ML12355A649
| ML12355A649 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/12/2012 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| SECY RAS | |
| References | |
| RAS 23919, 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NRC-2033 | |
| Download: ML12355A649 (231) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Entergy Nuclear Operations, Inc.
Indian Point Units 2 and 3 Docket Number: 50-247-LR and 50-286-LR ASLB Number: 07-858-03-LR-BD01 Location: Tarrytown, New York Date: Wednesday, December 12, 2012 Work Order No.: NRC-2033 Pages 3980-4208 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
3980 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 Wednesday, December 12, 2012 14 15 DoubleTree by Hilton Hotel Tarrytown 16 Westchester Ballroom 17 455 South Broadway 18 Tarrytown, New York 19 20 BEFORE:
21 LAWRENCE G. McDADE, Chair 22 MICHAEL F. KENNEDY, Administrative Judge 23 RICHARD E. WARDWELL, Administrative Judge 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3981 1 APPEARANCES:
2 On Behalf of Entergy Nuclear Operations, Inc.:
3 KATHRYN M. SUTTON, ESQ.
4 PAUL M. BESSETTE, ESQ.
5 BRAD FAGG, ESQ.
6 MARTIN J. O'NEILL, 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) 739-5191 (Fagg) 13 (713) 890-5710 (O'Neill) 14 ksutton@morganlewis.com 15 pbessette@morganlewis.com 16 bfagg@morganlewis.com 17 martin.o'neill@morganlewis.com 18 and 19 WILLIAM DENNIS, ESQ.
20 Assistant General Counsel 21 Entergy Nuclear Operations, Inc.
22 440 Hamilton Avenue 23 White Plains, New York 10601 24 (914) 272-3360 25 wdennis@entergy.com NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3982 1 On Behalf of the Nuclear Regulatory Commission:
2 SHERWIN E. TURK, ESQ.
3 BETH N. MIZUNO, ESQ.
4 DAVID E. ROTH, ESQ.
5 Office of the General Counsel 6 Mail Stop - O-15 D21 7 U.S. Nuclear Regulatory Commission 8 Washington, D.C. 20555-0001 9 (301) 415-1533 (Turk) 10 (301) 415-3122 (Mizuno) 11 (301) 415-2749 (Roth) 12 sherwin.turk@nrc.gov 13 beth.mizuno@nrc.gov 14 david.roth@nrc.gov 15 16 On Behalf of the State of New York:
17 JOHN J. SIPOS, ESQ.
18 Assistant Attorney 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 COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3983 1 and 2 LISA FEINER, ESQ.
3 JANICE A. DEAN, ESQ.
4 Assistant Attorneys General 5 Office of the Attorney General of the 6 State of New York 7 120 Broadway, 26th Floor 8 New York, New York 10271 9 (212) 416-8479 (Feiner) 10 (212) 416-8459 (Dean) 11 lisa.feiner@ag.ny.gov 12 janice.dean@ag.ny.gov 13 14 On Behalf of Riverkeeper, Inc.:
15 DEBORAH BRANCATO, ESQ.
16 Riverkeeper, Inc.
17 20 Secor Road 18 Ossining, New York 10562 19 (800) 21-RIVER 20 dbrancato@riverkeeper.org 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3984 1 On Behalf of Hudson River Sloop 2 Clearwater, Inc.:
3 KARLA RAIMUNDI 4 Hudson River Sloop Clearwater, Inc.
5 724 Wolcott Avenue 6 Beacon, New York 12508 7 (845) 265-8080 8 karla@clearwater.org 9
10 On Behalf of the Village of Buchanan:
11 TERESA KNICKERBOCKER, Deputy Mayor 12 Municipal Building 13 236 Tate Avenue 14 Buchanan, New York 10511-1298 15 (914) 737-1033 16 thresak@villageofbuchanan.com 17 18 On Behalf of Westchester County, New York:
19 CHRISTOPHER INZERO, ESQ.
20 Assistant County Attorney 21 Office of the County Attorney 22 600 Michaelian Office Building 23 148 Martine Avenue 24 White Plains, New York 10601 25 (914) 995-2660 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3985 1 P R O C E E D I N G S 2 8:02 a.m.
3 JUDGE McDADE: On the record. We will 4 come to order. We have a new group of witnesses here 5 this morning to testify on Contention 6 and 7 from New 6 York. Good morning.
7 Before we get started, let me explain a 8 little bit about how we're going to be proceeding 9 here. During the course of the morning and the 10 afternoon, we, the members of the Board, are going to 11 be asking you questions. Our questions are going to 12 be directed to you. Your answers back up to the 13 Board.
14 In many instances, there are going to be 15 situations where witnesses representing one party are 16 going to disagree with witnesses representing another 17 party. That's what we anticipate.
18 But this is not a dialogue between the 19 witnesses. You don't talk back and forth among 20 yourselves. You don't talk to your counsel. You 21 direct your answers to us. We direct our questions to 22 you.
23 If there's any questions you don't 24 understand, don't feel shy at all about asking us to 25 rephrase the question. It's important that you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3986 1 understand our questions so that your answer will be 2 understood by us in context.
3 Likewise, if for some reason you need a 4 break, don't feel at all shy about asking us to take 5 a break. If you don't catch our eye, ask your 6 counsel. Try to catch their eye and they won't be shy 7 about asking us for a break.
8 Does any member of the panel have any 9 questions before we get started here this morning?
10 (Chorus of nos.)
11 Okay. Apparently not. It is necessary 12 that the testimony you give be under oath. So at this 13 time would you all please raise your right hand. Do 14 you swear that the testimony you will be giving here 15 this morning is the truth, the whole truth and nothing 16 but the truth?
17 (Chorus of I dos and yeses.)
18 Okay. Thank you. Do counsel have 19 anything before we get started with the questioning of 20 the witnesses? From Entergy?
21 MR. BESSETTE: Yes, Your Honor. This is 22 Paul Bessette for Entergy. Just a couple of 23 preliminary matters. Yesterday and actually Monday 24 and Tuesday there was quite a bit of questioning and 25 testimony on the corrective action process. We wanted NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3987 1 to let you know that Entergy's corrective action 2 process procedure is an exhibit on that contention.
3 It's ENT000401 for the Court's reference.
4 Also there was quite a bit of discussion 5 on the 10 CFR 50.59 process and the 10 CFR 50.59 6 screening process. And if it would assist the record, 7 there are corporate procedures relevant to those. And 8 what we would propose to do is early next week offer 9 just those company procedures as exhibits. And I 10 would allow the parties to respond by the January 7th 11 motion in limine date. But we think those two 12 procedures just might be helpful to have in the 13 record, Your Honor.
14 JUDGE McDADE: I agree. Thank you, Mr.
15 Bessette.
16 MR. BESSETTE: And also with one other 17 reference yesterday to a soil sample analysis result 18 for IP2. And we would propose to include that in the 19 record as well. But we would file that motion early 20 next week.
21 JUDGE McDADE: Okay. Thank you.
22 From New York?
23 MR. SIPOS: Good morning, Your Honor.
24 First of all, I'd like to introduce or reintroduce my 25 colleague, Assistant Attorney General Lisa Feiner, who NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3988 1 is with us.
2 JUDGE McDADE: Good morning.
3 MR. SIPOS: And who was also with us back 4 in Rockville. And also I would just note as a 5 preliminary matter that there were some documents that 6 were initially designated as confidential or 7 proprietary. The State filed a letter with Your 8 Honors on September 14th. And that letter reflected 9 an understanding between Entergy and the State 10 regarding those exhibits.
11 And then Entergy followed up I believe on 12 September 21st and had removed the designations for 13 three of the four documents. So that should obviate 14 any concern about closing today's evidentiary hearing 15 with respect to proprietary information.
16 JUDGE McDADE: Okay. Thank you.
17 From Riverkeeper?
18 MS. BRANCATO: No, Your Honor.
19 JUDGE McDADE: Clearwater?
20 MS. RAIMUNDI: No, Your Honor.
21 JUDGE McDADE: And the Staff?
22 MR. RANDOLPH: David Roth for the Staff.
23 No, Your Honor.
24 JUDGE McDADE: And nothing from 25 Westchester?
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3989 1 MR. INZERO: Christopher Inzero for the 2 County. No, Your Honor.
3 JUDGE McDADE: Okay. One thing I do want 4 to also mention to you is it is important that the 5 court reporter be able to know who is talking when he 6 prepares the transcript. So what we would ask is when 7 you do respond to a question or you do talk if you 8 could preface it by stating your name. And that way 9 it will be clear on the record.
10 One of the last things we don't want is to 11 a witness from New York have something they say 12 attributed to Entergy or the other way around. We 13 need to have it attributed to the correct person. So 14 if you don't state your name, we will be interrupting 15 you or stating your name for you to make sure it's 16 clear on the record. But please try to do that.
17 Judge Kennedy.
18 JUDGE KENNEDY: Good morning, everybody.
19 First of all, welcome to 12/12/12. I predict we'll 20 have a monumental day here. That's not to say that 21 the other two days were not monumental as well.
22 I don't see any humor on my other judges' 23 faces.
24 JUDGE McDADE: This isn't the day that the 25 world ends according to the Mayan calendar.
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3990 1 JUDGE KENNEDY: Unfortunately not.
2 JUDGE McDADE: Okay. So I need to take 3 notes.
4 JUDGE KENNEDY: We need to take notes and 5 we need to be prepared. Anyhow, just a bit of humor.
6 It's just interesting how big of a deal the paper made 7 of the 12/12/12. I guess I will note for the record 8 I guess that this is the last triple digit day of the 9 century. So it truly is an exciting day. We probably 10 should figure out how to get extra cookies out of the 11 DoubleTree and pass them around.
12 All right. This is New York State 13 Contentions 6 and 7. And as it is our tradition, I'll 14 give a brief overview of what the contention at least 15 from our perspective is all about.
16 New York State 6 and 7 has been 17 categorized as a safety contention because of the 18 potential safety significance of the components 19 impacted by this Aging Management Program. The 20 contention for hearing today is composed of two major 21 issues.
22 The first issue relates to New York 23 State's assertion that the Indian Point Aging 24 Management Program lacks specificity necessary to 25 demonstrate that the effects of aging will be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3991 1 adequately managed for the period of extended 2 operation.
3 We've been down this path on a couple of 4 the other Aging Management Programs. We use the term 5 "level of detail." We'll be doing a lot of exploring 6 today as to where the level of detail is as we did 7 over the previous two days here.
8 Specifically, New York argues that the 9 Indian Point Aging Management Program for non EQ 10 inaccessible power cables lacks critical information 11 for corrective actions, testing methods and assessment 12 criteria and testing to be conducted before the period 13 of extended operation.
14 The second issue is that Entergy has 15 failed to provide an Aging Management Program for non-16 EQ inaccessible power cables exposed to excessive 17 heat. And so we have broken down our questioning and 18 aligned it according to those two issues.
19 And we'll start with the first issue which 20 is in a shortcut nomenclature relates to the level of 21 detail that has been provided in the Aging Management 22 Program, where it is provided in the Aging Management 23 Program and how one can come to a determination that 24 there is reasonable assurance that the effects of 25 aging could be managed for the systems, structures and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3992 1 components that will be managed by this program.
2 Let me start with just maybe an icebreaker 3 question or just some questions to orient ourselves.
4 Maybe I'll direct these first to Entergy since it's 5 their Aging Management Program. What is meant by non-6 EQ power cables? What is the characteristic that 7 differentiates those from other power cables within 8 the facility?
9 MR. RUCKER: This is Roger Rucker for 10 Entergy.
11 JUDGE KENNEDY: Could you say your name 12 again please?
13 MR. RUCKER: Roger Rucker for Entergy.
14 JUDGE KENNEDY: Thank you, sir.
15 MR. RUCKER: Non-EQ refers to 10 CFR 16 50.49. So non-EQ cables would mean those cables that 17 are not included in the 10 CFR 50.49 for Environmental 18 Qualification of Electrical Components Program.
19 JUDGE KENNEDY: So it's a subset of the 20 power cables in the plant.
21 MR. RUCKER: Correct. I mean anything 22 that's EQ by the rule, 10 CFR 50.49, those are the 23 cables that are required to function during an 24 accident when the conditions become harsh according to 25 the rule.
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3993 1 JUDGE KENNEDY: So there's a separate 2 Aging Management Program as I understand for those 3 cables.
4 MR. RUCKER: Right. It's a little bit 5 more than an Aging Management Program. It's a 6 qualification program where they are qualified for the 7 service, the life that they're associated with and the 8 accident on top of the life.
9 JUDGE KENNEDY: So one of the things that 10 differentiates these power cables is the environment 11 to which they're exposed. Is that fair or am I 12 overstating?
13 MR. RUCKER: The environment they can be 14 exposed to during an accident condition.
15 JUDGE KENNEDY: And that would be the EQ 16 cables.
17 MR. RUCKER: That's correct.
18 JUDGE KENNEDY: Okay. So the non EQ 19 cables are not expected to see that sort of 20 environment.
21 MR. RUCKER: Either they're not needed to 22 mitigate the consequences of the accident or they're 23 not going to be exposed to the environment of an 24 accident.
25 JUDGE KENNEDY: Would it be fair to say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3994 1 these power cables are exposed to plant operating 2 conditions and that's another differentiater for non 3 EQ versus EQ.
4 MR. RUCKER: I mean EQ and non EQ cables 5 are both going to be exposed to the plant operating 6 conditions. The difference is if the accident 7 condition is going to be harsher than the plant 8 operating condition and it has to continue to operate 9 during the accident.
10 JUDGE KENNEDY: Okay. So it's the duty to 11 continue to operate under a certain set of conditions.
12 MR. RUCKER: That's correct.
13 JUDGE KENNEDY: I see. Thank you.
14 I guess the next question which hopefully 15 is easier is what makes the cables inaccessible. What 16 am I looking for to differentiate these types of 17 cables from other cables? Or maybe they don't 18 differentiate. But I'm kind of taking the title apart 19 I guess.
20 MR. RUCKER: This is Roger Rucker for 21 Entergy. The Inaccessible Medium Voltage Cable 22 Program, that specific program, is for below grade or 23 underground cables. That's the specific thing that is 24 being looked at for aging effects in the environment.
25 The Non EQ Insulated Cables and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3995 1 Connections Program is applicable to accessible and 2 inaccessible cables that are above ground. For 3 example, a cable in a conduit would be considered 4 inaccessible and a cable in a cable tray would be 5 considered accessible.
6 JUDGE WARDWELL: Do you have any numbers 7 for those programs or something? Say the title over 8 again.
9 MR. RUCKER: If you look in Table 1 of our 10 testimony and I believe that's page 18.
11 JUDGE KENNEDY: Would you like us to 12 display that?
13 MR. RUCKER: That's up to you.
14 JUDGE WARDWELL: Do you have an exhibit 15 number for your testimony?
16 MR. RUCKER: That's 000233 I think.
17 MR. BESSETTE: Your Honor, this is Paul 18 Bessette, the Applicant. It would be helpful to 19 display that because it provides a summary for the 20 testimony road map.
21 MR. O'NEILL: Martin O'Neill for the 22 Applicant. The exhibit number is ENTR00233.
23 JUDGE KENNEDY: Mr. Welkie, could you put 24 that up please. And it was Table 1.
25 MR. RUCKER: That's correct. Page 18.
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3996 1 The first column gives an explanation of the rows to 2 be there. The second column is going to be the 3 Inaccessible Medium Voltage Cable Program. And the 4 last column is the Non EQ Insulated Cables Connections 5 Program.
6 It gives the LRA section that they're 7 applicable to, both Appendix A and Appendix B. It 8 gives the letters for the Amending RAIs to those 9 sections of the application. It gives the 10 corresponding NUREG-1801 program.
11 It gives a little bit about the scope of 12 the program, relevant aging effects, the Entergy fleet 13 procedures. And these are the executing or the 14 implementing procedures. Industry documents and the 15 SER sections.
16 JUDGE KENNEDY: All right. Thank you.
17 And so the first column here is the program that's the 18 focus of New York State 6 and 7. Is that your 19 understanding?
20 MR. RUCKER: Both of these would be 21 applicable to 6 and 7 because --
22 JUDGE KENNEDY: I see. Okay.
23 MR. RUCKER: The first one is below grade 24 cables and then the second one is above grade cables 25 or below ground above grade or above ground.
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3997 1 JUDGE KENNEDY: Okay. Thank you. That 2 clears up a question I had.
3 MR. RUCKER: Okay.
4 JUDGE KENNEDY: So the cable and 5 connections is all above ground. It's above ground 6 cabling.
7 MR. RUCKER: That's correct.
8 JUDGE KENNEDY: Okay. Yes, I guess in my 9 own mind -- and we'll talk a bit more about the second 10 column when we get to the as I call it the second 11 issue which is the potential for excessive heat 12 degradation. But I think I'm going to start with the 13 first column here on this table.
14 If I was -- This may be useful. I 15 appreciate putting this up. This may be useful. I 16 was going to focus on asking first Entergy where the 17 Aging Management Program is. And I think this table 18 answers it if I understand it. The LRA sections that 19 contain the AMP, where would you point this to for the 20 inaccessible cables?
21 MR. RUCKER: For the Inaccessible Medium 22 Voltage Cable Program, that's going to be in and the 23 AMP is described in Appendix B.1.23 and then as 24 amended by the RAI letters that are cited there.
25 JUDGE KENNEDY: Okay. I guess to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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3998 1 Staff. When you start the review for the adequacy of 2 the Aging Management Program, where do you start that 3 review in particular in regard to the Inaccessible 4 Medium Voltage cabling? And we have two Staff members 5 today.
6 MR. NGUYEN: My name is Duc Nguyen. I am 7 on the Staff. We review the Aging Management Program 8 and it's governed by the regulation. And the 9 regulation in 54.29(a) states that. A review license 10 may be issued by the Commission up to the term 11 authorized by the 54.38 if the Commission finds that 12 action had been identified and have been or will be 13 taken with respect to identify the aging effect 14 assuming that the Applicant will manage aging effect.
15 So the point is actions have been taken.
16 And we perform the audit at the site to verify that 17 the Applicant is consistent with the -- by reviewing 18 the ten attributes.
19 JUDGE KENNEDY: Mr. Nguyen, were you the 20 technical reviewer for this Aging Management Program 21 Aging Management Program ?
22 MR. NGUYEN: Yes, I am a technical 23 reviewer of this program when they are consistent with 24 GALL Rev 1.
25 JUDGE KENNEDY: Okay.
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3999 1 MR. NGUYEN: And later on we expand the 2 program by request for additional information to 3 expand the program to include the low voltage cable.
4 We also request the Applicant to provide more 5 restricted program by the testing of the cable every 6 sixth year within the ten years and also required the 7 Applicant to provide an manual inspection annually 8 instead of every two years as indicated in the GALL 9 Rev 1.
10 JUDGE KENNEDY: Could you say that last 11 sentence again?
12 MR. NGUYEN: Yes. For the inspection of 13 -- water the GALL Rev 1 only required to do every two 14 years. But the Applicant revised the program. Now 15 they require to inspect the water in the manhole at 16 least annually.
17 JUDGE KENNEDY: So it sounds like there 18 were three -- and maybe enhancements is the wrong word 19 -- additions to the Aging Management Program from the 20 point at which it was submitted in the original 21 License Renewal Application.
22 MR. NGUYEN: Yes, Your Honor.
23 JUDGE KENNEDY: If in the process of doing 24 your technical review -- I'm assuming and I'm going to 25 ask you to confirm it -- is your starting point the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4000 1 Aging Management Program that is in the license 2 renewal application?
3 MR. NGUYEN: Yes.
4 JUDGE KENNEDY: And in this case that 5 would be the B.1.23 section of the License Renewal 6 Application.
7 MR. NGUYEN: Yes, Your Honor.
8 JUDGE KENNEDY: Okay. I wonder, Andy or 9 Mr. Welkie, if we could call up an exhibit that would 10 display the Aging Management Program. I wrote down 11 Entergy Exhibit 000015B. But I'll stand corrected if 12 someone has a better idea. I wrote down Entergy 13 000015B and I have listed page B-81.
14 MR. DOUTT: This is Cliff Doutt. Another 15 reference might be New York 000147 A-D. Might be 16 probably in D.
17 JUDGE KENNEDY: Okay. Did I hear a better 18 reference?
19 MR. DOUTT: No, this is it.
20 JUDGE KENNEDY: Okay. So we're on Entergy 21 000015B, Andy. Okay.
22 So, Mr. Nguyen, is this the starting point 23 for your technical review?
24 MR. NGUYEN: Yes.
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4001 1 review begin before you travel to this -- I want to 2 separate your initial technical review from the site 3 audit. And again we've discussed the site audit 4 process in some of the previous answers. But I'd like 5 to go back to where this all begins. And I'd like to 6 know from your perspective. Is this where you start 7 your technical review?
8 MR. NGUYEN: Yes. I start my technical 9 review by first I review the Applicant's Final Safety 10 Analysis Report, in this case, Chapter 8 to understand 11 the electrical power system at the site, identify any 12 cable to perform the safety function, any cable in 13 accessible location whose failure could affect the 14 safety function and any inaccessible medium voltage 15 cable which are required in the regulation by station 16 blackout and the Environmental Qualification Defined 17 Regulation Rule.
18 JUDGE KENNEDY: Does that give you an 19 orientation to the electrical cabling world within IP2 20 and 3?
21 MR. NGUYEN: Yes.
22 JUDGE KENNEDY: Is that what you're trying 23 to say?
24 MR. NGUYEN: Yes. That's my starting 25 point.
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4002 1 Next I look at the Program Description and 2 I compare this Program Description to the Program 3 Description in the GALL. Most important element is 4 captured in the Program Description. What is the 5 medium voltage cable in this case computable to 35 6 feet of -- Keep in mind that we have not included low 7 voltage yet in the Rev 1.
8 JUDGE KENNEDY: Right. This is the 9 initial application.
10 MR. NGUYEN: Yes. And any cable that is 11 buried underground under conduit that is the scope of 12 this program. That's my starting point. And any 13 operating experience the Applicant may have, we can 14 maybe get that this program may not be adequate.
15 And then we go to the audit side and 16 review the basic documents.
17 JUDGE KENNEDY: Let's stay with this for 18 just a second. So as you pointed out in your mind the 19 Program Description here is an important starting 20 point for this Aging Management Program.
21 MR. NGUYEN: Yes, sir.
22 JUDGE KENNEDY: In your technical review.
23 MR. NGUYEN: Yes, sir.
24 JUDGE KENNEDY: Is there any information 25 on page B.82 or is this the entire AMP right here?
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4003 1 MR. NGUYEN: Can you repeat the question?
2 JUDGE KENNEDY: This is the -- Mr. Welkie, 3 is there any information related to this AMP on the 4 next page? Just the conclusion. Okay.
5 Let's go back to B.81. Again, 6 understanding from the perspective of this contention, 7 this contention challenges the level of detail or the 8 adequacy of the Aging Management Program to manage the 9 aging effects. Where on this page then would you 10 ascribe the details of this Aging Management Program?
11 MR. NGUYEN: Important element in this 12 description. But keep in mind we are going to do the 13 audit at the site. I look at the program attribute.
14 But look at this particular program description.
15 First of all, they will perform the 16 inspection of the water in the manhole and 17 periodically remove the water. And they will test the 18 cable to provide indication of the condition on the 19 cable insulation. That is the main part in the 20 program.
21 JUDGE KENNEDY: In your mind, is it then 22 less important how they test those cables? I mean 23 there's no specificity here as to the types of tests 24 that would be conducted, the acceptance criteria, so 25 on and so forth which is I think at the heart of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4004 1 concerns from the State of New York.
2 MR. NGUYEN: I understand, but in the GALL 3 we say we reviewed the example of the tests. But we 4 also give the option of the state-of-the-art because 5 we as the time goes by may have a better technique.
6 Then we give the Applicant the option to adapt the 7 better technique and this is based on the industry and 8 industry guidance.
9 So that's why we don't specify what kind 10 of test. But we give the example of what kind of test 11 the Applicant can use.
12 JUDGE KENNEDY: Let me pass back to 13 Entergy.
14 JUDGE WARDWELL: Can I just interject 15 quickly just to fix a point on this?
16 JUDGE KENNEDY: Yes.
17 JUDGE WARDWELL: Is there any technical 18 reason why you couldn't require the applicant to list 19 the current state-of-the-art procedure as a starting 20 point and then allow them within this description as 21 an example of more specificity within their actual 22 Aging Management Program? And then give them the 23 freedom to change that as those techniques change with 24 the state-of-the-art. And I'm strictly saying is 25 there a technical reason why they couldn't do that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4005 1 that you're aware of.
2 MR. NGUYEN: Okay. Let me explain in 3 detail. When we do an audit when we look at the 4 description I asked the Applicant a question to 5 identify the test to be consistent with the GALL 6 report. And in the response they revised the program 7 element to include the type of test that they're going 8 to perform.
9 JUDGE WARDWELL: Couldn't they just as 10 easily put that in this document as part of their 11 License Renewal Application?
12 MR. NGUYEN: That's is buried under ten 13 attributes of the program.
14 JUDGE WARDWELL: Well, they have to 15 address those ten attributes. So why can't they do 16 that here in their license application right under 17 this section?
18 MR. NGUYEN: So that's why we do the audit 19 to verify and I believe --
20 JUDGE WARDWELL: But do you know of any 21 technical reason why they couldn't do it here?
22 MR. DOUTT: This is Cliff Doutt. If 23 you're looking at the AMP, if the Applicant 24 essentially adopts the ten elements and say that's how 25 they're going to do that, from a regulatory point of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4006 1 view, that provides the adequate assurance.
2 JUDGE WARDWELL: Is there any technical 3 reason they couldn't?
4 MR. DOUTT: They could put that in there.
5 It's not necessary.
6 JUDGE WARDWELL: That's all I wanted to 7 make sure that there wasn't a technical barrier that 8 would prohibit that. That's all I wanted to make 9 sure.
10 MR. DOUTT: And this is in the LRA you're 11 talking about.
12 JUDGE WARDWELL: Correct. I lost my 13 thought.
14 JUDGE KENNEDY: I guess you've introduced 15 the ten elements, Mr Nguyen. At this stage from the 16 application perspective, how do the individual program 17 elements come in for this Aging Management Program?
18 Where are those details?
19 MR. NGUYEN: Those details are on the --
20 we call the basic document on the other side. They 21 spell out the attributes and how do they meet GALL.
22 We review at the site and if they don't consider GALL, 23 we ask for additional information at the site.
24 JUDGE KENNEDY: I think I'm missing a key.
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4007 1 go to the site, you have the knowledge that the 2 Applicant -- Do you have the knowledge that the 3 Applicant is declaring this to be consistent with 4 GALL?
5 MR. NGUYEN: Yes, sir. Because they say 6 it's consistent with GALL in the application 7 indicating it.
8 JUDGE KENNEDY: Is that where the details 9 of the ten elements are then?
10 MR. NGUYEN: Yes.
11 JUDGE KENNEDY: If I -- As New York State 12 tried to review this and they look at this 13 description, they don't see anything about corrective 14 actions, the GALL elements. But now that I hear you 15 speaking, is it this consistency statement that brings 16 the details from GALL into this program?
17 MR. NGUYEN: Yes, sir. If you look at the 18 GALL, you look at the program because they say they're 19 consistent with GALL and we go there and verify. The 20 details of this program, you can look at the GALL 21 detail. It's exactly the same.
22 JUDGE KENNEDY: I guess that's what I was 23 trying to get. Go back to Entergy. From this 24 exhibit, walk us through where the details of this 25 Aging Management Program are? And then we're going to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4008 1 go back to Mr. Nguyen and go through how he did his 2 assessment of those details.
3 MR. RUCKER: This is Roger Rucker for 4 Entergy. The details for the AMP by reference to 5 NUREG-1801,Section XI.E.3 means that the program 6 description is well as the ten elements are attributes 7 of the program described in that section of the NUREG 8 which is GALL. That would be the details for the 9 program. If we included those statements in this 10 document, it would be basically a cut and paste from 11 GALL.
12 JUDGE KENNEDY: I guess maybe for -- I'm 13 trying to get a visual here. So if I was to go get 14 this GALL AMP and do as you say. Cut out the program 15 elements and pasted them on this page I would have a 16 program description I guess I'll call it Indian Point 17 specific. And then the GALL program elements below 18 that adopted for Indian Point. And would that 19 constitute the level of detail for this Aging 20 Management Program?
21 MR. RUCKER: This is Roger Rucker. Yes.
22 That is correct.
23 JUDGE KENNEDY: And I guess what I'm 24 saying here in my own mind wondering if there's any 25 value to pulling up GALL.
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4009 1 JUDGE WARDWELL: Yes, there is.
2 JUDGE KENNEDY: Okay. So let's just to 3 use Judge Wardwell's term fix this point. So this is 4 one page summary of the Aging Management Program which 5 incorporates by reference the GALL AMP XI.E.3. Is 6 that right, Mr. Rucker?
7 MR. RUCKER: This is Roger Rucker. That 8 is correct.
9 JUDGE KENNEDY: So at this point we -- And 10 I did not write down the exhibit for it. This would 11 be GALL Rev 1. Actually, I did write it down. I have 12 New York State 000146 A-C.
13 MR. RUCKER: That's correct, Your Honor.
14 JUDGE KENNEDY: Correct.
15 MR. RUCKER: It's probably going to be C.
16 JUDGE KENNEDY: Probably C. Mr. Welkie, 17 let's try New York State 000146C and look for XI.E.3.
18 MR. COX: Judge Kennedy, this is Alan Cox.
19 While we're looking for that, I wanted to address a 20 point that Judge Wardwell raised a moment ago. He 21 asked is there a technical reason we couldn't put in 22 a test method. And I guess my answer to that would be 23 that the technical reason is that the GALL report says 24 we'll select a test method at the time of the first 25 test that's the state-of-the-art.
