ML15336B014
| ML15336B014 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/18/2015 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| SECY RAS | |
| References | |
| 50-247-LR, 50-286-LR, ASLBP 07-858-03-LR-BD01, NRC-2016, RAS 28606 | |
| Download: ML15336B014 (355) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Station Open Session Docket Number: 50-247-LR and 50-286-LR ASLBP Number: 07-858-03-LR-BD01 Location: Tarrytown, New York Date: Wednesday, November 18, 2015 Work Order No.: NRC-2016 Pages 5322-5675 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
5322 1 UNITED STATES OF AMERICA 2 U.S. NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5 + + + + +
6 OPEN SESSION 7 ________________________________
8 In the Matter of: : Docket No.
9 ENTERGY NUCLEAR OPERATIONS, INC. : 50-247-LR 10 (Indian Point Nuclear Generating : 50-286-LR 11 Station, Units 2 and 3) : ASLBP No.
12 ________________________________ : 07-858-03-LR-BD01 13 Wednesday, November 18, 2015 14 15 Doubletree Tarrytown 16 Westchester Ballroom 17 455 South Broadway 18 Tarrytown, New York 19 20 21 BEFORE:
22 LAWRENCE G. MCDADE, Chairman 23 MICHAEL F. KENNEDY, Administrative Judge 24 RICHARD E. WARDWELL, Administrative Judge 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5323 1 APPEARANCES:
2 On Behalf of the U.S. Nuclear Regulatory 3 Commission:
4 DAVID E. ROTH, ESQ.
5 SHERWIN E. TURK, ESQ.
6 BRIAN HARRIS, ESQ.
7 of: U.S. Nuclear Regulatory Commission 8 Office of General Counsel 9 Mail Stop 15 D21 10 Washington, D.C. 20555 11 david.roth@nrc.gov 12 sherwin.turk@nrc.gov 13 brian.harris@nrc.gov 14 301-415-2749 (Roth) 15 301-415-1533 (Turk) 16 301-415-1392 (Harris) 17 18 On Behalf of Entergy Nuclear Operations, Inc.:
19 KATHRYN M. SUTTON, ESQ.
20 PAUL M. BESSETTE, ESQ.
21 RAPHAEL "RAY" KUYLER, ESQ.
22 of: Morgan, Lewis & Brockius, LLP 23 1111 Pennsylvania Avenue, N.W.
24 Washington, D.C. 20004 25 202-739-5738 (Sutton)
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5324 1 202-739-5796 (Bessette) 2 202-739-5146 (Kuyler) 3 ksutton@morganlewis.com 4 pbessette@morganlewis.com 5 rkuyler@morganlewis.com 6
7 On Behalf of the State of New York:
8 JOHN J. SIPOS, ESQ.
9 LISA S. KWONG, ESQ.
10 MIHIR A. DESAI, ESQ.
11 of: New York State 12 Office of the Attorney General 13 Environmental Protection Bureau 14 The Capitol 15 Albany, New York 12224 16 brian.lusignan@ag.ny.gov 17 18 On Behalf of Riverkeeper Inc.:
19 DEBORAH BRANCATO, ESQ.
20 of: Riverkeeper, Inc.
21 20 Secor Road 22 Ossining, New York 10562 23 800-21-RIVER 24 info@riverkeeper.org 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5325 1 On Behalf of Westchester County:
2 CHRISTOPHER INZERO, ESQ.
3 Assistant County Attorney 4 of: Westchester County Government 5 148 Martine Avenue 6 Room 600 7 White Plains, New York 10601 8 914-995-2000 9
10 On Behalf of Westinghouse Electric Company:
11 RICHARD J. COLDREN, ESQ.
12 of: Westinghouse Electric Company 13 1000 Westinghouse Drive 14 Cranberry Township, Pennsylvania 16066 15 412-374-6645 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5326 1 TABLE OF CONTENTS 2 Witness Swearing In 3 by Judge Lawrence McDade, Chair . . . 5328 4 Answers to Previous Day's Questions 5 by Judge Lawrence McDade, Chair . . . 5329 6 Contention 26 7 by Judge Michael Kennedy, ASLBP . . . 5360 8 Afternoon Break 9 by Judge Lawrence McDade, Chair . . . 5505 10 Closed Session . . . . . . . . . . 5505 - 5595 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5327 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:34 a.m.)
3 CHAIRMAN MCDADE: Okay. The hearing 4 will come to order. The first order of business, 5 I believe we have some witnesses for 26 who were 6 not witnesses on 25. Do we have anyone here who 7 has not yet been sworn in who is going to be 8 proffered on 26?
9 MR. ROTH: Yes, Your Honor. We do.
10 CHAIRMAN MCDADE: Are you going to 11 move over to the witness tables?
12 MS. BRANCATO: Your Honor, this is 13 Deborah Brancato from Riverkeeper. Would you 14 like Dr. Hopenfeld to go over into the witness 15 table, too?
16 CHAIRMAN MCDADE: Next to Dr. Lahey, 17 Dr. Hopenfeld. Okay. And Dr. Hopenfeld was 18 sworn on Monday, so he doesn't need to be sworn 19 again. He's still under oath. The two new 20 witnesses --
21 MR. HARRIS: Your Honor, Brian Harris, 22 NRC. Do you want to swear the witness for 38 in 23 also at this time?
24 CHAIRMAN MCDADE: I mean we're not 25 going to be getting to 38 today, but we might as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5328 1 well.
2 MR. SIPOS: Judge McDade?
3 CHAIRMAN MCDADE: Yes.
4 MR. SIPOS: John Sipos for the State 5 of New York. Just to note, Dr. Duquette is not 6 yet present, but we do expect him.
7 CHAIRMAN MCDADE: Right, and before 8 Dr. Duquette begins to testify on 38, we will 9 swear him in. The new witnesses, would you 10 please identify yourself, your name and your 11 short job title and who you represent. Mr. Yee?
12 MR. YEE: On Yee, U.S. NRC, Reactor 13 Systems Engineer with NRC.
14 MR. NG: Ching Ng with the NRC, 15 Reliability and Risk Analyst.
16 MR. KARWOSKI: Ken Karwoski, Senior 17 Level Advisor for Steam Generators Materials 18 Inspection, NRC.
19 CHAIRMAN MCDADE: Okay. Would you 20 please rise? Would you raise your right hand?
21 Will you swear or affirm subject to the 22 penalties for perjury that the testimony you'll give 23 at this hearing will be the truth, the whole truth, 24 and nothing but the truth?
25 (Chorus of I do.)
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5329 1 CHAIRMAN MCDADE: Okay. Please be 2 seated. Certain things we told the other 3 witnesses, and we'll repeat for you right now.
4 First of all, it's important that we 5 have a record of the proceedings so that if you 6 are answering a question, before you answer the 7 question, state your name.
8 Now if the question is designed 9 directly towards you, so the judge has said Mr.
10 Yee, and then asks the question, you don't need 11 to repeat your name because the court reporter 12 will have it right there in context.
13 But in many instances, we're going to 14 be asking questions that are directed either to 15 the NRC staff or to Entergy or to the 16 interveners, and in which case then the 17 individual who is speaking should state their 18 name before they begin so that the record will 19 reflect which one of the witnesses was actually 20 speaking.
21 The other thing is we do take periodic 22 breaks. If for any reason you feel that you need 23 a break, don't suffer in silence. Let us know, 24 and we can arrange to take a break. Are there 25 any questions before we get started?
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5330 1 MR SIPOS: No questions.
2 CHAIRMAN MCDADE: Okay. There are a 3 few things, administrative matters and some 4 substantive matters that I want to take up before 5 we started.
6 First of all, at the conclusion of 7 yesterday, I asked a question I thought was a 8 simple question that was designed to sort of 9 summarize what had been said over hours of 10 testimony to put it in one place in the record.
11 Perhaps because I was tired, but in 12 any event, I failed miserably and wound up sort 13 of running us down a rabbit warren and wound up 14 confusing things rather than clarifying things.
15 Sort of a quote from the movie Cool 16 Hand Luke, "We had a failure to communicate," and 17 I apologize for that. We were talking about what 18 has been developed and what has still to be 19 developed.
20 And from the testimony, and what I 21 want to do is to sort of summarize a little bit 22 and then make sure from the witnesses, because 23 nothing I say is evidence, that what I'm saying 24 is correct.
25 That we look first of all to MRP-227, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5331 1 which is NRC Exhibit 114. That sets out various 2 inspection aspects. In Sections 4 and 5 of that 3 document, it talks about examination methods, the 4 qualifications for examination, the frequency of 5 examination, sampling and coverage, the expansion 6 based on observed degradation, evaluation of 7 results and flaw evaluation.
8 Specifically in that, it also 9 addresses Westinghouse manufactured plants 10 specifically. They have tables for Westinghouse 11 plants as well as for plants manufactured by 12 other entities.
13 But as part of those tables, they have 14 listed acceptance criteria. Among those 15 acceptance criteria, they have one for the baffle 16 former bolts.
17 But in that particular document, the 18 MRP-227 and specifically the table 5-3, not all 19 of the details with regard to the acceptance 20 criteria for baffle former bolts are specified, 21 that it indicates that for certain plant-22 specific, unit-specific details that they will be 23 established as part of the examination technical 24 justification.
25 Now that was then discussed back and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5332 1 forth between the NRC and Entergy, and it was 2 addressed specifically in Supplement 2 to the 3 SER, which is New York Supplement, excuse me, New 4 York Exhibit 503.
5 And in that, the NRC articulated its 6 position that those specifics, the UT 7 examinations for baffle former bolts have been 8 performed since the 1990s.
9 There's more than 20 years' experience 10 doing that inspections, which provide a 11 reasonable assurance that the examinations can be 12 implemented effectively and that finalizing the 13 TJ closer to the date of the inspection would 14 allow for the latest UT technology and lessons 15 learned for previous inspections to be 16 incorporated.
17 So what remained to be done, which 18 isn't in the original document or in the SER that 19 is in either MPR-227, Exhibit 114 or in the SER, 20 New York Exhibit 507, is the technical 21 justification for the examination.
22 Dr. Hiser, again, nothing I've said is 23 evidence. What I've just gone through, does that 24 accurately reflect the process here?
25 DR. HISER: Yes, I believe it does.
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5333 1 CHAIRMAN MCDADE: Okay. Do you have 2 anything to add to supplement that --
3 DR. HISER: No, I don't.
4 CHAIRMAN MCDADE: -- or to correct it?
5 DR. HISER: No, I do not.
6 CHAIRMAN MCDADE: Okay. And from 7 Entergy, does anybody have anything to supplement 8 or to correct?
9 MR. DOLANSKY: No, Your Honor. This 10 is Bob Dolansky from Entergy. No.
11 CHAIRMAN MCDADE: Okay. So what's 12 left to be done has to do with the technical 13 justification for the inspection, certain plant-14 specific details.
15 Dr. Hiser, could just very briefly 16 just put on the record what the technical 17 justification for examination is, or if someone 18 is better suited to it?
19 MR. POEHLER: This is Jeffrey Poehler, 20 the staff. I can address that. The technical 21 justification would be a report prepared probably 22 by the vendor that's performing, that will 23 perform the ultrasonic examination.
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5334 1 procedures. It would address things like the 2 detectability of flaws, like what's the minimum 3 size flaw you could detect in a bolt, such as for 4 example, 10 percent of wall thickness or 20 5 percent, something like that.
6 CHAIRMAN MCDADE: Okay. And has that 7 technical justification been received by the NRC?
8 MR. POEHLER: No, it has not. It 9 would not be something we would expect to be 10 submitted or require to be submitted.
11 CHAIRMAN MCDADE: Okay. It is 12 required to be prepared no later than six months 13 before the first inspection, but that is a 14 document that would be maintained at the facility 15 subject to inspection by the resident inspector 16 of the NRC. Correct?
17 MR. POEHLER: Correct.
18 CHAIRMAN MCDADE: Okay. And do you 19 agree with that, from Entergy?
20 MR. DOLANSKY: Yes.
21 CHAIRMAN MCDADE: What is the status 22 of the technical justification for the 23 inspection?
24 MR. DOLANSKY: It has been written.
25 This is Bob Dolansky with Entergy. You're asking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5335 1 --
2 CHAIRMAN MCDADE: Yes.
3 MR. DOLANSKY: -- has it been written.
4 Yes.
5 CHAIRMAN MCDADE: Okay. And can you 6 elaborate on the kind of details that are in that 7 document that are unit-specific?
8 MR. DOLANSKY: They talk about the 9 parameters of the, that the NDE inspector would 10 use, how he would set up his equipment, when he 11 does his calibration what type of reflectors he 12 would be looking for from the calibration block, 13 that type of thing.
14 CHAIRMAN MCDADE: Okay. And this is 15 intended, based on the words of the SER, to 16 utilize more recent, the most recent UT 17 technology as well as lessons learned from 18 previous inspections?
19 MR. DOLANSKY: Correct. For instance, 20 the vendor, Westinghouse, typically goes to 21 outages in the spring and fall. That's when 22 outages typically occur.
23 So they would go into outages this 24 past fall, now basically, and anything that came 25 out of those outages, if there any lessons NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5336 1 learned or anything like that, they would 2 incorporate that into the procedure before they 3 give it to us.
4 CHAIRMAN MCDADE: Okay. Judge 5 Wardwell, do you have anything further on that?
6 JUDGE WARDWELL: No, I think it's 7 fine. Thank you.
8 JUDGE KENNEDY: No, I do not.
9 CHAIRMAN MCDADE: Okay. I believe 10 that we had, I believe it was referred to 11 yesterday as sort of homework assignments that we 12 had questions that remained up in the air.
13 There was one, I believe, Dr. Lott.
14 There was a question with regard to the lower 15 support column of whether that was cast material, 16 and were you able to identify any other cast RVI 17 components?
18 DR. LOTT: I realize that question was 19 addressed to me, but I think it might better, and 20 I know this, some of my colleagues on the panel 21 here have been doing some research on that. So 22 I would like to turn it over to Mr. Azevedo.
23 CHAIRMAN MCDADE: Okay, Mr. Azevedo.
24 MR. AZEVEDO: Yes, Your Honor. We 25 looked into this. There's a total of six NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5337 1 components that are reactor vessel internals that 2 are made out of cast material.
3 Two of those six are expansion 4 components, which means they were determined to 5 be moderately susceptible to some form of 6 degradation mechanism. Therefore, they're 7 expansion components.
8 The other four components were 9 screened out as not being susceptible to any 10 degradation mechanism per MRP-191.
11 CHAIRMAN MCDADE: Okay. When you're 12 talking about expansion components, you're going 13 back to Section 4 of MPR-227. Correct, where it 14 lists primary then expansion and based on the 15 susceptibility?
16 MR. AZEVEDO: That's correct.
17 CHAIRMAN MCDADE: Okay. Anything 18 further, Mr. Azevedo, on that?
19 MR. AZEVEDO: No, Your Honor.
20 CHAIRMAN MCDADE: Okay. Dr. Lott, I 21 believe there was a question left for you asking 22 whether or not there was, you could point us to 23 a basis for the statement that low ferrite CASS 24 material would not show a meaningful combined 25 effect from thermal aging and irradiation.
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5338 1 Is there anything you could point to 2 us in support of that proposition?
3 DR. LOTT: Yes. I think that was, the 4 particulars of a question was in relation to 5 Question 8 of our supplemental testimony. And 6 that was really addressed to concerns about 7 embrittlement at or below the threshold for 8 radiation embrittlement materials.
9 So I wasn't trying to, and I don't 10 think we were trying to say anything about higher 11 fluence materials. And there's admittedly very 12 sparse data on this topic.
13 I think the statement itself contains 14 a direct reference to VWR-VIP-2015-025, and that 15 document does talk, I think part of the question 16 was why are we talking about these high ferrite 17 materials when you're telling us it's low ferrite 18 material.
19 That document does site actually a 20 Westinghouse study on a low ferrite, a 10 percent 21 cast material that showed that that material was 22 not subject to the same decrease in embrittlement 23 that the higher cast material say inside 184 24 were.
25 And we believe that, those materials NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5339 1 and that's the basis for our document. We'll 2 notice that the NRC has made similar arguments in 3 their justification for their suggestion of 15 4 percent as a standing level for ferrite material, 5 susceptibility in irradiated materials. And 6 that's in NRC Item 201.
7 CHAIRMAN MCDADE: I'm sorry. It is in 8 what?
9 DR. LOTT: NRC Exhibit 201.
10 CHAIRMAN MCDADE: Okay. And the 11 previous document referred to, do you have an 12 exhibit number for that?
13 MR. SIPOS: I think, Your Honor, it's 14 NRC 209, if I recall Mr. Lott's, Dr. Lott's 15 testimony from yesterday.
16 CHAIRMAN MCDADE: Okay. Thank you, 17 Mr. Sipos.
18 MR. KUYLER: I believe that Dr. Lott 19 was referring to Entergy Exhibit 663, Your Honor.
20 CHAIRMAN MCDADE: Well, we will go and 21 look at both of them. Thank you.
22 Okay. Dr. Lahey, I think we had a 23 question yesterday, and it may or may not have 24 been answered regarding NUREG 7184, New York 25 Exhibit 488. And we're talking about, I think at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5340 1 one point used the word synergistic in another 2 combination.
3 And whether or not there was any 4 evidence that demonstrated that the sum of the 5 thermal embrittlement and irradiation 6 embrittlement is greater than the sum of the 7 parts. Is there any language that you can point 8 us to that would support that proposition?
9 DR. LAHEY: I reviewed, at your 10 request Your Honor, 7184. As I had indicated 11 yesterday, I think, the original language in this 12 report used the work synergistic. And then later 13 on it was changed by the authors to combined.
14 In my view, when I use synergistic I 15 allow for a number of possibilities. I'm not 16 sure what the author allows for. For example, 17 when I use synergistic for a fatigue in 18 radiation, I mean greater than the individual 19 effects.
20 When I use synergistic for thermal and 21 irradiation, I mean combined effects, not 22 necessarily greater than the individual effects.
23 So I can't speak to what the author meant, but 24 they used both at one time.
25 CHAIRMAN MCDADE: Okay. And Dr.
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5341 1 Lahey, I believe there was a question put to you 2 as to whether or not you could identify other RVI 3 components subject to A/LAI 7.
4 DR. LAHEY: Right. Your Honor, I did 5 do a review of a document. It was MRP-191, which 6 carefully went through the various components and 7 the material that they had the radiation fluence 8 that they were subjected to.
9 And as you heard from previous 10 witness, there are a number. The one that 11 appeared to me to be of most concern, other than 12 the one we talked about yesterday, the cap on the 13 lower support plate column is the upper support 14 column base.
15 It has a fluence of around 10 to the 16 21st neutrons per centimeters square. The other 17 ones, at least in my view, didn't seem to be as 18 safety significant as that one might be.
19 CHAIRMAN MCDADE: Okay. Thank you, 20 Dr. Lahey. Judge Wardwell, did that answer your 21 question, or do you wish to follow up?
22 JUDGE WARDWELL: I think I'll follow 23 up with Mr. Azevedo if I might. Was the upper 24 support column base any one of those that you 25 have identified, and was it an expansion or a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5342 1 screened out component?
2 MR. AZEVEDO: Yes, Your Honor. That's 3 one of the six that I mentioned before, and it 4 was screened out as a Category A, which means not 5 susceptible to any degradation mechanisms.
6 JUDGE WARDWELL: Thank you.
7 CHAIRMAN MCDADE: Can you elaborate at 8 all on why it was screened out, the sort of 9 thought process that went on?
10 MR. AZEVEDO: I don't have the details 11 to how each one was screened out?
12 DR. LOTT: Perhaps I could help here.
13 This is Randy Lott --
14 CHAIRMAN MCDADE: Dr. Lott?
15 DR. LOTT: -- Entergy. In the process 16 of the evaluation, those materials were 17 originally identified as cast materials, but 18 there was a step in the process where we did 19 effectively FMECA analysis.
20 It's described in MRP-191, to look at 21 what the impact of these degradation mechanisms 22 were. There were certain components, including 23 the upper support columns, where it was 24 effectively decided that there was no credible 25 damage in impact or need to do additional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5343 1 analysis on the upper support columns.
2 And they were put into Category A. So 3 it was recognized there were cast materials, but 4 it was also felt that there were no stressors 5 that would challenge that particular component.
6 It was an engineering evaluation. I 7 can't speak to the details of it here, but I know 8 that that process is described in MRP-191.
9 CHAIRMAN MCDADE: Okay. Dr. Lahey, do 10 you wish to comment on the appropriateness of 11 that screening as explained by Dr. Lott?
12 DR. LAHEY: No, I understand what he 13 said, and it has to do with the criterion that 14 has been established for the onset of significant 15 radiation damage.
16 CHAIRMAN MCDADE: Okay. Yesterday I 17 believe there was a question to you, Dr. Lahey, 18 about addressing the WCAP methodology for 19 determining dynamic load, that you wanted to 20 review some documentation to comment on that.
21 DR. LAHEY: Yes, sir. I spent many 22 happy hours for that last night. And I was, so 23 there were two things that you may recall I was 24 concerned with.
25 It was the methodology that was used NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5344 1 to calculate the forces. Was it truly impact 2 force, or was it smear down? And then the other 3 one is what was analyzed. Was that appropriate?
4 So in this report, which was dated 5 2001, it was, and then it was the one that was 6 reviewed and approved later on by the U.S. NRC.
7 It was a generic study of a 4 loop Westinghouse 8 plant to determine what the minimum number of 9 baffle former bolts could be to withstand certain 10 accident events.
11 The methodology that was used is 12 called by Westinghouse a MULTIFLEX, and it's 13 Version 3. And I view that as sort of the 14 grandson or the son, I'm not sure, either an old 15 son or a young grandson of the WHAM code to show 16 it is, in fact, what I think should be used.
17 It's a sub-cool depressurization code, 18 so it propagates at the speed of sound, the 19 depressurization waves throughout the system. So 20 that was good news for me. I was very happy to 21 see that, and I think it's appropriate.
22 Later on in the transient, they switch 23 over to a version of the track code, which has 24 been married to a version of the Cobra codes. So 25 it's W Cobra slash --
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5345 1 MR. KUYLER: Your Honor, if I may 2 break in for a moment. This is Ray Kuyler from 3 Entergy. I would just note that we are 4 discussing a proprietary Westinghouse report at 5 this moment.
6 DR. LAHEY: I'm sorry.
7 CHAIRMAN MCDADE: Well, let's ask 8 whether or not, it does not appear that we're 9 discussing it in sufficient detail or the 10 proprietary aspects of it are going to be 11 released.
12 MS. SUTTON: Your Honor, let me 13 consult with Westinghouse's counsel. They need 14 to consult with their expert. One second.
15 DR. LAHEY: You're actually going to 16 like what I'm going to say, but go ahead.
17 MS. SUTTON: Okay, Your Honor. As 18 long as he remains at a high level of detail, we 19 can proceed, but if it sinks into greater levels 20 of detail, we'll alert you.
21 CHAIRMAN MCDADE: Okay. And Dr.
22 Lahey, actually we have the report.
23 DR. LAHEY: Right.
24 CHAIRMAN MCDADE: Perhaps can you 25 focus on the conclusions that you have drawn from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5346 1 the report rather than going into the specific 2 details of the report?
3 DR. LAHEY: Right.
4 CHAIRMAN MCDADE: We're interested in 5 your expert conclusions.
6 DR. LAHEY: I am definitely not going 7 to go into detail. In fact, this report has 8 precious few equations. That's in references 9 that I did not have access to. But anyway, the 10 track code and the Cobra code are widely known, 11 have been published in the open literature.
12 So they are the large control volume 13 codes, but it's only used for the flashing part 14 of the transient, and the loads there are very 15 small.
16 So all the loads that we're concerned 17 with in terms of the integrity of the bolts have 18 to do with the sub-cooled blow down phase. And 19 in that phase, the right technique is apparently 20 being used. So I was happy to see that.
21 Now the other part of my concern has 22 to do with what do you do with these methods, 23 which I've now said I think look appropriate?
24 I'm happy to see that.
25 What was done is a break size, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5347 1 was not the large design basis break size. It 2 was a smaller break size. And then use what the 3 NRC likes to call leak before break criteria for 4 opening time.
5 So it wasn't an instantaneous full leg 6 break of the reactor. It was a smaller line 7 break. So that, what that does is it reduces the 8 severity of the load, which propagates through 9 the system.
10 Nevertheless, I mean this was a 11 generic study, and I haven't seen what is being 12 done for the Westinghouse Plants at Indian Point, 13 and I don't think it has been published.
14 So all these things could have been 15 addressed that I'm going to alert you to, but 16 when this was done, it was found that about 50 17 percent of the bolts could withstand the 18 transient.
19 Fluid structure interaction was 20 modeled, all pretty much state of the art in my 21 view for this type of analysis was employed. So 22 that's good news.
23 If you then go to a design basis 24 accident, even though the NRC has said that leak 25 before break is what you do for such things as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5348 1 pipe width, you don't do it inside the core.
2 You still have to do the regular, 3 local loads. So if these are applied, then it'll 4 be significantly different in terms of the 5 integrity of the bolting.
6 So that remains to be seen, what will 7 be done there. And as I said, I haven't reviewed 8 that. I don't think it's available.
9 CHAIRMAN MCDADE: Okay. Thank you.
10 Judge Wardwell, does that answer your question?
11 JUDGE WARDWELL: Fine. Thank you.
12 CHAIRMAN MCDADE: Do you need any 13 follow up?
14 JUDGE WARDWELL: No.
15 MR. SIPOS: Your Honor, this is John 16 Sipos for the State of New York. I note in that 17 report there is a reference to a code. And that 18 we have checked, and we do not believe that code, 19 we do not have the code that was referenced.
20 And the reference is to WCAP-9735, and 21 it was in the bibliography. Just like to note 22 that for the record.
23 CHAIRMAN MCDADE: Okay. Thank you, 24 Mr. Sipos. Okay. Dr. Lahey, I believe there was 25 a reference that you made yesterday to an Argonne NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5349 1 report, and Judge Wardwell had asked you whether 2 or not you had a cite to an exhibit for that 3 report. Were you able to provide a cite?
4 DR. LAHEY: I believe you're talking 5 about NUREG/CR-7184. Is that the right one?
6 JUDGE WARDWELL: No. It's what you, 7 what are you talking about. It's not what I'm 8 talking about.
9 DR. LAHEY: In my testimony, I look 10 back at my testimony, and I did cite that 11 particular report.
12 JUDGE WARDWELL: Let's make sure we're 13 clear on this.
14 DR. LAHEY: Okay.
15 JUDGE WARDWELL: So your testimony 16 482, page 18, lines 16 through 22 says, "A recent 17 report prepared by Argonne National Lab," and 18 then it goes on for several lines with no cite of 19 what that report is.
20 Two pages later, you cite to two or 21 three different NUREGs.
22 DR. LAHEY: Right.
23 JUDGE WARDWELL: My question is, the 24 482, page 18, lines 16 through 22, Argonne 25 National Laboratory report that you referred to, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5350 1 what is the cite for that?
2 DR. LAHEY: Yes. I believe that 3 particular one was the Chopra report. The lead 4 author would be Dr. Chopra from ANL.
5 JUDGE WARDWELL: And what's the NUREG 6 number?
7 DR. LAHEY: Okay. Let's see.
8 JUDGE WARDWELL: Would it be 7027?
9 DR. LAHEY: It's possible.
10 JUDGE WARDWELL: The exhibit for that 11 one, at 7027, is New York State 487.
12 DR. LAHEY: Let me look.
13 JUDGE WARDWELL: Not to take the 14 thunder out of Entergy's crack cite locator, but 15 I have to show off sometimes.
16 DR. LAHEY: All right. I don't carry 17 around those numbers in my head, so I'm going to 18 have to look, Your Honor. Let's see.
19 (Pause.)
20 DR. LAHEY: Bear with me please, and 21 I'll search it down.
22 JUDGE WARDWELL: Let's just wait.
23 Could we call up New York State 487 and see if, 24 it would have the author as Chopra.
25 DR. HISER: Your Honor, this is Allen NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5351 1 Hiser of the staff. I think it is New York State 2 488 --
3 JUDGE WARDWELL: Okay.
4 DR. HISER: -- page XV. I believe 5 that top paragraph is executive summary about 6 two-thirds of the way down the paragraph.
7 DR. LAHEY: That one's the Chen report 8 you just put up, but that's not it.
9 JUDGE WARDWELL: You say that's not 10 it?
11 DR. LAHEY: That particular one that's 12 on the screen now, the lead author is Chen.
13 He's, I did reference that report, but you were 14 asking about a different one, I believe.
15 JUDGE WARDWELL: I don't know which 16 one you're asking.
17 DR. LAHEY: I believe it's --
18 JUDGE WARDWELL: I'm asking for your 19 482, page 18, lines 16 through 22, when you say, 20 "A recent report prepared by Argonne National 21 Laboratory for U.S. NRC" --
22 DR. LAHEY: Okay.
23 JUDGE WARDWELL: What is that report?
24 And you say it's the Chopra report. Correct?
25 MR. SIPOS: Your Honor, it's John NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5352 1 Sipos for the State of New York. May I try to 2 resolve this?
3 JUDGE WARDWELL: Sure.
4 MR. SIPOS: Lower down on line 22, I 5 believe, of New York State 482 on page 18, that's 6 where we are.
7 JUDGE WARDWELL: Yes.
8 MR. SIPOS: I believe there's a 9 reference to Chen, et. al. on the very last two 10 lines of that page carrying over.
11 JUDGE WARDWELL: Well, you address 12 that to your witness to have him verify that 13 that's what he's referring to is 488 then.
14 DR. LAHEY: Yes. What is the date of 15 the testimony that you're talking about, or what 16 is the New York State reference?
17 MR. SIPOS: June 2015.
18 DR. LAHEY: Okay.
19 CHAIRMAN MCDADE: Mr. Welkie, can you 20 pull up New York 488? This is 487, isn't it?
21 JUDGE WARDWELL: No, it's 482.
22 CHAIRMAN MCDADE: Never mind. Thank 23 you. All right.
24 DR. LAHEY: So this testimony is June 25 9, 2015, New York State 482. Is that the one, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5353 1 Your Honor?
2 JUDGE WARDWELL: It's your testimony.
3 DR. LAHEY: That's, I've done a lot of 4 testimony, but that's the one you're concerned 5 with?
6 JUDGE WARDWELL: Yes.
7 DR. LAHEY: All right. Tell me the 8 page number again.
9 JUDGE WARDWELL: 18.
10 DR. LAHEY: Okay.
11 JUDGE WARDWELL: And it's line 16, if 12 you go to line 16, that's where the, it's really 13 on 17, "Moreover, a recent --
14 DR. LAHEY: Right.
15 CHAIRMAN MCDADE: -- laboratory report 16 prepared by Argonne Lab."
17 DR. LAHEY: So that particular quote 18 is for the Chen report.
19 JUDGE WARDWELL: So it is. If we go 20 to the next page, it is 7184 then. Is that 21 correct?
22 DR. LAHEY: Yes, sir.
23 JUDGE WARDWELL: Thank you.
24 DR. LAHEY: Sorry it took so long.
25 JUDGE WARDWELL: No problem. We got NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5354 1 it all straightened out. We have so many numbers 2 of those.
3 CHAIRMAN MCDADE: Those were the only 4 homework assignments that I recall. Is there any 5 witness who right now was asked to look something 6 up that we haven't addressed here this morning so 7 far?
8 MR. GRIESBACH: Yes, Your Honor. This 9 is Tim Griesbach from Entergy.
10 CHAIRMAN MCDADE: Yes.
11 MR. GRIESBACH: I believe Judge 12 Wardwell had asked us to clarify the screening 13 criteria that were used for the cast components, 14 and I'm prepared to do that now.
15 CHAIRMAN MCDADE: Please.
16 MR. GRIESBACH: Let me go through the 17 sequence. The original criteria in MRP-191 18 stated both criteria for thermal embrittlement 19 and irradiation embrittlement. That's in New 20 York State 321, Tables 3-5 and 3-6.
21 They went through and screened the 22 various components, including the lower support 23 columns. There were several criteria, one based 24 on molybdenum content less than or greater than 25 0.5 percent, materials, whether they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5355 1 statically or centrifugally cast.
2 And then the ferrite content less than 3 or greater than 20 percent. There's separate 4 criteria for irradiation embrittlement based on 5 1 dpa fluence. So that was the criteria that 6 were used.
7 And in the NRC review of that, they 8 took issue with the criteria. Although those 9 criteria had been published in a letter, called 10 the Grimes Letter, that's NRC document 213, new 11 information particular to the effects of both 12 thermal and irradiation embrittlement came to 13 light.
14 And the NRC staff had offered revised 15 proposed criteria taking into account both. In 16 fact, NRC went back and looked at that, those 17 materials that had screened out per the new 18 criteria, and those can be found in NRC Exhibit 19 201.
20 The same molybdenum content, the same 21 static statically or centrifugally cast material, 22 but there was the combination of thermal and 23 irradiation embrittlement could be screened out 24 if the ferrite content were below 15 percent, 25 which was part of the confusion that we had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5356 1 yesterday.
2 In fact, those components in Indian 3 Point 2 and 3 did screen out for that very 4 reason. Although the separate criteria to 5 continue to look at them for irradiation 6 embrittlement would be if they exceeded a dpa 7 level of 1.5 dpa.
8 So that was the method, methods to 9 use. I believe Dr. Hiser discussed that 10 yesterday. And that is also very clearly stated 11 in the NRC testimony in their question 163 on NRC 12 Exhibit 197.
13 And that's stated on pages 94 and 95.
14 So I believe that reflects why there may have 15 been two different sets of criteria used and why 16 there was some confusion yesterday.
17 JUDGE WARDWELL: Thank you.
18 DR. HISER: Your Honor --
19 CHAIRMAN MCDADE: Dr. Hiser?
20 DR. HISER: This is Allen Hiser of 21 NRC. You also asked, posed a question yesterday 22 that if Entergy were to implement the 23 Westinghouse methodology on acceptability of 24 their bolt configuration post-inspection what the 25 NRC approval process, what process that would fit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5357 1 into, whether that would be something would be 2 available for the public to comment on or exactly 3 where that would fall. And I'm prepared to 4 discuss that.
5 CHAIRMAN MCDADE: Please.
6 DR. HISER: If that case were to 7 occur, that the applicant were to do it's 8 inspection and find that there were degraded 9 bolts that it could not justify, would they be 10 able to perform the individual bolt function?
11 And they then move that condition to 12 the corrective action program. If they were to 13 implement this engineering justification that 14 they discussed, then that analysis would be 15 evaluated through 50.59 to determine whether a 16 license amendment would be required by the 17 applicant.
18 If the conclusion was that a license 19 amendment would not be required, then 50.59 would 20 be documented, and it would be available for 21 staff review.
22 If a license amendment were to be 23 necessary, then the applicant would follow the 24 normal 50.90 process for license amendment. At 25 this point, we cannot make, we cannot prejudge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5358 1 what that 50.59 process, what the result would be 2 from that by the applicant.
3 CHAIRMAN MCDADE: Okay. Thank you, 4 Dr. Hiser. I appreciate that. Okay. I think 5 we're ready to get started then with regard to 6 specific questions regarding exhibit --
7 MR. BESSETTE: Your Honor, this is 8 Paul Bessette. Can we just have a moment to swap 9 witnesses, move one of our witnesses from the 10 back to the right? It might be more convenient 11 for Your Honor.
12 CHAIRMAN MCDADE: Yes, sure.
13 JUDGE WARDWELL: And witnesses that 14 are part of, that are only on 25 should leave the 15 table. But before we do that, I would like to 16 just thank all of the witnesses on 25.
17 I requested certain attributes that I 18 wanted from your answers, and I think it was 19 succeeded very successfully. We got through a 20 lot of stuff in about a day's a little change 21 worth of effort.
22 And it was due mostly because of your 23 succinct answers that you gave, and I want you 24 let you know I appreciate your responses.
25 MR. TURK: Your Honor, this is Sherwin NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5359 1 Turk.
2 CHAIRMAN MCDADE: Mr. Turk?
3 MR. TURK: Can we pause for a moment 4 or two? Some of our witnesses are not in the 5 room currently. They'll be back in a moment, or 6 at least one of them.
7 MS. SUTTON: Your Honor, one of our 8 witnesses needs to also take an emergency break.
9 We'll be very brief.
10 CHAIRMAN MCDADE: We're sort of in a 11 recessing place right now, so do you want to take 12 a short break, Dr. Lahey?
13 DR. LAHEY: If we're on a recess, I 14 will.
15 CHAIRMAN MCDADE: Actually, while we 16 get organized, rather than just sitting here, why 17 don't we take five minutes? And we'll come back 18 in five minutes.
19 MR. TURK: Thank you, Your Honor.
20 (Whereupon, the above-entitled matter 21 went off the record at 9:14 a.m. and resumed at 22 9:22 a.m.)
23 CHAIRMAN MCDADE: Okay. Judge 24 Kennedy?
25 JUDGE KENNEDY: I guess this brings us NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5360 1 to Contention 26. Similar to Contention 25 where 2 Judge Wardwell led the questioning, I'll take the 3 initial cut at questions for the witnesses and 4 New York State 26.
5 So it will proceed as we did for 25.
6 I know there's some new folks here that may not 7 have observed what we did, but I'm the lead 8 questioner, if you will, have the lead on the 9 contention.
