ML12298A228
| ML12298A228 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 10/16/2012 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| SECY RAS | |
| References | |
| RAS 23660, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01 | |
| Download: ML12298A228 (324) | |
Text
Page 1457 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 ATOMIC SAFETY AND LICENSING BOARD PANEL 5 + + + + +
6 HEARING 7 --------------------------------x Docket Nos.
8 In the Matter of: : 50-247-LR and 9 ENTERGY NUCLEAR OPERATIONS, INC.: 50-286-LR 10 (Indian Point Generating Units 2:
11 and 3) : ASLBP No.
12 --------------------------------x 07-858-03-LR-BD01 13 Tuesday, October 16, 2012 14 9:00 a.m.
15 16 DoubleTree by Hilton Hotel Tarrytown 17 Westchester Ballroom 18 455 South Broadway 19 Tarrytown, New York 20 21 BEFORE:
22 LAWRENCE G. McDADE, Chair 23 MICHAEL F. KENNEDY, Administrative Judge 24 RICHARD E. WARDWELL, Administrative Judge 25 Neal R. Gross & Co., Inc.
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Page 1458 1 APPEARANCES:
2 On Behalf of Entergy Nuclear Operations, Inc.:
3 KATHRYN M. SUTTON, ESQ.
4 PAUL M. BESSETTE, ESQ.
5 RAPHAEL KUYLER, ESQ.
6 BRAD FAGG, ESQ.
7 of: Morgan, Lewis & Bockius LLP 8 1111 Pennsylvania Avenue, N.W.
9 Washington, D.C. 20004 10 (202) 739-5738 (Sutton) 11 (202) 739-5796 (Bessette) 12 (202) 739-5146 (Kuyler) 13 (202) 739-5191 (Fagg) 14 ksutton@morganlewis.com 15 pbessette@morganlewis.com 16 rkuyler@morganlewis.com 17 bfagg@morganlewis.com 18 and 19 WILLIAM GLEW, ESQ.
20 Assistant General Counsel 21 Entergy Nuclear Operations, Inc.
22 440 Hamilton Avenue 23 White Plains, New York 24 (914) 272-3360 25 wglew@entergy.com Neal R. Gross & Co., Inc.
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Page 1459 1 On Behalf of the Nuclear Regulatory 2 Commission:
3 SHERWIN E. TURK, ESQ.
4 BETH N. MIZUNO, ESQ.
5 DAVID E. ROTH, ESQ.
6 Office of the General Counsel 7 Mail Stop - O-15 D21 8 U.S. Nuclear Regulatory Commission 9 Washington, D.C. 20555-0001 10 (301) 415-1533 (Turk) 11 (301) 415-3122 (Mizuno) 12 (301) 415-2749 (Roth) 13 sherwin.turk@nrc.gov 14 beth.mizuno@nrc.gov 15 david.roth@nrc.gov 16 On Behalf of the State of New York:
17 JOHN J. SIPOS, ESQ.
18 Assistant Attorneys General 19 Office of the Attorney General of the 20 State of New York 21 The Capitol 22 State Street 23 Albany, New York 12224 24 (518) 402-2251 25 john.sipos@ag.ny.gov Neal R. Gross & Co., Inc.
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Page 1460 1 On Behalf of the State of New York:
2 (cont.)
3 JANICE A. DEAN, ESQ.
4 KATHRYN LIBERATORE, ESQ.
5 Assistant Attorneys General 6 Office of the Attorney General of the 7 State of New York 8 120 Broadway, 26th Floor 9 New York, New York 10271 10 (212) 416-8459 (Dean) 11 (212) 416-8482 (Liberatore) 12 janice.dean@ag.ny.gov 13 kathyrn.liberatore@ag.ny.gov 14 15 On Behalf of Riverkeeper, Inc.:
16 PHILLIP MUSEGAAS, ESQ.
17 DEBORAH BRANCATO, ESQ.
18 Riverkeeper, Inc.
19 20 Secor Road 20 Ossining, New York 10562 21 (800) 21-RIVER 22 phillip@riverkeeper.org 23 dbrancato@riverkeeper.org 24 25 Neal R. Gross & Co., Inc.
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Page 1461 1 On Behalf of Hudson River Sloop 2 Clearwater, Inc.:
3 MANNA JO GREENE, Environmental Director 4 STEVEN C. FILLER 5 KARLA RAIMUNDI 6 Hudson River Sloop Clearwater, Inc.
7 724 Wolcott Avenue 8 Beacon, New York 12508 9 (845) 265-8080 10 mannajo@clearwater.org 11 12 On Behalf of the State of Connecticut:
13 ROBERT D. SNOOK, ESQ.
14 Assistant Attorney General 15 Office of the Attorney General 16 State of Connecticut 17 55 Elm Street 18 Post Office Box 120 19 Hartford, Connecticut 06141-0120 20 (860) 808-5020 21 robert.snook@po.state.ct.us 22 23 24 25 Neal R. Gross & Co., Inc.
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Page 1462 1 TABLE OF CONTENTS 2 WITNESSES 3 Robert M. Aleksick 4 Nelson Azevedo 5 Alan Cox 6 Allen Hiser 7 Joram Hopenfield 8 Jeffrey Horowitz 9 Ian D. Mew 10 Matthew Yoder 11 12 Exhibits: Mark Recd 13 NRCR40001 1474 14 NRC Staff 000165 1613 1613 15 NRC Staff 000166 1613 1613 16 Revised Staff Exhibit List 000001 1613 17 18 19 20 21 22 23 24 25 Neal R. Gross & Co., Inc.
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Page 1463 1 P R O C E E D I N G S 2 9:00 A.M.
3 JUDGE McDADE: Okay, the hearing will 4 come to order. There's a couple of preliminary 5 matters that we wanted to take up first of all with 6 regard to the proposed settlement agreement.
7 Is Cortlandt present this morning?
8 Apparently not.
9 Have the parties heard from Cortlandt 10 and have they expressed an opinion with regard to 11 the viability of the settlement agreement?
12 MR. BESSETTE: Paul Bessette for the 13 Applicant, Your Honor. We contacted Town of 14 Cortlandt attorney representatives and we did hear 15 from them yesterday. We forwarded them the proposed 16 settlement and the question posed by the Board and 17 they said that the Town of Cortlandt does not take a 18 position with the proposed settlement, with respect 19 to the proposed settlement.
20 JUDGE McDADE: Okay, one of the other 21 things that we had asked yesterday is with regard to 22 the REMP, how the settlement agreement would fit 23 into that from the standpoint of the NRC staff.
24 Mr. Turk?
25 MR. TURK: Yes, thank you, Your Honor.
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Page 1464 1 I did speak with our regional inspector who is 2 involved very much with the groundwater monitoring 3 and other aspects of releases from the plant. This 4 was Mr. James Noggle, who was listed as one of our 5 witnesses on the spent fuel pool leak contention.
6 I am informed that the NRC staff 7 inspects against the Radiological Environmental 8 Monitoring Program every two years. They do go out 9 and during that inspection observe whatever sampling 10 is being done at the time of the inspection.
11 Sometimes that may involve fish tissue sampling, 12 sometimes it does not. It depends what's going on 13 at the plant at that particular time.
14 I understand that there are two aspects 15 of the agreement between Entergy and Riverkeeper and 16 Clearwater. One aspect is that an additional fish 17 tissue sampling location will be established either 18 in or in the vicinity of Haverstraw Bay. That 19 additional tissue sampling location would be put 20 into the REMP. So the staff, during its 21 inspections, will be able to observe whether or not 22 that fish tissue sampling is going on.
23 And in fact, every year, the REMP must 24 be updated and the results of the tissue sampling 25 program are reported to the NRC pursuant to the Neal R. Gross & Co., Inc.
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Page 1465 1 REMP. So even if the staff was not present during 2 tissue sampling, they will receive reports annually 3 of the tissue sampling that's being conducted. So 4 the staff will be aware and will be able to inspect 5 against the REMP and that additional condition.
6 JUDGE McDADE: Okay, thank you, Mr.
7 Turk.
8 Is that acceptable to Riverkeeper?
9 MR. MUSEGAAS: Yes, Your Honor, it is.
10 JUDGE McDADE: And to Clearwater?
11 MS. GREENE: Yes, Your Honor.
12 JUDGE McDADE: Okay, one question and it 13 came up from what Mr. Turk just said. In the 14 settlement agreement, it talks about monitoring at 15 Haverstraw Bay or the vicinity. Can you explain to 16 me what "or the vicinity" means in that context?
17 MR. BESSETTE: Yes, Your Honor. This is 18 Paul Bessette. It's my understanding that there are 19 certain requirements for where fish samples cannot 20 be taken if the water is too warm. And my 21 understanding is that Haverstraw Bay is fairly 22 shallow. So under the unusual circumstance where 23 we're trying to take a fish sample, and the water is 24 too warm, per the permit requirement and the REMP, 25 we would have to go slightly outside the area for Neal R. Gross & Co., Inc.
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Page 1466 1 deeper water where it's cooler. So it is not -- we 2 fully intend to sample in Haverstraw Bay. It's only 3 if the temperature permit requirements require us to 4 go outside.
5 JUDGE McDADE: And Riverkeeper, that's 6 consistent with your understanding and acceptable to 7 you?
8 MR. MUSEGAAS: Yes, it is. That 9 depiction or description of Haverstraw Bay and the 10 environment and that part of the river is fairly 11 accurate. We would assume Entergy would seek a 12 sampling location either slightly north or slightly 13 south where the channel is deeper and you would be 14 able to collect the fish samples we would need, so 15 yes.
16 JUDGE McDADE: Okay, and that's 17 consistent with your understanding for Clearwater, 18 Ms. Greene?
19 MS. GREENE: Yes, it is, Your Honor.
20 JUDGE McDADE: Okay, thank you.
21 MR. TURK: Your Honor, I'm sorry. I 22 need to make one more statement. Sherwin Turk 23 again. One more statement so there's no 24 misunderstanding. The staff does not require that a 25 sampling location be established at Haverstraw Bay, Neal R. Gross & Co., Inc.
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Page 1467 1 so following the inclusion of that tissue sampling 2 location in the REMP, Entergy would be able to 3 change it without the NRC staff taking enforcement 4 action.
5 What the staff will require is that 6 every pathway that could be hazardous to man be 7 sampled. So in this instance, Entergy is already 8 sampling fish tissues near the outfall from the 9 effluent outfall from the plant. This would be an 10 additional sampling location.
11 So what the NRC staff will be concerned 12 about is to make sure that the ingestion pathway is 13 sampled so that if there's any hazard to man, the 14 NRC will be aware of it. But we will not require 15 any specific location at Haverstraw Bay be included 16 in the program.
17 JUDGE McDADE: I understand there is an 18 REMP in place and that will continue to be in place.
19 This is an additional commitment on the part of 20 Entergy made to Clearwater and Riverkeeper in 21 proposed settlement of this contention. And it's 22 understood in that light.
23 One other thing I would ask about this, 24 we had had a similar discussion back in January, 25 back in December. There was a settlement motion Neal R. Gross & Co., Inc.
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Page 1468 1 with regard to a New York contention, and 2 specifically, in the settlement agreement on New 3 York-24. At the end of that agreement, there was 4 language on the representation of Entergy that any 5 attempt to enforce the terms of the settlement 6 agreement or this order in any Court will not be 7 subject to objection by Entergy or any successor 8 interest to Entergy due to a lack of subject matter 9 jurisdiction. That was part of the agreement with 10 regard to the settlement on New York-24.
11 Would Entergy have any objection to that 12 language being added to the settlement agreement in 13 this instance?
14 MR. BESSETTE: Just one moment, Your 15 Honor.
16 (Pause.)
17 No, Your Honor, we have no objection to 18 that added language.
19 JUDGE McDADE: Judge Kennedy, Judge 20 Wardwell, do you have any other questions about a 21 settlement agreement?
22 JUDGE KENNEDY: I do not.
23 JUDGE McDADE: Are there any other 24 matters with regard to the settlement agreement that 25 any of the parties think that we should be aware of?
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Page 1469 1 Ms. Greene?
2 MS. GREENE: Yes, Your Honor. Mr. Turk 3 just made reference to the measurement at the 4 outfall. And I just would like to go on the record 5 as saying the measurement at the outfall is not the 6 same as the measurement at Haverstraw Bay.
7 One of Clearwater's concerns and we have 8 settled and we've agreed to the settlement, but one 9 of our concerns is that Haverstraw Bay is a 10 potential drinking water source. It does not seem 11 to us that the oversight that is in place and I re-12 read all of the documents last night. And it just 13 seems to me that that is seriously missing inasmuch 14 as several other drinking water sites are mentioned 15 as being at higher elevations.
16 And what occurs to me is that other than 17 this testing, the responsibility then becomes the 18 responsibility of the United Water of New York to 19 assure that they test and protect the people of 20 Rockland County. But it does seem to us that that 21 should, that that investigation should have been 22 part of this process.
23 Nonetheless, we agree with the 24 settlement. Just given that the outfall was just 25 cited as a test for drinking water, I think we -- I Neal R. Gross & Co., Inc.
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Page 1470 1 felt compelled to make that correction.
2 JUDGE McDADE: Okay, thank you. And I 3 understand that in that context and again, it's our 4 understanding from the settlement agreement that as 5 part of the settlement Entergy is agreeing to this 6 additional condition. And we've talked about how 7 that could be enforced.
8 First of all, through the monitoring of 9 the REMP by the NRC and in the event that either of 10 the parties believe that Entergy for some reason or 11 a successor interest was not living up to the terms 12 of its agreement, that they would not have any 13 objection to subject matter jurisdiction based on 14 subject matter jurisdiction in the event you were to 15 seek to enforce it.
16 MS. GREENE: Thank you.
17 JUDGE McDADE: What we're going to do, 18 we're not going to announce right now from the bench 19 what we're going to do with regard to the settlement 20 agreement. We understand that the parties are 21 concerned to get to this quickly because you want to 22 know what to do with the witnesses who are going to 23 be coming on that particular contention.
24 What we would propose to do is to 25 discuss it among ourselves. After the lunch break, Neal R. Gross & Co., Inc.
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Page 1471 1 we will announce our decision with regard to the 2 settlement agreement. We're required to issue on 3 any settlement agreement a written order, but we 4 would announce it orally after lunch and that we 5 would get the written order out as quickly as 6 possible thereafter.
7 Anything else with regard to the 8 settlement agreement?
9 MR. BESSETTE: Paul Bessette for the 10 Applicant. Nothing here, Your Honor.
11 JUDGE McDADE: Riverkeeper?
12 MR. MUSEGAAS: Nothing from Riverkeeper.
13 Thank you.
14 JUDGE McDADE: Excuse me. Clearwater?
15 MS. GREENE: We're okay, Your Honor.
16 JUDGE McDADE: For the NRC staff?
17 MR. TURK: Nothing further, Your Honor.
18 JUDGE McDADE: Okay, yesterday, there 19 was a discussion of additional testimony or a 20 revised testimony with regard to New York State-5.
21 What is the status with regard to that?
22 MS. DEAN: Could you clarify, Your 23 Honor? We discussed yesterday the motion, the 24 redaction that was incorrect?
25 JUDGE McDADE: Yes. And I take it we're Neal R. Gross & Co., Inc.
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Page 1472 1 not going to receive an additional exhibit. We're 2 just going to go with what was done orally. Is that 3 correct?
4 MS. DEAN: I'm sorry, Your Honor. I 5 understood that you did not want me to file a 6 corrected version, but I'm happy to if you'd like.
7 It might make --
8 JUDGE McDADE: No, it was totally up to 9 the State of New York whether they wished to file it 10 or not. I realize we're all here in the hearing and 11 the idea is not to create more administrative issues 12 than necessary.
13 MS. DEAN: We do intend to file a 14 corrected version later today, Your Honor.
15 JUDGE McDADE: Okay. One of the things 16 that I should mention with regard to that, we are in 17 all probability going to be receiving additional 18 exhibits and changes in testimony. There are other 19 contentions that we have dealt with that we're not 20 going to deal with during the course of this 21 particular hearing. We just won't get to and some 22 of them that we had asked about doing in December 23 and there were witness availability issues then.
24 If we do have any changes in the future, 25 what we need to do is to have a motion to strike Neal R. Gross & Co., Inc.
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Page 1473 1 what's already been received and a motion to replace 2 it with the new version. What I'm talking about is 3 just a very brief, just a one page simply explaining 4 what you're doing.
5 The other is last night we talked about 6 the new NRC 000165 and 000166. Are there any 7 objections to the admissions of those two exhibits 8 from any party?
9 Entergy?
10 MR. BESSETTE: Paul Bessette for the 11 Applicant, no, Your Honor, no objections.
12 JUDGE McDADE: New York?
13 MR. SIPOS: Your Honor, John Sipos. We 14 had some difficulty accessing the material. Ms.
15 Mizuno has handed us paper copies this morning.
16 With the Court's indulgence, we would request a 17 little extra time to review it. I would imagine we 18 could resolve that by the end of the day.
19 JUDGE McDADE: Okay, why don't we take 20 this up again after lunch with regard to those two 21 exhibits. Also with that the NRC submitted it's 22 revised exhibit list which would be Revision 4 on 23 the exhibit list. And in the event those exhibits 24 are accepted, then we would also accept NRC 4, 25 Revision 4 and have that bound into the transcript Neal R. Gross & Co., Inc.
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Page 1474 1 rather than the transcript having Revision 3.
2 (Whereupon, the above-referred to 3 document was marked as NRCR40001 for 4 identification.)
5 Are there any other preliminary matters 6 that we should take up before we proceed to the 7 testimony?
8 Mr. Sipos?
9 MR. SIPOS: Your Honor, John Sipos for 10 the State of New York. Just following up on your 11 first point of a few minutes ago, if there is 12 revised testimony or things of that nature, with the 13 motion to strike, how would you like the new 14 document that is being submitted designated 15 following the R protocol? Would it be the next 16 number after the R or would you like us to use the 17 same number, assuming it has already been revised?
18 JUDGE McDADE: If, for example, New 19 York-2 were revised, it would just simply be with 20 the R and 2. And as I sit here right now I don't 21 know whether or not New York-2 has already been 22 revised, but we have the revision number and then 23 the number of the exhibit later on.
24 MR. SIPOS: And so the motion to strike 25 would -- for example, in New York-5, I believe it's Neal R. Gross & Co., Inc.
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Page 1475 1 already an R in front of it. Do you wish it to be 2 another number after the R or are we replacing the 3 one in place through the motion to strike?
4 JUDGE McDADE: Yes. And I'm sorry that 5 that was somewhat confusing, but it would be New 6 York R-3 meaning revision 3 and then we have a 7 certain number of zeros and then we have 5 meaning 8 that's the exhibit number. So just like we have 9 with the -- and we've had a number of revisions with 10 regard to the exhibit lists, and the exhibit list is 11 usually exhibit 1, so it would be New York R-17, 12 then 0001. And if you revise the exhibit list 13 again, it would be R-180001.
14 MR. SIPOS: Very good. I think I 15 understand, Your Honor. Thank you.
16 JUDGE McDADE: Okay, I hope I do and I 17 haven't misled you.
18 Any other preliminaries from Entergy?
19 MR. ROTH: David Roth, counsel for the 20 staff.
21 JUDGE McDADE: First of all, from 22 Entergy?
23 MR. BESSETTE: Nothing, Your Honor.
24 JUDGE McDADE: Nothing further from New 25 York?
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Page 1476 1 MR. SIPOS: Correct, Your Honor.
2 Nothing further.
3 JUDGE McDADE: Riverkeeper?
4 MR. MUSEGAAS: Nothing further. Thank 5 you.
6 JUDGE McDADE: We're just sort of moving 7 from left to right here.
8 From the NRC staff?
9 MR. ROTH: David Roth from NRC staff. I 10 think you just answered the question already on how 11 to replace the testimony, but we've identified the 12 NRC's staff testimony in FAC is off in its numbering 13 for NRC exhibits. For instance, NRC, it lists 14 Exhibit 000101 when it should list Exhibit 000123.
15 And so we need to file a correction on that.
16 JUDGE McDADE: Okay, thank you.
17 Anything further from Clearwater before we get 18 started with the testimony?
19 MS. GREENE: Just an update, Your Honor, 20 that I did speak with the person I thought might be 21 an excellent translator and that person is not 22 available. So we'll keep looking as I expect --]
23 JUDGE McDADE: As will we, but thank 24 you.
25 MS. GREENE: Otherwise, nothing else, Neal R. Gross & Co., Inc.
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Page 1477 1 Your Honor.
2 JUDGE McDADE: All the witnesses are 3 ready, hopefully.
4 Judge Kennedy?
5 JUDGE KENNEDY: I'm ready.
6 JUDGE McDADE: Go for it.
7 JUDGE KENNEDY: This is Judge Kennedy.
8 I'd like to take us back through some of the 9 testimony yesterday. In the petition and in the 10 admitted contention, the inspection frequency, 11 inspection method, and the repair/replacement 12 criteria was called out as specific issues with the 13 Aging Management Program. In other words, they were 14 not identified in the Aging Management Program. And 15 we heard some testimony yesterday that shed some 16 light on it and I'd like to go back to that and make 17 sure I understand it clearly.
18 So I'd like to start with Mr. Cox and I 19 think we were going through NSAC-202. If it's 20 useful to put it up, we'll have that put up. I 21 think it was Riverkeeper 000012. And I guess what 22 I'd like to do, if that's the appropriate exhibit to 23 talk about where the inspection frequency criteria, 24 inspection method, and repair/replacement criteria 25 process is described.
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Page 1478 1 I recognize that specific numbers 2 weren't identified yesterday as much as a way to get 3 to that inspection frequency. Is this the correct 4 exhibit?
5 MR. COX: Yes, Your Honor, it is. This 6 is Alan Cox for the Applicant. Specifically, we 7 were looking at Section 4.7.3 on page 4-25 of that 8 exhibit.
9 JUDGE KENNEDY: What particular aspect 10 does this address then, Mr. Cox?
11 MR. COX: This is -- the first sentence 12 of this section is the recommendation that the 13 remaining service life be determined for each 14 component. And again, that's done every inspection 15 cycle, every refueling outage. We evaluate the 16 remaining service life. And in doing that, that 17 defines what components require inspection and when.
18 We look at how much remaining service it is, compare 19 that to the next scheduled inspection, and then we 20 either say that's acceptable or we can extend it to 21 a later inspection or we have to do a 22 repair/replacement at that point.
23 JUDGE KENNEDY: Then this is based on 24 the output of the CHECWORKS program?
25 MR. COX: Yes, Your Honor, it is.
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Page 1479 1 JUDGE KENNEDY: And this is the process 2 that would be used to establish the inspection 3 frequency for all locations?
4 MR. COX: This process would be used for 5 all locations. Again, you're not necessarily 6 establishing a frequency, but you're establishing 7 the necessary date for the next inspection.
8 JUDGE KENNEDY: Understand.
9 MR. MEW: Your Honor, Ian Mew for the 10 Applicant. The service life of a component is done 11 independently of CHECWORKS. It's done in accordance 12 with Entergy procedures determining when a component 13 needs to be repaired or replaced or it has 14 sufficient life to last through more than one cycle.
15 JUDGE KENNEDY: So what part of this 16 process then does CHECWORKS play a role in in terms 17 of this Section 4.7.3, if any?
18 MR. MEW: CHECWORKS only tells us what 19 the wear rates are and ranks it for us so we can do 20 -- perform an inspection scope. Once we get 21 measured data that's done in accordance with our 22 procedures.
23 JUDGE WARDWELL: And by that -- let me 24 make sure I understand you correctly. Is the 25 service life based on the wear rates from measured Neal R. Gross & Co., Inc.
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Page 1480 1 values or from CHECWORKS predictions?
2 MR. MEW: From measured values.
3 JUDGE WARDWELL: And likewise, are not 4 most of these calculations -- well that's what, 5 4.7.3 NSAC-202 is at service life, so that's based 6 on measured values not CHECWORKS, is that correct?
7 MR. MEW: That is correct.
8 JUDGE WARDWELL: I see heads nodding 9 from other witnesses. No one objects to that, that 10 representation of Mr. Mew?
11 JUDGE McDADE: Apparently not, but let 12 me just make sure I understand it. Your testimony 13 is that CHECWORKS is used to prioritize inspections, 14 so based on CHECWORKS you will identify what areas 15 you should inspect, but once the inspections are 16 done, then your decisions with regard to remaining 17 service life are based exclusively on the actually 18 observed data?
19 MR. MEW: That is correct.
20 JUDGE WARDWELL: Are all the location's 21 selections for inspections based on CHECWORKS or are 22 there other mechanisms to do that?
23 MR. MEW: There are different elements 24 of the FAC Program. One of the elements is the 25 predictive methodology. Okay? There are operating Neal R. Gross & Co., Inc.
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Page 1481 1 experience. There is engineering judgment. And 2 there is the non-modeled portion of piping in our 3 program.
4 JUDGE McDADE: What would enter into 5 your prioritizing a particular area for inspection 6 inconsistent with the CHECWORKS priorities?
7 MR. MEW: We look at the rankings and 8 based on the negative time to Tcrits we would look 9 at those and determine whether or not to be included 10 in the inspection scope. If we don't have a valid 11 reason as to whether or not they should be 12 inspected, we include them in the scope.
13 JUDGE McDADE: Now and when you say "we" 14 do you mean you?
15 MR. MEW: That's correct.
16 JUDGE McDADE: And your position again 17 at Indian Point, you are in charge of the FAC 18 Program?
19 MR. MEW: That is correct.
20 MR. ALEKSICK: If I might offer a 21 clarification, Your Honor? This is Rob Aleksick for 22 the Applicant.
23 I would just like to point Your Honors 24 to Answer 77 in our prefiled testimony which 25 discusses this issue in some detail. Specifically, Neal R. Gross & Co., Inc.
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Page 1482 1 it provides figures illustrating for each inspection 2 set of components that is done for each refueling 3 outage, what percentage of them come from CHECWORKS, 4 what percentage of them come from re-inspections, 5 operating experience, and so forth.
6 JUDGE McDADE: Thank you.
7 JUDGE KENNEDY: Could we continue on and 8 talk about the repair/replacement criteria, if 9 that's possible through this exhibit? Either Mr.
10 Cox or Mr. Mew.
11 MR. COX: The repair/replacement is 12 covered in the next section on this exhibit under 13 Repair and Replacing Components. I'll let Mr.
14 Azevedo or Mr. Mew to discuss that further.
15 MR. AZEVEDO: Yes, Your Honor, this is 16 Nelson Azevedo for Entergy. The criteria that were 17 used for repair and replacements is discussed in our 18 Q&A 73 and 78. And also comes from NSAC-202L, 19 Section 4.8 and also from our EN-DC-315 Section 20 5.13.
21 And from a high-level standpoint, what 22 that requires is that it requires us to calculate 23 the critical thickness that we need to ensure that 24 we don't exceed the code stress allowables and 25 ensure that we schedule an inspection or replacement Neal R. Gross & Co., Inc.
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Page 1483 1 or repair prior to reaching that point.
2 JUDGE KENNEDY: You now introduced again 3 the EN-DC-315 procedure. I guess what I'm looking 4 for the link in through GALL, through the Aging 5 Management Program is this document NSAC-202. What 6 is different between what's in NSAC-202 and what 7 would be provided in EN-DC-315?
8 MR. AZEVEDO: There really is nothing.
9 EN-DC-315 implements NSAC-202L.
10 JUDGE KENNEDY: So would NSAC-202 be the 11 guidance document that is implemented by 315?
12 MR. AZEVEDO: Yes, that's correct.
13 JUDGE KENNEDY: Just one last question 14 about inspection methods. Does NSAC speak to the 15 recommended inspection methods for flow-accelerated 16 corrosion or min. wall thickness?
17 MR. AZEVEDO: Yes, it does, Your Honor.
18 That's, I believe, Section 4.5. It's on page 4-11.
19 JUDGE KENNEDY: All right, thank you.
20 JUDGE McDADE: Before you move forward, 21 if I could just follow up on one thing that was 22 mentioned by Mr. Aleksick, if you could clarify for 23 me. You had made reference to the earlier testimony 24 that was presented. And it talks about a percentage 25 of overall inspections that are based on CHECWORKS, Neal R. Gross & Co., Inc.
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Page 1484 1 but it differentiates between new inspections and 2 repeat inspections.
3 So what percentage of the new 4 inspections, put aside the total number of 5 inspections, just of the new inspections are based 6 on -- are informed by the CHECWORKS priorities?
7 MR. ALEKSICK: It varies a bit from 8 cycle to cycle. But on average, it's around one 9 quarter of the total inspection scope would be newly 10 identified, previously uninspected components that 11 come from CHECWORKS.
12 JUDGE McDADE: Right, and that's what it 13 indicates in the testimony, but that's of new 14 inspections, areas that haven't been inspected 15 before, 25 percent.
16 My question is of those new areas, are 17 they all identified through CHECWORKS or a 18 percentage of the new as opposed to the re-19 inspections done through other mechanisms, 20 engineering judgment, experience at other 21 facilities, that's the nature of the question.
22 Because the first inspection identifying an area to 23 be inspected, that's what I'm curious about. Are 24 they all informed by CHECWORKS?
25 MR. MEW: Your Honor, Ian Mew for the Neal R. Gross & Co., Inc.
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Page 1485 1 Applicant. I can answer that question. If you will 2 turn to Exhibit 000057 which is the 2R19 scope for 3 Indian Point 2, there is -- you will see in there 4 that typically for that outage you will see 5 CHECWORKS has 26 percent of the inspections, 6 re-inspections were 46 percent, OE was 7 percent, 7 and components from the SMN model was 21 percent.
8 Similarly, if you look at Exhibit 61, 9 3R14 inspection in 2007, you will see CHECWORKS at 10 36 percent, re-inspections at 31 percent, SPU 11 contribution was 31 percent --
12 JUDGE WARDWELL: What's SPU?
13 MR. MEW: Stress power uprate.
14 JUDGE McDADE: Okay, Mr. Mew, the thing 15 that I'm not clear on, based on the exhibits and 16 based on the testimony, is a distinction between re-17 inspections and initial inspections. And I 18 understand that re-inspections are based on a number 19 of criteria. You've looked at it. You actually 20 have data on that particular location.
21 The exhibits, the testimony indicates 22 that -- I think it was about 24 percent, 26 percent 23 are based on CHECWORKS that are new inspections.
24 That's 26 percent of all of the inspections. My 25 question is of the new inspections, that 26 percent, Neal R. Gross & Co., Inc.
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Page 1486 1 are they all identified as locations to be inspected 2 through CHECWORKS or is there a percentage of that 3 26 percent, the new inspections that is identified 4 through some other mechanism? And if so, what is 5 the percentage and what is the mechanism?
6 MR. ALEKSICK: This is Rob Aleksick.
7 Roughly speaking, perhaps half of the inspected 8 components from each inspection set during an outage 9 are re-inspections. So if we set that aside and we 10 just look at the new inspections, roughly half of 11 those come from CHECWORKS, sometimes more, sometimes 12 less, but that's the general order of magnitude.
13 And then roughly half -- the other half 14 come from other sources including operating 15 experience, engineering judgment, and the 16 susceptible non-modeled rankings. Those are 17 components not modeled in CHECWORKS, but that may be 18 experiencing FAC.
19 JUDGE McDADE: Okay, and when you're 20 saying in there and I believe the testimony was 21 21 percent come from susceptible non-modeled 22 components, can you describe for me what a non-23 modeled component is and why it's non-modeled?
24 MR. ALEKSICK: Certainly, Your Honor.
25 CHECWORKS was designed originally, as we discussed Neal R. Gross & Co., Inc.
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Page 1487 1 yesterday, to address the high energy, large bore 2 piping that was -- well was originally identified in 3 the Generic Letter. As FAC programs developed over 4 the decades, greater awareness or greater focus was 5 placed on additional plant piping that might not be 6 able to be modeled for one reason or another.
7 By far, the largest category of that 8 piping is small bore piping. In fact, yesterday, in 9 Dr. Hopenfeld's presentation, he alluded to one of 10 those components. And if you look at the figure, it 11 shows that it was a three-quarter inch pipe and for 12 small bore lines like that instead of being butt-13 welded, they're socket-welded. And the nature of 14 that joining technique makes it difficult to model 15 and predict the extent or occurrence of FAC in those 16 lines.
17 And so for small bore lines, we have a 18 different ranking methodology. It's documented in 19 Entergy Exhibits 000048 and 000049, I believe. We 20 can go into as much detail as Your Honor would like, 21 but at a high level, essentially what we do is we 22 take these small bore lines and apply a more 23 qualitative ranking process to them.
24 I'd also like to point out that in 25 addition to the small bore lines, there are a few, Neal R. Gross & Co., Inc.
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Page 1488 1 small percentage, but a few large bore lines in that 2 category, for example, a balancing line that has no 3 well-defined flow rates, lines that are very 4 infrequently operated or that are operated in a 5 manner of changing operating conditions, maybe a 6 start-up line where the flow rates and pressures 7 change while that line is in service. And so lines 8 like that are covered under the FAC Program and are 9 inspected and are evaluated in the same manner once 10 we have the inspection data, but are not modeled.
11 And I would point Your Honors to 12 Question 68 in our prefiled testimony for additional 13 detail on this topic.
14 JUDGE McDADE: And the exhibit you just 15 referenced 000048 and 000049, excuse me, those are 16 the ones we looked at yesterday, 000048 for Unit 2; 17 000049 for Unit 3?
18 MR. ALEKSICK: I think we may have 19 looked at -- there are a large number of exhibits, 20 so I'm not --
21 JUDGE McDADE: It's the system 22 susceptibility evaluation.
23 MR. ALEKSICK: I was mistaken. Those 24 are the wrong exhibit numbers. I shouldn't rely on 25 my memory. If you give me one moment, I'll give you Neal R. Gross & Co., Inc.
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Page 1489 1 the correct exhibit number.
2 (Pause.)
3 Those were exhibits -- Entergy Exhibits 4 000052 and 000053, Your Honor.
5 JUDGE McDADE: Okay, thank you. Judge 6 Kennedy?
7 JUDGE KENNEDY: Just a -- if we take --
8 we've just walked through the inspection frequency 9 process, the repair/replacement criteria discussion 10 and the inspection methods, all based in NSAC-202.
11 If Entergy chose to make a change to those processes 12 that are currently founded on NSAC-202, how would 13 they go about doing that? What process would be 14 used?
15 MR. AZEVEDO: This is Nelson Azevedo for 16 Entergy again. The process that we would use would 17 be the 10 CFR 50.59 process where there's a review 18 process and the outcome of that process tells us 19 whether we can make the change and just document and 20 have the documentation available for NRC inspection 21 or whether we need to get NRC approval prior to 22 implementing the change. So that's the 50.59 23 process.
24 JUDGE KENNEDY: So if I understand what 25 you said, if the answer goes one way, you would file Neal R. Gross & Co., Inc.
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Page 1490 1 a license amendment. If the answer goes in another 2 direction, you could make the change and then file a 3 notice with the Agency that you have made such a 4 change? And how is that filed?
5 MR. AZEVEDO: We would make the change.
6 We'll keep the documentation on site. That will be 7 available for NRC review and I believe at the end of 8 the year, once a year, we update the NRC of any 9 changes that are made, but I'm not positive of that.
10 JUDGE KENNEDY: Does anyone know the 11 answer to that question?
12 From Entergy's side?
13 MR. COX: This is Alan Cox with 14 Applicant. We do once a year as part of FSAR 15 update, I believe, we provide records of 50.59 16 reviews that were done on site associated with 17 procedures changes.
18 JUDGE KENNEDY: Thank you. Maybe Dr.
19 Hiser? Site lines are tough.
20 You've just heard Entergy walk us 21 through using some specific examples of attributes 22 of GALL that I believe Riverkeeper has some issues 23 with. I guess I'd like to get your take on their 24 description and their process for control.
25 DR. HISER: This is Alan Hiser with NRC.
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Page 1491 1 I think in general, we would agree with the 2 characterization by Entergy and in particular, the 3 use of 50.59 or the 50.90 license amendment process, 4 if they were to make changes.
5 JUDGE KENNEDY: It seems in listening to 6 Entergy's testimony that the inclusion of 202, I 7 guess as a check on my understanding, the inclusion 8 of 202 in the program description and I guess in the 9 UFSAR update, leads to a process that the important 10 characteristics that they've identified would be 11 controlled and identified to the Agency if a change 12 is made. Do you see any flaws in that 13 understanding?
14 DR. HISER: No, I think you've 15 accurately characterized it. The use of the NSAC 16 guidance document is an essential part of the 17 program.
18 JUDGE KENNEDY: I think yesterday we 19 walked down this path and what we've uncovered is 20 that by the reference, as I understand it, the 21 reference to NSAC-202 through GALL and then brought 22 in to the description of the Aging Management 23 Program is a linkage to the additional details for 24 the Flow-Accelerated Corrosion Program. Would that 25 be your characterization?
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Page 1492 1 DR. HISER: I think that's accurate, 2 yes, I would agree.
3 JUDGE KENNEDY: Entergy, again, I think 4 that's been your view, but would you concur with 5 that assessment?
6 MR. COX: Yes, Your Honor. This is Alan 7 Cox with Applicant and I do concur with that.
8 JUDGE KENNEDY: And I think it's only 9 fair to ask Dr. Hopenfeld, these are three specific 10 issues that I think the petition has raised and were 11 admitted as part of the contention and you've just 12 heard Entergy provide an explanation of where that 13 level of detail, where that information is provided.
14 I guess I'd like to get your perspective on this 15 discussion that we've had over the ensuing two days.
16 DR. HOPENFELD: I just want to make sure 17 I don't wander off the time here. I just want to 18 make -- because I really don't know where to start 19 because I have so many issues here.
20 However, I'll just -- the last that was 21 mentioned and I'm sure, Your Honor, that you 22 understand that 50.59 is not a prescriptive 23 document. There's a lot of leeway. There's a lot 24 of judgment in there. The bottom line in a 50.59 25 and I read it very carefully is is there an effect Neal R. Gross & Co., Inc.
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Page 1493 1 of safety or whether the changes you make, whether 2 it's a big change or small change? Is there an 3 effect on safety? How can you determine that? You 4 do some risk analysis.
5 Now in this particular case, the first 6 step is to make sure that you inspect the component 7 before you reach the critical thickness. And we 8 have seen those equations. You can derive it right 9 here. You don't need the document for that. It's 10 just an obvious thing. You don't want to exceed the 11 critical thickness. If, if, you know which 12 component and if you know how fast it wears and 13 because of the local phenomenon and that's why we 14 went to all this mechanism thing, because of the 15 local phenomenon they don't know -- all three of 16 them.
17 Now if you assume, if the assumption is 18 correct, then the rate is linear and it could be, as 19 I said, a straight pipe or even if you use some 20 averages, it's not too bad. But because of the 21 locality of this, you cannot determine whether it's 22 one line or two lines or two identical components 23 whether they're going to behave the same. That's 24 the crux of the problem.
25 JUDGE KENNEDY: Let's -- you've said a Neal R. Gross & Co., Inc.
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Page 1494 1 lot.
2 DR. HOPENFELD: I'm sorry?
3 JUDGE KENNEDY: You've provided a lot of 4 information and I think that if I understand the way 5 the rest of the day will proceed, we're going to get 6 to a lot of the specific issues that you've raised.
7 What I'd like to focus on here, what 8 we've been pursuing over the latter part of 9 yesterday and through the beginning of this morning, 10 is whether there's a documented process and I 11 understand you may disagree with some of the 12 assessments that are performed that provide input to 13 that process. But do you or don't you agree that 14 Entergy has defined a process for these three 15 specific elements of GALL and that that process has 16 a documented basis for controlling the changes to 17 those processes?
18 DR. HOPENFELD: I agree there's a 19 general framework. The verbiage is generally 20 correct. The question is the implementation of it.
21 Look, I don't know after looking at all 22 of this how many components they inspect. You've 23 got thousands of components, do they inspect two or 24 three or five, what are we talking about -- like it 25 was a known.
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Page 1495 1 JUDGE KENNEDY: I think we're going to 2 get to that. I think that -- if we just again for 3 argument sake let's take the inspection frequency 4 discussion that we just heard. I believe they 5 pointed us to a document that they've committed to 6 and that if they were to make changes to that 7 process, it would go through either a 50.59 process 8 or ultimately if it fails the 50.59 test, a 50.90 9 process.
10 So it seems to me and I'm really trying 11 to make sure I understand your perspective that the 12 process has been identified. It's documented and 13 committed to. And changes to that process will see 14 the light of day driven by documentation provided by 15 Entergy to the Agency.
16 DR. HOPENFELD: I have no problem.
17 JUDGE KENNEDY: Is that your 18 understanding?
19 DR. HOPENFELD: Yes.
20 JUDGE KENNEDY: Okay.
21 JUDGE McDADE: Dr. Hopenfeld, if I 22 could, just to make sure I understand your position, 23 yesterday, we were led to Exhibit 000038 which was 24 the EN-DC-315 and we were led to Exhibits 000048 and 25 000049 which were the System Susceptibility Neal R. Gross & Co., Inc.
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Page 1496 1 Evaluation Reports for Units 2 and Units 3.
2 DR. HOPENFELD: I can't remember which 3 --
4 JUDGE McDADE: Well, forget the numbers 5 for right now. But is it accurate to say that you 6 would concede that there is documentation provided 7 by Entergy, but it is your view that the 8 documentation is so vague that it leaves so much to 9 individual judgment that it does not guarantee that 10 there is a reasonable assurance that the FAC will be 11 managed during the period of extended operation?
12 It's not the lack of documentation. It's the lack 13 of specificity in the documentation that you take 14 issue with?
15 DR. HOPENFELD: Yes, absolutely correct.
16 I would just like to add one point for 17 clarification, if I may. And that is from the 18 outside and I'm not familiar with the procedures of 19 Entergy. From the outside you look at it, it looks 20 like a contractor put all that together, the people 21 that did the ultrasonics or whoever does the 22 CHECWORKS summary, filed that thing, and it's 23 somewhere there. I don't see -- some of the stuff 24 there it's so out and I don't see any comments on 25 that.
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Page 1497 1 JUDGE WARDWELL: Can I ask you this?
2 Probably stepping back a bit, but getting back to 3 our discussion of what's in an AMP, do you have any 4 criticisms of their AMP as it stands, not again in 5 regards to some of the issues you're raising, but 6 just as an AMP, as presented in Appendix B, do you 7 have any criticisms of that?
8 DR. HOPENFELD: I'll try to answer your 9 question as close as I can. What I see in AMP three 10 aspects to it. One, you must inspect the component 11 before it reaches critical thickness. One, one 12 requirement.
13 JUDGE WARDWELL: And does it -- let me 14 just ask, doesn't the AMP have a procedure for doing 15 that in there?
16 DR. HOPENFELD: It may have a procedure, 17 but the results don't reflect that because they 18 constantly --
19 JUDGE WARDWELL: But the AMP, as it 20 stands --
21 DR. HOPENFELD: Yes, yes, yes.
22 JUDGE WARDWELL: You are satisfied with 23 that area of the AMP in Appendix B. Okay, go ahead.
24 DR. HOPENFELD: It says in 1801, you've 25 got to follow CHECWORKS and if CHECWORKS is working, Neal R. Gross & Co., Inc.
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Page 1498 1 you got it. I wouldn't be here.
2 Number two, you have to assess what 3 happened if you didn't reach that, if for some 4 reason you missed the inspection and the critical 5 thickness of that component has been reached.
6 JUDGE WARDWELL: And in that area --
7 DR. HOPENFELD: That's number two.
8 JUDGE WARDWELL: And that area, does the 9 AMP have a mechanism to --
10 DR. HOPENFELD: I don't believe so. I 11 haven't seen it. Maybe I didn't see it explicitly, 12 no. Let me tell you where the area is.
