ML073540349
| ML073540349 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/24/2007 |
| From: | Webster R Rutgers Environmental Law Clinic |
| To: | Hawkens E Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| 50-219-LR, ASLB 06-844-01-LR, RAS 14805 | |
| Download: ML073540349 (17) | |
Text
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RUTGERS ENVIRONMENTAL LA W CLINIC 4L1*
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Newark, NJ 07102-3094 Phone: (973) 353-5695 R'utgers, e11 State LIUrversiy ofNe I
jese School of Law - Newark Fax: (973) 353-5537 August 24, 2007 VIA E-MAIL and U.S. MAIL Judge E. Roy Hawkens, Chair Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 Tialm"Ots CpfifizitaI lfy 1
ual 18 iuun Nort ffiw Pul'liG Disp1"sure Pending, r@18aso 1gireumat to I1[ C F1
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Re:
Submittal of Proposed Questions Pursuant to 10 C.F.R. § 2.1207(a)(3) Regarding AmerGen and NRC Staff Initial and Rebuttal Testimony and Filing of Cross Examination Plan and Motion To Cross-Examine And For An Extension; AmerGen Energy Company, LLC (License Renewal Proceeding for Oyster Creek Nuclear Generating Station)
Docket No. 50-219
Dear Judge Hawkens:
In accordance with 10 C.F.R. § 2.1207(a)(3), Citizens are submitting the following confidential information:
- 1. the attached questions for the Board to consider asking AmerGen and NRC staff during the hearing in September. These questions are based on AmerGen and NRC staff initial and rebuttal testimony of July 20, and August 17, 2007, respectively.
- 2. Cross-examination plan for Peter Tamburro Citizens are also filing a Motion to Cross-Examine and for An Extension and some minor corrections to the previously submitted rebuttal testimony.
Respectfully Submitted, I
JL Richard Webster cc:
Service List (with copy of nonconfidential information only)
USNRC December 19, 2007 (9:55am)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF CarterH. Strickland, Jr., Esq.+
Jul Staff Attorney Sta cstrickland@kinoy.rutgsers.edu jhi
- Admitted in New Jersey Pursuant to 1:21-3(c)
TA P (6:fe :_!IC V_ 011q ia L. Huff, Esq.*+
ff Attorney uffqkinoy.rutgers.edu Kathleen J. Shrekgast, Esq.#
Richard Webster, Esq.+
Staff Attorney Staff Attorney kshrekgast@kinoy.rutgers.edu rwebster@kinoy.rutgers.edu
+ Also admitted in New York
- Also admitted in Pennsylvania
UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY In the Matter of
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Docket No. 50-0219-LR AMERGEN ENERGY COMPANY, LLC
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ASLB No. 06-844-01-LR (License Renewal for the Oyster Creek
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Nuclear Generating Station)
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August 24, 2007
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CERTIFICATE OF SERVICE I, Richard Webster, of full age, certify as follows:
I hereby certify that on August 24, 2007, I caused Submittal of Proposed Questions Pursuant to 10 C.F.R. § 2.1207(a)(3) Regarding AmerGen and NRC Staff Initial and Rebuttal Testimony and Filing of Cross Examination Plan and Motion To Cross-Examine And For An Extension to be served via email and U.S. Postal Service (as indicated) on the following:
Administrative Judge E. Roy Hawkens, Chair (Email and U.S. Postal Service)
Atomic Safety and Licensing Board Panel Mail Stop-T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: erh(nrc.goy Administrative Judge Dr. Paul B. Abramson (Email and U.S. Postal Service)
Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: pba(qnrc.gov I
Administrative Judge Dr. Anthony J. Baratta (Email and U.S. Postal Service)
Atomic Safety and Licensing Board Panel Mail Stop - T-3 F23 United States Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: aib5@nrc.gov Law Clerk Debra Wolf (Email and U.S. Postal Service)
Atomic Safety & Licensing Board Panel Mail Stop-T-3 F23 U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: DAWI anrc.gov MOTION ONLY Secretary of the Commission (Email and original and 2 copies via U.S Postal Service)
