ML12181A499

New York State (NYS) Pre-Filed Evidentiary Exhibit NYS000414, Rebuttal Testimony of Dr. Robert C. Degeneff, D. Eng

ML12181A499
Person / Time
Site:	Indian Point
Issue date:	06/29/2012
From:	Degeneff R State of NY, Office of the Attorney General
To:	Atomic Safety and Licensing Board Panel
SECY RAS
Shared Package
ML12181A496	List: ML12181A498 ML12181A499
References
RAS 22870, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01
Download: ML12181A499 (47)

Text

NYS000414 Submitted: June 29, 2012 1 UNITED STATES 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 -----------------------------------x 5 In re: Docket Nos. 50-247-LR; 50-286-LR 6 License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 7 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 8 Entergy Nuclear Indian Point 3, LLC, and 9 Entergy Nuclear Operations, Inc. June 28, 2012 10 -----------------------------------x 11 REBUTTAL TESTIMONY OF 12 DR. ROBERT C. DEGENEFF, D. ENG.

13 REGARDING CONTENTION NYS-8 14 On behalf of the State of New York (NYS or the State),

15 the Office of the Attorney General hereby submits the following 16 testimony by Dr. Robert C. Degeneff, D. Eng., regarding 17 Contention NYS-8.

18 Q. Please state your full name.

19 A. Dr. Robert C. Degeneff, D. Eng.

20 Q. Dr. Degeneff, could you briefly summarize the 21 testimony you provided on December 9, 2011?

22 A. I was retained by the State of New York to provide 23 expert testimony in connection with the States Contention 8, Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 1

1 which asserts that Entergys license renewal application (LRA) 2 should be denied because it improperly excludes transformers 3 from aging management review (AMR) in violation of 10 C.F.R. § 4 54.21 and does not include an aging management plan (AMP) for 5 transformers in violation of 10 C.F.R. § 54.29. In my 6 testimony, as well as my expert report, I explained that 7 transformers are passive devices, which are more similar to 8 components for which AMR is required than those components for 9 which AMR is not required. I also explained that age-related 10 functional degradation in transformers is not readily monitored 11 and so an AMP is needed to assure continued transformer 12 functionality.

13 Q. What is the purpose of this rebuttal testimony you are 14 now providing?

15 A. The State of New York has asked me to respond to 16 Entergys March 30, 2012 and NRC Staffs March 29, 2012 17 testimony on Contention 8.

18 Q. Have you reviewed any additional documents since your 19 December 9, 2011 testimony in preparation for this rebuttal 20 testimony?

21 A. Yes. I have reviewed the following documents filed by 22 Entergy on March 30, 2012: Applicants Statement of Position 23 Regarding Contention NYS-8 (Electrical Transformers) (ENT000090)

Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 2

1 (Entergy SOP); Testimony of Applicant Witnesses Roger Rucker, 2 Steven Dobbs, John Craig, and Thomas McCaffrey Regarding 3 Contention NYS-8 (Electrical Transformers) (ENTR00091) (Entergy 4 Test.); and the supporting exhibits (ENT000092-ENT00130B).

5 Additionally, I have reviewed the following documents filed 6 by NRC Staff on March 29, 2012: NRC Staffs Initial Statement of 7 Position on Contention NYS-8 (Transformers) (NRC000030) (Staff 8 SOP); NRC Staffs Testimony of Roy Mathew and Shelia Ray 9 Concerning Contention NYS-8 (Transformers) (NRC000031) (Staff 10 Test.); and the supporting exhibits (NRC000032-NRC000038).

11 Q. Do any of these documents change your opinion that 12 transformers are passive components that require AMR?

13 A. No. I maintain that transformers qualify as 14 components for which AMR is required under 10 C.F.R. § 54.21.

15 See Pre-Filed Written Testimony of Dr. Robert C. Degeneff 16 Regarding Contention NYS-8 (NYSR00003) (Degeneff Pre-Filed 17 Test.) at 6. Furthermore, in order to maintain transformer 18 functionality, under 10 C.F.R. § 54.29, an aging management 19 program (AMP) is required to provide a reasonable assurance 20 that the effects of transformer aging will be managed during the 21 relicensing period. The failure to properly manage transformer 22 aging may compromise: the integrity of the reactor coolant 23 pressure boundary; the capability to shut down the reactor and Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 3

1 maintain it in safe shutdown condition; or the capability to 2 prevent or mitigate the consequences of accidents which could 3 result in offsite exposures. See Report of Dr. Robert C.

4 Degeneff In Support of Contention NYS-8(NYSR00005) (Dec. 12, 5 2011) (Degeneff Report) at 17-22.

6 Q. Are there any significant points of agreement between 7 your testimony and that of Entergys and NRCs experts?

8 A. Yes. In order to qualify for AMR under 10 C.F.R. § 9 54.21 a component must: (1) have an intended function as set out 10 in 10 C.F.R. § 54.4; (2) perform that intended function without 11 moving parts; (3) perform that intended function without a 12 change in configuration or properties; and (4) not be subject to 13 replacement based on a qualified life or specified time period.

14 In their testimony, Entergys and NRCs experts admit that 15 transformers: (1) perform an intended function as set out in 10 16 C.F.R. § 54.4 (Entergy Test. at 98, A109; Staff Test. at 11, 17 A17); (2) perform that intended function without moving parts 18 (Entergy Test. at 40-41, A58; Staff Test. at 12, A20); and (3) 19 are not subject to replacement based on qualified life or 20 specified time period (Entergy Test. at 14, A24; Staff Test. at 21 8, A.13). Neither set of experts asserts that transformers 22 experience a change in configuration when functioning.

23 Therefore, the only criteria on which their experts and I Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 4

1 disagree is whether transformers function without a change in 2 properties (or state).

3 Q. Dr. Degeneff, Entergy asserts that you have no 4 experience specific to the nuclear power industry or nuclear 5 regulation (Entergy SOP at 9). Do you have any experience with 6 transformers that are used at nuclear plants similar to Indian 7 Point?

8 A. Yes. I own a small manufacturing company that 9 assembles systems of equipment containing transformers, which 10 have been applied in several nuclear facilities. These 11 transformers function no differently than transformers that my 12 company supplies for other industries. This is because a 13 transformers characteristics are exactly the same whether they 14 are applied in a nuclear facility, utility, industrial site, 15 factory, or residential setting. As I explained in my December 16 9, 2011 testimony, my education and professional experience 17 provide me with in-depth knowledge of how transformers work and 18 what is required to maintain their functionality. See Degeneff 19 Pre-Filed Test. at 1-2.