13 JUDGE WARDWELL: So didn't we just have 14 a discussion of that earlier this morning in regards 15 to getting down to the NSAC-202 presentation of 16 addressing that issue?
17 DR. HOPENFELD: Yes, but I didn't finish 18 what I was trying to say about what the second 19 element was. May I?
20 JUDGE WARDWELL: Yes.
21 DR. HOPENFELD: I'll go back to that.
22 The second element is to assess what happens if you 23 didn't reach the critical -- if for some reason you 24 missed by inspection, the critical thickness has 25 been reached. What you do there, you have to make Neal R. Gross & Co., Inc.
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Page 1499 1 something of a safety assessment. What would 2 happen?
3 Obviously, if that happened, some 4 components in the service water, who cares? But if 5 it happens somewhere in the blowdown line, it may be 6 very important. So the second thing, some kind of a 7 risk analysis.
8 Now I'm sure that there's verbiage there 9 if you go to 50.59, it's right there. So in the 10 whole picture, yes. There is nothing in there that 11 you couldn't find --
12 JUDGE WARDWELL: So you are satisfied 13 that the AMP through its series of threads that 14 we've talked about yesterday will get you to --
15 DR. HOPENFELD: If you implement it 16 correctly, yes. If, but that's a big if.
17 JUDGE WARDWELL: For now we are assuming 18 that implementation will take place. We will 19 address whether or not that takes place further on 20 --
21 DR. HOPENFELD: Sir, can I finish the 22 third?
23 JUDGE WARDWELL: Yes, go on to your 24 third. How many of these do you have by the way?
25 DR. HOPENFELD: I'm sorry?
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Page 1500 1 JUDGE WARDWELL: How many of these do 2 you have?
3 DR. HOPENFELD: I have only three.
4 Forgetting all these documents and all that, I only 5 have three elements. If I can get those across, I 6 think I've done my job. And so the third, I think I 7 got the first two. The third one is very important 8 is after all this experience to identify the right 9 components you are going to inspect, I've got 10 thousands of components, which one do I inspect.
11 JUDGE WARDWELL: And do they have a 12 procedure in their AMP as reflected in Appendix B of 13 the license renewal application that tries to 14 achieve that endeavor?
15 DR. HOPENFELD: Sure.
16 JUDGE WARDWELL: Thank you.
17 JUDGE McDADE: If I could, Dr.
18 Hopenfeld, just and make sure I understand what 19 you're saying. And we heard from Mr. Aleksick and 20 he was talking about the percentage of new 21 inspections that are based on CHECWORKS, the 22 percentage that are based on something other than 23 CHECWORKS. There's a differentiation between 24 susceptible and non-susceptible systems. The non-25 susceptible systems, small pipes aren't used with Neal R. Gross & Co., Inc.
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Page 1501 1 CHECWORKS.
2 For the non-susceptible systems, not 3 involving CHECWORKS, have you identified any 4 reliable mechanism for prioritizing the inspections 5 of those systems within the AMP of Entergy?
6 DR. HOPENFELD: I didn't compare 7 prepared to get into that kind of detail and I 8 really haven't put sufficient thought into that. I 9 realized at some time EPRI was talking about doing 10 some safety analysis about small bore piping, but I 11 don't know what happened on it. I don't know 12 whether they're doing it. But I think you've got to 13 approach it from the safety aspect of it.
14 JUDGE McDADE: Okay, and then going back 15 to the other, to those that are susceptible, again 16 it's that there's too much reliance on CHECWORKS for 17 the initial identification.
18 DR. HOPENFELD: Right.
19 JUDGE McDADE: And you don't think 20 CHECWORKS serves that purpose?
21 DR. HOPENFELD: I don't know. I know 22 the oil industry, there are a lot of small diameter 23 lines. The problem there is there's a lot of local 24 corrosion, pitting corrosion. You can't pick up 25 with any computer.
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Page 1502 1 JUDGE McDADE: Okay, thank you, Doctor.
2 MR. ALEKSICK: Your Honor, this is Rob 3 Aleksick for the Applicant. I apologize for 4 interrupting, but I think it's a point of 5 clarification that is somewhat important.
6 Your Honor referred to susceptible, then 7 non-susceptible components and lines. I think a 8 better term is modeled and non-modeled. They're all 9 susceptible to FAC and they're all addressed under 10 the FAC Program, but only some of them are modeled 11 and the ones that are susceptible, but not modeled, 12 that's the population of components that we were 13 discussing. I just wanted to make that clear.
14 JUDGE McDADE: Okay, and those are the 15 ones that you do not use CHECWORKS on.
16 MR. ALEKSICK: Yes.
17 JUDGE McDADE: Okay. Now on the others 18 that are modeled, when you say modeled, you mean 19 modeled by CHECWORKS?
20 MR. ALEKSICK: Exactly, yes, Your Honor.
21 JUDGE McDADE: Okay, and the -- and for 22 those that are modelable, I guess is a way of saying 23 it, do you rely exclusively on CHECWORKSs for 24 prioritizing those systems for inspection or do you 25 have a system in addition to CHECWORKS that Neal R. Gross & Co., Inc.
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Page 1503 1 identifies modeled systems for inspection as sort of 2 for lack of a better phrase check on CHECWORKS?
3 MR. ALEKSICK: For those components that 4 are modeled in CHECWORKS, I think it's fair to say 5 that CHECWORKS is the primary tool used in 6 identifying and selecting them for inspection.
7 However, it is certainly not the sole tool.
8 There's a fairly detailed process that 9 Mr. Mew goes through when he compiles, selects his 10 inspections and without taking too much of Your 11 Honor's time, I would just say that he considers 12 CHECWORKS' predictions, but he also considers 13 operating experience, uses engineering judgments, 14 and some other factors as well.
15 JUDGE McDADE: Can either you or Mr. Mew 16 refer us to a particular exhibit that we should 17 study to be able to better understand those other 18 factors that informs your judgment?
19 MR. ALEKSICK: I think Your Honor might 20 look at Question and Answer 95 in our prefiled 21 testimony for additional information on that.
22 JUDGE McDADE: Does that refer to a 23 particular exhibit?
24 MR. COX: This is Alan Cox for the 25 Applicant. There is a section in NSAC-202, an Neal R. Gross & Co., Inc.
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Page 1504 1 exhibit that we looked at earlier today that talks 2 about selecting components for inspection.
3 JUDGE McDADE: Okay, now it refers us 4 back to EN-DC 315.
5 MR. COX: This is actually the NSAC 6 document that -- this is the guidance that EN-DC 315 7 was based on. NSAC-202L.
8 JUDGE McDADE: Okay, which is what we 9 talked about yesterday, but in the testimony you're 10 referring to Entergy Exhibit 000038 which is the EN-11 DC 315, correct?
12 MR. COX: Yes, yes, that's correct.
13 JUDGE McDADE: And that's where Mr. Mew, 14 you would look to get guidance on how to exercise 15 this judgment with regard to additional testing, 16 identification of susceptible, but modeled systems?
17 MR. MEW: Yes, Your Honor, that would be 18 one of the areas that I'd look at.
19 JUDGE McDADE: Okay, any other place 20 that you could direct us to that we should look at 21 so that we could evaluate it?
22 MR. MEW: For engineering judgment, I 23 could point you to --
24 JUDGE McDADE: Okay, we can go and look 25 at pages 20 through 30 of Exhibit 000038 and we can Neal R. Gross & Co., Inc.
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Page 1505 1 study those. It's tough to study your engineering 2 judgment. So at this point, is there any other 3 document that you would specifically like to address 4 us to that you think would be important or helpful 5 to us to better understand the process?
6 MR. MEW: As I was saying, Your Honor, 7 for engineering judgment I would look into the 8 CHECWORKS as a bay model and look at the negative 9 time to Tcrit and if there's a component immediately 10 downstream of that negative time to Tcrit, in better 11 trying to understand what was happening, usually I 12 try to inspect those components.
13 JUDGE McDADE: Okay, so even though it 14 hadn't been identified by CHECWORKS, you would look 15 at it because it was downstream from a system that 16 had been identified by CHECWORKS and had been 17 identified based on prior testing as susceptible to 18 flow-accelerated corrosion.
19 MR. MEW: That's essentially correct, 20 Your Honor.
21 JUDGE McDADE: Thank you.
22 JUDGE WARDWELL: To make sure I 23 understand now going back again to these numbers of 24 the model versus the non-modeled.
25 Mr. Aleksick, you were saying that for Neal R. Gross & Co., Inc.
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Page 1506 1 those that are modeled, CHECWORKS is a primary tool.
2 We were saying that 25 percent of all inspections 3 are derived from CHECWORKS. Is that correct, 4 approximately?
5 MR. ALEKSICK: Let me clarify. And this 6 is Rob Aleksick for the Applicant. Once a component 7 is initially inspected, regardless of its origin or 8 the reason for that selection, whether it was 9 CHECWORKS or anything else, it goes into our 10 trending database and the inspection frequency is 11 determined by the discussion we had earlier today.
12 So I think this part of our discussion, 13 if I understand Your Honor correctly, we're focusing 14 on how previously uninspected components are 15 selected. Am I correct in my understanding?
16 JUDGE WARDWELL: Initially, no, that 17 wasn't my question, but as you clarified it, it is 18 now my question.
19 (Laughter.)
20 MR. ALEKSICK: I suppose that's good.
21 JUDGE WARDWELL: I don't know whether 22 good, bad, or indifferent. It is what it is.
23 MR. ALEKSICK: With that clarification 24 then, Your Honor, yes, I think it's a fair statement 25 that approximately one quarter of the inspections Neal R. Gross & Co., Inc.
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Page 1507 1 are identified based on CHECWORKS which is to say 2 approximately half of the newly inspected components 3 come from CHECWORKS.
4 Let me say that another way. Each 5 outage we inspect perhaps 100 components, perhaps 50 6 of those have been inspected before. Perhaps 50 of 7 them are new and of those new 50, 25 might be from 8 CHECWORKS.
9 JUDGE WARDWELL: Okay, that fixes it 10 nicely. By the way, that might not be bad 11 information to having an AMP for some people to 12 understand better or generally what's going on, but 13 that's just a sidebar from yesterday's discussion 14 which we may get back to a little bit.
15 Where I'm going now is this statement 16 that I'm trying to now see how the model versus the 17 non-model fit into this and you're saying that all 18 of those 25 percent are model components?
19 Naturally, because that's how they came from 20 CHECWORKS.
21 If the component -- how much of the 22 components that are modeled end up being inspected?
23 MR. ALEKSICK: There are approximately 24 8,000 components modeled across both units at 25 approximately 3,700 of those have been inspected Neal R. Gross & Co., Inc.
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Page 1508 1 since 1992 when we -- which is the earliest data 2 that we have.
3 JUDGE WARDWELL: And so that -- repeat 4 those numbers, I'm sorry.
5 MR. ALEKSICK: There are approximately 6 8,000 modeled components in CHECWORKS, so there are 7 additional components in the FAC Program, the non-8 modeled components. But in terms of CHECWORKS 9 modeled components, we have about 8,000. Of that 10 population, 3,700 or so have been inspected since 11 1992.
12 JUDGE WARDWELL: And are there hundreds 13 of thousands of total components that are in a plant 14 that are susceptible to flow-accelerated corrosion?
15 MR. ALEKSICK: No, Your Honor. The 16 number would not be that large. Our overall 17 approach is to start with -- there are hundreds of 18 thousands of components period.
19 JUDGE WARDWELL: Right.
20 MR. ALEKSICK: Some small fraction of 21 those are susceptible to FAC. Those are the ones 22 that we focus on and some subset of that is modeled 23 JUDGE WARDWELL: And what I was trying 24 to get a handle on is what are the leftover numbers 25 that are non-modeled?
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Page 1509 1 MR. ALEKSICK: I see. It depends on how 2 one counts. The modeled components are, generally 3 speaking, the components of highest priority, 4 highest concern. Those are the large bore, higher 5 energy piping systems that were the focus of the 6 Generic Letter.
7 However, they comprise a less than half 8 -- if one counts the number of lines that are 9 susceptible to FAC, maybe a quarter of those lines 10 are modeled in CHECWORKS and maybe three quarters of 11 them are in the susceptible, but non-modeled 12 category and are ranked in a separate analysis.
13 JUDGE WARDWELL: Okay, and let me just 14 make sure I understand that. If you looked at some 15 of those non-modeled components, are the SNMs, the 16 susceptible non-modeled, could some of those 17 actually be modeled or have you truly looked at them 18 and said no, we can't model them?
19 MR. ALEKSICK: We've looked at them in 20 great detail, Your Honor, and using very specific 21 criteria and very tight documentation on these. We 22 have dispositioned every single line. There are 23 approximately 1,200 lines that we've gone through, 24 listed, put in a table, and put each one of those 25 lines either into the modeled box or the non-modeled Neal R. Gross & Co., Inc.
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Page 1510 1 box based on strict criteria.
2 JUDGE WARDWELL: I have one last fixed 3 point and I lost it because I was listening too 4 close to your answer.
5 JUDGE McDADE: While Judge Wardwell is 6 trying to recall that, where would we look to find 7 those strict criteria?
8 MR. ALEKSICK: The -- I'm sorry, the 9 system susceptible evaluation that we discussed 10 yesterday 11 JUDGE McDADE: And those exhibits 000048 12 and 000049?
13 MR. ALEKSICK: Yes, thank you, Your 14 Honor. Those -- the main mission of those documents 15 is to present that list of 1,200 lines and the 16 disposition of each one and the criteria used to 17 make those dispositions are contained in those 18 documents.
19 JUDGE McDADE: Thank you.
20 JUDGE WARDWELL: Thank you, Judge 21 McDade, because I have remembered my last fixing 22 point.
23 Could you elaborate a little bit more on 24 the procedures that are used with the SNMs to rank 25 them?
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Page 1511 1 MR. ALEKSICK: Certainly, Your Honor.
2 We considered two primary factors. The first one is 3 the consequences of failure. If a given line, a 4 non-modeled line might upon failure cause a threat 5 to human safety or might cause a plant shutdown or a 6 derate or damage equipment or have any other 7 consequence that would be highly undesirable, or 8 even moderately undesirable, then those lines are 9 ranked as high consequence of failure.
10 If the line is in a locked room, it's 11 inaccessible, it would be unlikely to cause a 12 problem and so forth, then we would designate those 13 as not high consequence of failure lines. So that's 14 our first cut.
15 We make a second pass through that to 16 assess the level of susceptibility, the likelihood 17 of FAC actually occurring and those assessments are 18 made based on operating conditions such as 19 temperature and flow rates. They're based also on 20 maintenance records from the plant, so if a given 21 line -- and remember, these are typically small bore 22 lines. So if a given line has experienced leakage 23 or had repairs or replacements in the past, then 24 that line would be judged to be highly susceptible.
25 And finally, we would look at operating Neal R. Gross & Co., Inc.
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Page 1512 1 experience across the entire United States and 2 actually global fleet of nuclear plants to judge 3 which lines are likely to be higher levels of 4 susceptibility. And then we assign a ranking of 5 high, medium, or low level of FAC susceptibility.
6 And that's how we compile the rankings.
7 JUDGE WARDWELL: Thank you.
8 JUDGE KENNEDY: This discussion of 9 modeled and non-modeled lines makes me think of a 10 question for Dr. Hopenfeld.
11 I thought I heard you say yesterday that 12 you don't have a problem with CHECWORKS modeling 13 certain lines in the plant. Is that true?
14 Well, let me say it differently, is 15 there a range of applicability in modeling some of 16 the lines in the plant where CHECWORKS could do a 17 good job and consequently are there some you would 18 recommend will not do a good job? Looking sort of 19 generically or at some high level.
20 DR. HOPENFELD: Generically, I would say 21 all lines which are straight, simple geometry, 22 that's fine.
23 JUDGE KENNEDY: No matter what diameter?
24 Irrespective of the diameter of the line?
25 DR. HOPENFELD: Yes, irrespective of the Neal R. Gross & Co., Inc.
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Page 1513 1 diameter.
2 JUDGE KENNEDY: So straight pipes 3 everywhere.
4 DR. HOPENFELD: Straight pipe, except 5 the weld area I would worry about. I'd look at some 6 welding --
7 JUDGE KENNEDY: Any kind of welding?
8 DR. HOPENFELD: Sorry? Not specifically 9 because the weld material varies. But the welding 10 itself, the process varies. But straight line, 11 irrespective of the diameter wouldn't bother me.
12 The problem where you get is into the 13 geometrical problems, that which I alluded to 14 yesterday or tried to. So the answer to your 15 question, no, I don't have a problem with the --
16 with one exception, but even then it's not that 17 critical, that you don't know what the chromium 18 content of that material is. That goes to the input 19 of it. It varies. The specs vary.
20 So there is going to be a -- but in 21 straight lines, the corrosion rate is not that fast, 22 even after 60 years, you're still okay, probably, 23 but it's the complicated geometry that I'm concerned 24 with.
25 JUDGE KENNEDY: Could you explain a Neal R. Gross & Co., Inc.
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Page 1514 1 little bit more the geometry concern you have?
2 DR. HOPENFELD: Yes, all the geometry 3 that would cause local turbulence, it's not only the 4 velocity, the bulk velocity. You see, there's a 5 distinction between just the velocity itself.
6 Obviously, there's a relation between the tube, the 7 Reynolds number to the common number indicating the 8 intensity of turbulence is directly related to the 9 diameter and to the velocity. It's much more 10 complicated than that. It is the local instability 11 that caused creation of large areas, small areas, 12 whatever you have. So that gets into turbulence and 13 it's an entirely different area.
14 So it's the turbulence that causes the 15 problem. So any area where you have high 16 turbulence, stay away from it. This code cannot 17 predict it, whether it's straight or whatever it is.
18 JUDGE WARDWELL: This gets back to our 19 discussion yesterday that we briefly touched upon in 20 regards to local issues and linear versus non-linear 21 wear rates.
22 Can you provide us with any references 23 or cites or evidence that supports your contention 24 that this local type failure does result in non-25 linear rates has actually caused either impending or Neal R. Gross & Co., Inc.
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Page 1515 1 actual flow-accelerated corrosion failures?
2 DR. HOPENFELD: I can start with Surry 3 because over there all the corrosion occurred at the 4 elbow and it was very, very uneven. I went to the 5 plant. I touched it.
6 JUDGE WARDWELL: Surry is one -- the 7 grand daddy of them all?
8 DR. HOPENFELD: That's right.
9 JUDGE WARDWELL: So nothing was really 10 done on flow-accelerated corrosion prior to Surry?
11 DR. HOPENFELD: Sorry?
12 JUDGE WARDWELL: Was anything done to 13 monitor flow-accelerated corrosion prior to Surry?
14 DR. HOPENFELD: I don't believe so.
15 Your observation at Trojan. We're going back to 16 '87. These reactors were just getting online. So 17 we didn't have much -- it was a huge experience in 18 offshore industry. There's a huge experience in 19 refineries. And if you wish, I'll take a few 20 minutes to tell you how they were handling it.
21 JUDGE WARDWELL: I think there's enough 22 difference between refineries and power plants that 23 --
24 DR. HOPENFELD: To some degree.
25 JUDGE WARDWELL: I'd be more interested Neal R. Gross & Co., Inc.
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Page 1516 1 in what types of failures have occurred since Surry 2 and the power plants.
3 DR. HOPENFELD: There are quite a few.
4 Well, there was one in San Onofre which I thought 5 was very considered -- they found extreme thick 6 reduction in thickness in the distribution ring.
7 The distribution ring is the one on the top of the 8 steam generator, sits on top of the tubes and you 9 come with J-tubes and you distribute the flow. What 10 happens if I was a little man going with the flow, I 11 suddenly come to a stagnation point of distribution 12 where the flow splits and that's a very high 13 turbulence area. So in that component has a very 14 serious safety significance. That one did so 15 considerably at San Onofre.
16 Now there were two cases -- there was 17 one case --
18 JUDGE WARDWELL: Have you provided cites 19 to these in your testimony or anywhere so we could 20 refer to them?
21 DR. HOPENFELD: At San Onofre? I 22 believe it was referenced in one of the --
23 JUDGE WARDWELL: I'll word search it 24 then.
25 DR. HOPENFELD: I think the initial Neal R. Gross & Co., Inc.
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Page 1517 1 position, I think I provided more reference in the 2 case of Vermont, but I did provide them here, too.
3 I don't know if all of them --
4 JUDGE WARDWELL: I'm sorry, I didn't 5 hear you? In the case of what?
6 DR. HOPENFELD: In the case of Vermont, 7 I provided maybe a larger number of reference, but 8 also provided a number of references here. I don't 9 remember how many. But the next one -- there were 10 two in Japan and one fairly recently. I think it 11 was 2005 where a few people were killed. And it was 12 very, very local, completely unpredicted and I don't 13 know what their procedures are. Maybe they don't 14 have procedures. I don't know what they are. But 15 there were two cases which were very serious.
16 There were two cases fairly recent, one 17 was in Callaway, I believe and by the way, I think 18 the NRC mentioned that, then in the case of Callaway 19 when they looked at that thing there was a combined 20 erosion/corrosion mechanism. That's one reason why 21 they modified their definition of FAC recently. I 22 think it's out for public comments.
23 So Callaway, and going by memory, I 24 remember coming, when I was at NRC, there were blips 25 about looking at this line and getting this, but I Neal R. Gross & Co., Inc.
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Page 1518 1 don't remember all of them. There were quite a few.
2 You have to go to all the announcements, the NRC 3 announcements on failures.
4 JUDGE WARDWELL: Maybe I'll turn to 5 either NRC or Entergy to comment on those potential 6 failures.
7 DR. HOROWTIZ: Jeff Horowitz.
8 Certainly, Judge, which would you like me to comment 9 on first?
10 JUDGE WARDWELL: One that tickles your 11 fancy.
12 DR. HOROWTIZ: Okay, well, the first 13 one, Mihama which was I believe in 2004 in Japan, 14 and I would hardly characterize it as local. If you 15 look at the pictures you can see the large amount of 16 thinning evolves downstream of an orifice.
17 The Japanese do not use a predictive 18 method. They have a much more prescriptive method, 19 much like the ISI folks in that they have to inspect 20 all of the components in a certain temperature range 21 and certain quality range and it's all spelled out.
22 And what happened was they missed it.
23 When they used a procedure to follow -- in the plant 24 to follow the new procedure and they did their 25 breakdown, the engineer doing it used the wrong Neal R. Gross & Co., Inc.
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Page 1519 1 procedure and he left out downstream of the orifice.
2 And in the roughly 15 years since, nobody had 3 thought to check. That's what happened in Mihama.
4 They did use CHECWORKS. They didn't use 5 anything similar to CHECWORKS. They, as I said, had 6 a prescriptive program. We discussed it at some 7 length in our pre-filed testimony.
8 Callaway was, I think it was 1999, in 9 August. Re-did the drain line. We spoke about this 10 at some length at Vermont Yankee as I recall. Dr.
11 Hopenfeld is correct in that in some reports that 12 there was FAC and droplet impingement involved.
13 Frankly, I disagree with that assessment, but I've 14 never seen the photographs of the failure analysis, 15 so I don't really have a strong opinion one way or 16 another.
17 As to Surry, I would direct you to Dr.
18 Hopenfeld's rebuttal testimony on page 40. Could 19 you put that up, please?
20 JUDGE WARDWELL: What's the number for 21 that, the rebuttal testimony? I believe is 000111?
22 DR. HOROWTIZ: 000108.
23 JUDGE McDADE: 000108 is Dr. Hopenfeld's 24 rebuttal testimony. It's Exhibit 000108?
25 DR. HOROWTIZ: Yes.
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Page 1520 1 JUDGE McDADE: Riverkeeper 000108, yes.
2 DR. HOROWTIZ: Riverkeeper 000108.
3 JUDGE McDADE: And where in that, Dr.
4 Horowitz?
5 DR. HOROWITZ: The first paragraph on 6 the page.
7 JUDGE WARDWELL: Which page?
8 DR. HOROWITZ: Page 40.
9 JUDGE WARDWELL: Page 40. Page 4 or 40, 10 I'm sorry, I didn't understand.
11 DR. HOROWITZ: Four zero.
12 JUDGE WARDWELL: Yes.
13 DR. HOROWITZ: "Since starting at."
14 (Pause.)
15 When I read this, this rang a distant 16 bell in my mind where the 20 percent of all 17 thickness was lost in the 18-month sentence range a 18 bell and I checked into it. And it turns out that 19 sentence comes from the Generic Letter 89-08 which 20 is an exhibit, I don't know the number offhand. But 21 I know it's an exhibit. And the significance though 22 is that if you read that paragraph it seems that the 23 20 percent wall loss came before the rupture. And 24 that isn't the case.
25 The 20 percent wall loss turns out to be Neal R. Gross & Co., Inc.
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Page 1521 1 an erroneous conclusion made at the inspection of 2 the outage after the rupture. So I think that the 3 -- after reading this, you get the impression that 4 since the Surry elbow operated roughly 10 years that 5 the process was non-linear, but that turns out not 6 to be the case at all.
7 JUDGE WARDWELL: Any other --
8 MR. AZEVEDO: Yes, Your Honor, let me 9 comment on a couple of other issues of a couple 10 other incidents that came up. One was the feed 11 ring. The feed ring is located inside the secondary 12 side of the steam generators. We have a separate 13 program to monitor the degradation of the feed ring 14 that's generated in the program.
15 It is true that early during the 16 original steam generator design, there were issues 17 with FAC and the feed rings in the J-tubes.
18 However, both Indian Point Units 2 and 3 have 19 replacement steam generators. That issue was a 20 design modification. It was addressed, so the 21 current Indian Point 2 and 3 steam generators are 22 not susceptible to feed ring wear. And this has 23 been confirmed by the inspections that we have done 24 since.
25 JUDGE WARDWELL: Are any of those steam Neal R. Gross & Co., Inc.
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Page 1522 1 generator components susceptible to flow-accelerated 2 corrosion?
3 MR. AZEVEDO: No, they could have been 4 because of the original design, but the current 5 steam generators, no.
6 JUDGE WARDWELL: And furthermore, as you 7 stated, that a steam generator has its own AMP 8 associated with --
9 MR. AZEVEDO: It's monitored Entergy 10 steam generator integrity program. That's correct.
11 JUDGE WARDWELL: But it doesn't have 12 flow-accelerated component associated with it in 13 that AMP?
14 MR. AZEVEDO: No, the Flow-Accelerated 15 Corrosion Program are outside the steam generator.
16 JUDGE WARDWELL: Dr. Hopenfeld, would 17 you like to comment on that statement that the steam 18 generator is not susceptible to flow-accelerated 19 corrosion, if I paraphrased it correctly?
20 DR. HOPENFELD: It should. My 21 conclusion was based prior to the installation of 22 the modification of the J-tubes.
23 JUDGE KENNEDY: Could you speak up, 24 please?
25 DR. HOPENFELD: It is true that my Neal R. Gross & Co., Inc.
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Page 1523 1 conclusion --
2 JUDGE McDADE: Excuse me one second.
3 (Pause.)
4 JUDGE McDADE: Please continue.
5 DR. HOPENFELD: It is true that my 6 conclusions regarding to the distribution ring was 7 based on San Onofre at that time and if they had 8 modified the J-tube, welding was a material problem.
9 And if they modified the code, it would be to the 10 distribution ring and IP, that's great. I have no 11 problem with that. I didn't get into the detail of 12 it. I don't know.
13 With respect to Dr. Horowitz' comments, 14 I'm sure he's right. He's done much more detailed 15 analysis of it than I did. I just go as to what --
16 I talked to various people at the time. I visited 17 the plant at the time and I saw literature following 18 the accident and that's what I reported here. If he 19 has done additional analysis, I wish he had shared 20 it with us. I don't know.
21 With regard to this point that was just 22 brought up that the distribution ring, it's not the 23 only component in there. And maybe I'm straying off 24 the point here, but let me just tell you what it is.
25 There's a related issue that we have in a case of Neal R. Gross & Co., Inc.
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Page 1524 1 the fatigue problem.
2 Over there, one of the issues is stress 3 corrosion cracking of the divided plate down there 4 in the lower plenum. If it is true and there's been 5 European experience showing that those -- that the 6 coating under the plating on that plate is cracking, 7 if the base material is exposed to a lot of 8 turbulence and you go with the main flow in the 9 plenum on the primary side, although the dividing 10 leg is not a pressure item, okay? Because it's 11 pressure of the same side. It's a primary flow.
12 It's a gradient-active flow. It's a prime system.
13 So if that material is corroded and cracked, then it 14 is exposed to auxiliary corrosion locally.
15 Also on nozzles, nozzles in the steam 16 generators have been known to crack and they also 17 are susceptible to cracking to local auxiliary 18 corrosion. It depends how much cracking is. And 19 the blowdonw line. I haven't seen blowdown line as 20 a safety-related item. I haven't -- I know they are 21 inspecting them and I haven't seen anything in 22 CHECWORKS of how they predict it.
23 JUDGE WARDWELL: Back to the steam 24 generator components which was the start of this 25 questioning, line of questioning, is the fatigue Neal R. Gross & Co., Inc.
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Page 1525 1 monitored under an AMP for the steam generator to 2 your knowledge?
3 DR. HOPENFELD: Yes, the question is how 4 -- the question relates to the frequency. Yes, it 5 is monitored.
6 JUDGE WARDWELL: Okay. And that's not 7 part of this contention, right, as to the fatigue 8 analysis of the steam generator.
9 DR. HOPENFELD: It touches on it.
10 There's an interface there because what I just 11 mentioned that when you say I cannot predict how the 12 cladding is going to behave, one way is to say well, 13 let's pull out the cladding out of there, especially 14 in the nozzles. Then the underlying material is 15 exposed to flow-accelerated corrosion.
16 JUDGE WARDWELL: If fatigue did not 17 occur in the steam generator, then this is a non-18 issue, correct?
19 DR. HOPENFELD: That's correct, but it 20 does occur.
21 JUDGE WARDWELL: Well, in fact, that's a 22 fatigue issue to start with and then sure, if 23 fatigue isn't, that can lead to all different kinds 24 of problems?
25 DR. HOPENFELD: That's why I say, you Neal R. Gross & Co., Inc.
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Page 1526 1 have to be careful.
2 JUDGE WARDWELL: Isn't fatigue monitored 3 as part of the Aging Management Program for the 4 steam generator?
5 MR. AZEVEDO: Yes, it is, Your Honor.
6 JUDGE WARDWELL: Thank you.
7 MR. MEW: Your Honor, Ian Mew for the 8 Applicant. The steam generator blowdown lines are 9 part of the susceptible non-model program. So you 10 wouldn't find it in CHECWORKS.
11 JUDGE WARDWELL: So they are part of the 12 Flow-Accelerated Corrosion Program?
13 MR. MEW: That is correct.
14 MR. AZEVEDO: Your Honor, just to 15 clarify, that's the blowdown lines that's external 16 from the steam generator. So separating --
17 JUDGE WARDWELL: Right. I want to cut 18 Dr. Hopenfeld off at that point and then come back 19 to that because I wanted to fix the points on the 20 steam generator first.
21 Now I'll let you finish if you have 22 anything more to say.
23 DR. HOPENFELD: I don't have anything to 24 say except the blowdown, I don't what -- where the 25 interface is connected there.
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Page 1527 1 JUDGE WARDWELL: Thank you.
2 MS. BRANCATO: Your Honor, this is 3 Deborah Brancato for Riverkeeper. We'd just like to 4 note in response to your request for specific 5 references, if I could just note for the record and 6 for your benefit regarding the safety significance 7 fact that Riverkeeper Exhibits 000006 through 000011 8 do discuss the issues that Dr. Hopenfeld raised as 9 well as his expert report which is Riverkeeper 10 Exhibit 000005 at page 3.
11 JUDGE WARDWELL: And is that in regards 12 to both the history problems at other plants and 13 some of these issues that he's raised on the steam 14 generator and blowdown lines, etcetera?
15 MS. BRANCATO: To the former of what 16 you've just mentioned. Yes, thank you.
17 JUDGE WARDWELL: Great, thank you.
18 JUDGE McDADE: And I think in his 19 report, Riverkeeper 000005 starting at page 16 is 20 where he referred to it. And then starting at page 21 40 on Exhibit 000108, he also refers to it. Any 22 other references you'd like us to focus on?
23 MS. BRANCATO: No, Your Honor. Thank 24 you.
25 JUDGE McDADE: Okay, thank you.
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Page 1528 1 JUDGE WARDWELL: And since, I guess, I 2 still have the floor, I'll kind of switch gears a 3 little bit or I probably -- put the train in 4 reverse. But if we've got others that --
5 JUDGE KENNEDY: No, I was just curious, 6 after all the back and forth, I'm not sure that we 7 heard from the staff on at least U.S. operating 8 experience with flow-accelerated corrosion? Did you 9 have anything to add to what Entergy and Dr.
10 Hopenfeld has brought forth in terms of examples of 11 plant-operating issues?
12 DR. HISER: No, I think actually with 13 the principal citation being the 1986 Surry event 14 and no major FAC-related issues since then, I think 15 speaks to the effective of the NSAC Program that the 16 industry has implemented.
17 JUDGE KENNEDY: Did the Agency look into 18 the Japanese reactor accident which, as I remember, 19 was somewhat serious and if they did, what were 20 their conclusions, lessons learned, if you will?
21 DR. HISER: I'd have to go back and 22 review. We did issue, I believe it was an 23 Information Notice on the event and my recollection 24 without going back and re-reviewing that Information 25 Notice was that the system was not modeled and was Neal R. Gross & Co., Inc.
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Page 1529 1 not considered within the Japanese FAC Program. So 2 that was a sort of a fundamental programmatic 3 problem.
4 DR. HOPENFELD: May I comment on that?
5 JUDGE KENNEDY: Yes, sir. Go ahead.
6 DR. HOPENFELD: I read the report at the 7 time. It has been some time ago. And there was a 8 very comprehensive report. I think a group of NRC 9 people went there or talked about it. And it was a 10 very detailed report, but you really couldn't relate 11 it to what we're doing because we don't know what 12 their procedures were. And as you said, they --
13 there was no way.
14 I do know they do have a code, 15 equivalent to the ASME code which they follow, so 16 it's not that they are not, maybe they don't have it 17 exactly running a computer code like a CHECWORKS, 18 but the methodology is the same, I believe.
19 MR. YODER: Matthew Yoder from the NRC 20 staff. I want to make sure that we're very clear 21 that when we're talking about an ASME code we're 22 talking about a required component thickness. We're 23 not talking about modeling of wear rates. That was 24 not present at Mihama. And that information notice 25 is an exhibit. We can get the number for that, if Neal R. Gross & Co., Inc.
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Page 1530 1 you'd like it.
2 JUDGE KENNEDY: That would be 3 appreciated. I guess I need to go back to Dr.
4 Hopenfeld, then. You've brought forward this 5 Japanese reactor accident to provide some insight 6 into the issues here related to flow-accelerated 7 corrosion and I'm not sure -- I gathered that in 8 your most recent comments. Take us back through the 9 Japanese events and its relevance here to this 10 contention?
11 DR. HOPENFELD: There is. One, if you 12 look at the distribution of the piping and they have 13 a very detailed UT examination of the piping 14 downstream at various locations. And again, I'm 15 going based on memory here from about six or seven 16 years ago, there is a very clear indication from 17 their reg how local the phenomenon is.
18 First of all, it did go down the 19 orifice, but then I think went to the elbow. And if 20 you look at various sections, the locality is just 21 extremely similar to what you see here.
22 Secondly, there is data there. Up to 23 about 4,000 or 5,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> that they ran and I think 24 in some different facility show that there's no 25 linearity between time and corrosion on that Neal R. Gross & Co., Inc.
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Page 1531 1 particular thing. It went up to 6,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. So 2 there's no linearity.
3 And again, when you talk about 4 linearity, you have to be careful because when we 5 talk about linearity we always talk here about 6 average values, but that's relevant. Relevant is 7 one critical point. That's what's relevant. And 8 very little data on that. It's just a difficult 9 thing to measure.
10 DR. HISER: This is Alan Hiser from the 11 staff. The exhibit is Riverkeeper 000011 and that's 12 Information Notice 2006-08.
13 JUDGE KENNEDY: So the issue, Dr.
14 Hopenfeld, is the localized effects and non-15 linearity that that causes?
16 DR. HOPENFELD: Yes, definitely 17 indicated the locality. There's no question about 18 it. I have the profiles. Maybe I have it in my 19 hotel room.
20 JUDGE KENNEDY: That's sufficient.
21 DR. HOPENFELD: You can find them in the 22 NRC report. They did a good job on that.
23 JUDGE KENNEDY: I appreciate it. I 24 think we'll come back to this later on, but I think 25 we've noted your concern about the localized effects Neal R. Gross & Co., Inc.
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Page 1532 1 and the non-linear wear rates. And we'll come back 2 to that.
3 MR. KUYLER: Your Honor, this is Ray 4 Kuyler for the Applicant. Before we leave the 5 subject, I just wanted to point you for the record 6 to Entergy's testimony, Question and Answer 135 7 which addresses these various other events at other 8 facilities.
9 JUDGE KENNEDY: This addresses the 10 operating experience events. Is that --
11 MR. KUYLER: Yes, sir. The four 12 operating experience events at other facilities that 13 we've been talking about.
14 JUDGE KENNEDY: Thank you.
15 JUDGE WARDWELL: If I dare leap into the 16 breach here of staying with this topic for just a 17 while, for the sake of argument, let's assume you 18 are correct and local issues are a significant 19 concern. What would you suggest that the Agency 20 look at in regards to what addition should be added 21 to an Aging Management Program to address localized 22 conditions?
23 You've raised an issue. What's a 24 solution?
25 DR. HOPENFELD: Well, I thought about Neal R. Gross & Co., Inc.
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Page 1533 1 different ways of solutions. I honestly didn't come 2 prepared very well to discuss all the various 3 details. One, and you may not want to hear it, if 4 you get away with the CHECWORKS, it gives you 5 misleading results. Next, what you do -- very 6 similar to --
7 JUDGE WARDWELL: Can I just stop you 8 right there so I don't forget this?
9 DR. HOPENFELD: Yes.
10 JUDGE WARDWELL: So you're saying that 11 CHECWORKS has no use whatsoever in flow-accelerated 12 corrosion?
13 DR. HOPENFELD: Yes.
14 JUDGE WARDWELL: Is that your position?
15 DR. HOPENFELD: Yes, yes.
16 JUDGE WARDWELL: And doesn't that cover 17 all facilities and not just Indian Point? That's a 18 global issue, is it not?
19 DR. HOPENFELD: Globally, yes, but I've 20 been focused on Vermont seriously and now with IP, 21 so I really am not going to go to others. I haven't 22 really looked at enough.
23 JUDGE WARDWELL: But of all the plants 24 you've looked at --
25 DR. HOPENFELD: I have gone to just Neal R. Gross & Co., Inc.
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Page 1534 1 primarily this and Vermont, I would say yes.
2 There's a difference between Vermont and here.
3 JUDGE WARDWELL: Yes, I understand.
4 DR. HOPENFELD: To answer your question, 5 I would do globally, first, I'll give you the 6 overall answer. The French, and again, I go -- I 7 did visit them many years ago, but what I'm telling 8 you now is based on what I read in the literature 9 and very recent literature. They have a computer 10 code to do exactly the same thing because there's a 11 huge financial advantage.
12 JUDGE WARDWELL: What was the name of 13 their code?
14 DR. HOPENFELD: Deborah, do you 15 remember?
16 MS. BRANCATO: I can look that up for 17 you.
18 JUDGE WARDWELL: You're asking your 19 counsel if she remembers? Shame on you people.
20 DR. HOPENFELD: She has the reference.
21 JUDGE WARDWELL: But your testimony is 22 that you don't have the name of that code --
23 DR. HOPENFELD: I don't have the name.
24 JUDGE WARDWELL: That's fine.
25 MS. BRANCATO: We'll try to get it for Neal R. Gross & Co., Inc.
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Page 1535 1 you.
2 JUDGE WARDWELL: I've got a couple in my 3 background and I was wondering if it was one of 4 those and if you don't know it --
5 DR. HOPENFELD: It's some French name.
6 JUDGE WARDWELL: That's a legitimate 7 answer, okay.
8 DR. HOPENFELD: It's a French name.
9 JUDGE WARDWELL: It's not CICERO?
10 DR. HOPENFELD: Yes, yes, that's right.
11 You got it. That's correct, sir. Yes, yes. That's 12 what I asking the attorney.
13 JUDGE WARDWELL: Proceed then.
14 DR. HOPENFELD: I'm impressed. CICERO.
15 JUDGE WARDWELL: I shock myself.
16 DR. HOPENFELD: Anyway, what they have, 17 if you look at it, the data they presented out of 18 3,000 or 4,000 data points and I don't know they got 19 it, whatever it is. They all are within a very 20 narrow of uncertainty. They're all bunched 21 together, not scattered all over the place. They're 22 bunched together.
23 Now where they bunched up is on the non-24 conservative side. They're like 40 percent. But 25 what you can do there and I'm trying to answer your Neal R. Gross & Co., Inc.
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Page 1536 1 question, if you had a code like that that you know 2 it's consistent, then you can say okay, it predicts 3 non-conservative. I put a safety factor on it. And 4 that's my first point.
5 So if it's inconsistent by say a factor 6 of 50 percent, I'll put it, you know, twice as much 7 and I'll be conservative and I've got a data point.
8 Now, the CAGE code also had data points on erosion, 9 droplet erosion, cavitation erosion. They have 10 constance there that they have derived from their 11 experience. They don't have this F1, F2. They do 12 have also erosion, corrosion by chemical 13 dissolution, but they also have constance for 14 droplet cavitation or other erosion in the equation.
15 That's how many points out of those 3,000 do they 16 show? What kind of geometries they use, I don't 17 know.
18 JUDGE WARDWELL: So you would recommend 19 a revision of a code to incorporate some of the 20 similar items that are in that particular code?
21 DR. HOPENFELD: Yes, the most important 22 thing what I've seen and I've been surprised, in the 23 French work is they don't rely on input that -- on 24 the chromium input that is being used in CHECWORKS.
25 They measure it. They use an x-ray fluorescence to Neal R. Gross & Co., Inc.
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Page 1537 1 measure on each component what the chromium content 2 is and they showed in one of their papers relation 3 between the chromium content uncertainty and the 4 resultant corrosion rate. It's a factor of 10.
5 That's why they're measuring it.
6 Now I'm not here to sell French computer 7 codes. I don't know what they're doing. All I'm 8 just referring to what I read in the literature very 9 recently, a few months ago.
10 JUDGE McDADE: Now your comparison, just 11 to make sure I understand it, conservative, non-12 conservative, all that is is does it predict more or 13 less than the reality.
14 DR. HOPENFELD: Right.
15 JUDGE McDADE: That when you test it.
16 So it really doesn't make any difference in your 17 view whether it's conservative or non-conservative, 18 as long as it's consistent.
19 DR. HOPENFELD: Well, no -- yes, that's 20 true. Because if I know, you see, if you know where 21 are we going here, then you can put a factor of 22 factor. But if it's all over the place, it's exactly 23 the instance, yes.
24 JUDGE McDADE: So it doesn't matter 25 whether there's 50 percent that's conservative or 80 Neal R. Gross & Co., Inc.
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Page 1538 1 percent that's conservative or 85 percent that's 2 conservative, if it's consistent. You're concerned 3 with the standard deviation. First of all, if it is 4 conservative, if you're testing and it's less than 5 what's actually observed, the prediction is less 6 than what's observed, or more, it's how much. In 7 other words, if it's only slightly more or slightly 8 less than what's predicted, you would view it as a 9 viable predictor.
10 On the other hand, when you have 11 significant outliers where on one instance you will 12 have it by a factor of 10 and another instance a 13 factor of 1, that then you consider the code not a 14 viable predictor and we're going to get into the 15 data later. That's sort of the overview of what is 16 your opinion.
