ML12088A520

Entergy Pre-Filed Hearing Exhibit ENT000091, Testimony of Applicant Witnesses Roger Rucker, Steven Dobbs, John Craig, and Thomas Mccaffrey Regarding Contention NYS-8 (Electrical Transformers)

ML12088A520
Person / Time
Site:	Indian Point
Issue date:	03/28/2012
From:	Bessette P, Dennis W, Glew W, O'Neill M, Sutton K Entergy Nuclear Operations, Morgan, Morgan, Lewis & Bockius, LLP
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML12088A518	List: ML12088A519 ML12088A520
References
RAS 22109, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12088A520 (113)

Text

ENT000091 Submitted: March 28, 2012 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of ) Docket Nos. 50-247-LR and 50-286-LR

)

ENTERGY NUCLEAR OPERATIONS, INC. ) ASLBP No. 07-858-03-LR-BD01

)

(Indian Point Nuclear Generating Units 2 and 3) )

) March 28, 2012 TESTIMONY OF APPLICANT WITNESSES ROGER RUCKER, STEVEN DOBBS, JOHN CRAIG, AND THOMAS MCCAFFREY REGARDING CONTENTION NYS-8 (ELECTRICAL TRANSFORMERS)

William B. Glew, Jr., Esq. Kathryn M. Sutton, Esq.

William C. Dennis, Esq. Paul M. Bessette, Esq.

ENTERGY NUCLEAR OPERATIONS, INC. Martin J. ONeill, Esq.

440 Hamilton Avenue MORGAN, LEWIS & BOCKIUS LLP White Plains, NY 10601 1111 Pennsylvania Avenue, NW Phone: (914) 272-3202 Washington, DC 20004 Fax: (914) 272-3205 Phone: (202) 739-3000 E-mail: wglew@entergy.com Fax: (202) 739-3001 E-mail: wdennis@entergy.com E-mail: ksutton@morganlewis.com E-mail: pbessette@morganlewis.com E-mail: martin.oneill@morganlewis.com COUNSEL FOR ENTERGY NUCLEAR OPERATIONS, INC.

TABLE OF CONTENTS Page I. WITNESS BACKGROUND ............................................................................................. 1 A. Roger B. Rucker (RBR) ..................................................................................... 1 B. Steven E. Dobbs (SED) ...................................................................................... 3 C. John W. Craig (JWC) ......................................................................................... 4 D. Thomas S. McCaffrey (TSM) ............................................................................ 5 II. OVERVIEW OF CONTENTION NYS-8 ......................................................................... 6 III.

SUMMARY

OF TESTIMONY AND CONCLUSIONS ................................................ 10 IV. OVERVIEW OF APPLICABLE PART 54 REQUIREMENTS AND GUIDANCE ..................................................................................................................... 14 A. Applicable Part 54 Requirements ........................................................................ 14 B. Relevant NRC and Industry Guidance ................................................................. 18 C. Commission Guidance Implementing the License Renewal Rule: The Statements of Consideration for the 1995 Revisions to Part 54 .......................... 21 V. ENTERGYS COMPLIANCE WITH PART 54 REQUIREMENTS AND GUIDANCE APPLICABLE TO ELECTRICAL TRANSFORMERS ........................... 25 A. The Scoping Process as Applied to IPEC Transformers ..................................... 25 B. The Screening Process as Applied to IPEC Transformers................................... 25 VI. TECHNICAL BASIS FOR EXCLUSION OF TRANSFORMERS FROM AMR UNDER 10 C.F.R. PART 54 ........................................................................................... 26 A. Basic Theory of Transformer Operation .............................................................. 26 B. Discussion of Transformer Properties ................................................................. 30 VII. COMPARISON OF TRANSFORMERS TO COMPONENTS LISTED IN 10 C.F.R. § 54.21(A)(1)(i) .................................................................................................... 37 VIII. REBUTTAL TO NYSS CLAIM THAT TRANSFORMERS ARE PASSIVE DEVICES SUBJECT TO PART 54 AGING MANAGEMENT REVIEW .................... 49 A. The Definitions of Static and Passive Relied on By NYS Are Not Applicable to the Classification of Components Under 10 C.F.R.

§54.21(a)(1) ......................................................................................................... 49 B. Dr. Degeneffs Claim That Voltage, Current, and Magnetic Field Are Not Properties of a Transformer Lacks a Technical Foundation ................................ 54 C. Dr. Degeneffs Comparisons of Transformers to AMR-Included Components Are Technically Flawed and Unreliable ......................................... 65

1. Electric Cables ......................................................................................... 65

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TABLE OF CONTENTS Page

2. Pipes ......................................................................................................... 69

3. Heat Exchangers, Steam Generators, Reactor Vessel, and Containment ............................................................................................. 72 D. Dr. Degeneffs Attempts to Distinguish Transformers from Other AMR-Excluded Components Are Technically Flawed and Unreliable ......................... 73

1. Transistors ................................................................................................ 73

2. Batteries ................................................................................................... 80

3. Power Inverters ........................................................................................ 81

4. Power Supplies......................................................................................... 82 IX. REBUTTAL TO NYSS CLAIM THAT PART 54 REQUIRES AN AGING MANAGEMENT PROGRAM FOR IPEC TRANSFORMERS..................................... 86 A. Transformer Operation and Performance Are Governed by 10 C.F.R. Part 50 Requirements and Ongoing NRC Regulatory Oversight Programs ............... 86 B. Current Performance Monitoring and Preventive Maintenance Programs at Indian Point Are Adequate to Manage the Effects of Aging on the Functionality of Safety-Related Transformers..................................................... 96 X. CONCLUSIONS............................................................................................................ 108

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of ) Docket Nos. 50-247-LR and 50-286-LR

)

ENTERGY NUCLEAR OPERATIONS, INC. ) ASLBP No. 07-858-03-LR-BD01

)

(Indian Point Nuclear Generating Units 2 and 3) )

) March 28, 2012 TESTIMONY OF APPLICANT WITNESSES ROGER RUCKER, STEVEN DOBBS, JOHN CRAIG, AND THOMAS MCCAFFREY REGARDING CONTENTION NYS-8 (ELECTRICAL TRANSFORMERS)

I. WITNESS BACKGROUND A. Roger B. Rucker (RBR)

Q1. Please state your full name.

A1. (RBR) My name is Roger B. Rucker.

Q2. By whom are you employed and what is your position?

A2. (RBR) I am a self-employed Engineering Consultant with Rucker Nuclear Consultants, Inc. in Russellville, Arkansas. My consulting work focuses on electrical and instrumentation and control (I&C) applications in nuclear power plants, particularly as they relate to nuclear power plant operating license renewal. In this capacity, I provide technical services to Entergy Nuclear Operations, Inc.s (Entergy) License Renewal Services Division at its Arkansas Nuclear One office. I am the License Renewal Electrical Lead for a number of Entergy nuclear power plant license renewal projects, including Entergys project to renew the operating licenses for Indian Point Nuclear Generating Units 2 and 3 (IP2 and IP3), also known as Indian Point Energy Center (IPEC).

Q3. Please describe your professional qualifications, including relevant professional activities.

A3. (RBR) My qualifications are described in the attached curriculum vitae (ENT000092). In brief, I have over 22 years of work experience, most of which has been in the nuclear power industry. I hold a Bachelor of Science degree in Electrical Engineering from the University of Arkansas. I am a licensed Professional Engineer (P.E.) in the State of Arkansas. I am the Entergy representative for the Nuclear Energy Institute (NEI) License Renewal Electrical Working Group. Previously, I have been a member of NEI, Electric Power Research Institute (EPRI), and Institute of Electrical and Electronics Engineers (IEEE) groups involved with license renewal and aging management activities, such as the NEI Medium Voltage Cable Task Force, the NEI License Renewal Task Force, the EPRI cable users group, and the IEEE Standards Association. I served as principal investigator in the preparation of EPRIs License Renewal Electrical Handbook (referenced and cited below). In addition, I have served as the electrical lead for nine license renewal applications (LRA) and as the project manager for one additional license renewal project.

Q4. Please describe your role with respect to the IPEC LRA.

A4. (RBR) I prepared several documents that support the LRA. Those documents include the electrical aging management review (AMR) report, as well as the electrical portions of the (1) aging management program (AMP) evaluation report, (2) scoping and screening report, and (3) operating experience review reports. I also reviewed the electrical portions of the LRA prior to its submittal, and assisted in preparing responses to NRC audit and inspection questions, NRC requests for additional information (RAIs), and related Entergy amendments to the LRA. In addition, I supported Entergy at the related Advisory Committee on 2

Reactor Safeguards Subcommittee and Full Committee meetings for the IPEC LRA held in March 2009, and September 2009, respectively. Accordingly, I have personal knowledge of the development of the LRA, including the electrical scoping and screening processes described in the LRA and related documentation. I also am familiar with industry guidance documents and Entergy/IPEC procedures relevant to transformers.

B. Steven E. Dobbs (SED)

Q5. Please state your full name.

A5. (SED) My name is Steven E. Dobbs.

Q6. By whom are you employed and what is your position?

A6. (SED) I am a self-employed Engineering Consultant with Dobbs & Associates Engineering, Inc. in Russellville, Arkansas. I provide engineering consulting services with respect to electronics and computer applications, including their use in nuclear power plants. I have been retained by Entergy to provide expert services in connection with the adjudication of contention NYS-8, which relates to electrical transformers.

Q7. Please describe your professional qualifications, including relevant professional activities.

A7. (SED) My qualifications are described in the attached curriculum vitae (ENT000093). In summary, I have over 35 years of work experience, 16 years of which have been in the nuclear power industry. I hold a Bachelor of Science degree in Physics from Arkansas Tech University, a Master of Science degree in Electrophysics from George Washington University, and a Doctor of Philosophy in Electrical Engineering from the University of Arkansas.

I taught in the Engineering Department at Arkansas Tech University from 1977 until 1990. During that time, I taught classes in electrical machinery that covered the theory and 3

operation of transformers, motors, and generators. I also directed the laboratory associated with that class.

From 1990 to 2004, I worked as an electrical engineer at Arkansas Nuclear One, where I provided engineering support for computer and electronic systems throughout the plant. During that time, I worked in the Computer Support, Systems Engineering, and Design Engineering groups and attained the position of Senior Staff Engineer.

Since 2004, I have worked principally as an Engineering Consultant with Dobbs &

Associates Engineering, Inc. on matters involving electronics and computer applications. Since January 2007, much of my consulting work has involved electrical and computer systems at nuclear power plants.

C. John W. Craig (JWC)

Q8. Please state your full name.

A8. (JWC) My name is John W. Craig.

Q9. By whom are you employed and what is your position?

A9. (JWC) I am a Senior Nuclear Safety Consultant working for Talisman International, LLC (Talisman) in Washington, D.C. I have been retained by Entergy to provide expert services in connection with the adjudication of contention NYS-8, which relates to electrical transformers.

Q10. Please describe your professional qualifications, including relevant professional activities.

A10. (JWC) My qualifications are described in the attached curriculum vitae (ENT000094). Briefly, I hold a Bachelor of Science degree in Nuclear Engineering from the University of Maryland. I have over 35 years of experience in nuclear energy and nuclear safety matters, including positions with the NRC and in the U.S. Navys nuclear power program.

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I worked at the NRC from 1976 to 2005 and held numerous technical and management positions. I was the Director of the License Renewal and Environmental Project Directorate responsible for managing license renewal activities in the Office of Nuclear Reactor Regulation (NRR). I was directly responsible for managing NRR license renewal activities, including (1) development and issuance of the initial license renewal rule (i.e., 10 C.F.R. Part 54) and regulatory guidance documents for license renewal, including both the safety and environmental aspects of the rule; (2) review of technical license renewal reports submitted by industry groups; and (3) NRR interactions with the first nuclear plants seeking renewal of their operating licenses.

Subsequently, as Associate Director for Inspection and Programs, NRR, I was responsible for management of NRC inspection and oversight activities for all civilian nuclear power reactors and non-power reactors in the U.S. In this position, my responsibilities encompassed NRRs license renewal program; next-generation reactor designs/facilities; assessment of environmental issues; standard technical specifications, emergency planning, technical evaluations and assessments of operating reactor events; nuclear plant operator licensing; and licensee quality assurance programs. I have been a Senior Nuclear Safety Consultant with Talisman since 2006.

D. Thomas S. McCaffrey (TSM)

Q11. Please state your full name.

A11. (TSM) My name is Thomas S McCaffrey.

Q12. By whom are you employed and what is your position?

A12. (TSM) I am employed by Entergy as the Design Engineering Manager at Indian Point Energy Center. I am responsible for the design engineering staff that maintains the IP2 and IP3 design bases and performs modifications to systems, structures, and components (SSCs) for the station.

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Q13. Please describe your professional qualifications, including relevant professional activities.

A13. (TSM) My qualifications are described in the attached curriculum vitae (ENT000095). In brief, I have approximately 20 years of work experience, most of which has been in the nuclear power industry. I hold a Bachelor of Engineering degree in Electrical Engineering from the State University of New York - Maritime College. I am a licensed Professional Engineer in the State of New York. I worked in Consolidated Edisons Distribution Business before working at IPEC as an electrical system engineer responsible for the stations medium and high-voltage electrical systems. I was subsequently promoted to Electrical/I&C Systems Supervisor (2000-2003) and Systems Manager (2003-2005), and assumed oversight responsibility for numerous engineers involved in all aspects of the IPEC electrical and I&C systems. From 2005 to 2007, I spent 2 years working at the Institute of Nuclear Power Operations (INPO), where I reviewed nuclear power plant equipment performance. I assumed my current position, Design Engineering Manager, in July 2007.

II. OVERVIEW OF CONTENTION NYS-8 Q14. Are you familiar with Contention NYS-8, as originally proposed by NYS?

A14. (RBR, SED, JWC, TSM) Yes. We have reviewed the New York State Notice of Intention to Participate and Petition to Intervene, dated November 30, 2007 (NYS Petition);

the associated declaration of NYSs former consultant, Paul Blanch, dated November 28, 2007 (Nov. 2007 Blanch Declaration); and the New York Reply in Support of Petition to Intervene, dated February 22, 2008 (NYS Reply). NYS alleges that the IPEC LRA is inadequate because it does not include an [AMP] for each electrical transformer whose proper function is important for plant safety. NYS Petition at 103.

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Q15. Are you familiar with Contention NYS-8, as admitted by the Atomic Safety and Licensing Board (Board)?

A15. (RBR, SED, JWC, TSM) Yes. On July 31, 2008, the Board admitted NYS-8 to the extent that it questions the need for an AMP for safety-related electrical transformers that are required for compliance with 10 C.F.R. §§ 50.48 and 50.63. Entergy Nuclear Operations, Inc.

(Indian Point Nuclear Generating Units 2 & 3), LBP-08-13, 68 NRC 43, 89 (2008). 10 C.F.R.

§ 50.48, Fire protection, sets forth the NRCs fire protection requirements for operating nuclear power plants. 10 C.F.R. § 50.63, Loss of all alternating current power, requires operating nuclear power plants to be able to withstand for a specified duration and recover from a station blackout as defined in § 50.2 and specifies other related requirements. 10 C.F.R. § 50.63 (a)(1). Noting that 10 C.F.R. § 54.21(a)(1)(i) lists components that require AMR and also excludes other components that do not require AMR, the Board stated that it will require, inter alia, representations from the parties to help us determine whether transformers are more similar to the included, or to the excluded, component examples. Indian Point, LBP-08-13, 68 NRC at

43. The Board also cited the need for an explanation on how a transformer changes its configuration or properties in performing its functions. Id.

Q16. Have you reviewed any other NYS filings or Board issuances concerning NYS-8? If so, please identify those documents.

A16. (RBR, SED, JWC, TSM) Yes. On August 14, 2009, Entergy filed a Motion for Summary Disposition of NYS-8, in support of which we prepared declarations. We have reviewed the Response of the State of New York to Entergys Summary Disposition Motion and NRC Staffs Supporting Answer, dated September 23, 2009 (NYS Sept. 2009 Response),

including all supporting exhibits and the Declaration of Paul Blanch (Sept. 22, 2009) (Sept.

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2009 Blanch Declaration) (ENT000096). We also have reviewed the Boards Memorandum and Order (Ruling on Motions for Summary Disposition), dated November 3, 2009, in which the Board denied Entergys Motion for Summary Disposition of NYS-8.

Q17. Have you reviewed NYSs initial statement of position, prefiled testimony, and supporting exhibits for NYS-8, as filed in December 2011?

A17. (RBR, SED, JWC, TSM) Yes, we have reviewed the following documents filed by NYS on December 12, 2011: Exhibit NYS000002, New York State Initial Statement of Position, Contention NYS-8 (NYS-8 Statement of Position); Exhibit NYS000003, Pre-Filed Written Testimony of Dr. Robert C. Degeneff Regarding Contention NYS-8 (Degeneff Testimony); Exhibit NYS000004, Curriculum Vitae of Dr. Robert C. Degeneff; Exhibit NYS000005, Report of Dr. Robert C. Degeneff in Support of Contention NYS-8 (Degeneff Report); and Exhibits NYS000006 through NYS000044.

Q18. Have you reviewed other materials in preparing your testimony?

A18. (RBR, SED, JWC, TSM) Yes.

Q19. What are those materials?

A19. (RBR, SED, JWC, TSM) Many are documents prepared by government agencies, peer reviewed articles, or documents prepared by Entergy or the utility industry. These documents include, for example, NRC regulations and guidance documents, regulatory history documents, the IPEC LRA, the NRC Staffs associated August 2009 Safety Evaluation Report (SER) and August 2011 Supplemental SER, final NRC Staff safety evaluation reports for other license renewal applications, EPRI and IEEE guidance documents, technical papers, NEI guidance documents, NRC inspection manual chapters, and Entergy fleet and site procedures related to transformers.

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(TSM) In addition, due to my IPEC-specific engineering experience and responsibilities, I am very familiar with the stations electrical systems and current fleet/site programs or procedures that apply to those systems. Therefore, I am familiar with IPEC transformers and related performance monitoring and preventive maintenance programs that Entergy has implemented to meet 10 C.F.R. Part 50 requirements. These programs are not part of the LRA, but we discuss them in some detail below to fully address NYSs claims in NYS-8.

Q20. I show you what has been marked as Exhibit ENT000001. Do you recognize this document?

A20. (RBR, SED, JWC, TSM) Yes. It is a list of Entergys exhibits, and includes those documents which we used in preparing this testimony, ENT00015A-B and ENT000090 through ENT00130A-B.

Q21. I show you Exhibits ENT00015A-B and ENT000090 through ENT00130A-B.

Do you recognize these documents?

A21. (RBR, SED, JWC, TSM) Yes. These are true and accurate copies of the documents that we have referred to in preparing this testimony. In those cases in which we have attached only an excerpt of a document as an exhibit, that is noted on Entergys exhibit list.

Q22. How do these documents relate to the work that you do as an expert in forming opinions such as those contained in this testimony?

A22. (RBR, SED, JWC, TSM) These documents represent the type of information that persons within our fields of expertise reasonably rely upon in forming opinions of the type offered in this testimony. We note at the outset that we cannot offer legal opinions on the language of the NRC regulations discussed in our testimony or related Commission and NRC Staff guidance. However, reading those regulations and guidance documents as technical 9

statements, and using our expertise, we can interpret the technical meaning of those regulations as they relate to transformers.

III.

SUMMARY

OF TESTIMONY AND CONCLUSIONS Q23. What is the purpose of your testimony?

A23. (RBR, SED, JWC, TSM) The purpose of our testimony is to explain why NYS-8 lacks merit, and why Entergy has correctly concluded that transformers are not subject to aging management review under 10 C.F.R. Part 54. In summary, 10 C.F.R. § 54.21(a)(1)(i) requires AMR only for those structures and components that perform an intended function without moving parts or without a change in configuration or properties and for which aging degradation is not readily monitored. We will explain why transformers perform their intended functions with a readily monitorable change in configuration or properties and therefore do not meet the Section 54.21(a)(1)(i) AMR criterion and are properly excluded from AMR under Part 54.

Q24. Please summarize the basis for your disagreement with the claims made by NYS and its proffered experts in NYS-8.

A24. (RBR, SED, JWC, TSM) NYS claims that transformers should be subject to AMR because they allegedly function without moving parts or without a change in configuration or properties. NYS Petition at 103; see also Degeneff Testimony at 17 (NYS000003); Degeneff Report at 23 (NYS000005). This position contravenes established scientific principles and long-standing regulatory precedents. NRC and industry guidance documents have long classified transformers as active components that are excluded from AMR, and the NRC has never reached a different conclusion in approving 40 license renewal applications for 71 reactor units to date.

As this testimony will demonstrate, the exclusion of transformers from Part 54 AMR has sound technical and regulatory bases. In short, transformers perform the intended function of 10

supplying transformed voltage and current to electrical busses. When a transformer is energized from an electrical source, it changes from an idle state to an active state, and the electrical and magnetic properties of the transformer change. These changes in electric and magnetic properties are integral to transformer operation, necessary for performance of the transformers intended function, and can be directly measured or observed. A transformer is more similar to other electrical components in the AMR-excluded list because its terminal voltages and currentslike those of a power supply, battery charger, or power inverterchange as the transformer performs its intended function (i.e., transformation of the input voltage and current to some other form and/or value of voltage and current) and can be directly measured and monitored. Therefore, transformers are excluded from AMR under 10 C.F.R. § 54.21.