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4010 1 So we could predict what that might be and 2 put that in here. But we don't know what the state-3 of-the-art is. We may be doing this review five to 4 ten years before we do the first test. So we may not 5 know what the state-of-the-art is going to be.
6 There are several options listed in the 7 GALL report. But the specific test it says should be 8 selected based on the state-of-the-art at the time the 9 test is performed.
10 JUDGE KENNEDY: Thank you. Maybe while 11 we're on that point, let's see if we can find that 12 within this GALL AMP that speaks to the testing.
13 MR. COX: This is Alan Cox again. You can 14 go to the next page under Element 4, Detection of 15 Aging Effects.
16 MR. RUCKER: Actually -- this is Roger 17 Rucker -- I think you're going to find that in Element 18 3.
19 JUDGE KENNEDY: Now, as we think of this 20 as the Indian Point Aging Management Program, this is 21 -- Is this what would be incorporated under the Indian 22 Point Aging Management Program? So this is where the 23 testing philosophy or testing details would be 24 contained.
25 MR. COX: Yes, that's correct. Again, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4011 1 this is a new program. So we're basically making a 2 commitment to say we're going to be consistent with 3 GALL. The GALL elements have to be followed to be 4 able to make that statement. So we would implement 5 these methods as described here.
6 JUDGE KENNEDY: So then the testing method 7 would be conducted in accordance with the guidance 8 under Program Element 3 here, Parameters Monitored and 9 Inspected.
10 MR. COX: Three and four. I mean both of 11 those have steps about what testing and inspections 12 are required.
13 JUDGE KENNEDY: I mean in the -- And, Mr.
14 Bascom, I believe in your testimony you had challenged 15 the Aging Management Program here in regard to testing 16 and had suggested that details should include the 17 types of cable and a specific test for each of the 18 cables in the program. Maybe could you address this 19 guidance if you will or testing methodology? And 20 comment on its appropriateness.
21 MR. BASCOM: This is Mr. Bascom for the 22 State. Yes, in reviewing the two paragraphs, I felt 23 that there wasn't any detail summarizing for an 24 outside reviewer which types of cables they'd be 25 testing and what methods they'd be applying to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4012 1 those tests given the current state-of-the-art 2 recognizing that possibly there would be future 3 methods available that could be applied. And based 4 upon what I saw both in the License Renewal 5 Application that we showed on the previous display and 6 what's listed here in the GALL I didn't feel that I 7 could evaluate what sort of testing they would be 8 doing other than noting that they may consider some of 9 the tests that are listed here including the reference 10 to the EPRI document.
11 JUDGE KENNEDY: Did you get a chance to 12 review the EPRI document?
13 MR. BASCOM: Yes, sir. I did.
14 JUDGE KENNEDY: Does that provide at least 15 in your mind some adequate testing methods?
16 MR. BASCOM: This is Mr. Bascom. Yes.
17 It's basically a menu of methods that could be 18 applied. But I didn't see how they would designate it 19 for what they would do at Indian Point 2 and 3.
20 JUDGE KENNEDY: Do you have any discomfort 21 with this concept of state-of-the-art at the time of 22 the test to be performed? And again that's probably 23 the height of lack of specificity I guess.
24 MR. BASCOM: This is Mr. Bascom. Yes.
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4013 1 consider new technologies that become available. And 2 as far as I can tell in reviewing the documents there 3 is no restriction on a new method being applied if 4 they choose to select that method and it has merit.
5 But I think as the current state-of-the-art they would 6 select some method that's available including those 7 listed in the EPRI documents and at least identify 8 what they would intend to do at this point in time 9 given the state of their system and the existing 10 cables that they have in the plant.
11 JUDGE KENNEDY: In your review of the EPRI 12 document, do you have any concerns about the testing 13 methodology that's I guess discussed in that document?
14 MR. BASCOM: Mr. Bascom. In the context 15 of my review, first of all, I didn't know the types of 16 cables they had in the plant which would perhaps 17 refine or help select what methods would be most 18 applicable. But I thought the EPRI document did have 19 a comprehensive description of the methods that would 20 be applied. And I thought that was an adequate 21 description.
22 JUDGE KENNEDY: Mr. Nguyen, again now that 23 we're getting into the details here and going back to 24 your technical review, do you have a view of the 25 acceptability of not listing the specific test to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4014 1 performed for the specific cables within the IP 2 facility?
3 MR. NGUYEN: Yes, Your Honor, because the 4 test involves. The test, for example, will determine 5 the condition of insulation resistance. But most of 6 the tests cannot determine how long the cables will 7 last. So the insulation, the condition at that, but 8 predict the predictive condition at that time.
9 And right now the research community is 10 exploring all the test methods which may be better in 11 the future. So we don't want to tie down a particular 12 test. We just give the example of "This is one of the 13 acceptable tests." But in the future if something is 14 coming up the Applicant could have options to adapt.
15 JUDGE KENNEDY: How would that work? I 16 mean Entergy have a -- Is it their discretion to what 17 test they select to perform these cable tests 18 including the state-of-the-art? So once they've been 19 granted the renewed license and they decided to select 20 their test, is there any oversight that's provided by 21 the Agency? Do they need any prior approval from the 22 Agency on their testing methodology?
23 MR. NGUYEN: We do the 71003 inspection 24 for license renewal before the POO and our inspector 25 will look at the procedure. And if the test is not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4015 1 appropriate, then we will resolve at that time.
2 JUDGE KENNEDY: So it would be more of a 3 case of in the oversight function of the Agency in 4 reviewing the testing work that Indian Point performs.
5 There would be an assessment of the adequacy of that 6 testing.
7 MR. NGUYEN: Yes, sir.
8 JUDGE KENNEDY: Why in some cases -- Maybe 9 this is an unfair questions. It seems like in some 10 cases GALL provides very specific testing methods.
11 And in this case it has a recommendation for some 12 methods and then a flexibility to do something that 13 would be maybe more appropriate in the future. I 14 guess help us understand why in this particular aging 15 effect why it's okay not to be very specific about 16 what the test is that's to be performed. Is there 17 something fundamental behind the scenes that led the 18 Agency to write the GALL AMP in such a way that 19 provides this level of flexibility?
20 MR. DOUTT: This is Cliff Doutt with the 21 Staff. The intent was to provide -- from a standpoint 22 is to provide flexibility, the choice of the test with 23 the technology changing, the cables types, insulations 24 to provide the flexibility of a zone. That's the 25 reason it's there. We provide suggestions in guidance NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4016 1 documents and Rev 2 is a little bit different in that 2 area. But essentially similar tests are referenced.
3 So it was really to provide some 4 flexibility as time goes on as Duc mentioned earlier.
5 JUDGE KENNEDY: So I guess the takeaway I 6 have here is that in this EPRI document there is a 7 range of tests that GALL considers to be acceptable 8 for testing and then the GALL AMP allows some latitude 9 to select a different testing methodology at a future 10 date. Is that the way I should read this?
11 MR. NGUYEN: Yes, sir.
12 JUDGE WARDWELL: Along those lines, the 13 GALL really says there are two choices that you have, 14 does it not? It says you can use a proven test and 15 then it goes on and gives some examples in reference 16 to the EPRI document. And then it says or you can do 17 one for state-of-the-art.
18 I can't remember so I'm going to count on 19 your memory rather than calling it up again. But in 20 I think it was B.1.23, where we were when we were 21 looking at the license application, wherever that was 22 where we pulled up before, did you state there that 23 you were going to use the state-of-the-art approach as 24 opposed to the proven technologies?
25 MR. NGUYEN: During the audit, we have a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4017 1 question --
2 JUDGE WARDWELL: I'm not referring to the 3 audit. I'm referring to what's in the license 4 application.
5 MR. DOUTT: Can we bring that back up?
6 It's 000015B I think it was. Yes, 000015B.81.
7 JUDGE WARDWELL: There we go. Yes, B.123.
8 MR. NGUYEN: Can you repeat the question 9 again, sir?
10 JUDGE WARDWELL: Yes. Do you agree that 11 GALL really provided two methods for testing? One you 12 would use a proven test and they listed several 13 examples and then listed more in accordance with the 14 EPRI document. And it said or testing can be state-15 of-the-art.
16 And my question to you is have you stated 17 which of those avenues you are going to use in your 18 license renewal application. Are you going to select 19 one of the proven technologies at the time or are you 20 going to use a state-of-the-art? I wondered if you 21 even got to that degree of specificity in your license 22 application. We can just look through now.
23 I was counting on you to remember because 24 I couldn't remember just in our brief look.
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4018 1 the Staff or directed to the Applicant?
2 JUDGE WARDWELL: It probably would be 3 better to direct it to the Applicant. Let's do that.
4 MR. COX: If you go back to the -- This is 5 Alan Cox for Entergy. If you go back to the GALL 6 report, the statements that you're referring to where 7 you say there are two options --
8 JUDGE WARDWELL: Can you first answer my 9 question and then we can do that because we're right 10 on that? I don't want to go back to that as a pull-11 up. Can you just answer that? Have you selected here 12 within your application which of those two avenues you 13 propose to use?
14 MR. COX: What I was going to say is that 15 my reading of that same paragraph doesn't say that the 16 two avenues that you mentioned I don't read in that 17 statement. I read that statement to say you have to 18 select proven method. And it could be one of the 19 methods that are listed there or the state-of-the-art.
20 In either case --
21 JUDGE WARDWELL: So the answer to my 22 question is "No, it isn't selected here." Is that 23 correct here in the license application?
24 MR. COX: No, what's selected here is that 25 we will be consistent with what's in the GALL report.
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4019 1 JUDGE WARDWELL: Okay. And there's no 2 more specificity than that in regards to this avenue, 3 in regards to the testing.
4 MR. COX: That's correct.
5 JUDGE WARDWELL: Okay. Now let's go back 6 so we're all reading the same thing you're reading.
7 It helps if you answer the question. I'm not going to 8 cut you off and not let you go back. I just want to 9 cover one thing at a time while we've got that up 10 here. Let's go back now to the previous one that we 11 were looking at, the actual GALL.
12 (Off the record comments.)
13 JUDGE WARDWELL: The 000147. Yes, there 14 we go.
15 Now, Mr. Cox.
16 MR. COX: I would read that sentence to 17 say that it is to be a proven test for detecting the 18 deterioration of an insulation system such as one of 19 those listed there as described in the EPRI report or 20 testing that is state-of-the-art.
21 JUDGE WARDWELL: I see.
22 MR. COX: There are different ways of 23 reading.
24 JUDGE WARDWELL: I see.
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4020 1 sentences like that, you can -- And my experience with 2 the NRC is that they would take the most conservative 3 reading of that and when they come onsite to do their 4 audits, if we're not using a proven test, that could 5 be an issue.
6 JUDGE McDADE: When the test is selected, 7 it's originally selected by the Applicant, by Entergy.
8 Before you do the testing, does the Staff have to 9 approve or do you just go ahead and do the testing 10 subject to audit after the fact?
11 MR. COX: We would do the testing and the 12 NRC would be in a position to review that after the 13 fact.
14 JUDGE McDADE: And is that the Staff's 15 view as well as to how it operates?
16 MR. NGUYEN: Yes, sir. We would have 17 71003 licensing inspection and we would review the 18 implementation procedure to fulfill the commitment 19 that they state in the Final Safety Analysis Report.
20 JUDGE McDADE: And if the Staff didn't 21 believe that the testing chosen was state-of-the-art, 22 what then?
23 MR. NGUYEN: We will raise an issue.
24 MR. DOUTT: I think to clarify that is 25 that especially in GALL Rev 1 the confusion of two NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4021 1 choices. There really isn't two choices. There would 2 be significant time lag when the license is issued.
3 And what is the option, you know, the EPRI document 4 here lists some things. You could chose that. It's 5 a proven test.
6 Ten years from now before PEO, before that 7 test has to be implemented, that may in fact be 8 changed. So we would expect at that time you would 9 select the state-of-the-art test. Cliff Doutt of the 10 Staff.
11 JUDGE WARDWELL: And do you read it the 12 same way Mr. Cox reads it? I would read it that the 13 proven tests are the ones that are the "such as." And 14 then that the state-of-the-art is not a proven test.
15 And that's why the two choices are either a proven 16 test or the state-of-the-art.
17 He has read it that the "or testing" is in 18 reference to the "such as" list that's there.
19 MR. DOUTT: Right.
20 JUDGE WARDWELL: How would you read it?
21 Why isn't the state-of-the-art in contrast with the 22 proven test rather in contrast with the examples that 23 were provided under "such as" of those proven tests?
24 MR. DOUTT: Yes, one thing is -- Well, 25 we're doing Rev 1 here I guess. I'd look at it as a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4022 1 combination like Entergy looked at it. It is in fact 2 a choice. And you would have a proven test going 3 forward stated at that time. That would be a 4 demonstrated proven test by national standard, 5 industry recommendation guidance at that point. So I 6 don't think there's a differentiation.
7 JUDGE McDADE: Okay. And let me explain 8 a little bit of what I'm trying to get my arms around 9 here. We have to determine whether or not aging 10 management has been demonstrated. And we have here a 11 test which is unspecified in the future. The 12 Applicant chooses what that as yet unidentified test 13 is going to be.
14 How do we know sitting here today that 15 that testing will adequately control/manage aging?
16 What is the nature of the review of the Staff? Again, 17 we have a difference of option.
18 Down the line, five years from now, ten 19 years from now, the Applicant says "This is the state-20 of-the-art. This is the way we're going to do the 21 testing." An audit by the Agency disagrees. What 22 happens then? How is that resolved?
23 MR. DOUTT: We have to go back up. One is 24 that from a standpoint of adequacy and aging 25 management a reasonable assurance from our point of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4023 1 view that the ten attributes are. If, in fact, the 2 Applicant agrees to that or that commits to those ten 3 attributes by definition he's provided under CFR 54.29 4 reasonable assurance.
5 Going forward, if you're looking at what 6 tests will be picked or whatever, the 71003 inspection 7 would look to see if the commitments, whatever they 8 are, have been implemented correctly. After that, 9 once we're in Part 50 space, and the license position 10 was somewhere down the road, we audit. We inspect 11 procedures.
12 So I think there are methods existing 13 within their own inspection oversight process and that 14 would take care of your question. They were covered.
15 JUDGE KENNEDY: If we stay focused on this 16 particular element, and maybe we should take both 17 elements, as Mr. Cox said that testing is covered by 18 both of these.
19 MR. DOUTT: Yes. This is Cliff Doutt 20 again. Four is looking at the inspection criteria, 21 that manhole, that sort.
22 JUDGE KENNEDY: If I look at this GALL 23 element or both of these GALL elements and I'm looking 24 for what gives me reasonable assurance, I'm going to 25 ask you what gives you reasonable assurance. I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4024 1 you just went through it with us. But I want to have 2 you maybe go through it one more time at least related 3 to testing methods and maybe we can get into testing 4 frequency next. But what gives the Staff their 5 comfort level of reasonable assurance in regard to 6 testing methods?
7 MR. DOUTT: I think it's question --
8 Actually, it's in our original discussion on our 9 testing. We wrote -- Basically, there's two parts of 10 this. There was the GALL Rev 1. And then we issued 11 some supplemental RAIs for GALL Rev 2.
12 But if they're consistent with GALL Rev 1 13 and GALL Rev 2, whatever the case may be, the license 14 applicant who commits to implement these AMPs is 15 consistent with the corresponding AMP in GALL which is 16 what our audit is intending to do. That provides us 17 the reasonable assurance.
18 The requirement to include the procedure 19 and things like that is not required at that point.
20 That's not --
21 JUDGE KENNEDY: And I guess what I'm 22 looking for is what's the key. What's the hook?
23 What's the key hook in this GALL element that makes 24 this all work? I mean if you were look at this and 25 write a couple of sentences that said why you believe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4025 1 this Aging Management Program gives you a reasonable 2 assurance --
3 MR. DOUTT: I think if you go down 4 actually seven, eight and nine, from the standpoint of 5 Appendix B and QA and acceptance criteria, those will 6 make a -- Once those are listed, then that's audible 7 and inspectible.
8 MR. SIPOS: Excuse me, Your Honors. I 9 apologize. This is John Sipos. I apologize for 10 interrupting, but we are having a very hard time 11 hearing Mr. Doutt's testimony.
12 MR. DOUTT: Pardon me. I'm sorry.
13 MR. SIPOS: I don't know if it's the audio 14 or what. But it's the last four Q&As I think we've 15 missed a lot of it over here.
16 MR. DOUTT: Is that better?
17 MR. SIPOS: Yes.
18 JUDGE McDADE: The other thing perhaps if 19 you could speak a little bit slower. That would help 20 us.
21 MR. DOUTT: That's a problem. I 22 understand.
23 MR. SIPOS: Thank you, Your Honor.
24 JUDGE KENNEDY: And, Mr. Sipos, I think 25 we're going to stay on this topic for a little while.
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4026 1 So I suspect we'll circle back to those questions. I 2 don't think we're done with this topic yet. So stay 3 tuned.
4 MR. SIPOS: Thank you, Judge Kennedy.
5 JUDGE KENNEDY: You're starting to point 6 us to some downstream GALL elements and I think we 7 missed your last point you were making.
8 MR. DOUTT: I was looking at from a QA 9 Appendix B point of view seven, eight and nine, 10 essentially seven, Corrective Actions and/or 11 Acceptance Criteria No. 6, which we do also review.
12 Once those are defined, if you pick the test, whatever 13 it was, you picked Acceptance Criteria and those are 14 audible and inspectable.
15 And we review the Appendix B and the 16 Quality Program within -- actually scoping the screen 17 does it -- but RSCR in section -- I'll find it -- but 18 it says that basically the Appendix B program is 19 adequate for these AMPs. And we review their program 20 onsite and turn the audit in. I actually thinking 21 scoping the screen does it.
22 JUDGE KENNEDY: I guess I'd like to go 23 back to 3 and 4. Go ahead.
24 JUDGE WARDWELL: Can you just go back?
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4027 1 it.
2 JUDGE KENNEDY: I don't think we're going 3 to leave this topic for a bit, Judge Wardwell.
4 I guess from my perspective if I was doing 5 this the fact that there is a concept of a proven test 6 and it's unspecified. Although there's a list of 7 acceptable tests. I'm gaining that understanding in 8 this EPRI document.
9 And that if a state-of-the-art test was to 10 be used later on, my presumption is that is also a 11 proven test. And I believe I heard from the group 12 here that proven means it's an industry accepted 13 practice, a standard within the electrical industry.
14 And I guess I'm looking to confirm my 15 understanding of this which to me seems to be an 16 important concept. If the specifics on a specific 17 cable basis aren't listed so that we could then go 18 down the path as Mr. Bascom has suggested of here's 19 the types of cable. Here's what they're comprised of.
20 Here's the test method. Yes, it's acceptable.
21 This goes a different way. This says 22 there's a suite of tests. We believe you understand 23 what cables you have in your facility and you will 24 select a proven test for that cable. I guess I'm 25 trying to figure out if that's the understanding we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4028 1 should take away from this element.
2 I've heard pieces of all that in the early 3 portion of this morning here. I don't know. Let's 4 start with Mr. Cox. You've helped us before walk down 5 this path. Maybe you could. Do you have a sense of 6 what I'm struggling with?
7 MR. COX: I think this -- This is Alan Cox 8 for Entergy. I think you're right on track there. To 9 me when we -- We've got to assure ourselves that we 10 have an effective program, too.
11 And I think that assurance that we're 12 trying to convey to the NRC with this description is 13 that we will be using a proven test. And that test 14 can vary depending on the specific cable and state-of-15 the-art at the time that we do the test. I think to 16 me that's the hook that we are subject to when the NRC 17 comes onsite to see if we're implementing this program 18 appropriately. If we're not using a proven test, 19 that's going to be apparent and they're going to be 20 able to enforce this as a violation on us for not 21 meeting this commitment.
22 JUDGE KENNEDY: Do you see the word 23 "proven" also modifying the state-of-the-art test?
24 MR. COX: Yes, I do.
25 JUDGE KENNEDY: Just to clear that up.
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4029 1 JUDGE McDADE: Mr. Cox, perhaps we're 2 talking about here that you're allowed to use state-3 of-the-art. But in your document, in EN-DC-346 -- I 4 believe it's Entergy Exhibit 000237 -- haven't you 5 committed to use the tan delta and the VLF tests?
6 MR. RUCKER: This is Roger Rucker for 7 Entergy. That is correct. The most important thing 8 that's stated in the GALL and in the application is 9 that we're doing an insulation test. That's what's 10 being tested. These are just methods to test the 11 insulation. Okay. So we are conclusively stating 12 what is being tested.
13 JUDGE WARDWELL: I'm sorry. Which test?
14 Those two he just described or the ones that are shown 15 here?
16 MR. RUCKER: All of these tests. What we 17 have committed to is doing an insulation test. Okay.
18 We're trying to verify the integrity of the insulation 19 based on the cable design, based on the type of 20 insulation, based on the installation. All of those 21 things determine which is the best test to do to test 22 the insulation of the cable.
23 Now the procedure that you referenced, EN-24 DC-000346, that is an implementing or executing 25 procedure. That's our boots on the ground procedure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4030 1 to be used by the Entergy fleet. And that's not the 2 only test that was selected. The tan delta was the 3 selected test for medium voltage shielded cable.
4 MR. COX: And I think you said -- this is 5 Alan Cox again. Judge McDade, you said have we 6 committed to that. That is the method that we have 7 chosen as Roger said for the medium voltage cables to 8 meet that commitment. Now if we had a different type 9 of cable it could be a different method. We're not 10 committed to that method for all cables. We are using 11 that method in the procedure now.
12 If you recall kind of the history of this, 13 we submitted the application in 2007. That EN-DC 14 procedure did not exist at that time. So we put this 15 in as a commitment to have a program that met these 16 elements of the GALL report and that procedure was 17 developed subsequent to that to implement the 18 commitment. And that is the method that was chosen 19 for that particular type of cable.
20 JUDGE WARDWELL: So are you saying if you 21 wrote this today you would, in fact, list that in your 22 License Renewal Application?
23 MR. RUCKER: This is Roger Rucker for the 24 Applicant. No, that is an executing procedure. That 25 is not an Aging Management Program.
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4031 1 JUDGE WARDWELL: And what's the basis for 2 that? Why do you say that with such authority?
3 MR. RUCKER: Because that's designed to be 4 an executing or implementing procedure. It's not 5 designed to be a higher level program procedure. It 6 doesn't discuss the basis for the reason we're doing 7 the test which is we're doing insulation test, what 8 the frequency is. We're looking at the manhole 9 inspections, what the frequency is. What the 10 expectations are and also as Mr. Doutt pointed out 11 with the NRC the requirements to do all of this under 12 our 10 CFR Appendix B program.
13 JUDGE WARDWELL: Is there any technical 14 reason that if you were writing the license 15 application today that you could not under Section 3 16 when addressing Section 3 of the GALL in your License 17 Renewal Application state that for these groups of 18 cables we have selected this test, for this group of 19 cables we have selected this test, and for these 20 groups we have selected this? I mean it would be a 21 matter of one sentence with three sections in it, 22 wouldn't it?
23 MR. RUCKER: If you did that and then any 24 changes occurred, then you would have to keep amending 25 that portion. This is designed to be a program NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4032 1 document that covers the basis and gives you all the 2 information needed to apply those basis to the 3 specifics of the plant.
4 JUDGE WARDWELL: So does that mean that 5 you can change your inspection techniques without any 6 approval by anyone?
7 MR. RUCKER: We can change the method that 8 we use to do insulation resistance test. It's going 9 to be a proven test. We're going to use something 10 from EPRI, from IEEE. And as the NRC has stated that 11 is something that's inspected. They look at what 12 method we use.
13 JUDGE WARDWELL: But in the EN document 14 that we've just talked about where you have selected 15 this, if you now and a future date change that 16 selection test, can you do that without any approval 17 or oversight?
18 MR. RUCKER: Prior approval from the NRC, 19 that is correct.
20 JUDGE WARDWELL: So what's the difference 21 with putting it in here as opposed to the prior 22 approval you need that exists now? You said the 23 reason you didn't want to put that in your License 24 Renewal Application is because it would have to be 25 amended. Well, isn't that the same as getting prior NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4033 1 approval to change the test as a selected test in your 2 EN document?
3 MR. RUCKER: Well, the application itself, 4 I mean once the renewed license is submitted, you're 5 not going to amend the application any longer.
6 JUDGE WARDWELL: Right. So you don't have 7 to change that.
8 MR. RUCKER: But if you reference items in 9 here you're going to have -- It's not going to --
10 JUDGE WARDWELL: Again, let me see if I 11 can clarify. I'm not making myself clear I don't 12 think. I'm asking if you were writing it today, the 13 License Renewal Application, what is to technically 14 stop you from stating the types of tests you are going 15 to use for a group of cables so that you see some 16 specificity in your License Renewal Application in 17 that program that relates to your selection?
18 Your response to me was then we'd have to 19 -- If it changed later, we'd have to change it or 20 something you said, something to that effect as I 21 interpreted it. And my comment is you'd have to do 22 that anyhow, wouldn't you? And now you just said that 23 the license application really disappears after you're 24 granted the license. So it wouldn't have to be 25 changed, would it, with the license application?
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4034 1 MR. COX: Let me try to answer your 2 question. This is Alan Cox again. There's no 3 technical reason we couldn't put that in there. I 4 don't know that it adds much value because what you 5 have there now you have a menu of acceptable options 6 that can be applied. You could put one of those 7 options in there. That option could later change and 8 you could do something. You're still watching for 9 what's state-of-the-art, what's the best way to do 10 this test.
11 And we talked earlier about why this 12 program is not as specific as others. This issue of 13 how to test insulation for things like water train is 14 an evolving issue. There's a lot of research being 15 done on what is the best method.
16 So I think that's one more reason why this 17 flexibility was provided in this document. There's 18 not a well-defined, single standard at the time this 19 was written that says this is the best way to do that 20 test.
21 Some of the other programs are more 22 established. They're dealing with aging effects and 23 mechanisms that have been around and known for a long 24 time. And there's specific ways to address those that 25 are known. And I think that's one reason why the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4035 1 Staff when they wrote the NUREG was more specific in 2 those cases.
3 To answer your question, there's no 4 technical reason we couldn't put that in there. It's 5 not adding any assurance in my mind. It's adding some 6 specificity as to what we're doing today.
7 JUDGE WARDWELL: Would it not add some 8 additional information that provides the demonstration 9 that in fact you are consistent with GALL by seeing 10 such items as that?
11 MR. COX: Well, if there was a specific --
12 You know you've got a list here of several methods 13 that could be selected. If those are all acceptable 14 methods, I don't know that you've added any assurance 15 by saying which one of those. I mean you could change 16 that. But if you could interchange those three 17 methods and any one of them would be an effective 18 test, you haven't shown any more effectiveness by 19 picking one of those three.
20 JUDGE McDADE: Let me interject something 21 here, Mr. Rucker, to clarify in my own mind. You made 22 a very strong distinction between program and 23 procedure. Aren't the procedures part of the program, 24 how the program is going to be implemented?
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4036 1 Entergy. The procedure that you referenced, EN-DC-2 000346, that is implementing the requirements, the 3 commitments, of the program. That is correct.
4 JUDGE McDADE: At this point in time, I 5 mean the allegation is there's a lack of specificity 6 that we can't know that aging will be properly managed 7 because we don't know how the Applicant is going to go 8 about it. And as I'm reading the documents when I 9 look at EN-DC-00346 which is Entergy Exhibit 000239 it 10 seems to indicate that on pages 14 to 18 how you're 11 going to test the medium voltage and on pages 19-20 12 how you're going to test the low voltage. So there is 13 specificity there.
14 And as I understand it, these are the 15 tests that you would use unless a more state-of-the-16 art test were developed prior to the time of the 17 actual testing in which case the NUREG allows you 18 flexibility to use the state-of-the-art test subject 19 to receiving an imprimatur from the NRC to do so. Am 20 I understanding the procedure and the program 21 correctly, Mr. Cox?
22 MR. COX: Yes, I believe that's correct.
23 We have chosen those methods in that procedure to 24 implement the program that we've described in Appendix 25 B of the LRA.
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4037 1 JUDGE McDADE: Mr. Rucker, do you think I 2 need any clarification in that or do you think I 3 understand what the Applicant Entergy's position is?
4 MR. RUCKER: This is Roger Rucker for 5 Entergy. I think that's a clear understanding. But 6 the one thing I want to point out. That procedure 7 specifically allows other tests. That's the preferred 8 test. Those two sections that you referenced are the 9 preferred test for the cables that you indicated.
10 But, for example, if you have an unshielded cable it 11 goes into some other details about what you would need 12 to do.
13 JUDGE McDADE: Mr. Bascom, does that 14 supply the kind of specificity that you feel was 15 lacking?
16 MR. BASCOM: This is Mr. Bascom. Yes, I 17 mean it does define what tests would be performed 18 which was really in my view lacking in the License 19 Renewal Application. And at the time I reviewed the 20 License Renewal Application there wasn't any reference 21 to a program or suggestion that they had been 22 previously testing the cables in some manner which is 23 what I would expect is an engineering evaluation that 24 they had been doing some ongoing -- They had an 25 ongoing program of some type. And that would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4038 1 demonstrate before the license was renewed that they 2 could or they would be performing tests on a certain 3 group of cables.
4 And the Cable Reliability Program that's 5 been referenced does designate tests that they would 6 do on the two types of cables that are the subject of 7 this discussion.