17 DR. HOPENFELD: Right, you're absolutely 18 right. Except one thing, the definition of 19 slightly, that goes to safety. In some places 20 where, you know, I see a component that I have a 21 major effect and luckily on the secondary side, you 22 don't have that many, unless you get into the steam 23 generator, as I mentioned before, and the nozzles, 24 most of the stuff is not that safety related. It's 25 not a major -- but safety is a concern. You should Neal R. Gross & Co., Inc.
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Page 1539 1 look into it.
2 So when you say slightly, I look at it.
3 Obviously, I'm not going to look at every component 4 to safety risk analyze every component. I'm trying 5 to answer, to be responsive to the question you 6 asked me, what would you do and I would look into a 7 code that is consistent. Not 10 on one side and 10 8 on the other side.
9 JUDGE WARDWELL: Given the fact that 10 CHECWORKS only accounts for 25 percent of the 11 inspections and the previous testimony that says 12 that the service life is predicated on actual 13 measurements, why is the need to address the model 14 such a significant importance to you considering it 15 doesn't appear to be as significant tool as the way 16 it's being applied by Entergy?
17 DR. HOPENFELD: For two reasons. It's 18 good to have a computer code because it saves you 19 money, because if you don't have, if you go based on 20 plant experience, trending basically. If you look 21 at their graphs they showed you, most of the stuff 22 is trending. What that means is that you assume 23 that you have a linear rate and therefore I can just 24 look at two or three points and say well, it's going 25 to continue like that. That's a basic assumption.
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Page 1540 1 But another thing why you want a 2 computer code is because if you are doing what 3 you're doing here, you'll measure -- you've got two 4 things.
5 How many points do you measure and how 6 accurate do you measure on a particular component?
7 You know, there's accuracy to what you measure. Are 8 you really looking at the minimum? I was trying 9 yesterday to go to the grid to discuss that. Are 10 you really, when you trend, do you really have the 11 number that you're really basing your future 12 projection? And even if it was linear, which you 13 have, so that's number one. And then how good is 14 your statistical sampling? We haven't heard 15 anything about that.
16 The 75 percent, I've looked and looked.
17 I don't know what's included, what's not. I mean 18 talked about this line is safe and our feeling is 19 this. The only way you can say that it's safe or 20 not safe is to show somebody some kind of a risk 21 analysis, some kind of assessment, some statement to 22 the effect that if something happens here only the 23 rabbit is going to get killed. I mean there's 24 nothing there.
25 I'm sorry I'm emotional. It's my Neal R. Gross & Co., Inc.
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Page 1541 1 personality.
2 JUDGE McDADE: Let me just ask you a 3 question based on a question that Judge Wardwell 4 just asked, I may have a misconception in my own 5 mind that I'd like to clear up.
6 Mr. Aleksick, if you could, as I 7 recollected and what I took from what you testified 8 earlier, and correct me if I'm wrong, but about 25 9 percent of the inspections are informed by 10 CHECWORKS, but only about 50 percent of the new 11 inspections are informed by CHECWORKS and of the new 12 inspections of modeled components virtually all of 13 them are informed by CHECWORKS. Is that correct?
14 MR. ALEKSICK: Yes, Your Honor.
15 JUDGE McDADE: Okay, thank you.
16 MS. BRANCATO: Your Honor, this is 17 Deborah Brancato from Riverkeepers. Just before you 18 move on, if that's your intention at this point, I 19 just refer you to Riverkeeper Exhibit 000110 which 20 does discuss the French CICERO model that Dr.
21 Hopenfeld and you were discussing.
22 JUDGE McDADE: Could you repeat that 23 where?
24 MS. BRANCATO: That is Riverkeeper 25 Exhibit 000110.
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Page 1542 1 JUDGE McDADE: Thank you. It was 2 suggested this may be a good time for break. Ten 3 minutes, Judge Wardwell, is that sufficient?
4 JUDGE WARDWELL: Oh, yes.
5 JUDGE McDADE: Why don't we take a 10-6 minute break and again, it's important to try to get 7 back on time. It's now -- I have 20 minutes so we 8 will come back at 10 minutes of.
9 (Off the record.)
10 JUDGE McDADE: On the record.
11 MR. KUYLER: Your Honor, this is Ray 12 Kuyler from the Applicant again. Before the break, 13 we were talking about the BRT-CICERO program and Dr.
14 Hopenfeld's testimony on it which I believe came up 15 for the first time in rebuttal. And I do believe 16 that our witnesses can also provide some information 17 on the paper that Dr. Hopenfeld is referring to.
18 JUDGE McDADE: Good. Thank you.
19 JUDGE KENNEDY: Dr. Hopenfeld, I'd like 20 to go back and talk a little more about these 21 localized effects. I think in the context of that 22 you brought up the operating experience issues. Is 23 there anything else you'd like to point to to 24 support the importance of the localized or 25 geometrical effects?
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Page 1543 1 DR. HOPENFELD: Well, but again can I 2 talk about offshore oil observations?
3 JUDGE KENNEDY: I think we concluded 4 that it may be difficult to make that transition 5 from --
6 DR. HOPENFELD: Yes, I'm just saying the 7 localized corrosion you can even go on the internet 8 and click on the localized corrosion and get a whole 9 bunch of articles, pictures, anything. It's a 10 common experience. It's a multi-billion dollar --
11 It happens in -- I mean there are more non-nuclear 12 facilities and that's a major cost item.
13 And they haven't solved that still.
14 It's a major cost estimate item. Constantly 15 replacing material. And it was mostly based on my 16 experience, my discussions, everything. It's 17 because of the local nature of that beast.
18 JUDGE KENNEDY: I guess what I'm 19 struggling with here is I think the sum total of the 20 operating experience considering the amount of 21 operating reactors in the world or in the United 22 States even that it didn't seem like a large amount 23 of anecdotal information. So I'm trying to 24 understand in this context what seems to be 25 passionate concern about these localized effects.
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Page 1544 1 And you need to help get us there.
2 DR. HOPENFELD: Yes. I looked at about 3 100 grids. The grids is the ultrasonic map of those 4 components and an estimate of one or two and all 5 you've got to do is to go through there and you even 6 see a pattern. And what the pattern is is that you 7 get most of it -- In the case of an elbow, you can 8 almost predict where it's going to happen you know 9 on the outside. It varies, but it's consistent.
10 It starts pretty uniform and then it 11 goes extremely fast high. And you can look into 12 examples I gave you. It was one inch change within 13 six inches. That's a big change. I mean your 14 probe can't read it.
15 I think I'm trying to answer this in 16 other places that I've seen. I really spent some 17 time looking all the data they gave. And I went 18 through each one of those. And it stares at you.
19 So when I hear they say it's not a local 20 phenomena, it depends on how you define local. If 21 you say I have a line and maybe within the line it's 22 not a local, I don't know. But I'm trying the local 23 within the component that I look and I'm worried 24 about where it's going to leak.
25 JUDGE KENNEDY: The grid data and the Neal R. Gross & Co., Inc.
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Page 1545 1 experiential data you're talking about, is that in 2 the Entergy submittals?
3 DR. HOPENFELD: Their reference about 4 the French data, yes. I don't know exactly. All I 5 have is reading the paper they wrote.
6 JUDGE KENNEDY: I guess I'm thinking 7 about you reviewed some data about the localized 8 effects. Is that Indian Point data you reviewed or?
9 DR. HOPENFELD: The Japanese and I 10 believe that was referenced. It definitely was 11 referenced in the -- But I believe it was referenced 12 here, too. But if it's not that would have a very 13 clear indication.
14 And the Indian Point, I mean I believe I 15 did attach to one of those figures that I presented 16 yesterday. And by reference I believed we 17 referenced all the 100 figures or 200 figures that 18 they gave us in the offshore local phenomena.
19 JUDGE KENNEDY: I don't want to diminish 20 the importance of flow-accelerated corrosion. But 21 if this localized effect is such a dominant issue 22 I'm struggling with why we don't see more operating 23 experience of failures related to these localized 24 effects.
25 DR. HOPENFELD: I think we do. I think Neal R. Gross & Co., Inc.
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Page 1546 1 they have referenced or mentioned like 16 leaks and 2 numerous if you go to the data of exceeding the 3 critical thickness.
4 And so the local thing they say it's not 5 flow-accelerated corrosion because they don't define 6 it that way. They say it's erosion. But the leaks 7 occurred. So you see it.
8 JUDGE KENNEDY: The leaks occurred even 9 though they were above the --
10 DR. HOPENFELD: Even though what?
11 JUDGE KENNEDY: There were leaks that 12 occurred even though they were above the Tcrit or 13 min crit.
14 DR. HOPENFELD: I don't know. It wasn't 15 reported that way. All they reported was a leak and 16 I've seen like 16 over a certain period of time.
17 And obviously I'd seen references up to 2006 or 2007 18 of hundreds of leaks all over the place. But it's a 19 cost item. It's to a large degree a cost, cost for 20 the plant. If I was running the plant, I wouldn't 21 want to have that. It costs me money unnecessarily.
22 JUDGE KENNEDY: Can you focus this to an 23 exhibit? And I guess in that regard are we talking 24 about Indian Point data again or other operating 25 data?
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Page 1547 1 DR. HOPENFELD: Right now I'm talking 2 about the 100 figures, something like 100 figures, 3 that Indian Point 2 and 3 provided us. And I gave 4 you samples of two. One of the things was a small 5 line. The other one was a 30 inch line. One of 6 them I think was a steam line. So it must have been 7 wet steam. And the other one was a feedwater line.
8 MS. BRANCATO: Your Honor, this is 9 Deborah Brancato from Riverkeeper. If I may, Dr.
10 Hopenfeld is referring to the graphs that were in 11 his presentation yesterday which come from 12 Riverkeeper Exhibit 000130 and Riverkeeper Exhibit 13 000049. And in addition the instances of leaks that 14 Dr. Hopenfeld is referring are also provided as 15 Riverkeeper Exhibits 000025, 000026 and 000027.
16 JUDGE KENNEDY: Thank you. Maybe we 17 could get Entergy to address this.
18 JUDGE WARDWELL: Before you do, I have 19 another question for Dr. Hopenfeld on this issue.
20 And I don't know whether I -- I may have to pull 21 back my brilliance last time and maybe in this 22 model. Maybe there are two different models out 23 there. That's why I had several in my mind.
24 The French model, could it actually be 25 CIROCO rather than CICERO?
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Page 1548 1 DR. HOPENFELD: I'd have to ask our 2 attorney. She's got the references. I don't.
3 JUDGE WARDWELL: Well, regardless, have 4 you ever heard of CIROCO model?
5 DR. HOPENFELD: I may have but.
6 JUDGE WARDWELL: You don't know whether 7 that's it or not.
8 DR. HOPENFELD: I don't know. I just 9 read the article.
10 JUDGE WARDWELL: The French model, in 11 their modeling, what do they say about this 12 linearity issue?
13 DR. HOPENFELD: The thing that impressed 14 me what they said -- It's not anything that they 15 said because I don't know anything about the model.
16 But I was impressed with the fact that they have the 17 right approach. And that is "Look. I've a large 18 uncertainty in the input. I'm going to measure it."
19 And that is important.
20 The other thing that I was impressed 21 with is all the data points were consistent. That's 22 all. I really don't know anything about that. I 23 don't know what they did. I'm really not an 24 authority on that analysis.
25 But I do remember that when Dr. Horowitz Neal R. Gross & Co., Inc.
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Page 1549 1 was talking about all these labs he did mention the 2 French. When I read the French articles about that, 3 they did mention that either the issue of FAC 4 whether it's a corrosion or erosion is not clear 5 because there was a clear indication -- I referenced 6 it in several places -- that the velocity 7 independent was not a straightforward Reynolds type 8 of an equation. It wasn't.
9 At some places, the velocity was to the 10 cube which indicates that this is just not a 11 straightforward mass transfer control. Now they had 12 a theory, the British had a theory, where it is mass 13 transfer controlled and why it is to the cube, but 14 it was just a theory. There's no way of telling it 15 was corrosion or erosion or both.
16 I think what you see here is the 17 practical answer. You look at that elbow. Who 18 cares what it is? All I see -- It could be bananas 19 doing it. But all you really care is I see these 20 huge differences over a local distance and I don't 21 know how to predict it. That's all.
22 JUDGE WARDWELL: Okay. The thing I'm 23 referring to is Entergy's Exhibit 000036B on page 7-24 6. Could we pull that up quickly if possible? I 25 think this is the model that I'm referring to is the Neal R. Gross & Co., Inc.
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Page 1550 1 CIROCO and the author is a French name. I will 2 probably slay with great dexterity, Bouchacourt.
3 Does that author sound familiar to you, Dr.
4 Hopenfeld?
5 DR. HOPENFELD: Can I see it what you're 6 talking about?
7 JUDGE WARDWELL: Sure.
8 DR. HOPENFELD: I read it. It was 9 interesting. Oh yeah. I believe so, yes.
10 JUDGE WARDWELL: Well, there is a plot 11 of some results on page 7-6. Yeah. You can show 12 the plot, too. Show the whole thing. It's best to 13 leave the whole page up I think because they'll be 14 able to see --
15 DR. HOPENFELD: I don't believe that 16 that's the data I was looking at.
17 JUDGE WARDWELL: Say it again, Dr.
18 Hopenfeld.
19 DR. HOPENFELD: When I gave you a 20 reference, all the data were about -- The reference 21 I provided were way above. The last one I used in 22 the reference that I provided you, all the data 23 points were non-conservative. They were on one 24 side. That's all I remember.
25 JUDGE WARDWELL: What I'm interested in Neal R. Gross & Co., Inc.
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Page 1551 1 --
2 DR. HOPENFELD: It wasn't this figure.
3 JUDGE WARDWELL: What I was interested 4 in is the first bullet item there. Really that's a 5 core key dot, but I won't get into that. That's 6 another time for that.
7 The item there it says, "The thinning is 8 directly proportional to time" in regards to their 9 results. Would you like to comment on that?
10 DR. HOPENFELD: Where is this? Did I 11 reference this document?
12 JUDGE WARDWELL: No, I'm providing this 13 to see if first whether you recognize this author 14 that's under that figure as being the author of the 15 French code. And is the French code in fact the 16 CIROCO loop test results that were described here?
17 That's what you were referring to or not.
18 DR. HOPENFELD: No, that's not the one I 19 was referring to.
20 JUDGE WARDWELL: Okay.
21 DR. HOPENFELD: No, I was referring to a 22 very recent document like a few months ago.
23 JUDGE WARDWELL: But then I go on to 24 point out that you'll note that it does talk about 25 that the thinning is directly proportional to time.
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Page 1552 1 And if you haven't studied this exhibit, you can't 2 really comment on this.
3 DR. HOPENFELD: I did look at it and the 4 point is here that these are laboratory studies and 5 sure they're running the control condition. If they 6 are run at low Reynolds number or low velocity, 7 relative low turbulence, you'll get a linear 8 relation. There's no problem.
9 JUDGE WARDWELL: Okay. Thank you.
10 DR. HOPENFELD: I'm talking about 11 complex geometries. I don't think it's here.
12 JUDGE WARDWELL: Thank you.
13 JUDGE KENNEDY: I think we've been all 14 over this issue about localized effects. But I'm 15 not sure what Entergy's position is. How is this 16 aspect of the Flow-Accelerated Corrosion Program 17 treat the nonlinearity effects or the localized 18 geometry effects that Dr. Hopenfeld is talking 19 about, if it does?
20 MR. ALEKSICK: This is Rob Aleksick for 21 the Applicant. I'm sorry, Your Honor. I didn't 22 hear the last half of your question.
23 JUDGE KENNEDY: Let me try it again. I 24 did ramble a bit anyhow. We've been talking about 25 nonlinear, localized effects either due to geometry Neal R. Gross & Co., Inc.
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Page 1553 1 or flow conditions. And I'm wondering how the Aging 2 Management Program for FAC at Entergy deals with 3 these localized effects or if they're real at all.
4 I mean if it doesn't deal with them, is it because 5 they don't exist or if they do exist, how are they 6 treated?
7 MR. ALEKSICK: I would characterize FAC, 8 flow-accelerated corrosion, as a line level 9 phenomenon. FAC is like cockroaches. If you see 10 one, there's more going on there. And if the line 11 conditions, if the temperature and flow rates and 12 base material and pH which are typically constant 13 across a given line, if those conditions are 14 conducive to FAC and if you observe FAC in one 15 fitting, you often -- you typically in the majority 16 of cases observe FAC in some of the other fittings 17 along that line. And so in that sense I consider 18 FAC a line level phenomenon.
19 Now, of course, it's a local phenomenon 20 in the sense that the components wear locally and 21 the degree of wear may vary from component to 22 component based on its local geometry.
23 But in order to have an effective 24 program, we have to recognize that FAC is not a 25 random phenomenon that occurs in an unpredictable Neal R. Gross & Co., Inc.
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Page 1554 1 manner at a component level. We have thousands and 2 thousands of components. And if we had to treat 3 FAC as a random or purely local phenomenon we would 4 have an enormous challenge.
5 Fortunately, FAC is predictable at the 6 line level and we generally treat things at a line 7 level programmatically. And we dive down into the 8 component level for individual inspections and model 9 results and things like that.
10 But thinking programmatically we think 11 more about the line. Does that answer your question 12 now?
13 JUDGE KENNEDY: I guess I'm -- So you 14 said fittings, so like elbows and other geometrical 15 effects on the line flow conditions.
16 MR. COX: This is Alan Cox for the 17 Applicant. I could maybe clarify that a little bit.
18 Rob says line level, but you're correct that the 19 individual fittings are modeled in that line. So 20 basically what that means is if you've got a pipe 21 that has several bends and elbows in it that each of 22 the elbows of that line is going to see the same 23 flow conditions, the same temperatures. So each 24 elbow would be expected to see the same wear.
25 Now when you say line levels, that Neal R. Gross & Co., Inc.
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Page 1555 1 doesn't mean the pipe between the elbows is going to 2 see the same level because it doesn't have the same 3 geometry factor. But all the same components within 4 that line to see the same conditions are going to 5 see similar wear.
6 JUDGE KENNEDY: Is there some effect of 7 the fittings on the turbulence and flow regimes?
8 And does that have any bearing on the calculated 9 wear rate for that piece of the component or piece 10 of the line?
11 MR. ALEKSICK: This is Rob Aleksick 12 again, Your Honor. Yes, the local geometry, say a 13 90 degree elbow, will typically wear more rapidly 14 than a 45 degree elbow. But in terms of the 15 calculation of the wear rate based on the measured 16 wall thicknesses, the geometry doesn't play much of 17 a role. Once we know the wall thickness and knowing 18 that it's a linear phenomenon we can project flow 19 rate.
20 Perhaps an example would help. Dr.
21 Hopenfeld referred to what he called the huge 22 differences in measurement from point to point on 23 the grid that he presented in his presentation 24 yesterday. Do we have that? Could we perhaps put 25 that on the screen? It's not an exhibit, but it was Neal R. Gross & Co., Inc.
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Page 1556 1 a PowerPoint from yesterday.
2 JUDGE McDADE: It was part of Board 3 Exhibit 00002.
4 MR. ALEKSICK: Yes, that's it. Thank 5 you. And it would have been about the fourth or 6 fifth page. I believe it's the -- Right there.
7 Yes, great. If we could zoom in perhaps on that 8 figure. That's good. That's fine.
9 So this is a specific component, an 10 elbow, a 30 inch feedwater elbow, at Indian Point.
11 And if we go to the next page in this presentation 12 and if you could please zoom in on the sort of 13 lefthand side of the grid there, you can see that at 14 Coordinate C08 there's a parent measurement of 15 0.513. And next to it are measurements of on the 16 order of 1.5 inches. That looks like a fairly 17 significant step change.
18 Now if we could bring up Riverkeeper 19 Exhibit 000130. And that exhibit is the full 20 inspection package that Dr. Hopenfeld kind of 21 excerpted for his presentation here.
22 JUDGE WARDWELL: While we're doing that, 23 is it Dr. Hopenfeld or Dr. Hopenfeld or is it both?
24 DR. HOPENFELD: Anyway you call me 25 that's fine. I'll answer.
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Page 1557 1 JUDGE WARDWELL: What do you call it?
2 DR. HOPENFELD: Usually you call me 3 Hopenfeld or some of them -- my son is called Hoppy.
4 MR. ALEKSICK: And if you could go down 5 to the third or fourth page. Stop right there 6 please. Now this is the same figure that Dr.
7 Hopenfeld, right?
8 DR. HOPENFELD: Hopenfeld.
9 MR. ALEKSICK: Hopenfeld.
10 JUDGE WARDWELL: Just think of Hoppy.
11 DR. HOPENFELD: You can say it either 12 way.
13 MR. ALEKSICK: That the good doctor 14 excerpted it for his presentation.
15 DR. HOPENFELD: That's better.
16 MR. ALEKSICK: Unfortunately, in 17 preparing his presentation, he cropped out a key 18 fact here. If we could zoom in on that word 19 "lamination." Thank you. What we're looking at on 20 the lefthand side of the screen here was omitted 21 from yesterday's presentation. And it's a very 22 important fact.
23 A lamination. It's also if you scroll 24 down to the lower lefthand corner of this page 25 you'll see it again. There. Stop please. You see Neal R. Gross & Co., Inc.
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Page 1558 1 the second to bottom reading or second to bottom 2 sentence. It says, "Low readings due to 3 lamination."
4 A lamination is a condition that occurs 5 not infrequency in thick walled pipe like this.
6 This is a one and a half inch thick pipe roughly.
7 And in thick piping like that you sometimes come 8 across what is called a lamination which is 9 essentially a discontinuity in the metallurgy of the 10 pipe. And it will give when a standard UT reading 11 is taken an erroneous reading.
12 So this 0.513 reading is the depth of 13 that lamination. It is not the thickness of the 14 pipe. And we know that because it says it actually 15 in three different places on this inspection 16 package.
17 So my point, Your Honor, is that the 18 example that alleges huge differences in measured 19 pipe wall thicknesses is in fact due completely to a 20 lamination, not due to any kind of wall thinning or 21 reduction in wall thickness whatsoever. I would 22 just like to point that out.
23 JUDGE McDADE: From an engineering 24 standpoint, how do you determine that it's the 25 result of lamination?
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Page 1559 1 MR. AZEVEDO: Yes, Your Honor. This is 2 Nelson Azevedo for Entergy. There are a couple 3 different things that we do. Normally, the pipe 4 thickness is measured using a given transducer at a 5 given frequency or what we call a straight beam.
6 When we find conditions that look 7 suspect, we go and do a couple different things.
8 One is use a different frequency transducer and if 9 the lamination which is originally started as an 10 inclusive that was flattened out, if it's tight, you 11 can actually punch right through it and you can see 12 a reflection from the back wall with using a 13 different frequency transducer.
14 The other thing that we do is we shoot 15 on an angle and see if we can see the inside service 16 of the pipe underneath the inclusive. And that's 17 how we determine whether it's an inclusive called 18 lamination or whether it's true wall thinning.
19 JUDGE McDADE: Okay. Thank you.
20 MR. ALEKSICK: I guess I'd just like to 21 reiterate our conclusion which is that these wall 22 thickness readings are not due to flow-accelerated 23 corrosion and they do not reflect any reduction in 24 the wall thickness or the pressure retaining 25 capability of that component. They merely reflect a Neal R. Gross & Co., Inc.
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Page 1560 1 metallurgical property.
2 JUDGE KENNEDY: So they're not 3 demonstrative of a localized, nonlinear wall 4 thinning.
5 MR. ALEKSICK: Exactly, Your Honor. And 6 I completely reject the assertion that this dataset 7 represents "huge variations" in the wall thickness.
8 JUDGE WARDWELL: And can we go back to 9 that grid of the data points? Yes. And there are 10 others. So is that true of the one right below it 11 and the one following it? I mean there's almost --
12 And is that why they're shaded on this grid sheet 13 also because those are the ones that you consider to 14 be laminations?
15 MR. ALEKSICK: The shaded area is 16 representative of the lamination. However, shading 17 is not because of the lamination. The shading is 18 because of the number. The shading is applied by 19 the --
20 JUDGE WARDWELL: It's just fortuitous 21 then that it happened.
22 MR. ALEKSICK: Yes, precisely.
23 JUDGE WARDWELL: Okay.
24 JUDGE McDADE: But is it also your 25 testimony -- I just want to make sure -- that that Neal R. Gross & Co., Inc.
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Page 1561 1 lamination phenomenon in no way impacts the 2 integrity of the piping, its capacity to take the 3 pressure?
4 MR. AZEVEDO: Yes, that's correct, Your 5 Honor.
6 JUDGE WARDWELL: It's an artifact. It's 7 not a reality, this lamination. And the thickness 8 is there. It just happens at these locations to 9 create a lower than what it should be reading.
10 MR. AZEVEDO: Yes, as Mr. Aleksick said, 11 that's a metallurgical effect. And the reason why 12 it's structurally insignificant is because it's 13 parallel to the load path. So the load path doesn't 14 even see that it's there.
15 JUDGE WARDWELL: Dr. Hopenfeld, do you 16 agree that laminations are not an issue?
17 DR. HOPENFELD: Could be an issue, but 18 I'd like to answer your question. First of all, I 19 saw the lamination and I was very clear. I even 20 went to the dictionary to make sure I understood 21 what they were talking about.
22 The bottom line question is if there was 23 an accident. Let's say you let that lamination go 24 on or whatever happens here for another two years.
25 And then suddenly the valve somewhere or local Neal R. Gross & Co., Inc.
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Page 1562 1 occurred somewhere in the system. Is that going to 2 blow up that pipe? That's the question. The other 3 question is is it going to leak whether it's 4 lamination or it's imperfection or whatever it is.
5 Secondly, this is one that I brought up 6 because it was a large size. It had a straight 7 section. My main purpose was to show that the 8 process is not -- In the grid there, I picked up was 9 1.491 which doesn't indicate that it's a lamination 10 point because it's similar as they say.
11 And then I picked up a number next to it 12 which was the 0.513 which they reported. Plus they 13 also reported on the same grid a number even less 14 than 0.513.
15 This just represents -- I can give you 16 other elbows and orifices that doesn't say anything 17 about lamination. And you see the same ratio. You 18 see that it is not flow-accelerated corrosion. It's 19 an erosion problem. I picked it up because I had 20 only 50 minutes.
21 But I can give you more if you wish and 22 I'll show you the same numbers after I have it in my 23 notes. So this was not picked up. But the bottom 24 line with this lamination, imperfection, whatever it 25 is, doesn't really matter. What matters is am I Neal R. Gross & Co., Inc.
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Page 1563 1 going to have a LOCA and Part 50 requires you that 2 this component would withstand LOCA.
3 So when I hear lamination I say it's 4 safety. I don't care whether it's FAC or not. What 5 it is, is it safe. And we didn't get an answer that 6 it was safe.
7 I can tell you if you ask me what is a 8 constructive thing and how to do it. If you want me 9 to I'll get into more detail on that. If you would 10 wish I would like to. But I'll have to go to a 11 different industry.
12 JUDGE WARDWELL: Do you disagree that 13 the actual thickness at C08 is not 0.5 at that 14 location and in fact a value closer to the 1.5 inch?
15 Or do you believe that the actual thickness at C08 16 is 0.5?
17 DR. HOPENFELD: I looked at these from 18 three or four different angles on that very point 19 that you asked. One way of looking at it is to say 20 let me look at the one next to it and it's 1.492. I 21 don't know if it was lamination or not.
22 Let me put it just for a second. If it 23 is so bad, don't present it. Don't give it to me.
24 I don't want to waste my time with something if it's 25 bad data. Don't give it to us. Don't present it to Neal R. Gross & Co., Inc.
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Page 1564 1 us. It's your judgment. That's fine.
2 If you're going to their procedures and 3 how they presented the data, there is a whole bunch 4 of discussion as to the guy selected the notes. He 5 selected because of this. He selected because of 6 this. If this is bad, if this is not 7 representative, don't give it to me. But they gave 8 it to you. They gave it to us. And I believe that 9 these numbers represent something.
10 Now whether they represent -- I'll tell 11 you one thing. I don't believe that that 0.513 12 represents the minimum number. The minimum actual 13 thickness, that's what counts. It does not 14 represent the minimum actual thickness in that grid.
15 It's less.
16 But how much less? I would have to do a 17 lot of work. I don't know. You see there's one 18 thing you don't have here. And if I was running the 19 plant, I would insist that the contractor who did 20 the ultrasonic to give it to you to show you what is 21 the probability of detection for this particular 22 case, what's your accuracy, what the coupling that 23 you're using. I assume everything -- How many 24 points did they measure here?
25 Don't forget. That probe is only 0.32 Neal R. Gross & Co., Inc.
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Page 1565 1 inches. This is what you're looking. You have about 2 50 mL drag across the probe. That probe reads 3 average. So it must be less than it. If it's an 4 average, it must be at least 25 mL. So the number 5 must be at the minimum less than that.
6 But now if you have waves and pittance 7 and lamination or whatever you want to call it, who 8 knows what it is. That's the problem with it. It's 9 safe to run. That's what the gentleman said.
10 That's what the problem is.
11 I have no problem with the -- I 12 apologize. I did say the lamination and it didn't 13 come on the figure. It was not intentional.
14 JUDGE McDADE: Doctor, if I could 15 interrupt and again we want you to be talking to us, 16 not talking to you.
17 DR. HOPENFELD: Yes. It wasn't 18 intentional.
19 JUDGE McDADE: But let me just ask you a 20 question here. I mean we had from Mr. Azevedo an 21 explanation of how they are able to identify whether 22 or not it's lamination as opposed to flow-23 accelerated corrosion or erosion.
24 Based on your expertise, do you have any 25 reason to take issue with the explanation that they Neal R. Gross & Co., Inc.
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Page 1566 1 are able in fact to identify lamination as opposed 2 to corrosion or erosion?
3 DR. HOPENFELD: No, I don't know. First 4 of all, this is the only one I believe that had a 5 lamination note on it. But I didn't focus my -- I 6 looked at most of the others. This one just came 7 out. And I didn't pick up because of lamination. I 8 was debating whether I should.
9 But I did because it had a clean section 10 there. Because you have to realize --
11 JUDGE McDADE: I understand. We'll get 12 to that later. But we heard the testimony of Mr.
13 Azevedo and he explained how they were able to 14 identify that this is in fact lamination. You don't 15 take issue with the technology that he described 16 that that would be able to in fact identify 17 lamination.
18 DR. HOPENFELD: I've done -- I have some 19 hands-on experience with these probes. Not seeing 20 what the technician has done, I really can't. But I 21 trust that the gentleman knows what he's talking 22 about. And it's his judgment. I'm not questioning 23 that.
24 JUDGE McDADE: But you can't really 25 speak to it one way or the other. Okay. Next Mr.
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Page 1567 1 Aleksick testified that having identified it as 2 lamination that in his professional judgment the 3 lamination would not in any way affect the integrity 4 of the piping.
5 Now if in fact -- And it seemed to be 6 from your testimony if you had a LOCA, if you had 7 something else occurred, that the integrity of the 8 piping could be compromised. Do you believe that 9 the lamination can affect the integrity of the 10 piping and, if so, why?
11 DR. HOPENFELD: Yes. When you go 12 through the hoop stress, you don't ask yourself if 13 it's laminated or whatever it is. You just take the 14 operating pressure and multiply it by the radius, 15 divide it by the thickness and you look at the 16 allowable stress. And if the allowable stress is 17 not what the code allows you, then it's not going to 18 hold it. But if it's lamination or whatever is a 19 pit or whatever it is. Now --
20 JUDGE McDADE: Let me interrupt for a 21 second.
22 DR. HOPENFELD: Yes.
23 JUDGE McDADE: Mr. Aleksick, as I 24 understood your testimony that if you ran those 25 tests if it was laminated it would pass those -- If Neal R. Gross & Co., Inc.
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Page 1568 1 it was lamination as opposed to flow-accelerated 2 corrosion, it would pass the stress tests. Is that 3 correct?
4 MR. ALEKSICK: Yes, Your Honor. That's 5 correct because there is no metal loss. The pipe 6 wall is approximately 1.5 inches thick at that 7 point. It's merely indicated at 0.513 because the 8 ultrasound bounced off that discontinuity and gave 9 it erroneous reading.
10 JUDGE McDADE: And I believe actually it 11 came from Judge Wardwell rather than the witness, 12 but he described that as a artifact as opposed to 13 the reality.
14 MR. ALEKSICK: I think that's an 15 excellent choice of words, yes.
16 JUDGE McDADE: So that's something that 17 you would agree with that characterization.
18 MR. ALEKSICK: Yes, Your Honor.
19 JUDGE McDADE: Dr. Hopenfeld, would you 20 disagree with that characterization? And, if so, 21 why?
22 DR. HOPENFELD: I don't know enough 23 about it, but if this is a fluke, if this is an 24 outlier, if this doesn't represent anything, that's 25 fine. But I didn't really look at that.
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Page 1569 1 JUDGE McDADE: But they're not saying 2 it's --
3 DR. HOPENFELD: The same message and no 4 notes or elaboration.
5 JUDGE McDADE: They're not saying it's a 6 fluke or it's an outlier. They're saying that based 7 on the way that they test it it shows up. And then 8 they can test it further and identify whether or not 9 that original reading is correct and demonstrates an 10 absence of pipe thickness or whether or not it is 11 through this lamination which is an artifact where 12 there is in fact the appropriate pipe thickness. Do 13 you --
14 DR. HOPENFELD: It is reported as a 15 thickness. That's what the report says. It's wall 16 thickness. The question is that I would ask how you 17 determine whether it will take the pressure or not.
18 One way of doing it is very simple. Just run a 19 pressure test on it.
20 But I don't want to waste people's time.
21 This is just one. I didn't see any other notes 22 lamination that was that significant. But if you 23 have a problem with the lamination I can find 24 another grid.
25 In fact, I brought you the other figure.
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Page 1570 1 The next figure shows you also going from 0.59 what 2 it was -- My whole point here was to show you that 3 that ratio if you take that ratio and compare it to 4 CDF calculations showing you that this is not a 5 flow-accelerated corrosion as they defined it. That 6 was my whole message here.
7 JUDGE KENNEDY: But isn't that the 8 issue? Is there really evidence of a nonlinear wall 9 thinning here? My understanding of what this data 10 shows is that there is not any evidence of an 11 nonlinear or geometric effect wall thinning? Am I 12 missing the point? And all of you can speak up.
13 MR. AZEVEDO: Yes, Your Honor. This is 14 Nelson Azevedo for Entergy. Let me just make a 15 couple quick points if I may. This lamination it's 16 an original fabrication defect or inclusion. It's 17 not something that propagates with time.
18 The other point I'd like to make is just 19 to be positive that we were sure that this was 20 lamination and not flow-accelerated corrosion 21 induced thinning we went back the following outage 22 and verified that nothing had changed.
23 JUDGE WARDWELL: Dr. Hiser, do you have 24 any comments in this area? Or do you just want to 25 remain silent?
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Page 1571 1 MR. HISER: There have been a lot of 2 issues discussed.
3 JUDGE WARDWELL: I'll fold some things 4 in. Have you heard of this lamination before and is 5 it something that you commonly run across with other 6 plants? And is this a plausible reason for these 7 lower readings?
8 MR. HISER: Laminations are a phenomena 9 that occurs. I wouldn't call it necessarily --
10 Well, it is reality. It is a metallurgical 11 artifact, but it also is reality where the material 12 has --
13 JUDGE WARDWELL: Has a discontinuity.
14 MR. HISER: -- a discontinuity between 15 the two. And that's why in reality when you take 16 thickness measurements when the sound beam hits that 17 interface it reflects FAC. That's how the thickness 18 measurements are made overall. If you have a 19 portion of pipe without a lamination, it goes from 20 the outer surface to the inner surface when it hits 21 that interface and it reflects back.
22 That appears to be a plausible 23 explanation for this data. We have not 24 independently reviewed this data set.
25 JUDGE WARDWELL: Okay. Maybe I should Neal R. Gross & Co., Inc.
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Page 1572 1 go back to Entergy then with the next question.
2 Entergy, Mr. Azevedo, how are you sure that this 3 discontinuity hasn't weakened the strength 4 characteristics of this elbow regardless of the fact 5 that this wall thickness may still be 1.5? It ain't 6 as good as 1.5 without that discontinuity, is it?
7 MR. AZEVEDO: Well, it depends how you 8 look at it really. Naturally, you could argue that 9 it can make the pipe stronger if you will. Again, 10 just give me a second.
11 First, let me comment. How do I know 12 it's not weakened the pipe? And the way I know that 13 is because whether you look at the hoop stress or 14 the axial stresses. Both of those stresses are 15 perpendicular to the lamination. So if you have a 16 sheet of paper and you were to rip it down the 17 middle and then pull the ends, the fact that the 18 sheet of paper is ripped down the middle doesn't 19 really weaken the sheet of paper.
20 And to the other point you can actually 21 argue what makes it stronger is if you were to have 22 a flaw crack on the top of the paper that flaw could 23 grow to where the inclusion is and then stop. So we 24 don't take credit for it. I'm not saying it makes 25 the pipe stronger. But you could argue that it Neal R. Gross & Co., Inc.
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Page 1573 1 does.
2 But what I can say is because the 3 directions of the stresses the laminations don't 4 have a significant effect on the structure 5 capability of the pipe.
6 JUDGE WARDWELL: Dr. Hiser, have you 7 ever run across this at other situations at Indian 8 Point or at other situations at other plants?
9 MR. HISER: Not that I'm specifically 10 familiar with.
11 JUDGE WARDWELL: Thank you.
12 MR. HISER: But I know ASME code takes 13 into account things like laminations. And this 14 would I expect it would likely be acceptable by ASME 15 code perspective because the lamination is located 16 in the middle of the pipe. And as the Entergy 17 witnesses testified, the loadings here would not 18 enable that lamination to open up in a way that 19 could propagate the lamination or cause a structural 20 problem. The orientation of it would be such that 21 it would not have a significant impact on structural 22 integrity.
23 JUDGE WARDWELL: Dr. Hopenfeld, final 24 comments?
25 DR. HOPENFELD: Yes, I had two comments.
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Page 1574 1 One, if I was a pipe manufacturer or salesman and 2 came and sold you this pipe and told you it's 3 laminated --
4 JUDGE WARDWELL: Please talk to me for 5 two reasons. One, you should talk to me and, two, 6 that's where your mike is.
7 DR. HOPENFELD: I'm terribly sorry. If 8 I were a salesman and came to you and said, "Why 9 don't you buy that? I'll give you it at a discount.
10 It's got some lamination in it," would you buy it?
11 That's question number one.
12 Question number two -- and I haven't 13 done it, but I just looked at it here -- is I bet 14 you if I didn't go to these -- First of all, I 15 looked -- If you see my notes on the bottom there, I 16 looked at two points. But I believe if I looked at 17 other points between like 1.6 and 1.4, if I made 18 those calculations, I would still show the same 19 answer. I would still come up with the same. So I 20 don't know where the laminations are. There were no 21 pictures to show me where they are or where they are 22 not. Maybe I would have picked it up.
23 But the bottom line is would you buy a 24 pipe like that. Would the ASME account for that?
25 Do you want to know? This is not unique to only the Neal R. Gross & Co., Inc.
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Page 1575 1 nuclear industry. In fact, the API had a lot of 2 problems with that and a lot of problems primarily 3 in offshore oil facilities where you have a lot of 4 pitting. So you miss it.
5 In fact, in Trojan, there was a big pit 6 that was missed on a much smaller grid. There was a 7 four inch grid on a 30 inch pipe and they missed big 8 indications. So they are there from a different 9 angle. You know this is a wrong grid.
10 But going back to the thing, in order to 11 meet code for this particular case, the first thing 12 you look at and say "Well, the report is 0.513."
13 That's either close or lower than the allowed 14 thickness.
15 The next thing you can say "Do I have 16 somewhere in the code that allows you to look at the 17 next step?" And the same thing the API did. They 18 said, "If you have a little pit, who cares? This 19 would not affect the strength. Maybe a leak, but 20 it's not going to affect the strength of the hoop 21 stress of this thing."
22 So what you do is you take a look at how 23 long is it. Then you go and do calculations and see 24 whether it will take it or not. And I don't know 25 how long. You see you could look at this report.
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Page 1576 1 This is a vendor gave you something. You don't know 2 what it is. You don't know how many points he took.
3 The gentleman is right. You can get 4 reflection from the back wall and you get a 5 different reading. But look at this report. I 6 wouldn't buy this. It doesn't tell you anything 7 really. It tells you 0.513. You don't know that it 8 really is the smallest point within that grid.
9 That's not what you want to know is the smallest.
10 You want to know if you meet the code.
11 I don't know how you can tell from this that you 12 meet the code.
13 JUDGE KENNEDY: Dr. Hopenfeld, even with 14 the additional explanation that Mr. Azevedo has 15 provided of additional testing that was done on the 16 pipe? I mean it seems clear to me that this data is 17 an anomaly and not reflective of a minimum wall 18 thickness. But I gather from your testimony that 19 you see it exactly the opposite way. This to you, 20 this minimum wall thickness, is real. This 0.513 is 21 a real number to you.
22 And I'm thinking that what we've heard 23 from Entergy's testimony is that they took the data.
24 It was an anomalous reading that they pursued with 25 other testing methods and that they don't believe Neal R. Gross & Co., Inc.
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Page 1577 1 that wall thickness is of that magnitude. And I'm 2 struggling with how you have drawn a completely 3 different conclusion.
4 DR. HOPENFELD: First of all, I did use 5 this one as an example. And as I said before I 6 looked at many others. My point that the ratio is 7 above 1.6 which you see on the bottom there is not 8 unique to this particular case. And I look at other 9 points and they all show that this is not a 10 straightforward mass transfer FAC control phenomenon 11 the way they said.
12 So you can look at many other elbows 13 forgetting about this particular one with the 14 lamination. I don't want to discount the lamination 15 because you can say -- You basically say "I don't 16 know what I'm running with." That's basically what 17 it says.
18 We heard testimony that it is safe, but 19 it hasn't been shown that it is safe. I don't know.
20 All I know is it's a low point. It's reported as 21 0.513 and there's a little note lamination. Is that 22 enough to tell you that's okay?
23 But I'm willing to completely disregard 24 this because it's not the only one. My main point 25 was that that ratio was not 1.6. And you probably Neal R. Gross & Co., Inc.
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Page 1578 1 can go to some other places here and you'll find 2 that it is not.
3 JUDGE KENNEDY: I guess I have two 4 follow-up for Entergy. Is it your testimony that 5 the lamination explains the low readings there?
6 MR. AZEVEDO: Yes, Your Honor.
7 JUDGE KENNEDY: So let's go to question 8 two. To maybe head off the possibility that Dr.
9 Hopenfeld is going to go review his data again and 10 come up with a second example, from your 11 perspective, from Entergy's perspective and Indian 12 Point data, has there been any evidence that you've 13 seen of nonlinear wear in an elbow? And, if so, 14 how is the plant dealing with this?
15 MR. AZEVEDO: Well, I can say I'm the 16 supervisor of the group responsible for the FAC 17 Program. I can tell you from my experience I have 18 not seen it.
19 JUDGE KENNEDY: So there is no evidence 20 of a nonlinear wear rate in an elbow.
21 MR. AZEVEDO: I'm certainly not aware of 22 any.
23 DR. HOPENFELD: Can I show it?
24 JUDGE KENNEDY: Dr. Hopenfeld, you have 25 your hand up. Are you going to point us to a set of Neal R. Gross & Co., Inc.
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Page 1579 1 data that we can discuss here?