Furthermore, in revising its Part 54 license renewal regulations in 1995, the Commission concluded that established Part 50 programs and activities, including those required by the maintenance rule (10 C.F.R. § 50.65), are adequate to manage the effects of aging on the functionality of components that perform their intended functions with moving parts or with a change in configuration or properties. See Final Rule, Nuclear Power Plant License Renewal; Revisions, 60 Fed. Reg. 22,461, 22,471, 22,475-476. (May 8, 1995) (1995 License Renewal SOC) (NYS000016). As with other active components, Entergy has implemented at IPEC performance monitoring and preventive maintenance programs designed to monitor and assess the functionality of transformers that are consistent with NRC regulations and industry guidance.

Those programs are part of the IP2 and IP3 current licensing bases (CLB) and subject to ongoing NRC oversight and inspections. NYSs criticisms of those CLB programswhich are not part of Entergys LRAlack merit in any event.

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As explained below, NYSs principal arguments are technically flawed for numerous reasons. First, Dr. Degeneff uses the terms static and passive interchangeably, even though the term static is not contained in 10 C.F.R. Part 54 or its regulatory history, or in NRC guidance implementing 10 C.F.R. § 54.21. Moreover, he relies on definitions of those terms that are not applicable to the classification of components under 10 C.F.R. § 54.21(a)(1). Without citing any technical or regulatory basis in his testimony, Dr. Degeneff erroneously equates the electrical engineering communitys definitions of static and passive with the Commissions Part 54 concept of a passive component.

However, the Statements of Consideration (SOC) for the license renewal rule states:

The Commission has reviewed several industry concepts of passive structures and components and has determined that they do not accurately describe the structures and components that should be subject to an aging management review for license renewal. 1995 License Renewal SOC, 60 Fed. Reg. at 22,477 (NYS000016). In that SOC, the Commission further stated that it had developed its own description of passive characteristics of structures and components and directly incorporated these characteristics into the integrated plant assessment (IPA) process described in 10 C.F.R. § 54.21(a). Id. Finally, the Commission noted that the description of passive structures and components incorporated into 10 C.F.R.

§ 54.21(a) should be used only in connection with the IPA review in the license renewal process. Id. In sum, Dr. Degeneff erroneously classifies transformers as passive components under 10 C.F.R. Part 54, despite Commission and Staff guidance that indicates that transformers are not passive components.

Second, Dr. Degeneffs comparisons of transformers to components on the AMR-included and AMR-excluded lists in 10 C.F.R. § 54.21(a)(1)(i) are technically flawed and 12

inconsistent. As explained below, these flaws in Dr. Degeneffs analyses and comparisons of various components appear to stem from his use of a definition of property that is not consistent with Part 54s use of the term property.

This is particularly evident in an analogy on which Dr. Degeneff repeatedly relies in his testimony. Specifically, he erroneously posits that pressure and flow are properties of water (or other fluids) in a pipe and, similarly, that voltage and current in a transformer are properties of electricity. A property is something that is inherent to an object. As explained further below, pressure and flow are not properties of water, and voltage and current are not properties of electricity. Pressure, flow, voltage and current all must be created by some external force. Using Dr. Degeneffs pipe analogy, the change in water pressure in the pipe is actually caused by the external force associated with the change in the pipes diameter and, therefore, water pressure is not a property of the liquid itself. In comparison, a transformers terminal voltages and currents are properties of the transformer, not properties of the electricity passing through it. Indeed, a transformer is designed to have specific voltages and currents at its terminals that are inherent to, and thus properties of, the transformer. Our testimony explains this concept in detail. Therefore, Dr. Degeneffs analogy between a pipe and transformer is not a valid one.

Third, NYSs assertion that age-related degradation in transformers is not readily monitored is irrelevant. Contrary to NYSs and Dr. Degeneffs position, 10 C.F.R. Part 54 is concerned with managing the effects of aging on component functionality, not on managing aging mechanisms per se. The Commission emphasized this point when it revised Part 54 in 1995. 1995 License Renewal SOC at 22, 471, 22,475-76 (NYS000016). The possibility that certain aging mechanisms may not be detected by Part 50-mandated performance monitoring of transformers does not mean that transformers require a Part 54 aging management program.

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Further, when the NRC Staff recommended that transformers be excluded from Part 54 AMR in 1997, it noted the similarities between transformers and the electrical components (e.g., power supplies, power inverters) that are expressly excluded from AMR in 10 C.F.R. § 54.21(a)(1)(i) with respect to (1) how they perform their intended functions and (2) whether the effects of aging degradation on those functions can be readily monitored with available techniques. See Letter from Christopher Grimes, NRC, to Douglas J. Walters, NEI, Determination of Aging Management Review for Electrical Components, Attach. at 2 (Sept. 19, 1997) (1997 NRC Letter) (ENT000097). Importantly, the Staff concluded that degradation of the transformers ability to perform its intended function is readily monitorable by a change in the electrical performance of the transformer and the associated circuits. Id.

Finally, NYSs claim that transformers are subject to AMR because they are components for which periodic replacement is not generally scheduled is irrelevant. As explained below, transformers are still active components under the first prong of 10 C.F.R. § 54.21(a)(1) because they perform their intended functions through changes in their configuration or properties, irrespective of whether they are subject to periodic replacement.

IV. OVERVIEW OF APPLICABLE PART 54 REQUIREMENTS AND GUIDANCE A. Applicable Part 54 Requirements Q25. Please identify and briefly describe the NRCs license renewal requirements in 10 C.F.R. Part 54 regarding the identification of SSCs that are subject to aging management review.

A25. (RBR, JWC) 10 C.F.R. § 54.4(a)(1)-(3) outline the three general categories of SSCs that are within the scope of license renewal. From among these SSCs, license renewal applicants must identify and list, in an integrated plant assessment, those structures and 14

components subject to an aging management review. Section 54.21 provides the standards for determining which structures and components require an aging management review.

Q26. What are the three general categories of SSCs that are within the scope of license renewal, as set forth in 10 C.F.R. § 54.4(a)(1)-(3)?

A26. (RBR, JWC) The first category consists of safety-related SSCs. 10 C.F.R.

§ 54.4(a)(1). These are SSCs relied upon to remain functional during and following design-basis events to ensure the integrity of the reactor coolant pressure boundary, the capability to shut down the reactor and maintain it in a safe shutdown condition, or the capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to those referred to in 10 C.F.R. §§ 50.34(a)(1), 50.67(b)(2), or 100.11. See 10 C.F.R. § 50.2 (defining safety-related).

The second category consists of all non-safety-related SSCs whose failure could prevent satisfactory accomplishment of any of the safety functions identified above. 10 C.F.R.

§ 54.4(a)(2). For example, SSCs in this category would include non-safety auxiliary systems whose failure could impact the function of safety-related systems.

The third category consists of all SSCs relied on in safety analyses or plant evaluations to perform a function that demonstrates compliance with the NRCs regulations for fire protection (10 C.F.R. § 50.48), environmental qualification (10 C.F.R. § 50.49), pressurized thermal shock (10 C.F.R. § 50.61), anticipated transients without scram (10 C.F.R. § 50.62), and station blackout (10 C.F.R. § 50.63). 10 C.F.R. § 54.4(a)(3). These SSCs would include, for example, equipment necessary to meet these regulations as defined in a plants final safety analysis report, such as a plants fire protection system.

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Q27. What in-scope structures and components require an aging management review, as set forth in 10 C.F.R. § 54.21(a)(1)?

A27. (RBR, JWC, SED) If a structure or component performs no intended function as defined in 10 C.F.R. § 54.4(a)(1) to (3), then it is not subject to AMR. See 10 C.F.R. § 54.4(b).

Section 54.21(a)(1)(i), in turn, further limits the structures and components subject to AMR to those structures and components that perform an intended function [as defined in § 54.4(a)(1)-

(3)] without moving parts or without a change in configuration or properties and that are not subject to replacement based on a qualified life or specified time period. Id. § 54.21(a)(1)(i)-(ii).

Given the foregoing, the preparation of an LRA involves the following sequential, two-step process: (1) identification of the SSCs within the scope of the license renewal rule (as defined in 10 C.F.R. § 54.4) (also known as scoping) and then, among those in-scope SSCs, (2) identification of the structures and components that are subject to AMR (also known as screening). Screening is part of an applicants integrated plant assessment, or IPA, as defined in 10 C.F.R. § 54.21(a) and is performed to determine which structures and components in the scope of license renewal require aging management review.

Q28. Do NRC regulations identify those specific structures and components that are subject to aging management review?

A28. (RBR, JWC, SED ) 10 C.F.R. § 54.21(a)(1)(i) provides the general criterion discussed above (without moving parts or without a change in configuration or properties). It also provides, as examples, lists of structures and components that do and do not require AMR under that regulation. These are shown in Table 1 below. These lists were not intended to be exhaustive. Specifically, when the Commission revised Part 54 in 1995, it expressly included the structures and components listed in Section 54.21(a)(1)(i) only as examples of the 16

implementation of the IPA screening requirement. 1995 License Renewal SOC, 60 Fed. Reg. at 22,477 (NYS000016). The Commission stated its intent to include additional clarification and examples of components requiring an aging management review in its implementation guidance for the rule. Id. at 22,479. NRC and industry license renewal implementation guidance, discussed below, provides this additional clarification.

Table 1. Part 54 Examples of AMR-Included and AMR-Excluded Components Structures and Components Listed in Structures and Components Listed in 10 C.F.R. § 54.21(a)(1)(i) As Subject to 10 C.F.R. § 54.21(a)(1)(i) As NOT Subject to Aging Management Review Aging Management Review

• reactor vessel

• pumps (except casing)

• reactor coolant system pressure boundary

• valves (except body)

• steam generators

• motors

• pressurizer

• diesel generators

• piping

• air compressors

• pump casings

• snubbers

• valve bodies

• control rod drive

• core shroud

• ventilation dampers

• component supports

• pressure transmitters

• pressure retaining boundaries

• pressure indicators

• heat exchangers

• water level indicators

• ventilation ducts

• switchgears

• containment

• cooling fans

• containment liner

• transistors

• electrical and mechanical penetrations,

• batteries

• equipment hatches

• breakers

• seismic Category I structures,

• relays

• electrical cables and connections

• switches

• cable trays

• power inverters

• electrical cabinets

• circuit boards

• battery chargers

• power supplies 17

Q29. What findings must the NRC make to issue a renewed operating license?

A29. (RBR, JWC) As a general matter, the NRC must find that there is reasonable assurance that the activities authorized by the renewed license will continue to be conducted in accordance with the plants CLB during the period of extended operation. 10 C.F.R. § 54.29(a);

see also id. § 54.21(a)(3). Section 54.29(a)(1) also requires a finding that the applicant has identified and has taken, or will take, actions for managing the effects of aging during the period of extended operation on the functionality of those structures and components identified as subject to AMR under 10 C.F.R. § 54.21(a)(1).

B. Relevant NRC and Industry Guidance Q30. What guidance has the NRC Staff and the nuclear industry issued to assist license renewal applicants in meeting Part 54 requirements?

A30. (RBR, JWC) The NRC Staff reviews license renewal applications in accordance with the requirements in 10 C.F.R. Part 54 using Staff guidance contained in NUREG-1800, Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, Rev. 1 (Sept. 2005) (NUREG-1800 or SRP-LR) (NYS000195). NUREG-1801, Generic Aging Lessons Learned Report, Rev. 1 (Sept. 2005) (also called the GALL Report)

(NYS000146A-D) provides the technical basis for NUREG-1800 and identifies aging management programs that the Staff has accepted as meeting the requirements of 10 C.F.R. Part

54. The NRC Staff issued Revision 2 of NUREG-1800 and Revision 2 of NUREG-1801 in December 2010. See NYS000161, NYS00147A-D.

The nuclear industry has issued NEI 95-10, Industry Guideline for Implementing the Requirements of 10 CFR Part 54 - The License Renewal Rule, Rev. 6 (June 2005) (NEI 95-10 (ENT000098). NEI 95-10 is referenced in NUREG-1800 and endorsed by Regulatory Guide 1.188, Standard Format and Content for Applications to Renew Nuclear Power Plant Operating 18

Nuclear Power Plant Operating Licenses, Rev. 1, at 4 (Sept. 2005) (RG 1.188) (ENT000099).

NEI 95-10 provides guidance that the NRC Staff considers acceptable for meeting Part 54 requirements. RG 1.188, at 7. NEI 95-10 includes detailed guidance on the scoping and screening processes. Also relevant here, EPRI has issued Report 1013475, Plant Support Engineering: License Renewal Electrical Handbook, Revision 1 to EPRI 1003057 (EPRI 1013475) (Feb. 2007) (ENT000100), which addresses all phases of the license renewal electrical review process. EPRIs handbook is based on nuclear industry equipment aging experience and license renewal application review experience. As discussed further below, both NEI 95-10 and EPRI 1013475 reflect the consensus regulatory and industry view that transformers are not passive components requiring AMR under Part 54.

Q31. How do the SRP-LR and industry guidance classify transformers for purposes of aging management under 10 C.F.R. Part 54?

A31. (RBR, JWC) Table 2.1-5 of NUREG-1800 (Revisions 1 and 2) and Appendix B to NEI 95-10 list structures and components and indicate whether they meet the 10 C.F.R.

§ 54.21(a)(1)(i) criterion for AMR-included components (i.e., perform an intended function without moving parts or a change in configuration or properties). Both Table 2.1-5 of NUREG-1800 and Appendix B to NEI 95-10 state that transformers do not meet the 10 C.F.R.

§ 54.21(a)(1)(i) criterion. NUREG-1800, Rev. 1 at 2.1-23 (Table 2.1-5, Item 104)

(NYS000195); NUREG-1800, Rev. 2 at 2.1-26 (Table 2.1-5, Item 104) (NYS000161); NEI 95-10, App. B at B-14 (ENT000098).

Q32. Do NRC or industry guidance documents provide any additional explanation as to why transformers do not perform passive intended functions?

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A32. (RBR, JWC) Yes. During the NRC Staffs review of NEI 95-10, it identified the need for guidance on whether certain electrical components require aging management review.

NEI 95-10, App. C at C-10 (ENT000098). The Staff provided that guidance in a 1997 letter signed by the Director of the License Renewal Project Directorate. Therein, the Staff recommended that the industry revise Appendix B of NEI 95-10 to indicate that transformers do not require an aging management review. 1997 NRC Letter at 4 (ENT000097). That letter explains the technical basis for the Staffs conclusion that transformers do not require an AMR:

While § 54.21(a)(1)(i) excludes many electrical and I&C components from an aging management review for renewal, it also states that the exclusion is not limited to only these components. The staff has considered the aging management review requirements for transformers . . . with respect to the definitions, background, and specific electrical examples in the license renewal rule (circuit breakers, relays, motors, circuit boards, etc.). Based on the considerable discussion provided in the [1995 license renewal] rule and SOC [Statements of Consideration], the staff compared the electrical components identified above with the examples explicitly provided in the rule in terms of how the performance of their intended functions would be achieved and whether aging degradation of these components would be readily monitored using currently available techniques, in a similar way by which the examples in the rule (circuit breakers, relays, switches, etc.) would be monitored. These techniques include performance or condition monitoring by testing and maintenance/surveillance programs that include instrument checks, functional tests, calibration functional tests, and response time verification tests. The results of these tests and performance monitoring programs can be analyzed and trended to provide an indication of aging degradation for these electrical components as discussed below:

Transformers perform their intended function through a change in state by stepping down voltage from a higher to a lower value, stepping up voltage to a higher value, or providing isolation to a load.

Transformers perform their intended function through a change in state similar to switchgear, power supplies, battery chargers, and power inverters, which have been excluded in §54.21(a)(1)(i) from an aging management review. Any degradation of the transformers ability to perform its intended function is readily monitorable by a change in the electrical performance of the transformer and the 20

associated circuits. Trending electrical parameters measured during transformer surveillance and maintenance such as Doble test results, and advanced monitoring methods such as infrared thermography, and electrical circuit characterization and diagnosis provide a direct indication of the performance of the transformer. Therefore, transformers are not subject to an aging management review.

1997 NRC Letter at 1-2 (emphasis added) (ENT000097).

EPRIs License Renewal Electrical Handbook further explains why transformers are properly excluded from Part 54 aging management review:

The function of a transformer is to induce a voltage in a separate electrical circuit. Transformers achieve this function by passing current through a conductive winding to create an electromagnetic induction between the winding and a separate winding that is part of a separate electrical circuit. The passing current changes the physical properties of the transformer in a way that causes a voltage to be induced in the terminals of the separate winding. This induced voltage is not a natural state or characteristic of the secondary transformer terminals and only exists when it is performing its function. This property change of the transformer terminals is integral to the function of the transformer; i.e., a transformer performs its function by changing its physical properties. This indicates that transformers do not perform their function without moving parts or without a change in configuration or properties. Therefore, transformers are not subject to AMR based on the criteria of §54.21(a)(1)(i).

EPRI 1013475, App. B at B-9 (ENT000100).

C. Commission Guidance Implementing the License Renewal Rule: The Statements of Consideration for the 1995 Revisions to Part 54 Q33. What is the Statements of Consideration mentioned above, and why is it important to the interpretation and application of the license renewal rule in Part 54?

A33. (RBR, SED, JWC) The Commission publishes Statements of Consideration (SOC) for major rules and amendments. The SOC accompanying the Commissions 1995 revisions to Part 54 provides information from the NRC Commissioners regarding the clarification of the intent or basis of the rule, including historical context and supplementary information regarding the rule. EPRI 1013475, at xxii; see also id. at 2-1, 5-9 to 5-10, 8-6, App.

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B at B-10 to -11, B-18 to B-19; NUREG-1800, Rev. 1 at 2.1-6 to 2.1-10 (citing the 1995 License Renewal SOC as clarifying the intent of, and providing guidance on, the license renewal rule).

The 1995 License Renewal SOC explains the screening process in 10 C.F.R. § 54.21, including the relationship between the license renewal rule and the maintenance rule. It also explains the distinction between active and passive SSCs that lies at the center of Part 54.

Q34. You referred to the maintenance rule. What is it?

A34. (RBR, JWC) The NRC promulgated the maintenance rule, codified at 10 C.F.R.

§ 50.65, in July 1991. It became effective in July 1996. See Final Rule, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, 56 Fed. Reg. 31,306, 31,306 (July 10, 1991) (ENT000101), as amended at 58 Fed. Reg. 33,993 (June 23, 1993) (ENT000102). The fundamental purpose of the performance-based maintenance rule is to require monitoring of the performance of plant equipment to ensure that safety-related and certain nonsafety-related SSCs are capable of performing their intended functions. See 1995 License Renewal SOC at 22,470 (For systems, structures, and components that fall within the requirements of § 50.65(a)(1),

licensees must establish goals and monitor performance against these goals. An effective preventive maintenance program is required under § 50.65(a)(2) if monitoring under § 50.65(a)(1) is not performed.) (NYS000016). Importantly, the intent of the license renewal rule and the maintenance rule is similar (ensuring that the detrimental effects of aging on the functionality of important systems, structures, and components are effectively managed). Id. at 22,471 (emphasis added).

Q35. Returning to your discussion of the 1995 License Renewal SOC accompanying the amendments to 10 C.F.R. Part 54, did the Commission address existing maintenance activities and maintenance rule requirements for structures and components?

22

A35. (RBR, JWC) Yes. The Commission issued its initial license renewal rule in 1991; i.e., before any substantial implementation of the maintenance rule. In revising the license renewal rule in 1995, the Commission redefined its regulatory approach to managing aging effects to incorporate insights gained from maintenance rule implementation. 1995 License Renewal SOC at 22,465, 22,471 (NYS000016). As discussed in the 1995 License Renewal SOC, NRC regulations require licensees to develop and implement programs that ensure that conditions adverse to quality, including degraded SSCs, are promptly identified and corrected.

Id. at 22,475. These licensee programs include self-inspection, maintenance, and technical specification surveillance programs that monitor and test the physical condition of plant SSCs (including transformers). Id. The SOC states that the requirements in this rule [Part 54] reflect a greater reliance on existing licensee programs that manage the detrimental effects of aging on functionality, including those activities implemented to meet the requirements of the maintenance rule. Id. at 22,471. The 1995 License Renewal SOC thus reflects the Commissions intent to more fully integrate the maintenance rule and the license renewal rule, id., as well as the Commissions deliberate shift in focus from managing aging mechanisms to managing the effects of aging on functionality. Id. at 22,475-76 (emphasis added).

Q36. What is the significance of the Commissions decision to credit existing maintenance activities and requirements?

A36. (RBR, JWC, SED) In crediting the maintenance rule to address potential degradation of active structures and components, the Commission concluded that 10 C.F.R. Part 54 aging management review is not required for such structures and components that already are covered by maintenance rule programs and activities:

[T]he Commission believes that with the additional experience it has gained with age-related degradation reviews and with the 23

implementation of the maintenance rule, there is a sufficient basis for concluding that current licensee programs and activities, along with the regulatory process, will be adequate to manage the effects of aging on the active functions of all systems, structures, and components within the scope of license renewal during the period of extended operation . . . .

1995 License Renewal SOC at 22,471 (NYS00016) (emphasis added). The Commission emphasized that the existing regulatory process, existing licensee programs and activities, and the maintenance rule provide the basis for generically excluding structures and components that perform active functions from aging management review. Id. at 22,476. The AMR for license renewal thus focuses on structures and components that perform passive intended functions.

