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Category:Legal-Pre-Filed Testimony
MONTHYEARML20043E1212020-02-12012 February 2020
Declaration of Warren K. Brewer in Support of New York Petition
ML20043E1222020-02-12012 February 2020
Declaration of Daniel J. Evans in Support of New York Petition
ML20043E1262020-02-12012 February 2020
Declaration of Timothy B. Rice in Support of New York Petition
ML20043E1282020-02-12012 February 2020
Declaration of Chiara Trabucchi in Support of New York Petition
ML20043E1252020-02-10010 February 2020
Declaration of Alyse L. Peterson in Support of New York Petition
ML20043E1232020-02-0505 February 2020
Declaration of George W. Heitzman in Support of New York Petition
ML16064A5142016-03-0404 March 2016
NYS Non-Public Supplemental Written Testimony of Richard Lahey - Certificate of Service
ML16064A5122016-03-0404 March 2016
NYS000590 - NYS Supplemental Written Testimony of Richard Lahey - Public
ML16064A5112016-03-0404 March 2016
NYS Supplemental Written Testimony - Cover Letter
ML16064A5132016-03-0404 March 2016
NYS Supp Written Testimony - Certificate of Service - Public
ML15302A4602015-10-29029 October 2015
ENT000722 - Supplemental Testimony of Entergy Witnesses Nelson Azevedo, Timothy Griesbach & Randy Lott
ML15266A5442015-09-23023 September 2015
NYS000576 - Pre-Filed Supplemental Testimony of Richard T. Lahey Re Contentions NYS-25, NYS-26B/RK-TC-1B & NYS-38/RK-TC-5
ML15252A5742015-09-0909 September 2015
NYS000572 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015)
ML15252A5732015-09-0909 September 2015
NYS000571 - Pre-filed Supplemental Reply Testimony of David J. Duquette in Support of Contention NYS-38/RK-TC-5 (Public, Redacted) (September 9, 2015)
ML15252A5052015-09-0909 September 2015
NYS000569 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-26B/RK-TC-1B (Public, Redacted) (September 9, 2015)
ML15252A5032015-09-0909 September 2015
NYS00567 - Pre-filed Supplemental Reply Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-25 (Public, Redacted) (September 9, 2015)
ML15261A8352015-08-10010 August 2015
ENT000699 - Redacted Revised Testimony of Entergy Witnesses Nelson F. Azevedo, Robert J. Dolansky, Alan B. Cox, Jack R. Strosnider, Timothy J. Griesbach, Barry M. Gordon, Randy G. Lott, and Mark A. Gray Regarding Contention NYS-38/RK-TC-5..
ML15223A6732015-08-10010 August 2015
NRCR00161 - NRC Staff Testimony of Dr. Allen L. Hiser and Mr. Kenneth J. Karwoski Concerning Portions of State of New York and Riverkeeper, Inc. Joint Contention NYS-38/RK-TC5 (Revised)
ML15261A8332015-08-10010 August 2015
ENT000679 - Redacted Revised Testimony of Entergy Witnesses Nelson F. Azevedo, Alan B. Cox, Jack R. Strosnider, Randy G. Lott, Mark A. Gray, and Barry M. Gordon Regarding Contention NYS-26B/RK-TC-1B (Metal Fatigue) (Aug. 10, 2015)
ML15261A8312015-08-10010 August 2015
ENT000616 - Testimony of Entergy Witnesses Nelson F. Azevedo, Robert J. Dolansky, Alan B. Cox, Jack R. Strosnider, Timothy J. Griesbach, Randy G. Lott, and Mark A. Gray Regarding Contention NYS-25 (Embrittlement) (Aug. 10, 2015)
ML15223B0022015-08-10010 August 2015
NRC000168 - NRC Staff Testimony of Dr. Allen Hiser, Dr. Ching Ng, Mr. Gary Stevens, P.E., and Mr. on Yee, Concerning Contentions NYS-26B/RK-TC-1B and NYS-38/RK-TC-5
ML15223A7892015-08-10010 August 2015
NRC000197 - NRC Staff Testimony of Dr. Allen Hiser, Jeffrey Poehler, and Gary Stevens on NYS-25 and NYS-38/RK-TC-5
ML15161A3092015-06-0909 June 2015
NYS000530 - Revised Pre-filed Written Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-26B/RK-TC-1B (Public, Redacted) (June 2, 2015)
ML15161A3012015-06-0909 June 2015
NYS000482 - Revised Pre-filed Written Testimony of Richard T. Lahey, Jr. in Support of Contention NYS-25 (Public, Redacted) (June 2, 2015)
ML15161A2082015-06-0909 June 2015
