ML12338A472

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Official Exhibit - ENT000096-00-BD01 - Declaration of Paul Blanch
ML12338A472
Person / Time
Site: Indian Point  Entergy icon.png
Issue date: 03/28/2012
From: Blanch P
State of NY, Office of the Attorney General
To:
Atomic Safety and Licensing Board Panel
SECY RAS
References
RAS 22105, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR
Download: ML12338A472 (28)
v • d • e


Text

United States Nuclear Regulatory Commission Official Hearing Exhibit Entergy Nuclear Operations, Inc. ENT000096 In the Matter of:

(Indian Point Nuclear Generating Units 2 and 3) Submitted: March 28, 2012 ASLBP #: 07-858-03-LR-BD01 Docket #: 05000247 l 05000286 Exhibit #: ENT000096-00-BD01 Identified: 10/15/2012 Admitted: 10/15/2012 Withdrawn:

Rejected: Stricken:

Other:

UNITED STATES OF AMERICA*

NUCLEAR REGULATORYCOMMISSION ATOMIC SAF~TY AND LICENSING BOARD

.- -----------" -- ---- -------------- --- --- -------- -------- -------x \

In re:

Docket Nos. 50-247-LR and 50-286-LR License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BDOl

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Entergy Nuclear Indian Point 2, LLC, Entergy Nuclear Indian Point 3, LLC, and DPR-26, DPR-64 Entergy Nuclear Operations, Inc. .

-- .0 __ -- -- - ----- - - - -.- - - - -- - -- --- - - -- ---- - - - - --- - . - --- -- - -- -.- -- -- - -x DECLARATION OF PAUL BLANCH Paul Blanch, hereby declares under penalty of perjury that the following is true and correct:

1. 'I have been retained by the New York State Officeofthe ~ttorney General to provide expert services in connection with the application by Entergy

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Nuclear Operations, Inc. and its affiliates (collectively Ent~rgy) for a renewal ofthe two separate operating lice~ses for the nuclear power generating facilities located at Indian Point on the east bankofthe Hudson River in the Village of Buchanan, Westchester County, New York..

2.. I submit this declaration in opposition to Entergy's August 14, 200"9 motion for summ~ry disposition that seeks the dismissal of New York State Contention Number 8 concerning transformers.

Declaration of,.'paul Blanch in Opposition to I Entergys Motion for Summary Disposition On NYS Contention 8 - Transformers 1

Experience

3. Beginning in i964, I served in the U.S. Navy as a nuclear reactor and electric plant operator on Polari~ class submarines for seven years., These submarines typically were at sea for extended tours of duty. During my Navy

~ service, I and my fellow crew members were in close proximity to the submarines' nuclear reactors that powered the vessels whether they were under the sea or on the surface.

4. As a qualified Electric Plant Operator, I was responsible for the operation of motors, power supplies, inverters, breakers,switchgear, battery chargers, motor and steam-powered electric generators (AC and DC), and

.transformers.

5. I graduated from the U;S. Navy Electronics Technician School in 1_~64; the U.S. Navy Nuclear Power Schoo~, in 1966; and the U.S. Navy Submarine School, in 1968.
6. As part of my Navy duties, I was certified as an ope~atorlinstructor at the Navy prototype reactor (SIC) in Windsor Locks, Connecticut. I instructed Navy

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officers and enlisted personnel on reactor operations and maintenance including the subjects of electrical theory related to power generation, motors, generators, battery

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chargers, transformers, transistors, instrumentation and control systems,and magnetic amplifiers.

7. During my Navy service, we employ~d various test equipment thai Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition

, On NYS Contention 8 - Transformers 2

, I included active variable winding ratio transformers commonly referred to as

, "Variac" transformers.

8. I received an honorable discharge from the Navy in 1971. In 1972, I received a Bachelor of Science in Electrical Engineering from the University of Hartford.

~. I have rriore than 35 years of engineering,designj operations, maintenance, eng~neering management, ,and project coordination experience for the construction and operation .of nuclear power plants. This includes positions ~t Northeast Utilities that involved in the design, construction, operation, and maintenance of Millstone Units 1, 2, and 3 and Connecticut Yankee (Haddam Neck). During this period, I was under the direction of the Electrica] Engineering division within Northeast Utilities. I have also been employed by Co,nsolidated Edison and Entergy at ~ndilln Point Unit 2 as an advisor to the C~ief Nuclear Of:q.cer (CNO) at that facility. I served in a similar position at Maine Yankee reporting totheCNO of Maine Yankee Atomic Power Company.

10. I am a re'gistered professional engineer in the State of California (currently with an inactive status)
11. I.haveactively participated in industry standards writingactivitie~

with the American Nuclear Society (ANS), Instrumentation Society of America (ISA), and the Institute of Electrical and Electronics Engineers, Inc. (IEEE) for use by the nuclear industry.

Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS.Contention 8 - Transformers 3

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12. I haye been employed as a contractor for the Electric Power Research

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Institute (EPRI) for the development ofcomputerized monitoring systems for I

nuclear power plants including monitoring the conditions of active devices incl~ding pressure and level monitoring systems.