20 Additionally, I have been a member of the Institute of 21 Electrical and Electronics Engineers (IEEE) Transformers 22 Committee for approximately forty years. I currently serve as a 23 fellow on the committeea position that requires nomination and Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 5

1 election, and is held by only 2% of members. As a committee 2 member, I have served on subcommittees and working groups that 3 have written numerous standards providing guidance on the 4 necessary specifications for transformers applied in nuclear 5 plants. For example, I was involved in the creation of IEEE 6 C57.12.00, which provides the general requirements for liquid 7 immersed, distribution power and regulating transformers. I 8 have also worked on guides for the installation of transformers 9 (IEEE C57.12.11) and the testing of transformers insulation 10 capabilities (IEEE C57.12.14), among others. These IEEE guides 11 are used by nuclear plants across the country.

12 Unlike Entergys experts, this is the first time I have 13 consulted for anyone in the nuclear industry as such I have no 14 longer term agenda other than to report the characteristics of a 15 transformer properly.

16 Q. Entergys expert Dr. Dobbs takes issue with your use 17 of the terms static and passive in your December 9, 2011 18 report and testimony (Entergy Test. at 49-54). Can you please 19 explain your use of these terms?

20 A. In my report and testimony, I have used the terms 21 static and passive interchangeably to describe a component 22 that has no moving parts and that performs its function without 23 a change in configuration or properties. 10 C.F.R. § 54.21 does Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 6

1 not use the terms static or passive to refer to AMR-included 2 components. In fact, the term passive is only used for 3 convenience in the 1995 License Renewal Statement of 4 Consideration (SOC), (NYS000016) at 22477, to refer to 5 components that perform an intended function without moving 6 parts or without a change in configuration or properties. Thus, 7 Dr. Dobbss argument that I incorrectly conflate the terms 8 static and passive, is irrelevant to 10 C.F.R. § 54.21, 9 which uses neither term. As the Commission used the term 10 passive for convenience in the SOC, so too have I used the 11 terms passive and static interchangeably in my testimony to 12 succinctly refer to a device that has no moving parts and that 13 functions without a change in configuration or properties.

14 Q. Do the electrical engineering materials cited in your 15 expert report also use the terms static and passive 16 interchangeably?

17 A. No, the electrical engineering materials refer to 18 components that do not have moving parts or are fixed in one 19 place as static and components that do not experience a change 20 in configuration or properties as passive. The electrical 21 engineering materials frequently describe passive devices as 22 those that cannot be controlled externally. This is because an 23 external control is used to change a devices properties, state, Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 7

1 or configuration. A device that the electrical engineering 2 community considers to be both static and passive would require 3 AMR under 10 C.F.R. § 54.21.

4 The electrical engineering community considers a 5 transformer to be both static and passive (see NYS000006 and 6 NYS000007). A transistor, on the other hand, is considered 7 static and active because it does not have moving parts but it 8 undergoes a change in properties and state during its normal 9 intended use. The second edition of the IEEE dictionary defines 10 a transistor as An active semiconductor device with three or 11 more terminals. NYS000415 (emphasis added). And so, a 12 component can be both static and active under the electrical 13 engineering communitys definitions, but such a component would 14 not be subject to AMR under 10 C.F.R. § 54.21.

15 Q. Dr. Dobbs argues that the electrical engineering 16 materials cited in your expert report are not relevant to 17 determining if AMR is required under 10 C.F.R. § 54.21 (Entergy 18 Test. at 49-52). Do you agree?

19 A. No. The materials from the electrical engineering 20 community that I cite are applicable to the Commissions Part 54 21 concept of a passive component because they describe how a 22 transformer functions. Since transformers function the same way 23 in every context, the materials from the engineering community Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 8

1 are relevant to understanding how transformers function at 2 Indian Point. Only with an understanding of transformer 3 functionality can one determine if a transformer is the type of 4 component that requires AMR under 10 C.F.R. § 54.21. The 5 materials I cite reflect the consensus in the engineering 6 community that transformers function without moving parts and 7 without a change in configuration or properties.

8 Additionally, in their testimony, Entergys experts 9 acknowledge that Entergy relies on materials from the electrical 10 engineering community in its transformer management plan.

11 Entergy Test. at 104 (The Indian Point Energy Center Large 12 Power Transformer Life Cycle Management Plan (ENT000125) is 13 based on guidance provided by EPRI and the IEEE.). Therefore, 14 such materials are certainly relevant to this proceeding.

15 Properties of a Transformer 16 Q. Now lets turn to Dr. Dobbss discussion of 17 transformer properties (Entergy Test. at 30-37). Does 10 C.F.R. 18 Part 54 or the 1995 Statement of Consideration define the term 19 property as it is used in 10 C.F.R. § 54.21(a)(1)(i)?

20 A. No. Although the term property is not defined in 10 21 C.F.R. § 54.21(a)(1)(i), the Statement of Consideration does 22 mention that a battery changes its electrolyte properties when 23 discharging. SOC at 22477. This example illustrates what is Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 9

1 considered a property for the purposes of the regulation. A 2 battery is composed of chemicals that undergo physical changes 3 (chemical reactions) in order to produce the desired electrical 4 energy. As the battery discharges electrical energy, the 5 electrolytic properties (such as the conductivity, viscosity, 6 acidity, and density) of the chemicals change. Thus, the traits 7 of the constituent parts of a battery change during its 8 operation. This example shows that in 10 C.F.R. § 9 54.21(a)(1)(i) the term property refers to the qualities or 10 traits of an object.

11 Q. Is Dr. Dobbss definition of property consistent 12 with the definition of property as it is used in 10 C.F.R. § 13 54.21(a)(1)(i)?

14 A. No. Dr. Dobbs expands the definition of property to 15 include not only the traits of an object, but also the traits of 16 other materials with which an object interacts during its 17 operation. Dr. Dobbss definition is incorrect. An object does 18 not inherit the properties of another object or material simply 19 by interacting with it. If this were a valid concept of 20 property, then the pressure and flow rate (in gallons per 21 second) of the fluid in a pipe would be considered properties of 22 the pipe containing the fluid. The pipe then would be 23 considered an active component because the pressure and flow Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 10

1 rate of the fluid in the pipe may change. However, a pipe is 2 specifically listed in 10 C.F.R. § 54.21 as an object requiring 3 AMR because pressure and flow are not properties of the pipe; 4 they are properties of the fluid itself. This shows that Dr.

5 Dobbss concept of property does not match that of 10 C.F.R. 6 Part 54.

7 Q. What effect does Dr. Dobbss definition of property 8 have on his testimony regarding transformers?

9 A. According to Dr. Dobbss logic, since one must refer 10 to electricity, current, voltage, and magnetic field in 11 describing the operation of a transformer, these are the 12 properties of a transformer. Dr. Dobbss entire argument that 13 transformers are active components hinges on his conflation of 14 the properties of the electricity running through the 15 transformer and the properties of the transformer itself. He 16 argues that a transformer is an active component because the 17 current, voltage, and magnetic field travelling through the 18 transformer undergo a change during transformer operation.