10 But my colleagues here will also 11 chime in at various points to ask questions and 12 follow up questions. So I have a series of 13 questions that I'm going to go through and then 14 ask them to chime in as need be.
15 Contention 26, as the Board views it, 16 raises a general challenge to Metal Fatigue Aging 17 Management Program and in specific raises some 18 challenges to the calculations of the cumulative 19 usage factors and the CUFens that are used.
20 It appears to focus extensively on the 21 methodology and approach used to calculate these, 22 and so we'll get into a lot of discussion about 23 those calculations.
24 I know we almost completely avoided 25 any discussion on proprietary information, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5361 1 right at the finish line we started to get close.
2 I can assure you the Board's attempted to try to 3 deal with the issues on Contention 26 in a level 4 that we hope is high enough that we won't have to 5 close the meeting.
6 But I do appreciate the efforts of 7 Entergy to keep us on the right path here. As 8 always, we're still technical people, and we get 9 curious. And we raise questions, so I appreciate 10 your efforts and we'll try to deal with it.
11 But I can see this is a very technical 12 contention with a lot of methodology and a lot of 13 proprietary information. We've attempted to try 14 to address our questions at a level about the 15 specifics, if that makes sense at this point.
16 Hopefully it'll make sense as we go 17 through it. We've tried to stay at more of a 18 concept level, not use specific values to try to 19 deal with a lot of these issues from a conceptual 20 level.
21 At the end of the day we may not be 22 able to do that, so there may come times where it 23 has to get down, to really address a specific 24 question, into the details.
25 And again, we'll look to Entergy and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5362 1 to Westinghouse to help keep us from revealing 2 anything that shouldn't be revealed to the 3 public.
4 MS. SUTTON: Your Honor, this is 5 Kathryn Sutton for Entergy. We have advised our 6 experts that if they believe that they need to 7 wade into details that are proprietary, they 8 should first alert you.
9 But at the same time, we are concerned 10 that we do need to put the contention to bed and 11 make the case. So we will work with you, Your 12 Honor, to make sure that we protect the 13 information. And we'll work with Westinghouse as 14 well.
15 JUDGE KENNEDY: I appreciate that.
16 And as we get through this and get a little 17 experience with the issues at hand here, maybe a 18 path will be clear on how we'll deal with this.
19 I mean it's possible we could move all 20 of those issues to the end of the day or to an 21 appropriate time. Having said that, we're going 22 to try to not get down that road.
23 But I appreciate the difficulty in 24 being able to do this. The Board has spent a lot 25 of time reviewing the pre-filed testimony, and it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5363 1 contains a lot of proprietary information.
2 With that discussion, this is the 3 issues related to Contention 26. Before I get 4 into the specifics of my questions, it occurred 5 to the Board that it would be useful to have some 6 contextual discussion about CUFs.
7 We'll have to find out how to 8 pronounce some of this so we can communicate, but 9 have some initial discussion about what a CUF is, 10 how it's calculated.
11 And again, my intent is to do this at 12 a level to provide contextual information for the 13 follow up questions. So if you feel the need to 14 get way deep into a methodology detail, let us 15 know.
16 We can maybe park that for a while 17 until we get to more specifics on the details of 18 the calculations. But I wanted to at least have 19 some opening discussion about those parameters.
20 And then we'll use that in the 21 subsequent questions as background material for 22 our follow up questions.
23 My intent, at least to start, is to 24 direct these questions to Entergy. It's their 25 application. It's their CUFs for their plant.
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5364 1 And I guess Westinghouse has a role in this, too.
2 So I'm going start with a series of 3 questions to Westinghouse, to Entergy, and I'll 4 let you folks decide who the appropriate person 5 is.
6 But I had put together, sort of at a 7 high level, a series of questions that try to 8 address this whole CUFs issue, not to solve it, 9 but to provide some context so when we get into 10 the specific issues that have been raised by New 11 York State we have some backdrop information to 12 help make it clear.
13 I'm going to try to do the easy one 14 first. Someone can enlighten us at to what a CUF 15 is, maybe with what it's an acronym for to start 16 with.
17 MR. GRAY: Yes, Mark Gray for Entergy.
18 CUF stands for cumulative usage factor. It's 19 required by the ASME code. The calculation is 20 according to Section 3 of the code, Section NB-21 3222.4(e)[5].
22 And that section gives a prescribed 23 method for combining stress cycles that occur on 24 a component in a method that allows you to 25 calculate the usage factor, which is for each NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5365 1 pair of stress cycles that form a range.
2 That's called the alternating stress 3 range. It's the amplitude that you use on the 4 fatigue curve. So you calculate the stress 5 range. You get an amplitude, the alternating 6 stress for some stress cycle pair.
7 That stress cycle pair then is 8 assigned an allowable number of cycles from the 9 design fatigue curve. From that allowable number 10 of cycles, you also have the actual or design 11 number of cycles for that stress cycle pair.
12 The ratio of the actual number of 13 cycles in the design divided by the allowable 14 cycles from the curve is the usage factor for 15 that pair. So it's a calculation, to start with.
16 JUDGE KENNEDY: Yes, and sounds like 17 a complex calculation that tries to provide an 18 indication. Does it, the sense I get is it tries 19 to provide an indication based on actual versus 20 a design life of the component.
21 It sounds like it's a ratio. Is it a 22 ratio?
23 MR. GRAY: So it's a ratio of the 24 number of cycles expected for the component 25 divided by the allowable based on the fatigue NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5366 1 curve. So it's the fraction of the allowable 2 life of the component from that stress cycle.
3 The cumulative usage factor is the sum 4 of all those incremental usage factors for all 5 the stress cycles in the design.
6 JUDGE KENNEDY: So all the stress 7 cycles that a particular component or series of 8 components would be exposed to?
9 MR. GRAY: Yes.
10 JUDGE KENNEDY: And so it's a design 11 type calculation. In other words, it's done when 12 the plant is being designed?
13 MR. GRAY: Yes.
14 JUDGE KENNEDY: And it's an indication 15 based on some projected amount of actual cycles 16 that would occur during the operation of the 17 plant of how close you are to ultimate failure of 18 the component, the fatigue life of the component, 19 the design life of the component.
20 MR. GRAY: The design life of the 21 component is represented by that allowable 22 fatigue usage, cumulative fatigue usage factor of 23 1. So basically, it's 100 percent of the stress 24 cycles allowed by the design curve.
25 And you calculate the fraction of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5367 1 based on the loadings postulated for the 2 component of all the stress cycles that are 3 postulated for the component.
4 JUDGE KENNEDY: Does that imply that 5 the postulated cycles is less than the design 6 cycles? Is that, would it always be 1? We know 7 it's not, but --
8 MR. GRAY: No, let's clarify 9 terminology a little bit. Section 3 defines that 10 you need, requires a design specification for the 11 component. That design specification tells you 12 all the loads that have to be considered for the 13 component.
14 When it comes to the fatigue loads, 15 those loads are associated with a number of 16 cycles. Those loads translate then into stress 17 cycles on the component.
18 And then those stress cycles are used 19 to calculate the usage factor. So the design 20 cycles, when you say cycles, that's normally used 21 to refer to those number of cycles in the design 22 specification for the loads to be considered.
23 The allowable cycles are the allowable 24 cycles that you get from the design fatigue curve 25 for a given stress level.
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5368 1 JUDGE KENNEDY: So is the allowable 2 some sort of measure from the design perspective 3 of what that component is capable of 4 withstanding?
5 MR. GRAY: Yes, the design allowable 6 number of cycles is from the design fatigue 7 curve, which is based on test data plus margins.
8 JUDGE KENNEDY: And if this is a ratio 9 calculation, is that the denominator of the 10 calculation?
11 MR. GRAY: The denominator, yes.
12 JUDGE KENNEDY: So then the numerator 13 is an expected set of, expected level of --
14 MR. GRAY: Yes, expected number of 15 cycles for that stress cycle.
16 JUDGE KENNEDY: Okay.
17 MR. GRAY: And yes, you're right. The 18 stress cycles are a function of the number of 19 transients.
20 JUDGE KENNEDY: Okay.
21 MR. COX: Judge Kennedy, this is Alan 22 Cox with Entergy. One point of clarification.
23 We say expected cycles. I guess another way to 24 put that will be assumed cycles or cycles that 25 were specified in the design.
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5369 1 Again, these calculations were done 40 2 years ago as part of the design, so what was 3 assumed for some of those cycles, today we may 4 not expect to ever get there.
5 So it's some slight nuance there, but 6 it's something that could come into play because 7 of the operating history of the plant.
8 JUDGE KENNEDY: So the CUF value has 9 expected values in the numerator, and the 10 denominator is based on the design parameters.
11 And these are all done, the entire calculation is 12 done during the design process.
13 So these are, as Mr. Cox said, 14 historical values?
15 MR. GRAY: Well, this is Mark Gray 16 again. The original CUF was calculated during 17 the design process for the component when that 18 component was a Section 3 component.
19 JUDGE KENNEDY: Are you going to go on 20 to tell me that these have been recalculated 21 during the operation of the plant or due to 22 changes? Would you recalculate this design 23 parameter?
24 MR. GRAY: Yes. You can recalculate 25 that at any time. The reason I qualified what I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5370 1 said is not all of the Indian Point components 2 that have been evaluated for environmental 3 fatigue, had an original Section 3 design CUF 4 requirement.
5 JUDGE KENNEDY: So did those need to 6 be calculated to support the license renewal 7 application then?
8 MR. GRAY: Yes.
9 JUDGE KENNEDY: Okay. Would there be 10 any reason, during the life of the plant, to 11 recalculate other than say a need that you have 12 identified for the license renewal proceeding, to 13 recalculate the CUF?
14 MR. GRAY: Yes. In fact, there have 15 been instances of loadings that have been found 16 in operation at plants that weren't considered in 17 the original design.
18 And in those cases, a new analysis 19 would be performed to demonstrate that the 20 component was still good under the revised 21 loadings.
22 JUDGE KENNEDY: If the operating 23 history of the plant was different than the 24 allowable cycles, maybe I'm using the wrong word.
25 The actual cycles are allowable. I'm not sure.
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5371 1 Whatever's in the numerator, is that allowable?
2 There's head shaking going on over 3 here. Let's stay with Mr. Gray for a minute. Am 4 I getting crossed up again with this design 5 versus allowable?
6 MR. GRAY: Yes. Let me define. When 7 we, for a component that has a CUF calculation, 8 that CUF is based on the design fatigue curve.
9 And the denominator in those usage factor 10 calculations came from the design fatigue curve.
11 The numerator in those calculations 12 came from the design specification, the number of 13 expected loadings for the component. For 14 example, if there's an operational transient 15 that's discovered, that changes the numerator.
16 When the plant is counting their 17 cycles against what's been designed, now that 18 numerator now becomes the allowable for the plant 19 to track to because that's what was used in the 20 CUF calculation.
21 JUDGE KENNEDY: Okay. Yes, that helps 22 if I think in terms of fixed parameters versus 23 non-fixed parameters. From your testimony, I get 24 the sense that the denominator is a fixed 25 parameter and that the numerator could be fluid.
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5372 1 That may be a bad term in this context 2 but could change during the operation of the 3 facility as the operating history of the plant 4 changes. Is that fair?
5 MR. GRAY: That's a fair 6 interpretation, yes.
7 JUDGE KENNEDY: Okay.
8 MR. COX: This is Alan Cox again. I 9 think one clarification to that, or not 10 clarification, but another way to say it is the 11 allowable is the allowable for that analysis to 12 remain valid.
13 If the analysis said you had a low 14 CUF, you could allow additional cycles and revise 15 the analysis to accommodate those additional 16 cycles. But for that calculation, to calculate 17 that particular CUF to remain valid, you have to 18 stay below those number of cycles.
19 JUDGE KENNEDY: And I guess would the 20 limit then be on the allowable cycles up to a 21 value of, a ratio of 1.0? I mean if you 22 recalculate it, is that the limit to where you --
23 MR. COX: Yes. That's correct. You 24 could, that's the limit from the design spec.
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5373 1 valid. If you have a low CUF, you can revise the 2 calc to use a higher allowable.
3 And it would be up to the point of 4 where you exceeded 1.0 5 JUDGE KENNEDY: So starting at some 6 initial point, you had allowable and the design 7 values. Is that then the design basis for the 8 operation of the plant?
9 Is that monitored? Again, this is 10 probably not license renewal. Maybe it is 11 license renewal, but prior to the period of 12 extended operation, this was a design calculation 13 that was in place. I guess --
14 MR. AZEVEDO: This is Nelson Azevedo 15 from Entergy. Yes, Your Honor, just if I may try 16 to clarify, and maybe I won't. But the way I 17 think that they're the actual cycles the plant 18 sees.
19 Then next, they're the design cycles 20 that the plant was designed and then the 21 allowable cycles that the ASME code provides. So 22 that's the way I look at it, those three 23 different numbers.
24 So when the plant was originally 25 designed, or if it was modified, these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5374 1 calculations would get redone. It was designed 2 for X amount of cycles to make sure there 3 remained within the allowables from the ASME 4 code.
5 And now we track the actual cycles 6 versus the design cycles that were originally 7 used to design the component, if that clarifies 8 it.
9 JUDGE KENNEDY: The allowable, can 10 that, is that specified by the designer, or is it 11 specified by the code?
12 MR. AZEVEDO: The allowable cycles 13 comes from the ASME code. There's a stress range 14 versus number of allowable cycles. There's an SM 15 curve in the ASME code.
16 And for that specific stress, for that 17 specific cycle, you go to that curve, it'll tell 18 you what the allowable number of cycles is for 19 that specific condition.
20 JUDGE KENNEDY: And those constitute 21 the allowables?
22 MR. AZEVEDO: Those are the allowables 23 from the ASME code.
24 JUDGE KENNEDY: And that's in the 25 numerator or the denominator?
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5375 1 MR. AZEVEDO: That's in the 2 denominator.
3 JUDGE KENNEDY: Okay. So the actuals 4 are, whatever you, whatever's specified for the 5 design spec for the operation of a plant would go 6 in the numerator. And then that's tracked. Is 7 that tracked then through time?
8 MR. AZEVEDO: Yes. What we do is we 9 actually track the actual cycles versus the 10 design cycles that we used in the calculation.
11 The analyzed cycles, design cycles, those are 12 interchangeable terms.
13 JUDGE KENNEDY: Okay. Thanks. Mr.
14 Hiser, or Dr. Hiser, sorry. We're getting a 15 little, too. We've asked you too many questions.
16 They're getting a little too friendly here.
17 You seem to be expressing some, that's 18 the face. Are we tracking with how the NRC views 19 this CUF picture?
20 DR. HISER: This is Allen Hiser with 21 the staff. Yes, I think you're on the right 22 track now. It's very confusing between 23 allowable, design, projected and sorting that 24 out, I think, is a very important first step.
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5376 1 making the same face back at you because that's 2 where I was when we first started reading this 3 testimony.
4 DR. HISER: And I apologize. It's my 5 thinking of things and not --
6 (Simultaneous speaking.)
7 JUDGE KENNEDY: I believe we all do 8 it, and I apologize for bringing to anybody's 9 attention.
10 CHAIRMAN MCDADE: And we certainly 11 don't want to discourage you from thinking about 12 this.
13 DR. HISER: Thank you.
14 JUDGE KENNEDY: Maybe to the witnesses 15 for the State of New York, any concerns over the 16 discussion that Entergy's provided?
17 DR. LAHEY: This is Richard Lahey.
18 That's my understanding as well of the original 19 CUF.
20 JUDGE KENNEDY: Dr. Hopenfeld?
21 DR. HOPENFELD: This is Joram 22 Hopenfeld, Riverkeeper. There's one important 23 point that I would like to, can you hear me well?
24 Can you hear me okay?
25 JUDGE KENNEDY: Please take both, yes.
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5377 1 Maybe move the mic a little bit.
2 DR. HOPENFELD: It's not a detail, but 3 it's an important point because it relates to 4 your question as to what you do at the beginning 5 during the design stage.
6 After you take your maximum stress to 7 identify the minimal stress during that 8 transient. Take the difference. You have to 9 multiply that difference by a stress 10 concentration factor to allow for the fact that 11 LOCA stress may initiate or may propagate 12 differently than if you had just considered only 13 the average.
14 So the point is, that stress 15 concentration factor is a factor. It depends on 16 geometry. So if a situation in the plant, and 17 it's on the secondary side, due to geometry of 18 the changes or you have radiation effect.
19 JUDGE KENNEDY: Let me, I don't mean 20 to interrupt you, but we're going to get to that.
21 This, to me, is sort of setting the stage so that 22 we're all on the same page.
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5378 1 think try to deal with some of the points you 2 made.
3 I didn't mean to cut you off, but 4 we're going to get way beyond where I think we 5 need to be at this point. Appreciate it though.
6 Thank you.
7 MR. SIPOS: Excuse me, Your Honor, 8 John Sipos for the State of New York. Could I 9 move Dr. Hopenfeld's microphone closer to him?
10 CHAIRMAN MCDADE: Please.
11 MR. SIPOS: Thank you. Mr. Welkie can 12 do a better job of it than I can.
13 DR. HOPENFELD: Thank you.
14 CHAIRMAN MCDADE: All right. We're 15 going to get you a different microphone, Dr.
16 Hopenfeld. So we're going to continue. We've 17 got some questions over here to Entergy.
18 So by the time you're called on again, 19 Mr. Welkie will have a more effective microphone 20 for you.
21 DR. HOPENFELD: Hope it's not a 22 message for me.
23 JUDGE KENNEDY: Hopefully if you have 24 any questions before we get your microphone in 25 please jot them down so we don't lose them.
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5379 1 Let's go back to Entergy and maybe Mr. Gray, 2 we'll start with you.
3 Are there conservatisms built into 4 those calculations, and maybe, I guess I don't 5 want a simple yes or no because we're going to 6 get into conservatisms and margins later. But if 7 you could maybe outline if there are and sort of 8 in general terms, the types of conservatisms that 9 could be at play here.
10 MR. GRAY: Yes, and as you eluded to, 11 in our testimony we do make a distinction between 12 the ASME code margins and ASME code conservatisms 13 and analysis conservatisms.
14 Those are three categories of some 15 amount of conservatism. And the calculations 16 contain all three of those.
17 JUDGE KENNEDY: Right, and I 18 appreciate that, and I do remember that from the 19 testimony. And we'll have some specific 20 discussion about that and give New York State an 21 opportunity to weigh in.
22 But that's what I was looking for is 23 at that level, yes, there are conservatisms built 24 into it as you point out.
25 Does the WESTEMS code play a role in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5380 1 the CUF calculation, or is that a different 2 aspect of this, to this puzzle?
3 MR. GRAY: This is Mark Gray. The 4 WESTEMS code is the tool that Westinghouse used 5 for the ASME Section 3 evaluations, so yes, it 6 does the CUF calculation.
7 JUDGE KENNEDY: All right. Thank you.
8 Now let's move into, and I don't know how to say 9 these either. There's the CUFens. What's going 10 on there, and I'll start with Mr. Gray. And 11 there are probably others to answer.
12 So we started with just CUF, and now 13 we've added something to those calculations.
14 Maybe if you could address in sort of general 15 terms what that's all about and why it was done.
16 MR. GRAY: The CUF calculation was 17 done according to the ASME code, Section 3. The 18 penalty factor to account for the effects of 19 reactor water environment is termed Fen.
20 That methodology is prescribed by the 21 NUREGs, and there are a number of different ways 22 that that Fen can be applied. But essentially 23 the CUFen is the product of the ASME code CUF and 24 the Fen penalty factor to account for reactor 25 water environment.
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5381 1 And the reason that is done is because 2 the NRC has required that plants doing a license 3 renewal evaluation evaluate certain components 4 for the effects of the reactor water environment 5 on their design fatigue calculations.
6 JUDGE KENNEDY: And did you just 7 mention that those Fens, I'm not sure what, so 8 the environmental adjustment, that's prescribed 9 by the NRC and was used in these CUFen 10 calculations?
11 MR. GRAY: Yes. The Fen factors are 12 defined in different NUREG reports.
13 JUDGE KENNEDY: Okay. Let me go 14 backwards just a little bit because I was using 15 some terms relative to conservatisms. Later on 16 we're going to talk a little bit about safety 17 margin and reductions in safety margin and 18 conservatisms.
19 In your mind, is there a difference 20 between the term margins and conservatisms? Are 21 they different concepts? They trying to do 22 different things, or should the Board view those 23 as similar?
24 MR. GRAY: While they may have a 25 similar effect on the results of an analysis, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5382 1 do view those as having a different role. The 2 margin is something that, as an analyst, I can't 3 touch.
4 That's defined in the code methodology 5 and allowables, particularly the design fatigue 6 curve. The conservatism is a function of the way 7 the analysis is performed.
8 And that conservatism can be a 9 function of which section of the code I used to 10 do my analysis. The code allows different types 11 of analysis to be done that have different levels 12 of conservatism in them.
13 The other aspect of conservatism is 14 the assumptions that the analyst makes in the 15 inputs and the modeling. And that has to be 16 determined by the analyst and, of course, go 17 through a verification process.
18 JUDGE KENNEDY: So one distinction 19 that I heard you make is that margins are 20 dictated by the code and cannot be adjusted or 21 changed or reduced. Is that what I heard you 22 say?
23 MR. GRAY: Yes. I'll only qualify 24 that by the ASME code does have sort of a blanket 25 statement that if you can justify something other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5383 1 than what it says, you could do that.
2 But generally speaking, and what we've 3 done here, that hasn't been performed.
4 JUDGE KENNEDY: All right. Thank you.
5 Dr. Hopenfeld or Dr. Lahey, do you, we're going 6 to get into safety margins and reductions and 7 stuff. But do you have anything you'd like to 8 add to what Mr. Gray has said here about margins 9 and conservatisms?
10 DR. LAHEY: Your Honor, this is 11 Richard Lahey, not about the margins. When we 12 talked about Fen, then I have something to say.
13 JUDGE KENNEDY: Yes, and I think we're 14 going to get into, this is sort of the 15 preliminaries. We're going to get into the 16 details a little later, so just I'm sure we'll 17 get a chance to get into that.
18 Too many stickies here. At some point 19 in the testimony, and I guess New York State has 20 raised some objections or discussions about the 21 revision to the CUFen calculations that were 22 performed.
23 What motivated the, well, is that true 24 first of all? Were the CUFen calculations 25 revised during the license renewal process? And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5384 1 if so, why was that done? And I'll guess we'll 2 take it from there. Mr. Gray?
3 MR. GRAY: Yes. This is Mark Gray for 4 Entergy. There actually, in the whole process 5 there have been revisions to the calculations for 6 different reasons.
7 But I think the main thing that you're 8 referring to is that in the midst of performing 9 their fatigue management program, the cycles, the 10 actual cycles of different transients attract.
11 So as you know, this has been going on 12 over a number of years, so some of those original 13 CUFen calculations assumed a given number of 14 cycles for analysis based on projected cycles for 15 the plant.
16 As the cycle counts are updated, and 17 those projections are revised, then the 18 calculation may be revised to use a higher number 19 in the analysis so that there is more room for 20 the plant to operate within still an acceptable 21 number of analyzing cycles.
22 JUDGE KENNEDY: So these calculations 23 are revised to bring actual cycle information 24 into the calculation from the operation of the 25 plant. Is that what I heard?
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5385 1 MR. GRAY: Yes, and to allow more 2 because the plant's going to compare what they've 3 tracked against what we've analyzed.
4 So that's the plant's allowable versus 5 the analysts' allowable, which is the assigned 6 current allowable. I don't want to make, confuse 7 that again.
8 JUDGE KENNEDY: Does this include 9 being able to operate the plant beyond the 40 10 year life? I mean is that part of this puzzle 11 piece?
12 MR. GRAY: Yes. Let me qualify that 13 though by saying something, I think, that was 14 mentioned yesterday. The 40 year life is tied an 15 assumed number cycles in that 40 year life.
16 So the 60 year life, if it has been 17 justified that that 40 year design number of 18 cycles is really not even going to be reached in 19 a 60 year life, it's the 40 and the 60, it's 20 still defined by the same number of analyzed 21 cycles.
22 JUDGE KENNEDY: Okay. It seems like, 23 and this is, I don't really have anything here.
24 But it seems like from memory that a lot of these 25 revised CUF calculations were much lower than the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5386 1 original CUF calculations that were in the 2 application.
3 It would seem to me if you're, and I'm 4 not sure what caused that. Is it, as some would 5 say, a reduction in conservatisms or is it 6 bringing more actual plant data into the 7 calculation?
8 MR. GRAY: Okay. I think now you've 9 defined a context for me that I can better answer 10 your question.
11 JUDGE KENNEDY: Okay.
12 MR. GRAY: When you're referring to 13 the license renewal application, at that time, 14 the penalty factors and the CUF values that 15 Entergy used were simply, probably much more 16 conservative design fatigue usage factors.
17 Maybe at this point I should mention 18 that it's important to understand that when we do 19 a CUF calculation for design, we're not looking 20 to predict an exact or precise number.
21 We're looking to make sure that it's 22 within the allowable of one. When the analyst 23 gets the number under 1, he stops. And those 24 would be the types of numbers that Entergy 25 would've been taking from the design and applying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5387 1 a screening Fen factor, just to give an idea of 2 what components had to be analyzed further.
3 And when those components were 4 analyzed further within the details of how the 5 NUREGs say to apply the Fens and the current 6 industry practices, that analysis would have 7 removed a lot of conservatism from those original 8 design calculations. And that's why that big 9 difference.
10 JUDGE KENNEDY: Okay. And I think 11 we'll get into some of that discussion later on.
12 I know New York State has some questions that 13 we'll be addressing.
14 So there's now a set. At some point 15 there were CUFs. Now I guess as part of the 16 license renewal process, we have these CUFens.
17 So the values of CUFen that were developed, were 18 those developed as part of the license renewal 19 process? And are those the numbers that are 20 provided in the application?
21 MR. COX: This is Alan Cox with 22 Entergy. I think Mr. Gray eluded to the initial 23 calculations and using the initial CUF values 24 from the original design and then applying the, 25 what we consider bounding Fen factors, to give an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5388 1 estimate.
2 It was a projection that was put in 3 the LRA, and you saw some of the CUFen values 4 that were greater than one in that projection.
5 So that was, like I said, an initial screening 6 attempt.
7 The things that passed that screening 8 attempt didn't require further consideration.
9 The things that didn't pass that screening 10 attempt were slated for the revision of the 11 calculation, the more refined calculations that 12 Mr. Gray has since worked with Westinghouse to 13 accomplish.
14 JUDGE KENNEDY: All right. Thank you.
15 Yesterday we had some discussion about, maybe it 16 wasn't yesterday. It may have been Monday, the 17 discussion of time limited aging analyses.
18 Are these CUF, CUFen values considered 19 time limited aging analyses for the purpose of 20 license renewal?
21 MR. COX: This is Alan Cox for 22 Entergy. They are treated as time limited aging 23 analyses for the purpose of license renewal.
24 They are discussed in the same section.
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5389 1 licensing basis analysis. I believe, as Mr. Gray 2 indicated, the CUF, the environmental factor was 3 not a requirement of the initial design.
4 So that was not a, there was not a 5 CUFen calculation that was part of the current 6 licensing basis. So these environmental crushing 7 factors are applied as part of the aging 8 management program going forward for license 9 renewal.
10 JUDGE KENNEDY: Let me make sure I got 11 that clear. So the environmental adjustment is 12 performed on the current licensing basis, 13 cumulative usage factor calculations. Is that 14 what you just said?
15 MR. COX: That's correct. And in some 16 cases, that current licensing basis usage factor 17 calculation was revised along with applying the 18 Fen.
19 MR. STROSNIDER: This is Jack 20 Strosnider. Let me see if I, I'd like to see if 21 I can clarify one thing here that with regard to 22 the TLAA, the original fatigue calculation 23 originally calculated CUF without an 24 environmental factor is the TLAA because it was 25 in the licensing basis, the current licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5390 1 basis.
2 The environmental factor was not in 3 the current licensing basis, but the NRC 4 established guidance that it should be considered 5 as part of getting a renewed license.
6 So it will become part of the current 7 licensing basis when the license would be issued.
8 All right, so I don't know if that distinction 9 helps you.
10 But TLAA is actually the original 11 calculation because that's what was in the 12 licensing basis. And now there's some additional 13 work being done in support of license renewal to 14 adjust it for the environmental factor.
15 JUDGE KENNEDY: Just, Mr. Strosnider, 16 just to make sure I've got this clear. I think 17 Mr. Cox eluded to some revised CUF calculations 18 that were performed.
19 Those would be TLAAs that are part of 20 the current licensing basis once that revision 21 was done?
22 MR. STROSNIDER: Yes, recalculations 23 without the environmental factor would be one way 24 to manage the TLAA.
25 JUDGE KENNEDY: All right. Thank you.
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5391 1 That's what I thought I heard from Mr. Cox. I 2 appreciate it though. I don't know if anyone, 3 I'll go walk down the row here if the staff has 4 anything to offer in this sort of preliminary 5 discussion of CUFs and CUFens.
6 DR. HISER: This is Allen Hiser of the 7 staff. Now we agreed that CUF from the original 8 license, there's your CLB analyses, the RTLAAs, 9 revisions to those.
10 Clearly, it would just be updates to 11 the TLAA. The CUFen values are not TLAAs because 12 they are not in the CLB.
13 MR. STROSNIDER: Your Honor, this is 14 Jack Strosnider. If I could, you're asking, I'd 15 like to go back just for a second to the 16 discussion on margins because I think there's 17 something I should have pointed out that could 18 become important later.
19 That is that the fatigue analyses that 20 were being defined are captured in the 21 regulations in 10 CFR 5055(a). And the NRC has 22 said that you need to meet the fatigue analysis 23 and that the margins associated with ASME code 24 Section 3 analyses provide, essentially that's a 25 conclusion of adequate protection.
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5392 1 So what that translates to from a 2 practical point of view is that you need to meet 3 the cumulative usage factor of one and that 4 provides sufficient margin in accordance with the 5 regulations.
6 All right. So that could be different 7 than a margin less than one or something of that 8 nature. What the regulations require is 9 maintaining that cum and usage factor of 1 and 10 that that provides adequate margin.
11 So that could become part of the 12 discussion later.
13 JUDGE KENNEDY: All right. Thank you.
14 And just to be fair, do the New York State 15 witnesses have anything to offer in this 16 preliminary discussion?
17 DR. HOPENFELD: Joram Hopenfeld. I 18 can just make a comment, just an overall comment.
19 I don't want to get into details. It's important 20 to understand that the damage, the CUF really 21 represents damage to the material, fatigue 22 damage.
23 And that basically is a random 24 phenomenon, but what we are doing here, we are 25 using a deterministic method to calculate it.
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5393 1 And that's where the issue of conservatism would 2 come in.
3 JUDGE KENNEDY: All right. Thanks, 4 and we'll get into more of that as we move on.
5 I'll walk down the table of judges here. Is 6 there anything to ask in terms of the CUFs?
7 So we'll relieve you of this 8 preliminary discussion and move into some 9 specific questions. I have the questions 10 organized or grouped by topical area.
11 The first area I'd like to look at is, 12 as I mentioned in my opening remarks, the state, 13 I believe, has raised an overarching concern 14 issue with the adequacy of the Metal Fatigue 15 Aging Management Program.
16 I guess, for the record, I'd like to 17 ask Entergy to tell the Board what aging 18 management program is used for metal fatigue or 19 to manage?
20 MR. COX: It's the Fatigue Monitoring 21 Program.
22 JUDGE KENNEDY: Back to Entergy. In 23 your statement of position, you indicate that the 24 metal fatigue amp is consistent with GALL Rev 1 25 and the guidance in NUREG/CR-6250 and NUREG/CR-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5394 1 5999.
2 What's specific GALL AMP is consistent 3 with the fatigue monitoring program?
4 MR. COX: Your Honor, this is Alan Cox 5 for Entergy. That would be the GALL AMP that's 6 in Chapter 10. It's amp with a designation of 7 M1.
8 JUDGE KENNEDY: M1. What is the 9 relevance and --
10 (Simultaneous speaking.)
11 JUDGE WARDWELL: Excuse me. What's 12 the name on that one? Is there a name to that 13 amp?
14 MR. COX: I can get back to you on it.
15 I think it may be Fatigue Monitoring Program.
16 I'll have to check and get the exact --
17 JUDGE WARDWELL: Well, I can probably 18 look it up also myself. I just thought you might 19 know off the top of your head. Sorry.
20 MR. NG: This is Ching Ng from the 21 staff. The name of, the title of the amp is not, 22 M1 is metal fatigue of the pressure boundary.
23 JUDGE WARDWELL: Thank you.
24 JUDGE KENNEDY: Mr. Cox or whoever's 25 appropriate, the significance of the NUREG NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5395 1 citations, NUREG/CR-6250 and NUREG/CR-5999. Is 2 that 6260? I wrote 6250. Do I have it 3 incorrect?
4 MR. COX: I believe that 6260 is the 5 NUREG. And I believe, Mr. Gray can correct me if 6 I'm wrong, this is Alan Cox again. I believe 7 that NUREG 6260 is the NUREG that defines a set 8 of representative components that should be 9 assessed for environmental effects.
10 JUDGE KENNEDY: Any thoughts on CR-11 5999?
12 MR. GRAY: This is Mark Gray for 13 Entergy. CR-5999 was the initial NUREG to the 14 industry that identified a potential issue with 15 the effects of the reactor water environment.
16 And so NUREG/CR-6260 actually did 17 their evaluation to the curves of the CR-5999.
18 JUDGE KENNEDY: Dr. Lahey, and I guess 19 in fairness Dr. Hopenfeld, other than the issues 20 that New York State has raised with the CUFen 21 calculations and the synergistic effects, do you 22 have any specific concerns in your testimony that 23 you've identified with the Aging Management 24 Program for metal fatigue?
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5396 1 later on I hope we can get into it. It has to do 2 with the predictions by WESTEMS and the 3 uncertainty or what they would call the 4 conservatisms that are in there, how to quantify 5 that.
6 JUDGE KENNEDY: Would that be the 7 CUFen, the CUF calculations then? Yes. Okay.
8 DR. LAHEY: In the CUFen calculation.
9 JUDGE KENNEDY: And we will get to 10 that. Dr. Hopenfeld?
11 DR. HOPENFELD: It's the same.
12 JUDGE KENNEDY: Okay. So we'll get to 13 that. I just wanted to make sure there was 14 nothing specific about the Aging Management 15 Program that you had issues with outside of those 16 calculations.
17 The CUF calculations, are they 18 relevant to anything other than metal fatigue or 19 the CUFen calculations? Is that strictly a, I 20 guess I'll start with Entergy. Is that strictly 21 a metal fatigue issue?
22 MR. AZEVEDO: Nelson Azevedo for 23 Entergy. Yes, that's correct, Your Honor.
24 JUDGE KENNEDY: And so how does the 25 fatigue monitoring program manage the metal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5397 1 fatigue aging effect?
2 MR. AZEVEDO: We have a site-specific 3 procedure for each unit, and we have a table.
4 And that table has the allowable number of cycles 5 that were analyzed by Westinghouse to ensure that 6 the CUF stays below 1.
7 So that is our allowable number of 8 cycles for each transient. And then 9 periodically, we go back. We actually review the 10 operating blocks from the plant and count all the 11 cycles.
12 JUDGE KENNEDY: So this is a 13 monitoring and data analysis to deal with the 14 numerator of the CUF calculation. Is that where 15 this goes?
16 MR. AZEVEDO: That's correct.
17 JUDGE WARDWELL: And by each unit, you 18 mean each plant and not some groupings of system, 19 structure or components. Is that correct?
20 MR. AZEVEDO: Yes. We have one for 21 Unit 2 and one for Unit 3 because they have 22 different cycles.
23 JUDGE KENNEDY: And are those cycles 24 monitored then for each? Are there different 25 cycles that are monitored for each particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5398 1 component that's identified as subject to metal 2 fatigue?
3 MR. AZEVEDO: Whatever the number of 4 types of cycles that were analyzed for each 5 component, we monitored those, all those.
6 JUDGE KENNEDY: Okay. Thank you. I'm 7 at the limit of my questions on the adequacy of 8 the amp. Again, I think the real issues, as we 9 pointed out earlier, lie in the CUFen 10 calculations and the CUF calculations and the 11 relative margins.
12 With that, I'm going to move away from 13 the amp discussion unless anyone on the Board 14 has, I'd like to start a little bit of discussion 15 on synergistic effects.
16 I recognize that we spent quite a bit 17 of time yesterday on synergism, but I thought it 18 would be appropriate to at least touch this issue 19 again with Dr. Hopenfeld sitting here today as a 20 witness for 26.
21 I guess I would ask if there's 22 anything that you could point to. Again, this is 23 either Dr. Lahey or Dr. Hopenfeld, if there's 24 anything in your testimony that would enlighten 25 us beyond, that we didn't touch on yesterday in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5399 1 25.
2 Any specific point in your testimony 3 that you'd like us to be aware of that wasn't 4 covered yesterday?
5 DR. HOPENFELD: Yes.
6 JUDGE KENNEDY: And what would that 7 be, Dr. Hopenfeld?
8 DR. HOPENFELD: That would be related 9 to the proposition that neutron irradiation is 10 not going to affect metal fatigue RVI components 11 because they do not contain flaws.
12 According to my analysis, that is not 13 true. A number of them does contain flaws. So 14 a crack will propagate from those flaws.