RIV000143 - Supplemental Prefiled Written Testimony of Dr. Joram Hopenfeld Regarding Contention NYS-38/RK-TC-5
ML15161A2072015-06-0909 June 2015
RIV000142 - Supplemental Prefiled Written Testimony of Dr. Joram Hopenfeld Regarding Contention NYS-26B/RK-TC-1B
ML15161A3112015-06-0909 June 2015
NYS000562 - Revised Pre-filed Testimony of Dr. Richard T. Lahey, Jr. in Support of Joint Contention NYS-38/Rk-TC-5 (June 9, 2015) (Public, Redacted)
ML15163A1542015-06-0808 June 2015
NYS000532 - Pre-filled Written Supplemental Testimony of Dr. David J. Duquette Regarding Contention NYS-38/RK-TC-5
ML12342A4052012-12-0707 December 2012
NRC Staff Pre-filed Hearing Exhibit NRCR20016, NRC Staffs Testimony of Kimberly J. Green and William C. Holston Concerning Contention NYS-5 (Buried Pipes and Tanks) (Revised)
ML12341A1782012-12-0606 December 2012
Entergy Revised Pre-filed Evidentiary Hearing Exhibit ENTR30373, Testimony of Applicant Witnesses Alan Cox, Ted Ivy, Nelson Azevedo, Robert Lee, Stephen Biagiotti, and Jon Cavallo Concerning NYS-5 (Buried Piping and Tanks)
ML12338A6762012-12-0202 December 2012
New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000467, Written Supplemental Rebuttal Testimony of Stephen C. Sheppard Regarding Contention NYS-17B
ML12326A9842012-11-21021 November 2012
Entergy Pre-filed Evidentiary Hearing Exhibit ENT000592, Supplemental Testimony of Entergy Witness George S. Tolley Regarding Contention NYS-17b (Property Values)
ML12286A0852012-10-12012 October 2012
Entergy Pre-Filed Hearing Exhibit ENTR00029, Testimony of Entergy Witnesses Ian D. Mew, Alan B. Cox, Nelson F. Azevedo, Jeffrey S. Horowitz, and Robert M. Aleksick Regarding Contention RK-TC-2 (Flow-Accelerated Corrosion)
ML12283A4732012-10-0909 October 2012
NRC Staff Exhibit NRCR00081, NRC Staff'S Testimony of Jeffrey J. Rikhoff, Andrew L. Stuyvenberg, and John P. Boska Concerning Contentions NYS-17, 17A and 17B (Land Use) (Revised)
ML12283A4572012-10-0909 October 2012
Entergy Pre-Filed Evidentiary Hearing Exhibit ENTR20373 Testimony of Entergy Witnesses Alan Cox, Ted Ivy, Nelson Azevedo, Robert Lee, Stephen Biagiotti, and Jon Cavallo Concerning Contention NYS-5 (Buried Piping and Tanks)
ML12290A2422012-10-0505 October 2012
State of New York (NYS) Revised Pre-filed Evidentiary Hearing Exhibit NYSR20399, Pre-filed Rebuttal Testimony of Dr. David J. Duquette in Support of Contention NYS-5 (Jun. 6, 2012)
ML12279A2612012-10-0505 October 2012
Pre-Filed Written Rebuttal Testimony of Dr. David J. Duquette Regarding Contention NYS-5 - Revised
ML12265A4132012-09-21021 September 2012
Entergy Pre-Filed Evidentiary Hearing Exhibit ENTR00233, Testimony of Entergy Witnesses Alan B. Cox, Roger B. Rucker, Thomas S. Mccaffrey and Howard G. Sedding Concerning Contentions NYS-6/NYS-7 (Non-EQ Inaccessible Medium and Low Voltage C
ML12233A6842012-08-20020 August 2012
NRC Pre-Filed Evidentiary Hearing Exhibit NRC000161,Testimony of Dr. Allen L. Hiser and Mr. Kenneth J. Karowoski Concerning Portions of Joint Contention NYS-38/RK-TC5
ML12233A6732012-08-20020 August 2012
NRC Staff Pre-Filed Hearing Testimony NRC000148, NRC Staff'S Testimony of Dr. Allen L Hiser, Mr. on Yee, and Dr. Ching Ng Concerning Portions of Contention NYS-38
ML12184A2342012-06-29029 June 2012
New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000404, Pre-filed Rebuttal Testimony of Stephen C. Sheppard in Support of Contention NYS-16B (Jun. 29, 2012)
ML12184A1672012-06-29029 June 2012
New York State (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000241, Pre-Filed Written Rebuttal Testimony of Dr. Francios J. Lemay Regarding Consolidated Contention NYS-12C (NYS-12/12A/12N=B/12C)
ML12181A4992012-06-29029 June 2012
New York State (NYS) Pre-Filed Evidentiary Exhibit NYS000414, Rebuttal Testimony of Dr. Robert C. Degeneff, D. Eng
