ML082100169
| ML082100169 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 07/24/2008 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| SECY RAS | |
| References | |
| 50-271-LR, ASLBP 06-849-03-LR, NRC-2296, RAS M-153 | |
| Download: ML082100169 (293) | |
Text
/?AS H-(E55 Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Entergy Nuclear Vermont Yankee Docket Number: 50-271-LR; ASLBP No. 06-849-03-LR DOCKETED USNRC Location: Newfane, Vermont July 25, 2008 (1:50pm)
OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Date: Thursday, July 24, 2008 Work Order No.: NRC-2296 Pages 1451-1741 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
~O3A
1451 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3
4 ATOMIC SAFETY AND LICENSING BOARD 5 HEARING 6
7 In the Matter of:
8 ENTERGY NUCLEAR VERMONT 9 YANKEE, LLC Docket No. 50-271-LR 10 and ASLB No. 06-849-03-LR 11 ENTERGY NUCLEAR OPERATIONS, i' 12 INC. (Vermont Yankee Nuclear 13 Power Station) 14 15 Thursday, July 24, 2008 16 17 Windham County Superior Court 18 7 Court Street 19 Newfane, Vermont 20 21 BEFORE:
22 ALEX S. KARLIN, Chair, Administrative Judge 23 RICHARD E. WARDWELL, Admini.strative Judge 24 WILLIAM REED, Administrative Judge 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1452 1 APPEARANCES:
2 On Behalf of Entergy Nuclear Vermont Yankee, LLC 3 and Entergy Nuclear Operations, Inc.:
4 DAVID R. LEWIS, ESQ.
5 M4ATIAS F. TRAVIESO-DIAZ, ESQ.
6 ELINA TEPLINSKY, ESQ.
7 of: Pillsbury Winthrop Shaw Pittman LLP 8 2300 N Street, N.W.
9 Washington, D.C. 20037-1128 10 11 On Behalf of the Nuclear Regulatory Commission:
12 LLOYD B. SUBIN, ESQ.
13 DAVID E. ROTH, ESQ.
14 MARY C. BATY, ESQ.
15 JESSICA A. BIELECKI, ESQ.
16 Office of the General Counsel 17 Mail Stop - 0-15 D21 18 U.S. Nuclear Regulatory Commission 19 Washington, D.C. 20555-0001 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1453 1 On Behalf of the New England Coalition:
2 KAREN L. TYLER, ESQ.
3 ANDREW LAUBVOGEL, ESQ.
4 of: Shems Dunkiel Kassel & Saunders PLLC 5 - 91 College Street 6 Burlington, Vermont 05401.
7 8 On Behalf of the State of Vermont:
9 SARAH HOFMANN, ESQ.
10 Director for Public Advocacy 11 Department of Public Service 12 112 State Street - Drawer 20 13 Montpelier, Vermont 05620-2601 14 15 ANTHONY Z. ROISMAN, ESQ.
16 National Legal Scholars Law Firm 17 84 East Thetford Road 18 Lyme, New Hampshire 03768 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1454 1 On Behalf of the State of New Hampshire:
2 PETER C.L. ROTH, ESQ.
3 Senior Assistant Attorney General 4 State of New Hampshire 5 Office of the New Hampshire 6 Attorney General 7 33 Capitol Street 8 Concord, New Hampshire 03301 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1455 SP R O C E E D I N G S 2 8:30 A.M.
3 JUDGE KARLIN: Good morning. I'm Alex 4 Karlin. This is the fourth day of the Atomic Safety 5 and Licensing Board evidentiary hearing in the matter 6 of the application by Entergy for a license renewal 7 for 20 years for its Vermont Yankee Nuclear Power 8 Plant.
9 Today, we are proceeding with --
10 continuing on contention 4 that deals with flow-11 accelerated corrosion and we started yesterday 12 afternoon and I thought we made some progress. And 13 hopefully, we're going to try to cover everything we 14 need today. It is possible we'll have a session 15 tomorrow, but we think we can get it done today if the 16 witnesses can hopefully answer crisply our questions.
17 We'll try to ask direct questions and maybe we can get 18 this done today.
19 So with that I would like to remind the 20 witnesses that you're still under oath and if you'll 21 remember that as we proceed. I'm sure you will.
22 Is there anything from my colleagues?
23 (No response.)
24 Is there anything from counsel?
25 MR. LEWIS: Yes, Judge Karlin, I have two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1456 1 preliminary items. First, the Board had requested 2 that Entergy provide transient cycle information, the 3 actual cycles.
4 JUDGE KARLIN: Yes.
5 MR. LEWIS: We have obtained that data and 6 can pass it out now. We've produced a table and 7 marked it and I propose to pass it out and then the 8 Board can decide how they'd like to proceed with that.
9 JUDGE KARLIN: Why don't you hand it out 10 and let the-- has the other counsel seen it?
11 MR. LEWIS: Not yet.
12 JUDGE KARLIN: Okay. Absent any 13 objection, I suppose we'll bring it into the record.
14 Everyone should get a chance to look at it first..
15 (Pause.)
16 MR. LEWIS: May I approach the bench and 17 provide it to all the Board.
18 JUDGE KARLIN: Yes, Mr. Lewis, sure.
19 (Pause.)
20 JUDGE KARLIN: It's one page, right?
21 MR. LEWIS: Yes, Judge Karlin, one page.
22 Just for the record of what I've handed out it's 23 called Vermont Yankee transient counting status, July 24 23, 2008. We've marked it as A2-39 for identification 25 in case that's how the Board wants to treat it.
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1457 1 JUDGE KARLIN: All right, and what does 2 this reflect?
3 MR. LEWIS: This reflects in the left-hand 4 column, it's a three-column table. The lef t-hand 5 column is the description of the transients. The 6 middle, column is the number of cycles that were 7 actually assumed in the confirmatory analyses that 8 were performed. And the right-hand column is the 9 actual number of cycles as tracked by the plant.
10 JUDGE KARLIN: All right. Any objections 11 to -- I think this is a valuable thing that we asked 12 for this information. Absent any objections, I think 13 we're going to adm.it it as Exhibit E2-39.
14 MS. TYLER: Judge Karlin, I don't have an 15 objection to the admission of this document, but I 16 would like to note that none of the underlying 17 documentation from which they determined these numbers 18 is in the record.
19 JUDGE KARLIN: I think that's a good note,.
20 all right. So we'll admit it. Thank you for that 21 information, Ms. Tyler.
22 MR. LEWIS: The second preliminary item, 23 Judge Karlin, is -- and if you would object to the 24 witnesses for NEC using computers during their 25 questioning. We do have internet access in here and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1458 1 the witnesses' access to a computer does allow the 2 possibility of communications during the. questioning 3 which I would submit is improper.
4 In addition, witnesses are entitled to 5 have documents to refresh their recollections and with 6 a computer there's a potential they're looking at more 7 than that. I'm not saying they are. It just would 8 compromise the integrity of their questions. It is 9 the general rule as reflected in Rule 612 of the Rules 10 of Evidence that any document or material that the 11 witness takes to the stand to use t~o refresh his 12 recollection during testimony is subject to 13 examination by the other parties and by the tribunal.
14 A witness who has a computer could avoid that and so 15 we think it's just -- not suggesting the witnesses are 16 going to do anything improper, but I think it 17 challenges the integrity of their testimony.
18 JUDGE KARLIN: Well, seems to me that 19 we're using computers to try to access the huge volume 20 of material we're trying to refer to. Perhaps that's 21 what's going on.
22 Ms. Tyler, do you have any --
23 MS. TYLER: I think both Dr. Hausler and 24 possibly I'll assume Mr. Witte have the exhibits only 25 on their computer and they didn't even bring hard NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., Nw.W (202) 234-4433 WASHINGTON, D.C. 20005-3701 (202) 234-4433
1459 1 copies. That's they they're using the computers. I'm 2 not in email communication with them and I think that 3 they can represent that they're not looking at 4 anything other than the materials and that should be 5 adequate.
6 JUDGE KARLIN: All right. Let me ask Dr.
7 Hausler. Are you doing any internet, email 8 communication?
9 DR. HAUSLER: It's my understanding, 10 Judge, that there is a password for the internet and 11 I do not have the password.
12 JUDGE KARLIN: Well --
13 DR. HAUSLER: Which means I'm not on the 14 internet.
15 JUDGE KARLIN: You're not emailing anyone 16 while this is going on?
17 DR. HAUSLER: I am not.
18 JUDGE WARDWELL: Do you have the 19 capability to turn off your card, your wireless card?
20 DR. HAUSLER: I have to check that, sir.
21 I don't have a wireless card, but I probably do have 22 23 JUDGE KARLIN: I think it's sufficient --
24 DR. HAUSLER: It's not turned on.
25 MR. LEWIS: Judge Karlin, I would accept NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1460 1 the representation by the witnesses that they won't 2 use wireless Communication during testimony and I 3 guess I would also accept if they would simply 4 represent if they do use their computer to access any 5 document other than the exhibit, they identify what it 6 is that they're looking at.
7 JUDGE KARLIN: All right, let me ask the 8 witnesses that way. Will you affirm and commit that 9 you're not using anywireless communication while your 10 testimony is going on?
11 MR. WITTE: Yes, I will. I've got a 12 button here that I can turn --
13 JUDGE KARLIN: I don't care how you do it, 14 just so long as you don't do it.
15 Dr. Hausler, I guess you're --
16 DR. HAUSLER: Absolutely. That's easy.
17 I will not.
18 JUDGE KARLIN: Fine, and that the only 19 documents that you're accessing are the exhibits in 20 this case?
21 MS. TYLER: Judge Karlin, Dr. Hopenfeld is 22 looking at notes that he has before him and it's 23 possible that Dr. Hausler and Mr. Witte also have 24 notes on their computer that they're referring to 25 which I think is appropriate.
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1461 1 JUDGE KARLIN: I think we're going to let 2 it go. Everyone has got a huge pile of information in 3 front of them, documents, hard copies or whatever, and 4 I'm not going to try to figure out whether all of them 5 are exhibits or if they have anything in addition. So 6 thank you. I think we're going to let it proceed.
7 JUDGE WARDWELL: I think it be useful 8 though when you are reading from something that's 9 obviously one of our documents, if you let us know 10 what you're reading from. It's obvious --
11 DR. HAUSLER: Absolutely.
12 JUDGE WARDWELL: You know what they are, 13 but it's not so clear behind the screen.
14 JUDGE KARLIN: All right.
15 MR. LEWIS: We have no more preliminary 16 items.
17 JUDGE KARLIN: Thank you, Mr. Lewis.
18 MS. BATY: Your Honor, I have one 19 preliminary matter, clarification about Dr. Chang's 20 testimony. We have not yet offered that testimony as 21 an exhibit in this proceeding and I wanted to talk 22 with Marcia of how you would like for us to add that 23 as an exhibit in this proceeding.
24 JUDGE KARLIN: Yes, I think it should be 25 an exhibit to the proceeding rather than entered it as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1462 1 testimony.
2 MS. BATY: I will mark it as an exhibit, 3 as a staff exhibit and provide it to Ms. Carpentier.
4 JUDGE KARLIN: Okay.
5 MS. BATY: As appropriate --
6 JUDGE KARLIN: Please do. I think it 7 already had an exhibit number on it, did it not?
8 MS. BATY: Yes, it did.
9 JUDGE KARLIN: Can we use that one?
10 MS. BATY: I will stamp it and add that.
11 It will be -- probably be Staff Exhibit 2 which was 12 previously omitted because we were going to bind them, 13 the testimony into the transcript.
14 JUDGE KARLIN: And that is admitted into 15 the evidentiary record as an exhibit.
16 Thank you for helping us with that.
17 MS. BATY: I will do that.
18 JUDGE KARLIN: Good. Anything else? All 19 right.
20 It's show time, Dr. Wardwell.
21 JUDGE WARDWELL: Well, good morning, 22 everyone. I'd like to start off by thanking Dr.
23 Horowitz for his presentation yesterday afternoon. I 24 think that was pretty much what we were looking for 25 and appreciated the effort that you went through to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1463 1 introduce us to that.
2 I am now going to address other items 3 besides CHECWORKS and then get back to that later on.
4 I wanted to recognize you now so you didn't feel that 5 we were ignoring CHECWORKS and all the information 6 associated with it, but I'm really going to start my 7 questions dealing with just the definitions of flow-8 accelerated corrosion and then how it fits into the 9 Aging Management Program before we get into the aging 10 management plan and get into the details of CHECWORKS.
11 I did want to make sure I didn't forget to recognize 12 your efforts in that.
13 And in that regard, as we go through this 14 questioning, I'd like to remind the witnesses that we 15 have read everything. We know your basic positions, 16 so we don't need to hear those again. We're well 17 aware of what they are. So it would really expedite 18 the process and also it's to your benefit because it 19 clarifies your answer if you just directly answer the 20 questions that are being asked and I think things will 21 move smoother and faster without you trying to add on 22 editorial things that you're trying to emphasize that 23 aren't related to the question necessarily that are 24 repetitious of your testimony.
25 We're asking questions that are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1464 1 specifically things that confused us and we need 2 clarification on. The rest of that, we're well aware 3 of what your positions are. We've spent many hours 4 reading this testimony and it's inefficient to repeat 5 that. So we would appreciate your help in that.
6 MR. WITTE: Just one question, given the 7 way the 8 JUDGE WARDWELL: Could you speak up?
9 MR. WITTE: Yes. I would like the Court's 10 assistance in the event that you ask and I answer in 11 the territory that might be proprietary.
12 JUDGE WARDWELL: Good point. We discussed 13 that yesterday and we -- Entergy has assured us that 14 they will flag us as -- if we start to get off in that 15 area. We're as much at fault, if not more, than the 16 witnesses are if we start wandering into that area and 17 fail to remember that.
18 JUDGE KARLIN: Yes, and I think that's 19 right. And we talked about that.. I just have one 20 other thing to say about that. Let's not be too 21 anxious to start talking about proprietary -- we're 22 not going to get into proprietary, we don't think.
23 But if we do, we'd like you to let us know, but we're 24 not automatically going to shut down all avenues of 25 inquiry just because somebody raises a proprietary NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1465 1 flag. We can either go to a proprietary session or we 2 may not agree with the araument that something is 3 proprietary. So please be hesitant to start waving 4 the proprietary flag if we're not really getting into 5 it. But we'll honor that. Thank you.
6 JUDGE WARDWELL: Okay, with that said, I 7 think we'll move on in and I'd start off with some 8 questions for Entergy. I think Mr. Fitzpatrick will 9 probably be the best person who can address these 10 questions. And I'd like to start off with looking at 11 EPRI NSAC-202 which I think is Exhibit E-4-07.
12 (Pause.)
13 You would have thought I would have had 14 that pulled out considering it was my first question, 15 but I hadn't.
16 I'm really looking at the report summary 17 on little numeral five, the v. Are you there?
18 MR. FITZPATRICK: Yes.
19 JUDGE WARDWELL: And I look at the 20 background, under background, it says flow-accelerated 21 corrosion sometimes referred to as flow-assisted 22 corrosion or erosion corrosion leads to wall thinning, 23 metal loss, steel piping exposed to flowing water or 24 wet street.
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1466 1 words for this whole document, I assume, has both 2 flow-accelerated corrosion and erosion corrosion in 3 this.
4 (Pause.)
5 I understand that it is -- what is_.your 6 position with regards to the definition of flow-7 accelerated corrosion?
8 MR. FITZPATRICK: Flow loss, metal loss in 9 carbon steel piping due to a chemical process, the 10 interaction of a water environment and metal.
11 JUDGE WARDWELL: Does it include erosion 12 corrosion?
13 MR. FITZPATRICK: Not within the scope of 14 the program.
15 Everything was called erosion corrosion 20 16 years ago.
17 JUDGE WARDWELL: Sorry?
18 MR. FITZPATRICK: Everything was called 19 erosion corrosion 20 years ago, when the Surry 20 incident occurred?
21 JUDGE WARDWELL: What do you mean by 22 everything?
23 MR. FITZPATRICK: Well, a lot of unknowns.
24 The industry was learning. As time -- probably called 25 an erosion corrosion, the generic letter and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1467 1 bulletin I think that erosion corrosion in the title.
2 Through time, the definition was more 3 refined to be flow-accelerated and flow-assisted 4 corrosion.
5 JUDGE WARDWELL:-. Referring ,to Dr.
6 Horowitz' and I think it's your testimony, answer 46, 7 statements made that flow-accelerated corrosion 8 definition does not include localized erosion, erosion 9 corrosion, impingement or cavitation.
10 Is that your position, Mr. Fitzpatrick?
11 MR. FITZPATRICK: Within the context of 12 the FAC program, yes.
13 JUDGE .WARDWELL: Do these other 14 components, local corrosion, erosion corrosion, 15 impingement, or cavitation wear pipes?
16 MR. FITZPATRICK: Yes.
17 JUDGE WARDWELL: So pipes do thin from 18 those phenomena?
19 MR. FITZPATRICK: Yes.
20 JUDGE WARDWELL: When you perform a UT 21 test or I've forgotten exactly how you do do it, when 22 you measure wall thickness, do you use UT testing?
23 MR. FITZPATRICK: Generally, ultrasonic 24 technique measurements are taken in place.
25 JUDGE WARDWELL: When you measure that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1468 1 wall thickness, are you measuring flow-accelerated 2 corrosion only?
3 MR. FITZPATRICK: We're measuring wall 4 loss and --
5 JUDGE WARDWELL: Does the UT measurement 6 know whether it's flow-accelerated corrosion or 7 impingement or erosion corrosion or localized 8 corrosion?
9 MR. FITZPATRICK: No. It measures what's 10 left of the metal.
11 JUDGE WARDWELL: So it isn't very smart.
12 It doesn't know all this stuff. It just knows what 13 the thickness of the wall is.
14 MR. FITZPATRICK: Yes.
15 JUDGE WARDWELL: So why are -- and aren't 16 we concerned not with flow-accelerated corrosion wear, 17 but whether or not the pipe gets too thin?
18 MR. FITZPATRICK: That's the --
19 JUDGE WARDWELL: Regardless of how it 20 happens?
21 MR. FITZPATRICK: That is the primary 22 concern of the program.
23 JUDGE WARDWELL: If that's the primary 24 concern -- meaning that the wall does not get too thin 25 to create unacceptable limits remaining, correct?
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1469 1 MR. FITZPATRICK: Yes.
2 JUDGE WARDWELL: So if your program is 3 concerned with that, why aren't you concerned with 4 these other phenomenon beyond flow-accelerated 5 corrosion?
6 MR. FITZPATRICK: We are concerned with 7 the other phenomenon. And they've been evaluated --
8 they've been attributed to different programs, the 9 environment, steam and vector-water systems, 10 demineralized water. There isn't any solid particles 11 in the water to cause erosion, corrosion.
12 JUDGE WARDWELL: What about cavitation or 13 turbulence? Wouldn't that have some impact on the 14 wear of the pipe?
15 MR. FITZPATRICK: Yes. Cavitation is 16 usually a design problem.
17 JUDGE WARDWELL: Well, I'm sure. If the 18 pipe gets too thin it's a design problem, but that 19 still doesn't say it isn't there, does it?
20 MR. FITZPATRICK: No.
21 JUDGE WARDWELL: Dr. Horowitz, what does 22 CHECWORKS calculate?
23 DR. HOROWITZ: The flow-accelerated 24 corrosion as I defined it yesterday. It would be 25 metal dissolution.
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1470 1 JUDGE WARDWELL: And that is the cl_-ss_
2 or the new -- I don't know if it's new -- that's the 3 very restrictive definition of only that where you're 4 -- what I like to term in my mind, you're melting away 5 the oxide layer so that another oxide layer forms and 6 then you melt that away and progressively wear the 7 pipe out. Is that a fair representation?
8 DR. HOROWITZ: That's correct, but if I 9 may, the reason that we went to a more precise 10 definition is that there is and was confusion when one 11 used erosion corrosion because the counter 12 measurements, Jim or anyone else in the industry would 13 employ, differ tremendously whether the problem is 14 cavitation, impingement, solid particle erosion or 15 flow-accelerated corrosion.
16 Also, the communications become completely 17 useless. I am convinced personally that before the 18 Surry accident, if you go through the operator 19 experience report, there was, for example, a report of 20 an erosion corrosion failure at San Onofre about '85, 21 I believe. And that, I'm sure other people reading 22 the reports say oh, he must mean cavitation or he must 23 mean something else. Nobody knew for sure.
24 So what EPRI tried to do was say let's 25 have a definition that people understand and can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1471 1 apply. Certainly Jim mentioned that cavitation is 2 normally considered a design issue because once we 3 experience cavitation, you don't trend wear, you don't 4 measure. We fix the problem. So EPRI has an EPRI 5 aging management tools document that says essentially 6 that. Cavitation is not aging management. It's a 7 design problem and we fix the design problem.
8 JUDGE WARDWELL: So cavitation you would 9 view as a design problem and not an aging management 10 problem.
11 What about the others, the impingement --
12 DR. HOROWITZ: The impingement is kind of 13 in the middle. If you look at some of the exhibits 14 that Entergy has provided, particularly the scoping 15 documents you will lists of operating experience in 16 various plants where they had impingement damage or 17 liquid impingement --
18 JUDGE WARDWELL: Could you describe 19 physically how that impingement wears it and is there 20 a difference between droplet impingement and general 21 impingement or --
22 DR. HOROWITZ: Normally, not. And 23 normally, impingement damage occurs when you have high 24 velocity streams of drops in steam. High velocity for 25 carbon steel is on the order of -- you need about 300 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1472 1 feet a second. So this occurs often in heater vent 2 system where you have the pressure of the heater on 3 one side of a valve and the condenser ion the other 4 side. You have high velocity that's generated by the 5 choke flow.
6 It also occurs when you have upset 7 conditions in your extraction volume, if you have a 8 safety valve misfunctions, *something like that. So 9 impingement as contrasted with the FAC tends always to 10 be much more localized, you have little holes and it 11 often occurs under upset type conditions, not normal 12 operating conditions.
13 So as far as predictable; unpredictable 14 impingement damage is basically unpredictable. You 15 never know when a steam trap is going to fail or 16 something like that. So for Vermont Yankee and other 17 places people look at operating experience, look at 18 places to inspect and fix it if they find a problem.
19 Now note that if you have impingement 20 replacing the carbon steel with stainless steel or 21 low-alloy won't solve the problem. So again, that's 22 more of a design issue, even though impingement as I 23 say is in between. If you see some damage, you may be 24 tempted to trend it for a while.
25 JUDGE WARDWELL: And would you like to add NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1473 1 on to anything Mr. Fitzpatrick said in regards to 2 addressing erosion corrosion?
3 DR. HOROWITZ: The way I would use erosion 4 corrosion is, as I believe it was originally intended, 5 to deal with a process which has both erosion and 6 corrosion occurring.
7 JUDGE WARDWELL: Let's just call it 8 erosion then. If we're going to keep the word 9 corrosion for mean flow-accelerated corrosion, that's 10 fine. Let's then just talk about the erosion part of 11 the erosion corrosion.
12 DR. HOROWITZ: You have this phenomenon 13 mostly at entrance to heat exchangers, particularly 14 copper, copper, brass heat exchangers and what happens 15 there is the turbulence is sufficient to damage the 16 outside layer, exposed bare metal and have a process 17 where you have two different things occurring 18 simultaneously.
19 JUDGE WARDWELL: And is that not a problem 20 that needs to be addressed with Vermont Yankee as part 21 of their aging management for wearing of pipes?
22 DR. HOROWITZ: For the pipes we deal with, 23 they're carbon steel. With carbon steel, the 24 velocities necessary to cause this off-site damage are 25 much higher than you would expect to see and do see.
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1474 1 it's noL a question they're much higher. We don't see 2 that type of attack in lightwater damage.
3 JUDGE WARDWELL: Turning then to NEC for 4 a minute and probably Dr. Hopenfeld would be the best, 5 but if others think it more appropriate to answer, 6 that's fine, do you dispute any of the definitions of 7 the various components that wear a pipe that was just 8 presented by Entergy?
9 MR. HOPENFELD: Well --
10 JUDGE WARDWELL: It's a yes or no 11 question.
12 MR. HOPENFELD: Yes, I do dispute that.
13 JUDGE WARDWELL: And where do you dispute 14 that?
15 MR. HOPENFELD: Dr. Horowitz' specific 16 comment with respect to erosion corrosion and the 17 mechanism that he's talking about, it will take me 18 some time through the mechanism I dispute. I dispute 19 his definition --
20 JUDGE WARDWELL: What's your definition of 21 erosion?
22 MR. HOPENFELD: Erosion corrosion?
23 JUDGE WARDWELL: No, erosion.
24 MR. HOPENFELD: Oh, erosion --
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1475 1 portraying erosion corrosion to be a combined term 2 between the corrosion that we are now reserving to 3 mean flow-accelerated corrosion from that which is 4 caused mechanically as I interpolate him saying of an 5 erosion type of aspect. So what's your definition of 6 erosion under those assumptions that we're going to 7 reserve the word corrosion to be a shortened version 8 of FAC, flow-accelerated corrosion.
9 MR. HOPENFELD: Erosion, actually, I don't 10 even know -- it's completely separate from erosion 11 corrosion. I'll have to explain that. But strictly 12 speaking of erosion, my understanding would be you 13 have particles in steam, droplets in steam impinging 14 --
15 JUDGE WARDWELL: Is that steam droplet 16 impingement?
17 MR. HOPENFELD: Yes, that would be.
18 JUDGE WARDWELL: We separated that out.
19 MR. HOPENFELD: It could be called --
20 JUDGE WARDWELL: That's droplet 21 impingement, so back to the corrosion. If they 22 removed droplet impingement, do you agree with his 23 definition of erosion as a mechanical process --
24 MR. HOPENFELD: Not necessarily in the 25 context of corrosion and erosion, I can't separate it.
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~1476 1 I can explain to you why. You can't separate the two.
2 There is no acceptable theory as exactly what happens 3 during the erosion corrosion process. It is 4 acceptable for the last 30 or 40 years, but you don't 5 have enough shear stress, calculated shear forces 6 during normal flow. There is not enough shear there 7 to abrade or wash off, as NRC defines it, to wash off 8 that layer. There's been acceptance in the paper that 9 was written in '76 on that subject.
10 JUDGE WARDWELL: Let me stop you right 11 there.
12 It's my impression that flow-accelerated 13 corrosion isn't a physical washing off of the oxide, 14 but more of a chemical melting of it, my simplistic 15 mind, and I thought I heard Dr. Horowitz-- again, at 16 the next hearing I'm on, I'm going to limit how many 17 Hs are present for witnesses.
18 Dr. Horowitz seemed to agree to that.
19 MR. HOPENFELD: I took the next step.
20 JUDGE WARDWELL: There's no argument, no 21 one says there's enough shear forces to physically 22 remove it, but there's enough chemical action to melt 23 it, isn't there?
24 MR. HOPENFELD: No, no, no. NRC says it's 25 a washing away of the oxide.
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1477 I JUDGE WARDWELL: I'll get to the NRC.
2 MR. HOPENFELD: But back to what I was 3 coming to, there's no acceptable theory. There are 4 concepts. One concept I'm familiar with that has to 5 do -- that you can have very, very -- some velocity.
6 You may have sufficient, sufficient shear force. It 7 doesn't take much to affect the cohesion, to affect 8 the oxide layer. And I am not an expert on oxide 9 layer characteristics and all the details of that.
10 That's one theory. There are other theories, that Dr.
11 Hausler has proposed, the creation of local extremely 12 high pressure. I'd rather he talk about that.
13 Their definition doesn't cover those acts, 14 those two acts as I just said.
15 JUDGE WARDWELL: Dr. Hausler, would you 16 like to expound on that in regards to the definition?
17 DR. HAUSLER: Yes, sir. Your Honor, 18 actually, I would. With your permission I would like 19 to cut through this fog of definition fairly quickly.
20 What this demonstrates that in fact over 21 the years the corrosion engineers have made confusion 22 in their semantics. And the chronology has developed 23 over the years. I mean perhaps to be more specific as 24 to what it is that I want to say.
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1478 1 corrosion phenomena were the two extremes, were, in 2 fact, mixing with the salts, salts mixed into the 3 fluid streams. We did, in fact, then have abrasion, 4 mechanical removal of the surface layers. Now this is 5 not what we're looking at.
6 JUDGE WARDWELL: So are you saying we 7 don't have to worry about the erosion part of erosion 8 corrosion?
9 DR. HAUSLER: I think that the corrosion 10 engineers have, in fact, used erosion just like Dr.
11 Horowitz and as Mr. Fitzpatrick indicated in areas of 12 high turbulence where you have high turbulence and you 13 get somewhat localized corrosion, but without the 14 definition of what localized really means. And that 15 the corrosion engineers have identified that as 16 erosion.
17 To approach the problem, I think we would 18 be a lot better off to look maybe at the mechanism of 19 that fundamental. And here is what I would say is 20 that both are corrupt as well as what we might call 21 erosion corrosion due to high turbulence in a specific 22 location are, in fact, due to a dissolution mechanism 23 of the oxide layer on the surface. And the reason for 24 that is that very recently in Germany calculations 25 have been made with respect to the compressive NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1479 1 strength of all kinds of corrosion product layers on 2 the surface. In order to mechanically, remove with 3 flow some of these surface layers, you would in fact 4 need shear forces of the order of many megapascals and 5 actually in the order of a hundred megapascals to a 6 thousand megapascals.
7 And it is very difficult, it is extremely 8 difficult to generate sheer forces of that nature with 9 fluid. I heard Dr. Horowitz just say that it is 10 possible to do that with velocities of 300 feet per 11 second. That is a number that a long time ago had 12 been worked in Switzerland as well as by some 13 scientists, Luigi Piatti in particular, where he 14 mentioned that yes, you can cut metal with liquid 15 streams of the order of 100 or maybe 200 meters per 16 second which is in the same order of magnitude. So 17 coming back to what it is that we're actually dealing 18 with, I think, is a dissolution phenomenon that is 19 caused by the local velocity or shear force of the 20 liquid caused by turbulence effects. These turbulence 21 effects, you know, arrive as we all know from upset in 22 the flow.
23 When normally developed flow like -- say 24 develop turbulence flow and the pipe gets upset, you 25 start by some obstacle in the flow pattern. You get NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1480 1 turbulence. You get acceleration, local acceleration 2 of the flow. The local flow rate, that increases the 3 mass transfer and that accelerates the dissolution 4 process.
5 JUDGE WARDWELL: Thank you, Dr. Hausler.
6 Turning to the staff, Mr. Rowley or Mr.
7 Hsu, whoever would like to answer this, what did you 8 consider your definition of flow-accelerated corrosion 9 when you looked at an aging management plan for 10 license renewal.
11 MR. HSU: Engineering preparing fpr 12 license renewal, they have flow-accelerated corrosion.
13 This flow-accelerated corrosion, what we are looking 14 at is --
15 JUDGE WARDWELL: Can you speak up?
16 MR. HSU: Dissolution outside the 17 protective field being washed away due to the flow 18 accelerator. That's what we are looking at. What 19 they are talking about is like a singularity point of 20 view, like a one point of corrosion or all those 21 happening. This is a general program. Really, you 22 cannot really look at all the small portions. They 23 point out one singularity, hostile event, due to --
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1481 1 of view.
2 JUDGE WARDWELL: You're confusing me a 3 little bit. What is your definition of flow-4 accelerated corrosion? Does it include erosion? Does 5 it include localized corrosion from turbulence? Does 6 it include droplet impingement? Does it include 7 cavitation or does it not?
8 MR. HSU: It all depends. I followed Dr.
9 --
10 JUDGE WARDWELL: What did you consider 11 when you went through your review of the application 12 for the license renewal?
13 MR. HSU: We reviewed application for 14 license renewal based on whatever the current NRC 15 endorsed the program which is consistent with the GALL 16 definition.
17 JUDGE WARDWELL: So there's a definition 18 that's in GALL?
19 MR. HSU: Yes.
20 JUDGE WARDWELL: And what is the 21 definition in GALL?
22 Before you answer that question, in your 23 testimony on -- in response to answer four on page 24 three of Staff's five, at least -- I'm not sure it's 25 appropriate, but it's your testimony -- appropriate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1482 1 number for that. I think I added that number. But 2 staff, your affidavit on page three for answer four, 3 the question was what is flow-accelerated corrosion?
4 And you stated flow-accelerated corrosion is also 5 known as erosion corrosion 1s a corrosion attack 6 accelerated by high velocity flow either washing away 7 otherwise protective films or mechanically disturbing 8 the metal itself. That seems to lead me to believe 9 you're considering both of these mechanisms when you 10 reviewed their application in regards to how concerned 11 you may or may not be in their program to manage this 12 during the aging that occurs during the renewal 13 period.
14 MR. HSU: Yes, that definition is exactly 15 like that, but also NRC's NUREG, is flow-accelerated 16 corrosion in other countries very like limited, but in 17 the U.S. people put all those two things together.
18 JUDGE WARDWELL: Okay, but that's what 19 you've answered for what is flow-accelerated 20 corrosion, so I assume that's what you were concerned 21 about when you looked at the application?
22 MR. HSU: Yes.
23 JUDGE WARDWELL: Do you agree with Dr.
24 Horowitz that CHECWORKS only analyzes for the chemical 25 washing away of that oxide layer, melting of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1483 1 oxide layer as opposed to the mechanical. Do you 2 agree with that?
3 MR. HSUJ: Yes.
4 JUDGE WARDWELL: So in fact, there's no --
5 CHECWORKS d.oes not have a potential to predict -
6 MR. HSU: CHECWORKS does not have 7 potential to predict those singularity --
8 JUDGE WARDWELL: Mechanical one.
9 MR. HSU: Yes.
10 JUDGE WARDWELL: So how did you handle the
.11 mechanical one when you -- what program did they 12 recommend to yo u that is used to help manage the 13 mechanical wear of the pipe?
14 MR. HSU: Mechanical wear of the pipe is 15 basically like a corrosion. They have some other 16 maintenance or other type aging management program to 17 manage this type of effect, handling it like a 18 singularity problem.
19 JUDGE WARDWELL: And why is it necessarily 20 a singularity problem in regards to the mechanical 21 wearing away of the oxide layer?
22 MR. HSU: Because this involves a lot.
23 I'm certain because everybody started this erosion 24 corrosion for all those years from the knowledge-wise.
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1484 I no easy method they can predict.
2 JUDGE WARDWELL: Can you point us to where 3 that program is that you're referring to in the 4 testimony today that's used to manage mechanical 5 corrosion?
6 MR. ROWLEY: We just discussed flow-7 accelerated corrosion in our testimony. We don't 8 deviate and talk about any other program to handle the 9 corrosion aspect as you are asking us to show you.
10 JUDGE WARDWELL: Well, yes. That's 11 circular reasoning a bit here. You've defined flow-12 accelerated corrosion as including the chemical 13 melting away of the oxide layer and the mechanical 14 wearing away. Then what -- and I can understand how 15 CHECWORKS might contribute to the chemical melting 16 away of the oxide layer. How did you evaluate the 17 mechanical aspects of what you defined as being flow-18 accelerated corrosion?
19 Mr. Rowley.
20 MR. ROWLEY: We didn't address it here in 21 our testimony. We stuck with the --
22 JUDGE WARDWELL: That's what the 23 contention is about. It's relating to the aging 24 management program for flow-accelerated corrosion and 25 I've just heard testimony that says you define flow-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1485 1 accelerated corrosion as including both the mechanical 2 and the chemical. I can see where the chemical aspect 3 is handled. Mr. Hsu said there's other programs for 4 the mechanical one. Where are those programs that 5 relate to that portion of the flow-accelerated 6 corrosion as you, the staff, have *defined it?
7 MR. ROWLEY: As I said, we didn't address 8 it here in our testimony. I have to look in the SER 9 and get back with you where we address that. I will 10 have to look.
11 JUDGE KARLIN: Well, we understand you 12 didn't address it in your testimony. This is now 13 testimony right now.
14 Did you address it in the FSER?
15 MR. ROWLEY: I'll have to check.
16 JUDGE KARLIN: Well, check right now.
17 There's no getting back. Today is the day.
18 JUDGE WARDWELL: Today is the day.
19 JUDGE KARLIN: Presumably, you're 20 familiar with the FSER. You helped write it. As far 21 as I can tell, there's only three pages in the FSER 22 that deal with this.
23 (Pause.)
24 JUDGE WARDWELL: I'd like to move on.
25 (Pause.)
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14.86 1 JUDGE KARLIN: Where in the FSER -- and 2 the NRC makes a conclusion in the FSER that the flow-3 accelerated corrosion aging management plan is 4 adequate, that NRC makes this statement that you just 5 made, Mr. Hsu that that includes both mechanical and 6 chemical. Where in the FSER is the - -do you discuss 7 the mechanical flow-accelerated corrosion being 8 adequate?
9 I'm still with Mr. Rowley.
10 MR. ROWLEY: One moment, sir.
11 JUDGE KARLIN: It's page 3.15, 16, and 17, 12 I think.
13 MR. ROWLEY: Three dash --
14 JUDGE KARLIN: You don't know what page 15 this discussion is and you're a witness on the 16 subject? 3-14.
17 MR. ROWLEY: I know what the flow-18 accelerated corrosion discusses, yes.
19 JUDGE KARLIN: Three dash 15, flow-20 accelerated corrosion.
21 I would suggest counsel to ask their 22 witnesses to familiarize themselves with the FSER 23 section they wrote and they're going to testify on.
24 MR. ROWLEY: I do know what flow-25 accelerated corrosion. I was trying to get to where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1487 1 we discuss the mechanical.
2 JUDGE KARLIN: Yes, I'm trying to find 3 that too. I don't see it there. That's my point.
4 But if you can find it.
5 (Pause.)
6 This was obviously an issue in pleading, 7 so presumably you should expect a question.
8 Do you find anywhere in the FSER where the 9 staff discussed the mechanical flow-accelerated 10 corrosion component? Yes or no.
11 MR. ROWLEY: No, not for flow-accelerated 12 corrosion, but not in conjunction with the corrosion 13 part.
14 JUDGE KARLIN: All right. Mr. Hsu, do you 15 have anything in the FSER that discusses the 16 mechanical component of flow-accelerated corrosion, 17 sir?
18 MR. HSU: We did not discuss the 19 mechanical.
20 JUDGE KARLIN: Did you think about it when 21 you concluded that they had an adequate program to 22 manage flow-accelerated corrosion? Did you just leave 23 that out?
24 MR. HSU: It's not that we didn't think 25 about it. It's --
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1488 1 JUDGE KARLIN: Did you think about it?
