ML15252A574
| ML15252A574 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/09/2015 |
| From: | Lahey R Rensselaer Polytechnic Institute, State of NY, Office of the Attorney General |
| To: | Atomic Safety and Licensing Board Panel |
| SECY RAS | |
| References | |
| RAS 28274, ASLBP 07-858-03-LR-BD01, 50-247-LR, 50-286-LR | |
| Download: ML15252A574 (8) | |
Text
UNITED STATES 1
NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
x 4
In re:
Docket Nos. 50-247-LR; 50-286-LR 5
License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6
Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7
Entergy Nuclear Indian Point 3, LLC, and 8
Entergy Nuclear Operations, Inc.
September 9, 2015 9
x 10 PRE-FILED SUPPLEMENTAL REPLY WRITTEN TESTIMONY OF 11 DR. RICHARD T. LAHEY, JR.
12 REGARDING CONTENTION NYS-38 13 On behalf of the State of New York (NYS or the State),
14 the Office of the Attorney General hereby submits the following 15 testimony by RICHARD T. LAHEY, JR., PhD. regarding Contention 16 NYS-38/RK-TC-5.
17 Q.
Please state your full name.
18 A.
Richard T. Lahey, Jr.
19 Q.
By whom are you employed and what is your position?
20 A.
I am retired and am currently the Edward E. Hood 21 Professor Emeritus of Engineering at Rensselaer Polytechnic 22 Institute (RPI), which is located in Troy, New York.
23 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 1
NYS000572 (Public, Redacted)
Submitted: September 9, 2015
Q.
Have you previously summarized your educational and 1
professional qualifications?
2 A.
Yes, my education and professional qualifications and 3
experience are described in my Curricula Vitae and previously 4
filed testimony in this proceeding.
5 Q.
I show you what has been marked as Exhibit ENT000699.
6 Do you recognize that document?
7 A.
Yes. It is a copy of the pre-filed testimony of the 8
witnesses for Entergy on Contention NYS-38/RK-TC-5 that were 9
submitted in August 2015.
10 Q.
I show you what has been marked as Exhibit NRCR000161, 11 NRC000197 and NRC000168. Do you recognize those documents?
12 A.
Yes. They are copies of the pre-filed testimony of 13 the USNRC Staff witness that were submitted in August 2015. They 14 concern Contention NYS-38/RK-TC-5. I note that NRC000168 and 15 NRC000197 primarily discuss Contentions NYS-25 and NYS-26B/RK-16 TC-1B.
17 Q.
Have you had an opportunity to review ENT000699, 18 NRCR000161, NRC000168, and NRC000197?
19 A.
Yes.
20 Q.
Has Entergys and the USNRC Staffs August pre-filed 21 testimony caused you to change the testimony and opinions that 22 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 2
NYS000572 (Public, Redacted)
Submitted: September 9, 2015
you have previously submitted in this proceeding in connection 1
with Contention NYS-38?
2 A.
In general, no. Entergy and the USNRC Staff have 3
failed to resolve the age-related safety concerns that I have 4
raised throughout this proceeding. They continue to approach 5
various aging mechanisms in silos, without addressing the 6
potential synergistic interactions between multiple degradation 7
mechanisms. While Entergy has proposed a reactor vessel 8
internals (RVIs) aging management program based on MRP-227-A, 9
that program is fundamentally flawed due to its failure to 10 consider the potential synergism between irradiation 11 embrittlement and other aging degradation mechanisms and the 12 impact of various significant shock loads on highly-embrittled 13 and fatigue-weakened components. Entergys RVI Program also 14 lacks sufficient detail on issues relating to inspection 15 techniques and acceptance criteria. Entergy and Westinghouse 16 have presented to the USNRC final, revised cumulative usage 17 factors (CUFen) for various components; however, those values 18 were obtained using a flawed metal fatigue evaluation process in 19 which the level of conservatisms, if any, is unclear (i.e., see 20 my most recent testimony on contention NYS-26B (NYS000569).