8 JUDGE McDADE: Okay. Thank you.
9 Judge Kennedy.
10 JUDGE KENNEDY: Mr. Bascom, you've heard 11 a lot of discussion here about these GALL elements and 12 GALL attributes. And we've focused a lot on the use 13 of proven tests, again a list specified in the EPRI 14 document and then a potential for future tests. Do 15 you have any thoughts on should we be concerned? Does 16 that allow us the reasonable assurance? Is there 17 something you'd like to point out that you can see the 18 approach that's starting to form here?
19 We're focusing on the GALL element and 20 what path that drives us down. And I'd like to give 21 you an opportunity maybe at least as we beat this one 22 up to weigh in a little bit on the concept of a proven 23 test being acceptable to meet this particular part of 24 GALL.
25 MR. BASCOM: This is Mr. Bascom. The EPRI NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4039 1 and the GALL list like I said a menu of tests that 2 could be considered. And in a review I was looking 3 for some specificity that they had selected at least 4 one or two tests based upon the types of cable that 5 were available. The Cable Reliability Program does 6 list some specific tests.
7 The part that I was I guess lacking first 8 of all was that they didn't reference the reliability 9 program in their application. So there was no 10 indication from an outside reviewer which was my 11 function in looking at this that they had a program 12 and they had evaluated what test methods they would 13 select for their existing system.
14 JUDGE KENNEDY: Just maybe a follow-up 15 question for the Staff. We've been kicking around 16 this concept of proven. Is there anything within the 17 application or within GALL that quantifies what is 18 envisioned by proven? I mean we have testimony here 19 that says what proven is. I'm wondering if we went 20 outside of this testimony if there's something in the 21 license renewal documentation or GALL or regulation 22 that helps me grapple with what a proven test is.
23 MR. NGUYEN: This is Duc Nguyen for Staff.
24 If you look at a reference of the GALL it's a list of 25 the reference that this program is based on. And when NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4040 1 we revised the GALL Rev 2, we put more reference. So 2 the tests that we are listing here is the acceptable 3 industry's steps and the Cable Reliability Program, 4 one of the tests that they chose is listed in here.
5 So I think this test is acceptable. But if in the 6 future we have something else, if we develop some of 7 the state-of-the-art we can --
8 And this is ongoing between the industry 9 and NRC Research. So that's why we give the Applicant 10 the flexibility because we don't want to tie to a 11 particular test and when they change the test they 12 have to come up with an amendment. So that's why we 13 put it in the GALL in the way it is.
14 JUDGE KENNEDY: But it's qualified with 15 the word "proven." And I guess we've gotten an 16 understanding from the witnesses here what they 17 believe proven conveys to the audience. I was just 18 curious if there was any citation within GALL or with 19 regulations that would quantify or qualify what the 20 word "proven" means.
21 MR. DOUTT: I think to clarify -- This is 22 Cliff Doutt with the Staff -- what Duc was saying.
23 The GALL was developed based on operating experience 24 research of current standards. And so those tests 25 that are referenced there are either -- One of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4041 1 references is a NUREG and some standards. So those 2 suggestions came out of accepted industry practice.
3 And whether that's proven or not, I think 4 if you have the standard like for whatever standard 5 you want to reference, tan delta, whatever, that's an 6 accepted way to do it. That's a proven way of doing 7 it depending on the particular cable and insulation 8 type and whatever. That test would change.
9 JUDGE KENNEDY: All right. Thank you.
10 I guess at this point I'd like to go back 11 to Mr. Nguyen. I think we had you started walking us 12 through the process of how the NRC Staff comes to the 13 reasonable assurance determination. And we were at the 14 point where you were reviewing the Aging Management 15 Program. And then we got off into the specifics of 16 where the details were.
17 Maybe if you could take us through and 18 just complete that thought of how you perform the 19 technical review.
20 MR. NGUYEN: Yes, sir. The Staff 21 conducted its scope at Indian Point 2 and 3 located at 22 Brookhaven, New York. I did my testing during October 23 8 to 12. The focus was to make that the Applicant had 24 developed an adequate guidance to conduct the scope 25 and screen in the system to construct the component in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4042 1 accordance with the methodology described in the 2 License Renewal Application and the requirement of 10 3 CFR 50.54.
4 The Staff reviewed implementation of the 5 process level guidance and technical report described 6 the Applicant license renewal scope and screening 7 methodology. The Staff conducted detailed discussion 8 with the Applicant on the implementation of the 9 license application and reviewed administrative 10 documentation done by the Applicant during the scoping 11 and screening process.
12 The quality practice reviewed by the 13 Applicant to develop the license application and the 14 training and the qualification of the license renewal 15 application development team. The Staff evaluate the 16 quality attribute of the Applicant Aging Management 17 Program activity described in the Appendix A of the 18 FSAR report and Appendix B, Aging Management Program 19 and activity to the license application.
20 In support of the Staff's technical review 21 of the license application for Indian Point Units 2 22 and 3, the Division of Licensing Renewal led by the 23 project team that audit and reviewed the selected the 24 Aging Management Program review and associate Aging 25 Management Program and time limit aging analysis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4043 1 developed by the Applicant to support the license 2 renewal application at Indian Point 2 and Indian Point 3 3.
4 JUDGE KENNEDY: Can we stop just there?
5 I have a couple of questions. First of all, are you 6 reading from your testimony?
7 MR. NGUYEN: Yes, sir.
8 JUDGE KENNEDY: And could you just point 9 us to where in your testimony you're reading from and 10 then we can just note that?
11 MR. NGUYEN: Yes. This is the audit 12 report at Entergy Exhibit 000041.
13 JUDGE KENNEDY: So that wasn't your 14 personal testimony. That was another exhibit. Is 15 this part of the audit report that you're reading from 16 there? Is that what I heard you say?
17 MR. NGUYEN: Yes, sir.
18 JUDGE KENNEDY: And that was Entergy 19 Exhibit 000041.
20 MR. NGUYEN: 000041, page 4-5.
21 JUDGE KENNEDY: 4-5. A couple of 22 questions on your discussion there. You used the 23 words "scoping and screening." What is that to use a 24 nontechnical term? What is that all about?
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4044 1 Staff. I think the witness may have misunderstood the 2 question. I believe the witness was in fact reading 3 from his testimony on pages 13 and 14.
4 JUDGE KENNEDY: Okay. So let's try it 5 again. I guess you started with a discussion with 6 scoping and screening and then went on through a 7 number of other sentences. Was that from your 8 testimony?
9 MR. NGUYEN: Yes.
10 JUDGE KENNEDY: Okay.
11 MR. NGUYEN: But I only audit the Aging 12 Management Program and aging review. Scoping is done 13 by Auditing.
14 JUDGE KENNEDY: Okay. So you're giving us 15 a view of the overview process that the Staff uses.
16 MR. NGUYEN: Overall, yes.
17 JUDGE KENNEDY: And is that overall 18 process described in your testimony?
19 MR. NGUYEN: Yes, sir.
20 JUDGE KENNEDY: And that is pages?
21 MR. NGUYEN: Pages 13 and 14.
22 JUDGE McDADE: And that's NRC Exhibit 23 000017 starting at page 13 going over to page 14.
24 MR. NGUYEN: Yes.
25 JUDGE McDADE: That's answer 14.
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4045 1 MR. NGUYEN: Yes, sir.
2 JUDGE KENNEDY: All right. Thank you.
3 MR. ROTH: Your Honors, pardon me. David 4 Roth for the Staff. That's NRC 000077.
5 JUDGE McDADE: I'm sorry. What did I say?
6 Seventeen?
7 MR. ROTH: Yes.
8 JUDGE McDADE: I'm sorry. Thank you.
9 JUDGE KENNEDY: Okay. So let's just go 10 back now. Now we've clarified. I think where your 11 information is coming from. The scoping and 12 screening, you did not perform that. Does it have any 13 relevance to New York State 6 and 7? And if it 14 doesn't I can just let it go. Is there anything we 15 need to know about the scoping and screening audit 16 that is relevant to this contention?
17 MR. NGUYEN: First, I think it has some 18 relevance because first you have to scope in the 19 system components with the scope of license renewal.
20 JUDGE KENNEDY: So these are the 21 components that are within the scope.
22 MR. NGUYEN: Yes.
23 JUDGE KENNEDY: So that goes through all 24 the plants, systems, components.
25 MR. NGUYEN: Yes.
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4046 1 JUDGE KENNEDY: And BINSOM is whether in 2 license renewal or not in license renewal. Okay. And 3 that's scoping?
4 MR. NGUYEN: Yes, scoping is really -- And 5 that includes the medium voltage inaccessible cable 6 we're talking about.
7 JUDGE KENNEDY: Okay.
8 MR. COX: Judge Kennedy.
9 JUDGE KENNEDY: Yes, sir.
10 MR. COX: I'd like to take Judge McDade up 11 on this offer to request a break if we could.
12 JUDGE KENNEDY: Oh, we're having that much 13 fun?
14 JUDGE McDADE: Mr. Cox, would -- Anybody 15 need more than 10 minutes for break at this point in 16 time?
17 (No verbal response.)
18 I've got 9:25 a.m. So why don't we come 19 back at 9:35 a.m. We're in recess for ten minutes.
20 Off the record.
21 (Whereupon, a short recess was taken.)
22 JUDGE KENNEDY: Thank you. I guess let's 23 go back, you were walking us through the process and 24 I think we just -- we were talking about scoping and 25 screening and I think you've answered the scoping NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4047 1 question. Does screening have any relevance here to 2 this contention 6 and 7?
3 MR. NGUYEN: Yes, sir. The scoping and 4 screening has relevance here because the scoping 5 program in the second would perform the license 6 renewal function. And if you want I can describe, but 7 I already I described before.
8 So when we do scoping/screening then I 9 audit the Aging Management Program and Aging 10 Management Review.
11 JUDGE KENNEDY: Can I stop you just a 12 second? Is it fair to say coming out of the scoping 13 and screening, would you have a handle on the types of 14 cables that are in scope, what their construction is, 15 where they are? I don't know about where they are in 16 the plant or what systems they're related to.
17 MR. NGUYEN: Yes, during the AMP audit, 18 they list the cable type and the cable in the scope of 19 the program. But at the time because the low voltage 20 is not included in the scope, only from 2 kilovolt to 21 35 kilovolt.
22 However, if you read my audit report with 23 Entergy Exhibit 000041, page 23 to 26, we challenged 24 the applicant on the service water cable. And their 25 response was because this cable is only 480 volt so NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4048 1 that's why it's not in scope. With information we 2 have at that time, the only cable with the -- could be 3 subject to the water tree phenomenon in a medium 4 voltage, you have to have significant voltage in order 5 to create the water tree phenomenon. That's why we 6 did not require the applicant to include 480 volt 7 service water and auxiliary feedwater in the program.
8 And if you read my report, I requested 9 this information why the service water is not included 10 in the scope because typically the service water is 11 4160 volts, but this time they use the low voltage.
12 JUDGE KENNEDY: So the inclusion of --
13 it's sounding like the inclusion of the lower voltage 14 cables came out of the on-site audit and review 15 process?
16 MR. NGUYEN: No, it did not come out -- it 17 came out later in the revision 2. But to explain the 18 detail that I looked at, we did not take the 19 applicant's word for it. We looked at the on-line 20 diagram. We looked at the Final Safety Analysis 21 Report to describe their on-site and off-site power 22 system and then we questioned them. But at that time, 23 we did not have any reason to require them to include 24 the low voltage cable in the scope of the medium 25 voltage.
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4049 1 JUDGE KENNEDY: Thank you. So are we now 2 to the point where you are reviewing the -- and I 3 guess I'm not sure what the process is. You went 4 through scoping and screening and released in relative 5 to near state 6 and 7 that really relates to what's in 6 the scope and what's going to be managed by this 7 program.
8 Now are we to the point of the specific 9 Aging Management Program that is at issue here?
10 MR. NGUYEN: Yes.
11 JUDGE KENNEDY: And so are you now at the 12 point -- you've moved beyond just the peer technical 13 review of the License Renewal Application and you've 14 moved into an on-site phase?
15 MR. NGUYEN: Yes, sir.
16 JUDGE KENNEDY: That's the way I 17 understand it. And so what occurs during the on-site 18 portion of your review?
19 MR. NGUYEN: We have a breakout meeting 20 with the applicant to talk about the program after 21 we've reviewed what they call the basic documents at 22 the site.
23 When this program was proposed, this is a 24 new program, therefore, the applicant did not have the 25 implementation procedure. What we review in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4050 1 action, that the applicant will test to benefit the 2 aging will be managed. That's what we look at.
3 JUDGE KENNEDY: Is it a new program in the 4 context that it wasn't something that existed prior to 5 the License Renewal Application at Indian Point?
6 MR. NGUYEN: No, sir.
7 JUDGE KENNEDY: Thank you. So you're at 8 the -- I guess at the Indian Point facility and you're 9 doing an on-site review. I guess you called it an 10 audit. What else do we need to understand that occurs 11 during that process?
12 MR. NGUYEN: During that process, we have 13 a breakout meeting and I discuss and we go through 14 every element in that program and we compare where we 15 see a difference, we request for additional 16 information.
17 And also in my audit report I point out 18 that in the basic document they did not list the type 19 of the testing they were going to perform. So I asked 20 them a question and they include the type of cable L, 21 actually, it was No. 3. And they provide the basic 22 documents to resolve the differences.
23 JUDGE KENNEDY: I'm sorry, you were 24 pointing. Are you pointing at something on this 25 exhibit that's being displayed here?
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4051 1 MR. NGUYEN: I'm talking about -- yes. In 2 the audit report, if you go to -- let me point out the 3 Entergy Exhibit 000041, page 25.
4 JUDGE KENNEDY: Would it be worth viewing 5 that page?
6 MR. NGUYEN: Yes, sir.
7 JUDGE McDADE: Could we see Entergy 8 000041?
9 JUDGE KENNEDY: The audit report must be 10 a public document. Do we have an NRC exhibit that's 11 the audit report?
12 Mr. O'Neill?
13 MR. O'NEILL: I'm going to confirm, but 14 the audit report should be a public document.
15 JUDGE KENNEDY: It's referenced in the SER 16 and you can click on it and obtain it.
17 MS. FEINER: Your Honors, I don't believe 18 that Entergy ever designated the audit report as a 19 confidential or proprietary document.
20 MR. SIPOS: And this is John Sipos. It 21 wasn't any of the four documents that we were 22 discussing in the August-September 2012 time frame, so 23 we could remove the designations.
24 JUDGE McDADE: Right now we're just trying 25 to find the right exhibit number for the audit report NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4052 1 which is public as opposed to Entergy 000041.
2 JUDGE KENNEDY: Is that the right 3 reference?
4 MR. O'NEILL: Just give me a moment, I'll 5 verify that, Your Honor, because it would have been 6 apparently been submitted in connection with another 7 contention.
8 MR. TURK: Your Honor, it might be another 9 document. Let me double check. On my list I show NRC 10 000108 is the audit report. But let me verify that 11 that is, in fact, the right one.
12 MR. SIPOS: And Your Honor, there is 13 another document. There is an Entergy 000041 which is 14 an NRC audit report.
15 MR. O'NEILL: Yes, Entergy 000041. That's 16 correct, Your Honor. This is Martin O'Neill.
17 MR. SIPOS: And it's designated for 18 Riverkeeper New York 000067 and New York 000038.
19 JUDGE KENNEDY: And can you tell is this 20 designated as proprietary?
21 MR. SIPOS: It doesn't appear to be on the 22 witness list, excuse me, on the exhibit list.
23 JUDGE KENNEDY: Mr. Welkie?
24 JUDGE McDADE: Are you're on page 25 of 25 that, Mr. Nguyen?
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4053 1 MR. NGUYEN: Yes, sir. This is the 2 benefit of the level of detail that the staff audited 3 at the site and you can see that in the basic document 4 they did not list what type of test they were going to 5 use and the GALL Report lists the type of test that is 6 acceptable to the staff. And therefore, we asked the 7 question and the applicant revised the basic document 8 and included the exam or test that they were going to 9 perform.
10 JUDGE KENNEDY: Let me make sure I 11 understand this. Is this an attempt to get the basis 12 document to list the specific test or to get the -- I 13 guess now I'm getting -- it's been incorporated by 14 reference, the GALL portion of that --
15 MR. NGUYEN: Yes.
16 JUDGE KENNEDY: And that lists some 17 specific tests, plus a reference to an EPRI document?
18 MR. NGUYEN: What we tried to is align 19 that program with the GALL program.
20 JUDGE KENNEDY: So did the basis document 21 have the EPRI reference in it that is in GALL, but not 22 the specific list of tests?
23 MR. NGUYEN: Can you repeat again?
24 JUDGE KENNEDY: I guess I see an EPRI 25 document here and I'm wondering if that EPRI document NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4054 1 that was listed in the basis document is the EPRI 2 document that is listed in GALL.
3 MR. NGUYEN: I believe so.
4 JUDGE KENNEDY: Okay, but felt that there 5 was a need to go further and list specific tests?
6 MR. NGUYEN: Yes, sir.
7 JUDGE KENNEDY: I see.
8 MR. COX: Just Kennedy, this is Alan Cox 9 for Entergy. I might clarify that a little bit. The 10 basis document would have said that we were going to 11 be consistent with GALL. I think in this case there 12 wasn't a specific repeating of the words that said 13 these are the types of tests. And we were asking to 14 include that in the basis document in response to this 15 item and that's what we did.
16 JUDGE KENNEDY: I guess not to put words 17 in your mouth, Mr. Nguyen, you're trying to confirm 18 that the applicant's site basis document demonstrate 19 a consistency with GALL?
20 MR. NGUYEN: Yes, sir.
21 JUDGE KENNEDY: So that's the context of 22 what's going on here.
23 MR. NGUYEN: Yes, sir.
24 JUDGE KENNEDY: You're on site looking at 25 the specific on-site documents as opposed to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4055 1 application?
2 MR. NGUYEN: Yes, sir.
3 JUDGE KENNEDY: Trying to confirm that --
4 I don't know if implementation is the right word, but 5 the site documents have a consistency with GALL as 6 well?
7 MR. NGUYEN: Yes, sir.
8 JUDGE KENNEDY: Is that what's going on 9 here?
10 MR. NGUYEN: Yes, sir. Thank you.
11 JUDGE McDADE: Judge Kennedy, before you 12 move forward, if there's one thing I could just ask, 13 Mr. Bascom, Entergy provided Exhibits 000242 and 14 000243 which are the in-scope low voltage list and the 15 in-scope medium voltage list. Does New York have any 16 objection or complaint with the scoping? In other 17 words, do you have any reason to believe that all of 18 the appropriate cables that need to be covered by the 19 program have been included in the lists?
20 MR. BASCOM: This is Mr. Bascom. Would 21 you mind bringing up that exhibit on the display?
22 JUDGE McDADE: 000242, 000243 Entergy.
23 Let's just do 000242 first.
24 MR. BASCOM: Yes, this is Mr. Bascom. I 25 have no knowledge that the cables listed and the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4056 1 systems listed deviated from what they have at the 2 plant. So I have to take that on the word and the 3 information I was provided.
4 JUDGE McDADE: But that's not something 5 what New York is alleging is inadequate?
6 MR. BASCOM: In the initial License 7 Renewal Application, this is Mr. Bascom. In the 8 initial License Renewal Application I did not see a 9 list of the cables or systems that they have related 10 to this contention. So the issue was I just wasn't 11 aware of what cable systems they had and apparently 12 this information was made available after my initial 13 evaluation.
14 JUDGE McDADE: Okay, thank you.
15 Judge Kennedy?
16 JUDGE KENNEDY: I guess while we're on 17 this exhibit, where does this information reside?
18 Where did this exhibit come from? I remember seeing 19 it, but I don't remember its origin.
20 Maybe Entergy, Alan?
21 MR. COX: Let me start by saying the 22 systems that these cables are in would be able to be 23 determined from the License Renewal Application in 24 each system. I'm sorry --
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4057 1 and screening type information? Is there a linkage of 2 this exhibit to that information?
3 MR. COX: They already said that we would 4 include the medium voltage inaccessible cables that 5 are in the scope of license renewal and perform an 6 intended function, so that's the criteria that was 7 used to develop this list. And I think Mr. McCaffrey 8 could speak further about the details about where 9 these details come from.
10 JUDGE McDADE: The question, Mr. Cox, I 11 was just -- where does this list reside?
12 MR. McCAFFREY: This is Tom McCaffrey for 13 Entergy. This resides with our Cable Reliability 14 Program. So this is our basis for the program. We 15 used EN-DC-346 to come up with this list and this is 16 what's in our program.
17 JUDGE KENNEDY: So and I'm going to guess 18 the next exhibit, is that also in the Cable 19 Reliability Program?
20 MR. McCAFFREY: That's correct.
21 JUDGE KENNEDY: So that's where this 22 information resides?
23 MR. McCAFFREY: That's correct.
24 MR. COX: This is Alan Cox. And those are 25 plant documents to answer your question where they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4058 1 reside. They would be in the program information at 2 the plant.
3 JUDGE KENNEDY: Mr. Rucker, is that the 4 Cable Reliability Program document that you were 5 speaking to earlier where you were talking about 6 testing?
7 MR. RUCKER: This is Roger Rucker for 8 Entergy. These lists are not going to be included in 9 the procedures in DC-346. These are part of the Cable 10 Reliability Program documents. I think if you want 11 some more details of exactly what they are, Mr.
12 McCaffrey can answer that.
13 JUDGE McDADE: DC-346 is fleet-wide and 14 these are specific to Indian Point, is that correct?
15 MR. McCAFFREY: This is Tom McCaffrey for 16 Entergy. These are the site-specific implementation 17 sheets that we use so we take the information from DC-18 346, understand the systems that need to be included 19 in our Cable Reliability Program and this is what we 20 would use to determine the correct tests based upon 21 the cable manufacturer, type of cable for 22 implementation of our program.
23 JUDGE KENNEDY: Thank you. Can we go back 24 to Entergy 000041?
25 Mr. Nguyen, is there anything else you'd NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4059 1 like to communicate to the Board here from this audit 2 report?
3 MR. NGUYEN: No, sir.
4 JUDGE KENNEDY: Okay, so we're done with 5 this exhibit then? Okay.
6 Is there additional information you'd like 7 to provide as well into the process of the on-site 8 audit process?
9 MR. NGUYEN: No, sir. I already 10 explained.
11 JUDGE KENNEDY: Then let me ask a couple 12 of questions. What is the overall objective of the 13 staff performing the on-site review and I guess let's 14 focus just on the Aging Management Program.
15 MR. NGUYEN: To confirm that what the 16 applicant claims in the application is actually true 17 and to confirm that. The GALL program is a program 18 and provides reasonable assurance that the cable and 19 a secondary cable will perform the intended function.
20 JUDGE KENNEDY: So it's a confirmation 21 process?
22 MR. NGUYEN: Yes, sir.
23 JUDGE KENNEDY: Is it fair to say that the 24 staff does not obtain additional information to 25 augment their reasonable assurance determination as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4060 1 part of this on-site audit?
2 MR. NGUYEN: No, sir.
3 JUDGE KENNEDY: So it's a pure 4 confirmation and what would you say the basis would 5 be? Where do you base your reasonable assurance 6 determination on for this aging management effect and 7 program?
8 MR. NGUYEN: We find that if the applicant 9 committed to a program, that would provide reasonable 10 assurance.
11 JUDGE KENNEDY: So in this case, it 12 appears that Entergy has committed to a program 13 consistent with XI.E3?
14 MR. NGUYEN: Yes, sir.
15 JUDGE KENNEDY: And you have then 16 performed a confirmation audit to, I guess, confirm 17 that what they say in this application is consistent 18 with what you can see at the site at that point in 19 time?
20 MR. NGUYEN: Yes, sir.
21 JUDGE KENNEDY: So your reasonable 22 assurance is based, I guess, if we circle all the back 23 around, your reasonable assurance ultimately is based 24 on what's in the application or the application is 25 augmented by any RAIs?
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4061 1 MR. NGUYEN: Yes, sir.
2 JUDGE KENNEDY: And I think you pointed to 3 a few examples where the Aging Management Program was 4 augmented in terms of testing frequencies and manhole 5 inspection frequency?
6 MR. NGUYEN: Yes.
7 JUDGE KENNEDY: Is there -- there's one 8 other, but is there -- I guess -- does that ultimately 9 end up in a supplement to the License Renewal 10 Application?
11 MR. NGUYEN: Yes, sir.
12 JUDGE KENNEDY: The decrease of the 13 testing frequency from ten years to six years, what 14 was at the heart of driving that change?
15 MR. NGUYEN: During the -- we issued 16 Generic Letter 2007-01 to ask the licensee to provide 17 us any failure of the power cable. We performed a 18 safety function. In the Indian Point 2 and 3 case, 19 they have two failures, if I remember correctly. I 20 may be wrong, but applicant can correct me. Too low 21 voltage for 80 volt failure, but it's not due to 22 aging. It's due to mechanical, human error, whatever.
23 The other one is due to -- did not meet 24 the testing criteria at that time. However, they 25 include the low voltage cable and in response to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4062 1 Generic Letter 2007-01.
2 The number of the applicant indicates that 3 they have a number and I don't remember how many.
4 It's a low-voltage cable, but the exact cause of the 5 low cable is not known, but they have some failure.
6 Therefore, the staff acted proactively to go back and 7 ask the applicant to provide the justification of why 8 this cable is not in scope of the medium voltage.
9 In addition to that, we also expand the 10 technical frequency for every ten years to every six 11 years with the caveat. If they file any problem that 12 the test -- if the test does not meet acceptable 13 criteria they have to increase the frequency even more 14 or replace the cable.
15 Also, we also require the applicant to --
16 we also -- request additional information to change 17 the frequency of the inspection of the manhole from 18 every two years to annually, but the inspection 19 frequency will be changed based on operating 20 experience at the site.
21 We also eliminate the criteria with the 22 significant voltage is defined as energized more than 23 25 percent. That means if the cable is energized or 24 not energized, we require them to include in the 25 cable management program.
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4063 1 JUDGE KENNEDY: Okay. So now we've worked 2 our way from the application through the on-site audit 3 and ultimately, I guess we've had some modifications 4 to the License Renewal Application as initially 5 submitted. And are we now at the point where the 6 staff would be documenting their evaluation in the 7 SER?
8 MR. NGUYEN: Yes, sir. If you go to New 9 York State Exhibit 000160.
10 JUDGE KENNEDY: Was that New York State 11 000160?
12 MR. NGUYEN: Yes, sir. We document our 13 review at page 3.5, 3.6, 3.7. And if I may, will 14 read the point that the applicant revised their 15 application in response to our Request for Additional 16 Information. "The 60 volt voltage definition 17 applicable to medium-volt cable, 35 cables subject to 18 system voltage for more than 25 percent of the time is 19 remove at a scope of the program criterion."
20 JUDGE KENNEDY: Which page are you 21 starting on?
22 MR. NGUYEN: I am at 3.7, sir.
23 JUDGE KENNEDY: 3.7?
24 MR. NGUYEN: Yes. The issue with cable is 25 expanded to include 400 volts to 2 kilovolt in scope NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4064 1 of inaccessible low-voltage power cable.
2 JUDGE KENNEDY: Is that the second bullet 3 on this page?
4 MR. NGUYEN: Yes, sir. The performance of 5 manual inspection is increase to annually testing 6 inaccessible cable, 400 volts to 35 kilovolts, for 7 insulation will be performed at least once every six 8 years. Event-driven inspection. Example, heavy rain 9 or flooding are incorporated in a Non-EQ Inaccessible 10 Medium Voltage Cable Program.
11 Cable tests result in review to determine 12 the need for more frequent testing. And the last 13 point, manhole inspection results are evaluated to 14 determine the need for more frequent manhole 15 inspections.
16 JUDGE KENNEDY: So how do these enhance --
17 I guess, how do they -- how does this work its way 18 back into either or does it work its way back into the 19 UFSAR supplement or the program -- I guess I'm really 20 -- where's the hook that makes this all work?
21 MR. DOUTT: This is Cliff Doutt of the 22 staff. The seven attributes if you will, most of that 23 is based on operating experience, not necessarily 24 plant specific to Indian Point. But based on 25 operating experience and response to General Letter NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4065 1 2007-01, these specific points are in the FSAR, as far 2 as the FSAR summary update. They were included as 3 well.
4 MR. COX: This is Alan Cox. I can clarify 5 that. If you look at the very top of this page --
6 MR. DOUTT: It talks about FSAR --
7 MR. COX: It refers to the specific 8 sections in the Appendix B of the LRA and Appendix A 9 is the part that goes into the FSAR.
10 JUDGE KENNEDY: Do we have an exhibit with 11 the -- I guess it would be a modified FSAR supplement?
12 I didn't find one last night.
13 MR. O'NEILL: Your Honor, this is Martin 14 O'Neill for the applicant. I think we could look at 15 New York State Exhibit 000154.
16 JUDGE KENNEDY: New York State 000154?
17 Mr. Welkie, could we? And I guess what I'm taking 18 away from this is we started with the original 19 application. You went through an office review to an 20 on-site review to some changes proposed to the 21 drafting of an SER and the capture of some critical 22 changes for the Aging Management Program.
23 MR. NGUYEN: Yes, sir.
24 JUDGE KENNEDY: And I guess I'm looking to 25 see where this all ends up. Does it all end up -- I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4066 1 think Mr. Doutt just said in the FSAR Supplement?
2 MR. DOUTT: Yes, there's two things that 3 happened. There's a licensing commitment which lists 4 these enhancements and also the FSAR Supplement lists 5 these enhancements as well.