2 MR. HSU: NRC endorsed it, the GALL 3 program. We are doing our audit which the NRC 4 endorsed the program. And they are doing -- follow 5 the steps, endorsed the petition.
6 JUDGE KARLIN: Staff endorsed GALL, so all 7 you did was apply GALL?
8 MR. HSU: Yes.
9 JUDGE KARLIN: Can you show me in GALL 10 where it excludes mechanical aspects of flow-11 accelerated corrosion? Show me where it is in GALL 12 that excludes mechanical.
13 MR. ROWLEY: We don't have GALL before us, 14 Your Honor.
15 JUDGE KARLIN: You should have it. You're 16 testifying here on this issue.
17 (Pause.)
18 MR. ROWLEY: We just went through our 19 GALL, it's in elements to make sure that their program 20 21 JUDGE KARLIN: Show me in GALL, let me 22 know, I looked at GALL. I would just like to see 23 where it says something about this in GALL.
24 MR. ROWLEY: Sorry, sir. We don't have 25 that as an exhibit in front of us so I can't direct NEAL R. GROSS COURT REPORTERSAND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1489 1 you to that.
2 JUDGE KARLIN: Well, let's see if we can 3 find GALL. What exhibit is that, Ms. Baty?
4 MS. BATY: I believe that the relevant 5 section of --
6 JUDGE KARLIN: I just asked you what 7 exhibit it was first.
8 MS. BATY: The relevant section of GALL is 9 Exhibit, for this topic is one of any NEC's exhibits 10 and I'm trying to locate it. I believe it is exhibit 11 NEC UW-0 5.
12 JUDGE KARLIN: I believe it's E-4-05.
13 MS. BATY: Is that the -- E-4-05. It may 14 be duplicated.
15 JUDGE KARLIN: I think it's duplicated.
16 E-4-05.
17 Why don't you get that out, Mr. Rowley and 18 Mr. Hsu. It's only three pages.
19 (Pause.)
20 Exhibit 4-05-VY entitled -- I guess it's 21 an excerpt from GALL, Ms. Baty?
22 MS. BATY: Yes, that's the relevant 23 program section from GALL.
24 JUDGE KARLIN: Section ll.M17 flow-25 accelerated corrosion program description, evaluation NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1490 1 and technical basis 1, 2, 3, 4, 10. Those are the 10 2 you were referring to, Mr. Rowley?
3 MR. ROWLEY: Yes.
4 JUDGE KARLIN: Okay. Where does. it 5 exclude or cover or -.-mechanical. Maybe it does. I 6 don't know.
7 (Pause.)
8 Okay. I'll withdraw the question and we 9 can continue. I mean I think it is demonstrated you
.10 have not familiarized yourself with this on an issue 11 that was important in this case.
12 MR. ROWLEY: We followed this and made 13 sure that their program matched GALL and we said it 14 was consistent and --
15 JUDGE KARLIN: I asked for testimony in 16 this matter and Mr. Hsu's testimony in this matter 17 says that flow-accelerated corrosion includes both 18 mechanical and chemical. Now you're telling us that 19 your aging management plan consideration that you did 20 didn't deal with that.
21 And your answer is well, we were just 22 following GALL.
23 MR. ROWLEY: In our review, that's what we 24 did, sir.
25 JUDGE KARLIN: And GALL is guidance, isn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1491 1 it?
2 MR. ROWLEY: GALL is guidance.
3 JUDGE KARLIN: It doesn't mean that's the 4 only thing you do. It doesn't mean you don't think.
5 It means you have some guidance and you use it as 6 guidance.
7 MR. ROWLEY: Correct.
8 JUDGE KARLIN: All right.
9 JUDGE WARDWELL: Mr. Fitzpatrick, does 10 your core program address mechanical corrosion?
11 MR. FITZPATRICK: It would address the 12 effects of mechanical corrosion.
13 JUDGE WARDWELL: How?
14 MR. FITZPATRICK: By inspecting. The 15 steam train reactor water systems at Vermont Yankee 16 run with demineralized water. All the water that hits 17 the reactor in the steam feed train. It passes 18 through demineralizers. There is no --
19 JUDGE WARDWELL: Is that the only 20 pipelines that we're worried about in regards to 21 corrosion?
22 MR. FITZPATRICK: Within the FAC program, 23 yes.
24 JUDGE WARDWELL: How about in the plant?
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1492 1 those that are within the -- what you just described?
2 MR. FITZPATRICK: License renewals, they 3 review different systems, like service water and 4 there's different aging mechanisms as in the program 5 for the service water system. The FAC program, the 6 scope and the FAC program, is a steam and feedwater 7 system attached with a reactor.
8 JUDGE WARDWELL: Because the steam and 9 feedwater system --
10 MR. FITZPATRICK: And extraction steam, 11 whatever all the process steam systems.
12 JUDGE WARDWELL: Sorry, you trail off at 13 the end. Enunciate your words and project them, if 14 you will. It's a lot easier to hear you.
15 MR. FITZPATRICK: Basically, all the 16 process steam systems that turn the turbine are 17 included with scope of the FAC program.
18 JUDGE WARDWELL: And are there other pipes 19 that also have flow-accelerated corrosion outside of 20 those pipes?
21 MR. FITZPATRICK: No.
22 JUDGE WARDWELL: Thank you. Turning to E-23 4-04, which is an excerpt, I believe, from the 24 application.
25 Is that correct, Mr. Fitzpatrick?
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1493 1 MR. FITZPATRICK: Yes, sir.
2 JUDGE WARDWELL: And I'm looking at the, 3 right under the program description. It says, first 4 sentence, the flow accelerated corrosion fact, in 5 parenthesis, program at VYNPS, is comparable to the 6 program described in NUREG 1801. Is NUREG 1801 the 7 GALL?
8 MR. FITZPATRICK: Yes, sir.
9 JUDGE WARDWELL: Further down, under NUREG 10 1801 Consistency, it says the flow-accelerated 11 corrosion at NYNPS is consistent with the program 12 described in NUREG 1801, which is again the GALL?
13 MR. FITZPATRICK: Yes, sir.
14 JUDGE WARDWELL: Do you believe that the 15 words comparable and consistent are equivalent to the 16 words identical?
17 MR. FITZPATRICK: In absolute terms, no.
18 JUDGE WARDWELL: So in fact, your program 19 could be different than GALL, but a judgment factor 20 would determine whether or not it is comparable or 21 consistent, correct?
22 MR. FITZPATRICK: That's possible, yes.
23 JUDGE WARDWELL: Who is responsible for 24 making that judgment of being comparable and 25 consistent? You, the staff, or the intervener?
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1494 1 MR. FITZPATRICK: Us and the staff should 2 be responsible. We should be responsible making the 3 decision and the staff should review the decision. We 4 believe that's how the process works.
5 JUDGE WARDWELL: And where have you shown 6 in your application that it is, that can justify that 7 it is comparable and consistent?
8 MR. FITZPATRICK: The supporting documents 9 for the application did the review against the GALL, 10 the program review against the GALL. And those who 11 audit it, during the NRC inspection of the 12 application. They did a programs audit and 13 interviewed our programs against the GALL 14 requirements.
15 JUDGE WARDWELL: Why don't we turn back to 16 the GALL again. I think it's the next one, 05.
17 (Pause.)
18 The first line in the program description 19 says "the program relies on the implementation of 20 EPRI's guidelines in the NSAC-202L."
21 Would you agree that the GALL relies a lot 22 on the components as outlined in NSAC-202L for that, 23 the details of the program? Would you agree that it 24 relies on that for the details of the program?
25 MR. FITZPATRICK: The details no, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1495 1 guidance, yes. The details are in the plant-specific 2 FAC.
3 JUDGE WARDWELL: And where is that in your 4 license application.
5 MR. FITZPATRICK: I'm not sure --
6 JUDGE WARDWELL: I can refer you to your 7 exhibit on your application which is E-4-04.
8 MR. FITZPATRICK: All the programs or 9 references consistent to the GALL and the specific 10 programs are not listed in the application.
11 JUDGE WARDWELL: So as far as the excerpt 12 that you've provided under E-4-04 is the only 13 description of the aging management program for flow-14 accelerated corrosion that you submitted with your 15 application?
16 MR. FITZPATRICK: I believe it is.
17 JUDGE WARDWELL: Turning to -- he said 18 yes.
19 EPRI's -- and NSAC is an EPRI document, is 20 it not?
21 MR. FITZPATRICK: It was produced by EPRI 22 and it was written by the industry group, the CHECK 23 group.
24 JUDGE KARLIN: What group, sir?
25 MR. FITZPATRICK: CHECWORKS users group.
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1496 1 It's an industry group that's been focusing on FAC 2 since 1988.
3 JUDGE KARLIN: So it's--
4 MR. FITZPATRICK: CHECWORKS users group, 5 CHUG.
6 JUDGE KARLIN: CHUG, and that's a group of 7 people who are using Mr. Horowitz, Dr. Horowitz' 8 system, is that right? CHECWORKS users group.
9 MR. FITZPATRICK: Yes, sir.
10 JUDGE WARDWELL: Turning to that on E 11 07, I believe is the exhibit --. your testimony that 12 includes NSAC.
13 MR. FITZPATRICK: Yes, sir.
14 JUDGE WARDWELL: And let's turn to --
15 let's start off with page 1-3, under industry status.
16 (Pause.)
17 Are you there?
18 MR. FITZPATRICK: Yes, sir.
19 JUDGE WARDWELL: Second paragraph, third 20 line from the bottom of the paragraph, would you care 21 to read that sentence starting with "however"?
22 MR. FITZPATRICK: "However, since the 23 approach is based on the section of the prioritized 24 sample at an acceptable location, it is recognized 25 that it will never be possible vet all FAC-related NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1497 1 leaks and ruptures from occurring."
2 JUDGE WARDWELL: I ask you now to turn to 3 page 4-5. Under 4.3.1 FAC analysis and power uprates.
4 Could you read that first sentence?
5 MR. FITZPATRICK: ".It is recognized that 6 even small power uprates can have significant effects 7 on FAC leaks."
8 JUDGE WARDWELL: Given that Vermont Yankee 9 has going through a power uprate and.that NSAC also 10 says regardless of the power uprate it recognizes it 11 will never be possible to prevent all leaks, as you've 12 just read, doesn't it seem reasonable that you'd want 13 to be as conservative as possible in all aspects 14 associated with your FAC program given those somewhat 15 pessimistic view of attempts to address this 16 particular phenomenon?
17 MR. FITZPATRICK: I believe we're 18 conservative in what we've done.
19 JUDGE WARDWELL: So you agree that you 20 ought to be pretty conservative at all turning points 21 in order to address this, given the cloud over which 22 NSAC emphasizes the problems with addressing this 23 particular phenomenon?
24 MR. FITZPATRICK: I believe it's 25 conservative in all the aspects we've addressed. I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1498 1 believe too that any aspects we have addressed are 2 significant.
3 JUDGE WARDWELL: Going - back to 4 demonstrating your aging management plan and the facts 5 of it, turni.ng to page 2-1, it's really 2-1 through 2-6 5. There are basically six different areas that are 7 considered to be elements of an effective FAC program.
8 The first one is a corporate commitment.
9 Is that correct on that page, 2-1, 2.1 is corporate 10 commitment?
11 MR. FITZPATRICK: Yes, sir.
12 JUDGE WARDWELL: Where is your corporate 13 commitment to an effective FAC program established in 14 the license renewal application, specifically 15 demonstrating that the following recommendations that 16 are presented on 2-1 have been or will be carried out 17 during the license renewal period?
18 MR. FITZPATRICK: Specific commitments, 19 the FAC program of the license renewal period is the 20 same program that's in effect now at Vermont Yankee 21 and all the Entergy plants. It's a corporate program.
22 The commitments are the specific --
23 JUDGE WARDWELL: Have you submitted that 24 as an exhibit?
25 MR. FITZPATRICK: An exhibit, yes, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1499 1 have.
2 JUDGE WARDWELL: Can you show me where 3 that -- where is the commitment -- back up again.
4 Before you show me that, where do you state in your 5 license renewal application that you're committing to 6 the previous program? We should reference that so 7 we're clear if that's part of your aging management 8 plan.
9 MR. FITZPATRICK: I would be back on --
10 JUDGE WARDWELL: It would be in E-4-04 11 would it not be?
12 MR. FITZPATRICK: The license renewal 13 application doesn't list specific programs.
14 JUDGE WARDWELL: That wasn't my question.
15 I said where was the commitment to follow your 16 existing program in that license renewal application 17 under flow-accelerated corrosion that you just 18 portrayed would be the aging management, the details 19 of the aging management program that are only roughly 20 alluded to here under the application?
21 MR. FITZPATRICK: I don't believe the 22 existing program is listed in this section of the 23 application.
24 JUDGE WARDWELL: But this is the section 25 that deals with the aging management program, does it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1500 1 not?
2 MR. FITZPATRICK: This is the section that
.3 deals with flow-accelerated corrosion.
4 JUDGE WARDWELL: I assume to save some 5 time I was going to go through each six of those items 6 and ask where were the details of those presented in 7 your application. I assume that none of them are 8 there. Is that correct? Exclusive of -- none of them 9 are there in the section relating to the aging 10 management program.
11 MR. FITZPATRICK: I believe they're all in 12 the specific implementation program procedure.
13 JUDGE WARDWELL: Sorry?
14 MR. FITZPATRICK: They're in the specific 15 procedure that implements the program.
16 JUDGE WARDWELL: And what procedure is 17 that that is referenced in E-4-04 that you're 18 referring to?
19 MR. FITZPATRICK: It's not explicitly 20 referenced in the E-4-04.
21 JUDGE WARDWELL: Where then is it in your 22 application and where is -- can we turn to the exhibit 23 here where the existing program is outlined?
24 MR. FITZPATRICK: I'm not too sure in the 25 application if it's included.
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1501 1 JUDGE WARDWELL: So how is one able to 2 judge or provide any assurances that, in fact, these 3 things will be carried out if there's nothing in your 4 application that says it will as part of your aging 5 management plan? I guess I don't understand.
6 MR. FITZPATRICK: It says our program will 7 be consistent with the GALL.
8 And the program, the supporting documents 9 for the application that have those documents that 10 references in it, but they're not included in the 11 application.
12 JUDGE WARDWELL: But you do agree that --
13 you are testifying that your application says you'll 14 be consistent with the GAL-L and you also testified, I 15 believe, that nothing in the GALL says that there's a 16 commitment or a requirement to commit to an existing 17 program.
18 MR. FITZPATRICK: No.
19 JUDGE WARDWELL: And there's no other 20 commitments either in your application and certainly 21 not in the GALL because it didn't know what your 22 program is to commit to your existing program.
23 MR. FITZPATRICK: I'm trying to understand 24 the question, sir.
25 JUDGE WARDWELL: Your application does not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1502 1 commit to extend the exis tinfg program as part of your 2 flow-accelerated corrosion aging management plan 3 because all it does is reference GALL. Is that 4 correct?
5 MR. FITZPATRICK: The application 6 references GALL, yes.
7 JUDGE WARDWELL: Thank you. Now, your 8 existing program. Where is your -- what exhibit is 9 your existing program?
10 MR. FITZPATRICK: I'm looking that up.
11 JUDGE KARLIN: I believe it's E-4-06.
12 It's a document. We don't know what it is, actually, 13 but it seems to be a corporate document.
14 JUDGE WARDWELL: Is that what you consider 15 to your existing program?
16 MR. FITZPATRICK: This is the program 17 procedure, yes.
18 JUDGE WARDWELL: But isn't that a 19 corporate procedure? That's not a Vermont Yankee 20 procedure.
21 MR. FITZPATRICK: It's adopted by all the 22 plants.
23 JUDGE WARDWELL: But it's not specific --
24 okay, sorry. I'll back up.
25 Let's for example take the very first NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1503 1 proponent that's recommended by NSAC and that is the 2 corporate commitment. Where are the details of the 3 corporate commitment as applied to Vermont Yankee and 4 presented in this document?
5 MR. FITZPATRICK: The corporate commitment 6 is to have a program in place to monitor and address 7 FAC. Having the procedure satisfies that commitment.
8 I think there's a section eight that says commitments 9
10 JUDGE WARDWELL: I'll ask for an example.
11 2.1 under NSAC says that you will provide.as part of 12 your corporate commitment the financial resources to 13 ensure that all tasks are properly completed. Where 14 is the commitment of the financial resources that 15 Vermont Yankee proposes to dedicate to this as part of 16 this program to ensure that that goal is achieved?
17 MR. FITZPATRICK: That financial 18 commitment means to have a program in place and 19 implement the program. That's the intent of that 20 commitment -- statement.
21 JUDGE WARDWELL: You as a technical 22 person, as a technical person, can you explain why you 23 feel that bare bones commitment provides a 24 demonstration that aging management will be maintained 25 during the entire period of the uprate as required by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1504 1 the regulations?
2 MR. FITZPATRICK: Vermont and to an 3 extent, Entergy, in response to General Letter 89-08 4 had a formal commitment that we will have a program to 5 monitor FAC and address FAC.
6 That commitment and the procedures we've 7 developed over time have been folded into this one 8 program procedure. This is a corporate program 9 procedure. Every plant has to implement this.
10 JUDGE WARDWELL: But where is the 11 demonstration that it'.s going to be implemented at 12 Vermont Yankee that's required of the regulations?
13 Where are the technical aspects of those?
14 MR. FITZPATRICK: This program procedures 15 defines the technical aspects of the program we have 16 to have in place.
17 JUDGE WARDWELL: I understand that. Where 18 is the site-specific -- we're now dealing with an 19 application not for a fleet of generic power plants.
20 We're dealing with Vermont Yankee. Where does it 21 apply to Vermont Yankee?
22 MR. FITZPATRICK: It should be in the FSAR 23 supplement for the license renewal.
24 - JUDGE WARDWELL: Did you write the FSER?
25 MR. FITZPATRICK: No.
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1505 1 JUDGE WARDWELL: Did Entergy write the 2 FSER?
3 MR. FITZPATRICK: No, not the FSER. F-S-4 A-R. FSAR supplement for the application.
5 It should-.have the programs listed that 6 it's committed to. The aging management program 7 should be included in that. I don't have it in front 8 of me. I'll look it up.
9 JUDGE WARDWELL: Mr. Rowley of the staff, 10 where -- or Mr. Hsu --
11 JUDGE KARLIN: Can I just ask, is that 12 FSAR an exhibit here?
13 MR. FITZPATRICK: I don't know.
14 JUDGE KARLIN: And you're referring to the 15 UFSAR, I presume, the updated final safety analysis 16 report by Entergy?
17 MR. FITZPATRICK: I believe it's Appendix 18 A of the application, the FSAR changes.
19 JUDGE KARLIN: Well, maybe at the break, 20 counsel can help and can figure if that's an exhibit 21 here or not. I'm sorry.
22 MR. FITZPATRICK: No problem.
23 JUDGE WARDWELL: Mr. Rowley or Mr. Hsu, 24 you've reviewed their aging management plan and have 25 concluded from the technical standpoint that you felt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1506 1 there was sufficient information to demonstrate that 2 aging management will be maintained and taking place 3 during the period of extended operations. Is that 4 your conclusions in the FSER?
5 -. MR. HSU: Yes. Because --
6 JUDGE WARDWELL: I haven't asked a 7 question yet. Tell me what question you're answering 8 and you can go ahead and answer it.
9 MR. HSU: I just tried to paraphrase. The 10 last time you asked us about the technical and the 11 mechanical. Because FAC program uses NDE technology 12 and then check the wall thickness. When you check the 13 wall thickness you don't distinguish the loss due to 14 the chemical and do the mechanical. It's due to both, 15 the combination.
16 JUDGE WARDWELL: In fact, it would include 17 anything that wears the pipe?
18 MR. HSU: Yes, that's right.
19 JUDGE WARDWELL: Where do you measure 20 points? Do you inspect all the pipes?
21 MR. HSU: It's not all the pipes, only the 22 pipe which is FAC can be accelerate that. So they put 23 it FAC and ranking the accessibility. So that's the 24 reason.
25 JUDGE WARDWELL: Where does Entergy select NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1507 1 those points to measure? How do they select them?
2 MR. HSU: How they select it is they are 3 just like a factor. They consider all those --
4 JUDGE WARDWELL: Let me rephrase the 5 question. Is CHECWORKS used to select the locations 6 that you inspect?
7 MR. HSU: Yes.
8 JUDGE WARDWELL: What does CHECWORKS 9 model, do you know?
10 MR. HSU: CHECWORKS model?
11 JUDGE WARDWELL: Does it model mechanical 12 erosion?
13 MR. HSU: CHECWORKS, basically, did not 14 really specific put a mechanical section like they 15 talk about the shear force.
16 JUDGE WARDWELL: But you saw those F 17 factors. Are any of those F factors that go into the 18 equations, the equation that predicts the wear rate 19 deal with mechanical erosion? Dr. Horowitz earlier 20 today testified it didn't. Do you believe it does?
21 MR. HSU: I know this model did not really 22 consider the mechanical factor, but I know when 23 they're doing the NDE --
24 JUDGE KARLIN: Please define NDE.
25 MR. HSU: NDE, wall thickness measurement.
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1508 1 MR. ROWLEY: Non-destructive evaluation.
2 JUDGE WARDWELL: And Dr. Horowitz, did I 3 -- was I correct in saying that you testified that 4 CHECWORKS doesn't address the mechanical?
5 DR. HOROWITZ: Yes, that's exactly right.
6 And if I may, Vermont Yankee does not use only 7 CHECWORKS to select inspection location. And 8 particularly for mechanical damage the key way of 9 locating it is through operating experience of humans.
10 And so once it gets put into operating experience, 11 then inspections if they find a problem, then deal 12 with them. So CHECWORKS doesn't find the problem, but 13 operating experience does.
14 JUDGE WARDWELL: Thank you. I want to 15 clarify -- let me hang on a second.
16 (Pause.)
17 My other colleagues, I'm pausing now 18 because we've gone through the definition of FAC and 19 kind of the definition of what is in the aging 20 management program and what is not in the aging 21 management program and I thought I'd pause to see if 22 either of you have questions on it also and -- but not 23 on others, we'll move on to the others later. I think 24 it's a good opportunity to make sure we haven't missed 25 anything on this aspect. I'm afraid you guys will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1509 1 forgot to ask these.
2 JUDGE KARLIN: I think Dr. Wardwell has 3 raised a concern that I have and I think we all have 4 and so again. I'll turn and I'm going to maybe go over 5 a little more ground, but hopefully it will clarify it 6 for me.
7 Mr. Fitzpatrick, let's go to Exhibit E 8 04 which is part of your application. Now under the 9 regulations it's required that the application 10 demonstrate that aging management program will -- aging 11 management will be adequately managed during the 12 period of extended operations. The application is 13 supposed to demonstrate that and that's part of what's 14 been challenged here. They're saying it hasn't 15 demonstrated that.
16 Now I'm trying to find where in the 17 application is the flow-accelerated corrosion plan and 18 is E-4-04 the sum entirety of the flow-accelerated 19 corrosion plan in the application?
20 MR. FITZPATRICK: As described in the 21 application.
22 JUDGE KARLIN: Yes, in the application.
23 The application which is supposed to demonstrate that 24 it will be adequately managed. So these page 1-8 is 25 the whole plan.
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1510 1 MR. FITZPATRICK: It's not the whole plan.
2 What's --
3 JUDGE KARLIN: It's in the application.
4 And let me ask on the first sentence, "the 5 flow-accelerated corrosion program at Vermont Yankee 6 is comparable to the program described in NUREG 1801",
7 etcetera.
8 Next sentence, "this program applies."
9 When it says this program is it referring to the 10 immediately preceding referenced program?
11 "This program applies" -- to me, I read.
12 that to say the GALL program. There are two programs 13 referred to in the preceding sentence. When this 14 sentence says "this program applies" which program is 15 it referring to?
16 MR. FITZPATRICK: The flow-accelerated 17 corrosion program at VY.
18 JUDGE KARLIN: How do we know? That 19 doesn't look like it says that to me. Okay, I'll take 20 your word for it because that's your intent anyway.
21 And this program is based on -- when it 22 says -- next paragraph. It says "the program based on 23 EPRI report NSAC-202L." Isn't that referring to the 24 NUREG program?
25 MR. FITZPATRICK: There's no NUREG --
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1511 1 JUDGE KARLIN: Your program refers to the 2 GALL program which then refers to the EPRI program.
3 It's like Russian dolls all inside of each other, it's 4 getting smaller and smaller.
5 MR. FITZPATRICK: There is only one FACG 6 program. It's the existing program.
7 JUDGE KARLIN: This is the flow-8 accelerated corrosion program for this license 9 application, right here, this page.
10 You've already established there's nothing 11 in the application that makes any. reference to the 12 fact that you're going to adopt or use the existing 13 program. And if you've got anything on that, I'd like 14 to see it. I see you testified to that, but in the 15 application itself there's nothing said about that, at 16 least nothing you've presented to me. *This is the 17 whole application right here, I guess.
18 It's astounding. There's no beef in this 19 thing.
20 Now -- hold on a second.
21 JUDGE WARDWELL: While you're looking, I 22 can ask a question --
23 JUDGE KARLIN: Yes, sure.
24 JUDGE WARDWELL: Take your time. Start 25 with Entergy. We've interchanged and you hear this a
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1512 1 lot. Some people- call it aging management program, 2 some people call it an aging management plan. In your 3 mind, is there any difference?
4 MR. FITZPATRICK:. .A program is something -
5 6 JUDGE WARDWELL: Is there an aging 7 management plan?
8 MR. FITZPATRICK: It could be a plan.
9 Programs are typically more formal.
10 JUDGE WARDWELL: Sorry? Which is?
11 MR.. FITZPATRICK: You would consider a 12 program more formal than a plan in generality. We 13 have program in place. It's a program and it's got 14 procedures, requirements.
15 JUDGE WARDWELL: But when someone says an 16 aging management plan, there's nothing significant 17 about that misnomer, is there?
18 MR. FITZPATRICK: No.
19 JUDGE WARDWELL: In fact, you have 20 yesterday, I'm not sure that you were the witness, but 21 with the steam dryer, we had monitoring programs and 22 they were part of a plan. So in fact, the plan was 23 pretty formal and here's some details of it. At other 24 times, the program has plans within it. Is that 25 correct?
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1513 1 MR. FITZPATRICK: It could be, yes.
2 JUDGE WARDWELL: So inherently, just by 3 those words, it provides no implicit representation of 4 the complexity of either of those terms. Is that fair 5 to say in an enigineering sense?
6 MR. FITZPATRICK: In an engineering sense.
7 JUDGE WARDWELL: Staff, would you agree 8 that there is no real significance between whether a 9 program or a plan was used as the *end of a 10 nomenclature of any given thing? It would have to be, 11 it would have to stand on its own and not rely on the 12 definition of either program or plan to exactly 13 determine its complexity or the details, etcetera?
14 MR. ROWLEY: Correct.
15 JUDGE WARDWELL: You would agree with 16 that. And NRC, would you agree that there is no 17 significant difference between those two?
18 MR. WITTE: My background in configuration 19 20 JUDGE WARDWELL: Speak up please and 21 enunciate.
22 MR. WITTE: Okay. My background is in 23 configuration management and issues exactly like that 24 definition that you're wrestling with. A plan, in my 25 experience, in 28 years, is a finite task to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1514 1 accomplish something. A program, in the vernacular, 2 in the industry, is a living program that is, does not 3 have a finite life, that is laid down until someone 4 chooses to terminate it. There are differences.
5 JUDGE WARDWELL: Is a program above plan 6 or below it or aside it?
7 MR. WITTE: Any of the three. I'm sorry 8 to answer it that way, but typically a program is a 9 higher sphered documenE than a plan. A plan may ask 10 for a program and a program may ask for specific plans 11 as part of that program. Now I have thoroughly 12 confused Your Honor.
13 JUDGE WARDWELL: Sure did. Sounds like 14 this is a technical area that generalities, for anyone 15 besides configuration managers, probably plan and 16 program would be one and the same and they wouldn't 17 provide, they haven't provided any implicit 18 characteristics to the resulting documents, whether it 19 was categorized as a program or a plan for the general 20 engineering community associated with nuclear power.
21 MR. WITTE: Essentially, you have to read 22 past the words to figure out what they're talking 23 about.
24 JUDGE WARDWELL: Thank you.
25 JUDGE KARLIN: Now there are a couple of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1515 1 questions for the staff now. I would like you to 2 refer to the FSER page 3-15, please, Mr. H~su and Mr.
3 Rowley. Do you have that in front of you?
4 MR. ROWLEY: Yes.
5 MR. HSU: Yes.
6 JUDGE KARLIN: Great. And I would also 7 like you to refer to Exhibit E-4-04 at the same time.
8 Now this page 3-15 is the flow accelerated 9 corrosion program discussion in the FSER. Is that 10 correct, Mr. Hsu?
11 MR. HSU: Yes.
12 JUDGE KARLIN: Mr. Rowley?
13 MR. ROWLEY: Yes.
14 JUDGE KARLIN: And I would like you to 15 focus for a moment on the second full paragraph in 16 that page 3-15. The first sentence of that paragraph, 17 I would like you to compare that to the second 18 sentence in E-4-04.
19 MR. ROWLEY: It's the same, sir, except 20 for we wrote out, equated in equal two.
21 JUDGE KARLIN: So it is the identical 22 sentence except you wrote out greater than two?
23 MR. ROWLEY: Correct.
24 JUDGE KARLIN: Did you have quotation 25 marks around that when you quoted the application NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1516 1 verbatim?
2 MR. ROWLEY: Sir, understand that the 3 section you are reading is the summary of technical 4 information of the application.
5 JUDGE KARLIN: I realize that it is a 6 summary, but I didn't realize that you were quoting 7 the application. I thought you were stating something 8 in your own words. If you were quoting it, shouldn't 9 you put quotes around it?
10 MR. ROWLEY: We may should have done that ii 12 JUDGE KARLIN: Let's look at the next rest 13 of that paragraph.
14 MR. ROWLEY: The whole section is from the 15 application.
16 JUDGE KARLIN: It's a summary of the 17 application, it purports to be. It doesn't purport to 18 be a quotation of the application.
19 MR. ROWLEY: Correct.
20 JUDGE KARLIN: Let's look at the rest of 21 that paragraph which starts with "the program, based 22 on Electric Power Research Institute" blah, blah, blah 23 until the end. I would ask you to look at the third 24 paragraph in the E-4-04.
25 MR. ROWLEY: Yes.
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1517 1 JUDGE KARLIN: Isn't it true that that's 2 a verbatim quote from the application?
3 MR. ROWLEY: It is.
4 JUDGE KARLIN: And you didn't put it in 5 quotes?
6 MR. ROWLEY: We did not.
7 JUDGE KARLIN: And didn't the Inspector 8 General of the NRC take the staff to task for failing 9 to put quotation marks around parts of the FSER when 10 they were quoting?
11 MR. ROWLEY: They asked us to make sure we 12 were able to distinguish who said what.
13 JUDGE KARLIN: Right. And do you think 14 this accomplishes that?
15 MR. ROWLEY: We specifically state from 16 the application and that is contributed to --
17 JUDGE KARLIN: Where do you state that 18 you're quoting the application? It's a summary -- it 19 says summary of technical information in the 20 application. It doesn't say quotation of technical 21 information.
22 MR. ROWLEY: Right, but it's clearly 23 attributing everything there to the application.
24 JUDGE KARLIN: I think that's very 25 misleading and I think the staff should put things in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1518 1 quotes as the Inspector General indicated when you're 2 quoting because this is not a summary. This is a 3 quote.
4 MR. ROWLEY: We'll take that into 5 consideration.
6 JUDGE KARLIN: The NRC lawyers have 7 indicated to the Commissioners that they would try to 8 implement the recommendation of the Inspector 9 General's report and I just think you ought to have a 10 lawyer involved sometimes in working this out.
11 Because this is a quote. This isn't a summary.
12 MS. UTTAL: Excuse me, Your Honor --
13 JUDGE KARLIN: Yes.
14 MS. UTTAL: I don't think that this is 15 relevant --
16 JUDGE KARLIN: It is relevant and I'm 17 going to continue because I want to know what the 18 program is and I'm not finding out what the program 19 is. It seems to be an empty box.
20 Let's go down to the bottom of that page, 21 the penultimate paragraph, the second to the last 22 paragraph and as you say in a letter dated January 31, 23 2004, Vermont Yankee provided information. In this 24 letter, the Applicant provided its expected changes 25 and its flow-accelerated corrosion program. That's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1519 1 2004 flow-accelerated corrosion program?
2 MR. ROWLEY: Yes.
3 JUDGE KARLIN: What are we talking about 4 that for? The application didn't even come in until 5 2006?
6 MR. ROWLEY: They made changes to the 7 power uprate.
8 JUDGE KARLIN: This is not the uprate.
9 MR. ROWLEY: Right, but it gets tied into 10 license renewal because they are --
11 JUDGE KARLIN: How is it tied into license 12 renewal? Does the application say that they're going 13 to use that program?
14 MR. ROWLEY: No. Maybe not. It's 15 explicitly stated in the application that the program 16 they're currently using is the one they're going to 17 use. It's an existing program, sir.
18 JUDGE KARLIN: It's an existing program.
19 MR. ROWLEY: Correct.
20 JUDGE KARLIN: And it expires when the 21 license expires in 2010, 2012, right?
22 MR. ROWLEY: 2012. And if it's renewed it 23 carries forward.
24 JUDGE KARLIN: How do we know it carries 25 forward? How do I know it carries forward?
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1520 1 This paragraphs talks about -- there's a 2 reference in it "flow-accelerated corrosion program" 3 right?
4 MR. ROWLEY: Yes.
5 JUDGE KARLIN:. Next paragraph. And then 6 it-says "the staff noted that the selection criteria 7 were based in part on checklists."
8 Next page, page 3-16, first paragraph. Is 9 that paragraph discussing a flow-accelerated corrosion 10 program that you're talking about that was submitted 11 in 2004? The staff verified that the flow-accelerated 12 corrosion includes applicable acceptance criteria.
13 MR. ROWLEY: No, that's the current --
14 JUDGE KARLIN: Wait a minute, "the staff 15 verified that the flow-accelerated corrosion program" 16 -- that's the one that you were referring to in the 17 preceding paragraph?
18 MR. ROWLEY: That's the one from the 19 application from the preceding paragraph.
20 JUDGE KARLIN: Well, you had a capitalized 21 word in paragraph -- on page 3-16: flow-accelerated 22 corrosion program. Now later two paragraphs later you 23 use that same word, capitalized, flow-accelerated 24 corrosion program, so I assume you're referring to the 25 same program?
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1521 1 MR. ROWLEY: Yes, it is the same program.
2 JUDGE KARLIN: And then that paragraph 3 says "the staff finds this approach for aging 4 management to be acceptable because it is in 5 conformance with GALL." Right?
6 MR. ROWLEY: That's correct.
7 JUDGE KARLIN: So you're finding that 8 their 2004 program meets GALL?
9 MR. ROWLEY: No, the current program.
10 JUDGE KARLIN: The current program, okay.
11 MR. ROWLEY: Because 2004, there were some 12 changes made to the program due to the power uprate 13 and that carries forward. Because when you increase 14 by 20 percent 15 JUDGE KARLIN: All right, so it's the 16 current program, the one that they're using for their 17 current license that expires in 2012?
18 MR. ROWLEY: Right.
19 JUDGE KARLIN: And so the discussion in 20 the next paragraph, based on this review, the staff 21 concludes the program elements for the Applicant's 22 flow-accelerated corrosion program, all caps, provide 23 an adequate basis to manage. Again, you're referring 24 to the current program?
25 MR. ROWLEY: Correct.
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1522 1 JUDGE KARLIN: And the next paragraph 2 you're also referring to the current program?
3 MR. ROWLEY: Yes.
4 JUDGE KARLIN: And we've already 5 established, is there anywhere in this FSER where you 6 reflect the fact that the current program will be 7 binding upon them for the period of extended 8 operation?
9 MR. ROWLEY: It's not stated --
10 JUDGE KARLIN: You don't state it 11 implicitly either, do you?
12 MR. ROWLEY: Well, we know this is their 13 application, this is what they --
14 JUDGE KARLIN: You know that?
15 MR. ROWLEY: To review.
16 JUDGE KARLIN: Is it in the application 17 that they'll do that? Is it in the FSER that they'll 18 do that?
19 MR. ROWLEY: No, sir --
20 JUDGE KARLIN: Is it in the license 21 commitment? Fifty-one license commitments of Appendix 22 A of the FSER. Is it in there that they commit to do 23 that?
24 MR. ROWLEY: I have to see. They put it 25 into the UFSAR and that's binding.
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1523 1 JUDGE KARLIN: They put it into the UFSAR.
2 What does that mean?
3 MR. ROWLEY: They --
4 JUDGE KARLIN: That's in their report.
5 It's not a commitment, is it?
6 MR. ROWLEY: It is part of their --
7 JUDGE KARLIN: It's a report they submit 8 to you.
9 MR. ROWLEY: Correct.
10 JUDGE KARLIN: Is it a license condition?
11 MR. ROWLEY: It's --
12 JUDGE KARLIN: Is there anywhere in the 13 commitments --
14 MR. ROWLEY:. I can check. They have 15 committed to do certain programs and their commitment 16 list -- let me review it and I will see if the flow-17 accelerated corrosion program is one of those.
18 (Pause.)
19 No, that's not one of the programs they 20 have committed to implement for --
21 JUDGE KARLIN: All right, is it anywhere 22 in the licensing condition, Section 1.7 --
23 MR. ROWLEY: No, it's not an explicit 24 commitment to do the flow-accelerated corrosion 25 program, neither are any of the other programs that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1524 1 asked them.
2 JUDGE KARLIN: Could you speak up?
3 MR. ROWLEY: Neither are any of the other 4 programs not just 5 JUDGE KARLIN: Well, there are a lot of 6 commitments. There's 51 of them.
7 MR. ROWLEY: Correct. For them to -- they 8 didn't necessarily have to commit to an existing 9 program. They're already doing it. The CLB says that 10 what they're doing today, our license renewal 11 principle is what they're doing today, as far as the 12 current licensing basis will carry forward into the 13 period of extended operation if granted. That's how 14 it works.
15 I don't know -- that's just part of our 16 license renewal principles. It's a new license.
17 What's in their present license is updated. We modify 18 it a little bit and that new license contains old 19 stuff plus this new stuff of license renewal and 20 carries forward.
21 JUDGE KARLIN: So everything in their 22 current license goes over to their new license --
23 MR. ROWLEY: Correct.
24 JUDGE KARLIN: And no one has to say that?
25 MR. ROWLEY: The license itself states NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1525 1 that because we don't change other than adding to it.