19 Q. Do you agree with Dr. Dobbs that voltage and current 20 are properties of a transformer (Entergy Test. at 33-34, A53)?

21 A. No. Dr. Dobbs argues that voltage and current cannot 22 be properties of electricity because they are created by an 23 external force. However, this is fundamentally incorrect. The Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 11

1 laws of physics dictate that voltage and current are properties 2 of the electrical power flowing through the transformer, not 3 properties of the transformer itself. Current is the flow rate 4 of electric charge. Voltage is the electromagnetic force that 5 causes charge to flow through a conductor. The voltage that 6 pushes charge through a conductor is akin to the pressure that 7 pushes water through a pipe. It is commonly accepted that 8 voltage and current are properties of electricity. Dr. Dobbs 9 himself recognizes this fact. He states, In simple terms, 10 electrical power is defined by the equation: Power = (Voltage) x 11 (Current). Entergy Test. at 62, A74. It is immaterial how 12 current and voltage are created because the electricity is the 13 same regardless of whether it is created by a generator or a 14 battery. Electricity cannot exist without voltage and current 15 these are its properties.

16 Dr. Dobbs also makes the erroneous argument that since 17 current and voltage are not peculiar to electricity they 18 cannot be properties of it. Contrary to his assertion, there is 19 no requirement that an objects properties be unique to that 20 object. Moreover, a property does not cease to be a property of 21 one object simply because another object also possesses that 22 property. For example, one property of a transformer is its 23 conductor dimensions. This same conductor size could be used Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 12

1 for a cable or in a breaker. Since this conductor size is not 2 peculiar to the transformer, application of Dr. Dobbss 3 argument would mean that the conductor size is not a property of 4 the transformer (or cable or breaker). This is obviously not 5 the case.

6 Q. Do you agree with Dr. Dobbs that magnetic field is a 7 property of a transformer (Entergy Test. at 33-34, A53)?

8 A. No. Magnetic field is a property of electricity caused 9 by the movement of electric current. Dr. Dobbs acknowledges 10 this: [B]oth positive and negative electric charges are 11 surrounded by an electric field, and movement of those charges 12 produces a magnetic field. Entergy Test. at 33, A51. When 13 there is no electric current flowing into the transformer, there 14 is no magnetic field because the transformers coils and core 15 are incapable of producing one. A magnetic field is also 16 created when electric current passes through a cable, but this 17 component is still considered to be passive under 10 C.F.R. § 18 54.21. This is because the magnetic field created by the 19 electric current does not change the properties of the component 20 through which the current is traveling, be it a cable or a 21 transformer.

22 Dr. Dobbss statements regarding magnetic field illustrate 23 the fundamental inconsistency in his argument. First, he argues Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 13

1 that something cannot be a property of an object if it is 2 created by an external force. According to this reasoning, 3 since voltage and current are created by external forces, they 4 cannot be properties of electricity. Entergy Test. at 13 and 5 33. For the same reason, he concludes that pressure and flow 6 are not properties of water. Entergy Test. at 69, A78.

7 However, he then argues that a magnetic field is a property of a 8 transformer, despite acknowledging that it is created by an 9 external force. Dr. Dobbs states, The change in magnetism that 10 occurs in a transformers core occurs automatically through 11 external electric stimuli supplied by changes in the source and 12 load. Entergy Test. at 35, A54 (emphasis added). He also 13 states, [T]ransformers respond to external voltages, currents, 14 and changes in load. Id. at 78, A87 (emphasis added). Under 15 Dr. Dobbss own reasoning, magnetic field cannot be a property 16 of a transformer because it is created by an external force.

17 Q. What are a transformers properties?

18 A. As I stated in my December 9, 2011 testimony, 19 transformer properties include turns ratios, winding conductor 20 dimensions, insulation type and thickness, core dimensions, and 21 cooling capability. See Degeneff Pre-Filed Test. at 9. These 22 are the constituent parts of the transformer whose traits define 23 the transformers function. They remain the same before, Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 14

1 during, and after a transformers operation.

2 Q. Is the transformation ratio of the input and output 3 voltage a property of the transformer? If so, does this make 4 voltage a property of the transformer as Dr. Dobbs asserts 5 (Entergy Test. at 59-60, A71)?

6 A. The transformation ratio is a property of the 7 transformer. It is equivalent to the transformers turns ratio.

8 Both are determined by the number of turns on a transformers 9 primary winding divided by the number of turns on its secondary 10 winding. This ratio never changes because the number of turns 11 on a transformers primary and secondary windings never changes.

12 The ratio is described by the equation Vp/Vs = Np/Ns=N, where v 13 = voltage, N = turns, s = secondary, and p = primary. As 14 described by this ratio, the voltage of electricity moving 15 through the transformer will be stepped up or down in proportion 16 to the number of turns in the transformers windings. For 17 example, if there are twenty turns on the primary and two turns 18 on the secondary, the turns ratio is 10. The voltage 19 transformation ratio is also 10. So if the input voltage is 20 1000 volts, the output voltage will be 100 volts. This does not 21 make voltage a property of the transformer; it simply describes 22 the change voltage will undergo as it moves through the 23 transformer. Voltage is a property of electricity, not a Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 15

1 property of the transformer itself.

2 Q. Do you agree with Dr. Dobbs that transformers are 3 electrical sources and loads (Entergy Test. at 60, A73)?

4 A. No, Dr. Dobbs is incorrect. A transformer cannot 5 generate power. It is not a source of power any more than a 6 transmission cable is a source of power. The power must be 7 supplied from some other source a generator or battery, for 8 example. The transformer passively transmits power in exactly 9 the same way a cable transmits power.

10 Q. When the States former consultant, Mr. Blanch, 11 stated, Transformers have design properties such as turns 12 ratios, current, voltage, and power, (See 2009 Blanch 13 Declaration, ENT000096, at 6) did he mean that current and 14 voltage are properties of a transformer, as Dr. Dobbs argues 15 (Entergy Test. at 56, A69)?

16 A. No. Mr. Blanch was referring to the fact that each 17 transformer is built to withstand the flow of a certain amount 18 of current at a specified voltage magnitude. A transformers 19 properties, such as its insulation, must be designed to 20 withstand the anticipated maximum voltage of the system in which 21 it is installed. In like manner, the winding conductors are 22 sized to carry the anticipated transformer current. Each 23 transformer is built to withstand a certain range of voltage and Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 16

1 current. This does not make voltage and current properties of 2 the transformer.

3 Q. When you stated that both the input voltage and the 4 load served are completely independent of the design and 5 characteristics of the transformer, did you mean, as Dr. Dobbs 6 asserts, that any transformer will work in any application 7 (Entergy Test. at 64, A76)?