6 JUDGE KENNEDY: So there may be additional 7 stuff captured in a commitment?
8 MR. DOUTT: It's those bullets there and 9 a commitment as well. They're also in the FSAR.
10 JUDGE KENNEDY: Okay, so they're actually 11 in both places.
12 MR. DOUTT: They're in both places.
13 MR. O'NEILL: Excuse me, Your Honor. We 14 should look at page 4 of 24 in the PDF.
15 JUDGE KENNEDY: Thank you. That's a help.
16 MR. O'NEILL: I apologize for the 17 interruption.
18 JUDGE KENNEDY: No, that's a help. So is 19 it this A.2.1.22?
20 MR. DOUTT: That's correct.
21 JUDGE KENNEDY: It should be below it.
22 MR. DOUTT: Yes. This is one of the RAI 23 responses for clarification.
24 JUDGE KENNEDY: You may be a better person 25 than I. Did I understand you to say that the bullets NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4067 1 --
2 MR. DOUTT: Yes, if you read the text, the 3 seven bullets, they're there.
4 JUDGE KENNEDY: You're very confident with 5 that.
6 MR. DOUTT: That's why there's three RAIs 7 actually. Was to adjust the limits into the FSAR.
8 JUDGE KENNEDY: Okay. And this is really 9 the hook that I guess the Board has been looking for 10 and now you've walked us through the entire process 11 and this is where we end up. I understand this is a 12 mark up, but this is a binding -- do I need to view 13 this as a binding document on the licensee?
14 MR. DOUTT: With the commitment in the 15 FSAR, you're looking at the licensing basis, right.
16 JUDGE KENNEDY: Okay.
17 MR. O'NEILL: Your Honor, Martin O'Neill 18 for the applicant. Just for the record, the relevant 19 commitment is No. 15. License Renewal Commitment 15 20 which I believe is also contained in Attachment 2 to 21 this document.
22 JUDGE KENNEDY: And I understood from 23 testimony yesterday that commitments are listed in the 24 SER when it's drafted? Is that true?
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4068 1 Supplement Section in the in sectional report. If you 2 can turn to 3.8 of the SER, New York State 000160.
3 JUDGE KENNEDY: Of this document? Is that 4 --
5 MR. NGUYEN: Yes, that's where we discuss 6 about the Supplement.
7 MR. COX: This is Alan Cox for Entergy.
8 Thee's actually two places I think Mr. Nguyen is 9 referring to the text in the evaluation write-up in 10 the SER which refers to the commitment. That same 11 commitment is in a compiled list of commitments that 12 is Appendix A of the SER and that same list is also in 13 Attachment 2 to this letter. It would show the same 14 commitment.
15 JUDGE KENNEDY: Just for the record, does 16 someone have an exhibit for the SER itself?
17 MR. COX: New York State 160.
18 JUDGE KENNEDY: Sorry, someone already 19 said that. And so Appendix A to New York State 000160 20 would contain the commitment list?
21 MR. COX: Yes, that's correct.
22 JUDGE KENNEDY: Assuming that 000160 is 23 the SER.
24 MR. COX: I believe 000160 is the SER 25 Supplement which should have the latest revision of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4069 1 the commitment list.
2 MR. TURK: Your Honor, Sherwin Turk. That 3 is the latest published commitment list. As we noted 4 yesterday, there have been some further commitments 5 made.
6 JUDGE KENNEDY: Can someone verify that 7 Commitment 15 is in New York State 000160? Or should 8 we go to Appendix A?
9 MR. TURK: It is, Your Honor, and I can --
10 if you like, I can provide a copy to you or we can 11 pull it up on a screen.
12 JUDGE KENNEDY: Why don't we just ago 13 ahead and pull up New York 000160 and just close this 14 out.
15 MR. TURK: It's on page A-11 of the 16 document, New York 000160.
17 JUDGE KENNEDY: Thank you, Mr. Turk.
18 MR. TURK: A-11.
19 JUDGE WARDWELL: I'll ask this of Entergy, 20 does this also get folded into the UFSAR if I 21 understood it correctly from last two days' testimony?
22 MR. COX: This is Alan Cox for Entergy.
23 The current practice to the two most recent 24 applications I'm aware of the NRC has included these 25 -- this list of commitments as part of the FSAR. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4070 1 it's in there as this list. It's also in there as the 2 referenced sections that we just looked at as an 3 attachment to that letter that showed the A1.22 and 4 the A2.1.22, I mean 3. We have a section for IP 2 and 5 IP3 and we looked at -- I believe we looked at the IP2 6 section.
7 JUDGE KENNEDY: How does this actually 8 work? The first line says "implement a 90Q 9 inaccessible medium voltage cable program for IP2 and 10 IP3 as described in LRA Section B.1.2.23. Yet, we've 11 noticed that there's been modifications made to what 12 was submitted. How do I know that this gets me to 13 that updated --
14 MR. NGUYEN: I can answer. If you go to 15 FSAR Supplement A.2.1.22 and A.3.1.22, you will see 16 the revision to the FSAR Supplement. The commitment 17 lists either one that the applicant commits to preform 18 this before the PEO.
19 MR. COX: Judge Kennedy, to answer your 20 question as far as how you would get there, if you 21 look at the source in the last column, those are the 22 commitment letters from Entergy that revised or 23 affected that particular commitment.
24 JUDGE McDADE: Thank you, Mr. Cox.
25 JUDGE KENNEDY: Do I understand that to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4071 1 mean that those sources will modify the description 2 that's in the original LRA?
3 MR. COX: Yes, that is correct.
4 JUDGE KENNEDY: So if you had to sort 5 through all this, A2.1.22 and A3.1.22 would be 6 modified to incorporate the discussion we've been 7 going through here today that the modifications that 8 are in the SER?
9 MR. COX: Yes, that's correct.
10 JUDGE KENNEDY: It's not as intuitive as 11 I thought it was going to be. So I appreciate the 12 tour.
13 I'm wondering if we could call up New York 14 State Exhibit 000411 at page 2, please.
15 I'm looking, could you highlight lines 11 16 through 14?
17 Mr. Bascom, this statement, I believe, is 18 attributed to you and I think -- I guess I'd like you 19 to comment on -- I guess if you would please read 20 lines 11 through 13 and then let's talk about it.
21 MR. BASCOM: This is for Mr. Bascom?
22 JUDGE KENNEDY: Yes.
23 MR. BASCOM: In my opinion, the Cable 24 Reliability Program, if followed, will adequately 25 manage the effects of aging caused by the exposure of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4072 1 these cables to significant moisture.
2 JUDGE KENNEDY: And I guess, help us 3 understand what you mean by that?
4 What's your view? How would you like this 5 to work?
6 MR. BASCOM: My initial issue -- this is 7 Mr. Bascom. My initial issue was that the License 8 Renewal Application by itself did not reference 9 Entergy's Cable Reliability Program and without that 10 reference there was no specificity to what they would 11 be doing for the cables at Indian Point 2 and 3 for 12 medium- and low-voltage cables. This follow-up 13 testimony was after they made available as an exhibit 14 the Cable Reliability Program that we've been 15 discussing this morning.
16 The issue that I guess I still have some 17 trouble with is that I don't see where that 18 reliability program is directly linked their 19 application. And from the discussion this morning it 20 appeared to me there is no requirement that they 21 follow what's in that reliability program.
22 In other words, they have flexibility to 23 modify at will without any outside review because it's 24 an internal operating procedure as opposed to 25 something that's part of the UFSAR which survives NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4073 1 after the license application expires, assuming that 2 they do get approval for continued operation.
3 JUDGE KENNEDY: Let's set some baselines 4 here. Cable Reliability Program, do you remember 5 which document you reviewed? Do you have a --
6 MR. BASCOM: This is Mr. Bascom. They 7 provided an initial draft and the current version that 8 is available is EN-DC-346. I'm sorry, I don't have 9 the exhibit number.
10 JUDGE KENNEDY: I think we have that 11 earlier.
12 MR. O'NEILL: Your Honor, Martin O'Neill 13 for the applicant again. Pardon the interruption.
14 When we submitted the testimony, we originally 15 referenced EN-DC-343 provision 2 which is Entergy 16 Exhibit 000237. And I think our testimony generally 17 references that revision. Subsequent to the filing of 18 our testimony Revision 3 of the EN-DC-343 was issued 19 and we've moved that into evidence as Exhibit 20 ENT000583. So it's Entergy 000583. And that is, to 21 my understanding, the current revision of the 22 procedure, Revision 3.
23 JUDGE KENNEDY: Thank you. So it seems 24 like the -- this may be where the details that you've 25 been looking for exist. And maybe we should have some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4074 1 discussion here about how the Aging Management 2 Program, as described in the LRA, works with this 3 Cable Reliability Program which I think we'll turn to 4 Entergy and see if they can walk us through. I guess 5 starting with the Cable Reliability Program, I already 6 have forgotten if this is a fleet-wide program or an 7 Indian Point document and how we get this all to work 8 together. I don't know, Mr. Cox or --
9 MR. COX: Judge Kennedy, this is Alan Cox.
10 This is a fleet-wide procedure. The title of the 11 procedure is Cable Reliability Program and in the 12 context of license renewal we look at this as the 13 implementing procedure for the medium- to low-voltage 14 cable program that we've described in the LRA.
15 JUDGE KENNEDY: In terms of it being in 16 some sort of -- and I'm not sure what the right word 17 is, what sort of hooks there are to the NRC oversight 18 and review of this document and whether changes can be 19 made? I think we've had testimony over the last few 20 days, but it wouldn't hurt to refresh us all here on 21 this particular topic, how changes can be made to this 22 procedure, what level of oversight on the part of the 23 NRC exists for this document and so on and so forth?
24 MR. COX: Okay, this is Alan Cox again.
25 It's very similar to what we discussed yesterday. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4075 1 essential elements of the program, as Mr. Nguyen and 2 Mr. Doutt have indicated are included in the FSAR 3 Supplement.
4 The specific details of how we implement 5 those elements are in this procedure. This procedure 6 is on the street. It's been approved. It's subject 7 to change following processes that we've discussed 8 previously. The procedure change process requires us 9 to do the screening to determine if it involves an 10 activity described in the FSAR.
11 In this case, the test is describing the 12 FSAR, so we would have to evaluate that change against 13 what's in the FSAR to make sure we did not make a 14 change that would violate the commitment for the 15 program as described in the FSAR Supplement that we 16 will add for license renewal.
17 JUDGE KENNEDY: In this context, would it 18 be the test as described in that EPRI document that's 19 referenced in GALL or the list of tests that we talked 20 about or approved state-of-the-art?
21 MR. COX: I think the essential part of 22 that statement would be a proven test. We've used the 23 EPRI guidance as it says what would be a proven test 24 and that's what's written into the procedure now.
25 Again, that would be subject to changes under the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4076 1 50.59 process as we have previously discussed.
2 JUDGE KENNEDY: A change is described in 3 the FSAR. I'm playing with this proven test. If you 4 changed out one proven test for another proven test, 5 is that a change as described in the UFSAR or not?
6 MR. COX: That's a change. The UFSAR 7 Supplement doesn't identify which of those specific 8 tests. The UFSAR says it will be a -- it gives you a 9 menu of tests or it says a proven test. We can change 10 the specific test without requiring prior NRC approval 11 as long as we follow the 50.59 process to ensure it 12 doesn't affect the safety of the plant.
13 JUDGE KENNEDY: Let me try a different 14 subject. There's the screening portion of this and 15 then there's the actual 50.59 evaluation. Would a 16 change of that nature make it through the screening 17 process and enter the 50.59 evaluation using the 18 proven test example? Was that clear?
19 MR. COX: I think I understand your 20 question. I think I probably have to go through the 21 details of the questions that are in the screening 22 procedure to do that. I don't have that right in 23 front of me 24 JUDGE KENNEDY: A cleaner example may be 25 the testing frequency. If you did -- if you tested on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4077 1 an eight-year -- if you proposed testing on an eight-2 year frequency, that's maybe a cleaner example. Would 3 it go through the same process?
4 MR. COX: That would require the 50.59 5 evaluation. The screening would tell you you need to 6 evaluate that because it would be a change to a detail 7 that is described in the FSAR.
8 JUDGE KENNEDY: So at least for the 9 elements or the attributes that are captured in the 10 UFSAR, changes to EN-DC-346 could trigger a 50.59 11 evaluation. Other changes may not.
12 MR. COX: I believe that's a correct 13 characterization of it, yes.
14 JUDGE KENNEDY: Is EN-DC more of a program 15 document or more of an implementing-type procedure or 16 is that -- is that a misuse of the term?
17 MR. COX: I think it's difficult to -- for 18 me to make that distinction. I think for license 19 renewal purposes, the program is what we described in 20 Appendix B. The way I would refer to EN-DC-346 is 21 it's an implementing procedure. It's actually what's 22 used by the various sites to implement in this case 23 the commitment that Indian Point made in the Appendix 24 B of the LRA.
25 JUDGE KENNEDY: And as we discussed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4078 1 yesterday, there could be other procedures below that 2 procedure that drive things like specific types of 3 tests or inspections?
4 MR. COX: I'll let Mr. McCaffrey address 5 that.
6 MR. McCAFFREY: This is Tom McCaffrey for 7 Entergy. That's correct. There are some sub-8 procedures and I'll give you an example. In DC-346, 9 one of the reference documents is EN-MA-138 which is 10 the VLF tan delta withstand testing. So that's how we 11 would go implement the testing on the medium voltage.
12 Those are our actual instructions for the technicians 13 to perform that test.
14 MR. O'NEILL: Martin O'Neill for the 15 applicant. That particular sub-procedure, if you 16 will, is Entergy Exhibit 000254.
17 JUDGE KENNEDY: I guess maybe back to the 18 staff. I think we've sort of have been around and 19 around on the 50.59 process and the fact that there 20 are some levels of controls within Entergy's process 21 to manage the key attributes that were called on the 22 UFSAR Supplement. I thought I heard one of the staff 23 witnesses talking about the use of the license renewal 24 inspection and oversight process as another mechanism 25 for at least review and oversight of the process. If NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4079 1 either one of you could walk me through that.
2 MR. DOUTT: This is Cliff Doutt. I think 3 I mentioned the 103 inspection which is done prior to 4 PEO. I think at Indian Point it's a temporary 5 instruction, but what that does is take a look at the 6 commitments, make sure -- verify that they've been 7 actually -- that procedures that the AMP is 8 implementing procedures and the commitments have 9 actually been done. So that's one form.
10 And once you're in the PEO, then again 11 Part 50 is in place just like it always was as far as 12 Appendix B inspection and audit -- operating 13 experience from a standpoint -- I'm not making --
14 71003 first, that makes sure the AMP is incorporated.
15 The commitments are done, the conditions, the FSAR 16 Supplement. Prior to that or after that then really 17 Part 50, Appendix B inspection criteria. That's how 18 we picked some of these things up. And obviously, if 19 there was a change of procedure that changed the 20 licensing basis. That's a 50.59 and we would see that 21 as well.
22 JUDGE KENNEDY: Now as move out in time 23 and we're now in the period of extended operation, are 24 there similar inspection processes that occur? Let's 25 say for license renewal issues?
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4080 1 MR. DOUTT: I'm not specific to license 2 renewal because you're essentially Part 50, so as 3 today if there was a procedure being implemented that 4 either didn't follow the particular instructions, was 5 incorrect or generated a corrective action, something 6 like that, it would be the same process.
7 JUDGE KENNEDY: So it would fall back into 8 the general reactor oversight-type process?
9 MR. DOUTT: That's my understanding, yes.
10 JUDGE KENNEDY: Mr. Cox or someone from 11 Entergy, is that your understanding now once we enter 12 the period of extended operation, the Agency's 13 oversight of the license renewal activities?
14 MR. COX: Yes, it would fall under Part 50 15 process.
16 JUDGE KENNEDY: Thank you. Mr. Bascom, 17 does that comfort you in any way? Do you see some 18 issues with this oversight process, the inspection 19 process and at least a measure of control through I 20 guess the characteristics that at least were captured 21 as being key characteristics from GALL elements being 22 controlled under a 50.59 process and if that's not a 23 term that you understand, then we can get the 24 witnesses to work through it a little more. Does this 25 help at all in giving you some comfort that the Cable NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4081 1 Reliability Program works with the Aging Management 2 Program?
3 MR. BASCOM: This is Mr. Bascom. I 4 understand that there's a process by which the staff 5 could review changes internally to procedure that 6 Entergy is performing specific to the Cable 7 Reliability Program. It still appears. There is some 8 flexibility that they would have in modifying that 9 program that maybe wouldn't rise to the level where it 10 would pass the screening process.
11 It's unclear to me what discretion or what 12 level of evaluation that determination would be made.
13 But the Cable Reliability Program does address 14 managing the cables. It's just the link to where 15 that's regulated or required by the staff's review.
16 It still appears to be uncertainty in my view.
17 JUDGE KENNEDY: All right, thank you.
18 About to shift topics here a little bit so since I 19 can't yell all the way down to the other end of the 20 table, I'm going to move -- my proposal is I have a 21 number of detailed questions just related to this AMP 22 and I guess I'd like to open up to other board members 23 if they have any followups on this train of discussion 24 we've had here to do so at this time.
25 Are you good? Seriously? We'll move on.
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4082 1 (Laughter.)
2 MR. COX: Judge Kennedy, can I make one 3 comment before you shift gears there?
4 JUDGE KENNEDY: Yes, sir.
5 MR. COX: I don't want to leave the 6 impression that if we have some procedure that goes 7 through the screening process and doesn't require an 8 evaluation that there's no technical review of that 9 procedure. I think Mr. McCaffrey could probably speak 10 to the kind of review and oversight that goes into 11 making a procedure change, even a procedure change 12 that doesn't trigger the criteria for the 50.59 13 evaluation.
14 JUDGE KENNEDY: I think we had some of 15 that discussion yesterday, but it wouldn't hurt to 16 maybe refresh us.
17 MR. McCAFFREY: This is Tom McCaffrey for 18 Entergy. So we'll use -- I believe it's Entergy 19 000237 which is EN-DC-346 as our base reference here.
20 JUDGE KENNEDY: That's great.
21 MR. McCAFFREY: If I was the engineer and 22 I was going to make a change to this procedure, I 23 would have to evaluate all of the references that are 24 described in Section 2 to understand the change I'm 25 making. So if one of the references change, there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4083 1 a driving document or industry action for us making 2 that change.
3 The engineer would have to document that 4 review and its impact on the FSAR Supplement and our 5 commitment. So it goes through a technical review and 6 then you ask certain four questions that are contained 7 in the screening process, basically on the impact to, 8 the design function, the method of control and design 9 function, a method of test evaluation in the FSAR and 10 the fourth question I can't remember right now.
11 Basically, looking at those four questions to 12 understand the impact.
13 They're also going to make a review 14 against the commitment. There's specific commitments 15 in the back of EN-DC-346. I believe it's Section 8.
16 It lists the site-specific commitments and both the 17 Unit 2 and Unit 3 site-specific commitments for the 18 Cable Reliability Program are contained in that 19 procedure, so they'd have to further evaluate those 20 commitments to validate that we are still in 21 compliance with what we committed to in this 22 proceeding.
23 MR. O'NEILL: Your Honor, Martin O'Neill 24 for the applicant. In Entergy Exhibit 000237, that is 25 page 22 of 34, that contains the IPEC specific NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4084 1 commitments.
2 JUDGE KENNEDY: I'm curious to see what 3 that looks like. I wonder if we could take a look at 4 Entergy 000237. And Mr. O'Neill, I've already 5 forgotten the page again.
6 MR. O'NEILL: Page 22 of the document, PDF 7 as well.
8 JUDGE KENNEDY: Thank you.
9 MR. McCAFFREY: Again, this is Tom 10 McCaffrey for Entergy. If you look in Section 8 and 11 that's really what's on that page 22, it is a list of 12 all the commitments. As we said before this is a 13 fleet-implementing procedure for this program, so you 14 can see there's more than just Indian Point's 15 commitment, but both Unit 2 and Unit 3 commitments are 16 listed there at the top of page 22. So that would 17 require the engineer who is making this change to 18 evaluate the reference changes in the beginning 19 section and along with the commitment in addition to 20 the FSAR review.
21 JUDGE KENNEDY: So what would happen if a 22 line engineer tried to make a change to one of these 23 commitments? Does that trigger some sort of activity?
24 MR. McCAFFREY: There's a commitment 25 change process we can use. If for some reason there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4085 1 new technology and the industry and the NRC have 2 agreed to -- I'm going to make up something, we're 3 going to go to a six-month manhole frequency and 4 that's what industry, OE, and everybody has agreed to, 5 or 18 months, I'm sorry. Eighteen months is beyond 6 our thing. We'd have to go through a process with the 7 NRC to change our commitment because of some industry 8 OE that's driving us to make that change.
9 JUDGE KENNEDY: All right, thank you. Is 10 there anything else you'd want to add in this change 11 process?
12 MR. McCAFFREY: I want to say it's 13 prepared reviewer process. It gets an individual 14 contributor or an engineer prepares it and then he 15 gets a second review by another engineer who is not in 16 the preparation process. You get a dual verification 17 that we're meeting our compliance requirements from 18 our license basis documents.
19 JUDGE KENNEDY: And that would include 20 checking that these commitments aren't being changed 21 as part of that procedure change?
22 MR. McCAFFREY: That's correct. So you 23 have a program engineer and then you have a separate 24 individual reviewer competing another review of that 25 process.
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4086 1 The final part of that process is after 2 that's done it gets approved by a department-level 3 manager like myself on that change and we'll review 4 the 50.59 and the procedure change to make sure we're 5 not missing any of our commitments.
6 JUDGE KENNEDY: All right, thank you. At 7 this point I was going to try to hit a few what I call 8 detailed questions, but they're small issues that came 9 to me as I reviewed the testimony. So I'm going to go 10 forward with that.
11 Mr. Welkie, could you call up Entergy 12 000233? And I'm looking for page 39.
13 I guess I didn't write down the answer, 14 but what -- let's see, it's probably here. Under the 15 response to Question 64, it indicates that all cables 16 will be tested prior to the period of extended 17 operation. And I guess I'm just curious where IP2 and 18 IP3 are in that testing?
19 MR. McCAFFREY: This is Tom McCaffrey for 20 Entergy. Exhibits 000242 and 000243 for Entergy list 21 the cables that are in the program. All the low-22 voltage cables have been completed. And the cables 23 listed in 000243 for Unit 2, they were cables to be 24 tested in the first half of 2013.
25 JUDGE KENNEDY: So they'll be completed NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4087 1 before the period of extended operation then?
2 MR. McCAFFREY: That's correct.
3 JUDGE KENNEDY: And as I understand it, 4 the testing frequency, once you enter the period of 5 extended operation will be every six years after that?
6 MR. McCAFFREY: That's correct, unless we 7 find it, as the NRC staff has mentioned, we find any 8 type of condition that would warrant more frequent 9 testing.
10 JUDGE KENNEDY: Can we move to page 41?
11 JUDGE WARDWELL: Can we stay right on that 12 one while we're there?
13 JUDGE KENNEDY: Yes, sir.
14 JUDGE WARDWELL: And what is the 15 justification for that six-year period? Where did 16 that come from?
17 MR. RUCKER: This is Roger Rucker for 18 Entergy. That's from the GALL Report Section XI.E3, 19 Rev. 2 which is the basis for the migration of the 20 program for this application.
21 JUDGE WARDWELL: Thank you. Do you have 22 any insight into how GALL 2 happened to adopt that 23 time frame, Mr. Rucker?
24 MR. RUCKER: I can answer that. During 25 the review process for going from GALL Rev. 1 to GALL NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4088 1 Rev. 2, my understanding with the staff's concern was 2 the number of inspections that we would have, so being 3 able to trend results. And this was considered to be 4 the minimum or the maximum, depending on how you look 5 at this, criteria for achieving the results that they 6 needed to see, even if you were getting good test 7 results.
8 JUDGE WARDWELL: Thank you. Staff, either 9 of the witnesses. Is that your understanding or do 10 you have any more insight that would help us with 11 determining this essential period.
12 MR. DOUTT: This is Cliff Doutt. Part of 13 that in Rev. 1, it had a little statement in there, 14 essentially you have one test in the 20 years.
15 There's not much of a trend. So that's part of it.
16 The second part was on the responses and 17 operating experience and in Generic Letter 2007-01, 18 looking at that data we thought it was a reasonable 19 thing to also back that time period up from ten years.
20 JUDGE WARDWELL: Why didn't you reduce it 21 to three years?
22 MR. DOUTT: Just looking at the data, 23 essentially three was not necessary. It looks like 24 six would provide the data and cover the -- looks like 25 from what we saw from failures and a general NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4089 1 population, not specific to their plant specific that 2 that would cover it. So again, for plant specific if 3 they should find something different, those 4 frequencies would change.
5 JUDGE WARDWELL: Thank you. Mr. Bascom, 6 do you have any reason to argue against the six-year 7 interval or are you satisfied with that?
8 MR. BASCOM: This is Mr. Bascom. I have 9 no basis to suggest that a more frequent testing would 10 provide any additional information.
11 JUDGE WARDWELL: Thank you.
12 JUDGE KENNEDY: Could we move to Entergy 13 -- the same exhibit, page 41. Try 42, please.
14 In the response to A70, this is came to my 15 mind when I was thinking of some of Mr. Bascom's 16 concerns about where the corrective actions are 17 identified. And this suggests that Entergy will 18 evaluate any degradation detected under the Corrective 19 Action Program.
20 I know we've had a lot of discussion about 21 this Corrective Action Program. It appears, at least 22 as I see it, GALL doesn't specify any specific 23 corrective actions and so I think we're left with the 24 over-arching Corrective Action Program and I guess I'm 25 wondering -- again, I guess we've had previous NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4090 1 testimony about this, but I'm wondering how this all 2 works.
3 So we've got some cable test results that 4 will enter the Corrective Action Programs and I'm 5 wondering what the net result of that would or could 6 be? Maybe Mr. McCaffrey?
7 MR. McCAFFREY: This is Tom McCaffrey for 8 Entergy. We would enter the anomalous condition from 9 our cable testing and our Corrective Action Program 10 that would get assigned to an engineer to evaluate the 11 operability of that cable so we can make a prompt 12 determination of operability with our license 13 operators. And then we would evaluate the results we 14 had, do we need to increase the frequency of testing 15 or do we make some type of repairs to that cable 16 including replacement of that cable. And that would 17 be based upon the test results we received.
18 JUDGE KENNEDY: Is it possible it could go 19 beyond just cable replacement? I mean could there be 20 other things that would enter this program that could 21 impact the overall cable reliability program in terms 22 of maybe testing approaches or testing frequencies?
23 MR. McCAFFREY: I'm not really sure of the 24 question, Your Honor.
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4091 1 think something has a degraded condition going into 2 the Corrective Action Program. Then that fixes that 3 specific problem and I'm wondering if the program is 4 robust enough that it branches into looking at 5 recurrences of issues? Would it really force 6 increased testing of other cables, not just that 7 cable? I'm just wondering.
8 What I heard is it's broken and we should 9 fix it. It probably does require fixing or it's 10 degraded, but it's okay to continue. If the example 11 was a little more severe or there were more than one 12 or two -- I mean if there was a more frequent 13 occurrence of this particular issue, is the program 14 capable of dialing back into say the Cable Reliability 15 Program or ultimately the Aging Management -- I guess 16 that is the Aging Management Program to effect change 17 and so it's sort of a learning program.
18 MR. McCAFFREY: This is Tom McCaffrey for 19 Entergy. If there was a trend, we don't have a large 20 amount of cables. It's based on Exhibits 000242 and 21 000243. But if we saw a trend with two or three 22 cables having a problem, yes, that would increase us 23 doing more thorough evaluation and taking a larger 24 look at the program and other aspects we need to 25 address to ensure we have a sound reliability program NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4092 1 for our cables.
2 JUDGE KENNEDY: I guess it may be a 3 simpler example. Things that come to mind are the 4 manholes and the water or submergence of cables. How 5 the Corrective Action Program would look at 6 recurrences of those events and what criteria it would 7 or could use to trigger more broader actions within 8 the program and increased inspections or putting pumps 9 or so on and so forth.
10 MR. McCAFFREY: This is Tom McCaffrey for 11 Entergy again. We would look at the frequency of 12 occurrence. Let's take your example with water in 13 manholes. If we see manholes frequently have water in 14 there, water in the manhole during our inspections 15 would increase our inspection process to ensure that 16 we were removing the water and up to and including 17 installation of some type of sump pump or an alarm 18 that we can dispatch maintenance to remove the water 19 from there in a timely fashion. So that's part of the 20 corrective action process that would drive this.
21 MR. COX: This is Alan Cox. I would 22 clarify that that's an excellent example because 23 that's exactly what Mr. McCaffrey has done with the 24 program. The GALL specifies the frequency of once 25 every year and I believe there are actually based on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4093 1 the experience with those inspections, inspections are 2 being done at greater frequency than that.
3 MR. RUCKER: This is Roger Rucker. If you 4 look at Exhibit 000248, you'll see that almost all the 5 manholes that are in process are much more frequent 6 than once per year.
7 JUDGE KENNEDY: Could we call up -- is 8 that Entergy 000248?
9 MR. RUCKER: That's correct.
10 JUDGE KENNEDY: And is it your testimony 11 that the corrective action process, so I guess GALL 12 element 8 drove this type of change?
13 MR. McCAFFREY: This is Tom McCaffrey for 14 Entergy. That's correct. When maintenance went out 15 and did their inspection, they wrote a condition 16 report. That was evaluated by the Entergy staff and 17 changes were made to our frequency of our inspection 18 program.
19 JUDGE KENNEDY: I think this is a good 20 example of what I was contemplating. I mean maybe the 21 cable failure is a little harder to comprehend, but I 22 really was looking to make sure that I understood that 23 the corrective action process was broader than it's 24 broke and fix it, that it has -- and I guess we did 25 note that the corrective action process is an exhibit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4094 1 in this hearing. So I mean I think we can explore it, 2 but absent that, I was looking for some real-life 3 example and if your testimony says that this was 4 driven by the corrective action process into a 5 proactive change to change the inspection frequency, 6 I think that -- I'm comfortable with that as a much 7 broader action and something that would impact the 8 program in a positive way. So I appreciate the 9 example. I think it was useful to put this up.