2 DR. HOPENFELD: Sorry.
3 JUDGE KENNEDY: Are you going to point 4 us to a set of data that we could look at?
5 DR. HOPENFELD: It's not in evidence. I 6 just looked. Others and I have it in my notes here.
7 I have another elbow, but it's not in evidence. I 8 don't know. I can come back and show you another 9 number. I took it 2.0 points and the ratio came 6.0 10 as opposed to 1.6. It's a different elbow.
11 JUDGE KENNEDY: And you're reviewing 12 Indian Point data. Is that what you're telling us?
13 DR. HOPENFELD: Yes. It's from Indian 14 Point, but I don't know which. I can give you the -
15 - It's 3R15 IP3 and this particular one was I have 16 the drawing number and I have the grid number for 17 it, too. So I looked at others. This is just one 18 and I still don't want to discount the lamination 19 anyway because I don't understand it. The answer is 20 would you buy a pipe like that.
21 JUDGE McDADE: Okay. You gave some 22 numbers there that I wasn't quick enough to write 23 down. Could you repeat them?
24 DR. HOPENFELD: The numbers right now 25 that I gave you from different --
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Page 1580 1 JUDGE McDADE: Yes.
2 DR. HOPENFELD: I gave you a number like 3 6.0 I believe where I took two points on an elbow 4 and the ratio was 6.0.
5 MS. SUTTON: Kathryn Sutton for the 6 Applicant. Your Honor, I understand this is not in 7 evidence.
8 JUDGE McDADE: Well, I'm just trying to 9 -- We're not sure.
10 DR. HOPENFELD: It's not in evidence.
11 JUDGE McDADE: And then we can decide 12 whether it's in evidence or not.
13 MS. SUTTON: And if we could get some 14 more information as to what the witness is referring 15 to that would be very helpful.
16 JUDGE McDADE: I didn't have any idea 17 what he's referring to.
18 MS. SUTTON: Same here, Your Honor.
19 JUDGE McDADE: So that's what I'm trying 20 to find out. So could you just repeat it, Dr.
21 Hopenfeld?
22 DR. HOPENFELD: Yes, I looked at another 23 elbow and I have a number here showing a ratio of 24 6.0.
25 JUDGE McDADE: Right. But where is Neal R. Gross & Co., Inc.
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Page 1581 1 that?
2 DR. HOPENFELD: Well, I can -- All 3 right.
4 JUDGE McDADE: You gave some specifics.
5 DR. HOPENFELD: The grid is labeled as 6 FWO31B08E UTM whatever that means.
7 MS. BRANCATO: Your Honor, this is 8 Deborah Brancato for Riverkeeper. I believe Dr.
9 Hopenfeld is referring to a document that 10 Riverkeeper received in discovery. It should have 11 an Entergy Bates stamp on the bottom.
12 JUDGE McDADE: Okay. Perhaps why don't 13 we just move on from this. We're going to break for 14 lunch in about a half an hour. And at that point in 15 time if we can try to identify the specific document 16 that Dr. Hopenfeld is referring to and we can make 17 determinations based on that.
18 Dr. Hopenfeld.
19 DR. HOPENFELD: I do have one in 20 evidence right here. It's the next one, the one 21 that came up following this grid that is in evidence 22 or it's not evidence in the presentation. Oh, it is 23 in evidence, too. Could you give me the next one 24 please? The next figure with the one inch pipe.
25 The next figure, the following.
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Page 1582 1 No, that's the prior one. The next one.
2 Yes, that's the one. That one the ratio on this 3 particular pipe is 2.83. That's a one inch pipe.
4 JUDGE WARDWELL: What does this -- I 5 don't even know what this ratio is that you're 6 calculating.
7 DR. HOPENFELD: Okay. I defined it in 8 the presentation.
9 JUDGE WARDWELL: This is not in evidence 10 yet and it needs to --
11 DR. HOPENFELD: It's in the 12 presentation.
13 JUDGE WARDWELL: Before we get into 14 that, let's drop back and see whether or not you can 15 provide something and come back to us after lunch.
16 DR. HOPENFELD: Sure.
17 JUDGE WARDWELL: And then we'll decide 18 whether or not these types of things are in there 19 would be my suggestion, Mr. Chair.
20 JUDGE McDADE: Yes, and just so the 21 record is clear since we have taken a quick look at 22 this this is an excerpt from what has so far been 23 marked as Board Exhibit 000002 for identification.
24 And I'm not really certain. It's about page seven 25 of that, Mr. Wilkie.
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Page 1583 1 JUDGE WARDWELL: It's ten.
2 JUDGE McDADE: Ten. So we at least know 3 what was shown on the screen here and then we'll 4 come back and revisit this after the break.
5 MS. SUTTON: Your Honor, may I ask that 6 Ms. Brancato just repeat the Entergy disclosure 7 Bates number on the bottom of the page that was 8 referred to earlier?
9 JUDGE McDADE: She can do that and get 10 back to you when we have the break.
11 MS. SUTTON: That would be appreciated.
12 Thank you, Your Honor.
13 MR. MUSEGAAS: We'll take care of that 14 after the break. Thank you.
15 MS. BRANCATO: Your Honor, this is 16 Deborah Brancato. Just to clarify, Dr. Hopenfeld is 17 referring to what's on the screen now. That 18 excerpted graph is from an exhibit Riverkeeper 19 000049 that is in evidence just to clarification.
20 MR. FAGG: Just to further clarify, it 21 was admitted for a limited purpose. That was the 22 order of yesterday.
23 MS. BRANCATO: Your Honor, just to 24 respond to that, the PowerPoint presentation was 25 admitted for limited purpose. But Riverkeeper Neal R. Gross & Co., Inc.
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Page 1584 1 000049 is just an exhibit that Riverkeeper 2 submitted.
3 JUDGE McDADE: What I'm understanding 4 you to say is Dr. Hopenfeld used that particular 5 graph, put it in his PowerPoint presentation which 6 at this point hasn't been received. But it's only 7 been identified for identification. That graph 8 itself was taken from Riverkeeper Exhibit 000029 9 which --
10 MR. MUSEGAAS: Sorry, Your Honor. It's 11 Exhibit 000049.
12 JUDGE McDADE: 000049.
13 MR. MUSEGAAS: It was excerpted from 14 that exhibit for the PowerPoint.
15 JUDGE McDADE: Okay. Thank you.
16 MR. ALEKSICK: Your Honor, I apologize 17 for interrupting. This is Rob Aleksick for the 18 Applicant over here.
19 JUDGE McDADE: Okay.
20 MR. ALEKSICK: I'm sorry. This may save 21 the Court a bit of time. I'd just like to point out 22 that Riverkeeper 000049 that we're discussing here 23 is of a small bore component and we're discussing it 24 in the context of CHECWORKS when, in fact, this 25 component is not modeled in CHECWORKS. So I would Neal R. Gross & Co., Inc.
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Page 1585 1 just like to point that out. I don't know how 2 useful this example will be in discussing the 3 adequacy of CHECWORKS because it's not a CHECWORKS 4 modeled component because it's a small bore 5 component.
6 JUDGE WARDWELL: I'm not sure where we 7 started this discussion earlier. It's just part of 8 FAC overall or whether it was CHECWORKS. But we'll 9 take that. Thank you.
10 JUDGE McDADE: And part of this, Dr.
11 Hopenfeld, we don't mean to cut you off. We're 12 going to break for lunch in about a half an hour or 13 a little bit less and during that period of time if 14 there's another example. And I realize that it's 15 difficult for you as well as for us. There are 1400 16 exhibits in evidence here. To go to a specific 17 exhibit at a moment's notice. But if there is 18 another exhibit that you want to refer us to to help 19 explain your position we can do that after lunch.
20 You don't need to do that right now.
21 DR. HOPENFELD: Can I just make a 22 comment in regards to this exhibit? It doesn't 23 matter whether it's modeled or not modeled FAC.
24 That wasn't my point here at all.
25 My point here on this particular one is Neal R. Gross & Co., Inc.
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Page 1586 1 that the ratio -- Whether it's modeled or not, it 2 doesn't really matter. The ratio indicates that 3 this is not a mass transfer-controlled phenomenon 4 and that's what that F1 relies on. That is my 5 issue. Whether they modeled it or not has nothing 6 to do with that.
7 JUDGE McDADE: You said mass transfer.
8 DR. HOPENFELD: Mass transfer, correct.
9 Mass transfer-controlled phenomenon is something 10 that is directly related to the corrosion rate to 11 what you see in the wall thinning. If it's a 12 diffusional type of a control the oxide layer is 13 there. It's a slow process. It's a mass transfer 14 control. We know how to calculate it. I have no 15 problem with that.
16 JUDGE KENNEDY: Now you've --
17 DR. HOPENFELD: But I'm trying to tell 18 you is that this component, the other component, 19 other components, all show that it is not and that's 20 the only point. Whether they modeled it or not 21 modeled it has nothing to do with my point.
22 JUDGE McDADE: Thank you.
23 JUDGE KENNEDY: Now you've got me 24 confused. I was tracking you pretty good. As soon 25 as you bring up the F factors, are we not talking Neal R. Gross & Co., Inc.
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Page 1587 1 about the modeling in CHECWORKS?
2 DR. HOPENFELD: Yes.
3 JUDGE KENNEDY: And didn't Mr. Aleksick 4 just say they don't use CHECWORKS to predict the 5 wear rate for this component?
6 DR. HOPENFELD: Yes. And all I'm saying 7 --
8 JUDGE KENNEDY: What's the issue?
9 DR. HOPENFELD: -- independent of my 10 point, forgetting about CHECWORKS or anything else.
11 This shows that the process is not controlled, 12 whether they control it or not, because the diameter 13 is small that maybe they can't fit it in. But it 14 doesn't matter.
15 My point here is that the process itself 16 or the whole concept that CHECWORKS is built on is 17 not necessarily mass transfer-controlled under 18 complex geometries. That's my point. Whether they 19 use this particular component in the line or not is 20 not really my point.
21 JUDGE KENNEDY: Is the concern that 22 Entergy would not select an inspection location in 23 sufficient time to prevent loss of intended 24 function?
25 DR. HOPENFELD: That's the bottom line.
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Page 1588 1 JUDGE KENNEDY: So I guess, Mr.
2 Aleksick, you've now termed this particular set of 3 components as a non-modeled line. Help us 4 understand how the inspection location would be 5 selected for these types of locations if that's the 6 right way to phrase it. Do you understand Dr.
7 Hopenfeld's concern about the wear rate and whether 8 you're going to be able to inspect it in sufficient 9 time?
10 MR. ALEKSICK: I understand the big 11 picture concern. I confess I don't follow the 12 entire argument.
13 JUDGE KENNEDY: I'm struggling a little 14 bit, too. And I viewed it as a CHECWORKS argument 15 and then we would address it down that path. But 16 it's clear that this is not in that arena.
17 Maybe you could help us understand a 18 little bit how locations are selected for inspection 19 in the non-modeled regions. And I think we've 20 addressed this a little earlier. And I was just 21 going to bring up the inspection location selection 22 discussion. So if we'd rather do it then, then 23 we'll start down that path.
24 MR. ALEKSICK: Perhaps I could give a 25 brief answer and if Your Honor would like to go Neal R. Gross & Co., Inc.
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Page 1589 1 deeper now or later we can do that. First, I would 2 just like to point out that the title of this slide 3 is -- the first word of this title is "CHECWORKS."
4 So that's the basis for my belief that this figure 5 relates to the adequacy of CHECWORKS.
6 With respect to the method used to 7 select susceptible non-modeled components, again 8 these are susceptible to FAC but not modeled within 9 CHECWORKS.
10 We have the SNM ranking analysis which 11 essentially provides a ranking from most concerned 12 to lowest concerned. And as part of the every cycle 13 selection process for identifying the FAC 14 inspections, that document is reviewed using 15 guidance originally from NSAC-202L as implemented 16 through EN-DC-315 to select a representative set of 17 components from that ranking.
18 And if we wanted to get into more 19 detail, I suggest that perhaps another member of the 20 panel could give you more information on that.
21 JUDGE KENNEDY: And I think a couple 22 questions came to mind as you said that. In terms 23 of this non-modeled ranking process, how long has 24 that been in place at Indian Point? How long has 25 this process or selection technique been used?
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Page 1590 1 MR. ALEKSICK: I guess it's fair to say 2 that the idea of selecting non-modeled components 3 for inspection has been around for a long time. But 4 it became more formalized I think it was in 2005 or 5 so, give or take a year, when these ranking analyses 6 were first prepared in a very formalized and 7 detailed manner. I might point out for the record 8 that the criteria and guidance on preparing those 9 non-modeled rankings is contained in Appendix A of 10 NSAC-202L.
11 JUDGE KENNEDY: And I guess the other 12 question that came to mind is were there any 13 failures in the non-modeled piping that occurred say 14 since the inception of this ranking process.
15 MR. ALEKSICK: I think a different 16 member of the panel would be better equipped to 17 answer that question.
18 JUDGE KENNEDY: And that's fine.
19 MR. AZEVEDO: Your Honor, this is Nelson 20 Azevedo. Are you talking about Indian Point or?
21 JUDGE KENNEDY: I'm sorry. I'm talking 22 about Indian Point specifically.
23 MR. AZEVEDO: We have not had any 24 failures. We've had leaks as has been mentioned 25 before but not --
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Page 1591 1 JUDGE KENNEDY: You had what? I'm 2 sorry.
3 MR. AZEVEDO: We had leaks, but not 4 structural failures. Not failures of the pipe.
5 JUDGE KENNEDY: And again this 6 distinction is whether you have lost the intended 7 function. Is that it?
8 MR. AZEVEDO: Yes, that's correct.
9 JUDGE KENNEDY: I guess before I got off 10 on this tangent I wanted to come back to Dr.
11 Hopenfeld's rebuttal testimony and this is going to 12 take us back to CHECWORKS. I noted in your 13 testimony that you had indicated that you believed 14 that CHECWORKS was the primary tool for selection of 15 inspection locations. And (a) I would like to 16 confirm that and (b) get a little bit of your 17 perspective on why you feel that way.
18 DR. HOPENFELD: Well, because they 19 testified that 25 percent of the time or 15 percent 20 of the time they use it to select locations. That's 21 what they said.
22 JUDGE KENNEDY: Did you say 25 percent 23 or 15 percent?
24 DR. HOPENFELD: Well, there is a 25 or 25 22-25 number in those figures. But then they split Neal R. Gross & Co., Inc.
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Page 1592 1 it and they say half of it is for frequency and half 2 of it is for identified location. And I really 3 couldn't make it out what is what. But I assume 4 that 22 percent that's all they use CHECWORKS in 5 there.
6 If I may just digest for a second if 7 it's okay with you because just before I forget 8 about that it's about that non-modeling comment 9 that we just talked a minute ago. Can I make a 10 comment on that?
11 JUDGE KENNEDY: If you're going to be 12 quick.
13 DR. HOPENFELD: Very quick. You see my 14 point here that no matter what it is that and I kept 15 repeating it that if it's a mass transfer-control 16 you can figure out whether it's a linear time or 17 what happened or whatever. But it's not mass 18 transfer-controlled if it's not a dissolution type.
19 But if it's an erosion type all bets are off because 20 you don't know how long it's going to be.
21 And whether it's model or non-model you 22 cannot tell by trending alone which is how they do 23 it. You cannot tell whether it's linear or non-24 linear and what's going to happen to it. That is my 25 point. Locally. That was my point.
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Page 1593 1 JUDGE KENNEDY: I don't know. Maybe you 2 should comment on Mr. Azevedo's statement that at 3 least since 2005 they used an inspection process 4 selection that has not resulted in a loss of any 5 intended function.
6 DR. HOPENFELD: Yes. Can I make a 7 comment on that? The code doesn't say whether you 8 have to wait until that thing blows up or leaks or 9 whatever. The code says you meet those requirements 10 to prevent that thing from happening.
11 JUDGE KENNEDY: Wait. Whoa. Let's go -
12 - We're in licensing renewal.
13 DR. HOPENFELD: Sorry.
14 JUDGE KENNEDY: This is a license 15 renewal issue. And the issue as I understand it 16 would be loss of intended function which they have 17 testified that since at least 2005 there have been 18 no incidents where the intended function has been 19 lost in this non-modeled piping.
20 DR. HOPENFELD: How would you know?
21 You've got thousands of components. How do you know 22 what the thickness is of those non-modeled? You 23 don't know. You didn't sample it.
24 JUDGE KENNEDY: I'll let Mr. --
25 DR. HOPENFELD: That's a statement Neal R. Gross & Co., Inc.
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Page 1594 1 that's not backed up.
2 JUDGE KENNEDY: I think and I'm going to 3 let Mr. Azevedo clarify this, as I understood it, 4 this is based on operating experience of leaks at 5 Indian Point that were detected, didn't result in a 6 loss of intended function. Is that what you're 7 saying?
8 MR. AZEVEDO: Yes, Your Honor. Is there 9 a question in there? I couldn't --
10 JUDGE KENNEDY: I guess to confirm that.
11 That's the way I understood your testimony.
12 MR. AZEVEDO: Yes, that's correct.
13 JUDGE McDADE: Excuse me one second.
14 Dr. Hopenfeld, just again to make sure I understand 15 your testimony. The particular exhibit we've been 16 looking at --
17 DR. HOPENFELD: This one.
18 JUDGE McDADE: -- is a non-modeled 19 structure.
20 DR. HOPENFELD: Correct.
21 JUDGE McDADE: And we've heard testimony 22 that it's a non-modeled structure because of the 23 diameter of the pipe. It doesn't fit within their 24 modeling criteria.
25 Your use of it as an example is because Neal R. Gross & Co., Inc.
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Page 1595 1 you view the phenomenon of flow-accelerated 2 corrosion would operate the same regardless of the 3 diameter of the pipe. So therefore -- More or less.
4 So therefore this is a good example that you're 5 saying it is not just corrosion. It is corrosion 6 plus erosion and that you think that this 7 demonstrates that the view of Entergy that it's 8 either or is not supported by the evidence in the 9 field. This is evidence that you can have both at 10 the same time because as you view this exhibit it 11 demonstrates the existence of both at the same time.
12 And then you would interpret that if it exists here 13 it would exist in the other system.
14 DR. HOPENFELD: Yes.
15 JUDGE McDADE: Is that an accurate 16 summary of your testimony?
17 DR. HOPENFELD: Your Honor, I would like 18 to say there's a defect in my education. I couldn't 19 say it better.
20 JUDGE McDADE: It's not a question 21 whether you could say it better.
22 DR. HOPENFELD: I just say yes. The 23 answer is yes.
24 JUDGE McDADE: Okay. I just want to 25 make sure I understand what your testimony is.
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Page 1596 1 DR. HOPENFELD: You perfectly understand 2 it.
3 JUDGE WARDWELL: To fix a point we just 4 got off of a little bit, I'd like to back up just a 5 bit to get back to it and that is the statement that 6 -- Well, it's on page 10 of your rebuttal testimony.
7 So I can be specific because I would like to explore 8 that just a little bit more while we're there. If 9 we could pull up that and it's Riverkeeper 000108, 10 page 10.
11 While that's being pulled up, I'll 12 mention -- let me know when it's up. Okay. If you 13 notice at the bottom of the first full paragraph, 14 the second paragraph there and the sentence there, 15 the very last sentence it says "It appears that the 16 total CHECWORKS contribution to the FAC Program is 17 about 25 percent with less than half of that amount 18 being attributed to actual wear predictions and 19 inspection schedules with the balance providing 20 relative ranking." That's your testimony.
21 So when we take half of that 25 percent, 22 that brings us down to about 12.5 percent are really 23 associated with any wear prediction or inspection 24 schedules. We'll talk about this statement a little 25 bit more later on today.
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Page 1597 1 But you also make a statement several 2 times in your testimony that it's non-conservative 3 50 percent of the time. That means it's 4 conservative the other 50 percent of the time.
5 DR. HOPENFELD: Yes.
6 JUDGE WARDWELL: So if we take 50 7 percent of that 12.5 percent, that's 6.25 percent of 8 what's left over.
9 DR. HOPENFELD: Yes.
10 JUDGE WARDWELL: And so are you saying 11 therefore that the 6.25 percent of the aging 12 management effort will be attributed to the non-13 conservative estimates of CHECWORKS is a significant 14 parameter?
15 DR. HOPENFELD: The reason I brought it 16 up is because we were focusing on CHECWORKS where 17 it's really a small part of the whole program 18 instead of focusing on other parts.
19 JUDGE WARDWELL: Right. And you 20 conclude that the 6.25 percent is a significant 21 percent of Entergy's program.
22 DR. HOPENFELD: Assume with respect to 23 CHECWORKS, yes. Well, not only that. The 24 Regulation 1801 said no very clearly, the last 25 revision. You cannot be non-conservative. It has Neal R. Gross & Co., Inc.
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Page 1598 1 to be conservative.
2 JUDGE WARDWELL: Please let's not 3 convolute things. If we keep them a single issue 4 items, we may get through some of this before the 5 end of next week.
6 DR. HOPENFELD: Okay.
7 JUDGE WARDWELL: Maybe not though.
8 DR. HOPENFELD: All right. I apologize.
9 JUDGE WARDWELL: No, it's too easy. We 10 do it up here. So it's not just you. We do the 11 same thing.
12 DR. HOPENFELD: I'm glad you said that.
13 JUDGE WARDWELL: Somehow we're going to 14 have to get our arms around getting through some of 15 this. You then go on to say in the next line down 16 that -- Go a little bit further down, Andy. Scroll 17 to the very bottom.
18 And I'm starting with the second line, a 19 couple of things in it. It says, "The relative 20 guidelines in GALL and NSAC clearly emphasize that 21 the use of quantitative predictions of a computer 22 code such as CHECWORKS is a main tool to predict 23 wall thinning." And my question to you is where do 24 you believe that those documents say they clearly 25 emphasize that CHECWORKS is the main tool to manage Neal R. Gross & Co., Inc.
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Page 1599 1 flow-accelerated corrosion.
2 DR. HOPENFELD: One, if you go to 1801, 3 it mentions check points in different places, I 4 guess, acceptance criteria, a trending and -- So you 5 get the flavor that that's what's being used.
6 JUDGE WARDWELL: Does it mention any 7 other tools in that document?
8 DR. HOPENFELD: Yes, it did mention 9 other tools. There is no --
10 JUDGE WARDWELL: So it doesn't clearly 11 emphasize that CHECWORKS is a main tool, does it?
12 DR. HOPENFELD: Right. Then you read 13 through --
14 JUDGE WARDWELL: Wait. Did you say yes?
15 Right?
16 DR. HOPENFELD: Yes.
17 JUDGE WARDWELL: You are agreeing?
18 DR. HOPENFELD: Agreed. They did 19 mention other tools.
20 JUDGE WARDWELL: But I then said and I 21 don't think you heard so those documents don't 22 clearly emphasize that CHECWORKS is the main tool.
23 DR. HOPENFELD: Yes, yes.
24 JUDGE WARDWELL: You agree with that 25 statement.
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Page 1600 1 DR. HOPENFELD: Yes, yes.
2 JUDGE WARDWELL: Okay. Thank you.
3 DR. HOPENFELD: Those documents. But 4 the others --
5 JUDGE WARDWELL: Go ahead then.
6 DR. HOPENFELD: There are the 202.
7 JUDGE WARDWELL: Yes.
8 DR. HOPENFELD: If you read it in 9 context, okay, it doesn't say 50 percent here, 10 10 percent here, 30 percent here. In the context, it 11 says that the flavor of it is that you rely on 12 CHECWORKS as a predictive tool. The grid, 13 everything around it.
14 If you read the LRA, they --
15 JUDGE WARDWELL: We're focusing right on 16 this statement here in your testimony.
17 DR. HOPENFELD: Okay. That's what I'm -
18 -
19 JUDGE WARDWELL: GALL and NSAC. So are 20 you saying now that it's better to use the word it 21 has the "flavor" that CHECWORKS is the main tool 22 rather than "clearly emphasized"? This is a pretty 23 strong statement is why I'm saying this.
24 DR. HOPENFELD: Yes, CHECWORKS --
25 JUDGE WARDWELL: It says "clearly Neal R. Gross & Co., Inc.
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Page 1601 1 emphasized."
2 DR. HOPENFELD: There was no clear 3 definition in NUREG-1801 that says CHECWORKS is the 4 main tool. There is none in 202.
5 JUDGE WARDWELL: But there's a flavor of 6 that.
7 DR. HOPENFELD: That's what I concluded 8 from it.
9 JUDGE WARDWELL: Okay. Thank you.
10 JUDGE KENNEDY: I guess at this point 11 the path I was going to go down is to call up an 12 Entergy exhibit about how they select inspection 13 locations. And, Andy, I'm thinking of Entergy 14 000029, page 53 and 54. Try PDF page 53. Right.
15 That's it, Andy.
16 JUDGE WARDWELL: Judge Kennedy, could 17 you repeat what this document is?
18 JUDGE KENNEDY: This is Entergy 000029.
19 JUDGE WARDWELL: Okay.
20 JUDGE KENNEDY: And it's Figure 1 which 21 is on PDF page 53.
22 JUDGE WARDWELL: So this is the direct 23 testimony. Is that correct?
24 JUDGE KENNEDY: This is the direct 25 testimony. And I guess I would ask that someone Neal R. Gross & Co., Inc.
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Page 1602 1 from the Entergy side could walk us through this 2 graphic and what it's import is.
3 MR. ALEKSICK: This is Rob Aleksick for 4 the Applicant. I would be happy to do that, Your 5 Honor.
6 JUDGE KENNEDY: And I am struggling a 7 little bit with the colors. That's why I wanted to 8 go through this. The blues I'm not sure I got --
9 And maybe I'm evidencing some color blindness.
10 MR. ALEKSICK: I agree that it's 11 difficult to distinguish. There's a light blue and 12 a slightly lighter blue.
13 JUDGE KENNEDY: Yes. I guess if you 14 could somehow point this when we discuss CHECWORKS 15 which component here is CHECWORKS.
16 JUDGE WARDWELL: And can I just clarify 17 so we can answer it for me at least? If we start 18 from the left on the bottom code it says CHECWORKS.
19 That's also the lowest thing on the charts. Is that 20 correct? On each bar?
21 MR. ALEKSICK: That is correct, Your 22 Honor.
23 JUDGE WARDWELL: And we go to the right 24 it goes up the bar. Is that correct?
25 MR. ALEKSICK: That is correct.
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Page 1603 1 JUDGE KENNEDY: That will work for me 2 then. Thank you.
3 MR. ALEKSICK: Sure.
4 JUDGE KENNEDY: And then maybe from that 5 point let's talk about this figure.
6 MR. ALEKSICK: Certainly. This figure 7 represents for Unit 2 the last five outages and for 8 each one of those five outages we had a set of 9 inspections approximately 100 components per outage, 10 although sometimes it may be more and sometimes it 11 may be slightly less.
12 The bottom, the darker blue, of each of 13 those bars, each of the five bars, represents the 14 number of new CHECWORKS components. That is 15 components in the plant modeled in CHECWORKS that 16 have not been inspected before. And you ca see that 17 it varies, but it's generally between one-quarter 18 and one-third of the total.
19 JUDGE WARDWELL: And refresh my memory.
20 Why would have CHECWORKS come up with these as being 21 critical to be inspected again?
22 MR. ALEKSICK: I don't know that I would 23 call them necessarily critical to be inspected.
24 JUDGE WARDWELL: Okay.
25 MR. ALEKSICK: Not in the sense of an Neal R. Gross & Co., Inc.
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Page 1604 1 imminent pipe wall failure. But we selected --
2 JUDGE WARDWELL: Points of interest.
3 MR. ALEKSICK: Points of interest, I 4 agree with that characterization. We select 5 components from CHECWORKS primarily for two 6 purposes. One is if we believe that there may be 7 degradation present in that component. If there is 8 actually flow-accelerated corrosion going on, those 9 would be from analysis lines in CHECWORKS that are 10 well-calibrated typically.
11 Another reason that we might select a 12 component to inspect from CHECWORKS is to improve 13 the calibration. One of the guidelines from NSAC-14 202L and from the CHECWORKS users guide and various 15 other documents there's guidance out there that 16 discusses the criteria one must meet in order to 17 calibrate a CHECWORKS line. And one of those 18 criteria is to have a minimum number of inspections, 19 three, four, five, six, ten, depending on the 20 circumstances.
21 Another criterion is we need to have a 22 variety of geometry types. So if we have 100 23 component analysis line but we've only inspected 24 elbows, even if we've inspected all of the elbows, 25 we would not consider that line calibrated until we Neal R. Gross & Co., Inc.
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Page 1605 1 also looked at other geometries.
2 Does that answer Your Honor's question?
3 JUDGE WARDWELL: That was very good.
4 Thank you.
5 MR. ALEKSICK: The second bar, these are 6 stacked bars. So the bottom section represents the 7 new CHECWORKS inspections. The red section of the 8 bar represents operating experience. And so Indian 9 Point has a formal process of collecting operating 10 experience from a large variety of sources including 11 NRC information notices and other regulatory 12 documents, INPO documents, participation in the CHUG 13 users group and on and on.
14 And there is a formal process by which 15 that information is collected, reviewed, 16 dispositioned. And the disposition may include a 17 decision to not inspect if there's no good reason to 18 do so. Or often it will include the disposition 19 will be "Oh, we should inspect this" regardless of 20 anything else. Someone else had a problem in this 21 area. So we're going to look at it. And that's 22 what the red bar constitutes here.
23 The next bar above that is the green 24 one. That is the set of components that have been 25 previously inspected. It may have been inspected Neal R. Gross & Co., Inc.
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Page 1606 1 two years ago and it may have been inspected 25 2 years ago. Well, 20 years ago.
3 And at the time of the last inspection, 4 an evaluation was done. And one of the inputs of 5 that evaluation was the re-inspection frequency.
6 And Your Honors can see that that's generally about 7 half of the inspection scope.
8 JUDGE WARDWELL: And all of those were 9 generated, all those locations were generated, 10 because that calculation said it needed to be re-11 inspected at this time.
12 MR. ALEKSICK: Yes, Your Honor.
13 JUDGE WARDWELL: Thank you.
14 MR. ALEKSICK: Every single inspection 15 goes through that evaluation process regardless of 16 whether it's CHECWORKS or not.
17 The purple bar second from the top are 18 the susceptible non-modeled components. Often small 19 bore. Not always small bore. And those you can see 20 constitute between 15 and 25 percent on average.
21 Sometimes a little bit less.
22 And then the last bar, the --
23 JUDGE WARDWELL: Sorry to interrupt.
24 No, I'm not. Let me interrupt. Does that mean 25 there are no non-modeled ones in the re-inspections?
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Page 1607 1 That doesn't include ones that might be in the re-2 inspections. Is that correct?
3 MR. ALEKSICK: That is correct. The re-4 inspection category includes susceptible non-modeled 5 as well as everything else.
6 JUDGE WARDWELL: And engineering 7 judgment, operating experience, CHECWORKS things.
8 MR. ALEKSICK: Yes. In other words --
9 JUDGE WARDWELL: No, not CHECWORKS 10 things. No CHECWORKS things.
11 MR. ALEKSICK: Yes, that's right. Well, 12 let me back up. Once a component has been 13 inspected, regardless of the original reason for the 14 inspection, it could have been CHECWORKS or anything 15 else. Then it's outside of those silos and -- I see 16 your point. I understand.
17 JUDGE McDADE: So the purple is new, 18 non-modeled components.
19 MR. ALEKSICK: Yes, Your Honor.
20 Exactly.
21 JUDGE McDADE: And the one at the 22 bottom, the blue, is the new CHECWORKS identified.
23 MR. ALEKSICK: Yes, Your Honor.
24 JUDGE McDADE: And in between the green 25 are re-inspections both that had originally occurred Neal R. Gross & Co., Inc.
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Page 1608 1 as the result of CHECWORKS and those that had 2 occurred in non-modeled components.
3 MR. ALEKSICK: Exactly, Your Honor.
4 JUDGE McDADE: Okay. And then the 5 operating experience could be either modeled or 6 unmodeled.
7 JUDGE WARDWELL: Yeah, but will be new.
8 MR. ALEKSICK: Right. Occasionally, a 9 component may be in multiple categories.
10 JUDGE McDADE: But in any event those 11 are new inspections. The operating experience are 12 new inspections but they could be either modeled or 13 non-modeled.
14 MR. ALEKSICK: That is correct. And the 15 top bar is the engineering judgment bar. And those 16 are components that may be added to the scope for 17 reasons other than what we've already outlined. So 18 the FAC Program owner has the discretion to expand 19 his scope of its inspections based on judgment.
20 Does that answer the question, Your 21 Honor?
22 JUDGE KENNEDY: It does. Thank you.
23 I guess, Dr. Hopenfeld, in the context 24 of the primary tool being CHECWORKS and this 25 inspection location percentage, do you have any Neal R. Gross & Co., Inc.
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Page 1609 1 particular comments you'd like to address to the 2 Board?
3 DR. HOPENFELD: I do not. Evidently, 4 CHECWORKS is used -- It's not the primary tool for 5 inspection.
6 JUDGE KENNEDY: Okay. Thank you.
7 JUDGE McDADE: Actually, Mr. Aleksick, 8 I've got a question and approximately half as you go 9 through it are these previously inspected 10 components. And they can be identified either 11 through CHECWORKS or through prior operating 12 experience or prior engineering judgment or could be 13 non-modeled. Is there any way of estimating what 14 percentage of those were initially identified for 15 inspection through CHECWORKS?
16 MR. ALEKSICK: Yes, Your Honor. There 17 are two ways. One is I could give you a rough 18 estimate right now if you'd like. The other if the 19 Court would like a more precise answer, each one of 20 these components has a very detailed, traceable 21 history and we can go back and answer that question 22 very precisely if you'd like.
23 JUDGE McDADE: Based on your experience, 24 can you give us an approximate percentage?
25 MR. ALEKSICK: Roughly half.
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Page 1610 1 JUDGE WARDWELL: Half of the half.
2 MR. ALEKSICK: Yes, exactly. Maybe as a 3 point of clarification, if one goes earlier in the 4 plant inspection history, that percentage would be 5 larger.
6 JUDGE WARDWELL: But the reason it's in 7 there isn't because of CHECWORKS. The reason it's 8 being re-inspected isn't necessarily because it's a 9 CHECWORKS-derived initial inspection point.
10 MR. ALEKSICK: Yes, Your Honor. The re-11 inspection time is independent of CHECWORKS or 12 anything else and relies only on the wear evaluation 13 that we discussed earlier.
14 JUDGE WARDWELL: So is there any 15 significance that you can think of in regards to the 16 breakdown of those different initial origins of how 17 a location was selected falling into the re-18 inspected category? Did I convolute that question 19 as I tried to word it?
20 MR. ALEKSICK: I think I understand what 21 Your Honor is asking and I would say that there's 22 nothing magical about the breakdown. What we do is 23 we use a variety of techniques in a combined and 24 complementary manner that in accordance with NSAC-25 202L and GALL that gives the best coverage, the best Neal R. Gross & Co., Inc.
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Page 1611 1 inspection coverage, of all of the systems. We use 2 the right tool within the program for the right job 3 to provide reasonable assurance.
4 JUDGE KENNEDY: As far as the re-5 inspection, did I understand you to say the wear 6 rate is based on measured data and it's not a 7 predicted value?
8 MR. ALEKSICK: Yes, Your Honor. That's 9 correct.
10 JUDGE KENNEDY: And does it assume a 11 linear over time relationship? I mean, going 12 forward, is it linear, the wear rate?
13 MR. ALEKSICK: That is true in general.
14 Yes, Your Honor.
15 JUDGE KENNEDY: Generally?
16 MR. ALEKSICK: It may not be true in the 17 case where we know there was a change in operating 18 conditions.
19 JUDGE KENNEDY: I see.
20 (Off the record comment.)
21 JUDGE KENNEDY: Probably is. May I ask 22 one more question before we break? No, I'd probably 23 not. It will probably open a can of worms. We can 24 save it for later.
25 JUDGE McDADE: It's now about 12:15 p.m.
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Page 1612 1 It may be a good time to break for lunch until 1:15 2 p.m.
3 MS. SUTTON: Your Honor, Kathryn Sutton 4 for the Applicant. I realize this may be difficult 5 to predict. Any guesstimate, estimate, on the SAMA 6 panel members? We have them here today. Should we 7 be retaining them here? Do you think we will begin 8 with SAMAs today?
9 JUDGE McDADE: We will give you an 10 answer right after lunch.
11 MS. SUTTON: Thank you.
12 JUDGE McDADE: Based on the time that 13 it's taken so far I have sort of a gut reaction.
14 But I'd like to talk to my colleagues about it and 15 we'll let you know right after the lunch break on 16 that.
17 MS. SUTTON: Much appreciated, Your 18 Honor.
19 JUDGE McDADE: Anything else before we 20 take the lunch break?
21 MR. SIPOS: Your Honor, this is John 22 Sipos. You asked at the outset of this morning's 23 proceedings about the State's positions on NRC 24 Exhibits 000165 and 000166. We've had a brief 25 opportunity to review them. And at this time, the Neal R. Gross & Co., Inc.
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Page 1613 1 State does not object to NRC offering and 2 introducing those exhibits.
3 I would suggest that the description 4 reflect that they are actually excerpts of larger 5 documents.
6 JUDGE McDADE: Okay. And there being no 7 other objections to the admission of NRC Staff 8 Exhibits 000165 and 000166.
9 MS. SUTTON: No objection, Your Honor.
10 JUDGE McDADE: That they will be 11 admitted then.
12 (Whereupon, the above-referred 13 to documents marked for 14 identification as NRC Staff 15 Exhibits 000165 and 000166 16 were received into evidence.)
17 And we will also then admit the revised 18 exhibit list of the staff with the notation that 19 these are not the entire documents, but are excerpts 20 from the documents, both 000165 and 000166.
21 (Whereupon, the above-referred 22 to document revised and marked 23 for identification as NRC 24 Staff Exhibit 000001 was 25 received into evidence.)
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Page 1614 1 And with that we will break for lunch 2 and we will be back. It's now about 12:20 p.m. So 3 why don't we come back at 1:20 p.m. from lunch. We 4 are in recess. Off the record.
5 (Whereupon, the above-entitled matter 6 was recessed at 12:18 p.m. to return at 1:20 p.m.
7 the same day.)
8 JUDGE McDADE: The hearing will come to 9 order. There are a couple of preliminaries before 10 we get started on it. The first has to do with the 11 proposed settlement agreement with regard to 12 Riverkeeper Environmental Contention 3.
13 The Board will approve the settlement 14 agreement, with the addition of the paragraph that 15 we discussed earlier today, that Entergy and the 16 parties agreed to with regard to subject matter 17 jurisdiction.
18 We will get a written order out on that 19 later in the week. But for the purposes of the 20 parties, they can anticipate that we will not be 21 hearing Riverkeeper Exhibit, Environmental 22 Contention 3, that that is no longer on the 23 schedule.
24 The next question had to do with our 25 current schedule, and to advise witnesses. We can Neal R. Gross & Co., Inc.
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Page 1615 1 anticipate that Riverkeeper Technical Contention 2 2 will take us at least the remainder of the day. So 3 therefore, if there are witnesses here with regard 4 to New York Contention 12, those witnesses can be 5 released for today.
6 We are hopeful that we will be able to 7 start with them first thing in the morning, hopeful 8 but not necessarily over-confident. In any event, 9 we believe that we will not get beyond New York 10 Contention 12 tomorrow.
11 So therefore, those witnesses who would 12 begin testifying on New York Contention 16 need not 13 be here tomorrow. They can be here on Thursday 14 morning, because we're confident that we won't get 15 beyond New York State 12 tomorrow.
16 MS. DEAN: Your Honor, Janice Dean from 17 the State. Mine doesn't have a light. I just want 18 to let you know and let the parties know that 19 momentarily they will be seeing my motion to correct 20 the testimony on Contention 5 come across the EIE.
21 It's nothing more than a clarifying motion to strike 22 our earlier exhibit and file a corrected exhibit.
23 JUDGE McDADE: Okay. Thank you, Ms.
24 Dean.
25 MS. DEAN: You're welcome, thank you.
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Page 1616 1 MR. TURK: Your Honor, one more question 2 about the schedule, if I may. Sherwin Turk.
3 JUDGE McDADE: Yes.
4 MR. TURK: We have witnesses who will be 5 flying in from Washington on buried piping, New York 6 5, which comes up after New York 17 and 37, property 7 values and no action alternative. Is it safe to 8 assume that we won't reach buried piping this week, 9 and I can tell them to come next week?
10 JUDGE McDADE: I think that is a more 11 than safe assumption. If we get through New York 12 12 tomorrow, New York 16, 17 and 37, I don't think any 13 of those three are going to take the amount of time 14 that we have spent on Riverkeeper Technical 15 Contention 2.
16 But at the same time, I think between, 17 among those three, 16, 17 and 37, if we get started 18 on those on Thursday morning, if we get done with 19 all three of them. It will certainly be late in the 20 day, and therefore given the fact that it will be a 21 travel over the weekend and coming back, I think it 22 would be advisable to tell the individuals who will 23 testify on New York State 5 that they should be 24 available and ready to go nine o'clock Monday 25 morning.
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Page 1617 1 If the schedule changes, and I don't 2 think the schedule will appreciably speed up; but if 3 the schedule slows down any, we will advise you of 4 that as soon as possible.
5 MR. TURK: Thank you. I appreciate 6 that. Thank you, Your Honor.
7 JUDGE McDADE: Anything further?
8 (No response.)
9 JUDGE McDADE: Judge Kennedy.
10 JUDGE KENNEDY: This is Judge Kennedy.
11 I guess I'd like to start with an exhibit, and if we 12 could have Riverkeeper 111. All right, thank you.
13 Dr. Hopenfeld, this is an exhibit that you've 14 provided for Riverkeeper. There appears to be 15 Indian Point data here. Was this just extracted?
16 I mean I'm trying to avoid putting an 17 Entergy exhibit up here. I want to confirm that 18 this is Indian Point-specific data, which is what it 19 appears to be.
20 DR. HOPENFELD: Yes.
21 JUDGE KENNEDY: Is there any different 22 opinion from Entergy? Can you tell?
23 MR. ALEKSICK: This is Rob Aleksick for 24 the applicant. Yes, Your Honor, that looks -- this 25 is Indian Point-specific CHECWORKS output.
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Page 1618 1 JUDGE KENNEDY: All right. I would like 2 to spend some time going through this figure, and I 3 think it would be best to start with someone from 4 Entergy, to walk us through this, and talk about the 5 highlights of what is the plus 50 percent line, the 6 minus 50 percent line? What is a line correction 7 factor? How is it computed? How is it calculated?
8 If there's any outlier data on here that 9 we heard, that was described yesterday in the 10 testimony, maybe we could talk a little bit about 11 that. So maybe if someone from Entergy would like 12 to walk through this, and then we'll have a number 13 of additional questions about this figure.
14 MR. ALEKSICK: Certainly, Your Honor.
15 This is Rob Aleksick for the applicant. I'd be 16 happy to discuss that with you. If Your Honor would 17 give me just a moment to pull up the documentation.
18 JUDGE KENNEDY: That's fine.
19 (Pause.)
20 MR. ALEKSICK: Thank you for your 21 patience, Your Honor. The exhibit that we're 22 looking at is what we call a scatterplot, which is 23 one of the outputs that CHECWORKS provides for each 24 of the analysis lines.
25 JUDGE KENNEDY: Is this further Neal R. Gross & Co., Inc.
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Page 1619 1 representative of the -- I mean as I understand it, 2 there's a number of these plots all through the 3 exhibits. Is this a good example to walk through, 4 to be typical of a scatterplot?
5 MR. ALEKSICK: Well, this would be a 6 good example of a scatterplot that shows not 7 particularly good agreement between predictions and 8 observations. So if that is what you all would 9 like to walk through, then yes, this would be a good 10 example for that.