8 A. No. My statement was that a transformer with certain 9 design characteristics can be inserted into multiple systems and 10 perform satisfactorily. For example, lets assume we have a 60 11 hertz (Hz) 10 megavolt ampere (MVA) transformer designed to 12 accept 230 kilovolts (kV) input voltage and output 69kV 13 voltage. One would expect to apply this transformer with the 14 input power delivered at 230kV and the load receiving the power 15 at 69kV. However, this transformer could be applied equally 16 well serving a 5MVA load receiving power at 115kV and deliver 17 that power at 34.5kV. This may not be an economical 18 arrangement, but it is perfectly acceptable technically. In 19 short, a transformers fixed design properties can work with 20 multiple input and output voltages. In other words, a 21 transformers terminal voltages and currents are subject to 22 change based on how the transformer is being applied or used.

23 Under Dr. Dobbss own reasoning, terminal voltages and currents Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 17

1 cannot be properties of a transformer because they are not 2 inherent to the transformer.

3 Q. Does your description of transformer operation 4 resemble that contained in EPRIs License Renewal Electrical 5 Handbook, as Dr. Dobbs argues (Entergy Test. at 56, A69)?

6 A. No. The description of transformer operation contained 7 in the EPRI handbook was written by representatives from Duke 8 Power (now Duke Energy) as part of a prior, unrelated license 9 renewal application. The change in the physical properties of 10 the transformer that these representatives refer to is a change 11 in the voltage and current traveling through the transformer.

12 As I have stated, current and voltage are properties of 13 electricity, not properties of a transformer. Thus, the 14 description of transformer operation contained in the EPRI 15 handbook conflates the properties of electricity and the 16 properties of a transformer.

17 Q. Is your paper, A Method for Constructing Reduced 18 Order Transformer Models for System Studies from Detailed Lumped 19 Parameter Models, at odds with your testimony, as Dr. Dobbs 20 asserts (Entergy Test. at 56-57, A69)?

21 A. No. Dr. Dobbs has fundamentally misunderstood the 22 paper, which discusses a method for creating a computer model 23 that utility engineers can use to perform system studies Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 18

1 involving transformers. The paper states that a transformers 2 terminal impedance (the transformers impedance to the flow of 3 electricity at its input at a specific frequency) is influenced 4 by the frequency of the electric current (the number of times 5 the current alternates per second) flowing through it. During 6 normal operations the frequency is unchanging (e.g., it remains 7 at 60 Hz); however, an external event (such as lightening 8 striking the transformer or a breaker opening the circuit) can 9 change the frequency and subject the transformer to transient 10 voltages. The structure of a transformers insulation must be 11 engineered to withstand differing transient voltages. In order 12 to design the insulation, transformer manufacturers maintain 13 complex computer programs that compute the internal transient 14 voltage distribution when the transformer is subjected to 15 transient voltages. My paper suggests a method for creating a 16 simpler model that can be used by utility engineers to perform 17 system studies. This paper in no way conflicts with my 18 testimony. In fact, it supports my argument that under normal 19 operations, a transformers properties do not change. The 20 frequency characteristic of the transformer, like the turns 21 ratio, is a property of the transformer, and unless there is a 22 problem with the transformer (an internal failure or fault), it 23 will be invariant. This is one measure to determine if there is Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 19

1 a problem with a transformer.

2 Q. Dr. Dobbs asserts that a transformer experiences a 3 change of state when it is put into service (Entergy Test. at 4 11, A24). NRCs experts argue that a transformer changes its 5 state by transforming electrical energy into magnetic energy, 6 then back into electrical energy again. Staff Test. at 6, A8.

7 Do you agree with either of these assertions?

8 A. No. State refers to the condition of matter with 9 respect to structure, form, constitution, phase, or the like.

10 For example, water can change state from a liquid to a gas.

11 During its operation, a transformer does not experience a change 12 in state its constituent parts are exactly the same before the 13 transformer is placed in service and during the period it is in 14 service. For example, unlike a transistor which changes state 15 from a conductor to an insulator during operation, a transformer 16 remains a conductor throughout its operation. NRCs experts 17 incorrectly conflate the properties of electricity and the 18 properties of the transformer. Although the current and voltage 19 in the transformer change, the transformer itself does not.

20 Q. Does a transformer change configuration during its 21 operation?

22 A. No. Configuration refers to the arrangement of an 23 objects physical parts. A change in configuration is a Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 20

1 physical change in the objects arrangement that affects how 2 that object functions. For example, a valve, which is on the 3 AMR-excluded list, changes configuration by physically opening 4 and closing. None of the transformers physical parts change 5 arrangement during operation, and therefore, a transformer does 6 not change configuration. Neither Entergy nor NRC Staff 7 contends that a transformer experiences a change in 8 configuration during operation.

9 Comparisons of Transformers to AMR-Included 10 and AMR-Excluded Components 11 Q. Dr. Degeneff, now lets discuss Entergys and Staffs 12 experts arguments concerning the differences and similarities 13 between transformers and the components listed in 10 C.F.R. § 14 54.21(a)(1)(i). Does Dr. Dobbs present an accurate analysis of 15 your comparison between cables (AMR-included) and transformers 16 (Entergy Test. at 65-68)?

17 A. No. Dr. Dobbss statements regarding cables are 18 technically misleading and misrepresent the physical reality of 19 the situation. Dr. Dobbs presents three cable arrangements when 20 only the third is relevant to my comments. This third 21 arrangement can be represented with the same basic electrical 22 equation that represents a simple two winding transformer. My 23 point was that since a transformers function can be represented Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 21

1 by the same equation as a cables function, a transformer should 2 also be considered a passive component.

3 A transformer in its simplest arrangement consists of two 4 conductors, one supplied with power and the other delivering 5 power to a load. As such, the equations and characteristics of 6 the simple two cable arrangement and a more complex transformer 7 are exactly the same. This is basic to the understanding of 8 cable and transformer operation. It is discussed in Chapters 3 9 and 4 of N. Hancocks book Matrix Analysis of Electrical 10 Machinery, 2nd Edition, excerpted in NYS000416. Moreover, NRC 11 Staffs experts agree that two cables can function as a simple 12 transformer. Staff Test. at 23, A30 (Dr. Degeneff is correct, 13 in a theoretical sense, that two cables in close proximity to 14 each other can function as a simple transformer. . .).

15 Q. NRC Staffs experts argue that the similarities 16 between cables and transformers are not relevant to the question 17 of whether a transformer is an active or passive component.