10 MR. COX: This is Alan Cox. One line of 11 correction. I think you referred to Element 8. I 12 believe corrective action is actually Element 7.
13 JUDGE KENNEDY: I noticed some of the NRC 14 staff were smiling when I said that. Thank you, 15 though. I appreciate that. Memory not so good.
16 Bear with me just a second. I'm going to 17 check one last time to make sure I don't have any more 18 questions.
19 (Pause.)
20 Your indulgence is appreciated and I have 21 no additional detailed questions and at least from my 22 perspective if I consider this particular contention 23 broken into two different issues one being what we've 24 just discussed here on the inaccessible non-EQ cables, 25 I guess to me the next issue to take up is whether NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4095 1 excessive heat is an aging management effect that 2 needs to be considered for all the cables at Indian 3 Point.
4 I guess I'll ask -- I think at this point 5 I'm going to take Mr. Cox up on this request and have 6 us take a ten-minute break if that's okay.
7 JUDGE McDADE: Okay, it's about 11 minutes 8 of 11. Does anyone need a break of longer than ten 9 minutes? We come back at 11.
10 JUDGE KENNEDY: It's mostly because my 11 fellow Judges have stolen my water.
12 (Laughter.)
13 JUDGE WARDWELL: Don't say fellow Judges.
14 I have my water.
15 JUDGE KENNEDY: My water is your water.
16 JUDGE McDADE: Does that mean we don't 17 need a break?
18 JUDGE KENNEDY: We need a break. Mr. Cox 19 has requested a break.
20 JUDGE McDADE: We'll stand in recess until 21 11.
22 (Whereupon, the foregoing hearing went off 23 the record at 10:50 a.m. and went back on the record 24 at 11:07 a.m.)
25 JUDGE KENNEDY: The hearing will come to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4096 1 order. Everybody have a water pitcher?
2 I guess at this point I would like to take 3 us into some discussion on the second part of this 4 contention which relates to Entergy not having an 5 Aging Management Program for inaccessible non-EQ 6 medium voltage cables exposed to excessive heat. And 7 I guess I would like to start with Mr. Bascom and have 8 him explain why he believes such an Aging Management 9 Program would be needed for Indian Point.
10 MR. BASCOM: This is Mr. Bascom. I guess 11 I would like to start out with a clarification in 12 regards to EQ and non-EQ and my evaluation that a 13 Thermal Aging Management Plan should be in place. It 14 is in regards to the non-EQ cables.
15 So cables that are in normal parts of the 16 plant under what would be considered typical 17 conditions not exposed to the adverse environment that 18 environmentally qualified cables would be exposed to 19 but still conditions that would be outside the realm 20 of where they would be expected to operate. And I can 21 clarify in regards to ambient temperature that is 22 higher than design limits or intended thermal 23 resistivity of soils that are above the design values 24 that were used to develop the cables and situations 25 where there is multiple cables in close proximity that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4097 1 would result in mutual heating where one cable is 2 causing elevated temperature on an adjacent cable, the 3 combined effects would be that it would be operating 4 above its intended operating limits.
5 And in my assessment or review of the 6 License Renewal Application and understanding and 7 admittedly a basic understanding of the way the cables 8 are installed, it appears that some of those 9 conditions might exist if the right conditions were 10 present.
11 And so I was seeking to have in the 12 License Renewal Application some evidence that, first 13 of all, the Applicant has considered those conditions 14 and dismissed them because there is evidence that 15 there is no issue specifically related to IP2 and IP3.
16 And I did not see that in any portion of what they had 17 submitted as part of their License Application Renewal 18 process.
19 JUDGE KENNEDY: Let me try to put it in my 20 words. Again, you used the term excessive heat, I 21 think, in your testimony. In your initial remarks 22 here, you are trying to clarify, I understand, what 23 you mean by excessive heat. So these are outside --
24 this is -- I heard you differentiating between design 25 conditions which would be like a normal operating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4098 1 parameter and then looking for situations within a 2 plant that could lead to elevated temperatures in the 3 vicinity of those cables, either due to close 4 proximity to other cables or some other heat source 5 that would lead to exposure of the external surface of 6 the cable to higher temperatures.
7 And again, you did differentiate between 8 the equipment qualification type case. You are not 9 looking at post-accident type conditions. You are 10 looking at something that occurs during normal 11 operating range?
12 MR. BASCOM: This is Mr. Bascom. Yes, the 13 basis is that when the cable system is designed for a 14 certain capacity of power transfer, there is either 15 measurements or design assumptions are incorporated 16 into the sizing of the cable and the number of cables 17 that would be installed in a particular area.
18 And there are generally constraints on how 19 well that information and be understood such that for 20 example if the cable is a cross-linked polyethylene or 21 an EPR insulated cable designed to operate at 90 22 degrees Celsius as a maximum conductor temperature and 23 it is operating at 100 or 105 degrees C -- Celsius, it 24 won't immediately fail under those conditions. But 25 over an extended period of time if that situation were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4099 1 to reoccur, there would be aging and degradation of 2 the performance of the cable that could lead to a 3 failure.
4 And I was seeking to have some 5 verification or description that that doesn't occur 6 specific to IP2 and IP3, recognizing that there are 7 some EPRI documents and other sources that have 8 indicated that that generally doesn't happen, but not 9 specific to IP2 and IP3.
10 JUDGE KENNEDY: I'm not sure whether to 11 start with you or maybe move to Entergy. Let's move 12 to Entergy.
13 I guess as I understand through your 14 testimony that there has been at least some 15 modifications to the License Renewal Application, 16 whether it was in direct response to the New York 17 State's contention or due to other measures. But in 18 regard to the issues that Mr. Bascom has just raised, 19 as Entergy modified their License Renewal Application 20 in any way? And I guess I am looking for instances 21 where the modification would have a bearing on this 22 contention.
23 And I don't know -- I'm looking down the 24 table and everybody else is looking down the table.
25 MR. COX: This is Alan Cox for Entergy and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4100 1 I will start with that. Roger, Mr. Rucker, may have 2 more to add but I am not aware of any changes that 3 were made specifically due to this concern. I believe 4 we have a program that has always -- specifically for 5 above-ground cables we have always had a program that 6 looks for these high temperature areas. And we have 7 not made any changes specifically to address this 8 concern.
9 JUDGE KENNEDY: So that was in the 10 original application then. Are you referring to the 11 cable connections --
12 MR. COX: Yes.
13 JUDGE KENNEDY: -- Aging Management 14 Program?
15 MR. COX: That is correct. It is actually 16 titled non-EQ insulated cables in connection with the 17 program.
18 JUDGE KENNEDY: And what section of the 19 LRA is that contained in?
20 MR. RUCKER: This is Roger Rucker for 21 Entergy. That is B.1.25. B.1.25? Okay. And that is 22 basically as we discussed earlier, that is the above 23 ground table. So if you look at that table, that 24 would be the last column.
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4101 1 those are addressed in that program for the below-2 grade cables, which is B.1.23. Heating is not 3 considered an aging effect requiring management.
4 JUDGE KENNEDY: Let me take it a piece at 5 a time. Mr. Bascom, did you get a chance to look at 6 the B.1.25, Aging Management Program, and did that 7 address any of the concerns you were trying to raise?
8 And if not, why not?
9 MR. BASCOM: This is Mr. Bascom. I did 10 review the B.1.25 and it did not address the thermal 11 aging issue as would apply to inaccessible portions of 12 the cable. It was essentially for above-ground cable 13 or where the connections are located, which I guess by 14 definition would be accessible locations.
15 JUDGE KENNEDY: And why doesn't it address 16 the inaccessible locations?
17 MR. BASCOM: This is Mr. Bascom. As far 18 as I can tell, it is just not in the scope because 19 inaccessible cables are below ground in conduits where 20 there is really no ability to reach the cables or 21 inspect them where their connections would be normally 22 where equipment is attached to the cables, you know, 23 motors, pumps, that type of equipment where an 24 inspection could be done.
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4102 1 Entergy again, and I don't know if Mr. Rucker is the 2 appropriate person but you pointed us to B.1.25 for a 3 reason here. Do you view that that particular Aging 4 Management Program addresses the issue that Mr. Bascom 5 has raised or am I over-characterizing?
6 MR. RUCKER: No, this is Roger Rucker.
7 That does address thermal. That is for 8 accessible/inaccessible cables. But as we discussed 9 earlier, when we talk about inaccessible in that 10 program, that is meaning the cables that are above 11 ground. So inaccessible would be cables in a conduit 12 or cables in a junction box and you can't assess the 13 environment around that area. And the program does 14 apply to that if you find an adverse environment.
15 For the underground cables, Mr. Bascom is 16 correct. You cannot assess the external environment.
17 That is why we test those cables.
18 JUDGE KENNEDY: So let's go back to the 19 B.1.25. It sounds to me that Mr. Rucker you have just 20 told us something that contradicts Mr. Bascom's 21 statement that you are actually managing the above-22 ground cables, the inaccessible and accessible 23 portions of the above-ground cable. Did I understand 24 your testimony to mean that?
25 MR. RUCKER: This is Roger Rucker. Yes, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4103 1 that is correct.
2 JUDGE KENNEDY: Mr. Bascom, did you see 3 something in this program that would lead you to 4 believe that that is not true?
5 MR. BASCOM: This is Mr. Bascom. As I 6 understand B.1.25, the inaccessible cables are cables, 7 for example, that would be in conduits but otherwise 8 not below ground. And the scope of the contention is 9 related to below-ground inaccessible cables. So I did 10 not see where extending what was in B.1.25 applied 11 directly to -- or it would really be B.1.23 that we 12 discussed earlier because those would be below-ground 13 cables.
14 JUDGE KENNEDY: So I guess maybe I 15 overstated your original concern. Did you not have a 16 concern about above-ground inaccessible cables exposed 17 to heat or did you?
18 MR. BASCOM: I had no basis to evaluate or 19 assume that there would be an issue with the above-20 ground cables that were inaccessible from that 21 standpoint.
22 JUDGE KENNEDY: So we are back to the 23 below-ground. So we are back to B.1.23 then. Is that 24 what you are saying? Okay.
25 So maybe back to Entergy. Why does NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4104 1 Entergy believe that this aging effect, or at least 2 potential impact on an aging effect doesn't need to be 3 managed for below-ground cables?
4 MR. MC CAFFREY: Okay, this is Tom 5 McCaffrey for Entergy.
6 The first thing I would like to make 7 everyone aware is that the plant was designed to take 8 these design thermal issues into account for only 9 heating of cables. In the FSAR, in both Unit 2 and 10 Unit 3 are references of an insulated cable engineer 11 standard for impacity, which is basically what Mr.
12 Bascom is talking about. You take credit for the soil 13 you are in, how many cables, how much load is in each 14 cable, how many cables you are running in a conduit.
15 That has all been accounted for in our design.
16 Our operating experience from the site 17 here is we have seen no degradation or failures on our 18 medium voltage cables or our underground cables due to 19 aging. We have had the three cable failures which we 20 mentioned in our testimony that were due to mechanical 21 issues.
22 In addition, we believe that the testing 23 we do of our cable program, of our underground cables, 24 via low voltage or medium voltage processes will 25 detect any signs of degradation due to aging from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4105 1 thermal elements.
2 I have reviewed all of the site drawings.
3 I do not see an external source of heat for the 4 underground cables. So the only potential source of 5 heat would be cables themselves. And again, that was 6 designed for in the original design of the plant.
7 JUDGE McDADE: How do you address the 8 possibility of hot spots in these underground cables?
9 MR. MC CAFFREY: Hot spots from where, 10 Your Honor?
11 JUDGE McDADE: Well I mean one of the 12 issues was raised had to do with methods to detect hot 13 spots on inaccessible cables at an early time before 14 cable insulation degradation occurs. Now, is there 15 any way to identify hot spots or to determine whether 16 or not they can have an impact on the degradation of 17 the cable?
18 MR. MC CAFFREY: Your Honor, I reviewed 19 all the site drawings. In my knowledge of the site, 20 there is no external sources that could create a hot 21 spot at the site.
22 JUDGE McDADE: Okay, Mr. Bascom, why is 23 this a concern?
24 MR. BASCOM: This is Mr. Bascom. In 25 addition to external sources of heating, all ohmic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4106 1 losses from the cables themselves can generate 2 elevated temperatures because the heat leaving the 3 cables passes through the thermal resistivity, thermal 4 resistance of the environment which the cables are 5 installed. And as far as I can tell, there was no 6 consideration for that in the License Renewal 7 Application.
8 In the cable reliability program that we 9 discussed earlier this morning focused strictly on 10 moistures but did not address thermal issues. And for 11 that reason I felt there was a deficiency in what was 12 being provided in the License Renewal Application as 13 regards to thermal issues.
14 JUDGE McDADE: Okay. For these 15 underground cables, how would you identify hot spots 16 and how would you manage them, Mr. Bascom?
17 MR. BASCOM: This is Mr. Bascom. There 18 are methods to identify hot spots. It is possible to 19 install what are called thermocouples, which are point 20 sensors that measure temperature. There is also the 21 ability to put in a fiber optic cable, non-conducting 22 cable that provides a distributed temperature sensing 23 profile along the length of the cable. So that would 24 give you a measurement approximately every three feet 25 along the length of the line. Conceptually, you could NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4107 1 have one of these fibers installed along the cables to 2 monitor for hot spots. And several utilities do do 3 that routinely.
4 JUDGE WARDWELL: And by utilities, do you 5 mean nuclear utilities or are these the other people 6 involved in the electrical industry?
7 MR. BASCOM: This is Mr. Bascom. Yes, 8 outside my experience with the nuclear industry. You 9 know, just the general utilities operating both 10 transmission and distribution cable systems.
11 JUDGE WARDWELL: And is it your testimony 12 that for their buried cables they do install either 13 the thermocouples or the second --
14 MR. BASCOM: This is Mr. Bascom. A 15 distributed temperature-sensing fiber optics.
16 JUDGE WARDWELL: Fiber optics. And that 17 is your testimony that they have done that?
18 MR. BASCOM: This is Mr. Bascom. Yes, 19 these systems are commercially available and are 20 installed for cable systems.
21 JUDGE WARDWELL: And do they do it for all 22 their cables at a given facility or is it just one?
23 MR. BASCOM: This is Mr. Bascom. No, it 24 is selective. So it is based upon critical need or 25 whether there is perceived problems. The technology NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4108 1 has been around for perhaps 15 or 20 years but is not 2 done extensively on every system. It is basically on 3 a select basis.
4 JUDGE WARDWELL: Mr. McCaffrey, what 5 knowledge do you have that in fact the design did 6 consider the resistance of the soil and potential heat 7 buildup from just the resistance and the buildup of 8 heat by being surrounded by soil or other materials 9 for the buried cables?
10 MR. MC CAFFREY: This is Tom McCaffrey for 11 Entergy. I reviewed a number of calculations that was 12 prepared for the design of the plant and they did 13 account for soil temperatures and impacity in 14 accordance with the cable standard I mentioned before 15 that was referenced in the UFSAR for both units.
16 JUDGE WARDWELL: And that calculation 17 includes the heat build-up associated with being 18 buried and surrounded by what other cables are there 19 and the insulation effect associated with the soil?
20 MR. MC CAFFREY: Yes, sir.
21 JUDGE WARDWELL: Thank you.
22 JUDGE McDADE: Okay, Mr. Bascom, just to 23 make sure that I understand the way you are describing 24 it, just describe what you mean by a hot spot and what 25 are the causes of hot spots and what are the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4109 1 implications of hot spots.
2 MR. BASCOM: Sure, this is Mr. Bascom. A 3 hot spot is a condition that results in an elevated 4 temperature along the line, along the cable circuit 5 that --
6 JUDGE McDADE: Are we talking about 7 elevated by a degree, by ten degrees? At what point 8 would it constitute, in your view, a hot spot?
9 MR. BASCOM: This is Mr. Bascom. Really 10 any elevation would be considered a hot spot. The 11 concern would be where the temperature is elevated to 12 the point where it would degradate the performance of 13 the insulation either because there is an external 14 temperature source, which I understand there is 15 testimony that says that there are none or that none 16 have been identified, but also from ohmic losses from 17 the cables themselves, which generate heat and that 18 heat then passes through the surrounding soil or the 19 environment in which the cables are installed.
20 Generally during the design of a cable 21 circuit, the samples of the soil are measured and 22 evaluated for their characteristics and an impacity 23 calculation is done to evaluate the variations along 24 the line. It is practical and it is usual during a 25 design to constrain the number of measurements that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4110 1 are performed. So there is often some uncertainty and 2 the assumptions are built into developing the impacity 3 ratings and sizing the cable.
4 I was seeking to get some evidence that 5 that had been evaluated and either summarily dismissed 6 or was an area that there is an ongoing assessment 7 that is factored into the Applicant's Aging Management 8 Plan.
9 The end of your question is what is the 10 impact on the cable if the cable experiences this 11 elevated temperature. It is a matter of degree.
12 Obviously, elevated temperature at the higher level 13 will further degrade the cable and ultimately we are 14 concerned about degrading the insulation material, 15 which would then prevent it from supporting its line 16 to ground both along the length of the line.
17 JUDGE McDADE: Okay. And how high would 18 these temperatures have to be to impact the viability 19 of the cable and how long would they have to be 20 maintained, in your view?
21 MR. BASCOM: This is Mr. Bascom. The 22 cable is designed for a normal continuous operation.
23 And with crossing polyethylene EPR cables that are 24 typically involved, it can be anywhere from 90 to 130 25 degrees Celsius is a normal operation. With paper NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4111 1 cables, I understand there are some paper lead cables 2 in the plant, it is typically 80 to 90 degrees 3 Celsius, depending on the design and the requirements 4 of the cable system.
5 So the elevated temperature can be five to 6 ten degrees or several tens of degrees above. And it 7 is a time temperature effect. So if the temperature 8 is elevated for a short period of time at a very high 9 temperature, the aging occurs quickly. And my view is 10 that since these cables have been in service for some 11 time, that type of condition probably would have 12 identified itself already by the presence of cable 13 failures.
14 The issue is that there may be some 15 elevated temperatures along the line that over an 16 extended period of time could be accelerating the 17 aging on the cable. And there should be some effort 18 to identify that those conditions are occurring or 19 identify that they are not occurring so that they know 20 there is not an aging management issue related to 21 those cables.
22 JUDGE McDADE: Okay, thank you.
23 JUDGE KENNEDY: Mr. Bascom, does the 24 increased testing frequency of the cables from 25 reducing it from ten years to six years help alleviate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4112 1 any of your concerns about this issue?
2 MR. BASCOM: This is Mr. Bascom.
3 Certainly shortening the testing interval will improve 4 the likelihood of identifying a problem. The testing 5 methods that have been suggested would likely detect 6 a degradation of the insulation after it has happened.
7 But there could be some effort to monitor the 8 temperature to identify hot spots prior to that 9 condition developing. And that was the basis for what 10 I was listing in the contention with regard to the 11 License Renewal Application.
12 JUDGE KENNEDY: Maybe turning back to 13 Entergy.
14 JUDGE WARDWELL: Could we just make stick 15 with this point right here?
16 JUDGE KENNEDY: Go ahead.
17 JUDGE WARDWELL: Mr. Bascom, would the 18 existing testing program do much to detect the gradual 19 degradation of the insulation to the point prior to 20 failure but just before it completely say loses its 21 integrity? Would you be able to pick that up in 22 trending the analysis from the tests, such that you 23 could predict impending failure, rather than just 24 failure?
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4113 1 to the thermal issues, it generally has to progress 2 for an extended period of time before the insulation 3 would degrade to the point that you detect it one of 4 these tests. Unlike, for example, water treeing, 5 where there are some methods that would detect a 6 degradation of the insulation that would give an 7 indication you have to do a management program to 8 replace the cable. And I think there are other tests 9 that could be done or an investigation that you could 10 evaluate the thermal hot spots. And certainly, as was 11 testified earlier, evaluating the installation 12 conditions and looking at drawings is part of that 13 assessment. But there are some actual tests that can 14 be done, as I described earlier.
15 JUDGE WARDWELL: How would that be done in 16 a retrofit situation such as we are facing here at the 17 plant?
18 MR. BASCOM: This is Mr. Bascom. It's an 19 excellent question.
20 Retrofitting can be done in existing 21 conduits, if there is a spare conduit. It can also be 22 done to a limited extent in occupied conduits.
23 JUDGE WARDWELL: In what?
24 MR. BASCOM: Occupied, where there is 25 already cables placed inside the conduit.
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4114 1 So it is possible to do it and it is 2 certainly when the cables are already present in the 3 conduit, it does complicate the process of performing 4 some of those tests. But on a limited basis, it could 5 be done just to do an evaluation to see if any 6 conditions do exist.
7 JUDGE WARDWELL: Thank you.
8 JUDGE KENNEDY: I'm just curious. From 9 Entergy's perspective is there something within the 10 plant environment that would detect not so much the 11 hot spots but any of the excessive heat-type 12 conditions in these cable routing areas? I mean, is 13 it part of a normal walk-down program?
14 I mean, is there is anything that would 15 evidence itself, other than just testing the cable 16 that an ohmic heating type situation was going on or 17 is it something that would be undetected until you had 18 some insulation issues?
19 MR. MC CAFFREY: This is Tom McCaffrey, 20 Entergy. I am going to ask the question back and see 21 if I understood the question.
22 Is there any methods or monitoring that 23 the site does for underground cables that can detect 24 an ohmic heating situation that could impact the cable 25 insulation?
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4115 1 JUDGE KENNEDY: Correct.
2 MR. MC CAFFREY: These are underground 3 cables. There is no visible means to detect any type 4 of ohmic heating due to mutual heating from cables.
5 If there was some new external event that would be 6 detected by our operator walk-arounds and our engineer 7 walk-arounds of the plant.
8 JUDGE KENNEDY: The first line of defense 9 sounds like it is handled through design, then, that 10 the design of the facility, the design of the cable 11 runs and so on is intended to minimize the potential 12 for any of this ohmic heating?
13 MR. MC CAFFREY: That is correct. That is 14 the first line defense. Our second would be our cable 15 reliability program.
16 JUDGE KENNEDY: And that is the testing 17 portion?
18 MR. MC CAFFREY: That is correct.
19 JUDGE KENNEDY: I don't know if -- I guess 20 what I am curious about is if you are aware is there 21 any operating history within first Indian Point and 22 then maybe second within the industry that indicates 23 that this is an industry issue or potential issue?
24 MR. MC CAFFREY: This is Tom McCaffrey, 25 Entergy. For Indian Point I know of no history of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4116 1 ohmic heating that has caused degradation of the 2 cables.
3 Dr. Sedding, from your industry 4 perspective?
5 DR. SEDDING: Howard Sedding for Entergy.
6 In the normal course of the business of my company, we 7 perform dissections and forensic analysis of cables 8 typical of those installed at Indian Point. And 9 basically over the dealings of my company, we are not 10 aware at present date of any failures that we have 11 observed due to excessive ohmic heating.
12 Ohmic heating will, as a natural 13 consequence, be present but we haven't seen any 14 failures that have resulted that we could detect by, 15 in some cases, what is left of the cable from ohmic 16 heating.
17 JUDGE KENNEDY: What about any enhanced 18 degradation that wasn't expected. I mean is there 19 evidence that this is a potential impact, even though 20 there hasn't been a failure? I mean if you are doing 21 a forensic on the insulation, have you seen any 22 evidence that maybe wouldn't be explainable by just 23 the normal operating ranges or conditions within the 24 cables?
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4117 1 in order to get this, I think -- I'm not trying to put 2 words in your mouth but I think maybe one of the 3 question you are asking here is are there methods, 4 chemical or forensic, for assessing whether maybe you 5 don't see excessive overheating but there is 6 overheating taking place.
7 JUDGE KENNEDY: Yes, I guess that is what 8 I am looking for. It would be in the context of you 9 don't expect it to be there, so it raises some 10 attention.
11 DR. SEDDING: Yes. One of the -- again, 12 this is Howard Sedding for Entergy.
13 One of the tests that can be used, and 14 this is after the cable has failed and has been 15 removed from the ground, one can probe the thermal 16 history of the cable insulation using techniques such 17 as thermogravimetric analysis or differential scanning 18 calorimetry which, to cut a long story short, were 19 built to tell you the ultimate temperature that that 20 cable insulation went to. And this is very applicable 21 in the case of a cross-linked polyethylene systems.
22 In the work that we have done I think 23 there has only been one or two cases where we have 24 seen evidence of overheating. And in that case we 25 didn't really need those sophisticated techniques NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4118 1 because the cross-link polyethylene was basically 2 almost burned black. But in that particular case, it 3 was an installation error caused by the single phasing 4 of a 13.8 kV cable that connected a generator output 5 breaker to the transformer. So this was a very rapid 6 failure.
7 Our experience when there are issues with 8 impacity that they are at least incorrectly designed 9 cable impacity in the utility that I worked for, which 10 was Ontario Hydro, is that the failures such as there 11 are due to those modes tend to be fairly rapid within 12 in some cases months of commencing operation.
13 JUDGE KENNEDY: Yes, I think that was 14 going to be part two of the question.
15 The evidence or the occurrence of ohmic 16 heating, I am assuming that most of this cabling has 17 been installed since the plant was first constructed, 18 if it doesn't evidence itself in the first number of 19 years, is it a potential that it could evidence itself 20 later on? Or is there some condition that could 21 exacerbate a condition that didn't exist during a 22 number of years and then all of a sudden it is a real 23 possibility?
24 DR. SEDDING: Typically those situations 25 may occur for one, say for example, increases for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4119 1 various reasons decides to run more current through 2 the cable. However, my experience of utilities is 3 that once the plant is designed, it operates as per 4 the design and this is even more so in the nuclear 5 industry, which is so heavily regulated.
6 So to answer your question, if you 7 increased the amount of current you are pumping 8 through that cable, yes. But then as a normal 9 consequence of that consideration, one would redo the 10 calculations that Mr. McCaffrey referred to, which is 11 the basic design impacity calculations, since to me I 12 still look at this issue as more of a design issue, 13 rather than an aging management issue.
14 JUDGE WARDWELL: Dr. Sedding, to piggyback 15 on that a little bit, have you ever been involved or 16 looked at a situation where the temperatures were just 17 elevated a bit above the normal design operating 18 temperatures but have been there consistently for a 19 very long while and then now it is proposed to be 20 there for an addition a long while such that it was a 21 gradual degradation of the insulation that occurred, 22 or embrittlement, or whatever else occurs from this 23 elevated temperature until finally the integrity of 24 that insulation no longer exists and there is a 25 problem? Have you ever investigated and looked at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4120 1 something like that? And what is your experience with 2 being able to detect such a potential situation like 3 that, if they are inaccessible?
4 DR. SEDDING: Well, Your Honors, Howard 5 Sedding once again for Entergy, I think the simple 6 answer to your question is no. I haven't --
7 JUDGE WARDWELL: You are one of the 8 persons that has ever answered my question directly 9 right off the bat and I appreciate that.
10 DR. SEDDING: I'm now going to -- I will 11 be batting for a thousand now because my addendum to 12 that answer is that if I was ever in a situation where 13 -- because effectively what we are seeing here is that 14 I am aware of a deficient system. So we are basically 15 operating a cable beyond its design capability because 16 I think that is the logical conclusion of sort of your 17 question of do I have experience of essentially 18 operating a cable above its designed operating 19 characteristics.
20 The answer to that is really if I was 21 faced with that situation, I would probably not take 22 too much further part, unless it was a situation in 23 which -- because sometimes utilities have to basically 24 make it either to the next outage or when it is 25 convenient to take an outage. So therefore, there is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4121 1 dispositions that have to be written. But the basic 2 answer to your question is no because I would probably 3 not get involved in a situation where I am being asked 4 to operate or give recommendations to operate a cable 5 above its design criteria.
6 JUDGE WARDWELL: A cable has a certain 7 design temperature, correct, operating temperature?
8 DR. SEDDING: Correct, as Mr. Bascom 9 pointed out.
10 JUDGE WARDWELL: Does that mean that that 11 cable could be operated at that temperature forever?
12 DR. SEDDING: I think --
13 JUDGE WARDWELL: Or do they put a time 14 limit on it or is there an implied time limit?
15 DR. SEDDING: And this gets into a sort of 16 interesting area, sort of -- once again this is Howard 17 Sedding for Entergy.
18 With respect to the concept of operating 19 forever, the only cables in a nuclear power plant that 20 have a so-called qualified life are those that have 21 been through an Environmental Qualification or EQ 22 Program. So that is where the concept of finite 23 lifetimes kind of begins and ends.
24 So therefore, for EQ applications you will 25 have perhaps, depending upon the test results, 40, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4122 1 maybe 60 years of qualified life and that is one of 2 the design bases of the plan.
3 With respect to the concept of operating 4 a cable forever based upon the knowledge of what 5 temperature you are operating that cable at, I mean 6 forever is a long time. But cable insulation, in fact 7 most electrical, in fact all electrical insulation 8 systems are thermally classified according to 9 essentially a process in which you do multiple agings 10 of cable insulation in ovens and you are looking at a 11 performance of those cables and this is all based upon 12 concepts like the Arrhenius Equation. And this is 13 where this concept of the Arrhenius Equation gives us 14 this idea of -- which is a chemical rate equation --
15 gives us a concept as a rule of thumb for every 16 approximately ten degrees Celsius that you operate an 17 insulation system above its thermal classification, 18 you are halving the life.
19 JUDGE WARDWELL: I'm sorry?
20 DR. SEDDING: You are cutting the life of 21 that insulation system in half.
22 So on the basis of most insulation systems 23 I have ever dealt with tend to actually operate in 24 very quite benign environments well below these 90 25 Celsius, 105 Celsius nominal conductor ratings that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4123 1 XLPE and EPR respectively have, they would go on for 2 a practical point of view, if forever is a lifetime of 3 that generating station, that is the answer.