11 JUDGE KENNEDY: Part of the motivation 12 for selecting this is on the next page, I have Dr.
13 Hopenfeld's redo of this data. So we're going to 14 have an opportunity to go back and forth, using a 15 similar set of data. So if this at least typical, 16 you know.
17 This would explain to us what is 18 involved in the scatterplot, and what important 19 information is gleaned from it.
20 MR. ALEKSICK: I think this would be a 21 good exhibit of that discussion, yes Your Honor.
22 This is, as we mentioned earlier, there are 23 approximately 40, four-zero, analysis lines per 24 unit. This is one of those for Unit 2.
25 This happens to be for the third point Neal R. Gross & Co., Inc.
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Page 1620 1 extraction steam analysis line. So these are two 2 phase lines. A mixture of steam and water is being 3 transported through these pipes. The first thing I 4 would like to call your attention to is that the 5 graph is a plot of predicted wear on the vertical 6 axis, versus measured wear on the horizontal axis.
7 So for example, if we take the point, 8 the most upper left-hand point just for discussion, 9 that looks as though the predicted wear is on the 10 order of 220 mils, and the measured wear for that 11 component is on the order of 20 to 30 mils.
12 JUDGE WARDWELL: And just to highlight, 13 to make sure we're all on the same page also, that 14 the scales for the vertical and the horizontal are 15 different; is that correct? We're measuring the 16 same thing, i.e., mils, mils of wear. One's 17 predictive, one's measured. But it's still mils of 18 wear.
19 You chose not to keep the same scale, 20 but in fact changed the scale for the vertical and 21 the horizontal.
22 MR. ALEKSICK: It is correct, that the 23 vertical and horizontal scales are different 24 measurements. This is a stretchable graph in the 25 CHECWORKS output, and one can grab and size it and Neal R. Gross & Co., Inc.
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Page 1621 1 make it square or rectangular. This one happens to 2 be rectangular, yes.
3 But there's no particular reason to do 4 it that way. It's just, that's just the way it fit 5 on the page.
6 JUDGE WARDWELL: There would be some 7 reasons to keep them square in regards to visually 8 seeing something like the middle line. But let's 9 proceed.
10 MR. ALEKSICK: I agree. A square might 11 -- if we were making judgments visually, a square 12 would be preferable. However, we have quantitative 13 methods to assess the calibration status.
14 So we have vertical and horizontal axes 15 for the measured wear. Each point plotted 16 represents an inspection. So again, take the upper 17 left-hand corner as an example, that represents a 18 single component, probably one to two hundred actual 19 wall thickness measurements were taken on that 20 component.
21 The data from that grid was reduced to a 22 single representative value of measured wear, and 23 that was compared to the CHECWORKS predicted wear 24 for the component, and then the plot, I'm sorry, the 25 point was then plotted.
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Page 1622 1 JUDGE WARDWELL: And there's no 2 duplicates of measurements at that particular point; 3 is that correct?
4 MR. ALEKSICK: That is correct. Each 5 point on the graph represents a single component, 6 and in fact represents the most recent inspection of 7 that component. One other thing I would point out 8 is that the diamond-shaped points represent 9 components that are physically installed and 10 operational, as of the time of analysis.
11 The square-shaped points represent 12 components that were replaced at some point in the 13 past. So they were presumably, they were physically 14 replaced, presumably because they were degraded by 15 FAC, severely enough to require replacement.
16 JUDGE McDADE: I'm not sure that I 17 understand. The square, does that component, is it 18 removed at the time you're looking at? For example, 19 the one in the lower right. You have predicted wear 20 of about 75 mils, actual wear of 200 mils.
21 You're saying that at the time it was 22 tested and found to have 200 mils of wear, that 23 component was already out of the facility, or was it 24 taken out of the facility? Or was it taken out 25 because it had 200 mils of wear?
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Page 1623 1 MR. ALEKSICK: Presumably, it was taken 2 out because of that wear, and that may have been 10 3 or 15 years ago. The data on this plot goes back to 4 1992 or thereabouts.
5 JUDGE WARDWELL: So this is cumulative 6 wear up to this point?
7 MR. ALEKSICK: That is correct.
8 JUDGE WARDWELL: And do you carry forth 9 that wear once it's been replaced, and still keep it 10 to that component?
11 MR. ALEKSICK: Yes. Once a component is 12 physically removed from the system, its historical 13 data is retained, because that's good calibration 14 data. But of course there is a new physical 15 component in its place that is typically subject to 16 inspection, although it may have been replaced with 17 upgraded material that is immune to FAC and perhaps 18 not inspected there, because of that.
19 MR. COX: I'd like to -- this is Alan 20 Cox for Entergy. I'd like to clarify. When we say 21 "cumulative wear," I think Rob means cumulative up 22 to the point of when that measurement point was 23 taken? We may have points that were measured 10, 15 24 years ago. That was the wear at the point of the 25 measurement, the time of the measurement.
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Page 1624 1 MR. ALEKSICK: That is correct.
2 JUDGE WARDWELL: I'm sorry. I'm afraid 3 --
4 (Simultaneous speaking.)
5 JUDGE WARDWELL: --the way you clarified 6 it, you confused me.
7 JUDGE McDADE: The wear at the time of 8 the most recent measurement.
9 JUDGE WARDWELL: And the prediction is 10 what would be predicted at that time as well?
11 MR. ALEKSICK: At that time, yes. Yes, 12 Your Honor. The CHECWORKS model is a function of 13 time, and so some of these inspections might have 14 been from 1992, and the wear measured at that time 15 would be compared to the wear predicted at that time 16 and plotted.
17 JUDGE McDADE: And then for one of the 18 components that are marked with the squares, as 19 opposed to the diamonds, once that part were 20 removed, you would then start again with predicted 21 wear would be zero, actual wear would be zero, and 22 then you would track that the same way that you had 23 tracked that component before?
24 MR. ALEKSICK: Exactly, Your Honor.
25 JUDGE McDADE: And if it shows up in a Neal R. Gross & Co., Inc.
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Page 1625 1 chart like this later on, it would be the wear, 2 predicted wear from the time of replacement until 3 the time of testing?
4 MR. ALEKSICK: Yes Your Honor, exactly.
5 JUDGE WARDWELL: Oh really? I thought 6 you said the opposite.
7 JUDGE McDADE: Perhaps, well let's make 8 --
9 JUDGE WARDWELL: So how do you know on 10 these replaced components? Does a replaced 11 component, a square, then turn into a triangle?
12 MR. ALEKSICK: If the component is 13 replaced, that is represented as a square. If the 14 new component is subsequently inspected, then it 15 turns into a diamond, yes.
16 JUDGE WARDWELL: Okay. So that one 17 example that Judge McDade gave, that's fixed it.
18 That will not change in the next scatter chart 19 that's plotted. That will be there forever?
20 MR. ALEKSICK: That is correct.
21 However, if a diamond were subsequently inspected, 22 it could change.
23 JUDGE WARDWELL: Sure, oh yeah.
24 MR. ALEKSICK: The next thing I'd like 25 to call Your Honor's attention to is the 45 degree Neal R. Gross & Co., Inc.
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Page 1626 1 line through the 00 point up to the 300, 300 point.
2 JUDGE WARDWELL: Which is not 45 3 degrees.
4 MR. ALEKSICK: That is correct. We call 5 it that, but on this non-square graph, it is less 6 than 45 degrees. That line represents the ideal. If 7 CHECWORKS predicted, that prediction is agreed 8 precisely with field observations. All of the 9 points would be on that line.
10 JUDGE WARDWELL: And that's the middle 11 line?
12 MR. ALEKSICK: That is the middle line.
13 That's the best estimate line. It's drawn through 14 the scatter plot, right through the median value.
15 JUDGE WARDWELL: And it is not related 16 whatsoever to a line correction factor that's at the 17 end of that line. That just happens to be where 18 you've placed the value of the line correction 19 factor. Is that correct?
20 MR. ALEKSICK: Not exactly. The line 21 correction factor in this case is in the upper 22 right-hand corner, where it says "LCF equals 1.060."
23 That indicates that the median value is very close.
24 The component that is the median --
25 JUDGE WARDWELL: Don't start in on that Neal R. Gross & Co., Inc.
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Page 1627 1 just yet. My question was that 45 degree line is 2 not an LCF line or it's -- you just placed the LCF 3 equals 1.060 there. It's placed on that part of the 4 graph, because that's where it was placed. It is a 5 place there, because the 45 line happens to be close 6 to it?
7 MR. ALEKSICK: Yes, Your Honor. I'm 8 sorry.
9 (Simultaneous speaking.)
10 MR. ALEKSICK: That's just in all plots, 11 regardless of the details --
12 JUDGE WARDWELL: That's where that value 13 will reside when you're looking for it.
14 MR. ALEKSICK: Yes, exactly.
15 JUDGE WARDWELL: Now you can go on and 16 explain LCF if you want to. I didn't want to --
17 MR. ALEKSICK: Well if Your Honor would 18 like me to, I'd be happy to.
19 JUDGE WARDWELL: Well, at some point I 20 want to. I want you to, yes.
21 MR. ALEKSICK: Okay. Well, I think now 22 would be a good time then.
23 JUDGE WARDWELL: Go ahead then.
24 MR. ALEKSICK: Again, the LCF is the --
25 of the number of points here, I haven't counted Neal R. Gross & Co., Inc.
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Page 1628 1 them, but it looks, maybe there are 40 of them, 41.
2 There's an odd number of points.
3 If one takes the ratio for each of 4 those, let's pretend it's 41 points; the ratio of 5 the predicted, I'm sorry, the measured to predicted 6 values of wear, you'll end up with 41 ratios.
7 In the upper left-hand corner, the ratio 8 will be 30 mils of measured wear to 220 mils of 9 predicted wear. We create 41 ratios like that, and 10 the median value of those ratios is by definition 11 the line correction factor.
12 So another way to say that is the median 13 value, the median ratio was of a component that was 14 1.060, that value times the predicted wear equaled 15 the measured wear for that component. And you can 16 see that point.
17 We don't really have a facility for a 18 laser pointer, but if you look in the middle of that 19 pseudo 45-degree angle line, there is one point that 20 lies precisely in the middle of it, and it's right 21 about at 120, both predicted and measured.
22 And you see that that, the middle line 23 goes right through that middle point. So that 24 point, that one component of all the inspected 25 components of this line is the middle value, and is Neal R. Gross & Co., Inc.
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Page 1629 1 therefore the line correction factor, and therefore 2 all of the predictions of components for this line, 3 the past one predictions, are multiplied by that 4 value to obtain the past two predictions.
5 This graph, by the way, is produced by 6 CHECWORKS. There's no, this is a direct output from 7 CHECWORKS. So there's no manual calculation of the 8 LCF going on here.
9 JUDGE WARDWELL: What are the plus and 10 minus 50 lines, and what does 50 percent, plus or 11 minus 50 percent mean?
12 MR. ALEKSICK: Those lines are there, 13 not for a strict quantitative purpose, but more to 14 guide the I. They're also there to define outliers.
15 Any of the points that fall outside of those two 16 lines we call outliers, and pay more attention to 17 them and try to understand why they are there.
18 In this particular case, we don't have a 19 very tight cluster of data around that center line.
20 So we have, in the document that controls and 21 documents the CHECWORKS model, we have a detailed 22 write-up of this line, and that discusses the 23 outliers and draws a conclusion of whether the line 24 is calibrated or not calibrated, and what the basis 25 for that conclusion is.
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Page 1630 1 If Your Honors would like, I can point 2 you to that. It's in one of the Entergy exhibits.
3 We can bring that up, if you'd like.
4 JUDGE WARDWELL: Looking at this -- and 5 how is it drawn? Is that a 50 percent less slope 6 and a 50 percent more slope, or what does the plus 7 or minus 50 percent mean?
8 MR. ALEKSICK: It's -- the minus 50 9 percent line is 50 percent less of the ideal 45 10 degree, pseudo 45 degree line.
11 JUDGE WARDWELL: A less slope?
12 MR. ALEKSICK: Less --
13 JUDGE WARDWELL: Each value -- yeah, I 14 mean we can say 50 percent less slope; it's also 50 15 percent less value around a given vertical axis, I 16 guess, vertical line.
17 MR. ALEKSICK: Right. If we look at say 18 the 100, 100 coordinate, okay, a 45 degree line 19 passes right through that.
20 JUDGE WARDWELL: Yeah.
21 MR. ALEKSICK: The minus 50 percent line 22 passes through --
23 JUDGE WARDWELL: The 50.
24 MR. ALEKSICK: The 50/100ths. So it's 25 50 percent less. Now I'd like to point out that the Neal R. Gross & Co., Inc.
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Page 1631 1 upper bound, that is labeled "plus 50 percent," is 2 perhaps a slightly confusing label. It's really 100 3 percent.
4 JUDGE WARDWELL: It's very confusing.
5 MR. ALEKSICK: But those are the lines 6 that are there, to sort of indicate graphically and 7 visually that we desire a cluster around that 45 8 degree line.
9 JUDGE WARDWELL: But what is that plus 10 50 percent line? I mean it's just disappeared 11 there. It's 100 percent different. It's double.
12 MR. ALEKSICK: It is. It probably 13 should be labeled "plus 100 percent," and I can't 14 speak to that, Your Honor. I don't know why that is 15 the case.
16 MR. COX: This is Alan Cox. Could I add 17 one thing? I think that was realized that that was 18 perhaps the wrong, incorrect label, and the latest 19 versions of CHECWORKS have a graph that uses -- the 20 plus 50 percent line is running through the 100, 100 21 point. So it is actually a plus or minus 50 percent 22 of the measured wear.
23 JUDGE WARDWELL: Of what use are these 24 plus and minus 50's? Just to, I guess you said, I 25 guess I just should ask that. You just said to Neal R. Gross & Co., Inc.
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Page 1632 1 highlight outliers?
2 MR. ALEKSICK: Well frankly speaking, 3 they're not essential lines. They're not -- I don't 4 want to say they're useless. They help guide the 5 eye towards that line.
6 But as we disposition and evaluate the 7 results of this, we don't really use those lines.
8 They come out of the program and they're nice to 9 have, but they're not essential in our --
10 JUDGE WARDWELL: How do you identify 11 outliers, and what's the definition of an outlier, 12 mathematically or I don't mean in regards to oh gee, 13 it's something that's, you know, beyond the norm or 14 something. How do you -- what's the definition of 15 how you designate and deem a particular point to be 16 an outlier?
17 MR. ALEKSICK: It would be if the point 18 were outside that plus, the line labeled plus or 19 minus 50 percent.
20 JUDGE WARDWELL: So if you've changed 21 the line, then there's going to be more outliers 22 now. If you now truly bring that back down to what 23 a normal person might consider to be a plus 50, you 24 would have more outliers?
25 MR. ALEKSICK: That is true, Your Honor, Neal R. Gross & Co., Inc.
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Page 1633 1 yes.
2 JUDGE WARDWELL: And what do you do with 3 outliers when you see them? Do you automatically 4 throw them out of your database? Do you reinspect 5 them? Any activities? What excitement do you give 6 around these points?
7 MR. ALEKSICK: Well, we certainly don't 8 throw them out. With respect to reinspection, any 9 of this CHECWORKS business that we're discussing now 10 doesn't come into play in that decision.
11 The sole criterion for determining 12 whether a component and when a component is to be 13 reinspected is the set of wall thickness 14 measurements and the minimal allowable thickness.
15 The way that we do use the outliers is 16 in understanding the model. If there are for a 17 given analysis line, if there are a large number of 18 outliers, that's telling us something very 19 important.
20 It's telling us that the model is not 21 matching up well with the field, and that's why it's 22 very important, and why Entergy follows the guidance 23 in NSAC-202L, to review each one of these 24 scatterplots, and determine if it is well-calibrated 25 or not.
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Page 1634 1 A large number of outliers would 2 indicate generally, almost always, a poor 3 calibration, or a not good one.
4 JUDGE McDADE: The way this is set -- if 5 I could, just briefly. They way this is set up, if 6 you go, for example, to 100 on the horizontal line, 7 50 on the vertical line, you have a data point 8 there. That would indicate that that particular 9 component, there was twice as much wear as was 10 anticipated under CHECWORKS; correct?
11 MR. ALEKSICK: Yes, Your Honor.
12 JUDGE McDADE: Do you make any kind of 13 analysis to determine whether there was any 14 commonality among those components, where there is 15 more actual wear than predicted wear, so that you 16 will be able to then input that and change the 17 program, to be able to predict greater wear for 18 certain kinds of components, or under certain kinds 19 of conditions?
20 MR. ALEKSICK: Yes, Your Honor. We look 21 at the outliers, not just the outliers. We look at 22 all the points and seek to understand what is the 23 data telling us about the model, and the level of 24 confidence that we can place in the model for this 25 particular line.
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Page 1635 1 And quite often we will find a common or 2 generic reason. Chemistry is a global variable that 3 affects all of the components' wear rates, and that 4 might be sometimes a reason for the entire data set 5 to be higher or lower than anticipated.
6 But sometimes, the effects are more 7 specific to that particular component. So there 8 might have been a manufactured wall thickness 9 variations, for example, that were not indicative of 10 FAC wear, but are indicative of conditions in the 11 pipe when it left the factory.
12 Or there might be other variations in 13 the wall thickness that are not due to FAC, and that 14 therefore CHECWORKS would not predict, that might 15 explain. But there are many, many reasons that a 16 given point might be an outlier.
17 JUDGE McDADE: So what you're saying 18 there, for example, and I just want to make sure 19 I've got this correct, that particular data point, 20 50 on the vertical or 100 on the horizontal, if it 21 is generated by CHECWORKS, it means that's the first 22 inspection.
23 And you're telling me, I think, that the 24 reason there could be a narrowed wall there, is 25 because of a manufacturer defect, because this would Neal R. Gross & Co., Inc.
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Page 1636 1 have been the first time you would have inspected 2 it, and this would be the first time that you would 3 have become aware that the thickness is not what it 4 should be; is that correct?
5 MR. ALEKSICK: No, Your Honor. I 6 wouldn't put it quite that way. These aren't 7 necessarily the first time that we've inspected 8 something. In fact, these points are the last, most 9 recent time that we've inspected them.
10 If a given component were inspected five 11 times over the period from 1992 to today, only that 12 fifth most recent inspection would appear on this 13 graph.
14 JUDGE McDADE: Okay. So the chart that 15 we had immediately before the lunch break, which 16 indicated what kind of an inspection was going on, 17 whether it was CHECWORKS-generated, whether or not 18 it was a reinspection based on prior inspection 19 results, this particular chart would not 20 differentiate between those different precipitants 21 of the inspection.
22 In other words, on this chart, there 23 could be some that are based on it, engineering 24 judgment; some that are based on experience at other 25 facilities; some that are based on CHECWORKS; and Neal R. Gross & Co., Inc.
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Page 1637 1 some that are based on prior inspection?
2 MR. ALEKSICK: The points on the graph 3 are all CHECWORKS-modeled components. They may have 4 been selected for inspection for other reasons, the 5 ones Your Honor just outlined, for example. But 6 they are all CHECWORKS-modeled components.
7 So the purpose of this graph is to help 8 us understand and interpret and imply and improve 9 the model. The purpose of this -- it is not the 10 purpose of this graph to assess the structural 11 integrity of any given component.
12 This is about improving the model, and 13 so regardless of the original reason for the first 14 inspection selection, the data is useful in 15 qualifying the model and calibrating the model.
16 JUDGE McDADE: Okay, and again, I just 17 want to make sure I don't have a misapprehension, 18 because you have first inspections and then 19 subsequent inspections. If the CHECWORKS model 20 works out perfectly, in other words, you've done a 21 CHECWORKS inspection; CHECWORKS is what precipitated 22 it, you predict with CHECWORKS that there should be 23 50 mils of wear, and you check it and it is actually 24 50 mils of wear, and that's well within the 25 acceptable range for that particular component.
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Page 1638 1 Wouldn't that then either have a low 2 priority or no priority for subsequent inspections?
3 Wouldn't it only be those where the predictive and 4 the actual are inconsistent, that you would have a 5 higher priority for reinspection?
6 MR. ALEKSICK: To a point, but that's 7 not entirely the case. The priority for inspection 8 is not based solely on the degree of agreement 9 between CHECWORKS predictions and field 10 measurements. The priority of inspection is 11 primarily determined by the wear rates and the 12 remaining margin of that component.
13 So if we had, for example, perfect 14 agreement, as Your Honor hypothesized, if the 15 agreement were perfect and it was one mil of 16 predicted wear and one mil of observed wear, then 17 yes, that would be a low priority inspection.
18 But if it were predicted at 250 mils of 19 wear and observed at 250 mils of wear, then that 20 would be a high priority inspection or perhaps even 21 a replacement.
22 JUDGE WARDWELL: Getting back to the 23 mechanics of this plot, just before getting back to 24 the real mechanics, as I hear you describe this, it 25 also says to me that this plot might be useful to Neal R. Gross & Co., Inc.
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Page 1639 1 give an indication of how good CHECWORKS is working.
2 So I might critique a plot such as this, 3 to point out that CHECWORKS isn't worth much, 4 because it's got such scatter, and that's not a bad 5 use of this particular plot. Is that a fair 6 assessment? And there might be a witness here 7 amongst us right now that has done such a thing, 8 that we'll question about it.
9 MR. ALEKSICK: It is certainly the case, 10 Your Honor, that some of the CHECWORKS plots agree 11 well with observations, and some of them do not 12 agree well with observations. That is the entire 13 basis for our practice of examining every single 14 line, to determine where that agreement exists and 15 where it does not exist.
16 JUDGE WARDWELL: Let's talk about that a 17 little bit more indepth here looking at this plot, 18 with some observations that could be made from this 19 plot. First, if someone was trying to assess the 20 abilities of CHECWORKS to provide conservative 21 estimates, if one was to have some scatter, one 22 would like all the scatter to be, and I'm pausing 23 here to make sure I say this right. That's why I'm 24 pausing, to be above the line.
25 Points above the line have -- of that Neal R. Gross & Co., Inc.
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Page 1640 1 middle line have predicted wear that is greater than 2 the measured wear. So if there was scatter and it 3 was all above the line, at least one could comfort 4 themselves that they would be notified of more wear 5 than actually occurs.
6 Someone might judge that to be a much 7 better situation that if the model predicted wear 8 that was less than what the measured wear was. A 9 fair assessment?
10 MR. ALEKSICK: I disagree with that 11 assessment for the following reason.
12 JUDGE WARDWELL: I didn't get it 13 backwards, though. I didn't flip-flop it though, 14 did I?
15 MR. ALEKSICK: No. You described it 16 correctly.
17 JUDGE McDADE: You're just wrong.
18 JUDGE WARDWELL: You're just wrong. No, 19 you're not wrong; you just screwed up.
20 JUDGE McDADE: It's right but screwed 21 up.
22 MR. ALEKSICK: That would be the case if 23 we relied on CHECWORKS as our sole tool.
24 JUDGE WARDWELL: And let's assume that, 25 because we've been through that; we've explored Neal R. Gross & Co., Inc.
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Page 1641 1 that. But exclusive of that, I understand all that 2 and Horowitz, we've already got testimony on how 3 you're estimating the time for criticality and all 4 that other stuff earlier this morning.
5 So let's just assume we're trying to 6 just use CHECWORKS and exclusive of that. But go 7 ahead, then. Because again, this is -- I'm saying 8 this is on a premise. We're judging CHECWORKS as a 9 model. Not your Flow Acceleration Corrosion 10 Program; just CHECWORKS part of it.
11 MR. ALEKSICK: Okay. CHECWORKS, as 12 we've stated numerous times in our pre-filed 13 testimony, is a best estimate code, and what Your 14 Honor is describing is a bounding code. It's not, 15 I'm not here to argue that a bounding code is a bad 16 thing or somehow inappropriate to use.
17 Instead, my contention is that 18 CHECWORKS, as a best estimate code, is a useful 19 tool, and in particular it's useful to have it as a 20 best estimate code because one of the good 21 consequences of that, is we can look at a scatter 22 plot like this and tell pretty easily if the model 23 agrees with reality or not.
24 That is the context in which we use 25 CHECWORKS in the FAC program. We use it to predict Neal R. Gross & Co., Inc.
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Page 1642 1 what's going on in uninspected components, and in 2 order to use those results effectively, we need to 3 know where the model is -- where we can treat the 4 model with high confidence and where we can't.
5 In those areas where we can't, and this 6 may be one of those cases; this does not look like a 7 particularly tight cluster to me. We would 8 typically inspect a significantly larger number of 9 components.
10 JUDGE WARDWELL: Thank you.
11 JUDGE McDADE: Now when you say 12 components, where it would be and wouldn't be, are 13 you talking about identifying it as, you know, pipes 14 of more than two inches in diameter, with more than 15 a 45 degree angle, with more than so many pounds per 16 square inch of pressure. Is that the kind of thing 17 you're trying to describe, as to where it would be a 18 good predictor and where it wouldn't be?
19 MR. ALEKSICK: I wouldn't phrase it that 20 way, Your Honor. This result that we're looking at 21 now is from one of the 40 lines in CHECWORKS, and 22 this particular line, third point extraction steam, 23 probably has 100 to 150 components, elbows, straight 24 pipes, nozzles. There may be some reducers in this 25 line, maybe a valve, check valve.
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Page 1643 1 So within that subset of the plant, 2 we're looking at the CHECWORKS results and 3 concluding only for that subset of the plant, do we 4 have confidence in the model's predictions or do we 5 not. If we do not, then for that subset of the 6 plant, we would increase our inspection coverage.
7 JUDGE McDADE: But wouldn't there be 8 commonalities in different subsections of the plant, 9 that wouldn't exist internally within that 10 subsection? Certain characteristics of particular 11 areas of the plant that would be repeated over and 12 over in different sections of the plant, that would 13 be -- have commonality, whereas in a particular 14 section, you know, and I believe Dr. Hopenfeld 15 testified, without contradiction, that in a straight 16 piece of pipe, you were, in his view, your CHECWORKS 17 would be a very good predictor?
18 In any one subsection of the plant, you 19 would have sections that would be straight pipes.
20 You would have a good predictor with CHECWORKS, but 21 that if Dr. Hopenfeld is correct, that in other 22 places within that same subsection, where you have 23 different geometry, you would have a totally 24 different ability to predict where, using your 25 program. Is that accurate, or how would you respond Neal R. Gross & Co., Inc.
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Page 1644 1 to that?
2 MR. ALEKSICK: What I would say to that, 3 Your Honor, is that the method that we use to create 4 these analysis lines, this analysis line, the third 5 point extraction, was identified in CHECWORKS, of 6 the thousands and thousands of components in 7 CHECWORKS.
8 We grouped these several hundred 9 together into this one line, because they share 10 common operating and chemistry parameters. So the 11 only difference between the components within this 12 line really is the geometry. So we've in effect 13 isolated the variables.
14 JUDGE WARDWELL: There are errors in 15 CHECWORKS' abilities to predict the measured wear.
16 There's also errors in taking the measurement of the 17 measured wear. If we make the assumption, for the 18 purposes of this discussion, that the measure wear 19 is an absolute value, that is truth. There's no 20 error in measuring that.
21 Then is not this scatter an indication 22 of the precision by which CHECWORKS is able to 23 replicate the measure wear, and I'm using the term 24 precision very specifically, and I'm using it 25 different than the term "accuracy." By precision, I Neal R. Gross & Co., Inc.
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Page 1645 1 mean the abilities to replicate the value over and 2 over again.
3 DR. HOROWITZ: Jeff Horowitz for 4 applicant. Okay. Well first of all, assuming that 5 measured wear is correct and precise.
6 JUDGE WARDWELL: We have to do that for 7 now.
8 DR. HOROWITZ: Your statement is true.
9 The difference, one of the differences you would see 10 are -- you'd see probably differences for two, 11 three, four reasons.
12 One would be trace chrome. If we're not 13 measuring trace chrome, as is current practice here, 14 for example, the components at 30 mils of measured 15 wear. Those two guys probably have some chrome in 16 it, and that's why they're so far to the left.
17 Another difference would be, and that 18 could make a big difference. Dr. Hopenfeld 19 mentioned that. I agree with that. Another 20 difference would be, that will be probably the 21 biggest difference you will see. Other differences 22 would be minor geometric goal, differences such as 23 weld grounds sticking into the pipe.
24 But we're talking probably ten percent 25 difference in wear and stuff like that. So those Neal R. Gross & Co., Inc.
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Page 1646 1 are probably the main two reasons. The other would 2 be a 90 degree elbows, really 85 degrees. Another 3 reason would be the weld grip being different from 4 one elbow to another because the elbow was out of 5 ground, you had it ground to be round, things like 6 that. But those would all be fairly small.
7 But getting back to your assumption, in 8 point of fact, the measured wear is probably less 9 precise than the predictions, and this is true 10 because the NDE isn't precise; it's just that the 11 amount of wear you measure is small compares to the 12 propagation of error.
13 I did some work for EPRI a few years 14 ago, and I was shocked about how that occurs. I 15 think that's a good part of the reason for the 16 scatter you see.
17 JUDGE WARDWELL: So we see the 18 scatteredness because there is imprecision with both 19 the model being able to predict truth, and the 20 imprecision with our measuring technique being able 21 to predict truth?
22 DR. HOROWITZ: Yes, thank you. Let me 23 also mention to a comment that Judge McDade made.
24 Your pointing here is not the wear rate, not the 25 wear; it is the amount of margin available. So you Neal R. Gross & Co., Inc.
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Page 1647 1 could have one of the components here that has a lot 2 of wear, but it has a lot of margin available. So 3 that's another thing to keep in mind.
4 JUDGE WARDWELL: True. But I'm trying 5 to keep just with understanding the plot itself, and 6 what the various data points represent, such that 7 scatter around -- the amount of scatter doesn't 8 necessarily say that the -- strike that.
9 In this instance, we are fortunate 10 because we happen to know what truth is with this 11 plot, which is not true with lots of other plots 12 that we have of data. Because truth is that 45 13 degree line, is it not? I mean just box that up; 14 that's truth.
15 So the closeness with which the sum of 16 all those points attempt to be able to predict that 17 truth is of some measure of our abilities to have an 18 accurate predictor capability associated with that 19 model, and the measurements feeding into the input 20 of that model.
21 DR. HOROWITZ: Okay. I agree with that.
22 JUDGE WARDWELL: Is that a fair 23 assessment?
24 DR. HOROWITZ: Yes, I think so.
25 JUDGE WARDWELL: And if in fact these Neal R. Gross & Co., Inc.
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Page 1648 1 data points predicted truth exactly on the average 2 with all those, would not the line correction factor 3 be 1.0?
4 DR. HOROWITZ: Yes, assuming things like 5 all your global data was correct.
6 JUDGE WARDWELL: That's --
7 DR. HOROWITZ: If everything's correct, 8 certainly.
9 JUDGE WARDWELL: In this case, it is six 10 percent over prediction. It's not a 45 degree line; 11 it's a six percent steeper line, that being the 1.06 12 or the line correction factor being six percent 13 greater than 1.
14 DR. HOROWITZ: Sure.
15 JUDGE WARDWELL: So if one, and that was 16 the heart of my original question, was using this to 17 get just a feeling for how well CHECWORKS works, 18 would say that he were probably six percent on the 19 side we really wouldn't want to be on if we had our 20 choice. It's much nicer to be a line correction 21 factor of .94?
22 DR. HOROWITZ: Right. Well, and again, 23 getting back to your question to Mr. Aleksick, about 24 bounding a best estimate, I don't think the decision 25 is that clear-cut. We started this best estimate 20 Neal R. Gross & Co., Inc.
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Page 1649 1 years ago, partly because we knew when we came out 2 and showed the graph like this, people were going to 3 make this graph, whether we provided it or not.
4 The BRT-CICERO is the best estimate 5 code. The German code KOMMSIE is -- no excuse me.
6 The BRT-CICERO is a bounding code. The KOMMSIE code 7 written by AREVA is almost bounding. It bounds, I 8 think, all but one standard deviation, something 9 like that with the data. So it's close to that.
10 When the found that out, and they found 11 it out fairly recently, I talked at length with the 12 EPRI program manager about do we want to change 13 CHECWORKS to be bounding, which would take adding 14 one code, one line of FORTRAN, that's all, and a 15 code of this. We decided no, mostly because we had 16 20-something years of experience, where people 17 looked at this plot, and I think that's where we 18 are, unless somebody tells us otherwise.
19 JUDGE WARDWELL: With any best estimate 20 model, isn't it fair to say that 50 percent of the 21 time you'll be above that and 50 percent you'll be 22 below on any one point?
23 DR. HOROWITZ: Certainly.
24 JUDGE WARDWELL: That's the definition 25 of best estimate, isn't it? I mean statistically Neal R. Gross & Co., Inc.
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Page 1650 1 you will be half the time you'll over and half the 2 time you'll under-predict it.
3 JUDGE McDADE: Okay. If I could --
4 JUDGE WARDWELL: Give you model results.
5 JUDGE McDADE: If I could interject, and 6 let me try to paraphrase at least what I took away 7 from what Dr. Hopenfeld said, make sure I've 8 paraphrased it correctly, and then ask you to 9 respond, that as you've designed the CHECWORKS 10 program, you looked to the median and you looked to 11 the standard deviation.
12 But that in Dr. Hopenfeld's view, the 13 standard deviation really isn't operative. It's the 14 absolute deviation, where you have these significant 15 outliers that are unexplained, that those pose a 16 significant risk, and that therefore CHECWORKS is 17 unable to pick them up, and without another 18 predictor, that adversely impacts the ability of the 19 Flow-Accelerated Corrosion Program to ensure that 20 the intended use is maintained. Am I correctly 21 paraphrasing you, Dr. Hopenfeld?
22 DR. HOPENFELD: Well, my main point was 23 that it's non-conservative by more than a -- as much 24 as a factor of ten. That was my point.
25 JUDGE McDADE: Okay. But the operative Neal R. Gross & Co., Inc.
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Page 1651 1 thing isn't whether it's conservative or non-2 conservative, meaning whether it's above or below 3 prediction; it's the fact that it's significantly 4 above or below prediction, and even though the 5 standard --
6 JUDGE WARDWELL: Could you speak into 7 the mic, Dr. Hopenfeld.
8 JUDGE McDADE: And even though the 9 standard deviation is relatively minor, as expressed 10 here with the line correction factor, the fact that 11 you have certain outliers that are so far beyond, 12 that that makes it a not valuable tool for 13 predicting Flow-Accelerated Corrosion?
14 DR. HOPENFELD: Let me just say, if I 15 may, I'll just say, add one word here. I didn't 16 come from the moon in making that kind of statement.
17 I made some back, some calculation. I think I even 18 referred to them, to see well look, if I am off by 19 50 percent for that kind of a wall, what's going to 20 happen if I didn't detect it?
21 So I did this. I used these numbers, 22 although these are not really good numbers to use, 23 because they're averages. They represent, you see 24 like the gentleman said, he's using average volumes.
25 If you're really interested in the maximum, local Neal R. Gross & Co., Inc.
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Page 1652 1 maximum, you really shouldn't use them.
2 But nevertheless, even using averages, 3 you can see, because in a plant, the actual 4 thickness varies, something like between one or half 5 a mil to ten mils per year. So it depends on the 6 particular component you're looking at.
7 But you can sort of do sensitivity 8 studies, which I did, and that's why I said well 9 look. When you're off by as much as -- most of the 10 time you're off, but it's not ten or outliers. But 11 most of the time, oh on probably a lot of them, is 12 marred by a factor of ten. A factor of ten for some 13 components which, you know, if you have a very thick 14 wall and you operate at very low turbulence, that's 15 okay.
16 JUDGE McDADE: I'm sorry.
17 JUDGE WARDWELL: Okay. Thank you, Dr.
18 Hopenfeld.
19 DR. HOPENFELD: But if you operate, you 20 have a thinner wall, you operate with a lot of 21 turbulence, that kind of -- and you realize, and you 22 say well, in the pre-inspection, I've got three 23 years and four years and five years, you're not 24 there. That's my point.
25 JUDGE McDADE: Okay. Dr. Horowitz, if Neal R. Gross & Co., Inc.
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Page 1653 1 you could, could you basically respond to my 2 question about the value of CHECWORKS, when in 3 addition to the median and the standard deviation, 4 you also have some significant outliers, and is 5 there a way that that can be adjusted for within the 6 CHECWORKS program?
7 DR. HOROWITZ: Okay. First of all, I 8 don't think it's a matter inside the CHECWORKS 9 program. As Mr. Aleksick pointed out, any outlier, 10 and you're interested obviously in the outliers that 11 are wearing more than you think they should be, or 12 have been inspected, if they're too thin at this 13 point they'll be replaced. If they aren't, they'll 14 return them.
15 So for whatever reason, if there is a 16 reason that CHECWORKS is predicting that component 17 wrong, you're not basing future inspections on 18 CHECWORKS.
19 JUDGE McDADE: No, but I understand, and 20 it's been explained this morning in some detail, 21 what happens when you have an outlier and what is 22 then done.
23 What I'm trying to get at and trying to 24 understand is when you have an outlier, it means 25 that CHECWORKS didn't predict the actual wear. Is Neal R. Gross & Co., Inc.
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Page 1654 1 there any way that that is then plugged back into 2 the CHECWORKS program, so that same kind of 3 deviation won't occur again?
4 Again here, you've identified a place 5 where the wall thickness is below what you think it 6 should be. You fixed it. But there are a lot of 7 areas that haven't been inspected, and the question 8 is how do you have assurance that those other areas 9 that haven't been identified for inspection by 10 CHECWORKS don't have this same problem, where the 11 wear is significantly higher than what you would 12 predict?
13 DR. HOROWITZ: Okay. There are two 14 things. Number one, as I just pointed out to Judge 15 Wardwell, the measured wear is hardly a precise 16 number. It's probably less precise than the 17 CHECWORKS predictions. That's true for a number of 18 reasons that I pointed out.
19 I think the more important reason is 20 programmatically, if we see a lot of outliers, that 21 line is not calibrated and more inspections are 22 done. And I think -- I suggest that's your defense 23 against what you outlined.
24 One more thing. Dr. Hopenfeld just now, 25 and in his presentation, said that CHECWORKS Neal R. Gross & Co., Inc.
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Page 1655 1 predicts an average rate of thinning. That's 2 incorrect. It uses the maximum rate of thinning on 3 the components.
4 JUDGE McDADE: Okay. Thank you, Doctor.
5 JUDGE KENNEDY: How does that relate to 6 the best estimate nature of the program? I'm 7 misunderstanding what Dr. Horowitz just said. Dr.
8 Horowitz, you --
9 DR. HOPENFELD: I think what he's 10 talking about maximum and what I talk about maximum 11 are two different things. Going back to the elbow, 12 you see the average -- he's talking about maximum, 13 what in that F3 as a geometrical factor. I believe 14 that's what he's talking about. It's still the 15 average. It's not the local thing that I'm talking 16 about.
17 JUDGE KENNEDY: Let's ask Dr. Horowitz.
18 Did you just say it predicts the maximum wear rate?
19 DR. HOROWITZ: That is correct.
20 JUDGE KENNEDY: In the context of a best 21 estimate tool or computer program, what does that --
22 DR. HOROWITZ: It's just saying it 23 doesn't matter best estimate or not.
24 JUDGE KENNEDY: So the best estimate 25 maximum wear rate?
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Page 1656 1 DR. HOROWITZ: That's correct.
2 JUDGE WARDWELL: And how do you know 3 that is the maximum wear rate?
4 DR. HOROWITZ: Okay. This gets into 5 something we've been skirting. Now what we call the 6 geometry factors with what the Wang paper that Dr.
7 Hopenfeld -- he has an exhibit called something 8 else, is the ratio of the maximum wear on a given 9 component, to the maximum -- to the wear in a 10 straight pipe with the same conditions.
11 That's how Dr. Paulson defined it in his 12 paper; that's how Dr. Wang defined it in his paper, 13 using different words.
14 JUDGE WARDWELL: One other question I 15 had, backing up a bit to where I was, that I just 16 wanted to fix, to make sure I understand this 17 correctly. Back to the statement saying it was a 18 best estimate, and half the time it would be above 19 and half the time it would be below.
20 That half time it would be above and 21 half time being below, has nothing to do with the 22 plus or minus 50 percent we have on this graph. Is 23 that correct if I understand it?
24 DR. HOROWITZ: Yes it is, Judge.
25 JUDGE WARDWELL: Yeah, that's -- okay.
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Page 1657 1 These plus and minus 50's are just purely plot lines 2 for visual aids; is that a fair assessment?
3 DR. HOROWITZ: Excuse me. One more 4 thing. Just looking here --
5 JUDGE WARDWELL: Sorry. Could I just 6 get that? Is that a fair assessment, that --
7 DR. HOROWITZ: Yes it is, but looking at 8 your comment that the one line was mislabeled.
9 Looking at more recent output of CHECWORKS, that's 10 been corrected.
11 JUDGE WARDWELL: Say that again, Dr.
12 Horowitz?
13 (Off record comment.)
14 JUDGE WARDWELL: You want to strike 15 that?
16 DR. HOROWITZ: Yes, please.
17 JUDGE WARDWELL: Okay.
18 JUDGE KENNEDY: Ready to turn to -- now 19 can we go to the next page?
20 MR. TURK: May I ask a clarifying 21 question? Sherwin Turk. Your Honors, when I look 22 at that chart and I see the 50 percent value, 23 perhaps my understanding is incorrect, but I 24 understand that the central line is 50 percent lower 25 than the upper line, and that the lowest line is 50 Neal R. Gross & Co., Inc.
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Page 1658 1 percent less than the middle line. Is that 2 something that --
3 JUDGE WARDWELL: That's not my 4 understanding.
5 JUDGE McDADE: I don't know that was a 6 clarifying question, but I believe Mr. Cox indicated 7 that it's actually 100 percent, and that on the more 8 recent graphs that are produced, indicates that it 9 is 100 percent.
10 JUDGE WARDWELL: Well, 50 percent below 11 will be 100 percent above.
12 DR. HOROWITZ: Yes.
13 JUDGE WARDWELL: Just to ask. I mean 14 the point is the lines are just lines.
15 MR. TURK: Sorry for the interruption.
16 JUDGE WARDWELL: Let's, could we --
17 before we go to the next line, and then I'll let you 18 take over, I think now might be -- Dr. Hopenfeld, 19 you make the statement that these values are off by 20 an order of magnitude of ten.
21 DR. HOPENFELD: Uh-huh.
22 JUDGE WARDWELL: Where do you get that 23 from this plot, or did you get it from some other 24 plot, or some other analysis?
25 DR. HOPENFELD: I was very careful in my Neal R. Gross & Co., Inc.
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Page 1659 1 language. I said I've looked at close to 7,000 2 points, and based on those, and I'm not sure if it's 3 in here, but here you can see that it's off by --
4 this is, there are others which are more than ten.
5 But I said, to be conservative, I said 6 as much as ten. I don't know whether it's in here, 7 but we can check that. This is 220 versus 100, so 8 that would be by a factor of -- on the outlier.
9 Let's see, the outlier. So there would be 300 --
10 JUDGE WARDWELL: All right. Which point 11 are you pointing out? I'm sorry. Which one?
12 DR. HOPENFELD: If you look at the two 13 points here, you'll see there will be 200.
14 JUDGE WARDWELL: In the upper left?
15 DR. HOPENFELD: On the upper left would 16 be 200, what 20, 220, divided by 20. So what would 17 that be? Just as a point. But there are many 18 others.
19 JUDGE WARDWELL: So the most extreme 20 outliers would be an order of magnitude --
21 DR. HOPENFELD: Yeah, yeah. That's what 22 I'm talking about. I didn't say either way. It's 23 either way. In this particular instance, it doesn't 24 matter which way it is.
25 JUDGE WARDWELL: But in this particular Neal R. Gross & Co., Inc.
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Page 1660 1 chart, if you look to the lower right, the furthest 2 outlier is measured wear about 225, predicted wear 3 75. So it's a factor of 3.