United States Nuclear Regulatory Commission Washington, DC 20555-0001 Attention: Rulemaking and Adjudications Staff E-mail: HEARINGDOCKET@NRC.GOV Office of General Counsel (Email and U.S. Postal Service)
United States Nuclear Regulatory Commission Washington, DC 20555-0001 E-mail: OGCMAILCENTER@NRC.GOV Mitzi Young (Email and U.S. Postal Service)
U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: 0-15 D21:
Washington, DC 20555-0001 E-mail: may@nrc.gov Mary C. Batty (Email and U.S. Postal Service)
U.S. Nuclear Regulatory Commission Office of the General Counsel Mail Stop: 0-15 D21 Washington, DC 20555-0001 E-mail: mcbl @nrc.gov Alex S. Polonsky, Esq. (Email and U.S. Postal Service)
Morgan, Lewis, & Bockius LLP 11 11 Pennsylvania Avenue, NW Washington, DC 20004 E-mail: apolonsky(morganlewis.com 2
Kathryn M. Sutton, Esq. (Email and U.S. Postal Service)
Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 E-mail: ksutton@morganlewis.com Donald Silverman, Esq. (Email and U.S. Postal Service)
Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 E-mail: dsilvermana@morganlewis.com J. Bradley Fewell (Email and U.S. Postal Service)
Exelon Corporation 200 Exelon Way, Suite 200 Kennett Square, PA 19348 E-mail: bradley.fewell @exceloncorp.com John Covino, DAG (Email and U.S. Postal Service)
State of New Jersey Department of Law and Public Safety Office of the Attorney General*
Hughes Justice Complex 25 West Market Street P.O. Box 093 Trenton, NJ 08625 E-mail: john.corvino@dol.lps.state.ni.us Valerie Gray (Email)
State of New Jersey Department of Law and Public Safety Office of the Attorney General Hughes Justice Complex 25 West Market Street P.O. Box 093 Trenton, NJ 08625 E-mail: valerie. gray@dol.lps.state.nj.us.
Paul Gunter (Email and U.S. Postal Service) c/o Nuclear Information and Resource Service 6930 Carroll Ave., Suite 340 Takoma Park, MD 20912-4446 E-mail: paul@beyondnuclear.or*
Edith Gbur (Email)
Jersey Shore Nuclear Watch, Inc.
3
364 Costa Mesa Drive. Toms River, New Jersey 08757 E-mail: aburl@comcast.net Paula Gotsch (Email)
GRAMMIES 205 6th Avenue Normandy Beach, New Jersey 08723 E-mail: paulagotsch@verizon.net Jeff Tittel (Email)
New Jersey Sierra Club 139 West Hanover Street Trenton New Jersey 08618 E-mail: Jeff.Tittel@sierraclub.org Peggy Sturmfels (Email)
New Jersey Environmental Federation 1002 Ocean Avenue Belmar, New Jersey 07319 E-mail: psturmfels@cleanwater.org Michele Donato, Esq. (Email)
PO Box 145 Lavalette, NJ 08735 E-mail: mdonato@micheledonatoesq.com RiMard Webster Signed:
Dated: August 24, 2007 4
PAURPORAMMVIAA
-W-VW1VFaEU1AL 7ýv UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFICE OF THE SECRETARY ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:
E. Roy Hawkens, Chair Dr. Paul B. Abramson Dr. Anthony J. Baratta In the Matter of
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AMERGEN ENERGY COMPANY, LLC
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OYSTER CREEK NUCLEAR
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GENERATING STATION
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License Renewal for Oyster Creek Nuclear
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Generating Station
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Docket No. 50-219 August 24, 2007 CITIZENS' PROPOSED QUESTIQNS REGARDING AMERGEN AND NRC STAFF INITIAL AND REBUTTAL TESTIMONY PRELIMINARY STATEMENT In accordance with an Order from the Atomic Safety and Licensing-Board (the "Board"), dated April 17, 2007, these proposed questions for the Board to ask witnesses from AmerGen Energy Company LLC ("AmerGen") and the NRC Staff are submitted on behalf of Nuclear Information and Resource Service, Jersey Shore Nuclear Watch, Inc.,
Grandmothers, Mothers and More for Energy Safety, New Jersey Public Interest Research Group, New Jersey Sierra Club, and New Jersey Environmental Federation (collectively "Citizens").