21 Entergy has confirmed that, despite its prior commitment to 22 address potential primary water stress corrosion cracking in 23 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 3
NYS000572 (Public, Redacted)
Submitted: September 9, 2015
steam generator components, it is now considering reliance on 1
industry-funded analysis of the problem rather than the 2
performance of actual inspections. I have discussed these 3
deficiencies in Entergys analyses in my prior testimony of June 4
9, 2015 (NYS000562) and in my most recent testimony relating to 5
Contentions NYS-25 and NYS-26B/RK-TC-1B (NYS000567, NYS000569),
6 both of which I incorporate by reference and am supplementing 7
today.
8 Q.
With respect to steam generators, Entergy states that 9
it has analyzed in detail the impact of thermal and pressure 10 shock loads on a degraded divider plate. (A196) Do you agree?
11 A.
No. In support of that claim, Entergy cites to the 12 22 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 4
NYS000572 (Public, Redacted)
Submitted: September 9, 2015
(ENT000683). Thus, its integrity for such loads during the 1
period of extended operations remains unclear.
2 Q.
Entergy also states that any reduction in a steam 3
generators heat removal capability caused by a cracked divider 4
plate would be negligible or insignificant. Entergy 5
Testimony at A197 (ENT000699). Would you agree?
6 A.
Again, the problem is that Entergy has not applied the 7
correct shock pressure loading across the crack-weakened steam 8
generators divider plate using an appropriate shock code. A 9
proper evaluation must consider LOCAs, such as the DBA LOCA for 10 a very large pipe break on the primary side. However, it must 11 also take into account severe LOCAs which can occur on the 12 secondary side (e.g., a steam line break and subsequent SCRAM) 13 that can lead to significant thermal shocks on the primary side.
14 To be clear, I am concerned with all LOCA-type events that can 15 lead to significant pressure and/or thermal shocks on the 16 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 Q.
Finally, Entergy asserts that cracks will not initiate 3
or propagate from the tubesheet cladding to tube-to-tubesheet 4
welds due to compressive forces in that area. Entergy Testimony 5
at A199 (ENT000699). Do you agree?
6 A.
No, I do not agree.
It 20 therefore continues to be my opinion that Entergy must perform 21 inspections of the steam generator channel head assembly, 22 including the divider plate and tube-to-tubesheet welds, prior 23 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 6
NYS000572 (Public, Redacted)
Submitted: September 9, 2015
to entering the period of extended operation (or as soon 1
thereafter, for IP2), as a condition of license renewal.
2 Q. Does this complete your testimony?
3 A. Yes, it does. I do, however, reserve the right to 4
supplement my testimony if new information is disclosed or 5
introduced.
6 7
Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 7
NYS000572 (Public, Redacted)
Submitted: September 9, 2015
UNITED STATES 1
NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 3
x 4
In re:
Docket Nos. 50-247-LR; 50-286-LR 5
License Renewal Application Submitted by ASLBP No. 07-858-03-LR-BD01 6
Entergy Nuclear Indian Point 2, LLC, DPR-26, DPR-64 7
Entergy Nuclear Indian Point 3, LLC, and 8
Entergy Nuclear Operations, Inc.
September 9, 2015 9
x 10 DECLARATION OF RICHARD T. LAHEY, JR.
11 I, Richard T. Lahey, Jr., do hereby declare under penalty 12 of perjury that my statements in the foregoing testimony and my 13 statement of professional qualifications are true and correct to 14 the best of my knowledge and belief.
15 Executed in Accord with 10 C.F.R. § 2.304(d) 16 17 18 Dr. Richard T. Lahey, Jr.
19 The Edward E. Hood Professor Emeritus of Engineering 20 Rensselaer Polytechnic Institute, Troy, NY 12180 21 (518) 495-3884, laheyr@rpi.edu 22 Pre-filed Supplemental Reply Written Testimony of Richard T. Lahey, Jr.
Contention NYS-38 8
NYS000572 (Public, Redacted)
Submitted: September 9, 2015