, 13. I have been engaged as a contractor to Nuclear Energy Institute (NEI, previously ,~RC) to educate Chief Nuclear Officers on the attributes of a Safety

, Conscious Work Environment (SCWE).

14. In 1993, I was named "Engineer of the Year" by Westinghouse Electric and Control maga'zine for my efforts in identifying the subtle failures of active electrical devices such as pressure, level, and flow transmit'ters and indicators. All of these devices contain active components such as transistors and integrated and digital circuits that require an external energy source. These components; by "design, undergo a "change in state" and vary their conductive, resistive, and other properties without'moving parts. These ,devices may also include passive components such as resistors, capacitors, inductors/transformers, and printed circuit boards that do not change state to perform their intended function.
15. I have reviewed the April 30, 2007 License Renewal Appl~cation submitted by Entergy to renew the operating licenses for Indian Point Unit' 2 and Unit 3. I have also reviewedpertinent sections of the recent' August 12, 2009 Safety Evaluation Report prepared by NRC Sta.ff, the August 14, 2009 Motiori for Summary Disposition filed by Entergy, lind the September 14, 2009 filing by NRC Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition

, On NYS Contention 8 - Transformers ,

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Staff in support of Entergy'smotion. As set out in my November 2007 declaration and as developed in the relevant Contentions contained in the State of New York's Petition to Intervene, it is my opinion that the proposed aging management programs f!lil to provide reasonable assurance that IP2 and IP3 will operate safely through their proposed license renewal periods.

Transforiners

  • 16. A transformer is an electrical device that can convert alternating

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currents and voltal5es to different voltages and currents or provide isolation of circuits. Transformers typically contain two insulated wires that are wrapped or coiled around form called a "core" that is frequently made of iron or metal all~ys.

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Transformers contain a primar;y winding and one or more secondary windings. In its most basic form, a transformer need not even contain a physical s,:ore: two coils of wire adjacent to, one another can act as a transformer. Two parallel wires. or cables

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may also act as a transformer in that varying current in o~e wire or conductor may' induce voltages, and currents in the adjacent wire orconductor.

17. .Transformers do not contain any nioving parts for their basic.

functions.i During their. normal operation, there is no change in the configuration 'of lWnile there is* a subcategory of transformers that could be viewed as containing active' components, those devices are not induded within Contention 8. Thus, this description would not apply to "Variac" transformers, which are m~mually or motor operated variable transformers (manufactured by Staco Energy Products and Variac - Trade Mark of Power Designs, Inc.). Additionally, some transformers may Decl~ration of Paul Blanch in Opposition 'to

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Entergys Motion for Summary Disposition On NYS Contention 8 - Transformers 5

transformers or their constituent parts, nor are there intended changes in the properties of transformers. Transformers have design properties such as turns ratios, current, voltage, and power. Transformers have the capability to function through a phenomenon known as electromagnetism: when an electrical current input passes through a coil of wire, a magnetic field is generated; in turn, the electrical current is induced from one coil to another through the changing magnetic field., When an electrical current flows into a transformer, that electrical input will .

create an electromagnetic field within the transformer. Conversely; when there is I

no current flow into the transformer, there is no magnetic field; the coils and the core do not produce a/magnetic field on 'their owJ? when there is no incoining electrical current~ None of these properties and capabilities is designed to change during normal operation of a transformer.

18. The Handbook of Transformer Design & Application states that "Transformers are passive devices for transforming voltage and current,:' Flanagan, The Handbook of Transformer Design & Application (2nd Edition), page 1.1, McGraw-Hill, 1993; ISBN 0-07-021291-0. Another text book states that a transformer is "a static electrical device, involving no c(::mti~uously moving parts, used in electrical power systems to'transfer power between circuits through use of electromagnetic induction." Harlow, Electric Power Transformer Engineering: page 2-1, CRC Press (2004) ISBN 0-8493-1704-5 (referencing ANSI/IEEE) ; Harlow, have cooling systems, but these cooling systems are not necessary for the basic functional capability of the transformer. '.

Declaration of Panl Blanch in Opposition to Entergy's Motion for Snmmary Disposition.

On NYS Contention 8 - Transforn;ers 6

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Electric Power Transformer Engineering, page 2-1 (2d Edition) CRe Press (2007)

ISBN 0-8493-9186-5. The sixth edition ofthe IEEE Standard Dictionary of Electrical aQ,d Electronic Terms includes the following definition of transformer: "A static electrical device consisting of a winding,. ortwoor more coupled windings',

with o~ without a magnetic core, for introducing mutual coupling between electrical circuits." .IEEE Standard Dictionary of Electric~l and Electronic Terms, IEEE Std 100-1996 (6 th Edition), page 1i31, ISBN 1-55937-833-6(1996).