18 Staff Test. at 23, A30. Do you agree?

19 A. No, the similarities are very relevant for this 20 inquiry. Because cables and transformers are both passive 21 devices involved in the transportation of electricity, the same 22 elements that make it difficult to detect functional degradation 23 in cables also make it difficult to detect functional Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 22

1 degradation in transformers. Responding to a commenter who 2 argued that the aging effects of cables would be immediately 3 detected during normal operation or functional testing, the 4 1995 Statement of Consideration states:

5 The Commission disagrees with the commenters 6 assertion that the aging effects of cable make it 7 easy to monitor functional degradation. Although 8 there have been significant advances in this area, 9 there is no single method or combination of methods 10 that can provide the necessary information about the 11 condition of electrical cable currently in service 12 regarding the extent of aging degradation or 13 remaining qualified life. Degradation due to aging 14 of electrical cables caused by elevated temperature 15 and radiation can cause embrittlement in the form of 16 cracking of insulation and jacket materials. The 17 cracks degrade the electrical properties of the 18 insulation materials. The major concern is that 19 failures of deteriorated cable systems (cables, 20 connections, and penetrations) might be induced 21 during accident conditions. Because these components 22 are relied on to remain functional during and 23 following design-basis events (including conditions 24 of normal operations) and there are currently no 25 known effective methods for continuous monitoring of 26 cable systems, these examples of passive electrical 27 components subject to an aging management review 28 will remain in 10 C.F.R. § 54.21(a)(1)(i) and 29 Section III(f)(i)(a) of the SOC.

30 31 SOC at 22477-78.

32 Just as aging degradation can cause embrittlement in cables 33 that is difficult to detect, it can also cause embrittlement 34 (reducing the degree of polymerization) in transformer 35 insulation structures that cannot be detected simply by 36 monitoring the voltage and current moving through the Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 23

1 transformer. The concern with both is exactly the sameas the 2 insulation embrittles and degrades, the components ability to 3 withstand electrical stress decreases. This decrease cannot be 4 observed in the electrical performance of the transformer or the 5 cable, and left undetected will lead to catastrophic insulation 6 failures.

7 Q. Do you agree with Dr. Dobbss analysis of the 8 differences between pipes and transformers (Entergy Test. at 69-9 72)?

10 A. No. First, as I mentioned above, Dr. Dobbs presents an 11 inconsistent argument on what constitutes a property of an 12 object. He argues that pressure and flow are not properties of 13 fluid because they result from outside forces acting on the 14 fluid. Entergy Test. at 69, A78. However, on page 35, A54, he 15 argues that magnetic field is a property of the transformer, 16 despite admitting that the magnetic field is caused by an 17 external force acting on the transformer. As discussed 18 previously, this characterization of property is incorrect.

19 Pressure and flow are properties of fluid, not properties of a 20 pipe. Furthermore, if these were properties of the pipe, the 21 pipe would be considered an active component, which it is not.

22 Second, Dr. Dobbs misrepresents the analogy between a pipe 23 and a transformer, and fails to properly relate Bernoullis Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 24

1 equation. The analogy between a transformer and a pipe with a 2 changing diameter is as follows:

3

• The power delivered into the transformer (S-in, e.g., MVA 4 or electrical power) is the same as the power flowing out 5 (S-out) of the transformer (the transformer may induce a 6 change in voltage, yet the power remains unchanged). In 7 other words S-in = S-out. The analogy with the pipe is 8 that the volume of fluid per unit time in (Q-in e.g.,

9 cubic feet/sec) is equal to the volume of fluid per unit 10 time flowing out (Q-out) or Q-in = Q-out.

11

• The voltage into the transformer (V-in) is analogous to 12 the area of the pipe at its start (A-in). The voltage 13 out of the transformer (V-out) is analogous to the area 14 of the pipe at its termination (A-out).

15

• The current flowing into the primary winding of the 16 transformer is analogous to the velocity of the flow into 17 the pipe. The current flowing out of the transformers 18 secondary winding is analogous to the velocity of the fluid 19 flowing out of the pipe.

20

• The turns ratio of the transformer (which is invariant) 21 dictates the relationship between the voltage in and the 22 voltage out of the transformer, e.g., N = V-in/V-out. In Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 25

1 like manner, the relationship between the area of the pipe 2 in to that of the area of the pipe out (which is also 3 invariant) is N = A-in/A-out.

4

• The current into the transformer divided by the current out 5 of the transformer is inversely proportional to N, the 6 turns ratio or (V-in/V-out). In an analogous manner, the 7 velocity of the fluid flowing into the pipe divided by the 8 velocity of fluid flowing out of the pipe is inversely 9 proportional to N, the area of the pipe in divided by the 10 area of the pipe out (A-in/A-out).

11 The pipe with a change in diameter is considered a passive 12 device. Since the transformer is performing an analogous 13 transformation it must also be considered a passive device. In 14 both cases, the transformer and the pipe with a changing 15 diameter, the fact that electric power or a fluid flows through 16 each device does not change the properties of either device.

17 Just as the unchanging properties of a pipe cause the change in 18 the fluid, the unchanging properties of the transformer cause 19 the change in the electricity moving through it.

20 Q. NRC Staffs experts argue that transformers are not 21 like pipes because pipes can transport fluid without changing 22 its properties, but transformers cannot transport power without 23 changing current or voltage (Staff Test. at 22, A29). Do you Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 26

1 agree?

2 A. No. The electricity flowing through the transformer 3 need not undergo a change during transformer operation.

4 Normally, the transformer is used to adjust the voltage of the 5 power flowing through the transformer, but if the turns ratio is 6 1 to 1 then the power transmitted through the transformer will 7 remain at the same voltage. This type of transformation is 8 often used in power quality applications. By providing 9 isolation, a transformer with a turns ration of 1 to 1 reduces 10 electrical noise. In such a situation, the current and voltage 11 of the electricity flowing through the transformer would not 12 undergo any change. I have supplied this type of transformer to 13 the nuclear industry.

14 Q. Dr. Dobbs argues that the only aspect relevant to 15 classifying a pipe, heat exchanger, steam generator, and reactor 16 vessel as passive is that they all serve as pressure retaining 17 boundaries (Entergy Test. at 72-73). Do you agree?

18 A. No. As stated in 10 C.F.R. § 54.21, the relevant 19 inquiry is whether a component undergoes changes in 20 configuration, properties, or state during operation. These 21 objects are considered passive because they do not experience a 22 change in configuration, properties, or state. The comparison I 23 made between the pipe, heat exchanger, steam generator, reactor Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 27

1 vessel, and the transformer is that during operation, all of 2 these components contain external materials (fluid or nuclear 3 fuel) that undergo a change in properties or state; however, the 4 components themselves does not change properties, configuration 5 or state. For example, as a steam generator converts liquid to 6 steam, the liquid undergoes a change in state and properties, 7 but the steam generator is still considered passive. Similarly, 8 the nuclear fuel within the reactor vessel changes properties or 9 state, but the component itself does not change. My point is 10 that a component is not considered active merely because the 11 external materials moving through that component change 12 configuration, properties, or state. This is also true of the 13 transformer, where the electricity traveling through the 14 transformer may change magnitude, but the component itself does 15 not change.

16 Q. Do you agree with Dr. Dobbs that the change in 17 resistivity in a transistor is directly analogous to the change 18 in magnetic field inside a transformer (Entergy Test. at 74, 19 A82)?