15 JUDGE KENNEDY: Can you point us to an 16 exhibit or a place in your testimony for support 17 for that assertion?
18 DR. HOPENFELD: Yes.
19 JUDGE KENNEDY: And if you need some 20 time, we can move on, and we could come back to 21 it. I'll give you a brief amount of time --
22 DR. HOPENFELD: Very brief. If you 23 look at my June 15th report on page 18.
24 CHAIRMAN MCDADE: Okay. Dr.
25 Hopenfeld, if you could, you tend a little bit to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5400 1 bob and weave when you're testifying --
2 DR. HOPENFELD: I'm sorry.
3 CHAIRMAN MCDADE: -- so you're coming 4 closer and further away from the microphone.
5 DR. HOPENFELD: As you can see, I'm 6 not a public speaker.
7 CHAIRMAN MCDADE: So maybe pull the 8 microphone a little to you so that you won't get 9 so far away from it.
10 DR. HOPENFELD: Yes. Page 18 on my 11 June 15th report.
12 MS. BRANCATO: That's Riverkeeper 13 Exhibit 144.
14 JUDGE KENNEDY: 144, and I guess that 15 reminds me. I've been referring to these as New 16 York State witnesses. I appreciate the fact that 17 Dr. Hopenfeld is here representing Riverkeeper.
18 My mistake. Thank you.
19 Page 18 of Riverkeeper 144. Is that 20 what you said, Dr. Hopenfeld?
21 DR. HOPENFELD: Yes. Do you see I 22 referring to numbers like CUFen of a factor of 3, 23 larger than the numbers that they have presented.
24 When you have factor of 3 on top of a number of, 25 this is not proprietary information.
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5401 1 JUDGE KENNEDY: I guess, Dr.
2 Hopenfeld, what support do you have for this 3 factor of 3? I wasn't able in your report to --
4 DR. HOPENFELD: Thank you. Thank you 5 very much. Can we go to Entergy 00683?
6 JUDGE KENNEDY: Are you asking us to 7 call up that --
8 DR. HOPENFELD: Riverkeeper, it's 9 NUREG 6909.
10 MS. BRANCATO: And that's actually --
11 DR. HOPENFELD: 857. Okay, NUREG 12 6909.
13 JUDGE KENNEDY: Dr. Hopenfeld?
14 CHAIRMAN MCDADE: Can you repeat the 15 exhibit number, Doctor? What was the exhibit 16 number for that, for NUREG 6909?
17 DR. HOPENFELD: It's New York 357.
18 CHAIRMAN MCDADE: 3-5-7?
19 DR. HOPENFELD: Yes.
20 CHAIRMAN MCDADE: Okay. You said New 21 York. I believe, is that Entergy 357?
22 MS. BRANCATO: No. He misspoke when 23 he referred to an Entergy exhibit. He's 24 referring to NUREG 6909, which is New York State 25 357.
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5402 1 CHAIRMAN MCDADE: Okay. Thank you.
2 DR. HOPENFELD: Can we go, can I 3 continue?
4 JUDGE KENNEDY: And this reference 5 that you've had us put up, this is to support 6 your assertion that there could be a factor of 3?
7 DR. HOPENFELD: That's correct, and 8 when you have a factor of 3, we use that on top 9 of their numbers. And again, I don't want to say 10 the number. And you put the number on their 11 numbers.
12 Then you come with the CUF or Fen 13 larger than 1, which indicates that there is an 14 engineering crack. There is a flaw.
15 Furthermore, even if the CUFen piece below 1, you 16 can also have a flaw.
17 JUDGE KENNEDY: I'm sort of a slow 18 reader here, but is there some specific section, 19 page that you're --
20 DR. HOPENFELD: Yes, page, I'm going 21 to go on. It's page 26 on that NUREG. And page 22 37, 28 and page 47.
23 JUDGE KENNEDY: You're going overload 24 us --
25 DR. HOPENFELD: Okay.
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5403 1 JUDGE KENNEDY: -- here, Dr.
2 Hopenfeld. Do you want to start with one 3 particular page?
4 DR. HOPENFELD: Let's start with page 5 26. Would you like me to make comment?
6 JUDGE KENNEDY: Point us to what 7 you're --
8 DR. HOPENFELD: Oh, yes. Would you 9 like me to comment on it?
10 JUDGE KENNEDY: In a perfect world I'm 11 hoping that you can point us to the support for 12 your assertion of the factor of 3.
13 DR. HOPENFELD: Yes, page 26.
14 JUDGE KENNEDY: Okay. Do we need to 15 come down a little bit? This appears to be 26.
16 DR. HOPENFELD: My page 26 is 17 different than this. Oh, here we go. Here we 18 go. It's just on top of 4.2.4, just a trigger, 19 just on top.
20 JUDGE KENNEDY: Are you, you want us 21 to be looking at Figure 15?
22 DR. HOPENFELD: Yes, the other figure.
23 This is for carbon scale. The other figure is of 24 --
25 (Simultaneous speaking.)
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5404 1 MR. HARRIS: I can't hear you, Doctor.
2 DR. HOPENFELD: This is for carbon 3 scale. The other figure is for stainless steel 4 or similar.
5 CHAIRMAN MCDADE: So I see a factor of 6 3 on there.
7 DR. HOPENFELD: Yes.
8 CHAIRMAN MCDADE: Is that the point 9 you're trying to make here?
10 DR. HOPENFELD: Yes.
11 CHAIRMAN MCDADE: And you're looking 12 at Figure 15, the left hand side, the middle of 13 it?
14 DR. HOPENFELD: That's correct.
15 JUDGE WARDWELL: And a factor of 3 16 basically covers the bounding limits, the upper 17 limits of all the scatter of the data rather than 18 the mean. Is that a fair assessment?
19 DR. HOPENFELD: That's correct. It 20 covers the scatter, the data. They took a series 21 of experiments, and obviously you have scatter.
22 So then they tried to correlate the light, which 23 is defined by a crack which is 3 millimeters 24 deep.
25 They tried to correlate it with an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5405 1 equation so they can deterministically calculate 2 it. And if you see here, to be conservative, 3 really you have to, you must calculate the 4 numbers by a factor of 3.
5 So when they say that the CUFen is, 6 and this is an inherent number in the 7 calculation. There is not new modeling or 8 anything up to this point.
9 The modeling would be the next step.
10 The assumptions and uncertainties in the models 11 have nothing to do with this. This is inherent 12 in the equation that they are using to calculate 13 the CUFen.
14 JUDGE KENNEDY: I guess, Dr.
15 Hopenfeld, I'm not sure I'm tracking how this 16 translates from this data to the need to apply a 17 factor of 3 on the cumulative usage factor.
18 DR. HOPENFELD: Okay. I think the 19 question is why do I apply a factor of 3.
20 JUDGE KENNEDY: Yes.
21 DR. HOPENFELD: If you take the Fen 22 factor, which is a correction factor for the 23 environment, and multiply it by the CLB CUF --
24 CHAIRMAN MCDADE: Okay. Excuse me, 25 Dr. Hopenfeld. Let me interrupt for a second.
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5406 1 There's a popular book out now referred to as 2 Lean In. Could you do that in a different 3 context?
4 You need to lean in to get closer to 5 the microphone. It's important for us to 6 understand what you're saying.
7 DR. HOPENFELD: Absolutely.
8 CHAIRMAN MCDADE: But in order to 9 understand it, we've got to hear it.
10 DR. HOPENFELD: Okay. The Fen, which 11 is a ratio of light and air to life in water, so 12 when you calculate the Fen, the Fen is based on 13 the ability to predict life in water. And that 14 represents, is represented by this data.
15 JUDGE KENNEDY: I guess, here's where 16 I'm struggling.
17 DR. HOPENFELD: Okay.
18 JUDGE KENNEDY: Entergy, admittedly, 19 was our overview discussion about CUFs and 20 CUFens, but what I heard him say is when they 21 apply the environmental adjustment factor, they 22 use a set of parameters or a methodology that has 23 been provided by the NRC and approved.
24 Is this suggesting that the NRC 25 methodology is incorrect? I don't know how to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5407 1 reconcile this with what Entergy has just 2 testified to how they adjust the CUF for 3 environmental factors.
4 I mean they clearly, well, I don't 5 think they apply a factor of three, yet they have 6 adjusted the CUF values for the plant for 7 environmental conditions.
8 We've got a lot of experts here. I 9 see it. I see a factor of 3 that covers the 10 spread in the data, but yet I recognize that the 11 Agency has provided a set of adjustment equations 12 that Entergy has said they faithfully have 13 applied.
14 We have four NRC staff witnesses. Any 15 thoughts on --
16 MR. STEVENS: Your Honor, Gary Stevens 17 of the staff. We're looking at this figure a 18 little bit out of context, so let me try and put 19 it in context for you.
20 This is an interim figure that 21 evaluating data scatter and material durability, 22 and it's not in any way indicating that the Fen 23 is off by a factor of 3.
24 And if you refer to page 25 at the 25 bottom, the text, and the discussion about Figure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5408 1 15, it in fact tells you that, the argument is 2 being made is that this modified rate approach 3 works very well and that most of the scatter is 4 due to heat variation, which we call material 5 variability.
6 The important discussion, therefore, 7 is really in Chapter 7 of this document, which 8 begins on page 71, Chapter 7, which discusses all 9 the margins that need to be accounted for in 10 doing these kinds of evaluation.
11 And specifically, material variability 12 and data scatter is discussed in Section 7 that 13 begins on page 90, or sorry, 73. And what you 14 see from all of this discussion in this chapter 15 is there are factors that are applied to the 16 design fatigue curves to account for these kinds 17 of variations that are picked up by the Fen.
18 One of those factors is data scatter 19 and material variability, and that's really where 20 this factor of 3 comes in.
21 DR. HISER: And I think, Your Honor, 22 if you go to the figure or Table 12 --
23 MR. STEVENS: What page is it?
24 DR. HISER: It's on page 76 of New 25 York State 357.
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5409 1 MR. STEVENS: So what you see in this 2 table, and thank you Dr. Hiser for point that 3 out, the very top line is material variability 4 and data scatter.
5 And what you see is in the original 6 Section 3, ASME Fatigue Curves, they considered 7 a factor of 2 originally. And in this study, 8 we've increased that.
9 These are log normal distributions 10 that were considered, but the range is 2.1 to 11 2.8. And that's effectively that factor of 3 you 12 saw in that other figure.
13 Those are built into the design 14 fatigue curve for calculating the CUF itself.
15 So, in fact, the factor 3 is accounted for in the 16 CUF calculation.
17 JUDGE KENNEDY: So Mr. Stevens, it 18 would be your expectation in the calculations 19 that Entergy performed, they would have already 20 considered this factor of 3 in the scatter of the 21 data?
22 MR. STEVENS: Correct.
23 JUDGE WARDWELL: But this Table 12 24 says present report is 2.1 to 2.8. How do we get 25 from that number to showing where the actual NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5410 1 number that was used for the fatigue curves that 2 demonstrate where in that range it was using?
3 Or does it have that range plotted 4 that you use to then estimate somewhere in 5 between it? How does that work?
6 MR. STEVENS: This is Gary Stevens 7 with the staff. The factors that are shown in 8 Table 12 are log normal distributions of how 9 these factors play into, and there's a Monte 10 Carlo statistical analysis that's done to develop 11 a fatigue curve that it bounds 95 percent of the 12 data with 95 percent confidence.
13 The results of that Monte Carlo 14 statistical evaluation results in reduction 15 factors applied to the curve, which if you scroll 16 down to Table 13 on page 77, you'll see the end 17 result is that there's a reduction in life of 18 approximately 12 to 13 applied to the curves for 19 the different materials.
20 So what you may have read in the, I'm 21 sure you did read in the testimony, are factors 22 of 2 and 20 or 2 and 12. This is where they came 23 from. The life, the fatigue, the design curve is 24 reduced by a factor of 2 on stress or 12 on life, 25 whichever is more conservative.
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5411 1 And this is where they come from. So 2 based on the statistical evaluation of those log 3 normal distributions in Table 12, to get a 95 4 percent lower bound and 95 percent confidence 5 curve, you would come up with these factors on 6 life.
7 JUDGE WARDWELL: And again, just to 8 make sure I'm clear, this is all in relationship 9 to the Fen calculation.
10 MR. STEVENS: No. This is in relation 11 to actually the design fatigue curve that would 12 be used for the CUF calculation.
13 JUDGE WARDWELL: So I guess I'd go to 14 Dr. Hopenfeld then. I think you said that this, 15 that first graph that had the factor of 3 arrow 16 applied to the water condition.
17 And doesn't that seem to conflict with 18 where we've sugared this all down to in Table 13, 19 where if it's only involved with the CU 20 calculation, the CUF calculation?
21 DR. HOPENFELD: Yes. Can I answer 22 now? We confusing two things here, I believe.
23 JUDGE WARDWELL: If you can't hear 24 yourself over the speaker, we can't hear you for 25 sure.
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5412 1 DR. HOPENFELD: I think we're 2 confusing two things. Table 3 relates to the 3 ASME code, to the uncertainty in the ASME.
4 JUDGE WARDWELL: You say Table 3 or 5 13?
6 DR. HOPENFELD: Table 13. Excuse me.
7 Table 13 relates to the ASME code, to the margins 8 that we talked. That's what he is talking about 9 here.
10 What I was talking about, the factor 11 of 3, has nothing to do, the ASME code never 12 heard of Fen. They never heard of that. This 13 was done 30 or 40 years --
14 JUDGE WARDWELL: But can you show that 15 that previous figure you referenced, and what was 16 the figure again? Let's go back to that quickly.
17 DR. HOPENFELD: That was --
18 MR. SIPOS: I believe it was Figure 19 15, Your Honor.
20 DR. HOPENFELD: 15.
21 JUDGE WARDWELL: Sorry.
22 MR. SIPOS: Figure 15.
23 JUDGE WARDWELL: Okay. There we go.
24 There it is. It's in front of you now.
25 DR. HOPENFELD: Okay. This you can --
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5413 1 JUDGE WARDWELL: Where does that show 2 that that deals with the water effects, the Fen 3 part of this equation?
4 DR. HOPENFELD: Because this data was 5 obtained in water. There is also --
6 JUDGE WARDWELL: Where is that stated?
7 DR. HOPENFELD: Yes. If you take a 8 look at the equation that you have, you see, I 9 don't know which page it is. The equation that 10 comes from this figure, the mean equation, the 11 average equation for Fen --
12 JUDGE WARDWELL: Well, maybe I can 13 simplify it. Mr. Stevens for staff, do you agree 14 that this Figure 15 relates to in water types of 15 analyses?
16 MR. STEVENS: Yes.
17 JUDGE WARDWELL: Okay. Thank you.
18 Dr. Hopenfeld, is that, do you have anything 19 further to add? I mean it seems --
20 DR. HOPENFELD: Well, I just want to 21 make sure that we understand that the 22 uncertainties in the code have nothing to do with 23 this factor of 3. It's just two different 24 animals.
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5414 1 a large number of tests, and they had to put it 2 in a matter that one could calculate the 3 conversion factor.
4 So they correlate it. You see, and 5 they correlate it. You see that correlation is 6 good within a factor of 3. And it's the same 7 thing for, this is for carbon steel, but they are 8 the same thing for stainless steel that use the 9 other pages I gave you.
10 And there's more data than these, so 11 there's a lot of data that all show that they 12 fall within a factor of 3, the ability of Argonne 13 to correlate their data so the user can put it 14 somewhere in a deterministic way.
15 That's what I prefaced my presentation 16 before. So you can calculate it analytically.
17 But if you looked at this, it is because you are 18 using a deterministic method to calculate the 19 CUFen.
20 You have to use, you have to be 21 conservative. You can look at a minus 3. You 22 cannot look at the lower. You have to take the 23 ends of your distribution.
24 You have to be conservative. That's 25 why you have to multiply this by a factor of 3.
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5415 1 JUDGE KENNEDY: Said another way, Dr.
2 Hopenfeld, are you challenging the final 3 conclusions of this overall report, which seem to 4 lead to a way to deal with the scatter in the 5 data?
6 I mean it seems like these data 7 scatter issues are addressed as Mr. Stevens has 8 pointed out. And going back to the original 9 figure doesn't seem to convince me that it's not 10 included.
11 So I think we're at an impasse here.
12 I appreciate you bringing to our attention, and 13 I appreciate members of the staff taking us 14 through the report.
15 This seems to me to be an indication 16 that what you have identified is included in the 17 ultimate calculation. I'm not suggesting you 18 agree with that, but I haven't seen anything here 19 that would lead me to believe it's not being 20 accounted for.
21 And we're going to come back. I'm 22 sure this is going to come up again. I know 23 you've got issues all through here on the 24 conservatisms and the margins embedded in the 25 calculations.
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5416 1 But at least for now, I'd like to move 2 off of this figure and off of this topic.
3 MR. SIPOS: Excuse me, Judge Kennedy, 4 John Sipos over here for the State of New York.
5 I understand Your Honor's desire to move forward.
6 I'd just note for the record the Dr. Hopenfeld, 7 I believe, also referred to page, to charts on 8 page 37 and possibly 47.
9 And page 37 is PDF frame 57 of this 10 document should we wish to ever return to it.
11 JUDGE KENNEDY: Is there something, 12 let's at least put one of those pages up and see 13 if it enlightens us differently, 37.
14 MR. SIPOS: So page 37 is PDF frame 15 57.
16 JUDGE KENNEDY: Is this not just the 17 same data for different conditions and has a 18 displayed scatter? It may lack the factor of 3, 19 but it seems more of the same to me.
20 CHAIRMAN MCDADE: That's a question to 21 you, Dr. Hopenfeld.
22 JUDGE KENNEDY: Oh, I'm sorry. Does 23 this lead us to a different conclusion that we 24 would have with Figure 15?
25 DR. HOPENFELD: Can I answer that?
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5417 1 JUDGE KENNEDY: Oh, I'm sorry, Doctor.
2 Yes, I guess I'm not being clear.
3 DR. HOPENFELD: No. It's the same, 4 just gives you more data. But the point is, it's 5 more useful. And I should have probably started 6 with this page because you can see when you 7 derive the Fen, you see that Equation 21.
8 That equation that you see here is the 9 best fit line, you see. So that is the best fit.
10 It doesn't have a factor of 3 in here. It's for 11 you to, when you calculate the CUFen, you should 12 use the factor of 3.
13 JUDGE KENNEDY: I guess instead of me 14 testifying, Mr. Stevens, would you care to 15 address this yet again? It seems to me to be the 16 same issue.
17 MR. STEVENS: You're correct. It's 18 the same issue, just with more data. The 19 previous graph on page 26 I think it was, was 20 limited because it was doing an estimate using a 21 modified rate approach.
22 So it was just done on a subset of the 23 data, and here you're seeing all the data. So 24 it's essentially the same thing.
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5418 1 in Equation 21 is not the best fit curve 2 regarding the fatigue. Equation 21 has to do 3 with the Fen factor, so I just wanted to correct 4 that.
5 JUDGE KENNEDY: All right. Thank you.
6 Just I guess as a curiosity, and we keep using 7 the words margin and conservatism. Maybe I keep 8 using them.
9 These factors to try to deal with data 10 scatter, would you view those as, and I guess 11 I'll direct it to Mr. Stevens first. Is that a 12 margin, a conservatism, or are we talking about 13 the same thing?
14 MR. STEVENS: It's a difficult 15 question. Let me see if I can clarify. And I'm 16 going to, if you'll allow me to back up just a 17 little bit on the discussion on margins and 18 conservatisms, I'm going to give you my spin on 19 this.
20 So what I would call this is a part of 21 a design factor that's built into the design 22 curve. A design factor is, in fact, contributes 23 to a margin.
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5419 1 allowed to go. And I break it into two pieces.
2 Some might think of margin as the difference 3 between where you are and what might constitute 4 a failure or a crack to initiate.
5 And another one is a margin between 6 where you are and where you're allowed to go. In 7 this case, we have an allowed CUFen of 1.0.
8 There are two different margins. And one we can 9 play with, and one we can't.
10 In the first case, the code itself 11 applies to the design factors to come in and the 12 methodology and the limit of 1.0 for CUF values.
13 And we're not allowed to play with the margins 14 that go into that value.
15 So these design factors we're talking 16 about that go into the design curve, they 17 contribute to that margin. And that's something 18 that we must meet. We can't change that.
19 And there's not even an argument to be 20 made where we can change those values and justify 21 them. It's a requirement of the code to maintain 22 those. That's one margin.
23 Another margin is if I calculate a 24 CUF, say of 0.5, I have margin between that and 25 the allowed value of 1. And that's something NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5420 1 that I can deal with and address.
2 That allows me to, for example, apply 3 more loading to the component and still maintain 4 its original design because I'm allowed, the 5 criteria that I'm allowed to go to is a CUF 6 allowed of 1.0.
7 So I look at margin as those two 8 parts. One is I can't touch, and the other I 9 can. And these design factors that we showed 10 here that went into the building of the design 11 curve that's in the ASME code, we're not allowed 12 to touch those.
13 Then we can talk about conservatisms 14 because as an analyst, if I'm doing a 15 calculation, the objective I have is to show 16 acceptability, not margin.
17 So once I achieve a CUF of less than 18 or equal to 1, my job is complete. I can stop 19 work. Any additional margins to drive that 20 calculated value lower, I'm not required to do.
21 JUDGE KENNEDY: But in the analysis to 22 try to get to that acceptable value, did I 23 understand you to say that there's a piece of 24 margin there that you can't touch, and that's the 25 stuff that's embedded in the code?
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5421 1 MR. STEVENS: The stuff that's 2 embedded into the code with respect to the limit 3 on the usage factor of 1.0 and the design fatigue 4 curves and the margins they contain and the 5 stress allowables and the design factors that 6 might be applied to those, I'm not allowed to 7 touch those.
8 Now another we can talk about is 9 conservatism, and what I kind of view 10 conservatism as are simplifications I might do as 11 an analyst to get the job done quicker.
12 For example, if I have to evaluate 100 13 different loads, I may choose to pick the worst 14 one and just assume all the other 99 are of that 15 severity to make my job to complete it quicker.
16 And that's a conservatism that I as an 17 analyst choose to put into the analysis, and I'm 18 allowed to do so much as, so long as I continue 19 to meet those required margins.
20 In this case, my CUF I calculate must 21 be equal to or less than 1.0. If I don't achieve 22 that, then obviously that simplification was a 23 little too gross, and I might have to refine that 24 simplification to still meet those margins that 25 I cannot change.
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5422 1 So I look at, we have margins. Again, 2 I'll repeat. We have a margin that I'm not 3 allowed to touch. And these design factors we're 4 talking about that are built into fatigue curves 5 fall into that category.
6 Stress limits in the code and other 7 design factors fall into that category. There's 8 a margin I might obtain in my analysis with 9 respect to what I calculate versus what I'm 10 allowed.
11 And there's conservatisms that I might 12 apply, which I look at as simplifications that I 13 might use in my calculation process to get me to 14 the end. And those are what I would call 15 conservatisms.
16 Another form of conservatism, if there 17 is some embedded in the methodology, specified by 18 ASME code and by how they calculate, how they 19 combine stresses and what limits they use.
20 And again, those are, I put that into 21 the margin category as opposed to a conservatism.
22 It is a conservative thing to do, but it's a 23 margin that I'm not allowed to touch. I hope 24 that clarifies.
25 JUDGE KENNEDY: Thank you, Mr.
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5423 1 Stevens.
2 CHAIRMAN MCDADE: If you could, 3 regrettably, I need to ask you to clarify it a 4 little bit more. We're talking about certain 5 things that you can play with.
6 And to me, that's sort of engineering 7 speak for what you can legitimately adjust. Can 8 you give me a sort of summary of those kinds of 9 factors that you can legitimately adjust and 10 those that you can't, just sort of a quick 11 summary of that? Give some examples.
12 MR. STEVENS: Some examples, I gave 13 one, which would be in the number of different 14 loads I might evaluate. I can adjust. I still 15 must look at all the different loads, but how 16 exactly I consider those loads is within the 17 purview of what I can alter.
18 Things I can't change, I can't change 19 the stress limit I'm designing to. I cannot 20 change the usage factor limit that I have to 21 design to. I cannot change the fatigue curve I 22 use to calculate that usage factor in any way.
23 Other things I might change, heat 24 transfer coefficient, things of that nature that 25 go into the analysis. I can use different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5424 1 assumptions, apply different conservatisms in 2 that.
3 So there's many aspects of the code 4 methodology that are not explicitly defined that 5 are left up to analyst judgment. And those 6 things that are explicitly defined in words in 7 the code are the things that I can't change.
8 CHAIRMAN MCDADE: Okay. Thank you, 9 Mr. Stevens.
10 JUDGE KENNEDY: Not to keep this 11 whole, Mr. Gray, earlier in the opening remarks 12 you talked about different types of conservatisms 13 and what was allowed to be changed by the analyst 14 and where there was flexibility.
15 Could you maybe put the Entergy 16 approach in the same context that Mr. Stevens 17 just did, if it's possible?
18 MR. GRAY: Yes. This is Mark Gray for 19 Entergy. I think what Mr. Stevens just said is 20 just a different semantical way of saying what I 21 said earlier.
22 The margins that are in the code 23 methodology and design curve, we did not touch.
24 We used the code design curve. We also used the 25 Fen expressions that were defined by the NUREGs.
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5425 1 The conservatisms that were, for 2 example, in that original, the original Section 3 3 design analyses were conservatism that we did 4 touch. And so we performed a more detailed 5 analysis of a component.
6 Find an element analysis versus an 7 interaction analysis, for example, and used more 8 specific loadings, using less enveloping or 9 grouping, as Mr. Stevens referred to, to remove 10 any gross conservatisms in the methodology, 11 particularly with the loadings.
12 JUDGE KENNEDY: So later on when we, 13 and I think we're going to get to a discussion 14 with Dr. Lahey and Dr. Hopenfeld about margins 15 and margin reductions.
16 I'm going to use that framework 17 hopefully when we pose questions coming up. So 18 Dr. Lahey, you have your hand up. I'll --
19 DR. LAHEY: Thank you. Can you hear 20 me all right?
21 JUDGE KENNEDY: I can. Just recognize 22 we're going to give you an opportunity to get 23 into safety margins and conservatism.
24 DR. LAHEY: Yes. And I'm only going 25 to talk about Fen right now because that's what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5426 1 you've been talking about, how to handle any 2 uncertainty by that factor.
3 JUDGE KENNEDY: To be honest, this 4 started as a discussion on synergism, and Figure 5 15 was used as an example of a synergistic issue 6 that needed to be dealt with in the CUF 7 calculation.
8 That's what I thought I had asked, and 9 maybe I've taken us down a long road. But that's 10 what I, my intent was to deal with synergism and 11 to offer up an opportunity to put anything in the 12 current testimony in front of us on Contention 26 13 that we didn't address yesterday.
14 And I know Dr. Hopenfeld didn't 15 participate yesterday even though he was here.
16 He wasn't a witness on 25. So I wanted to give 17 him that opportunity to bring that up. And 18 that's what he offered.
19 DR. LAHEY: So you don't want to talk 20 about any other uncertainty in Fen that's not 21 reflected here?
22 JUDGE KENNEDY: I believe we're going 23 to get to that.
24 DR. LAHEY: Okay.
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5427 1 to give you an opportunity. We'll have an 2 opportunity to go through that. I guess what I 3 was trying to do is close out some issues on 4 synergism.
5 And I've got a couple more questions 6 here and then possibly we can take a break.
7 CHAIRMAN MCDADE: Before you do, Judge 8 Kennedy, just to Dr. Hopenfeld, you had referred 9 not only to page 37 but also to page 47. And on 10 page 47, there's a Figure 36.
11 And that figure is basically the same 12 sort of data that was on page 37, except here is 13 relates to austenitic stainless steel and air as 14 opposed to carbon steels and low alloy steels in 15 the LWR environment. Is that correct?
16 DR. HOPENFELD: Probably, yes.
17 CHAIRMAN MCDADE: Okay.
18 JUDGE KENNEDY: Thinking back again to 19 the synergistic effects, and again here we're 20 dealing with the effect of potential irradiation 21 on metal fatigue.
22 Dr. Lahey, you provided a number of 23 references to support your synergism argument in 24 your pre-file testimony.
25 If I put aside for the time being, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5428 1 expanded materials degradation assessment report 2 or reference, what, I had a difficult time going 3 through.
4 I went through all your references.
5 I had a difficult time finding any examples that 6 would support your synergistic argument.
7 So I'm going to give you the 8 opportunity to point me to something in your 9 references, your exhibits and pre-file testimony 10 that would support your synergistic argument on 11 the potential that I missed them when I reviewed 12 your documents.
13 DR. LAHEY: All right, and thank you, 14 Your Honor. There was a report, the technical 15 paper by Korth, et. al. And I can get you a copy 16 of that if you don't have it.
17 JUDGE KENNEDY: If you could just give 18 me the exhibit number, that would be, and in a 19 perfect world if you could point me, unless it's 20 a short document. I'm pretty sure I've looked 21 through these, but --
22 DR. LAHEY: Well, we talked about it.
23 I would think you have. But anyway, in there is 24 a discussion of experiments. Now this was done 25 for fast breeder reactor conditions --
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5429 1 JUDGE KENNEDY: Right.
2 DR. LAHEY: -- higher temperature.
3 But in there they stated that when they ran low 4 cycle, I mean low amplitude, high frequency 5 fatigue experiments, because of the hardening due 6 to radiation-induced embrittlement, things were 7 better in terms of the fatigue.
8 The failure cycles were increased.
9 When they ran large amplitude, low frequency 10 fatigue experiments, it was the opposite. In 11 fact, in decreased by a factor of 2.
12 So there was a significant decrease.
13 When we talked about the experiments that Mr.
14 Lott was a coauthor of, that particular paper, 15 they also made similar statement.
16 Although they, their particular 17 experiments for light water reactor conditions, 18 which are our concern, were only done for low 19 amplitude, higher frequency fatigue.
20 But nevertheless, they cited the same 21 issue. So there's no perfect data set that I 22 know of exactly for our conditions, which would 23 allow us to quantify the degradation due to 24 embrittlement for fatigue for light water reactor 25 conditions.
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5430 1 But there's indication that there is 2 an effect, and this is being worked on for sure 3 by the light water reactor sustainability folks 4 in Chicago. So this is the basis of that 5 assertion that I made.
6 MR. SIPOS: And Judge Kennedy, just 7 for record identification, you were asking for 8 exhibit numbers.
9 JUDGE KENNEDY: Please.
10 MR. SIPOS: Korth, K-O-R-T-H, 11 Riverkeeper Exhibit 152, Arai, New York Exhibit 12 564 and Kanasaki, NRC Exhibit 177.
13 JUDGE KENNEDY: All right. Thank you, 14 Mr. Sipos. This question, I don't remember if it 15 came up yesterday, but this discussion about --
16 CHAIRMAN MCDADE: Excuse me. Just one 17 second if I could, and the Kanasaki exhibit, 18 that's the one that you were a coauthor on.
19 Correct, Dr. Lott?
20 DR. LOTT: That's correct.
21 CHAIRMAN MCDADE: And that's the one 22 you were referring to?
23 DR. LAHEY: Yes, Your Honor.
24 DR. LOTT: It's actually Kanasaki, 25 Hiroshi Kanasaki.
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5431 1 CHAIRMAN MCDADE: Okay. Thank you.
2 JUDGE WARDWELL: And what's the 3 exhibit number again?
5 JUDGE WARDWELL: Thank you.
6 JUDGE KENNEDY: I direct this question 7 to Entergy. This fast breeder reactor data with 8 the large amplitude, low frequency, is that data 9 at all relevant for metal fatigue in light water 10 reactors?
11 Is the type of fatigue that's being 12 dealt with in Indian Point 2 or 3 subject to 13 large, I guess, large amplitude, low frequency 14 fatigue.
15 DR. LOTT: No, I do not believe that 16 data is directly related to any PWR reactor 17 internals application. And we actually have done 18 some looking at the strain ranges that are in the 19 irradiated internals.
20 It's a small, very small number of 21 irradiated internals in the cumulative usage 22 factor calculations. And those tend to be on the 23 low side of the strain range within the limits 24 that were in the Kanasaki paper.
25 JUDGE KENNEDY: Dr. Lahey, any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5432 1 rebuttal to the assertion that large amplitude, 2 low frequency isn't a concern for metal fatigue 3 in Indian Point 2 or 3?
4 DR. LAHEY: No, I disagree with his 5 conclusion. I think that remains to be seen. We 6 do need a database sufficient to quantify, but 7 there's no doubt in my mind there will be an 8 effect, a detrimental effect.
9 JUDGE KENNEDY: All right. Make sure 10 I understood what you just said. Are you 11 disagreeing that large amplitude, low frequency 12 cycles are not, now we've got too many nots here.
13 Dr. Lott seemed to testify that, 14 appeared to testify that large amplitude, low 15 frequency cycling is not of a concern at Indian 16 Point 2 or 3. Is that what you're disagreeing 17 with, or are you disagreeing with something else?
18 DR. LAHEY: Yes, Your Honor. I would 19 disagree with that. The high frequency fatigue 20 is associated with things like flow induced 21 vibration, which have small amplitude but a lot 22 of cycles.
23 And I can clearly understand how the 24 hardening associated with irradiation can improve 25 the fatigue life. But when you go to the type of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5433 1 cycles that we look at here, which are associated 2 with thermal transients, with operation of the 3 pressurizer, scram, so in many different cycles 4 that they go through in a plant.
5 I think it's clearly a lower 6 frequency, larger amplitude type of application.
7 JUDGE KENNEDY: Are you saying that 8 you would characterize those types of transients 9 to be large amplitude, low frequency?
10 DR. LAHEY: Some of them definitely 11 will be.
12 JUDGE KENNEDY: Entergy?
13 MR. GRIESBACH: Your Honor, this is 14 Tim Griesbach from Entergy. I've looked at that 15 Korth and Harper paper also. That was done under 16 the liquid metal fast breeder reactor program at 17 very high temperatures, between 900 and 1100 18 degrees Fahrenheit and at very high strain 19 levels.
20 That would be considered more of a 21 creep fatigue rupture. And that describes 22 mechanisms that clearly we don't see in the PWR 23 operating environment under the stress levels and 24 strain levels that we would expect.
25 JUDGE KENNEDY: Thank you. Maybe does NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5434 1 the staff have any view towards this large 2 amplitude, low frequency? Should we be concerned 3 about it for light water reactors?
4 MR. STEVENS: This is Gary Stevens of 5 the staff. Those types of cycles are, which I 6 think we're really going to, the discussion in 7 the last few days has centered on accident loads, 8 are not something that would be considered in a 9 CUF calculation.
10 ASME code, it's not important to the 11 evaluation of those events, and ASME code doesn't 12 include the evaluation of those types of cycles 13 in the calculation of CUF.
14 JUDGE KENNEDY: Would those types of 15 events be more applicable to the shock loading 16 type discussion that Dr. Lahey has brought up?
17 MR. STEVENS: That's correct. This is 18 Gary Stevens of the staff. They're low 19 frequency, low probably events. And crack 20 initiation, fatigue crack initiation is not the 21 important thing that you evaluate for for those 22 events.
23 And that's not to say they're not 24 evaluated by ASME code. In fact, they are. It's 25 just that they're not included in a fatigue NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5435 1 calculation.
2 JUDGE KENNEDY: All right. Thank you 3 very much. Unless one of my board mates has a 4 follow up question, I would like to offer this up 5 as a time for a break --
6 CHAIRMAN MCDADE: Okay, it's just a --
7 JUDGE KENNEDY: -- if I may be so 8 bold.
9 CHAIRMAN MCDADE: -- few minutes 10 between 11:00 and 11:05. Should we come back at 11 11:15? Does anybody need any additional time?
12 MS. SUTTON: That works, Your Honor.
13 CHAIRMAN MCDADE: And we are in 14 recess.
15 (Whereupon, the above-entitled matter 16 went off the record at 11:01 a.m. and resumed at 17 11:15 a.m.)
18 CHAIRMAN MCDADE: Please be seated.
19 The hearing will come to order.
20 JUDGE KENNEDY: I have a few 21 additional questions on the general topic of 22 synergism and its relationship to metal fatigue.
23 Dr. Lahey, in my previous question I excluded the 24 expanded materials degradation assessment.
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5436 1 that come back in. It seemed to me that that was 2 a series of studies that focused on extension of 3 operating licenses beyond the 60 years.
4 And I think you used the term 5 sustainability a couple of times in the hearing.
6 I guess what I'm really wanting to discuss, and 7 conceding that there's work to be done to extend 8 the licenses from 60 to 80 years, how should the 9 Board view those particular references in this 10 particular licensing proceeding here today?
11 What's the relevance of that material?
12 Is there something in there that you can point to 13 that we need to pay attention to even though it's 14 for a 60 to 80 year license extension, if you 15 could address that?
16 DR. LAHEY: Thank you, Your Honor. As 17 I had indicated yesterday, this study is, in 18 fact, funded to go out to as far as 80 years.
19 However, no one believes, including those 20 researchers, that there's a sharp demarcation in 21 time.
22 So a lot of the issues that they're 23 concerned with extend down to 50 years, 60 years, 24 70 years, whatever. All right.
25 So they're working on what happens in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5437 1 terms of degradation, what we can count on as 2 going longer, what we have to fix or replace in 3 some way or what we can't do period.
4 And so that was the source of that.
5 Some of the things we're talking about here are 6 underway. The particular one we just got through 7 talking about, irradiation and the synergism or 8 possible synergism of embrittled material due to 9 radiation with fatigue is an experiment that 10 really there's only one place in the country it 11 can be done.