19. Transformers play important roles in the operation of a nuclear power plant. Transformers can com~ in a variety of sizes. Byway of example, some large transformers used at pow~r reactors likely would iriclude Station Auxiliary Transformers, Station Service Transformers, Station Black Out (SBO) transformer, 15 KVA GRD Tr~nsformer for the gas turbines, instrumentation transformers, and, lighting transformers. Some smaller transformers ih use at power reactors would.

include those used in c~ntrot circuits. A review of various publicly available

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electrical one-line diagrams for IP2 aridJP3 reflects that there are numerous electri~al transformers ranging from 345 .KV to 120 volts located throughout the Indian Point facilities that perform a function described in §§ 54.4(a)(1)/(2) and (3).

e The role of some of the transformers

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in providing for safety functions is described in Chapter 8 (Electrical System's) ofthe UFSAIt for each Unit on pp', 1167-68, 1333-43 of the UFSAR for IP3 and on pp. 1039-50 ofthe UFSAR for IP2. TheUFSARfor IP2 includes a one-line diagram for the electrical plan for IP2; that diagram

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. Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS Contention 8 - Transformers 7

identifies some of the transformers at IP2 and the central role that they play in the electrical systemofthe plant. IP2 UFSAR, figure 8.2-1,8.2-2; Indian Point No.3 Nuclear Power Plant, Electrical Distribution & Transmission System, DWG NO 9321-F-33853, REV 17.

NRC Regulations

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20. In preparing this declaration, I reviewed 10 C.F.R. § 54.21.

Specifically, § 54.21(a)(I) provide$:

Structures and components subject to an aging management review shall encompass those structures

,and components-(i) That perform an intended function, as described in -,

§ 54.4, without moving parts or without a change in configuration or properties. These structures and components include, but are not limited to, .the reactor vessel, the reactor coolant system pressure boundary, steam generators, the pressurizer, piping, pump casings, "

valve bodies, the core shroud, component supports; pressure retaining boundaries, heat exchangers, ventilation ducts, the containment, the containment liner, electrical and mechanical penetrations, equipment hatches, seismic Category I structures, electrical cable,S and connections, cable trays, and electrical cabinets, excluding, but not limited to, pumps (except casing),

valves (except body), motors, diesel generators, air compressors, snubbers, the control rod drive, ventilation dampers, ,pressure transmitters, pressure indicators, water level indicators, switchgears, cooling fans, transistors, batteries, breakers, relays, switches, power inverters, circuit boards, battery chargers, and power supplies; and Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition

. On NYS Contention 8 - Transfor:mers 8

(ii) That are not subject to replacement based on a qualified life or specified time period. )

10 C.F.R. § 54.21(a)(I)(i), (ii).

21. Based on my review of 10 C.F.R. § 54.21(a)(1), it is my understanding
'" that NRC regulations provide that structures or components without moving parts.

.i or without a change in configuration or properties are included within the scop*e of the rule. The regulation contains a non-exhaustive list of such structures and /

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y cOmp01).ents. My understanding of the regulation is that those struct~res and components are to be included in an aging management review. The regulation the~ also provides anothernon~exhaustive list of structures and componints that

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are not within the scope of the rule. The NRC has elected to exclude this second category of structures and components from\aging management review. 10 C.F.R. . . , § 54.21(a)(I)(i). I'

22. The*text of § 54.21(a)(1)(i) expressly inCludes* the following components as *w ithin the first category and 'therefore within tJ1e scope of the regulatiOri: the reactor l

vessel, the reactor coolant system pressure boundary; steamge~erators, the pressurizer~ piping, pump casIngs; valve bodies, the core shroud, component supports, pressure retaining boundaries, ..reat exchangers, ventilation ducts, the I . ' \ . . ' . r containment, the-containment liner; electrical and mechanical penetrations,

. equipment hatches, seismic Category I structures, electrical cables and connections,

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cable trays, and electrical cabinets. Because these components are expressly

  • ( I included in the first category, they are subject to agi~g'managementreview. 10 Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS Contention 8 - Transformers 9

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  • C.F.R. § 54.21(a)(1)(i).
23. On the o:ther hand, pumps (except casing), valves (except body),

motors, diesel generators, air compressors, snubbers, the control rod drive; ventilation dampers, pressure transmitters, pressure indicators, water level indicators, switchgears, cooling fans; transistors; batteries, breakers, relays, I r switches, power inverters, circuit boards, battery chargers, and power supplies are included inthe second category'and therefore are not subject to aging management review. 10 C.F.R. § 54.21(a)(1)(i).

Comparison of Transformers to Inciuded and Exclu,ded Components

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24. In preparin~ this declaration, I also revie'Yed the Atomic Safety and Licensing Board's July 31, 2008 decision concerning the admission of various

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contentions including the admission of New York State Contention No. 8,which

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concerns transformers. The Board further stated: "Ip addressing this contention; the Board will requGe, inter alia, representations from the parties to help us determine whether transformers are more similar to the included, or to the excluded, component examples." July 31, 2008 ASLB Memorandum and Order at 45.