2 We don't delete anything.
3 JUDGE KARLIN: But the application has to 4 demonstrate that they will manage aging. I don't see 5 it in the application.
6 MR. ROWLEY: We perform the review of 7 their program which they just gave a description of 8 the program. It's not a lengthy, drawn out -- because 9 if they were to do that applications would come in.
10 JUDGE KARLIN: Who big is the application?
11 A hundred pages?
12 MR. ROWLEY: Over a thousand.
13 JUDGE KARLIN: A thousand pages and you're 14 worried about being too lengthy and drawn out?
15 MR. ROWLEY: Well, it would be 16 superfluous.
17 JUDGE KARLIN: Oh.
18 MR. ROWLEY: To put all this stuff in. We 19 know we're going to do audits. We go and we look at 20 the documentation. Maybe not the public, but yes, we 21 do.
22 JUDGE KARLIN: You know, but as you say 23 the public doesn't know, do they?
24 MR. ROWLEY: No.
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1526 1 have any more questions.
2 Do we want to take a break? Why don't we 3 take a break. It's 10:05. We will take a 15-minute 4 break. We stand adjourned.
5 (Off the record.)
6 JUDGE KARLIN: We're now back on the 7 record. I would remind the witnesses you're still 8 under oath please and we will continue with the 9 questioning.
10 JUDGE WARDWELL: Mr. Fitzpatrick, 11 returning back to the EPRI NSAC-202L E4-07, page four, 12 Section 4.3, pages four to five of that section.
13 MR. FITZPATRICK: Section 4.3? I missed 14 that.
15 JUDGE WARDWELL: Yes, it's -- I have 16 Section 4.3. Yes, page 4-5. I'm sorry. That's where 17 my confusion was. Yes. Section 4.3, page 4.05 of 18 E04-07 and it says, "It has recognized that even small 19 power applies." I'm sorry. That's the wrong quote 20 here. I apologize. Yes, at the very top of that 21 right under "Performing FAC Analysis." It says, "Once 22 susceptible large bore piping systems have been 23 identified, it is recommended that detailed FAC 24 analysis be performed by CHECWORKS" I think is what 25 the sentence basically says. How are small bore NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1527 i piping systems handled?
2 MR. FITZPATRICK: Small bore piping 3 systems, all the piping systems are identified as FAC 4 susceptible or not in a susceptibility screen and --
5 for the CHECWORKS or a -- All the small susceptible 6 small bore piping becomes a population that's 7 addressed under the program and --
8 JUDGE WARDWELL: Under the --
9 MR. FITZPATRICK: -- under the FAC.
10 JUDGE WARDWELL: Okay.
11 MR. FITZPATRICK: Locations on those, the 12 small bore piping, generally are from found community 13 dispute disparities. We started inspecting small bore 14 lines in '93 and '95 for NSAC guidance on small bore 15 resolving. They are based on a majority of the small 16 bore inspections in the '93 and '95 time frame.
17 JUDGE WARDWELL: This might be a good time 18 and I didn't have it on my question list at this stage 19 and I know it's further in those question lists. But 20 rather than dig out my question, Dr. Horowitz 21 references earlier also that there are things besides 22 CHECWORKS that dictate where an inspection will be 23 done and there are other things in the program besides 24 CHECWORKS. CHECWORKS isn"t the end-all or be-all of 25 the management program. There are some factors. Do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1528 1 you remember those off the top of your head? If you 2 don't, that's fine. I'll get to it and I'll have a 3 reference for it.
4 MR. FITZPATRICK: Yes. Industry 5 experience is one. Previous inspection data in the 6 plant from previous inspections we identified a 7 component should be. We inspected CHECWORKS modeling 8 for large bore. Maintenance records, we find out the 9 valves and leaking. We put the piping -- and 10 inspection and scope in the next outage and ensure 11 that there's no damage. OE is a big thing. OE is, 12 operational experience you impose. You use quite a 13 bit.
14 JUDGE WARDWELL: Okay. Thank you. On 15 page 4-7, I'm mean Figure 4-7 on page 425. Yes.
16 Figure 4-7 shows a relationship between plant 17 operating time and component fitness. And in that 18 diagram, it shows a range of UT inaccuracies and 19 illustrates their point that they're trying to 20 illustrate there.
21 MR. FITZPATRICK: Yes.
22 JUDGE WARDWELL: My question deals with 23 has that error analysis for UT testing been determined 24 at Vermont Yankee.
25 MR. FITZPATRICK: We count the defects of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1529 the error, the possible error, in UT analysis in a wear rate predictions prompt actual data. We put a 1.1. In the past, they put a 1.2 factor in the old procedure. We use a 1.1 factor on the wear rate calculated for the number of measured inspections --
JUDGE WARDWELL: So that 1.1 came from this range of UT inaccuracies.
MR. FITZPATRICK: Yes, that was an intended item and I think it was included in the 10 section below there, Safety Factor 473.
11 JUDGE WARDWELL: I'm sorry. Where are you 12 pointing to?
13 MR. FITZPATRICK: The same -- Page 425.
14 JUDGE WARDWELL: Yes.
15 MR. FITZPATRICK: Right below there. The 16 predicted wear, when you get into predicted wear you 17 put a safety factor on it to -- You measure where you 18 put a safety factor on the measured wear for your 19 predicted thickness.
20 JUDGE WARDWELL: So you say you increase 21 -- Did you say by ten percer Ten percent.
22 MR. FITZPATRICK:
Ten percent.
23 JUDGE WARDWELL:
24 MR. FITZPATRICK: Currently ten percent 25 from the beginning to mid 20.
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1530 1 JUDGE WARDWELL: Okay. But that's a 2 safety factor. Do you have the actual plus or minus 3 accuracy of your UT measurements?
4 MR. FITZPATRICK: On the instruments that 5 we've been using with data that is published it is 6 plus or minus 0.004 inches.
7 JUDGE WARDWELL: And what are the wall 8 thicknesses? In relation to the wall thicknesses?
9 MR. FITZPATRICK: Feedwater, 16 inch 10 feedwater is 1.216. Eighteen inch feedwater is 1.375.
11 JUDGE WARDWELL: What's your thinnest 12 design pipe?
13 MR. FITZPATRICK: Design pipe, the small 14 bore could be like one quarter inch thick.
15 JUDGE WARDWELL: But no thinner than one 16 quarter inch.
17 MR. FITZPATRICK: Typically, they might --
18 I mean it's three quarter inch lines and we get into 19 a real small line maybe like three-sixteenths.
20 JUDGE WARDWELL: Okay.
21 JUDGE REED: Did I understand that the 22 accuracy of the ultrasonic testing was 0.004 of an 23 inch?
24 MR. FITZPATRICK: Plus or minus 0.004 as 25 published in the regional -- EPRI.
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1531 1 JUDGE REED: Thank you. -
2 JUDGE WARDWELL: Going on to Section 4.9 3 on page 427 to 428, the first paragraph end of the 4 third line down, the sentence starts, "It is 5 recommended that only one safety factor be used in the 6 process and that it be applied when determining 7 fitness for continued service and the reinspection 8 interval." Would you elaborate more on what that 9 means? What does that safety factor at Vermont 10 Yankee?
11 MR. FITZPATRICK: That's 1.1 on the 12 predicted fitness. You take a measurement at a 13 refueling outage and you calculate the wear from 14 either previous measurements or methods recommended by 15 EPRI that have been demonstrated to show some 16 conservatism or wear. Then you apply the safety 17 factor of the predicted thickness at the next outage.
18 I call it peak predicted. So you always predict the 19 wear an outage ahead to make sure that it's still 20 going to -- if we have wear it will meet the Code in 21 the next outage. You're always looking one cycle 22 ahead when you do this.
23 JUDGE WARDWELL: And --
24 MR. FITZPATRICK: The -- Excuse me.
25 JUDGE WARDWELL: I'm sorry.
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1532 1 MR. FITZPATRICK: The concern is if you 2 started adding factors all along the way it just 3 mushrooms out like the diagram. You start getting all 4 possibilities.
5 JUDGE WARDWELL: And both factors that 6 you're referring to are the factors that Dr. Horowitz 7 put up on the screen yesterday.
8 MR. FITZPATRICK: No. That's totally 9 different.
10 JUDGE WARDWELL: Okay. What are they?
11 MR. FITZPATRICK: This is addressing the 12 measured wear.
13 JUDGE WARDWELL: The wear.
14 MR. FITZPATRICK: You're predicting wear 15 from measurements.
16 JUDGE WARDWELL: This is strictly the 17 inspection program. Nothing to do with the analysis 18 program.
19 MR. FITZPATRICK: No, sir.
20 JUDGE WARDWELL: Thank you.
21 MR. FITZPATRICK: Yes, sir, for your 22 question.
23 JUDGE WARDWELL: I understood. I knew 24 which way you were answering that.
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1533 I believe that in your Exhibit E4-01 on page three you 2 mention that either the aging management program or 3 CHECWORKS applies only to carbon steel and yet I saw 4 somewhere that people also reference low-alloy steel.
5 Is there a real significance with that? Do you have 6 much low-allow? Does, in fact, the program address 7 both or does it only address carbon steel? What's the 8 deal with low-allow steel?
9 MR. FITZPATRICK: The FAC is generally 10 carbon steel. If you have low-alloy steel, it 11 significantly reduces the potential for FAC. It's not 12 an absolute theory that it will never be in FAC. But 13 the protected wear rates are much, much less.
14 JUDGE WARDWELL: Dr. Horowitz, did you do 15 the modeling at Vermont Yankee or --
16 DR. HOROWITZ: No, sir.
17 JUDGE WARDWELL: Sorry.
18 DR. HOROWITZ: No, sir, I did not.
19 JUDGE WARDWELL: Mr. Fitzpatrick, in the 20 CHECWORKS modeling at Vermont Yankee, was it ever 21 applied to low-alloy steels?
22 MR. FITZPATRICK: Yes.
23 JUDGE WARDWELL: In a way that would still 24 be conservative?
25 MR. FITZPATRICK: Yes. It actually NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1534 1 predicts wear in low-alloy steels-at times and --
2 JUDGE WARDWELL: And do you see that those 3 end up being corrected a lot due to the actual 4 measurements that.the program supposedly does?
5 MR. FITZPATRICK: Yes. If you put in --
6 Early on, we did -- When CHECWORKS first came out, we 7 did inspections on low-alloy steel. We weren't seeing 8 any wear and it shows up in the CHECWORKS model where 9 all the components show long-time wear -- times the --
10 which is a measure of time (inaudible.)
11 JUDGE WARDWELL; At a constant power 12 level, how long does it take the program to self-13 correct itself with the various inspections that are 14 performed until it really focuses in on the --
15 prediction?
16 MR. FITZPATRICK: In a CHECWORKS model?
17 JUDGE WARDWELL: Yes.
18 MR. FITZPATRICK: It would depend on how 19 it modeled it, what you modeled it, whether it was 20 modeled in separate sections where -- The way we break 21 up the CHECWORKS models is the same chemical 22 processes, the same temperature conditions, the same 23 flow conditions. There are certain sections where 24 there is a few components, two or three components, in 25 that line there's enough to do it. Other sections NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1535 1 where there's a lot of piping, you may do more 2 inspections data.
3 JUDGE WARDWELL: Okay. We'll get into 4 that in more-detail probably after lunch now. I still 5 want to stay with mostly j.ust what's here and what's 6 in the aging management plan.
7 In your Exhibit 4-09, page three, and this 8 exhibit is a "Declaration of Neal Wilmshurst in 9 Support of EPRI's Opposition To Motion to Compel,"
10 page nine, page three, I'm sorry, it says, "CHECWORKS 11 is". . on number 11, it says, "CHECWORKS is not 12 recommended for use in the prediction of FAC in pipes 13 smaller than two inches in diameter." How do you 14 handle the two inches in diameter pipes?
15 MR. FITZPATRICK: Throw them in a lump 16 into the small bore program where we don't do 17 CHECWORKS analysis. We just inspect.
18 JUDGE WARDWELL: Is there a -- Where are 19 the details of that program spelled out in the license 20 renewal application?
21 MR. FITZPATRICK: In the application 22 specifically by reference to the existing FAC program.
23 JUDGE WARDWELL: Thank you. Sorry. No 24 thank you.
25 MR. FITZPATRICK: It explicitly is not in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1536 1 the license renewal application, but it's quite an 2 existing factor.
3 JUDGE WARDWELL: It's consistent with your 4 position that's embedded in all the documentation 5 somewhere with regards to reference to continuing with 6 the existing inspection program.
7 MR. FITZPATRICK: Yes.
8 JUDGE WARDWELL: Question 15, yes. I 9 mean, the paragraph 15 I guess is what this is. It 10 states that "No other person has within or without 11 EPRI has access to CHECWORKS source code or 12 mathematical algorithms.' Dr. Horowitz, what is meant 13 here by "the mathematical algorithms'?
14 DR. HOROWITZ: Basically, those f-factors 15 as shown here, a series of factors, what goes into 16 making them f-l, for example.
17 JUDGE WARDWELL: So the information in and 18 how you derive those f-factors are the algorithms and 19 not the ultimate wear equation we saw yesterday.
20 DR. HOROWITZ: I think the way they're 21 using it here would be both. It means both are the 22 means basically to form a partner statement. The 23 equation we use is the equation I showed. What's 24 proprietary is what makes up those individual factors.
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1537 1 more of those details and what those things are this 2 afternoon.
3 In NEC's rebuttal, they're maintaining 4 that there should be no distinction between leaks and 5 ruptures. I assume you believe differently and, if 6 so, would you like to explain why aren't we concerned 7 with leaks as well as the ruptures?
8 MR. FITZPATRICK: In an generic sense or 9 a specific sense?
10 JUDGE WARDWELL: We'll start with Mr.
11 Fitzpatrick. Mr. Fitzpatrick, I dodged.
12 MR. FITZPATRICK: We are concerned about 13 the leaks. We are concerned about the ruptures. But 14 I'm trying to think of the context where they're 15 saying -- A major leak is not a program -- A little 16 leak is not a program failure. Power plants do have 17 small drain lines that do leak on occasion and they're 18 addressed and small leaks in non-safety piping have 19 occurred, probably will occur in the future, but they 20 don't affect the safety of the plant.
21 JUDGE WARDWELL: Are leaks in non-safety 22 piping -- Do they fall under the aging management 23 review?
24 MR. FITZPATRICK: If they're critical to 25 the piping in the FAC program, yes, they do.
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1538 1 JUDGE WARDWELL: If they are what?
2 MR. FITZPATRICK: All leaks in any plant I system are addressed. The plant has to address them.
4 The piping that falls under the program that I've been 5 working on, we have to find, there were no corrective 6 action process, find out why it's leaking and then 7 come up with a compensatory measure for that.
8 JUDGE WARDWELL: But not all pipes fall 9 under aging management, do they?
10 MR. FITZPATRICK: All the pipes I can 11 guess the ones in the FAC do.
12 JUDGE WARDWELL: You're driving me around 13 in circles.
14 MR. FITZPATRICK: I'm sorry, sir. I'm 15 just --
16 JUDGE WARDWELL: What piping falls under 17 aging management review? I think you testified 18 earlier today. I just don't want to quote you because 19 I'll quote you wrong.
20 MR. FITZPATRICK: Thanks.
21 JUDGE WARDWELL: I'll look at the 22 transcript.
23 MR. FITZPATRICK: I'm not familiar with 24 the entire scope of the aging management program and 25 the entire scope for the license renewal application.
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1539 1 I deal with the FAC program and the piping there. I 2 know of some other piping. The service water piping 3 is under an aging management program.
4 JUDGE WARDWELL: So to cut to the quick, 5 you didn't select the types that are in the FAC 6 program. You have implemented the FAC program for the 7 pipes that were given to you.
8 MR. FITZPATRICK: No. I think you drilled 9 down a little bit too much. Up here, we identified 10 what's in the scope of the FAC program in the 11 susceptibility evaluation and we looked at all the 12 piping in the plant. This is before the license 13 renewal application. You screen all the piping in the 14 plant and identify what should be in the FAC program.
15 JUDGE WARDWELL: And in that 16 susceptibility program, what made the grade to be part 17 of the FAC program?:
18 MR. FITZPATRICK: This criteria in NSAC-19 202L and the screening criteria --
20 JUDGE WARDWELL: Can you refer us to that?
21 (Off the record discussion.)
22 JUDGE WARDWELL: Four-zero-seven.
23 MR. FITZPATRICK: I have the older 24 version, too. Yes, the Section 4.2, Identifying 25 Susceptible Systems and the criteria, you go through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1540 1 each of the systems and see if it fits one of these 2 criteria. You screen -- You take all the piping and 3 you screen it again around the program based on the 4 criteria in Section 4.22.
5 JUDGE WARDWELL: Mr. Rowley.
6 MR. ROWLEY: Yes.
7 JUDGE WARDWELL: Am I pronouncing that 8 right by the way?
9 MR. ROWLEY: Yes, you are. Rowley.
10 JUDGE WARDWELL: Thank you. Do you 11 consider all the piping that makes this criteria in 12 4.22 to be part of the aging management program?
13 MR. ROWLEY: Yes, we did a scope and 14 screening methodology review and determined that what 15 they had put in scope for this go-around was asked.
16 JUDGE WARDWELL: Are you confident that 17 it includes all the safety piping at a minimum?
18 MR. ROWLEY: Yes.
19 JUDGE WARDWELL: Thank you.
20 What do you do about, Mr. Fitzpatrick, the 21 small leaks that you say you are concerned about but 22 really aren't in the aging management program or the 23 FAC program, I should say?
24 MR. FITZPATRICK: The piping that's within 25 the -- The piping is in the program. You said the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1541 1 leaks were in Lhe program-2 JUDGE WARDWELL: So all leaks are in the 3 program.
4 MR. FITZPATRICK: The leaks in the piping, 5 there are different aging management programs. Piping 6 falls within this program. We were concerned about 7 leaks.
8 JUDGE WARDWELL: So if it makes the NSAC 9 susceptibility criteria and it's in the program, any 10 leaks associated with that would, in fact, be 11 addressed by your FAC program but would be restricted 12 in regards to the smaller stuff related to strictly 13 inspections when you get piping so small that 14 CHECWORKS really doesn't assist you in that evaluation 15 of its integrity.
16 MR. FITZPATRICK: Yes, that would be fair.
17 JUDGE WARDWELL: Thank you.
18 I believe in the application -- Let's turn 19 to it. I'm not 100 percent sure it's there. But I'm 20 interested in some repairs that were made in 1995. Is 21 that referred to in the application? I happened to 22 reference that and I just don't know why I referenced 23 that as I turn to it.
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1542 I anyhow --
2 MR. FITZPATRICK: -- Appendix B on Exhibit 3 E4-04 and it was cited as an example of operating --
4 JUDGE WARDWELL: Okay. So you say it's in 5 Appendix B to that.
6 MR. FITZPATRICK: Well, Appendix B, the -
7 program we were discussing before and it cited an 8 example of operating scheme.
9 (Off the record discussion.)
10 JUDGE WARDWELL: I have another one. I 11 have a question. Yes. What were those repairs and 12 why were they conducted? That's what I wanted to 13 know.
14 MR. FITZPATRICK: That was the 1995 per 15 month to replace both low-pressure turbines and 16 turbine casings with a FAC resistant material. The 17 piping going from a high-pressure turbine to a low-18 pressure turbine had been showing FAC wear. We had 19 been done periodic inspections and repairs.
20 At the same time, the moisture separators 21 that go between the high-pressure turbine was modified 22 to take out more moisture. Than we saw wear and we 23 did an inspection, alone we probably had 95, to build 24 any piping wall thickness on the inside that was below 25 the required thickness of the design basis.
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1543 1 JUDGE WARDWELL: In your testimony to 2 answer 18, that should be on page 10-11. It says the 3 FAC program includes several activities and it goes on 4 to describe what those are and then references the use 5 of CHECWORKS. Is.CHECWORKS the only program that can 6 be used to do any of these analyses?
7 MR. FITZPATRICK: No.
8 JUDGE WARDWELL: There are other programs 9 out there.
10 MR. FITZPATRICK: Commercially available, 11 not to my knowledge.
12 JUDGE WARDWELL: Dr. Horowitz.
13 DR. HOROWITZ: Yes, there are. There are 14 what I would call two similar products. One is the 15 BRT-CICERO Program which was issued about ten years 16 ago by EDF, Electricite de France, and there's a 17 program by AVERA called COMSY, C-O-M-S-Y. There's 18 also a Russian program. I think it's called REMEK.
19 I think it's in Mr. Wilmsh~urst's affidavit which I 20 have heard described but I don't really know if it's 21 a commercial product.
22 JUDGE WARDWELL: Mr. Fitzpatrick, why did 23 you select CHECWORKS?
24 MR. FITZPATRICK: Because it's industry 25 accepted guidance and there needs to be consensus to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1544 1 use CHECWORKS.
2 JUDGE WARDWELL: Do you know of any other 3 plant that has used any other program but CHECWORKS in 4 the United States>
5 MR. FITZPATRICK: Early on, some of the 6 plants had different models or some programs were 7 developed themselves. I'm not too sure, but I think 8 everybody -- didn't know the status, but I think all 9 the plants have adopted CHECWORKS.
10 JUDGE WARDWELL: Dr. Horowitz, have you 11 cornered the market in the United States in regards to 12 this aspect in the industry's need?
13 (Laughter.)
14 DR. HOROWITZ: Yes. All the nuclear units 15 in the United States, Canada and Mexico use CHECWORKS 16 now as well as a few plants in Europe and some in 17 Asia.
18 JUDGE WARDWELL: Thank you.
19 Mr. Horowitz, in your answer of 18, part 20 of it says that there has to be some baseline 21 inspections performed prior to those inspections 22 performed to confirm predictions from CHECWORKS.
23 Correct?
24 DR. HOROWITZ: The --
25 JUDGE WARDWELL: No, Mr. Fitzpatrick. Did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1545 1 I say Mr. Horowitz?
2 MR. FITZPATRICK: You said Horowitz.
3 JUDGE WARDWELL: I meant Mr. --
4 MR. FITZPATRICK: Yes, those inspections 5 have been on-going since 1989.
6 JUDGE WARDWELL: If you change a power 7 rate, do you have to change your baseline inspections?
8 MR. FITZPATRICK: No.
9 JUDGE WARDWELL: And why not?
10 MR. FITZPATRICK: Let me clarify my 11 answer. I'm not changing how I'm inspecting. I am 12 changing the number of inspections since we did the 13 power uprate so I have more data to calibrate the 14 models recognizing that some things are going to 15 change in the model. We've added more inspections 16 since we've started as of the power uprate than we did 17 prior to power uprate. That's to get more data to 18 feed into CHECWORKS and to have more data with power 19 uprate flows to develop a level of confidence in 20 measured and predicted wearing.
21 JUDGE WARDWELL: Didn't we talk about 22 earlier this morning how CHECWORKS is or flow 23 accelerated corrosion is very sensitive to power 24 uprates?
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1546 1 insight and that could be for one particular line with 2 the phase changes. Some lines, I've seen power uprate 3 studies in other plants where other lines change 4 nothing. Other lines go up significantly. Other 5 lines go down.
6 JUDGE WARDWELL:. So you don't have any 7 idea what's going to happen at the power uprate at any 8 given line until it happens, until you actually 9 perform it.
10 MR. FITZPATRICK: No. Most of the single 11 phase changes I've seen in proportion with velocity 12 given everything else is similar. So prior to going 13 with power uprate we started -- we were going to 14 factor -- we've taken all existing data and factored 15 the wear rates calculated from the measured data by 25 16 percent reject total. We trend data from actual 17 inspection measurements. We don't use CHECWORKS for 18 trending wear.
19 JUDGE REED: You used a term I don't 20 understand, the word "line." It was also used in your 21 presentation yesterday, Dr. Horowitz. Would you 22 explain what is a "line"? And is it a line of piping 23 or tell me what.
24 DR. HOROWITZ: In CHECWORKS, a line or an 25 analysis line is a collection of components. In NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1547 1 practice, it's a piece of piping from here to here and 2 possibly a parallel bit as well. But it's chosen by 3 methodology as I discussed very briefly yesterday.
4 The attributes of a line should be it has the same 5 water chemistry and roughly the same temperature along 6 the line. So we feel that any determent wear or wear 7 rate in any individual component in that line is 8 relatable to any other component in that line and 9 experience backs that up.
10 JUDGE REED: They are all experiencing the 11 same wear rate.
12 DR. HOROWITZ: No. They will not. They 13 will -- The wear rate they will experience will differ 14 by the local geometry.
15 JUDGE REED: And then I didn't understand.
16 What's -- You said they were relatively -- the same 17 relative to each other.
18 DR. HOROWITZ: Okay. They --
19 JUDGE REED: What's the reason to group 20 something, a connection of components, into something 21 called a line?
22 DR. HOROWITZ: Okay. If you think back 23 about one of the slides I showed yesterday, the one 24 with the simplified equation, with the number of 25 factors, it seems reasonable and this is what we did NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1548 1 20 years to say that the greater number of factors in 2 common between different components the more accurate 3 the comparisons were. The more accurate comparisons 4 would be among the components in the line.
5 So let's take an example. Let's have 6 constant diameter line that has an elbow, that has a 7 45-degree elbow, has a valve, has a reducer, 8 something, whatever. The components in that line will 9 have the same dissolved oxygen, will have the same pH, 10 will have the same temperature, will have the same 11 flow rate. So in that case what's different i.s the 12 local velocity with the changes and what we call the 13 geometry factor which is specific to a type of 14 fitting. Okay. So a 90-degree elbow wears a little 15 more than a 45-degree elbow. A pipe downstream with 16 a valve wears more than a 90-degree elbow. So by 17 taking data on that analysis line and comparing 18 inspections, we have done everything possible to 19 minimize the random scatter inherent in the growth and 20 process.
21 So what the analyst does is by breaking 22 the plant into lines analyzes looking at comparisons.
23 If the comparison is good, the analyst says, "Well, if 24 the comparison is good for the sample of inspection --
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1549 1 predictions of the other components. If, on the other 2 hand, there isn't good comparison, then the analyst 3 either has to take more inspections or try to 4 understand what's going on. And this is kind of a 5 continuing process.
6 (Off the record comment.)
7 JUDGE WARDWELL: Mr. Fitzpatrick, when you 8 first were back talking about these baseline 9 inspections, did you -- was CHECWORKS implemented when 10 the plant first started up in the '70s?
11 MR. FITZPATRICK:. No.
12 JUDGE WARDWELL: It wasn't.
13 MR. FITZPATRICK: No, there was no 14 CHECWORKS program.
15 JUDGE WARDWELL: So at some point you 16 installed CHECWORKS and started using it. Is that 17 correct?
18 MR. FITZPATRICK: Yes.
19 (Off the record discussion.)
20 JUDGE WARDWELL: Were you there at the 21 time that i t was first implemented?
22 MR. FITZPATRICK: Yes, sir.
23 JUDGE WARDWELL: Did you do baseline 24 inspections at that time?
25 MR. FITZPATRICK: We had been doing --
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1550 1 There was a predecessor, two predecessor programs to 2 CHECWORKS, CHEC, CHECMATE and CHECWORKS and CHEC came 3 out late '87, early '88 after the Surry and it could 4 handle single phase piping.
5 JUDGE WARDWELL: . And did you install that 6 at Vermont Yankee?
7 MR. FITZPATRICK: You don't install it.
8 You analyze it On a computer.
9 JUDGE WARDWELL: That's fine. Yes.
10 MR. FITZPATRICK: We use that to help 11 select the first set of inspections right after -- the 12 first set of inspections.
13 JUDGE WARDWELL: Okay, and how many of 14 these inspections were considered? What makes a 15 inspection a baseline inspection as opposed to 16 inspections to confirm predictions? Are they more 17 frequent to start with that you gain several of these 18 to get a feeling for what the variability of your data 19 is and then use some average value of that to start 20 the feedback program or the baseline condition that 21 you establish when you first set up the CHEC or 22 CHECWORKS model?
23 MR. FITZPATRICK: You start adding data 24 into CHECWORKS and it counts when that data is 25 included and it will factor all that into the wearing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1551 1 calculation.
2 DR. HOROWITZ: Along with that, I want to 3 clarify the terminology. I think by baseline 4 inspection Jim means first inspection and in one 5 previous .addition to then CHEC we talked about initial 6 inspection which is perhaps a better term than 7 baseline because initial inspection could be how a 8 component that's been in service for a number of years 9 and has a degradational record. Baseline to me 10 implies that the component hasn't been exposed to 11 service. So it's brand new.
12 JUDGE WARDWELL: But there's really not 13 much significance. The day you start using this 14 program, I mean, the day you first start taking 15 measurements the pipe is what it is and --
16 DR. HOROWITZ: No. Excuse me. I'm just 17 clarifying the terminology.
18 JUDGE WARDWELL: Right. Fine. We can 19 call it initial or baseline whichever we want to.
20 Where I'm getting at is did you only take one set of 21 measurements for your initial/baseline inspection or 22 did you take several spread out over a period of time 23 short enough that you don't expect any wear but long 24 enough so that you get -- you're sure you're not --
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15.52 1 error bar around your measurements. That's what I 2 interpret to be what initial/baseline inspections 3 would be used for.
4 MR. FITZPATRICK: Yes. We're taking 5 multiple measurements of certain components and we're 6 taking peak inspections and slope. There are two 7 pieces to this. We do some of the peak inspections on 8 components and we inspect more components. So that's 9 a combined database.
10 JUDGE WARDWELL: Every time you're dealing 11 with a new component that hasn't been measured before 12 and isn't part of a line within CHECWORKS or is in a 13 line but now is an area that's all of a sudden come up 14 as susceptible to flow accelerated corrosion.
15 MR. FITZPATRICK: (Inaudible.)
16 JUDGE WARDWELL: Okay.
17 MR. FITZPATRICK: All the components will 18 be considered as susceptible in that line.
19 JUDGE WARDWELL: Okay.
20 MR. FITZPATRICK: You can put inspection 21 data like the components and it will take the initial 22 predictions and factor them into measured wear. And 23 as you add components, it just adds more data to 24 improve that correlation where you can take -- You end 25 up with a better correlation than you predicted. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1553 1 it's depicted to the measure with more data.
2 JUDGE WARDWELL: But I thought you said as 3 you add components.
4 MR. FITZPATRICK: Over time. You do so 5 many inspections or an outage. The next --
6 JUDGE WARDWELL: So your components are 7 datapoints or results from inspections?
8 MR. FITZPATRICK: Yes.
9 JUDGE WARDWELL: I view components as what 10 I thought Dr. Horowitz was saying make up a line.
11 MR. FITZPATRICK: No. Wait a minute.
12 Each component has inspection data associated with it 13 and there's a dataset for that component and that's 14 tracked. For example, an elbow. Back in '90, we 15 measured the elbow. In '95, I measured the elbow 16 again. In 2001, I may have measured that again. So 17 I have three sets of data for that one elbow.
18 JUDGE WARDWELL: At three sets of data, 19 which is your initial/baseline data? Which is your 20 predictive data to refine prediction?
21 MR. FITZPATRICK: The only thing we need 22 for credit is the actual data. The predictive, 23 whatever comes out of CHECWORKS is what comes out of 24 CHECWORKS. Sometimes there was a discrepancy between 25 -- CHECWORKS generally shows you have more wear than NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1554 1 what we're actually seeing in the --
2 JUDGE WARDWELL: Okay. Let me try to 3 explain it another way. You're going to add a 4 component in to your measurements. You're going to 5 start taking measurements of a component starting 6 today.
7 MR. FITZPATRICK: Yes.
8 JUDGE WARDWELL: And it's never been 9 measured before. But all of a sudden you're going to 10 do that for whatever reason. To input into CHECWORKS, 11 you need to install a thickness, a wall thickness, to 12 start with. Is that correct?
13 MR. FITZPATRICK: Yes.
14 JUDGE WARDWELL: Dr. Horowitz?
15 MR. FITZPATRICK: We put in -- We've 16 modeled all the piping with the design thickness.
17 JUDGE WARDWELL: Okay.
18 MR. FITZPATRICK: That's our initial 19 point.
20 JUDGE WARDWELL: Regardless of when you 21 first t .ook your first measurement.
22 MR. FITZPATRICK: Well, at time zero, we 23 put it in. The plant was modeled using the standard 24 piping properties.
25 JUDGE WARDWELL: But you didn't start NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1555 1 measuring until years after it was operational.
2 MR. FITZPATRICK: Yes.
3 DR. HOROWITZ: What you put in the case of 4 Vermont Yankee is the normal practice which is that 5 you start inspecting this given elbow. What Jim puts 6 into the program is a matrix of thickness measurements 7 corresponding to a grid.
8 JUDGE WARDWELL: And those are actual 9 measured.
10 DR. HOROWITZ: Those are actual 11 measurements, yes.
- 12. JUDGE WARDWELL: That's my point. Okay.
13 So you are putting in the thickness at the time you 14 started this effort.
15 MR. FITZPATRICK: Yes.
16 JUDGE WARDWELL: Is that one measurement 17 of the thickness or is it several measures of the 18 thickness so that you eliminate some of the 19 variability and you have a better estimate of what 20 that initial thickness is? That's where I'm trying to 21 get to.
22 DR. HOROWITZ: Typically, it's one 23 measurement and normally procedures, Vermont Yankee's 24 procedure, calls for a review of the data by an 25 engineer before that information is put in. So you'll NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1556 1 see a point that looks odd, looks high, looks low.
2 Then you'll normally have it reinspected before the 3 data is entered in the program.
4 JUDGE WARDWELL: But it won't be sensitive 5 enough to indicate the variability and the accuracy of 6 the ability to measure that thickness at that given 7 location in the plant.
8 MR. FITZPATRICK: I think we're touching 9 on two different subjects. The data that's put into 10 CHECWORKS is usually the minimum measurement of all 11 the measurements on that pipe and that's what you use 12 to put into CHECWORKS.
13 JUDGE WARDWELL: So you measure the pipe -
14 15 MR. FITZPATRICK: Inspection data. I've 16 been putting the minimum measurements in, the most --
17 in the worse case.
18 JUDGE WARDWELL: Dr. Horowitz, you really 19 like that approach I can see.
20 JUDGE KARLIN: Do you agree with that, Dr.
21 Horowitz?
22 DR. HOROWITZ: No. The data is what we 23 put in the matrix and the program can manipulate that 24 in various ways of the operator. I think, Jim, maybe 25 you're referring to --
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1557 1 JUDGE KARLIN: Could you refer to him as 2 Mr. Fitzpatrick because for the record please?
3 DR. HOROWITZ: Sorry. Mr. Fitzpatrick is 4 referring to a step before that. There are --
5 Virtually all large bore measurements.are made on a 6- grid, normally a square grid pattern, on the 7 components. There are two general philosophies that 8 were used. Some units will measure, put the 9 transducer right on the X that is the inspection 10 location. So thickness here is what it is. The data 11 logger writes it down. Puts the transducer on every 12 X on a component. The other --
13 JUDGE WARDWELL: And that's one 14 measurement.
15 DR. HOROWITZ: At each point.
16 JUDGE WARDWELL: To start with at each 17 point.
18 DR. HOROWITZ: Yes.
19 JUDGE WARDWELL: And there is -- What I'm 20 understanding from you, Mr. Fitzpatrick, is that you 21 don't measure that. You don't take the measurement 22 instrument, go out of the room, come back in again and 23 measure it at -- try to measure it at that same point 24 again, two or three times to get some indication of 25 the variability of your capabilities to measure it.
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-155.8 1 MR. FITZPATRICK: At the same time on the 2 same day?
3 JUDGE WARDWELL: I don't. care whether it's 4 -- I just don't want it to be -- You don't sit there 5 and press a button three times, but you try to 6 replicate you coming into that location and putting 7 that instrument on there.
8 MR. FITZPATRICK: That's why you put the 9 grids on and you put the grids on the pipe so you can 10 always get to the same location.
11 JUDGE WARDWELL: But you can't get to the 12 same location with the grids. There's a finite 13 thickness of everything. There's going to be -
14 You're not going to get it right over that every time.
15 Different operator. Whatever. There is going to be 16 some variability in your measurement.
17 MR. FITZPATRICK: Yes. There is 18 variability and -
19 JUDGE WARDWELL: Do you make any attempts 20 to try to quantify the variability of any single 21 measurement? That's what I'm trying to get at.
22 MR. FITZPATRICK: In the wear rates 23 predicted from that. We'll take -
24 JUDGE WARDWELL: No.
25 MR. FITZPATRICK: Okay.
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1559 1 JUDGE WARDWELL: Answer my question. No 2 is an answer. If it's no, it's no.
3 MR. FITZPATRICK: I can say the answer is 4 yes, but I don't --
5 JUDGE WARDWELL: Here's the pipe.
6 MR. FITZPATRICK: Yes.
7 JUDGE WJARDWELL: Here's my measuring 8 device. I measure the The thickness is X. Do I 9 live with that or do I comne right back to that same 10 grid point and try to measure it again to come up with 11 X prime and then do I come back again and measure it 12 to come up with X prime and then that's double prime 13 and then say, 'Okay. Gee, my variability, just my 14 ability to measure the thickness is such and such with 15 this particular technique and these particular 16 operators."
17 MR. FITZPATRICK: At VY, the inspectors 18 put the UT program a grid square. They'll do 100 19 percent search of that square. They move the probe 20 around and the data logger will always refer to the 21 lowest one and they'll go back in and find out, "Yeah, 22 that's the lowest: one I found" and then press the 23 button and it goes into a data log.
24 JUDGE WJARDWELL: And then do. you ten 25 minutes later after sending the operator away from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1560 1 that. location send them back and repeat that same 2 process to see what your variability is and able to 3 measure the thickness at any given point in time?
4 MR. FITZPATRICK: No.
5 JUDGE WARDWELL: Thank you. So to me that 6 says that your baseline inspection is a single 7 measurement process.
8 MR. FITZPATRICK: Yes.
9 JUDGE WARDWELL: That will help you 10 better.
11 MR. FITZPATRICK: The process itself, they 12 have a calibration block where they're calibrating --
13 JUDGE WARDWELL: I'm aware of that. The 14 calibration is a different thing than the ability to 15 reproduce the value.
16 MR. FITZPATRICK: Yes.
17 JUDGE WARDWELL: So when we start talking 18 about CHECWORKS this afternoon and we're talking about 19 the wear rates that are derived from inspection 20 programs, we know they have an error bar, that the 21 actual measurement has an error bar, around it and we 22 don't know what that error bar is. It has to be -- It 23 will be sugared out as the CHECWORKS long term 24 eventually incorporates that and the plus and minus 25 will go around whatever the mean is. But any one data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1561
.1 point we don't know what that is and that's yes, 2 right, Mr. Horowitz?