12 And that's in Idaho in their hot cells 13 and using their facility. And that's not an 14 experiment that's underway to my knowledge right 15 now because it's a big ticket, long duration item 16 if you think about how you have to do their 17 parametric experiments.
18 But it's definitely one that they have 19 in mind doing. It's just a question when it'll 20 be done. So my concern is not that we have data 21 that we can use right now to quantify the effect.
22 I know we do not. However, there's 23 indication that there is an effect. People say 24 there's uncertainty. We ought to take data.
25 Even the NRC said it's inclusive.
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5438 1 My concern is what do you do in the 2 meantime. Do you just say okay, we'll press on 3 and use our inspection program and that's good 4 enough? Or do you say there's a possibility and 5 try to put a factor in there so it's F 6 embrittlement.
7 So it's not only CUF times Fen. It's 8 times F embrittlement. And that's a number 9 greater than 1. How big it is depends on what 10 kind of margin you allow.
11 So that's really the crux of where we 12 stand. I would never say that we have the data 13 from the fast breeder program was sufficient to 14 work up the effect. I know it's not.
15 JUDGE KENNEDY: Okay.
16 DR. LAHEY: But it's not irrelevant 17 either. I do not believe it's irrelevant.
18 JUDGE KENNEDY: Let me turn it around 19 just slightly since you seem to indicate that 20 there's relevance in those documents.
21 Is there something that you could 22 point to in those references that would call into 23 question any particular decisions we would be 24 inclined to make here in this proceeding relative 25 to metal fatigue?
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5439 1 And maybe you've already done it, but 2 I'm not sure. I've got it fixed in my mind.
3 DR. LAHEY: Well, I think we've talked 4 about that issue. Yesterday, we talked about the 5 fact that you have researchers, like Dr. Chopra, 6 saying that we need, we don't have sufficient 7 data to understand any synergism that may occur.
8 We need to take data. All right. And 9 you have all these things that we've been talking 10 about today and yesterday were reviewed by the 11 NRC when they made a decision as to what to do.
12 And you had people make input as to 13 what they should consider, what they should do.
14 So it's not new. I'm not bringing up anything 15 that hasn't been discussed before.
16 What I'm suggesting is it just seems 17 to me to be questionable engineering to not take 18 into account some uncertainty when there is 19 uncertainty as to what's going to happen.
20 And it's going to happen. If it 21 happens, it's going to happen in a bad direction, 22 not a good direction.
23 JUDGE KENNEDY: Let me be more 24 specific, be even more specific. Is there 25 something in those reports that draws into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5440 1 question what has been going on over the last 20 2 years, which is extending licenses from 40 to 60 3 years?
4 Is there something specific that you 5 would point to in there that would lead us to 6 take note of what we're trying to do in this 7 proceeding, which is grant a license for another 8 20 years of operation for Indian Point?
9 I think we all recognize on the Board 10 that's there's a need to continue to grow the 11 data set and to look at issues that have, that 12 would resurrect themselves in the 60 to 80 time 13 frame.
14 But I think what we're trying to point 15 to is could we find something in those documents 16 that would draw into question what we're trying 17 to do here, which is extend a license from 20 to 18 60 years.
19 DR. LAHEY: In my view, not anything 20 different than the opinions, the suggestions and 21 the conclusions that we've already talked about 22 in the various documents, both Argonne Lab 23 documents, both informal discussions by people, 24 researchers and the technical papers, which you 25 had asked about earlier.
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5441 1 JUDGE KENNEDY: And in a nutshell, 2 what are those conclusions that those researchers 3 would offer to us?
4 DR. LAHEY: That there's the potential 5 for degradation in the fatigue life due to 6 embrittlement, and more work is needed to work up 7 a database so that we can find what that 8 degradation is, level of degradation.
9 JUDGE KENNEDY: And you view those 10 researchers as being concerned in extending the 11 life of a, extending a license from 40 to 60 12 years as well as looking forward beyond that?
13 DR. LAHEY: Absolutely, and you may 14 recall, my overarching concern is not only the 15 degradation of the fatigue life but at any time 16 during the extended operation, if you have an 17 impulsive load withstanding that in terms of core 18 coolability and damage to those components.
19 JUDGE KENNEDY: All right. Thank you.
20 Maybe I could turn to the NRC staff. Do you 21 share Dr. Lahey's concern that there may be some 22 issues that need to be addressed in this 40 to 60 23 year time period?
24 MR. STEVENS: This is Gary Stevens of 25 the NRC staff. No, we don't. Specifically, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5442 1 guess I'll point to a few things. We earlier 2 were discussing NUREG 6909, which was New York 3 State Exhibit 357.
4 And that document itself really 5 doesn't have much in the way of discussion of 6 radiation effects. However, New York State 7 Exhibit 490A, which is the draft revision 1 of 8 that document, we have a section, 1.3.2, that 9 discusses this.
10 So staff is cognizant of the issue, 11 and we're not ignoring it. And, in fact, the 12 three citations that Dr. Lahey has offered in his 13 testimony are discussed in that section of 14 NUREG/CR-6909, one of the implicitly.
15 The Arai paper, which is New York 16 State 564 is actually referenced in the Kanasaki 17 paper, which is NRC 177.
18 You've already heard testimony from a 19 lot of the experts regarding the impact of the 20 radiation on strengthened materials and what all 21 the experts say about the impact on fatigue crack 22 life initiation, fatigue initiation crack life, 23 sorry.
24 That tends to improve that. You've 25 also heard testimony regarding the Korth and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5443 1 Harper paper, which is Riverkeeper 152, that in 2 fact that testing was done at very high 3 temperatures, 900 to 1100 degrees Fahrenheit.
4 And the concerns we have with that is, 5 as was mentioned by Mr. Griesbach, fatigue creep 6 and other effects that aren't applicable to light 7 water reactors.
8 From our perspective, if I could point 9 you to one thing that probably does the best job 10 to summarize where we are with this, it would be 11 Figure 12 of the Kanasaki paper, which is NRC 12 177.
13 JUDGE KENNEDY: Should we call that 14 up?
15 MR. STEVENS: That would be helpful.
16 Yes, thanks.
17 JUDGE KENNEDY: Mr. Welkie?
18 MR. STEVENS: Okay. Figure 12 here is 19 a comparison of the test data that was irradiated 20 with respect to the ASME design fatigue curve, 21 which is what is used to calculate CUF factors.
22 And as you can see, even though 23 there's a lack of data, the data we see tells us 24 that the ASME design sufficiently covers 25 irradiation effects.
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5444 1 We've had a lot of discussion on low 2 amplitude, high cycle, high amplitude, low cycle.
3 And generally speaking, the differentiation 4 between those two comes between 10 to the 4th, 10 5 to the 5th cycle.
6 So what you see here is the data 7 stands low and high cycle regimes. In fact, this 8 plot I would say covers the general level of 9 strain amplitudes that are seen in light water 10 reactor conditions under normal and upset 11 conditions.
12 And so we have no evidence, and we're 13 reasonably assured that radiation effects are 14 adequately covered by what we know right now.
15 We agree that more data would be 16 helpful and to quantify, but all the evidence we 17 have to date supports that what we're doing is 18 adequate.
19 JUDGE KENNEDY: All right. Thank you, 20 Mr. Stevens. Dr. Lahey, would you like to 21 respond to Figure 12?
22 DR. LAHEY: Yes. I'm certainly 23 familiar with that and this paper, and I have no 24 doubt that because of the hardening that occurs 25 with irradiation embrittlement that when you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5445 1 have smaller amplitudes, like was run here, that 2 things get better.
3 My concern is for larger amplitudes, 4 and I really want to get into that when we 5 discuss the WESTEMS code and what it calculates 6 right now and some problems with those 7 calculations. But I think it's not the right 8 time at this point.
9 JUDGE KENNEDY: When you say large 10 amplitude, small amplitude, how do I view that on 11 this Figure 12? What would constitute, I guess, 12 large amplitude? What would constitute low 13 amplitude?
14 DR. LAHEY: To understand that, you 15 really need to draw the stress-strain curve or a 16 hardened material. And it steepens, the stress 17 versus strain on the ordinate and abscissa.
18 And it steepens so you get a higher 19 yield strength, a higher ultimate strength, but 20 it drops off at a much lower strain. All right.
21 So to know exactly what the strain is, you'd have 22 to know exactly what the fluence is and the 23 damage is.
24 JUDGE KENNEDY: Maybe I could go back 25 to Mr. Stevens. This strain amplitude versus NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5446 1 fatigue life, what's being represented on the Y-2 axis? And does it bear any, provide any input or 3 insight to the large amplitude, low amplitude 4 discussion?
5 MR. STEVENS: You heard testimony, 6 this is Gary Stevens of the NRC staff. You heard 7 testimony earlier of an S-N curve, and this is an 8 example of one of those.
9 And what you see on the left, the 10 vertical axis, is a measure of the stress-strain 11 that would a complement where material would be 12 exposed to. What I would call high amplitude, 13 low cycle would be the left side of the figure.
14 JUDGE KENNEDY: Okay.
15 MR. STEVENS: Left, upper left.
16 JUDGE KENNEDY: Upper left. And Dr.
17 Lahey, that would not be your characterization of 18 large amplitude, low cycle?
19 DR. LAHEY: I mean you got to 20 understand the strain is elongation over the 21 initial length, right?
22 JUDGE KENNEDY: Yes, sir.
23 DR. LAHEY: I think it depends 24 entirely on the forcing function that you put on 25 a component, which strain it goes to. And I do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5447 1 not necessarily view this as large amplitude 2 strain.
3 CHAIRMAN MCDADE: Can you quantify for 4 me what you would consider high amplitude strain?
5 DR. LAHEY: Certainly strains that get 6 you up into the plastic region. What I mean, 7 beyond the yield strength, when you're up into 8 the plastic region and beyond. Those are high 9 strains.
10 So if you plot it, you have, you want 11 me to try to draw it?
12 CHAIRMAN MCDADE: Well, just describe 13 it for here.
14 DR. LAHEY: Okay. So it comes up.
15 Then you have yield and then ultimate, and then 16 you're gone. All right. And this is strain. So 17 when you're up into the plastic region, when 18 you're out of the elastic region, that's high 19 amplitude. And then beyond it's higher.
20 JUDGE KENNEDY: What sort of events 21 would we, would lead to those types of 22 conditions?
23 DR. LAHEY: Significant bloating of 24 structures, impulsive bloating of structures with 25 thermal events.
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5448 1 JUDGE KENNEDY: Caused by?
2 DR. LAHEY: Caused by your normal 3 operational transients. We'll talk about that in 4 detail, how it's being done now and what I view 5 as the deficiencies in the code.
6 My guess is we'll need to clear the 7 courtroom when we do that.
8 JUDGE KENNEDY: I guess. I mean 9 Entergy testified earlier that in terms of metal 10 fatigue, they don't view these large amplitude, 11 low cycle events to be of concern for metal 12 fatigue.
13 Are you, again, suggesting otherwise?
14 Are we back to that disagreement?
15 DR. LAHEY: Yes, sir. I think they 16 get results, which depend entirely on the models 17 they use and the transients that are assumed.
18 And if you did things in a different way, you get 19 a significantly higher amplitude.
20 JUDGE KENNEDY: So you're suggesting 21 for the same forcing function or same event, you 22 could get different results, depending on the 23 methodology?
24 DR. LAHEY: Yes. And I'll show you 25 some reasons why they get the results they get.
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5449 1 JUDGE KENNEDY: All right.
2 CHAIRMAN MCDADE: And the clarify in 3 my own mind that it's the position of Entergy 4 that these high amplitude events are not of 5 concern is because they're not going to happen in 6 the Indian Point environment. Is that correct?
7 DR. LOTT: This is Randy Lott for 8 Entergy. That is essentially correct. Yes.
9 We're not, we believe that the particular cases 10 we have with irradiated internals will fit into 11 the scheme that's described by this Figure 12.
12 CHAIRMAN MCDADE: Okay. And your 13 disagreement is that you believe in the 14 environment present at Indian Point, these will 15 occur or may occur.
16 DR. LAHEY: Your Honor, I believe 17 they're under-predicting it right now, and I'll 18 show you why when we get into that.
19 CHAIRMAN MCDADE: Okay. And are you, 20 to differentiate, are you saying they will occur, 21 or are you saying they may occur?
22 DR. LAHEY: They may occur.
23 CHAIRMAN MCDADE: Okay.
24 JUDGE KENNEDY: All right. Thank you.
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5450 1 make a clarification. This is Gary Stevens, NRC 2 staff.
3 JUDGE KENNEDY: Okay.
4 MR. STEVENS: You have to recognize 5 that if there's a load in the design basis, even 6 one cycle of a load, it could not fall above the 7 dotted line with respect to strain amplitude, or 8 you would calculate a CUF greater than 1 and you 9 would not have an acceptable design.
10 So I just wanted to make sure that 11 we're not discussing strain amplitude loads that 12 are off the chart here because you would not be 13 able to qualify such a load for an adequate 14 design.
15 JUDGE KENNEDY: Maybe I'm mishearing 16 Dr. Lahey, but I believe he's suggesting for the 17 same events that Entergy's analyzing, he's 18 contending that he would get a different result 19 or someone else would get a different result for 20 the same event.
21 I don't know if that, where that falls 22 in this fatigue curve discussion. But I think 23 it, seems to have a general disagreement of what 24 the amplitude would be for the same event.
25 CHAIRMAN MCDADE: Is that correct, Dr.
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5451 1 Lahey?
2 DR. LAHEY: Yes, sir.
3 JUDGE KENNEDY: I needed a couple 4 minutes. There's a whole bunch of questions here 5 that were already asked yesterday on 26, so I 6 need to make sure I don't miss one nor ask you 7 that you guys have already answered.
8 At this point, I'd like to start some 9 discussion related to Dr. Lahey's supplemental 10 reply testimony. In particular, so this is New 11 York State 567.
12 And in there, there's a Figure 1, 13 which I believe Dr. Lahey has offered to try to 14 explain his position. And I think the Board has, 15 at least a number of questions to try to 16 understand what's being presented in Figure 1.
17 So Mr. Welkie, could you, if I've got 18 the right citation, it's New York State 567. And 19 there's a Figure 1 back about five or six pages.
20 DR. LAHEY: All right, Your Honor. As 21 I discuss this, you'll need to tell me what is 22 proprietary and what is not.
23 JUDGE KENNEDY: Are you suggesting 24 there's real data in there?
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5452 1 discuss the way WESTEMS works and the way, what's 2 missing and things like that. So I don't know 3 how nervous that makes Westinghouse.
4 JUDGE KENNEDY: This is a great 5 example where I thought I had a bunch of 6 conceptual questions on a depiction that had no, 7 I mean it has the concepts displayed but no basis 8 in Indian Point data or WESTEMS methodology.
9 But is it, can we start first with 10 just the figure itself? I know you don't know 11 what questions we're going to ask. But is there 12 any problem with that figure? I'm sorry?
13 MR. KUYLER: Yes, Your Honor. There's 14 no problem discussing this figure.
15 JUDGE KENNEDY: So we'll ask our 16 questions slowly, give you a chance to react.
17 MS. SUTTON: Yes, Your Honor. If we 18 start getting into the WESTEMS methodology, in 19 particular, we'll slow you down.
20 JUDGE KENNEDY: And I guess from my 21 perspective, I would, I'm a little shocked to 22 find out we're going to get into WESTEMS 23 methodology.
24 But maybe I, maybe it's a good 25 indication I don't understand this figure. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5453 1 start to walk us through it, at least with an 2 overview of what is being displayed here.
3 And we'll stop before you go into 4 WESTEMS methodology unless you can't describe 5 this figure without going into the WESTEMS 6 methodology, and we'll go a different way.
7 Could you at least, from an overview 8 perspective, describe what's being displayed 9 here?
10 DR. LAHEY: Certainly. I will do my 11 best to keep away from any sensitive information.
12 On the vertical access, the ordinate, is CUFen.
13 And you've now defined that carefully.
14 And on the abscissa, the horizontal 15 axis, is a time scale. So there's actually two 16 scales there. One is fluence, which is the 17 integrated, high energy neutron flux times time, 18 the time you're at that level and the other 19 scale, which is time itself.
20 So both of them are proportional to 21 time. So you can think about it, the horizontal 22 axis is a time axis. The only reason it's not 23 perfect is because you don't operate all the 24 time.
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5454 1 wouldn't be operating. But it's convenient to 2 just think about it as a time axis.
3 JUDGE WARDWELL: I've got to ask this 4 question right off the bat, I guess, Dr. Lahey.
5 This is Judge Wardwell. There's only one value 6 shown on each of the two axes.
7 That gives us no relation, no idea of 8 how long any of the axes are. There's no way to, 9 there's no scale, if you will, in regards to the 10 two axes such that this is only a schematic. Is 11 that a fair assessment? There's no --
12 DR. LAHEY: You should think about it 13 as a cartoon, a schematic, yes.
14 JUDGE WARDWELL: Thank you.
15 DR. LAHEY: The 10 to the 17th there, 16 when you think about fluence because it's 17 normally quoted in decades, 10 to the 21, 10 to 18 the 22, that sort of thing, you should think 19 about it as a log scale.
20 And so, 10 to the 17th was put there 21 just as a benchmark for the onset of irradiation 22 damage to carbon steel.
23 JUDGE WARDWELL: Right, but it doesn't 24 get us into any indication of where is 10 to the 25 22nd.
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5455 1 DR. LAHEY: No, but --
2 JUDGE WARDWELL: And same with the 3 CUFen on the vertical axis, we've got one.
4 That's fine, but I have no idea where 0.5 is.
5 DR. LAHEY: Well zero is on the 6 bottom.
7 JUDGE WARDWELL: Well, there's not a 8 zero there.
9 DR. LAHEY: No, but I'm telling you.
10 JUDGE WARDWELL: So that is a zero.
11 DR. LAHEY: It should be there, and so 12 halfway in between would be the 0.5.
13 JUDGE WARDWELL: Is zero on the 14 horizontal axis, or is that horizontal axis log 15 rhythmic for both values?
16 DR. LAHEY: it's a log scale.
17 JUDGE WARDWELL: Thank you.
18 DR. LAHEY: But down to the left on 19 that axis is a low fluence. So it's not of any 20 concern in terms of radiation damage. So what 21 I'm trying to show on this figure is at least 22 three things.
23 I'm sorry if I put so much data on one 24 figure, but hopefully I can talk you through it.
25 So the first thing is just let's look at what I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5456 1 call the limit line, the LL.
2 The limit line is the predictions that 3 are being done by WESTEMS now. And why do I call 4 it a limit line? Because that's what you 5 normally call a prediction or a correlation that 6 is conservative.
7 And the way WESTEMS is used and the 8 way it's been formulated is you try to make 9 assumptions such that the results have 10 conservatism in that.
11 And so it's always below. It's always 12 better, or excuse me, not below. It's always 13 closer to CUFen of 1 than what you really think 14 it should be. Is that clear to everybody?
15 All right. So as time goes on, this 16 dotted line goes up until you get to the end of 17 light for the period of extended operations. And 18 in this case, at that point, there's a margin, a 19 small margin.
20 So it would be some number slightly 21 less than 1. I don't want to quote a number, but 22 less than 1. All right.
23 Now the question is, the fundamental 24 question is because the way WESTEMS is used, 25 you're allowed to systematically, if you're above NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5457 1 1, if you make assumptions which are too 2 conservative and it gives you a result that's 3 above 1, you're allowed to go back and 4 recalculate, make different assumptions as long 5 as you can justify them, until you get below 1.
6 So in the end, as that goes on and on 7 and you get closer and closer to unity, which is 8 your failure criteria, and you start really 9 pushing it, then the question of how conservative 10 is WESTEMS? What's the margin? What really is 11 the margin that's there?
12 And everyone says it's conservative.
13 Don't worry about it because we got a lot of 14 conservatism in there. But then the question is 15 we're willing to trust, but you need to verify.
16 So how do you verify the margin? So 17 a good way to do that, the normal way to do that, 18 is you make the run. It doesn't have to be for 19 every component. You just pick one that's 20 sensitive, and you make a best estimate 21 prediction.
22 So instead of saying I'm using what I 23 think is a large heat transfer coefficient, you 24 use your best estimate for the heat transfer 25 coefficient.
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5458 1 Instead of doing all kinds of 2 assumptions that are built into the model, with 3 some conservatism, use your best estimate. And 4 then do what's known is a propagation of error 5 analysis.
6 I know the NRC likes to think about it 7 as a propagation of uncertainty. But I didn't 8 make up the words. That's what people call it.
9 And work out the intervals in plus or minus 10 uncertainty.
11 And these are, if you read any 12 technical paper, a journal paper and you see 13 experimental data with an error band on it, plus 14 or minus, that's what we're talking about.
15 It's the best fit to the data plus or 16 minus the uncertainty due to measurement errors 17 and whatever. Okay. So this is the uncertainty 18 due to prediction errors, modeling errors, et 19 cetera.
20 And that's what I've called delta. So 21 I drew three cases here. Case 1, which is all 22 the way to the right, is my best estimate line 23 assuming no degradation in the prediction due to 24 irradiation.
25 So this is no embrittlement. So BE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5459 1 means best estimate. Sub NE means no 2 embrittlement. All right. So that's what right 3 now the licensing process would propose.
4 And so if we go out here at this 5 point, then you look at plus or minus 6 uncertainty. And how do I do that? I'm 7 suggesting, and I've put in my testimony, you can 8 use a number of ways to do it.
9 One way is the Kline & McClintock 10 propagation of error analysis. And so I won't 11 write it down, but I'll tell you how it goes.
12 You just take the partial, so if you, partial 13 derivative.
14 So if you're an engineer, you just 15 love this method because you say the uncertainty 16 squared is equal to partial of a function of 17 different variables that contribute to error.
18 Partial of F, respect to X1 squared 19 and then the error in X1 squared plus the partial 20 of F at function, respect to X2 squared times the 21 error of that variable squared. So --
22 JUDGE KENNEDY: So --
23 DR. LAHEY: -- let me just give you a 24 specific example --
25 JUDGE KENNEDY: Okay.
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5460 1 DR. LAHEY: -- so it'll make it 2 concrete.
3 JUDGE KENNEDY: That's what I was 4 going to ask you for.
5 DR. LAHEY: Okay. So power is equal 6 to I square R. Right? Everybody okay with that?
7 Power is equal to I square R, electric power. R 8 is --
9 JUDGE KENNEDY: I don't know what it 10 does to fatigue, but I'll let you keep going.
11 JUDGE WARDWELL: You're just 12 illustrating the propagation of error.
13 DR. LAHEY: I'm illustrating the 14 method with something that's easy to do. So now 15 the error in power is the partial of I square R 16 with respect to I. So it'd be 2I times R times 17 the error in our current measurement.
18 So if you run an experiment, you have 19 plus or minus 2 percent error in reading the 20 amps. Okay. Plus, and so you square that. Plus 21 the partial of power respect to R.
22 So that's just I square times the 23 error in R. So you go to the manufacturer of 24 your resister, and it says this has so many ohms 25 plus or minus 2 percent. Put that in.
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5461 1 You then take the square root of both 2 sides. You have the error in your power 3 measurement. So that's just a simple way. You 4 can do it with any function.
5 And so it's not, I had the question or 6 not the question, the criticism come back, you're 7 talking about random sort of stuff. And this is 8 deterministic. This is highly deterministic.
9 You're just talking about the 10 uncertainty in these particular models. All 11 right, or these particular evaluations. So 12 that's how you get plus or minus delta.
13 Is that clear because I mean it's 14 nothing magic? It's pretty straightforward.
15 Engineers love it because it's easy to do. It 16 gets them to use their calculus, and they crank 17 their way to victory.
18 Okay. So now I've assumed, just for 19 argument's sake, that my plus error band or my 20 error bar plus delta is as shown there so that 21 the upper part of it is above CUF of 1. Okay.
22 So what does that mean? That means 23 that even my best estimate prediction has some 24 chance of exceeding 1. The best estimate is 25 significantly below, but there is an error or an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5462 1 uncertainty, which allows it to be above 1.
2 So even though, when I, now I compared 3 the limit line with the best estimate, and I 4 would say in that case, the limit line is not 5 really conservative. It's not. They think it 6 is. It's not. On the other hand --
7 JUDGE WARDWELL: But as I look at 8 this, just to make sure I understand what you're 9 saying, the error you have in that, your 10 propagation of error results ended up to be about 11 0.25 worth of CUF.
12 DR. LAHEY: Yes. They're large.
13 JUDGE WARDWELL: Order of the CUF.
14 DR. LAHEY: It would be the error --
15 JUDGE WARDWELL: That's just your 16 schematic assumption. It has, that was no 17 calculation that you derived based on CUF 18 analyses, right? That's just schematically 19 showing if you did have --
20 DR. LAHEY: If I did have this 0.25 21 arranging CUF --
22 JUDGE WARDWELL: Right.
23 DR. LAHEY: -- that's what it would 24 be. And it could be the other way. It could be 25 the top of those error bars is below, in which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5463 1 case the conclusion is the limit line is 2 adequately conservative.
3 JUDGE WARDWELL: Or another way to say 4 it, if in fact the propagation of error was only 5 0.1 in the CUF, it would be well below it.
6 DR. LAHEY: Yes.
7 JUDGE WARDWELL: Okay.
8 DR. LAHEY: If, in fact, the best 9 estimate is that far below, as shown here, 10 exactly that.
11 JUDGE WARDWELL: Or on top of it. If 12 the propagation of error resulted in 0.01 instead 13 of 0.25 as you have schematically represented --
14 DR. LAHEY: Right.
15 JUDGE WARDWELL: -- then schematically 16 representing this, it would show a very tiny, a 17 bit above the best estimate line and be well 18 below the limit line. Correct?
19 DR. LAHEY: Exactly.
20 JUDGE WARDWELL: Okay.
21 DR. LAHEY: Then I would be very 22 happy. I'd say I'm happy.
23 JUDGE WARDWELL: And you don't have 24 any data to show what that bar should be.
25 DR. LAHEY: I don't have anything, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5464 1 when they get really, really tight, and they 2 start working out in the plasticity region, 3 you're really pushing the envelope.
4 And I need to know what the margins, 5 I think it's very imprudent not to know what the 6 margin is. I mean if we're really working our 7 way out in the bathtub curve towards the upper 8 part.
9 JUDGE WARDWELL: This schematic, 10 again, is just illustrating what it might look 11 like, if in fact, you hit it up with --
12 DR. LAHEY: -- a large bar --
13 JUDGE WARDWELL: -- error bar like a 14 quarter of a total distance.
15 DR. LAHEY: Where would that bar come 16 from? For example, can I deviate, Your Honor, 17 from this plot for a little bit?
18 JUDGE KENNEDY: Let's stay right here 19 for a second.
20 DR. LAHEY: Because I can tell you why 21 that error bar may be large. And we'll come back 22 to it. All right. So the next part of this is, 23 now let's say that the concerns not only that I 24 have but others have about the possible 25 degradation of the fatigue life due to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5465 1 embrittlement, due to radiation-induced 2 embrittlement or thermally-induced embrittlement, 3 but here, radiation because of fluence.
4 So now I have a curve, which goes up.
5 And until it gets to about, I don't know, 10 to 6 the 21 or six point, they have a criterion, 6.7 7 times 10 to the something or other, it'll stay 8 essentially the same.
9 And then it starts getting worse 10 because the denominator gets worse. Remember, 11 it's the number of cycles over the number of 12 cycles to failure times Fen.
13 So the number of cycles to failure.
14 If embrittlement reduces that, the denominator 15 gets smaller. Therefore, the CUFen prediction 16 gets bigger. So now --
17 JUDGE KENNEDY: Just for argument's 18 sake, we've been at this for a couple of days.
19 I'm still not sure we've seen the support for the 20 premise that that synergistic effect occurs.
21 I mean it's an interesting hypothesis, 22 and this certainly demonstrates the hypothesis 23 that's been in front of us through all this 24 testimony. But I'm still looking for that 25 citation that points us to where this hypothesis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5466 1 has been supported.
2 DR. LAHEY: I would love to bring you 3 the data, Your Honor, but it won't be here for a 4 few years. That's the problem.
5 JUDGE KENNEDY: So you're --
6 DR. LAHEY: But people aren't spending 7 millions and millions of dollars of taxpayer 8 money just for the fun of it. I mean they're 9 worried about it as well.
10 CHAIRMAN MCDADE: Excuse me. Dr.
11 Lahey, let me make sure I understand. What 12 you're saying is because of an absence of data, 13 that in your view, this error bar should be 14 large?
15 DR. LAHEY: No. And Your Honor, I'm 16 not trying to tie that to our uncertainty as to 17 whether this embrittlement impacts it or not.
18 I'm going to assume here it does for this 19 particular curve.
20 JUDGE WARDWELL: The comment I would 21 like to make would be to get this on even footing 22 would be that you've got the lines labeled wrong.
23 It's not BE with no embrittlement.
24 It's really BE assuming embrittlement 25 doesn't affect the strength, and then your BE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5467 1 with the E isn't BE with embrittlement.
2 DR. LAHEY: Exactly.
3 JUDGE WARDWELL: It's BE with the 4 assumption that embrittlement does affect fatigue 5 life.
6 DR. LAHEY: I agree. That's a very 7 good way to think about it. Or it could be 8 something without embrittlement. I mean just no 9 irradiation, but that's a very good way to think 10 about it.
11 JUDGE WARDWELL: Right.
12 DR. LAHEY: So anyway, if you'll buy 13 this just to see what happens, what happens as 14 time goes on, this fluence goes on. It's gets 15 worse and worse.
16 And at some point, it hits 1.0 well 17 before the end of a period of extended operation.
18 In fact, so that's 0.2. But in fact, at 0.3, if 19 you tie on the uncertainty --
20 JUDGE WARDWELL: There's no facts in 21 this figure. Is that correct?
22 DR. LAHEY: Well, in fact, that's the 23 only fact. Yes. I mean this is my cartoon, man.
24 I'm the cartoonist, so I can do as I wish. So 25 anyway, when you get to 0.3, you now have that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5468 1 uncertainty bar.
2 And you see that well before the end 3 of the period of extended operation, if it 4 happens that there is synergism with irradiation 5 and fatigue, you will have a good chance of 6 fatigue failure.
7 So that's how this all fits together.
8 Now, the reason I put this in my testimony was 9 because we kept saying for years you're giving us 10 this limit line prediction.
11 You're giving us these CUFen results, 12 and you keep cranking it up, cranking it up.
13 You're going to make sure what they call 14 conservatism, you keep eliminating them.
15 And I'm worried about at some point, 16 it's not longer conservatisms. It's necessary 17 margins that you're cutting into, design margins.
18 And so I need, to feel comfortable, I need to 19 know what's the margin.
20 Is it really that conservative, to 21 don't worry about anything? You can just keep 22 iterating. Or at some point, are you non-23 conservative?
24 And the only way I know to get that, 25 and we've been suggesting it for years is do an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5469 1 error analysis. And this is how you do an error 2 analysis. I sent references to a textbook all 3 sophomores at RPI used to learn how to do this.
4 And it bounced.
5 It didn't work. They thought, it 6 doesn't matter what they thought. But anyway, 7 now I figure if I draw a cartoon and write down 8 the equation for a propagation of errors, you 9 can't miss it.
10 That's what I'm talking about. So 11 this is a plea to do this because I don't know 12 any other way to know what the margin is.
13 It's not good enough to say there's 14 conservatism, and I've done this and that because 15 later on I'm going to show you other pictures, 16 which show you things that they believe are 17 conservative assumptions, which are not.
18 They're doing them in the wrong way.
19 I mean they're not conservative. They're missing 20 the boat on some of these things.
21 JUDGE KENNEDY: I've got millions of 22 questions. One thought that comes to mind, we 23 had a lot of discussion earlier about margins, 24 the margins that are in the ASME code calculation 25 plus the margin to CUF of 1, and then on top of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5470 1 that, the concept of conservatisms.
2 I'm assuming you tracked that 3 conversation before.
4 DR. LAHEY: Yes.
5 JUDGE KENNEDY: How does that bear 6 into this cartoon here? Does the best estimate 7 have margins in it?
8 DR. LAHEY: I would suggest to compare 9 apples and apples, that all the ASME code 10 conservatism, which is similar to what we talked 11 about earlier, all right, should remain in the 12 best estimate. I have no trouble with that.
13 JUDGE KENNEDY: Right. And I believe 14 I heard Entergy testify that they don't and will 15 not reduce those margins, that those are off the 16 table.
17 DR. LAHEY: I think they're off the 18 table.
19 MR. GRAY: Yes, that's correct.
20 DR. LAHEY: They're off the table.
21 JUDGE KENNEDY: So we've got margins 22 --
23 DR. LAHEY: Yes.
24 JUDGE KENNEDY: -- that nobody's 25 disputing.
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5471 1 DR. LAHEY: So you might quarrel with 2 it being called best estimate, but anyway, those 3 margins are in there because fatigue, the onset 4 of a crack is a random process.
5 I used to do this at GE, and you run 6 these samples. And they all look the same, but 7 they all don't have the same number of cycles to 8 failure. But if you then plot it up, they're 9 within a band.
10 And then the uncertainty that the ASME 11 puts on bounds that plus a little more surface 12 finish and et cetera, et cetera. So I think 13 that, you don't touch.
14 That's not part of the best estimate.
15 Otherwise, it's really not apples and apples 16 comparison with your limit line.
17 JUDGE KENNEDY: I mean I think the 18 other question you've already, you already 19 testified that the limit line, again, potential 20 WESTEMS calculation has conservatisms built in 21 it.
22 And it's difficult to me. I can sort 23 of, I sort of understand your best estimate and 24 then doing an error analysis and getting an 25 uncertainty and laying that on top of there.
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5472 1 I don't know how to translate that to 2 the load limit line and put an uncertainty on 3 that in the same manner because it already has 4 conservatisms built into it.
5 DR. LAHEY: I'm sorry I'm mislead you.
6 I'm not recommending you put a plus or minus 7 uncertainty on the limit line.
8 JUDGE KENNEDY: Well, I --
9 DR. LAHEY: The limit line, by 10 definition, is supposed to be conservative.
11 JUDGE KENNEDY: But I thought I heard 12 you say that because of the uncertainty, even 13 though the limit line shows a CUF less than 1 at 14 end of life, it could actually be greater than 1 15 because of the uncertainty.
16 And I guess all I'm suggesting, do you 17 really intend to apply the same uncertainty to 18 the best estimate line and the limit line?
19 DR. LAHEY: So let's go back to Case 20 1 again. And so we can say here's the best 21 estimate, which I would agree with Judge 22 Wardwell, we could think about as a best estimate 23 calculation where no effective embrittlement is 24 taken into account.
25 And then you have an uncertainty bar, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5473 1 and we can talk about what goes into that, why I 2 think it might be large. It exceeds unity at the 3 top. The plus delta exceeds unity.
4 So that says if you really do the best 5 you can do and do the error analysis or the 6 uncertainty analysis, there's a pretty good 7 chance you're going to have a failure at that 8 point or actually a little before that point.
9 So your prediction in your limit line, 10 which says it's below 1 is wrong. It really --
11 JUDGE KENNEDY: I'm sorry.
12 DR. LAHEY: -- is not taking into 13 account what the true situation is. It can fail 14 earlier. It's not conservative.
15 JUDGE KENNEDY: I guess I don't know 16 how you, well, again, recognizing this is a 17 cartoon, but we're trying to bring it into the 18 real world here because it is demonstrative of 19 the issues we're trying to deal with.
20 DR. LAHEY: Exactly.
21 JUDGE KENNEDY: And we're going to get 22 to margins and conservatisms probably as we move 23 through the day.
24 I have a difficult time trying to 25 think in the same terms of a best estimate line NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5474 1 with uncertainties and a limit line that has 2 uncertainties or conservatisms already embedded 3 in it with the same uncertainty band around it.
4 So, I mean I could argue on the other 5 side, and maybe Entergy would and maybe we should 6 give them a chance, that that limit line is so 7 conservative there's no uncertainties to be 8 placed on that limit line. And it's good to go.
9 DR. LAHEY: That's exactly what they 10 do, Your Honor. And now the question is, is it 11 that conservative? And here's how you determine.
12 Let me tell you where, I'll give you another 13 example.
14 I don't know exactly your background, 15 so I don't know if this is helpful. But in the 16 world that I have lived in, we worry about the 17 thermal limits on the fuel, so-called critical 18 heat flux.
19 So if you plot the flux versus 20 quality, you take the experimental data. And one 21 way to run your plant is draw a line underneath 22 all that data. That's the limit line.
23 And as long as you don't go in heat 24 flux greater than that, you're okay. The other 25 way is to make a best fit of that data plus or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5475 1 minus uncertainty and then evaluate it.
2 Both ways have been used in the past.
3 I've used both ways.
4 JUDGE KENNEDY: Are those the two ways 5 that are evidenced on this chart?
6 DR. LAHEY: That's our two ways. But 7 the question is, because we don't have any way to 8 know has this been drawn under all the data. I 9 mean is it, are they living in a fool's paradise, 10 I mean is one way to think about it.
11 Do they think they're all that 12 conservative, and they're not really?
13 JUDGE KENNEDY: I guess said another 14 way, if that limit line isn't right, we should be 15 seeing failures in real plant data with CUFs less 16 than 1. So we have a CUF prediction based on the 17 limit line that's 0.9. That component fails due 18 to metal fatigue.
