accordance with current guidance per NUREG 1801, GE-SIL-644 and possibly future guidance from BWRVIP-139, if approved by NRC. No matter which guidance Entergy follows, the status of the existing dryer cracks must be continuously monitored and assessed by a competent engineer.
2 As further discussed below, no fatigue induced cracks were identified in the May 2007 steam dryer inspection, and NEC's "expert" did not opine that My were actually found.
Declaration of Dr. Joram Hopenfeld (May 12, 2006) ("Hopenfeld Decl.").
3
Entergy's proposed monitoring techniques are not adequate to detect crack propagation and growth because they are not based on actual measurements of crack initiation and growth. Instead, Entergy relies on unproven computer models and moisture monitors which only indicate that the dryer was already damaged.
The estimated fatigue loads on the dryer are based on theoretical calculations of two computer models: the [CFD] Model and the [AC] Model. Neither the CFD nor the ACM were benchmarked against properly scaled dryer structure and therefore their predictions are subject to large uncertainties.
LBP-06-20, 64 N.R.C. 131, 190 (2006), quoting Hopenfeld Decl., ¶¶ 18-19. However, the computer models cited by Dr. Hopenfeld were only used to estimate the peak loads on the steam dryer as part of the analysis supporting the uprate, and the proposed program for monitoring and managing the aging of the VY steam dryer during the period of extended plant operation neither requires the use of computer models nor relies on the result of analyses using those models.
Hoffman Decl., %¶11, 19, 24, 30. Nothing in NEC's Supplement or its supporting "Second Declaration of Ulrich Witte" ("Witte's Second Declaration") provides any indication that VY is using the computer models in managing the aging of the steam dryer. To the contrary, Witte's Second Declaration and the materials it attaches show that VY is managing aging by visual inspections and evaluations of the appearance, orientation and size of indications in themselves and as compared to previous inspection results. This is consistent with the requirements of the current license and with the aging management plan for the dryer set forth in the VY license renewal application. See Hoffman Decl., T¶ 20-23, 25.
In addition, neither NEC's Supplement nor Witte's Second Declaration include any factual assertions supporting Dr. Hopenfeld's claims that the computer model stress predictions used in the uprate analysis are unreliable. Indeed, as discussed later, after having reviewed the video of the steam dryer inspections and images of the indications, the indication notification reports, the engineering evaluations of those indications, and the corrective action reports, 4
Witte's Second Declaration makes no claim that fatigue-related cracking is occurring. Thus, NEC's Supplement fails to provide any support for this aspect of NEC's contention.
II. THE RESULTS OF THE MAY 2007 STEAM DRYER INSPECTION RAISED NO ISSUES THAT WOULD PRECLUDE
SUMMARY
DISPOSITION OF NEC CONTENTION 3 NEC's Supplement does not raise any issues arising from the May 2007 inspection that that would require adjudication at a hearing or preclude summary disposition of the contention.
A. NEC'S "EXPERT" IS NOT QUALIFIED TO OPINE ON THE EXISTENCE OF FATIGUE-INDUCED CRACKS IN THE VY STEAM DRYER NEC's Supplement is supported solely by Witte's Second Declaration. Mr. Witte avers that his background is in the areas of "configuration management, engineering design change controls, and licensing basis reconstitution." Witte's Second Declaration, ¶ 1. He further states that his experience "has generally focused on assisting nuclear plant owners in reestablishing fidelity of the licensing and design bases with the current plant design configuration, and with actual plant operations." Id. Nowhere in his Second Declaration does Mr. Witte indicate that he has any experience whatsoever in the design, analysis, or inspection of steam dryers.4 The absence of any credentials in this area makes Mr. Witte unqualified to render expert opinions on the condition of the VY steam dryer and his statements in his Second Declaration should be given no weight. See, e.g., Florida Power & Light Co. (Turkey Point Plant, Units 3 and 4), LBP-86-23, 24 NRC 108, 116 (1986); Duke Cogema Stone & Webster (Savannah River Mixed Oxide Fuel Fabrication Facility), LBP-05-04, 61 NRC 71, 81 (2005); Pacific Gas & Electric Co.
4 Also, no indication that Mr. Witte possesses any experience or qualifications with respect to steam dryer performance is found in his extensive curriculum vitae, attached as Exhibit A to his first Declaration in support of NEC's Opposition to Entergy's Motion for Summary Disposition of NEC Contention 4 (Flow-Accelerated Corrosion), filed on July 16, 2007.
5
(Diablo Canyon Nuclear Power Plant, Units I and 2), LBP-78-36, 8 NRC 567, 569-74 (1978).
Accordingly, NEC's Supplement is without factual or expert opinion support.