1
PROPOSED QUESTIONS Proposed Questions for NRC Staff A. Purpose The purpose of the questioning is to:
i) establish whether the Current Licensing Basis ("CLB") includes meeting the ASME criterion that the factor of safety for buckling must be 2.0 or greater; ii) establish whether the CLB includes the GE sensitivity analysis; iii) establish that the aim of the acceptance criteria is to maintain compliance with the ASME code requirements and why the Staff believe the use of the least stringent local area acceptance criterion is justified; iv) establish how the local area acceptance criteria are applied to actual data; v) establish that, as applied, the acceptance criteria alleged by the witnesses could allow the shell to deteriorate to below ASME requirements (this shows that the local area acceptance criterion alleged by AmerGen and NRC staff are not actually the appropriate criterion);
vi) establish that the internal grid measurements do not represent the state of the shell in each bay because they are placed above the corroded zone in certain Bays; vii) establish why the staff and Sandia Laboratories used only the external measurements from 1992 to characterize the state of the sandbed region in each bay; viii) establish that the Sandia Study does not show that the drywell shell currently meets the ASME code; ix) establish whether the staff believes the Hausler contour plots provide a reasonable interpretation of the data; x) establish whether, if the areas of severe corrosion were as depicted in Calc. 24 Rev 2, the factor of safety would also be less than 2.0; xi) establish that the UT monitoring program does not and will not accurately define the extent of areas thinner than 0.736 inches; xii) establish whether NRC staff believe that revision 2 of the 24 Calculation confirms compliance with the local area acceptance criterion; xiii) establish that it is unclear whether the thinnest areas of the drywell shell have been measured; xiv) establish that the combined potential future corrosion rate has not been well estimated; xv) establish whether NRC staff believe that the lower 95% confidence limit of the thickness data should be compared to the acceptance criteria; xvi) establish whether Staff believes AmerGen's allowance of 0.01 inches for potential systematic error is reasonable; and xvii) establish that NRC has determined that corrosion during the period of extended operation is possible; 2
B. Proposed Questions
- 1.
Does the NRC Staff acknowledge that the CLB for Oyster Creek requires the drywell to meet the requirement for a safety factor of 2.0 during refueling contained in the ASME code?
IF YES, skip to Q.3, IF NO, ask:
- 2.
Wasn't the purpose of the GE modeling of a uniformly thick sandbed in 1992 to provide assurance that this ASME requirement was met? (ref. to Staff Initial Test. at A7.)
- 3.
Is there any official correspondence that shows that the cut out areas depicted in the GE sensitivity analysis were incorporated into the CLB?
IF NO to 3, skip to Q.5, if YES ask:
- 4.
Please describe that correspondence.
- 5.
Did the GE sensitivity analysis use cut outs that were 9 feet by 4.5 feet at the extreme edge-of one side of a Bay?
- 6.
Is the purpose of the'acceptance criteria for the UT data to ensure that the ASME required factor of safety is 2 or more?
- 7.
If not why not.
- 8.
Did the GE model predict that the factor of safety would be 2.0 for a uniform 0.736 inches thick sandbed in the most critical scenario? (ref. to AmerGen Ex. 3 at 6-9)
- 9.
If not why not?
- 10.
How does allowing the mean to be 0.736 inches, and the cut out area within each Bay to be 9 feet by 9 feet, ensure that the ASME required factor of safety of 2 ismaintained, when the modeled area reduced the factor of safety by 9.5%?
- 11.
If the extent of the areas thinner than 0.736 inches goes beyond the spatial envelope of the 9 feet by 9 feet tray in any dimension, would that mean that the drywell no longer meets the acceptance criteria?
- 12.
If not why not.
- 13.
Isn't it true that in certain Bays the corrosion occurred below the level at which the internal grids were taken? (ref Citizens' Ex. 46 at OCLR29744-46)
- 14.
Doesn't that mean that in some Bays the means of the internal grids do not represent the mean thickness of the Bay? (ref. Citizens! Ex. 46 at OCLR29745-46)
- 15.
How did the Sandia Report use the 1992 external measurements as inputs?
16, Why did the Staff in conjunction with Sandia decide to use the external measurements and not the internal grids when undertaking the Sandia Report?
3
- 17.
Staff has stated that if Dr. Hausler's contour plots are correct, the safety factor would be around 1.9, please outline how Staff reached this conclusion?