ML12181A4672012-06-29029 June 2012
State of New York (NYS) Pre-Filed Evidentiary Hearing Exhibit NYS000437, Pre-Filed Written Rebuttal Testimony of David A. Schlissel Regarding Contention NYS-37
ML12181A3712012-06-29029 June 2012
Riverkeeper Pre-Filed Testimony RIV000108, Prefiled Rebuttal Testimony of Dr. Joram Hopenfeld Regarding Riverkeeper Contention TC-2- Flow Accelerated Corrosion
ML12180A6432012-06-28028 June 2012
Intervenor Pre-File Evidentiary Hearing Exhibit CLE000045, Rebuttal Statement Supporting Contention EC-3A Regarding Environmental Justice
ML12180A6442012-06-28028 June 2012
Intervenor Pre-File Evidentiary Hearing Exhibit - Certificate of Service for Listed Documents
ML12180A6452012-06-28028 June 2012
Intervenor Pre-File Evidentiary Hearing Exhibit CLE000046, Rebuttal Testimony of Manna Jo Greene Regarding Clearwaters Environmental Justice Contention EC-3A
ML12180A6462012-06-28028 June 2012
Intervenor Pre-File Evidentiary Hearing Exhibit CLE000047, Rebuttal Testimony of Dr. Michael Edelstein Regarding Clearwaters Environmental Justice Contention EC-3A
ML12180A6472012-06-28028 June 2012
Intervenor Pre-File Evidentiary Hearing Exhibit CLE000048, Rebuttal Testimony of Dr. Andrew Kanter Regarding Clearwaters Environmental Justice Contention EC-3A
2020-02-05
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Text
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 1 UNITED STATES 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 -----------------------------------x 5 In re: Docket Nos. 50-247-LR; 50-286-LR 6 License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 7 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 8 Entergy Nuclear Indian Point 3, LLC, and 9 Entergy Nuclear Operations, Inc. September 9, 2015 10 -----------------------------------x 11 PRE-FILED SUPPLEMENTAL REPLY WRITTEN TESTIMONY OF 12 DR. RICHARD T. LAHEY, JR.
13 REGARDING CONTENTION NYS-38 14 On behalf of the State of New York (NYS or the State),
15 the Office of the Attorney General hereby submits the following 16 testimony by RICHARD T. LAHEY, JR., PhD. regarding Contention 17 NYS-38/RK-TC-5.
18 Q. Please state your full name.
19 A. Richard T. Lahey, Jr.
20 Q. By whom are you employed and what is your position?
21 A. I am retired and am currently the Edward E. Hood 22 Professor Emeritus of Engineering at Rensselaer Polytechnic 23 Institute (RPI), which is located in Troy, New York.
Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 1
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 1 Q. Have you previously summarized your educational and 2 professional qualifications?
3 A. Yes, my education and professional qualifications and 4 experience are described in my Curricula Vitae and previously 5 filed testimony in this proceeding.
6 Q. I show you what has been marked as Exhibit ENT000699.
7 Do you recognize that document?
8 A. Yes. It is a copy of the pre-filed testimony of the 9 witnesses for Entergy on Contention NYS-38/RK-TC-5 that were 10 submitted in August 2015.
11 Q. I show you what has been marked as Exhibit NRCR000161, 12 NRC000197 and NRC000168. Do you recognize those documents?
13 A. Yes. They are copies of the pre-filed testimony of 14 the USNRC Staff witness that were submitted in August 2015. They 15 concern Contention NYS-38/RK-TC-5. I note that NRC000168 and 16 NRC000197 primarily discuss Contentions NYS-25 and NYS-26B/RK-17 TC-1B.
18 Q. Have you had an opportunity to review ENT000699, 19 NRCR000161, NRC000168, and NRC000197?
20 A. Yes.
21 Q. Has Entergys and the USNRC Staffs August pre-filed 22 testimony caused you to change the testimony and opinions that Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 2
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 1 you have previously submitted in this proceeding in connection 2 with Contention NYS-38?