19 DR. LAHEY: Well, there have been some 20 failures, which have been attributed to 21 manufacturing flaws and things like that when 22 they're below 1.
23 But in fact, we haven't run this out 24 far enough to take into account the effect of 25 embrittlement, for example, and what that might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5476 1 do to it.
2 JUDGE KENNEDY: And again, that's the 3 inconclusive data that you constantly point to.
4 DR. LAHEY: That's one way to do it.
5 JUDGE KENNEDY: Maybe just in case I 6 didn't hear it right, you don't, you're not aware 7 of any metal fatigue failures where a predictive 8 technique would have predicted that the metal 9 shouldn't have fatigued and failed.
10 Is there any evidence of that that 11 you've seen?
12 DR. LAHEY: Yes. There has been that 13 data. I don't know I can give you the reference 14 off the --
15 JUDGE KENNEDY: Is that different than 16 the manufacturing defects that you just --
17 DR. LAHEY: That's what they attribute 18 it to.
19 JUDGE KENNEDY: Maybe --
20 DR. LAHEY: I think it was a 0.7, 21 Havana 0.7.
22 JUDGE KENNEDY: What would that be 23 indicative of in this whole discussion here about 24 trying to manage aging for metal fatigue? Is 25 that an issue that's not included, not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5477 1 considered?
2 DR. LAHEY: The reason I'm doing this 3 and I'm concerned with it is because we have been 4 asked to trust the results are conservative.
5 Trust us. They're conservative.
6 And then we can go back and keep 7 reducing what we view as conservatisms that are 8 unnecessary because we have so much margin we 9 don't need them.
10 And it just gets tighter and tighter 11 and tighter. And at some point, you worry about 12 how do you know what the conservatism is. How 13 much conservatism do you really have? And this 14 is the only way I know how to actually get at 15 that.
16 JUDGE KENNEDY: If Entergy reduced the 17 conservatisms, took all the conservatisms out and 18 left only the margin, design margins or whatever 19 the right word is in the ASME code, is that still 20 a conservative calculation?
21 DR. LAHEY: I think they could use, 22 the WESTEMS code is really an encoding of a 23 procedure that we used to do by hand. In 1961, 24 when I did my first job, I was doing exactly 25 this, thermal stress analysis, but we did it all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5478 1 by hand.
2 Now it's much more encoded, and I 3 think that's great. It helps out as long as you 4 get it right. I can show you later on what they 5 would need to do to that code to do a best 6 estimate calculation.
7 They do it with that code. And then 8 do the error analysis and sit the problem, answer 9 the concern. Is it conservative or not?
10 JUDGE KENNEDY: And again, I guess 11 what we'd be most interested in is can you 12 identify a problem with using the margins that 13 are in the ASME code plus some conservatisms or 14 no conservatisms to generate a load limit line.
15 What is fundamentally wrong with that?
16 DR. LAHEY: At the end of the day, 17 that may cover all the concerns. But it's not 18 for sure. And when you're playing with the 19 health and safety of people in this area of the 20 country, I think it's not the right thing to do.
21 JUDGE KENNEDY: Are you suggesting 22 that there's insufficient margin in the ASME 23 calculation to cover the uncertainties in, I 24 guess, the overall calculation?
25 DR. LAHEY: Yes. For example, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5479 1 ASME code, the 20 cycles and the factor, or 2 excuse me, the two cycles and the factor of 20, 3 20 cycles and a factor of 2 on stress, that is 4 for the air data.
5 If you look at the Fen prediction, and 6 you think about how did they take that data. So 7 how did they take that data? They did it in 8 autoclave. So they put the little machine that 9 runs the fatigue experiments, and you could 10 control the chemistry, the temperature.
11 You could do a precise job. And then 12 that's what they fit and got the Fen correlation.
13 The problem is, when you go to the plant, then 14 you look at a flow situation where you have 15 turbulence and you start thinking about what the 16 chemical engineers called surface renewal theory, 17 sub-shielding of the oxygen.
18 You get a lot of sub-shielding in an 19 autoclave that you would not get in the real 20 application. So is the Fen really accurate, and 21 how do you put that uncertainty into the thing?
22 Well, this is one way to do that.
23 It's part of the delta.
24 JUDGE KENNEDY: So your concern isn't 25 with the original CUF calculation and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5480 1 uncertainties in that. Your concern is with the 2 environmental adjustment factor and covering the 3 uncertainties in that.
4 DR. LAHEY: It's only one part.
5 There's also part of the modelings that we can 6 get into, which are not, which are really not 7 conservative at all. They're non-conservative.
8 JUDGE KENNEDY: I think, let's stay on 9 the cartoon for a while.
10 JUDGE WARDWELL: I got a question 11 before we leave this cartoon.
12 (Simultaneous speaking.)
13 JUDGE WARDWELL: -- one clarifying 14 thing that may --
15 JUDGE KENNEDY: Thank you, Dr. Lahey.
16 JUDGE WARDWELL: Give you some time, 17 give you time to think of something else. But I 18 do want to clarify one statement you made early 19 on. You stated that that limit line is 20 associated with the WESTEMS calculation.
21 Correct? That's what you said.
22 DR. LAHEY: I'm calling the results of 23 the WESTEMS calculation a limit line, yes.
24 JUDGE WARDWELL: Okay. But isn't the 25 WESTEMS just a computer code that is one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5481 1 mechanism to calculate out the CUFs. The limit 2 line is just a calculation of the CUFs. Could it 3 not have been done by hand?
4 DR. LAHEY: Absolutely.
5 JUDGE WARDWELL: Okay. So that limit 6 line is not necessarily indicate of WESTEMS or 7 not. It's the calculation of the CUF line.
8 DR. LAHEY: Right. If you made the 9 same assumptions that they make in the code --
10 JUDGE WARDWELL: Right.
11 DR. LAHEY: -- and did it by hand, 12 well they may, you may have a WESTEMS limit line.
13 JUDGE WARDWELL: Right. You may have 14 whatever, but a limit line is not unique, I'm 15 saying, in regard, your cartoon is not unique to 16 WESTEMS.
17 It could be a cartoon for any limit 18 line that happened to be calculated to, happened 19 to be done, calculating out the CUF relationship 20 with either the time for a period event at 21 operation or the fluence.
22 DR. LAHEY: Yes, sir. When I say 23 limit line, what I mean is instead of a best 24 estimate, it's a supposedly conservative 25 calculation.
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5482 1 JUDGE WARDWELL: Right.
2 (Simultaneous speaking.)
3 DR. LAHEY: Right now the question is 4 --
5 JUDGE WARDWELL: However it was done.
6 DR. LAHEY: -- is it really, and 7 what's the margin.
8 JUDGE WARDWELL: Fine. I just wanted 9 to clarify that point --
10 DR. LAHEY: Right.
11 JUDGE WARDWELL: -- that it's not just 12 a WESTEMS calc.
13 JUDGE KENNEDY: All right. Dr. Lahey, 14 is there anything additional that you'd like to 15 discuss? This is Judge Kennedy, on this figure.
16 DR. LAHEY: Unless there's any 17 questions, I've tried to explain it. If I didn't 18 do it, please have somebody ask me.
19 JUDGE KENNEDY: I think we'll have 20 additional questions when we get to the 21 conservatisms discussion later.
22 DR. LAHEY: All right.
23 JUDGE KENNEDY: I guess I'll turn to 24 Entergy. Do you have any rebuttal to this 25 figure, this cartoon, other than what's been --
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5483 1 MR. GRAY: This is Mark Gray for 2 Entergy. The concept is pretty straightforward, 3 and if we were trying to do a precise 4 calculation, we probably could use such a 5 technique.
6 But what we would propose, in fact, is 7 you can do this on the front end or on the back 8 end. If you do it on the front end, you select 9 your inputs in such a way that the only error 10 that you're going to get is going to go below the 11 limit line.
12 And so when we are maximizing stresses 13 so that we can get a conservative usage factor, 14 we select the inputs to the stress calculation, 15 and we model the calculation that we do for the 16 stresses, such that we're already calculating a 17 larger than expected load and stress range that 18 we use for the fatigue calculation.
19 So I would say that the calculation 20 that we've done is sufficient because any 21 uncertainty on our assumptions would go in the, 22 would make the answer less.
23 JUDGE KENNEDY: So you don't, do you 24 not feel the need to add any uncertainty upon 25 your calculation, as Dr. Lahey has indicated, a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5484 1 delta above your calculation to account for 2 uncertainties?
3 MR. GRAY: No, we do not.
4 JUDGE KENNEDY: Do you believe they're 5 included in the original calculation, analysis 6 method?
7 MR. GRAY: Yes.
8 JUDGE KENNEDY: This discussion of the 9 ASME margins that I may have miscommunicated, 10 going back to some conservatisms can be removed, 11 margins cannot be removed.
12 So one thought I had in trying to 13 address Dr. Lahey's concern about the reduction 14 in conservatism is to suggest that there's still 15 margins in the code evaluations.
16 Is that a true statement? Is their 17 margin still, are those untouchable margins in 18 the code something that can be relied on to give 19 confidence in the final result?
20 MR. GRAY: Yes. As we said 21 previously, we're not touching those margins in 22 our selection of inputs and conservatisms in the 23 analysis.
24 JUDGE KENNEDY: Are those margins 25 sufficient to cover potential uncertainties in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5485 1 the analysis, or is that the wrong way to be 2 thinking about this?
3 MR. GRAY: The ASME code doesn't 4 dictate the method that you use to get your 5 stresses, for example.
6 It has some very high level guidelines 7 of the ways that you treat the stresses that you 8 calculate and how you conform them to the 9 equations that are stipulated that you meet in 10 the code on your way to calculation of the usage 11 factor.
12 After that, the analyst must justify 13 that his stress calculation is a conservative.
14 JUDGE KENNEDY: Go ahead.
15 DR. LAHEY: Your Honor, could I say 16 one thing on that his?
17 JUDGE KENNEDY: On the ASME margins?
18 DR. LAHEY: On the statement and your 19 suggestion. By definition, a limit line 20 shouldn't have any plus or minus delta on it. I 21 mean it's very consistent to use ASME code 22 assumptions of conservatism in a limit line.
23 It's very consistent to make 24 assumptions to make it conservative. But by 25 definition, it doesn't need any uncertainty NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5486 1 because it's a bounding calculation.
2 It has enough conservatism built in.
3 The only thing of concern is what is it. I mean 4 --
5 (Simultaneous speaking.)
6 JUDGE WARDWELL: Yes. I think that 7 will get into my questions I have for Mr. Gray.
8 So as I heard you said that you know what those, 9 as you're assuming conservative parameters for 10 your input that you're allowed to do, you're 11 aware of those that you are doing.
12 And you're usually motivated, as I 13 heard Mr. Stevens say, usually probably because 14 it's a less expensive analysis because you can 15 simplify some of the runs or whatever else.
16 But you are aware of what those are.
17 Correct?
18 MR. GRAY: That's correct.
19 JUDGE WARDWELL: Right. And so you 20 are developing a limit line. And what you're 21 saying is that with that limit line, as long as 22 we're below 1, we know we're conservative.
23 MR. GRAY: That's correct.
24 JUDGE WARDWELL: But likewise, you 25 could also take out all those conservatisms out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5487 1 of that for every one of the parameters. Could 2 you not right off the bat?
3 MR. GRAY: Theoretically you could.
4 JUDGE WARDWELL: And so you could 5 create a best estimate line because that's where 6 you would be at that point. Would it not be the 7 closest to your guess of what truth would be in 8 that particular sets of materials and the 9 resulting CUFs that you're calculating with the 10 cycles that are applied to it?
11 MR. GRAY: While your suggestion might 12 be a responsibility --
13 JUDGE WARDWELL: I'm not suggesting 14 anything. I'm just saying you could come up with 15 that best estimate line, if in fact, you 16 eliminated all the, you took your best estimate 17 of all the parameters that you're putting in, not 18 incorporating any of the conservatisms, the 19 margins.
20 MR. GRAY: If you had a way to do 21 that, that might be possible, but I don't believe 22 that that's possible. So we do always make some 23 conservative assumptions, yes.
24 JUDGE WARDWELL: Well, I thought you 25 knew how much conservatism, conservative nature NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5488 1 of your inputs that developed your limit line.
2 MR. GRAY: You know what maximum loads 3 are. You know what maximum inputs are, for 4 example. That doesn't mean you know precisely 5 what the actual value might be.
6 JUDGE WARDWELL: Or another way to say 7 it, you really don't know what you would want to 8 say is your minimum loads necessarily.
9 MR. GRAY: Or best estimate.
10 JUDGE WARDWELL: Best estimate load.
11 Okay. Thank you. Let me just finish up. But if 12 you could, if you were able, I understand what 13 you just said.
14 But if you were able to, that would 15 just create a best estimate line. Correct, in 16 regards to just trying to correlate what you're 17 saying with this cartoon?
18 MR. GRAY: That could be possible.
19 JUDGE WARDWELL: Okay.
20 MR. STEVENS: Your Honor, Gary Stevens 21 as NRC staff. Would you mind if I said a few 22 words here?
23 JUDGE WARDWELL: Not at all.
24 MR. STEVENS: I guess I would 25 interpret it that he would not be allowed to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5489 1 a best estimate line because, let's go back to 2 the margin discussion that I had earlier.
3 Part of the margin is things he can't 4 touch. In order to do an appropriate uncertainty 5 analysis, if you could, which by the way you 6 can't because the code would not allow that.
7 And the reason it would not allow that 8 is because part of your best estimate analysis 9 would be to use a best estimate fatigue curve, 10 which you're not allowed to do.
11 JUDGE WARDWELL: Of the what curve?
12 MR. STEVENS: Fatigue curve or the S-N 13 curve, to calculate your CUF. You're not allowed 14 to do that with the code. You have to use the 15 design curve --
16 JUDGE WARDWELL: But haven't we taken 17 out, we all agree that we're not going to touch 18 those code things. And those are as if there are 19 no margin. We were taking those at those values, 20 and we're not touching them.
21 MR. STEVENS: Well to me, that's not 22 a best estimate analysis.
23 JUDGE WARDWELL: I'm only using that 24 phrase in regards to this cartoon. I'm not 25 giving it any other credence in regards to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5490 1 bestness of it or the estimate of it. It's just 2 nomenclature to relate to this cartoon. That's 3 all.
4 You would create a line below your 5 limit line that would have the conservative 6 assumptions that you've made and are allowed to 7 make out of it is all I'm saying.
8 You could derive a line for that is 9 what I was asking. Okay.
10 MR. STEVENS: Okay.
11 JUDGE WARDWELL: Any other comments on 12 that? So I understand that there are those 13 margins from the code and actions required by the 14 code that limit the degree that you can touch.
15 And I think we all agree those are 16 untouchable and will always be in there.
17 MR. COX: Yes. Your Honor, one 18 comment on that. I think if I understand Mr.
19 Stevens correctly, you could do that, but you 20 wouldn't have a best estimate line. You would 21 have a lower limit line.
22 JUDGE WARDWELL: Well, call it 23 anything you want to. I'm only using, again, I 24 only use that nomenclature in reference to 25 picturing this on this cartoon.
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5491 1 Call it an Ernie line if you want. I 2 don't care what you call the line. I'm not 3 giving it any credence that it is the best 4 estimate. I'm just giving it a, being consistent 5 with what's on the cartoon. That's all. Thank 6 you.
7 DR. LAHEY: Your Honor, I certainly 8 agree. And I think I said earlier, to do this 9 "best estimate" --
10 JUDGE WARDWELL: You don't like my 11 suggestion of Ernie?
12 DR. LAHEY: But I would recommend you 13 retain the ASME code. And so it's not exactly a 14 best estimate, but then it's apples and apples 15 comparison.
16 So some things that, just so you 17 understand, one of the things that we're talking 18 about here is right now you make an assumption of 19 so many scrams during the light.
20 Let's say your best estimate of number 21 of scrams is 100, and so, but you really don't 22 use the same thing. I mean you can use 200 in 23 your limit line.
24 And you say I got conservatism here, 25 which you do if you really believe you only have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5492 1 100. So you'd use 200 in the limit line and 100 2 in the best estimate and go through each one like 3 that.
4 And in the end, you have some way to 5 define what sort of margin. We have some ability 6 to understand what's the cushion, if any. Right 7 now we don't know, particularly as you get closer 8 and closer and closer.
9 I come from a background where if I'm 10 sitting there in my office, and I ask somebody to 11 design a piece of equipment to last for 60 years 12 and fatigue is one of the issues, and they come 13 in with a design where they're rapidly 14 approaching 1 and they got all kinds of, it's 15 really at the bitter edge, I'd throw them out of 16 the office.
17 I'd say, listen guy. You're not going 18 to design a piece of equipment like that. But 19 now because we can't redesign the reactor, we're 20 asking to get out there, the stuff that any 21 rational engineer would never accept.
22 So what you need is enough confidence 23 you got enough margin in there to take into 24 account anything that may happen. That's where 25 we're at.
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5493 1 JUDGE KENNEDY: I can't let the 2 rapidly approaching 1 go by the wayside without 3 asking a question. Do you perceive the CUF 4 values that are calculated for Indian Point 1 and 5 2, 2 and 3?
6 I don't know what the values of 1 7 would be, for 2 and 3 are rapidly approaching 1 8 over the next 20 years?
9 DR. LAHEY: Well, they're --
10 JUDGE KENNEDY: And I'm not sure what 11 --
12 DR. LAHEY: Yes, they're --
13 JUDGE KENNEDY: -- graphically 14 approaching means in this context.
15 DR. LAHEY: I can give you a numerical 16 value, but I was asked not to do it.
17 JUDGE KENNEDY: Well, let's --
18 DR. LAHEY: There are several 19 components are --
20 JUDGE KENNEDY: Let's say for 21 argument's sake they're all going to get to 1, 20 22 years from now. Is that your concept of rapidly 23 approaching?
24 DR. LAHEY: Yes.
25 JUDGE KENNEDY: And why is that a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5494 1 concern?
2 DR. LAHEY: If you get to 1 or beyond, 3 you got a problem. Well, even in the licensing 4 basis, they would have to take action at that 5 point, yes.
6 JUDGE KENNEDY: Right.
7 DR. LAHEY: If I'm, if you calculate 8 at the end of 60 years, end of period of extended 9 operation, you have a CUFen of 0.2, I'm not 10 really concerned about that.
11 But if it's decimal point, you know 12 what I'm saying?
13 JUDGE KENNEDY: So your concern, as it 14 gets to 1, what do you perceive happens when the 15 CUF value gets to 1? Do we lose the intended 16 function? Do we crack? Do we fail?
17 DR. LAHEY: The assumption, of course, 18 is you get a crack of 3 millimeters. My, as you 19 may remember from the last couple days, my 20 problem is as this, and this is a new discussion 21 I'm going to create.
22 JUDGE KENNEDY: It is.
23 DR. LAHEY: As this thing fatigues --
24 JUDGE KENNEDY: I started it.
25 DR. LAHEY: We hear and we hear, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5495 1 you get a number of microcracks. And all of a 2 sudden you have an impulsive load. Then you've 3 got a big problem. So I don't want a design 4 where things get very degraded.
5 JUDGE KENNEDY: I guess I'm getting 6 confused again because I thought we put to bed 7 this question of did they analyze these shock 8 loads. And I'm assuming that this covers all the 9 way up to the maximum CUF values that they have 10 in their analysis to date.
11 Are you suggesting they did not do 12 that? I thought we just settled that question.
13 DR. LAHEY: What we talked about this 14 morning was for the baffle bolt, baffle former 15 bolts. An analytical method has been set up, 16 which I believe will create the right kind of 17 shock loads.
18 And they could be applied to other 19 components as well. I haven't seen that, but 20 this type of sub-cool decompression model could 21 be applied throughout the system.
22 But as you may recall, right now I 23 haven't seen them do the type of design basis 24 LOCA breaks with a type of opening times that 25 would create the larger ones.
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5496 1 In principle, they can get the loads.
2 They can get the loads right, but it makes a huge 3 difference if it's a snap load or a gradual load.
4 JUDGE KENNEDY: But didn't they do 5 that for the original design, and why is it 6 different?
7 DR. LAHEY: Using a different code, 8 they have done that. And to assure if you have 9 ductile structures, you will maintain an intact 10 geometry.
11 And as I said yesterday, we spent a 12 lot of taxpayer money verifying that in the LOCA 13 program to show that indeed you could maintain 14 the coolable geometry and cool the core.
15 Now that we're winding up with a 16 highly degraded geometry, both due to fatigue and 17 irradiation, that hasn't been done.
18 JUDGE KENNEDY: We have no CUF values 19 at the end of life greater than 1 according to 20 the testimony of Entergy. Why are we in a highly 21 degraded condition?
22 DR. LAHEY: Okay. The CUF value is a 23 moving target. I mean there was a really nice 24 Westinghouse paper, and I think the author of it 25 is in the room, which described the process for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5497 1 a RHR accumulator nozzle.
2 It's an iterative process. You make 3 certain assumptions, and they're supposedly very 4 conservative. And if you get a CUF of less than 5 1, CUFen less than 1, you stop. It's good 6 enough.
7 Maybe that's fine, but if it becomes 8 19, which happened, then you go back and start 9 looking at what did you do that you might want to 10 relax. And some of them are obviously 11 conservative.
12 If you assume too many cycles of a 13 certain transient, so back it up. You did this 14 or that. Back it up. But as you keep doing this 15 and you keep going over and over, there's no 16 limit to what you can cut in order to get below 17 1.
18 And that's where we become very 19 concerned. At some point, you're cutting into 20 design margins. It's not just conservatism.
21 JUDGE KENNEDY: This is where I keep 22 getting confused. I thought there was a point 23 beyond which these reductions are off the table.
24 And I guess maybe I keep getting 25 myself confused between conservatisms and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5498 1 margins, which we tried to earlier have a lot of 2 discussion about.
3 But I keep hearing from Entergy that 4 there's a limit to this refinement of 5 calculation, that there's areas that they do not 6 go. Are you suggesting that's not true?
7 DR. LAHEY: Well, I think maybe the 8 NRC should comment on it, but what I've read says 9 that if they have that situation, they can either 10 fix it or they can recalculate it.
11 They're allowed to recalculate it, and 12 then if they can justify that that's a 13 conservative calculation, fine. The problem is 14 they just say it's conservative.
15 I mean there's no, there's nothing 16 that has been defined as what conservatism really 17 is in the code. That's the concern.
18 JUDGE KENNEDY: Are you saying in the 19 code or in the analysis method, in the input, I 20 mean are you opening it up to the whole --
21 DR. LAHEY: Into the results of 22 WESTEMS, which includes all of those things.
23 JUDGE KENNEDY: I think we'll get back 24 to this in the afternoon. But I appreciate your 25 input.
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5499 1 DR. LAHEY: I mean, I want to say that 2 I understand the approach. And even though if 3 you don't really understand what they're doing, 4 it looks pretty startling when you see numbers go 5 from 20 down to 0.8.
6 And you say oh my God. What's going 7 on? And then you realize it's a process that 8 they do. And I don't even mind the process. I 9 understand it.
10 It's just at some point as you keep 11 doing it, you're cutting into the bone. All 12 right. And we need to know --
13 JUDGE KENNEDY: How would you know 14 when we're at that point? Do you have a sense of 15 where that point is?
16 DR. LAHEY: The only way I know is to 17 determine what sort of margin you have and to 18 compare it, something like this.
19 JUDGE KENNEDY: To do a best estimates 20 calculation.
21 DR. LAHEY: Best estimate with 22 uncertainty. And then you say okay, compared to 23 that, my error bar is below the limit line and --
24 (Simultaneous speaking.)
25 JUDGE KENNEDY: So you're not buying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5500 1 Entergy's argument that in doing the calculations 2 or in essence doing a load limit type 3 calculation.
4 DR. LAHEY: I believe President Reagan 5 was right. You trust but verify.
6 CHAIRMAN MCDADE: Okay. And I don't 7 want to get into a big discussion here right 8 before lunch.
9 But just to satisfy me, from your 10 standpoint, if you were looking at it during the 11 period of extended operation and the 12 environmental adjusted CUF was 0.1, you wouldn't 13 have very many concerns because you would believe 14 that there would be sufficient margin there so 15 that there would not be a potential for problem.
16 At the other end of the spectrum, if 17 within the period of extended operation, the 18 environmentally adjusted CUF was 0.99, you would 19 be very concerned because of the possibility of 20 insufficient margin.
21 (Simultaneous speaking.)
22 CHAIRMAN MCDADE: So that, in fact, it 23 might be above 1, although their calculation is 24 below 1. Is that correct?
25 DR. LAHEY: Yes, Your Honor. That's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5501 1 exactly right.
2 CHAIRMAN MCDADE: Okay. And that in 3 factoring, in preparing their environmental 4 adjustment for the CUF, in your view, there are 5 factors that are not adequately considered, such 6 as the effect of neutron embrittlement and such 7 as the fact that in your view, there are the 8 potential for high amplitude events within the 9 design basis that have not factored in.
10 DR. LAHEY: And we'll get into that 11 after lunch, I guess, on some of the modeling 12 assumptions that are made, some of the models 13 that are used and how if you do those correctly, 14 you dramatically increase the amplitude.
15 CHAIRMAN MCDADE: Okay. But at least 16 the way I described it is consistent with the 17 testimony you were hoping that we would 18 understand this morning. Nothing that I said was 19 --
20 (Simultaneous speaking.)
21 DR. LAHEY: I agree with what you 22 said, except there's also modeling things that 23 are influencing the result --
24 CHAIRMAN MCDADE: Right, in addition 25 to --
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5502 1 DR. LAHEY: -- that were non-2 conservative in my view.
3 CHAIRMAN MCDADE: In addition to that 4 we're going to get into later.
5 DR. LAHEY: Yes.
6 CHAIRMAN MCDADE: Okay. Thank you.
7 Judge Kennedy, your suggestion?
8 JUDGE KENNEDY: I suggest we take a 9 break at this time.
10 CHAIRMAN MCDADE: Okay. One quick 11 thing before we do break for lunch, and let me 12 just note for administrative. There was an 13 Entergy document, Entergy R-00186. It was filed 14 in connection with Track 1.
15 It was an R document. There was a new 16 one that was filed in connection with the Track 17 2, and we are going to sua sponte make that 18 Entergy R-20186. So when you do your revised 19 exhibit list, if you could have that correspond.
20 It is now 12:40. Would it be 21 appropriate to break until 1:40? Okay. And the 22 next question is, and I'm thinking this may well 23 be that when we come back at 1:40, it might be 24 appropriate for us to go into a closed session 25 initially so that Dr. Lahey might comment on some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5503 1 proprietary information.
2 So for the individuals who are 3 spectators and all of the participants here have 4 signed the non-disclosure agreements. But we 5 will at least at 1:40 have a closed session.
6 And for anybody who is present 7 probably we're hopeful that by 2 o'clock then we 8 would be able to open up the session again to the 9 public session.
10 So we will stand at recess until 1:40, 11 have a closed session with anticipation we'll 12 open it approximately 2 o'clock.
13 MR. SIPOS: Excuse me, Your Honor?
14 John Sipos for the State of New York. I just 15 wanted to clarify one question for the Board, and 16 it follows up on a question from Judge Kennedy.
17 There was some discussion of the 18 phrase "rapidly approaching 1 or 1.0 or unity,"
19 and that was a phrase that we picked up during 20 the November 5 pre-hearing conference.
21 And it was our understand that that 22 was a safe harbor phrase that would be 23 acceptable.
24 MS. SUTTON: Your Honor, this is 25 Kathryn Sutton. This is the third time counsel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5504 1 from New York has testified on behalf of his 2 witnesses. And we object.
3 MR. SIPOS: I'm not.
4 CHAIRMAN MCDADE: Okay. I don't 5 believe that Mr. Sipos was testifying. I believe 6 that he was clarifying.
7 And I think that he correctly 8 commented on what was said during the status 9 conference, that we did not want the witnesses 10 and asked parties to instruct the witnesses not 11 to use specifics but that, again, the term that 12 as I understood it, what Dr. Lahey was saying by 13 rapidly approaching meaning in his view, the 14 environmental adjusted CUF was close to.
15 It had nothing to do with speed. It 16 had to do with its nearness to the 0.1 or 1.0, 17 which then raised concerns in his mind. Is that 18 how you were using the term, Dr. Lahey?
19 DR. LAHEY: Yes, sir. Yes, Your 20 Honor.
21 CHAIRMAN MCDADE: And that is what you 22 were referring to, Mr. Sipos?
23 MR. SIPOS: Yes, Your Honor. And I 24 was not trying to testify. I was trying to 25 provide --
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5505 1 CHAIRMAN MCDADE: I didn't anticipate 2 that you were testifying. I thought you were 3 trying to clarify something for the Board so that 4 we would properly understand Mr. Lahey, Dr.
5 Lahey's testimony.
6 MR. SIPOS: And it was a phrase that 7 originated from the Board.
8 CHAIRMAN MCDADE: I believe, actually 9 from me.
10 MR. SIPOS: I believe so, Your Honor.
11 That's all I was trying to clarify.
12 MS. SUTTON: It's good to know, Your 13 Honor, that we can make similar clarifications as 14 necessary. So thank you very much.
15 CHAIRMAN MCDADE: If you believe that 16 it is necessary to clarify something, I am 17 confident that you will not be shot.
18 MS. SUTTON: Thank you, Your Honor.
19 CHAIRMAN MCDADE: We are in recess.
20 (Whereupon, the above-entitled matter 21 went off the record at 12:41 p.m. and resumed at 22 1:44 p.m. in Closed Session.)
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13 CHAIRMAN MCDADE: Okay. Are we ready 14 to go? We're on the record and we're in an open 15 session. And the public has been seated. I've 16 got two final questions back on the old synergism 17 topic that we had this morning. Entergy, on Page 18 152 of your pre-filed testimony which I believe 19 is Entergy 679, you state that fatigue in a 20 radiation embrittlement contribute to potential 21 aging effects in very different ways.
22 And then you go on to say, no basis to 23 apply additional fatigue correction factor to 24 address, there is no basis to apply an additional 25 fatigue correction factor to address potential NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5596 1 embrittlement. And it cites to ENT631 at D3. I 2 can't find that statement at D3. Either my 3 reading is failing or the cite may be inaccurate.
4 So it starts on Page 152 of the pre-5 filed testimony and it's discussing fatigue in a 6 radiation embrittlement and how they contribute 7 in very different ways. I mean, I think this is 8 an attempt to address Dr. Lahey's thoughts of 9 adding another additional factor to deal with 10 embrittlement and its combined effect on fatigue.
11 MR. KUYLER: Your Honor, would it be 12 possible to have Entergy Exhibit 631, Page D3 put 13 up on the screen?
14 CHAIRMAN MCDADE: That would be fine.
15 Mr. Welkie? It's not proprietary, it's just 16 copyrighted, correct?
17 MR. KUYLER: Your Honor, I believe 18 that exhibit is full text copyrighted but not 19 proprietary.
20 CHAIRMAN MCDADE: Okay. Thank you.
21 JUDGE KENNEDY: It's quite a ways into 22 the document. And if it leaps off the page at 23 us, I'll stand corrected. So that's D3. I 24 believe the discussion is related to fatigue and 25 radiation embrittlement contributions, aging NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5597 1 effects.
2 DR. LOTT: Can we go back up?
3 JUDGE KENNEDY: If it's going to be 4 anywhere, it's probably going to be in that.
5 DR. LOTT: Yes. I think we were 6 referring to the statement at the end of, I guess 7 it's the top paragraph on this view at least.
8 That the work of several researches suggest that 9 neutron radiation does not result in further 10 reduction of fatigue properties. And some cases 11 suggest an improvement which is effectively a 12 description of the discussion we've had in 6909.
13 However, minimal data on the combined 14 effects of water chemistry and neutron influence 15 currently exist in literature.
16 JUDGE KENNEDY: Okay. I mean I guess 17 --
18 MR. LOTT: Did we present that as a 19 direct cite? Or was it --
20 JUDGE KENNEDY: Well I was thinking it 21 was a direct quote from your, in your pre-filed 22 testimony from D3. So if that's the statement, 23 the indication is that there's no data to 24 support.
25 DR. LOTT: Well I think it suggests NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5598 1 that work of several researchers that neutron 2 embrittlement does not result in further 3 reduction. So I think that's a positive 4 statement rather than a fairly negative statement 5 as you suggested.
6 JUDGE KENNEDY: Oh I see. I got you.
7 All right. I think I see the logic better -- I 8 had a question about walk us through the logic 9 but given the way the statement's worded here 10 which is different than I had written down -- and 11 I'll have to go back and check this out.
12 If your testimony is that this is the 13 support for the statement of why no additional 14 fatigue correction factor is warranted to address 15 potential embrittlement --
16 DR. LOTT: Yes.
17 JUDGE KENNEDY: And I'll think about 18 that in relation to the way it's, fold it back 19 into the original testimony.
20 DR. LOTT: Okay.
21 JUDGE KENNEDY: So D3, the last 22 sentence in the paragraph. I guess the first 23 paragraph. All right, I'm going to have to think 24 about it. I really just wanted to find the 25 support and where I looked, I wasn't finding the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5599 1 words that were in the original testimony. That 2 helps.
3 DR. LOTT: Okay.
4 JUDGE KENNEDY: Well it may help but 5 I'll take it for now. It's the best we can do.
6 I have a number of questions related to a safety 7 margins discussion that Dr. Lahey has started.
8 I'll start first with Dr. Lahey.
9 You've introduced a set of concerns 10 related to the reduction in conservatisms in the 11 CUFen calculations. And your concern appears to 12 be that they could be reducing the safety 13 margins. And I first want to start by having you 14 clarify what you mean by safety margins.
15 I mean, we recognize we're reducing 16 conservatisms. But I think your concern goes to 17 a reduction in safety margins.
18 DR. LAHEY: That's correct. In the, 19 what I call the limit line approach or the 20 WESTEMS approach, what's assumed is that there's 21 a lot of conservatism and from various sources, 22 modeling or number of cycles or various ways that 23 they proceed with this calculation.
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5600 1 it's above CUFen of one then they're free to go 2 back and redo that if they can identify something 3 that's a conservatism that's pretty obvious. And 4 they can relax it and justify it. So they do.
5 And there's nothing wrong with that 6 approach except at some point, you start cutting 7 into -- you go from conservatisms to margins, 8 engineering margins that allow for uncertainties.
9 And if you keep cutting too much, you're really 10 cutting into things that are important.
11 Normally, there's a demarcation for 12 that but we see no demarcation at all. There 13 seems to be no rules, no guidance as to what you 14 can do or what you can't. To the point you have 15 some components that -- I'm going to use, you 16 know, my normal language. They're playing every 17 trick in the book. All right?
18 They're doing all the things you're 19 allowed. And they're all the way up to working 20 in the plasticity range. And once you get there, 21 you're pushing that thing pretty hard. You're 22 way up there towards fatigue failure.
23 So to us, we believe it's very 24 important to know what margins there are. I 25 mean, I'm sure that the people who do that feel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5601 1 comfortable that there's enough residual 2 conservatism so that that's not such a scary 3 thing. But unless you know what that is, it's 4 potentially pretty scary.
5 So that was the whole thing that I 6 discussed earlier about how to quantify the 7 margin.
8 JUDGE KENNEDY: So if I understand you 9 correctly, you don't have necessarily a concern 10 about reduction in conservatisms. It's 11 constantly reducing the conservatisms and not 12 knowing that you haven't eroded the safety 13 margins.
14 DR. LAHEY: That's correct Your Honor.
15 ` JUDGE KENNEDY: And this concern arose 16 as you reviewed the revised calculations that 17 were presented in the testimony. And the 18 potential to redo those calculations, I guess at 19 any time.
20 DR. LAHEY: That's correct. I mean, 21 I've been looking at all this for eight years 22 now. And you get a result that's high and then 23 next time you see it, it's really low and then 24 the next time you see it, it's halfway between.
25 I mean it just floats all over the place.
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5602 1 And once it gets up, essentially to 2 unity, then I'm very concerned. Because I don't 3 know what's left. Is it enough?
4 JUDGE KENNEDY: Fair enough. Let's 5 turn to Entergy. I think we talked a little bit 6 about this this morning but I'm not sure we got 7 all the way through the problem. So I thought 8 I'd bring the safety margins discussion back up.
9 We talked about margins and we talked about 10 conservatisms this morning.
11 I guess I would like to see if you 12 could address how the analyst knows that he can't 13 continue to reduce conservatisms and erode safety 14 margins. Where is the guidance for the analyst 15 to know that they're not taking away margins that 16 are needed to cover for uncertainties or other 17 issues? And I'll look to Mr. Gray first.
18 MR. GRAY: Mark Gray for Entergy. I 19 think the primary guidance that every analyst has 20 in this industry is the ASME code. We must 21 follow the code and the conservative methods that 22 are explicitly given within the code.
23 As we said earlier, the code designed 24 fatigue curve includes margin. The code methods 25 for stress allowables -- for example, the design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5603 1 stress intensity allowable in Section 3 is an 2 allowable stress with built in margin that 3 affects factors in your evaluation.
4 And so, these are given margins that 5 we must live with. We can't change. After that, 6 as far as conservatism goes, I also have 7 different methods that I can use within the 8 boundaries of the code. And let me use the 9 example.
10 These analyses that have been 11 performed are still elastic analyses. They are 12 linear elastic analyses. Now NB-3228 of the code 13 allows you to do a plastic analysis. We have not 14 done that yet. So at this point, we have not 15 even gone to that. And that would be, within 16 Section 3, that would be your next major step in 17 reducing conservatism in your analysis.