- 18.
Can you estimate the factor of safety if AmerGen's assessment of the extent of the areas thinner than 0.736 inches given in Calc. 24 Rev 2is correct?
If YES ask "What is that factor?" and skip to 19, IF NO ask:
- 19.
Are the areas outlined in Calc 24 rev 2 generally larger or smaller than those given on the Hausler plots?
- 20.
So would the safety factor be bigger or smaller if the assessment in Calc 24 rev 2 is correct?
- 21.
Do you believe the Hausler contour plots to be a reasonable way to interpolate the available data?
- 22.
If yes, please explain your answer, if no, how can the available data be better interpolated to estimate the extent of the areas thinner than 0.736 inches?
- 23.
How accurately do you believe the UT monitoring program allows you to estimate the extent of the areas thinner than 0.736 inches?
- 24.
Citizens have argued that because Calc 24 rev 2 shows a 9 feet by 9 feet area Bay 1 that has an average thickness of 0.696 inches, the area thinner than 0.736 inches on average in Bay 1 is likely to be larger than 9 feet by 9 feet, if AmerGen's assessment is correct. Do you agree with this argument?
- 25.
If this argument is correct, wouldn't that mean the local area acceptance criterion will not be met at the start of any extended period of operation?
- 26.
How much confidence do you have that the thinnest areas of the drywell shell have been measured?
- 27.
Has NRC Staff estimated the range of the potential corrosion rates from the interior and the exterior?
- 28.
If so, what are ranges of those rates? If not, why not?
- 29.
What are the main problems in providing estimates of the potential future corrosion rates?
- 30.
The 95% confidence limit has been used in various ways. Taking an example, do you believe that an appropriately conservative approach to determine the current margin above the acceptance criterion for mean thickness would be to compare the lower 95% confidence limit of the available data thickness data sets in each Bay to 0.736 inches?
31:
If not why not?
- 32.
Would you use both the internal data and the external data?
- 33.
Please explain your answer.
- 34.
Staff found a systematic bias in the UT measurements taken internally in 1996, what was the magnitude of the observed bias?
- 35.
Did the 1994 results also suffer from the same problem?
4
- 36.
Do you believe the 1992 external results also suffered from the same problem?
- 37.
AmerGen has said that an allowance 6f 0.01 inches should be made for potential bias in the UT data, do you believe this is reasonable?
- 38.
Please explain your answer.
II.
-Proposed Questions for AmerGen Panel 1: John O'Rourke, Fred Polaski, Michael Gallagher A. Purpose The purpose of the questioning is to:
i) establish that forced outages where the reactor cavity has to be filled with water would likely cause water to leak on to the exterior of the drywell shell in the sandbed region.
B. Proposed Questions
- 1.
You have testified that the reactor may be forced into an outage that requires the reactor cavity, to be filled. In such an outage, would there be time for the strippable coating and tape to be applied to the cavity to minimize leakage?
- 2.
How long could such an outage last?
III.
Proposed Questions for AmerGen Panel 2: Michael Gallagher, Peter Tamburro A. Purpose The purpose of the questioning is to:
i) establish Mr. Tamburro's scope of expertise;.
ii) establish the meaning of Citizens Ex. 3 and how the issues raised were resolved; iii) establish that the Current Licensing Basis ("CLB") includes meeting the ASME criterion requiring a factor of safety for buckling to be 2.0 or greater; iv) establish whether the CLB requires the areas thinner than 0.736 inches to "highly localized;"
v) establish how the local area acceptance criteria are applied to actual data; vi) establish that the aim of the acceptance criteria is to maintain compliance with the ASME code requirements; vii) establish why the stated local acceptance criteria have changed in each revision to the 24 Calc.; and 5
viii) establish that, as applied, the acceptance criteria alleged by the witnesses could allow the shell to deteriorate to below ASME requirements (this shows that the acceptance criteria alleged by AmerGen are not actually the appropriate criteria)
B. Proposed Questions
- 1.
Mr. Tamburro, are you an expert in statistics?
IF NO skip to 3
- 2.
Mr Tamburro, in a normal distribution, how much of the data would be within a range of plus or minus one standard deviation?
- 3.