Q37. Is this Commission determination reflected in 10 C.F.R. Part 54?

A37. (RBR, JWC, SED) Yes. The rule requires AMR only for those structures and components that perform an intended function without moving parts or without a change in configuration or properties. 10 C.F.R. § 54.21(a)(1)(i). In contrast to passive structures and components, active structures and components are readily monitorable and generically excluded from an [AMR] on the basis of performance or condition-monitoring programs. 1995 License Renewal SOC at 22,472, 22,476-77 (NYS000016). Specifically, functional degradation resulting from the effects of aging on active functions is more readily determinable, such that current programs, including required maintenance programs, can directly detect the effects of aging on components performing active functions. Id. at 22,472. Therefore, active components are excluded from the requirement to perform AMR in 10 C.F.R. § 54.21(a)(1)(i). Id. at 22,477.

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V. ENTERGYS COMPLIANCE WITH PART 54 REQUIREMENTS AND GUIDANCE APPLICABLE TO ELECTRICAL TRANSFORMERS A. The Scoping Process as Applied to IPEC Transformers Q38. Please describe the scoping process that Entergy conducted in preparing the IPEC LRA, particularly as it relates to IPEC transformers.

A38. (RBR) Entergy used a bounding approach by including in the scope of license renewal all plant electrical and instrumentation and control systems. LRA Tables 2.2-1b-IP2, and 2.2-1b-IP3 list those specific systems within the scope of license renewal for IP2 and IP3, respectively. LRA at 2.5-1, 2.2-12 to -16 (ENT00015A). This bounding method assures that components are not improperly excluded from the scope of license renewal, and is one of the suggested scoping methods in NEI 95-10 (ENT000098) and EPRI 1013475 (ENT000100).

Q39. Do these electrical systems include plant transformers?

A39. (RBR) Yes. Entergy included in the scope of license renewal all plant transformers. See LRA at 2.5-1 to 2.5-2.

B. The Screening Process as Applied to IPEC Transformers Q40. Please describe the screening process that Entergy performed in preparing the LRA to determine whether electrical structures and components are subject to AMR.

A40. (RBR) In accordance with 10 C.F.R. § 54.21(a)(1), Entergy conducted screening to determine which in-scope electrical structures and components are subject to AMR. As part of this process, and to identify passive component types, Entergy compared a complete list of IP2 and IP3 electrical and I&C component types to those listed in NEI 95-10, Appendix B, Typical Structure, Component and Commodity Groupings and Active/Passive Determinations for the Integrated Plant Assessment. NEI 95-10, Appendix B, which provides the complete list of potential passive components, indicates that transformers do not meet the 10 C.F.R. 25

§ 54.21(a)(1)(i) criterion for a passive component. NEI 95-10, App. B at B-14 (Item 104)

(ENT000098). Therefore, transformers are considered active components and not subject to aging management review. This same determination is reflected in NUREG-1800, Rev. 1. SRP-LR at 2.1-23, Tbl. 2.1-5 (Item 104) (NYS000195).

Q41. Has the NRC Staff reviewed the IPEC LRA and concurred with Entergys determination that IPEC transformers are not subject to AMR under Part 54?

A41. (RBR, JWC) Yes. The NRC Staff published its SER for the IPEC LRA in 2009.

See NUREG-1930, Safety Evaluation Report Related to the License Renewal of Indian Point Nuclear Generating Unit Nos. 2 and 3, Docket Nos. 50-247 and 50-286, Entergy Nuclear Operations, Inc. (Nov. 2009) (NYS00326A-F). The SER documents the Staffs review of the scoping and screening methodology described by Entergy in LRA Section 2. See id. at 2-1; see also generally id. at 2-1 to -232. The Staff concluded that the applicant has adequately identified those systems and components within the scope of license renewal, as required by 10 CFR 54.4(a), and those subject to an AMR, as required by 10 CFR 54.21(a)(1). Id. at 2-231 to

-232. Thus, the Staff approved Entergys determination that transformers are not subject to AMR. The Staff did not revisit or alter this conclusion in its August 2011 Supplemental SER.

VI. TECHNICAL BASIS FOR EXCLUSION OF TRANSFORMERS FROM AMR UNDER 10 C.F.R. PART 54: TRANSFORMER OPERATION AND PROPERTIES A. Basic Theory of Transformer Operation Q42. What is an electrical transformer?

A42. (SED) A transformer is an electrical device that converts alternating current (AC) power at a certain voltage level to AC power at a different voltage level, without changing the frequency, or which provides isolation to electrical circuits. Current refers to the passage of electrons through a conductor (i.e., a material that easily permits electric current to 26

flow). AC is electrical current that constantly changes amplitude and changes polarity at regular intervals. Voltage is a force that causes current to flow through an electrical conductor. See D.E. Johnson, J.L. Hilburn, & J.R. Johnson, Basic Electric Circuit Analysis at 5-8 (2d ed. 1984)

(ENT000103).

Q43. How is a basic transformer constructed?

A43. (SED) As illustrated in Figure 1 below, a transformer is a series of wire windings positioned around some type of core. The core usually is constructed of a material that has a high magnetic permeability (i.e., the ability of a material to act as a path for magnetic lines of force), such as iron or steel. There can be many windings or as few as one.

In its simplest form, a transformer is formed by winding two coils of wire around the same iron form or core. The coil or winding used to input power to the transformer is called the primary winding. The coil or winding used to output power from the transformer is called the secondary winding.

Figure 1. Illustration of a Basic Transformer Source: Rod Elliott, Transformers - The Basics (Section 1), Elliott Sound Products (Mar. 24, 2001), http://sound.

westhost.com/xfmr.htm#reference (ENT000104).

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An alternating current is used to excite the primary winding. This current creates a magnetic field in the core. Because alternating current is used to drive the primary coil, the magnitude of the magnetic field produced in the core varies over time. This magnetic field that varies over time induces a voltage in the secondary winding that is transferred to anything connected to that winding.

Whatever is connected to the secondary winding is usually referred to as the load. The voltages and currents that appear at the input and output terminals of the transformer are determined by how many turns of wire exist in the primary and secondary transformer windings.

The ratio of these turns is usually expressed as NS / NP , where NS is the number of turns in the secondary winding and NP is the number of turns in the primary winding. This ratio is usually referred to as the turns ratio of the transformer. (Some authorities define NP / NS as the turns ratio. Either definition is acceptable.)

In Figure 1 above, VP is the voltage applied to the primary coil, IP is the primary coil current, VS is the voltage created at the terminals of the secondary winding, and IS is the current in the secondary winding. As discussed further below, without voltage and current changes, there is no transformer operation. Transformer operation may be described in mathematical terms by the following equation, which is derived from Faradays Law:

This equation is only true for an ideal transformer. An ideal transformer is a lossless transformer that has 100% magnetic coupling between the primary and secondary windings. A lossless transformer is one that consumes no power; that is, the output power is equal to the input power. This equation is conceptually true for real life transformers but considerations must 28

be made for internal transformer losses and the fact that not all of the magnetic field produced by the primary winding is coupled into the secondary winding(s).

Q44. What is the intended function of a transformer?

A44. (SED) The intended function of a transformer is to step up voltage, to step down voltage, or to provide isolation between the input and output circuits. (Isolation is provided when there is no electrical connection between the primary and secondary windings.) Voltage transformation is provided through the turns ratio as shown in Table 2 below.

Table 2. Voltage Transformation as Function of Turns Ratio NS /NP (Turns Ratio) VS in terms of VP IS in terms of IP Type of Transformer 10 10 VP 0.1 IP Step-up 1/10 0.1 VP 10 IP Step-down 1 Vp IP Isolation if windings are not electrically connected Q45. How does the loading condition affect the voltages and currents of a transformer?

A45. (SED) The input and output voltages and currents of a transformer change depending on the loading condition of the transformer. (In using the term load here, we are referring to the amount of current being drawn from the secondary winding. Increasing the load means increasing the current being drawn from the secondary winding. Decreasing the load means decreasing the current being drawn from the secondary winding.) The following table (Table 3) which shows AC voltages and currents in a typical step-up transformer having a rated capacity of 100 kilovolt-ampere (KVA) and a turns ratio of 10 under various load conditions, illustrates this point.

29

Table 3. Relationship Between Load Condition and Transformer Voltage and Current Transformer Load Condition VP Vs Ip Is State Not Energized 0% 0 0 0 0 Energized 0% 100 VAC 1000 VAC 0 0 Energized 50% 100 VAC 1000 VAC 500 AAC 50 AAC Energized 100% 100 VAC 1000 VAC 1000 AAC 100 AAC This table is based on the operation of an ideal transformer where magnetization current is ignored and a power source capable of supplying the required loads without a voltage drop.

Q46. Do the principles described above apply to all transformers, regardless of transformer size or type?

A46. (SED) Yes. These principles apply to all transformersfrom the smallest electronic unit to the largest distribution transformerirrespective of how the transformer is constructed or the purpose for which it is used. Consideration of losses and magnetic coupling will add variables and complexities to the calculations for the reasons stated in Answer 43 above, but it will not change the underlying principles described above.

B. Discussion of Transformer Properties Q47. How do you define the term property?

A47. (SED) In my testimony, I use the dictionary definition of a property; i.e., a characteristic trait or peculiarity, esp. one serving to define or describe its possessor. The American Heritage College Dictionary 1097 (3d ed. 1997) (ENT000105). In other words, a property is a characteristic or trait of an object that is inherent to the object, such that it is not possible to fully describe or understand the object without consideration of the property.

A property is also defined as a characteristic attribute possessed by all members of a class. Id. Any trait that is not common to all components in a class is, therefore, not a property 30

of the component and cannot be used to classify that component as included or excluded.

For example, although the core material of a transformer may be an attribute of its design, it cannot be a property used to classify transformers, because the core material may vary between different transformers. Core materials may be iron, steel, or air. In contrast, and as explained further below (see Answer 53), the magnetic field, terminal voltages and currents, and the turns ratio are inherent to the description and operation of any transformer.

Q48. Why is it important to define the term property for purposes of the present discussion?

A48. (SED) Having a clear understanding of the term property as it is used in the NRCs governing Part 54 regulations and 1995 License Renewal SOC is key to properly resolving the issues raised in NYS-8 and Dr. Degeneffs associated testimony. As discussed above, the Commission has determined that passive structures and components for which aging degradation is not readily monitored are those that perform an intended function without moving parts or without a change in configuration or properties. 10 C.F.R. § 54.21(a)(1)(i)

(emphasis added); see also 1995 License Renewal SOC at 22,477 (NYS000016). Neither Part 54 nor the 1995 License Renewal SOC explicitly defines the term property, although the SOC states that the Commission has concluded that a change in configuration or properties should be interpreted to include a change in state, such as may occur in a transistor. Id. at 22,477.

Dr. Degeneffs use of an incorrect definition of the term property leads to numerous errors and inconsistencies in his testimony and evinces the lack of technical support for NYS-8.

Q49. Please provide some examples of properties.

A49. (SED) Chemical composition is one. For example, water is composed of the elements hydrogen and oxygen. Water also has unique physical properties, such as its density, 31

freezing point, and boiling point under specified conditions. These properties always are present irrespective of where water is located or its surrounding conditions.

The chemical composition of water is a property that does not change. The boiling point of water is an example of a property that changes according to an externally-applied pressure and, therefore, cannot be represented as a single value. Water boils at a higher temperature at sea level than it does at 5,000 feet elevation. It is possible to plot the boiling point of water versus the ambient pressure, and the resulting curve will be characteristic of, or inherent to, water. By way of analogy, electrical components have characteristic voltage-current (V-I) curves, as discussed further below. See Answers 62-64, infra.

Q50. Can you provide some examples of things associated with water that are not properties?

A50. (SED) Yes. Pressure and flow are attributes associated with, but not properties of, water. As defined above, a property is something that is inherent in the object. Neither pressure nor flow is inherent to water. If water is not acted upon by some external force, then it has neither pressure nor flow. I will address this point in greater detail in Answer 78 below.

Consider the example of a simple water tank with a valve on the bottom of the tank. The water tank on earth has water pressure, and when the valve is opened, there is flow. However, if we remove the tank from a gravitational field, it will not exhibit pressure or flow. Likewise, water acted upon by a pump can have both pressure and flow, but if we remove the outside force of the pump, then both pressure and flow disappear. Therefore, such pressure and flow are properties of the pumpnot the water itself.

Q51. Does electricity have properties?

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A51. (SED) Yes. Electricity is a fundamental entity of nature consisting of positive and negative charges. It has the properties of being either positive or negative, of like charges repelling each other, and of unlike charges attracting each other. In addition, both positive and negative electric charges are surrounded by an electric field, and movement of those charges produces a magnetic field.

Q52. Are voltage and current properties of electricity, as Dr. Degeneff suggests in his testimony and report? See Degeneff Testimony at 10; Degeneff Report at 9.

A52. (SED) No. Dr. Degeneffs contrary assertion is a fundamental error in his analysis. Voltage, also referred to as electromotive force, is the measure of force that is created when unlike charges are separated. See Basic Electric Circuit Analysis, at 8 (ENT000103). It is the force that tries to drive the charges back together, and that causes current to flow through an electrical conductor. Voltage is not inherent in electricity and must be created by some external force. In the case of an electrical power plant, that external force is the generator. In the case of a battery, it is the chemical reaction inside the battery.

Similarly, current is not a property of electricity. Current is simply the flow of charge when acted upon by an external force that is usually measured in volts. Just like pressure and flow in water is created by an external force (e.g., a pump), voltage and current only exist when charge (electricity) is acted upon by some external force (e.g., an AC power source).

Q53. Applying the definition of property set forth above, what are common properties of all transformers?

A53. (SED) The magnetic field, terminal voltages and currents, and the turns ratio are common properties of a transformer. A transformers internal magnetic field is a property 33

because it is this field that produces transformer operation. Without it, there is no transformer operation.

The terminal voltages and currents also are properties of a transformer for two reasons.

First, the terminal voltages and currents create the internal magnetic field of a transformer. The terminal voltages drive the terminal currents, which create the internal magnetic field.

Therefore, defining the magnetic field as a property requires that the associated terminal voltages and currents be included as properties. Second, a transformer is an electrical component, and virtually all electrical components are described by their terminal voltages and currents, i.e., their terminal characteristics. In other words, a transformers terminal voltages and currents are inherent to the transformer and necessary to fully understand and describe how the transformer operates.

In addition, because a transformer either transforms input voltage to some other voltage at the output or isolates voltage (both as a function of its turns ratio), the turns ratio of the transformer is a property of the transformer.

Q54. In your professional opinion, do these properties of a transformer change during its operation?

A54. (SED) Yes. Above, I explained why the magnetic field and the terminal voltages and currents are properties of a transformer. Now, I will explain how these properties change as the transformer performs its intended function. In doing so, I will paraphrase Dr. Degeneffs own description of a transistorwhich is an AMR-excluded component listed in § 54.21(a)(1)(i))and apply that description to a transformer to illustrate the clear parallels between these two components. Specifically, Dr. Degeneff describes transistors as follows:

Transistors are made from semiconductor materials, the resistivity of which can be changed by applying an electric current to the 34

material; a semiconductors electrical resistance can be made to vary between that of a conductor (full flow or very low resistance) and that of an insulator (very low flow or very high resistance). In fact, a transistor is designed to change its resistivity, which change is clearly a change in its properties and, in some cases, a change in state as from conductor to insulator. The transistor cannot change the properties of the power flowing through it unless it also changes its own resistivity. The change in resistivity that occurs in the semiconductor device can be thought of as a valve whose position may be changed through an external electric stimulus. A small change in the voltage input to a basic transistor gate drive changes the properties (resistance and/or conductance) of the semiconductors main conducting path.

Degeneff Testimony at 21:12-22:7 (ENT000003).

In comparison, transformers, are made with magnetic core materials, the magnetism of which can be changed by applying electric current to the primary winding. A transformers magnetism can be made to vary between very strong (full load) and very weak (no load). In fact, a transformer is designed to change its magnetism, which clearly is a change in its properties and, in some cases, a change in state from being On to being Off (or vice versa). A transformer cannot change the voltage and current at its output unless it also changes the strength of the magnetism in its core. The change in magnetism that occurs in a transformers core occurs automatically through external electric stimuli supplied by changes in the source and load.

These changes in a transformers electromagnetic properties result directly from the transformer performing its intended function of supplying a load circuit with current at a specific voltage under varying conditions. Clearly, the magnetic changes that occur within a transformer as it performs its intended function are directly analogous to the electrical resistive changes that occur in a transistor as it performs its intended function.

For example, consider a transformer that is out of service or off. It has no input voltage, no output voltage, and no internal magnetic field. When the transformer is put into 35

service, it is connected to a voltage source and a load circuit. When these two items are connected, the terminal is turned on, terminal voltages and currents appear, and an internal magnetic field is created. It has just experienced a change of state that can be monitored at its terminals.

Next, consider a load increase, in which more current is drawn from the secondary side of the transformer. For this to happen, more current must be supplied to the primary winding by the voltage source. The currents at the transformer terminals and the internal magnetic field all have changed due to the load change. Depending upon the voltage source, the design of the transformer, and the size of the load increase, the terminal voltages of the transformer also may have changed.

Finally, consider a load decrease, in which less current is drawn from the secondary side of the transformer. As a result, less current is drawn from the voltage source on the primary side, and the internal magnetic field decreases in strength. Again, the currents at the transformer terminals and the internal magnetic field all have changed. Minor changes in the terminal voltages also may have occurred.

In conclusion, the internal magnetic field and the terminal voltages and currents are transformer properties that change as the transformer performs its intended function of supplying a load circuit with current at a specific voltage under varying power plant load conditions.

Q55. Can the changes in the properties of a power plant transformer be readily monitored during transformer operation?

A55. (SED) Yes. A change in transformer properties can be observed via directly measurable changes in the transformer terminal voltages and currents.

36

A transformer with no power supplied to its primary winding is off. There is no changing magnetic field in its core and no voltages or currents are present at its terminals. The fact that the transformer is off is readily monitored at its terminals.

When power is applied to the primary winding, a transformer is on. Voltage appears at the primary terminals, current flows in the primary winding, a magnetic field is created in the core, and a voltage appears at the secondary terminals. A transformer cannot perform its intended function unless power is supplied to its primary to cause this change in state. The primary voltage and current are readily monitored at the primary terminals. The fact that the magnetic field exists is readily monitored at the secondary terminals. Voltage in the secondary winding is created by magnetic induction in the core so that the presence of a secondary voltage indicates that a magnetic field exists in the core. If a load is connected to the secondary winding, then current will flow, which is readily monitored by instrumentation or the reaction at the load (e.g., a motor starts). If the load is varied, then the terminal voltages and currents will vary, as will the internal magnetic field. All of these properties are readily monitored at the terminals of the transformer.

VII. COMPARISON OF TRANSFORMERS TO COMPONENTS LISTED IN 10 C.F.R.

§ 54.21(A)(1)(I)

Q56. Based upon your review of Part 54 and its regulatory history (i.e., the 1995 License Renewal SOC), what is your understanding of the purpose of the included and excluded component lists in 10 C.F.R. § 54.21(a)(1)(i)?

A56. (RBR, SED, JWC) The component lists in 10 C.F.R. § 54.21(a)(1)(i) are important because they provide examples of SSCs that are excluded from AMR because they perform an intended function with moving parts or with a change in configuration or properties.

The change in configuration or properties can include a change in state. 1995 License Renewal 37

SOC at 22,477 (NYS000016). As discussed below, these lists must be read and applied in conjunction with the statement that precedes them. Specifically, 10 C.F.R. § 54.21(a)(1)(i) states: Structures and components subject to an aging management review shall encompass those structures and components(i) That perform an intended function as described in § 54.4 without moving parts or without a change in configuration or properties.

The 1995 License Renewal SOC underscores the importance of the lists in applying

§ 54.21(a)(1)(i) to non-listed components, such as transformers. Specifically, in two places, the 1995 License Renewal SOC contains statements similar to that contained in § 54.21(a)(1)(i), but in both cases, the 1995 License Renewal SOC further clarifies the intended meaning of the phrase without moving parts or without a change in configuration or properties.

• On page 22,477, column 1, the SOC states: The Commission has determined that passive structures and components for which aging degradation is not readily monitored are those that perform an intended function without moving parts or without a change in configuration or properties. 1995 License Renewal SOC at 22,477 (emphasis added).

• On page 22,477, column 3, the SOC states that the examples of electrical components (e.g., electrical cables, connections, and penetrations) listed in Section 54.21(a)(1) as requiring aging management review are properly categorized as passive because they perform their intended function without moving parts or without a change in configuration or properties and the effects of aging degradation for these components are not readily monitorable. Id. (emphasis added).

In 10 C.F.R. § 54.21(a)(1)(i), the clarification for which aging degradation is not readily monitored is not expressly included. Instead, it has been replaced by the two component lists.

These lists supply this important clarification by listing examples of (1) components that are subject to AMR because aging degradation in them is not readily monitored, and (2) components that are excluded from AMR because aging degradation in them is readily monitored. The 1995 License Renewal SOC discusses the logic underlying the component lists. The primary difference between the components in each list is whether or not the effects of aging degradation 38

can be readily monitored when the components perform their intended functions; i.e., moving parts and changes in configuration, properties, or state can be readily monitored as these components perform their intended functions.