3 A. In general, no. Entergy and the USNRC Staff have 4 failed to resolve the age-related safety concerns that I have 5 raised throughout this proceeding. They continue to approach 6 various aging mechanisms in silos, without addressing the 7 potential synergistic interactions between multiple degradation 8 mechanisms. While Entergy has proposed a reactor vessel 9 internals (RVIs) aging management program based on MRP-227-A, 10 that program is fundamentally flawed due to its failure to 11 consider the potential synergism between irradiation 12 embrittlement and other aging degradation mechanisms and the 13 impact of various significant shock loads on highly-embrittled 14 and fatigue-weakened components. Entergys RVI Program also 15 lacks sufficient detail on issues relating to inspection 16 techniques and acceptance criteria. Entergy and Westinghouse 17 have presented to the USNRC final, revised cumulative usage 18 factors (CUFen) for various components; however, those values 19 were obtained using a flawed metal fatigue evaluation process in 20 which the level of conservatisms, if any, is unclear (i.e., see 21 my most recent testimony on contention NYS-26B (NYS000569).
22 Entergy has confirmed that, despite its prior commitment to 23 address potential primary water stress corrosion cracking in Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 3
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 1 steam generator components, it is now considering reliance on 2 industry-funded analysis of the problem rather than the 3 performance of actual inspections. I have discussed these 4 deficiencies in Entergys analyses in my prior testimony of June 5 9, 2015 (NYS000562) and in my most recent testimony relating to 6 Contentions NYS-25 and NYS-26B/RK-TC-1B (NYS000567, NYS000569),
7 both of which I incorporate by reference and am supplementing 8 today.
9 Q. With respect to steam generators, Entergy states that 10 it has analyzed in detail the impact of thermal and pressure 11 shock loads on a degraded divider plate. (A196) Do you agree?
12 A. No. In support of that claim, Entergy cites to the 22 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 4
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 1 (ENT000683). Thus, its integrity for such loads during the 2 period of extended operations remains unclear.
3 Q. Entergy also states that any reduction in a steam 4 generators heat removal capability caused by a cracked divider 5 plate would be negligible or insignificant. Entergy 6 Testimony at A197 (ENT000699). Would you agree?
7 A. Again, the problem is that Entergy has not applied the 8 correct shock pressure loading across the crack-weakened steam 9 generators divider plate using an appropriate shock code. A 10 proper evaluation must consider LOCAs, such as the DBA LOCA for 11 a very large pipe break on the primary side. However, it must 12 also take into account severe LOCAs which can occur on the 13 secondary side (e.g., a steam line break and subsequent SCRAM) 14 that can lead to significant thermal shocks on the primary side.
15 To be clear, I am concerned with all LOCA-type events that can 16 lead to significant pressure and/or thermal shocks on the divider plate.
22 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 5
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 2
3 Q. Finally, Entergy asserts that cracks will not initiate 4 or propagate from the tubesheet cladding to tube-to-tubesheet 5 welds due to compressive forces in that area. Entergy Testimony 6 at A199 (ENT000699). Do you agree?
A. No, I do not agree.
20 It 21 therefore continues to be my opinion that Entergy must perform 22 inspections of the steam generator channel head assembly, 23 including the divider plate and tube-to-tubesheet welds, prior Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 6
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 1 to entering the period of extended operation (or as soon 2 thereafter, for IP2), as a condition of license renewal.
3 Q. Does this complete your testimony?
4 A. Yes, it does. I do, however, reserve the right to 5 supplement my testimony if new information is disclosed or 6 introduced.
7 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 7
NYS000572 (Public, Redacted)
Submitted: September 9, 2015 1 UNITED STATES 2 NUCLEAR REGULATORY COMMISSION 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4 -----------------------------------x 5 In re: Docket Nos. 50-247-LR; 50-286-LR 6 License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 7 Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 8 Entergy Nuclear Indian Point 3, LLC, and 9 Entergy Nuclear Operations, Inc. September 9, 2015 10 -----------------------------------x 11 DECLARATION OF RICHARD T. LAHEY, JR.
12 I, Richard T. Lahey, Jr., do hereby declare under penalty 13 of perjury that my statements in the foregoing testimony and my 14 statement of professional qualifications are true and correct to 15 the best of my knowledge and belief.
16 Executed in Accord with 10 C.F.R. § 2.304(d) 17 18 ________________________
19 Dr. Richard T. Lahey, Jr.
20 The Edward E. Hood Professor Emeritus of Engineering 21 Rensselaer Polytechnic Institute, Troy, NY 12180 22 (518) 495-3884, laheyr@rpi.edu Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 8