4 JUDGE WARDWELL: And Mr. McCaffrey, your 5 design calculations, did you do them yourself or did 6 you just review the design calculations that were 7 performed?
8 MR. MC CAFFREY: I just reviewed them, 9 Your Honor.
10 JUDGE WARDWELL: And did you extend yours 11 through the period of extended operation when you did 12 your calculations? Are they time-related 13 calculations?
14 MR. MC CAFFREY: They are not 15 Environmentally Qualified cables. They are the other 16 cables that Dr. Sedding talked about. So they did an 17 impacity calc when the plant was designed to say they 18 can handle that impacity at a certain cable 19 temperature.
20 JUDGE WARDWELL: And so there is not a 21 time element associated with your calculations.
22 MR. MC CAFFREY: That's correct.
23 JUDGE WARDWELL: And that is what I am 24 driving at because it seems to me logical, in my mind, 25 that there is a potential for a cable's insulation to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4124 1 age, become more brittle, et cetera. I don't know 2 where I have experienced it but I remember seeing it.
3 I do a fair amount of remodeling of old homes and I 4 pull out old cables and maybe that is when I saw, for 5 instance, some of these when I started pulling on 6 them, the insulation actually cracked and fell off.
7 That is not to rate some of my homes with a nuclear 8 power plant, certainly. Especially if I was involved 9 with the initial design, you want to leery of this 10 problem.
11 But what I am trying to get a handle on is 12 can we somehow get our arms around this time effect 13 and what it may be doing to gradually impacting these 14 cables? And I am not sure your calculation is the one 15 I want to know. Because you know, a cable cannot, can 16 it maintain under even its operating temperature 17 forever without potentially degrading the insulation, 18 it seems to me. So that is the background of what my 19 thinking is here.
20 So I will go back to the testing. The 21 tests that you perform, are they successful in 22 detecting impending failure or are they really only 23 successful for detecting the failure of the cable?
24 DR. SEDDING: Howard Sedding for --
25 JUDGE WARDWELL: I was talking -- let me NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4125 1 finish with Mr. McCaffrey.
2 DR. SEDDING: I apologize.
3 MR. MC CAFFREY: Then if you want to 4 comment, that will be fine.
5 MR. MC CAFFREY: The testing we do is able 6 to detect degradation of cable before it fails.
7 Just to make sure I characterize it, you 8 know my experience I have worked for Con Edison 9 utility in New York City --
10 JUDGE WARDWELL: Before you get to that, 11 can I just fix a point because I am going to forget.
12 And don't you forget what you want to say right now.
13 You say it is able to detect prior to 14 failure. Quite a distance between failure where you 15 can start to see a little bit of degradation and more 16 and more and more and then finally failure or is it 17 just prior to failure that you are able to detect it?
18 MR. MC CAFFREY: I am going -- Dr. Sedding 19 has a little more experience in that aspect.
20 JUDGE WARDWELL: Okay, then wait on that 21 and we can --
22 MR. MC CAFFREY: We can answer that now.
23 JUDGE WARDWELL: I'm not interrupting your 24 flow of thought, am I?
25 MR. MC CAFFREY: Gosh, no.
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4126 1 JUDGE WARDWELL: Now do I still have any 2 left over questions for you? I am going to get to the 3 gradual aging with Dr. Sedding when I go with him.
4 What was the last question I asked you?
5 Let me see where I am at with this.
6 MR. MC CAFFREY: I was going to respond 7 that my experience, I have worked for a utility in New 8 York City, Con Edison, and I have pulled cable out 9 that is close to -- it was installed in 1908 and it 10 was perfectly satisfactory in its insulation and 11 design.
12 So there is experience with the type of 13 cables we have that they can work perfectly fine for 14 years if properly designed and installed in the proper 15 location. So if we did our initial design correctly, 16 which I believe we did, there is no ohmic heating 17 issues that are going to drive aging of our cables.
18 And I mentioned before the program we have 19 will detect any signs of insulation degradation, which 20 if we did some design issue wrong or something 21 happened over time, that is going to be picked up.
22 The question of how soon it is going to be picked up, 23 I think Dr. Sedding might have a better perspective on 24 how soon did tan delta testing, for example, could 25 pick up a degradation before a failure but it will NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4127 1 pick it up before.
2 JUDGE WARDWELL: And after you answer that 3 question, then just go right on to whatever else you 4 were wanting to comment on the others if there was 5 something.
6 JUDGE McDADE: And also, Dr. Sedding, if 7 you could explain to me how it picks it up, how it 8 picks up the degradation prior to failure.
9 JUDGE WARDWELL: Because he is an 10 electrical engineer and will want to know that.
11 DR. SEDDING: Your Honor, Howard Sedding 12 for Entergy. I think I would like to make one comment 13 with respect to what these tests actually do and the 14 mode in which most utilities and service providers use 15 them.
16 The most effective deployment of these 17 diagnostic tests is in the trending mode, which is 18 something that is recognized by in all the documents 19 I have seen.
20 JUDGE WARDWELL: I'm sorry. In what kind 21 of mode?
22 DR. SEDDING: A trending mode.
23 JUDGE WARDWELL: A trending mode.
24 DR. SEDDING: It is therefore basically 25 one performs a test at time equals zero and so on.
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4128 1 And basically, if you are doing a test which is 2 trendable, which is one of the criteria in the GALL 3 Reports, which is looked for, then over time you can 4 see this trend of deterioration.
5 So in my experience, there has been very 6 few cases in which if we have been testing and we test 7 -- I get to test anything that has an electrical 8 insulating function, be it cables, switch gear, 9 rotating machines. There is actually no -- there is 10 not this concept that we are doing a test and then we 11 get to one month or one week before it is going to 12 fail and we see that the light goes on. It tends to 13 be -- what we are trying to do in the utility industry 14 is use these tests largely to direct appropriate 15 maintenance. So in other words, you are trying to not 16 do maintenance that is not necessary but you are also 17 trying to focus on the maintenance that is for both 18 economic and safety requirements.
19 So when we do testing, we are looking --
20 we are basically doing -- there is an insulation 21 resistance test or the VLF/tan delta test or partial 22 discharge test. By and large we are looking for a 23 trend because electrical insulation systems are not 24 the nice -- it would be much easier for us to deal in 25 metals because metals have largely close form NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4129 1 solutions in terms of there is analytical equations 2 for metallic systems where you can tell if you bend a 3 thing so many times it is going to fail. Electrical 4 insulation, unfortunately, doesn't work that way. And 5 also it doesn't work that way because in most cases 6 one is dealing with not one pure system but you are 7 dealing with a polymer.
8 So for an example, an electrical ethylene 9 propylene rubber insulation EPR can have multiple 10 components. It is a real mess. It has got the basic 11 ethylene propylene rubber. It has got fillers. And 12 you have to, when you are doing your test, you have to 13 actually interpret what all of this means.
14 So in terms of the testing that is being 15 performed at Indian Point which for the low voltage 16 cables, and these are cables that are 600 volts and 17 below the 480 volt systems, the basic test in 18 insulation resistance. In the case of the medium 19 voltage cable systems, you are using VLF/tan delta.
20 And both of these are recognized as being 21 means, as appropriate means of detecting moisture 22 intrusion and, to a certain extent, thermal 23 deterioration.
24 JUDGE WARDWELL: And would you -- I 25 understand that there is some trending available. Are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4130 1 you comfortable with that six-year period in regards 2 to the time frame between inspections being able to 3 pick it up not a month or a year before but in fact we 4 would want to be able to pick it up certainly sooner 5 than six years and preferably closer to 12, so that we 6 could trend it and then prepare for that either by 7 increasing the inspections or knowing that something 8 is taking place. Is that six-year period sufficient 9 or could in fact we test it once and then five years 10 later not be picking up the trends that would lead to 11 a failure at that point?
12 DR. SEDDING: Howard Sedding for Entergy 13 again. With respect to the -- I think there was a 14 discussion previously in this hearing about the 15 frequency of testing. The frequency of six years is 16 informed largely by industry experience because the 17 six years comes amid the NRC guidance basically comes 18 also from an analysis of industry and peer review 19 documents.
20 Also within the experience that I have 21 working for the utility that I did for many years, we 22 found that if you tested every six months, every six 23 years, it really didn't make a lot of difference, as 24 far as we could see, with respect to the reliability 25 of the equipment. Because insulation systems tend to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4131 1 deteriorate at a relatively glacial pace, unless you 2 have some poor insulation or some other event that 3 occurs, some external event, such as a transient or a 4 dig-in, or some other like a tsunami sweeping over the 5 walls of Fukushima.
6 So therefore, there is always a debate 7 going on about what is the most appropriate frequency 8 of testing. But in my view, the six-year interval is 9 not out with industry experience in what is 10 reasonable.
11 JUDGE WARDWELL: So it is your expert 12 testimony that if in fact the hypothesis I raised, 13 that is this gradual degradation due to a slightly 14 elevated temperature above the operating design of the 15 cable for long periods of time would be able to be 16 picked up well before failure with a six-year 17 interval?
18 DR. SEDDING: I think my answer to that 19 question is that if you are slightly above the -- well 20 first of all, --
21 JUDGE WARDWELL: And by slightly I mean I 22 want to make sure it is not this huge amount that is 23 above there.
24 DR. SEDDING: I think I will qualify this 25 response by saying that again that the design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4132 1 assumptions in all utilities, not just nuclear 2 utilities are very conservative. So therefore, the 3 probability of any cable system or the conductor of 4 temperature being at or close to the maximum operating 5 temperatures defined by the manufacturers by the 6 standards is extremely small.
7 The design criteria, by and large in all 8 cases, seek to make sure that in fact in normal 9 operation over the periods that that cable is going to 10 be in operation will be well below the maximum 11 operating temperature.
12 So in terms of if I am slightly above, to 13 your definition, sir, of the normal operating 14 temperature, I am still well below the performance 15 characteristics of that cable insulation system.
16 Therefore, I wouldn't expect to see much in the way of 17 a change in the response of whatever diagnostic 18 parameter I was looking at. I have not seen that 19 because there is in fact no damage being inflicted on 20 the cable insulation system.
21 JUDGE WARDWELL: Yes, and I understand you 22 may not have seen it but I still -- in your 23 professional opinion, if it was above the design 24 operating temperature, even to reach the performance 25 operation or halfway to it, let's say, for a long NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4133 1 period of time, is it your opinion that you using a 2 six-year interval will be able to detect that 3 potential degradation well before failure of the 4 insulation?
5 DR. SEDDING: Howard Sedding again for 6 Entergy. I think the -- because I don't want to 7 conjecture --
8 JUDGE WARDWELL: I'm sorry?
9 DR. SEDDING: I don't want to conjecture.
10 I don't want to.
11 In terms of the materials that I normally 12 deal with are very robust. So therefore, if you are 13 overheating insulation -- I'm trying to think of a way 14 of phrasing this properly.
15 JUDGE WARDWELL: Are you just trying to 16 dodge the -- my request is in your expert opinion on 17 whether or not -- and you are here as an expert, 18 correct?
19 DR. SEDDING: Yes.
20 JUDGE WARDWELL: And I just wondered --
21 and if you don't have an opinion and you don't want to 22 give one, you don't have to. But I just wondered in 23 your expert opinion, would you be able to say that you 24 believe that these low and medium voltage cables, non-25 E qualified inaccessible ones that are being monitored NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4134 1 with Entergy's proposed program pick up the 2 incremental degradation of the cable insulation using 3 a six-year interval? And if you can't that is fine.
4 DR. SEDDING: Okay.
5 MR. FAGG: I'm sorry to interrupt. This 6 is Brad Fagg. And I apologize, Your Honor, but I 7 think the last question included above design basis, 8 as I heard it. And your repeat of the question 9 didn't. And I apologize if I gobbled that but I just 10 want to make sure the record is clear.
11 JUDGE WARDWELL: I'm sorry. What did you 12 --
13 MR. FAGG: I think the question the first 14 time you posed it, Your Honor, you used the phrase, 15 and I wrote it down, above design -- above design 16 basis, but I didn't hear that in the repeat of the 17 question.
18 JUDGE WARDWELL: Okay, yes -- and it is 19 elevated above the design basis.
20 DR. SEDDING: Well I think the answer to 21 this question actually comes down to the criteria that 22 are being used to make the assessment. So there is 23 sort of two answers to this. One is could I guarantee 24 that I would be able to see that form of degradation 25 with the measurements. I cannot guarantee that.
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4135 1 JUDGE WARDWELL: I don't want you to 2 guarantee it. I just want your opinion.
3 DR. SEDDING: So the answer is no.
4 However, in common with most utilities, Entergy does 5 in fact establish criteria which are contained in 6 their Cable Aging Management Program and it is 7 basically what has been established there is that if 8 you are above this level say for example of insulation 9 resistance, you are safe to operate. If you are below 10 it, you are no longer. So therefore, on the basis it 11 is still insulation deterioration mechanisms tend to 12 be relatively slow, then once you fall below that 13 criterion, then that is when it will trigger an 14 action.
15 JUDGE McDADE: Okay. If I could, we were 16 talking about elevated above design basis. I believe 17 earlier you indicated that about ten degrees Celsius 18 above design basis would cut the expected life in 19 half, if it were operating at ten degrees Celsius 20 above design for an extended period of time, would the 21 utility know that? Would there be any way of 22 identifying that that existed in-between these tests 23 at a six-year interval?
24 MR. MC CAFFREY: Your Honor, this is Tom 25 McCaffrey for Entergy.
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4136 1 There is no, as Mr. Bascom described, a 2 thermal temperature measurements installed in the 3 conduits or in the duct bank systems. So there would 4 be no way for us to determine if there was an actual 5 ten degree increase in temperature, as you suggested.
6 But I again go back to that if the plant 7 was designed in accordance with the cable standard, 8 then we would not design the plant in that fashion.
9 As Dr. Sedding said, if we made any modifications to 10 the facility, we go back and redo those calculations 11 to verify they are not invalidating my temperature 12 requirements for my cable.
13 So I have a hard time coming up with a 14 postulated theory of how I would all of a sudden get 15 to a situation where my cables would be running ten 16 degrees hotter than the design of the plant because 17 again, there is no external heat source and I designed 18 the cables in accordance with the cable standards.
19 JUDGE McDADE: Okay. And on the 20 insulation testing, resistance testing that you do, is 21 there a way to determine whether or not any 22 degradation is the result of moisture intrusion as 23 opposed to heat degradation?
24 DR. SEDDING: Your Honor, Howard Sedding 25 for Entergy. The simple answer is no. And it is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4137 1 basically all the testing that is done because you set 2 criteria. What you are looking at is a failure to 3 meet those criteria, which would then trigger an 4 action to go and understand and investigate why that 5 is the case.
6 MR. MC CAFFREY: So this is Tom McCaffrey, 7 just to clarify what Dr. Sedding said. So if he found 8 a below acceptance criteria cable, we are going to 9 enter in a Corrective Action Program, as we talked 10 before, and we are going to have to do some 11 investigation why that occurred, you know, we 12 mentioned before we might do increased testing. If it 13 was at such a level, we might take apart that cable to 14 understand what was driving that condition. And as I 15 think we discussed before about a corrective action 16 process, that would be part of our evaluation.
17 JUDGE McDADE: Okay, thank you.
18 JUDGE WARDWELL: Mr. McCaffrey, what is 19 your experience with testing these cables and trending 20 the data from the test of these cables -- inaccessible 21 cables?
22 MR. MC CAFFREY: We have a fairly good 23 experience with the low voltage cables. We have done 24 a number of years of insulation resistance testing of 25 that cable. We recently started the tan/delta NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4138 1 testing. We have had some good success with that 2 cable. I don't have a lot of experience with 3 tan/delta because it is a new process for us.
4 JUDGE WARDWELL: And in the earlier ones 5 when you said we, you have been involved with that and 6 have been reviewing the results and are familiar with 7 that?
8 MR. MC CAFFREY: Yes.
9 JUDGE WARDWELL: Based on your experience, 10 would you be able to state your professional opinion 11 on whether or not if these cables were operated above 12 their design temperature for a long period of time, 13 would you be able to pick up incremental degradation 14 of this using a six-year period to then use that data 15 to project when the cable might in fact fail?
16 MR. MC CAFFREY: Again, this is Tom 17 McCaffrey for Entergy.
18 I believe that with the acceptance 19 criteria we have spelled out and the trending we will 20 do, we will be able to detect and determine when those 21 cables would fail prior to their failure, based upon 22 our test data.
23 JUDGE WARDWELL: Thank you.
24 JUDGE McDADE: Mr. Bascom, as I understood 25 the testimony from Entergy that this is a design, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4139 1 rather than an aging management issue, that if the 2 design were defective, if these cables were going to 3 be carrying a significant load above what was 4 anticipated, they would expect the failure very early 5 in the system, that here we are almost 40 years into 6 the system, why would you be concerned that heat 7 degradation at this point that hadn't shown as a 8 design defect would impact as an aging management 9 issue?
10 MR. BASCOM: This is Mr. Bascom. As some 11 of the testimony that was offered this morning 12 suggested, if for example a paper insulated cable was 13 operated at eight to ten degrees C above its rated 14 temperature, which may be 85 degrees Celsius, the life 15 would be cut in half. And since this plant has been 16 in operation for 20 years, it is conceivable that over 17 that time the cable may have accelerated its aging, 18 instead of lasting for 40 years as an anticipated 19 design life, that life might have been reduced.
20 And what I was seeking to have in the 21 License Renewal Application is some evidence that the 22 Applicant had gone to the extent of evaluating if that 23 condition may have occurred or used a method where 24 they could evaluate or measure that that elevated 25 temperature condition may have happened.
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4140 1 So as Entergy had testified, if the 2 temperature was above rated temperature, there may 3 have been no significant degradation that would be 4 observed by any of the testing that has been done, 5 recognizing that they are just now starting their 6 testing program, or least that is the way I understand 7 it. And that with another 20 years of operation of 8 the plant, that potentially we could be beyond the 9 design life of the cable system.
10 JUDGE McDADE: But wouldn't the insulation 11 resistance testing pick up that kind of slow 12 degradation well in advance of failure?
13 MR. BASCOM: This is Mr. Bascom. It may.
14 I cannot say conclusively that it would or would not 15 but there are other tests or evaluations I think that 16 could be done. For example, and this is deviating 17 from what the contention is about, but for accessible 18 terminals on cables, they might do a thermographic 19 image to look for hot spots. And there is some 20 evidence that they would try to do that if there is a 21 hot location where a connection is made between an 22 accessible cable or an inaccessible cable but in an 23 accessible location.
24 A similar level of attention, I think, 25 would be worthwhile for an underground cable that is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4141 1 inaccessible to also evaluate that there are no hot 2 spots or at least review loading that may have changed 3 over the life of the system that might increase ohmic 4 losses or additional cables being installed in 5 parallel that provide mutual heating that could 6 contribute to elevated temperature.
7 JUDGE McDADE: But this thermal imaging 8 wouldn't be possible for the underground cables, would 9 it?
10 MR. BASCOM: This is Mr. Bascom. No, that 11 is correct. Thermal imaging or thermographic imaging 12 is for an accessible location but I was drawing an 13 analogy that for example a thermocouple or distributed 14 temperature sensing which can be used in inaccessible 15 locations would be methods and means that could be 16 used to evaluate the temperature of inaccessible 17 locations, just indicating that there are technologies 18 available that could be applied. And if the Applicant 19 is confident that there is no issue related to those 20 conditions, perhaps by the fact that there is a 21 significant factor in the way that load is carried on 22 the cables or the design of the cables or that there 23 is no mutual heating conditions that that issue 24 doesn't occur. But it just seemed relevant that with 25 these cables installed and potentially the life of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4142 1 them might be exceeded for another 20 years of 2 operation, that some part of the Aging Management Plan 3 might address the thermal issues, as well as the other 4 issues that we have talked about with moisture and so 5 forth this morning.
6 JUDGE McDADE: Dr. Sedding, why does that 7 not concern you as well, given that the period of 8 time, slow degradation over that 40-year period?
9 DR. SEDDING: Your Honor, Howard Sedding 10 here for Entergy.
11 I see the experience of the industry 12 informs that cables that are operating below these 13 excessive temperatures tend to stay in the ground 14 operating successfully for many decades.
15 For example, in the case of PILC, which is 16 paper-insulated lead-covered cables, these are 17 actually very robust cables which have been with us 18 sitting in the ground in our cities for something 19 close on a hundred years. And there are documented 20 studies in which cables have been removed after 70 21 years of service, PILC cables specifically, and 22 analyzed to determine their integrity after that kind 23 of period of time. And this is in fact, and it 24 escapes me right now which is the Entergy exhibit, a 25 paper by Carlos Katz, et al. It is Entergy 000246, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4143 1 which basically did a very careful analysis of these 2 types of cables.
3 So in the case of PILC cables, they are 4 reliable. The specifications for other cable systems, 5 there is no reason to believe that if a cable operates 6 at its own temperature, which again are well below the 7 maximum operating temperatures, that these cables 8 should not successfully, with respect to thermal 9 issues, stay in operation for the -- into the period 10 of operation.
11 I should also add though that the premise 12 here is not the expectation that we have to live with 13 these cables in the plant until the end of the period 14 of extended operation because that is the purpose of 15 testing. The purpose of testing is to continually 16 improve the integrity of these insulation systems of 17 which one of the corrective actions in the case of a 18 failure to meet a test can include up to cable 19 replacement.
20 JUDGE McDADE: Okay. Then if we had a 21 situation where the design temperature for a long 22 period of time was only slightly above, and say with 23 the paper lead I believe you indicated 80 to 90 24 degrees Celsius would be the design temperature, if it 25 operated for a significant period of time at say 91 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4144 1 degrees Celsius, is it your view that the insulation 2 resistance testing that is mandated would pick up any 3 degradation in the insulation, whether it be heat 4 generated or, as the result of moisture intrusion, 5 prior to the time of failure so that appropriate 6 corrective action could be taken?
7 DR. SEDDING: Howard Sedding here for 8 Entergy once again, Your Honor.
9 With all due respect, sir, I hesitate to 10 get into speculative or hypothetical because when I 11 test a cable I don't actually have -- in many cases 12 the class of cables that I am testing, I don't have a 13 lot of operating history. So in other words, what I 14 know typically is the cable design, the cable 15 insulation material, and basically when it was put in 16 service, and some nominal almost no point parameters 17 such as voltage class of cable, the conductor size 18 which determines the current rating. So to speculate 19 on if I have tested a cable -- for me to speculate on 20 whether I tested a cable that has been operating just 21 above its normal operating temperature is a little bit 22 of a stretch for me.
23 However, I would say that if you were 24 looking at the case of, as you mentioned, a PILC 25 cable, then in principle the measurements are being NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4145 1 done, such as VLF/tan delta, would probably indicate 2 -- I shouldn't say that. I am going to rephrase this 3 -- would have the probability of determining --
4 telling me if there was a deterioration mechanism in 5 process. It is not telling me specifically that it is 6 due to this being five or six degrees above the normal 7 operating temperature. It is telling me that there is 8 a problem.
9 Because in my earlier response to one of 10 your questions, sir, I think I said that there is no 11 way a terminal test can determine whether it was -- if 12 they were to meet the test criterion is due to 13 moisture, thermal problems, or in fact some of the 14 other problems which are inherent in cable insulation 15 systems. What we are saying is that we are making a 16 determination that something should be done. Further 17 investigation is required.
18 I hope that responds to your question.
19 JUDGE McDADE: Yes, thank you.
20 JUDGE KENNEDY: And moving in a slightly 21 different direction, I heard Mr. Bascom introduce the 22 potential for these cables to operate at an increased 23 load. I wonder if Entergy could at least discuss with 24 us the likelihood would be a real situation or a real 25 scenario and whether that is of a concern to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4146 1 management of these cables.
2 MR. MC CAFFREY: This is Tom McCaffrey for 3 Entergy. If we were to change to facility -- I will 4 give you an example. We talked about the service 5 water pumps. If were to change to a different service 6 water pump that had a higher capacity, needed more 7 amperage, that would require us to do a modification.
8 We would evaluate the change of that loading on the 9 cable and cable system to verify that it would still 10 would meet the original design requirements. And that 11 would take place in our modification change process.
12 JUDGE KENNEDY: And if it didn't meet the 13 original design modifications?
14 MR. MC CAFFREY: That would require a 15 change to the cable size, rerouting the cable. I 16 would do something to meet the original design 17 requirements. I would not just operate the cable at 18 a permanent type of design for the facility where all 19 of a sudden I would now operate a cable ten degrees 20 hotter because that is what we are doing. We would 21 make a modification in the facility to be able to 22 bring it back in accordance with the design.
23 JUDGE KENNEDY: Thank you. I am just 24 curious. We haven't heard from the Staff and we 25 waiting. They are patiently sitting there. I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4147 1 there is some discussion in your testimony that the 2 NRC research doesn't indicate that this is 3 particularly a problem for nuclear power plants but 4 maybe if you could elaborate on that and I can give 5 you the cite in your testimony, if that is useful.
6 But maybe discuss both your views on whether you view 7 this as a problem and then we would like to follow up 8 with some discussion of you have heard today that the 9 Aging Management Program would be able to detect 10 degradation in the insulation and get your views on 11 that as well, either one of you.
12 MR. NGUYEN: First of all the XI.E1, Mr.
13 Bascom were correct. It is not detect excessive heat 14 in a certain location. That is only above the ground 15 near the heat source. That type of point that Mr.
16 Bascom bring up to discuss today, first of all he have 17 a concern about ohmic heating.
18 When the cable have a current go to the 19 conductor, the ohmic heating will be I squared times 20 R. I is the current and R is the resistance. But 21 ohmic heating is also a concern during the design of 22 the cable. If you design the cable correctly, we talk 23 about the impacity. Impacity is the capacity of the 24 cable to carry the current. That will result in the 25 cable operate below the rated temperature. If you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4148 1 design correctly, the cable should not have any ohmic 2 heating.
3 Let me give you an example. In order to 4 decide a cable site, we have to look at the base 5 impacity equal to the full load current and then we 6 multiply by 1.25 percent we call the safety factor to 7 account for the current change during the voltage 8 fluctuation. If the voltage go down, we can have 9 potential current to go.
10 So the impacity will calculate when we 11 design the plant and Your Honor, here we are not 12 questioning the current design basics. We are here to 13 testify to the aging effect of the inaccessible 14 voltage cable.
15 So if you design correctly, the impacity 16 of the cables will be calculated such that the cable 17 will never exceed the rated temperature. After you 18 come up with base capacity, then you have to take into 19 account how many cables are inside a conduit and the 20 ambient temperature we call the impacity corrective 21 factor. That is explained clearly in the Sandia 22 Report New York Exhibit 000156B, page 4.9. That maybe 23 will help the Board to understand how the design when 24 the plant was originally licensed. And the Staff 25 reviewed the design when we give them license. So the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4149 1 design has not been changed.
2 That if we talk about overheating so 3 overheat is not -- if it is the designed correctly, is 4 not should be any aging effect for inaccessible cable.
5 If Mr. Bascom alerts that the design is 6 not correctly, we can handle under Part 50, under 7 Petition 2.206 we have regulation to handle that. But 8 here we don't question the current licensing basis.
9 Secondly, Mr. Bascom mentioned about the 10 external source.
11 JUDGE McDADE: I'm sorry. Could you 12 repeat that?
13 MR. NGUYEN: Yes. First I address about 14 overheating. Second, I go to --
15 JUDGE McDADE: No, no. I just didn't 16 understand the last word you said, sir.
17 Mr. Bascom discussed --
18 MR. NGUYEN: Yes, the second that he 19 mentioned about the ambient temperature around the 20 cable due to external heat source. And I want to 21 address this point that he bring for the Board to 22 understand.
23 The ohmic heating if that happen, it will 24 happen the whole length of the cable, not localized.
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4150 1 source. And the heat source is only when we are 2 concerned about the XI.E1 localized hot spot. We talk 3 about near a steam line, near the pressurized -- that 4 we talked about. And that indication will be 5 embrittlement melting. So in the accessible location, 6 we are not expect this cable installed near the steam 7 line, not located in the main steam isolation valve, 8 not expect to near the external heat source.
9 Third, he mentioned about a mutual heating 10 due to cable, multiple cable together. And I 11 explained when you design the cable conduit loading, 12 you can see how many cable go together, location, 13 geometry of the cable. You design that in order to 14 calculate impacity and you choose the correct cable 15 size.
16 The other thing I want to point out, even 17 if designed for full load current, the load will not 18 operate at the full current, maybe 50 percent, 20 19 percent, 30 percent. And some of the cable even isn't 20 energized. So we have a lot of conservative to build 21 in the cable site. And as I mentioned, if they change 22 the loading, then they have to go back to design 23 calculation to see at this time a cable can handle the 24 impacity or not. If it is, they have to change the 25 design. That is considered in the design.
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4151 1 Secondly, I want to point out that during 2 the license renewal research and I can send you a 3 report either one of example, we look at all the aging 4 effects possible that can happen in a nuclear power 5 plant. We account for **12:23:22** XI.E1. We account 6 for the moisture intrusion, water tree aging effect, 7 XI.E3. We account for cable connection, metallic 8 cable connection loosening, due to different thermal 9 coefficient but we account for it. But our research 10 did not identify the localized hot spot applicable in 11 inaccessible cable.
12 Secondly, and you hear the testify from 13 Entergy the testing methods that they propose will 14 detect the aging effect due to heating because of 15 reduced insulation resistance will be picked up by the 16 testing procedure.