Referring to Citizens' Ex. 3, please tell us if AmerGen satisfactorily addressed item 4?
- 4.
Specifically with reference to Item 4, does Calc 24 revision 2 contain a justification that-the 9.5 reduction in buckling load would still meet the required factor of safety of 2.0?
- 5.
If yes, please indicate where this justification is provided?
- 6.
Does the CLB require the drywell shell to have a factor of safety of 2 during a refueling outage?
- 7.
Does the CLB require the extent of areas thinner than 0.736 inches tobe "highly localized"?
- 8.
Are the acceptance criteria. designed to ensure that the shell will continue to meet the ASME code requirements?
- 9.
If the spatial envelope of the corrosion in any Bay goes beyond the tray cut outs modeled in the GE sensitivity analysis in any dimension, would that mean that the local area criterion would not be met?
- 10.
Please explain your answer.
- 11.
Why did the stated local area acceptance criteria change over time?
- 12.
For example, why did Calc. 24 Rev 1 use a local area acceptance criterion requiring areas thinner than 0.736 inches to be less than 12 inches by 12 inches in extent and thicker than 0.636 inches? (ref. to AmerGen Ex. 18 at 5)
- 13.
Did any of the concerns expressed in Citizens' Ex 3 have any influence on this choice of acceptance criterion?
142 If so, which concerns had the most influence?
- 15.
Why did Calc. 24 Rev 2, written 6 months later use a less stringent local area acceptance criterion requiring areas thinner than 0.736 inches to be less than 3 feet by 3 feet in extent and thicker than 0.636 inches? (ref. to AmerGen Ex. 18 at 10-11)?
6
IV.
Proposed Questions for AmerGen Panel 3: Fred Polaski, David Harlow, Julien Abramovici, Peter Tamburro A. Purpose The purpose of the questioning is to:
i) establish that the internal grid measurements in each bay do not represent the average thickness of each bay; ii) establish how many of the points were actually ground and whether the ground area was left flat; iii) establish that the grinding should not materially change the margins or the measurements themselves; iv) establish that Calc 24 rev. 2 suggests that the extent of areas thinner than 0.736 inches is already larger than 9 square feet; v) establish that the margin beyond the local area acceptance criterion is unknown; vi) establish the basis. of the opinion that the effective stresses in the thinnest areas are 20% less than at the extremes; vii) establish that systematic error has been observed in the 1996 internal readings and alleged in the 1992 external readings; viii) establish whether the witnesses believe that AmerGen's past assessment that systematic error could be up to 0.01 inches is correct; ix) establish that the moulds taken in Bay 13 suggest the surface roughness is around 0.01 inches.
x) establish that the surface roughness does not justify the correction applied to the external data; xi) establish why scans were not carried out at each measurement location; xii) establish that the severely corroded area in Bay 1 could extend into the most sensitive area; and xiii) establish how the average thickness of the drywell in each bay can be estimated if the internal grids are not representative and the degree of bias in the external measurements is not known.
B. Proposed Questions
- 1.
In order to build a new computer model of the drywell shell, you have
- been involved in deciding what the representative thickness of each bay should be haven't you?
If NO, use Citizens Ex. 42 to remind witness of involvement. If YES refer witness to Citizens Ex. 42 and state that the next few questions will be based on that document.
- 2.
What do you think the term "representative thickness" means in this document?
7
- 3.
For the sandbed region, how did you derive the representative thicknesses for each Bay?
- 4.
Why didn't you just use the thicknesses shown by the mean of the interior grids in each bay?
- 5.
For example, for Bay 1 you selected 0.826 inches as the average thickness, but the thickness from the 7 point grid would be over 1 inch, wouldn't it?
- a. Was the estimate of 0.826 inches for the thickness of Bay 1 derived from grid measurements in Bay 19?
- b. Why did you use this value and not the values measured from the interior in Bay I?
- c. The pattern of corrosion in Bay I is totally different to the pattern of corrosion in Bay 19 isn't it? (ref. Hausler contour plots)
- d. If the pattern of corrosion in Bay 19 is different, why is the estimate of the mean thickness of Bay. 1 based on measurements taken in Bay 19 rather than the external measurements in Bay 1?
- e. Why didn't you use the thickness estimate of 0.800 inches, provided in AmerGen Ex. 18 at 14?