3 DR. HOROWITZ: Yes.
.4 JUDGE WARDWELL: I mean no, Mr.
5 Fitzpatrick.
6 MR. FITZPATRICK: Yes.
7 JUDGE WARDWELL: And from what I 8 understand you were saying and why you got the 9 somewhat unusual reaction from Dr. Horowitz is that at 10 Vermont Yankee you never go to one grid point. You 11 always go to a grid area and find the minimum.
12 MR. FITZPATRICK: Yes. I think we might 13 have been confusing --
14 JUDGE WARDWELL: Even though other people 15 like Dr. Horowitz is sometimes go to grid points. You 16 go to grid areas and look for the lowest.
17 MR. FITZPATRICK: Some of the confusion is 18 I think coming out from the inspections and what 19 action is for the checklist. That's where I'm --
20 JUDGE WARDWELL: Yes, I tried to mean it 21 all inspections, but I --
22 MR. FITZPATRICK: Yes. There are two 23 aspects. I think we have to talk about them 24 separately.
25 JUDGE WARDWELL: I'm only talking about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1562 1 measurements. We ain't at CHECWORKS yet.
2 DR. HOROWITZ: May I? Two points. One, 3 a second way of doing it is as Mr. Fitzpatrick 4 described in doing 150 sent scan. Secondly, some 5 operators occasionally will have done exactly what you 6 said and send an inspector team out to inspect an 7 elbow and then send another team out and the 8 comparison is about what you would expect. You have 9 the normal kind of distribution between the two sets 10 of --
11 JUDGE WARDWELL: Yes, and I'm surprised 12 that would take place. Again, no one really --
13 MR. FITZPATRICK: We had our people verify 14 inspection methods, anything we will sample. The 15 people that run the inspection program will on 16 occasion sample. There's no required specific "you 17 shall, we do 16 percent of these." But we do do on 18 occasion re-verify this especially when Engineering 19 looks at the data.
20 JUDGE WARDWELL: And what's your error 21 around your measurements from that?
22 MR. FITZPATRICK: From the published data 23 it's plus or minus --
24 JUDGE WARDWELL: No, I'm not interested in 25 the public data. I know what the instrument can NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1563 1 reproduce. But that's the instrument sitting on a gauge block turned on three or four times. I'm 3 interested in --
4 MR. FITZPATRICK: All right. And --
5 JUDGE WARDWELL: What happens when 6 different operators go out and try to replicate each 7 other?
8 MR. FITZPATRICK: Very similar. They're 9 a decimal place typically.
10 JUDGE WARDWELL: Thank you. How often are 11 the inspections performed to confirm to predictions 12 now?
13 MR. FITZPATRICK: It depends on the 14 results. If, say, the inspection data at time A shows 15 a type is greater than design thickness, we would 16 schedule it, reschedule an inspection be further out 17 in time. If it was less than, it's kind of 18 programmatic in the procedure depending on the 19 inspection results, we schedule inspections further 20 in. If it's any thinner, we inspect it closer, 21 sooner, than we would if it was advanced.
22 JUDGE WARDWELL: What's the -- Where does 23 most of this piping come in and how often could it be 24 inspected if one had unlimited budgets and unlimited 25 labor, etc.?
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1564 1 MR. FITZPATRICK: You could only do this 2 during refueling outages. We have to go into areas, 3 the boiling water reactors, you know, around the 4 turbine bay, the radiation. field in the reactor 5 building. So during an outage, they have to. put 6 scaffolding in, pull the insulation, unwrap the pipes, 7 do the inspection, evaluate the data, assemble all if 8 it's acceptable, put everything back together and go 9 to the next one. It's a process all these plants 10 have.
11 JUDGE WARDWELL: An~d do you wait until the 12 end before you update your information both in regards 13 to your database for the measured wear rates and to 14 incorporate that data into CHECWORKS?
15 MR. FITZPATRICK: Yes:- It's screened in 16 the beginning just to get the data to get a level 17 power plant. Two engineers review the data, say it's 18 acceptable to put the insulation back on the pipe and 19 then we start working on the before and after -
20 JUDGE WARDWELL: What are you requirements 21 for how soon after the data is collected that it has 22 to be updated into the program?
23 MR. FITZPATRICK: There was a specific 24 time limit on certain aspects in the other program and 25 the new program I'd have to look up the time.
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1565 1 (Off the record comment.)
2 JUDGE KARLIN: May I ask a question, Mr.
3 Fitzpatrick? We're asking about the frequency of how 4 often the inspections are done. Is it every refueling 5 outage the pipe is measured for purposes of CHECWORKS?
6 MR. FITZPATRICK: Piping is inspected 7 every outage. Not every pipe is inspected every 8 outage.
9 JUDGE KARLIN: I understand not every pipe 10 every outage, but are there measurements done for 11 purposes of CHECWORKS at every refueling outage?
12 MR. FITZPATRICK: We have data that's 13 taken every outage and whether it's imported into 14 CHECWORKS or not we have data. We have actual data 15 for the components.
16 JUDGE KARLIN: So you take measurements 17 or -- Is the answer yes? You do measurements at every 18 refueling outage.
19 MR. FITZPATRICK: Yes.
20 JUDGE KARLIN: Do you enter that data in 21 CHECWORKS after every refueling outage? No.
22 MR. FITZPATRICK: No, sir.
23 JUDGE WARDWELL: And why not?
24 JUDGE KARLIN: Why not?
25 MR. FITZPATRICK: If the data shows us no NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1566 1 wear and I have conservative predictions in CHECWORKS 2 saying there is wear if I base future inspections on 3 the CHECWORKS model that has a high wear rate, I 4 should be having conservative --
5 . JUDGE KARLIN: So what's the -- So 6 somebody makes a judgment on whether to enter it into 7 CHECWORKS or not.
8 MR. FITZPATRICK: I did, yes.
9 JUDGE KARLIN: And what is the criterion 10 for that judgment no wear?
11 MR. FITZPATRICK: That's what I --
12 JUDGE KARLIN: And what is the definition 13 of no wear?
14 MR. FITZPATRICK: Well, the previous 15 inspection data shows no wear or you have a very, very 16 large time that we --
17 JUDGE KARLIN: By no wear, you mean the 18 measurement is identical to the prior measurement.
19 MR. FITZPATRICK: For equipment. I put a 20 -- on that. Put minimum wear on that.
21 JUDGE KARLIN: I see.
22 JUDGE WARDWELL: And where was that 23 derived from?
24 MR. FITZPATRICK: It's in the VT-7028, the 25 previous procedure, and it's also the existing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1567 1 procedure which is -
2 JUDGE WARDWELL: No, I was interested in 3 how you derive that error -
4 MR. FITZPATRICK: The '05 number that I 5 just pointed out, it's a factor on the wear.
6 JUDGE WARDWELL: I would have to look at 7 your statement. Obviously, I can remember what your 8 statement was. I can't remember what you were 9 referring to.
10 MR. FITZPATRICK: I'm not clear of the 11 question.
12 JUDGE WARDWELL: It's not overly pleasing 13 to back up the transcript.
14 JUDGE KARLIN: Maybe this is the question.
15 I don't know. But every refueling outage you take 16 measurements of the pipe with what? What kind of 17 instrument?
18 MR. FITZPATRICK: Ultrasonic thickness 19 measure.
20 JUDGE KARLIN: Ultrasonic something.
22 JUDGE KARLIN: UT. And for every 23 refueling outage you take measurements of some pipes, 24 not the same pipe every time, but some representative 25 presumably sampling of the pipes.
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1568 1 MR. FITZPATRICK: Yes.
2 JUDGE KARLIN: And then you make a 3 decision whether to enter that into CHECWORKS. Right?
4 MR. FITZPATRICK: Yes.
5 JUDGE KARLIN: And the decision is based 6 upon whether it shows no wear. There's no wear. Then 7 you don't enter it into CHECWORKS. Right?
8 MR. FITZPATRICK: There's no decision --
9 Sometimes we have time to --
10 JUDGE KARLIN: Sometimes you do.
11 Sometimes you don't.
12 MR. FITZPATRICK: -- you don't. Yes.
13 JUDGE KARLIN: And by no wear, is there a 14 -- I asked a question. By no wear do you mean the 15 exact same measurement and you said no. There could 16 be a band there and that's the error band I believe 17 Dr. Wardwell was asking about.
18 JUDGE WARDWELL: Yes. An error. You said 19 it.
20 JUDGE KARLIN: So what is the band? If 21 it's not exactly the same, what if it's X plus -- I 22 mean, what's the error range of the band?
23 MR. FITZPATRICK: In our inspection 24 reports, we use 0.005.
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1569 1 derive from?
2 JUDGE KARLIN: 0.005 inches?
3 MR. FITZPATRICK: It's bigger. 0.005 4 inches. The same measurements. I'm always biasing 5 towards somewhere.
6 JUDGE KARLIN: Okay.
7 MR. FITZPATRICK: And that's bigger than 8 the 0.004 in the published data and I had been doing 9 that since 1999.
10 JUDGE KARLIN: How many feet of piping are 11 we talking about, linear feet, that are safety 12 related, whatever ..
13 JUDGE WARDWELL: That are in the FAC 14 program.
15 JUDGE KARLIN: -- in the FAC program?
16 MR. FITZPATRICK: Lineal feet, it may not 17 be a good measure because we concentrate on elbows and 18 fittings where there is --
19 JUDGE KARLIN: Right.
20 MR. FITZPATRICK: Safety related, I'd say 21 it's less than five percent of the program.
22 JUDGE WARDWELL: Well, how many were 23 covered by -- Just how many feet? Linear feet?
24 MR. FITZPATRICK: Thousands.
25 JUDGE WARDWELL: Thousands.
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1570 1 MR. FITZPATRICK: Thousands.
2 JUDGE WARDWELL: Okay.
3 (Off the record comments.)
4 JUDGE KARLIN: Dr. Horowitz, do you have 5 a--
6 DR. HOROWITZ: No, I'm just wanted to be 7 sure that Mr. Fitzpatrick is talking safety related 8 and non-safety related.
9 JUDGE WARDWELL: Okay. We're talking if 10 that's in the FAC.
11 JUDGE KARLIN: Say thousands of linear 12 feet of piping safety related.
13 MR. FITZPATRICK: Right. I would estimate 14 that the safety related is less than five percent of 15 that.
16 JUDGE KARLIN: So how many feet of piping 17 safety related?
18 MR. FITZPATRICK: Safety related?
19 Feedwater.
20 JUDGE KARLIN: Fifty? Three? Five 21 hundred? One thousand?
22 MR. FITZPATRICK: Around five hundred 23 feet.
24 JUDGE KARLIN: And how many measurements 25 are taken at each refueling outage? Ten? Twenty?
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1571 1 Fifty? Two thousand?
2 MR. FITZPATRICK: Large bore we have been 3 taking --
4 JUDGE KARLIN: What kind?
5 MR. FITZPATRICK: Large bore.
6 JUDGE KARLIN: Large bore, yes.
7 MR. FITZPATRICK: We have been taking 25, 8 30, 35 prior to EPU. As we've increased the number, 9 we've been taking 50s. We've done one outage I think 10 we had 49.
11 JUDGE KARLIN: Does the aging management 12 plan specify how many measurements would be taken?
13 MR. FITZPATRICK: No.
14 JUDGE KARLIN: Why not? Is it a judgment 15 call?
16 MR. FITZPATRICK: Yes.
17 JUDGE KARLIN: Whose judgment?
18 MR. FITZPATRICK: The FAC program engineer 19 and the basis for including inspection components is 20 documented in the scoping document every outage, why 21 some things are included, why aren't they included.
22 Every refueling outage has a scoping development, why 23 you're inspecting things, what data you evaluated and 24 reasons for including them in the inspection program 25 or putting in future inspections and that's documented NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1572 1 when it's done after every refueling outage to go to 2 the next outage.
3 JUDGE WARDWELL: And just so we don't have 4 to keep on repeating this in. future questions this 5 afternoon if it comes up every time you reference a 6 procedure like that we can safely assume that it's not 7 delineated in your aging management plan and your 8 application but it's abstractly linked as you describe 9 for other types of things earlier to --
10 MR. FITZPATRICK: The application doesn't 11 explicitly say the existing FAC program but the intent 12 is the existing FAC program is the FAC program and we 13 will do a FAC program.
14 JUDGE KARLIN: But does the existing FAC 15 program, the one that is exhibit here, does that say 16 50 locations or ten locations? It doesn't say at all, 17 does it? So even the existing FAC program does not 18 specify the number of samples or number of 19 measurements that are done at each refueling outage.
20 MR. FITZPATRICK: No.
21 JUDGE KARLIN: Okay.
22 JUDGE WARDWELL: Why not update CHECWORKS 23 after each refueling outage? What's the labor effort 24 to do that?
25 MR. FITZPATRICK: A couple months. Two or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1573 1 three months depending on how many different systems 2 were inspected.
3 JUDGE WARDWELL: So it takes one person 4 two or three months to input.
5 MR. FITZPATRICK: You have to have someone 6 else to review it. It's taking the data, evaluating 7 the data, getting that into CHECWORKS into the 8 database and then doing wearing analysis. So there's 9 a lot of front end work on doing the actual wear rate 10 analysis once the data is put into CHECWORKS. You 11 know, the amount of systems we have, it takes a lot of 12 work to get that done.
13 JUDGE WARDWELL: I still -- But even if 14 you waited, then you're going to have twice the data 15 the next time.
16 MR. FITZPATRICK: And the results --
17 JUDGE WARDWELL: And it still has to be 18 done at some point. Right?
19 MR. FITZPATRICK: Yes.
20 JUDGE WARDWELL: All the data eventually 21 gets in there. Correct?
22 MR. FITZPATRICK: It all eventually gets 23 in there, yes, and currently it's up-to-date.
24 JUDGE WARDWELL: Is that purely 25 coincidental that we're holding this hearing at this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1574 1 time in anticipation of that question or is it 2 anticipation of that question?
3 MR. FITZPATRICK: I'm anticipating that 4 question.
5 -JUDGE WARDWELL: There. You're honest.
6 I appreciate that in that regards.
7 MR. FITZPATRICK: They have -- In the past 8 few years -- eventually has been putting in the model 9 and we have a dedicated FAC engineer and his job is 10 just the FAC program.
11 JUDGE KARLIN: May I ask? When you said 12 a couple months, how long is a couple? Does that mean 13 one person working full-time for two months if that's 14 what it takes or -- Is that what it means?
15 MR. FITZPATRICK: If that's about the time 16 it takes, you have to close out -
17 JUDGE KARLIN: That's how much work is 18 involved? Two months? A person working two months at 19 a time?
20 MR. FITZPATRICK: It could be less. it 21 could be less, could be more, depending on how much 22 data you have to put in.
23 JUDGE KARLIN: Okay.
24 JUDGE WARDWELL: But again, there's no 25 efficiencies gained by waiting to do an all in one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1575 1 fell swoop after three refueling outages. It's going 2 to take three times the amount of time after three 3 refueling outages.
4 MR. FITZPATRICK: Yes.
5 JUDGE WARDWELL: So your total labor is 6 going to remain the same regardless of when you 7 updated pretty much.
8 MR. FITZPATRICK: Yes.
9 JUDGE WARDWELL: Moving on, turning to 10 staff, I'm interested in what you did for a review of 11 this aging management program in a little bit more 12 depth. Have you reviewed the -- Has the staff audited 13 their current FAC program?
14 MR. ROWLEY: Yes, we have.
15 JUDGE WARDWELL: And who did that?
16 MR. ROWLEY: When we performed the audit -
17 18 MR. HSU: Okay, I was the audit member and 19 1 observed all the work of the basic program and we 20 have a lot of staff which already checked it out to 21 some other place.
22 JUDGE WARDWELL: So you were a member.
23 Was it all NRC staff or was it also contracted out to 24 do this audit?
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1576 1 contract out. So team composed of the NRIC staff and 2 the contractor.
3JUDGE WARDWELL: And as a result of your 4 review, has Entergy demonstrated consideration of all 5 those ten elements that were brought up in the 6 standard review plan for license renewals for the FAC 7 program?
8 MR. HSU: Yes.
9 JUDGE WARDWELL: They have considered all 10 of that.
11 JUDGE KARLIN: May I ask? When did this 12 audit take place that you are referring to?
13 MR. ROWLEY: There were five audits. So 14 that would have been -
15 JUDGE KARLIN: Just give me the dates of 16 all five.
17 MR. H-SU: We will have to get them for 18 you.
19 JUDGE KARLIN: Give me the last three.
20 MR. ROWLEY: The last one was January '08.
21 JUDGE KARLIN: Okay.
22 MR. ROWLEY: And then December '07 and 23 then the one prior to that was then August -- I would 24 have to get back to you with an exact date.
25 JUDGE KARLIN: No, that's fine. Two are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1577 1 relatively recent. Thank you.
2 JUDGE WARDWELL: And are those completely 3 fresh new audits or are those replications of each 4 other or are different aspects?
5 MR. ROWLEY: This one was new and they are 6 different measures each audit. They might have 7 touched on the same aging component program twice but 8 just with different aspects of it.
9 JUDGE WARDWELL: In your audit review, 10 recognizing that it's not expected that the FAC 11 program will indicate all leaks, were there anything, 12 any steps, that the Applicant was taking to help 13 assure you that they tried to quantify how likely 14 these leaks are that will not be predictive and to 15 benchmark their program and to improve on their 16 abilities to correlate the actual wear to the 17 CHECWORKS model?
18 MR. HSU: Those portions, we forget about 19 them. It's implementation of the program and wishing 20 that -- which is a regional office and what we are 21 looking at is this adequate of the program and we 22 reviewed the adequacy of the program and we think the 23 program which is adequate to reasonable assurance of 24 safety of the plant in the implementation portion 25 which is regional. It's doing the computers NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1578 1 inspection.
2 JUDGE WARDWELL: Thank you. Turning to --
3 We'll look it up first to make sure.
4 JUDGE KARLIN: Are any of these audits 5 reflected in your discussion of flow accelerated 6 corrosion program in the FSER? If so --
7 MR. HSU: I think it's the audit sheet --
8 MR. ROWLEY: We have the audit report, 9 sir, that discusses what happens in an audit and as 10 you see we state that the audit report details --
11 evaluation of this ANP in the FSER. So we in turn 12 spoke to the audit report for more specifics than what
.13 you see here.
14 JUDGE KARLIN: Okay. So is there a 15 reference in the FSER to the fact that you've audited?
16 You've conducted these audits?
17 MR. ROWLEY: Yes. Right here, Staff 18 Evaluation, second sentence.
19 JUDGE KARLIN: Of what page? I'm sorry.
20 MR. ROWLEY: Of page 3-15.
21 JUDGE KARLIN: Three-15, okay.
22 MR. ROWLEY: In section, Staff Evaluation, 23 underlined Staff Evaluation.
24 JUDGE KARLIN: Which paragraph, sir?
25 MR. ROWLEY: Third paragraph.
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1579 1 JUDGE KARLIN: Third paragraph.
2 MR- ROWLEY: Second sentence.
3 JUDGE KARLIN: Okay. Third paragraph, 4 Staff Evaluation. "During the audit and review, 5 Staff.... Okay. So that's "during its audit -and 6 review, the Staff reviewed the Applicant's claim."
7 Okay. So which audit was that?
8 MR. ROWLEY: It might have been -- We have 9 -- I can't remember the exact date, but our process is 10 we go and do a time limit age analysis audit, an aging 11 management program audit and aging management review 12 audit. This would have been done through the aging 13 management program audit which would have been the 14 application came in in January 2006. So it would have 15 been six months after that. So July --
16 JUDGE KARLIN: Of '06.
17 MR. ROWLEY: '06.
18 JUDGE KARLIN: Okay.
19 JUDGE WARDWELL: Turning to --
20 MR. ROWLEY: Somewhere in that time frame 21 of '06.
22 JUDGE WARDWELL: -- NEC's Exhibit UW-09.
23 It was in -- It took me awhile to get it. It was in 24 Volume I of the four exhibits behind several JH 25 exhibits, NEC JH.
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1580 1 (Off the record discussion.)
3 JUDGE WARDWELL: Zero-nine. It's in 4 Volume I yellow -- And, Entergy, as soon as you are 5 there, can you let me know?
6 MR. FITZPATRICK: Yes sir.
7 JUDGE WARDWELL: Do you have it? I'll 8 give you a few more minutes because I see people even 9 with computer searching some hard paper. I don't 10 understand.
11 (Laughter.)
12 JUDGE WARDWELL: What are we looking at 13 here in this document that's been submitted by NEC of 14 yours?
15 MR. FITZPATRICK: Quality assurance side 16 of the programs in 2004.
17 JUDGE WARDWELL: And this is an Entergy 18 document. Correct?
19 MR. FITZPATRICK: Yes.
20 JUDGE WARDWELL: And is this your audit or 21 is it the Staff's audit?
22 MR. FITZPATRICK: That's the internal 23 Entergy audit.
24 JUDGE WARDWELL: Turning to page two, 25 there's a table in the middle of page two with the top NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1581 1 column headings of Elements, Results and No. Of CRs 2 AFIs. The third element down is flow accelerated 3 corrosion program and under the Result category it 4 says "Unsatisfactory."
5 MR. FITZPATRICK: Yes.
6 JUDGE WARDWELL: What bells did that. ring 7 in Entergy's engineering staff and what actions were 8 taken as a result of what appears to be a very 9 discouraging result?
10 MR. FITZPATRICK: The two CRs were written ii 12 JUDGE KARLIN: CR?
13 MR. FITZPATRICK: Yes, the condition 14 reports that's part of the corrective action process.
15 The two CRs were written, the first one was written on 16 not getting inspection data into the data management 17 system on time. We had data in fireproof cabinets and 18 we didn't get it within some time limit within the 19 record management system.
20 JUDGE WARDWELL: And so there are really 21 two steps when you have the data. You first have to 22 get it into your old spreadsheets if you will.
23 MR. FITZPATRICK: Yes.
24 JUDGE WARDWELL: And then you have to get 25 it into the program.
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1582 1 MR. FITZPATRICK: Yes.
2 JUDGE WARDWELL: And you didn't even get 3 it into your spreadsheets.
4 MR. FITZPATRICK: No.
5 JUDGE WARDWELL: In a timely fashion.
6 JUDGE KARLIN: Yes or no?
7 MR. FITZPATRICK: I -- No.
8 JUDGE KARLIN: No.
9 JUDGE"WARDWELL: Yes, we have no bananas 10 or --
iI (Laughter.)
12 Did you or did you not get it into the 13 spreadsheet program in a timely fashion?
14 MR. FITZPATRICK: Yes, we had it in our 15 programs in there.
16 JUDGE WARDWELL: All right.
17 MR. FITZPATRICK: We had the data 18 evaluated.
19 JUDGE WARDWELL: Yes.
20 MR. FITZPATRICK: The evaluation reports 21 and all the data, the raw data sheets and everything, 22 that go up to that report weren't microfilmed at that 23 point in time.
24 JUDGE WARDWELL: So you had no backup.
25 MR. FITZPATRICK: It was -- prior to the -
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1583 1 - But it wasn't in -- says you have to get this out on 2 the next R&B and the second CR was we had the draft of 3 -- had an issue with the report to the outage, 4 previous outage, and it was in draft form at that 5 point in time we wrote a CR on that -- set of acting 6 immediately to get the data in the rims and issue the 7 report.
8 JUDGE WARDWELL: Mr. Witte.
9 MR. WITTE: Yes, sir.
10 JUDGE WARDWELL: Sir, you submitted this.
11 Did the response from Entergy seem to allay your 12 concerns in regards to addressing this unsatisfactory 13 result?
14 MR. WITTE: No, sir. It did not. If we 15 follow the discussion one step further, the 16 implications are that the data from that inspection 17 was not properly incorporated in a reasonable period 18 of time such that the Licensee can prepare for the 19 next inspection and do the next task with CHECWORKS 20 to identify those wear points that should be looked at 21 in the next inspection. This report done by Entergy's 22 own staff brought to light a number of issues. The 23 CRs are just two of them. So I agree with the first 24 one, but I don't agree with the second one.
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1584 1 to that, Mr. Fitzpatrick? Guilty as charged?
2 MR. FITZPATRICK: Guilty of what I said we 3 did and we didn't finish the draft report and 4 inspection still for the next outage would be based on 5 the draft. The CHECWORKS model at that time was not 6 being updated based on the conservative wear rates and 7 the inspection data we'd taken -- They were assuring 8 no wear in the existing inspection data and at that 9 time I had gotten to the point of updating the 10 CHECWORKS model at that point.
11 JUDGE KARLIN: If I can jump in. Is there 12 any minimum requirement specified somewhere as to 13 when, how often, you have to update it?
14 MR. FITZPATRICK: It's recommended that --
15 The new NSAC may have a time limit on it, but it's a 16 resource issue.
17 JUDGE KARLIN: So it's a resource issue.
18 MR. FITZPATRICK: Yes.
19 JUDGE KARLIN: There's no -- There is no 20 minimum amount of time and it says you must update 21 CHECWORKS after X amount of time. Correct?
22 MR. FITZPATRICK: Not in the new 23 procedure.
24 JUDGE KARLIN: Are there any minimum 25 number of cycles or refueling outages?
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1585' 1 MR. FITZPATRICK: It's recommended to do 2 it after each outage.
3 JUDGE KARLIN: But what you actually do is 4 a function of what your resources are..
5 MR. FITZPATRICK: What I did at the time, 6 yes.
7 JUDGE KARLIN: So what is the actual 8 amount of time that usually -- Is it once -- What's 9 the longest amount of time you've gone without 10 updating CHECWORKS with the data?
11 JUDGE WARDWELL: Or going with a draft 12 document because all those reasons --
13 JUDGE KARLIN: Yes, over the history of 14 this.
15 MR. FITZPATRICK: Over the history, I 16 think it's three years in 2002 to 2005.
17 JUDGE KARLIN: All right.
18 MR. FITZPATRICK: Dr 2003 to 2006. It's 19 like a two cycle period.
20 JUDGE KARLIN: So it was three years was 21 the longest time you went without updating the 22 CHECWORKS.
23 MR. FITZPATRICK: Yes.
24 JUDGE KARLIN: And this normal time, can 25 you give us a normal time that you --
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1586 1 MR. FITZPATRICK: You should do -- -I would 2 do it if I had -- I would start after the outage while 3 everything was fresh and get it done. But -
4 JUDGE KARLIN: I'm not saying what you 5 should do. I'm saying what do you actually do.
6 What's your actual normal average time?
7 MR. FITZPATRICK: I would say maybe it's 8 been right after the other, 2006, 2007. All the data 9 is in there now coming into 2008 to the end.
10 JUDGE KARLIN: And this proceeding was 11 pending during that time frame and the license 12 application was pending.
13 MR. FITZPATRICK: Okay..
14 JUDGE WARDWELL: Couldn't one extrapolate 15 this piece of information to say that, in fact, you 16 haven't met the requirements of NSAC 2.1 saying that 17 you have the corporate financial resources necessary 18 to implement the aging management program?
19 MR. FITZPATRICK: We could extrapolate 20 that, but it presents it into the corrective action 21 process and that's why CRs are written to identify 22 these issues.
23 JUDGE KARLIN: Can I? This is for the 24 Staff. Does the Staff think that it ought to be 25 specified a minimum amount of time before they enter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1587 1 the data into CHECWORKS?
2 MR. ROWLEY: That would be something that 3 the operating or current operating team would have to 4 make that determination. We in license renewal 5 wouldn't.
6 JUDGE KARLIN: You're making a license 7 renewal determination.
8 MR. ROWLEY: Based on the adequacy of that 9 program.
10 JUDGE KARLIN: Adequacy of the program and 11 the program is silent~as to whether the data needs to 12 be entered. Is that right?
13 MR. ROWLEY: Well, it's the time it would 14 take to enter. But -- you have to assume they have 15 the data in.
16 JUDGE KARLIN: So let's assume that you 17 approve this. You found it adequate and Mr.
18 Fitzpatrick decided to resource matters he wasn't 19 going to enter that data in for ten years. Now could 20 you come in and say to Mr. Fitzpatrick, "Look here.
21 You're not following what we required you to do."
22 Could you enforce that? object to that?
23 MR. ROWLEY: I don't know that our 24 enforcement regulations well enough to answer that 25 question.
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1588 1 JUDGE KARLIN: If you have a permit 2 condition that's prescribed, you have to do it every 3 outage.
4 MR. ROWLEY: Or if something comes up.
5 JUDGE KA.RLIN: Then if they didn't do it 6 every outage you couldenforce that.
7 MR. ROWLEY: Right.
8 JUDGE KARLIN: Now if you don't have the 9 provision there that says you have to do it every 10 outage, then you can't enforce that, can you?
11 MR. ROWLEY: They are breaking their 12 current licensing basis we would have a lot of 13 consider.
14 JUDGE KARLIN: Their current licensing 15 basis doesn't say how frequently they had to do it.
16 MR. ROWLEY: Right.
17 JUDGE KARLIN: So they are not breaking --
18 So they could wait for ten years.
19 JUDGE WARDWELL: Moving on, Entergy, what 20 is your response to an updated CHECWORKS result that 21 indicates that failure of the pipe is eminent within 22 the next two refueling cycles?
23 MR. FITZPATRICK: We'd schedule for 24 inspection for the next outage.
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1589 1 going to before the next refueling outage?
2 MR. FITZPATRICK: As an engineer, I would 3 look to what went into that prediction.
4 JUDGE WARDWELL: And nothing seems -- Or 5 all seems correct and as far as you know that's real 6 information and as good a prediction rate as possibly 7 could be done. Do you have a hierarchy of corrective 8 actions that you would take based on how soon the 9 predicted wear rate, WR, would reach the critical 10 level?
11 MR. FITZPATRICK: There is, 12 programmatically there is a procedure that's based on 13 wear rates at times -- CHECWORKS, for example, one of 14 the components, if you have two parallel trains, I 15 have inspection data on a sister component here and I 16 have inspection data on the component here and here 17 and they show there is no wear and CHECWORKS is still 18 indicating for the identical conditions that there is 19 still very large wear rate and the actual inspection 20 data exacted for this one shows very small wear rates, 21 I'd make a judgment on the results and say, "Okay. We-22 should inspect it or I can defer it."
23 JUDGE WARDWELL: What if they both showed 24 it?
25 MR. FITZPATRICK: Inspect them.
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1590 1 JUDGE WARDWELL: But you can't inspect it 2 until the outage. What if it's predicted that's going 3 to reach a critical level before?
4 MR. FITZPATRICK: At this point in time, 5 we have 12 or 13 outings of data here and it's all 6 factored into the model.
7 JUDGE WARDWELL: Yes. And then all of a 8 sudden because of a measurement and the fact that you 9 were tardy in updating this so you didn't recognize it 10 for awhile and all of a sudden you updated the 11 information and it shows it's going to reach its 12 critical level prior to next refueling outage. Is 13 there any procedure set aside to address that 14 situation?
15 MR. FITZPATRICK: Yes. The corrective 16 action program we did for that.
17 JUDGE WARDWELL: And what would you do?
18 MR. FITZPATRICK: If we believe the 19 results, we would have the corrective action program 20 and if it needed reinspection at the next outage or we 21 would work out a plan to address it either by going 22 down power and inspecting it if it was a real result.
23 JUDGE WARDWELL: Is that spelled out in so 24 many words somewhere?
25 MR. FITZPATRICK: CHECWORKS --
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1591 1 JUDGE WARDWELL: Somewhere. I don't even 2 care if it's -- I know it's not in the aging 3 management plan. But is that spelled out in your FAC 4 or any other.document that FAC refers to?
5 MR. FITZPATRICK: Explicitly, no.
6 However, real data, measured data, when it indicates 7 there is a problem with the design basis, that's 8 programmatic with repair and inspect of complaints and 9 we make decisions on real inspection data.
10 We use the CHECWORKS as a planning tool.
11 It's not a safety program. It's used for tracking and 12 tracking and trending and we have *data in there. We 13 have enough data on these to make sound engineering 14 judgments. So we should inspect the problem.
15 JUDGE KARLIN: Question. This may be for 16 Dr. Horowitz. Well, first, let me stay with Mr.
17 Fitzpatrick. I think I hear you saying CHECWORKS is 18 there to make predictions as to flow accelerate 19 corrosion. Right?
20 MR. FITZPATRICK: Yes.
21 JUDGE KARLIN: And then you go out and 22 take measurements of flow accelerated corrosion or 23 actual data. Right?
24 MR. FITZPATRICK: Yes.
25 JUDGE KARLIN: And sometimes the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1592 1 predictions are correct. Is this right?
2 MR. FITZPATRICK: Generally, for us, 3 they've been over conservative.
4 JUDGE KARLIN: And sometimes they are not 5 correct. The data is -- They show more corrosion than 6 CHECWORKS predicted or less corrosion than CHECWORKS 7 predicted.
8 MR. FITZPATRICK: All the inspection data 9 has been showing less wear than CHECWORKS predicts.
10 JUDGE KARLIN: Well, right now, I'm not 11 focusing on whether it's less or more. I'm trying to 12 focus on whether the predictions are always exactly 13 correct and whether there's error in one way or the 14 other. So sometimes the data is different than what 15 CHECWORKS would have predicted. Right?
16 MR. FITZPATRICK: Yes.
17 JUDGE KARLIN: This then is for Dr.
18 Horowitz perhaps. Has there ever been any independent 19 study or analysis of the error rate of CHECWORKS? I 20 mean, obviously you're not independent because you're 21 the vendor of that program? Any third party 22 independent study?
23 DR. HOROWITZ: No.
24 JUDGE KARLIN: Dr. Hopenfeld, do you agree 25 with that that there's been no independent study of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1593 1 the accuracy?
2 DR. HOPENFELD: Not that I know of and I 3 believe it's against the nuclear regulations. It's 4 not an explicit regulation. It's definitely a part of 5 the -- It's the usual NRC procedure to verify codes 6 through various means and one is from the peer review.
7 JUDGE KARLIN: All right.
8 DR. HOPENFELD: Independent study review -
9 10 JUDGE KARLIN: NRC and Mr. Rowley or Mr.
11 Hsu, is it normally NRC's procedure to have it 12 verified as Dr. Hopenfeld just said?
13 MR. HSU: if this is a real precise 14 calculation, then you need to have that. But this one 15 is for the assessment. They are just based on those 16 ready to do the ranking susceptibility, just like a 17 very easy concept. Everybody knows in the -- if 18 you're going to have a higher susceptibility than the 19 piping itself. So this is like a assessment tool 20 doing the ranking and as far as the trending power, 21 that's just like a pretty easy algorithm. This is 22 this inspection. This is next inspection. This is --
23 JUDGE KARLIN: But the question is is it 24 normally NRC normally required for nuclear type of 25 codes like this to have some verification study done?
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1594 1 I don't know. Is it? Or is this the type that you're 2 saying, no, it's not?
3 MR. HSU: I'm not quite sure, but I think 4 CHECWORKS did not really have the verification to the 5 NRC because all those data --
6 JUDGE KARLIN: Those what? All those 7 data, okay.
8 MR. HSU: Yes. The database which is 9 coming from the laboratory which is coming from all 10 the plants, everything. We do not have that 11 accessibility and --
12 JUDGE KARLIN: You don't have what?
13 JUDGE WARDWELL: Accessibility.
14 MR. HSU: Yes.
15 JUDGE KARLIN: Why not?
16 MR. HSU: That's all proprietary 17 information.
18 JUDGE KARLIN: You're the regulator. You 19 can get that information.
20 MR. HSU: Yes, we know we can get that 21 information.
22 JUDGE KARLIN: You have access.
23 Accessibility is not an issue.
24 MR. HSU: Yes, it's not an issue for the -
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1595 1 these because it's for the assessment purpose. Then 2 from the NRC's point of view, this assessment purpose 3 and also it's initiated by the EPRI and also all the -
4 5 JUDGE KARLIN: Ini-tiated by EPRI. Now 6 EPRI is a nuclear industry group of companies. Right?
7 MR. HSU: All the utilities.
8 JUDGE KARLIN: All the utilities.
9 MR. HSU: Yes.
10 JUDGE KARLIN: Okay. So these are the 11 regulated - This is a study by the regulated 12 entities, the ones you're regulating. I'll withdraw 13 the question.
14 Dr. Horowitz, I guess the response you 15 might say is, and Mr. Fitzpatrick is indicating, if 16 the errors are all on the conservative side so it were 17 okay. Is that kind of the response?
18 DR. HOROWITZ: No. In the case of Vermont 19 Yankee, which EPRI looked at the program that is the 20 case, let me address a broader question. EPRI has 21 looked at doing nuclear ratings at the various level.
22 When they asked the member utilities, "You know, if we 23 do nuclear level QA on this program, it's a very 24 expensive item. Do you folks as the users of the 25 program want this step, this level of QA?"
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1596 1 JUDGE KARLIN: So you asked the people 2 that have to spend the money whether they want to 3 spend the money and they say no.
4 DR. HOROWITZ: They say no, yes. But 5 there are going to be hearings like this where they 6 have to answer these questions and they have to deal 7 with the regulators and have to answer these 8 questions.
9 JUDGE KARLIN: Well, the regulators don't 10 seem to have asked that question,- but we now have.
1-1 DR. HOROWITZ: So the answer has come back
-12 that the utilities view this program as not used for 13 nuclear design or nuclear applicability but just to 14 provide information to FAC engineers just like Mr.
15 Fitzpatrick and that --
16 JUDGE KARLIN: Okay.
17 DR. HOROWITZ: The information has been 18 filtered and used. So the information produced by 19 CHECWORKS is not directly used for functions typically 20 covered by nuclear level QA.
21 JUDGE KARLIN: Isn't that sort of like the 22 fox is deciding whether we should put a guard on the 23 hen house?
24 DR. HOROWITZ: I don't consider EPRI the 25 either fox or hen.
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1597 1 JUDGE KARLIN: They're regulated entities, 2 the ones who are being regulated by NRC and the NRC is 3 working on behalf of the public.
4 DR. HOROWITZ: Well, the people --
5 JUDGE KARLIN: When I used to work at EPA, 6 would we go and ask the chemical companies whether 7 they wanted to be inspected? It wasn't their vote.
8 It was EPA's vote.
9 DR. HOROWITZ: I certainly understand 10 that, but that's still the -- EPRI is a creature of 11 the utility industry and their members pay the bills 12 such that we don't think it's a reasonable expense of 13 money. EPRI does not have to follow recommendations 14 in this case such that it makes sense.
15 JUDGE KARLIN: It's like the Chemical 16- Manufacturers Association deciding whether some 17 chemical should be regulated by EPA. All right.