17 So in conclusion, the heat that Mr. Bascom 18 exaggerates is not credible. Secondly, the test that 19 Entergy, if it works, tests that Entergy can detect 20 the rate the cable is, as you see, 90 degrees Celsius, 21 a very high temperature. And if you talk about 22 inaccessible localized inaccessible cable, we will to 23 see water there, we see moisture there. That also 24 help to reduce the temperature if that were the case.
25 The only concern we have is water tree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4152 1 submersion. That is aging effect we are talking about 2 today, not the localized heat source. That is only 3 applicable above the ground and we have the aging 4 program to deal with it.
5 That concludes my testimony, Your Honor.
6 JUDGE KENNEDY: Thank you. Reviewing 7 detailed questions.
8 JUDGE WARDWELL: While you are looking, I 9 will jump in --
10 JUDGE KENNEDY: Please.
11 JUDGE WARDWELL: -- with some to tie up 12 some loose ends is about what they are.
13 Let me turn to Staff, either witness or 14 both, to comment on my previous statement, if they 15 feel they have the experience to so comment. And that 16 is whether or not the testing as proposed by Entergy 17 would be able to pick up the slow degradation of 18 insulation through the period of extended operation 19 with a six-year interval of testing to ascertain the 20 incremental degradation of it, rather than just the 21 failure of the cable.
22 MR. DOUTT: If I understand the question, 23 would the testing at six years be adequate enough to 24 preclude identifying the degradation prior to failure.
25 Is that --
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4153 1 JUDGE WARDWELL: In regards to a slow 2 degradation of it, rather than some major event that 3 might have caused a catastrophic failure of it 4 immediately.
5 MR. DOUTT: A couple of clarifications, I 6 think. One is that we keep mentioning the six year 7 number as a fixed number. That number is established 8 but we are expecting the testing to be completed prior 9 to PEO. So in fact, it would depend on what was --
10 some of this is depending on what you would find at 11 that time.
12 JUDGE WARDWELL: Get a little closer to 13 your mike.
14 MR. DOUTT: I'm sorry. That would depend 15 on --
16 JUDGE WARDWELL: It seems like New York's 17 ears are getting closer and closer, the further way 18 you are getting from your mike.
19 MR. DOUTT: So just one thing, the six 20 years, that based on test results that could change.
21 So that is not necessarily a fixed number.
22 JUDGE WARDWELL: Sure. And that is what 23 I am really interested in. Will we be able to pick up 24 the incremental degradation of that so that something 25 like that you would be put on notice to let's change NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4154 1 the frequency.
2 MR. DOUTT: Right. In GALL -- a couple of 3 things too I want to mention is operating experience.
4 GALL looks at operating experience, industry 5 standards, guidance. And a thermal AMP is not 6 considered to be included in GALL. So you can look at 7 GALL as looking at this and making a conclusion 8 already.
9 As far as well this test will pick it up, 10 I guess I would reference NUREG-07000, which I think 11 is New York Exhibit 000148. There is a table in there 12 that gives you this condition monitoring technique, 13 plus the applicable stressor. And for the test that 14 they are proposing, thermal would be one of the 15 stressors that could be detected by that test.
16 JUDGE WARDWELL: And it would pick it up?
17 MR. DOUTT: One thing to think is that 18 although the aging mechanism may be different, the 19 aging effect would be the same. You are looking at 20 how did it degrade the insulation. And that 21 degradation, that test -- that is what we are designed 22 to look for.
23 JUDGE WARDWELL: So you are satisfied that 24 the six year interval is sufficient to accomplish 25 this?
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4155 1 MR. DOUTT: Yes.
2 JUDGE WARDWELL: Thank you. Dr. Sedding, 3 --
4 MR. DOUTT: This is Cliff Doutt again. I 5 am satisfied that six year as an interval, a basis 6 interval.
7 JUDGE WARDWELL: Right.
8 MR. DOUTT: Okay.
9 JUDGE WARDWELL: Yes.
10 Now to Dr. Sedding. In your experience, 11 if you have any in this area, do you agree with Mr.
12 Bascom that installing these heat sensors, whether 13 they are thermocouples or fiber optic, is feasible at 14 some location for some of these inaccessible cables?
15 DR. SEDDING: Howard Sedding here for 16 Entergy.
17 I think what one would have to look at is 18 what kind of installation we are dealing with here.
19 In this particular case at IPEC 2 and 3, you are 20 essentially looking at installed cables and duct 21 banks.
22 And the other item here to the best of my 23 knowledge one would gain the most benefit from these 24 distributed fiber optic temperature sensors by having 25 them actually installed actually on an intimate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4156 1 contact with the cable, or at least very close to the 2 surface of that cable. So therefore, I am not -- I am 3 somewhat doubtful about the prospects for monitoring 4 for hot spots as a function of let's call it ohmic 5 heating for the sake of the didactic here in another 6 duct, basically in an unoccupied duct. To me, the 7 germane point here is what is going on with the cable.
8 So therefore, I would not necessarily 9 agree that installing fiber optic temperature sensors 10 is basically feasible in this particular case.
11 And my experience of fiber optic 12 temperature sensors in cable applications has 13 principally been at the transmission class level. And 14 by transmission class, I will define that term, that 15 would be cable applications of 69 kV and above.
16 JUDGE WARDWELL: And if I understand you 17 correctly, your definition of feasibility in this case 18 relies in part on the fact that it may not achieve the 19 desired goal that you are after.
20 DR. SEDDING: Well I think first of all 21 there is the -- I'm sorry, it is Howard Sedding here 22 again for Entergy.
23 To me there is a practical issue here of 24 retrofitting fiber optics and these are somewhat 25 delicate fibers we are talking about, success with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4157 1 installing fibers basically in an existing 2 installation in a duct bank that is several years old.
3 So I am --
4 JUDGE WARDWELL: So even logistically you 5 think it is a challenge.
6 DR. SEDDING: That would be a correct 7 characterization, sir.
8 JUDGE WARDWELL: Thank you.
9 Now I need some time or are you done?
10 JUDGE KENNEDY: I'm done.
11 JUDGE WARDWELL: Okay, let me ask -- just 12 I have got about two and I am done.
13 JUDGE KENNEDY: Go ahead.
14 JUDGE WARDWELL: New York, in your 15 testimony Mr. Bascom, that is Exhibit 000136, page 31, 16 you mention this Sandia Report, SAND 96-0344. And on 17 page 56 in regards to answer 93, you state that that 18 report analyzed potential aging mechanisms and their 19 effects on low voltage and medium voltage electric 20 cables in termination -- strike that. That is not the 21 reference I want to do.
22 I would like to go back to New York State 23 again. It is 000136, page 31. I'm sorry it is 24 Exhibit 136 of New York, page 31 you state that the 25 Sandia Report, the SAND 96-0344 report was issued in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4158 1 1996 and concluded that thermal embrittlement of 2 insulation is one of the most significant aging 3 mechanisms for low-voltage cables.
4 And I guess I would ask how does that 5 really relate to the issue that you are raising here.
6 Isn't it obvious that that is going to occur? But how 7 is that problem magnified here at Indian Point, as 8 opposed to anywhere else in the country or in the 9 historic history of the energy generation industry?
10 MR. BASCOM: This is Mr. Bascom. The 11 issue is that I just thought there should be some 12 effort to evaluate if thermal aging could be occurring 13 as the plant has been in operation for several years.
14 And I cited as an example that was identified in the 15 Sandia Report that you mentioned, that they identified 16 thermal embrittlement and heating as a potential 17 issue. Not that it is an issue at Indian Point 2 and 18 3 but it is a potential issue and as a potential 19 issue, it seems as though it should be evaluated as 20 part of an ongoing operation of the plant. And I felt 21 that it should be part of the renewal application as 22 part of the Aging Management as the plant is aging, 23 that that has been considered.
24 JUDGE WARDWELL: Are you aware of anyone 25 in the electrical industry that has had a problem with NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4159 1 the one that you are describing, an elevated 2 temperature above the operating design value that 3 exists for long periods of time that might lead to a 4 gradual degradation of the cable?
5 MR. BASCOM: This is Mr. Bascom. In my 6 testimony I cited an example that was in the public 7 domain in a sense, and it was not in a nuclear power 8 plant, and it was for higher voltage cables. But it 9 was a situation where cables had been installed for an 10 extended period of time.
11 JUDGE WARDWELL: Is this the one in New 12 Zealand, I believe?
13 MR. BASCOM: This is Mr. Bascom. Yes, it 14 is, sir.
15 This is Mr. Bascom. Basically, I was 16 citing that as an example where the due diligence 17 presumably that the utility had intended when they 18 designed the system and size of the cable, and the 19 cable was allowed to continue for operation 20 successfully for many years, a situation developed 21 where it was really under-designed and prolonged 22 exposure or operation in that condition eventually led 23 to its thermal failure.
24 And in that particular case, it was a 25 cascading event where basically four circuits NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4160 1 successfully failed. As one failed, the additionals 2 picked up the load and they additionally experienced 3 even more significant elevated temperature. They 4 subsequently failed.
5 Again, it is not representative of the 6 cables that are in Indian Point 2 and 3, as I 7 understand them, but it was an example that is 8 basically publicly documented and well-know, where 9 after the initial design conditions were configured, 10 there was a period where it operated successfully and 11 then it did fail from thermal issues. And it was from 12 ohmic losses from the cables themselves because in the 13 conditions that failed, there were no, to my 14 knowledge, there were no outside external heat 15 sources.
16 So my point was that it does happen. And 17 to some extent with an older plant, there should be 18 some effort to evaluate the ongoing successful 19 operation of the cables that are in the plant.
20 JUDGE WARDWELL: Thank you. Staff, in 21 their testimony at 000077, Exhibit 000077, page 26, 22 answer 29, points out that that Sandia Report also 23 stated that most of these thermal and even the 24 mechanical mechanisms occurred primarily near the end 25 devices or connection loads. How does that impact NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4161 1 your position on this issue? Yes, Mr. Bascom?
2 MR. BASCOM: This is Mr. Bascom. The 3 Sandia Report uses a key word that I think is 4 important and if I can read from that: "These thermal 5 and mechanical aging mechanisms occur predominately,"
6 which provides the opportunity that it is not 7 exclusively, "near the end devices or connected 8 loads." So it is suggesting to me that there is some 9 knowledge that this may happen in other locations, 10 other than where the connections are made. They are 11 aboveground. And because of that, it should be at 12 least considered.
13 JUDGE WARDWELL: One last question on this 14 area. Mr. McCaffrey talked about the review he 15 performed and the calculations that he performed to 16 evaluate the design of the cables that are in place 17 and extending it through the period of extended 18 operation. Did you hear anything that raised a flag 19 in regards to that particular description of his 20 calculations that concerns you?
21 MR. BASCOM: This is Mr. Bascom. The 22 efforts that Mr. McCaffrey made are consistent with 23 evaluating the ongoing evaluation of the cable system 24 but from my view, it was not part of the process in 25 terms of renewing the license; that it was something NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4162 1 that he may do as an ongoing basis. But in terms of 2 assuring the ongoing operation of the plant, it should 3 be part of that evaluation and at least considered in 4 the Aging Management Plan as the plant is aging.
5 JUDGE WARDWELL: Thank you.
6 JUDGE McDADE: A good place to break for 7 lunch?
8 JUDGE WARDWELL: Yes.
9 JUDGE McDADE: Okay. It is now about 10 12:40. I think it might be a good time for us to 11 break for lunch. And we will propose to break until 12 1:45.
13 Are there any matters to be taken up prior 14 to our break, Mr. Sipos?
15 MR. SIPOS: Yes, thank you, Your Honor.
16 John Sipos for the State of New York. I just wanted 17 to clarify something for the record now, rather than 18 wait for later with errata or something like that.
19 I believe and I didn't want to jump in 20 with Your Honor's questions because I was reluctant to 21 do so and break up the train of questions there. But 22 I believe Judge McDade, about 40 minutes ago you 23 started a series of questions with Mr. Bascom. And 24 Mr. Bascom was responding and in the first part of his 25 response I think I heard him say in a situation where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4163 1 the plants had been operating for 20 years. In the 2 situation that we have here, it is closer to 40, give 3 or take, 37 to 39. I just wanted to clear that on the 4 record right now. I think it was inadvertent. Maybe 5 I misheard it but I just would like to clarify that.
6 Thank you.
7 JUDGE McDADE: Anything from Entergy 8 before we break?
9 MR. FAGG: No, Your Honor.
10 JUDGE McDADE: Riverkeeper?
11 MS. BRANCATO: No, Your Honor.
12 JUDGE McDADE: Clearwater?
13 MS. RAIMUNDI: No, Your Honor.
14 JUDGE McDADE: The Staff?
15 MR. ROTH: No, Your Honor.
16 JUDGE McDADE: Westchester?
17 MR. INZERO: No, Your Honor.
18 JUDGE McDADE: Okay, we are not going to 19 have a whole lot after the lunch break by the way of 20 questions. So what I would ask the parties to do and 21 question whether or not you will need any additional 22 time to do it, is to prepare to ask questions if you 23 are going to have any questions on this particular 24 contention, so that we would then be able to go ahead 25 with that questioning without an additional break NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4164 1 after the Board finishes up its questions. Do you 2 think you will need more time? Is 1:45 sufficient, 3 Entergy?
4 MR. FAGG: Yes, I think so, Your Honor.
5 Thank you.
6 MR. SIPOS: Yes, Your Honor, 1:45.
7 MR. ROTH: Yes, Your Honor.
8 JUDGE McDADE: And in putting together 9 your questions, just let me just reemphasize 10 something. I mean from the Board's standpoint, the 11 purpose of this questioning is to allow you to 12 emphasize those matters that you think are most 13 important and to correct or expand the record to make 14 sure that from the testimony to prevent the Board from 15 making an erroneous conclusion, the idea is not just 16 simply to repeat testimony that we have already heard, 17 we are obviously going to allow some limited questions 18 that are repeats, in order to set the stage for 19 further questions. But it was at least my perception 20 that yesterday there were repetitive questions that 21 then didn't serve as a basis for a follow-up question 22 to either correct or to expand the record. So in 23 putting together your questions, if you could, again, 24 try to focus again on those matters that where you 25 think the Board may have missed something and that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4165 1 either the absence of testimony or the testimony that 2 has come in as it currently sits could mislead the 3 Board to an erroneous conclusion.
4 That said, we will stand in recess until 5 1:45.
6 (Whereupon, at 12:43 a lunch recess was 7 taken.)
8 9
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4166 1 A F T E R N O O N S E S S I O N 2 (1:51 p.m.)
3 JUDGE McDADE: Please be seated.
4 JUDGE WARDWELL: Are you waiting for me?
5 JUDGE McDADE: Yes, we're waiting for you.
6 JUDGE WARDWELL: I want to start with 7 anyone from Entergy. Your testimony, that's Exhibit 8 233, I don't think you have to call it up, so just let 9 me read it. You can call it up if you want to. I 10 don't have it available automatically, but I'm not 11 going to ask to have it called up unless you need to 12 see it.
13 But it's page 43 on Answer 71. You're 14 talking about the manhole inspections that they'll 15 minimize cable exposures to moisture, and thus 16 minimize the potential for water-related degradation 17 in the underground cables.
18 About how far apart are these manholes on 19 the site? You know, are they -- we didn't see many 20 when we had a site tour. I just wondered how many of 21 them are there on the site and how far apart are they 22 and that type of thing.
23 MR. McCAFFREY: Your Honor, this is Tom 24 McCaffrey for Entergy. There's approximately 30 25 manholes that would be part of the Cable Reliability NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4167 1 Program. For how far apart they are, I'm not really 2 sure how to describe that.
3 JUDGE WARDWELL: They're just kind of 4 scattered around.
5 MR. McCAFFREY: They're scattered around.
6 They're not like all on 15 foot or one elevation.
7 They're scattered around, and they're usually 8 somewhere in between the termination points.
9 JUDGE WARDWELL: And these are all 10 outdoors? There's none that you would have that 11 you're referring to in regards to being within the 12 plant itself; is that correct?
13 MR. McCAFFREY: They're all external to a 14 building on site.
15 JUDGE WARDWELL: So there's a reasonable 16 probability that the conditions between the manholes 17 might be different than what we're observing at the 18 manholes, isn't it, in regards to moisture conditions 19 and that type of thing?
20 MR. McCAFFREY: Yes, Your Honor.
21 JUDGE WARDWELL: And how is that handled?
22 Is there just nothing we can do about it or --
23 MR. McCAFFREY: Well Your Honor, at any 24 point, the low voltage cables, if we go to ENT 242.
25 I think that describes our low voltage cable list. In NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4168 1 there, it also takes about a sheath. The low voltage 2 cables at Indian Point, everyone but one has a lead 3 sheet.
4 Lead's impervious to water. So for all 5 low voltage cables that typically are safety-related, 6 the emergency safeguard components all have lead 7 sheaths on there that would prevent any type of water 8 intrusion from impacting it. There are some on the 9 13/8, but it's not as widespread.
10 MR. COX: Judge Wardwell, this is Alan Cox 11 for Entergy. I'd like to add one other clarifying 12 point. If we could assure that there was no water in 13 the cables, in the manholes, or in the cable duct bank 14 between the manholes, we wouldn't be needing to do the 15 testing.
16 So to answer your question, what we're 17 doing about the cables in the duct bank where we don't 18 know what the condition is, we're doing the testing 19 that's specified as part of this program.
20 MR. McCAFFREY: This is Tom McCaffrey 21 again, Your Honor. Just another thing to put in mind.
22 We took no credit in the development of our Cable 23 Reliability Program for these lead sheaths. We did 24 not say we did not have to do any testing.
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4169 1 testing. Lead sheaths are in addition, another 2 barrier we would have for cables, for water intrusion 3 into our cables.
4 JUDGE WARDWELL: And what actions do you 5 do if you do find water in a manhole?
6 MR. McCAFFREY: Well, right now if we find 7 water, maintenance is pumping the water out, removing 8 the water, and returning that in accordance with their 9 Corrective Action Program.
10 I also think we talked about this table 11 before. We brought it up as one of the exhibits, 12 showed how the frequencies are changing, based upon 13 what we're seeing in the manholes.
14 JUDGE WARDWELL: Thank you. And is most 15 of that -- well, let me get back to that. Is most of 16 that documented in EN-DC-346, or is it in your 17 Corrective Action Program, or is it in both?
18 MR. McCAFFREY: Is mostly what, Your 19 Honor?
20 JUDGE WARDWELL: Most of these procedures 21 that you just described, that you would pump it out 22 and increasing inspections if, for whatever criteria?
23 MR. McCAFFREY: Those actions -- this is 24 Tom McCaffrey, Entergy. Those actions to change the 25 frequency, based upon what we're finding, is described NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4170 1 in EN-DC-346. So that procedure tells us we had a, 2 you know, we have to increase the frequency of our 3 manhole inspections, based upon what we're seeing.
4 JUDGE WARDWELL: Well, I never saw 5 anywhere where it says you're going to remove the 6 water. Was that not said because it was obvious, or 7 do you actually commit to doing that? I mean I think 8 it would be fairly obvious. If you see it, you would 9 sop it up.
10 MR. McCAFFREY: I do believe it says --
11 can you give me a second? I just want to look for it.
12 MR. O'NEILL: Your Honor, it's Marin 13 O'Neill for the Applicant. Section 5.7 of EN-DC-346 14 may be a place to look.
15 MR. McCAFFREY: Thanks, Martin. This is 16 Tom McCaffrey again from Entergy. So as Marty 17 mentioned, Section 5.7 describes the manhole 18 inspections dewatering, and talks about what actions 19 we're going to take, based upon water being found in 20 manholes.
21 MR. O'NEILL: What's that a section of?
22 MR. McCAFFREY: It's in the EN-DC-346 23 procedure. It's Section 5.7. It's titled "Manhole 24 Inspections and Dewatering."
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4171 1 touched upon this this morning, but I got a little bit 2 confused on it. I just want to make sure this is 3 true. This relates to the water trees and with medium 4 voltage cables.
5 Entergy, in your testimony, that's Exhibit 6 233, page 25, Answer 41, you state that for medium 7 voltage cables, the primary concern raised by New York 8 State is the possible formation of water trees. Maybe 9 I'll go, I think I'll go to Mr. Bascom first, in 10 regards to the fact that you raise this as an issue, 11 and would you describe the issue and whether or not 12 it's still of concern to you or not?
13 MR. BASCOM: This is Mr. Bascom. Just a 14 clarification, the issue with water trees.
15 JUDGE WARDWELL: Right.
16 MR. BASCOM: Okay. This is Mr. Bascom.
17 The issue of water trees is basically in the presence 18 of voltage and water. The insulation can develop 19 channels, in somewhat layman's terms, through the 20 insulation, to grade the quality of the installation.
21 Over time, an event called partial 22 discharge can develop, where there's basically some 23 localized electrical discharges in the insulation, 24 that over time carbonize the water channels and form 25 what are called electrical trees.
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4172 1 They're called water trees and electrical 2 trees because to a casual observer, they look somewhat 3 like trees you'd see in the environment. When the 4 electrical trees form, the dielectric strength of the 5 insulation is more significantly compromised, and to 6 an extent, the electrical tree can bridge the gap 7 between the conductor and the surrounding shield or 8 sheath, and eventually lead to failure, a breakdown of 9 the insulation, which is a failure.
10 In the cable systems as they're listed, 11 they have a lead sheath on them, and generally lead 12 will prevent moisture intrusion into the insulation.
13 So that's a hermetic seal that prevents moisture from 14 getting into the cables.
15 When I raised this contention, we did not 16 have a list of what the cables and their construction, 17 and that was also one of the issues that I commented 18 upon. Some from the perspective, the type of cable 19 construction is such that it would generally lend 20 itself to avoiding the presence of moisture getting 21 into the cables.
22 JUDGE WARDWELL: And so you're satisfied 23 that with the type of cable that they're using, this 24 is not an issue at Indian Point?
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4173 1 as I can tell from the table that's provided, the lead 2 sheath would prevent moisture from getting into the 3 cables.
4 JUDGE WARDWELL: That saves me from asking 5 Entergy a question. So I appreciate that. I know we 6 touched upon this again this morning, but I want to go 7 over one more time. New York, in your Exhibit 136, I 8 don't have a page for it. I'll just -- forget the 9 reference.
10 Let me just ask again, and I guess I'll 11 ask Entergy, whoever wants to answer this, to again 12 describe the cable failures that have occurred at 13 Indian Point.
14 What was the cause of them, what was done, 15 and then hypothesize how a similar type of failure 16 occurring in the future, during the period of extended 17 operation, would be handled under your aging 18 management program?
19 MR. McCAFFREY: This is Tom McCaffrey for 20 Entergy. I'd like to direct our response to our 21 testimony on Question 68 on page 41.
22 JUDGE WARDWELL: Let's call that up.
23 What's the exhibit number. Is that 233?
24 MR. McCAFFREY: 233.
25 JUDGE WARDWELL: I think that's R-233; is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4174 1 that correct?
2 MR. O'NEILL: Yes, that's correct, Your 3 Honor.
4 JUDGE WARDWELL: And the question number 5 or the page number?
6 MR. McCAFFREY: Question 68, I believe, is 7 on page 41. So there, we describe in the response to 8 the generic letter 2007-01, there were two cable 9 failures at Unit 3 that occurred prior to that, and 10 they were both due to mechanical damage.
11 That was to a service water pump cable.
12 That cable was removed and replaced with new cable.
13 Subsequent to the submittal of that generic letter 14 response, there was one more cable failure. The 15 contractor on site hit a cable with a fence pole, and 16 that caused a catastrophic failure of that cable, 17 requiring that cable to be cut out and replaced.
18 So all three operating streams at the site 19 were mechanically-induced failures and not aging 20 related failures. So that would not get worked in our 21 aging management program for the underground cables, 22 as we've been discussing.
23 JUDGE WARDWELL: And what was the 24 mechanical action that took place that did this 25 damage?
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4175 1 MR. McCAFFREY: For the first cable, 2 they're both incorrect insulations. The cable got 3 installed in a conduit. There was mechanical damage 4 done during the cable during installation. The first 5 failure happened, it occurred without our knowing, 6 without us detecting it.
7 The second failure was picked up during 8 our insulation measurement testing of that cable, and 9 we were able to take corrective action before that 10 cable failed.
11 JUDGE WARDWELL: And then in regards to 12 hypothesis, these wouldn't fall under the aging 13 management, because they were mechanical failures?
14 MR. McCAFFREY: Correct.
15 JUDGE WARDWELL: Thank you. That's all I 16 have.
17 JUDGE McDADE: Okay. We'll use the same 18 procedure we did yesterday. New York, Entergy and 19 then the staff. New York?
20 MS. FEINER: Yes, Your Honor. Lisa 21 Feiner. I'll be asking just a few questions, and I'm 22 standing up, because I can't see Mr. Rucker. Good 23 afternoon, Mr. Rucker. You testified about Entergy's 24 Cable Reliability Program, Exhibit 237, EN-DC-346.
25 Do you remember that?
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4176 1 MR. RUCKER: Yes.
2 MS. FEINER: And you testified that 3 Entergy selected, I believe it's the tan delta test 4 for shielded medium voltage cables; is that correct?
5 MR. RUCKER: In that procedure, that is 6 the preferred method for shielded medium voltage 7 cable, that's correct.
8 MS. FEINER: Right, and that was what was 9 identified in the Cable Reliability Program as the 10 test that would be used for those cables?
11 MR. RUCKER: That is correct.
12 MS. FEINER: Now I believe Judge Wardwell 13 asked you whether Entergy could change the tan delta 14 test to another test, without first informing the NRC.
15 Do you remember being asked that question?
16 MR. RUCKER: Yes, I do.
17 MS. FEINER: And what was your answer?
18 MR. RUCKER: Actually, I think Mr. Cox 19 answered that, and I don't know if he wants to answer 20 this one or --
21 MS. FEINER: No. I believe you did.
22 MR. RUCKER: Okay. As far as changing 23 that test, you know, as we described in other things, 24 we're staying with the group of tests that are 25 identified as what's stated in the Appendix Alpha of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4177 1 the application, which will become part of the UFSAR.
2 That would have to be reviewed, to see if 3 it rose to the level, you know, through the screening 4 criteria, and again, you'd have to go through the 5 checklist and make sure you answered all the 6 questions.
7 If you selected another test that was on 8 that, like for example, if you decided you wanted to 9 do partial discharge, then that would not -- I would 10 not see that being, you know, a change that would rise 11 to the level where you'd have to have prior approval.
12 MS. FEINER: Okay, thank you. And now I'd 13 like to ask a few questions of Mr. Doutt.
14 MR. DOUTT: Sure.
15 MS. FEINER: I'd like to have pulled up on 16 the screen Entergy Exhibit 583, which is the latest 17 revision of the Cable Reliability Program, Revision 3, 18 and again, it's procedure number EN-DC-346. If you 19 could go to -- Mr. Welkie, if you could go to page 21.
20 That's fine.
21 Now Mr. Doutt, I'm looking at the first 22 paragraph on that document, and if you wouldn't mind 23 just reading that?
24 MR. DOUTT: That's the number two in 25 brackets?
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4178 1 MS. FEINER: Yes.
2 MR. DOUTT: That says "If unshielded cable 3 aging is identified and long-term (reading) cannot be 4 eliminated, the cable should be placed prior to 5 failure, and consideration should be given to the use 6 of impervious cable design for the replacement cable."
7 MS. FEINER: Now would Entergy have to 8 inform the NRC if it dropped this replacement 9 requirement from its Cable Reliability Program?
10 MR. DOUTT: No. I think this is -- but 11 from their point of view, this is their corrective 12 action that they developed.
13 MS. FEINER: I'm sorry.
14 MR. DOUTT: I'm sorry. From our, if they 15 change this and said this is their corrective action 16 if they found it, there is other options that they 17 could use, I mean, from an Appendix B point of view.
18 MR. NGUYEN: May I add something to Mr.
19 Doutt, if I may?
20 JUDGE McDADE: You may, yes.
21 MR. NGUYEN: If it is a defective cable, 22 under regulation they have to issue licensing event 23 report, and part of the licensing event report, they 24 have to identify the cause of the problem, what is 25 their correction will be. That's a regulation.
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4179 1 That's a required regulation. So I believe that they 2 have to take the action.
3 MR. DOUTT: I don't know from this, number 4 two, exactly what -- I know in the Cable Reliability 5 Program, if it's in-scope cable, if it's -- what it 6 was, a failure is not.
7 This is, if you can't identify, can't get 8 of the long-term wetting, then they're making an 9 assumption, then, that that cable submergence will 10 lead to eventual failure, so the cable should be 11 replaced, and it would be best to replace that cable 12 with one that's not subject to water intrusion.
13 MS. FEINER: Well, if you look at the 14 first page of this document, Revision 3 of the Cable 15 Reliability Program. I'm sorry. If you could scroll, 16 okay. And if you count up from the bottom to the six 17 bullet points up.
18 MR. DOUTT: Correct.
19 MS. FEINER: And that section says "Added 20 Section 5.5 bracket [2] to require cable replacement 21 if unshielded cable aging is identified, and long-term 22 wetting cannot be eliminated, the cable should be 23 replaced prior to failure."
24 Now that suggests that the previous 25 revision document did not include that requirement; NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4180 1 correct?
2 MR. DOUTT: Or it's been revised, yes. It 3 said it added a section, so I'd say it's new.
4 MS. FEINER: So I guess I'll just ask it 5 one more time. Could Entergy remove the requirement 6 to replace a cable in these conditions, without 7 informing the NRC, assuming there's been no condition 8 related to that yet?
9 So there's no condition report or not 10 inspection. Could it just remove that requirement and 11 go back to its previous version of this Cable 12 Reliability Program, that did not require replacement 13 in that situation?
14 MR. DOUTT: If this change removed this 15 change, or go back to the other change, does not 16 impact the licensing basis and whatever, it's still a 17 50.59. They'd have to screen and do the review to 18 decide whether that impact is there or not. Yes, it's 19 possible they did have to tell us.