20 A. No, these changes are not analogous. Resistance is a 21 property of a transistor. During operation, a transistors 22 resistance is changed, causing a change in the transistors 23 properties. Furthermore, the change in resistance can cause a Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 28

1 change in the transistors state from a conductor to an 2 insulator. The Statement of Consideration specifically cites 3 this change in state as the reason for excluding transistors 4 from AMR:

5 Further, the Commission has concluded that a 6 change in configuration or properties should 7 be interpreted to include a change in state .

8 . . For example, a transistor can change its 9 state and therefore would not be screened in 10 under this description.

11 12 SOC at 22477.

13 As I discussed earlier, magnetic field is not a property of 14 a transformer. It is created by the electric current flowing 15 through the transformer. The magnetic field does not cause a 16 change in the transformers properties or state. Unlike the 17 transistor, the transformer always remains a conductor. In 18 comparison, a magnetic field is also created by the electric 19 current traveling through a cable, but this does not make a 20 cable an active component under the regulations.

21 The similarities between transformers and transistors 22 discussed by Dr. Dobbs in his testimony and in ENT000111 are not 23 relevant for the purpose of determining whether a transformer is 24 an active or passive device under 10 C.F.R. § 54.21. The 25 relevant criterion here is whether the device undergoes a change 26 in configuration or properties (including state). The Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 29

1 transistor undergoes a change in properties and state; the 2 transformer does not. Dr. Dobbs attempts to complicate the 3 matter in order to obscure this basic fact.

4 Q. Do you agree with Dr. Dobbs that the differences 5 between batteries and transformers are the same as the 6 differences between batteries and transistors?

7 A. No. Again, Dr. Dobbs attempts to confuse the matter 8 to distract from the relevant distinction between the 9 components. During operation, batteries and transistors undergo 10 a change in properties. The chemical properties of the battery 11 change, and the resistance of the transistor changes. A 12 transistor may also experience a change in state from a 13 conductor to an insulator. A transformer experiences neither a 14 change in properties nor a change in state. This is the 15 relevant difference for purposes of determining whether AMR is 16 required under 10 C.F.R. § 54.21.

17 Q. As with transistors, Entergys expert argues that the 18 fact that power inverters and power supplies require external 19 control in order to perform their intended functions is 20 irrelevant because this is not a valid basis for including them 21 in AMR (Entergy Test. at 81-82). Staffs expert makes a similar 22 argument and notes that transformers can have external control 23 mechanisms that dynamically control the relationship between Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 30

1 input and output voltages (Staff Test. at 24). What is your 2 response?

3 A. First, the transformers to which NRCs expert refers 4 contain on-load tap changers, which have the ability to 5 automatically change the transformer ratio. Such devices are 6 not necessary for transformer functionality and do not change 7 the basic function of the transformer. A tap changer can be 8 compared to a valve on a pipe.

9 Second, like the transistor, the external controls on power 10 inverters and power supplies cause those devices to change 11 state. If the device has an external control then, depending 12 upon the signal from the outside source, the device will perform 13 some activity and change state or configuration, making it an 14 active device. A transformer never changes state, even if it 15 has a tap changer.

16 Q. Is Dr. Dobbs correct in asserting that you apply a 17 theory of inherited exclusion when classifying power 18 inverters, circuit boards, battery chargers, and power supplies 19 as active components (Entergy Test. at 83, A95)?

20 A. No. Dr. Dobbs provides a flawed analysis of the 21 classifications in the chart entitled Comparison of Various 22 Structures and Components on pages 36-38 of my report 23 (NYS000005). He mischaracterizes my argument saying that I Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 31

1 present the idea that power inverters, power supplies, and 2 circuit boards are all excluded from AMR merely because they 3 have solid state devices. My actual statement was that since 4 these components have solid state devices they can change state 5 from a conductor to an insulator (or vice versa), and as such 6 would be considered active devices. Contrary to Dr. Dobbss 7 statement, this is not true for transformers, which cannot 8 change state.

9 Q. Staffs experts distinguish active and passive 10 components arguing that failure of active equipment is usually 11 readily apparent while [f]ailure of a passive structure or 12 component may not be readily apparent. Staff Test. at 8, A11 13 and A12. Do you agree with this characterization?

14 A. No. First, the 10 C.F.R. § 54.21 characterizes AMR-15 included, or passive, components as those that do not have 16 moving parts, do not function with a change in configuration or 17 properties, and are not subject to replacement based on a 18 qualified life or specified time period. The license renewal 19 rule does not say that AMR-included components are those for 20 which failure is not readily apparent.

21 Moreover, the detectability of failure is not a valid 22 criteria for distinguishing active and passive devices.

23 Contrary to Staffs experts assertion, the failure of passive Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 32

1 components may be immediately obvious. For example, the failure 2 of a cable would be readily detected by protective relaying on 3 the system. If a pipe failed it would also be obvious because 4 there would be a drastic change in pressure on the system, an 5 increase in temperature on the system, or liquid would be 6 visually spilling from the pipe. Furthermore, the failure of an 7 active device may not be readily apparent. For example, if a 8 circuit breaker or a transistor failed, it would not be obvious 9 until a signal was sent to one of those devices and it did not 10 respond.

11 Monitoring of Age-Related Degradation in Transformers 12 Q. Dr. Degeneff, now lets discuss the monitoring of 13 aging degradation in transformers. Do you agree with Entergys 14 and Staffs experts that an AMP is not necessary for 15 transformers because aging management is addressed through the 16 requirements of 10 C.F.R. § 50.65 (the maintenance rule) 17 (Entergy Test. at 87, A96, Staff Test. at 20, A26)?

18 A. No, I do not agree. The regulations do not state that 19 those components that would otherwise qualify for AMR under 10 20 C.F.R. § 54.21, are excluded from AMR because they are covered 21 by the maintenance rule. Therefore, the sufficiency of the 22 maintenance rule is not relevant to determining whether a 23 component qualifies for AMR.

Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 33

1 Moreover, the high incidence of transformer failures at 2 nuclear facilities in the last few years is indisputable 3 evidence that the Part 50 regulatory framework is inadequate for 4 monitoring aging degradation and preserving the functionality of 5 transformers. NRCs 2009-2010 Information Notice found: A 6 relatively high incidence of transformer failures has occurred 7 in the last few years, the majority of which could have been 8 avoided had the licensee fully evaluated and effectively 9 implemented corrective actions and recommendations identified in 10 industry operating experience. NRC Information Notice 2009-10, 11 Transformer Failures-Recent Operating Experience (July 7, 12 2009)(NYS000019) at OAG 10000526_ 000002. In other words, if 13 the licensees had taken additional actions, the transformer 14 failures could have been prevented. However, the corrective 15 actions and recommendations indentified in industry operating 16 experience, such as in the IEEE Guide for the Evaluation and 17 Reconditioning of Liquid Immersed Power Transformers, have not 18 been endorsed by NRC and are not NRC requirements. Therefore, 19 the Information Notice states that the majority of transformer 20 failures could have been prevented if licensees had taken 21 voluntary steps. The problem is not that failures arent 22 preventable, but that such preventative measures are not 23 requirements under the Part 50 regulations. Mandating an AMP Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 34

1 for transformers would force licensees to take such additional 2 steps. As the numerous failures show, the Part 50 requirements 3 alone are not effective at preventing transformer failure.