18 JUDGE WARDWELL: Dr. Hopenfeld, as I look 19 at your testimony in JH-01, Answer 22, where you were 20 asked to briefly summarize the basis for your 21 assessment the aging management program.
22 DR. HOPENFELD: JH-01?
23 JUDGE WARDWELL: Yes, JH-01 and I'm 24 looking at Answer 22 and really 23 and I'm only 25 looking at it in an engineering sense. I don't really NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1598 1 think you need to see it. That's where the root of 2 this came from. If you can remember your assessment 3 of this program, it seems like you were pretty 4 pessimistic regarding any attempts to predict the flow 5 accelerated corrosion.
6 DR. HOPENFELD: Correct.
7 JUDGE WARDWELL: As I read this, that's my 8 interpretation of it. Given that, what would you 9 suggest ought to be done to detect and predict flow 10 accelerated corrosion in the alternative?
11 DR. HOPENFELD: I believe we should 12 recalibrate --
13 JUDGE WARDWELL: What do you mean by 14 "recalibrate"?
15 DR. HOPENFELD: Re-benchmark --
16 JUDGE WARDWELL: And what do you mean by 17 "re-benchmark"? What's the difference between the 18 two?
19 DR. HOPENFELD: Not much. It's just --
20 Let me just tell you what the benchmarking is and 21 there's a very slight difference and I think the way 22 I see it benchmarking, the reason that we should 23 benchmark, is you take the computer code which you 24 already have and you compare it with plant data and 25 you make adjustments if they are necessary or you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1599 1 don't make adjustments or you just specify-2 Now calibration sometimes is usually a 3 tiny little bit different because you start with a set 4 of equations, you know -- or something. You guess as 5 to what the thing would look like and then you start 6 correlating the data. They're almost the same.
7 That's the way I heard it expressed.
8 JUDGE WARDWELL: I'm looking through some 9 future notes here. But it seems like there was 10 another phrase that came up also. Was it one point 11 you said it's not qualifying I think, if my memory 12 serves me correct because I can't put my finger right 13 at the moment? Did you use that phrase at some point 14 in your testimony?
15 DR. HOPENFELD: I don't remember but 16 (Inaudible) question -- I think that definition is 17 somewhere in the NRC analogy. There was also some 18 definition-with regards to it.
19 JUDGE WARDWELL: Okay. Can I just put 20 your thoughts just on hold for a second because I want 21 to finish this point?
22 DR. HOPENFELD: Sure.
23 JUDGE WARDWELL: Otherwise, I would have 24 to get back to it later on.
25 Entergy, is there any difference between NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1600 1 benchmarking, calibration and qualification of the 2 CHECWORKS model? Dr. Horowitz.
3 DR. HOROWITZ: To me trying to explain, 4 the word that's normally used in software QA type 5 activities is called validation.
6 JUDGE WARDWELL: So we have another word.
7 That word is on my list, too.
8 DR. HOROWITZ: Normally, in software, you 9 have a process called verification and verification 10 means that the handwritten equations are properly 11 implemented in the program and obviously for 12 complicated things that can be a complicated process.
13 Validation refers to the process of answering the 14 question "Is the program producing the results you 15 want them to produce, " in other words, predicting the 16 phenomenon within reasonable error and I think 17 benchmarking or -- What was the other -- I forgot the 18 other term is qualification. That is clearly 19 something different. I think what we're talking about 20 here is validation of the program.
21 JUDGE WARDWELL: But your validation as I 22 had heard your definition of it is merely 23 demonstrating that the computer code that the computer 24 code which has blocks of different lines of program 25 coding in it. Does it in fact solve the calculations NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1601 I you want it to solve?
2 DR. HOROWITZ: No. It shouldn't. That's 3 verification.
4 JUDGE WARDWELL: That's what I said. Your 5 verification is -
6 DR. HOROWITZ: Verification. I'm sorry.
7 JUDGE WARDWELL: Just does this program 8 solve equations we want?
9 DR. HOROWITZ: Right.
10 JUDGE WARDWELL: Benchmarking would be 11 something different, wouldn't it, in regards to -
12 Isn't there a need also to take the program and say, 13 "Now is it able to accurately model the real life 14 situation that we're trying to use the darn thing for 15 and you would apply it to simplistic cases where you 16 know exact solutions or something like that to say, 17 'Yes, we are able to also model the physical 18 phenomenon that we're interested in' "?
19 DR. HOROWITZ: I'm sorry I didn't make 20 myself clear. That process is called is validation.
21 JUDGE WARDWELL: Both those things.
22 DR. HOROWITZ: No. Verification and 23 validation.
24 JUDGE WARDWELL: I'm sorry. Maybe I got 25 confused. Yes, I may. Two Vs, okay.
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1602 1 DR. HOROWITZ: Right..
2 JUDGE WARDWELL: Sorry. So verification 3 the model does the calculations. Validation the model 4 knows the -- represents true physical phenomenon.
5 DR. HOROWITZ: Exactly.
6 JUDGE WARDWELL: And you would use the 7 word benchinarking or which would benchmark. You would 8 be the closer to the validation.
9 DR. HOROWITZ: Probably.
10 JUDGE WARDWELL: And what about 11 qualification? You don't know.
12 DR. HOROWITZ: No answer.
13 JUDGE WARDWELL: NRC, do you have any 14 specific definitions that the staff uses in this 15 regard?
16 MR. HSU: Benchmark means you want to try 17 to verify something you can use another -
18 JUDGE WARDWELL: Another what?
19 MR. HSU: Another independent method to 20 validate that is NSAC which is normal and then you 21 have this program which can generate exactly the same 22 answer which is already validated and solution.
23 That's the benchmark.
24 JUDGE WARDWELL: So it's almost a set of 25 your validation. I would put that as a subset where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1603 1 you have a known result.
2 MR. HSU: yes.
3 JUDGE WARDWELL: A true known physical 4 result.-
5 MR. HSU: I true known physical
-. result.
6 JUDGE WARDWELL: And you are able to model 7 it precisely and say, "Yes, we benchmark it to that" 8 and then other validation efforts could take place 9 where we're not where we don't have an exact 10 solution or a precise one, but we have an indication 11 of what the physical phenomena is and see how well it 12 does against that because we've observed that for a 13 number of years or something like that.
14 MR. HSU: Right.
15 JUDGE WARDWELL: To see how well it does.
16 I can buy that. Do you have any arguments with those 17 definitions, Dr. Hopenfeld?
18 DR. HOPENFELD: People use them 19 differently.
20 JUDGE WARDWELL: Sure.
21 DR. HOPENFELD: Like, for example, we've 22 discussed talking about the EPU and remember we had 23 codes that were benchmarked against some turbine trip 24 transients and the word was constantly used, 25 benchmark. So it's kind of subjective.
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1604 1 JUDGE WARDWELL: So your benchmarking is 2 pretty much now Mr. Hsu's defining it.
3 DR. HOPENFELD: I have the same problem.,
4 Yes, I'm not a psychology expert. But some of these 5 words have different meanings, but a little different 6 equation. When you say you validated it, you are 7 making sure that it's correct.
8 JUDGE WARDWELL: Trust me. If you get on 9 a board like this and work with legal people, they 10 really start pinning us technical people down. We 11 start throwing these words around.
12 DR. HOPENFELD: I'm not legal. I'm not a 13 legal person. Nor am I a psychiatrist.
14 JUDGE WARDWELL: But you want to be both, 15 don't you?
16 DR. HOPENFELD: No, I do not.
17 JUDGE WARDWELL: Okay. I'm just checking.
18 (Laughter.)
19 DR. HOPENFELD: I honestly do not.
20 JUDGE WARDWELL: Thank you.
21 Back to what would you suggest them to do?
22 We're back to the point that you're pretty pessimistic 23 about this ability to predict FAC. You started to 24 talk about benchmark and I interrupted you because I 25 wanted to clarify that definition.
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1605 1 DR. HOPENFELD: Yes.
2 JUDGE WARDWELL: And now I'm interested in 3 what would you suggest.- Fine. You criticiz-e it all.
4 But what else could they do?
5 DR. HOPENFELD: Well, first of all 6 JUDGE WARDWELL: Let me break it down.
7 DR. HOPENFELD: Yes. I think I can answer 8 if you break it down.
9 JUDGE WARDWELL: I'll break it down a bit.
10 DR. HOPENFELD: Yes.
11 JUDGE WARDWELL: Let's start with the 12 bigger picture and then I think you'll probably get 13 into the smaller picture. So I'm interested in the 14 bigger picture. What could they do completely 15 different? Let's not even in your first answer try to 16 start getting any critiquing CHECWORKS and proving 17 that or improving how that output is done or inputted.
18 Is there any other bigger thing that they could do 19 drastically different that would really improve their 20 FAC program that's really innovative that people 21 haven't thought about and yet is very practical to do?
22 DR. HOPENFELD: Very innovative. I think 23 their basic approach that they had started 20 years 24 ago, the concept, could have been -- it was okay.
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1606 1 having an opportunity from the outside. Those are --
2 JUDGE WARDWELL: But is there anything 3 outside of the CHECWORKS community that now exists, 4 granted maybe something could have done better back 5 there, but now is there anything big that you people 6 have really just kind of overlooked? I don't mean 7 innovative. I said that but I didn't mean it. That 8 people have overlooked that you're aware of that "Gee, 9 why don't we just do this? Gee I hadn't thought of 10 that. That might be a good idea." Do you know of 11 anything out there?
12 DR. HOPENFELD: I'll give you one example.
13 Okay. Prior to CHECWORKS and all of that, industry 14 had a lot of problems with corrosion or --
15 JUDGE WARDWELL: Yes. We're on the watch 16 now.
17 DR. HOPENFELD: Okay. One is each plant 18 had an expert that would be working on, completely 19 dedicated, all his life has been working on this and 20 knows every file and every place in that system and is 21 well communicated with other systems, not necessarily 22 new systems. That would be one way from eliminating 23 any computer codes because therefore we would be doing 24 it for hundreds of years.
25 There are some instrumentation we can do.
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1607 1 But we're getting into a different subject. It's 2 difficult to do certain instrumentation reports.
3 There's no reason for it. In other words, we could in 4 the chemistry effect and corrosion and some part of 5 system we could -- not necessarily the mainstream but 6 you could run side -- and find out. There are things 7 you can do -- given the safety 8 (Off the record comment.)
9 JUDGE WARDWELL: Dr. -- I would like to 10 interrupt you because I want to hear more of this and 11 I really think we want to take a break and I don't 12 want to cut you short. So I'll get back to this and 13 I know Dr. Hausler may have had some comments and I'd 14 rather not try to push it. I was trying to squeeze 15 this all in and I got off on the benchmarking and I'd 16 rather just pick it up right after lunch and we'll get 17 right back to that point.
18 JUDGE KARLIN: All right. With that, we 19 will stand adjourned until 1:15 p.m. Off the record.
20 (Whereupon, at 12:01 p.m., the above-21 entitled matter recessed and reconvened at 1:15 p.m.
22 the same day.)
23 JUDGE KARLIN: Please be seated. The 24 Board will now continue. Back on the record, Mr.
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1608 1 questioning of expert witnesses on Contention Four.
2 I will again remind the witnesses that you are under 3 oath, so you recognize that, I'm sure. And with. that, 4 Dr. Wardwell, I think has -
5 JUDGE WARDWELL: Dr. Hopenfeld, I think 6 where we left off at lunch break, you were describing 7 potential other techniques or modifications to the 8 existing techniques that could be used in a flow 9 accelerated corrosion program.
10 DR. HOPENFELD: I was general. However, 11 that's the following I would have. And that, as we 12 discussed the other day, we started with a new plan, 13 basically a new plan. And I think we ought to start 14 with new data evidence. As we go along gathering the 15 database -
16 JUDGE WARDWELL: And what would be added 17 to the existing database, do you suggest?
18 DR. HOPENFELD: I have recOhimended -- I 19 provided the initiative which indicates how to collect 20 that data.
21 JUDGE WARDWELL: Okay. Thank you.
22 DR. HOPENFELD: There's a table, I can 23 give you the table on it, if you will.
24 JUDGE WARDWELL: Yes, just reference the 25 table number. You don't have to read it. Just so I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1609 1 can refer to it once I read the transcript.
2 DR. HOPENFELD: Give the table to you. I 3 don't think you're going to find the table, but it's 4 at end of the initial position, which I think is the 5 last page.
6 JUDGE WARDWELL: In the Statement of 7 Position?
8 DR. HOPENFELD: Yes.
9 MS. TYLER: May I provide a reference?
10 JUDGE KARLIN: Yes, please.
11 MS. TYLER: It's JH-36 at 15.
12 JUDGE KARLIN: JH-36 at 15.
13 MS. TYLER: Yes.
14 JUDGE KARLIN: All right. Thank you.
15 DR. HOPENFELD: JH-36, page?
16 JUDGE KARLIN: 15. We've got it, Dr.
17 Hopenfeld.
18 DR. HOPENFELD: You got it?
19 JUDGE KARLIN: Yes. No, we don't need to 20 refer to it. We know that it's there. We'll look at 21 it later.
22 DR. HOPENFELD: And you see there's one --
23 there are two aspects to this. One, it has a much 24 denser grid compared to what we've got now. And the 25 reason for that is to get away from all the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1610 1 uncertainties, and I would say very arbitrary 2 equations that were -- and which checkpoint the 3 status. Now we go further in corrective ways to 4 advance. This would get away from the issue of 5 discontinuities, the issue of local turbulence 6 covering the whole area. I ran a lot of incentive 7 checks on this side of the field, and this probably 8 doesn't say how many, around how many components we 9 are -- it's divided into A, B, C, D, and dividedinto 10 only three -- the width.
11 The first thing you do, you select what 12 you're going to include in this group. You're not 13 classifying what is the larger. The smaller they are, 14 the pipes, you're going to see how risk-significant 15 those parameters are. If you wish me to give you 16 criterion for that, which I haven't heard these 17 gentlemen even mention it. One which I used to do all 18 the time was CDF. That's one criteria that you would 19 use to say if I have this, you could be very, very 20 well -- this is very valuable, and you may not even 21 detect it, but suddenly you have a water hammer 22 somewhere and a systemic rupture. So that concept 23 that was proposed to you, we have this concept of leak 24 before break, it has not been yet accepted by the NRC, 25 to the best of my knowledge.
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1611 1 JUDGE REED: Could we stop there and ask 2 the NRC whether they would concur with what you're 3 saying?
4 DR. HAUSLER: I'm sorry. I didn't hear 5 the question.
6 JUDGE REED: He said leak before break.
7 JUDGE KARLIN: It's a question for NRC.
8 JUDGE REED: Yes. The question is 9 directed to the NRC.
10 MR. HSU: Leak before break actually we 11 should apply to that -
12 JUDGE REED: We can't hear you.
13 MR. HSU: Leak before break is applied to 14 the cracking, and which is not applied to the FAC.
15 FAC is talking about a big area material loose. Leak 16 before break is talking about cracking, very small 17 cracking, gradually expanding. It's different aging 18 mechanism.
19 JUDGE REED: What about erosion type of -
20 MR. HSU: Erosion type, which is not 21 considered -
22 JUDGE REED: Is leak before break 23 appropriate there?
24 MR. HSU: Leak before break is not 25 appropriate in there.
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1612 1 JUDGE REED: Not appropriate for any kind 2 of corrosive thinning. Is that what you're saying?
3 MR. HSU: Because corrosive thinning, 4 which is you're going to loose a big area. And leak 5 before break,--which only allow you like a one GPM, you 6 lost one GPM, that range, so which is very small 7 opening.
8 JUDGE REED: Well, let me ask Entergy.
9 Dr. Horowitz, what's your position? My understanding 10 was that it was -- what we've been calling flow 11 accelerated corrosion, that occurs over large areas, 12 and produces a sudden rupture of the pipe. But if you 13 have other corrosive phenomena, you might get very 14 small pinhole leaks. Am I wrong?
15 DR. HOROWITZ: No, that's correct. With 16 FAC, as use the term, the damage is widespread, and 17 the leaks are the extent -- you're up to sudden 18 catastrophic, such as Surry. Behavior such as erosion 19 is kind of -7 to me, you could apply leak before break 20 because you don't want to just get small jets, small 21 pinhole-type leaks, but it's not exactly the same as 22 cracking where you're estimating that the crack is 23 going to grow, the leak is going to increase with the 24 -- particularly with impingement kind of failures, you 25 just get a hole just to blowout that hole pretty much NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1613 1 forever. The hole is not going to enlarge a great 2 deal.
3 JUDGE REED: Okay. I'm sorry for the 4 interruption.
-5 DR. HOPENFELD: It's classified as A, B, 6 C, D, and you classify those in terms of safety-7 significance. By doing that, you have eliminated a 8 large number of components that you don't have to do 9 it -- but you have to do it quantitatively. We 10 haven't seen -- I don't believe you have seen any 11 quantitative indications. We have heard statements, 12 well, this is not safety-related, safety-related. I 13 don't know. There's a number for that. When the NRC 14 does a generic safety evaluation, cost benefit 15 studies, the numbers they come in, the criteria, the 16 CDF. And the CDF is an indicator. We've indicated 17 that it indicates that this protects the public. When 18 there's criteria with CDF, that takes the effective 19 nine to five away. So that's what you have to do.
20 And you have a criteria -
21 JUDGE REED: Pardon me. Could you define 22 CDF?
23 DR. HOPENFELD: CDF is Core Damage 24 Frequency. What kind of accident -- so you do that.
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1614 1 on a logical defensive basis. The next thing you do, 2 you take a computer code, and I'd be very happy to 3 have CHECWORCS, as well. You already have the 4 mathematics of storing data, all you have to do is 5 modify. How are you going to modify? Some of the 6 equations there are just way -- they're way off. They 7 don't have to do with experiment, they don't have to 8 do with anything else. To show you that, it is so 9 obvious. I would have to go further into that, if you 10 allow me.
11 JUDGE WARDWELL: And you'll provide that 12 in the testimony?
13 DR. HOPENFELD: Some. There's not new 14 information. We need all the information is in the 15 testimony, but I did some background calculations 16 further yet. Do you want me to provide it?
17 JUDGE REED: You've alleged several times 18 that there are incorrect equations in the CHECWORKS, 19 so I think we have to stop and ask you to at least 20 identify one or two.
21 DR. HOPENFELD: oh, okay.
22 JUDGE REED: I don't want a long lengthy 23 discourse -
24 JUDGE WARDWELL: Just say what they are.
25 JUDGE REED: Just say what they are.
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1615 1 JUDGE WARDWELL: Which ones?
2 DR. HOPENFELD: Okay, the one that is of 3 most concern is the whole develop -- the relationship 4 between corrosion and velocity is based on data, and 5 I believe I gave you it in the write-up, of the copper 6 dissolution in hydrochloric acid. We do not have 7 cooling in that reactor with hydrochloric acid. Most 8 of the material is not copper.
9 JUDGE WARDWELL: Okay. What's the next 10 one?
11 DR. HOPENFELD: Okay. The next one, there 12 is an equation in one of the graphs that relates the 13 local corrosion rate to the total -- to the average 14 corrosion rate in a fitting, a pipe, an elbow, 15 whatever. There's a typographical error, I believe, 16 there, because it said A=A+A times D. Okay? I gave 17 you that equation. You say equal A, equal A, you see 18 also -- there must be some error with EPRI there.
19 There must be some typo. But if you forget about the 20 typo, if you look at the numbers of B -
21 JUDGE REED: I'm sorry. Are you alleging 22 that EPRI made a typo, or you made a typo?
23 DR. HOPENFELD: No, I didn't make the 24 typo. I just took their equation from the documents 25 they provided us.
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1616 1 JUDGE REED: Okay.
2 DR. HOPENFELD: I just copied -- I don't 3 remember which document it was. I think it's the one 4 with the two or three guidance, the guidance up to the 5 CHECWORCS. What they do, the concept that they use is 6 incorrect, too. They're using an average value, which 7 is represented in a way by -
8 JUDGE WARDWELL: An average value of what?
9 DR. HOPENFELD: Average value for a given 10 consideration. You have a different, a valve to have 11 a different A.
12 JUDGE WARDWELL: Is this a geometric 13 factor? Which factor of those factors that were 14 presented in regards to CHECWORKS does this apply to 15 that you're talking about?
16 DR. HOPENFELD: There was a table shown 17 that - and I can give you the reference - the table 18 with all the fittings, it's used engineering. You can 19 look it up in any handbook. It's being used to 20 calculate pressure drops of a fitting, and that's 21 what we used. But what's missing here, this is an 22 average value. It's not -- what's you're really 23 interested is in the local value, not the average. So 24 he has a correction in there, and his correction is 25 Factor B that came from one specific experiment, from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1617 one specific geometry. If you take that correction, 2 then compare it to real life data, so you see that 3 that would be by order of magnitude, they would be off 4 by an order of magnitude. And the particular -
5 JUDGE WARDWELL: What's your next one?
6 DR. HOPENFELD: I'm sorry. Okay. The 7 next one in CHECWORKS, I would say the inability to 8 relate the computer code, too, unless I'm repeating 9 myself. The inability to calculate local corrosion 10 rate. They have testified that local, instead of kind 11 of -
12 JUDGE WARDWELL: What's your next one?
13 DR. HOPENFELD: Well -
14 JUDGE WARDWELL: Is that it?
15 DR. HOPENFELD: No, I just have -- I think 16 there's just one more. I was interrupted, but these 17 were the two major ones. The inability to calculate 18 the local thing, the inability to -- oh, here's the 19 major one. If you look at the correlation for --
20 every now and then it gets specific. If you look at 21 the correlation for VY -
22 JUDGE WARDWELL: That's velocity.
23 DR. HOPENFELD: I'm sorry?
24 JUDGE WARDWELL: VY is velocity?
25 DR. HOPENFELD: Vermont Yankee, no.
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1618 1 JUDGE WARDWELL: Oh, oh, Vermont Yankee.
2 DR. HOPENFELD: Look at the correlation of 3 the prediction, when we talk about predictions, and 4 they give you three lines. If you take those three 5 lines away, and I ran a test. I took those three 6 lines away and I asked five people, a couple of them 7 were engineers, three of them, I don't know, they were 8 not -- I don't know, psychology maybe. And I ask them 9 take a look at this. What's the best line to run over 10 this data? Know what they said? Straight line. What 11 straight line means? No correlation. The code 12 doesn't predict anything.
13 JUDGE WARDWELL: And what graph or data 14 are you using that you're -
15 DR. HOPENFELD: Yes. I would like -- Dr.
16 Hausler to look into this much deeper than I did, but 17 let me give you the draft first. The one I'm talking 18 about, I have two. One is E-4-30 at 39.
19 JUDGE WARDWELL: Okay.
20 DR. HOPENFELD: The other one, E-4-29 at 21 10.1 have another one, and that is NEC JH-37 at Figure 22 5.
23 JUDGE WARDWELL: Say that again, now.
24 DR. HOPENFELD: JH-37 at Figure 5.
25 JUDGE WARDWELL: Okay. Thank you. Is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1619 1 that all your main issues?
2 DR. HOPENFELD: Yes.
3 JUDGE WARDWELL: You said you had three, 4 and those are three.
5 DR. HOPENFELD: Yes, I was going to tell 6 you why, though.
7 JUDGE WARDWELL: No, no. I've got the 8 why. I think I understand.
9 DR. HOPENFELD: Okay. One thing that 10 hasn't been brought up, if I may, on the -- and that 11 goes .to some degree to the definitions. If you look 12 at that Figure 5 that I gave you, the NRC position was 13 from that figure that there's no time effect 14 whatsoever on corrosion. In other words, once you 15 measure the corrosion rate in the morning, it's to be 16 there forever like that. If you look at this figure, 17 there is nothing in the universe that talks about 18 corrosion rate here. However, they concluded from 19 that figure that there is no effect of time -
20 JUDGE WARDWELL: What figure, sir?
21 DR. HOPENFELD: It's Figure 5 in JH-37.
22 JUDGE WARDWELL: Okay. Thank you.
23 Entergy, Dr. Horowitz, would you like to respond to 24 those particular aspects?
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1620 1 clear. The first issue was how FAC varies with 2 velocity. The second was the AV figures on Figure 7-3 2. The third was copper modeling and -- I think it's 4 copper modeling and geometry factors. And the fourth 5 has-.to do with predictions.
6 JUDGE WARDWELL: I have them written a 7 little bit different, but proceed ahead.
8 DR. HOROWITZ: Okay.
9 JUDGE WARDWELL: I thought there was a 10 wear versus flow relationship that was derived from 11 copper tests.
12 DR. HOROWITZ: I think that's really the 13 first one.
14 JUDGE WARDWELL: Okay.
15 DR. HOROWITZ: Let me speak to it. I 16 can't be very brisk because some of these are long, 17 intricate answers.
18 JUDGE WARDWELL: Try to make them short 19 and simplistic answers.
20 DR. HOROWITZ: First of all, let's talk 21 about the variation of velocity with -- flow-22 accelerated corrosion rate with velocity. And Dr.
23 Hopenfeld cites work done in England by Geoff Bignold, 24 et al, and Ian Woolsey, et al. And it's interesting 25 that my first involvement in FAC was right after the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1621 1 Surry accident. Bindy Jackzo was putting -- was on 2 the team putting together an EPRI White Paper, and 3 Bindy prepared an assessment of what a post accident 4 prediction would use using best available technology.
5 And he selected that exact technology, and he put 6 together the appendix, he asked me to check what he 7 had done, and to computerize what he had done. He 8 also asked me to look at -- he had assembled, as I 9 said yesterday, laboratory data from England and 10 France.
11 JUDGE WARDWELL: I'd like to cut you 12 short.
13 DR. HOROWITZ: Okay.
14 JUDGE WARDWELL: Love the reminiscing, but 15 for what we need here is, we need an explanation of 16 why would the wear rates from a copper test be 17 appropriately applied to what is indicated to be the 18 relationship that's used here for that relationship as 19 it relates to flow, not how it was -- just why.
20 DR. HOROWITZ: Fine, but that was three 21 different questions you just asked. Let me finish the 22 first, and I'll get to the other two.
23 I was the first one to look at that 24 English and French data. My bias was towards Woolsey 25 and Bignold, who said velocity was second or third NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1622 1 power. It took me less than a half an hour to 2 convince myself that the velocity dependency was much 3 more than linear. That is based on laboratory data.
4 We have seen the same thing in 20 years with the plant 5 data. If the exponent was any year in the range of 6 2.4 to 6, as Dr. Hopenfeld has said in his testimony, 7 we would have seen that instantly. The program 8 wouldn't have worked, nobody would use it. So that's 9 my comment on velocity.
10 JUDGE WARDWELL: So your opinion is that 11 it is linear because your initial studies of the lab 12 data clearly showed that within a very short period of 13 time of looking at that, and it's been proven to be 14 correct because your model was able to track 15 reasonably well what you're getting in the plants.
16 DR. HOROWITZ: Yes.
17 JUDGE WARDWELL: Thank you.
18 DR. HOROWITZ: One more sentence, and that 19 linear dependency matches the French model, the EDF 20 model, which is generally accepted model for FAC.
21 JUDGE KARLIN: For what? Generally 22 accepted for -
23 JUDGE WARDWELL: FAC.
24 DR. HOROWITZ: For FAC prediction.
25 JUDGE KARLIN: Okay, FAC. I'm sorry.
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1623 1 DR. HOROWITZ: Secondly, the figure that 2 Dr. Hopenfeld was referring to is from the FAC book.
3 JUDGE WARDWELL: Which figure? He 4 referenced several figures. Which one are you 5 referring to?
6 DR. HOROWITZ: The figure -
7 DR. HOPENFELD: D-408.
8 DR. HOROWITZ: A and B Factor.
9 JUDGE WARDWELL: Yes.
10 DR. HOROWITZ: And that is not used in 11 CHECWORKS. In fact, it's not used by EPRI. That is 12 EDF background figure used in their code BRT-CICERO 13 that I mentioned earlier today. So that really has no 14 relevance to CHECWORKS and what we're doing.
15 Third point, copper. The copper tests 16 were not used to establish wear rates. They were not 17 used to define geometry tables. They were just used 18 to give us a fast way of doing tests of various 19 geometries. The paper, one of my exhibits by Drs.
20 Paulson and Robinson talk about the derivation of that 21 method, and how, indeed, it does scale CO corrosion 22 with FAC.
23 In looking at the results of the tests we 24 funded, it turned out that there were differences 25 between copper and steel, but not qualitatively. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1624 1 we used the qualitative results, but all the geometry 2 factors in CHECWORKS come from plant data.
3 JUDGE WARDWELL: Okay.
4 DR. HOROWITZ: The last one was Vermont 5 Yankee predictions.
6 JUDGE WARDWELL: The correlations using 7 scattered data shown on the Figures E-4-30 at 79, E 8 29 at 10, and JH-37 at Figure 5.
9 MR. FITZPATRICK: Is E-4-30 at -
10 JUDGE WARDWELL: I have E-40-30 at 79.
11 MR. FITZPATRICK: 79. E-4-30. What is 12 the title? Is that the graph with -
13 JUDGE WARDWELL: I don't know. Dr.
14 Hopenfeld, I'm looking at page 79 of E-4-30 and it's 15 a table of data. Are you talking about 78, where it's 16 the comparison of wear prediction, prediction rate
- 17. versus measured wear?
18 DR. HOPENFELD: No, I wasn't talking about 19 a table, I was talking about the graph. E-4-30 at 79.
20 As a matter of fact, it's also given -
21 JUDGE WARDWELL: But listen to me, E-4-30 22 at 79 is a table.
23 DR. HOPENFELD: If that's the case, then 24 we have another one at JH, which I believe is the same 25 one. I don't know why -
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1625 1 JUDGE WARDWELL: How about -
2 DR. HOPENFELD: It's RH-05, the last --
3 it's Figure 3, and I think it's page 12 of 12.
4 DR. HAUSLER: Page 57 would be a good 5 example.
6 JUDGE WARDWELL: I'm sorry, Dr. Hausler?
7 DR. HAUSLER: There are a number of these 8 graphs in that particular exhibit.
9 JUDGE WARDWELL: And this is RH -
10 DR. HAUSLER: What I'm saying is that page 11 59 might be an excellent example .to illustrate what 12 Dr. Hopenfeld wants to study.
13 JUDGE WARDWELL: And this is in RH-05?
14 DR. HAUSLER: This is in Exhibit E-4-30, 15 and it's on page 57.
16 JUDGE WARDWELL: Okay.
17 DR. HAUSLER: It's a handwritten page in 18 there.
19 JUDGE WARDWELL: Yes. How about that, E-20 4-30 at 57? And there are a number of these graphs in 21 this particular exhibit, of which this is one. And 22 the criticism is that ocularly one could easily say 23 that should be a horizontal line instead of a sloped 24 line, and still probably have as much -- have as good 25 a fit to the data as the slope line you have. If NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1626 you'd like to respond to that.
2 DR. HOROWITZ: Okay. First, let's all 3 look at that same figure. And what you're seeing is 4 a large amount of feedwater data. As Mr. Fitzpatrick 5 mentioned this morning, feedwater data at Vermont 6 Yankee is wearing very slowly, if at all. If you turn 7 the page -
8 JUDGE WARDWELL: Is what? I'm sorry. I 9 didn't hear that.
10 DR. HOROWITZ: Is wearing very slowly, if 11 at all. I'm sorry.
12 JUDGE WARDWELL: Oh, the feedwater -- all 13 right.
14 DR. HOROWITZ: And that fact is indicated 15 by the line direction factor be so low. If you turn 16 the page, you'll see that the thick -
17 JUDGE KARLIN: Let me stop you. We're 18 referring to page 58 now?
19 DR. HOROWITZ: Yes.
20 JUDGE KARLIN: Thank you.
21 DR. HOROWITZ: E-4-30.
22 JUDGE WARDWELL: 58.
23 DR. HOROWITZ: That's the same data 24 plotted not as difference data, but as thickness data.
25 And you can see that for most points, the thickness of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1627 1 the pipe was 1200 mils, or 1.2 inches, and so the 2 amount of wear that you're seeing on the previous page 3 is quite small as a percentage of that.
4 The other point I'd like to mention is 5 that we have seen similar behavior for CHECWORKS for 6 BWR feedwater lines in other units. And we are 7 considering efforts to understand what's going on in 8 that area, because this is a particular problem area 9 we know about, as far as the under-prediction of BWR 10 feedwater.
- 11. JUDGE REED: Could you repeat that? I 12 didn't hear you. As far as the under-protection?
13 DR. HOROWITZ: Under-prediction.
14 JUDGE REED: Under-prediction of -- I just 15 didn't hear you.
16 DR. HOROWITZ: Of corrosion rates. I'm 17 sorry. If you look at the line correction factor, the 18 line correction factor is in the perfect world unity, 19 we like it to be between 0.5 and 2.5. The fact that 20 it's this low indicates that the model was not 21 performing well, and you see the same behavior in 22 other units.
23 JUDGE REED: So this is an indication that 24 the model is not performing well?
25 DR. HOROWITZ: That's correct.
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1628 1 JUDGE REED: For this particular pump -
2 DR. HOROWITZ: This particular line, yes.
3 JUDGE REED: Is this typical of how it 4 performs across the -
5 DR. HOROWITZ: No. As I said, in general, 6 the model performs much better, and it turns out, as 7 luck would have it, except for BWR feedwater line, you 8 can see this problem pretty much across the board.
9 JUDGE WARDWELL: What was the range you'd 10 like the line correction factors to be?
11 DR. HOROWITZ: 0.5 to 2.5.
12 JUDGE WARDWELL: Are you familiar with 13 this particular exhibit? Yes, you provided it, E 14 30. Do you have a table of all the line correction 15 factors so we don't have to leaf through this to see 16 how many there are? I look at page 32 - that's a 17 feedwater line again. I'm just curious to see whether 18 or not, how many of the lines -- do you plot out one 19 of these for each different component?
20 MR. FITZPATRICK: That represents each 21 line, or segment of piping in the plant. For example, 22 from the feedwater pumps to the feedwater heater, that 23 would be one line. The number of piping components, 24 each one of those graphs represents that, so there's 25 50 or 60 components, say, in that line. And they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1629 1 all listed -
2 JUDGE WARDWELL: So just for 3 clarification, that's an analysis line. Each one is -
4 5 MR. FITZPATRICK: Yes.
6 JUDGE WARDWELL: So how many plots like 7 this do you have in this exhibit, so I don't have to 8 wade through. Do you know?
9 MR. FITZPATRICK: Almost 10, I think, 10 around 10. There's different sections of feedwater in 11 sections that are -- These are the most susceptible 12 piping at VY.
13 JUDGE WARDWELL: But how many -- what else 14 do you have besides the feedwater lines then, that 15 you're analyzing? What other lines are there? How 16 many total lines are there that you're analyzing?
17 MR. FITZPATRICK: It's hard to say without 18 seeing the whole database in front of me. If you look 19 at how this is picked out, look at page 16, for 20 example.
21 JUDGE WARDWELL: Sixteen? Say that -
22 MR. FITZPATRICK: One six.
23 JUDGE WARDWELL: One six of what?
24 MR. FITZPATRICK: Of the same figure. E-25 4-30 VY.
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1630 1 JUDGE WARDWELL: And I'm looking at a 2 screen print?
3 MR. FITZPATRICK: Screen, yes. E-4 are 4 the lines -- if you look at the charts down there, 5 there's a box on the left. Each line in the plant, 6 there's a line identifier for each line in the plant.
7 You can click on that, you can get all the piping 8 components from that.
9 This screen, you pick which ones you want 10 to lump together as an analysis. For instance, 11 there's only two lines in this one. And the middle 12 box, 01-16-FDOl, and 03-16-FDO3, those are two 13 feedwater pumps lines going through the feedwater 14 heater up to the head. And that's -- there's probably 15 50 components total between those two lines. And this 16 is a wear rate analysis of those lines based on the 17 latest inspection. All the data -
18 JUDGE WARDWELL: Then other categories of 19 lines include condensate lines?
20 MR. FITZPATRICK: Condensate lines.
21 JUDGE WARDWELL: Four point extraction 22 steam lines. But you're saying that all the FDWs or 23 anything dealing with the feedwater tends to have this 24 line correction factor?
25 MR. FITZPATRICK: Single phase, but yes.
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1631 1 Those lines, because they're single phase flow.
2 CHECWORKS is under-predicting the wear. I'm sorry, 3 over-predicting the wear with the line correction. If 4 the line correction factor is less than one, it will 5 over-predict the wear.
6 JUDGE WARDWELL: So you predict more wear 7 than is actually there.
8 MR. FITZPATRICK: Yes.
9 JUDGE WARDWELL: When you're below one on 10 your line correction factor.
11 MR. FITZPATRICK: Yes.
12 JUDGE WARDWELL: How many of these run 13 definitions are there? That's a scroll that I see 14 here, and I assume this exhibit doesn't have a plot 15 for every one of the run definitions in the lines that 16 are incorporated under each. I assume that you select 17 a different run definition on the right-hand side of 18 this block that's shown here on the print screen.
19 Then the number of database lines shown on the left-20 hand changes.
21 MR. FITZPATRICK: Yes. They're individual 22 23 JUDGE WARDWELL: And it shows all the 24 groups of the actual lines that CHECWORKS does for 25 each of these run definitions.
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1632 1 MR. FITZPATRICK: The column on the right, 2 yes, represents the different wear rate analysis that 3 are done.
4 JUDGE WARDWELL: And-you're testifying 5 that the results for things that aren't feedwater 6 related have line correction factors between .5 and 7 the two that you want, or whatever that number was 8 that you testified. Is that correct?
9 MR. FITZPATRICK: No. The feedwater has 10 line correction factors less than one. Some of the 11 other lines are factor resistant material. We ran in 12 the models, anyway. Their line correction factors can 13 be off, can be high, can be low. Each line is 14 evaluated separately.
15 JUDGE WARDWELL: Right. But I was just 16 saying that Dr. Horowitz said there's been an anomaly 17 that they're trying to resolve in regards to feedwater 18 lines. Is that correct, Dr. Horowitz?
19 DR. HOROWITZ: Yes.
20 JUDGE WARDWELL: And so looking at page 16 21 in these run definitions, everything that's related to 22 feedwater is liable to have that same anomaly that 23 you're wondering about. Is that correct, Dr.
24 Horowitz?
25 DR. HOROWITZ: Yes, that's correct, Judge.
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1633 I JUDGE WARDWELL: Thank you. Yes, Dr.