20 MS. FEINER: And they would have to tell 21 you if this were part of the UFSAR, this requirement?
22 MR. DOUTT: If in fact this -- during 23 their screening process, and I'm talking for them, so 24 maybe it's better that they answer this question. If 25 they added this in as corrective action, that's what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4181 1 they felt they needed to do.
2 If they replaced this, and it doesn't meet 3 our licensing basis or their screening process says 4 that yes, in fact, there's license amendment required, 5 then we would review it.
6 MS. FEINER: So they might have to inform 7 you and they might not have to inform you, depending 8 on their screening process?
9 MR. DOUTT: Looking at a Corrective Action 10 Program, Appendix B, there's different ways that they 11 could resolve that issue. One is a cable replacement.
12 One would be more frequent testing.
13 In fact, if testing indicated that, you 14 know, what we're doing here, at least procedurally in 15 our AMP, is we're looking at what the condition of the 16 installation is, and then what decision should be 17 made.
18 If they've made a prior, if in fact they 19 can't correct a particular area, they made a decision 20 that cable replacement is what they will do.
21 MS. FEINER: So it's possible they could 22 drop this requirement without informing the NRC, 23 right?
24 MR. DOUTT: Depending on their screening 25 and what would happen, yes.
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4182 1 MS. FEINER: And that's their internal 2 screening; correct?
3 MR. DOUTT: Yes. That would be what they 4 would need to do for 50.59.
5 JUDGE McDADE: Let me interrupt for just 6 a second. Mr. Nguyen, as I understood your prior 7 testimony, that if this were a safety-related cable, 8 then per se they would need prior approval.
9 If it were not a safety-related cable, 10 then you would go through the 50.59 screening process, 11 and depending on the answer to the questions under the 12 50.59 screening process, they may or may not be able 13 to make the change without prior approval from the 14 agency. Did I recall your testimony correctly?
15 MR. NGUYEN: Yes, Your Honor.
16 MR. DOUTT: Yes, that's what I'm saying.
17 There will be some process in here. This essentially 18 leads to -- the screening process is part of 50.59, 19 whether this is license basis or not. That's 20 essentially an agreement with Duke that that's what 21 would have to occur.
22 JUDGE McDADE: Oh, thank you Mr. Doutt.
23 Please continue.
24 MS. FEINER: I have no further questions.
25 JUDGE McDADE: Mr. Sipos.
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4183 1 MR. SIPOS: Thank you, Your Honor. The 2 first question is directed to Mr. Bascom. Mr. Bascom, 3 I believe that I heard Mr. Nguyen testify earlier 4 today before lunch that electric cables operating 5 within their design parameters would not experience 6 ohmic loss. First of all, did you hear that, and if 7 so, do you agree with that?
8 MR. BASCOM: This is Mr. Bascom. I didn't 9 hear that, I believe, and no, I do not agree.
10 MR. SIPOS: And could you explain why you 11 disagree?
12 MR. BASCOM: This is Mr. Bascom.
13 Basically, a power cable that is carrying electrical 14 current, whether it's operating above or below its 15 temperature limits, would generate ohmic losses, 16 because there's current and as Mr. Nguyen described, 17 the current squared times the electrical resistence 18 will produce heat or watts.
19 So as long as there's current flowing 20 through the conductor, there will be heat generated.
21 Whether it's operating above or below its designed 22 temperature, or design temperature limit.
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4184 1 interval, and assuming that Indian Point Unit 2 2 completes its cable inspections in 2013, which I 3 believe we heard testimony that that would occur this 4 morning, would that mean that the additional 5 inspections would then take place by 2019, 2025 and 6 2031, and I'm just adding six years to 2013? But I 7 want to make sure I have that clearly fixed in my 8 mind?
9 MR. DOUTT: The first question, you said 10 inspection. I assume you're talking about the six-11 year test?
12 MR. SIPOS: Yes.
13 MR. DOUTT: Okay. Base time frame is six 14 years, every other outage essentially, unless, you 15 know, unless in the PEO, prior to PEO and they finish 16 up, and they find a cable that needs to be, have 17 testing, based on the results needs to be increased.
18 Those terms would remain.
19 MR. SIPOS: Thank you. Mr. Nguyen, did I 20 understand you to testify right before lunch to the 21 effect that moisture present, if moisture was present 22 around an electric cable or a set of electric cables, 23 that that would help reduce the temperature around 24 those cables?
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4185 1 conditions, but the point I want to make is if you 2 designed a cable and the technical consideration, the 3 capacity of the cable, if you design the cable 4 correctly, you will not operate above the regular 5 current, regular current of the cable.
6 For example, typical cable will be at 90 7 degree Celsius. Let me give you an example, that for 8 the 14 AWG, American wide gauge, for this kind of 9 optic cable, maximum capacity of the cable is 80 10 amperes.
11 So if you operate this cable, 80 amperes 12 will be low, you will not exceed the 90 degree Celsius 13 rating of this cable. You can operate indefinitely 14 with that capacity.
15 MR. SIPOS: But did I understand you also 16 to testify this morning that moisture would reduce the 17 heat around cables?
18 MR. NGUYEN: That's my point of view.
19 MR. SIPOS: Thank you. Mr. Doutt, just 20 coming back to you quickly. Sitting here today, can 21 you tell us what version of NUREG-1801 GALL applies to 22 Entergy's license renewal application, with respect to 23 the cables that we've been discussing today?
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4186 1 the four -- the RAI, request for information I believe 2 was in March or February. We had four responses, 3 March to July and then August.
4 Those requests were based on additional 5 operating experience and GALL Rev 2. The additional 6 criteria that was put in there for this particular 7 AMP, it would make it essentially have the essential 8 elements of GALL Rev 2.
9 MR. SIPOS: And when you were talking 10 about March to July, I believe were you referring to 11 March to July of 2011?
12 MR. DOUTT: That's correct.
13 MR. SIPOS: Thank you.
14 MR. DOUTT: The four RAI responses from 15 Entergy.
16 MR. SIPOS: And that was in the lead-up to 17 this supplemental safety evaluation report?
18 MR. DOUTT: That's correct, right. The 19 supplement was issued later in August, I believe, of 20 2011.
21 MR. SIPOS: My next question is to 22 Entergy's witnesses, and I'm wondering, and it 23 concerns the Corrective Action Program. I'm wondering 24 if any of you are familiar with the July 2008 report 25 from the outside panel of safety experts?
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4187 1 MR. McCAFFREY: This is Tom McCaffrey for 2 Entergy. I am aware of the independent safety 3 evaluation, but maybe not the specific discussion that 4 you want to have.
5 MR. SIPOS: Are you aware that that report 6 expressed concern about the number of open issues in 7 the Corrective Action Program for Indian Point?
8 MR. McCAFFREY: I do not remember that.
9 MR. SIPOS: Thank you. Your Honor, I have 10 no further questions.
11 JUDGE McDADE: Entergy?
12 MR. FAGG: Thank you, Your Honor. Brad 13 Fagg for Entergy, briefly. If we have, or did we have 14 Entergy 233 or R-233, the testimony up, and if we 15 could go to Answer 56, and my first question I guess 16 is not so much of a question, but I'll direct it to 17 Mr. Cox.
18 We talked, over the course of today, sort 19 of about the chronology and the evolution of this 20 program. I guess I just wanted to point all of us to 21 point in the record where that's kind of summarized.
22 Is the Question and Answer 56 a place we could go to 23 find a sort of summary of the chronology of the 24 evolution of these programs?
25 MR. COX: Yes, it is.
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4188 1 MR. FAGG: Okay, thanks. Let's, the next 2 one, I guess, is for Mr. McCafferty (sic), and could 3 we go to EN-DC-346, which I believe is Entergy Exhibit 4 583 as Rev 3.
5 What I'd like to do is just sort of tick 6 and tie, if we could, the connection between this 7 document and some of the lists that you identified 8 earlier, Mr. McCafferty, I believe Entergy Exhibit 242 9 and 243. Do you recall testifying about those lists?
10 MR. McCAFFREY: Yes, I do.
11 MR. FAGG: Okay. Let me direct your 12 attention to page 18 of 36 of this document, EN-DC-13 346, and Section 5.3 bracket [5]. My question to you 14 will be does this Entergy procedure inform or relate 15 to the creation of the lists that are now marked as 16 Entergy Exhibits 242 and 243?
17 MR. McCAFFREY: That's correct. I believe 18 bracket [2] is for the medium voltage, and bracket [5]
19 is for the low voltage list.
20 MR. FAGG: So am I correct in 21 understanding that those lists were prepared in 22 connection with the requirements of this procedure?
23 MR. McCAFFREY: That's correct.
24 MR. FAGG: Okay, thank you. Mr. Cox. I 25 heard Mr. Bascom testify this morning, and I wrote the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4189 1 phrase down he used, that the Entergy procedures, that 2 Entergy had the flexibility to "modify at will" those 3 procedures.
4 I guess I wanted to just follow up with 5 you briefly, and ask you whether you think that 6 characterization by Mr. Bascom is a fair 7 characterization of the process we've been talking 8 about here?
9 MR. BASCOM: I believe that is an 10 incorrect characterization.
11 MR. FAGG: Can you elaborate on that or 12 explain why?
13 MR. BASCOM: We can't change procedures at 14 will. We have to follow established processes to do 15 the appropriate technical reviews and the reviews 16 against the licensing, the current licensing basis, 17 which invokes the requirements of 10 C.F.R. 50.59.
18 So it's a rigorous process, been 19 established for many years, and it's used throughout 20 the plant to control changes to procedures.
21 MR. FAGG: Okay, and just sticking with 22 the 50.59 issues for a bit more here, we had some 23 testimony on this in the last couple of days. But 24 just to briefly summarize, for purposes of the record 25 in this contention, I understand there's a screening NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4190 1 process; is that right?
2 MR. COX: That's correct.
3 MR. FAGG: Is that screening process 4 documented?
5 MR. COX: Yes. That is a documented 6 procedural attachment, that has to be filled out and 7 maintained in records.
8 MR. FAGG: Okay, and if the NRC wanted to 9 come in and review and assess the determinations that 10 Entergy made in connection with that screening 11 process, is there a mechanism by which they can do 12 that?
13 MR. COX: Certainly. Those records are 14 available to the on-site NRC inspectors.
15 MR. FAGG: And if the NRC determined that 16 it disagreed with the determinations made by the 17 company in connection with that screening process, do 18 you have any doubt that the NRC would have an ability 19 to let you know that?
20 MR. COX: I have no doubt that they have 21 the ability to issue an enforcement action, if they 22 disagreed with the way we perform that procedure.
23 MR. FAGG: Thank you. Let me shift over 24 to Mr. McCafferty, and we talked, in response to some 25 of the questions from Judge Kennedy this morning about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4191 1 the manhole inspections and the interaction of the 2 Corrective Action Program and the modifications to the 3 procedures. Do you recall that dialogue?
4 MR. McCAFFREY: Yes, I do.
5 MR. FAGG: And I'd just like to ask more 6 globally if you can sort of describe. Does the 7 Corrective Action Program feed into and do the trends 8 that might be reflected in the Corrective Action 9 Program process affect, the procedures by which 10 Entergy operates in this area?
11 MR. McCAFFREY: Yes, they do. As we kind 12 of talked this morning briefly about, if we find water 13 in the manhole, that will get a condition report. It 14 would get rated and evaluated by an engineer.
15 Frequencies will be adjusted, as we showed on the 16 attachment, and it will feed back into the program, 17 and that's a continuous cycle. It would be like a big 18 circle.
19 We'll go out and do more frequent 20 inspections. Based upon those inspections, additional 21 condition reports will be written that will drive our 22 process.
23 MR. FAGG: Okay, and then again, the 24 manhole example we looked at is a real world example 25 of that happening?
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4192 1 MR. McCAFFREY: That's correct.
2 MR. FAGG: Okay. Thank you. Let me 3 shift, and I'm now moving into sort of the second 4 issue, if you will, as Judge Kennedy described these 5 this morning. A question for you Mr. Rucker. Mr.
6 Bascom described the fiber detections and other formal 7 detection strategies. Do you recall hearing some of 8 that testimony?
9 MR. RUCKER: Yes, I do.
10 MR. FAGG: Okay. To your knowledge Mr.
11 Rucker, is there any nuclear power plant in the 12 country that has put in those kinds of strategies or 13 detection devices as a matter of retrofitting, in 14 connection with low or medium voltage cable?
15 MR. RUCKER: I'm not aware of any nuclear 16 plant doing a retrofit, to add a monitoring process 17 like this.
18 MR. FAGG: Are you in a position where you 19 think you would know about that if it happened?
20 MR. RUCKER: I regularly attend working 21 group meetings through NEI, which is specific to 22 license renewal, as well as EPRI and IEEE working 23 groups.
24 MR. FAGG: Okay, and I'd like to follow up 25 a little bit --
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4193 1 JUDGE McDADE: So the answer is yes.
2 MR. RUCKER: Yes.
3 MR. FAGG: Thank you, and thank you, 4 Judge. I'd like to just talk a little bit about the 5 logistics.
6 We touched on that briefly, but the 7 logistics of installing these types of systems, if we 8 determine to do them as a retrofit, and I guess I'd 9 ask the Entergy panel, maybe Mr. McCaffrey, can you 10 elaborate a little bit on what that would entail, and 11 whether it would be plausible?
12 MR. McCAFFREY: This is Tom McCaffrey for 13 Entergy. To install these systems, we'd have to 14 remove the currently installed cable, due to the cable 15 size. There's insufficient size to be able to sneak 16 another cable on top of our power cables down the 17 conduit, without having some reasonable assurance that 18 would not damage the installed cables.
19 So that to remove a cable and reinstall a 20 new cable, when you do that, you do have the potential 21 to cause some type of mechanical damage during the 22 installation of that cable. As I kind of talked about 23 the 20E we have from Unit 3, dealing with 33 service 24 water pumps, we have seen mechanical damage due to the 25 installation of cable.
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4194 1 MR. FAGG: Thank you. Sticking with you, 2 Mr. McCaffrey, we talked just in the last few moments 3 about the lead sheathing. Do you recall that?
4 MR. FAGG: Is Indian Point unique in the 5 industry or typical of the industry with respect to 6 the lead sheathing?
7 MR. McCAFFREY: It's not typical to have 8 a lead sheath installed around your cables. That is, 9 was a design condition carried over from Con Edison's 10 experience in New York City, when they did the 11 distribution system there. That got carried over into 12 the design of the Indian Point Units 2 and 3.
13 MR. FAGG: So is that a level of comfort 14 that exists at Indian Point, that doesn't exist in 15 most nuclear power plants?
16 MR. McCAFFREY: That's correct.
17 MR. FAGG: Okay. Dr. Sedding, I'd like to 18 follow up just briefly with you. You testified, I 19 believe in response to one of Judge Wardwell's 20 questions, that you were not aware of any failure to 21 do the ohmic heating. Do you recall that?
22 DR. SEDDING: Yes, I do.
23 MR. FAGG: Okay. I just want to put a 24 little context in that. Prior to, you know, I'm not 25 aware of any either, but that doesn't mean much coming NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4195 1 from me. I guess can you describe sort of the 2 universe of the exposure, and what you draw upon to 3 make that observation?
4 DR. SEDDING: This is Howard Sedding for 5 Entergy. With respect to that question, I have to go 6 with the collective and cumulative experience of the 7 company that I work for, in which several thousand 8 cables have been subject to forensic analysis over the 9 years, and we have not, to the best of our knowledge, 10 seen any evidence of failures directly due to ohmic 11 heating.
12 MR. FAGG: Thank you, and sticking with 13 you, Dr. Sedding, I'd like to follow up again on some 14 of Judge Wardwell's questions, where he asked you 15 whether, under certain assumptions, a cable would last 16 forever. I guess I'd like to change or alter the 17 question just a bit. The term "forever" I think makes 18 all of us pause a little bit.
19 But let me ask it in a slightly different 20 way, if I could. For non-EQ applications, if the 21 cables were operated as they were intended to be 22 operated, do you believe, and is it your professional 23 judgment that those cables would operate well past the 24 renewed license life at Indian Point?
25 DR. SEDDING: In my professional opinion, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4196 1 yes.
2 MR. FAGG: And is there any doubt or 3 equivocation nor is that a close call?
4 DR. SEDDING: No, there is not.
5 MR. FAGG: Let me go, if I could, to Mr.
6 McCaffrey for a few questions here about some of the 7 hypotheticals that we spent some time talking about 8 this morning. We threw around some terms. I'd like 9 you to define a couple of terms.
10 We were talking about ratings, and 11 different kinds of ratings. I guess, as I understand 12 it, there may be three, at least, different types of 13 concepts we're talking about. Is the term "cable 14 rating" a term you're familiar with?
15 MR. McCAFFREY: Yes, I am.
16 MR. FAGG: Can you tell me what you mean 17 by that?
18 MR. McCAFFREY: What we mean by "cable 19 rating," this is the manufacturer rating, what a 20 design temperature for certain cable or capacity 21 rating.
22 MR. FAGG: Okay. Is that different than 23 a design rating?
24 MR. McCAFFREY: Yes. The design rating is 25 what I would calculate at the site to be what I expect NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4197 1 that temperature to be for that conductor, based upon 2 the mutual conductors in the area, the capacity it's 3 going to carry, what temperature we think the cable's 4 going to operate at.
5 MR. FAGG: Okay, and so is the cable 6 rating higher than the design rating?
7 MR. McCAFFREY: In all cases, yes.
8 MR. FAGG: Okay, and then what about 9 operating temperature? Is that a different concept?
10 MR. McCAFFREY: The operating temperature, 11 as the Entergy staff talked about, some of the safety 12 margins and stuff that goes into the design rating, is 13 usually typically much lower than the design 14 temperature that we designed the plant for.
15 MR. FAGG: Okay. So in ranking these, the 16 highest would be cable rating, then design rating and 17 then operating temperature?
18 MR. McCAFFREY: That's correct.
19 MR. FAGG: Okay. Let me pose a few 20 questions to you under each of those three scenarios.
21 If you operated a non-EQ cable at one degree above its 22 cable rating for an extended period of time, do you 23 have confidence that the programs at Indian Point 24 would detect any thermal-related degradation?
25 MR. McCAFFREY: Yes, I do.
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4198 1 MR. FAGG: Let me ask you the same 2 question with respect to operation. At one degree 3 above the design rating for an extended period of 4 time, would the procedures at Indian Point catch any 5 thermal-related degradation?
6 MR. McCAFFREY: Yes, it would.
7 MR. FAGG: And then finally, the same 8 question with respect to the operating temperature.
9 If it was operated at one degree above the operating 10 temperature for an extended period of time, would the 11 procedures at Indian Point capture and detect any 12 thermal-related degradation?
13 MR. McCAFFREY: It would detect any signs 14 of thermal degradation. I just wanted to point out 15 those last, the operating temperatures is well below 16 its cable rating. So it will probably have no impact 17 on the thermal insulation, based upon that 18 temperature.
19 MR. FAGG: Dr. Sedding, did you hear what 20 Mr. McCaffrey just testified to?
21 DR. SEDDING: Yes, I did.
22 MR. FAGG: Do you have any dispute or 23 disagreement with any of that?
24 DR. SEDDING: No, I do not.
25 MR. FAGG: Okay. Finally, right at the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4199 1 end, I guess, of the testimony, there were some 2 references to event in New Zealand. Dr. Sedding, are 3 you familiar with the event in New Zealand that Mr.
4 Bascom identified?
5 DR. SEDDING: Yes, I am.
6 MR. FAGG: And can you just briefly 7 summarize why or why not that event sheds light on the 8 inquiries we're pursuing here today?
9 DR. SEDDING: In my opinion, the events in 10 New Zealand are not germane to the situation at IP2 or 11 3. For the reason, there are a number of reasons, but 12 if I can be brief. The cables that were subject of 13 the problems in New Zealand were transmission class 14 cables, and in this particular case operating 110 kV 15 carrying several megawatts of power.
16 The conclusions that were reached, and 17 these are, can be found in New York State Exhibit 155, 18 are summarized in the first couple of pages of the 19 report that was made by the external consultants.
20 Essentially, there's four basic conclusions that the 21 consultants made.
22 There was a basic installation or design 23 problem with the cables. There was relatively, and by 24 almost no experience within the utility who was 25 operating the cables to properly operate and maintain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4200 1 those systems.
2 There was no systematic test program 3 available, and finally, and just to speak to the point 4 of the consequences of the failure, the difference in 5 New Zealand, if one could ever transpose it to what's 6 the situation in Indian Point, is in New Zealand, one 7 of the problems was that as one cable failed, other 8 cables were then left to take up the load.
9 Because of inadequacies in their design, 10 operation and maintenance, those cables very rapidly 11 became overloaded. In the case of Indian Point, the 12 loads that these cables are basically, from a design 13 point of view, separated. So therefore the failure of 14 one system and the probable event that it occurred, 15 would not affect the integrity of the other systems.
16 MR. FAGG: Thank you, Dr. Sedding, and 17 thank you to the Board. No further questions.
18 JUDGE McDADE: Thank you. The staff?
19 MR. ROTH: David Roth for the staff. Just 20 a limited number of questions to the staff's 21 witnesses. First, staff in your testimony at NRC 22 Exhibit 77, page 19, you refer to Inspection Procedure 23 71-003. Do you have an exhibit number for that?
24 MR. NGUYEN: Yes, Your Honor. The exhibit 25 number is ENT 251.
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4201 1 MR. ROTH: Thank you, and the second 2 question, this went to Mr. Nguyen, you testified 3 earlier that there was 1.25 percent safety factor in 4 cable design. Can you clarify that please?
5 MR. NGUYEN: Yes, I want to clarify. It's 6 125 percent of the safety factor, multiplied by the 7 safety factor of 125 percent.
8 MR. ROTH: So that's 125 percent, right?
9 MR. NGUYEN: Yes.
10 MR. ROTH: Thank you. Third, you 11 described documents that you reviewed on the site.
12 Could you please re-describe those documents?
13 MR. NGUYEN: Yes. I was, I will mention 14 that I only reviewed the basic document, but actually 15 I reviewed more than that.
16 When I refreshed my memory, because I did 17 that a long time ago, beside the basic document I also 18 looked at the corrective action report. I also looked 19 at the operating experience, and I also looked at the 20 aging management review report, beside the AMP, Aging 21 Management Program basic document.
22 MR. ROTH: Okay, thank you, and you also 23 earlier testified that ohmic heating was a concern 24 across all lengths of the cable; right?
25 MR. NGUYEN: Yes.
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4202 1 MR. ROTH: In context, what was that 2 testimony concerning? As in at the time, what was the 3 topic of discussion? Was it heat along the entire 4 length of the cable, or point sources?
5 MR. NGUYEN: Yes. If the ohmic heating 6 happened, if it happened the entire length of the 7 cable, not at the localized, this will not add any --.
8 MR. ROTH: So in other words, ohmic 9 heating does not cause a point source of heat?
10 MR. NGUYEN: Yes sir.
11 MR. ROTH: And you also just testified 12 concerning a license event report, saying that if a 13 cable failed, as you were looking at the document, 14 that there could be a licensee event report; is that 15 correct?
16 MR. NGUYEN: Yes sir.
17 MR. ROTH: Is there a regulation you could 18 point the Board to, addressing licensing event 19 reports?
20 MR. NGUYEN: I think it is, but I have to 21 look at the 10 C.F.R. Part 50. I not know right off 22 my head right now.
23 MR. ROTH: Can you open the 10 C.F.R. 24 50.73 please?
25 MR. NGUYEN: 50.73?
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4203 1 (Witness reviewing document.)
2 MR. NGUYEN: Yes.
3 MR. ROTH: All right. So I understand 4 that that's the regulation controlling what's 5 reported?
6 MR. NGUYEN: Yes.
7 MR. ROTH: All right, thank you. No 8 further questions.
9 JUDGE McDADE: Okay, thank you. That ends 10 things for today. A couple of very brief housekeeping 11 things from the standpoint of the Board. First of 12 all, I wanted to note that there were certain 13 exhibits, specifically Entergy 41, that were submitted 14 in March of 2012, and New York 270B that was submitted 15 in December of 2011.
16 The NRC Document Processing Center 17 designated these as not publicly available, based on 18 their content review. We have had nothing to do with 19 that. What I would like is that by the time, you 20 know, by January 7th, when we hear about the other 21 exhibits, if you can't get back to us before then, 22 certainly by then, just let us know from the 23 standpoint of the parties, whether or not you have any 24 need for those documents to remain not publicly 25 available. Mr. Sipos?
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4204 1 MR. SIPOS: Your Honor, maybe I could 2 accelerate the process somewhat. Ms. Manzi and I have 3 looked at New York State 270B during the lunch break.
4 That is a document that Entergy produced as a publicly 5 available document to us, I believe in the latter part 6 of 2009, early 2010.
7 And it was given to the State of New York 8 without any restrictions. I would note that part-way 9 through the document, there appears to be a header 10 that says something along the lines of "Attorney Work 11 Product." But that is a document that the state has 12 had for three years, without any restriction.
13 So, and this was actually the MACCS. I 14 believe this was the part of the MACCS 2009 15 reanalysis, that gave rise to certain contentions and 16 has been discussed in various public submissions.
17 So as to that document, from the State of 18 New York's perspective at least, there would not be, 19 again from the state's perspective, any reason that 20 that document would not be publicly available, or 21 should not be publicly available, I should say.
22 JUDGE McDADE: Okay, thank you, and form 23 Entergy's standpoint, can you state at this point 24 whether or not either Entergy 41 or New York 270B 25 should be treated confidentially by the Board, that we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4205 1 should prevent public disclosure?
2 MR. FAGG: I think we're going to have to 3 take a look at the one Mr. Sipos was just describing.
4 I don't have it in front of me right now.
5 JUDGE McDADE: And again, if you could by 6 the January 7th date --
7 MR. FAGG: Certainly, we'll do that.
8 JUDGE McDADE: Just give us a note in a 9 letter, you know, of whether or not you feel a need 10 for us to maintain that as a non-publicly disclosed 11 document. The next thing has to with scheduling.
12 We're going to start tomorrow morning at eight o'clock 13 with regard to the testimony on New York 8.
14 It is often difficult for the Board to 15 determine how long our inquiry is going to last, 16 because we know what we're going to ask, but we don't 17 know what's going to get answered.
18 As far as scheduling goes, the hotel would 19 like very much for us to be able to start breaking 20 down by the early afternoon on Friday. We will have 21 a much better idea by the time we close tomorrow, as 22 to how much we will have left on Friday.
23 But a question that I have is if in order 24 to accommodate our -- and hosts; since we're paying, 25 I don't know it's a good term, but to accommodate our NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4206 1 hosts, if we were to start even earlier on Friday, if 2 we view that necessary, say at seven o'clock, if you 3 could let us know whether or not that would pose 4 particular issues, problems for either counsel or 5 their witnesses.
6 You don't need to answer -- if you know 7 now, Ms. Sutton, that's fine.
8 MS. SUTTON: We'll be ready to go at 9 seven, Your Honor.
10 JUDGE McDADE: Okay.
11 MR. SIPOS: And Your Honor, I was 12 wondering if I could come at in a slightly different 13 angle. Does the Board have an idea of how long it 14 might have questions? I mean would it be possible, 15 instead of starting at seven on Friday, to perhaps go 16 later tomorrow?
17 JUDGE McDADE: The answer is I don't know, 18 and here's basically the thing, you know. If doing a 19 little bit later on Thursday will get this whole thing 20 done, then we'd be predisposed to go a little bit 21 later on Thursday.
22 On the other hand, if at our normal 23 breaking point of approximately, between 5:00 and 6:00 24 on Thursday, we feel we still have another three or 25 four hours to go, then you know, just to, at a certain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4207 1 point, you know, perhaps you've noticed the Board 2 getting less coherent as the day goes on.
3 So if we intended to move forward and keep 4 going, starting at eight in the morning and be still 5 going at nine or ten at night, you know, it might not 6 be a useful exercise.
7 So you know, we're going to play it by 8 ear. If we could finish it tomorrow, that would be 9 great. But you know, we're not going to go well into 10 the night, in order to accomplish that. So I just 11 wanted to raise it as a possibility with the parties, 12 you know, with witnesses getting here. I don't know 13 where they commute from, you know, and the commuting 14 in this area.
15 But I just wanted to raise that as a 16 possibility, of perhaps, and again, it just falls in 17 the "perhaps" category, of starting even a little bit 18 earlier on Friday, if that would mean we could 19 definitely get out of here in the early, by the very 20 early afternoon on Friday.
21 JUDGE WARDWELL: Saying it another way, 22 I'd just like to add that if we're going to put an 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> extra into the system, it really has to be in the 24 morning on Friday rather than in the evening of 25 Thursday, because of the durability of these old folks NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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4208 1 at the bench.
2 MR. SIPOS: I assume you're talking about 3 all of us, Your Honor.
4 JUDGE WARDWELL: If it was a G proceeding, 5 where we could sit back and listen to the questions 6 and answers, it would be a different situation.
7 MR. SIPOS: It's all part of aging 8 management.
9 JUDGE WARDWELL: It is very, very much so.
10 You nailed it perfectly. We have a very poor aging 11 management program up here.
12 JUDGE McDADE: Okay. I think that's how 13 -- I want to thank the witnesses very much. You've 14 been very helpful for us, in taking a look at these 15 particular issues.
16 I really appreciate the testimony you've 17 given, your candor and your insight into the issues.
18 Thank you very much. We are then in recess until 19 eight o'clock tomorrow morning. Thank you.
20 (Whereupon, at 2:43 p.m., the hearing was 21 recessed, to reconvene on Thursday, December 13, 2012 22 at 8:00 a.m.)
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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.
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(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com