25. I have prepared a table that compares the included and excluded structures and components expressly-listed in 10 C:F.R. § 54.21(a)(1) to transformers. This table entitled, Comparison ()fVarious Structures and Declaration of Paul Bla'nch in Opposition to Entergy's Motion for, Summary Disposition On NYS Contention 8 - Transformers 10

Components," accompanies this declaration, and it de~onstrates that transformers are similar to the category of structures and components that are expressly listed as included in 10 C.F.R. § 54.2l(a)(1) in that transformers, like the included structures and components, contain no moving parts, do not change properties or configuration, and do not undergo any change of state. The table summarizes whether a structure or component contains moving parts, experiences a change in

. I configuration orproperties, experiences a change in state, is active or passive, and is specifically listed in § 54.2l(a)(1).2

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26: To be sure, many of these "included" structures and components do change the "properties;' of the fl~ids, voltages, currents, or fuel that travel through

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or is contained within those structures and components; however, the "properties" of the included structures and component~ themselves do not change during their intended use. Likewise, a transformer may increase or decrease the voltage of the electrical current that passes through transformer; however, the properties of the transformer itself do not change during its intended use.

27.- Electric Cables. Electric cables do not have moving parts. When AC current passes through a cable, a varying magnetic field is generated aro'und the cable. The properties of the currents and voltages in and out of an electric cable 2 In my review oflO C.F.R. § 54.2i(a)(1)(i), I observed that the provision does not contain the terms "active," "passive," or a "change in state." I am also aware that the Commissioners have stated "Further the Commission ha~ concluded that ,~

change in configuration or properties' should be interpreted to include 'a change in state,' which is a term sometimes found in the literature relating to 'passive.'" 60 Fed. Reg. at 22,477 Declaration of Paul Blanch in Opposition .to

. Entergy's Motion for Sttmmary Disposition

.. On NYS c:ontention 8 - Transformers 11

may change, but the properties 'of the cable (e.g.,

r~sistance, capacitance) are not designed to change. 'Cables are included as within the scope of§54.21(a)(1).

28. Pipes. The properties of fluids contained within piping may change.

These prop~rties of such fluids include pressure, velocity, flow rates, and temperature. The phase of the fluid . in a pipe may even change. Yet, a pipe is a

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component which is included within the scope of § 54.21(a)(1). A pipe's diameter may narrow at a particular location or the pipe may contain a restriction (e.g.,

"elbow," or "tee") that may change the velocity or pressure of the fluid contained in the pipe; however, the properties of the pipe itself ~ave not changed~ Stated differently, the properties of the contents (fluid) may change, but not the conduit (pipe). The pipe itself is not designed to change its own properties.

29. Heat Exchanger. The tempera.ture properties of the fluids contained.

within a heat exchanger may change, as can a fluid's flow rates. The properties of the fluid in a heat exchanger change in a manner similar to the change in voltage and current that takes place in a transformer. A heat exchanger (another

<?omponent which is included within the scope of § 54.21(a)(1>> is not designed to change its own properties.

30. Steam Generator. The properties and the state of the fluids in a steam generator may both change. The ~uid's,temperature may increase'and the fluid's state may change from Ii,quid to steam'. However, the steam generator itself

,(another component which is included ~ithinthe scope of § 54.21(a)(1>> is not Declaration of Paul Blanch in Opposition to Entergy's Motion for SllmmaryDisposition On NYS Contention 8 - Transformers 12

designed to change its own properties during its normal use .

. 31. Reactor Vessel & Containment. Further, various nuclear processes do occur within the reactor vessel, the containment* liner, or the containment, but those components ar~ included in § 54:21(a)(1). Those processes cause some. wear on those. components,, and that wear is the subject of aging I\lanagement.

32. Turning to transformers, transformers do not have moving parts. The (

properties of the currents and voltages in and out of a transformer may change, but

-the properties and configuration of the transformer and its capabilities (ability to

. \ r transform electricity from one voltage to another) are not designed to change during nor~al operation. Furthermore, ttansformersthemselves do not experi~nce ~

"change of state" as that term is commonly used .

. . Entergy's Argument

33. Dr. Dobbs, in his declaration dated A~gust 12, 2009 piesents a position that transformers change "properties" in that:
20. The table above (paragraph 19) demonstrates that the voltage and

. , current properties ora transformer change depending on the load condition of the transformer.

While I agree with the recognition that the "properties" of the current and voltage inputs and outputs are changed when they pass through a transforrner,I disagree with Dr: Dobbs' implication that those 'are "properties" of the transformer or that the transformer component it~elf changes . .The transformer does not change its

.' Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS Contention 8 . Transformers

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configuration or properties during its intended use; the wire coils do not change state, nor does the internal metal core. Input and output voltages are not I .

"properties" of the transformer itself.

'f 34 . Dr. Dobbs also contends that a transformer is similar to a transistor in'

. that the properties of the transformer and transistor change with the operation of

.the device.

35. As noted above, transformers have properties such as turns ratios, .

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resistance, and capacitance and also have the capability to transform electricity from one voltage to another through a magnetic field generated by the input electrical current. None ofthese properties or capabilities is designed to change during normal operation of a transformer.