2 Hopenfeld?
3 DR. HOPENFELD: I"d like to be fair, so I 4 did go to the next one, which I -- I went to the next 5 figure which I gave, which was E-4-29 at 10- The line 6 correction factor is .649. And if you take a couple 7 of points out of there, there's another horizontal 8 line. However, in this case, I went further to see 9 what the impact would be on the EPU. What are the 10 consequences of that, and they are very severe, 11 because you will think that you will -- 10 years. I 12 took one pipe component with wall thickness of 1-1/4 13 inch when it was installed 34 years ago, or 36 years 14 ago. Then I took that component and I let it corrode 15 at the rate before the EPU. Okay? Then I let it -- I 16 compared the prediction of that component after the 17 EPU, 10 years into the EPU, using the correction for 18 the velocity. And I put a range of corrections.
19 There's no correction, say velocity harder than 20 effect. I included the corrections that I have 21 provided you, which were, I believe, between 2.4 and 22 6, based on data.
23 JUDGE WARDWELL: And you've provided this 24 in the testimony.
25 DR. HOPENFELD: Yes. No, I didn't put the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1634 1 calculation on -
2 JUDGE WARDWELL: Give us the results.
3 DR. HOPENFELD: Well, the results are that 4 if you use the CHECWORKS prediction on this data, you 5 come in with 5 mils, but- the actual is going to be 10 6 mils if you look at that line, twice as much. It's 7 not 50 plus or minus 50, it's twice as much, so you 8 may be thinking your best estimate is five years.
9 Actually going there and cooking it 10 years. So you 10 go on like that for 34 years, suddenly you increase 11 the velocity, you lower the oxygen, although this feed 12 line the oxygen probably was the same, but you 13 increase the velocity. And you increase the velocity 14 over a range, because some components are going to be 15 in the range of velocity I gave. So on the extreme 16 side, you're going to pin it down to .37, then on the 17 higher side, you know, when the velocity effect is not 18 as pronounced, you have .71. In both cases, you're 19 below the -- you're actually below the ASME design 20 thickness.
21 Now, the ASME gave you a stamp and it asks 22 you to be within the ASME limits. Now, we're talking 23 about another issue. They're supposed to meet the 24 ASME requirements of the minimum design thickness.
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1635 1 and then you allow corrosion. You make a corrosion 2 allowance, so what we have here, we're exceeding.
3 JUDGE WARDWELL: Okay. What you're saying 4 is you performed a sensitivity analysis to show how 5 sensitive these calculations are to changes in 6 velocity.
7 DR. HOPENFELD: Right.
8 JUDGE WARDWELL: Is that correct?
9 DR. HOPENFELD: Right. But Dr. Hausler 10 has done it in a different way.
11 JUDGE WARDWELL: Dr. Horowitz, have you 12 performed similar sensitivity analysis for all the 13 various input parameters that you showed yesterday on 14 your presentation that go into calculating out the 15 wear from CHECWORKS, and how sensitive is that program 16 to the various -
17 DR. HOROWITZ: I have not done that 18 formally for CHECWORKS, but I can answer your 19 question, because EDF did exactly the sort of analysis 20 you're referring to. And the answer came out to be 21 the single most important variable was chromium 22 content, and everything else was insignificant.
23 JUDGE WARDWELL: So chromium content would
- 24. be what, your F6, your alloy factor?
25 DR. HOROWITZ: Yes.
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1636 1 JUDGE WARDWELL: That's the most 2 important.
3 DR. HOROWITZ: By far.
4 JUDGE WARDWELL: That's most sensitive to 5 that.
6 DR. HOROWITZ: By far. And the reason is 7 - let me finish - is that the normal carbon steel pipe 8 with fittings, the chromium level is unknown, between 9 zero and .4 percent. And so you can have one piece of 10 pipe that has a low amount of chrome and out of wear, 11 another piece of pipe has .2 percent of the loop cert.
12 JUDGE WARDWELL: Do you recall what the --
13 which of these factors are influenced by velocity of 14 your seven factors?
15 DR. HOROWITZ: It would be the mass 16 transfer factor, chromium bromide.
17 JUDGE WARDWELL: As is mass -- so velocity 18 influences mass transfer, we're really getting into an 19 argument or a discussion of whether or not that's a 20 linear relationship between mass transfer and an 21 exponential relationship. Is that correct?
22 DR. HOROWITZ: A little more complicated, 23 but essentially.
24 JUDGE WARDWELL: I've got to call you one 25 more time, Dr. Hopenfeld. From now on, if I don't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1637 1 have a question for you, I'd like for you not to raise 2 your hand. We're not in school here. Okay? I don't 3 have a question, but go ahead.
4 DR. HOPENFELD: Well, I just wanted to 5 make a comment on the line -- I wasn't telling you 6 anything different. Dr. Hausler has information, or 7 would like to comment about the completeness of my -
8 JUDGE WARDWELL: And I understand that, 9 and if I have a question for Dr. Hausler, I will ask 10 it. The reason I say that, Dr. Horowitz, is because -
11 - I mean Dr. Hopenfeld 12 DR. HOPENFELD: I understand.
13 JUDGE-WARDWELL: -- is that we have the 14 pre-filed testimony. Some of the testimony is clearer 15 to understand than others. And it's not to say that 16 the amount of questioning is any relationship to the 17 weight of the testimony. It's all weighted equally, 18 and then evaluated in regards to its credibility. But 19 it may be just that his testimony is clearer, so I 20 personally don't have questions.
21 DR. HOPENFELD: I apologize.
22 JUDGE WARDWELL: Well, I'll get it to when 23 I come down. I have a list of questions in regards to 24 velocity. Rather than trying to find it, I'd rather 25 go through mine in the order of things. It will take NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1638 1 more time for me to find it than when we eventually 2 get to it.
3 Are there any other factors in here --
4 but, Dr. Horowitz, it's fair to say, though, that it 5 would be argumentative in regards to whether or not 6 the mass transfer factor would, in fact, have a bigger 7 -- a larger impact on the ultimate results as you 8 change mass transfer if, in fact, you incorporated 9 some other relationship between that parameter and 10 velocity. If you use an exponential relationship 11 between that, in fact, your F2 factor dealing with 12 mass transfer would have a very large impact on the 13 ultimate results.
14 DR. HOROWITZ: Sure.
15 JUDGE WARDWELL: Is there any other one, 16 the temperature, geometry, pH, or oxygen factor that 17 would be highly sensitive in regards to testimony that 18 has been presented by NEC in this proceeding that you 19 wish to defend?
20 DR. HOROWITZ: Thank you for the 21 opportunity to defend the program. The other factor 22 that has been discussed in testimony has to do with 23 the concept of geometry factor. In fact, Dr.
24 Hopenfeld alluded to that earlier.
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1639 1 geometry factor to relate a lot of geometry factors.
2 The geometry factor relates the maximum corrosion rate
- 3. in the fittings to the maximum corrosion rate in 4 equivalent straight pipe; This approach was 5 originated by Mr. Keller in Germany in the early '70s, 6 and it's used in every crack prediction method that 7 I'm aware of, including the other programs I mentioned 8 this morning, this afternoon.
9 -The concept of geometry factor we related 10 in our testimony to loss coefficients and pressure, so 11 what we do, though, is not relate an average parameter 12 but a local parameter. And so if you have an elbow.,
13 we've looked at a lot of data, and taken the maximum 14 corrosion rate in the elbow, looked at the attached 15 pipe, looked at the corrosion rate there in the gear 16 shift. Admittedly, there's a scatter in the process, 17 but on the other hand, you get a result that's easy to 18 use, and works well enough for our purposes.
19 The other approach Dr. Hopenfeld 20 mentioned, and he quoted a reference, and that's 21 probably the first and only reference. If you use 22 computational fluid dynamics, you can say I might be 23 able to get a better answer, but you have to have 24 detailed modeling in whatever area you're looking at.
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1640 1 spend some time to really understand it, that's 2 perhaps a good approach. But that's not what we do in 3 CHECWORKS. CHECWORKS is a tool to help you pick 4 inspection locations. The use of geometry factors for 5 this purpose seems to work fine.
6 If you bear with me for two more sentences 7 or so. Last May there was a failure in a fossil plant 8 in Missouri, two men were killed. The utility hired 9 a consulting firm, did a CFB analysis and the stuff, 10 to look at that thing in great detail. They also 11 hired a consulting firm to do the CHECWORKS analysis 12 of all their single phased piping. In 1800 components 13 in single phase, the failure location was in the top 14 five CHECWORKS, so I think it works pretty well.
15 JUDGE WARDWELL: Is that your only 16 indication that CHECWORKS works well? Do you have 17 anything else from the -- either Vermont Yankee or the 18 rest of the nuclear industry that demonstrates the 19 ability of this program to predict wear? I mean, as 20 I look at those line correction factors, I'm not very 21 enthusiastic in regards to everything dealing with the 22 feedwater system.
23 DR. HOROWITZ: I understand, and I agree.
24 But I can't think of anecdotal experience off hand as 25 good as that one, but on the other hand, as I said NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1641 1 before, there are other programs available. And if 2 neople are unhappy with CHECWORKS, I don't see anybody 3 flocking to try it. I think that's -
4 JUDGE WARDWELL: In regards to the 5 geometric features or factors, does these count for 6 discontinuities in any manner within the geometry of 7 the component?
8 DR. HOROWITZ: The experience has been 9 that small discontinuities, irregular welds, do not 10 have a major effect on result. The problem you get 11 into is one tha.t if you know -- you have no way of 12 knowing what the detailed discontinuities are unless 13 you do a radiographic inspection. So you have a 14 feedwater line over there that you want to inspect, 15 you can only use the information you know, and that's 16 the gross characteristics of the piping system.
17 JUDGE WARDWELL: You have referenced E 18 08 in your testimony, and we've been looking at it.
19 I'm not sure I saw the date on that, and I was curious 20 about the date of that publication.
21 DR. HOROWITZ: Excuse me. Would you 22 repeat the number, please?
23 JUDGE WARDWELL: E-4-08. It's the flow-24 accelerated corrosion in power plants, Revision 1, NEC 25 03-7446. So, obviously, the interveners have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1642 1 published this document. That's a joke, boy. I'm 2 laughing.
3 (Off the record comments.)
4 DR. HOROWITZ: What page?
5 JUDGE WARDWELL: Just -- I don't know 6 where there's a date on it. I can't give you a page, 7 because there is no date. I was curious of the date.
8 MR. FITZPATRICK: E-4-08?
9 JUDGE WARDWELL: Yes. When was that 10 published?
11 DR. HOROWITZ: It was published, the Rev.
12 1, 1998.
13 JUDGE WARDWELL: Thank you. Explain 14 again, Dr. Horowitz, what the results of CHECWORKS 15 provides to someone like Mr. Fitzpatrick in regards to 16 selecting the components for inspection. I gather it 17 doesn't dictate it, but that it just presents where 18 the -- well, you tell me what it presents in order, 19 and then how Mr. Fitzpatrick - or you can turn it over 20 to him on how he actually selects the points.
21 DR. HOROWITZ: What the program does for 22 each analysis line is presents predicted wear rate, 23 and predicted total wear for that component. For 24 components with measured data, it also compares the 25 predicted wear with the measured wear at the time of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1643 1 that inspection. That's the main thing it does.
2 JUDGE WARDWELL: Does it rank it in any 3 fashion, or highlight those that are a certain 4 criteria?
DR. HOROWITZ: At the user's option, you 6 can sort it, mix and match, whatever. And the other 7 thing that's presented is time to reach a user-defined 8 critical thickness.
9 JUDGE WARDWELL: And that's presented in 10 just a results tabular fashion?
11 DR. HOROWITZ: Those are those tables we 12 were looking at earlier.
13 JUDGE WARDWELL: And there's no other 14 editorial or recommendational type of subfunction that 15 gives it any other weight or emphasis besides -
16 DR. HOROWITZ: Yes. As far as CHECWORKS 17 is concerned, that's exactly right. There are third-18 party software add-ons that do back-end calculations, 19 but that's not -
20 JUDGE WARDWELL: So, Mr. Fitzpatrick, how 21 do you use that now to dictate the selection of the 22 inspection points? What criteria do you use? What 23 determines where and how many inspections you will 24 conduct?
25 MR. FITZPATRICK: Can I walk you through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1644 1 what we did, the example we did?
2 JUDGE WARDWELL: Sure.
3 MR. FITZPATRICK: E-4-40 would be the 4 previous outage.
5 JUDGE KARLIN: Could you speak up, sir?
6 MR. FITZPATRICK: E-4-40. These were for 7 the 2004 outage. The old program name is on the top.
8 The process is the same. Go to page -- well, the 9 first page lists the criteria. We match the criteria 10 in the procedure. On the first page, lateral piping.
11 This is just a general list, and then there's a 12 selection process in the following pages. Components 13 selected from where from previous inspections. We 14 identify the susceptible ones in CHECWORKS. We use 15 industry experience points, the nuclear -
16 JUDGE WARDWELL: Well, let me interrupt.
17 I'm rather -- I guess I don't want the example. I'd 18 rather know what's your philosophy on it. I don't want 19 to just go through it, and read what you did. I want 20 to know what you're thinking. I mean, you got these 21 results, and now you've got to interpret them. What 22 do you do to interpret them?
23 MR. FITZPATRICK: The CHECWORKS?
24 JUDGE WARDWELL: Yes. How do you 25 interpret, and then take that CHECWORKS data and end NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1645 I up with this as a result?
2 MR. FIT7PATRICK: Whatever CHECWORKS 3 results you have at that time. You look at. components 4 with the highest wear rates that you don't have any 5 inspection data on. You can select those.
6 JUDGE WARDWELL: So you'll sort it by 7 highest wear rates.
8 MR. FITZPATRICK: Or pick them out.
9 That's one inspection. Highest wear rates is one 10 criteria. The time to t min predicted by CHECWORKS 11 for the event, inspection data on that :component.
12 That's another factor. And then other areas of the 13 model, if we don't have that much inspection for that 14 -- data for that one line, we will add components in 15 to help work on a correct correlation.
16 JUDGE WARDWELL: Do you do this yourself?
17 MR. FITZPATRICK: Yes.
18 JUDGE WARDWELL: Does anyone else do it 19 separately, and then you get together and compare 20 notes to see whether you both reached the same 21 conclusion, or is it just you do it?
22 MR. FITZPATRICK: I do it, and another 23 engineer reviews it. He may add more components and 24 say why are you doing these? And it's a peer review 25 thing.
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1646 1 JUDGE WARDWELL: But it isn't a separate 2 analysis, it's a review of your's.
MR. FITZPATRICK: Yes.
4 JUDGE WARDWELL: Dr. Horowitz, does 5 CHECWORKS use average velocities, or maximum 6 velocities in its mass transfer coefficients?
7 DR. HOROWITZ: CHECWORKS uses average 8 velocities.
9 JUDGE WARDWELL: Is there a reason for 10 that?
11 DR. HOROWITZ: Yes. The reason is that's 12 the available number for the plant. There's the mass 13 flow rate, easily converted velocity.
14 JUDGE WARDWELL: Are there usually -- is 15 there much difference between those two, and which 16 would be the most likely to influence flow accelerated 17 corrosion, and how would it possibly impact the 18 CHECWORKS results?
19 DR. HOROWITZ: Excuse me. You're asking 20 from average to maximum velocity?
21 JUDGE WARDWELL: No. I said what would be 22 the difference between average and maximum velocities, 23 and what effect would it have on the mass transfer 24 rates, in your professional opinion?
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1647 1 question correctly, you're saying you have a component 2, that over the course of a cycle your velocities vary 3 with time. Is that the sense, or is it something 4 different?
5 JUDGE WARDWELL: All of that, but is there 6 a uniform -- is it uniform velocity in all the 7 components in the cross-section also? There's both a 8 time faction, there's a time factor, there's a life 9 factor, I assume, and it's liable to vary at various 10 lengths, various positions along your total line. And 11 there. may be a cross-sectional, any of those?
12 DR. HOROWITZ: Thank you. I understand 13 what you're driving at. First of all, the way nuclear 14 plants run, they basically run at the same conditions 15 for long periods of time. So, temporally we use the 16 average velocity corresponding to the power plants' 17 run time.
18 As far as geometric changes in local 19 velocity due to things like elbows, like Dr. Hopenfeld 20 and Dr. Hausler both pointed out in their testimony, 21 and other geometrical fittings, what we use is we use 22 the average velocity in the cross-section, and we use 23 the geometry factors to correct for the different flow 24 patterns that occur in elbows, for example. So we use 25 average velocity for everything the user doesn't have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1648 1 to be concerned about variations of velocity, say
ý2 downstream of an orifice, or an elbow, or whatever.
3 JUDGE WARDWELL: Can I get a feeling on 4 how well these line works in package form? You have 5 assumed a linear velocity relationship with mass 6 transfer.
7 DR. HOROWITZ: Yes. Let me say, I can't 8 say in detail, but it's close.
9 JUDGE WARDWELL: I promise you I won't 10 steal it and go write a program. I understand. If, 11 in fact, it was exponential say to a 1.1 factor, or 12 anything really, 1.5, 2, whatever, in reality, and you 13 were incorporating a linear relationship, would not 14 that show up after the next plant inspection was 15 incorporated into the CHECWORKS program in a new 16 linear line correction factor, because you would be 17 off by quite a bit, wouldn't you?
18 DR. HOROWITZ: Yes. I think that -
19 JUDGE WARDWELL: As Dr. Hopenfeld has 20 said.
21 DR. HOROWITZ: You'd be off quite a bit, 22 and you would be off -- see, the velocity changes not 23 only something like a power uprate, but also changes 24 if you have a T and you add flow, so downstream end of 25 the Ts increase, or if you have a reducer. You have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1649 1 an eight inch pipe going to a six inch pipe, the 2 downstream velocity is roughly twice. And I think if 3 we were off in that manner, we were off as far as the 4 velocity exponent, that would be about the first thing 5 the user would see, that they would see that the 6 upstream pipe, upstream components, or the downstream 7 components, that the eight inch and the six inch 8 components are way di ff erent. The eight inch would be 9 over-predicted, and the six inch would be under-10 predicted based on a higher velocity power. So I am 11 quite confident that the velocity power functionality 12 we use is correct, because nobody has complained in 20 13 years about it.
1.4 JUDGE WARDWELL: How strong an influence 15 is a line correction factor in trying to correct any 16 of your less than accurate assumptions that you've 17 made in your correlations, or just your error bar in 18 your correlations for the various six or seven 19 factors? Is it -- let's say you went in there right 20 now and put in a relationship between velocity and 21 mass transfer to the fourth power. Maybe that's a 22 little extreme, but I'm just curious. I want to get a 23 feeling for how fast the line correction factor would 24 compensate for that based on comparing your predicted 25 data to the actual measured data.
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1650 1 DR. HOROWITZ: I believe I can understand, 2 and I'll try to answer that. The line correction 3 factor does different things depending on different 4 situations. For example, if you have variations in 5 plant water chemistry in some range, the engineer has 6 to make an estimate of what technical value to use, 7 and that introduces a non-linearity.
8 In the case that hypothetically if you 9 change the model, whatever power you want, fourth say, 10 and the situation -- if you just had a straight piece, 11 say you had a straight piece of pipe, same diameter 12 elbow., other elbow, other piece of pipe, and you did 13 it, the line correction factor would solve that 14 problem, even though your model is way off, because 15 it's modifying all the results by the same event.
16 The problem would come in, and I think it 17 would be noticeable, is if the velocity is changing 18 along the line. If you have change in pipe diameter, 19 change in flow rates -
20 JUDGE KARLIN: Mr. Raubvogel, could we 21 minimize the conversations over at NEC's table, 22 please?
23 MR. RAUBVOGEL: Yes, sir.
24 JUDGE KARLIN: Thank you. Please proceed, 25 Dr. Horowitz.
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1651 1 DR. HOROWITZ: i don't know, but my 2 speculation is that the user would see a very large 3 amount of scatter. If he were curious enough to take 4 a look, he would see that the low velocity points were 5 here, and the high velocity points were there, and say 6 something is messed up with the model, because that's 7 not what you wanted to see.
8 JUDGE WARDWELL: In a general sense for 9 all of the factors, is it fair to say that your model 10 is not designed to rely on the line correction factor 11 to correct gross errors in any of your correlation, 12 but more to fine tune the results to be a better 13 predictive tool?
14 DR. HOROWITZ: Yes, that's exactly right.
15 JUDGE WARDWELL: So you can't count on 16 that to make up for bad correlations in your -
17 DR. HOROWITZ: That's exactly correct.
18 JUDGE WARDWELL: And it is -- your 19 correlations being proprietary, and rightfully so, are 20 unknown to us, but it sounds pretty much that they're 21 based on empirical data, as opposed to a theoretical 22 solution of any hydraulic or other heat transfer, or 23 any of the other types of things that may relate to 24 each individual factor?
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1652 1 statement. We understand the scientific 2 underpinnings, but the correlation itself is 3 correlation.
4 JUDGE WARDWELL: So, in essence, it's 5 built on plant data from a number of sources to start 6 with.
7 DR. HOROWITZ: Absolutely.
8 JUDGE WARDWELL: Built on not a 9 theoretical solution that you're trying to now apply 10 to this, but is built on hey, this is what we've seen.
11 Did it take place over the years?
12 DR. HOROWITZ: That is correct.
13 JUDGE WARDWELL: How much of that data is 14 related to the power levels we're dealing with here 15 for line eight?
16 DR. HOROWITZ: The power level as a 17 percent, the power level as a power, or -
18 JUDGE WARDWELL: Well, you tell me, but I 19 believe it would be more important to be the absolute 20 level of power, rather than just the fact that it's 21 gone up 20 percent. That's important at Vermont 22 Yankee. I mean, yes, it's -- the increase of 20 23 percent is important, but that number has no magic.
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1653 1 correctly?
2 DR. HOROWITZ: CHECWORKS covers the range 3 of conditions at Vermont Yankee. It covers the range 4 of conditions at operating light water reactors. The 5 change at Vermont Yankee is primarily one of velocity, 6 and the velocity, checked with Mr. Fitzpatrick the 7 other day, maximum velocity is just under 25 feet a 8 second in the feedwater system, and this is comparable 9 with any number of other plants.
10 JUDGE WARDWELL: And what is the absolute 11 power level there that's now being used, Mr.
12 Fitzpatrick, at Vermont Yankee? What are we at?
13 MR. FITZPATRICK: Power level?
14 JUDGE WARDWELL: Yes.
15 MR. FITZPATRICK: 1912 megawatts thermal.
16 JUDGE WARDWELL: Have you looked at the 17 distribution of your data that generates these 18 correlations, Dr. Horowitz, as it relates to various 19 absolute power levels? My question focused towards, 20 is there, in fact, a bias in your program towards the 21 lower power levels, in fact, masking some of the 22 effects associated with the higher power levels, such 23 that Vermont Yankee is at?
24 DR. HOROWITZ: The answer to the first 25 part of your question is no. We assembled most of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1654 1 data and most of the re-validation before anybody was.
2 thinking about power uprates. In fact, originally 3 around '88, and later about '94-95 -
4 JUDGE WARDWELL: So most of those were at 5 what power level, about?
6 DR. HOROWITZ: There were, as I recall, 30 7 different units. I can tell you, but I'd have to dig 8 out the information.
9 JUDGE WARDWELL: Would you have a rough 10 idea, Mr. Fitzpatrick? Well, what were you before the 11 power uprate?
12 MR. FITZPATRICK: 1593.
13 JUDGE WARDWELL: And that's thermal, 14 right?
15 MR. FITZPATRICK: Megawatts thermal. His 16 direct inputs are really the velocity and 17 temperatures, and that could be -- our 120 percent 18 power and velocity and temperature is conducted at 80 19 percent power in another plant.
20 JUDGE WARDWELL: That's my point.
21 MR. FITZPATRICK: Yes.
22 JUDGE WARDWELL: But my point is also, how 23 does that compare to the range of velocities and 24 temperatures, or power, whichever you want to call it.
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1655 1 that was used to generate the correlations. What I'm 2 concerned about is that we're masking the effects of 3 the higher power level at Vermont Yankee but this huge 4 database of information from the other plants that 5 were at a lower-- power level. And has anyone 6 considered getting rid of some that database that's at 7 the lower power level, and only dealing and 8 calibrating CHECWORKS based on the range of power 9 levels that are there?
10 DR. HOROWITZ: Again, I couldn't list for 11 you today the -- like I said, about 30 units, whatever 12 it was, that we used, but even though this has been a 13 while ago, Vermont Yankee with the uprate is still a 14 fairly small plant in terms of power level. I can't 15 really see how -
16 JUDGE WARDWELL: So they're at the low 17 end, you say, of your database, you believe?
18 DR. HOROWITZ: I would speculate so, 19 because 600 megawatts electric is still a pretty small 20 plant. And I'd kind of be surprised the other way if 21 they have a lot of plants that small, they're the 22 plant on the computer.
23 JUDGE WARDWELL: Dr. Horowitz, do you know 24 off the top of your head what the oxygen levels were 25 before the switch to hydrogenated water, and what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1656 1 effect that had on the oxygen levels, and what 2 resulting effect that might have on the CHECWORKS 3 results and prediction capabilities?
4 DR. HOROWITZ: I don't know off-hand the 5 -level. I can discuss at great length more if you want 6 to hear, hydrogenated water. Jim, do you know?
7 MR. FITZPATRICK: The oxygen levels are 8 the same as before, around the same amount of oxygen -
9 - the same amount of oxygen is injected in the lines.
10 We didn't reduce oxygen levels in the feedwater piping 11 in order to introduce -- as the content of the 12 feedwater piping where it's introduced to the reactor 13 for power uprate. There was no drastic change in 14 oxygen levels introduced in the feedwater condensate 15 piping.
16 JUDGE WARDWELL: So are you testifying 17 that the dissolved oxygen is the same in the water 18 system after the hydrogenated water efforts?
19 MR. FITZPATRICK: In the feedwater and 20 condensate, yes. The CHECWORKS model has an option 21 for the hydrogen water chemistry, and they included 22 that change when that occurred in the CHECWORKS notes.
23 It affects steam system and other parts of the 24 chemistry calculations they use.
25 JUDGE WARDWELL: And did you see -- that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1657 1 certainly changed your oxygen level in those systems,.
2 though, didn't it?
3 MR. FITZPATRICK: In the steam system -
4 JUDGE WARDWELL: Right.
5 MR. FITZPATRICK: Most of those are crac k-6 resistant material.
7 JUDGE WARDWELL: Thank you. What about 8 this local flow velocity, the potential for turbulence 9 that Dr. Hopenfeld brought up in regards to one of the 10 components he's - concerned about, do you have any 11 comments on that?
12 DR. HOROWITZ: Yes. We believe the 13 geometry factor accounts for that local turbulence.
14 That's what causes the factor to be greater than one.
15 JUDGE WARDWELL: Mr. Fitzpatrick, how 16 large is your grid size that you use for your 17 inspection program?
18 MR. FITZPATRICK: It's a function -- it 19 varies with the size, the outside diameter of the 20 pipe. To carry on the procedure, there's a chart for 21 diameter to grid size that is used.
22 JUDGE WARDWELL: Give me a range of 23 things. Give me your largest pipe in the grid size, 24 and the smallest pipe that you do inspections on, the 25 grid size-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1658 1 MR. FITZPATRICK: One to six inch diameter 2 we use a one inch grid spacer.
3 JUDGE WARDWELL: A one inch?
4 MR. FITZPATRICK: One inch.
5 JUDGE WARDWELL: Thank you.
6 MR. FITZPATRICK: And it goes up, eight to 7 ten is a two inch. Twelve to fourteen is a three 8 inch. Sixteen to eighteen is a four inch.
9 JUDGE KARLIN: Are you reading from an 10 exhibit, sir?
11 MR. FITZPATRICK: Yes.
12 JUDGE KARLIN: Okay. Can you cite that?
13 MR. FITZPATRICK: There's two exhibits 14 that show it. Sorry. It's the fact program procedure 15 itself. I left my glasses at the -
16 JUDGE KARLIN: Well, maybe you can tell us 17 that after the break.
18 DR. HOROWITZ: It's EN-25 at page 6.
19 JUDGE KARLIN: Thank you.
20 JUDGE WARDWELL: One last question before 21 we break. Are you presently using the current version 22 of CHECWORKS?
23 MR. FITZPATRICK: Yes.
24 JUDGE WARDWELL: And that version is?
25 MR. FITZPATRICK: It's SFA 2.2. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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- 1659 1 version was done the end of last year into this year.
2 JUDGE WARDWELL: Okay.
3 JUDGE KARLIN: All right. We've all been 4 on the stand for a while. Things are getting warm.
5 Let us take a break. Because we are hoping to 6 complete today, I think we should just take a 10-7 minute break, so we will be adjourned for 10 minutes.
8 (Whereupon, the proceedings went off the 9 record at 2:28 p.m., and went back on the record at 10 2:39 p.m.)
11 JUDGE KARLIN: I would -remind the 12 witnesses you are still under oath, and we proceed 13 with questioning on Contention Number 4. Dr.
14 Wardwell?
15 JUDGE WARDWELL: Mr. Fitzpatrick, how did 16 you determine those grid sizes that you gave us just 17 before the break? Was there a method that you did, or 18 is it just. pulled out of a hat?
19 MR. FITZPATRICK: No. They were 20 recommended in NSAC, and even before NSAC-202 they 21 were in the NUMARC guidelines that were developed 22 after the Surry accident. It evolved over time.
23 JUDGE WARDWELL: Is there a procedure in 24 NSAC that is available to calculate out?
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1660 1think it's presented as a table, a recommended grid 2 size. After we -- I think EPRI some work in the 3 beginning that related to reinforcing poles and pipe 4 and how much extra reinforcing they had to have, if 5 you had a flaw in that grid size. There may be pipe 6 without the flaw which would still meet the code.
7 That's the theory behind it.
8 JUDGE REED: So you told us how large the 9 grid size is, but I don't have a feel for the extent 10 of the grid. In other words, how many of these --- oh.
11 MR. FITZPATRICK: If you have a 12-inch.
12 pipe, you might have, geez, 12, 16 around, depending 13 on, you know -- they divide that and try to make it 14 even.
15 JUDGE REED: And to what extent axially 16 along the pipe?
17 MR. FITZPATRICK: That's what I was going 18 to get to. Typically, we do -- if it's an elbow into 19 the entire elbow 20 JUDGE REED: Okay. All the way around --
21 MR. FITZPATRICK: Yes. You paint the pipe 22 with the grid line and mark Xs. It represents the 23 elbow.
24 JUDGE REED: Okay.
25 MR. FITZPATRICK: The downstream pipe is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1661 1 two diameters. And so the flow inspector is 24 2 inches.
3 JUDGE REED: And, again, all the way 4 around.
5 MR. FITZPATRICK: All the way around, so 6 you end up with a matrix 12 by 14 or 12 by 20.
7 JUDGE REED: Thank you.
8 JUDGE WARDWELL: What led you to believe 9 that was sufficient diameters downstream from the 10 elbow that you needed the inspections to take place?
11 Dr. Horowitz?
12 DR. HOROWITZ: The procedure in NSAC, and 13 the procedure most people follow -- or everybody 14 follows -- is you inspect within the first two 15 diameters, and if you see any degradation continuing 16 you follow -- you follow the degradation. Normally, 17 though, the weardown screen or the fittings, accepted 18 orifice, is pretty close to the -- the maximum wear in 19 the pipe is pretty close to the rim.
20 JUDGE WARDWELL: NEC -- I'll start with 21 Dr. Hopenfeld, what do you feel is the minimum number 22 of diameters that should -- do you agree with that 23 procedure?
24 DR. HOPENFELD: No, I don't.
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1662 1 should be?
-) DR. HOPENFELD: It depends. If we take a 3 look at NEC JH-24 at 65, also if you would look after 4 that at --
5 JUDGE WARDWELL: Let's start-with one at 6 a time. Because if you give us more than one, it 7 doesn't help us. 53 8 DR. HOPENFELD: 53.
9 JUDGE WARDWELL: This is JH, correct?
10 DR. HOPENFELD: JH-63 at 65. This is 11 Japanese data from --
12 JUDGE WARDWELL: Well, we're looking at a 13 figure that's unnumbered. It says, "Investigative 14 Results of Thinning at Secondary System, " is that 15 correct?
16 DR. HOPENFELD: Okay. You see a valve in 17 the envelope, correct?
18 JUDGE WARDWELL: Yes, that's in the --
19 you're speaking of the flow pattern analysis around --
20 DR. HOPENFELD: Yes.
21 JUDGE WARDWELL: -- small square in the 22 lower left-hand corner of this figure on page 65.
23 DR. HOPENFELD: Correct. That's correct.
24 If you look at this, what happened here, there was a 25 flow disturbance in the valve, and that flow NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1663 1 disturbance affected the flow turbulence further 2 downstream.
3 JUDGE WARDWELL: Thank you. Let me 4 interrupt you right there.
5 Mr-. Fitzpatrick, have you found that yet?
6 MR. FITZPATRICK: I'm trying to find the 7 page.
8 JUDGE KARLIN: He's got it.
9 DR. HOPENFELD: And the question is -- if 10 we get this scalar, VY, we would model the pipe 11 downstream and the valve, an elbow, and another plant.
12 So there would be three components inspected 13 downstream of that valve, and we would probably 14 inspect them all.
15 JUDGE WARDWELL: So your two diameters 16 doesn't -- isn't -- doesn't affect -- well, it would 17 still stay, but you've got a countervailing component, 18 so you would analyze that.
19 MR. FITZPATRICK: Yes. Strike that as a 20 component. You go two diameters from the well to the 21 vertical pipe to the left.
22 JUDGE WARDWELL: And if you happen -- if 23 there happened to be some other component within those 24 two diameters, then you would start to -- you would 25 model that and then start -- you'd measure that and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1664 1 then go on until you found two diameters of straight 2 pipe beyond the components, is that correct?
3 MR. FITZPATRICK: If the component is in 4 -- if you have a component in two diameters, it's in 5- the CHECWORKS model, or whatever distance it is, it's 6 in the CHEC --
7 JUDGE WARDWELL: Can you give us an 8 example where there aren't these components in it, 9 just -- what would you say the amount of diameters 10 downstream should they be taking measurements on a 11 straight piece of pipe beyond an elbow?
12 DR. HOPENFELD: Well, as we talked about 13 yesterday, about cross-threading, would be a minimum 14 something like 25 to 45 diameters. That's the 15 engineering number.
16 JUDGE WARDWELL: And what basis is that?
17 Does anyone else -- is that someone else's --
18 DR. HOPENFELD: This is a customary --
19 there was no number that has been around in any 20 textbook or handbook for the last -- for a while, many 21 years -- the section where the flow is fully 22 developed.
23 JUDGE WARDWELL: Do we need to be in the 24 fully developed flow based on the program they set for 25 flow accelerated corrosion where they are applying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1665 1 CHECWORKS?
2 DR. HOPENFELD: No. We need to do that.
3 We never had it. We looked at the data. I think if 4 you look at the piping, it's so -- they are hardly 5 anywhere there. But --
6 JUDGE WARDWELL: Dr. Horowitz said that 7 they measured the two diameters. If they find wear, 8 then they expand the program.
9 DR. HOPENFELD: It's not sufficient. Two 10 diameters of flow is not -- is not very much at all.
11 JUDGE WARDWELL: Have you shown any 12 difference, Mr. Fitzpatrick? Have you shown excessive 13 wear using your approach in the straight pipes beyond 14 the component?
15 MR. FITZPATRICK: No, we haven't. We have 16 looked at four lines, six diameter, four specific 17 lines in the feedwater line, six feet of measurements, 18 have a 10-inch pipe. So it's -- we haven't seen any.
19 Also, I think the flow is fully developed 20 for the velocities that we have for these elbows.
21 JUDGE WARDWELL: Dr. Hausler, did you 22 comment on the floor diameters -- I can't remember --
23 in your testimony? And, if so, would you like to say 24 anything in regards to what you feel is the number for 25 the diameters?
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1666 1 DR. HAUSLER: No, Your Honor. I did not 2 comment directly on it. However, I would like to make 3 a very brief comment. The important consideration is 4 where the point of reattachment occurs. That is, if 5 you flow through an orifice, you get turbulence near 6 the orifice -- downstream of the orifice, near the 7 orifice you get an eddy, you know, close by. You 8 know, you get a point of reattachment of the flow on 9 the pipe.
10 At that point, the reattachment moves 11 further away where the higher velocity is. And that 12 is the consideration that says, you know, how many 13 diameters you have to be away, you know, from -- pipe 14 diameters you have to be away from the obstruction.
15 Now, it kind of sticks in my mind that 16 it's more than two, but I -- I cannot --
17 JUDGE WARDWELL: Thank you for that 18 explanation.
19 Mr. Fitzpatrick, do you disagree with the 20 description that Dr. Hausler just provided? And has 21 that been considered in your selection of the 22 diameters downstream of the component?
23 MR. FITZPATRICK: I believe he is talking 24 plate orifices for flow through an orifice, a regular 25 plate orifice. For the orifices in the main process NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1667 1 steam feedwater condensate at VY, the Venturi is a 2 pipe that -- shaped Venturi, smooth transition, smooth 3 bore area, and a smooth transition out.
4 We have looked two, three, even four 5 diameters downstream, and a number of fittings 6 downstream, and we haven't found any wear.
7 JUDGE WARDWELL: Thank you.
8 Dr. Horowitz, why wouldn't the water 9 chemistry change during the power uprate and have an 10 influence? Or does it have no influence -- have very 11 little influence on your results, in addition to the 12 flow rates and temperature?
13 DR. HOROWITZ: Well, let me just make one 14 comment. The two diameters here comes from British 15 data for orifices, and the point of maximum wear 16 downstream of an orifice as determined by a lot of 17 British data is about one to one and a quarter 18 diameters. So two diameters would capture steam from 19 orifice.
20 Hydrogen water chemistry power uprate, the 21 power uprate by itself shouldn't change the water 22 chemistry in the areas of interest, because you're 23 still injecting enough oxygen to bring the feedwater 24 concentration up to about 40 parts per billion. So 25 you're running a little water, you are just running NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1668 1 miore oxygen. As virtually all of the areas of 2 interest and from what I can see from what FAC are 3 concerned, that's the water chemistry they see.
4 JUDGE WARDWELL: Dr. Hausler, do you agree 5 that the water chemistry would change with the power 6 uprate? Or do you have any opinion?
7 DR. HAUSLER: No, I don't think that the 8 water chemistry would be directly affected by the 9 power uprate. However, what does happen is that in 10 the corrosion process oxygen is actually consumed.
11 And as the mass transfer of oxygen through the pipe 12 increases because of increased velocity, more oxygen 13 is being consumed. That will affect, of course, the 14 corrosion rate that one observes downstream of the 15 pipe from, you know, wherever oxygen is injected.