Thus, the lists provide the basis for the AMR screening guidance contained in NUREG-1800 and NEI 95-10. Consider the first list of items identified as requiring aging management review. Structures and components in that list reflect the Commissions conclusion that the regulatory process and existing licensee programs and activities may not adequately manage the detrimental effects of aging on the functionality of these structures and components during extended operations. For example, piping, pump casings, and valve bodies can degrade in such a way as to reduce their ability to maintain design pressures (i.e., pressure boundaries)their intended function as discussed in the current licensing basis. In other words, structures and components subject to AMR (1) have properties that can degrade with age, and (2) the degradation is not readily monitored. See 1995 License Renewal SOC at 22,471, 22,477.

On the other hand, the list of structures and components excluded from AMR contains items with and without moving parts. Those with moving parts (e.g., pumps or valves) have properties or configurations that change. Those components on the AMR-excluded list that do not have moving parts have properties or configurations that change and include electrical components; e.g., transistors, batteries, power inverters, circuit boards, battery chargers, and power supplies. For those items, the terminal voltages and currents measurably change and can be readily monitored as the items perform their intended functions. Transformers fall into this category of components.

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In summary, to ensure the correct classification of non-listed structures and components, it is necessary to consider both the component lists in 10 C.F.R. § 54.21(a)(1)(i) and the associated discussion in the 1995 License Renewal SOC.

Q57. Do the AMR-excluded electrical components without moving parts listed in 10 C.F.R. § 54.21(a)(1)(i) have certain common traits?

A57. (SED) Yes. For example, the following statements apply to all electrical components without moving parts identified in the AMR-excluded list:

• The components are easily identified and found at discrete locations in the plant. (In contrast, not all components on the AMR-included list are found at a specific location within the plant. For example, electrical cables or pipes tend to be extensive in number and routed all over the plant, with termination points at different locations within the plant.)

• The components have defined functions that are easily described in terms of their terminal voltages and currents.

• The performance of the components can be readily monitored as they perform their intended function. (In contrast, AMR-included components perform functions that are defined in terms of properties that cannot be easily monitored as the components perform their intended functions.)

• Except for batteries, each of these components transforms the input voltage and current to some other form and/or value of voltage and current.

• Functional degradation resulting from the effects of aging can be monitored online (i.e.,

while operating). (In contrast, AMR-included components have aging-related degradation of their passive intended functions that cannot be monitored online.) See 1995 License Renewal SOC at 22,472, 22,477-78 (NYS000016).

• If these components have a change in configuration or properties as they perform their intended function, then the changing properties clearly include the terminal voltages and currents, because these are the only properties that are defined in the functional description of the components. (Batteries have a change in chemical composition as well as a change in their terminal voltage.)

Q58. How do transformers compare on each of these points?

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A58. (SED) Like the electrical components without moving parts in the AMR-excluded list, transformers satisfy every point.

Q59. Please elaborate on that conclusion.

A59. (SED) The parallels between a transformer and a transistor further illustrate this point. Dr. Degeneff largely has described the operation of a transistor in terms of its resistivity. See Degeneff Testimony at 21-22, 25 (NYS000003); Degeneff Report at 8-10 (NYS000005). The resistivity to which he refers is a direct consequence of the electric fields inside the transistor that are created by the externally applied voltages and currents. In fact, such resistivity is defined as the electric field strength divided by the current density. Thus, any changing resistivity described by Dr. Degeneff is the result of a changing electric field.

Similarly, changes in the terminal voltages and currents of a transformer are a direct result of changes in the internal magnetic field. Transformers and transistors are very similar in that they both transform voltages and currents at their input to different voltages and currents at their output. In the case of a transistor, the transformation is performed by changing electric fields. In the case of a transformer, the transformation is performed by a changing magnetic field.

With the exception of batteries, all of the other AMR-excluded electrical components without moving parts listed in § 54.21(a)(1)(i) perform similarly. They transform the input voltage and current to some different value and/or convert between AC and DC. Since they have no moving parts, all such transformations are accomplished by changing electromagnetic fields within the components. I discuss this principle in greater detail below.

Q60. In response to the Boards inquiry, do you conclude that transformers are more similar to the AMR-excluded component examples listed in Section 54.21((a)(1)(i)?

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A60. (SED) Yes. Transformers are similar to the AMR-excluded components in that the terminal voltages and currents can be readily monitored and directly indicate the health of the component (e.g., the ability of the transformer to perform its intended function when fully loaded). The excluded list contains such items as motors, diesel generators, pressure transmitters, pressure indicators, transistors, batteries, breakers, relays, switches, power inverters, battery chargers, and power supplies. These items have properties that change or parts that move to perform the intended functions. These changes can be directly observed or monitored. The output fluid pressure of a pump, the output voltage and frequency of a diesel generator, the air pressure of a compressor, the output signal of a pressure indicator, the output voltage of a battery, the electrical output of a power supply, the position of a valve, and the status or condition of a relay all are readily monitored.

In contrast, the AMR-included component list contains such items as the reactor vessel, pressure-retaining boundaries, piping, component supports, valve bodies, penetrations, electrical cables, and electrical cabinets. These structures and components perform their intended functions without moving parts or a change in configuration or properties. A common characteristic of these items is that each ones ability to perform its intended function is not directly verifiable by monitoring moving parts or a change in configuration or properties.

Instead, indirect measurements, tests, and observations are used to predict degradation of the item based on an analysis of this secondary information. For example, the ability of a pipe to perform its intended function is monitored indirectly by measuring the thickness of the pipes wall and inspecting it for signs of corrosion (because monitoring fluid pressure alone is not necessarily indicative of the pipes ability to perform its intended function at higher pressures if, for example, unacceptable wall thinning has occurred in the pipe).

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In summary, transformers are similar to other electrical components in the AMR-excluded list because their terminal voltages and currents, which are properties of the components, change as the components perform their intended function (i.e., transformation of the input voltage and current to some other form and/or value of voltage and current) and can be directly measured and monitored. Figure 2 illustrates the foregoing concepts and why transformers belong on the AMR-excluded component list.

Figure 2. Comparison of Transformers to AMR-Included and AMR-Excluded Components 43

Q61. Do differences in the construction details of the components discussed above affect whether they are excluded from AMR under Part 54?

A61. (SED) No. None of the components listed as excluded from AMR in 10 C.F.R.

§ 54.21(a)(1)(i)including power inverters, circuit boards, battery chargers, and power supplieswas excluded based on any construction detail. Since no construction details are provided for any component identified in the list (10 C.F.R. § 54.21(a)(1)(i); 1995 License Renewal SOC at 22,477), I conclude that none of those components was excluded from AMR due to its construction details. From an electrical engineering perspective, the only thing common to all of these electrical components is that each has electrical properties or configurations that change as the component performs its intended function, and which can be directly measured or observed.

For example, all we need to know about a power supply are the requirements for the input and output voltages and currents. From an AMR classification perspective, any other details are irrelevant. Once the required terminal properties are known, we can directly monitor those properties to determine if the power supply is performing its required function.

Consider another example. The only thing known about a generic circuit board is that it has electrical terminals. It is listed as an AMR-excluded component without any restrictions.

Circuit boards also have terminal voltages and currents that are properties of the circuit board and change as the circuit board performs its intended function.

The Commissions inclusion of power inverters, circuit boards, battery chargers, power supplies in the AMR-excluded list without any additional details (construction or otherwise) further reinforces the conclusion that terminal voltages and currents must be considered 44

properties of these components. Otherwise, we are left with no identifiable changing property to explain their inclusion in the list of AMR-excluded components in 10 C.F.R. § 54.21(a)(1)(i).

Q62. In your opinion, are the construction details of a transistor, an AMR-excluded component that Dr. Degeneff tries to distinguish from a transformer, relevant to its classification under 10 C.F.R. § 54.21(a)(1)(i)?

A62. (SED) No. Most electrical engineers trying to use a transistor in a circuit are concerned with how the transistor affects the circuits they are designingnot with the details of its construction. In fact, they may treat the transistor as a black box. See IEEE Std 100-1996, The IEEE Standard Dictionary of Electrical and Electronic Terms at 95 (6th Ed. 1996)

(ENT000106) (defining black box and black box model); L.O. Chua, Introduction to Nonlinear Network Theory at 6-18, 28-30, 35-38, 40 (1969) (ENT000107). Using a black box also is referred to as port theory. A port is a set of input or output terminals. See id. at 793.

In port theory, the engineer places something in a box that has a specified number of ports and then tries to describe what is in the box in terms of what happens at the ports.

Transistors are three-terminal devices that are handled by a box having two ports consisting of a set of input terminals and a set of output terminals. Since the box has only two ports and the transistor has three leads, one transistor lead is common to one input lead and one output lead, as illustrated in Figure 3 below.

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Figure 3. Illustration of Black Box Model/Port Theory Using a Transistor Once the transistor is in the box, the port terminals are excited and measured in various ways to allow collection of information on how the box reacts to different conditions. This information is then used to build a model of what is in the box. Such a model uses standard ideal electrical engineering components, which are assigned values based on the analysis of the data obtained from the box. Three such models for transistors are the h-parameter model, the y-parameter model, and the hybrid model.

All transistor circuit design and analysis use models such as those identified above. From an engineering standpoint, it does not matter what is inside the box or how it accomplishes its task. All that matters is the voltage-current response at the terminals. I purposely used the hyphenated terminology voltage-current response because these two quantities are very closely linked, and the manner in which they are linked is determined by the device being used.

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Q63. Please explain how the terminal voltages and currents are linked.

A63. (SED) The best way to explain this linkage is with a basic example. Consider a diode, which is a device that rectifies signals (i.e., passes current in only one direction). Figure 3 shows the voltage-current (V-I) characteristic for a typical diode.

Figure 4. V-I Characteristic for a Typical Diode Although the V-I characteristic will vary slightly depending upon environmental conditions such as temperature, for purposes of illustration, it can be considered to be fixed and unchanging.

The V-I characteristic is the primary source of information needed to use a diode in a circuit. It defines the voltage and current response at the diode terminals for varying circuit conditions. Since it defines operation of the diode, it must be considered to be a property of the diode, but it does not change during diode operation.

The terminal voltages and currents do change during diode operation. As the voltage across the diode changes, the current changes as determined by the curve above. For example, when a voltage of V1 is present across the diode, the diode is at P1 on its curve, a current of I1 is 47

present, and the diode is in its ON state; i.e., current flows. When a voltage of V2, which is negative, is present across the diode, the diode is at P2 on its curve, the current of I2 is essentially zero, and the diode is in its OFF state; i.e., no current flows.

The V-I characteristic is inherent to the diode, is a property of the diode, and does not change during diode operation. The changes that do occur during diode operation are the actual voltages and currents that appear at the terminals. These voltages and currents are bound together by the V-I characteristic of the diode, such that they must change as defined by this curve. Because the terminal voltages and currents are inherently linked in this manner, they are properties of the diode. Monitoring the terminal voltages and currents of the diode can determine if the diode is operating properly. If the voltage and current measurements follow the curve, then the diode is performing properly. If the measurements depart from the expected curve, then the diode is defective. Thus, the terminal voltages and currents of a diode provide a direct measure of the health of the diode.

Transistor operation is much more complicated, but again, the transistors V-I characteristics do not change during its operation. Instead, they define the relationship between the terminal voltages and currents, which do change. Just like the diode, both the V-I characteristics of the transistor and the terminal voltages and currents that appear during its operation are inseparable from the transistor and thus are properties of the device.

A very good discussion of black boxes and terminal characteristics is provided in the first three chapters of L.O. Chua, Introduction to Nonlinear Network Theory (1969) (ENT000107).

Tables 1-1, 2-1, 3-1, and Appendix D give many examples of V-I characteristic curves for common electrical components. See id. at 20-22, 64-65, 100-01, 943-57.

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Q64. How does the V-I characteristic concept apply to a transformer?

A64. (SED) One terminal characteristic of an ideal transformer is defined by the turns ratio. If the secondary voltage is plotted as a function of the primary voltage for a range of primary voltages, then the resulting graph would be a straight line having a slope equal to the turns ratio. This would be a V-V characteristic. It is the simplest transformer terminal characteristic to understand. The transformer will also have V-I characteristics at each set of terminals. For a discussion of one method of modeling a transformer by using its terminal characteristics, see Degeneff et al., A Method for Constructing Reduced Order Transformer Models for System Studies from Detailed Lumped Parameter Models at 532-38 (1991)

(ENT000109). Like a diode, the terminal characteristic of this ideal transformer does not change during operation; rather, it is the primary and secondary terminal voltages that change. As with a diode, correct operation can be determined by checking to see if the measured primary and secondary voltages at any instant in time result in a point defined by the characteristic turns ratio graph.

VIII. REBUTTAL TO NYSS CLAIM THAT TRANSFORMERS ARE PASSIVE DEVICES SUBJECT TO PART 54 AGING MANAGEMENT REVIEW A. The Definitions of Static and Passive Relied on By NYS Are Not Applicable to the Classification of Components Under 10 C.F.R. §54.21(a)(1)

Q65. Dr. Degeneff asserts that transformers are static or passive devices and, claims that every authority he has reviewed characterizes transformers as such.

Degeneff Testimony at 6-12, 28, 42; Degeneff Report at 1-3, 23, 26, 30, 32. Are the definitions of static and passive cited by Dr. Degeneff applicable here?

A65. (SED) No. Dr. Degeneff relies on the following authorities in asserting that transformers are static or passive devices:

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• L.F. Blume, General Electric Co., Transformer Engineering (2d ed. 1951)

(NYS000006)

• W.F. Flanagan, Handbook of Transformer Design and Application (2d ed. 1993)

(NYS000007)

• J.H. Harlow, Electric Power Transformer Engineering (2004) (NYS000008)

• J.H. Harlow, Electric Power Transformer Engineering (2d ed. 2007) (NYS000009)

• IEEE, IEEE Std 100-1996, The IEEE Standard Dictionary of Electrical and Electronic Terms (6th Ed. 1996) (IEEE Std 100-1996) (NYS000010)

• IEEE, IEEE Std C57.12.80TM-2010, Standard Terminology for Power and Distribution Transformers (Sept. 30, 2010) (NYSR00011)

As evident from their titles, all of the cited documents identify standards that concern general transformer engineering principles or electrical terms used within the electrical engineering community. None of the cited documents is germane to NRC regulation of nuclear power plants.

More specifically, none of the references relates to the application of 10 C.F.R.

§ 54.21(a)(1)(i) to transformers. Therefore, his reliance on those documents to define transformers as static or passive components is fundamentally misplaced. First, Dr.

Degeneff incorrectly conflates the terms static and passive. See, e.g., Degeneff Testimony at 8:19-20 (Transformers are passive, or static, devices, the properties of which do not change during operation.). However, the term static is not used anywhere in § 54.21(a)(1)(i) or in the 1995 License Renewal SOC.

Second, without citing technical or regulatory basis, Dr. Degeneff equates the electrical engineering communitys definitions of those terms with the Commissions Part 54 concept of a passive component. For example, he states: The transformer is a static device as defined by the IEEE and its Transformers Committee. A transformer does not change its configuration nor its 50

properties when it is performing its intended operation. Degeneff Testimony at 42:12-16.

However, the IEEE defines the terms transformer, static, and passive device as follows:

transformer (2) (power and distribution transformers) A static electric device consisting of a winding, or two or more coupled windings, with or without a magnetic core, for introducing mutual coupling between electric circuits. Transformers are extensively used in electric power systems to transfer power by electromagnetic induction between circuits at the same frequency, usually with changed values of voltage and current. IEEE Std 100-1996 at 1131 (ENT000106).

static (2) (adjective) (automatic control) Referring to a state in which a quantity exhibits no appreciable change within an arbitrarily long time interval. Id. at 1041.

passive device A device that does not require power and contains no active components. The term encompasses taps, directional couplers, splitters, power inserters, and in-line equalizers. Id. at 750.

None of these definitions resembles the language used in § 54.21(a)(1)(i) or is relevant to the classification of electrical components under that regulation as subject to, or not subject to, aging management review. Nor do they resemble the language used by the Commission in the 1995 License Renewal SOC to describe passive functions or components for purposes of Part 54:

• For passive functions, the relationship between the measurable parameters and the required function is less directly verified. Passive functions such as pressure boundary and structural integrity are generally verified indirectly, by confirmation of physical dimensions or component physical condition. 1995 License Renewal SOC at 22, 471.

• The Commission has determined that passive structures and components for which aging degradation is not readily monitored are those that perform an intended function without moving parts or without a change in configuration or properties. Id. at 22,477.

In the 1995 License Renewal SOC, the Commission expressly distinguished between conventional industry concepts of passive structures and components and the Part 54 description of passive characteristics of structures and components, noting that the latter is specific to the Part 54 integrated plant assessment process:

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The Commission has reviewed several industry concepts of passive structures and components and has determined that they do not accurately describe the structures and components that should be subject to an aging management review for license renewal. Accordingly, the Commission has developed a description of passive characteristics of structures and components.

Furthermore, the Commission has directly incorporated these characteristics into the IPA process to avoid the creation of a new term, passive. This SOC uses the term passive for convenience.

1995 License Renewal SOC at 22,477 (emphasis added) (NYS000016). The Commission stated that the description of passive structures and components incorporated into Section 54.21(a) should be used only in connection with the [integrated plant assessment] review in the license renewal process. Id. The definitions of static and passive that Dr. Degeneff has taken from various electrical engineering references cannot be equated with passive as that term is used in connection with § 54.21 and defined in the 1995 License Renewal SOC. Thus, NYSs use of the term passive is imprecise and ignores explicit Commission statements directly relevant to this issue.

Q66. Have you reviewed the various references cited by Dr. Degeneff in support of the claim that transformers are passive or static components?

A66. (SED) Yes.

Q67. Do you have any additional comments concerning Dr. Degeneffs use of those references?

A67. (SED) Yes. Relevance aside, Dr. Degeneffs use of these references in his testimony is imprecise and self-contradictory. For example, Dr. Degeneff quotes the 6th Edition of the IEEE Standard Dictionary of Electrical and Electronic Terms definition of a transformer, which refers to a transformer as a static electrical device. IEEE Std 100-1996, at 1131 (ENT000106). However, the only applicable definition of static provided by that same 52

reference states: Referring to a state in which a quantity exhibits no appreciable change within an arbitrarily long time interval. Id. at 1041.

The IEEE definition of static in the reference cited by Dr. Degeneff to define a transformer does not focus on changes in the electromagnetic properties of the component as it performs its function (the relevant inquiry under Part 54). This fact is evident in other IEEE definitions:

battery charger As defined in IEEE Std 602-1996, static equipment that is capable of restoring and maintaining the charge in a storage battery. IEEE Std 100-1996, at 82 (emphasis added).

static converter (electric installations on shipboard) A unit that employs static rectifier devices such as semiconductor rectifiers or controlled rectifiers (thyristors) transistors, electron tubes, or magnetic amplifiers to change ac power to dc power or vice-versa. IEEE Std 100-1996, at 1041 (emphasis added).

The IEEE dictionary cited by Dr. Degeneff that describes transformers as static, also classifies semiconductor diodes, thyristors, transistors, electron tubes, magnetic amplifiers, and battery chargers as static components. As noted above, however, transistors and battery chargers are expressly excluded from AMR by NRC regulation. Further compounding this error, Dr.

Degeneff later refers to transistors and other active devices like electric tubes, magnetic amplifiers, breakers. Degeneff Report at 12 (emphasis added). These are the very items that the IEEE dictionary cited by Dr. Degeneff describes as static devices.

In short, any part of Dr. Degeneffs testimony that makes use of the term static should be disregarded as irrelevant and unreliable. Dr. Degeneffs testimony is irrelevant because the IEEE dictionary definition of static is not interchangeable with the Part 54 concept of passive. His testimony is unreliable because it contains statements that are plainly inconsistent with 10 C.F.R. § 54.21(a)(1)(i) and the AMR component classifications therein. Accordingly, 53

there is no relevance to his claim that [t]he uncontroversial consensus of the technical community is that transformers are static components. Degeneff Report at 1.

B. Dr. Degeneffs Claim That Voltage, Current, and Magnetic Field Are Not Properties of a Transformer Lacks a Technical Foundation Q68. Dr. Degeneff asserts that a transformers terminal voltages and current and magnetic field are not properties of a transformer. See Degeneff Testimony at 10-11. Do you agree?

A68. (SED) No. Dr. Degeneffs testimony on this point contains technical flaws and internal inconsistencies. First, the terminal voltages and currents of electrical components (i.e.,

characteristics, characteristic curves or terminal characteristics) are universally accepted in electrical engineering as properties of the components. It is not possible to describe operation of electrical components without referring to their terminal voltages and currents. Electrical engineers use of the term characteristics instead of properties does not alter this fact. As noted previously, a very good discussion of the use of terminal characteristics to define electrical components is provided in the text by L.O. Chua, Introduction to Nonlinear Network Theory (1969) (ENT000107). Tables 1-1, 2-1, 3-1, and Appendix D give many examples of characteristic curves for common electrical components. See id. at 20-22, 64-65, 100-01, 943-

57. Although most college texts on electric circuit theory and electronics do not provide such a detailed discussion of terminal characteristics, all use the concepts discussed by Chua.

Furthermore, manufacturers of electrical components usually provide data sheets that describe operation of their components via characteristic curves.