36. In contrast, the properties of a transistor itself do change during its normal intended use. Transistor~ are commonly three wire s~lid state d~vices

. initially made from germanium (Ge) and silicon (8i) semiconductor material. A' semiconductor is a material whose resistivity can be changed by applying an electric current to the rriateria.l;a semiconductor's electrical resistance can vary between that of a conductor*(full flow) and that of an insulator (no flow). An external

. electrical field or voltage changes a 'semiconductor's resistiVIty -- which is a property' of the component itself. A transistor clearly undergoes a change in its propert~es and, in some cases, a change in state (from conductor to insulator).

37. This change in resistivity that occurs in the semiconductor canbe

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. Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition

. On NYS Contention'8 - Transformers 14

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thought of as a valve ~hose position maybe changed through an external electric' (stimulus. A small change in the voltage input to a basic transistor changes the properties (resistance and/or 'conductance) of the semiconductor. As a result of this applied yoltage, the semiconductor changes its properties and may act as an insulator, conductor, or variable resistor controlling relatively large currents. , These

. characteristics are the direct result of a cltange in properties oftheseniiconductor.

Many transistors such as silicon controlled rectifiers undergo I .

a"change of state" c

from a conductor to an insulator depending on the applied voltage and the polarity of the applied voltage.

38. A transistor, one of the listed components that are expressly excluded in10 C.F.R. § 54.21(a)(1)(i), is a device that relies on external power to operate and I

requires an external source of energy ,to control its operations. 3 Because of this intended ability t6vary. its resistivity, it is possible

. . to continuously control the

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operation of a transistor and its valve"like function by changing its state (its resistivity). Acco~dingly, a transistor and most/other solid state devices are considered active devices whose properties continu~usly change.

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39. Transistors, tubes, magnetic amplifiers, and other active electronic devices have the capability to control and switch large currents and change/amp~ify J I understand that when the Commissioners modified the license renewal regulations they said "'a change in configuration or properties' should be interpreted

. to in<;:l~de 'a change in state,' which is a term sometimes found in the literature relating to passive. For example a transistor can 'change its state' and therefore would not be screened in under this description." Final Rule, Nuclear power Plant License Renewal; Revisions, 60 Fed. Reg. 22,461, 22,477 (May 8, 1995). '

Declaration of Paul Blanch in Opposition to E~tergy's Motion for' Summary Disposition

. On NYS Contention 8 . Transformers 15

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the power input. Active devices including transistors and other solid state devices normally require an external source of energy (power supply) to perform its function

,of power amplification an"dlor switching. Passive electrical devices, such as resistors, cables,connectors, capacitors, inductors, and transfor'mers are not

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designed or capable of power amplification, changing I

conductance, or otherwise changing the output power based upon an external control sig"nat'

40. "An analogy may be helpful to understand the acti~e nature of a transistor. One might iI"nagine-a simple g~rden hose that has properties such as internal and external diameters, length, stiffness, and materials

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of construction. It may also have design capacities such as maximum flow rate and temperature limitations. I would suggest that a hose is a passive device similar to a pipe. When water flows through'a hose, the properties ofthe hose do not change. Increasing or decreasing the flow does not change the prope~ties ofthe hose. However,if some external force is applied to the hose such as squeezing or crimping the hose with one's hand or foot, the properties of the hose are >changed as a result of changing the

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effective internal diameter of the hose. Turning back to electrical components, a resistor is an electrical component that restricts the flow of electrical~urrent; but it does so at a fixed rate much like a section of hose or pipe. In much the same way that a person might squeeze a hose, the invention of the transistor made it possible for a small voltage from an external source to change the properties of a fixed resistance previously provided by a resistor. Thus, the name "transistor." The Declaration of Paul Blanch in Opposition to Entergy's Motionfor Summary Disposition On NYS Contention 8 - Transformers 16

semiconductor in the transistor changes state in much the same way that the' diameter ofthe hose is 'decreased when someone squeezes the hose. The resistivity pr~perties of a tr~nsistor can be changed on an,ongoi~g manner throughthe application of an external electrical stimulus.

Consequences of Inadequate Management of Transformers

41. As noted in my iriitial (November 2007 declaration and the State of New York's petition; the failure to properly manage aging of Electrical, Transformers at Indian Point may compromise:
a. The integrity of the reactor coolant pressure boundary;
b. Tpe capability to shut down the reactor andmaintain it in ~afe shutdowri condition; or C.l The capability to prevent or mitigate the consequences of I

acciqents which could result in potential offsite exposures

. comparable~o thos~ referred to'in §§ 50.34(a)(I), 50.67(b)(2)(or § 100.11 of ~his bhapter, as applicable. 10 C.F.R. §§ 54.4(a)(I)(2) and (3).

42. Tlhe consequence of failures of Electrical Transformers may result in accidents beyond the Design Basis Accidents resulting in exposures to the_public

" , i, exceeding 10 C.F.R. § 100 limits. ( \

43. Failure to properly manage aging of electrical transformers could

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Declaration of Paul Blanch in Oppositioh to Entergy's Motion for Summary Disposition On NYS Contention 8 - Transformers 17

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, result in loss of emergency power to the 4,80 volt safety equipment and 6.9kV busses including station blackout loads.