4 Q. Do you agree with Entergys experts that NUREG/CR-5753 5 provides support for the argument that AMR is not needed for 6 transformers (Entergy Test. at 93, A103)?

7 A. No. Although NUREG/CR-5753 found that there is no 8 presently identified transformer aging mechanism that would 9 cause a safety concern, this study is outdated (NYS000012 at 10 ix-x, emphasis added). It was published 16 years ago, prior to 11 the eighteen instances since 2007 in which catastrophic failures 12 have occurred in transformers at nuclear power reactors. See 13 Degeneff Report at 18-22. The study itself noted that 14 transformers were relatively young at the time of the study and 15 recommended additional review every five years.

16 Entergys experts cite an industry guidance document, EPRI 17 1002913, Power Transformer Maintenance and Application Guide, to 18 support their argument that significant changes have been made 19 in surveillance and maintenance practices and programs since 20 NUREG/CR-5753 was written. Entergy Test. at 93, A103. This 21 document itself is ten years old, and like NUREG/CR-5753, does 22 not take into account the recent wave of large transformer 23 failures.

Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 35

1 Q. Entergys experts also argue that AMR is not required 2 for transformers because Generic Safety Issue (GSI) 107 found 3 that the safety significance of identified transformer 4 performance issues was not sufficient to justify new 5 requirements, and that maintenance rule requirements provide a 6 sufficient means by which to address transformer performance 7 issues . . . Entergy Test. at 94, A105. What is your response?

8 A. Again, I do not agree that the maintenance rule must 9 be found insufficient for the license renewal rule to apply to 10 transformers.

11 Like the other studies cited by Entergys experts, GSI 107 12 was issued 12 years ago, in 2000, before the recent wave of 13 transformer failures. Since GSI 107 compared the risk of 14 transformer failure to the cost of regulatory development, the 15 recent increase in transformer failure could change the outcome 16 of the evaluation. Therefore, GSI 107 does not present an 17 accurate assessment of the current situation.

18 Q. Are you arguing, as Entergys experts assert, that 19 Entergy is required to detect, in advance of failure, all of 20 the aging defects and degradation phenomena in components, 21 including transformers (Entergy Test. at 96, A107)?

22 A. No, I am not arguing that an AMP is required to detect 23 all aging degradation in transformers. I am arguing that an AMP Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 36

1 is necessary to detect degradation that can cause the loss of 2 transformer functionality. The SOC specifically states, The 3 Commission believes that regardless of the specific aging 4 mechanism, only aging degradation that leads to degraded 5 performance or condition (i.e. detrimental effects) during the 6 period of extended operation is of principal concern for license 7 renewal. SOC at 22469. Clearly transformer degradation that 8 causes transformer failure is the type of degradation this rule 9 aims to prevent. On pages 14-17 of my December 2011 report, I 10 listed types of aging degradation that can cause loss of 11 transformer functionality. I also explained how these types of 12 degradation can go undetected without an AMP. Entergys experts 13 mischaracterize my argument when they assert that I am concerned 14 with detecting all of the aging effects and degradation 15 phenomena in transformers. I do not believe an AMP is needed to 16 detect all aging effects, but to detect degradation that can 17 lead to failure of the transformer and related systems. While 18 there can never be a guarantee that no failures will occur, the 19 purpose of the license renewal rule is to provide a reasonable 20 assurance that transformers will not fail. The recent history 21 of transformer failure shows that the maintenance rule is 22 insufficient, on its own, to provide this reasonable assurance.

23 Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 37

1 Q. Do you agree with Entergys and NRC Staffs experts 2 that a transformers performance can be readily monitored as it 3 performs its intended function (Entergy Test. at 42, A60; Staff 4 Test. at 12, A20)?

5 A. No. Entergys and NRC Staffs experts are incorrect 6 when they contend that transformer degradation results in a 7 change in the electrical performance of the transformer and the 8 associated circuit. Due to the transformers passive nature, 9 electricity can continue to pass through a degraded transformer 10 up until the moment of transformer failure. For example, 11 degradation to a transformers insulation will not result in any 12 noticeable change to the current and voltage, but over time this 13 can lead to transformer failure. This is explained in more 14 detail on pages 38-40 of my report (NYS000005).

15 Q. Do you agree with Staffs and Entergys experts that 16 the relevant consideration for purposes of determining whether 17 AMR is required, is whether gross failure of transformers is 18 readily detectable (Staff Test. at 8, 15, 23-24; Entergy Test.

19 at 107, A116)?

20 A. No, the purpose of the license renewal rule is to 21 prevent gross failure, not to detect it. Entergy and NRC Staff 22 argue that as long as electricity is flowing correctly through 23 the transformer, its performance is not degraded, and when the Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 38

1 transformer fails it is obvious. But it is the failure that is 2 readily apparent, not the degradation. Transformer failure is 3 the effect of unnoticed degradation, which is what an AMP is 4 meant to prevent. This is why the Statement of Consideration 5 says that the Commission is concerned with aging degradation 6 that leads to degraded performance or condition (i.e.

7 detrimental effects) . . . A transformer that appears to be 8 functioning properly can nonetheless be in a degraded condition 9 that will lead to failure. The presence of certain age-related 10 degradation that can cause failure and is undetectable by 11 performance monitoring is the very reason why an AMP is 12 necessary for transformers.

13 I have participated in numerous transformer failure post 14 mortems, which have found that the transformer failure could 15 have been prevented if the transformer owners had had an 16 effective aging management program.

17 Q. Can the age-related degradation of transformers be 18 monitored online (i.e., while the transformer is operating)?

19 A. No. Many of the tests to determine transformer 20 degradation must be conducted while the transformer is offline.

21 For example, the aging of cellulose insulation cannot be 22 monitored with the transformer operating. Nor can all the 23 dissolved gas in the transformers oil be determined with the Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 39

1 transformer operating. Additionally, the mechanical integrity 2 of the core and coils can not be determined with the unit 3 operating. This requires physical inspection of the 4 transformer, where the transformer is taken offline and drained 5 of oil. It is unrealistic to represent that the aging condition 6 of a transformer can be ascertained while the transformer is in 7 operation.

8 This is significant because Entergy states that for all 9 electrical components without moving parts indentified in the 10 AMR-excluded lists, the functional degradation resulting from 11 the effects of aging can be monitored online (i.e., while 12 operating). Entergy Test. at 40, A57. In contrast, the AMR-13 included components have aging-related degradation of their 14 passive intended functions that cannot be monitored online.