18 So we haven't used that approach.
19 We've used the linear elastic approach given in 20 NB-3200 along with the other conservatisms that 21 are there. There is such a thing called, in NB-22 3228.5 --
23 CHAIRMAN MCDADE: Sorry, could you 24 repeat that?
25 MR. GRAY: NB-3228.5. There's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5604 1 penalty factor called K sub E which is known 2 throughout the industry to give a very 3 conservative correction when your primary plus 4 secondary stress intensity exceeds an allowable 5 value. You're allowed to that then check another 6 equation and penalize your usage factor 7 calculation with KE.
8 All of these are still in the analysis 9 that we've been done. So at this point, even 10 these calculations haven't used the least 11 conservative method that the code allows.
12 CHAIRMAN MCDADE: And perhaps, is 13 there any way that you can, you know, sort of 14 briefly summarize that when the environmentally 15 adjusted CUF is recalculated, how the analyst 16 determines and quantifies the impact on the 17 safety margin.
18 MR. GRAY: Once again, the safety 19 margin is defined by the code. And so, the 20 inherent margins that we're not allowed to touch, 21 the analyst meets by meeting the 1.0 allowable in 22 the code. And making sure that the corresponding 23 stresses are within the design stress intensity 24 allowables. And so, that's a place that we don't 25 touch. And that's the margin in the analysis.
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5605 1 CHAIRMAN MCDADE: But what Dr. Lahey 2 was talking about is that you look at the 3 analysis, it is at a particular level, just it's 4 X. That it's then recalculated and it's X minus 5 .2. And then you look at it again and it's X 6 minus .3.
7 When it's recalculated, how does the 8 analyst determine whether that recalculation has 9 an impact on the conservatism? And if so, what 10 that impact is. Is there any way of quantifying 11 that?
12 MR. GRAY: Your first question was how 13 does the analyst deal with margin? Now you've 14 asked me how the analyst deals with conservatism.
15 CHAIRMAN MCDADE: Well you seem to be 16 saying that the margin is in the code itself. So 17 that's I changed it from margin to conservatism.
18 MR. GRAY: Okay. So for conservatism, 19 there are different levels of conservatism that 20 are generally used in these analyses. For 21 example, you group your transients. When you 22 know that that's too conservative, when the 23 answer is too high, you can ungroup those 24 transients.
25 CHAIRMAN MCDADE: But why are those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5606 1 two terms synonymous? That it's too high and 2 therefore, it's --
3 MR. GRAY: Okay. I'll fix my words.
4 When it does not meet the allowable. That's the 5 only thing that makes it too high, when it 6 doesn't meet the allowable. This is binary.
7 JUDGE KENNEDY: And by bundling them, 8 that's an assumption the analyst has made to 9 simplify the calculation?
10 MR. GRAY: Correct.
11 JUDGE KENNEDY: And so, they don't 12 meet the allowable so now they're going to 13 unbundle -- as if I know what these terms mean.
14 Unbundle the transients and do individual 15 calculations. And that's perceived as a 16 reduction in conservatism?
17 MR. GRAY: Yes because all the 18 transients are not of the same severity. So if 19 I'm going to be conservative, if I have 500 20 cycles of different transients, I take the worst 21 transient with the worst severity will give me 22 the worst stress range. And I assume all 500 23 cycles are of that severity, that's conservative.
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5607 1 of different severities, I can unbundle, to use 2 your word, those transients into ten different 3 cases with their respective cycles.
4 JUDGE KENNEDY: In some ways, a more 5 accurate calculation, maybe more reflective of 6 the actual conditions. I don't know about 7 accuracy but more reflective of the actual 8 conditions. As opposed to bundling them and 9 using a maximum --
10 MR. GRAY: Yes.
11 JUDGE KENNEDY: -- a parameter that 12 would maximally impact the cumulative usage 13 factor.
14 MR. GRAY: Yes.
15 CHAIRMAN MCDADE: That's your view Mr.
16 Gray and the view of Entergy?
17 MR. GRAY: Yes.
18 CHAIRMAN MCDADE: Okay.
19 MR. STROSNIDER: This is Jack 20 Strosnider for Entergy. I'd like to give a 21 little perspective on this concept of margin in 22 terms of what it takes to meet the regulations.
23 I want to start off with the fact that the 24 tendency of 55A endorses the ASME code which 25 establishes a very clear demarcation in terms of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5608 1 what margin needs to be maintained.
2 You need to meet a usage factor, 3 cumulative usage factor of one with those margins 4 that are in the ASME code. And that's why you've 5 heard numerous witnesses already testify that 6 they don't touch that. That's what you have to 7 maintain, the margin you have to maintain in 8 order to meet the regulations and in order to 9 satisfy Part 54 in terms of maintaining your 10 current licensing basis.
11 The people also talk about a margin 12 between what they're calculated cumulative usage 13 factor is and that demarcation point of one. The 14 example was given earlier today of what if it's 15 .5? Then I've got a margin of .5 to one. That's 16 not the margin that's required by the 17 regulations. And you can go and you can 18 recalculate and you can use up some of that 19 margin if you want to characterize it that way.
20 But as long as you're meeting the 21 usage factor of one as calculated with the 22 margins that are in the ASME code, you're 23 satisfying the regulations. And that is adjusted 24 now for the environmental effects as consistent 25 with the guidance to meet Part 54.
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5609 1 So I just wanted to make sure that 2 it's very clear, the margin we're talking about 3 that's necessary to satisfy the license renewal 4 rule, if you will.
5 JUDGE KENNEDY: That's the, I guess to 6 put it back to the original question, would that 7 be perceived to be the safety margin at the 8 untouchable part of the calculation?
9 MR. STROSNIDER: Yes, that's correct.
10 And that is, you know, by endorsing that in the 11 regulations, the NRC has concluded that that's 12 what's necessary for reasonable assurance. All 13 right, it's a regulation and that margin is 14 there. And that's why people don't touch it and 15 that's what you need to meet.
16 The rest of the margin and the 17 conservatisms are things that people can work 18 with. But they need to meet what's in the code 19 as endorsed in the regulations.
20 JUDGE KENNEDY: Thank you. Dr. Lahey?
21 CHAIRMAN MCDADE: I was just going to 22 say, our concern in understanding this is that 23 when you take the first glance at this, you say 24 that the environmental adjusted CUF can't exceed 25 one. But when it approaches one, it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5610 1 recalculated. And you know that it needs to be 2 recalculated because it's approaching one.
3 And then if it approaches one again, 4 you recalculate it again. So almost by 5 definition then, it can never exceed one because 6 before it reaches one, it's going to be 7 recalculated. So what we need to have clear in 8 our minds and on the record is the justification 9 for the recalculation. And the assurance that 10 the recalculation provides the accurate 11 description of reality of what's actually there.
12 And that's, I think, what Dr.
13 Kennedy's questions are and I think that was Dr.
14 Lahey's concern. And we're just trying to see --
15 I want to make sure I understand how Entergy and 16 the NRC staff is addressing the concern of that 17 perception. Am I correct in what your concern 18 was Dr. Leahy?
19 DR. LAHEY: Yes, sir. My concern is 20 in this process of iterating, getting below one, 21 that you don't throw out necessary design margin.
22 CHAIRMAN MCDADE: And necessary 23 conservatisms.
24 DR. LAHEY: That's correct.
25 MR. STROSNIDER: This is Jack NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5611 1 Strosnider for Entergy. I'd like to address that 2 again if I can. I think the problem is that 3 people are dismissing those margins that are 4 required by the ASME code. The margins are 5 there. All right? That's what's required.
6 And when you recalculate because 7 you're using a less conservative analysis method, 8 you can do that. You haven't touched the margins 9 that are required by the ASME code. And those 10 margins, I mean those design rules provide 11 margin.
12 The other thing I want to comment on 13 is this notion that people keep saying that you 14 can just redo this cumulative usage factor 15 forever and never reach one. And that's not the 16 case. There are examples and I know some of the 17 people from Entergy can speak to examples where 18 they've actually had to go in and do other 19 actions because they couldn't.
20 You know, they have to change the 21 loading or they have to change components. So 22 it's not a given that you can always recalculate 23 and get it less than one. All right? So I hope 24 that's helpful.
25 MR. AZEVEDO: Your Honor, this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5612 1 Nelson Azevedo. If I may add some --
2 CHAIRMAN MCDADE: Yes, sir. Go ahead.
3 MR. AZEVEDO: Yes. In fact, Mr. Gray 4 a few moments ago mentioned plastic analysis. We 5 haven't gotten to that point yet. Some of the 6 analysis, especially once again to the elastic 7 plastic analysis become very expensive.
8 And there have been cases that I've 9 been involved with, in fact some at Indian Point, 10 where it's cheaper for us to either modify the 11 way we run the plant or just replace the end 12 component.
13 One case I was involved with was to 14 pressurize a spray piping at another plant. We 15 just chose to replace the piping. It was just 16 more cost effective than getting to these elastic 17 plastic analyses were very expensive.
18 Specific at Indian Point, back in the 19 '90s on the charging nozzle, we use what we call 20 the normal charging nozzle. And we were coming 21 up to a CUF of one. And we just decided to use 22 a different nozzle. So we changed the way we run 23 the plant just to address, you know, these 24 issues.
25 So the idea that we can just keep NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5613 1 going forever and ever and keep redoing these 2 analyses, it's not practical and it's not even 3 cost effective. If I may just say another 4 comment, I heard statements like we play every 5 trick in the book and manipulate these analyses.
6 I am the owner of these issues at 7 Indian Point. And we absolutely make sure that 8 we meet all our safety margins. And we do not 9 manipulate any of these calculations.
10 JUDGE KENNEDY: Thank you Mr. Azevedo.
11 CHAIRMAN MCDADE: Dr. Leahy, do you 12 now understand where the safety margins are?
13 DR. LAHEY: I like a couple of the 14 comments and I agree with them. I like in 15 particular, the last one. We wholeheartedly 16 endorse that approach. My understanding is that 17 for one of the Indian Point reactors, and I can 18 identify if you wish, the CUF end is for the 19 pressurizer spray nozzle rapidly approaching 20 unity. And they have done what I call every 21 trick in the book but they're allowed. I mean, 22 they've done the averaging of the stresses, peak 23 averaging, et cetera, including elastic plastic 24 analysis. We had two -- that's the documentation 25 that we were sent. So we've had two people say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5614 1 they don't do any elastic plastic analysis.
2 But that's very different from what we 3 read. But the approach of, once you get to that 4 point which is sort of pushing the envelope, then 5 it should be a decision based on cost. And we 6 wholeheartedly embrace the thought of replacement 7 and make the problem go away versus keep 8 iterating the calculation.
9 CHAIRMAN MCDADE: Okay. And if I 10 could interject here, Dr. Lahey a couple of 11 things. One, you know, when you use the term 12 every trick in the book, we did not interpret 13 that as a pejorative term in any way. I 14 interpreted as, that there were certain 15 mechanisms that are available to them and that 16 they were utilizing the mechanisms that are 17 identified.
18 The second is, you again used the 19 term, you know, rapidly approaching unity. And 20 as we had a discussion with Mr. Sipos before 21 lunch, that that phrase originated with me. And 22 perhaps it's, since it's not necessarily 23 temporally related, getting darn close might be 24 a better, more descriptive way of doing that.
25 So rather than just simply adopting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5615 1 the inarticulate phrase that I used, you know, 2 would getting darn close be a, perhaps, more 3 accurate substitute?
4 DR. LAHEY: Extremely close, yes. I 5 agree, darn close.
6 JUDGE KENNEDY: And again, that is 7 darn close at end of life or today?
8 DR. LAHEY: Yes, calculated for the 9 end of life or the extended operation.
10 JUDGE KENNEDY: Thank you. In the 11 discussion that you heard from Entergy, did you 12 understand there to be any reduction in safety 13 margins or margins that you're concerned about in 14 the approach that they've taken?
15 DR. LAHEY: I mean I understand the 16 position that there's inherent margin in the ASME 17 code. All right? We do appreciate that. That's 18 from the error data. But now, they have other 19 things going on. I've described some of them.
20 The Fen factor has uncertainty. And I talked 21 about, you know, what the real situation is in 22 the plant versus the autoclave data.
23 There's a lot of things that, in the 24 end, we would like to have some understanding of 25 what the real margin is. If the only thing it is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5616 1 is this 20 cycles, factor 20 on cycles or two on 2 stress, okay, that's where it's known. If 3 there's other things, better yet. But we don't 4 know what it is.
5 CHAIRMAN MCDADE: Dr. Hopenfeld, did 6 you have something to add to that?
7 DR. HOPENFELD: Yes. Just as a note, 8 I took a course from the father of all the ASME 9 code, Dr. Cooper many, many years. One thing I 10 do remember, what he said was that these things 11 are not for modeling the margins that you have in 12 the code off a scanner for materials variability.
13 Some statistical as to how the stresses were 14 counted.
15 They are not for stress concentration 16 factors. They are not for the effect of the 17 environment. They are not to affect for modeling 18 or assumptions or input. This is up to the user.
19 Now according to Entergy, and I can 20 quote it, according to them, because there is a 21 margin there, a factor of two and a factor of 20 22 -- and I think they change it now. But because 23 of those factors, they can go back and the 24 analyst can come up with any model he feels or is 25 in his judgment to use and he will satisfy the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5617 1 code. And that is just not true.
2 There's one example because I was 3 concerned about the effect of it, was the effect 4 of oxygen on the Fen. The Argonne recommended to 5 use a certain value for a reason to which we will 6 later go into tomorrow. They said well, we use 7 this number, the result is too high. So it's too 8 conservative.
9 In other words, the word too 10 conservative is immediate tells you that what are 11 they are doing, they're really shaving the 12 margin. They are trying to get a number that 13 they want to get.
14 So what you want to do to do it in an 15 honest way, you put in your best estimate of what 16 the input is. And in this case, you're supposed 17 to use the conservative value of the input 18 because it's a deterministic method. So you use 19 a conservative value but if the result isn't, you 20 use the result whatever it is.
21 But when they see the result is too 22 high, they just say well, we changed the model.
23 That's what they do. And that's what's wrong 24 about it.
25 CHAIRMAN MCDADE: They're not just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5618 1 changing it. They have to --
2 DR. HOPENFELD: So you can keep on 3 going with it as long as you go back and devise 4 another model. Now stress concentration, for 5 example, there is a definite technical reason why 6 there is a synergy. And what I mean a synergy, 7 that one and one together more than one 8 separately.
9 There is a symmetry between stress 10 energy, stress corrosion cracking and metal 11 fatigue. Both for the initiation part of it and 12 for the propagation part of it. That additional 13 static stress that you have due to stress 14 corrosion cracking reduces the time of destroying 15 the oxide layer. So it needs fixing. But they 16 don't account for that.
17 This is just one example. That can go 18 to the heat transfer too. We started discussing 19 it. We'll get more into it tomorrow about 20 thermal static. Most of the previous that 21 occurred due to thermal fatigue were due to 22 stratification. And they made a lot, all of it 23 is based on models. They had lost but they don't 24 have data for 20 years which is half of a 25 lifetime of the plant.
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5619 1 For the thermal stratification on the 2 pressurized, surge line on the pressurizer.
3 There must be uncertainties. When you have data, 4 you must have some kind of a model to come up 5 with data. You don't have thermal data so you 6 generate something. It's impossible to conceive 7 that there are no uncertainties in this.
8 CHAIRMAN MCDADE: Okay. Thank you Dr.
9 Hopenfeld.
10 JUDGE KENNEDY: One last question 11 maybe for Mr. Gray and I'm trying to this from 12 memory from the discussion this morning. I think 13 we get the point about the code driven margins.
14 And you know, I've been using the term safety 15 margins because those seem to be areas that just 16 aren't touched.
17 There are some modeling assumptions 18 and user inputs that are adjustable. Are there 19 likewise some user inputs, techniques that are 20 applied to calculate the thermal stresses that 21 are also off the table for the user?
22 In other words, the example I'm 23 thinking of that comes to mind when I hear this 24 discussion is the delta T that was applied for 25 the stratification and the way that was done.
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5620 1 Could a user go in and change that? Could they 2 do it differently?
3 I mean, I'm sure they can. But is 4 that sort of thing that's not allowed within the 5 process that you have built at Entergy for Indian 6 Point?
7 CHAIRMAN MCDADE: And if I could add, 8 and if so, what would be necessary to justify it?
9 MR. GRAY: The delta T is an input to 10 the problem. In fact, my earlier example I think 11 might be what you're talking about. Where I 12 could look at the worst temperature difference 13 that could ever occur across the component and 14 use that for all the cycles that could ever 15 occur.
16 But when we know better and we have 17 information that tells us that it's not always 18 that high, then what would be required of the 19 analyst is to justify lower delta Ts for some 20 number of cycles.
21 And for example, that's what I 22 referred to earlier in WCAP 17199. You'll see 23 that, for example, for the charging nozzle.
24 That's what was done. The nature of the design 25 transient, its shape was not changed but those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5621 1 values were. And those were based on a 2 calculation and just a whole development of a 3 methodology that had to be justified and verified 4 by an independent verifier.
5 JUDGE KENNEDY: So the only rock solid 6 margins that we can point to, the untouchables, 7 would be the code based margins? I mean, other 8 than the justification of changing techniques 9 that would have to meet someone's review and 10 approval. I mean, those are all on a case by 11 case basis.
12 MR. GRAY: They are case by case.
13 MR. COX: This is Alan Cox for 14 Entergy. Let me add just a little bit to that.
15 I mean, we're talking about removing 16 conservatisms. We're not removing all of the 17 conservatisms. The analyst that's working for 18 Mark doing these calculations, when he makes 19 these changes to remove excess conservatism, he 20 still has to justify that the result that he has 21 or the input that he ends up with is still 22 conservative.
23 The one exception I can think of to 24 that might be the number of transients. Now you 25 could say we're going to use a best estimate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5622 1 number for transients instead of using the design 2 value. And you might say, well that's a problem.
3 Well it would be a problem except we 4 have a program that's set up to monitor the 5 number of actual transients to make sure that we 6 don't ever go over that number without taking 7 actions to address the situation.
8 So I think, you know, you never get to 9 a point where you've taken all the conservatism 10 out of these estimates. You always end up with 11 a conservative input even though it may not be as 12 conservative as where you started in the initial 13 revision of the calculation.
14 JUDGE KENNEDY: So a check and balance 15 on the reduction in conservatisms is the review 16 of the calculation? And the need for the analyst 17 to prove that the calculation is conservative 18 with the new set of inputs?
19 MR. COX: That's correct. It's 20 incumbent upon the analyst and his reviewer to 21 make sure that those assumptions are justifiable.
22 JUDGE KENNEDY: Are these calculations 23 all done under the Appendix B program for the 24 station?
25 MR. AZEVEDO: Yes, Your Honor. This NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5623 1 is Nelson Azevedo. They're done under -- I can't 2 speak for, I'm sure the Westinghouse methodology 3 is similar to what we have at the site. So all 4 calculations are done under our 10 CFR 50 5 Appendix B program.
6 Mr. Cox stated, they're independently 7 reviewed and they're approved by a supervisor.
8 In addition to that, we have an independent 9 oversight organization. From time to time, they 10 pull these documents and they go through and they 11 verify that everything was done appropriately.
12 And on top of that, the NRC comes on 13 site and audits as well. So it's not just the 14 independent reviewer. It's the approver and the 15 on-site organization and the NRC as well.
16 JUDGE KENNEDY: Thank you. And that 17 brings up an interesting question. Maybe Mr.
18 Stevens, you've heard the back and forth on the 19 reduction of conservatisms and the redoing of 20 calculations or refinement of calculations or 21 whatever word that you want to use. From the 22 staff's perspective, is there any level of 23 discomfort in what you've heard here?
24 MR. STEVENS: No, sir.
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5624 1 expand a little bit, what raises your comfort 2 level in this discussion?
3 MR. STEVENS: This is Gary Stevens 4 with the staff. So I guess I'll reflect first 5 back to my discussion when I talked about two 6 margins and conservatism. And I said, I'll call 7 it margin one is something that's implicit or 8 explicit in the code and we can't touch it.
9 And margin two is a result of our 10 calculation and that we might be less than the 11 allowable and there's some margin left. And then 12 conservatism is simplifications we may have put 13 into the analysis.
14 And I think the testimony has been 15 pretty clear that nobody can touch margin one.
16 I guess one observation I wanted to make, you 17 know, because I think a lot of the discussion 18 I've heard is we're trying to quantify margins.
19 And in some cases we can do that.
20 I showed you factors of two and twelve 21 on fatigue curves and two and 20. So we can 22 quantify that. Section 3 tends to use a factor 23 of three against ultimate failure. We can 24 quantify that.
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5625 1 to the margin one term that can't be touched.
2 And one example that I'll give is, when you have 3 several transients you're analyzing, how you 4 combine those into paired loads for use in a 5 fatigue calculation.
6 The code is explicit on how you do 7 that and there's conservatism in that process.
8 Because from a designer point of view, you don't 9 know the order of occurrence that these loads may 10 occur in. And the code, the way, the process 11 they use is to take the worst case scenario of 12 how those loads might occur to make a 13 conservative evaluation.
14 So there's other things that go into 15 that margin one term that really can't be 16 quantified but they're explicit in the code 17 methodology. And I tried to allude to that 18 earlier when I talked about margin one and that 19 there are certain design factors as well as 20 explicit instructions in the code that lead to 21 that margin.
22 So I bring that up because what the 23 analysts can change or alter is those things that 24 contribute to margin two and the conservatism.
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5626 1 it seems like the analyst has an unlimited 2 opportunity to go back and revisit those, the 3 reality is there's not an infinite opportunity.
4 There were a finite amount of 5 assumptions that the analyst would have built in.
6 An experienced person like myself or some of the 7 other expert witnesses, it would be a function of 8 each analysis.
9 You know, they would look at an 10 analysis and, from their own experience and 11 industry experience and what they know about code 12 analysis, they would come up with a list of those 13 things that contributed to margin two and 14 conservatism such that if they were going to 15 revisit that analysis, they would pick off from 16 that list those things they could do to come up 17 with an acceptable result.
18 The staff doesn't have any discomfort 19 with that process because in the final analysis, 20 we have reasonable assurance, with our knowledge 21 of the code, the processes used, the industry 22 practices that have been adopted, that in the 23 final analysis a CUF or a CUFen of less than one 24 provides reasonable assurance that there's low 25 likelihood of crack initiation.
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5627 1 JUDGE KENNEDY: All right, thank you.
2 I hazard to look to Dr. Lahey. One final closure 3 statement you care to make on safety margins and 4 reduction in conservatisms?
5 DR. LAHEY: Well I think that it's 6 been a good discussion. I find there's great 7 inconsistency in the discussions we had 8 associated with some of the issues I brought up 9 with nodalization, heat transfer coefficient 10 locally, that sort of thing and some other input 11 that we had.
12 They can't both be true. So that's 13 why I want to look at the record a little bit and 14 try to understand what's happening. I mean, if 15 in fact it doesn't matter what the heat transfer 16 coefficient is, there's a lot of people talking 17 about stuff that they don't have to. And a lot 18 of write up on things they don't have to.
19 And why worry about the code going 20 unstable at 8,00 BTU per hour foot square if it 21 doesn't matter? So you know, there's things like 22 that. But by and large, I think it was a 23 reasonable discussion.
24 I want to say again -- I know for the 25 people who have been here all the time, it seems NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5628 1 like a long time now, three days. My overarching 2 concern is not that you just cycle this baby 3 until you get a crack. I mean, that's something 4 we have to worry about.
5 But I'm really concerned about the 6 weakening of the material as you cycle it. And 7 at some point in time, you get a significant 8 shock load which causes failure. And if that 9 leads to a uncoolable geometry, we're in big 10 trouble.
11 So I've merged all my silos with 12 embrittlement, fatigue, and safety analysis. And 13 hopefully, future meetings like this will involve 14 it all. I noticed from day one, our discussion 15 sort of covered everything. And that's a big 16 change from when we started. Where we were told, 17 look that has nothing to do with fatigue. You 18 know, you're talking about embrittlement.
19 So I think we've made some progress.
20 And I think in the right direction. And I 21 appreciate the opportunity to participate.
22 JUDGE KENNEDY: All right, thank you.
23 Dr. Hopenfeld, last words?
24 DR. HOPENFELD: I'd like to make a 25 couple of words regarding conservatism. We can't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5629 1 just talk about conservatism. There must be some 2 kind of a test to see what that really means. I 3 can tell you what it doesn't mean.
4 It definitely doesn't mean that 5 counting the number of that you repeat in your 6 report, that you are conservative almost every 7 second setting, that that is the proof that you 8 are conservative. That is not proof that you are 9 conservative.
10 So I would like to know when they keep 11 on saying that they are conservative, that all 12 their models, all their assumptions, even the 13 over simplified model are all conservative, the 14 inputs they used are conservative and Entergy, I 15 mean NRC agrees with that. I'd like to know 16 where is the test? Where is the verification of 17 that? What's the philosophy behind it that you 18 can show me yes, this is conservative.
19 And the reason it's important, because 20 going back to what I said at the beginning, the 21 CUFen are calculated, that's a deterministic 22 calculation. The ASME requires you, that the 23 burden of proof is on them, not on us. They have 24 to defend it, not just say well, I'm 25 conservative, the analyst thinks that this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5630 1 fine. That is not enough.
2 And as regulations say, you have to 3 verify it. And I don't believe that NRC, from 4 what they have testified here, that they verify.
5 They do not verify it.
6 JUDGE KENNEDY: All right. Thank you 7 Dr. Hopenfeld. Maybe a question for, certainly 8 related to the revision of the CUFen calculation.
9 On Page 66, Dr. Lahey, of your pre-filed 10 testimony which is New York State 530, you raised 11 some concerns with these revised calculations.
12 Two things caught my eye. One is you 13 had concerns related to the use of modified 14 design transients and 60 year projected cycles.
15 I guess first of all, what do you mean by 16 modified design transients? And what's the 17 problem with their usage?
18 DR. LAHEY: I don't actually recall 19 the quote. But I think we did talk about the 20 number of transients and that we have a track 21 record. It seems right to me, if you know what 22 the various transients are, to take advantage of 23 it.
24 But you have to also remember that you 25 have to extrapolate that out for 20 more years.
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5631 1 And so, you can't always tell when you're going 2 to get a scram or some other event like that. So 3 there has to be some margin built in.
4 And I take it from what I've seen, 5 they've tried to preserve that. They've tried to 6 do it.
7 JUDGE KENNEDY: Does it provide you 8 any comfort that they're also monitoring these 9 transients continuously?
10 DR. LAHEY: Yes, that's what I said.
11 I think it's good to take advantage of what's 12 happened historically, monitor it, you know, do 13 a guesstimation of what it's going to be in the 14 future, monitor it and then take whatever action 15 you have.
16 And let me say why. Because we have 17 a couple of components that I'm seriously 18 concerned about. One we talked about that has 19 already gone into the elastic plastic analysis so 20 you're beyond the yield curve.
21 And the other one is your RHR 22 accumulator, low pressure injection, intermediate 23 pressure injection nozzle. So this particular 24 nozzle is, I won't say rapidly approaching one, 25 but darn high in CUF. And if it fails, you not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5632 1 only create a loss of coolant accident, but you 2 knock our your accumulator, you knock our several 3 of your engineering ECC system, emergency core 4 coolant system.
5 If you want to fail something, that's 6 probably the worst thing to fail. And so I think 7 it's very incumbent upon us to make sure we don't 8 push that margin too hard because there's some 9 consequences for those kind of failures.
10 JUDGE KENNEDY: I understand your 11 concern but is not, at least as I understand it, 12 all the current cumulative usage fatigue values 13 at Indian point less than one, project to the end 14 of life today?
15 DR. LAHEY: They are. Some of them 16 are hard to get to. All right? I don't want to 17 say pulling all the tricks out but you've had to 18 do a lot of things to get there.
19 JUDGE KENNEDY: All right, thank you.
20 Another question for you, Dr. Lahey and I think 21 it, well it comes out of your testimony. And I 22 guess we may have to go to Entergy to get the 23 answer. But you raised a question about the FEN 24 values used for two similar reactor coolant 25 system pressure boundary components. That for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5633 1 IP2, they have one value and for IP3, another 2 value.
3 And I think you raised the concern of 4 why that would be. And I guess I don't have an 5 explanation but I'm hoping that Entergy does.
6 DR. LAHEY: Let me tell you my guess 7 and they can tell you what really happened. I 8 think it's part of the game. They found in one, 9 they didn't have to be any lower so they left it 10 what it was and it wound up less than one. On 11 the other one, that wouldn't do it so they did 12 some averaging of strain rate or some other way 13 to reduce it and they reduced it. Maybe I'm 14 wrong, but I think that's just a reflection of 15 this iterative game.
16 JUDGE KENNEDY: I guess --
17 CHAIRMAN MCDADE: Can we substitute 18 part of the analysis for part of the game?
19 DR. LAHEY: What's that?
20 CHAIRMAN MCDADE: Can we substitute 21 part of their analysis?
22 DR. LAHEY: Yes, sir.
23 CHAIRMAN MCDADE: To part of their 24 game?
25 DR. LAHEY: Right. It's so much fun NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5634 1 to do stress analysis, I can tell you.
2 JUDGE KENNEDY: I may not have been 3 clear on my question. I think you pointed to the 4 FEN values for these components. That you 5 indicate they differ substantially and you don't 6 understand why they would between IP2 and IP3.
7 And unfortunately, I didn't write down what this 8 component was. It's on Page 28 of New York State 9 568. Maybe we could look it up. I don't know.
10 Andy, is it something you could put up? 28 of 11 568, New York State.
12 DR. LAHEY: I have to get the -- oh 13 you're going to put it up? Okay. Is that not it 14 Andy, or was it? It's 568 which -- is it Dr.
15 Lahey's supplemental pre-filed testimony on the 16 cover?
17 567 has -- specifically 567, Page 28 18 it makes, for example, for the RHR accumulator 19 nozzle fatigue analysis for IP2, it has a FEN of 20 13.8 and for IP2, 7.79 for IP3.
21 DR. LAHEY: So I gave you my guess as 22 to why but I'd love to hear what the real reason 23 is.
24 MR. GRAY: May I offer an answer to 25 that?
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5635 1 JUDGE KENNEDY: Answers are good.
2 CHAIRMAN MCDADE: We hope so.
3 JUDGE KENNEDY: Go ahead.
4 MR. GRAY: Yes. I think it's a 5 misunderstanding of the value that's in the table 6 in the report. The process that's used to 7 calculate the CUFen is using what the new regs 8 call the modified rate approach. The modified 9 rate approach actually calculates an integrated 10 Fen based on the details of the stress cycle 11 history for every fatigue pair.
12 And so, there's an integration done --
13 and this is described in our WCAP, of how that's 14 performed. There's an integration done for the 15 stress cycle applying the Fen equations for each 16 one of the fatigue pairs that are then summed to 17 give you a cumulative answer.
18 The details of all of that aren't, 19 they're in the calculations but they're not in 20 the final report. So that Fen is an effective 21 Fen that you get from dividing the integrated 22 CUFen that you did with that complicated process, 23 divide that by the CUF before you did that. So 24 that's an overall effective Fen.
25 So when you do that process for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5636 1 two different units, the inputs for the two units 2 are different. They're a different number of 3 cycles of different transients. Different 4 transients will pair causing different strain 5 rates to be used in those integrated processes.
6 So because they're a different number 7 of cycles of different transients and all of 8 those different fatigue pairs, it's very 9 conceivable that you're going to get a final 10 answer that's different. And then when you 11 couple that with the fact that because the cycles 12 are different, the CUF without the environmental 13 factor, those were also different, that overall 14 effective ratio is going to be different.
15 JUDGE KENNEDY: So it comes down to 16 different transients for the two different 17 plants? Different operating history?
18 MR. GRAY: Yes.
19 JUDGE KENNEDY: Dr. Lahey, does that 20 help?
21 DR. LAHEY: Yes, I understood that.
22 I mean, sort of, I view Fen as an environmental 23 correction factor and it depends on various 24 variables like oxygen content. So I'm not sure 25 how all that is consistent but I understand what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5637 1 they've done.
2 JUDGE KENNEDY: Thank you.
3 CHAIRMAN MCDADE: Okay. Just a follow 4 up. I mean, on the face of it, it would seem 5 like these two would be relatively close given 6 the relatively similar history of the plants.
7 They would both have the same, basically the same 8 water chemistry program. Although IP2 went 9 online earlier, would have more transients. But 10 wouldn't it, why is the number so different? Mr.
11 Gray?
12 MR. GRAY: Mark Gray for Entergy.
13 This is mostly going to be a function of the way, 14 not only how long the plant ran but the way the 15 plant was operated. And especially on these 16 nozzles, you could have more safety injections, 17 for example, at the beginning in life from 18 testing or whatever other phenomena could happen 19 in the operation of the plant. So yes, these 20 things can be variable from unit to unit.
21 CHAIRMAN MCDADE: Okay. And there 22 would be a sufficient difference in the way the 23 plants were operated to, you know, explain the 24 significant difference or at least the size of 25 the difference between the two?
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5638 1 MR. GRAY: Yes, there could.
2 CHAIRMAN MCDADE: Okay.
3 JUDGE KENNEDY: Entergy, in responding 4 to Dr. Lahey's interest in having an error 5 analysis performed, you responded that the EAF 6 calculation is deterministic and therefore, an 7 uncertainty analysis is not required. What do 8 you mean that the EAF analysis is deterministic?
9 And I'll take anybody.
10 MR. GRAY: Mark Gray for Entergy. The 11 term deterministic is in opposition to a 12 probabilistic method where in probabilistic 13 methods, error analyses are more appropriate and 14 often done. And deterministic approach, as we 15 have already discussed, chooses inputs that are 16 chosen to be conservative inputs to give you 17 conservative outputs.
18 JUDGE KENNEDY: So the uncertainty in 19 various parameters is dealt with by selecting 20 conservative inputs? Is that what you're saying?
21 MR. GRAY: The worst case or bounding 22 value, yes.
23 JUDGE KENNEDY: So by properly 24 selecting conservative inputs, you're suggesting 25 that an error analysis is unnecessary?
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5639 1 MR. GRAY: Yes.
2 JUDGE KENNEDY: Dr. Lahey?
3 DR. LAHEY: Well I think we discussed 4 that in great detail this morning. And 5 hopefully, I allayed their fear that I was not 6 looking for a probabilistic analysis. What's 7 called an error analysis is this propagation of 8 error type of uncertainty analysis that you apply 9 to best estimate or such things.
10 And I gave the example of power equals 11 I square R. So everything's deterministic but it 12 gives you a measure of the uncertainty in the 13 prediction.
14 JUDGE KENNEDY: Do you feel that the 15 approach that Entergy has taken in performing 16 these calculations by using conservative 17 assumptions sufficiently covers the uncertainty 18 in the inputs?
19 DR. LAHEY: No, Your Honor. I still 20 have no clue as to what the margin really is. As 21 they get up very close to unity, I don't know 22 what the margin is compared to a best estimate 23 plus uncertainty. Is it more or less? I mean, 24 are they really where they think they are? Or 25 are they on the other side of the line?
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5640 1 JUDGE KENNEDY: Thank you.
2 JUDGE WARDWELL: Can I interject some 3 additional for Mr. Gray if I might? I believe 4 your quote was, an uncertainty analysis is not 5 required for a deterministic evaluation. That 6 isn't necessarily an error propagation analysis, 7 is it? As was highlighted in our earlier 8 discussions looking at the cartoon that Dr. Lahey 9 had put up.
10 MR. GRAY: Mark Gray from Entergy. My 11 interpretation is that those would be synonymous 12 terms.
13 JUDGE WARDWELL: The error 14 propagation, as was discussed earlier, isn't that 15 almost limited to deterministic analyses? You 16 wouldn't need to do that with a probabilistic 17 uncertainty analysis, would you? It's just the 18 opposite of what you're stating it seems to me.
19 MR. GRAY: I don't see the connection 20 you're making, no.
21 JUDGE WARDWELL: Dr. Lahey?
22 DR. LAHEY: You're correct Your Honor.
23 JUDGE WARDWELL: Thank you. I'm not 24 thanking you saying I'm correct. I just wanted 25 to make sure what your opinion was.
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5641 1 MR. COX: Alan Cox for Entergy. I'd 2 like to add one point. I mean, when we talk 3 about an error analysis, I mean what we're doing 4 with the approach that we're using for these 5 analyses, I want to say we're intentionally 6 introducing errors in the conservative direction.
7 So it's not clear to me how you could 8 get any benefit from an error analysis when 9 you've intentionally not chosen the best estimate 10 values. You have erred on the conservative side 11 in all of your inputs. So what, you know, I see 12 limited value in doing an error analysis when 13 you've intentionally skewed your results in that 14 direction.
15 JUDGE WARDWELL: Well okay. Let's 16 talk about that a bit then. Why couldn't you 17 come up with a best estimate, a best guess of 18 what you think the actual CUF calculation should 19 be? Is there any reason why you couldn't do 20 that?
21 MR. COX: Well I think Mr. Gray talked 22 about that a little bit this morning. It would 23 be a difficult task because of all the --
24 JUDGE WARDWELL: Regardless of the 25 difficulty. I understand why you may not want to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5642 1 do it. I'm interested in, could it not be done?