Second, terminal voltages and currents are properties of electrical components because they provide a complete understanding of how the component performs in a circuit. Again, only 54

the terminal properties of electrical components are used to perform circuit design or analysisa fact that can be verified by looking at any college textbook on circuit theory.

Third, all terminal voltages and currents of a transformer are tied to the magnetic flux inside the transformer. See Declaration of Steven E. Dobbs in Support of Entergy's Motion for Summary Disposition of New York State Contention 8 at 2-7 (Aug. 2009) (ENT000108). The magnetic flux of a transformer must be considered a property of the transformer because there is no transformer operation without it.

Q69. Dr. Degeneff also asserts that a transformer does not change its configuration or properties during its intended use. Degeneff Report at 25. Do you agree?

A69. (SED) No. In Section VI.A above, I explained how the magnetic field and terminal voltage and current properties of a transformer change during its operation. It suffices to say that, while Dr. Degeneff asserts otherwise, he implicitly acknowledges that the terminal currents, voltages, and the magnetic field all are properties of a transformer, because he is unable to describe transformer operation without referring to these properties. For example, in defining a transformer and describing its operation, Dr. Degeneff states:

Transformers perform their current and voltage transformation through a phenomenon known as electromagnetism, e.g., when an electric current passes through a wire (or cable or conductor), a magnetic field is generated around that wire. When that generated magnetic field touches (or links) another current carrying conductor, a voltage is generated across the second conductor. If the second conductor is connected so that current can flow, electric power is transformed from the first conductor to the second conductor.

Degeneff Report at 2 (emphasis added); see also Degeneff Testimony at 8. Thus, in describing transformer operation, Dr. Degeneff refers to properties that define a transformer:

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1. The terminal voltages and currents. The terminal voltage and current at the input are transformed to different values of voltage and current at the output.

2. The internal magnetic field. It is the operation of this field on the wire coils that performs the described transformations.

In fact, Dr. Degeneffs description of transformer operation resembles that contained in EPRIs License Renewal Electrical Handbook and quoted in Answer 32 above, in which EPRI concludes that a transformer performs its intended function through a change in its physical properties.

EPRI 1013475, App. B at B-9 (The passing current changes the physical properties of the transformer in a way that causes a voltage to be induced in the terminals of the separate winding.).

Dr. Degeneffs description of transformer operation recognizes that the terminal voltages and currents and the internal magnetic field of a transformer change as it operates. It also is worth noting that another NYS consultant, Mr. Blanch, previously described transformers as having design properties such as turns ratios, current, voltage, and power, and explicitly referred to the terminal voltages and currents and the changing magnetic field of transformer in describing its operation. Sept. 2009 Blanch Decl. ¶¶ 16-18 (ENT000096).

I also have reviewed technical papers authored by Dr. Degeneff. At least one of those papers recognizes that a transformer has properties relating to its terminal voltages and currents.

See R.C. Degeneff et al., A Method for Constructing Reduced Order Transformer Models for System Studies from Detailed Lumped Parameter Models at 532-38 (1991) (presented at the IEEE Transmission and Distribution 1991 International Conference) (ENT000109). That paper states:

• Reduced order models for utility system studies are either constructed from terminal characteristics or by greatly simplifying the detailed model obtained from the transformer design study. Id. at 532.

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• Preliminary results suggest that the transient voltages at the terminals of a transformer in the field are, in some measure, a function of the impedance characteristic of the transformer itself. Id.

• By definition, the zeros of the terminal impedance function coincide with the natural frequencies of the circuit. Id. at 533.

• The reduced model must essentially contain the same poles and zeros in its terminal impedance and transfer functions as the complete model. Id.

In the first statement, Dr. Degeneff refers to terminal characteristics. By definition, a characteristic is a distinguishing trait, quality, or property. In the other statements, he refers to impedance characteristic and terminal impedance function. Terminal impedance is defined as the voltage divided by the current at the terminals and reflects the opposition offered to the flow of an alternating current. Thus, in one of his own papers, Dr. Degeneff discusses how transformers can be modeled using the terminal voltage and current properties. Dr. Degeneff's testimony for NYS is in direct conflict with what he presents in this paper.

Q70. What attributes does Dr. Degeneff deem to be properties of a transformer in his testimony and report?

A70. (SED) Dr. Degeneffs testimony on the subject of transformer properties varies considerably, highlighting the technical flaws and inconsistencies in his position. These shortfalls result principally from his failure to apply the definition of property uniformly. As a result, Dr. Degeneff defines the following items as properties of a transformer: turns ratio; windings; conductor size; insulation type; insulation thickness; cooling capability; winding number; winding location; size, weight, and nature of core material; and dimensions of the turns.

Degeneff Report at 3, 24.

While many of the attributes cited by Dr. Degeneff (e.g., insulation type, core material) may be attributes of a given transformers design, they cannot be properties used to classify 57

transformers because they may vary between different transformers. One example is shown in Figure 3 below. Imagine that the two items are built to identical specifications. The only difference is that the first one has external terminals that allow it to have terminal voltages, terminal currents, and an internal magnetic field. The second item has its windings connected together so that it has no external terminals. Without terminals, it can have no voltages, no currents, and no magnetic field and, consequently, is not a transformer.

Figure 5. Transformer Properties: Terminal Voltages and Currents and Magnetic Field This example shows that the transformer properties cited by Dr. Degeneff are not consistent with the definition of property stated in Answer 46 above, i.e., a characteristic trait or peculiarity, especially one serving to define or describe its possessor.

Thus, Dr. Degeneffs list omits the most important properties of a transformer, i.e., the terminal properties. Terminal properties include such things as the input voltage and current characteristics, the output voltage and current characteristics, and power rating information. The transformer attributes listed by NYS are all reflected in the transformers terminal properties.

Dr. Degeneff suggests that the cited attributes are design properties that do not change during transformer operation. See Degeneff Report at 3, 23. His statement is irrelevant.

Electrical engineers generally use the terminal characteristics (i.e., properties) of the transformer 58

when specifying a transformer for an application or analyzing transformer performance in a circuit. Indeed, the terminal characteristics are used universally to specify operation of electronic components, including other AMR-excluded components such as transistors and circuit boards.

Q71. In claiming that the key property of any transformer is its turns ratio (Degeneff Testimony at 9), does Dr. Degeneff adequately discuss the relationship between the turns ratio of a transformer and its terminal voltages and currents?

A71. (SED) No, he does not. Although I agree that the turns ratio is a property of a transformer for the reasons discussed in Section VI.B above, I do not agree that the turns ratio is the key property of a transformer. If the primary terminals of an ideal transformer are excited with an appropriate ac voltage and the voltage that appears at the secondary terminals is measured, then the ratio VOUT / VIN = VS / VP = NS / NP is the turns ratio of the transformer by definition. VP is the voltage applied to the primary coil and VS is the voltage created at the terminals of the secondary winding. NS is the number of turns in the secondary winding and NP is the number of turns in the primary winding. See Figure 1, supra. Thus, if the key turns ratio property of a transformer is defined in terms of the terminal voltages, then the defining voltages clearly also must be key properties of the transformer.

In his report, Dr. Degeneff emphatically states: Input and output voltages are not properties of the transformer itself. The turns ratio is a property of the transformer and it does not change in normal use. Degeneff Report at 25. But in the reports introduction he states:

The turns ratio (ratio of the turns contained in the input winding divided by the turns in the output winding) may be taken as the voltage transformation ratio between the input and output winding and the inverse of the current transformation ratio.

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Id. at 1. Dr. Degeneffs inconsistent statements beg several questions. How can the turns ratio be a property of the transformer and the voltage transformation ratio not be a property, if they are as closely related as Dr. Degeneff claims? Dr. Degeneff also states that the number of windings (which defines the turns ratio) is a property. Why then are the terminal voltages, which define the voltage transformation ratio, not properties? The same can be said for the current transformation ratio. The only correct answer to these questions is that the terminal voltages and currents of a transformer are properties of the transformer.

Q72. Dr. Degeneff accuses Entergy of incorrectly conflating the properties of a transformer and the properties of the power being transformed (i.e., voltage and current) by a transformer. Degeneff Testimony at 10. What is your response to that assertion?

A72. (SED) I do not agree. It is Dr. Degeneff who erroneously asserts that voltage and current are properties of: (1) electricity, (2) power, and (3) source and load. Below, I will address each of his erroneous assertions, all of which stem from Dr. Degeneffs imprecise and inconsistent use of the term property. I also will address several corollary arguments by Dr.

Degeneff that are similarly flawed.

Q73. Lets begin with Dr. Degeneffs assertion that voltage and current are properties of the electricity flowing through a transformer, not the transformer itself. See Degeneff Testimony at 10. Why is that statement incorrect?

A73. (SED) I have previously explained in response to Question 52 why voltage and current are not properties of electricity. In brief, electricity is charge. It has no voltage or current unless it is acted on by some external force. Possible outside forces include loads and sources. In the case of a transformer, it is both a load and a source.

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For example, consider a circuit consisting of a generator, a transformer, and a load. The generator creates voltage and current by mechanically separating charge using a rotating magnetic field. The generator is connected to the primary winding of the transformer. Charge flows out of the generator to the transformer and through the primary winding. Thus, the primary winding of a transformer is a load to the generator. The primary winding resists the flow of charge from the generator causing charge to pile up at one input terminal, thus creating voltage at the input. The varying magnetic field inside the transformer core forces charge separation in the secondary winding creating a voltage at the output terminals of the transformer.

The voltage at the secondary winding causes charge to flow through the load connected to the secondary winding. Thus, the secondary winding of the transformer is a source. The load connected to the secondary winding resists the flow of charge so as to create a voltage at its terminals.

This example illustrates how voltages and currents are created by the sources and loads in a circuit. Without such outside forces, voltage and current would not exist. In this example, the generator is the origin of all the voltage and current in the circuit. If the transformer or the load is removed and replaced with another unit, then some voltages and currents in the circuit will also change. If the original transformer and load are restored, the original voltages and currents will return. The voltages and currents in the circuit described above follow the components, not the source of electricity. Therefore, the terminal voltages and currents of the transformer are properties of the transformer, not properties of the charge passing through it.

Q74. What is your response to Dr. Degeneffs statement that voltage and current are also properties of the power being transformed? Degeneff Testimony at 10.

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A74. (SED) He is incorrect. In fact, Dr. Degeneffs statement gives rise to a logical conundrum. In simple terms, electrical power is defined by the equation: Power = (Voltage) x (Current). If we accept that voltage and current are properties of power because they define power, then we also must accept that the terminal voltages of a transformer are properties of the transformer, because the turns ratio of an ideal transformer is defined as: Turns Ratio = VS / VP.

In any case, voltage and current are not properties of power. Power is not a physical object. It is a mathematical concept defined by the following equation:

Power = Work/Time, where Work = Force x Distance.

Voltage and current are not characteristics peculiar to power. There are many types of power that have nothing to do with electricity (e.g., a gasoline engine). In a nuclear power plant, nuclear fission produces heat and the heat boils water to produce steam. The steam performs work by pushing on turbine blades to produce rotational power. This rotational power then turns a generator to produce electrical power. Since power is present in this sequence long before voltage and current are present, it is obvious that power exists without voltage or current.

Voltage and current are not characteristics peculiar to power. In contrast, terminal voltages and currents in a transformer are peculiar to (and properties of) a transformer.

Q75. Dr. Degeneff also states that [v]oltage and current are not properties of the transformer, but rather are properties of the source of power being supplied to the transformer and of the load being served. Degeneff Report at 24. Is his statement valid?

A75. (SED) No. In Section VI.B above, I explained why voltage and current are not properties of electricity or the source of that electricity. I will further address this point here.

Consider the circuit shown in Figure 6 below.

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Figure 6. Circuit In Which Transformer Acts as Both Electrical Source and Load At first, the AC source is active and all switches are open as shown. The AC source is generating an ac voltage of VS, but IS is zero because Switch 1 is open. When Switch 1 is closed, Transformer 1 becomes the load on the AC source and IS becomes a value other than zero. The value of IS is determined entirely by how much current the transformer demands at the applied voltage to establish its internal magnetic field; that is, IS is the magnetization current of the transformer. When the switch is first closed, VS may dip because the AC source is supplying current. Depending on how well that source is regulated, it may or may not return to the same value as before Switch 1 was closed.

When Switch 2 is closed, the circuit undergoes more changes. Now Transformer 1 is supplying power to Transformer 2. Thus, Transformer 1 has become a power source while Transformer 2 is a power load. Now I1 OUT = I2 IN and is equal to the magnetization current of Transformer 2. IS is now at a value that reflects the magnetization currents of both transformers.

Again Vs, as well as V1 IN and V1 OUT, may have been affected.

When Switch 3 is closed, still more changes occur. IL becomes nonzero. This additional current demand causes all other currents in the circuit to increase. All voltages may change as well. These voltage and current values might be thought of as negotiated values, as all of the 63

currents and voltages within the circuit are interrelated. If any single value changes, then all values will change as demanded by the terminal properties of the components.

This circuit example demonstrates that transformers act as both electrical sources and loads. Thus, Dr. Degeneffs statement, Voltage and current . . . are properties of the source of power being supplied . . . and of the load being served, confirms that voltage and current are indeed properties of a transformer. Degeneff Report at 24.

Q76. Dr. Dobbs, in Answer 72 above, you referred to several corollary arguments made by Dr. Degeneff in his testimony and report. Can you address those arguments?

A76. (SED) Certainly. First, Dr. Degeneff states that [b]oth the input voltage and the load served are completely independent of the design and characteristics of the transformer.

Degeneff Report at 25. This statement is obviously flawed. If the input voltage and load are independent of the design of the transformer, then the design of the transformer must be independent of the source and load. This means that any transformer will work in any application. This is not true. Each application requires that a transformer with appropriate design characteristics be chosen. Since this statement is flawed, it does not support any conclusion.

Second, Dr. Degeneff asserts that the flux of the magnetic field produced in [a]

transformer is a product of the power supplied to the transformer. Degeneff Testimony at 10:15-16. That statement is correct, but it does not change the facts that: (1) the magnetic field varies as the transformer performs its intended function, and (2) the effects of that changing magnetic field are readily monitored at the terminals of the transformer. To put this statement in perspective, consider another true statement: The electric fields produced in the transistor are a 64

function of the power supplied to the transistor. If Dr. Degeneffs statement were assumed to support the conclusion that a transformer should be subject to AMR, then the same conclusion should apply to a transistor. However, 10 C.F.R. § 54.21(a)(1)(i) excludes transistors (among other components) from aging management review. Thus, Dr. Degeneffs argument fails to demonstrate that the magnetic field is not a property of a transformer.

Third, Dr. Degeneff further testifies that [t]he flow of direct current will not produce a magnetic flux with the desired properties, and the coils and the core do not produce a magnetic field on their own when there is no incoming electrical current at all. Degeneff Testimony at 10:18-22. He then opines that [e]verything is dependent on the properties of the power, e.g., its magnitude and frequency, supplied by an external source. Id. at 10:22-11:2. Again, Dr.

Degeneff tries to assign properties to power, but the properties listed are terminal properties of the power sourcenot the power itself. The only relevant point he makes is that transformer operation requires an appropriate source of power. The same is true of a transistor, a power inverter, a circuit board, or a battery chargerother active components that the Commission excluded from AMR in § 54.21(a)(1)(i).

C. Dr. Degeneffs Comparisons of Transformers to AMR-Included Components Are Technically Flawed and Unreliable

1. Electric Cables Q77. Dr. Degeneff states that [t]he physical laws that describe how the magnetic field is developed around a cable are exactly the same physical laws that describe how a magnetic field is developed in a transformer. Degeneff Report at 7. Do you agree?

A77. (SED) I agree with Dr. Degeneffs statement only to the extent that electrical phenomena are described by Maxwells equations, which underlie electromagnetic theory and provide a basic description of all electromagnetic interactions. But I disagree with Dr.

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Degeneffs broad-brush analogy between electrical cables and transformers, and the implication that both should be classified as passive components under 10 C.F.R. Part 54. The fallacy in Dr.

Degeneffs logic is identified by the diagrams in Figure 7 below, which show three ways in which two cables running through the plant might run parallel to one another.

Figure 7. Comparison of Cable Configurations to a Transformer Configuration 1 Configuration 2 66

Configuration 3 Transformer Diagram Supplied by Dr. Degeneff Only Configuration 3 remotely resembles the configuration of a transformer (as shown by Dr. Degeneffs own illustration). However, if such a configuration were attempted at the normal power plant operating frequency of 60 hertz (Hz), the source and load would be shorted out due to insufficient inductance in the cable, tripping a breaker, or destroying the source. Further, no power plant cable is connected to a load as shown in Configuration 3, because the load would not have voltage or current of sufficient magnitude to operate. Power plant cables are routed in a way that minimizes such magnetic coupling. Any electromagnetic coupling between power cables is referred to as crosstalk or noise and is undesirable.

In contrast, the magnetic coupling in a transformer is maximized by design and transfers considerable power from the primary winding to the secondary winding. Dr. Degeneffs example, therefore, is not valid. Two wires or cables in proximity to one another do not constitute a transformer in form or operation.

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Also, if we take Dr. Degeneffs argument to its logical extreme, we end up with incongruous results. For example, if Dr. Degeneffs description is taken to be accurate, then a circuit board transformer of the type shown in Figure 8 below is possible.

Figure 8. Circuit Board Transformer (Based on Dr. Degeneffs Statement: Two wires or cables in proximity will also act as a transformer in that varying current in one wire or conductor will induce voltages and currents in the adjacent wire or conductor.)

Like Configuration 3 above, the circuit board transformer pictured in Figure 8 above would provide dead shorts to both the source and the load at the normal power plant operating frequency of 60 Hz. However, using available planar magnetic design and construction techniques (e.g., windings that are integrated into printed circuit-boards, or PCBs), it is possible to design a circuit board transformer, like that shown in exhibit ENT000110, which could successfully operate at higher frequencies. See Ferroxcube, Design of Planar Power Transformers (May 1997), available at http://www.ferroxcube.com/appl/info/plandesi.pdf (ENT000110). But such a device would be excluded from AMR under Part 54 because it is a circuit board. This further illustrates that Dr. Degeneffs analogy between electrical cables and transformers is overly simplistic, incorrect, and technically unsupported.

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2. Pipes Q78. Dr. Degeneff also compares a transformer to pipe carrying a liquid. He states, in part: Voltage and current are no more properties of the transformer than water pressure is a property of a pipe that is carrying the liquid. Degeneff Report at 26. Does this analogy have merit?

A78. (SED) No. In short, Dr. Degeneffs argument is based on the erroneous notions that pressure and flow are properties of water (or other fluids) and, similarly, that voltage and current are properties of electricity. As I explained above, pressure and flow are not properties of water; they result from outside forces acting on the water. Similarly, electricity is charge. It has no voltage or current unless it is acted on by some outside force.

Dr. Degeneffs arguments violate well-known and settled principles of fluid mechanics.

As excerpted from his testimony and report, Dr. Degeneff states as follows:

Like the voltage of the power flowing through a transformer, the properties of fluids contained within a pipe can change. Yet, a pipe itself is a component which is included within the scope of § 54.21(a). A pipes diameter may narrow at a particular location or the pipe may contain a restriction (e.g., elbow or tee) that may change the velocity and/or pressure of the fluid contained in the pipe; however, the properties of the pipe itself have not changed. Stated differently, the properties of the contents of the pipe (a fluid) may change, but not the conduit (pipe). The pipe itself is not designed to change its own properties. In fact, if the pipes properties changed it would present significant engineering and design problems. For example, when a fluid passes through a pipe with a constriction, the amount of fluid that passes through the pipe is constant. The pressure of the fluid will change at the constriction, but the pipe remains invariant, its properties and characteristics unchanged. This is exactly the same situation with transformers, in that power merely passes through a transformer.

Degeneff Testimony at 18:19-19:17.

Lets consider the example posited by Dr. Degeneff. Figure 9 below shows a section of pipe carrying water that starts at a larger diameter and then narrows to a smaller diameter at 69

some point (i.e., a pipe nozzle). The pipe is supported so that its centerline is always at the same elevation.

Figure 9. Water Pressure and Velocity as Consequences of External Forces Exerted by Pipe In this case, a simplified form of Bernoullis equation applies to the water in the pipe and can be stated as:

P + (K

• V2) = constant The pressure (P) forcing the water down the pipe plus the velocity (V) of the water squared multiplied by a constant (K) remains at a constant value throughout the length of the pipe.

In this example, the water starts out in the larger diameter section of the pipe (shown by cross-sectional area A1) with a pressure P1 and a velocity V1. After it passes the reduction in pipe diameter, the water must have a new velocity (V2) because the same amount of water must flow in the smaller diameter area (cross-sectional area A2) as was flowing in the larger diameter area A2. Bernoullis equation stipulates that if the velocity of the water has changed, then its pressure must also have changed. A new pressure, P2, is required by the equation to keep the left side at a constant value after the change in velocity. Thus, the change in water pressure in the pipe is caused by a property of the pipeviz., the change in its diameter. According to accepted physical theory (Bernoullis equation), and contrary to Dr. Degeneffs claim, water pressure is 70

created by the force that causes the water to flow in the pipe, and is transformed by a change in the diameter of the pipenot by a property of the water itself. Pressure and velocity are not inherent in water, and thus are not properly considered properties of water.