15 This is true of the transformer.

16 Q. Are Entergys experts correct that some of the 17 procedures you suggest for monitoring age-related degradation in 18 transformers may be detrimental to transformer operation because 19 they can introduce moisture and contaminants into the 20 transformer internals and oil?

21 A. No, Entergys experts representation of my comments 22 about monitoring the condition of the transformer takes an 23 extreme and unrealistic position. Monitoring the health of the Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 40

1 transformer does not place the transformer in danger. All of 2 the monitoring activities I suggested have been applied safely 3 in the utility industry. A program for inspecting a transformer 4 must be tailored to each unique transformer and its performance 5 history. This is alluded to in the EPRI Copper Book when it 6 discusses the draining of oil from the unit. See ENT000129. A 7 transformer monitoring program must meet the prudent guidance of 8 the electrical industry.

9 On page 101 of Entergys testimony a section of EPRIs 10 Copper Book is reproduced. A careful reading shows that there 11 are instances when internal inspection is warranted and this can 12 be accomplished safely. Furthermore, Entergys Large Power 13 Transformer Inspection Guidelines (ENT000121) contains 14 guidelines on conducting internal inspections of transformers.

15 Entergys experts state in their testimony: If transformer 16 degradation was detected through the current monitoring that 17 Entergy performs on the transformers, then Entergy would, if 18 warranted, perform an internal inspection of the transformer to 19 determine and correct the cause. See generally, EN-EE-G-001 20 (ENT000121). ENTR00091 at 104.

21 Q. In a chart on pages 103-104 of their testimony, 22 Entergys experts explain the means by which they claim to 23 address your concerns regarding the monitoring of aging Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 41

1 degradation in transformers. Does this chart alleviate your 2 concern that aging degradation will go unnoticed in transformers 3 at Indian Point?

4 A. No. The rate of transformer failure at nuclear 5 plants across the country shows that performance monitoring is 6 insufficient to provide a reasonable assurance that transformer 7 functionality will be maintained. This is because there are 8 significant transformer failure modes that involve aging 9 degradation of transformer components that do not affect 10 transformer operating performance until the transformer fails.

11 Therefore, the performance monitoring outlined in Table 4, which 12 is in accordance with Part 50, is insufficient to maintain the 13 functionality of aging transformers. For example, Entergys 14 experts assert that [m]echanical changes in the transformer can 15 be detected through capacitance testing as is performed at 16 IPEC. Entergy Test. at 103. Capacitance testing, however, is 17 inadequate for monitoring the mechanical and structural 18 integrity of the coil assembly. Visual inspection of the coil 19 assembly is the only way to properly assess its integrity. As 20 this requires draining the oil from the transformer, such 21 degradation is not observed through performance monitoring.

22 Similarly, Entergys experts assert that furanic compound 23 analysis of the oil is Entergys method of detecting Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 42

1 polymerization. Id. However, as I explain on page 14 of my 2 December report, visual inspection is necessary to determine 3 whether the polymerization is occurring to a small degree and 4 without significant risk throughout the insulation, or whether 5 it is occurring intensely and with significant risk at a small 6 number of locations.

7 Importantly, this chart refutes Entergys and Staffs 8 claim that age-related degradation in transformers is readily 9 monitored, since Entergys experts admit that there are 10 conditions that may require the transformer oil to be drained so 11 that a physical inspection of the transformers internal 12 structure can be conducted. This shows that the transformers 13 ability to perform its intended function is not monitored solely 14 by a change in the electrical performance of the transformer and 15 associated circuits.

16 Q. Your December 9, 2011 report cited a number of 17 recent transformer failures. NYS000005 at 18-22. Have you come 18 across any additional transformer failures that were not 19 prevented by performance monitoring but could have been 20 prevented with an AMP?

21 A. Yes. I have found two additional licensee event 22 reports involving transformer failures that were not prevented 23 by current monitoring but could possibly have been prevented by Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 43

1 an AMP:

2

• On June 27, 2011, the off-site AC power sources to Unit 2 3 Prairie Island Nuclear Generating Plant were declared 4 inoperable as a result of Transformer 2RY lockout and 5 less than the required minimum voltage on the 6 transmission system. The overcurrent ground detection 7 relay actuated due to a bus phase to ground fault 8 resulting from failed gasket material, causing the 9 transformer lockout. It was determined that a less than 10 adequate review of the Preventive Maintenance Deferral 11 Process delayed bus inspection that would likely have 12 identified and corrected the problem (a hole in the bus 13 duct due to exposure to moisture and rain). See 14 NYS000417. This problem could have been prevented with 15 more frequent inspection of the bus duct. The bus ducts 16 degradation did not result in a change to the 17 transformers electrical performance until the moment of 18 lockout.

19

• On January 30, 2012, Byron Station Unit 2 experienced a 20 loss of normal offsite power and a reactor trip. On 21 February 28, 2012, Byron Station Unit 1 experienced a 22 loss of normal offsite power. Both events were caused by 23 the failure of system auxiliary transformer inverted Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 44

1 insulators (bushings). The insulator failures were 2 caused by service propagation of a large manufacturing 3 material defect. See NYS000418. It is possible that 4 these bushing defects could have been found through 5 visual inspection, but not performance monitoring.

6 Several of the recent transformer failures have been 7 caused by bushing failures. For example, the main 8 transformer failures at Indian Point Units 3 and 2 in 9 2007 and 2010, respectively, were caused by bushing 10 failures. Entergy Test. at 105-06, A115. The bushing is 11 an integral part of the high voltage power transformer.

12 A high voltage power transformer cannot function reliably 13 without bushings. The bushing is the point of electrical 14 connection between the electrical system and the 15 transformer. The purpose of the electrical 16 characteristics of the bushing are the same as those of 17 the high voltage cable, i.e., to provide a low impedance 18 path over which the power can flow and concomitantly to 19 provide insulation between the conductor and ground (or 20 other phase conductors). The degradation of the ability 21 of either to perform its intended task cannot be 22 consistently determined by measuring the change in the 23 transformers electrical performance.

Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 45

1 Q. Do you have any concluding remarks?

2 A. Transformers are a critical component in 3 maintaining the safety and reliability of the Indian Point 4 facility. Entergy claims that the program they have in place 5 can maintain the safety and reliability of the system without an 6 AMP for transformers. This is simply not the case, as 7 demonstrated by the transformer failure rate in recent years.

8 Without an AMP, there cannot be reasonable assurance that the 9 effects of aging will be adequately managed so that transformer 10 functionality will be maintained consistent with the CLB for the 11 period of extended operation.

12 Q. Does this conclude your testimony?

13 A. Yes.

Rebuttal Testimony of Dr. Robert Degeneff, D. Eng.

Contention NYS-8 46