44. Recentl/'there h~ve been a number oftransfa'rmer failures at power reactors, which although ~RC staff believes generally do not involve safety related transformers, provide evidence that since the time of the 1997 Grimes memorandum and 1995 NEI paper, there is agrowing realization ofthe importance of the need for the proper mainten~nce and aging management oftransformers.

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For example, as disc~ssed in NRC Information Notice 2009-10 4 :

  • Iri.dian Point, Unit 3~On AprilS, 2007, while operating at 92-percent.

power, a fault occurred on the No. 3.1 main transformer resulting in an automatic reactor trip and transformer explosio'n and fire.

  • Limerick Generating Stati0I1, Unit 2c-On February 1, 2008, a low

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. voltage bushing connection failed on the 2A main transformer

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resulting in a turbine trip and reactor scram. '

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  • Diablo Canyon, Unit 2-0nAugust 16, 2008, an automatic reactor trip.

occurred resulting from the failure of the main electrical transformer C phase. PI~nt operators subsequently declared a Notification of Unusual Event due to an observed fire at the C phase transformer.

  • North Anna, Unit 2-0n October 29,2008, while.cI'ttempting to place th~ unit on line, the turbine tripped on a generator lockout relay 4 NRC Information Notice 2009-10, Transformer Failures - Recent Operating

~ Experience, July 7, 2009, ADAMS ML090540218.

Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS Contention 8 - Transformers 18

actuation. The C main transformer was discovered to be spraying oil.

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  • Oyster Creek-On November 28, 2008, an electrical fault internal to

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the MIA main transformer led tq an automatic reactor scram due to load reject. ' That transformer was replaced with the spare, and on February 1, 2009, this replacement transformer failed due to a bushing failure , resultin'g in a reactor scram, fire, and declaration 'of a I Notification of Unusual Event.

45. In 2003, EPRI publ~shed ,a report that identified a growing problem withfailures in large transformers and a wide range of mai~tenance programs that it recommended be implemented by nuclear utilities to address these problems including the problem of aging degradation of transformers. EPRI Life Cycle Management Planning Sourcebooks, Volume 4, Large Power Transformers,

, [1007422], March 2003, at 4-1 to 4~ 6, 4-17 and 6-2 to 6-.13 '

46. In 2006, EPRI.published 1:!notherreport that also identified problems with failures in large transformers a~d a wide range of diagnostic pro'g rams that it recommended be implemented by nuclear plant operators to address these problems including the problem of aging degradation of transformers and develop contingency

. planning to preClude end-of-life failures. EPRI, Large Transformer End-of-Expected-Life' Considerations and the Need for Planning [1013566], December 2006

47. In 2006, IEEE published a report listing failure modes ,of transformers and methods for detecting these failures before they occur. IEEE Guide for the Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS Contention 8 - Transformers

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Evaluation and Reconditioning of Liquid Immersed Power Transformers (IEEE Std C57.140-2006) at 11-15.

48. . In 1994, Sandia National Laboratories published a report identifying aging degradation mechanisms for transformers. Sandia, Aging-Management Guideline for Commercial Nuclear Power Plants Power and Distribution Transformers, SAND93-7068' UC-523 Unlimited'Release, May 1994; at 4-1 to 4-23.
49. These reports make clear that while some modes of transformer failure can be detected by performqnce monitoring there are significant transformer failure modes that involve aging degradation of transformer components that do not affect transformer operating perform:;tnce until the transformer fails and for which aging.

management programs that go beyond performance monitoring a~e required.

50. Over time transformers age and can) experience failure. For example, over time, the insulation can deteriorate, internal shorts' could develop, moistur'e can collect in the components, or cdimectlons can Qecome loose; also, there could be a loss of coolant, an accumulation of oil, dirt, or salt spray, or corrosion.
51. The 'aging degradation of some constituent parts of transformers is not

'detected by performance monitoring~ Nevertheless, aging management programs!

could be implemented to address transformer component agin-g and help to ensure that the transformers will be capable of performing their designated function. Not

. only should transformers in active operating electrical systems be age managed, but so should transformers that are part of electrical systems that are used less Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS Contention 8 - Transformers, 20

frequently such as the~~3 transformers for Appendix R (6.9KV/480V),' 15 KVA GRD transforme~s for the gas turbines, Station Service Transformers and transformers for Station Black Out (SBO). Some of these transformers may not normally be energized and/or operating under full load conditions.

52. The 2009 Information I:'Jotice, EPRI~ s 2003 report entitled Large'

.Transformer End-of-Expected-Life

( ' .

Considerations and the Need for Planning

\

. . \

[1013566], and IEEE's 2007 report entitled IEEE Guide for the Evaluation and Reconditioning of Liquid Immersed Power Transformers[C57.140TM-2006], indicate.

that current monitoring procedures for detecting the performance of transformers, such as'those in use at Indian Point,are not adequateto detect, in advance of

. , I

\ failure, all of the aging de(ects and degradation phenomena in transformers. The

. declaration of Mr. Rucker makes general reference (at paragraphs 19-21) to monitoring programs that seem to be focused on the performance of the transformers, but not onthe condition ofthe transformer components themselves.