For these reasons, Dr. Degeneffs repeated analogies to a pipe nozzle (a passive component) and a transformer (an active component) fail for lack of technical support. To assist the Board in understanding these key points, and to fully refute Dr. Degeneffs pipe nozzle analogy, I have prepared Figure 10 below. Figure 10 summarizes the fundamental differences between a pipe nozzle and a transformer for purposes of AMR classification under Part 54.

Figure 10. Direct Comparison of Pipe Nozzle and Transformer PIPE NOZZLE TRANSFORMER PIPE NOZZLE TRANSFORMER The pipe does not change in any way when it The magnetic field of the transformer changes performs its intended function. continuously when it performs its intended function.

The water that flows out at velocity V2 is the same The current that flows out when a transformer water that flowed in at velocity V1 when the pipe performs its intended function as IOUT is new performs its intended function. current that has been created by the magnetic field interacting with the secondary winding. IOUT contains no part of the current IIN.

The changes in the pressure and velocity of the The terminal voltages and currents of the fluid when the pipe performs its intended function transformer when it performs its intended function are due to the forces exerted on the fluid by the are a direct result of transformer action. All pipe. If pressure and flow are deemed to be terminal values depend on the terminal properties, then they must be properties of the pipe characteristics of the transformer, which themselves nozzle that changes them and not the fluid. depend upon the magnetic characteristics of the transformer and the changing magnetic field. Thus, 71

PIPE NOZZLE TRANSFORMER the terminal voltages and currents and the magnetic field are properties of the transformer that change during operation. It is the transformer that produces the change in voltage and current from the input to the output.

Regardless of any other function that piping might Transformers perform no function that is defined as perform, all piping within the scope of 54.4 passive by the 1995 License Renewal SOC.

operates as a pressure boundary, a function that is Instead, they transform voltage and current at the specifically defined as passive by the 1995 License primary terminals to different voltage and current at Renewal SOC (at 22,477) the secondary terminals. This function is very similar to the functions performed by other electrical components without moving parts that are in the AMR-excluded list in 10 C.F.R. § 54.21(a)(1)(i).

3. Heat Exchanger, Steam Generator, Reactor Vessel, and Containment Q79. Dr. Degeneff also states that changes in the temperature, flow rate, and state of fluids in a heat exchanger or steam generator are like the changes in voltage and current that occur during transformer operation? He also analogizes transformers to the reactor vessel and its containment. See Degeneff Report at 7-8. Are any of these comparisons valid?

A79. (SED) No. The fields of fluid dynamics and electromagnetism are two different scientific fields that are governed by different physical laws and described by different mathematical equations. Reliance on analogies between the two fields is prone to error, as I already have shown in my testimony.

Dr. Degeneff attempts to compare a transformer to a heat exchanger, steam generator, reactor vessel, and containment structure are factually deficient and unclear. The only clear aspect of any of these comparisons is a pattern of incorrectly equating transformers with 72

components that perform a known passive function. However, the 1995 License Renewal SOC explains why these components are considered to be passive and are included:

[T]he Commission considers structures and components meeting the passive description as including, but not limited to, the reactor vessel, the reactor coolant system pressure boundary, steam generators, the pressurizer, piping, pump casings, valve bodies, the core shroud, component supports, pressure retaining boundaries, heat exchangers .

1995 License Renewal SOC at 22,477, col. 2 (emphasis added) (NYS00016), and The Commission does not limit the consideration of pressure boundaries for an aging management review to only the reactor coolant pressure boundary. All pressure retaining boundaries necessary for the performance of the intended functions delineated in

§ 54.4 would be subject to an aging management review.

Id., col. 3 (emphasis added).

In summary, heat exchangers, steam generators, the reactor vessel, and containment all perform the passive function of providing a pressure retaining boundary. This fact is, in itself, sufficient cause for their being in the AMR-included list. Thus, no other aspect of these components is relevant to their classification, and any similarity of transformers to any of these components, real or imagined, is not relevant to the classification of transformers.

D. Dr. Degeneffs Purported Distinctions Between Transformers from Other AMR-Excluded Components Are Technically Flawed and Unreliable

1. Transistors Q80. What is a transistor, and how does it perform its intended function?

A80. (SED) In simple terms, a transistor is a three-terminal device usually made of a single piece of silicon. Silicon is a semiconductor in that it has a few electrons in the conduction band and other electrons that can be easily promoted into the conduction band by application of an electric field. The availability of electrons in the silicon can be modified by introducing various levels of impurities. The introduction of impurities is called doping.

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Operation of a transistor consists of applying external voltages to bias the transistor into the desired state. Biasing the transistor causes charge promotion and migration in the silicon so as to allow for control of the flow of current through the device. In many cases, a small amount of current in the input circuit can control a much larger current in the output circuit.

Q81. On what basis does Dr. Degeneff claim that transformers are unlike transistors?

A81. (SED) He distinguishes transistors from transformers by claiming that:

• A transistor is designed to change its resistivity, which is clearly a change in its properties and, in some cases, a change in state as from conductor to insulator. Degeneff Testimony at 21-22 (NYS000003).

• The transistor cannot change the properties of the power flowing through it unless it also changes its own resistivity. Id. at 21.

• The change in resistivity that occurs in the semiconductor device can be thought of as a valve whose position may be changed through an external electric stimulus. Id. at 21-22.

A small change in the voltage input to a basic transistor gate drive changes the properties (resistance and/or conductance) of the semiconductors main conducting path. Id. at 22.

• Nothing of this nature is present in a transformer, which performs its intended function without the need for an external control. Id.

Q82. Do you agree with Dr. Degeneffs reasoning?

A82. (SED) No. In fact, the change in resistivity described by Dr. Degeneff is directly-analogous to the change in the magnetic field inside a transformer. Resistivity can be defined as the ratio of the electric field and the current density. For transistors, one or both of these quantities are controlled by externally applied voltages and currents. As Dr. Degeneff explains, the resistivity in a transistor can be controlled by an external source, whereas the magnetism inside a transformer self-adjusts as the load changes. Specifically, transistors perform their function by internal electric fields that change with the external bias, the input signal, or the load demands. Transformers perform their function by an internal magnetic field 74

that changes with changes in the voltage and current supplied by the source and the current demand of the load. However, the changing resistivity of the transistor and the changing magnetism of the transformer are both created and observed at the electrical terminals of the components where the voltages and currents vary during operation. The fact that the magnetism inside a transformer changes without a separately controllable source in no way invalidates the fact that its electromagnetic properties change as it performs its intended function. Moreover, there is no requirement in 10 C.F.R. § 54.21(a)(1)(i) for electronics in the AMR-excluded list to respond to some secondary control signal.

Q83. Please summarize why you consider the changing magnetism in the core of a transformer analogous to the changing resistivity in a transistor, such that both components belong in the AMR-excluded group.

A83. (SED) In summary, the changing magnetism in the core of a transformer is analogous to the changing resistivity in a transistor for the following principal reasons.

• The changing magnetism and resistivity described are both driven by external electrical sources.

• Magnetism is the physical manifestation of a magnetic field. Resistivity is the physical manifestation of an electric field.

• Changing magnetism in a transformer and resistivity in a transistor are controlled from and visible at the terminals of their respective devices.

• Because of the interactions between the magnetism of a transformer and the resistivity of a transistor with the terminal voltages and current of those devices, the terminal voltages and currents also must be considered properties of both devices.

Q84. Dr. Degeneff also states (1) that a transformers physical characteristics are independent of the applied power, and (2) that a transformer does not change its properties during operation. Degeneff Testimony at 22-23. Do these statements support his conclusion that transformers are not similar to transistors for purposes of Part 54 AMR?

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A84. (SED) No. With regard to Dr. Degeneffs first point, the physical characteristics of a transistor similarly are independent of the applied power. The internal structure of a transistor is set at the time of construction and determines how it transforms the voltages and currents that are applied to it. Just as the turns ratio of a transformer does not vary during operation, the internal structure of a transistor does not vary during operation. The variables in both cases are the internal electromagnetic fields. The fields present in both components are totally dependent upon externally-applied voltages and currents and vary during operation, as is visible in their readily monitorable terminal voltages and currents.

With regard to the second point, a transformer does not change its structural attributes during operation. But neither does a transistor. However, the internal electromagnetic fields of transformers and transistors change during operation, and in both cases, the changes occur because of externally-applied voltages, currents, and loads. It is incorrect to state or imply that a transistor has the ability to unilaterally change its properties.

Q85. Dr. Degeneff states that [t]he example of a cable illustrates the difference between transformers and transistors. Degeneff Report at 9. Do you agree?

A85. (SED) No. Dr. Degeneffs states as follows:

If 100 volts are applied to two cables connected to a 50 ohm load, the current in the cables will be 2 amperes. If the voltage is increased to 150 volts, the current increases to 3 amperes, while if the voltage is reduced to 50 volts the current reduces to 1 ampere. In other words, both the transformer and the cable function in the same way. To suggest that the properties or state of the transformer change is incorrect. If one were to observe only the properties of the electricity flowing through either a one to one transformer or through two cables, the performance of the two devices would be indistinguishable.

Degeneff Report at 9. This example is incorrect. First, in this example, Dr. Degeneff restricts his comparison to a very special case. Specifically, he uses a transformer with a turns ratio of 76

one (i.e., an isolation transformer). Isolation transformers are used only in special applications.

If a turns ratio other than one were used, then it would be immediately obvious that a transformer performs much differently than two cables, because the voltage and current at the load would be markedly different than those at the source (which is not the case in a cable).

Second, Dr. Degeneffs assertion that the performance of the two devices would be indistinguishable is only true for the very specific case that he describes. Degeneff Report at 9.

Closer examination of the two configurations reveals that they are very different. Namely, if the 50 ohm load is removed from the two cables, then all current would cease to flow throughout the circuit. If the 50 ohm load is removed from the transformer circuit, then the magnetization current would continue to flow at the source end, while current would cease to flow at the load end. Other checks of the circuits, such as transient response, continuity, and inductance, all would yield very different results from the two configurations. This is another example where Dr. Degeneff uses a comparison that is irrelevant.

Third, Dr. Degeneffs statement that both the transformer and the cable function in the same way is false. Degeneff Report at 9. If the two configurations functioned in the same way, then all of the tests enumerated above would produce the same results for both configurations.

But it is clear that they would not.

In short, the particular example described by Dr. Degeneff is invalid, because he suggests that it can be extrapolated to support the (erroneous) conclusion that transformers are like cables.

In reality, the two components perform entirely different functions.

Q86. Dr. Degeneff also asserts that a transistor is distinguishable from a transformer because a transistor cannot perform its intended function without the 77

application of a control voltage. See Degeneff Report at 9. Does that matter for purposes of classifying the two component types under Part 54?

A86. (SED) No. The presence of a control voltage (controlling a large amount of power using a small amount of power), as cited by Dr. Degeneff, is irrelevant. Similarly, any argument that an electrical device must switch large currents, change/amplify power, change conductance, or change output power based on a control input to be considered active for purposes of Part 54 is incorrect. Circuit boards, batteries, battery chargers, and power supplies all are on the AMR-excluded list, yet none of these components necessarily performs any of the cited functions.

For purposes of Part 54, transistors are similar to transformers in that the terminal voltages and currents of both components are directly measurable quantities that indicate the components ability to perform its intended function. Further, the performance of both transformers and transistors can be readily monitored at their terminals. In fact, the only way anything is known about what is happening inside a transistor is through its terminal voltage and current characteristics (i.e., properties). Transistors are on the AMR-excluded list because their directly measurable properties (terminal voltage and current) change as transistors perform their intended function.

Q87. Dr. Degeneff states that a transformer does not require an external signal to perform its intended function, in contrast to a transistor that responds to changes in external forces. Degeneff Testimony at 25. Do you agree?

A87. (SED) No. This statement is inaccurate and not relevant for the reasons stated in the prior response. The transformer primary must be driven by some AC power source. Also, both transistors and transformers respond to external voltages, currents, and changes in load.

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Q88. On pages 11-12 of his report, Dr. Degeneff presents figures that purportedly support the scientific fact that transformers, unlike transistors, perform their intended function without application of an external force. See Degeneff Testimony at 25-26. Dr.

Dobbs, have you reviewed those figures?

A88. (SED) Yes.

Q89. Do you have any opinions on Dr. Degeneffs characterization and use of those figures?

A89. (SED) Yes. Dr. Degeneff presents these figures ostensibly to refute my statement earlier in this proceeding that, of the electrical components specifically listed in

§ 54.21(a)(1)(i), the closest match to a transformer is a transistor, which is found on the AMR-excluded list. He claims the drawings on pages 11 to 12 of his report will assist the court and the parties and demonstrate the differences between transformers and transistors. Degeneff Report at 10. However, the drawings and visual comparison prepared by Dr. Degeneff are inaccurate. See Degeneff Testimony at 25. Specifically, the diagram labeled as Transistor (id.

at 12) is, in actuality, a transistor circuit that contains two thyristors and many other components that are necessary to provide the Control Signal but which are not shown by Dr. Degeneff.

Furthermore, even the individual Transistor or Thyristor chosen by Dr. Degeneff is not appropriate. A thyristor performs as, and can be considered to be, two transistors wired together.

Accordingly, to provide the Board with a correct and useful visual representation of a transformer and a transistor, I have prepared exhibit ENT000111, Examples of Transistors and Transformers in Simplified Circuits. The drawings in exhibit ENT000111 demonstrate the similarities between transistors and transformers, both of which must be placed in a circuit with other components to perform their intended functions.

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Q90. Please summarize why you conclude that transformers, like transistors, belong on the list of AMR-excluded components in 10 C.F.R. § 54.21(a)(1)(i).

A90. (SED) A comparison of a transistor and a transformer outside of any circuit indicates that they are similar in the following key respects:

• Transistors and transformers are basic electrical components. They are not made up of any combination of other electrical components. Any attempt to further simplify them will destroy their identity.

• The key property that allows both transistors and transformers to perform their intended functions is one or more electromagnetic fields. In the case of the transformer it is a magnetic field. In the case of a transistor, it is one or more electric fields.

• In their natural states, transistors and transformers are dead; i.e., the electromagnetic fields required by the components for operation are powered from external sources.

• To perform their intended functions, transistors and transformers must be placed in a circuit with other components. See ENT000111 (showing examples of transistors and transformers in simplified circuits).

• During operation, the electromagnetic fields in both devices vary in time.

• The relationships of (1) the output voltage to the input voltage and (2) the output current to the input current can be similarly expressed for both devices:

o VOUT = (Turns Ratio) x VIN for a transformer circuit o VOUT = (Voltage Gain) x VIN for the transistor circuit o IOUT = [1 / (Turns Ratio)] x IIN for the transformer circuit o IOUT = (Current Gain) x IIN for the transistor circuit.

• Proper operation of a transformer or a transistor can be readily monitored at its external terminals as it operates.

2. Batteries Q91. Dr. Degeneff suggests that because transformers are different from batteries, they must be AMR-included components. See Degeneff Testimony at 26. What is your response?

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A91. (SED) Dr. Degeneffs reasoning is flawed. Clearly, everything that is not a transformer is different from a transformer in some way. The same can be said for numerous items that are explicitly identified in 10 C.F.R. § 54.21(a)(1)(i) as excluded from aging management review. To illustrate the fallacy in Dr. Degeneffs logic, below I have substituted transistor for transformer in an otherwise verbatim passage from Dr. Degeneffs testimony:

[Transistors] are different from batteries, which are excluded components. . . . The electrolytic properties of the chemicals of which the battery is composed change as the battery discharges. In contrast, only the properties of the power flowing through a

[transistor] change. The key properties of a battery that has been discharged will be different from a full battery, but the key properties of a [transistor] that has had power flow through it will not be different from the properties of a [transistor] which has not been used.

Degeneff Testimony at 26: Given that this statement applies equally to a transistor as to a transformer, it either proves that a transformer is excluded from AMR, or it has no value in determining the classification of a transformer.

For purposes of Part 54 license renewal, the relevant facts are that both transformers and batteries experience a change in their configuration or properties in performing their intended functions, and that proper operation of either device can be readily monitored at its external terminals as it operates. The fact that these two components differ in other respects is irrelevant.

3. Power Inverters Q92. On what basis does Dr. Degeneff try to distinguish transformers from power inverters, which are excluded from AMR in 10 C.F.R. § 54.21(a)(1)(i)? Is it valid?

A92. (SED) Dr. Degeneff states, Like a transistor, the inverter requires an external control in order to perform its intended function. Degeneff Testimony at 26. As explained above, this statement is not a valid basis or criterion for subjecting transformers to, or excluding them from, aging management review. An inverter transforms a direct current input into an 81

alternating current output, possibly at a different voltage. How much control is or is not present has nothing to do with its classification as active and AMR-excluded in the context of 10 C.F.R. Part 54.

4. Power Supplies Q93. Does Dr. Degeneffs purported distinction between transformers and power supplies lack validity for the same reason?

A93. (SED) Yes. Dr. Degeneff states: Like the transistor and the inverter, the power supply requires an external control to perform its intended function. Degeneff Testimony at 27.

A power supply transforms an alternating current input into a direct current output, possibly at a different voltage. Again, how much control is or is not present is irrelevant to its classification as active or excluded in context of the Part 54. Dr. Degeneff also states that power supplies require voltage regulation. Id. Voltage regulation is not required for purposes of determining whether a component is subject to AMR under Part 54. No power supply details are given in 10 C.F.R. § 54.21(a)(1)(i) or in the 1995 License Renewal SOC, so the fact that power supplies are on the AMR-excluded list has nothing to do with voltage regulation.

Q94. On page 6 of his report, Dr. Degeneff also relies on a table entitled Comparison of Various Structures and Components. Have your reviewed that table?

A94. (SED) Yes. That table was appended to the September 2009 Blanch Declaration, which NYS submitted to support its opposition to Entergys August 14, 2009 Motion for Summary Disposition of NYS-8. I also have reviewed that declaration. Paragraphs 25 to 32 of Mr. Blanchs declaration discuss the table. See Sept. 2009 Blanch Decl. ¶¶ 25-32. Dr. Degeneff has appended the table to his report on pages 36 to 38 (NYS00005) and discusses the table on page 6 of that report. The table lists numerous structures and components and indicates whether they contain moving parts, experience changes in configuration or properties, experience 82

changes in state, are active or passive, and are specifically listed in § 54.21(a)(1). According to Dr. Degeneff, the table demonstrates that transformers are similar to the category of structures and components that are expressly listed as included in 10 C.F.R. § 54.21(a)(1). Degeneff Report at 6.

Q95. Do you agree with the methodology used to prepare the aforementioned table, or the results of Dr. Degeneffs comparisons of transformers to other components?

A95. (SED) No. The referenced discussion and table contain numerous errors that largely have been addressed in my preceding testimony. This response focuses on significant flaws in NYSs comparison of transformers with other components that have not been discussed elsewhere in this testimony.

First, consider how power inverters, circuit boards, battery chargers, and power supplies are classified by NYS. To be sure, they are classified correctly in NYSs table because their classification simply follows that of 10 C.F.R. § 54.21(a)(1)(i). The matter of interest is the method used by NYS to arrive at these classifications. Note that each of these components is accompanied by an endnote explaining how the classification was achieved. Those footnotes are numbered 6, 7, 8, and 9. Degeneff Report at 37. The purported logic of these endnotes can be summarized as follows: Transistors are solid state devices that are active and excluded from AMR. Therefore, all other solid state devices are active and excluded from AMR. Power inverters, battery chargers, and power supplies all have solid state devices in them; therefore, they are active and excluded from AMR. Circuit boards are assumed to have solid state devices on them, so they are active and excluded. For purposes of this discussion, I refer to this as Dr. Degeneffs theory of inherited exclusion.

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Dr. Degeneffs approach is incorrect because it relies upon suppositions and assumptions that are not supported by 10 C.F.R. § 54.21(a)(1)(i) or the 1995 License Renewal SOC. As we have previously explained, since power inverters, circuit boards, battery chargers and power supplies are included in the AMR-excluded list without qualification, their exclusion from AMR is not tied to any detail of how they are constructed, for example, whether they include solid-state devices.

Accepting Dr. Degeneffs adopted theory of inherited exclusion leads to significant, unexplained contradictions in the classifications of components that are expressly listed in 10 C.F.R. § 54.21(a)(1)(i). Take, for example, a power supply. Most modern electronic power supplies contain some solid state devices such as rectifier diodes, transistors, and perhaps thyristors. However, they also will most assuredly contain one or more transformersa component that Dr. Degeneff has classified in the table as Passive (included). If the power supply inherits the classification of its components, how should it be classified when it contains both active and passive components, as characterized by Dr. Degeneff? Classification of power supplies as passive would contradict the actual classification of power supplies as AMR-excluded components in 10 C.F.R. § 54.21(a)(1)(i).

Another example is even more striking. Consider a circuit board containing only a transformer. By regulation, a circuit board is excluded from an AMR. However, if a circuit board inherits the classification of its components, as supposed by Dr. Degeneff, and the transformer is classified as passive (AMR-included) as stated in NYSs table, then the circuit board clearly would be classified as passive and included in AMR. Yet, this classification is in error. Therefore, NYSs methodology must be rejected as flawed.

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Further, Dr. Degeneffs classifications of components not specifically mentioned in Section 54.21(a)(1)s lists of AMR-included and AMR-excluded components also are flawed.