B. NEC'S "EXPERT" PROFFERS NO OPINION THAT FATIGUE-INDUCED CRACKS WERE IDENTIFIED DURING THE MAY 2007 STEAM DRYER INSPECTION.
Mr. Witte's Second Declaration offers a number of observations, questions, and concerns relating to his review of the records (including videotapes) of the May 2007 steam dryer inspection at Vy. 5 When all is said and done, however, Mr. Witte does not opine that any fatigue-induced cracks have developed in the VY steam dryer. The sum total of his conclusions is that "I have not reviewed analysis from which I could conclude that none of these new cracks or incidences of crack growth or change were fatigue induced." Witte's Second Declaration, I 18. In other words, based on his documentation review, he cannot assert that any fatigue-induced cracks have developed at the VY steam dryer. 6 A statement by an expert that he cannot tell whether a deficiency exists does not support an allegation that the deficiency does exist. A 5Mr. Witte refers to what he claims to be certain documentation inconsistencies, which are actually non-existent.
For example, he states that flaws reported in four of sixteen Indication Notification Reports were further evaluated in two GE Nuclear Energy Reports, and that Entergy has not produced GE's assessment of flaws identified in the other twelve. Witte's Second Declaration, ¶ 7. Since Mr. Witte states that he reviewed all the relevant Indication Notification Reports as well as Corrective Action Reports, he is or should be aware that most inspections did not identify any discernible change in indications that had been identified in the 2005 refueling outage. Accordingly, there was no need for additional evaluations by GE. Thus, NEC's insinuation that there may be additional GE reports evaluating the indications from the 2007 outage is baseless.
Mr. Witte's assertions in paragraph 8 of his Second Declaration are similarly misleading. He states that VY Engineering Report VTY-RPT-07000-1 1. Rev. 2 references a 2005 GE evaluation, which he points out does not cover a new indication found in the 2007 inspection. The VY Engineering Report in question, which is part of Exhibit A to NEC's motion, evaluates that new indication and references the 2005 GE evaluation only with respect to the remainder of the indications, which were previously identified in the 2005 outage and showed no sign of growth. Once again, NEC's attempt to manufacture a documentation issue has no foundation in fact.
Most importantly, despite'Mr. Witte's (groundless) claims of documentation discrepancies, his Second Declaration does not point to any actual physical conditions in the steam dryer that would indicate that fatigue-induced cracks have developed.
6 Mr. Witte's inability to identify any fatigue-induced cracks in the VY steam dryer is not surprising, given that experienced inspectors and analysts at VY and at General Electric Co., the steam dryer manufacturer, found no fatigue-induced cracks during the May 2007 dryer inspection. Se, e~. Attachment A hereto, Entergy's Engineering Report No. VY-RPT-07-0001 I (Rev. 2, June 15, 2007), entitled "Evaluation of New RF1026 Steam Dryer Indication." (As noted above, this report is part of Exhibit A to Witte's Second Declaration. It was transmitted belatedly by NEC to the Board and parties in one of eight e-inails sent on July 24, 2007, and was included in the document transmitted as "Part 3 or 8").
6
party opposing summary disposition of a cotttention has the responsibility of providing something more than suspicions or bald assertions as the basis for any purported dispute of material fact. Private Fuel Storage, L.L.C. (Independent Spent Fuel Installation), LBP-99-35, 50 NRC 180, 194 (1999), ciin Advanced Medical Systems, Inc. (One Factory Row, Geneva, Ohio 44041), CLI-94-6, 39 NRC 285, 306-07, aff'd, Advanced Medical Systems, Inc. v. NRC, 61 F.3d 903 ( 6 th Cir. 1995).
The sole basis for NEC requesting leave to file a supplementary response to Entergy's Motion for Summary Disposition was that the results of the May 2007 steam dryer inspection could contradict Entergy's contention that fatigue-induced cracking of the VY steam dryer is not occurring. See New England Coalition, Inc.'s (NEC) Motion to Withhold Decision of Entergy's Motion for Summary Disposition of New England Coalition Contention 3 (Steam Dryer), dated June 19, 2007 at 2. Neither NEC's Supplement nor Witte's Second Declaration contain anything that does contradict Mr. Hoffman's assertions that "only superficial cracks have been observed in the VY steam dryer and those cracks have not shown any measurable growth in the successive dryer inspections," Hoffman's Decl., ¶ 28, and that "fatigue-induced cracking of the VY steam dryer is not occurring." Id., ¶ 18. NEC's Supplement does not identify any relevant disputed questions of fact, nor does it provide any expert opinion that could give rise to litigable issues.