- f. Did you estimate the confidence intervals on the estimate of 0.826 inches?
- g. If not, why not? If so, what were those confidence intervals?
- 6.
Referring to Citizens Ex. 46, for Bay 3 the document states that "using the grid average for the entire bay would not adequately represent the corrosion below 11 '0" (Citizens' Ex. 46 at OCLR29745)
- a. Is this statement correct?
- b. How did you derive the Bay 3 representative thickness measurements?
- c. Why not use the external measurements in Bay 3 to estimate the mean thickness of Bay 3, rather than measurements in other Bays?
- 7.
How many of the external points were actually ground before external UT measurements were taken? (ref. Citizens Ex. 43)
- 8.
Was the final surface of the ground points flat?
- 9.
If not, what was the surface like?
- 10.
If the grinding was done properly, it should not have made the thinnest point any thinner should it?
- 11.
Even if the grinding removed good metal, was the area that was ground big enough so that removing that metal would affect the buckling margins?
- 12.
Please explain your answer.
- 13.
For some points in 2006, the technicians scanned over the ground area didn'tthey? (ref. AmerGen Ex. 20 at OCLR27961)
- 14.
Was this done at every location that was ground?
8
- 15.
If not, why not. If so, how many points had scan results reported in 2006?
(ref. AmerGen Ex. 20 OCLR27947-65)
- 16.
Turning to Calc 24 Rev 2, you imposed a 36 inch by 36 inch square upon a plot of the data and determined average thicknesses, didn't you? (ref.
AmerGen Rebuttal Test. Part 3 A;36)
- 17.
Referring to AmerGen Ex. 16 at 29 and 34, if the size of the evaluation square had been a few inches larger you would have concluded that Bay 1 contains an area larger than 36 inches' by-36 inches that is on average 0.696 inches thick, wouldn't you?
- 18.
Referring to AmerGen Ex. 16 at 29 what constrains the size of the bathtub ring? Couldn't the bathtub extend across the whole Bay, based on these results?
- 19.
Similarly, referringto AmerGen Ex. 16 at 95 and 99, if the size of the evaluation square had been a few inches larger you would have concluded that Bay 19 contains an area larger than 36 inches by 36 inches that is on average 0.720 inches thick, wouldn't you?
- 20.
Please explain your answer.
- 21.
By using an evaluation area that is 36 inches by 36 inches aren't you letting shapes that were chosen for modeling convenience drive the interpretation of the external data?
- 22.
Referring to AmerGen Ex. 16 at 32, did you take account of uncertainty when you concluded this profile was acceptable?
- 23.
Based on AmerGen Ex. 16 at 32, what levelof certainty do you have that the evaluated area meets the required thickness profile?
- 24.
Is it your position that the external results cannot be used to estimate the margin beyond the local area acceptance criterion?
- 25.
If not, what is AmerGen's estimation of how much corrosion would have to occur before the local acceptance criterion is violated. If so, how can AmerGen be certain that the acceptance criterion for mean thickness is the most constraining criterion?
- 26.
InAmerGen Initial Test. Part 3 A.36 you have stated that the effective stresses for the purposes of buckling are up to 20% less in the areas where the thinnest points are located. How did you derive that estimate?
- 27.
What is the difference between systematic and random error?
- 28.
Is it your position that systematic error leading to overestimation of the actual thickness of the drywell has been observed in the internal UT results in 1996 and in the external UT results taken in 1992?
- 29.
Please explain your answer.
- 30.
If most of the measurements were taken at locations that were ground flat from the exterior, how did the bias in the 1992 data arise (ref. Citizens' Ex. 51)?
- 31.
AmerGen has stated in the past that an allowance of 0.01 inches should be made for possible systematic bias. Do you believe that this is correct?
- 32. "
Please explain your answer.
- 33.
Referring to Citizens' Ex. 3, please tell us if AmerGen satisfactorily addressed item 3?
9
- 34.
Specifically with reference to Citizens' Ex. 3, Item 3, why does the evaluation thickness method use the mean plus one standard deviation of the micrometer measurements to determine an average roughness for Bay 13? (ref AmerGen Ex. 18 at 50-5 1)
- 35.
How can you justify using that average roughness for all the other Bays?