Consider the table entries of Lamps (incandescent), Lamps (LED), and Lamps (CFL). Degeneff Report at 37. It is hard to imagine a better example of something that exhibits a change of state than a lamp. When it is on, the lamp is lit. When it is off, the lamp is dark. The two states of on and off for these three devices are clearly defined, directly observable, and readily monitored. Yet Dr. Degeneffs table defines only LED and CFL Lamps as exhibiting a change of state. See Degeneff Report at 37. The explanations contained in endnotes 10 and 11 of the table lack a technical basis. See id. at 38. The table suggests that an LED Lamps operation involves a change of state solely because it is either forward or reverse-biased. However, LEDs are seldom, if ever, intentionally reversed biased. Rather, they are turned on and off just like an incandescent lamp (i.e., by applying and removing power), which Dr. Degeneff classifies as a passive component with no change of state. For the CFL Lamp, Dr. Degeneff again uses this flawed theory of inherited classification.

At this point, the question arises as to why Dr. Degeneff classifies incandescent lamps as not exhibiting a change of state while classifying the other two lamps (LED and CFL) as having a change of state. The answer seems to be tied to the way in which the lamps achieve a change in state. Incandescent lamps achieve their change of state by applying and removing power. If Dr. Degeneff accepts this fact, then he also must accept the fact that a transformer changes state when power is applied. In the former case the change of state is the presence or absence of light. In the latter case it is the presence or absence of a magnetic field. The explanation set forth in footnotes 10 and 11 of Dr. Degeneffs table rests on fundamentally flawed reasoning.

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In conclusion, although Dr. Degeneffs table reflects proper classifications for structures or components that are listed in 10 C.F.R. § 54.21(a)(1)(i), those classifications are correct only because that regulation provides the answer. The methodology applied by Dr. Degeneff to construct his table remains flawed. In classifying other non-listed components, such as lamps, Dr. Degeneff appears to rely on technically incorrect assumptions that are also at odds with

§ 54.21(a)(1)(i) and the 1995 License Renewal SOC. As a result, the only correct entries concerning transformers in the table are that the basic unit has no moving parts and that it is not listed in § 54.21(a)(1)(i). The entries in the other three columns are all incorrect.

IX. REBUTTAL TO NYSS CLAIM THAT PART 54 REQUIRES AN AGING MANAGEMENT PROGRAM FOR IPEC TRANSFORMERS A. Transformer Operation and Performance Are Governed by 10 C.F.R. Part 50 Requirements and Ongoing NRC Regulatory Oversight Programs Q96. NYS claims that Entergy should subject IPEC transformers to an aging management review and implement special programs to address aging problems in its transformers prior to license renewal. Do you agree?

A96. (RBR, JWC, TSM) No. As discussed above, the Commission concluded that Part 54 aging management review is not required for active structures and components, which include transformers. The NRC Staff made an evaluation in which it specifically reviewed the classification of transformers to determine if, using the definitions discussed in the 1995 License Renewal SOC, transformers should be classified as active or passive components. See 1997 NRC Letter at 1-2 (ENT000097). The Staff determined that transformers are active components and excluded from the AMR requirements in 10 C.F.R. § 54.21. See id. Significantly, this conclusion is reflected in the LRAs and NRC safety evaluations associated with each of the 71 renewed operating licenses issued by the Commission to date.

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In addition, transformer performance is addressed by the 10 C.F.R. Part 50 regulatory process. An important aspect of that process, as discussed in the 1995 License Renewal SOC, is reliance on the maintenance rule, 10 C.F.R. § 50.65. See generally 1995 License Renewal SOC (NYS000016). The CLB for all NRC-licensed operating nuclear power plants include § 50.65, which requires that power reactor licensees monitor the performance or condition of SSCs against licensee-established goals to provide reasonable assurance that such SSCs are capable of fulfilling their intended functions. Maintenance activities include activities associated with the planning, scheduling, post-maintenance testing, return-to-service for surveillance, and preventive and corrective maintenance. Transformers and activities related to transformer monitoring and maintenance activities are within the scope of equipment and activities governed by 10 C.F.R.

§ 50.65. The NRC routinely inspects licensee maintenance programs and activities. For example, NRC Inspection Procedure 71111.12, Maintenance Effectiveness (Apr. 29, 2011)

(ENT000112), is used, in part, to verify that licensees are appropriately addressing SSC performance or condition problems within the scope of the maintenance rule.

Q97. Are there other Part 50 regulatory requirements applicable to transformers within the scope of NYS-8?

A97. (JWC, RBR, TSM) Yes. Transformers within the scope of NYS-8 that supply power to safety-related systems and components are required to conform to requirements that are part of the CLB for operating nuclear power plants. For example, 10 C.F.R. Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, includes criteria applicable to electrical systems that focus on system design, independence, and redundancy (Criterion 17), and periodic inspection and testing (Criterion 18). 10 C.F.R. Part 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, establishes requirements 87

applicable to all activities affecting the safety functions of those SSCs, including designing, inspecting, testing, operating, maintaining, repairing, and modifying the SSCs. The procedures and processes used to evaluate any degraded performance and implement corrective action(s) are governed by the criteria in Appendix B to 10 C.F.R. Part 50.

Additionally, transformer-related maintenance, performance monitoring, and corrective actions must be documented in accordance with NRC records and reporting requirements.

Section 50.71 requires NRC licensees to maintain records and make reports to the NRC; § 50.72, requires licensees to make reports when the plant is in defined plant conditions; and § 50.73 requires licensees to report the occurrence of defined events to the NRC through licensee event reports (LERs). Depending on the specific circumstances, transformer performance degradation or failure of safety-related and non safety-related transformers would be reportable under one or more of those regulations.

Q98. You also mentioned that electrical transformers are subject to ongoing NRC oversight programs or initiatives. Please identify those programs.

A98. (JWC) NRC regulatory oversight programs include the NRCs Inspection Program, agency review of industry operating experience, the Generic Communications Program, the Generic Issues Program, and NRCs research program. Plant transients related to transformer performance are reviewed by NRC inspectors. These inspections and NRC review of licensee operating experience, including the information contained in reports required by

§ 50.72, are part of the NRCs generic communication process. Transformer performance has been the subject of operating event reports, NRC evaluations, and NRC generic communications as part of the current regulatory process since 1979. The transformer-related operating 88

experience discussed in these generic communications includes events caused by degradation due to the effects of aging and highlights the importance of proper transformer maintenance.

The NRCs Generic Issue Program evaluates technical issues to determine the safety significance of a particular issue and identifies, as applicable, potential resolutions, including new requirements when warranted. As summarized below, one issue generic issue related to transformer performance and was evaluated as part of the Generic Issue Program, Generic Safety Issue (GSI) 107. See NUREG-0933, Resolution of Generic Safety Issues, Main Report with Supplements 1-34, Issue 107: Main Transformer Failures (Rev. 3) (Dec. 2011) (ENT000113).

GSI 107 concerned an observed high failure frequency of main transformers and the associated safety implications. This issue was identified as a result of numerous main transformer failures and related reactor trips at the North Anna Power Station in the early 1980s.

Safety-related loads in nuclear plants are supplied from buses that can be supplied from any one of the following sources: (1) the unit auxiliary (main) transformer, (2) the startup transformer (or reserve auxiliary transformer), or (3) the emergency onsite power supply (i.e., diesel generators).

A main transformer failure will result in a loss of load or an unbalanced load on the main generator, thereby causing a turbine/generator trip and the unavailability of power to the unit transformers for the station power. However, station power can be obtained from the grid through the startup transformer or from emergency onsite power sources. Switchyards have redundant systems to provide sufficient relaying and circuit breakers, such that a transformer failure is not expected to cause a loss of offsite power.

The potential generic concerns identified in the report included the overhead conductor/buses and oil-filled transformers in general. The NRCs analysis included an assessment of the need for new actions by the licensees to prevent main transformer failures.

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Potential new actions considered included a review of the adequacy of maintenance and operating procedures for the main transformers. The NRC concluded that no new action(s) was warranted based on the low safety significance of the issue, and the observation that existing designs of operating nuclear power plants incorporate various independent means of supplying loads, such that main transformer failures would not cause a total loss of offsite power. In addition, the then-anticipated promulgation of the station blackout rule (10 C.F.R. § 50.63) was expected to further reduce the risk from loss of AC power.

Q99. Can you provide some specific examples of other NRC generic communications that focus on or relate to electrical transformers?

A99. (JWC) Yes. The NRC has issued numerous generic communications concerning transformer performance that date back to 1979. Key examples of NRC generic communications involving transformers include:

• IE Bulletin 79-23, Potential Failure of Emergency Diesel Generator Field Exciter Transformer (Sept. 12, 1979) (ENT000114)

• Information Notice 82-53, Main Transformer Failures at the North Anna Nuclear Power Station (Dec. 22, 1982) (ENT000115)

• Information Notice 83-37, Transformer Failure Resulting From Degraded Internal Connection Cables (June 13, 1983) (ENT000116)

• Information Notice 84-84, Deficiencies in Ferro-Resonant Transformers (Nov. 27, 1984)

(ENT000117), and Information Notice No. 84-84, Rev. 1 (Apr. 24, 1985) (ENT000118)

• Information Notice 92-63, Cracked Insulators in ASL Dry Type Transformers Manufactured By Westinghouse Electric Corporation (Aug. 26, 1992) (ENT000119)

• Information Notice 97-37, Main Transformer Fault With Ensuing Oil Spill Into Turbine Building (June 20, 1997) (ENT000120)

• Information Notice No. 2009-10, Transformer Failures - Recent Operating Experience (July 7, 2009) (Info. Notice 2009-10) (NYS000019).

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Q100. NYS and Dr. Degeneff cite Information Notice 2009-10 and various Licensee Event Reports in arguing that an aging management program for transformers should be instituted at IPEC as part of the Part 54 license renewal process. Do you agree?

A100. (RBR, JWC, TSM) No. Aging management for transformers should continue to be addressed through Part 50 regulatory framework. Information Notice 2009-10 states that there has been a relatively high incidence of large transformer failures in the last few years, with eight events from January 2007 to February 2009. Info. Notice 2009-10, at 2 (NYS000019).

However, it further states that the majority of the cited events could have been avoided had the licensee fully evaluated and effectively implemented corrective actions and recommendations identified by industry operating experience. Id. Information Notice 2009-10 does not impose new requirements. Nor does it state or otherwise suggest that such corrective actions or recommendations must be implemented as part of the Part 54 license renewal process. In fact, it states that the large transformers discussed therein are within the scope of the Maintenance Rule, id., which explicitly directs licensees to take into account industry-wide operating experience when developing performance goals. Entergy previously has considered the operating experience described in Information Notice 2009-10, among other sources of information, as part of its CLB reviews of relevant transformer-related operating experience.

Entergy review of relevant operating experience is documented in Entergy Fleet Engineering Guide EN-EG-G-001, Large Power Transformer Inspection Guidelines, Rev. 2, Attach. 6.9, at 47-67 (ENT000121).

Q101. What is the significance of these generic program examples?

A101. (JWC) These examples demonstrate the NRCs continuing robust evaluation of the technical, system safety, and overall risk aspects of transformer failuresa process that 91

began over 30 years ago. They also demonstrate that transformer performance, transformer degradation, and the effectiveness of industrys transformer maintenance activities have been, and continue to be, part of the ongoing NRC regulatory process for operating reactors.

Q102. Have there been any NRC-sponsored research projects related to transformers?

A102. (JWC) Yes. For example, NUREG/CR-5753, Aging of Safety Class 1E Transformers in Safety Systems of Nuclear Power Plants (Feb. 1996) (NYS000012), documents the study performed for the NRC by Idaho National Engineering Laboratory (INEL).

NUREG/CR-5753 discusses the aging effects on safety-related power transformers in nuclear power plants. The INEL team evaluated transformer maintenance, testing, and monitoring practices with respect to their effectiveness in detecting and mitigating the effects of aging. It also investigated materials used in transformer construction, reviewed stressors and aging mechanisms, reviewed operating and testing experience with aging effects, analyzed transformer failure events reported in various databases, and evaluated maintenance practices. See NUREG/CR-5753, at ix, 1-2.

Notably, the NUREG/CR-5753 study was performed as part of the NRCs Nuclear Plant-Aging Research (NPAR) Program. The NPAR Program was implemented by the NRCs Office of Nuclear Regulatory Research in 1985 to identify and resolve technical safety issues related to the aging of SSCs in operating nuclear power plants. See NUREG/CR-5753, at 1.

NPAR Program documents were utilized by the NRC Staff to evaluate the effectiveness of maintenance and surveillance activities to manage age-related degradation in developing NUREG-1801 (the GALL Report).1 1

The original GALL Report (NUREG-1801, Rev. 0) is built on a previous report, NUREG/CR-6490, Nuclear Power Plant Generic Aging Lessons Learned (GALL) (Dec. 1996) (ENT000122A-D), which is a systematic 92

Q103. What conclusions were reached about class 1E transformers as discussed in NUREG/CR 5753?

A103. (JWC) NUREG/CR-5753 (NYS000012), at ix-x, states:

[T]here is no presently identified transformer aging mechanism that would cause a safety concern. If nuclear plants use currently recognized monitoring and testing methods and follow a rigorous surveillance, testing, maintenance, and replacement program (based on current and future manufacturers and industry guidelines) the effects of transformer aging will not increase the risk to nuclear plant safety.

These conclusions are based on our review of (a) the transformer aging mechanisms, (b) the accepted transformer monitoring and testing methods, (c) the manufacturer's and industry transformer maintenance and surveillance guidelines, (d) the current transformer surveillance and maintenance practices at an operating nuclear station, and (e) the transformer plant operating experience for 88 nuclear plants.

NUREG/CR-5753 further stated that, because many Class 1E power transformers in use at nuclear plants were relatively young at the time (1995), past experience may not be indicative of the effects of transformer aging or the then-current industry surveillance and maintenance practices. See NUREG/CR-5753, at 28. Consequently, the authors suggested a review of plant operating data at 5-year intervals to determine if there were significant trends. See id. at 51. It is important to note that there have been significant changes in surveillance and maintenance practices and programs for transformers since NUREG/CR-5753 was written. See, e.g., EPRI 1002913, Power Transformer Maintenance and Application Guide (2002) (ENT000123A-B).

These changes are a result of improved instrumentation and monitoring technology and a result of implementation of 10 C.F.R. § 50.65.

compilation of plant aging information. NUREG-1801, Rev. 0 extended the information in NUREG/CR-6490 to provide an evaluation of the adequacy of AMPs for license renewal. The NUREG/CR-6490 report was based on information in over 500 documents, including NPAR program reports, industry reports addressing license renewal for major structures and components, LERs, information notices, generic letters, and bulletins.

NUREG-1801, at 1. NUREG/CR-6490 reflects explicit consideration of operating experience and aging effects for transformers, which the NRC Staff has concluded are not subject to AMR under Part 54. See, e.g.,

NUREG/CR-6490, Vol. 1 at 19, 27, 38, 40; id. App. A, Tbl. A.1, at 20A, 20B; id. Tbl. A.2, at 26A, 44A to 47B (ENT000122A-B).

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Q104. Is a review of plant operating data or experience being done at operating nuclear plants as part of CLB activities?

A104. (JWC, TSM) Yes. As noted previously, the CLB for every operating reactor includes 10 C.F.R. § 50.65, the maintenance rule. Section 50.65 requires licensees to establish goals and monitor equipment performance to identify trends. It also requires that the cause(s) of equipment performance degradation be identified. Periodic re-evaluations are performed to review operating experience. Section 50.65(a)(3) states:

Performance and condition monitoring activities and associated goals and preventive maintenance activities shall be evaluated at least every refueling cycle provided the interval between evaluations does not exceed 24 months. The evaluations shall take into account, where practical, industry-wide operating experience. Adjustments shall be made where necessary to ensure that the objective of preventing failures of structures, systems, and components through maintenance is appropriately balanced against the objective of minimizing unavailability of structures, systems, and components due to monitoring or preventive maintenance.

10 C.F.R. § 50.65(a)(3).

Q105. Has the NRC ever concluded that current Part 50 programs and processes are inadequate to ensure that transformers are capable of performing their intended functions, such that a Part 54 aging management program might be required?

A105. (JWC) No. To the contrary, the Commission specifically excluded current Part 50 or CLB issues from the scope of license renewal as defined in 10 C.F.R. § 54. 30, Matters not subject to a renewal review. Additionally, the NRC has not identified or imposed new requirements specifically focused on electrical transformers as part of license renewal. The evaluation of transformer performance conducted as part of GSI 107 found that the safety significance of identified transformer performance issues was not sufficient to justify new requirements, and that maintenance rule requirements provide sufficient means by which to 94

address transformer performance issues (e.g., performing post-maintenance testing, return-to-service activities for surveillances, and preventive and corrective maintenance).

Q106. Has the NRC ever concluded that transformers are components that require aging management review in accordance with Section 10 C.F.R. § 54.21(a)(1)(i)?

A106. (JWC) No. The revised license renewal rule was issued in June 1995. The first renewal application was submitted to the NRC in 1998, and the first approved or renewed license was issued in 2000. In the 13 years since the first license renewal application was received by the NRC, every one of the license renewal applications approved by the NRC for 71 reactor units has defined electrical transformers as not being subject to aging management review. As discussed in Section IV.B above, NRC guidance (NUREG-1800 and the 1997 NRC Letter) explicitly states that transformers are not subject to AMR under Part 54.

Q107. Dr. Degeneff contends that the operating experience cited in his testimony and report indicates that current transformer monitoring programs are inadequate, and that transformers should be subject to AMR under Part 54. Do you agree?

A107. (JWC) No. Although NYS and Dr. Degeneff may not agree with the NRCs approach to ensuring adequate safety with respect to transformer performance issues, the examples cited in their submissions demonstrate that transformer performance is part of the CLBs and ongoing regulatory oversight process for all operating nuclear plants, including IP2 and IP3. The license renewal rule does not change initial design and operating license requirements, which are part of a plants CLB. I do not think the Commission was wrong, as suggested by Dr. Degeneff, to conclude that the current regulatory process is adequate to ensure an adequate level of safety and safe operation of nuclear plants with respect to current operating equipment issues such as those involving transformers.

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Additionally, I do not agree that the Commission intended the Staff to include current operating term issues as part of license renewal, as suggested by Dr. Degeneff. The Commission has been quite clear that current operating term issues are not to be included as part of license renewal. 10 C.F.R. § 54.30, Matters not subject to a renewal review, excludes current license term issues from being included from the scope of license renewal.

Dr. Degeneffs assertion is misguided in other major respects. For example, while the maintenance rule establishes a goal of preventing failures, NRC regulations do not require applicants for initial or renewed operating licenses to prevent all equipment failure. NRC nuclear power plant design requirements assume that component failures may occur and, for that reason, include requirements for independence, redundancy and diversity as part of the Commissions defense-in-depth approach to providing the reasonable assurance required for an operating license. See 10 C.F.R. § 50.57. Further, NRC regulations do not require licensees to detect, in advance of failure, all of the aging defects and degradation phenomena in components, including transformers. The license renewal rule requires reasonable assurance that SSCs are capable of performing their intended functions during the period of extended operationnot detection of all degradation. 1995 License Renewal SOC at 22,469 (NYS000016).

B. Current Performance Monitoring and Preventive Maintenance Programs at Indian Point Are Adequate to Manage the Effects of Aging on the Functionality of Safety-Related Transformers Q108. What programs has Entergy implemented at IPEC to ensure the continued functionality of the types of transformers cited in NYSs prefiled testimony?

A108. (TSM, RBR) In accordance with 10 C.F.R. Part 50, including the maintenance rule, Entergy has implemented preventive maintenance and performance monitoring programs at IPEC to manage active systems and components. These programs are intended to ensure plant 96

reliability by identifying and correcting any potential degradation issues, including age-related degradation associated with active systems and components, including electrical transformers.

In its prefiled testimony and related exhibits, NYS focuses on large oil-filled transformers, which, at IPEC, include the main transformers, station auxiliary transformers, unit auxiliary transformer and the Unit 3 GT auto transformer.

Entergy uses industry standard preventive and predictive maintenance techniques on its large oil-filled transformers. For example, predictive and preventive maintenance techniques used on large oil-filled transformers include monitoring or assessment of the following.

• Power Factor

• Winding Insulation Resistance

• Capacitance

• Sweep Frequency Response Analysis (SFRA)

• Hot Collar, on applicable

• Oil Dissolved Gas Analysis (DGA) bushings

• Excitation Current

• Oil Quality

• Leakage Reactance

• Furanic Compound Analysis in Oil

• Transformer Turns Ratio

• Visual Inspections/Cleaning

• Winding Resistance

• Thermography

• Corona Scan Specific details on IPEC large power transformer inspection and maintenance practices are contained in Entergy Fleet Engineering Guide EN-EG-G-001, Large Power Transformer Inspection Guidelines, Rev. 2 (Mar. 2011) (EN-EG-G-001) (ENT000121). IPEC Maintenance Procedure 0-XFR-407-ELC, Rev. 0, Station or Unit Auxiliary Transformer Annual In-Service Inspection (May 18, 2007) (ENT000124) is an example of an IPEC-specific procedure detailing in-service inspection activities for certain large oil-filled transformers.