III. CONCLUSION Neither NEC's May 9, 2007 Opposition to Entergy's Motion for Summary Disposition nor NEC's Supplement raises issues of material fact with respect to NEC's Contention 3 that 7
warrant adjudication. For the reasons discussed above and in Entergy's Motion for Summary Disposition, Entergy is entitled to a decision as a matter of law on that contention.
Respectfully Submitted, David R. Lewis Matias F. Travieso-Diaz PILLSBURY WINTHROP SHAW PITTMAN LLP 2300 N Street, N.W.
Washington, DC 20037-1128 Tel. (202) 663-8000 Counsel for Entergy Dated: July 26, 2007 8
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )
)
Entergy Nuclear Vermont Yankee, LLC ) Docket No. 50-271-LR and Entergy Nuclear Operations, Inc. ) ASLBP No. 06-849-03-LR
)
(Vermont Yankee Nuclear Power Station)
CERTIFICATE OF SERVICE I hereby certify that copies of"Entergy's Response to New England Coalition's Supplement to Opposition to Entergy's Motion for Summary Disposition of New England Coalition Contention 3 (Steam Dryer)," dated July 26, 2007, were served on the persons listed below by deposit in the U.S. Mail, first class, postage prepaid, or with respect to Judge Elleman by overnight mail, and where indicated by an asterisk by electronic mail, this 2 6thth day of July, 2007.
- Administrative Judge *Administrative Judge Alex S. Karlin, Esq., Chairman Dr. Richard E. Wardwell Atomic Safety and Licensing Board Atomic Safety and Licensing Board Mail Stop T-3 F23 Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001 ask2(-nrc.gov rew@,nrc.gov
- Administrative Judge *Secretary Dr. Thomas S. Elleman Att'n: Rulemakings and Adjudications Staff Atomic Safety and Licensing Board Mail Stop 0-16 CI 5207 Creedmoor Road, #101, U.S. Nuclear Regulatory Commission Raleigh, NC 27612. Washington, D.C. 20555-0001 tse(-n rc.gov; elleman~c-heos.ncsu.edu secy@nrc.gov, heari.ngdocket(&Tnrc.gov
Office of Commission Appellate Adjudication Atomic Safety and Licensing Board Mail Stop 0-16 CI Mail Stop T-3 F23 U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Washington, D.C. 20555-0001
- Lloyd B. Subin, Esq. *Sarah Hofmann, Esq.
- Mary C. Baty, Esq. Director of Public Advocacy Office of the General Counsel Department of Public Service Mail Stop O-15 D21 112 State Street - Drawer 20 U.S. Nuclear Regulatory Commission Montpelier, VT 05620-2601 Washington, D.C. 20555-0001 Sarah.hofinlann(c-istate.vt.us lbs3@.nrc.grov; mcblh cInrc.gov
- Anthony Z. Roisman, Esq. *Ronald A. Shems, Esq.
National Legal Scholars Law Finn *Karen Tyler, Esq.
84 East Thetford Road Shems, Dunkiel, Kassel & Saunders, PLLC Lyme, NH 03768 9 College Street aroisman(c.national le galscholars.com Burlington, VT 05401 rshems(ciisdkslaw.com ktylerr-)sdkslaw.com
- Peter C. L. Roth, Esq. *Marcia Carpentier, Esq.
Senior Assistant Attorney General Law Clerk State of New Hampshire Atomic Safety and Licensing Board Panel Office of the Attorney General Mail Stop: T-3F23 33 Capitol Street U.S. Nuclear Regulatory Commission Concord, NH 03301 Washington, DC 20555-0001 Peter.Rotl aVdoi.nh.gov mxc7(dnrc.gov Matias F. Travieso-Diaz 2
9.1 ENGINEERING REPORT COVER SHEET &..1NSThUCi1ONS.
ATTACHMENT
.ATT-ACHMMENT9-9,1 ENG.N, EERI!NG REPO.RT CO VER.SHE9.T &..INSTR.UC.TIONS SHEET 1.OF 2 Engineering Report-No.-- --VY-RPT-07-OOO f -- Rev Page 1 of 3
-En.atergy- . ENTERG.Y NUCLEAR Engineering Report Cover Sheet Engineering ReportTitle:
EVALUA-TION OFNEW RF026 STEAM:DRYER INDICATION Engineering Report Typeý New ID Revision E' Cancelled . -Superseded . -
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Evaluation of Steam Dryer Indication Introduction During RF026 steam dryer visual inspections, flaw indications were reported in the dryer end plates for the internal vane assemblies. Most of these:indications were previously identified in RFO5 and were evaluated by GE. as being acceptable, to leave as is per Reference 1.1 The intent of this paper is to evaluateone new. indic~tio.n identified di ing RF026 and determine whefther it should be accepted as is.