4 DR. HOPENFELD: Right. That's a small 5 one, yeah. I said as. I would recommend, so not to 6 get carried away with the outliers, I can go back to 7 it. But we just looked at the extremes, within the 8 plus or minus 50 lines, so they won't get any 9 confusion. Make it simpler.
10 JUDGE McDADE: Go the next chart.
11 JUDGE KENNEDY: Could you say that 12 again? I'm not sure I understand.
13 DR. HOPENFELD: I'm saying that we can 14 talk about the outliers, and in my presentation, I 15 said as much as a factor of ten. But most of them, 16 and I have a table showing how many are those far 17 out. So I have a table. You have the data in front 18 of you somewhere in evidence.
19 But let, we can easier not just talk 20 about what's within the bounding lines. It's just 21 easier to talk about it.
22 JUDGE KENNEDY: Okay, and we've had an 23 explanation from Entergy of how they deal with the 24 outliers, and you're suggesting we just stay out of 25 that arena?
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Page 1661 1 DR. HOPENFELD: Just for this 2 conversation, this discussion of this, what I'm 3 trying to demonstrate with what I said, optical 4 illusion.
5 JUDGE KENNEDY: Okay. Should we go on 6 to the next page?
7 JUDGE McDADE: Yes.
8 JUDGE KENNEDY: Now Dr. Hopenfeld, I 9 think this is an exhibit that you prepared? Is that 10 true?
11 DR. HOPENFELD: Yes.
12 JUDGE KENNEDY: Could you walk us 13 through your explanation of what is important on 14 this graph and what is presented here?
15 DR. HOPENFELD: Yes. You see if you 16 look at the original graph, the one which you 17 previously showed us, you look at it and you say 18 hey, everything is perfect here. It looks pretty 19 good. It's within this plus or minus 50 percent.
20 Actually, you're really interested in the lower 21 number, because we're interested in the non-22 conservative.
23 That's what we're interest in and that's 24 what 1801 talks about. So you're interested in the 25 data below the LCF towards the non-conservative Neal R. Gross & Co., Inc.
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Page 1662 1 predictions. If you look at it, you say well, it 2 doesn't look that bad.
3 JUDGE WARDWELL: What do you mean by an 4 LCF line?
5 DR. HOPENFELD: LCF is the one that they 6 had over there, which was labeled 106?
7 JUDGE WARDWELL: It wasn't labeled.
8 That's the point. It wasn't labeled 106.
9 DR. HOPENFELD: Well, on the top. But 10 it's that line.
11 JUDGE WARDWELL: So 45 degree line?
12 DR. HOPENFELD: Yeah. I just copied.
13 All I did, sir, was just take their --
14 JUDGE WARDWELL: Okay. Just wanted to 15 make sure. That's the 45 degree line.
16 DR. HOPENFELD: Yeah, yeah. All I did 17 is just went to one of those programs in the 18 computer, and just flipped that, and I used X = Y, Y 19 = X and I changed the coordinates. So I took the 20 same data point and to the best of view, I don't 21 know which program I used.
22 But I put the points and started 23 replotting it, okay? The reason I'm replotting it 24 because it's third grade mathematics. If you take a 25 number and divide by a small number, you get a Neal R. Gross & Co., Inc.
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Page 1663 1 larger number. That's what happened here.
2 Now if you look at this then, you'll see 3 now suddenly a lot of numbers that were bounded 4 before, okay. Now they're not bounded anymore, 5 okay. That was my point. No, no, no. I'm sorry.
6 This is the wrong number here. This is the next --
7 oh, I thought that you were -- I'm terribly sorry.
8 I thought you were showing the figures from 9 yesterday's presentation.
10 Okay. Let's go to the third one. I 11 confused -- I thought that we were, I didn't include 12 that draft in my presentation yesterday.
13 JUDGE WARDWELL: This is an exhibit that 14 you prepared?
15 DR. HOPENFELD: Yeah, right, right. I 16 just, that was the next step, to show you look, if 17 you just look at the LCF line and the numbers below 18 that, that's what you see, okay. Measured and 19 predicted. The next one, I flipped it over.
20 Yesterday, I didn't even show this one.
21 JUDGE WARDWELL: Okay, and you're 22 showing this, mostly to make that same qualitative 23 discussion that I was bringing up, that points below 24 the line have measured rates that are higher than 25 the predicted rates.
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Page 1664 1 So if one could call that, as you have, 2 non-conservative, meaning that it's more desirable 3 to be above the line. All this is saying is it's 4 more desirable to be above the line.
5 DR. HOPENFELD: Right. This is just a 6 copy.
7 JUDGE WARDWELL: But their testimony 8 says that it's a best guess. Not best guess, best 9 estimate model, and so you would expect to have 10 points below the line, as well as above the line, 11 wouldn't you?
12 DR. HOPENFELD: Sure.
13 JUDGE WARDWELL: Right, okay.
14 DR. HOPENFELD: The question is how 15 much. That's the question, by how much.
16 JUDGE WARDWELL: But it's not -- is it 17 appropriate to call it non-conservative? Non-18 conservative in regards to what?
19 DR. HOPENFELD: Yes. No matter what it 20 is, it's still non-conservative below that line.
21 JUDGE WARDWELL: Why? Why? For what?
22 DR. HOPENFELD: It's below what you 23 would predict. It's below one. If it was 1 to 1 --
24 JUDGE WARDWELL: But why is that 25 conservative? It's just below.
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Page 1665 1 DR. HOPENFELD: No. 1 to 1 is correct; 2 but anything below that would be non-conservative.
3 JUDGE WARDWELL: So why -- so the one 4 above it would be ultra non --
5 DR. HOPENFELD: No. The higher, the one 6 below would be that you predicted something less 7 than what you measured.
8 JUDGE WARDWELL: Okay, but so it's less 9 than, but it's not necessarily conservative or not 10 conservative?
11 DR. HOPENFELD: Well, if it's less than, 12 than it would be non-conservative.
13 JUDGE WARDWELL: It would be, if in fact 14 you were only -- if you were using this to dictate 15 when in fact you were going to replace a component 16 or repair it. But they aren't using this for that; 17 is that correct?
18 DR. HOPENFELD: I think they do.
19 JUDGE WARDWELL: We had testimony this 20 morning that said they used measured values and 21 calculations for most measured values, to determine 22 how they're going to handle those components. Is 23 not that correct?
24 DR. HOPENFELD: There was still 50 25 percent of the time it's being used to screen Neal R. Gross & Co., Inc.
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Page 1666 1 components and predict frequency.
2 JUDGE WARDWELL: But they weren't using 3 them in regards to replacing or repairing a 4 component, to meet its intended function, were they?
5 They were using measured values and calculations 6 from them in regards to the service life?
7 DR. HOPENFELD: After they identified 8 the component with this.
9 JUDGE WARDWELL: But it's not a non-10 conservative or non-conservative in regards to being 11 below the line, and they don't use this for all 12 their even selections.
13 DR. HOPENFELD: No. I don't understand 14 it that way, because if you say that they don't use 15 CHECWORKS, period.
16 JUDGE WARDWELL: I don't say. It's they 17 who are --
18 (Simultaneous speaking.)
19 DR. HOPENFELD: Yeah, okay. They say 20 they don't use CHECWORKS, period, which now they say 21 they use it very little. Then we can just go and 22 focus on what they are using. But right now, the 23 conversation is about CHECWORKS, and what is 24 predicted and what is conservative and what's not 25 conservative, and that's what I'm talking about Neal R. Gross & Co., Inc.
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Page 1667 1 here.
2 JUDGE WARDWELL: But that's why I don't 3 understand the definition of conservatism, when 4 you're talking about what's just talking about 5 model. You're putting a qualitative adjective, 6 conservative and non-conservative, on to being above 7 and below this line.
8 DR. HOPENFELD: Yes.
9 JUDGE WARDWELL: And did the same thing.
10 The testimony I heard from Entergy in regards to 11 well, it isn't really, and I, you know, accepted 12 that testimony and am now questioning you in regards 13 to that same testimony, the fact that they're not 14 using it in any actual implementation of corrective 15 measures associated with their management program, 16 that convinced me that maybe I shouldn't have used 17 that term, more desirable, less desirable.
18 In the same way, I'm asking you, should 19 you be using the term "non-conservative" or not?
20 DR. HOPENFELD: From reading all the 21 testimony they provided us, it's my understanding 22 that they are using it to some extent. They're not 23 using it to the extent that I originally thought 24 they were when I read the LRA. I thought they were 25 mostly using it.
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Page 1668 1 But as time was going on, we found 2 they're using it -- until they gave us this chart 3 with those colors that you had, I didn't know how 4 much they were using it. When they gave us the 5 color, the color chart, it became obvious they were 6 using it for like total 25 percent.
7 But I couldn't figure out half of it is 8 used or half of it is for frequency. It was very 9 confusing.
10 JUDGE WARDWELL: Yeah, and that chart 11 was to predict, to determine the measurement 12 locations. It didn't even -- they are still several 13 steps from the activity.
14 (Simultaneous speaking.)
15 JUDGE McDADE: Can I go back, because 16 I'm getting more confused, and let me just interrupt 17 here for a second, Dr. Hopenfeld. As I understand 18 it, you're not using the term conservative/non-19 conservative as either good or bad. When you use 20 the term "conservative," that means that the actual 21 wear is less than the predicted wear. When you use 22 the term "non-conservative," it means that the 23 actual wear is more.
24 DR. HOPENFELD: Correct.
25 JUDGE McDADE: Not good or bad; it's Neal R. Gross & Co., Inc.
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Page 1669 1 just that's the way you're defining the two terms.
2 DR. HOPENFELD: That's the way I'm 3 defining. That's the way it was defined in 1801, I 4 believe.
5 JUDGE McDADE: And then when you get to 6 the next part, they replace, based on -- and repair, 7 based on actual measurements. But your concern, as 8 you expressed it this morning, at least as I 9 interpret it, is that they identify those areas to 10 be inspected, new inspections through CHECWORKS, for 11 a significant portion of those.
12 DR. HOPENFELD: Correct.
13 JUDGE McDADE: If in fact they identify 14 it and there is excessive wear, they then can take 15 corrective action.
16 DR. HOPENFELD: That's correct.
17 JUDGE McDADE: But that your concern is 18 using CHECWORKS, given what you perceive as its 19 deficiencies, that are components that will never be 20 inspected, but nevertheless are going to have 21 significant wear that had they been inspected --
22 DR. HOPENFELD: Right.
23 JUDGE McDADE: The wear would have been 24 far more than predicted. They're not inspected, 25 because the predicted wear is low, and that that Neal R. Gross & Co., Inc.
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Page 1670 1 poses, in your view, an unacceptable risk that the 2 component will fail and not perform its intended 3 function.
4 DR. HOPENFELD: Absolutely.
5 JUDGE McDADE: Okay. I just want to 6 make sure I understand your position.
7 (Simultaneous speaking.)
8 DR. HOPENFELD: You understood what I 9 meant.
10 JUDGE McDADE: Okay.
11 MR. AZEVEDO: Your Honor, may I make a 12 comment?
13 JUDGE McDADE: Sure.
14 (Simultaneous speaking.)
15 JUDGE McDADE: I mean this is -- again, 16 we're just trying to make sure I understand his 17 position and I understand that that position is not 18 necessarily shared by Entergy.
19 MR. AZEVEDO: Yes. I'd just like to 20 make a couple of comments. Number one, we've been 21 talking about this specific line. This specific 22 line was not calibrated. So we're not making the 23 argument this is a good line that we rely on. This 24 is a non-calibrated line, so we recognize the 25 scatter on this line.
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Page 1671 1 The second comment is, as you pointed 2 out, the determination whether that component's fit 3 to be placed in service or not is not -- we don't 4 rely on CHECWORKS wear. We rely on measured wear.
5 I just want to make sure that that's clear.
6 The third point I would like to make is 7 that the judgment as to whether CHECWORKS is an 8 effective program or not should be based, in my 9 view, primarily on the ranking mechanism, because 10 that's how we use it.
11 We don't necessarily use the wear rate 12 alone; we look at it, but the benefit of CHECWORKS 13 is the ranking tool, and the highest ranking 14 locations. Those are the ones that we inspect.
15 So the judgment as to whether the 16 program is effective or not should be based on the 17 ranking, not just on the wear rate.
18 JUDGE WARDWELL: But isn't it true that 19 if in fact because of the results of CHECWORKS, 20 there might be a situation where a component has 21 predicted wear very low, and actually has a lot of 22 measured wear, but you'll never get to that point, 23 because you never will have taken a measurement of 24 that point?
25 MR. AZEVEDO: Well in this particular Neal R. Gross & Co., Inc.
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Page 1672 1 case, because the line is not calibrated, what this 2 will tell us is that we have to do more --
3 JUDGE WARDWELL: And don't focus on --
4 we're not focusing on this as a target of what a 5 different decision should be on this. We don't 6 really care what this is. This could be a 7 hypothetical line, as far as we're concerned.
8 Just understand the concepts that are 9 trying to be portrayed here, and as I understand 10 what Dr. Hopenfeld says, is there -- by looking at 11 this data, he says there's a chance some of these 12 outliers may never be identified for inspection.
13 If that's true, then in fact we'll never 14 get to the point that it's even considered in some 15 of your other criteria, and certainly wouldn't even 16 come up with the calculation to be derived for it, 17 to see whether or not it needs to be repaired or 18 replaced. Isn't that correct?
19 MR. AZEVEDO: If that was the only tool 20 that we'd use, that we use, I would agree with that.
21 But that is not the only tool.
22 MR. COX: I guess one of the things we 23 mentioned, this is Alan Cox for Entergy. One of the 24 things we mentioned was whether a line was 25 calibrated. In the scenario that you described, Neal R. Gross & Co., Inc.
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Page 1673 1 Judge Wardwell, you're saying we haven't done an 2 inspection because we show up as low wear on the 3 prediction.
4 If we haven't done any inspections, we 5 don't consider the line calibrated. So we're not 6 going to not inspect that line, based solely on 7 CHECWORKS. We're going to have to have inspections 8 before we can rely on CHECWORKS to say whether you 9 need to do more inspections or not.
10 So I don't think you're ever going to 11 get to that scenario, where we're never going to 12 look at a line, because we have a CHECWORKS model 13 that says we have low wear.
14 JUDGE KENNEDY: This discussion of 15 conservative, non-conservative makes me, takes me 16 back to some points that Dr. Hopenfeld was making 17 about NUREG-1801. There's a comment in there that 18 if the CHECWORKS model is not conservative, it needs 19 to be calibrated.
20 And now I think I've lost my path, as to 21 where the term conservative comes in here. So I 22 think Dr. Hiser is just itching to help us 23 understand what GALL means by if the CHECWORKS model 24 is non-conservative, it needs to be calibrated.
25 MR. YODER: I'll address that. Matthew Neal R. Gross & Co., Inc.
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Page 1674 1 Yoder from the NRC staff. I think one thing that 2 the staff and Dr. Hopenfeld agree on is that the 3 entire program must rely on your ability to inspect 4 prior to reaching a critical thickness for a 5 component.
6 I think that is the intent of what's 7 written in the GALL. For the specific section that 8 discusses CHECWORKS and the FAC program being 9 bounding for FAC, that is the intent of that.
10 The language stating that the analysis 11 is bounding, because in general, the predicted wear 12 rates and component thicknesses are conservative 13 when compared to actual field measurements, was 14 added as part of Rev 2 to the goal.
15 We recognized that that is confusing 16 language, and we have actually put in an interim 17 staff guidance which, among other things, removes 18 that language from the document. That is an 19 exhibit. I can provide the number.
20 JUDGE WARDWELL: So you're now not 21 saying that CHECWORKS is a bounding analysis?
22 MR. YODER: Well I guess what I'm saying 23 is that was never the intent, and I won't, I don't 24 know how this specific sentence wound up in Rev 2 of 25 the goal. But going back to Rev 1, that was not Neal R. Gross & Co., Inc.
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Page 1675 1 present. What was present was the statement that 2 CHECWORKS is acceptable because it provides a 3 bounding analysis for FAC.
4 What we mean by that is you're going to 5 identify and inspect the component prior to 6 challenging that minimum component thickness. So it 7 bounds the wear associated with FAC, before you 8 challenge the component integrity. That has always 9 been the intent of this document.
10 JUDGE WARDWELL: But the phrase that the 11 model is a bounding model is a different phrase 12 then, is what you're saying? In contrast to a best 13 estimate model.
14 MR. YODER: That's right. The staff 15 recognizes that CHECWORKS is a best estimate model, 16 and this phrase would imply that you could interpret 17 this phrase to mean that it is. We see it as a 18 bounding model. We do not agree with that.
19 JUDGE WARDWELL: And so your proposed 20 interim staff guidance merely strikes that sentence?
21 MR. YODER: Among other things. It also 22 adds --
23 JUDGE WARDWELL: No, but does it replace 24 anything in this context? I don't need the other 25 things that it does.
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Page 1676 1 MR. YODER: No. It strikes that 2 language.
3 DR. HISER: Yeah, I think if you -- this 4 is Allen Hiser of the staff. If you look at the 5 following sentence, it says "It is recognized that 6 CHECWORKS is not always conservative in predicting 7 component thickness. Therefore, when measurements 8 show the predictions should be non-conservative, the 9 model must be recalibrated using the latest field 10 data."
11 That's the Pass 2, the line correction 12 factor approach that is within the CHECWORKS code.
13 That's what we were trying to get to there. In 14 terms of the fact that we don't, did not expect that 15 every data point would be bounding. So we wanted to 16 ensure that there was some feedback of the measured 17 inspection data to the CHECWORKS program, so that 18 future predictions would be informed by that 19 inspection data.
20 So the wording is confusing. The way 21 that we believe that it was intended was to be 22 bounding, in terms of predicting component 23 performance, and ensuring that inspections and 24 corrective actions would be taken as necessary, 25 before the acceptance criteria would be exceeded for Neal R. Gross & Co., Inc.
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Page 1677 1 those components.
2 So it's not data point by data point 3 bounding, but it's component bounding is what we 4 believe the intent is.
5 JUDGE KENNEDY: A compounding bounding 6 in the sense that inspection would occur, or --
7 DR. HISER: Right, that inspection would 8 occur, and if acceptance criteria are not met, then 9 corrective actions would be taken.
10 JUDGE KENNEDY: Said a different way, is 11 the caution that Judge Wardwell was trying to give 12 us on making qualitative statements about 13 conservative, non-conservative, is that all wrapped 14 into this discussion? I mean we're starting to walk 15 down a path that if a lot of data was below the 16 line, we've got issues.
17 I was envisioning a long discussion 18 about recalibrating the model. But it's sounding 19 like to me that this discussion is moving in a 20 different direction.
21 DR. HISER: Well, I think the wording 22 that is within the GALL report has been misconstrued 23 and is not clear, in terms of what's intended by 24 CHECWORKS, by the statement of CHECWORKS as a 25 bounding code.
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Page 1678 1 JUDGE KENNEDY: And the interim staff 2 guidance clears that up?
3 DR. HISER: There is a draft interim 4 staff guidance document that makes corrections to 5 that, to ensure that the meaning is much clearer.
6 JUDGE KENNEDY: Is that an exhibit 7 within this proceeding?
8 DR. HISER: I believe it's one of the 9 Entergy exhibits. I don't have the exhibit number.
10 MR. YODER: Your Honor --
11 MR. ROTH: David Roth for the staff.
12 It's Entergy 573.
13 JUDGE KENNEDY: ENT 573?
14 MR. ROTH: That is correct, Your Honor.
15 JUDGE KENNEDY: And does that go out for 16 comment or what happens to it?
17 DR. HISER: I believe that it is out for 18 public comment. I'm not sure of the exact status.
19 It has not been finalized yet.
20 JUDGE KENNEDY: Dr. Hiser, again looking 21 at where we are within the licensing proceeding, the 22 availability or the implementation of this interim 23 staff guidance, would that change the condition or 24 the staff's view of Entergy's Flow-Accelerated 25 Corrosion Program at this time?
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Page 1679 1 DR. HISER: Well, it really would have 2 no impact on the acceptability of the program. The 3 way that we see the program, CHECWORKS is a tool 4 used within the program to provide assurance of 5 integrity of the components that are susceptible to 6 FAC.
7 JUDGE KENNEDY: And so this draft 8 guidance, in your mind, really provides 9 clarification, so that people clearly understand 10 what was intended by the statements?
11 DR. HISER: That's correct, with the 12 impact to the ISG on this portion of the GALL AMP.
13 That would, that is correct. It's for 14 clarification.
15 JUDGE KENNEDY: Thank you.
16 MR. YODER: Just one more, before we 17 leave this. Matthew Yoder from the staff. The 18 statement that we've been discussing is not present 19 in GALL Rev 1, which is the guidance document that 20 was in place when Indian Point applied for license 21 renewal.
22 JUDGE KENNEDY: And was it the GALL 23 version that the SER was written to? Because I 24 thought we heard testimony yesterday to the 25 contrary, that GALL Rev 2 was.
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Page 1680 1 MR. YODER: Well, let me try to explain 2 it this way. The changes to GALL Rev 2 in this area 3 would have been operating experience-based in 4 particular. That's what would have been important 5 for plants to or applicants such as Indian Point to 6 consider.
7 There were no changes to operating 8 experience for FAC. So because the wording of Rev 1 9 and Rev 2 are very similar, other than this one 10 sentence that was added and the update of NSAC. Now 11 NSAC 202-L Rev 2 and Rev 3 are accepted in Revision 12 2.
13 With those being the only changes, I 14 think one would say that -- I think I would say that 15 Indian Point's application, the FAC AMP, is 16 consistent with both Rev 1 and Rev 2.
17 JUDGE KENNEDY: I guess maybe I 18 misunderstood Mr. Yoder's comment, about what's in 19 Rev 1.
20 MR. YODER: All right. So if we look at 21 the specific passages that we've been discussing.
22 The statement regarding -- okay. So under 23 monitoring and trending, should we pull this up?
24 JUDGE KENNEDY: We could. Do you have 25 the exhibit number?
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Page 1681 1 MR. KUYLER: Your Honor, Ray Kuyler for 2 Entergy. It's New York State 147D.
3 JUDGE KENNEDY: Would this be GALL Rev 2 4 then?
5 DR. HISER: I believe so.
6 (Off record comment.)
7 DR. HISER: Probably need to go down 8 many pages. We're looking for page number XI.M17-1.
9 (Pause.)
10 MR. TURK: Your Honor, I'm sorry to 11 interrupt. Sherwin Turk.
12 JUDGE KENNEDY: Yes sir.
13 MR. TURK: I might be able to give you 14 some quick clarification. The staff's SER is dated 15 November 2009.
16 JUDGE KENNEDY: So before Rev 2?
17 MR. TURK: The SER considered Rev 1.
18 GALL Rev 2 was issued December 2010, one year after 19 the SER came out, and there was, of course, the SER 20 supplement that came out more recently, on limited 21 issues. But the evaluation was against Rev 1, and 22 later we were guided, we had information from 23 operating experience that we considered.
24 JUDGE KENNEDY: And maybe, is that what 25 you were trying to say? I'm confused where this Neal R. Gross & Co., Inc.
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Page 1682 1 bounding comment is, if it's in GALL Rev 1 or GALL 2 Rev 2.
3 MR. YODER: This is Matthew Yoder from 4 the staff. The comment regarding whether the model 5 is bounding is in Rev 2 of the GALL.
6 JUDGE KENNEDY: And not in Rev 1?
7 MR. YODER: That is correct, and the SER 8 was written prior to the issuance of Rev 2 of the 9 GALL.
10 JUDGE KENNEDY: Okay. Now we have 11 clarification to the GALL Rev 2, which is in the 12 draft ISG.
13 MR. YODER: I'm sorry. Could you repeat 14 the question?
15 JUDGE KENNEDY: Is the draft interim 16 staff guidance, is that to clarify GALL Rev 2?
17 MR. YODER: That's correct. It modifies 18 GALL Rev 2 and it's -- this specific passage we're 19 talking about, as well as a lot of other areas, that 20 get into erosion and droplet impingement and some of 21 the other topics which we have discussed during this 22 hearing.
23 But we have the exhibit up now, if you 24 want to look at that exact language. This is GALL 25 Rev 2. It would be under the Monitoring and Neal R. Gross & Co., Inc.
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Page 1683 1 Trending, Element 5. So the specific phrase starts 2 on the fourth line. It starts with "The analysis is 3 bounding."
4 JUDGE KENNEDY: Okay. So that's how I 5 got myself into this.
6 MR. YODER: Right. So that was not in 7 Rev 1 of the GALL, and it is not in the staff's 8 proposed guidance going forward.
9 JUDGE KENNEDY: Okay. I think I found 10 my way back. So I appreciate that.
11 JUDGE McDADE: But sort of cutting to 12 the chase on this, that this particular exhibit, New 13 York 147D, is the GALL as of December 2010. The SER 14 was based on the previous version.
15 It came out in November of 2009, and 16 that in any event, this language from Revision 2 was 17 being modified and if we're looking for the 18 modification, we go to Entergy Exhibit 573, the 19 draft interim staff guidance.
20 MR. YODER: That's correct.
21 JUDGE McDADE: And that sort of walks us 22 through. So when we go back and start reading the 23 record in one place, that's sort of the path we 24 follow?
25 MR. YODER: That's correct.
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Page 1684 1 JUDGE McDADE: And it's the position of 2 the staff, the NRC at this point, that the draft 3 interim staff guidance, Exhibit Entergy 573, states 4 the current NRC staff position on this?
5 MR. YODER: That is correct, except I 6 would caveat that, that that is a draft interim 7 staff guidance. It has not gone through its full 8 public comment period, and it has not become 9 official document yet. But yes, that is the staff's 10 proposed position.
11 DR. HISER: This is Allen Hiser again 12 from the staff. But I think it would -- we can say 13 it would be the staff's intent to correct the 14 misinterpretations that can occur, because of the 15 way this is worded.
16 JUDGE McDADE: Thank you, Dr. Hiser.
17 DR. HISER: Whether it's the wording 18 that's in Entergy 573 or some alternative that we 19 come out with, we need to make these corrections.
20 JUDGE McDADE: Because you think the 21 language in the Revision 2 to the GALL, which is in 22 our evidence is New York 147D, is misleading?
23 DR. HISER: I think that's correct. I 24 think that's caused a lot of the confusion here this 25 afternoon.
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Page 1685 1 JUDGE McDADE: Well, at least we can 2 justify our confusion on something. Thank you.
3 PM Your Honor, Philip Musegaas for 4 Riverkeeper. If I may, I think unfortunately I'm 5 confused now. If I can request some clarification.
6 Just between what Dr. Hiser and Mr. Yoder said, and 7 what Sherwin Turk from the NRC staff counsel said.
8 So is the NRC -- my question would be is the NRC 9 staff's evaluation of the FAC based on GALL Rev 1, 10 or is it -- how does this language that we're 11 discussing, how is that integrated into their 12 assessment of whether this, the AMP is sufficient?
13 JUDGE McDADE: Well I think ultimately, 14 the three of us in the short term are going to have 15 to figure that our ourselves, just sort of following 16 the bidding here, which I think is like a 2 no trump 17 at this point, is it was GALL Revision 1 that was 18 the NRC guidance when the SER, or excuse me, when 19 the license application was submitted.
20 When the original SER was prepared, we 21 then had a modification in GALL Revision 2 that was 22 in place when the supplement to the SER was issued, 23 that upon review, the NRC staff believes that there 24 is confusion generated by Revision 2, which they 25 hope to correct, that started that process with the Neal R. Gross & Co., Inc.
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Page 1686 1 draft guidance that they have issued, that is now 2 out for public comment.
3 I don't know that I jotted down the date 4 of the draft interim staff guidance, but it's 5 Exhibit 573, and that's where we are today.
6 Ultimately, we're going to have to decide with all 7 of that, and Dr. Hiser, have I -- since I can't 8 testify, you can. Did I just sort of accurately 9 describe the evolution of this within the NRC staff?
10 DR. HISER: Yeah. I think that's 11 correct.
12 JUDGE McDADE: Okay, and then we have to 13 decide whether or not, as it currently exists, 14 things demonstrate that the effects of aging will be 15 managed during the period of extended operation.
16 But can we proceed?
17 JUDGE KENNEDY: I think that's good. Do 18 we want to keep going? I have just one additional 19 question for Dr. Hopenfeld. In your, I think it's 20 your initial testimony on page 39, you challenge the 21 effectiveness of Entergy's Aging Management Program 22 for Flow-Accelerated Corrosion, and you state it's 23 based on leaks and excessive wall thinning.
24 DR. HOPENFELD: Yes.
25 JUDGE KENNEDY: I think we've heard some Neal R. Gross & Co., Inc.
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Page 1687 1 testimony today. If you could sort of point us to 2 what information you used to come to that 3 conclusion, and maybe walk us through your thought 4 process, to get to what appears to be a very 5 extensive program not being effective.
6 JUDGE WARDWELL: What page number is 7 that?
8 JUDGE KENNEDY: I think it's page 39.
9 JUDGE WARDWELL: That must be in the 10 rebuttal.
11 JUDGE KENNEDY: Is it in the rebuttal?
12 DR. HOPENFELD: It's somewhere --
13 JUDGE KENNEDY: I think it's in the 14 initial.
15 JUDGE WARDWELL: I don't think the 16 initial goes to page 39. It doesn't.
17 JUDGE KENNEDY: Okay. Then it must --
18 let's check the rebuttal.
19 DR. HOPENFELD: Would I have an 20 opportunity to correct the record, as to what the 21 NRC stated now, what was done in connection with the 22 revision of GALL?
23 JUDGE KENNEDY: Let me first do one 24 thing. It is the rebuttal testimony, page 39.
25 DR. HOPENFELD: Okay.
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Page 1688 1 JUDGE KENNEDY: And did you ask a 2 question, Dr. Hopenfeld?
3 DR. HOPENFELD: I'm sorry?
4 JUDGE KENNEDY: You asked a question?
5 DR. HOPENFELD: No. I was asking would 6 I have an opportunity to comment on what was said by 7 the NRC later on? Whatever you want.
8 JUDGE KENNEDY: Would you like to do so 9 now?
10 DR. HOPENFELD: Yes, that would be fine, 11 before I forget. One thing, I well realize about 12 Revision 1, and let me tell you the history, a 13 little bit about the history. But first, it's a 14 moot point because Entergy stated in their statement 15 that they accepted in their compliance with Revision 16 2.
17 It's in there. So everything about 1801 18 and before is not really applicable there. They 19 accepted it; they agreed to it. They are in 20 compliance with it. That's what they said.
21 Secondly --
22 MS. SUTTON: Your Honor, Kathryn Sutton, 23 Entergy. We object to that statement.
24 JUDGE McDADE: Well, we're not going to 25 strike it. I mean the situation is the witness is Neal R. Gross & Co., Inc.
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Page 1689 1 testifying. The witness well could be wrong.
2 MS. SUTTON: And just mark our 3 objection, that he is not testifying on our behalf.
4 We do object to that.
5 JUDGE McDADE: I think it's quite 6 evident to the Board that he's not testifying on 7 your behalf, and Dr. Hopenfeld is stating what his 8 opinion is, and you certainly will have an 9 opportunity to disavow it. But right now, and we 10 can do it one of two ways.
11 We'll probably be asking follow-up 12 questions of your witnesses, and I would anticipate 13 they would disavow it, and before we're all done 14 with this, you'll have an opportunity to state from 15 a lawyer's standpoint, and disavow it yet again.
16 MS. SUTTON: Thank you, Your Honor.
17 JUDGE McDADE: Dr. Hopenfeld, continue.
18 DR. HOPENFELD: With respect to Revision 19 1, the original definition was confusing, because 20 bounding, what does it mean? It wasn't defined. So 21 I believe somewhere there, and you know how the 22 government works. You get it out, you get a lot of 23 comments.
24 And evidently, that document for 25 Revision 2 probably internally was circulating, and Neal R. Gross & Co., Inc.
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Page 1690 1 some of the initial circulation didn't indicate that 2 there were comments with regarding to the 3 conservatism. There were some other changes, but 4 there was not --
5 Just before I think it went out for 6 public comments, or maybe after it became public, 7 that thing was added, about that it has to be 8 conservative, or it has to be recalibrated. Now I 9 don't know who added it, because I think it was not 10 complete. But it was in the right direction.
11 I believe it is better than it was 12 previously, because it was open-ended. It's more 13 defined. It's still not close. It still needs some 14 fine-tuning, but I don't -- I don't think that they 15 should just scratch it. But you know, it's their 16 decision.
17 JUDGE McDADE: Okay.
18 MS. BRANCATO: Your Honor, this is 19 Deborah Brancato from Riverkeeper. I'd just like to 20 clarify, for the record, that in relation to Dr.
21 Hopenfeld's characterization of whether Entergy was 22 in compliance with GALL Revision 2, that is 23 contained in A35 in Entergy's testimony. So his 24 understanding is based upon his review of Entergy's 25 testimony.
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Page 1691 1 JUDGE McDADE: Okay. Let me just sort 2 of move on from here at the moment, okay. I mean 3 first of all, these individuals are testifying as 4 experts. They're testifying. For Dr. Hopenfeld, he 5 is recognized as an expert in Mechanical 6 Engineering. As far as what Entergy is required to 7 do and what they aren't required to do, that's our 8 job to figure it out.
9 Ms. Sutton's comment, I think, was well-10 taken, in that Dr. Hopenfeld was going beyond his 11 area of expertise. You as attorneys, before this is 12 over, will have an opportunity to comment, and ask 13 us to draw conclusions from the testimony that's 14 been presented by these experts, and what is 15 presented in the record by Entergy.
16 But you know, it's taken us enough time, 17 you know, trying to get through this, where we're 18 trying to limit the experts to engineering and 19 technical issues. If we allow them to opine on 20 legal issues as well, we'll be here way longer.
21 While we need them and rely on them as 22 experts in Mechanical Engineering and Nuclear 23 Engineering and Computer Science, you know, we can't 24 rely on them for compliance and legal issues. We 25 have to make up our own mind on that, and that's not Neal R. Gross & Co., Inc.
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Page 1692 1 subject to testimony. That said, Judge Kennedy.
2 JUDGE KENNEDY: I guess I'd like to take 3 us back to page 39 of the rebuttal testimony. If we 4 could bring that up. And again, my understanding in 5 reading that page of that testimony, you are 6 challenging the effectiveness of Entergy's Aging 7 Management Program for Flow-Accelerated Corrosion.
8 DR. HOPENFELD: Could you please amplify 9 a little bit? I can't read it.
10 JUDGE KENNEDY: Can we blow it up a 11 little bit.
12 DR. HOPENFELD: Yeah, blow it up a 13 little bit.
14 JUDGE WARDWELL: Which question are you 15 interested in?
16 DR. HOPENFELD: Which one are we talking 17 about?
18 JUDGE KENNEDY: Roll it up a bit. I'm 19 sorry. Scroll, roll it up. Page 39, please.
20 JUDGE WARDWELL: Yeah, that's the wrong 21 exhibit. It's 108. We're looking for 108.
22 DR. HOPENFELD: Which looks like it's 23 fatigue.
24 JUDGE WARDWELL: That's fatigue. That's 25 wrong.
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Page 1693 1 DR. HOPENFELD: This is metal fatigue.
2 That's the wrong one.
3 JUDGE McDADE: It's exhibit, Riverkeeper 4 Exhibit 108, page 39.
5 DR. HOPENFELD: Okay. I've got it now.
6 Okay. The question is with regard to the comments I 7 made, that they don't have an effective program 8 because there are leaks. There's no indication.
9 JUDGE KENNEDY: And I guess what I'm 10 wondering, there's no citation here to data. I'm 11 just wondering how you formulated this opinion, and 12 if the excessive wall thinning goes to your 13 testimony about the model deficiencies of CHECWORKS, 14 I don't think we need to revisit that.
15 So I guess what I'm asking is, do you 16 have anecdotal evidence of leaks that were not 17 managed effectively before the loss of intended 18 function, and do you have any evidence to put 19 forward of excessive wall thinning, beyond the 20 theoretical argument over the models.
21 DR. HOPENFELD: They have testified that 22 they had observed like 15 leaks over a certain 23 period of time. I don't remember what it was. Then 24 they also, and that really what got me there, when 25 they explained how they are trying to prevent those Neal R. Gross & Co., Inc.
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Page 1694 1 leaks from occurring, they said well, we located 2 components and are monitoring based on -- when we 3 observe a leak, then this is the database.
4 My point was in here, and that was the 5 main thing that I was thinking, you don't wait until 6 you have a leak to tell you that you've got to 7 monitor it. That was my thinking. Now again, the 8 bottom line is why they don't have an effective AMP 9 was one, as I said before, there are numerous 10 numbers.
11 If you go to the data, and you see where 12 they exceeded the critical --. There are comments 13 on it. I don't have it in front of me, but you go 14 through the data, and the data numbers you'll see, 15 because they have a number that is critical, 16 observed, and not observed.
17 You'll see that many of them were 18 observed, were exceeded. So I don't know what, what 19 part, the number of those components that are 20 measured versus the total number of components, 21 because they never told us.
22 But I assume, if it's based on the 23 philosophy that it is all corrosion control, and you 24 don't take into account the local effect, going back 25 to that, then there is a lot of unknown. You're Neal R. Gross & Co., Inc.
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Page 1695 1 running the plants in unknowable condition.
2 This one case that was brought in, it 3 could be an outlier. But the fact that you don't 4 know and you can't even measure it, because of 5 lamination, you still don't know what it is. So 6 it's all these unknowables put together, it gives 7 you the fact that you don't have a program.
8 JUDGE KENNEDY: So you would measure 9 effectiveness based on the components of the 10 program, either not predicting the right wear rate 11 or --
12 DR. HOPENFELD: Frequency.
13 JUDGE KENNEDY: And some leaking pipes 14 would be an effectiveness measure in your book?
15 DR. HOPENFELD: Leaking pipes would be 16 one of those, yeah, would be an indication that you 17 wait until a leak in the pipe. But, more important 18 than that, there was a statement made, and I can't 19 remember where it was, when it was clearly stated we 20 have thinning, wall thinning.
21 Then we're going to assess whether that 22 is adequate, as far as Part 50, which I mean as far 23 as local loads or earthquake loads --. You don't 24 wait until the thinning is, reaches that point, and 25 decide well, let's do some evaluation for that Neal R. Gross & Co., Inc.
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Page 1696 1 particular component. You should have criteria 2 before you get there. So that is an indication 3 there is no AMP program.
4 JUDGE KENNEDY: But they did detect the 5 wall thinning.
6 DR. HOPENFELD: I'm sorry?
7 JUDGE KENNEDY: They detected the wall 8 thinning before failure?
9 DR. HOPENFELD: Oh yes, yes. Many 10 times.
11 JUDGE KENNEDY: I guess maybe I'll turn 12 to the staff, just for some discussion about how 13 they would view the effectiveness. How would you 14 measure the effectiveness of a Flow-Accelerated 15 Corrosion Aging Management Program? If there's a 16 qualitative way you could describe what you would 17 believe to be the attributes of an effective 18 program.
19 DR. HISER: The attributes of an 20 effective program, I believe, are outlined in the 21 GALL report. In terms of assessing the 22 effectiveness of it, I think principally it would be 23 based on operating experience.
24 JUDGE KENNEDY: So it would be the 25 attributes of GALL, supported by operating Neal R. Gross & Co., Inc.
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Page 1697 1 experience?
2 DR. HISER: Right, that indicates that 3 they would have an acceptance criteria. If they 4 approach or exceed acceptance criteria, then they 5 take corrective actions such repair, replacement or 6 reanalysis, as suitable.
7 JUDGE KENNEDY: I mean I know it's 8 difficult, because we're not in the period of 9 extended operation. But there has been a Flow-10 Accelerated Corrosion Program currently in place at 11 Indian Point, and does the staff view that program, 12 under its current licensing basis, as effective?
13 DR. HISER: Oh I think even in the 14 safety evaluation report for license renewal, the 15 audit, I think we concluded that the program is 16 effective, yes.
17 JUDGE KENNEDY: All right, thank you.
18 MR. YODER: Also, the staff -- this is 19 Matthew Yoder, NRC staff. The staff had previously 20 reviewed the Indian Point Flow-Accelerated Corrosion 21 Program as part of the power uprates. So we 22 provided a safety evaluation at that time, stating 23 that we were satisfied with the Flow-Accelerated 24 Corrosion Program.
25 JUDGE McDADE: In his testimony, and Neal R. Gross & Co., Inc.
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Page 1698 1 also in his expert report that he submitted, which 2 is now Riverkeeper Exhibit 105, Dr. Hopenfeld 3 referred to instances at Indian Point, and also 4 instances at other facilities around the country, in 5 which inspections uncovered component wall 6 thicknesses below minimum allowable limits, 7 including leaks from components that resulted from 8 undetected flow accelerated corrosion.
9 In light of that, has that caused the 10 NRC staff to reconsider at all what its requirements 11 should be, as far as inspections and evaluation of 12 the impact of flow-accelerated corrosion?
13 MR. YODER: First, I would state that 14 I'm not sure that we have seen any evidence, the NRC 15 staff, that any leaks that have been identified by 16 the licensee were indeed attributed to flow-17 accelerated corrosion.
18 In other words, you know, these leaks 19 that have been discussed may have been caused by 20 another corrosion mechanism, which would not 21 necessarily be reflected in the FAC program.
22 JUDGE McDADE: Okay. Dr. Hopenfeld, going 23 back to your report and beginning -- your discussion 24 of this begins on page 17 of your report which is 25 Riverkeeper Exhibit 105, what is your basis there Neal R. Gross & Co., Inc.
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Page 1699 1 for saying that these failures, leaks, and 2 unacceptable thinning were the result of flow 3 accelerated corrosion?
4 DR. HOPENFELD: Well, first of all I 5 define flow accelerated corrosion different than 6 they do. I define it as erosion/corrosion, whatever 7 it is, it is. The wall thinning is going to not 8 listen to what NRC thinks it should be. The 9 erosion/corrosion is going to happen. Okay? And 10 that's what I'm talking about.
11 Now, when I say FAC I don't make a 12 distinction between this and the wall thinning. And 13 I think -- so, let me start there. Again, there were 14 15 leaks over a certain period of time. They were 15 reported. The explanation was given that -- one 16 explanation was given when a leak occurs we're using 17 as an indication where we should be looking for it.
18 And I'm saying that is not how you manage a program.
19 You try to avoid leaks, and you don't use a 20 definition, an arbitrary definition to tell you what 21 you should be looking -- having this part of your 22 program, and that part of the program.
23 And I'd like to congratulate the NRC.
24 They have a document out there for public comments.
25 I don't know if it -- it's in evidence I believe Neal R. Gross & Co., Inc.
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Page 1700 1 somewhere, where they said this whole issue of FAC 2 and wall thinning has been very confusing. It's not 3 consistent with what we have seen in the field. And 4 they redefined the thing that FAC covers everything, 5 the wall thinning -- actually, Part 54 controls it.
6 And Part 54 is not talking about FAC, how EPRI 7 decided to define it. It talks about wall thinning.
8 And I think NRC has gone in the right direction 9 doing that. It's out for public -- I believe it's 10 out for public comment. And when that has come out 11 it'll clarify some of what we're talking about here.
12 JUDGE McDADE: Okay. But, Dr. Hopenfeld, 13 then in your report where you characterize it as 14 undetected flow accelerating corrosion, you then 15 have several -- you have a citation then to several 16 reports. Is it your testimony now that those reports 17 don't necessarily use the same language that you do, 18 flow accelerated corrosion, that they maybe refer to 19 it as wall thinning from different phenomenon, 20 including --
21 DR. HOPENFELD: I would have to go look 22 at the specific reports that you're talking about.
23 But in general you are correct.
24 My thinking, I'm not making a 25 distinction. FAC as far as I'm concerned is Neal R. Gross & Co., Inc.
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Page 1701 1 erosion/corrosion. They can call it any way you want 2 to. I like to prefer calling erosion/corrosion, 3 because as I said before FAC, cavitation, droplet 4 impingement, they're all affected by flow. They are 5 all accelerated by flow, so the terminology is poor.