2 That is taking your best guess at all your input 3 parameters of what truth is.
4 MR. AZEVEDO: This is Nelson Azevedo 5 for Entergy. Yes, Your Honor, you could do a 6 best estimate analysis.
7 JUDGE WARDWELL: So by definition, 8 that best guess is your best guess with what 9 would be taking place there. And those input 10 parameters, even though you still have that, will 11 have some plus or minus associated with that.
12 Would that not be correct in some of the cases?
13 They're not absolutes.
14 MR. AZEVEDO: Well Your Honor, the 15 difficulty comes in how you quantify that. I 16 mean, if you have --
17 JUDGE WARDWELL: I fully understand 18 the difficulty. Don't get me wrong. I'm not 19 saying you should necessarily do this. But I'm 20 countering your testimony that says uncertainty 21 analysis isn't good for deterministic. And that 22 I understand. But I don't think that's the same 23 as an error propagation where it's only limited 24 to basically, deterministic analyses where you're 25 taking the error bars around a parameter input NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5643 1 that you have and then seeing how that 2 propagates. So that you can have an estimate of 3 what is the total plus or minus once you're done 4 through your calculations. And I'm just saying, 5 could not that be done?
6 MR. AZEVEDO: This is Nelson Azevedo 7 for Entergy. Yes, Your Honor, it could be done.
8 Personally, I don't see how that would be 9 different from what we already do which we take 10 the penalty up front by assuming conservative 11 values and then just do it that way. Also, if I 12 may add --
13 JUDGE WARDWELL: Can I? Save your 14 thought because I want to address hat comment 15 first and then give me your next comment.
16 Because you'll lose me and I'm going to put the 17 burden on you to remember what you were going to 18 say rather than me trying to remember when I'm 19 going to ask you a question on your first 20 statement. So I cheat because I've got the 21 gavel. Or he's got the gavel and will let me use 22 it.
23 Isn't the difference that with doing 24 it up front, when you get to the very end and you 25 have a number, you don't know what the plus and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5644 1 minus is around that number. Where if you did it 2 the other way, you would at least have some 3 estimate of what that might be. Would not that 4 be the case?
5 MR. AZEVEDO: That is true. We don't 6 know what the delta. However, what we do know is 7 that whatever that number is, its below what we 8 calculated.
9 JUDGE WARDWELL: Yes. And you know 10 that in both too. But I just, I wanted -- so you 11 do agree that at least there is some difference 12 because you at least have some estimate of that 13 number?
14 MR. AZEVEDO: Yes, I do agree.
15 JUDGE WARDWELL: Now what was your 16 second comment? And I hope you forgot it because 17 then I don't have to worry about it.
18 MR. AZEVEDO: What I was going to say 19 is both the paper that's referenced by New York 20 State on this issue and other papers that I've 21 looked at and on the internet, this idea of 22 propagation of error in similar evaluations are 23 really applicable to random data.
24 Like if you're doing a test, you're 25 collecting a lot of data and you want to analyze NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5645 1 the data. This is definitely appropriate. In 2 this case, I really don't see how that's 3 appropriate.
4 JUDGE WARDWELL: Thank you. That's 5 helpful.
6 DR. LAHEY: Your Honor, that is really 7 incorrect statement. This is not for random 8 data.
9 JUDGE WARDWELL: Do you have a comment 10 on that Dr. Leahy?
11 DR. LAHEY: It's craziness, what you 12 just heard.
13 CHAIRMAN MCDADE: Do you want to 14 elaborate on that Dr. Leahy? You said this is 15 not random data.
16 DR. LAHEY: No. I think the real 17 confusion was -- I mean, I've been asking for 18 what's the uncertainty, what's in their analysis 19 for a long time. And I thought sort of everybody 20 knew what that meant. But apparently not because 21 when I send a reference, a book that we use at 22 university in sophomore level so people know how 23 to treat random data, how to treat deterministic 24 predictions with plus or minus uncertainty.
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5646 1 deal with random data, we do deterministic 2 calculations. So I thought okay, let's try it 3 again. And so finally, you know, I sent them the 4 formula. And so I don't see why they're still 5 thinking it's random data.
6 What I'm talking about is a 7 deterministic calculation. And then you have a 8 process which is called propagation of error.
9 Kline and McClintock goes way back in time, been 10 used for decades. And it will allow you to work 11 out what the plus or minus uncertainty is.
12 It's wide used by experimentalists.
13 That's how you get the error bars on your 14 experimental data. So it has mothing to do with 15 randomness.
16 CHAIRMAN MCDADE: Can you explain in, 17 say a minute or less, what a propagation of error 18 analysis would consist of?
19 DR. LAHEY: I didn't write it. Do you 20 want me to write it?
21 CHAIRMAN MCDADE: No. Just explain 22 it.
23 DR. LAHEY: It's the partial 24 derivatives. You have a function of a bunch, the 25 result is a function of a bunch of variables. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5647 1 CUF N depends on a number of things. So you take 2 the partial of CUF N with respect to the first 3 variable times the uncertainty in that. All 4 right? You square it. Plus the partial of CUF 5 N with respect to the next variable.
6 CHAIRMAN MCDADE: And how do you 7 determine the uncertainty in each of these?
8 DR. LAHEY: It depends on what the 9 variable is. You know, depending on the 10 variable, you have information as to the 11 uncertainty.
12 For example, if you did a best fit 13 calculation, one of the parameters you'd have in 14 there would be the Dittus-Boelter correlation.
15 The Dittus-Boelter correlation has a plus or 16 minus uncertainty of 25 percent. So that would 17 be what you'd use there.
18 You go to the next variable that 19 they're using. What's your uncertainty in flow 20 rate, et cetera, et cetera. And you add them all 21 up and then you wind up with this final estimate 22 of the uncertainty. That's wide used.
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5648 1 there's another formula which has second 2 derivatives we could talk about. But this, I 3 think, would be a very useful exercise because 4 for the first time, we can see how they, where 5 they are when they're up against the limit.
6 Is there significant margin? If that 7 error bar is below the limit line, I for one am 8 pretty comfortable.
9 CHAIRMAN MCDADE: Okay. To Entergy, 10 in light of the way Dr. Lahey just explained the 11 propagation of error analysis as he understands 12 it and believes that it's documented. What does 13 that, what is random data? How does that fit in 14 or affect that?
15 MR. AZEVEDO: Well Your Honor, this is 16 Nelson Azevedo for Entergy. The basis for my 17 statement is New York State 347, Page 311. And 18 in the middle of the page, it says propagation of 19 error formulas. For 5.58, 5.59 and the box 20 starts, if X, Y, and Z are independent, random 21 variables and G is well behaved. So that's where 22 it comes from, from New York State Exhibit 347.
23 DR. LAHEY: So maybe I shouldn't have 24 used the word random. They're independent 25 variables. They're uncorrelated variables is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5649 1 what I meant.
2 CHAIRMAN MCDADE: Okay. But the 3 question is, in a deterministic analysis, why is 4 Entergy not doing a propagation of error 5 analysis?
6 MR. AZEVEDO: This is Nelson Azevedo 7 again. Again Your Honor, because we feel that 8 the conservative assumptions that we're making by 9 assuming conservative values bounds the problem 10 that we're solving. So doing a -- personally I, 11 maybe somebody else in the Entergy panel can 12 speak to.
13 But personally, I don't know how to 14 calculate these kinds of errors in a 15 deterministic manner. I know in a probabilistic 16 manner.
17 MR. STROSNIDER: This is Jack 18 Strosnider for Entergy. I have some experience 19 in performing probabilistic assessments of 20 structural integrity issues. So my perspective 21 on this -- and I think there may be some 22 semantics here.
23 But I think in the first case, when 24 you talk about a propagation of error analysis, 25 as Dr. Leahy said, that's typically the way NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5650 1 experimentalists, that's what they talk about 2 doing. And it has to do with measuring. All 3 right? Measurement errors and the various, the 4 variables in an experiment that you're measuring 5 and how you propagate those errors through the 6 measurements.
7 If you want to look at a structural 8 analysis from an uncertainty point of view, what 9 you would do is a probabilistic assessment which 10 means that each variable in the analysis, you 11 treat as a random variable and then you put 12 together a distribution.
13 And that's one of the challenges here, 14 is if you really want to do an uncertainty 15 analysis on a structural evaluation, you need a 16 distribution. You need to know the shape of the 17 distribution, you need to know the parameters of 18 the distribution. And then you can go -- and you 19 need to know their dependencies, if there are 20 any.
21 Then you can go through and you can do 22 an analysis. And when you want to understand the 23 uncertainty in that, you do that by performing 24 sensitivity studies and by doing calculations, 25 for example, to look at confidence intervals NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5651 1 based on the amount of data that you have and 2 those sort of things.
3 It's a very sophisticated analysis, 4 not easy to do, to collect all that information 5 and do it properly. Now when you look at the 6 deterministic analysis, you're taking each one of 7 those random variables, you're making an 8 assumption about what that variable is.
9 Typically and as explained in this 10 case, a conservative assumption. And you run 11 your analysis with that. One insight I want to 12 share is that what you typically find, any time 13 you compare deterministic analysis with a true 14 probabilistic assessment where you assess the 15 uncertainties.
16 If you look at, for example, a 9595 17 confidence level on an outcome from a 18 probabilistic assessment of a structure, it is 19 almost always lower than the numbers that you get 20 when you do the deterministic analysis and assume 21 all those bounding values.
22 When you assume all the founding 23 values as they're doing in these analyses, you 24 come out with things that are very, very high 25 confidence levels, 9999 kind of stuff which, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5652 1 know, typically what's used in these in these 2 structural evaluations is 9595. That's what the 3 NRC has found as acceptable.
4 So I don't know if that helps. But I 5 think that's the range of the type of analyses 6 that you can do. There's no -- to come back to 7 doing this sort of uncertainty analysis which 8 would probably be the more appropriate. You 9 know, if you were going to do something, that 10 would probably be what you want to do.
11 First of all, there's no requirement 12 for it. The experience shows that when you do a 13 deterministic analysis with bounding values, that 14 you're going to come out with higher confidence 15 levels than you would by doing the random, you 16 know, the random probabilistic assessment.
17 And I just want to come back one more 18 time to re-emphasize that the margins that are 19 established in the regulations and the margins 20 that are established in the ASME code, those 21 things are not put in there lightly. All right?
22 There's a lot work. The ASME code is 23 a consensus code. You've got some of the best 24 people in the country. You've got the NRC 25 participating. And they're looking to put the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5653 1 right levels of conservatism in those 2 evaluations. And the NRC doesn't put it into 3 regulations until they have it there.
4 So I don't know if that's helpful.
5 But like I said, I've done probabilistic risk 6 assessments on pressure vessels and piping and 7 steam generator tubes. You know, when you do the 8 deterministic analysis, it comes out with a 9 higher confidence level than these other types of 10 evaluations. That's what you typically find.
11 CHAIRMAN MCDADE: Okay. And Dr.
12 Lahey, as I understand what your concern here is, 13 is that in the absence of a propagation of error 14 analysis, it's not possible to quantify with any 15 degree of certainty, the margin of error. And 16 that therefore, you are not sanguine that the 17 conservatives built in are adequate to ensure, 18 provide reasonable assurance with regard to the 19 continued viability of the component. Is that 20 correct?
21 DR. LAHEY: Yes. What I'm looking for 22 -- yes sir, it's correct. I'm looking for some 23 indication that the margin that they think is 24 there is really there. This is one idea to do 25 it. I don't disagree you can do a more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5654 1 sophisticated analysis. But that isn't what I 2 think we need to do here.
3 Rather, I think we should assume, in 4 the best estimate, the ASME code is there. All 5 right? So you take care of that there. Same in 6 your limit line. And then all the other 7 parameters that affect the CUF end, those are 8 things that you can get either analytically with 9 the derivatives or numerically by running it with 10 different ones and dividing it by the same and 11 you get the numerical derivative. All right?
12 It's a very doable thing and it would 13 give a lot of confidence in terms of where we're 14 at.
15 CHAIRMAN MCDADE: And Mr. Azevedo, as 16 I understand the position of Entergy is that 17 given the margins that are built into the code 18 and given the conservatives that are also present 19 in your analysis, that you are satisfied that 20 even with these adjustments, there are sufficient 21 margins and conservatives left that were not 22 close to falling out of, you know, that they 23 still provide reasonable assurance. And they do 24 it by, with a significant degree of reliability.
25 MR. AZEVEDO: Yes Your Honor, I agree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5655 1 with that.
2 CHAIRMAN MCDADE: That's your 3 position?
4 MR. AZEVEDO: Yes it is.
5 CHAIRMAN MCDADE: Okay. And Dr.
6 Hiser, Mr. Stevens, what's the view of the NRC 7 with regard to this?
8 MR. STEVENS: This is Gary Stevens of 9 the staff. I think I can point you to a couple 10 things in our testimony and in the exhibits 11 that'll help out with this. First I'll say that, 12 you know, the code approach that's being used to 13 calculate CUF is not unique to that.
14 There are many other integrity 15 evaluations that are done using code throughout 16 the regulation that are consistent. And the 17 intent is to use bounding values of inputs that 18 lead to very conservative results. That's the 19 definition of a deterministic evaluation.
20 I support the testimony regarding 21 probabilistic. But if I go with the flow here, 22 and I think what I'm hearing is what happens if 23 I tweak some of the inputs in the analysis? How 24 much does it affect the analysis?
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5656 1 earlier in response to Dr. Wardwell's question, 2 yes it's possible to do that. It's very 3 difficult but it's possible. And in fact, over 4 the course of the history of the industry, there 5 have been some attempts to do that.
6 I'm going to refer you to our 7 testimony, Answer 163 on Page 177 of NRC 168. As 8 you can imagine, some of these analyses get quite 9 complicated. And the number of inputs you could 10 potentially adjust for best estimate is large.
11 Our testimony here talks about 12 adjusting one of the those which is the input 13 loading. There's been many studies and we point 14 out one, or actually two here, that looked at 15 instead of using bounding design basis 16 transients, what's the effect on CUF if we use 17 best estimate transients like those actually 18 experienced in a plant?
19 And so, if you will, the analysis 20 that's cited here which is in NRC Exhibit 175.
21 It's a 1973 pressure vessel and piping technical 22 paper. That was an example of analysis that 23 looked at, if all I did in the evaluation was to 24 change the transient definitions to best 25 estimate, what happens?
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5657 1 And what's been shown for more than 30 2 years now throughout the industry, that has a 3 very overwhelming effect on CUF. It drops by as 4 much as two orders of magnitude. What you get 5 from these studies -- and there was also some in 6 new Reg CR6260. I don't have the exhibit number 7 for that off hand. It is one of the exhibits.
8 Similar things were done where they 9 looked at not only transient severity, but some 10 other inputs. And I'll put it in, they looked at 11 best estimate type adjustments to those. And 12 what you conclude from this wealth of experience 13 is that when you look at best estimate 14 evaluations of CUF, it drops substantially, if 15 you will, the delta bar down from what we're 16 calculating is orders of magnitude.
17 And what you conclude from those is 18 that the calculations we're doing are very, very 19 conservative. And if we were to go down the path 20 of doing an error propagation analysis, we in 21 fact would show that we have is very 22 conservative.
23 So I would direct you to our testimony 24 there. And that is just one example of how the 25 industry has looked at best estimate types of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5658 1 estimates of CUF and the impact of that and what 2 those errors might be.
3 CHAIRMAN MCDADE: Okay. Thank you Mr.
4 Stevens.
5 JUDGE KENNEDY: All right, thank you.
6 Moving on a bit, moving away from uncertainties 7 and margins. I have a couple questions for Dr.
8 Hopenfeld. On Page 4 of your pre-filed testimony 9 which I believe is Riverkeeper 142, you raised 10 concerns about failing to consider the impact of 11 dissolved oxygen in the refined fatigue 12 evaluations.
13 First of all, is this in regard to the 14 environmental assisted portion of the 15 calculation?
16 MR. HOPENFELD: Yes, in regard to the 17 calculation of the Fen.
18 JUDGE KENNEDY: Relative to the Fen?
19 Is that what you said?
20 MR. HOPENFELD: The Fen, yes.
21 JUDGE KENNEDY: It appears to me that 22 the equations that Entergy's used for adjusting 23 for environmental factors accounts for dissolved 24 oxygen. Do you agree with that?
25 MR. HOPENFELD: No.
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5659 1 JUDGE KENNEDY: And why don't you 2 agree?
3 MR. HOPENFELD: The equation they're 4 using I agree. But how they use the equation, I 5 don't.
6 JUDGE KENNEDY: Okay. So the equation 7 is capable of accounting for dissolved oxygen?
8 MR. HOPENFELD: Oh sure.
9 JUDGE KENNEDY: Is that what you're 10 saying?
11 MR. HOPENFELD: Yes.
12 JUDGE KENNEDY: But Entergy, in their 13 calculations are not properly accounting for the 14 dissolved oxygen?
15 MR. HOPENFELD: That's correct.
16 JUDGE KENNEDY: And why is that?
17 MR. HOPENFELD: Okay. This is an 18 important subject and I feel that, from the 19 testimony that Entergy provided and NRC, they 20 don't understand how that Fen was obtained. So 21 give me a minute or second just to go through it.
22 These tests were conducted in the 23 little autoclave, like 20 gallon, little system 24 where the water was circulating. The 25 measurements temperature, the measurement of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5660 1 oxygen were extremely accurate. They were taken 2 all the time. They knew exactly what happens at 3 the surface with the oxygen.
4 So when the measurements of oxygen was 5 taken, that reflected what happened with oxygen.
6 Because this was a very small, small tiny little 7 system. The water was pure, everything was 8 clean, everything was known. And imagine if 9 there were billions. They're not using 10 continuous online but almost continuous online 11 measurements.
12 Now what they said, what Entergy says 13 or it's their perception that the Fens, as they 14 were generated in these little tests, are 15 directly applicable to the reactor system.
16 Because everything in the Fen that was measured 17 is really is directly applicable to the coolant 18 chemistry of the reactor. And this is absolutely 19 not true.
20 Again, what you are measuring, what 21 you're supposed to do in calculating the Fen, 22 you're supposed to put as specified by Argonne --
23 and they know what's involved in them, they ran 24 the test. They know what you have to do.
25 And what they specify that you have to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5661 1 calculate, you have to put it into the equation 2 the -- for carbon steel you have to put the 3 maximum oxygen during the transient. For 4 stainless steel, you have to put the minimum 5 oxygen you extract.
6 Now, they realized that we don't know 7 that. There's no mention of it. Nobody sits 8 there. In the plant, you measure the oxygen in 9 the bulk, sometimes for the sampling, which also, 10 you have to have a lot of correction. You do it 11 maybe once a week. I don't know how often they 12 do it but they don't do it during the transients.
13 So what Argonne has done and EPRI too, 14 they specified look, if you don't know what it 15 is, here's a guideline, use Form 4. And Entergy 16 looks at it and said, .4, I get numbers larger 17 than one if I use that. That is too 18 conservative.
19 In other words, what I'm saying, when 20 they talk about conservatism, they're not talking 21 about conservatism. They're talking a number 22 that they can adjust. And they're going to quote 23 something conservative that's not conservative.
24 The number they get to find an answer they want.
25 Now Argonne was very specific as to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5662 1 what number should be used during the transient.
2 EPRI was very specific. And they said no, we 3 don't have to worry about that because all we 4 have to do is use the steady state concentration 5 during the transient.
6 But this has nothing to do with what 7 happens at the surface. It's completely two 8 different animals. Furthermore, now somebody at 9 Westinghouse probably understood the problem.
10 And what he did and he realized it -- and from my 11 testimonies, I think other people in the country 12 realize the problem.
13 It's not a simple thing to do, the way 14 they are rationalizing it. What the person from 15 Westinghouse -- I spent three or four pages on 16 that. They said, look we know oxygen gets into 17 the system during the heat up period. And when 18 it gets in there, however, look at the equation.
19 The equation, it doesn't matter. In 20 other words, he's saying and then he calls down 21 and say, well the equation says that if the 22 oxygen -- when it gets in there, that a 23 temperature of 150 then the term in the 24 exponential cancels out and it doesn't matter.
25 And this is true.
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5663 1 But then he says it doesn't matter.
2 He says well but, we have proven an assumption.
3 Because originally, they made an assumption that 4 oxygen is .05. What they said that we have 5 proven with this equation that oxygen in the 6 plant is .05.
7 That's equivalent to saying that you 8 can have some equation that was the Fen equation 9 that was done in laboratory as predicting its own 10 input. That's exactly what it says. And then 11 they extended that to the case that where they 12 applied zero oxygen throughout the transients.
13 Now I have asked, we've asked for the 14 last four or five years, please give us data on 15 the transients during the heat up and cool down.
16 We never got the answer. And I know there is 17 such a thing because EPRI produced such data for 18 BWRs.
19 And you can see that during the 20 transient, the oxygen changes by orders of 21 magnitude as the temperature changes. Now the 22 first criticism that we got was, well this is not 23 up to us because this is high oxygen, this is 24 BWR.
25 It was the principle that I was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5664 1 showing. During the transients, things change.
2 Argonne, EPRI, all specified you have to account 3 for oxygen during the transient and you have to 4 use the maximum value. Well they say now the 5 maximum value is .005 which is the steady state 6 value. But that has nothing to do with the 7 transient.
8 Now I don't know the physics of it, of 9 oxygen mechanism during the transient for a 10 particular component. This is not, I hope so, 11 this is not a tiny little system about that size.
12 In comparison, it's smaller than that. But you 13 can get and you can see everything.
14 You're measuring and you say, well 15 that's what's going to happen somewhere in the 16 reactor vessel. These are two different animals.
17 And they keep coming back to it and using .005 in 18 the calculations. So when I put the number of .4 19 ppm which Argonne recommended, it's not my 20 number. I cannot put a factor of five on the Fen 21 which translates the factor and the CUF.
22 So you see, when I was telling you 23 this morning that uncertain in the Fen which is 24 a factor of three. That's just inherent 25 uncertainty of expressing the experimental data.
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5665 1 That's all it is. That's in there, you can't get 2 away from that.
3 In addition to have, you have these 4 input calculations. Now if you go back -- if 5 they want to do a deterministic analysis, do you 6 say, look I don't know what the oxygen is but 7 it's my responsibility to look at the end point.
8 No matter what, even if I don't know, if you 9 would happen to describe it, I have to use .4.
10 That's what they're telling me that's an end 11 point.
12 But the person from Entergy looked at 13 it and said oh we're not going to use that, 14 that's too conservative. So you see, they choose 15 what conservatism that goes back to the modeling.
16 JUDGE KENNEDY: So Dr. Hopenfeld, your 17 concern is they're not using a proper transient 18 based dissolved oxygen content?
19 MR. HOPENFELD: I am concerned that 20 during the transient, they should be using, 21 during the transient they should not be using the 22 steady state value of .005. They should be using 23 the number that was specified by Argonne, the 24 people who designed and ran these experiments.
25 That's what they should be using instead of just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5666 1 I will use something that, theoretically, it was 2 calculated that we are running, that the reactor 3 runs at .005 during the transient. That's just 4 not true.
5 JUDGE KENNEDY: So the recommendation 6 of EPRI and the Argonne people is to use .4?
7 MR. HOPENFELD: Correct.
8 JUDGE KENNEDY: For this parameter if 9 you don't know the transient values?
10 MR. HOPENFELD: Yes. Take a look at 11 NUREG-6905. Hopefully I remember this, at 85.
12 Okay. 6909, I'm sorry, at A5.
13 JUDGE KENNEDY: Page 85?
14 MR. HOPENFELD: A5. A, it's Appendix 15 5 on the bottom.
16 JUDGE KENNEDY: All right, thank you.
17 Entergy, do you have a response to the transient 18 issue here, the issue with the transient 19 dissolved oxygen?
20 MR. COX: This is Alan Cox. Let me 21 start out and some of my colleagues may want to 22 jump in here. But the first point I'd like to 23 make is we're not using the steady state value.
24 We're using a value that is an order of magnitude 25 higher than the steady state value.
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5667 1 The normal operating concentration is 2 .005 ppm, five ppb. And the threshold in the 3 equation that we're using is .05. So it's an 4 order of magnitude higher than our normal 5 operating concentration. And we've not seen 6 anything to indicate that, during a transient, 7 that oxygen spontaneously appears in the system 8 in such a way that it increases by an order of 9 magnitude to where it would exceed that 10 particular threshold.
11 JUDGE KENNEDY: Is it possible to 12 measure the dissolved oxygen during a transient?
13 I mean, is this being monitored continuously?
14 Would the system be able to pick up that 15 difference?
16 MR. COX: It's monitored at a point.
17 I don't know that we see any changes during 18 transients. It's monitored at one point in the 19 system. The other I'd like to point out, there's 20 a difference in BWRs and PWRs here.
21 In a PWR, you run with a hydrogen over 22 pressure so that scavenges the available oxygen.
23 That's what allows us to keep the numbers as low 24 as they are. In a BWE, your primary system goes 25 into, turns into steam, goes through the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5668 1 condenser. You can't fill your condenser with a 2 bunch of non-condensable hydrogen gas. So you 3 don't have that ability to control oxygen with 4 hydrogen.
5 So it's a completely different 6 scenario. In the BWR world, there is an EPRI 7 program that's used to calculate the oxygen at 8 different points in the system. Because it does 9 change much more drastically than it does in a 10 PWR.
11 JUDGE KENNEDY: Anything from anyone 12 else on the Entergy side?
13 MR. AZEVEDO: This is Nelson Azevedo.
14 Just to add to your question, Your Honor. We 15 monitor the oxygen about ten times a day.
16 They'll have a data sheet here in front of me.
17 I guess we could monitor more often but that's 18 how often we monitor now. So it's monitored 19 pretty often and we have actual values.
20 JUDGE KENNEDY: Do the values display 21 much variation through the day? This is an 22 example.
23 MR. AZEVEDO: No. They're obviously 24 different when we are shut down. But once we 25 start up, we add the hydrogen and the hydrazine NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5669 1 to the primary side which essentially scavenges 2 all the oxygen. And then from there on, until we 3 open up the system again as Mr. Cox said, it's 4 about five ppd.
5 JUDGE KENNEDY: How would --
6 CHAIRMAN MCDADE: Is this all part of 7 that water chemistry AMP we discussed the other 8 day?
9 MR. AZEVEDO: That's correct.
10 JUDGE KENNEDY: If I understand what 11 Dr. Hopenfeld's saying, there's a recommendation 12 on the table from EPRI or Argonne or both that 13 indicates if you don't know the dissolved oxygen 14 during a transient, a value of .4 would be 15 applicable. Is this a case that's, should you be 16 using .4 for Indian Point?
17 MR. AZEVEDO: This is Nelson Azevedo 18 again. Mr. Gray or somebody can jump in. That 19 is when you don't have actual numbers. We have 20 actual numbers, measured numbers. And again, as 21 Mr. Cox said, during a transient, oxygen does not 22 spontaneously generate in the reactor coolant 23 system.
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5670 1 than what we're measuring.
2 JUDGE KENNEDY: Mr. Gray?
3 MR. GRAY: This is Mark Gray for 4 Entergy. The reference in new reg CR6909 on Page 5 A5 says that the dissolved oxygen values obtained 6 from each transient constituting the stress cycle 7 for carbon and low alloy steels, the dissolved 8 oxygen content, DO, associated with the stress 9 cycle is the highest oxygen level in the 10 transient, et cetera.
11 That last sentence says a value of .4 12 ppm for carbon and low alloy steels and .05 ppm 13 for Austenitic steels can be used for the DO 14 content to perform a conservative evaluation. So 15 that implied that when you don't know the value, 16 when you have nothing to go by, that's the 17 conservative input to the equation.
18 They operate the plant according to a 19 spec that gives a maximum value for dissolved 20 oxygen. And I won't reiterate what these 21 gentlemen have already said.
22 The other important thing to recognize 23 though that may have been mischaracterized is the 24 new regs from Argonne have repeatedly said, not 25 just 6909, that in order to have this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5671 1 environmental effect, that you have to have a 2 combination of the parameters to be above their 3 threshold limits to have this environmental 4 effect.
5 We refer to that in our answer --
6 sorry, I have to put my glasses on. On our 7 answer 184 in our testimony. In new reg CR6815, 8 for example, that's Entergy 225 where the new reg 9 says that it's the product of the transformed 10 strain rate oxygen and temperature values is 11 based on experimental data.
12 And we quote that new reg that says 13 it's significant. The environmental factor is 14 significant only when four conditions are 15 satisfied simultaneously. When the strain 16 amplitude temperature and dissolved oxygen and 17 water are above certain threshold values, and the 18 strain rate is below a threshold value.
19 So going back to the point that was 20 made before, when the temperature is below it's 21 threshold value, even if I use this maximum DO 22 value, the Fen is still at its threshold value.
23 The equation that they've given us to use in the 24 new reg reinforces this statement that is made in 25 the new reg.
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5672 1 That unless the product of those 2 parameters is non zero, I don't get a higher Fen.
3 JUDGE KENNEDY: Thank you. Maybe Mr.
4 Stevens or someone from the NRC, any concerns 5 with the application of the dissolved oxygen 6 factor for Indian Point?
7 MR. STEVENS: This is Gary Stevens for 8 the staff. No, Your Honor. In general, I agree 9 with what Entergy has testified and how they 10 characterized the statement in new reg CR6909.
11 JUDGE KENNEDY: All right, thank you.
12 Dr. Hopenfeld, the final word?
13 MR. HOPENFELD: My final word is that 14 they disregard the guidelines that both -- the 15 NPR47 I believe.
16 JUDGE KENNEDY: Could you say that 17 again? I missed that last --
18 MR. HOPENFELD: NPR 47, it's EPRI 19 guidelines also indicated that you have to input 20 into your equation the maximum oxygen, the oxygen 21 during the maximum -- the maximum amount of 22 oxygen during the transient.
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5673 1 about. The oxygen during the transient is not 2 what they are talking about.
3 Again, I was going back to this little 4 test. That little test is a measure value of 5 oxygen that really happens at the surface. He's 6 talking about adding hydrazine as a catalyst.
7 You have tons and tons of material. You've got 8 all kind of reactions going on in there. You 9 don't know what it is.
10 You cannot use this analytical 11 equation to tell me that it predicts what the 12 oxygen is in the plant. That's what they say.
13 MR. STEVENS: Your Honor, may I?
14 JUDGE KENNEDY: Go ahead Mr. Stevens.
15 MR. STEVENS: Gary Stevens, NRC staff.
16 I'll comment on NRP47 because I was a co-author 17 of that document. And I'll just say that in 18 there, there are some guidelines for treating 19 dissolved oxygen on a time averaged approach.
20 And I'll just say that from the testimony I've 21 heard and read, that Entergy's approach is 22 consistent with that.
23 Second thing, I think we need to 24 correct a few things for the record that were 25 stated here. I had some difficulty understanding NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5674 1 Dr. Hopenfeld but there was a lot of discussion 2 regarding the experimental set ups that Argonne 3 National Laboratory used to collect this 4 information.
5 And I heard some mention that 6 dissolved oxygen was measured at the surface of 7 specimens and its relevance or lack thereof to 8 components. And that's not true. One of the --
9 in New York State 356, there's a good discussion 10 of the experimental setup and tests in Section 2 11 of new reg CR6583 which is New York State Exhibit 12 356.
13 And what you'll see in there very 14 clearly is that, that would be a very difficult 15 achievement to measure dissolved oxygen at the 16 surface of a component. It's measured, the bulk 17 dissolved oxygen content of the fluid in the 18 circuit is measured in those tests. There's a 19 figure that shows that in that section and a nice 20 write up on how those tests are conducted.
21 And that's entirely consistent with 22 how dissolved oxygen measurements are taken in 23 the plant. So there shouldn't be any concerns 24 about inconsistencies with dissolved oxygen 25 measurements between test setups and plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5675 1 measurements.
2 JUDGE KENNEDY: All right. Thank you 3 Mr. Stevens.
4 CHAIRMAN MCDADE: It might be 5 appropriate, we're approaching 6:00, we've been 6 going for a while. It might be appropriate to 7 break until tomorrow morning. I would propose 8 that we start at 8:30. Does that pose any 9 problems?
10 MR. HARRIS: No, Your Honor.
11 MR. SIPOS: No, Your Honor.
12 MR. ROTH: No, Your Honor.
13 CHAIRMAN MCDADE: Okay. I believe we 14 had one homework assignment. I guess Mr. Gray 15 identifying documents about the way Entergy's 16 WESTEMS handles the coupling, thermal couple 17 data.
18 DR. LAHEY: I understand that to mean 19 how we treated the thermal couple data in the 20 development of the transients.
21 CHAIRMAN MCDADE: Okay. That said, we 22 are in recess until 8:30 tomorrow morning. Thank 23 you.
24 (Whereupon, the above-entitled matter 25 went off the record at 5:45 p.m.)
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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Station Open Session Docket Number: 50-247-LR and 50-286-LR ASLBP Number: 07-858-03-LR-BD01 Location: Tarrytown, New York Date: Wednesday, November 18, 2015 Work Order No.: NRC-2016 Pages 5322-5675 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
5322 1 UNITED STATES OF AMERICA 2 U.S. NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5 + + + + +
6 OPEN SESSION 7 ________________________________
8 In the Matter of: : Docket No.
9 ENTERGY NUCLEAR OPERATIONS, INC. : 50-247-LR 10 (Indian Point Nuclear Generating : 50-286-LR 11 Station, Units 2 and 3) : ASLBP No.
12 ________________________________ : 07-858-03-LR-BD01 13 Wednesday, November 18, 2015 14 15 Doubletree Tarrytown 16 Westchester Ballroom 17 455 South Broadway 18 Tarrytown, New York 19 20 21 BEFORE:
22 LAWRENCE G. MCDADE, Chairman 23 MICHAEL F. KENNEDY, Administrative Judge 24 RICHARD E. WARDWELL, Administrative Judge 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5323 1 APPEARANCES:
2 On Behalf of the U.S. Nuclear Regulatory 3 Commission:
4 DAVID E. ROTH, ESQ.
5 SHERWIN E. TURK, ESQ.
6 BRIAN HARRIS, ESQ.
7 of: U.S. Nuclear Regulatory Commission 8 Office of General Counsel 9 Mail Stop 15 D21 10 Washington, D.C. 20555 11 david.roth@nrc.gov 12 sherwin.turk@nrc.gov 13 brian.harris@nrc.gov 14 301-415-2749 (Roth) 15 301-415-1533 (Turk) 16 301-415-1392 (Harris) 17 18 On Behalf of Entergy Nuclear Operations, Inc.:
19 KATHRYN M. SUTTON, ESQ.
20 PAUL M. BESSETTE, ESQ.
21 RAPHAEL "RAY" KUYLER, ESQ.
22 of: Morgan, Lewis & Brockius, LLP 23 1111 Pennsylvania Avenue, N.W.
24 Washington, D.C. 20004 25 202-739-5738 (Sutton)
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5324 1 202-739-5796 (Bessette) 2 202-739-5146 (Kuyler) 3 ksutton@morganlewis.com 4 pbessette@morganlewis.com 5 rkuyler@morganlewis.com 6
7 On Behalf of the State of New York:
8 JOHN J. SIPOS, ESQ.
9 LISA S. KWONG, ESQ.
10 MIHIR A. DESAI, ESQ.
11 of: New York State 12 Office of the Attorney General 13 Environmental Protection Bureau 14 The Capitol 15 Albany, New York 12224 16 brian.lusignan@ag.ny.gov 17 18 On Behalf of Riverkeeper Inc.:
19 DEBORAH BRANCATO, ESQ.
20 of: Riverkeeper, Inc.
21 20 Secor Road 22 Ossining, New York 10562 23 800-21-RIVER 24 info@riverkeeper.org 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5325 1 On Behalf of Westchester County:
2 CHRISTOPHER INZERO, ESQ.
3 Assistant County Attorney 4 of: Westchester County Government 5 148 Martine Avenue 6 Room 600 7 White Plains, New York 10601 8 914-995-2000 9
10 On Behalf of Westinghouse Electric Company:
11 RICHARD J. COLDREN, ESQ.
12 of: Westinghouse Electric Company 13 1000 Westinghouse Drive 14 Cranberry Township, Pennsylvania 16066 15 412-374-6645 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5326 1 TABLE OF CONTENTS 2 Witness Swearing In 3 by Judge Lawrence McDade, Chair . . . 5328 4 Answers to Previous Day's Questions 5 by Judge Lawrence McDade, Chair . . . 5329 6 Contention 26 7 by Judge Michael Kennedy, ASLBP . . . 5360 8 Afternoon Break 9 by Judge Lawrence McDade, Chair . . . 5505 10 Closed Session . . . . . . . . . . 5505 - 5595 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5327 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:34 a.m.)
3 CHAIRMAN MCDADE: Okay. The hearing 4 will come to order. The first order of business, 5 I believe we have some witnesses for 26 who were 6 not witnesses on 25. Do we have anyone here who 7 has not yet been sworn in who is going to be 8 proffered on 26?
9 MR. ROTH: Yes, Your Honor. We do.
10 CHAIRMAN MCDADE: Are you going to 11 move over to the witness tables?
12 MS. BRANCATO: Your Honor, this is 13 Deborah Brancato from Riverkeeper. Would you 14 like Dr. Hopenfeld to go over into the witness 15 table, too?