Discussion One new jiniatio.,was.:.found adjacent: to weld HB-V04, located oa,ba.n B: .atdie .0° end and is labeled as the P indication on' INR-IVVtNVYR26&07-10 Rev. [ Reference 2).
This indicationis of similar. appearance, oiientation and.sizel as those previau*ly .seon.
Because, of thisit is being -treated similar to those indications. identified in RF025. The remainder of indic4ations o the starm dryer .isted as. References 1-10 were pre'qv!usly identified and Show no signs of growth. These indications are acceptable tQoeave 'as :is "perGE evauationr GENE-0000-004712767 (Reference 11) performed. in RF025.
Therefore, the-oie tlew indication deseribed, above is the only one'reqairing an evaluation.
It should be mentioned that not,all. indications, identified in'RF025 were- e-identified i4 RF026. The reons for this varywbum can. be, the limitations of the equipnment..cru
.,layers maskdng,.ie s-face of the indication ox the technique of different :examiners.
Evaluation of fndicatioifi GE's.evaluation in RUO2S cites 1G5CC as being thze lJ*ely cause of most of the!
indications previously observed. This is. based on the jagged appearape aud Iocation in the weld heat affected Zone, (IHAZ),. The =n"t end-plates, may have cold work resu-lting from. cold formiing. Cold working Type 304 material Can promote initiation of stress corrosion cracks When exposed to the' BWR enviionment. The dryer unit end plates are lopated in the. dryr. i-ntior and tre not subjectedto any:dhirct main ste*mlina.. acu.stic loading, Contuited growth is.unikely bec.a.use all of hese indIctiopn appear t.o hae stopped without; propagatng into ihe verticl weld; this is 'indicative of IGSCC behavior as opposed to fatigue, since weld material is, more resistant. to IGSCC.. The flanges:have experienced a iear infinite number of fluictuating load cycles and if fktiguei drIvenA, mote significant. crm ng is: likey to lave occurred. after many years of operatiom, IG .CCin steam dryersfhas .bee typipally limited in depth and length since in' many ases it i~s caused'by cold work or weld. induced residual stress.
The dyer unit end plate, with the indication, is securely attached and captured within the structure oflth.esteam dryer bank assembly, The vertical edge s of thesie end plates are attached:to: the dryer-assembly with:3/16"' fillet welds, each weld. approximately 48" long.
There were no relevant ihdications reported in these vertical welds. The.geometric configuration of the unit end plates is such that the steam dryer assembly mechanically captures the upperarnd lower edges. The reported horizontal indications were seen in the
.inlet side end plate flange. The vanes, prevent inspection of the central endplate surface,
_ b. ut-inspectionof-the-outlet-side end.plate.flange~s..at-both oations-fomd-no-ind cations- -
If it-is postulated that the end plate horizoiltal indications propagate across the entire.
8.75" unit end plate width including both the inlet and outletside flange, such full width, through-thick-ness cracks would have no structural impact Nor is there any concern for loose parts. The separated end plate sectios ar.e1sill attached and will continue to.
function.
Safety. B _V .
Tho steam dryer assembly has no s.fety jknction., Se BWRVIP-06A for additional discussion of steam dryor assembly safety, The flaw indications. reported in :the stem dryer INR's from RF026 will not likely result in any lost parts at operating conditions.
Therefore, there is no safety concern with continued operation with the Reference 1-10 indications left as is.
Conclisions:i-nd.Recommendations The,dryer unit end pib.tes flaw assessWmenit is baged -o the following factrs: (1).. it is. a highly redundant structure -andthere is no st 1.al consequence of the cracking. and <(2.)
postulated significan.t flaw extensionlea. to"*J, flaw reaching the ul scion of the
-channel geometry would not create: the oppon'Rwity for lQose parts. Field experiencr supports this as-is operation decision. in the contest that the indications will be re-inspected at the next .otage. It is. recoxMeuded that the new visual indication. given in Reference 2 be accepted vas is. Repair is not recommended.
References I GE II-R-IVVI-VYR2,:6-07 Rev I I GE*NR-IrVVI-VYR26-07-.10 Rev.. 1
- 3. GE INR-.WVI-VYR26-07-11
- 4. OGE INR-IVYI-VYI 26-07-12
,5. GE .IN-VVl-VYR26Q7-.,3
- 66. GE INR-IVVI-VYR26-07-.4*
- 7. GE INR-IVVI-VYR26-07-1i5
- 10. GE INR-IVVI-VYR26-07-19 I1. GENE-0000-0047-2767