- 36.
If the interior grids are not representative of the thickness of certain Bays and the external results are not useful to estimate the thickness of each Bay, how can you make an accurate assessment of the mean thickness of each Bay?
V.
Proposed Questions for AmerGen Panel 4: John O'Rourke, Ahmed Ouaou, Francis Ray, Jon Hawkins, and Scott Erickson A. Purpose The purpose of the questioning is to establish that the water found in the bottles that catch the sandbed drainage could be from condensation.
B. Proposed Question Does the chemical analysis of the water found in March 2006 in the bottles catching the sandbed drainage allow you to conclude that condensation was not the source of that water?
VI.
" Proposed Questions for AmerGen Panel 5: Jon Cavallo, Martin McAllister, Jon Hawkins, and Scott Erickson A. Purpose The purpose of the questioning is to establish whether there are inaccessible areas of the sandbed that could not be coated or inspected.
B. Proposed Questions I.
Referring to Citizens Exhibits 40 and 41 at OCLR22257, is it possible that some areas of the exterior sandbed were never coated?
- 2.
Please explain your answer.
3.'
It is also possible that inaccessible areas have not been inspected?
.4.
Please explain your answer.
10
VII.
Proposed Questions for AmnerGen Panel 6: Barry Gordon, Michael Gallagher, Peter Tamburro, and Edwin Hosterman A. Purpose The purpose of the questioning is to establish that the potential rate of future exterior corrosion is unknown.
B. Proposed Questions
- 1.
If the coating fails and there is water in the sandbed region on the exterior, what would the corrosion rate be?
- 2.
How certain is this prediction?
VIII. Proposed Questions for AmerGen Panel 7: Michael Gallagher, and Peter Tamburro No Proposed Questions.
Respectfully submitted Richard Webster, Esq RUTGERS ENVIRONMENTAL LAW CLINIC Attorneys for Petitioners Dated: August 24, 2007 I
11
CROSS-EXAMINATION PLAN FOR PETER TAMBURRO I.
Objective Of The Examination
- 1)
Discover the motivation behind the drafting of Citizens' Ex. 3
- 2)
Discover how AmerGen responded to Citizen's Ex. 3 and whether Mr. Tamburro believes the issues raised therein have been resolved.
- 3)
Resolve inconsistencies in documents and testimony regarding the acceptance criteria.
- 4)
Establish that the latest revision to the 24 Calc. (AmerGen Ex. 16) shows that the drywell probably violates the acceptance criteria, or the margins are, at best, minimal.
- 5)
Establish that the correction technique applied to the external UT results is not justified.
II.
Proposed Lines Of Questioning
- 1)
Ask why he wrote Citizen's Ex. 3 after allowing the initial draft of the 24 Calc.
(AmerGen Ex. 17) to be relied upon for 13 years.
- 2)
Ask if he notified management he was going to submit Citizen's Ex. 3 and how they reacted.
- 3)
Ask how management responded to Citizens Ex. 3 and whether he believes the issues have been -resolved.
- 4)
Question why he has testified the full cut out modeled by GE can be used as the local area acceptance criterion when he previously said that the 9.5% reduction in buckling capacity such a cut out caused had not been shown to be acceptable.
- 5)
Show that Rev. 2 of the 24 Calc. (AmerGen Ex. 16) shows that even the most expansive version of the local area acceptance criterion is not met, by questioning
- him about the areas that are 9 feet by 9 feet and are on average thinner than 0.736 inches.
- 6)
Show that Rev. 2 of the 24 Calc.. (AmerGen Ex. 16) shows that, at best, the margins are minimal and non-existent if uncorrected data are used by questioning him about the profiles and the ways in which the 9 feet by 9 feet areas that are thinner than 0.736 inches would expand if any corrosion occurred.
- 7)
Go through the contradictions between his affidavit and, testimony and Rev. 2 of the 24 Calc. (AmerGen Ex. 16).
- 8)
Ask why he applied the correction technique to the 2006 results event though he concluded in Citzens' Ex. 3 that the technique was not properly justified.
- 9)
Using Rev. 2 of the 24 Calc. (AmerGen Ex. 16), require him to either justify why he believes that the correction technique to the raw UT data is justified or acknowledge that it is not.