16 What that means, basically, is that you 17 cannot assume that the oxygen concentration is 18 constant through the flow path.
19 JUDGE WARDWELL: Mr. Fitzpatrick, do you 20 have any observations that indicate that that -- that 21 the oxygen does maintain constant, or in fact is 22 altered by the corrosion that is taking place -- the 23 increased corrosion that is taking place with the 24 increased flow rate?
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1669 I question, and I think Dr. Horowitz would be a better 2 person to address that.
3 JUDGE WARDWELL: That's fine.
4 MR. FITZPATRICK: But we measure oxygen 5 going in, and that doesn't seem to do anything- but 6 change, it would suggest that, but I'm not sure.
7 JUDGE WARDWELL: You say you are seeing 8 changes in regards to what he's suggesting, or you 9 don't see any changes that would support what he's 10 suggesting?
11 MR. FITZPATRICK: No, in our measurements 12 in oxygen, it is pretty much constant the entire 13 metrics that we see.
14 JUDGE WARDWELL: Dr. Horowitz?
15 DR. HOROWITZ: I was going to say I 16 believe Dr. Hausler is correct, but I don't think it's 17 a first order impact. I think the amount could change 18 and oxygen levels could be pretty small.
19 JUDGE WARDWELL: Thank'you.
20 Dr. Hopenfeld, do you believe the water 21 chemistry changes with the power uprate?
22 DR. HOPENFELD: It's hard to tell, because 23 talking to the CDTP people, looking back a long time 24 ago, and looking at the data, it's not that simple.
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1670 1 sources and sinks in that place. But Dr.. Hausler 2 isn't really running something of a calculation on 3 model, telling you what happened to the oxygen, 4 because there is an indication that there oxygen is 5 being consumed. And, therefore, it is almost 6 impossible to answer your question as close as 20 7 percent from the top.
8 JUDGE WARDWELL: Thank you, Dr. Hopenfeld.
9 Mr. Fitzpatrick, isn't it logical to 10 assume that with the increased flow rates that the 11 location for the critical measurements are liable to 12 change with those increased flow rates?
MR. FITZPATRICK: I don't believe so.
14 Locations that CHECWORKS shows as having the highest 15 flow rates, highest wear rates, are typically those 16 with the most tortuous geometry, around control 17 valves, the reducers, downstream of valve lines. That 18 won't change. All of the elbows of the model.
19 We already inspected the ones that had 20 previously been -- had been identified as the most 21 susceptible. And as we, over time, expand components 22 we will add more of those.
23 JUDGE WARDWELL: Another thought just came 24 to mind -- it's kind of off the screen -- as you were 25 describing that, your image of what would take place.
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1671 1 But are we or are we not applying this model to both 2 one-phase, single-phase, and two-phase flow, to your 3 system?
4 MR. FITZPATRICK: Yes.
5 JUDGE WARDWELL: And the one-phase flow 6 we're talking about is water, and the two-phase is 7 water and steam.
8 MR. FITZPATRICK: Yes.
9 JUDGE KARLIN: Could you clarify that?
10 Maybe I wasn't listening carefully, but I think you
- 11. said, "Are we or are we not?" and he said yes. And 12 I'm not sure which one is right.
13 MR. FITZPATRICK: It applies to single-14 phase piping. Most of the two-phase piping of the 15 model is already constructed with FAC-resistant 16 material.
17 JUDGE KARLIN: Is what?
18 MR. FITZPATRICK: Constructed of FAC-19 resistant material.
20 JUDGE KARLIN: But are any of -- is any of 21 it not such that you are also modeling two-phase flow 22 at Vermont?
23 MR. FITZPATRICK: We model it, but we're 24 inspecting the remaining locations that are still 25 carbon steel.
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1672 I JUDGE KARLIN: I think you referenced on 2 A-40 of your testimony that there was -- something in 3 the neighborhood of four and a half years worth of 4 data will be obtained prior to the power uprate I 5 think.
6 MR. FITZPATRICK: That's three cycles, 18-7 month cycles. We'll have three inspections with our 8 uprate experience.
9 JUDGE KARLIN: And so that will give you 10 three inspections over a --
ii, MR. FITZPATRICK: Yes.
12 JUDGE KARLIN: What is the technical basis 13 for you saying that that's sufficient data? That was 14 your argument on -- basically, on A-40.
15 MR. FITZPATRICK: We aren't seeing wear 16 rates now -- any significant wear now in one 17 inspection that is now completed. We don't expect to 18 see any change in the next two inspections. If it 19 does show up in the CHECWORKS models, we'll inspect 20 those components. But we have a high level of 21 confidence that we're not going to see any difference.
22 JUDGE KARLIN: But you are also going to 23 change the location if engineering judgment or all of 24 those other factors indicate that you should also look 25 at other locations, correct? You're not going to rely NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1673 1 solely on the CHECWORKS model?
2 MR. FITZPATRICK: No, sir. We're going to 3 use engineering judgment for the procedure, the steps 4 that we have in place to select components for 5 inspection.
6 JUDGE REED: Could you give us an idea 7 about how many inspection points you have chosen that 8 were not directly selected from CHECWORKS? How many 9 components, engineering judgment as opposed to how 10 many from CHECWORKS, on each inspection? Currently.
11 MR. FITZPATRICK: It's 60 drivable 12 components. It is approximately 60 drivable 13 components selected for the next refueling outage.
14 JUDGE REED: Okay.
15 MR. FITZPATRICK: I don't have this in 16 front of me, I think it's like 10 from CHECWORKS, 10 17 from previous inspection data, and maybe more, I think 18 it will be more. Say 20 from CHECWORKS, 20 from 19 previous inspection data, and the remainder is OE.
20 JUDGE REED: The remainder is what?
21 MR. FITZPATRICK: Operational experience, 22 OE.
23 JUDGE REED: Operational experience.
24 That's engineering judgment or --
25 MR. FITZPATRICK: Other plants --
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1674 1 JUDGE REED: Okay.
2 MR. FITZPATRICK: We get information from 3 INPO and --
4 JUDGE REED: So out of 60 inspection 5 locations, only 20 are coming from CHECWORKS?
6 MR. FITZPATRICK: Well, you could say a 7 third on average.
8 JUDGE REED: A third.
9 MR. FITZPATRICK: Yes.
10 JUDGE REED: If we took CHECWORKS away 11 from you and said, "Don't use it anymore, " would it be 12 a major disaster for you?
13 MR. FITZPATRICK: No.
14 JUDGE REED: Okay.
15 JUDGE WARDWELL: Your current flow 16 accelerated corrosion program calls for -- that you 17 had approved for the power uprate.
18 MR. FITZPATRICK: Right. Yes.
19 JUDGE WARDWELL: But then, it ends because 20 that's the end of your license. What's the frequency 21 of inspections for the -- for the extended period of 22 operation?
23 MR. FITZPATRICK: Every refueling outage 24 we will perform FAC inspections. That's the way the 25 procedure is written.
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1675 1 JUDGE WARDWELL: Where is that written?
2 If it's the same answer you're going to give uis that 3 you gave us for the discussion we had of the aging 4 management plan, we'll assume that --
5 JUDGE KARLIN: Don't get him started.
6 JUDGE WARDWELL: Yes. Don't get this --
7 (Laughter.)
8 We understand where it is --
9 JUDGE KARLIN: I woke up.
10 JUDGE WARDWELL: I know. We got him 11 excited now.
12 (Laughter.)
13 We had him sleeping and it was going fine.
14 We started pulling out books; we're in trouble.
15 (Laughter.)
16 If it is where you have alleged other 17 technical details are associated with our discussions 18 earlier this morning, I think we are familiar where it 19 is and where it is not.
20 MR. FITZPATRICK: Yes, it's through the 21 inspections, program procedure.
22 JUDGE WARDWELL: I think I'll start off 23 with Dr. Hausler again, and then move to Dr.
24 Hopenfeld. What is your justification for saying that 25 15 years of data is needed to benchmark CHECWORKS?
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1676 1 What is the basis of that? i was going to start with 2 Dr. Hausler.
3 DR. HAUSLER: Well, basically, the.
4 justification is this, that there are a large number 5 of points that have to be measured. They cannot all 6 be measured at one outage. They have to be measured 7 in succession.
8 And in order to determine the wear rate, 9 which is really not just used to select the points 10 where you are going to make your next measurement; 11 but, in fact, predict at what point in time a 12 particular item is going to be -- the wall thickness 13 of that particular item is going to be below curve.
14 In order to do that, you -- I'm sorry. In 15 order to do that, you would have to have fairly 16 accurate wear rates -- in such a way that you can 17 project when you need to either reexamine that 18 particular tank, or in fact to -- when you need to 19 replace it.
20 And in order to get reasonably accurate 21 forecasts, my estimation was that you would have to 22 have at least three data points to get yourself in the 23 direction -- to get the line -- three to at least be 24 able to not only calculate the slope but perhaps, you 25 know, put a confidence rate on that slope. So that's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1677 1 three.
2 You would have to -- if you do one-third 3 update measuring points of each outage, you have to 4 go, you know, nine times 1.5 years. You know, it 5 comes up to -- what -- 12, 14, 15 years, something 6 like that. That was the calculation, basically.
7 JUDGE WARDWELL: Mr. Fitzpatrick, it is 8 correct that you aren't measuring every point every 9 time?
10 MR. FITZPATRICK: Yes, sir.
11 JUDGE WARDWELL:. In your four and a half 12 years of data, which is three -- three sets of 13 inspections, correct?
14 MR. FITZPATRICK: Yes, sir.
15 JUDGE WARDWELL: That means you are 16 getting one measurement from each point.
17 MR. FITZPATRICK: Some will be two, others 18 will be one. We are going to inspect some of the 19 components that we inspected this last outage on the 20 power uprate conditions and get another data point in 21 the power uprate measurement. So we have a 22 significant database of inspection data prior to power 23 uprate, and we'll be comparing post-power uprates 24 inspection data with the pre-power uprate inspection 25 data to see if there's any changes.
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1678 1 JUDGE WARDWELL: But you should see 2 changes in your wear rate, I don't know what you call 3 that.
4 MR. FITZPATRICK: For the feedwater and 5 condensate system, we aren't--detecting wear -- it's 6 within the band of the UT, so you're -- we use a 7 default 005.
8 JUDGE WARDWELL: But it really doesn't 9 matter whether you're detecting it or aren't. The 10 point is, with one data point, you have no indications 11 if that is. the accurate, correct rate for a given 12 point.
13 MR. FITZPATRICK: We have more than one 14 data point because we have a pre- data point. We have 15 at least two data points.
16 JUDGE WARDWELL: You're got more than 17 that, but they are all taking place at a previous 18 power rate. I'm interested in --
19 MR. FITZPATRICK: And if you --
20 JUDGE WARDWELL: It's a question of 21 whether or not you don't need more -- how much 22 information you need to assure yourself that you've 23 got a good indication of what the power uprate is 24 doing to the flow accelerated corrosion.
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1679 1 measure of the differences in thickness from plant A 2 to plant B.
3 JUDGE WARDWELL: Right.
4 MR. FITZPATRICK: And that -- we can make 5 some assessment. If we start to see any real wear, 6 we'll increase the inspection scope for the procedure 7 and increase the number of inspections and the 8 frequency. But right now we don't have the data to 9 say we should do that.
10 JUDGE WARDWELL: But there are some points 11 now that you measured -- how many months into the 12 power uprate was your last inspection?
13 MR. FITZPATRICK: Twelve months.
14 JUDGE WARDWELL: Twelve months. That you 15 will never measure again until you go to the extended 16 period of operation, is that correct?
17 MR. FITZPATRICK: Yes. And there will be 18 others that have two points in the period. But if 19 you've got --
20 JUDGE WARDWELL: That doesn't impress me.
21 If you think that impresses me, it doesn't, because 22 when I plot off things, Dr. Hausler's explanation is 23 more consistent with what I use before I start making 24 engineering judgments, and that is, gee, I need a 25 minimum of three, because I can always put a straight NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1680 1 line between two points. That's not a problem.
2 MR. FITZPATRICK: We have a pre-3 established wear rate for a number of components based 4 on multiple inspection data prior to power uprate.
5 JUDGE WARDWELL: Fine. I want to know 6 what happens after power uprate.
7 MR. FITZPATRICK: Right now, all of the 8 wear rates that we are using for data selection, we 9 increase those calculated error rates 25 percent. All 10 of our planning is based on a 25 percent increase in 11 actual measured wear.
12 JUDGE KARLIN: Isn't that an assumption of 13 the proportionality almost?
14 MR. FITZPATRICK: Yes.
15 JUDGE KARLIN: Well, is it 25 percent 16 *that --
17 MR. FITZPATRICK: It's proportional to 18 the 19 JUDGE KARLIN: That's an assumption.
20 MR. FITZPATRICK: Yes.
21 JUDGE KARLIN: We're looking for data.
22 MR. FITZPATRICK: And we are taking the 23 data that will verify this subsequent. Right now, we 24 still have -- what I'm seeing is zero wear based on 25 one data point. We'll have another data point in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1681 1 fall.
2 JUDGE WARDWELL: Not for all, just other 3 components.
4 MR. FITZPATRICK: Yes.
5 JUDGE WARDWELL: So how do you know that 6 the one measurement you made -- was it January of '07?
7 MR. FITZPATRICK: That's why we increased 8 the number of inspections 50 percent, at least for the 9 first three outages, just to get an established wear 10 rate. That's -- we're talking trending real data, not 11 CHECWORKS. This is --
12 JUDGE WARDWELL: Right. Nothing to do 13 with CHECWORKS. This is strictly, just as Judge Reed 14 said, pretend you threw out CHECWORKS. For your aging 15 management program, in order to establish that, for 16 the power uprate I don't see how you can do it on one 17 data point.
18 MR. FITZPATRICK: If you have one outage, 19 you can get one data point. Regarding -- even before 20 we do power uprate, we are -- we are assuming there is 21 a 25 percent increase in wear due to the power uprate, 22 and we're planning on that that -- we're proceeding to 23 make inspections at the location and frequency that is 24 based on the 25 percent increase right now.
25 JUDGE WARDWELL: Dr. Hausler?
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1682 1 DR. HAUSLER: Thank you, Your Honor. I 2 would like to make a point. We just heard that every 3 point is in fact measured every outage -- every 4 outage. I would like to --
5 JUDGE WARDWELL: I'm sorry. What did you 6 just say?
7 DR. HAUSLER: Didn't Mr. Fitzpatrick just 8 say that every point is measured in fact at every 9 outage?
10 JUDGE WARDWELL: No, I don't believe he 11 said that at all. He said just the opposite. I mean, 12 he said that some may be measured twice over -- prior 13 to the extended period of operation. But a large 14 number will have only been measured once. Some of 15 them will only have been measured one time 12 months 16 after the power uprate. Others will be measured only 17 one time two and a half years after. And some will be 18 measured only once four years afterwards.
19 DR. HAUSLER: I'm sorry. It's late in the 20 afternoon. I must have misunderstood.
21 The other comment I wanted to make, if you 22 were indulge me just a second, is that we've heard the 23 comment against that localized flow-induced 24 accelerated corrosion is proportional to the velocity.
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1683 1 flow. If you have a disturbance in that flow, then 2 that correlation is not correct anymore, and that has 3 been shown in fact by many people, including our --
4 you know, the Dechema studies in Germany. So I think 5 we have to be very careful in using that kind of, you 6 know, correlation.
7 JUDGE WARDWELL: Dr. Horowitz, did you 8 testify earlier that the effects of potential 9 turbulence is incorporated into your model? And in 10 what aspect?
11 DR. HOROWITZ: In the geometry factors.
12 JUDGE WARDWELL: Thank you.
13 Dr. Hopenfeld, why do you -- what is your 14 basis, specific basis, that led you to believe 15 15 years of data is needed at the power uprate?
16 DR. HOPENFELD: Until an hour ago, I had 17 two -- I had -- an hour ago I had two reasons. Now I 18 have four reasons. So the first one --
19 JUDGE WARDWELL: And your reasons are a 20 function of time.
21 (Laughter.)
22 DR. HOPENFELD: I have prepared a matrix, 23 as I said before, based on four groups, and I told you 24 those groups are identified first by some component of 25 safety. And then, there are -- the grid on all of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1684 1 them is one inch, and that takes care of all of the 2 uncertainty, all the uncertainties, on all of the 3 discussions about turbulence and discontinuities, and 4 so forth.
5 Now, as I understand, to some degree they 6 have a blanket system. I don't know. I'm going by 7 what's been said. They are already looking for 8 smaller grids that you would have that we specified in 9 that way. And the reason we want to go to a smaller 10 grid, the --
11 JUDGE WARDWELL: Dr. Hopenfeld,. I am 12 begging you to answer the question.
13 DR. HOPENFELD: I'm just telling you --
14 JUDGE WARDWELL: The question had nothing 15 to do with the grid size. The question -- had 15 16 years of data, you said early on as part of your 17 original contention, needed to benchmark.
18 DR. HOPENFELD: That's correct.
19 JUDGE WARDWELL: I'm asking you if you 20 could explain why the -- what is the basis -- the 21 technical basis for you selecting 15 years. Dr.-
22 Hausler was very specific. I would like to have the 23 same specificity from you if I possibly could.
24 DR. HOPENFELD: To cover the matrix and the 25 eight inspections -- eight inspections with about a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1685 1 year and a half for the first inspection. That's all.
2 JUDGE WARDWELL: Thank you.
3 DR. HOPENFELD: You want the other answer?
4 JUDGE WARDWELL: No, if you've got another 5 answer, you've got another one.
6 DR. HOPENFELD: I've got three.
7 JUDGE WARDWELL: Yes, give me the other 8 three quickly.
9 DR. HOPENFELD: The other ones are based 10 on judgment. All of the major problems we have -- not 11 any big ones -- Surry, the Japanese accident several 12 years ago, the major ones, not really accident, but 13 really significant -- where we were over 15 to maybe 14 28, 30 years. And if that's the time scale, things 15 are going under and this is a slow process.
16 So this is the time scale that we talked 17 about, a year? Some of them it may be 10. It's an 18 average. But it's a ballpark number, and it also 19 tells you, look, they have been looking. I mean, they 20 have been -- people didn't stop looking --
21 JUDGE WARDWELL: Great. That's the second 22 one. Good one. Third one?
23 DR. HOPENFELD: -- they've been looking 24 for year.
25 JUDGE WARDWELL: Now the third one.
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1686 1 DR. HOPENFELD: The third one? It was 2 testified by -- I believe it's the first time I agree 3 with you -- that we could get away with CHECWORKS and 4 still be here today.
5 JUDGE WARDWELL:-- Thank you.
6 JUDGE REED: I would like to ask a couple 7 of questions, please.
8 JUDGE KARLIN: Sure.
9 JUDGE REED: It has been my impression 10 throughout this proceeding that the rate of corrosion, 11 flow accelerated corrosion, is essentially constant in 12 time. Whatever it is at a point, as long as the 13 reactor conditions don't change, the corrosion rate is 14 a corrosion rate and it corrodes essentially at a 15 constant rate. Is that wrong? Well, let me as Dr.
16 Horowitz.
17 DR. HOROWITZ: If the water chemistry is 18 the same?
19 JUDGE REED: Yes, everything is the same.
20 DR. HOROWITZ: Yes, they would be 21 constant.
22 JUDGE REED: This is constant. So in 23 order to determine -- in order to determine that rate, 24 it really only takes two points. Is that correct?
25 DR. HOROWITZ: Yes.
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1687 1 JUDGE REED: Okay. Now --
2 JUDGE WARDWELL: Can we ask, Dr.
3 Hopenfeld, do you agree with that?
4 DR. HOPENFELD: No. Because I --
5 -JUDGE WARDWELL: Okay. That's all. You 6 don't have to do that.
7 JUDGE REED: Okay. Let me ask the staff 8 of the NRC. Do you agree that corrosion rates are 9 essentially constant given constant conditions? That 10 the conditions don't change, the rate at which the
.11 metal corrodes is constant?
12 MR. HSU: Yes.
13 JUDGE REED: So basically the wall 14 thickness is basically reduced at a constant rate 15 until it's gone.
16 MR. HSU: That's right. Otherwise, you 17 cannot do any kind of testing. Your testing becomes 18 like useless, because it's going to keep changing.
19 Like in the testing data we have never really seen 20 this kind of development there.
21 JUDGE REED: Do Hausler, do you agree?
22 DR. HAUSLER: It's patently wrong.
23 JUDGE REED: Patently wrong?
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1688 1 is in the question. The conditions do not remain the 2 same.
3 JUDGE REED: Oh, no, no. I'm sorry. I 4 asked you --
-" 5 DR. HAUSLER: Let me explain what I mean 6 by that, please. The temperature, the pressures, the 7 environmental conditions remain the same. However, 8 the surface changes. As the surface changes, the 9 turbulence changes, and thereby the mass transfer. So 10 it is absolutely impossible that the corrosion rate 11 remains the same.
12 JUDGE REED: Is there any experimental 13 evidence to support this linear assumption, a constant 14 rate assumption? Dr. Horowitz?
15 DR. HOROWITZ: Tremendous number, 16 including some -- in Dr. Hopenfeld's written 17 statement.
18 JUDGE REED: And could you provide a 19 citation for us?
20 DR. HOROWITZ: Sure. NEC JH-72.
21 JUDGE REED: We don't need to take the 22 time to look them up. I'd just like to know what they 23 are.
24 JUDGE KARLIN: No, no, may I just ask a 25 question?
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1689 1 JUDGE REED: Certainly.
2 JUDGE. KARLIN: I mean, it seemed like Dr.
3 Hausler's point was a valid one, in that there is 4 something that doesn't -- the situation does not 5- remain the same, because the, corrosion that is 6 occurring over time necessarily changes the thickness 7 of the pipe. So that is a variation. Does he have a 8 point there, Dr. Horowitz?
9 DR. HOROWITZ: Let me address your point 10 and his point.
11 JUDGE KARLIN: Yes, sir.
12 DR. HOROWITZ: okay. Your point, first, 13 is correct that that's a very small variation. When 14 you have a large pipe, the area flow rate doesn't 15 change that much.
16 JUDGE KARLIN: All right.
17 DR. HOROWITZ: As far as the changing 18 conditions, I mentioned at least once in this 19 testimony Dr. Bryan Poulson. Bryan is a corrosion 20 metallurgist who specializes in mass transfer.
21 JUDGE KARLIN: He is a what?
22 DR. HOROWITZ: He specializes in mass --
23 JUDGE KARLIN: He is a --
24 DR. HOROWITZ: A corrosion metallurgist.
25 JUDGE KARLIN: What is that word?
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1690 I DR. HOROWITZ: Corrosion.
2 JUDGE KARLIN: Corrosion. I'm sorry, 3 corrosion.
4 DR. HOROWITZ: Corrosion metallurgist who 5 specializes in mass transfer.
6 JUDGE KARLIN: Okay.
7 DR. HOROWITZ: And we used to have 8 discussions with him about this third issue, about how 9 -- factoring the change over times with the roughening 10 of the surface. Okay. That sounds good. Bryan did 11 some experiments with copper, and he also wrote some 12 papers based on the data.
13 With copper, the surface roughens more 14 than steel. You do see that impact, but only in small 15 sizes. But the more interesting thing he has done is 16 he has correlated mass transfer coefficient as a 17 function of flow conditions, including roughness. And 18 he came to the surprising conclusion -- it was 19 surprising to him -- that once a surface is rough, it 20 doesn't matter anymore how rough it gets. And that 21 was as surprising to him as it was to me.
22 So, number one, he disagreed that you 23 start with the surface, it gets rough, the coefficient 24 -- the corrosion rate changes, and you keeps changing 25 for ever and ever. I don't think that's true based on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1691 1 Bryan's results.
2 Secondly, looking at a lot of pipes 3 that --
4 JUDGE REED: I'm sorry. Let me interrupt 5 you. Would your point be that, since this reactor has 6 been operating for 30-some years, the surface is about 7 as rough as it's going to get --
8 DR. HOROWITZ: Yes.
9 JUDGE REED: Now -- and so there's not 10 going to be an effective change in the roughness for 11 the next 20 years.
12 DR. HOROWITZ: Right.
13 JUDGE REED: All right. Thank you.
14 DR. HOROWITZ: The surface is a steady-15 state common condition.
16 JUDGE REED: Well, I wonder if that 17 wouldn't imply, if you really believe that the 18 corrosion rate is a constant, instead of being 19 assessed with points to validate a code under 20 CHECWORKS, wouldn't it be better once you got a couple 21 of data points, or the points that you're examining 22 with -- as a result of the recommendations out of 23 CHECWORKS, to -- would it profit us to look elsewhere 24 in the reactor system for other places where corrosion 25 might occur, rather than continuing to look for 15 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1692 1 years at the same old places and verify this linear 2 assumption with five or six data points on a straight 3 line? That is a question for Dr. Horowitz.
4 DR. HOROWITZ: Okay. That's a very good 5 point. Once you have a lot of data, and your 6 conditions are the same, CHECWORKS doesn't really add 7 a whole lot of value. CHECWORKS adds value when 8 conditions are changing, you want to forecast what 9 impact it has on corrosion.
10 NSAC-202 recommends basically that 11 procedure. It says, "When you look at the list of 12 inspections, we do inspections, about half should be 13 new locations, and about half should be old 14 locations." That's the rule of thumb. But that is, 15 clearly, the guidance we have seen talking to a lot of 16 people throughout the industry.
17 JUDGE REED: Okay. Thank you. That's 18 all.
19 JUDGE WARDWELL: Mr. Fitzpatrick, in your 20 testimony -- you don't need to refer to it -- I think 21 you'll agree that at A-43, page 27, or somewhere near 22 there -- I think that's correct, that it's there --
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1693 1 CHECWORKS with maybe your flow accelerated corrosion 2 program.
3 While you do have a lot of experience at 4 Vermont Yankee, your experience under the current 5 power uprate is pretty limited, isn't it? .
6 MR. FITZPATRICK: Once cycle, yes.
7 JUDGE WARDWELL: Yes. So you don't have 8 much under this -- these conditions, correct?
9 MR. FITZPATRICK: Yes.
10 JUDGE WARDWELL: Have you studied the 11 results of flow accelerated corrosions from other 12 plants that have been operating for longer periods of 13 time at the powers that -- power level that you 14 currently are at?
15 MR. FITZPATRICK: I have looked at studies 16 from other plants, the CHECWORKS studies, and saw 17 increases proportional to velocity. That's what we 18 based our 25 percent number one. They had smaller 19 power uprates, and they --
20 JUDGE WARDWELL: Do you know about what 21 their absolute level of power is? Because, again, you 22 agree that it's not necessarily the percentage of 23 increase, it's where you end up at the power level 24 that's critical. You could have a 90 percent increase 25 if you start off real low and ended up at 500 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1694 1 megawatts of power, and you would have --
2 MR. FITZPATRICK: If there's a big BWR, 3 I'd be -- 400-something megawatts electric.
4 JUDGE WARDWELL: So much larger than what 5 you are --
6 MR. FITZPATRICK: Yes.
7 JUDGE WARDWELL: So a much higher power 8 level.
9 MR. FITZPATRICK: Yes.
10 JUDGE WARDWELL: Thank you.
1i Dr. Horowitz, you reviewed a lot of 12 different pipe failures from various other plants.
13 And, miraculously, you were able to attribute all of 14 the ruptures to something other than CHECWORKS.
15 DR. HOROWITZ: Yes.
16 JUDGE WARDWELL: Some of those related to 17 the effectiveness of it at non-U.S. plants. Others I 18 believe were related to inappropriate application of 19 CHECWORKS by the operator at the plants. Were there 20 any other types of reasons for these unanticipated 21 ruptures to have occurred, that you can remember off 22 the top of your head that I can't?
23 DR. HOROWITZ: First of all, I was the one 24 who characterized the causes of failures. I think 25 you're talking about Fort Calhoun in particular, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1695 I Millstone 3 in particular. It was the NRC who 2 characterized it, not me.
3 JUDGE WARDWELL: Okay. Thank you.
4 DR. HOROWITZ: I can't think of a foreign 5 plant that had a failure using CHECWORKS or PAN. If 6 you're referring to Mihama in Japan three years ago, 7 or four years ago, that was nothing to do with 8 CHECWORKS, nothing to do with BENSAC. They have their 9 own way of doing business, and it's completely 10 different than we have.
11 I think for all the plants -- the ones 12 that were discussed here in testimony --
13 JUDGE WARDWELL: And there were some in 14 there that you or someone else attributed to modeling 15 errors, is that correct?
16 DR. HOROWITZ: Fort Calhoun is the only 17 one that leaps to mind. Millstone 3 was a modeling 18 error in that lines were omitted from the analysis.
19 JUDGE WARDWELL: I think there were some 20 modeling difficulties associated with the time 21 tracking of the model was one of the ones I had, but 22 that's fine.
23 I guess my point here is: is there 24 something inherently difficult in the model to apply 25 it that the errors occur? Or are these in fact --
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1696 1 DR. HOROWITZ: I think, in fairness -
2 I'll put my EPRI hat on - EPRI bears some of the 3 blame for that trend. EPRI has beefed up its training 4 in the last several years. And as time goe s by, they 5 do training again and again, and we learn from each 6 one, and we try and make the software as easy to use 7 as possible in each of our training.
8 The other side is it's a lot of 9 information that has to be put in by an engineer, and 10 it should be checked by an engineer. The common -- I 11 don't see any common mistake that people are making 12 is, 'Well, here's the wrong components code for this 13 situation."' Fort Calhoun is one thing, Millstone 3 14 was something else, so I -- you know, I don't see how 15 we can fix the problems until we better understand 16 what's causing them.
17 JUDGE WARDWELL: All right. Thank you.
18 Mr. Fitzpatrick, when you make a 19 measurement, that's -- the measurement you're making 20 is of the wall thickness. That is a result of total 21 thinning, or the --
22 MR. FITZPATRICK: It's basically the 23 condition of the pipe at the time of the measure.
24 JUDGE WARDWELL: What's the thickness of 25 the wall.
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1697 1 MR. FITZPATRICK: Yes.
2 JUDGE WARDWELL: That's what you're 3 measuring.
4 MR. FITZPATRICK: Yes, sir.
5 JUDGE WARDWELL: And, again, I think we 6 discussed this earlier this morning -- that thickness 7 in the wall is what it is, and it's a result of 8 whatever phenomena is occurring in that pipe, whether 9 it's flow accelerated corrosion, droplet impingement, 10 cavitation, erosion -- the whole enchilada. Whatever 11 that result, it's a global measurement effect, right?
12 And with no discrimination between the causal effects 13 or resulting in the thickness that it happened to be 14 at that given time, correct?
15 MR. FITZPATRICK: Yes, sir.
16 JUDGE WARDWELL: Dr. Horowitz, when that 17 is incorporated into CHECWORKS, CHECWORKS pretends 18 that is all flow accelerated corrosion, doesn't it?
19 DR. HOROWITZ: That's right.
20 JUDGE WARDWELL: There's a dichotomy 21 there. I mean, it's --
22 DR. HOROWITZ: That's true, and we 23 understand that. We only see the way -- the saving 24 grace as it were, in the fact that all of the studies 25 I've seen say that flow accelerated corrosion is by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1698 1 far the predominant degradation mechanism in the 2 systems.
3 The other point I can make, and sometimes 4 comes into play, is if you have impingement in 5 particular and you make measurements on a grid. The 6 wear pattern for impingement is fairly different. The 7 wear 'is much more localized, and an experienced 8 engineer can recognize the difference. That doesn't 9 happen all the time, but it happens with some of them.
10 So it's not quite as bad a situation as you may think.
11 JUDGE WARDWELL: When you run the pass-to 12 of the program, and it tries now to apply thi s linear 13 correction factor to the results, the first time you 14 do that pass-to -- strike that last statement. The 15 magnitude of the linear correction factor is 16 influenced, isn't it, by those other phenomenon, if in 17 fact it were occurring at that particular location?
18 DR. HOROWITZ: That's certainly true. In 19 general, though, if you're measuring, say, five 20 components in the line, you wouldn't -- no, I think 21 it's very unlikely that you'd have five components 22 damaged by other mechanisms in FAC.
23 JUDGE WARDWELL: So that line correction 24 factor is just what it says. It's for the whole 25 string, not for the individual components.
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16ý99 1 DR. HOROWITZ: That's correct.
2 JUDGE WARDWELL: Thank you.
3 Dr. Hausler, do you agree that droplet 4 impingement produces a different type of wall thinning 5 pattern than flow accelerated corrosion does?
6 DR. HAUSLER: Well, the morphology of the 7 -- patterns as you called them, is very likely 8 different, yes, indeed. The mechanism, however, I 9 think is essentially the same. If you have a-droplet 10 impinge on the surface, the -- whatever is between the 11 droplet and the surface is being squeezed out. That 12 squeezing mechanism generates very high velocities, 13 and, in fact, you know, sort of like a suction in the 14 sense that now the droplet is, you know, almost sucked 15 into the surface so to speak.
16 At that point, you have locally extremely 17 high shear stress, and, therefore, very high mass 18 transfer. And that, of course, causes the -- you 19 know, the corrosion to be sort of localized. Now, if 20 that droplet always hits the same point, then you will 21 get kind of a trough. If that droplet, however, hits 22 the surface randomly -- I mean, if droplets hit the 23 surface randomly, you may well see in the end a larger 24 trough with kind of orange peel surface maybe. No, 25 actually, it's more like perhaps a golf ball type of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1700 1 surface.
2 JUDGE WARDWELL: If, in fact, the droplet 3 stayed in one position, would it do what was alleged 4 by I think it was Entergy that you would get a hole, 5 and that hole would -not tend to grow?
6 DR. HAUSLER: No. I think if a droplet 7 hits the surface it cannot possibly stay in the same 8 position. Did I misunderstand the question?
9 JUDGE WARDWELL: If it did, if it kept 10 hitting the same location, would it not make a hole 11 and then 12 DR. HAUSLER: If successive droplets hit 13 the same location --
14 JUDGE WARDWELL: Right, yes.
15 DR. HAUSLER: -- constantly, yes, you will 16 get in fact -- you know, that's like a drill. You 17 know, you can go through a wall, you know, like 18 drilling.
19 JUDGE WARDWELL: Dr. Horowitz, I think it 20 was you that testified about the droplet. What leads 21 you to believe the droplet would hit the same location 22 all the time and not hit other locations? Just keep 23 on sweeping back and forth and eventually wear it very 24 similar to what flow accelerated corrosion would?
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1701 1 that. There is numerous experience showing pinhole 2 leaks, particularly heater vent lines where you have 3 exactly this phenomenon occuring. You have one hole 4 or maybe one or two little holes, and it looks like 5 somebody took the drill and broke through that pipe 6 hole.
7 JUDGE WARDWELL: I~n that same experience, 8 recorded experience, documented experience, was there 9 any indication that it tended to migrate and, in fact, 10 would create a larger area of failure than just a 11 pinhole?
12 DR. HOROWITZ: "Larger" is relatively most 13 failures -- most failures of the pressure boundaries 14 like that are under an inch or -- or probably mostly 15 under average.
16 JUDGE WARDWELL: I'm sorry. Mostly?
17 DR. HOROWITZ: Well, it would be around an 18 inch. Most of the ones would be under a half an inch.
19 For example, let me give you -
20 JUDGE WARDWELL: I'm sorry. I think 21 you're answering the wrong -- I didn't make myself 22 clear in regards to my question. My question was: at 23 those documented -- the documentation that you just 24 said from the plethora of experience you say there is 25 with this droplet impingement producing a hole, was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1702.
1 there any indication that at some of the locations the 2 droplet did not hit the same location, but in fact 3 migrated at various other locations nearby, so that it 4 produced a larger non-circular type of failure, like 5 a crack, a broader-based crack, the wall thinning over 6 a larger area, so that you ended up with a breach --
7 a crack, a breach in one -- in a line as opposed to a 8 circle here.
9 DR. HOROWITZ: The experience varies 10 actually. In general you have pinholes and slightly 11 larger holes, perhaps a quarter inch, perhaps a half 12 inch. Occasionally, you'll see something that looks 13 a little different, and it's more of a challenge.
14 But if you look, for example -- and Mr.
15 Witte referred to one of the scoping reports, and 16 there is some experience listed, and in that they talk 17 about pinhole leaks and holes in vent lines. Those 18 are in the category of small -- small leaks I think is 19 the way it was characterized.
20 JUDGE WARDWELL: Thank you.
21 Dr. Hausler, could you clarify for the 22 Board what was the basis for concluding that the 23 accuracy of CHECWORKS is within two? I think that was 24 part of your testimony on page 3 of RH-04.
25 DR. HAUSLER: Yes. We looked a little NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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11703 1 earlier at one of those graphs that shows the diagonal 2 for the prediction of the measured wear on the break.
3 And we saw two lines -- one is 5.0 percent, the other 4 one 50 percent on the lower end.
5 -Now, if you look -- if you think about 6 what the 50 percent means, it's that the prediction is 7 50 percent of what you find. That is not the focus or 8 the objective of what is being done. We would like to 9 know how accurate the measurement is with respect to 10 the prediction.
11 If you go back and look at these curves 12 you will find that the 50 percent line is actually a 13 factor of two over the prediction. Simfilarly, the 14 minus 50 percent line, if you look at it again, you 15 will find it is half of the prediction -- again, a 16 factor of two.
17 If you permit me to comment, it is nice to 18 have 50 percent accuracy in corrosion, because that 19 would be, you know, quite tolerable. It is not so 20 nice to have an accuracy of a factor of two in 21 corrosion, because that puts into question the -- you 22 know, the prediction of what is going to happen in the 23 future. In other words, you cannot really, you know,
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1704 1 know, you are below code.
2' That is the basis for my -- for my 3 comment. Perhaps it's --- you know, it's -
4 JUDGE WARDWELL: Well, it's basically, 5 you're taking the inverse of the 50 percent, and that 6 is where the two factors sort of basically comes up.
7 And it's a communication tool to put a handle of how, 8 as you say, accurate --
9 DR. HOROWITZ: And I --
10 JUDGE WARDWELL: And you're saying, aren't 11 you, that it's better to word it that it's a factor of 12 two, rather than 50 percent accuracy, and it better 13 represents your ability to predict something.
14 DR. HOROWITZ: I think it's a matter of 15 logic as well.
16 JUDGE WARDWELL: That's fine.
17 DR. HOROWITZ: Because, you know, you can 18 cite on the one side the prediction. The prediction 19 is 50 percent of what we see. On the other side, 20 towards the lower values, we would say the prediction 21 is -- what we see is 50 percent of the prediction.