Predictive maintenance results are monitored and trended to identify degrading conditions within transformers. Entergy also has used such results to develop the Indian Point 97

Energy Center Large Power Transformer Life Cycle Management Plan (2011) (IPEC Transformer Management Plan) (ENT000125). The plan provides reasonable assurance that the transformers operate satisfactorily until the planned replacement date of the transformers.2 The plan is a living document, updated as necessary based on operating experience and changing plant conditions. This new information is used to ensure that the IPEC large power transformer replacement and maintenance strategies are still valid and sufficient to provide reasonable assurance that an in-service transformer failure does not occur.

Finally, Entergy also performs predictive and preventive maintenance on dry type transformers, including visual inspections/cleaning, insulation resistance measurement, and winding resistance measurement. IPEC Maintenance Procedure 0-XFR-401-ELC Station Service and Load Center Transformers Outage Inspection (Apr. 5, 2007) (ENT000126) is an example of a plant procedure governing outage-related inspection and maintenance activities for dry type transformers.

Q109. Which of the large oil-filled transformers at IPEC mentioned above perform license renewal intended functions?

A109. (TSM, RBR) Although Entergy included all electrical components in the scope of license renewal, the main transformers and the unit auxiliary transformers do not perform a license renewal intended function as defined in 10 C.F.R. § 54.4. The station auxiliary transformers and the Unit 3 GT auto transformer perform license renewal intended functions.

Q110. Have you reviewed Dr. Degeneffs allegations regarding transformer monitoring practices in Section 5 of his report and on pages 29 to 41 of his testimony?

A110. (RBR, JWC) Yes.

2 The service life stated in IPEC Large Power Transformer Life Cycle Management Plan should not be interpreted as a definitive date by which transformer will fail or become unable to perform its intended functions; it is only meant to validate IPECs replacement and maintenance strategies.

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Q111. In your opinion, do Dr. Degeneffs assertions call into question the adequacy of IPEC performance monitoring and preventive maintenance practices for transformers, or indicate the need for a Part 54 aging management program?

A111. (RBR, JWC) No. His assertions do not provide any evidence that Part 50 programs are ineffective, or that transformers should be considered passive, such that a Part 54 program would be necessary or more effective than established programs. Dr. Degeneff contends that because it is not possible to detect all transformer degradation mechanisms through performance monitoring at the terminals, transformers should be placed in the AMR-included group and require an aging management program. As explained above, however, Part 54 focuses on component functionality, not on managing any and all postulated or potential aging mechanisms. This was a point of emphasis in the Commissions 1995 revisions to Part 54. See 1995 License Renewal SOC at 22,461, 22,471, 22,475-76 (NYS000016). The Commission expressly concluded that the focus on identification of aging mechanisms is not necessary because regardless of the aging mechanism, only those that lead to degraded component performance or condition (i.e., potential loss of functionality) are of concern. Id. at 22,488.

Further, the Commission stated that [f]unctional degradation resulting from the effects of aging on active functions [such as those performed by transformers] is more readily determinable, and existing programs and requirements are expected to directly detect the effects of aging. Id. at 22,472 (emphasis added).

Q112. Does the possible presence of certain age-related degradation mechanisms that are undetectable by performance monitoring mean that a component must be placed on the AMR-included list?

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A112. (SED) No. For example, both transistors and circuit boards are in the AMR-excluded group, yet these excluded components have some types of age-related degradation that cannot be detected by performance monitoring. Some transistor-related examples include electromigration, carrier injection, dielectric breakdown, package failure, failure of wire bonds connecting the external leads to the semiconductor material, and heat sink failure. See, e.g., J.

Keane & C. Kim, Transistor Aging, IEEE Spectrum, http://spectrum.ieee.org/semiconductors/

processors/transistor-aging/0 (May 2011) (ENT000127). The above degradation mechanisms can be detected only by removing the transistor from the circuit and testing it by itself or by destructively examining the transistor.

Similarly, there are numerous degradation mechanisms for circuit boards and circuit board components. See EPRI 1018534, EPRI Nuclear Maintenance Applications Center:

Assessment of Printed Circuit Board Diagnostic Techniques, Final Report, § 2.3 [(Failure Mechanisms)] at 2-18 to 2-21 (Mar. 2009) (ENT000128). In Part 54, transistors and circuit boards still are classified as active components. Thus, having such degradation mechanisms is not a valid criterion for placing a component in the AMR-included group.

Q113. Dr. Degeneff asserts that age related degradation in transformers is not readily monitorable, but instead requires invasive, expensive and time consuming procedures, such as removal of oil and internal inspections? Degeneff Report at 32. Do you agree?

A113. (TSM, RBR) No. A transformers ability to perform its intended function can be readily monitored without performing internal inspections. Furthermore, the invasive procedure advocated by Dr. Degeneff may be detrimental to transformer operation, because its performance in the field can introduce moisture and contaminants into the transformer internals and oil. For 100

that reason, it should be used only in limited circumstances and settings. EPRI guidance supports this conclusion. Section 8.8.3 (Internal Inspections) of EPRIs Copper Book states:

From both a cost and transformer reliability point of view, it is not desirable to drain the oil and breach the transformer tank unless absolutely necessary. Whenever the windings and insulation are exposed to the outside environment, the probability for problems upon re-energization increases. However, there are instances where an internal inspection might be necessary in light of a potential fault or if the condition assessment testing indicates an abnormal condition.

Also, there may be occasions where the oil must be drained for other reasons (field dryout, oil processing, bushing replacement). In these rare instances, it is a good idea to take advantage of the opportunity to perform an internal inspection, if possible. Some utilities perform pre-inspection testing and post-inspection testing to ensure that no damage has been done during the inspection. Tests that have been used are:

winding resistance, capacitance and power factor, insulation resistance, turn ratio, DGA, and oil quality.

EPRI Transformer Guidebook Development: The Copper Book at 8-164 (2011) (ENT000129).

Similarly, Dr. Degeneff suggests that visual inspections are necessary to assess the extent of risk posed by polymerization of insulating paper in a transformer. Again, his suggestion runs counter to industry guidance in Section 9.8.1.2 (Degree of Polymerization Measurements from Paper Samples) of the EPRI Copper Book. That guidance states that sampling of insulation paper for degree of polymerization testing is a risky and costly endeavor and should only be considered as a last resort after careful deliberation, because it is necessary to take the transformer offline and drain the oil. Id. at 9-142 to -143. Section 9.8.1.2 further states that, with these limitations, the use of the non-invasive furan testwhich Entergy usesis very desirable. Id. at 9-146. See IPEC Transformer Management Plan at 10, 20, 32, 44, 67, 79, 92, and 102 (presenting furanic compound test results). The furan test is used to test transformer oil for the presence of oil-soluble, furanic compounds (which are derived from the organic compound furan) that may result from thermal degradation of transformer insulating paper. See 101

EPRI 1013566, Plant Support Engineering: Large Transformer end-of-Expected-Life Considerations and the Need for Planning at 3-4 (Dec. 2006) (NYS000020).

Q114. Do current IPEC performance monitoring and/or preventive maintenance practices, in any event, address the types of aging mechanisms cited by Dr. Degeneff?

A114. (TSM, RBR) Yes. On pages 31 to 34 of his testimony and pages 14 to 15 of his report, Dr. Degeneff identifies a number of age-related transformer degradation mechanisms that he alleges are not addressed by current performance monitoring and maintenance practices.

Specifically, he identifies the following aging degradation mechanisms:

• polymerization of the insulation;

• diminishment in the mechanical and structural integrity of the core and coil assembly due to thermal stresses and the torque created by the flow of strong electric currents;

• internal arcing in the insulation structure due to the movement of windings;

• corona or radio interference voltage (RIV) generated by the transformer, which will have no effect on the operating characteristics of the transformer but is a sure indication of a problem with the transformer; and

• accumulation of oil, dirt, or salt spray, or corrosion of the bushings, which increases the possibility of a flashover that can lead to catastrophic failure.

See Degeneff Testimony at 31-34; Degeneff Report at 14-15. Table 4 below indicates how IPEC monitoring and maintenance practices address the specific concerns identified by Dr. Degeneff.

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Table 4. IPEC Performance Monitoring and Predictive Maintenance Practices Aging Mechanism or Other Concern Identified by Dr. Degeneff Means By Which Entergy Addresses Alleged Concern at IPEC Polymerization of the insulation has a dramatic effect on the electrical Consistent with industry guidance, Entergy performs routine furanic strength of the transformer. Degeneff Testimony at 31 (NYS0000002); compound analysis of the oil. See, e.g., IPEC Transformer Degeneff Report at 14 (NYS000005). Management Plan at 10, 20, 32, 44, 67, 79, 92, and 102 (ENT000125).

Although dissolved gas analysis (DGA) may reveal the presence of In addition to DGA, Entergy performs routine furanic compound gasses associated with one of several types of degradation, one also analysis of the oil, along with power factor and capacitance testing of must look at the insulation capability of the oil. Degeneff Testimony at the insulation system. IPEC also checks the insulating capability of the 30; Degeneff Report at 15, 31-32. oil through oil quality tests. See, e.g., IPEC Transformer Management Plan at 5-6, 14 (ENT000125).

The impedance versus frequency scan is a complicated procedure that Entergy performs Sweep Frequency Response Analysis (SFRA) requires precise calibration and which must be repeated frequently in testing of transformers on a routine basis. SFRA is not complicated.

order to develop the trending data which is necessary to effectively Mechanical changes in the windings also are detected by capacitance reveal degradation. Degeneff Testimony at 31. testing. See, e.g., IPEC Transformer Management Plan at 14 (ENT000125).

Diminished mechanical and structural integrity of the core and coil Mechanical changes in the transformer can be detected through assembly may have no effect on the operating characteristics of the capacitance testing as is performed at IPEC. With respect to the core:

transformer. Degeneff Testimony at 32; Degeneff Report at 15. (1) multiple grounds would be indicated by overheating through DGA; (2) loss of core ground would be indicated by arcing or a significant decrease in CL capacitance; and (3) looseness would be indicated by a change in 60 Hz noise.

Individual windings also may deform and affect adjacent windings, Entergy performs DGA testing on a frequent basis (more frequent than leading to internal arcing in the insulation structure. This internal IEEE recommendations). Any changes in the gassing would prompt the arcing due to deformed windings would have no effect on the operating plant perform an evaluation and increase the sampling frequency, as characteristics until it causes failure. Although DGA could produce necessary. If the conditions warranted, IPEC would perform an some evidence of insulation failure or hotspots, a relatively frequent internal inspection of the transformer to determine and correct the inspection interval is required to identify whether the problem is cause. For the Main Transformers, IPEC has installed DGA monitors worsening. Degeneff Testimony at 32-33; Degeneff Report at 15. that sample the transformers every few hours. IPEC also plans to install DGA monitors on the Station Auxiliary Transformers and the Unit Auxiliary Transformers when those transformers are replaced.

-103-

Aging Mechanism or Other Concern Identified by Dr. Degeneff Means By Which Entergy Addresses Alleged Concern at IPEC A corona or radio interference voltage (RIV) generated by the If transformer degradation was detected through the current monitoring transformer indicates a problem with the transformer. Although an that Entergy performs on the transformers, then Entergy would, if acoustical test could identify the existence of a corona, a visual warranted, perform an internal inspection of the transformer to inspection is required to identify the actual structural flaw in the determine and correct the cause. See generally, EN-EE-G-001 transformer that is causing the corona or RIV. Degeneff Testimony at (ENT000121).

33; Degeneff Report at 15.

IEEE and EPRI reports indicate that a meaningful aging management As discussed in Answer 108 above, Entergy performs numerous program for transformers may include physical inspections, power monitoring and preventive maintenance techniques, including those factor testing, analysis of insulation resistance, oil leakage, gas- in-oil, cited by NYS. The Indian Point Energy Center Large Power comparison with original factory test reports, vibration (humming), and Transformer Life Cycle Management Plan (ENT000125) is based on impedance versus frequency analysis. Degeneff Testimony at 36; guidance provided by EPRI and the IEEE.

Degeneff Report at 16-17.

A complex mixture of testing at different intervals is required to As discussed in Answer 108 above, Entergy performs numerous manage the effects of aging in transformers. Detection of different monitoring and preventive maintenance techniques both while the kinds of age-related degradation requires varied tests performed at transformers are online and offline.

regular intervals, when the transformer is online and offline. Degeneff Testimony at 37.

Transformers that are part of electrical systems that are used less The cited transformers are within the scope of the maintenance rule and frequently, such as Appendix R transformers for the gas turbines, subject to routine predictive and preventive maintenance techniques.

station service transformers, and transformers for station black out also For dry transformers, these techniques include: visual inspections and should be regularly tested for age degradation. Some of these cleaning, insulation resistance testing, and winding resistance testing.

transformers may not normally be energized and/or operating under full A normally de-energized transformer would not be subject to notable load conditions, so unidentified flaws may be apparent only when they aging mechanisms, as the most significant aging mechanism is related are energized. Degeneff Testimony at 37-38; Degeneff Report at 15-16. to thermal aging.

Power transformers can have thousands of turns, and the ability to Entergy performs routine turns ratio testing to determine if there are any measure within the accuracy of one turn would be required to assess the shorted turns. Contrary to NYSs claim, this is not physically health of the transformer. This is physically impractical with the impractical. Turns ratio is defined as VS/VP. Therefore, it can be transformer energized. Degeneff Testimony at 41; Degeneff Report at measured as accurately as the terminal voltages can be measured during

26. operation.

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REVISED DRAFT (2/8/12) - Privileged and Confidential Litigation Work Product; Attorney-Client Communication Q115. Dr. Degeneff cites transformer failures that occurred at IPEC in 2007 and 2010.

See Degeneff Report at 18, 21. Do those events suggest that such transformers should be managed under Part 54?

A115. (RBR, JWC, TSM) No. The first event, which is identified in NRC Information Notice 2009-10, happened on April 6, 2007, when a fault occurred on the IP3 No. 31 main transformer (a large oil-filled transformer). Info. Notice 2009-10, at 1. This transformer is within the scope of the maintenance rule, which requires that appropriate corrective actions be taken when the performance or condition of an SSC does not meet established goals.

In accordance with IPEC programs required by 10 C.F.R. Part 50, Entergy conducted a root cause analysis and instituted significant corrective actions in response to the event. Entergy determined the most probable cause of the event to be a design flaw in the transformer Phase B bushing (i.e., a GE condenser Type U bushing), not the effects of aging on the transformer.3 In response, Entergy, among other things: (1) replaced the 31 main transformer with a spare transformer that uses a different bushing design; (2) performed testing and inspection on the 32 main transformer, the replacement transformer for the failed 31 main transformer, the unit auxiliary transformer, and high-voltage equipment; (3) established Doble acceptance criteria for large transformers and included the criteria in applicable documents; (4) revised applicable transformer outage preventive maintenance procedures to require engineering review and trending of test data and to specify acceptance criteria for power factor and capacitance testing; and (5) commissioned an independent failure analysis of the failed bushing to assess the need for any further corrective actions. See EN-EE-G-001, Rev. 2 at 65-67 (ENT000121).

3 Bushings are insulating devices used on liquid-immersed transformers to insulate and seal the winding terminal connections through the grounded metal cover or sidewall of the transformer tank. Bushings insulate the primary and secondary windings from the tank.

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The second event occurred in November 2010 in the IP2 21 main transformer (also a large oil-filled transformer) as a result of the failure of main transformer B phase high-voltage bushing.

This transformer also is in the scope of the maintenance rule. Entergy performed a root cause evaluation and determined that appropriate maintenance testing and analyses (including Doble testing and physical inspections) had been performed on the IP2 21 main transformer prior to the event, with no adverse trends or abnormalities noted. The faulty high-voltage bushing had a good operating history and no indications of degradation during predictive monitoring. In addition, when the 21 main transformer was installed in 2006, there was no known operating experience involving deficiencies associated with the high-voltage bushings supplied by the transformer vendor. Entergy arranged for an independent equipment failure analysis of the failed bushing by vendor Lucius Pitkin. That analysis, which included electrical testing and bushing teardowns in the bushing manufacturers facilities, concluded that the bushing failure was due to a design/manufacturing weakness in the high-voltage bushing. Related corrective actions at IPEC included replacing affected main transformer bushings and increasing the frequency of electrical testing of the main transformers from every four years to every two years. See Root Cause Evaluation Report, IP2 Turbine Trip/Reactor Trip Due to 21 Main Transformer Fault, CR-IP2-2010-6801; Event Date: 11-07-2010, Rev. 1 (Oct. 27, 2011) (ENT000130).

Importantly, the definition of components subject to AMR in 10 C.F.R. § 54.21(a)(1) does not include consideration of the number of component failures. Furthermore, the 2007 and 2010 transformer failure eventsneither of which resulted from the effects of aging on the transformersillustrate how the applicable IPEC programs ensure that problems are analyzed, root cause determinations are performed, and corrective actions, including programmatic actions, are defined and implemented in accordance with Part 50 requirements and Entergy procedures.

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Q116. Would a significant loss of functionality in the large power transformers at issue here likely be detected immediately by station operators?

A116. (TSM, RBR, JWC) Yes. For example, in addition to the preventive maintenance and performance monitoring activities discussed above, station operators monitor the in-service performance of large power transformers. For example, the status of voltage on the electrical buses is directly and continuously monitored. If voltage conditions are outside the defined range, then operators in the control room are alerted through automatic actuation of an alarm on the 480V electrical buses so that they may take appropriate corrective actions. IP2 Updated Final Safety Analysis Report, Rev. 20, at 89-90 (2006) (NYS000014F). Additionally, in the event of sustained undervoltage, the normal 480V feeds to the safeguards buses are tripped. Id. at 89.

Q117. Please summarize your response to Dr. Degeneffs concerns related to current transformer monitoring and maintenance practices.

A117. (RBR, JWC, TSM) Dr. Degeneff alleges that established performance monitoring programs are not adequate to detect all of the aging effects and degradation phenomena in transformers and to preclude all failures and, therefore, a Part 54 aging management program is necessary. However, the intent of the maintenance rule and the license renewal rule is to provide reasonable assurance of the continued functionality of SSCs within the scope of those rules, not reasonable assurance that no failures will ever occur or that no aging effect will go undetected.

Like other licensees, Entergy has implemented performance monitoring and preventive maintenance programs as part of the IPEC CLB that are designed to continually monitor and assess the functionality of transformers.

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X. CONCLUSIONS Q118. Please summarize your conclusions regarding Contention NYS-8, as supported by the testimony of Dr. Degeneff A118. (RBR, SED, JWC, TSM) Contention NYS-8 lacks merit for all of the reasons stated above. Several points warrant re-emphasis here. First, one of the fundamental flaws in Dr.

Degeneffs testimony is his failure to use definitions of key terms that are consistent with 10 C.F.R.

§ 54.21 and the 1995 License Renewal SOC. For example, he uses the terms static and passive interchangeably, even though the term static is not contained in 10 C.F.R. Part 54 or the SOC, or in NRC guidance implementing 10 C.F.R. § 54.21.

In addition, Dr. Degeneff erroneously equates the electrical engineering communitys definitions of static and passive with the Commissions Part 54 concept of a passive component. The 1995 License Renewal SOC makes clear that: (1) the Commission developed its own description of passive characteristics of structures and components and directly incorporated these characteristics into the § 54.21(a) IPA process; (2) the Commission intended that the description of passive structures and components incorporated into § 54.21(a) be used only in connection with the license renewal IPA process; and (3) other definitions of passive (such as those cited by Dr. Degeneff) do not apply to Part 54.

As a result, Dr. Degeneffs testimony is filled with errors and contradictions. We have provided numerous explanations and examples that illustrate these significant shortcomings in NYSs testimony. Dr. Degeneffs flawed analogy of a transformer to a pipe is especially noteworthy given the prominence ascribed to it by Dr. Degeneff in his testimony.

Additionally, NYS and Dr. Degeneff do not acknowledge that Part 54 is concerned with managing the effects of aging on component functionality, not on managing aging mechanisms per 108

se. That is, Part 54 requires reasonable assurance that in-scope components will continue to perform their intended functions. It does not seek assurance that components will never fail.

In contrast to NYS, we have provided a comprehensive explanation of why transformers are properly classified as components that are excluded from AMR under Part 54. We have shown how this classification is in agreement with the meaning of active and passive components as explained in the Commissions 1995 License Renewal SOC and implemented in 10 C.F.R. § 54.21(a)(1). We also have shown how the application of this same methodology results in the correct classifications of other components provided in the lists in § 54.21(a)(1)(i).

We have explained why a transformer is more similar to other electrical components in the AMR-excluded list: because its terminal voltages and currentslike those of a power supply, battery charger, power inverter, or transistorchange as the transformer performs its intended function (transformation of the input voltage and current to some other form and/or value of voltage and current) and can be directly measured and monitored. Additionally, we have shown that the classification of transformers as active components that are excluded from AMR in the IP2 and IP3 LRA is consistent with existing NRC guidance, and the NRC Staff LRA review criteria used to during the approval of 71 reactor unit LRAs to date.

Finally, we have explained how Entergy has implemented performance monitoring and preventive maintenance programs at IPEC that are consistent with current industry guidance and appropriate to monitor and assess the continuing functionality of IPEC transformers. In doing so, we have further shown that NYSs criticisms of industry and IPEC-specific monitoring and maintenance programs for transformers (albeit irrelevant to the IPEC LRA) are invalid.

Q119. Does this conclude your testimony?

A119. (RBR, SED, JWC, TSM) Yes.

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Steven E. Dobbs Engineering Consultant Dobbs & Associates Engineering, Inc.

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Thomas S. McCaffrey Entergy Nuclear Operations Inc.

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