6 But forget about the terminology, it's 7 not important. What is important is that we don't 8 get ourselves confused. And what's confusing here, 9 very confusing, the fact we say oh, we put that 10 thing in a box. Well, this is FAC and I don't care, 11 I don't look at anything else. And I think NRC is 12 trying to correct that now.
13 JUDGE McDADE: Dr. Hiser, let me go to 14 you and ask, from your standpoint when you're 15 talking about flow accelerated corrosion from 16 speaking for the NRC, are we talking about corrosion 17 alone, are we talking about erosion, a combination 18 of the two, are we looking at wall thinning from any 19 phenomena, any source?
20 DR. HISER: Flow accelerated corrosion we 21 consider to be the chemical dissolution process, the 22 corrosion part that has been discussed the last two 23 days.
24 JUDGE McDADE: Not the mechanical forces 25 of erosion.
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Page 1702 1 DR. HISER: The FAC is not the erosion 2 forces. It's not mechanical wall thinning. The 3 License Renewal Interim Staff Guidance document, 4 just to correct a little bit of what Dr. Hopenfeld 5 said, the ISG does not broaden the definition of FAC 6 to include the mechanical wall thinning mechanisms.
7 But what it says is the FAC Program, the Aging 8 Management Program addresses wall thinning due to 9 FAC, but also due to the mechanical erosion sorts of 10 processes. So, the definition of FAC is still what 11 FAC has been, but the program, we agree, can address 12 some of the other wall thinning mechanisms.
13 JUDGE McDADE: Okay. Thank you, doctor.
14 JUDGE WARDWELL: How much has erosion 15 created problems in your experience at nuclear power 16 plants, and specifically Indian Point?
17 DR. HISER: I'm not aware of specific 18 operating experience at Indian Point, but the reason 19 that the ISG was developed was that in general we 20 expect that the mechanical erosion sorts of 21 mechanisms will be treated as a design concern and 22 will be addressed through changes in design.
23 What we found was that in some instances 24 plants have chosen to do aging management, so 25 they're aware that, for example, cavitation is Neal R. Gross & Co., Inc.
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Page 1703 1 occurring, but they've chosen instead of making 2 design changes, they monitor, do inspections, and 3 then replace components based on the inspection 4 results.
5 JUDGE WARDWELL: But is cavitation 6 erosion?
7 DR. HISER: Cavitation creates wall 8 thinning from an erosion mechanism, yes.
9 JUDGE WARDWELL: So, it would be lumped 10 in with erosion? I always envision erosion as being 11 a mechanical shearing, if you will, of the wall, and 12 now we have cavitation, we have impingement, and we 13 have dissolution, classical corrosion.
14 DR. HISER: I guess what I would probably 15 say is if we separate chemical wall thinning from 16 mechanical wall thinning, and lump in the mechanical 17 as erosion, cavitation, droplet impingement, et 18 cetera, those kinds of things, within the ISG we 19 have determined that because the FAC program is 20 based on inspections of the wall thickness, the wall 21 thickness measurements don't know that any wall 22 thinning has been due to chemical or mechanical 23 processes, so it measures everything.
24 The one distinction that I think we make 25 in the Interim Staff Guidance is that the modeling, Neal R. Gross & Co., Inc.
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Page 1704 1 the predictive modeling is only for the chemical 2 wall thinning, because CHECWORKS only models the 3 chemical dissolution sort of process. It does not --
4 5 JUDGE WARDWELL: But not absolutely 6 because it does have this line correction factor in.
7 Doesn't that account for whatever wearing is 8 occurring, just as you state?
9 DR. HISER: I think that's another way --
10 one could interpret the LCF that way, that it does 11 -- clearly, since it's based on the inspection 12 measurements of wall thinning, and they cannot 13 differentiate chemical wall thinning from 14 mechanical, then it is somewhat embedded. But I 15 think in terms of the base predictive methodology, 16 the equation with the F factors that does not 17 clearly predict cavitation or the mechanical wall 18 thinning --
19 JUDGE WARDWELL: Is there an Aging 20 Management Program for the mechanical wall thinning 21 on its own?
22 DR. HISER: I would -- I guess I would 23 address that a couple of different ways. One is that 24 if things like cavitation are identified, and I 25 think they are noticeable beyond doing inspection Neal R. Gross & Co., Inc.
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Page 1705 1 just due to the noise and things like that, then 2 normally design changes are made, maybe different 3 materials, some change is made to eliminate the 4 mechanism. So, from that perspective it tends not to 5 be a License Renewal and Aging problem, because it's 6 remedied upon detection.
7 ASME Code inspections and things like 8 that would also serve to identify wall thinning due 9 to erosion. But, in general, I think there are 10 design changes that are made to eliminate the 11 mechanism.
12 JUDGE McDADE: But, Dr. Hiser, as I 13 understand what you just said, that for wall 14 thinning that is caused by mechanical phenomenon it 15 can be from the NRC's standpoint adequately 16 addressed either through design changes, or it can 17 be addressed through an AMP.
18 DR. HISER: The ISG to modify the FAC AMP 19 does allow license, or applicants to incorporate the 20 mechanical wall thinning mechanisms.
21 JUDGE McDADE: Now, as part of that AMP 22 would they need to have a mechanism in place for 23 identifying the potential areas of mechanical -- of 24 wall thinning through mechanical phenomenon?
25 DR. HISER: The answer to that is yes. If Neal R. Gross & Co., Inc.
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Page 1706 1 you look at the description even of the current FAC 2 program, it has three essential elements. One is 3 performing an analysis to determine critical 4 locations. Now, for FAC, CHECWORKS is normally used 5 to do that along with the other tools that Entergy 6 has described.
7 The second element of the FAC program is 8 limited baseline inspections to determine the extent 9 of thinning at these locations, so that's 10 inspection-based again. And then third is follow-up 11 inspections to confirm the predictions, or repair or 12 replacing components is necessary. So, there's three 13 elements. Two of them would apply to any wall 14 thinning mechanism. The first one of identifying 15 locations would require some sort of an engineering 16 evaluation for cavitation, for example, for the 17 mechanical wall thinning mechanisms so that one 18 could identify those areas that should be inspected.
19 JUDGE WARDWELL: How would you suggest 20 handling localized turbulence that may cause erosion 21 that is hypothesized by Riverkeeper?
22 DR. HISER: I really don't have an answer 23 for that. But I think in general, I think the 24 expectations is that with highly localized phenomena 25 like that, that the leaks that would occur would not Neal R. Gross & Co., Inc.
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Page 1707 1 challenge the functionality of the components.
2 Conversely, FAC tends to be a broader 3 surface area that's affected, and as the failures as 4 Surry and Mihama indicated, they have catastrophic 5 consequences. Small leaks that may occur from highly 6 localized degradation are a concern, but the safety 7 implications are much less.
8 JUDGE WARDWELL: When you said you're not 9 sure how to answer that, that implies to me, and 10 correct me if I'm wrong, that someone might 11 interpret that to mean you aren't concerned with 12 localized failure -- potential wall thinning, and 13 that -- nor that you have either a design element 14 that would address that as part of current licensing 15 basis, and those activities, or an Aging Management 16 Program system established to address that issue.
17 Why am I wrong in that interpretation?
18 MR. YODER: If I could help, this is 19 Matthew Yoder from the Staff. I think that the 20 Staff's position is similar to what you heard from 21 the Applicant's witnesses, in that we don't believe 22 that you have flow-accelerated corrosion as well as 23 these what we termed local effects such as erosion 24 or droplet impingement occurring in the same 25 location.
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Page 1708 1 What we've said in the Interim Staff 2 Guidance is, and I'll quote directly from that, "For 3 erosion mechanisms, the program includes the 4 identification of susceptible locations based on 5 plant-specific or industry operating experience. If 6 wall thinning due to an erosion mechanism, e.g.
7 cavitation, flashing droplet impingement, or solid 8 particle impingement is identified, then the 9 Applicant performs an extensive condition review to 10 identify other components that are comparably 11 susceptible to the same mechanism." So, I believe 12 that sums up the NRC Staff's position on all of 13 those localized effects.
14 And I think as we heard from the 15 Applicant's witnesses I believe yesterday, that's a 16 separate program from what is dealt with in 17 CHECWORKS, and it relies solely on operating 18 experience and engineering judgment as the means to 19 identify those locations.
20 JUDGE WARDWELL: And are those part of 21 the FAC AMP, or are those --
22 MR. YODER: As the AMP is currently 23 written in GALL Rev 2, it is not included in that.
24 Many licensees have chosen to include in their flow-25 accelerated corrosion AMP those mechanisms. Other Neal R. Gross & Co., Inc.
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Page 1709 1 licensees have chosen to have those as a separate 2 plant-specific program to monitor and trend those 3 degradation mechanisms.
4 JUDGE WARDWELL: Refresh my memory, what 5 has Entergy done for Indian Point? And if you don't 6 know, then I'll ask them.
7 MR. YODER: I think we'd kick that one to 8 the Applicant, if you don't mind.
9 JUDGE WARDWELL: Anyone on the 10 Applicant's set of witnesses would like to address 11 that question?
12 MR. COX: Well, I think the examples in 13 our experience have been very few where you've had 14 these other mechanisms acting. I think feedwater 15 heater shells are one example where you have 16 potential droplet impingement. There may also be 17 some flow-accelerated corrosion going on there, but 18 that is an example of operating experience where 19 we've added things to the Flow-Accelerated Corrosion 20 Program to address a mechanism that may not be 100 21 percent flow-accelerated corrosion.
22 So, I think as the Staff indicated, 23 operating experience, and the review of that 24 operating experience is the primary analysis method 25 that we would use to pick up any examples of Neal R. Gross & Co., Inc.
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Page 1710 1 erosion, local erosion due to other effects other 2 than FAC.
3 DR. HOROWITZ: Jeff Horowitz. Two things 4 about that. Number one, EPRI has put out some recent 5 publications dealing with erosion and where to look, 6 so I think that the industry will be fairly well 7 covered by those publications.
8 Secondly, the operating experience has 9 been, as confirmed by one foreign utility, told us 10 that erosion is an availability issue much more in 11 the site. You get small holes, you shut the plant 12 down. That's a problem. There has not been to my 13 knowledge any significant erosion failures such as 14 Surry, such as Mihama, such as whatever, as long as 15 I've gone back and looked.
16 MR. COX: And this is Alan Cox, again. I 17 would agree with that. I'd like to add one thing, 18 and Dr. Hiser mentioned this, that the whole issue 19 of flow-accelerated corrosion has become what it is 20 because of the catastrophic failures. And it's, as 21 he explained, it could considered local corrosion to 22 a component, but it's fairly widespread within the 23 component. So, you wind up with a large area that 24 sometimes gets very thin until it reaches a point 25 where it ruptures in a fish mount or a double-ended Neal R. Gross & Co., Inc.
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Page 1711 1 shear. It's a catastrophic failure.
2 The erosion mechanisms that we're 3 talking about here particularly much more localized, 4 and you're not going to fail the entire component.
5 You're going to have a leak. You're going to be able 6 to detect that, take corrective action, but you're 7 not going to have the kind of failures that you 8 would get from a FAC failure of a large component 9 that has widespread thinning in an elbow, for 10 example.
11 JUDGE WARDWELL: But in regards to my 12 question, as it currently stands you don't have any 13 extensive program associated with localized erosion 14 types of failures in either your FAC or in your 15 design basis approach to managing that?
16 MR. AZEVEDO: Your Honor, this is Nelson 17 Azevedo for Entergy. We do have cases where we have 18 mechanical erosion going on when it's the auxiliary 19 feedwater system. We do perform inspections and we 20 track that in the FAC Program. And the location is 21 selected just like FAC locations. The only exception 22 is we obviously don't have CHECWORKS so we don't 23 have a predictive model, but we use operating 24 experience, we using engineering judgment, and we 25 select those locations and we inspect them and we Neal R. Gross & Co., Inc.
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Page 1712 1 track them in the FAC Program. That's the one 2 example where there's mechanical erosion going on, 3 not FAC. And we do keep track of it in the FAC 4 program.
5 JUDGE WARDWELL: Thank you. I'm good. I'm 6 done.
7 JUDGE McDADE: It's almost 3:30 right 8 now, 3:25. It may be appropriate for us to take 9 about a 10-minute break. Please try to be back in 10 10 minutes, and we will start up again at 3:35. Thank 11 you.
12 (Whereupon, the proceedings went off the 13 record at 3:26 p.m., and went back on the record at 14 3:40 p.m.)
15 JUDGE McDADE: The hearing will come to 16 order. We're back on the record. Judge Kennedy.
17 JUDGE KENNEDY: I have a question on the 18 Staff's pre-filed testimony. I believe it's page 7, 19 if you could put that exhibit up. I don't have the 20 exhibit number.
21 JUDGE McDADE: NRC-120. We're still 22 getting to NRC-120.
23 MR. TURK: Your Honor, I believe it's 24 121.
25 JUDGE KENNEDY: Thank you. Yes, 121, page Neal R. Gross & Co., Inc.
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Page 1713 1 7. What I'm looking for and I don't see it -- oh, 2 here it is. In the middle paragraph there's a --
3 yes, thanks. The third sentence that begins, "The 4 FAC Program." "The FAC Program and the 5 implementation of CHECWORKS at Indian Point were 6 important parts of the NRC approval of power uprate 7 and associated change to the licensing basis for IP2 8 and IP3, but were not re-reviewed as part of the 9 license renewal review." I guess I'm curious what 10 that means, and what the import is relative to this 11 proceeding, if any.
12 MR. YODER: This is Matthew Yoder from 13 the Staff. I think that what we're trying to say 14 with that statement is that we did not review the 15 current licensing basis as part of this license 16 renewal application. We did go back and familiarize 17 ourselves with previous reviews related to the 18 technical programs that were associated with this 19 license renewal application, but we did not base any 20 decisions on license renewal on the current 21 licensing basis, including those uprate reviews.
22 JUDGE KENNEDY: So, the Staff did re-23 review the CHECWORKS implementation as part of 24 license --
25 MR. YODER: The Staff did go back and Neal R. Gross & Co., Inc.
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Page 1714 1 read all of those previous flow-accelerated 2 corrosion-related applications and subsequent safety 3 evaluations.
4 JUDGE KENNEDY: Under the license renewal 5 review.
6 MR. YODER: As part of our review of the 7 License Renewal Application.
8 JUDGE KENNEDY: All right, thank you.:
9 JUDGE McDADE: Wall thinning as a 10 phenomenon would necessarily be a ongoing process; 11 therefore, when the plant was originally licensed, 12 the original current operating basis was established 13 at licensing. All of the pipes in the facility were 14 new.
15 At the time of the extended operation, 16 if granted, all of the pipes that have not been 17 replaced would already have had 40 years of wear.
18 You indicated that their FAC Program was not 19 reviewed as part of the license renewal, but 20 wouldn't it be necessary to review a Aging 21 Management Program for FAC specifically because all 22 of the piping already had up to 40 years of age in 23 it? Is this saying you didn't look at the Aging 24 Management aspects of it?
25 MR. YODER: No, I think what I'm trying Neal R. Gross & Co., Inc.
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Page 1715 1 to say is that we went into the License Renewal 2 Application and gave that a clean look independent 3 of what had previously been approved under the 4 current licensing basis. That's not to say that we 5 discounted any wear that had occurred prior to this 6 application. So, the fact that these pipes have been 7 in service was certainly taken into account as part 8 of our review for license renewal.
9 JUDGE McDADE: Okay. But I think the 10 thing that had confused me, and I thought it had 11 confused Judge Kennedy, is the language in here 12 "were not reviewed as part of the license renewal 13 review." And it would seem like the Aging Management 14 Plan necessarily would be part of that review. Was 15 it?
16 DR. HISER: This is Allen Hiser of the 17 Staff. I think the AMP we did review. There was -- I 18 think there was a presumption that because the 19 program is a continuing existing program without 20 modifications, then we did not go back and review in 21 gory detail the FAC Program itself.
22 Now, during the AMP audit we did go back 23 and review some of the underlying documents, such as 24 the EN-DC-315, and some of the other procedures just 25 to provide us with, if you will, additional Neal R. Gross & Co., Inc.
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Page 1716 1 assurance that the program would continue to be 2 effective during the PEO. So, I think that is what 3 that wording is trying to indicate, that we did not 4 go through and do a rigorous from the bottom up 5 review of the program because it has been a 6 longstanding program that has received review 7 initially with the Generic Letter responses up 8 through the power uprate reviews that were 9 performed.
10 JUDGE McDADE: Okay. Because on the face 11 of it, it would appear inconsistent with what you 12 had described earlier as part of the AMP audit that 13 was conducted. And you're indicating that it's 14 perhaps misleading saying not re-reviewed. You're 15 saying it wasn't reviewed in the same way it would 16 have been reviewed in a new license situation.
17 DR. HISER: I think that's correct, yes.
18 That's the way the wording -- that's the way we 19 interpreted it, but I can easily see how the wording 20 is not that clear.
21 JUDGE McDADE: Okay. But there was a full 22 AMP audit from your standpoint, and the Staff 23 satisfied itself as part of that review that given 24 the age of the facility and that the piping would be 25 going from 40 to 60 years, that the program would be Neal R. Gross & Co., Inc.
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Page 1717 1 adequate to maintain the reasonable assurance that 2 they would operate appropriately and serve their 3 intended purpose during that extended period of 4 operation.
5 DR. HISER: That's correct. I would agree 6 with that.
7 JUDGE McDADE: Okay. Thank you, Dr.
8 Hiser.
9 JUDGE WARDWELL: In that regard, I'd like 10 to reflect back to yesterday, and you made the 11 statement that you've performed an audit of Indian 12 Point or something like that. And you quickly said 13 something about either it was an 1170 audit, or that 14 it wasn't an 1170, or maybe that isn't even the 15 right number. But you were alluding to some sort of 16 more detailed audit that other staff members may 17 have been performing. And I wanted some 18 clarification on what have you done at Indian Point 19 to audit their AMP for flow-accelerated corrosion, 20 and how does it compare to what you kind of alleged 21 was some more detailed review, as I interpreted what 22 you were saying yesterday?
23 DR. HISER: Okay. Neither myself, nor I 24 believe Mr. Yoder performed the AMP audit, but the 25 NRC Staff did an AMP audit that went into a high Neal R. Gross & Co., Inc.
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Page 1718 1 level of detail on the program. And that's reflected 2 in our testimony through the reference to the AMP 3 audit report, and then also in the SER. There are 4 many parts of that report that are extracted and 5 used in the SER to demonstrate acceptability of the 6 program.
7 What I may have mentioned is Inspection 8 Program or IP71003 Inspection, and that will be 9 implemented prior to PEO. Generally, it's 10 implemented prior to PEO just to insure that the 11 implementation of the AMPs, that the 12 Applicant/Licensee is ready to implement those 13 during the PEO.
14 JUDGE WARDWELL: And is that a more 15 extensive inspection than what the Staff has current 16 done just to audit the AMP? That's what's kind -- I 17 got the --
18 DR. HISER: It really is different. The 19 AMP audit is looking at is the program a program 20 that's consistent with GALL. If implemented 21 appropriately, will the program be effective?
22 IP71003 Inspection takes it past philosophical, if 23 you will, to do they have the right procedures in 24 place for an existing program? They would take a 25 look at operating experience, things like that to Neal R. Gross & Co., Inc.
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Page 1719 1 verify the fact that the AMP has been, or is ready 2 to be implemented for the PEO. So, there's different 3 -- they're really shooting at different targets in 4 this case.
5 JUDGE WARDWELL: The AMP audit that the 6 Staff performs as part of license renewal is 7 documented where?
8 DR. HISER: The AMP audit is documented 9 in the Audit Report.
10 JUDGE WARDWELL: Do we have that as an 11 exhibit?
12 DR. HISER: Yes, it is one of the 13 exhibits. That should be I believe Entergy 00041.
14 JUDGE WARDWELL: Have you got that, EN-15 41.
16 MR. TURK: Your Honor, we need to verify.
17 Sherwin Turk. Give us a moment, we'll see if that's 18 correct.
19 JUDGE McDADE: I'm sorry, Mr. Turk. I 20 didn't hear what you said.
21 JUDGE WARDWELL: In the process he --
22 well, there it is. It's up before you so now you 23 can -- the full page on that, please. Yes. So, is 24 that correct, Dr. Hiser?
25 DR. HISER: Yes, that's correct.
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Page 1720 1 JUDGE WARDWELL: And that document is 99 2 pages long.
3 JUDGE McDADE: Are you taking that just 4 on Judge Wardwell's word?
5 JUDGE WARDWELL: I know, because it says 6 99 next to the arrow there. Let's drop down to the 7 Table of Contents, just for interest. No, keep it a 8 full page. We don't want to get the detail. Just 9 scroll down another page. Okay.
10 I'm back to -- and I'm trying to tie the 11 loop and complete the stuff I didn't get done 12 yesterday, I guess. And I didn't have a chance to 13 ask you the same thing I asked Entergy, and that is 14 how many plants have you been participating in in 15 regards to flow-accelerated corrosion AMPs?
16 DR. HISER: Myself, personally, maybe 17 eight or ten.
18 JUDGE WARDWELL: Okay. How do the AMPs 19 differ from the one that Indian Point has submitted?
20 DR. HISER: In general, they're very 21 consistent. Actually, let me clarify one thing. I 22 was the Branch Chief of the Engineering Branch that 23 reviewed the FAC Program at Indian Point, so I did 24 not do the review myself, but I reviewed --
25 JUDGE WARDWELL: You're familiar with it.
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Page 1721 1 That's all I'm after.
2 DR. HISER: Yes. It's very consistent.
3 Again, this is -- the FAC Program is an existing 4 program established across the industry in the late 5 `80s, so it's a longstanding program, and has had 6 really a lot of stability overall.
7 JUDGE WARDWELL: On a scale of gee, it's 8 very similar to almost identical where would you 9 place all those AMPs?
10 DR. HISER: You mean from the various 11 plants?
12 JUDGE WARDWELL: Yes.
13 DR. HISER: I think --
14 JUDGE WARDWELL: Close, would it be fair 15 to say they're close to identical?
16 DR. HISER: They're very, very similar, 17 yes.
18 JUDGE WARDWELL: Because they're just --
19 DR. HISER: 90 percent -- right.
20 JUDGE WARDWELL: Yes, they're really 21 repeating GALL back.
22 DR. HISER: They're repeating GALL back, 23 and GALL describes the programs that came out of the 24 Generic Letters, and other generic correspondences 25 from the late 1980s.
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Page 1722 1 JUDGE WARDWELL: As a for instance, could 2 you convey to me why it is unfeasible to summarize 3 a part of this audit report and put it into an AMP 4 to make it a little more site-specific, or 5 infeasible, depending upon what is the correct 6 English, or not feasible.
7 DR. HISER: As an NRC Staff member, I 8 guess my only --
9 JUDGE WARDWELL: No, as a technical 10 person involved with this, and as one who is 11 experienced based on your demeanor and your 12 expertise conveyed here, it's clear you are, you 13 clearly are experienced, expert who might want to 14 see some of this if it was in an area you weren't 15 involved with. Would it not be feasible to do that?
16 DR. HISER: I guess what -- if I can 17 answer in two parts. The first part would be the AMP 18 audit report is publicly available, and it really 19 does provide a lot more information than likely 20 would ever be in the application. The Safety 21 Evaluation Report provides a lot of detail beyond 22 what is in the application, so with those as caveats 23 I would say there is a lot of information that is 24 available. Would it be possible to provide more 25 information in the application? Yes, I think it Neal R. Gross & Co., Inc.
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Page 1723 1 clearly would be possible to do that.
2 JUDGE WARDWELL: And one would be just 3 summarizing aspects of the audit report. I've taken 4 the whole 99 pages because that would be 5 unreasonable in my mind.
6 DR. HISER: Right.
7 JUDGE WARDWELL: Thank you.
8 MS. SUTTON: Your Honor, Kathryn Sutton 9 on behalf of the Applicant. Just one point of 10 clarification. The AMP audit report comes after in 11 time, after the application is submitted and prior 12 to issuance of the FSER.
13 JUDGE WARDWELL: And recognizing that 14 these don't come out at the same time, but still 15 these types of information is feasible to put in to 16 make it more site-specific, because you're aware of 17 what's going on there because you've had a program 18 in existence there that is merely being carried 19 forward. So, in fact, you probably didn't discover 20 much in your audit report that wasn't already known 21 based on your previous experience base that you had 22 for over a decade at the plant.
23 DR. HISER: Although much of the 24 information would have been available to the Staff 25 based on prior interactions, reviewing Generic Neal R. Gross & Co., Inc.
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Page 1724 1 Letter responses and things like that, the AMP audit 2 is still -- is a fairly thorough review of what the 3 -- how the Aging Management Program is implemented 4 at the plant.
5 JUDGE WARDWELL: I was merely using that 6 as an example of some information that's available 7 that again not you have to put in the AMP, but that 8 you would ask the Applicant to do so that that would 9 be information available to people to understand 10 better how it is applied specifically to Indian 11 Point. It's feasible to do that from a technical 12 basis.
13 DR. HISER: Yes. From the Staff 14 perspective, because we do the AMP audit under a 15 presumption that the program is consistent with 16 GALL, we have access to that information.
17 JUDGE WARDWELL: Thank you. Entergy, I 18 guess I'll let whoever wants to answer this question 19 answer it, but it came up yesterday and we really 20 got busy with this topic, and I wanted to get back 21 to it again. And that was the grid size that we 22 showed over an elbow. There was a -- we looked at 23 one figure that showed the grid size, and the size 24 was predicated on the suggested values based on the 25 pipe diameters or something like that.
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Page 1725 1 Was any engineering judgment used in 2 changing the grid size, or altering it, or do you 3 often do that for components that aren't just 4 straight line pipes?
5 MR. AZEVEDO: Your Honor, this is Nelson 6 Azevedo for Entergy. We use the grid size specified 7 in NSAC-202L and in EN-DC-315. If we find signs of 8 wear or signs of flow-accelerated corrosion going --
9 wall thinning, we do go back and we either do grid 10 scans or we do micro grids. In other words, we use 11 the smaller grid size, but if all the inspections 12 come back and they're consistent, then we just use 13 the grid size that we started out with.
14 JUDGE WARDWELL: Thank you. Dr.
15 Hopenfeld, I wrote down things that you said that 16 you were concerned about. And you said this is what 17 I'm really concerned about, and later on today you 18 say something else, and so I tried to jot those 19 down. And here are some of the ones I've got.
20 You mentioned concerns about turbulence, 21 and that's localized erosion types of stuff caused 22 by that turbulence. And that leads into the whole 23 definition and whether erosion is part of corrosion 24 was a concern of your's with this local phenomenon.
25 The other one I heard you say is about Neal R. Gross & Co., Inc.
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Page 1726 1 the chromium content, and understand the chromium 2 content. What I didn't hear you say, and I want to 3 make sure that it isn't a concern, or if it is let's 4 pursue it more, is something that was covered in 5 your testimony. And this is the lack of benchmarking 6 of CHECWORKS. Based on the direct testimony, has 7 that started to drop down the ladder of your 8 concerns? Is it not a concern any more, or is it 9 still an issue?
10 DR. HOPENFELD: Can I answer?
11 JUDGE WARDWELL: Yes.
12 DR. HOPENFELD: It originally was a 13 concern. That's where the whole thing started. When 14 I started -- after looking at 7,000 data points and 15 after trying to get -- and I realized that some data 16 points were going back to `92, we asked to see --
17 let's see, compare the history of this. So, we 18 asked Entergy to provide us data for prior to 2000, 19 and they said we lost that. We don't have it, and 20 it's misplaced, so we went and appealed to get the 21 data. And they said it was denied.
22 So then in the -- recently in their 23 statement said well, we gave you all the data. It's 24 somewhere among these points. I can't go -- no human 25 being can go through these numbers and say yes, this Neal R. Gross & Co., Inc.
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Page 1727 1 came from 1991, December `91, Christmas `95. You 2 can't say that. How I am supposed to go and tell you 3 where this come from? And that's what the gentleman 4 said, well, some of it was in `92. Can you tell 5 which one?
6 So, the issue came here after looking at 7 all the data, and 40 to 60 percent of the time it 8 was non-conservative. And I still believe the non-9 conservative thing is the right engineering 10 approach, because all these things are not 11 perspective. You have to have a non-conservative 12 approach to this because there are so many 13 assumptions, so many unknowns, so do the non-14 conservative thing.
15 JUDGE WARDWELL: Can I just interrupt you 16 quickly? I have no problem with what you're saying.
17 What I would like you to do, though, is answer my 18 question and then go on and elaborate.
19 DR. HOPENFELD: Yes, I was just stating -
20 -
21 JUDGE WARDWELL: Is benchmarking still an 22 issue, or have you been satisfied that it isn't any 23 issue any more with --
24 DR. HOPENFELD: I don't think it's an 25 issue because it's impossible to benchmark it any Neal R. Gross & Co., Inc.
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Page 1728 1 more.
2 JUDGE WARDWELL: Why do you say that?
3 DR. HOPENFELD: Because when you look at 4 7,000 points and all of them are not -- are 5 scattered all over the place, and you look at the 6 basic assumptions, there's no way to recalibrate it.
7 If you don't know the chromium within a factor of 8 10, even with the same line, this component might 9 have .05 and this one may have .02. How are you 10 going to recalibrate something like that?
11 JUDGE WARDWELL: Is there -- what's the 12 difference between benchmarking and calibrating? I'm 13 sorry.
14 DR. HOPENFELD: I really don't know. I 15 would -- my understanding is if you write F=AMX and 16 then you say it's semi-empirical, I don't have 17 empirical value to it. Then you run a whole bunch of 18 tests and try to fit X with the data, and you call 19 it calibrated. Now, benchmarking, I looked it up 20 once but I don't know there's a major difference 21 here.
22 JUDGE WARDWELL: How would you benchmark 23 this if you were going to do it?
24 DR. HOPENFELD: I don't think --
25 JUDGE WARDWELL: You're saying it's Neal R. Gross & Co., Inc.
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Page 1729 1 impossible. How would you?
2 DR. HOPENFELD: I wouldn't know how to do 3 it. Oh, how? If I knew what the chromium content is, 4 and forgetting -- assuming the measurements are 5 okay, let's say they're all what I showed you, this 6 lamination and -- not important. But assuming the 7 measurements are okay, you have to know the chromium 8 first. If you don't know the chromium, there's no 9 way of doing.
10 Secondly, you have to redefine what 11 you're looking for. What is wall thinning? It's --
12 the NRC defined it originally, didn't really define 13 it but now they keep to the definition that FAC is 14 only dissolution control. I showed you there's a 15 factor of 50 there difference between a straight 16 wall and an elbow. And it would be physically 17 impossible, that kind of thing would be dissolution 18 control. So, they don't separate the two. I think --
19 I get my retirement from the NRC, let me give you -
20 - I would give them indirectly advice. Start from a 21 clear definition. Don't patch up what you had 22 before.
23 Originally, the definition was 24 incorrect. I think they are trying to patch it up 25 now. I would go and redefine what really wall Neal R. Gross & Co., Inc.
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Page 1730 1 thinning is. That's what you're interested. I don't 2 care what caused that wall thinning. You want to 3 come up with a program, call it any way you want to.
4 This is wall thinning. Know what -- independently 5 what the mechanism is.
6 And what I was trying to show you with 7 those numbers yesterday, that there's no way of 8 distinguishing the two. Secondly, if you do 9 mineralography on this, after you take and cut it 10 out and look at it, you couldn't tell whether it was 11 -- to some degree you could. You'd get some expert, 12 and some degree you could, but not that easy whether 13 it was erosion, corrosion, or whatever it was. It's 14 the wall thinning that's important. That's why 15 recalibration doesn't mean anything.
16 JUDGE WARDWELL: So, this is really a 17 challenge to CHECWORKS as a whole applied to all 18 plants in the United States then. It's not unique to 19 Indian Point, is it? Because it couldn't be done at 20 Vermont Yankee or Indian Point, doesn't that say it 21 probably can't be benchmarked anywhere?
22 DR. HOPENFELD: I think it's an important 23 question. I really should address that. And I focus 24 on Indian Point, and Vermont -- although Vermont not 25 that long. But I did focus on this particular plant Neal R. Gross & Co., Inc.
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Page 1731 1 for several reasons, because I got a lot -- they did 2 give me a lot of data. After a lot of struggling we 3 did get some data, so I did focus on that.
4 But I have seen other data from other 5 plants. In fact, they have been shown to the ACRS.
6 And one of the ACRS members just threw his hand, 7 said I don't believe, it doesn't make any sense.
8 It's in the record.
9 JUDGE WARDWELL: So, you have no reason 10 to believe the same problem doesn't exist at other 11 plants.
12 DR. HOPENFELD: I do believe from what 13 I've seen that basically the same problem exists in 14 all of them. But, you see, the thing is, to a large 15 degree these people applying it as some kind of a --
16 mainly, it has been conceived for many years that 17 it's primarily a cost problem, so it was kind of 18 treated as a second cousin. It wasn't treated as a 19 serious safety issue. I think there is a line here 20 that we're getting into that 60-year life, that I am 21 not sure that that cost issue is the only one.
22 That's the point.
23 I look into the sewers. I look in 24 Rockville. We get blowing up pipes all over the 25 place, and they've been there over -- I understand Neal R. Gross & Co., Inc.
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Page 1732 1 that that's not the same thing as a power plant. But 2 the aging issue is the same thing. You go to power 3 plants, non-conventional -- non-nuclear power 4 plants. Their major deterioration -- one of the 5 major cause is FAC. They call it wall thinning, I 6 don't know, whatever you call it. But it is a cost 7 problem primarily, but I --
8 JUDGE WARDWELL: I guess I don't 9 understand why it's a cost problem in regards to the 10 calibration of CHECWORKS.
11 DR. HOPENFELD: I'm sorry. You asked me 12 what -- how does it affect other plants.
13 JUDGE WARDWELL: Right.
14 DR. HOPENFELD: What I'm saying --
15 JUDGE WARDWELL: Let me be more specific 16 then. I guess I wasn't clear enough. The problem 17 that you've addressed here that you concluded that 18 CHECWORKS can't be benchmarked so it's not a concern 19 any more --
20 DR. HOPENFELD: Correct.
21 JUDGE WARDWELL: -- because you've 22 thrown up your hands and said it really can't be 23 benchmarked.
24 DR. HOPENFELD: Correct.
25 JUDGE WARDWELL: Doesn't that apply -- do Neal R. Gross & Co., Inc.
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Page 1733 1 you have any evidence to show that that doesn't 2 apply to every plant in the United States?
3 DR. HOPENFELD: No, I do not. I do not. I 4 haven't looked.
5 JUDGE WARDWELL: So, there's every 6 indication that, in fact, they're going to have the 7 same situation.
8 DR. HOPENFELD: I suspect that's the 9 case, but I'm not going to say that.
10 JUDGE WARDWELL: So, it is a global 11 problem.
12 Entergy, whoever wishes to address this.
13 JUDGE McDADE: Before you go to Entergy, 14 if I could just follow-up quickly with Dr.
15 Hopenfeld. Doctor, from your earlier testimony, 16 direct testimony, sworn testimony, written report, 17 it appeared that your concern or a concern you had 18 on benchmarking was that there was insufficient 19 data; that since the power uprates at Indian Point 20 there have been insufficient data points from which 21 an expert could conclude or could make a reasonable 22 estimate as to the effectiveness of the program.
23 Okay. And I thought you had testified yesterday with 24 regard to discussing with Judge Wardwell about 25 programs that are used elsewhere. And I think there Neal R. Gross & Co., Inc.
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Page 1734 1 was one -- a program, CICERO I believe it was 2 referred to.
3 DR. HOPENFELD: It was a different name, 4 but close enough.
5 JUDGE McDADE: That you thought was more 6 effective not because it had more data points, but 7 because it was more sophisticated. It had more input 8 parameters into it.
9 DR. HOPENFELD: Yes.
10 JUDGE McDADE: And what I'm trying to 11 understand right now is, is it your position now 12 that CHECWORKS is deficient because there are not 13 enough input parameters, or is it because there's 14 not enough data input, or a combination of both?
15 DR. HOPENFELD: I think the input 16 uncertainty is a major uncertainty, a major 17 contribution to this. If you have the input, let's 18 say for some reason they would measure the chromium 19 content the way the French do, and use that in that 20 F3, I mean, one of those, and use that, that would 21 improve it. The second thing that I don't know how 22 you improve is when you go through this very high 23 turbulence, local thing in an orifice, an elbow, 24 downstream, that is not fixable. That you cannot 25 fix. So, you can recalibrate it. And the proof of Neal R. Gross & Co., Inc.
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Page 1735 1 that is they've been working on it for 20 years and 2 you look before they operate and after they operate, 3 there's absolutely no difference.
4 JUDGE McDADE: Okay. When you say you 5 can't fix it, are you saying that you can't fix it 6 in the context of a computer code, or are you saying 7 you can't fix it at all? In other words, I believe 8 the testimony of the Entergy representatives were 9 that for that kind of turbulence, those kinds of 10 mechanical causes of wall thinning, they use 11 different. They don't use CHECWORKS. They have 12 several other engineering forms of analysis to 13 identify those areas that would be subject to this 14 wall thinning through a mechanical phenomenon. Why 15 would that not be adequate for mechanical thinning 16 in CHECWORKS if there were sufficient data for 17 chemical wall thinning?
18 DR. HOPENFELD: Because as I showed you 19 yesterday on that elbow, in one place in this 20 distance it's all chemical probably. It was very 21 slow. Then you go into the high turbulence, it's all 22 erosive. The mechanism changes locally. That's what 23 the problem is. And when they're talking about what 24 you just said, they're talking about we have -- we 25 are looking at where -- in area like a straight pipe Neal R. Gross & Co., Inc.
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Page 1736 1 where we know it's dissolving equally, or they were 2 looking at some places where we know there's a 3 pressure drop and we have cavitation. We know we 4 have wet steam and we have droplet -- that's what 5 they're talking about.
6 But you're still confusing this 7 definition thing. When they say I don't see anywhere 8 in this program whether trending or anywhere that 9 you would take an elbow and look -- and do -- forget 10 about the lamination, let's say you look at an elbow 11 and you get one reading on the top, and then you go 12 down and you say half an inch less. And then you ask 13 yourself okay, how am I going to predict that from -
14 - when I should be looking at that elbow next time?
15 And how am I going to do -- use this information on 16 this elbow and go to the other room, or the next 17 building, or whatever and determine that that elbow 18 is going to behave the same way? I don't see 19 anywhere in there.
20 JUDGE McDADE: Okay. And, again, trying 21 to divide this up so it's easier at least for me to 22 grasp. As I understood the testimony of Entergy, 23 they're saying CHECWORKS is only designed to 24 identify those areas, those components that would be 25 most susceptible, to rank according to Neal R. Gross & Co., Inc.
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Page 1737 1 susceptibility those components subject to wall 2 thinning through a chemical process. That's all it's 3 designed to do.
4 Now, is it your view that they have 5 sufficient data points now to benchmark CHECWORKS 6 for that limited purpose?
7 DR. HOPENFELD: Sir, the reason I'm 8 having trouble honestly is because I don't know how 9 to separate the two. Because that data point that 10 you showed here represent an average over that 11 elbow. It's got the high local area where it was 12 very turbulent. It's got the other area where it's 13 fairly uniform. That's in there, so I don't know how 14 I could really answer the question. That's my 15 difficulty with the whole thing, because you cannot 16 separate the two. And I showed you. That was my 17 first thing yesterday showing you that look, I look 18 at a whole bunch of points here, and it doesn't 19 matter whether it's laminated or not, but I looked 20 all over at enough components to show that the ratio 21 is way above 1.6. If it was 1.6, that CHECWORKS is 22 perfect. But it isn't, so you've got all these 23 numbers here in between there, and I don't know how 24 to do it. And I don't how to do it just even by 25 trending. You see, even if I didn't have this, I Neal R. Gross & Co., Inc.
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Page 1738 1 don't know how to do that. Maybe there's a way, some 2 conservative way or some practical way of doing it.
3 But I really didn't come sufficiently prepared to 4 talk about it. It's not a trivial problem, because 5 in the erosive kind of thing it -- by this kind of 6 mechanism is not something we know how to predict.
7 JUDGE McDADE: Okay. But you're -- what 8 I'm hearing right now is you're testifying that 9 additional data points, another year, another 10 10 years, another 20 years of data points wouldn't 11 solve the problem that you perceive because it only 12 addresses wall thinning by a chemical process, not a 13 mechanical process. And the two are so intertwined 14 that you can't separate them from a practical 15 standpoint.
16 DR. HOPENFELD: That is correct, if we 17 pursue this program as you have done in the past.
18 I'm not saying if you, as I said, start from 19 scratch, a clean piece of paper, that you couldn't 20 do more. You could come up with a little better --
21 I'll tell you one thing that bothers me is, when I 22 look at all the data, there's millions of dollars 23 worth of good data in there, and I don't see anybody 24 looking at it. Do you see what I mean?
25 The thickness measurement guy writes a Neal R. Gross & Co., Inc.
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Page 1739 1 report, it goes in there, and sometimes you see 2 comments, sometimes you don't see it. Those are 3 little comments of lamination, that's all it was.
4 Believe me there's much more to this.
5 JUDGE McDADE: Okay. But stepping back 6 from CHECWORKS for a moment, because what Entergy, 7 as I understand their testimony, is trying to 8 explain is that CHECWORKS isn't their Aging 9 Management Program, that CHECWORKS is used for a 10 particular purpose which is to rank components for 11 inspection priority. That's number one.
12 Two, they recognize that there are 13 components that can't be properly ranked for 14 inspection priority using CHECWORKS and they've gone 15 into great detail about the other mechanisms that 16 they use to rank those. So, we now have two systems 17 to rank components for inspection priority.
18 They then do the inspections and then 19 once the inspection is done, they then monitor those 20 areas that have been inspected. If there has been 21 significant wall erosion, they inspect them more 22 frequently. If there has been not frequent, or not 23 significant wall erosion, they inspect them less 24 frequently. But that all that CHECWORKS does is just 25 originally help them prioritize who -- which Neal R. Gross & Co., Inc.
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Page 1740 1 components they're going to inspect first.
2 Now, as described the purpose of their 3 Aging Management Program is to provide reasonable 4 assurance that these components are going to operate 5 as they are intended to operate during the period of 6 extended operation. What else could an operator of a 7 plant do to increase that insurance given what they 8 have already done and the way they've described it, 9 and the limitations of identifying mechanical 10 erosion through a computer algorithm? I realize 11 that's a somewhat complex question.
12 DR. HOPENFELD: I think I understand the 13 gist of it. I think the answer here is, for one, if 14 you look at the data back to this thing, what you 15 see, there was no scatter. It wasn't -- if it was 16 only one one side. We've been through this this 17 morning. But since it's all over the place, it's 18 plus or minus, then you don't know whether you're 19 selecting the right component or not. You may be 20 selecting the wrong component, you see. So, using 21 CHECWORKS as a guide, it doesn't -- the only guide 22 would get you is if you have straight pipes.
23 JUDGE McDADE: Okay. Let's go back and 24 just so I'm certain, from my standpoint you can't 25 inspect a wrong component. I mean, you can inspect Neal R. Gross & Co., Inc.
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Page 1741 1 it. The problem is if you fail to inspect a 2 component that should have been inspected.