22 And so, you know, you shift the argument 23 depending on which side of the curve you look at. And 24 the way I'm trying to explain it is a lot more 25 consistent, because on the high side we've got a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1705 1 factor of two, and on the lower side we've got a 2 factor of two as well.
3 And what you're really interested in is 4 not a prediction. What you are really -- is not, you 5 know, what the model tells you. What you are really 6 interested in is what actually happens in the field --
7 in real life.
8 JUDGE WARDWELL: That's good. Thank you.
9 That helped a lot.
10 Your RH-03 -- and I was quickly trying to 11 look for it, and I -- I can't place my fingers on it 12 right off the bat. I've got 04 and 05. I've got 01 13 and 02.
14 JUDGE KARLIN: RH-03.
15 JUDGE WARDWELL: It would appear I dreamt 16 it, except we have a gap also.
17 JUDGE KARLIN: I believe it's -- is it 18 testimony?
19 JUDGE WARDWELL: I assume it's a report.
20 There's a figure in there that I'm interested in 21 seeing where the data points came from.
22 MS. TYLER: We have it, Judge Karlin.
23 JUDGE KARLIN: Oh, okay.
24 JUDGE WARDWELL: Where is that bound?
25 MS. TYLER: It's in the big volume.
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1706 1 JUDGE WARDWELL:. Oh, okay. Oh, there it 2 is. Yes, it snuck in -- oh, tricky, yes, tucked right 3 in between JH-53 and UW-03.
4 JUDGE KARLIN: Okay.
5 JUDGE WARDWELL: Ah ha. I know it's not 6 me going senile. And it is a report discussing this 7 by him, and it's 8 of 12, I believe.
8 JUDGE KARLIN: It's a report by whom?
9 JUDGE WARDWELL: RH-03 at 8, and I think 10 it's slash 12. Let me see if I can find it again.
11 It's a report by Dr. Hausler, and it's Figure 3.
12 Okay. There we go. Okay. Figure 3.
13 DR. HAUSLER: What page?
14 JUDGE WARDWELL: It's 11 of 18. I've got 15 Figure 3, but -- bear with me for a minute. Well, I 16 must have been thinking about Figure 5, and I just 17 have it typed wrong, because that's the only figure 18 that has data points on it. That must be it, the mass 19 loss rate of Figure 5, 12 of 18. That's all I can 20 figure.
21 Where did those figures come from, and 22 what are the various data points? What are we varying 23 there?
24 DR. HAUSLER: Well, the data points are 25 the mass loss rate plotted versus the X over D. In NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1707 1 other words, the distance and the relative distance 2 normalized to the diameter of the pipe.
3 JUDGE WARDWELL: Okay. So that's --
4 that's the plate orifice that you were talking about 5 earlier, that you referenced.
6 DR. HAUSLER: That's correct, yes.
7 JUDGE WARDWELL: The pipe and the orifice 8 you're representing is that figure up above.
9 DR. HAUSLER: Correct.
10 JUDGE WARDWELL: The top part is --
11 DR. HAUSLER: Correct.
12 JUDGE WARDWELL: Got you. But what are --
13 what I don't understand is, what are the various 14 lines? What is the triangle, the circle?
15 DR. HAUSLER: They are -- it's a function 16 of the parameters, velocity, meters per second. U 17 equals --
18 JUDGE WARDWELL: So that's velocity.
19 DR. HAUSLER: That's velocity.
20 JUDGE WARDWELL: Okay. So the different 21 lines of the graph are the velocity.
22 DR. HAUSLER: Different velocities, that's 23 correct.
24 JUDGE WARDWELL: And do you have a 25 reference for who did this work?
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1708.
1 DR. HAUSLER: Yes. The reference is 2 actually listed in the paper, in one of the footnotes.
3 That's -- it comes from a paper by Heitz and Durman.
4 It's --
5 JUDGE REED: Am I reading this correctly?
6 This particular --
7 DR. HAUSLER: It's Reference 8.
8 JUDGE REED: Pardon me. Am I reading this 9 correctly? This is not -- this is for stainless 10 steel, or it represents stainless steel?
11 DR. HAUSLER: That's correct.
12 JUDGE REED: And it also contains sand.
13 DR. HAUSLER: That's correct. The reason 14 why this graph is in here is to demonstrate that in 15 fact the corrosion -- in order to demonstrate the flow 16 path. And the flow path, you know, obviously carries 17 the sand at certain velocities. And, you know, where 18 the velocity is high -- in fact, in this case it was 19 abrasion. Not just erosion or corrosion, but 20 typically abrasion.
21 And what I wanted to demonstrate with this 22 is that, you know, a very high, you know, velocity can 23 be prior to the orifice. In other words, the 24 corrosion has not only happened after the orifice, but 25 it happens prior to the orifice as well.
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1709 1 In other words, the flow pattern is such 2 that you can expect, even if you didn't'have any, say, 3 high turbulence right ahead of the orifice as well as 4 after the orifice. And that has been observed not 5 just in this but with -- you know, in other systems as 6 well.
7 JUDGE REED: Okay. I take your point.
8 But I would like to ask Dr. Horowitz, did you think 9 this particular chart -- do you have it in front of 10 you? Does it have any relevance or applicability to 11 flow accelerated corrosion where we do them with 12 carbon steels and we don't have sand hopefully in 13 other reactor systems?
14 DR. HOROWITZ: I don't see the relevance 15 to flow accelerated corrosion.
16 JUDGE WARDWELL: What's your indication 17 that it doesn't have the same type of relationship?
18 DR. HOROWITZ: Well, Dr. Hausler is 19 correct you have flow pattern disturbance upstream of 20 the orifice. But, with direct flow missing, it's a 21 different mechanism. It's primarily erosion or some 22 particle erosion. And I don't think there is anybody 23 who is going to argue that if you had a geometry like 24 this, or any arbitrary geometry where the diameter is 25 changing, that the corrosion rate would vary along the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1710 1 top.
2 JUDGE WARDWELL: So you think it's more a 3 function of the geometry than it is the fact that this 4 is dealing with the mechanical erosion primarily as 5 opposed to a chemical erosion factor.
6 DR. HOROWITZ: Yes. I mean -
7 JUDGE WARDWELL: It really influences the 8 geometry. If you put pure water through it, you know, 9 you're able to measure the flow accelerated corrosion 10 associated with this -- not pure water, but the 11 reactor-type water, that would have the appropriate 12 chemicals to cause the melting of that, so flow 13 accelerated corrosion. That you might very well see 14 the effects downstream and initially upstream similar 15 to what has happened here for mechanical, but that you
- 16. don't have orifices like this in a plant.
17 DR. HOROWITZ: Not normally. You only see 18 this with carbon steel.
19 JUDGE WARDWELL: Thank you. I think 20 that's it. I'm done.
21 JUDGE KARLIN: okay. I thank you. We 22 have completed our initial questions of the witness 23 panel on Contention Number 4. We will now take a 24 break, at which time we will go through our notes and 25 try to assess whether we may have some other questions NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1711 1 we Missed or want to ask.
2 We ask the parties to give us this -
3 their suggestions, if any. We are not encouraging it, 4 If you don't have any, that's fine, too. And maybe we 5 should take a break for, well, 20 minutes let's try.
6 JUDGE WARDWELL: Why don't we take a two-7 phase break. We will -7you know, have them get it 8 into us by a certain time, and then give us that much 9 more extra time, because we always seem to go longer 10 every time we did this so far.
11 JUDGE KARLIN: Right. Right. I want 12 to --
13 JUDGE WARDWELL: We need at least 15 14 minutes to review all of it.
15 JUDGE KARLIN: Yes. I think we will ask 16 for you to get them to us in 10 minutes. Would that 17 be feasible? Entergy, are you okay with that? I 18 mean, maybe you've been working on them all along? I 19 don't know.
20 JUDGE WARDWELL: Knowing how busy you've 21 been at the various tables, I assume that there may 22 have been times --
23 JUDGE KARLIN: Try to get them to us in 10 24 or 15 minutes, and then we will let you know how much 25 more time it looks like it will take us to study them.
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1712 1 We will stand adjourned now.
2 (Whereupon, the proceedings in the 3 foregoing matter went off the record at 4 3:50 p.m. and went back on the record at 5 4:31 p.m.)
6 JUDGE KARLIN: We will go back on the 7 record.
8 We are now at the finale of asking 9 questions with regard to contention #4. We have 10 received proposed written questions from Entergy, the 11 New England Coalition, the State of New Hampshire, and 12 from the staff, and we have thought about other 13 questions we might want to follow up with.
14 And I think Judge Wardwell will -
15 JUDGE WARDELL: Leap into the breach.
16 First the question for Entergy, we heard 17 from Dr. Horowitz that - and as I think is outlined in 18 NSAC-202L that CHECWORKS isn't good for pipelines 19 under two inches.
20 Does NSAC-202L provide inspection 21 recommendations for pipelines less than two inches in 22 diameter, Mr. Fitzpatrick?
23 MR. FITZPATRICK: Yes. NSAC-202L has a 24 recommendation for small bore pipes.
25 JUDGE WARDELL: So that's specified within NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1713 1 here, what that program should be?
2 MR. FITZPATRICK: Yes.
3 JUDGE WARDELL: In a more general sense you 4 have been testifying here, are you currently an 5 employee of Vermont Yankee?
6 MR. FITZPATRICK: No, I left there in 7 March.
8 JUDGE WARDELL: Are you an employee of 9 Entergy?
10 MR. FITZPATRICK: No.
11 JUDGE WARDELL: I remember at one point you 12 did use the phrase, we, and I think you have been 13 representing Entergy here.
14 Have you been authorized to make 15 statements on their behalf? And authorized to express 16 what that company intends to do?
17 MR. FITZPATRICK: I believe so.
18 JUDGE KARLIN: Have you been authorized to 19 commit - you say, we are going to do this. We are 20 going to do that. Does that mean you are authorized 21 to commit here under oath that Entergy is going to do 22 those things for the period of extended operation?
23 MR. FITZPATRICK: Entergy has already 24 committed to do those things, by the licensing 25 process.
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1714 1 JUDGE KARLIN: -Okay, so there is some - we 2 are not going to get into that again.
3 (Laughter) 4 JUDGE WARDELL: We don't have half a day 5 left here.
6 Dr. Horow.'itz, how often do you recommend 7 a plan update CHECWORKS for optimal use?
8 DR. HOROWITZ: I personally recommend after 9 every outage NSAC-202L is a little slippery on the 10 subject, it's when convenient, whatever that means.
11 JUDGE WARDELL: I'm sorry?
12 DR. HOROWITZ: Something to the effect that 13 it is recommended to be done when convenient without 14 really defining what that means.
15 JUDGE WARDELL: But what do you f eel in 16 your professional opinion should be done?
17 DR. HOROWITZ: After every outage.
18 JUDGE WARDELL: And how soon? Personally.
19 Professionally and personally?
20 DR. HOROWITZ: Probably within 60 to 90 21 days.
22 JUDGE WARDELL: Within what? I'm sorry.
23 DR. HOROWITZ: Sixty to 90 days.
24 JUDGE WARDELL: Thank you.
25 Mr. Fitzpatrick, I think you had two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1715 1 different answers in regards to why the model wasn't 2 updated, what the inspection data wasn't incorporated 3 until close to the next refueling cycle.
4 You first said that you used the criteria 5 that if the inspection didn't show wear, then you used 6 the criteria of resource availability, or at least the 7 excuse rather than the criteria.
8 Which is it in regards to updating the 9 model?
10 MR. FITZPATRICK: Not updating the model is 11 resource availability. The only resource 12 availability, the model should be updated every cycle.
13 I wrote CRS because we were updating the 14 model, and identifying the management for the resource 15 - to get resources.
16 JUDGE WARDELL: So you wrote correction 17 action?
18 MR. FITZPATRICK: Correction action, yes.
19 JUDGE WARDELL: For what now?
20 MR. FITZPATRICK: Identifying when we 21 hadn't updated a model at two different points in 22 time.
23 JUDGE WARDELL: Within that refueling 24 period?
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1716 1 different outages.
2 JUDG E WARDELL: Oh, okay. How soon do you 3 write thosqe?
4 MR. FITZPATRICK: When we start to realize 5 -or you know when we know we are getting along on the 6 time to do an updated model.
7 JUDGE WARDELL: Do you remember when you 8 did write them specifically for these two instances?
9 MR. FITZPATRICK: 2005, and 2006.
10 JUDGE WARDELL: For the inspections that 11 took place when?
12 MR. FITZPATRICK: Well, that was for the 13 models for inspections, 2004, 2005.
14 JUDGE WARDELL: So within the next year, it 15 hadn't occurred within how many months about then? Do 16 you think you wrote these?
17 MR. FITZPATRICK: I know the dates I wrote 18 them. The last one was written August, 2006.
19 JUDGE WARDELL: For an inspection that was 20 taken when?
21 MR. FITZPATRICK: Spring or fall, 2005.
22 JUDGE WARDELL: Well, big difference.
23 MR. FITZPATRICK: it does make a 24 difference. Fall of 2000, in the outage, spring.
25 JUDGE WARDELL: That's sufficient.
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1717 I At Vermont Yankee do you have any 2 instances of a pipe burst for which you have 3 correlated your data. Did the model predict it?
4 MR. FITZPATRICK: Pipe burst?
5 JUDGE WARDELL: Yeah, or-failure.
6 MR. FITZPATRICK: The CHECWORKS model? No.
7 JUDGE WARDELL: Let's refer back to UW-07.
8 (Pause) 9 JUDGE KARLIN: While we're waiting maybe I 10 could ask that same question of Dr. Horowitz, which 11 is, I think, has there been a pipe burst against which 12 you have correlated your data? And did your model 13 predict it, CHECWORKS? Ever?
14 DR. HOROWITZ: I think the answer is no.
15 JUDGE KARLIN: So there has never been a 16 pipe burst against which - at a facility that was 17 using CHECWORKS?
18 DR. HOROWITZ: That's correct. That's a 19 little of - are you using CHECWORKS?
20 JUDGE KARLIN: Yes.
21 DR. HOROWITZ: Say it that way, I would say 22 Ft. Calhoun and 99, excuse me, not Ft. Calhoun, 23 Callaway and 99.
24 JUDGE KARLIN: All right, and so that was 25 a facility that was using CHECWORKS or its NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1718 1 predecessor, and there was a pipe burst, yes?
2 DR. HOROWITZ: Yes.
3 JUDGE KARLIN: And did your model predict 4 it?
5 DR. HOROWITZ: No, not for that one.
6 JUDGE KARLIN: Why not?
DR. HOROWITZ: The conditions at Callaway 8 were very unusual compared to typical conditions 9 around the nuclear plants. There are only two plants 10 having similar lines. And that one failed, the sister 11 locations at Callaway and Wolf Creek, the sister 12 plant, some showed damage and some did not show 13 damage.
14 And so it seemed to be a case where the 15 flow regime was different enough that there was a 16 variability between locations.
17 JUDGE KARLIN: All right, thank you.
18 JUDGE WARDELL: Let me ask this, then.
19 Under UW-07, at page NEC 038428, the bottom row talks 20 about pipe replacements, unplanned and during cycle 21 errata.
22 What is that related to?
23 MR. FITZPATRICK: This is a standard form 24 that the program engineers fill out. It's an 25 assessment form, and this is the criteria they use.
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.1719 1 If your unplanned replacements, and you are finding 2 unexpected wear, or you have a leak and you have to do 3 a repair, you indicate the number - the number on the 4 chart, and that ranks you where you are, if you have -
5 -. this is a criteria for high. If you have zero or 6 three-7 JUDGE WARDELL: Am I reading this correctly 8 that there was an unplanned pipe or component 9 replacement due to current outage finding?
10 MR. FITZPATRICK: I think there is a 11 mistake there, sir. It should be a zero. The note 12 says no outage this quarter, no unplanned piping 13 replacements in the operating cycle. Arid I wrote that 14 note on the leak on the small bore SSO low point gray 15 line. That should be one, not two.
16 JUDGE WARDELL: Why is that one and not 17 two? Because you have done a replacement? You mean 18 it's a white criteria as opposed to a red?
19 MR. FITZPATRICK: Red would be more than 20 two. We identified one component.
21 JUDGE WARDELL: Oh, I see. I understand 22 now.
23 MR. FITZPATRICK: And that work order was 24 written about the same time.
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1720 1 may not be a rupture, but it's a leak, isn't it?
2 MR. FITZPATRICK: It's a leak in a small-3 bore drain line through the elbow that connects the 4 condenser, operates at 4 psi, and one end is tracking 5 the other.
6 JUDGE WARDELL: And it is part of the FAC?
7 MR. FITZPATRICK: The concluding FAC 8 program and the small-bore product, yes, sir.
9 JUDGE WARDELL: And so, and so the NSAC 10 procedure that you followed for less than 2-inch 11 diameter pipes didn't work in this instance?
12 MR. FITZPATRICK: Didn't work? I wouldn't 13 characterize it like that There was a leak in the 14 pipe. We had inspected for the condenser. We hadn't 15 inspected up at the other end of the pipe yet.
16 It was prioritized low because of the low 17 pressure and low consequence.
18 JUDGE WARDELL: And it was replaced during 19 this outage?
20 MR. FITZPATRICK: Yes it was replaced.
21 JUDGE WARDELL: Has the staff, EPRI, or any 22 other auditing group or peer review ever indicated any 23 weaknesses in the facts or potential for improvements 24 in your current fact program.
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1721 1 program?
2 JUDGE WARDELL: Yes.
3 MR. FITZPATRICK: No,. I think the program 4 is put together in the past two or three years, the 5 NNTC procedure, the EN procedure, was implemented 6 March, 2006.
7 JUDGE WARDELL: So at least in the last two 8 years the current backed program hasn't been audited 9 by anyone?
10 MR. FITZPATRICK: Other than a Q/A with 11 implementation audit at one of the sites. It's used 12 at all the Entergy sites, not at BY there wasn't.
13 JUDGE WARDELL: Did you have a FAC program 14 prior to the power uprate?
15 MR. FITZPATRICK: Yes.
16 JUDGE WARDELL: And was that ever indicated 17 to have any weaknesses by an audit from either staff, 18 EPRI, or any other -
19 MR. FITZPATRICK: Yes, an EPRI assessment 20 in '99, they gave recommendations. We've had NFC 21 audits, an NFC audit of 2005 prior to the power 22 uprate. They spent a week looking into programs.
23 And their recommendation was, get the - they were 24 really concerned about getting CHECWORKS models 25 completed on time. EPRI and NRC feels the predictive
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f1722 1 elements of the program are important and should be 2 used the way it's recommended it be used. And that's 3 why we wrote- a CR.
4 JUDGE WARDELL: Thank you.
5 Staff, is that consistent with your 6 understanding of the audits and comments that have 7 been made with regard to the past FAC programs at 8 Vermont Yankee?
9 MR. ROWLEY: It's my understanding that 10 that was done for power uprates, that they essentially 11 look at the program.
12 JUDGE WARDELL: And do you know of any 13 other audits or comments from either EPRI or yourself 14 that have critiqued the previous FAC?
15 MR. ROWLEY: Mr. Horowitz himself did a 16 critique -
17 JUDGE WARDELL: Sorry?
18 MR. ROWLEY: Mr. Horowitz himself had did 19 a critique of their program not too long ago in the 20 past three or four years.
21 JUDGE WARDELL: Of the items identified 22 that were questionable, did Mr. Fitzpatrick 23 characterize the ones that you are familiar with?
24 MR. ROWLEY: Repeat. I'm not sure I 25 understand the question.
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1723 I JUDGE WARDELL: Well, he identified some 2 deficiencies that were noted in a previous audit from 3 either yourselves, EPRI, or some other auditing 4 organization in his previous program that they have 5 rectified in regards to their current program, and 6 their current program hasn't received any yet.
7 Now is that your understanding?
8 MR. ROWLEY: I understand that during the 9 power uprate proceedings was the last time NRC has 10 looked at it - looked at it for licensing only.
11 JUDGE WARDELL: Mr. Fitzpatrick, would you 12 like to elaborate?
13 MR. FITZPATRICK: As part of the license 14 renewal audits, Region One came in. They looked at 15 the program definitions, and reviewed the application.
16 Region One came in in either spring - it was either 17 January, February, March time, of 2007, looked at 18 programs for implementation. They looked at our 19 program procedures, and see if we were doing what we 20 committed to do.
21 JUDGE WARDELL: Thank you 22 JUDGE KARLIN: They came in and did a 23 review of your procedures and see if you were doing 24 what you were supposed to do?
25 MR. FITZPATRICK: Show me an example of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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172-4 1 this, show me an example -
2 JUDGE KARLIN: What did they-find?
3 MR. FITZPATRICK: No significant findings, 4 I believe. They determined that reasonable assurance 5 that the program is being carried out as designed or-.
6 written.
7 JUDGE KARLIN: Is that document in the 8 record here, do you know?
9 DR. HOROWITZ: That was a regional 10 inspection report issued in June that documents that.
11 That is not referenced in our. license renewal 12 application, but it was done. It is part of one of 13 the things that has to be done in order for an 14 applicant to go through an license renewal process, 15 separate from our safety evaluation report. But the 16 inspection report, the regional team comes in and does 17 their on-site inspection. They write a separate 18 report and gets to that issue, which was done in June 19 of -
20 JUDGE KARLIN: June of 2008?
21 DR. HOROWITZ: 2007.
22 JUDGE KARLIN: Okay. And clo you agree 23 with Mr. Fitzpatrick?
24 DR. HOROWITZ: My reading of that report, 25 it does state no significant issues.
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1725 1 JUDGE KARLIN: No significant issues? All 2 right.
3 JUDGE WARDELL: Dr. Horowitz, in 2005 the 4 Maihama Nuclear Plant - did I pronounce that right, 5 Japan?
6 DR. HOROWITZ: I think it was 2004 when 7 Maihama was burned.
8 JUDGE WARDELL: Okay, and it had a pipe 9 rupture; is that correct?
10 DR. HOROWITZ: Yes, sir.
11 JUDGE WARDELL: And it was in a downstream 12 of a small pipe wall orifice; is that correct? Was 13 that an FAC phenomena, or was it some other phenomena?
14 DR. HOROWITZ: FAC clearly.
15 JUDGE WARDELL: In your professional 16 opinion do you believe, or have you done any fact-17 fitting analysis of that that would demonstrate that 18 CHECWORKS would have predicted this thing?
19 DR. HOROWITZ: I did not. We never found 20 out from the utility what the water chemistry 21 conditions were. EDF did an analysis with their code, 22 and they predicted - would have predicted the failure.
23 The fact of the matter is, is that any 24 experienced FAC engineer would have inspected that 25 location because it was an obvious location for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1726 1 failure downstream of the main flow measuring.
- 2. JUDGE WARDELL: Do you have any idea what 3 besides the fact that they should have caught it with 4 an inspection, did they have any other program that 5 they were using to assist them in highlighting 6 locations that might be critical in their inspection 7 programs?
8 DR. HOROWITZ: No, sir, they had no 9 analytical program, and that's true for the state.
10 Their philosophy had been to inspect, and divulge 11 instructions.
12 JUDGE WARDELL: Thank you. That's all I 13 have.
- 14. JUDGE KARLIN: Okay, I think we have asked 15 all our questions, with regard to contention #4.
16 So we are ready I think to conclude the 17 proceeding. And happily we may be able to finish with 18 some - with five minutes to spare.
19 No, we are not finished yet unfortunately.
20 But we are finished with the witness panel.
21 So I want to thank you all for your time 22 and effort. I know that many of you come from some 23 distance to be here. A lot of time' and expense 24 involved in all of the witnesses being here and being 25 prepared.
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1727 1 So thank you, gentlemen, for your 2 testimony and your patience with our questioning.
3 1 think what we need to do before we close 4 is, I have at least four things that I want to talk 5 -about, and I also want to elicit from the counsel if 6 there is anything else they think we should cover.
7 First I want to talk about transcript 8 corrections, the mechanics of that, make sure we get 9 the dates and the mechanics down.
10 Second, closing the record, we'll have to 11 do that.
12 Third, we are thinking about, we want to 13 reserve a date for an oral argument with regard to the 14 two issues that were briefed in July by the parties.
15 We may or may not need that oral argument. Quite 16 frankly we have not finished reviewing those briefs.
17 We spent a lot of time reading the materials, and we 18 want to continue to do that.
19 But we want to reserve a date as a hold 20 date for an oral argument sometime relatively soon.
21 And fourth, we want to talk about - a 22 little bit about the proposed findings of fact and 23 conclusions of law that are going to be due in 30 24 days, per the initial scheduling order we issued a 25 long time ago.
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1728 1 Is there anything else that any of the 2 parties have at this time?
3 MR. HOFMANN: We have a hearing time 4 reserved in September, and I assume we can take the 5 lock off our schedules on that?
6 JUDGE KARLIN: Definitely, yes. We can 7 dispense with that. Good point.
8 MS. TAYLOR: Judge Karlin, do you know when 9 the transcripts will be available in Adams? NEC is 10 not buying them.
11 JUDGE KARLIN: Well, it's usually a week to 12 10 days. I do not know.
13 MS. TAYLOR: I think if that is the case, 14 I'm wondering if we could extend the deadline for the 15 conclusions of fact and laws to account for the fact 16 that we won't have them for a couple of weeks it 17 sounds like.
18 JUDGE KARLIN: Well, the regulations 19 prescribe a 30-day period with the court and the board 20 having an opportunity to change that. Yes, so we 21 would have the opportunity to change it. If we were 22 going to change it, I'd almost want to accelerate it.
23 I don't think we want to change it.
24 We need to get this matter resolved, and 25 I think the transcripts will be available in seven to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1729 1 10 days.
2 So are there any other matters other than 3 the four I just mentioned?
4 Okay. With regard to transcripts 5 corrections, first subject, transcript corrections, 6 please focus on material type changes and problems.
7 Don't give us a lot of minutiae. We don't need huge 8 long lists of errata.
9 And when you do submit your proposed 10 transcript corrections, we want you to have listened 11 to the tape beforehand, and you need to certify in 12 your transcript correction that you have listened to 13 the tape, and that the corrections you are proposing 14 are based upon what you heard and how it's corrected; 15 not what you think it should have been or might have 16 been or whatever.
17 Now the exceptions for that might be where 18 it's an acronym, or it's a word that is misspelled, or 19 a technical term that the court reporter may not have 20 captured. But if it's anything else, a yes to a no, 21 a did to a didn't, someone better listen. You need to 22 certify that you listened to the tape that the court 23 reporter has, and that's what you counsel, verify you 24 believe is the correct word there.
25 Because we have had situations before in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1730 1 the Vermont Yankee uprate, in fact, where there was a 2 dispute as to the wording. And you know what happens 3 then? We have to listen to the tape. And if there is 4 a dispute, we will have to listen to the tape. So we 5 want you to listen to the tape first, and that will 6 eliminate some disputes.
7 MS. UTTAL: Your Honor, how do we get the 8 tape?
9 JUDGE KARLIN: Well, you contact the court 10 reporter and you get a tape from him.
11 MS. UTTAL: Okay, will do.
12 JUDGE KARLIN: And then before you submit 13 your proposed transcript corrections, you also per the 14 normal motion practice you need to confer with the 15 other parties and see if they agree.
16 And so I think what we'd like to suggest, 17 and what we are going to say, is that all that needs 18 to be done, and the deadline for submitting proposed 19 transcript corrections is August 8, Friday, August 8, 20 16 days I think or so, 15 days from today.
21 So you are going to have to get this stuff 22 pretty fast from the court reporter.
23 DR. HAUSLER: Your Honor?
24 JUDGE KARLIN: Yes. Well, no wait a 25 second, you are not here to speak, sir. We are talking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1731 1 fl about the parties at this point.
2 1 would ask Enterrnj to take the lead in 3 this matter, and to come up with a list that they 4 share with the other parties in terms of transcript 5 corrections.
6 And others of you, obviously anyone else 7 can take a laboring oar as well. But I think if 8 Entergy would-take the lead, on the 1 6 1h -on August 9 8t please submit your - confer with your other 10 parties and on August 13 submit your proposed 11 transcript corrections to us.
12 So by the 8 "h you need to exchange them 13 among yourselves; by the 13 "h submit them to us; five 14 days later, on the 18 "h, you have - anyone who doesn't 15 like those corrections, if there are still some 16 residual problems with those corrections, they have 17 until the 1 8 "h of August to submit this - to submit 18 their objections.
19 With regard to closing the record, the 20 record will be closed - well, it's essentially closed 21 now. We are obviously not going to take any more 22 testimony; any more written exhibits.
23 But on the 1 3 "h of August is when the 24 errata or corrections come in, and at that point the 25 only thing that will change with regard to the record NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1732 1 or any - we will accept any changes due to the 2 erratas, and. we have an issue with regard to the 3 Commonwealth of -Massachusetts, who have this appeal in 4 the 1" Circuit, and there is an order out there that 5 we can't close the records entirely.
6 . But we are closing the record with regard 7 to everything of these contentions. And there is. this 8 technical hold that is there because of the 1"~
9 Circuit's decision for their issue.
10 Yes.
11 MR. LEWIS: Judge Karlin?
12 JUDGE KARLIN: Yes.
13 M.LEWIS: For clarification purposes, in 14 the Pilgrim proceeding, that did not prevent -the 15 closure of the record. The mandate in that case has 16 since issued,, and therefore -the 1 "t Circuit's 17 administrative stay has also lapsed.
18 JUDGE KARLIN: Okay. Well, that's helpful; 19 I will review that. Let me review that.
20 I did read the decision with regard to 21 Pilgrim case. I'm not sure, I'll have to read it 22 again, I'm not sure where that goes. We will hold 23 that in abeyance. I just don't want to foreclose Ms.
24 Curran and the State. of Massachusetts from whatever 25 thing they may have.
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1733 1 If their time is expired, I will probably 2 - we are going to dispense - everything that has been 3 litigated here is shut down and closed. If there is 4 some footnote that is going on with Massachusetts, or 5 something that happens in the l%* Circuit, obviously 6 we are not going to try to foreclose that.
7 I just wanted to recognize that as a 8 footnote to the closing of the record, and I will look 9 at that.
10 MR. RAUBVOGEL: Judge Karlin?
11 JUDGE KARLIN: Yes, sir.
12 MR. RAUBVOGEL: I'm sorry to go backwards, 13 but just to go for a second on the question of the 14 transcript, as I understand what you just said, the 15 corrections on the transcript I think you said are due 16 within 16 days.
17 JUDGE KARLIN: August 8 *h No, no, they 18 are due to - what you do is submit them to each other; 19 exchange them; and then on the 13 "h of August you can 20 submit them to us.
21 MR. RAUBVOGEL: My point was going to be 22 that as my co-counsel mentioned, our client doesn't 23 have the resources to buy the transcript so we have to 24 wait until they are posted.
25 So I would ask if you can do two things.
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1734 1 One is if you can find out whether an expedited 2 transcript can be ordered from the stenographer so 3 that it gets in the hands of the staff as soon as 4 possible; and then to ask that the staff post it 5 immediately so-that there is no question that we are 6 going to get it as soon as we can.
7 Otherwise it's possible that NEC may not 8 have an opportunity, really, a meaningful opportunity 9 to review that transcript.
10 MS. BATY: Just for the record, we don't -
11 we staff don't post it. It's the FOB that is 12 responsible for doing it exactly with the additive.
13 JUDGE KARLIN: Well, I'm not even sure 14 whether he has LDP posted quite frankly. We turned 15 SECY, the people over at the Secretary's office post 16 it.
17 I noted on my email last night I already 18 had the transcript for Monday, but that's because 19 that's the contract, a three-day turn-around.
20 And I will instruct Mr. Emile Julian, or 21 whoever else there is, that we get this thing posted 22 as soon as humanly possible, expedited, and we will 23 try to give a report to everybody on that.
24 And if I find that it is going to be 25 significantly delayed or a problem, well, we will try NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1735 1 to deal with that.
2 But we will try to get it as expedited as 3 humanly possible.
4 MR. RAUBVOGEL: Thank you.
5 JUDGE KARLIN: Oral argument: I guess we 6 can go to that. We think maybe a two-hour oral 7 argument, if we are going to have one, it's not going 8 to be long. It would involve the four parties who 9 have briefed this issue, or the three parties and the 10 State of Vermont if they wish.
11 I think they - I would say three - two to 12 three hours at most. I would like - and we are 13 proposing to have that on the morning of August 7 "'.
14 Would counsel look at - now I would note 15 that every party here has got multiple counsel, so 16 there has got to be somebody who is going to be 17 available on August 7'. or one of these days at 9:00 18 a.m.
19 We would probably have it in Rockville, in 20 our hearing room in Rockville. Anyone who wanted to 21 could participate by telephonic connection, so you 22 could save money or avoid travel.
23 August 7'h at 9:00 a.m. Mr. Lewis, are 24 you available?
25 MR. LEWIS: August 7 th, yes.
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1736 1 JUDGE KARLIN: NRC staff?
2 MS. BATY: Yes. I have jury duty, but 3 someone - one of us will be available.
4 JUDGE KARLIN: Okay, and Ms. Tyler?
5 MS. TYLER: Yes, I'm available.
6 JUDGE KARLIN: Great. Ms. Hoffman, Mr.
7 Roisman.
8 MS. HOFMAN: Mr. Roisman is available.
9 JUDGE KARLIN: Great. All right, then we 10 will schedule - well, we will tentatively schedule 11 oral argument for Thursday, August 7 h, at 9:00 a.m.
12 We will let you know whether we are really going to 13 proceed with that.
14 I mean if we get done reading and we don't 15 have - don't think we need it, we won't - we will 16 cancel it, okay? But it's a go unless we cancel; 17 that's probably they way to put that.
18 MR. ROTH: Judge Karlin?
19 JUDGE KARLIN: Yes.
20 MR. ROTH: We briefed that matter at hand 21 in federal argument, and I don't intend to ask for the 22 right to appear and argue. But I would like to be 23 able to listen in telephonically. Would that be 24 possible?
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1737 1 participate by phone, listen in telephonically.
2 MR. ROTH: Thank you.
3 JUDGE KARLIN: And Ms. Curran from the 4 State of Massachusetts can sit in too if she wants, 5 but she is not here.
6 JUDGE WARDELL: Mr. Lewis, do you plan on 7 being there in person?
8 MR. LEWIS: It would be my plan, yes.
9 JUDGE WARDELL: So the staff will be here 10 in person?
11 JUDGE KARLIN: Okay. All right, I think -
12 is that it? I think that covers it.
13 Before we close I would just like to 14 thank, express some appreciation first to the parties.
15 They spent an enormous amount of time and effort 16 preparing, marshaling evidence and presenting it in 17 the prehearing filings while the piles of which -. this 18 is just one pile for one contention, and we have three 19 piles and more. So obviously, a tremendous amount of 20 work.
21 The witnesses, long hot days, patient 22 explanations and answers to our not always 23 sophisticated questions, certainly from me anyway, I 24 would take that.
25 I would also thank, in addition to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1738 1 witnesses and the parties, the lawyers who usually 2 play a large role in a hearing, in a trial; in this 3 case they had to bite their tongues and all sit 4 quietly, and they did a tremendous job in being calm 5 and collected through this long process. I don't know 6 how you did it.
7 JUDGE WARDELL: And hardly dozed.
8 JUDGE KARLIN: Yeah. We would also thank 9 the courtroom here, Mr. Robinson, and the sheriff of 10 the county, and the judges who have this courtroom in 11 making it available. It was warm, but it's a 12 beautiful courtroom, and we like it.
13 I want to express thanks to Karen Valloch 14 of our staff, and our two law clerks, Marcia 15 Carpentier and Lauren Bregman.
16 Finally, I would also express thanks to 17 the concerned citizens of Vermont. I don't know the 18 people who came in here on the first day, and there 19 were a tremendous number of people, standing room 20 only; a number of dedicated and hearty souls who 21 stayed through the entire proceeding, and who have 22 kept a vigil, and kept an eye on us through the whole 23 thing. And we know that, and we appreciate that. I 24 don't know whether they are pro, I don't know whether 25 they are con. But we take seriously our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1739 1 responsibility, and I appreciate them being here, and 2 observing, because this is a public process, and we 3 appreciate that we are able to conduct this in a 4 peaceable way and to get through a lot of material, so 5 that was good.
6 Where do we go from here? We are not 7 going to decide this case today obviously. In 30 days 8 there will be proposed findings of fact and 9 conclusions of law.
10 Ah, I want to just speak to that if I 11 could. I forgot to really talk about that.
12 When you do your proposed findings of fact 13 and conclusions of law, please, this is to help us try 14 to help us develop a decision and write our decision.
15 And if you want us to rule in your favor, then you 16 probably want to write it in a way that helps us, and 17 I think all the lawyers know that.
18 Cite the transcript pages, if you say 19 somebody made a statement, and cite the names of the 20 witnesses who made the statement. Don't just say, the 21 staff testified X. There are a lot of staff people 22 who have been involved here, and maybe one witness -
23 we want to know the names of the witnesses who 24 testified; we want to know the exhibits, and cite them 25 and cite the pages of the exhibits because some of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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.1740 1 these are hundreds of pages long, and we want to know 2 specifically what page, because we - because that's 3 how we are going to try to cite it when we - if we are 4 writing it, and that's how we are going to cite the 5 transcript.
6 And when you cite the law, one thing that 7 is sort of a nuance that you might not be familiar 8 with, when you cite the NRC :case law, like 60 NRC at 9 235, cite the. LBP number or the CLI not number but 10 letters, because that makes a big difference. LBP 11 means it's a licensing board; and CLI means it's a 12 commission decision. And commission decisions, if 13 they are relevant and on point and it's a holding, 14 they are binding on us. And if it's a board decision, 15 like some other board, where just like another trial 16 court, and they are helpful, could be helpful, but 17 they are not binding. So it would be very helpful if 18 you could have that.
19 So 30 days from now we will get the 20 proposed finding of fact, conclusions of law, and 21 under the regs, basically, we shoot to get the 22 decision out 90 days after that. So 120 days from 23 today, and we are going to try to make that. There is 24 a lot of material; there are three big contentions.
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- 1741 1 you for your attention and patience, and we are now 2 adjourned.
3 (Whereupon at 5:09 p.m. the proceeding in 4 the above-entitled matter was adjourned) 5 6
7 8
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CERTIFICATE This is to certify that the attached proceedings before the Uni.ted States Nuclear Regulatory Commission in the matter of: Entergy Nuclear Vermont Yankee, LLC & Entergy Nuclear Operations, Inc.
Name of Proceeding: Hearing Docket Number: 50-271-LR, ASLBP No. 06-849-03-LR 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.
-/Toby4 0alte -r Offic ia* Reporter Neal R. Gross & Co., Inc.
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com