Mr. Rucker:s declaration contains only generalities about performance monitoring .

. It also contains many qualifiers that make it difficult to understand the depth or the extent of such monitoring. While it makes reference to "transformers" or "certain" transformers, it does not demonstrate that the licensee will monitor the I

perfor'mance of all transformers that would be within the scope of Part 54, nor does it explain how the licensee monitors transformers that may not normally he

. )

~ energized and/or operating under full load conditions.

Declaration of Paul Blanch in Opposition to Entergy's

)..

Motion for. Summary Disposition

. .On NYS Contention 8 - Transfornters 21

53. Moreover,~imply monitoring the performance of transformers may not ensure that critical transformer components are not degrading to the point of componentfailure -- now or during the period oflicense extension. As discussed in the 1994 Sandia Report, the2003 EPRI report, the 2006 EPRI report, and the 2006 IEEE report, monit~ring pr~cedures such as component performance monitoring, personnel training, and quality assurance audits are not adequate. Such
  • *0 monitoring procedures do not provide the level of aging management sufficient to demonstrate that the various transformers will perform their intended functions during the *period of extended operation including a potential design basis accident or incident. Additional aging management programs could be implemented to detect aging degradation of transformers and their component parts in advance of failure. See,e.g."EPRI 2003 Report, at 7-2 & sec. 7.1.2. Aging management, programs for age related degradation of transformers may include physical inspections, power factor testing, analysis of insulation resistance, oil leakage, gas-in-oil, comparison with original factory test reports, and vibration (humming). By way of example; the 2003 EPRI Report identifies additional testing, surveillance; and inspection techniques that could support a meaningful aging management program. See, e.g., EPRI 2003 Report, at 6-1 to 6-16
54. Attached to thi!? declaration is a true and correct copy of NRC

. )

Information N~tice 2009-10, Transformer Failures - Recent Operating Experience, July 7,2009, ADAMS ML090540218 as wE?ll as excerpts of: IEEE Standard Declaration of Paul Blanch in Opposition to Entergy's Motion for Summary Disposition On NYS Contention 8 - Transformers

,22

National Laboratories, Aging Management Guideline for Commercial Nuclear

(

Power Plants Power and pistribution Transformers, SAND93~7068* UC-523 Unlimited Release, May 1994.

Declaratian af Paul Blanch in Oppositian to.

Entergy's Matian far Summary Dispasitian On NYS Cantentian 8 - Transfarmers 23.

  • ,'1 WiJB~ETF:EE .;£.4TILE  :'i'. ... ;* *

.... - ,:, ~..

_ "'" J

' : ' : "I :

J .. ........... "

L~*.u l.Jc.~ ' CJ ......... - t"tU

  • r . G...J Pursuant to.28 U.S:C. § 1746, I declare under pe~alty of perjurY under the lawBofthe United States of Amerie~ that the foregoing i.s true and correct.

Dated; September 22. 20.0.9 Seattle, Washington

/

/ Paul Blanch

/

\'

Declarat~onol Paul B14nchin Oppo,~io1\. Co Ent.rgy'(I Motio", for SLl.1nmory Dispositioll On NYS Contentdl1\. 8 . TraM/or-mers 24

\ .

REFERENCES Flanagan, The 'H andbook of Transformer Design & Application (2nd Addition) page 1.1, McGraw-Hill 1993, ISBN 0-07-0212~1-0 .

Harlow, Electric Power Transformer Engineering, page 2-1, CRCPress (2004) ISBN 0-8493- i 704-5 (

Harlow, Electric Power Transformer Engineering, page 2-1 (2d Edition) CRC Press (2007) ISBN 0-8493-9186-5 IEEE Standard Dictionary of Electrical and Electronic Terms, IEEE Std 100-1996 (6 th Edition), page 1131, ISBN 1-55987-833-6 (1996)

UFSAR, Indian Point Unit 2, Chapter 8 (2007) .

UFSAR, Indian Point Unit 2, figure 8.2-1, 8 .2-2 (electrical drawing)

  • \ '. I - ' I'
  • J ' " '

UFSAR, India~ Point Unit 3, Chapter 8 (2007)

Indian Point No.3 Nuclear Power Plant, Electrical Distribution & ,Transmission System, DWG NO 9321-F-33853, REV 17 (electrical drawing)

NRC Information Notice 2009-10, Transformer Faih.lres -Recent Qperating Experience, July 7, 2009, ADAMS ML090540218 .

EPRI report, EPRI Life Cycle Management Planning Sourcebooks, Volume 4, Larg~

Power Transformers, [1007422], March 2003 EPRI report, Plant Support Engineering: Large T~ansformer End-of-Expected~Life Considerations and the Need for Planning [1013566], December 2006 IEEE report, IEEE Guide for the Eva:luation;and Reconditioning of Liquid Immersed Power Tra!1sformers [C5?140TM-2006] , April, 2007 Sandia Na.tionalLaboratories report, Aging Management Guideline for Commercial '

Nuclear Power Plants Power and Distribution Transformers, SAND93-7068* UC-523, Unlimited Release; May 1994 .