3 DR. HOPENFELD: Right.
4 JUDGE McDADE: That's what the issue is.
5 (Simultaneous speech.)
6 JUDGE McDADE: Not if you've done too 7 many inspections, but if you have not identified a 8 at-risk component which then can fail before you 9 inspect it. But my question is can you suggest 10 anything else that the operator of a plant could do 11 in order to increase this level of assurance that 12 hasn't been described by the experts from Entergy 13 over the last couple of days?
14 DR. HOPENFELD: Okay. I'd like to tell 15 you what I -- from what I have seen. And, again, I'm 16 at a disadvantage because I didn't speak to the 17 French people, but what I saw in the paper that's in 18 evidence, it looked pretty good.
19 Hypothetically, let's say that all the 20 data point that we saw this morning were on one 21 side, conservative or not -- whatever it was. And 22 there were thin scatter but, you know, like they had 23 40, 50 percent. Then I would say I probably could 24 use the thing as a first level indicator what I 25 should look further. It would be a good tool.
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Page 1742 1 Now, the difference is, what the French 2 have there, first they measure the chromium.
3 Secondly, they have some constants in there, and 4 maybe some theoretical rationing in one of these F1 5 parameters for mechanical parameters, for droplets, 6 or corrosion, or whatever they have. There was an 7 erosion part of it in there.
8 Now, how good this whole thing is is 9 beyond me. I don't know. I haven't been there, and I 10 really don't even want to go there. But to tell you, 11 that would be the first thing that you would do. You 12 have a first level looking at it, and say okay, 13 well, you can look at this component. Then you look 14 at experience, and look at elbows. But don't tell me 15 I have something with lamination because that's 16 really bad, because that tells you I have a 17 component I don't know how to inspect. It's an 18 uninspectable component. I wouldn't buy anything 19 like -- and the question is how many more of those 20 you have? So, if I have a Management Program, if I 21 have components I don't even know to inspect, well, 22 they're uninspectable, and I don't have a program.
23 JUDGE McDADE: Okay, thank you. Let me 24 follow-up. Mr. Aleksick or Dr. Horowitz, can you 25 describe for us just very briefly what you view as Neal R. Gross & Co., Inc.
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Page 1743 1 the methodology for calibration, and how it is 2 accomplished to calibrate the system?
3 DR. HOROWITZ: Your Honor, if you could 4 clarify what you mean. Dr. Hopenfeld was kind of 5 varied all over the place about what you mean by 6 calibration, benchmarking.
7 JUDGE McDADE: Well, I'm concerned with 8 what you mean by calibration, from the standpoint of 9 Entergy when you're talking about calibrating the 10 system, calibrating --
11 DR. HOROWITZ: Okay, thank you. That's 12 very clear. Calibration process is defined in NSAC-13 202L, Rev 3, Section 4.1, I believe. And that gives 14 the process for doing what we call calibration.
15 The other processes which you folks have 16 gone around is when we get -- we, EPRI, get user 17 feedback, what do we do? Well, we investigate and if 18 necessary fix the problem. We have roughly 100, 150 19 users, most of them go to meetings every six months, 20 and if there's a problem we hear about it. If 21 there's a problem, we hear about it and we deal with 22 it. That's what we do. We have made -- we were 23 talking last night about four or five significant 24 changes since CHECWORKS has been about, about 20 25 years.
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Page 1744 1 JUDGE McDADE: Okay, if you could go 2 through it a little bit. You made reference to your 3 guidance on it, and let me just sort of confess, I 4 think you're going to be able to explain to me 5 better than I will understand it from the document.
6 So, can you just explain, sort of summarize for me -
7 -
8 DR. HOROWITZ: I think Mr. Aleksick 9 probably does this more often than I do.
10 JUDGE McDADE: Okay.
11 MR. ALEKSICK: Thank you, Dr. Horowitz.
12 I'm sorry, Your Honor. Could you restate the 13 question for me, please?
14 JUDGE McDADE: Can you just walk me 15 through the calibration process?
16 MR. ALEKSICK: Sure. Sure. Typically, 17 immediately following the outage we have our data 18 set of perhaps 100 components that have been 19 inspected. We go through each one of those 20 individually, look at the matrix of wall thickness 21 measurements from each component. Go through a 22 software process in CHECWORKS whereby we import that 23 data, that grid of wall thicknesses into CHECWORKS, 24 go through some manipulations in the program to 25 eliminate a component -- eliminate -- I should say Neal R. Gross & Co., Inc.
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Page 1745 1 disregard where measurements that might not be 2 useful in calibration, and those measurements 3 primarily consist of components where there is very 4 little wear, or components where the wear is not 5 caused by flow-accelerated corrosion. And then run a 6 wear rate analysis inside of CHECWORKS, and what 7 CHECWORKS does at that point is generates the 8 scatter plots that we reviewed earlier, and also 9 generates new sets of predicted wear rates, wall 10 thicknesses, and times to Tcrit based on the new 11 line correction factors that it derives from the new 12 set of inspection data.
13 JUDGE WARDWELL: Why is that a 14 calibration? Isn't that just how you incorporate the 15 measurements in, and proceed ahead with the program 16 evaluation of the data?
17 MR. ALEKSICK: It's a calibration because 18 we are taking the CHECWORKS predictions and 19 adjusting them upwards or downwards to match the 20 field observations. So, in a sense, it's a 21 continuous calibration. Every outage we calibrate 22 and refine a little bit more.
23 JUDGE WARDWELL: Using the line 24 correction factors.
25 MR. ALEKSICK: The line correction factor Neal R. Gross & Co., Inc.
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Page 1746 1 is -- yes, the short answer to your question is yes.
2 JUDGE WARDWELL: And is there a 3 difference between benchmarking and calibrating?
4 MR. ALEKSICK: Not in the testimony that 5 I have given. No, Your Honor.
6 JUDGE WARDWELL: How many sets of 7 measurements have you had since the power uprate?
8 MR. ALEKSICK: Since the power uprate, I 9 can do it roughly. The power uprate was in the 2004 10 time frame, I believe. We've had approximately on 11 the order of 500 inspections since then, I believe.
12 JUDGE WARDWELL: Now, over how many 13 different outages? You only perform these when 14 there's a power outage. Right?
15 MR. ALEKSICK: Generally, yes.
16 Occasionally, you might do an inspection at power, 17 but the large majority are done doing refuel 18 outages. For example, for Unit 2 the refuel -- the 19 extended power uprate outage was refuel 16, and the 20 most recent refuel in 2010 was 19, so that is a 21 total of four refueling outages. And an average of 22 100 inspections per, that would be about 400 23 inspections.
24 JUDGE WARDWELL: What did you notice in 25 the wear rates between post and pre power uprates?
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Page 1747 1 MR. ALEKSICK: We looked at that from two 2 perspectives. One, there was a power uprate revision 3 to the CHECWORKS model at the time to revise the 4 model to account for the new operating conditions 5 post power uprate.
6 JUDGE WARDWELL: And by that you mean you 7 incorporated the new operating parameters into the 8 model?
9 MR. ALEKSICK: Yes, the new temperatures, 10 flow rates. There's some pH changes due to the 11 temperatures changes, so the model now contains both 12 pre uprate operating and chemistry conditions, as 13 well as post uprate operating conditions.
14 JUDGE WARDWELL: And it's able to use the 15 pre ones for those data points that you had prior to 16 the uprate and applies the new ones to the new 17 points, I gather.
18 MR. ALEKSICK: Yes, Your Honor. And we 19 prepared -- and it's one of our exhibits, a document 20 for each unit to document and draw conclusions from 21 the CHECWORKS model after it had been revised to 22 account for the power uprate. And depending on the 23 level of detail you wish to go into, I can point you 24 to tables comparing before and after, and the 25 limiting examples. But the short answer is, we saw -
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Page 1748 1 - in terms of CHECWORKS we saw very small predicted 2 changes on the order of 1 to 4 mils per year at the 3 high end; 1 to 4 or negative 1 to negative 4 both, 4 sometimes the wear rates decrease. So, very small 5 changes.
6 JUDGE WARDWELL: Compared to what is the 7 wear rate -- what was the wear rate before?
8 MR. ALEKSICK: Maybe a better way to say 9 it is in the most extreme cases of changes -- and 10 remember there are 8,000 modeled components, and of 11 those 8,000 modeled components if you look at the 12 top 10 and sort them by the largest changes, the 13 largest changes were on the order of 1, 2, 3, maybe 14 as much as 4 mils per year, which is a very small 15 number considering that the average predicted wear 16 rates might be 10, 20, or 30 mils per year.
17 JUDGE WARDWELL: I'm not sure who this 18 should be addressed to at Entergy, but have you 19 considered measuring chromium, and if you decided 20 not to, why haven't you?
21 MR. AZEVEDO: Yes, Your Honor. This is 22 Nelson Azevedo for Entergy. We do have a metal 23 analyzer. We do have the ability to measure chrome, 24 and we do go out there and measure chrome when we 25 feel that's appropriate. So, if there's some Neal R. Gross & Co., Inc.
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Page 1749 1 indication that the chemical content of the 2 component may have additional alloy material, in the 3 case of chromium, we do have the ability to go out 4 there and measure, but it's on a limited basis.
5 JUDGE WARDWELL: When you've done that 6 have you seen any reduction in the scatter of those 7 scatter plots that CHECWORKS provides as output?
8 MR. AZEVEDO: Well, we don't really do it 9 to enough data points to impact the scatter. Again, 10 as I said, we'll measure, if there's 1, 2, maybe 3 11 locations in a given outage that we feel it's 12 appropriate, we'll go out there and measure. But 13 it's a small number, so I wouldn't expect it to 14 impact the scatter of the data.
15 JUDGE WARDWELL: Is this a labor-16 intensive measurement? Is it non-destructive? Give 17 me some feeling for what type of --
18 MR. AZEVEDO: It's not because it's 19 labor-intensive. You have to keep in mind if you go 20 out there and measure the chromium content, it's not 21 necessarily uniform throughout the entire component, 22 so it will give you kind of better than order of 23 magnitude. It will tell you if you have significant 24 chromium content or not, but it's not going to 25 measure the chromium content at every location in Neal R. Gross & Co., Inc.
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Page 1750 1 the component because it varies. So, you know, if we 2 assume a very low chromium content, you go out there 3 and measure, say twice as high, we know what -- this 4 explains where it was lower or vice versa.
5 JUDGE WARDWELL: Switching topics -- does 6 anyone else have anything on benchmarking or 7 calibrating? Hang on just a second.
8 I'll refer you, hopefully this is 9 correct, to Entergy's testimony 029 on Answer 86, 10 page 59. Now, after I stated that I'll look it up to 11 see how wrong I was. Oh, I'm sorry, I was on page 12 86, looking for answer -- yes, and it's on the very 13 bottom of that page, the last paragraph. No, we want 14 to be on page 59, answer 86. Right there at the very 15 bottom.
16 The reviewer then classified Analysis 17 Lines as either calibrated or non-calibrated. Can 18 you go on and discuss how that's done, and why it's 19 done, and then what impact it has on CHECWORKS?
20 MR. ALEKSICK: Certainly, Your Honor. Rob 21 Aleksick for the Applicant. If you'll indulge me, I 22 just -- I want to grab one document.
23 JUDGE WARDWELL: Sure. Dr. Hopenfeld is 24 laughing that we need as much attention with our 25 microphone as he does.
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Page 1751 1 DR. HOPENFELD: I'm sorry. I didn't hear.
2 JUDGE WARDWELL: You're laughing at us 3 that we need as much care taking by our IT with our 4 microphones as you do.
5 DR. HOPENFELD: Oh, I'm just not used to 6 this kind of setup. I'm used to the old pointers.
7 MR. ALEKSICK: This is Rob Aleksick, 8 again, for the Applicant.
9 JUDGE WARDWELL: Chalkboards, right?
10 Sorry.
11 MR. ALEKSICK: To answer your question, 12 Your Honor, following the process I described a 13 moment ago about the importation and evaluation of 14 the inspection data in CHECWORKS, we follow a 15 process of reviewing the new CHECWORKS predictions 16 to determine if -- to determine their calibration 17 status.
18 To do that, we follow the guidance in 19 NSAC-202L, specifically on page 4-1 as referenced in 20 our testimony. There are five criteria that we apply 21 to determine if any given Analysis Line is or is not 22 calibrated. In brief, those are first that the 23 Analysis Line is defined properly, that is to say 24 that the physical plant lines analyzed together are 25 experiencing similar operational and chemistry Neal R. Gross & Co., Inc.
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Page 1752 1 conditions. The second is that at least five 2 inspections have been performed in that line. At 3 this point in the life of the FAC Program, we've far 4 exceeded that in essentially every inspection. We've 5 done I believe approximately 3,700 FAC inspections 6 over plant -- CHECWORKS FAC inspections over the 7 plant life.
8 Third, that the Line Correction Factor 9 is between 0.5 and 2.5. Fourth, that a reasonably 10 good correlation exists in that scatterplot, the 11 same on that we reviewed before. And, finally, that 12 the inspection coverage in the line under 13 consideration considered a variety of geometry --
14 component geometries.
15 So, based on those factors we go through 16 each line, determine whether or not it is -- whether 17 it meets the criteria to be considered calibration.
18 We document that analysis in Appendix B of the SFA 19 reports that are provided as Exhibits 50 and 51, 20 Entergy Exhibits 50 and 51. There's a table in there 21 that lists a clear yes or no, is it calibrated, and 22 a clear response to each of these criteria, as well 23 as a verbal discussion of the reasoning behind the 24 conclusion.
25 JUDGE WARDWELL: And what is that used Neal R. Gross & Co., Inc.
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Page 1753 1 for, just to flag things as being calibrated or non-2 calibrated, or is there some other use that's made 3 of that?
4 MR. ALEKSICK: It's used partially to 5 flag whether it's calibrated or not. It's also used 6 when we proceed to the next refueling outage and 7 we're identifying the set of components that we wish 8 to inspect, the new inspections.
9 Again, if a component has been 10 previously inspected, the determination of when to 11 reinspect it is based purely on the trending and the 12 measured wall thicknesses. But for uninspected 13 components, we use the uninspected modeled 14 components. We use these determinations of 15 calibration in selecting where and how many 16 components to examine. So, for example, in a poorly 17 calibrated line that has wear in it, we will examine 18 a much larger number of components.
19 I would like to point out that one of 20 the, and perhaps the primary reason for lines to be 21 not well calibrated is the instance where there's 22 very low wear. And in that case, the measurement 23 uncertainty of the UT process is larger than the 24 wear, so it becomes essentially impossible to -- the 25 wear is essentially undetectable, so those runs Neal R. Gross & Co., Inc.
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Page 1754 1 remain uncalibrated. But the good part of that is 2 that these are very low wear lines that we don't 3 have a great deal of concern about.
4 JUDGE WARDWELL: Where did you come up 5 with, or where did NSAC come up with the values in 6 0.5 to 2.5? It seems like a strange set of numbers.
7 DR. HOROWITZ: Jeff Horowitz, again. The 8 -- those numbers date back to CHECMATE, when 9 CHECMATE was released in `89. We put those numbers 10 out as guidance based on the early data we saw in 11 the beta test, and we waited for people to say these 12 are too big or too little, and nobody has talked to 13 us about them since. It just seems to match the 14 process.
15 JUDGE WARDWELL: Is there a reason why 16 they're skewed one way or the other? I mean, from .5 17 below to 2.5 above the one line is what it means.
18 Right?
19 DR. HOROWITZ: I think that's a real good 20 question, one I've never thought about. But I think 21 the answer is because you tend to overstate the 22 wear, the measured wear by nature of the process for 23 calculating it.
24 JUDGE WARDWELL: At Indian Point, do you 25 have a rough idea of how many of the lines are Neal R. Gross & Co., Inc.
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Page 1755 1 calibrated, how many are non-calibrated? Just to get 2 a feeling for what's there.
3 DR. HOROWITZ: I believe it's in 4 testimony. I'd have to look for a second to find it.
5 JUDGE WARDWELL: Does anyone know, 6 approximately? We don't have --
7 MR. ALEKSICK: I can answer. This is Rob 8 Aleksick. Approximately two-thirds of the lines are 9 calibrated.
10 JUDGE WARDWELL: Dr. Hopenfeld, when you 11 looked at the data did you observe any accelerated 12 wear rates beyond the levels that were reported here 13 by Entergy after the power uprate?
14 DR. HOPENFELD: No, you couldn't tell the 15 difference. There's no -- the scatter was the same.
16 I'm sorry. That's what I'm saying, it's not -- it 17 can't be recalibrated, first, because after 20 years 18 it hasn't been calibrated, so -- and after the 19 uprate -- first of all, there wasn't a huge uprate.
20 I mean, the change in velocity weren't that huge, 21 although the temperature could have affected it.
22 However, you couldn't tell. There was no difference 23 as far as the scatter. And if it was only 2 or 3 24 mils, that would be within a factor of 10 of their 25 uncertainty. You couldn't tell.
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Page 1756 1 But my problem, my pain with this thing 2 is, if I may, or I'm just straying off the farm 3 again here. Can I say it? But we have been asking 4 Entergy for four years, and asking them where is 5 that .5 to 2.5 comes from, because it's a criteria.
6 It's how --
7 JUDGE WARDWELL: And who is "we" that's 8 been asking them?
9 DR. HOPENFELD: Through our attorney I've 10 been asking. We asked Entergy to tell us where that 11 comes from. We got a reply in their initial 12 statement, or in reply to our questioning this, and 13 they said we don't really know where it came from.
14 And just as Dr. Horowitz said, it was there.
15 Now, if I was starting from scratch, I 16 would come up with a criteria that is controlled by 17 safety. That's what I'm interested -- I'm not 18 interested in anything else. Now, if it comes from 19 cost consideration maybe there will be a different 20 criteria.
21 JUDGE WARDWELL: How would you derive 22 those numbers for safety?
23 DR. HOPENFELD: I don't know where they 24 come from.
25 JUDGE WARDWELL: How would you derive Neal R. Gross & Co., Inc.
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Page 1757 1 them from a safety standpoint?
2 DR. HOPENFELD: Oh, I would say that it -
3 - I would -- I can't answer your question here right 4 now. I would have to do a lot of thinking. My 5 criteria, if something is acceptable or not would be 6 based on safety. In fact, I probably wouldn't even 7 consider a whole bunch of components that wouldn't 8 fit into that because they're no major safety 9 concern. So, I -- the criteria of acceptance of that 10 kind of data should be based on safety. How to do 11 it, I really don't know how to answer right now. But 12 I just could never understand the .5 to 2.5.
13 Secondly, if you look at the 14 instructions that they have to their -- whether the 15 data is acceptable or not is plus or minus 50 16 percent. That's reasonable, and it's an acceptable.
17 If you go out to the data sheets that they have 18 provided, where they have looked at, a lot of 19 comments, and there's a lot of leeway, and there's a 20 lot of judgment as to what they include in the 21 calculation, and what's not included in the 22 calculation. So, a person like me, all he can do is 23 just look at the data they provide us. That's all I 24 can do. I don't know how much was excluded. How much 25 is not included in here.
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Page 1758 1 JUDGE WARDWELL: Thank you, Dr.
2 Hopenfeld. Mr. Azevedo, I think maybe the best 3 person, but if not, anyone from that back table is 4 free to chime in. But about what is the precision of 5 UT measurements?
6 MR. AZEVEDO: I would say it's pretty 7 precise. There's a -- the NDE inspector when he goes 8 out to inspect his pipes he has a calibration block 9 which is a step-wedge, and he calibrates his 10 transducer from say 50 mils up to 400 mils, whatever 11 the different steps are depending on how thick the 12 pipe is. So, it's pretty accurate, pretty precise.
13 Now, the roughness of the pipe does impact the 14 accuracy a little bit, but I'd say it's very 15 precise.
16 JUDGE WARDWELL: So, do you disagree with 17 Dr. Horowitz, who claimed that the scatter was 18 reflected -- that the precision of the measured 19 rates, the measured wear, wasn't rates in fact, the 20 measure of wear was as much if not more than the 21 scatter from anything else associated with those 22 plots?
23 MR. AZEVEDO: No, I wouldn't disagree 24 with him. There is some uncertainty, it's not 100 25 percent, and especially if you're talking about wall Neal R. Gross & Co., Inc.
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Page 1759 1 wear. As Mr. Aleksick said, uncertainty in the 2 measurement -- and there is uncertainty. I would say 3 it's small, but it's not zero, it would impact the 4 calculation of the wear.
5 JUDGE WARDWELL: But doesn't that 6 equipment have some indication of what its precision 7 is, and if not, couldn't you determine it just by 8 taking repetitive measurements to get a handle on 9 how well that instrument can actually provide the 10 data?
11 MR. AZEVEDO: Well, the instrument is 12 pretty accurate. I mean, not 100 percent, but pretty 13 accurate. The factors that impact the accuracy of 14 the actual number is the -- how smooth is the 15 outside surface of the pipe, and how smooth is the 16 inside surface of the pipe. That does have an 17 impact, because keep in mind you're sending a sound 18 wave through the pipe, and most of these pipes are a 19 quarter to three-eights of an inch thick, so if the 20 roughness -- you know, if it's not perfectly smooth 21 it does have a little bit of impact, so it's not 100 22 percent. But the instrument itself, that's pretty 23 accurate.
24 JUDGE WARDWELL: So, you're saying the 25 instrument is accurate when you actually get into Neal R. Gross & Co., Inc.
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Page 1760 1 the field and perform a measurement, if you could 2 precisely replicate that in the field several times 3 you're liable to get a variation on top of the 4 imprecision associated with the instrument itself 5 that would lead to a wider scatter of the measured 6 rates in addition to the CHECWORKS predicted rates.
7 Is that what you're saying?
8 MR. AZEVEDO: Yes.
9 DR. HOROWITZ: If I may, Jeff Horowitz 10 again. It's not so much the accuracy of the 11 measurement, it's the fact you're going to be 12 subtracting about the same number from it. So, 13 therefore your error propagate and go through the 14 process of comparing matrices. It turns out it 15 propagates a lot big number than you would think off 16 hand.
17 JUDGE WARDWELL: Dr. Horowitz, do you 18 have any comments on what they just stated --
19 DR. HOROWITZ: Are you asking me?
20 JUDGE WARDWELL: Dr. Hopenfeld.
21 DR. HOPENFELD: I'm sorry. Sure, 22 absolutely do. First of all, I'm -- you know, terms 23 like small, good, these are not engineering terms 24 that I'm used to. I don't know what it means. But 25 it's true, it depends on the coupling, it depends on Neal R. Gross & Co., Inc.
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Page 1761 1 the training of the operator, how many points does 2 he take. All that is not described, so I really 3 don't know to what degree, whether he takes one --
4 when he says .5 free, is he taking the lowest 5 point? Where did he take it?
6 If your question was what's the accuracy 7 and the main thing in the answer was the fact, take 8 a look. The figure that I showed you on the first 9 day there was a gradient over there, even though 10 lamination, whatever, but there was a gradient 11 there. There was a change in one inch over six 12 inches. Okay? That's roughly like -- what was it, 13 about 160 or 170 mils per inch. And that particular 14 transducer has a thickness to it, so because of the 15 steep change that -- if it's -- if the transducer is 16 -- it was like 320 mils. Okay? Sees a 50 mil 17 gradient, so you know right there it's not -- it 18 must be less than -- because average -- there's a 19 whole technique or statistical analysis to do, which 20 they completely ignore, and it's not even included 21 here. It should, but it's not, so at least 52. And 22 then the operator doesn't tell you if you have a 23 gradient like that going from 1.46 or the number I 24 used going down to .513, you don't know where he 25 measured. He could have -- I mean, maybe the --
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Page 1762 1 there could have been a point there that was zero 2 he completely missed, even if it wasn't a 3 lamination.
4 Now, this may be an extreme case that 5 these are very high gradients, but there are other 6 cases, not as much as an elbow. You really more --
7 when you look at orifices because over a very short 8 period of time you can have a lot of changes. And, 9 also, the small piping, where you can very, very 10 large gradients. So, this is an over-simplified 11 explanation of UT measurements. There's much more to 12 it.
13 I would -- I don't know. I've looked all 14 over, I didn't see any report as to what the 15 probability of missing it, what's the probability of 16 error? If you go into experience of steam 17 generators, you always -- people specify what the 18 probability of missing a crack in the tube. There's 19 nothing here. That's not how you report ultrasonic 20 testing. But when I said there's no AMP, that's one 21 component of it. It's not there.
22 JUDGE WARDWELL: Thank you. One last 23 question for you, if I can find it now. Bear with me 24 just a second while I search. On page 45 of your 25 rebuttal testimony, that's Riverkeeper-108, if we Neal R. Gross & Co., Inc.
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Page 1763 1 could get that up on the board. Page 45, and go down 2 to the bottom line, 21-23, no, 20-26.
3 DR. HOPENFELD: Can you blow it up for 4 me, sir, please?
5 JUDGE WARDWELL: Yes.
6 DR. HOPENFELD: Okay.
7 JUDGE WARDWELL: And it starts with the 8 words, "First, in that statement I was not 9 discussing balance of plant components but rather 10 reactor vessel nozzles which are part of the reactor 11 cooling system. Second, my comment about the 12 stainless steel cladding was related to the fact 13 that in their fatigue analysis, Entergy used a model 14 for an unclad nozzle." Did you bring up anything in 15 regards to these nozzles in your direct testimony?
16 DR. HOPENFELD: In my direct testimony?
17 No, this was a fallout of the fatigue thing, because 18 this was related to the fatigue issue.
19 JUDGE WARDWELL: And did Entergy comment 20 in regards to these fatigue issues in their direct 21 testimony in response to something Entergy said?
22 DR. HOPENFELD: They said it has nothing 23 to do with CLB, and if I may, I'll have to go to the 24 physical problem here, what really I was talking 25 about. It is related to that issue.
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Page 1764 1 JUDGE WARDWELL: To the fatigue issue?
2 DR. HOPENFELD: Yes, it is related to the 3 fatigue issue, because in the fatigue table, in 4 their results they indicated that the inlet nozzle -
5 - or using the fatigue calculation like it was 6 carbon steel.
7 JUDGE WARDWELL: Okay, excuse me for a 8 minute. Let me make sure I understand this.
9 DR. HOPENFELD: Yes.
10 JUDGE WARDWELL: You're responding to a 11 statement that Entergy made under the fatigue 12 contention, or did they --
13 DR. HOPENFELD: No.
14 JUDGE WARDWELL: -- make in regards to 15 their direct testimony in response to your direct 16 testimony?
17 DR. HOPENFELD: Honestly, I don't know 18 the response -- I think their response was in 19 connection with the fatigue. But I raised the thing 20 as a technical issue because if you don't consider 21 the cladding or -- and it's -- because one of the 22 NRC documents requires you to take environmental 23 effects in consideration. And if there's a 24 possibility that the cladding will corrode, or 25 crack, or disappear then you have a bare metal, then Neal R. Gross & Co., Inc.
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Page 1765 1 you do have an FAC problem. But it's not -- and 2 there has been analysis when you have a cracked 3 nozzle what kind of corrosion do you have in the 4 crack. It's not insignificant. So, that's how it 5 comes in there.
6 Now, whether it's legally related to 7 this document, that document, I honestly don't know.
8 I may be off on that.
9 MS. BRANCATO: Your Honor, Deborah 10 Brancato for Riverkeeper. If I could just clarify 11 the record for you. Dr. Hopenfeld did raise this 12 concern related to metal fatigue in his direct 13 testimony, and what you are referring to now in his 14 rebuttal is in response to Entergy's response to 15 that initial testimony. And I believe if you go down 16 to the footnotes, this testimony is in response to 17 Entergy's testimony at Answer 144.
18 JUDGE WARDWELL: 144, thank you.
19 MR. FAGG: And just so the record is 20 clear, we understand that's not testimony by 21 counsel. Right? That was a clarifying statement.
22 MS. BRANCATO: That's correct.
23 MR. FAGG: I'm sorry. Brad Fagg for 24 Entergy. It sounded a bit like testimony to me, but 25 just so the record is clear, that's not testimony, Neal R. Gross & Co., Inc.
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Page 1766 1 that clarifying statement. Correct?
2 MS. BRANCATO: That's correct.
3 JUDGE WARDWELL: That's clear, yes.
4 MR. FAGG: Thank you.
5 JUDGE KENNEDY: I have a couple of just 6 follow-up questions based on the discussion here.
7 One point going back to yesterday, we were 8 discussing the linearity of the wear rate, and I 9 think Entergy testified that if we wanted to 10 understand whether the wear rate was linear, we 11 should look at Dr. Horowitz' book. And I guess now 12 that we've heard there's been 3,700 inspections at 13 Indian Point, I'm wondering if there's anything in 14 the data that's been taken at Indian Point that 15 would inform the linear assumption of wear rate. If 16 anyone from Entergy is willing to comment.
17 MR. ALEKSICK: Rob Aleksick for the 18 Applicant. Yes, Your Honor, one could go back to the 19 data set of 3,700 historical inspections. Some of 20 the components in that data set have been inspected 21 multiple times, two, three, four times over a period 22 of many years. And plot those, and I think 23 demonstrate the linear nature of FAC. We have not 24 done that as far as I know, because there's no 25 reason to do so, but I'm sure that would be --
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Page 1767 1 that's a possibility.
2 JUDGE KENNEDY: And is the fact that 3 there's no reason to do so because after the first 4 pass you're using measured wear rate? Why would you 5 not think it would be useful to mine that data?
6 MR. AZEVEDO: Your Honor, this is Nelson 7 Azevedo for Entergy again. You could as a 8 theoretical exercise. You have to keep in mind that 9 because of the changes in chemistry since the plant 10 first went on line, you have to adjust that wear 11 rate for a given cycle for the operating conditions.
12 That would be very difficult to do. It could 13 potentially be done, but we don't really see any 14 benefit of doing that.
15 JUDGE KENNEDY: So, there may be 16 insufficient quality data to make an informed --
17 could you -- I'm understanding you could not make 18 an informed decision based on the Indian Point data 19 at this point.
20 MR. AZEVEDO: Well, we haven't done that.
21 We have, to be honest with you, haven't thought 22 about it. But if we were to go back and do that, we 23 have to, again, adjust the wear rates for each cycle 24 based on the operating conditions for that cycle.
25 And because the operating conditions, namely the Neal R. Gross & Co., Inc.
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Page 1768 1 chemistry, have changed over time, we would have to 2 adjust the data to account for that.
3 JUDGE KENNEDY: Thank you.
4 MS. BRANCATO: Your Honor, I apologize 5 for the interruption, but -- this is Deborah 6 Brancato from Riverkeeper. Given the subject matter, 7 this may be an appropriate time, and if it's not, 8 just advise me to revisit the earlier issue we had 9 before lunch where Dr. Hopenfeld -- we were 10 discussing non-linear corrosion, and Dr. Hopenfeld 11 was citing to instances. And there was a problem 12 identifying the document. And during the lunch hour, 13 Riverkeeper did find the documents. They are not 14 currently in evidence, but Dr. Hopenfeld has 15 identified two examples that illustrate his point.
16 And they are Entergy documents that were provided in 17 discovery, sent via email, the particular documents 18 to Entergy's counsel. And though they are not 19 currently in evidence, I do believe it will be 20 helpful and beneficial given the lengthy discussion 21 that was had earlier to clarify the point that Dr.
22 Hopenfeld was trying to make.
23 JUDGE McDADE: Okay. They're documents 24 you received through discovery. They have Entergy 25 Bates stamp numbers but they have not been received Neal R. Gross & Co., Inc.
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Page 1769 1 in evidence at this point?
2 MS. BRANCATO: These particular documents 3 do not have Bates stamps but they were received in 4 discovery, and that is correct, they have not been 5 received into evidence.
6 MR. KUYLER: Your Honor?
7 JUDGE McDADE: Just one second. What I'm 8 going to suggest is this. We are -- and I realize 9 you probably never thought you would hear this, we 10 are nearing the end of our questioning on 11 Riverkeeper-TC-2. One of the things that based on 12 the nature of the testimony that we have that we 13 were going to propose is to allow Entergy, 14 Riverkeeper, and the NRC Staff if they wished to 15 conduct a brief interrogation of the witnesses to 16 incorporate both what could be considered redirect 17 and also cross. If there is testimony of your 18 witness that you believe perhaps has come out 19 unclear, and that the Board could be misled as a 20 result of it, you will be offered the opportunity to 21 clarify that through your witness. And, also, if you 22 wish to bring out something through one of the other 23 parties' witnesses, allowed to do that briefly.
24 Many years ago, I used to teach some 25 trial practice at the Department of Justice, and one Neal R. Gross & Co., Inc.
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Page 1770 1 of the things I used to say is that redirect, the 2 value of redirect testimony tended to decrease 3 exponentially after about 10 minutes. So, what we 4 are going to do is allow a very brief period of 5 time.
6 But what we could do at this point is 7 break. There is a possibility after we review our 8 notes that we may have a few more questions of these 9 particular witnesses. At that point, over the course 10 of the evening, Ms. Brancato, if you could provide 11 those documents to Entergy so that they would have 12 an opportunity to review them and to comment as to 13 whether or not they should be received into evidence 14 before we get started tomorrow. And then when we get 15 started tomorrow, as I said, there's a possibility 16 we may have a few more questions in the morning 17 based on a review of our notes, at that point ask 18 you with regard to your desires to ask to 19 interrogate the witnesses again very briefly. I 20 would anticipate that the entire process for all 21 three of the parties involved in this contention 22 would be under an hour. And, also, if there is 23 anything that needs to be clarified with those 24 documents, if they are received in evidence, Ms.
25 Brancato, you will be able to ask Dr. Hopenfeld Neal R. Gross & Co., Inc.
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Page 1771 1 about them.
2 I believe that if Judge Kennedy had a 3 few more questions that he wanted to go through this 4 evening before we break, but what I would propose to 5 do is to have Judge Kennedy finish up those few 6 questions, to then break for this evening, and then 7 that would give you the opportunity, one, overnight 8 to perhaps edit the several hours of questions that 9 you've developed over the last couple of days down 10 into what we view as a workable time frame. And, 11 also, make the decision, first of all, whether or 12 not you wish to avail yourself of that opportunity.
13 So, to a degree I'm sort of making a motion for you 14 to allow the interrogation of the witnesses, and 15 then allowing you to comment on that first thing in 16 the morning.
17 Anyway, that's something to think about.
18 Judge Kennedy, if you'd finish up with your 19 questions for this evening.
20 JUDGE KENNEDY: Thank you, Judge McDade.
21 I have two questions. First is for Mr. Aleksick.
22 This is Judge Kennedy.
23 I want to clarify, you were referring to 24 Entergy Exhibits 50 and 51. And I -- the way I 25 understood it, they contain the summary of all the Neal R. Gross & Co., Inc.
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Page 1772 1 appropriate data for CHECWORKS. Is that true?
2 MR. ALEKSICK: Yes, Your Honor.
3 JUDGE KENNEDY: So, all the relevant 4 data, whether we're talking about calibration, 5 benchmarking, but it is the relevant inspection data 6 for Indian Point Units 2 and 3 in those two 7 exhibits?
8 MR. ALEKSICK: The reason I'm hesitating 9 is that -- the answer is yes with respect to all 10 modeled components and all of the inspection data 11 collected for those components. However, there may 12 be non-modeled components that by definition are not 13 in the CHECWORKS model; and, therefore, the data is 14 not in it.
15 JUDGE KENNEDY: So, it's the data 16 relevant to CHECWORKS.
17 MR. ALEKSICK: It's the inspection data 18 of CHECWORKS modeled components, yes.
19 JUDGE KENNEDY: I wonder if we could put 20 Exhibit 50 and 51 on the screen, at least the first 21 page, Entergy-50 and Entergy-51. I guess I'd like to 22 turn to Dr. Hopenfeld. Did you have a chance to 23 review this information? Is this the data you were 24 talking about?
25 DR. HOPENFELD: I don't know what I'm Neal R. Gross & Co., Inc.
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Page 1773 1 looking at. I see CSI --
2 JUDGE KENNEDY: Would you like us to 3 scroll through it a bit?
4 DR. HOPENFELD: Yes.
5 JUDGE WARDWELL: This is Entergy's 6 Exhibit 51. Is that correct, Andy?
7 DR. HOPENFELD: It looks familiar. Yes, 8 I'm sure I looked at it. Yes. I went through it, 9 absolutely, yes.
10 JUDGE KENNEDY: Maybe we could take a 11 look at Appendix F. And maybe not.
12 PARTICIPANT: Judge Kennedy, do you have 13 a page?
14 JUDGE KENNEDY: I do not. I was hoping it 15 would say Appendix F. Maybe we should go back to the 16 Table of Contents. I'm -- it's my understanding that 17 the data is contained in Appendix F.
18 JUDGE WARDWELL: UT inspection data is 19 Appendix F.
20 JUDGE KENNEDY: Did it give a page number 21 on the Table of Contents?
22 JUDGE WARDWELL: Well, the text is about 23 41, I think, because it says page of 41, so if we go 24 down that will bring us to Appendix A, at least.
25 MR. ROTH: Your Honor, it's Dave Roth for Neal R. Gross & Co., Inc.
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Page 1774 1 the Staff. It looks like it's page 200 of 1,277 in 2 the PDF.
3 JUDGE KENNEDY: Thank you.
4 JUDGE WARDWELL: One thousand --
5 JUDGE KENNEDY: Two hundred --
6 MR. ROTH: Page 200 of 1,277.
7 (Off the record comments.)
8 MR. ROTH: Your Honors are on Exhibit 50 9 or Exhibit 51?
10 JUDGE WARDWELL: We're on 51.
11 MR. ROTH: Okay.
12 JUDGE KENNEDY: I'm looking for Appendix 13 F in either document, and I guess what I'm trying to 14 pursue here is whether Dr. Hopenfeld had a chance to 15 review this data.
16 DR. HOPENFELD: I've looked at all these 17 documents. To what degree, I don't know.
18 JUDGE KENNEDY: Mr. Aleksick, is this the 19 inspection data for the modeled components that you 20 were referring to?
21 MR. ALEKSICK: Yes, Your Honor, this is 22 one location. It is in other places, as well. This 23 is the most -- this is the best summary.
24 JUDGE KENNEDY: Mr. Aleksick, do you have 25 a sense of how far back this data goes?
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Page 1775 1 MR. ALEKSICK: Yes, I have more than a 2 sense, Your Honor, I know precisely. If we look at 3 page F-2, Foxtrot 2, the very top line working from 4 left to right you see the CHECWORKS line name at the 5 very top, the component name within that line, and 6 go a few -- to the fourth column, it says "period."
7 So, that component was inspected in Refuel 8 which 8 was in 1992.
9 JUDGE KENNEDY: 1992? If we were to look 10 at the -- I'm sorry, this is Unit 3, or Unit 2?
11 MR. ALEKSICK: Unit 3, Your Honor.
12 JUDGE KENNEDY: Now, if we were to look 13 in Exhibit 50, I think it -- we could go through 14 Exhibit 50.
15 MR. ALEKSICK: Yes, Your Honor, there is 16 an analogous table, or an analogous appendix in 17 Exhibit 50. However, in that -- that is the Unit 2, 18 which had a change of ownership before it was -- it 19 was a Consolidated Edison Plant before it came under 20 the umbrella of sister plants with Unit 3. So, the 21 history of the Unit 2 document here starts at a 22 later point in time, so that table in that exhibit 23 does not go all the way back to that outage.
24 However, there are -- I can point Your Honor to 25 different sections in that report that do provide Neal R. Gross & Co., Inc.
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Page 1776 1 traceability back to I believe it's 1993, where 2 there is UT data from that period.
3 JUDGE KENNEDY: So, I wouldn't look in 4 Appendix F to go all the way back to the original, 5 or the oldest data that may be exist for Unit 2.
6 MR. ALEKSICK: That's correct, Your 7 Honor. I would point Your Honor to Appendix I.
8 JUDGE KENNEDY: And, Dr. Hopenfeld, did 9 you have a chance to look at the Unit 2 data, as 10 well? These are the data reports that you were 11 referring to when you --
12 DR. HOPENFELD: If I may, I can tell you 13 what I did when I got the data. I got the data and I 14 saw that I'm getting data here for four or five 15 outages. And I think they're listed on the table 16 that I provided. And I didn't delve into the 17 possibility there would be some two, or three, or 18 four points that were provided from 1992. I thought 19 that most of the data came from the latest outages.
20 That's how it was labeled. I didn't go through each 21 point in the back to see where it came from, so we 22 asked, we asked Entergy please provide us the data, 23 the comparison, the same comparison that you're 24 doing here for these outages starting from 2003, or 25 whatever it was. There were some at 2000, but that's Neal R. Gross & Co., Inc.
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Page 1777 1 where it started, before it changed ownership. Just 2 provide us data, because I wanted to see what the 3 progression was, all the data, not a few points, 4 separate, just outage by outage. Just they gave us 5 outage 15, 16, 17, I wanted outage one or whatever 6 they started in `92, I wanted the same thing so I 7 can see how the thing progresses. And they said that 8 they've lost the data, they misplaced the data. And 9 now they say well, we gave it to you. It's somewhere 10 in there. Yes, it could be somewhere. I don't know 11 where I could go. I mean, there's limited time that 12 we can spend looking at every data point here. There 13 are thousands of data points. It's not fair to ask 14 us to do that, what was labeled an outage. The 15 figure didn't say this point is from `92. If they 16 felt it was important, they should have done so.
17 JUDGE KENNEDY: But do you feel that this 18 data reflects data that goes back as far as 1992?
19 DR. HOPENFELD: No, it doesn't.
20 JUDGE KENNEDY: At least in this case, I 21 guess --
22 DR. HOPENFELD: No, it doesn't, may have 23 a few points, but it doesn't reflect that, not that 24 I saw. I saw -- what I saw when I was looking at it, 25 it was the latest data all the way to a year ago.
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Page 1778 1 JUDGE KENNEDY: Okay.
2 DR. HOPENFELD: I was looking for outage, 3 whatever it is, outage 10, 11, 12, whatever is done, 4 `92, and see in each case to see a comparison.
5 That's what I was looking for.
6 JUDGE KENNEDY: All right, thank you.
7 JUDGE McDADE: Okay. Anything further 8 before we break for tonight? Mr. Turk, from the NRC 9 Staff?
10 MR. TURK: Not for tonight, Your Honor.
11 JUDGE McDADE: From Clearwater?
12 MS. RAIMUNDI: Nothing for --
13 JUDGE McDADE: I was looking to see 14 whether -- Ms. Greene was down behind the big screen 15 there.
16 MS. RAIMUNDI: Hello, can you hear me?
17 JUDGE McDADE: Anything from Clearwater?
18 MS. RAIMUNDI: No, no. And Ms. Greene is 19 not here. She had a prior commitment that she had to 20 honor.
21 JUDGE McDADE: Okay, from Riverkeeper.
22 MS. BRANCATO: No, Your Honor, thank you.
23 JUDGE McDADE: New York?
24 MR. SIPOS: No, Your Honor.
25 JUDGE McDADE: Entergy?
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Page 1779 1 MS. SUTTON: Nothing further.
2 JUDGE McDADE: We will see you then 3 tomorrow morning, 9:00. And, again, for planning 4 purposes, we plan to go for at least an hour or up 5 to an hour on TC-2, and then to get started on New 6 York's contention. Thank you.
7 (Whereupon, the proceedings went off the 8 record at 5:15 p.m.)
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Neal R. Gross & Co., Inc.
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CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission Proceeding: Entergy Nuclear Operations, Inc.
Indian Point Units 2 and 3 Docket Number: 50-247-LR and 50-286-LR ASLBP Number: 07-858-03-LR-BD01 Location: Tarrytown, New York were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken and thereafter reduced to typewriting under my direction and that said transcript is a true and accurate record of the proceedings.
Official Reporter Neal R. Gross & Co., Inc.
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com