Declaration of Palll Blanch in Opposition to Entergy's lv/otion for Summary Disposition On NYS Contention 8 - Transformers 25

COMPARISON OF VARIOUS STRUCTURES AND COMPONENTS Change Included, Change Active Moving In Excluded Component In or Parts Config u ration/ 2 In 1 State Passive Properties 10 CFR 54.21 Reactor vessel No No No' Passive Included Reactor coolant system No No No Passive Included pressure boundary Steam generators No No No Passive Included Pressurizer No No No Passive Included Piping No No -No Passive Included Pump Casings No No No Passive Included Valve Bodies No No No Passive Included Core Shroud No No No Passive Included Component Supports No No No Passive Included Pressure Retaining Boundaries No No No Passive Included Heat Exchangers No No No - No No Passive Passive Included Ventilation Ducts No Included Containment and Liner No No No Passive Included Penetrations No No No Passive Included Equipment Hatches No No No Passive Included Seismic Structures No No No Passive Included Cable Trays No No No* Passive Included Cables and Connectors No No No Passive Included Electrical Cabinets No No No Passive Included Pumps (except casings) Yes Yes Yes Active Excluded Valves (except bodies) Yes Yes .Yes Active Excluded Motors Yes Yes Yes Active Excluded Diesel Generators Yes Yes Yes Active Excluded Air Compressors Yes Yes Yes Active Excluded Snubbers Yes No Yes Active Excluded Control Rod Drive Yes Yes Yes Active Excluded Ventilation Dampers Yes Yes Yes Active Excluded 3 4 Pressure Transmitters Yes NA Yes Active Excluded Pressure Indicators Yes NA Yes Active Excluded Water Level Indicators Yes NA Yes Active Excluded SwitchRears Yes Yes Yes Active Excluded Cooling Fans Yes Yes Yes Active Excluded Transistors No Yes Yes Active Excluded /

Batteries No NA Yes Active Excluded Breakers Yes Yes Yes Active Excluded o

Relays Yes Yes Yes Active* Excluded Switches Yes Yes Yes Active Excluded Power Inverters No Yes Yes Active b Excluded Circuit Boards No Yes Yes Active Excluded Battery Chargers No Yes Yes ActiveO Excluded Power Supplies No No Yes Active" Excluded Table - Comparison of Various

. Structures and Components T-l

/

\

Change Included, Change Active Moving .In Excluded Component In or Parts Configurationl In State 2 Passive Properties 1 10 CFR 54.21 Transformers f No No No Passive Neither Included nor

- Excluded Heaters No No No Passive Neither Included not Excluded Lamps (incandescent) , No No I No Passive Neither Included nor Excluded lU Lamps (LED) No Yes Yes Active Neither Included nor Excluded Lamps (CFL) _ No Yes Yes Active Neither, Included nor Excluded Fuses No No Yes'.' Active' Neither Included. nor-

. I Excluded Resistors No No No Passive Neither Capacitors Included nor Inductors Excluded Endnotes appear on p. T-3 ,

Table - Comparison of Various Structures and Components T-2

Table Endnotes:

I Change in configuration occurs only with an externa'l energy source applied.

2 Final Rule, Nuclear Power Plant License Renewal; Revisions , 60 'Fed . Reg . 22,461, 22,477 (May 8, 1995): "Further, the Commissionhas concluded that 'a change in configuration orproperties,' should be interpreted to include 'a change in state,' which is a term sometimes found in the literature relating to

'passive.'" .

.J Pressure and level transmitters mayor may not contain moving parts. Solid state indicators (LEOs or plasma) contain no moving parts; however. they do .contain solid state devices such as transistors.

4 Most process transmitters and indicators (level, flow, pressure) contain either moving parts or transistors (solid state devices) and are considered "active."

5 Solid state relays and switches do not contain moving parts; howev~r, they are considered active based upon the Commission's SOC related to transistors. .

. \ .

6 Power inverters employ solid state and other active devices to convert DC power to AC power. Power output may be controlled by external inputs.

7 Circuit boards are assumed for the purpose of this discussion to contain active components such as transistors and other solid state devices. .

8 Battery chargers convert AC voltages and currents to DC using solid stClte active devices such as transistors and rectifiers. Power output ')lay be controlled by external inputs.

9

  • Power supplies convert AC voltages and currents to DC regulated voltages using solid state active devices such as transistors and rectifiers.

10 Light Emitting Diodes (LEOs) change state (conductance) when a voltage is applied . *Stateis .

determined by the polarity of the applied voltage. .

II Compact Fluorescent Lights (CFL) lamps contain active devices such as diodes and transistors and may also contain passive devices including transformers: .

12 In order to perform their intended function, fuses undergo a change of state (conductance).

Table - Comparison of Various Structu res and Components T-3

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