16 CHAIRMAN MCDADE: Next to Dr. Lahey, 17 Dr. Hopenfeld. Okay. And Dr. Hopenfeld was 18 sworn on Monday, so he doesn't need to be sworn 19 again. He's still under oath. The two new 20 witnesses --
21 MR. HARRIS: Your Honor, Brian Harris, 22 NRC. Do you want to swear the witness for 38 in 23 also at this time?
24 CHAIRMAN MCDADE: I mean we're not 25 going to be getting to 38 today, but we might as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5328 1 well.
2 MR. SIPOS: Judge McDade?
3 CHAIRMAN MCDADE: Yes.
4 MR. SIPOS: John Sipos for the State 5 of New York. Just to note, Dr. Duquette is not 6 yet present, but we do expect him.
7 CHAIRMAN MCDADE: Right, and before 8 Dr. Duquette begins to testify on 38, we will 9 swear him in. The new witnesses, would you 10 please identify yourself, your name and your 11 short job title and who you represent. Mr. Yee?
12 MR. YEE: On Yee, U.S. NRC, Reactor 13 Systems Engineer with NRC.
14 MR. NG: Ching Ng with the NRC, 15 Reliability and Risk Analyst.
16 MR. KARWOSKI: Ken Karwoski, Senior 17 Level Advisor for Steam Generators Materials 18 Inspection, NRC.
19 CHAIRMAN MCDADE: Okay. Would you 20 please rise? Would you raise your right hand?
21 Will you swear or affirm subject to the 22 penalties for perjury that the testimony you'll give 23 at this hearing will be the truth, the whole truth, 24 and nothing but the truth?
25 (Chorus of I do.)
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5329 1 CHAIRMAN MCDADE: Okay. Please be 2 seated. Certain things we told the other 3 witnesses, and we'll repeat for you right now.
4 First of all, it's important that we 5 have a record of the proceedings so that if you 6 are answering a question, before you answer the 7 question, state your name.
8 Now if the question is designed 9 directly towards you, so the judge has said Mr.
10 Yee, and then asks the question, you don't need 11 to repeat your name because the court reporter 12 will have it right there in context.
13 But in many instances, we're going to 14 be asking questions that are directed either to 15 the NRC staff or to Entergy or to the 16 interveners, and in which case then the 17 individual who is speaking should state their 18 name before they begin so that the record will 19 reflect which one of the witnesses was actually 20 speaking.
21 The other thing is we do take periodic 22 breaks. If for any reason you feel that you need 23 a break, don't suffer in silence. Let us know, 24 and we can arrange to take a break. Are there 25 any questions before we get started?
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5330 1 MR SIPOS: No questions.
2 CHAIRMAN MCDADE: Okay. There are a 3 few things, administrative matters and some 4 substantive matters that I want to take up before 5 we started.
6 First of all, at the conclusion of 7 yesterday, I asked a question I thought was a 8 simple question that was designed to sort of 9 summarize what had been said over hours of 10 testimony to put it in one place in the record.
11 Perhaps because I was tired, but in 12 any event, I failed miserably and wound up sort 13 of running us down a rabbit warren and wound up 14 confusing things rather than clarifying things.
15 Sort of a quote from the movie Cool 16 Hand Luke, "We had a failure to communicate," and 17 I apologize for that. We were talking about what 18 has been developed and what has still to be 19 developed.
20 And from the testimony, and what I 21 want to do is to sort of summarize a little bit 22 and then make sure from the witnesses, because 23 nothing I say is evidence, that what I'm saying 24 is correct.
25 That we look first of all to MRP-227, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5331 1 which is NRC Exhibit 114. That sets out various 2 inspection aspects. In Sections 4 and 5 of that 3 document, it talks about examination methods, the 4 qualifications for examination, the frequency of 5 examination, sampling and coverage, the expansion 6 based on observed degradation, evaluation of 7 results and flaw evaluation.
8 Specifically in that, it also 9 addresses Westinghouse manufactured plants 10 specifically. They have tables for Westinghouse 11 plants as well as for plants manufactured by 12 other entities.
13 But as part of those tables, they have 14 listed acceptance criteria. Among those 15 acceptance criteria, they have one for the baffle 16 former bolts.
17 But in that particular document, the 18 MRP-227 and specifically the table 5-3, not all 19 of the details with regard to the acceptance 20 criteria for baffle former bolts are specified, 21 that it indicates that for certain plant-22 specific, unit-specific details that they will be 23 established as part of the examination technical 24 justification.
25 Now that was then discussed back and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5332 1 forth between the NRC and Entergy, and it was 2 addressed specifically in Supplement 2 to the 3 SER, which is New York Supplement, excuse me, New 4 York Exhibit 503.
5 And in that, the NRC articulated its 6 position that those specifics, the UT 7 examinations for baffle former bolts have been 8 performed since the 1990s.
9 There's more than 20 years' experience 10 doing that inspections, which provide a 11 reasonable assurance that the examinations can be 12 implemented effectively and that finalizing the 13 TJ closer to the date of the inspection would 14 allow for the latest UT technology and lessons 15 learned for previous inspections to be 16 incorporated.
17 So what remained to be done, which 18 isn't in the original document or in the SER that 19 is in either MPR-227, Exhibit 114 or in the SER, 20 New York Exhibit 507, is the technical 21 justification for the examination.
22 Dr. Hiser, again, nothing I've said is 23 evidence. What I've just gone through, does that 24 accurately reflect the process here?
25 DR. HISER: Yes, I believe it does.
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5333 1 CHAIRMAN MCDADE: Okay. Do you have 2 anything to add to supplement that --
3 DR. HISER: No, I don't.
4 CHAIRMAN MCDADE: -- or to correct it?
5 DR. HISER: No, I do not.
6 CHAIRMAN MCDADE: Okay. And from 7 Entergy, does anybody have anything to supplement 8 or to correct?
9 MR. DOLANSKY: No, Your Honor. This 10 is Bob Dolansky from Entergy. No.
11 CHAIRMAN MCDADE: Okay. So what's 12 left to be done has to do with the technical 13 justification for the inspection, certain plant-14 specific details.
15 Dr. Hiser, could just very briefly 16 just put on the record what the technical 17 justification for examination is, or if someone 18 is better suited to it?
19 MR. POEHLER: This is Jeffrey Poehler, 20 the staff. I can address that. The technical 21 justification would be a report prepared probably 22 by the vendor that's performing, that will 23 perform the ultrasonic examination.
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5334 1 procedures. It would address things like the 2 detectability of flaws, like what's the minimum 3 size flaw you could detect in a bolt, such as for 4 example, 10 percent of wall thickness or 20 5 percent, something like that.
6 CHAIRMAN MCDADE: Okay. And has that 7 technical justification been received by the NRC?
8 MR. POEHLER: No, it has not. It 9 would not be something we would expect to be 10 submitted or require to be submitted.
11 CHAIRMAN MCDADE: Okay. It is 12 required to be prepared no later than six months 13 before the first inspection, but that is a 14 document that would be maintained at the facility 15 subject to inspection by the resident inspector 16 of the NRC. Correct?
17 MR. POEHLER: Correct.
18 CHAIRMAN MCDADE: Okay. And do you 19 agree with that, from Entergy?
20 MR. DOLANSKY: Yes.
21 CHAIRMAN MCDADE: What is the status 22 of the technical justification for the 23 inspection?
24 MR. DOLANSKY: It has been written.
25 This is Bob Dolansky with Entergy. You're asking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5335 1 --
2 CHAIRMAN MCDADE: Yes.
3 MR. DOLANSKY: -- has it been written.
4 Yes.
5 CHAIRMAN MCDADE: Okay. And can you 6 elaborate on the kind of details that are in that 7 document that are unit-specific?
8 MR. DOLANSKY: They talk about the 9 parameters of the, that the NDE inspector would 10 use, how he would set up his equipment, when he 11 does his calibration what type of reflectors he 12 would be looking for from the calibration block, 13 that type of thing.
14 CHAIRMAN MCDADE: Okay. And this is 15 intended, based on the words of the SER, to 16 utilize more recent, the most recent UT 17 technology as well as lessons learned from 18 previous inspections?
19 MR. DOLANSKY: Correct. For instance, 20 the vendor, Westinghouse, typically goes to 21 outages in the spring and fall. That's when 22 outages typically occur.
23 So they would go into outages this 24 past fall, now basically, and anything that came 25 out of those outages, if there any lessons NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5336 1 learned or anything like that, they would 2 incorporate that into the procedure before they 3 give it to us.
4 CHAIRMAN MCDADE: Okay. Judge 5 Wardwell, do you have anything further on that?
6 JUDGE WARDWELL: No, I think it's 7 fine. Thank you.
8 JUDGE KENNEDY: No, I do not.
9 CHAIRMAN MCDADE: Okay. I believe 10 that we had, I believe it was referred to 11 yesterday as sort of homework assignments that we 12 had questions that remained up in the air.
13 There was one, I believe, Dr. Lott.
14 There was a question with regard to the lower 15 support column of whether that was cast material, 16 and were you able to identify any other cast RVI 17 components?
18 DR. LOTT: I realize that question was 19 addressed to me, but I think it might better, and 20 I know this, some of my colleagues on the panel 21 here have been doing some research on that. So 22 I would like to turn it over to Mr. Azevedo.
23 CHAIRMAN MCDADE: Okay, Mr. Azevedo.
24 MR. AZEVEDO: Yes, Your Honor. We 25 looked into this. There's a total of six NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5337 1 components that are reactor vessel internals that 2 are made out of cast material.
3 Two of those six are expansion 4 components, which means they were determined to 5 be moderately susceptible to some form of 6 degradation mechanism. Therefore, they're 7 expansion components.
8 The other four components were 9 screened out as not being susceptible to any 10 degradation mechanism per MRP-191.
11 CHAIRMAN MCDADE: Okay. When you're 12 talking about expansion components, you're going 13 back to Section 4 of MPR-227. Correct, where it 14 lists primary then expansion and based on the 15 susceptibility?
16 MR. AZEVEDO: That's correct.
17 CHAIRMAN MCDADE: Okay. Anything 18 further, Mr. Azevedo, on that?
19 MR. AZEVEDO: No, Your Honor.
20 CHAIRMAN MCDADE: Okay. Dr. Lott, I 21 believe there was a question left for you asking 22 whether or not there was, you could point us to 23 a basis for the statement that low ferrite CASS 24 material would not show a meaningful combined 25 effect from thermal aging and irradiation.
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5338 1 Is there anything you could point to 2 us in support of that proposition?
3 DR. LOTT: Yes. I think that was, the 4 particulars of a question was in relation to 5 Question 8 of our supplemental testimony. And 6 that was really addressed to concerns about 7 embrittlement at or below the threshold for 8 radiation embrittlement materials.
9 So I wasn't trying to, and I don't 10 think we were trying to say anything about higher 11 fluence materials. And there's admittedly very 12 sparse data on this topic.
13 I think the statement itself contains 14 a direct reference to VWR-VIP-2015-025, and that 15 document does talk, I think part of the question 16 was why are we talking about these high ferrite 17 materials when you're telling us it's low ferrite 18 material.
19 That document does site actually a 20 Westinghouse study on a low ferrite, a 10 percent 21 cast material that showed that that material was 22 not subject to the same decrease in embrittlement 23 that the higher cast material say inside 184 24 were.
25 And we believe that, those materials NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5339 1 and that's the basis for our document. We'll 2 notice that the NRC has made similar arguments in 3 their justification for their suggestion of 15 4 percent as a standing level for ferrite material, 5 susceptibility in irradiated materials. And 6 that's in NRC Item 201.
7 CHAIRMAN MCDADE: I'm sorry. It is in 8 what?
9 DR. LOTT: NRC Exhibit 201.
10 CHAIRMAN MCDADE: Okay. And the 11 previous document referred to, do you have an 12 exhibit number for that?
13 MR. SIPOS: I think, Your Honor, it's 14 NRC 209, if I recall Mr. Lott's, Dr. Lott's 15 testimony from yesterday.
16 CHAIRMAN MCDADE: Okay. Thank you, 17 Mr. Sipos.
18 MR. KUYLER: I believe that Dr. Lott 19 was referring to Entergy Exhibit 663, Your Honor.
20 CHAIRMAN MCDADE: Well, we will go and 21 look at both of them. Thank you.
22 Okay. Dr. Lahey, I think we had a 23 question yesterday, and it may or may not have 24 been answered regarding NUREG 7184, New York 25 Exhibit 488. And we're talking about, I think at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5340 1 one point used the word synergistic in another 2 combination.
3 And whether or not there was any 4 evidence that demonstrated that the sum of the 5 thermal embrittlement and irradiation 6 embrittlement is greater than the sum of the 7 parts. Is there any language that you can point 8 us to that would support that proposition?
9 DR. LAHEY: I reviewed, at your 10 request Your Honor, 7184. As I had indicated 11 yesterday, I think, the original language in this 12 report used the work synergistic. And then later 13 on it was changed by the authors to combined.
14 In my view, when I use synergistic I 15 allow for a number of possibilities. I'm not 16 sure what the author allows for. For example, 17 when I use synergistic for a fatigue in 18 radiation, I mean greater than the individual 19 effects.
20 When I use synergistic for thermal and 21 irradiation, I mean combined effects, not 22 necessarily greater than the individual effects.
23 So I can't speak to what the author meant, but 24 they used both at one time.
25 CHAIRMAN MCDADE: Okay. And Dr.
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5341 1 Lahey, I believe there was a question put to you 2 as to whether or not you could identify other RVI 3 components subject to A/LAI 7.
4 DR. LAHEY: Right. Your Honor, I did 5 do a review of a document. It was MRP-191, which 6 carefully went through the various components and 7 the material that they had the radiation fluence 8 that they were subjected to.
9 And as you heard from previous 10 witness, there are a number. The one that 11 appeared to me to be of most concern, other than 12 the one we talked about yesterday, the cap on the 13 lower support plate column is the upper support 14 column base.
15 It has a fluence of around 10 to the 16 21st neutrons per centimeters square. The other 17 ones, at least in my view, didn't seem to be as 18 safety significant as that one might be.
19 CHAIRMAN MCDADE: Okay. Thank you, 20 Dr. Lahey. Judge Wardwell, did that answer your 21 question, or do you wish to follow up?
22 JUDGE WARDWELL: I think I'll follow 23 up with Mr. Azevedo if I might. Was the upper 24 support column base any one of those that you 25 have identified, and was it an expansion or a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5342 1 screened out component?
2 MR. AZEVEDO: Yes, Your Honor. That's 3 one of the six that I mentioned before, and it 4 was screened out as a Category A, which means not 5 susceptible to any degradation mechanisms.
6 JUDGE WARDWELL: Thank you.
7 CHAIRMAN MCDADE: Can you elaborate at 8 all on why it was screened out, the sort of 9 thought process that went on?
10 MR. AZEVEDO: I don't have the details 11 to how each one was screened out?
12 DR. LOTT: Perhaps I could help here.
13 This is Randy Lott --
14 CHAIRMAN MCDADE: Dr. Lott?
15 DR. LOTT: -- Entergy. In the process 16 of the evaluation, those materials were 17 originally identified as cast materials, but 18 there was a step in the process where we did 19 effectively FMECA analysis.
20 It's described in MRP-191, to look at 21 what the impact of these degradation mechanisms 22 were. There were certain components, including 23 the upper support columns, where it was 24 effectively decided that there was no credible 25 damage in impact or need to do additional NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5343 1 analysis on the upper support columns.
2 And they were put into Category A. So 3 it was recognized there were cast materials, but 4 it was also felt that there were no stressors 5 that would challenge that particular component.
6 It was an engineering evaluation. I 7 can't speak to the details of it here, but I know 8 that that process is described in MRP-191.
9 CHAIRMAN MCDADE: Okay. Dr. Lahey, do 10 you wish to comment on the appropriateness of 11 that screening as explained by Dr. Lott?
12 DR. LAHEY: No, I understand what he 13 said, and it has to do with the criterion that 14 has been established for the onset of significant 15 radiation damage.
16 CHAIRMAN MCDADE: Okay. Yesterday I 17 believe there was a question to you, Dr. Lahey, 18 about addressing the WCAP methodology for 19 determining dynamic load, that you wanted to 20 review some documentation to comment on that.
21 DR. LAHEY: Yes, sir. I spent many 22 happy hours for that last night. And I was, so 23 there were two things that you may recall I was 24 concerned with.
25 It was the methodology that was used NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5344 1 to calculate the forces. Was it truly impact 2 force, or was it smear down? And then the other 3 one is what was analyzed. Was that appropriate?
4 So in this report, which was dated 5 2001, it was, and then it was the one that was 6 reviewed and approved later on by the U.S. NRC.
7 It was a generic study of a 4 loop Westinghouse 8 plant to determine what the minimum number of 9 baffle former bolts could be to withstand certain 10 accident events.
11 The methodology that was used is 12 called by Westinghouse a MULTIFLEX, and it's 13 Version 3. And I view that as sort of the 14 grandson or the son, I'm not sure, either an old 15 son or a young grandson of the WHAM code to show 16 it is, in fact, what I think should be used.
17 It's a sub-cool depressurization code, 18 so it propagates at the speed of sound, the 19 depressurization waves throughout the system. So 20 that was good news for me. I was very happy to 21 see that, and I think it's appropriate.
22 Later on in the transient, they switch 23 over to a version of the track code, which has 24 been married to a version of the Cobra codes. So 25 it's W Cobra slash --
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5345 1 MR. KUYLER: Your Honor, if I may 2 break in for a moment. This is Ray Kuyler from 3 Entergy. I would just note that we are 4 discussing a proprietary Westinghouse report at 5 this moment.
6 DR. LAHEY: I'm sorry.
7 CHAIRMAN MCDADE: Well, let's ask 8 whether or not, it does not appear that we're 9 discussing it in sufficient detail or the 10 proprietary aspects of it are going to be 11 released.
12 MS. SUTTON: Your Honor, let me 13 consult with Westinghouse's counsel. They need 14 to consult with their expert. One second.
15 DR. LAHEY: You're actually going to 16 like what I'm going to say, but go ahead.
17 MS. SUTTON: Okay, Your Honor. As 18 long as he remains at a high level of detail, we 19 can proceed, but if it sinks into greater levels 20 of detail, we'll alert you.
21 CHAIRMAN MCDADE: Okay. And Dr.
22 Lahey, actually we have the report.
23 DR. LAHEY: Right.
24 CHAIRMAN MCDADE: Perhaps can you 25 focus on the conclusions that you have drawn from NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5346 1 the report rather than going into the specific 2 details of the report?
3 DR. LAHEY: Right.
4 CHAIRMAN MCDADE: We're interested in 5 your expert conclusions.
6 DR. LAHEY: I am definitely not going 7 to go into detail. In fact, this report has 8 precious few equations. That's in references 9 that I did not have access to. But anyway, the 10 track code and the Cobra code are widely known, 11 have been published in the open literature.
12 So they are the large control volume 13 codes, but it's only used for the flashing part 14 of the transient, and the loads there are very 15 small.
16 So all the loads that we're concerned 17 with in terms of the integrity of the bolts have 18 to do with the sub-cooled blow down phase. And 19 in that phase, the right technique is apparently 20 being used. So I was happy to see that.
21 Now the other part of my concern has 22 to do with what do you do with these methods, 23 which I've now said I think look appropriate?
24 I'm happy to see that.
25 What was done is a break size, which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5347 1 was not the large design basis break size. It 2 was a smaller break size. And then use what the 3 NRC likes to call leak before break criteria for 4 opening time.
5 So it wasn't an instantaneous full leg 6 break of the reactor. It was a smaller line 7 break. So that, what that does is it reduces the 8 severity of the load, which propagates through 9 the system.
10 Nevertheless, I mean this was a 11 generic study, and I haven't seen what is being 12 done for the Westinghouse Plants at Indian Point, 13 and I don't think it has been published.
14 So all these things could have been 15 addressed that I'm going to alert you to, but 16 when this was done, it was found that about 50 17 percent of the bolts could withstand the 18 transient.
19 Fluid structure interaction was 20 modeled, all pretty much state of the art in my 21 view for this type of analysis was employed. So 22 that's good news.
23 If you then go to a design basis 24 accident, even though the NRC has said that leak 25 before break is what you do for such things as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5348 1 pipe width, you don't do it inside the core.
2 You still have to do the regular, 3 local loads. So if these are applied, then it'll 4 be significantly different in terms of the 5 integrity of the bolting.
6 So that remains to be seen, what will 7 be done there. And as I said, I haven't reviewed 8 that. I don't think it's available.
9 CHAIRMAN MCDADE: Okay. Thank you.
10 Judge Wardwell, does that answer your question?
11 JUDGE WARDWELL: Fine. Thank you.
12 CHAIRMAN MCDADE: Do you need any 13 follow up?
14 JUDGE WARDWELL: No.
15 MR. SIPOS: Your Honor, this is John 16 Sipos for the State of New York. I note in that 17 report there is a reference to a code. And that 18 we have checked, and we do not believe that code, 19 we do not have the code that was referenced.
20 And the reference is to WCAP-9735, and 21 it was in the bibliography. Just like to note 22 that for the record.
23 CHAIRMAN MCDADE: Okay. Thank you, 24 Mr. Sipos. Okay. Dr. Lahey, I believe there was 25 a reference that you made yesterday to an Argonne NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5349 1 report, and Judge Wardwell had asked you whether 2 or not you had a cite to an exhibit for that 3 report. Were you able to provide a cite?
4 DR. LAHEY: I believe you're talking 5 about NUREG/CR-7184. Is that the right one?
6 JUDGE WARDWELL: No. It's what you, 7 what are you talking about. It's not what I'm 8 talking about.
9 DR. LAHEY: In my testimony, I look 10 back at my testimony, and I did cite that 11 particular report.
12 JUDGE WARDWELL: Let's make sure we're 13 clear on this.
14 DR. LAHEY: Okay.
15 JUDGE WARDWELL: So your testimony 16 482, page 18, lines 16 through 22 says, "A recent 17 report prepared by Argonne National Lab," and 18 then it goes on for several lines with no cite of 19 what that report is.
20 Two pages later, you cite to two or 21 three different NUREGs.
22 DR. LAHEY: Right.
23 JUDGE WARDWELL: My question is, the 24 482, page 18, lines 16 through 22, Argonne 25 National Laboratory report that you referred to, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5350 1 what is the cite for that?
2 DR. LAHEY: Yes. I believe that 3 particular one was the Chopra report. The lead 4 author would be Dr. Chopra from ANL.
5 JUDGE WARDWELL: And what's the NUREG 6 number?
7 DR. LAHEY: Okay. Let's see.
8 JUDGE WARDWELL: Would it be 7027?
9 DR. LAHEY: It's possible.
10 JUDGE WARDWELL: The exhibit for that 11 one, at 7027, is New York State 487.
12 DR. LAHEY: Let me look.
13 JUDGE WARDWELL: Not to take the 14 thunder out of Entergy's crack cite locator, but 15 I have to show off sometimes.
16 DR. LAHEY: All right. I don't carry 17 around those numbers in my head, so I'm going to 18 have to look, Your Honor. Let's see.
19 (Pause.)
20 DR. LAHEY: Bear with me please, and 21 I'll search it down.
22 JUDGE WARDWELL: Let's just wait.
23 Could we call up New York State 487 and see if, 24 it would have the author as Chopra.
25 DR. HISER: Your Honor, this is Allen NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5351 1 Hiser of the staff. I think it is New York State 2 488 --
3 JUDGE WARDWELL: Okay.
4 DR. HISER: -- page XV. I believe 5 that top paragraph is executive summary about 6 two-thirds of the way down the paragraph.
7 DR. LAHEY: That one's the Chen report 8 you just put up, but that's not it.
9 JUDGE WARDWELL: You say that's not 10 it?
11 DR. LAHEY: That particular one that's 12 on the screen now, the lead author is Chen.
13 He's, I did reference that report, but you were 14 asking about a different one, I believe.
15 JUDGE WARDWELL: I don't know which 16 one you're asking.
17 DR. LAHEY: I believe it's --
18 JUDGE WARDWELL: I'm asking for your 19 482, page 18, lines 16 through 22, when you say, 20 "A recent report prepared by Argonne National 21 Laboratory for U.S. NRC" --
22 DR. LAHEY: Okay.
23 JUDGE WARDWELL: What is that report?
24 And you say it's the Chopra report. Correct?
25 MR. SIPOS: Your Honor, it's John NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5352 1 Sipos for the State of New York. May I try to 2 resolve this?
3 JUDGE WARDWELL: Sure.
4 MR. SIPOS: Lower down on line 22, I 5 believe, of New York State 482 on page 18, that's 6 where we are.
7 JUDGE WARDWELL: Yes.
8 MR. SIPOS: I believe there's a 9 reference to Chen, et. al. on the very last two 10 lines of that page carrying over.
11 JUDGE WARDWELL: Well, you address 12 that to your witness to have him verify that 13 that's what he's referring to is 488 then.
14 DR. LAHEY: Yes. What is the date of 15 the testimony that you're talking about, or what 16 is the New York State reference?
17 MR. SIPOS: June 2015.
18 DR. LAHEY: Okay.
19 CHAIRMAN MCDADE: Mr. Welkie, can you 20 pull up New York 488? This is 487, isn't it?
21 JUDGE WARDWELL: No, it's 482.
22 CHAIRMAN MCDADE: Never mind. Thank 23 you. All right.
24 DR. LAHEY: So this testimony is June 25 9, 2015, New York State 482. Is that the one, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5353 1 Your Honor?
2 JUDGE WARDWELL: It's your testimony.
3 DR. LAHEY: That's, I've done a lot of 4 testimony, but that's the one you're concerned 5 with?
6 JUDGE WARDWELL: Yes.
7 DR. LAHEY: All right. Tell me the 8 page number again.
9 JUDGE WARDWELL: 18.
10 DR. LAHEY: Okay.
11 JUDGE WARDWELL: And it's line 16, if 12 you go to line 16, that's where the, it's really 13 on 17, "Moreover, a recent --
14 DR. LAHEY: Right.
15 CHAIRMAN MCDADE: -- laboratory report 16 prepared by Argonne Lab."
17 DR. LAHEY: So that particular quote 18 is for the Chen report.
19 JUDGE WARDWELL: So it is. If we go 20 to the next page, it is 7184 then. Is that 21 correct?
22 DR. LAHEY: Yes, sir.
23 JUDGE WARDWELL: Thank you.
24 DR. LAHEY: Sorry it took so long.
25 JUDGE WARDWELL: No problem. We got NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5354 1 it all straightened out. We have so many numbers 2 of those.
3 CHAIRMAN MCDADE: Those were the only 4 homework assignments that I recall. Is there any 5 witness who right now was asked to look something 6 up that we haven't addressed here this morning so 7 far?
8 MR. GRIESBACH: Yes, Your Honor. This 9 is Tim Griesbach from Entergy.
10 CHAIRMAN MCDADE: Yes.
11 MR. GRIESBACH: I believe Judge 12 Wardwell had asked us to clarify the screening 13 criteria that were used for the cast components, 14 and I'm prepared to do that now.
15 CHAIRMAN MCDADE: Please.
16 MR. GRIESBACH: Let me go through the 17 sequence. The original criteria in MRP-191 18 stated both criteria for thermal embrittlement 19 and irradiation embrittlement. That's in New 20 York State 321, Tables 3-5 and 3-6.
21 They went through and screened the 22 various components, including the lower support 23 columns. There were several criteria, one based 24 on molybdenum content less than or greater than 25 0.5 percent, materials, whether they're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5355 1 statically or centrifugally cast.
2 And then the ferrite content less than 3 or greater than 20 percent. There's separate 4 criteria for irradiation embrittlement based on 5 1 dpa fluence. So that was the criteria that 6 were used.
7 And in the NRC review of that, they 8 took issue with the criteria. Although those 9 criteria had been published in a letter, called 10 the Grimes Letter, that's NRC document 213, new 11 information particular to the effects of both 12 thermal and irradiation embrittlement came to 13 light.
14 And the NRC staff had offered revised 15 proposed criteria taking into account both. In 16 fact, NRC went back and looked at that, those 17 materials that had screened out per the new 18 criteria, and those can be found in NRC Exhibit 19 201.
20 The same molybdenum content, the same 21 static statically or centrifugally cast material, 22 but there was the combination of thermal and 23 irradiation embrittlement could be screened out 24 if the ferrite content were below 15 percent, 25 which was part of the confusion that we had NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5356 1 yesterday.
2 In fact, those components in Indian 3 Point 2 and 3 did screen out for that very 4 reason. Although the separate criteria to 5 continue to look at them for irradiation 6 embrittlement would be if they exceeded a dpa 7 level of 1.5 dpa.
8 So that was the method, methods to 9 use. I believe Dr. Hiser discussed that 10 yesterday. And that is also very clearly stated 11 in the NRC testimony in their question 163 on NRC 12 Exhibit 197.
13 And that's stated on pages 94 and 95.
14 So I believe that reflects why there may have 15 been two different sets of criteria used and why 16 there was some confusion yesterday.
17 JUDGE WARDWELL: Thank you.
18 DR. HISER: Your Honor --
19 CHAIRMAN MCDADE: Dr. Hiser?
20 DR. HISER: This is Allen Hiser of 21 NRC. You also asked, posed a question yesterday 22 that if Entergy were to implement the 23 Westinghouse methodology on acceptability of 24 their bolt configuration post-inspection what the 25 NRC approval process, what process that would fit NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5357 1 into, whether that would be something would be 2 available for the public to comment on or exactly 3 where that would fall. And I'm prepared to 4 discuss that.
5 CHAIRMAN MCDADE: Please.
6 DR. HISER: If that case were to 7 occur, that the applicant were to do it's 8 inspection and find that there were degraded 9 bolts that it could not justify, would they be 10 able to perform the individual bolt function?
11 And they then move that condition to 12 the corrective action program. If they were to 13 implement this engineering justification that 14 they discussed, then that analysis would be 15 evaluated through 50.59 to determine whether a 16 license amendment would be required by the 17 applicant.
18 If the conclusion was that a license 19 amendment would not be required, then 50.59 would 20 be documented, and it would be available for 21 staff review.
22 If a license amendment were to be 23 necessary, then the applicant would follow the 24 normal 50.90 process for license amendment. At 25 this point, we cannot make, we cannot prejudge NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5358 1 what that 50.59 process, what the result would be 2 from that by the applicant.
3 CHAIRMAN MCDADE: Okay. Thank you, 4 Dr. Hiser. I appreciate that. Okay. I think 5 we're ready to get started then with regard to 6 specific questions regarding exhibit --
7 MR. BESSETTE: Your Honor, this is 8 Paul Bessette. Can we just have a moment to swap 9 witnesses, move one of our witnesses from the 10 back to the right? It might be more convenient 11 for Your Honor.
12 CHAIRMAN MCDADE: Yes, sure.
13 JUDGE WARDWELL: And witnesses that 14 are part of, that are only on 25 should leave the 15 table. But before we do that, I would like to 16 just thank all of the witnesses on 25.
17 I requested certain attributes that I 18 wanted from your answers, and I think it was 19 succeeded very successfully. We got through a 20 lot of stuff in about a day's a little change 21 worth of effort.
22 And it was due mostly because of your 23 succinct answers that you gave, and I want you 24 let you know I appreciate your responses.
25 MR. TURK: Your Honor, this is Sherwin NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5359 1 Turk.
2 CHAIRMAN MCDADE: Mr. Turk?
3 MR. TURK: Can we pause for a moment 4 or two? Some of our witnesses are not in the 5 room currently. They'll be back in a moment, or 6 at least one of them.
7 MS. SUTTON: Your Honor, one of our 8 witnesses needs to also take an emergency break.
9 We'll be very brief.
10 CHAIRMAN MCDADE: We're sort of in a 11 recessing place right now, so do you want to take 12 a short break, Dr. Lahey?
13 DR. LAHEY: If we're on a recess, I 14 will.
15 CHAIRMAN MCDADE: Actually, while we 16 get organized, rather than just sitting here, why 17 don't we take five minutes? And we'll come back 18 in five minutes.
19 MR. TURK: Thank you, Your Honor.
20 (Whereupon, the above-entitled matter 21 went off the record at 9:14 a.m. and resumed at 22 9:22 a.m.)
23 CHAIRMAN MCDADE: Okay. Judge 24 Kennedy?
25 JUDGE KENNEDY: I guess this brings us NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5360 1 to Contention 26. Similar to Contention 25 where 2 Judge Wardwell led the questioning, I'll take the 3 initial cut at questions for the witnesses and 4 New York State 26.
5 So it will proceed as we did for 25.
6 I know there's some new folks here that may not 7 have observed what we did, but I'm the lead 8 questioner, if you will, have the lead on the 9 contention.
10 But my colleagues here will also 11 chime in at various points to ask questions and 12 follow up questions. So I have a series of 13 questions that I'm going to go through and then 14 ask them to chime in as need be.
15 Contention 26, as the Board views it, 16 raises a general challenge to Metal Fatigue Aging 17 Management Program and in specific raises some 18 challenges to the calculations of the cumulative 19 usage factors and the CUFens that are used.
20 It appears to focus extensively on the 21 methodology and approach used to calculate these, 22 and so we'll get into a lot of discussion about 23 those calculations.
24 I know we almost completely avoided 25 any discussion on proprietary information, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5361 1 right at the finish line we started to get close.
2 I can assure you the Board's attempted to try to 3 deal with the issues on Contention 26 in a level 4 that we hope is high enough that we won't have to 5 close the meeting.
6 But I do appreciate the efforts of 7 Entergy to keep us on the right path here. As 8 always, we're still technical people, and we get 9 curious. And we raise questions, so I appreciate 10 your efforts and we'll try to deal with it.
11 But I can see this is a very technical 12 contention with a lot of methodology and a lot of 13 proprietary information. We've attempted to try 14 to address our questions at a level about the 15 specifics, if that makes sense at this point.
16 Hopefully it'll make sense as we go 17 through it. We've tried to stay at more of a 18 concept level, not use specific values to try to 19 deal with a lot of these issues from a conceptual 20 level.
21 At the end of the day we may not be 22 able to do that, so there may come times where it 23 has to get down, to really address a specific 24 question, into the details.
25 And again, we'll look to Entergy and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5362 1 to Westinghouse to help keep us from revealing 2 anything that shouldn't be revealed to the 3 public.
4 MS. SUTTON: Your Honor, this is 5 Kathryn Sutton for Entergy. We have advised our 6 experts that if they believe that they need to 7 wade into details that are proprietary, they 8 should first alert you.
9 But at the same time, we are concerned 10 that we do need to put the contention to bed and 11 make the case. So we will work with you, Your 12 Honor, to make sure that we protect the 13 information. And we'll work with Westinghouse as 14 well.
15 JUDGE KENNEDY: I appreciate that.
16 And as we get through this and get a little 17 experience with the issues at hand here, maybe a 18 path will be clear on how we'll deal with this.
19 I mean it's possible we could move all 20 of those issues to the end of the day or to an 21 appropriate time. Having said that, we're going 22 to try to not get down that road.
23 But I appreciate the difficulty in 24 being able to do this. The Board has spent a lot 25 of time reviewing the pre-filed testimony, and it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5363 1 contains a lot of proprietary information.
2 With that discussion, this is the 3 issues related to Contention 26. Before I get 4 into the specifics of my questions, it occurred 5 to the Board that it would be useful to have some 6 contextual discussion about CUFs.
7 We'll have to find out how to 8 pronounce some of this so we can communicate, but 9 have some initial discussion about what a CUF is, 10 how it's calculated.
11 And again, my intent is to do this at 12 a level to provide contextual information for the 13 follow up questions. So if you feel the need to 14 get way deep into a methodology detail, let us 15 know.
16 We can maybe park that for a while 17 until we get to more specifics on the details of 18 the calculations. But I wanted to at least have 19 some opening discussion about those parameters.
20 And then we'll use that in the 21 subsequent questions as background material for 22 our follow up questions.
23 My intent, at least to start, is to 24 direct these questions to Entergy. It's their 25 application. It's their CUFs for their plant.
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5364 1 And I guess Westinghouse has a role in this, too.
2 So I'm going start with a series of 3 questions to Westinghouse, to Entergy, and I'll 4 let you folks decide who the appropriate person 5 is.
6 But I had put together, sort of at a 7 high level, a series of questions that try to 8 address this whole CUFs issue, not to solve it, 9 but to provide some context so when we get into 10 the specific issues that have been raised by New 11 York State we have some backdrop information to 12 help make it clear.
13 I'm going to try to do the easy one 14 first. Someone can enlighten us at to what a CUF 15 is, maybe with what it's an acronym for to start 16 with.
17 MR. GRAY: Yes, Mark Gray for Entergy.
18 CUF stands for cumulative usage factor. It's 19 required by the ASME code. The calculation is 20 according to Section 3 of the code, Section NB-21 3222.4(e)[5].
22 And that section gives a prescribed 23 method for combining stress cycles that occur on 24 a component in a method that allows you to 25 calculate the usage factor, which is for each NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5365 1 pair of stress cycles that form a range.
2 That's called the alternating stress 3 range. It's the amplitude that you use on the 4 fatigue curve. So you calculate the stress 5 range. You get an amplitude, the alternating 6 stress for some stress cycle pair.
7 That stress cycle pair then is 8 assigned an allowable number of cycles from the 9 design fatigue curve. From that allowable number 10 of cycles, you also have the actual or design 11 number of cycles for that stress cycle pair.
12 The ratio of the actual number of 13 cycles in the design divided by the allowable 14 cycles from the curve is the usage factor for 15 that pair. So it's a calculation, to start with.
16 JUDGE KENNEDY: Yes, and sounds like 17 a complex calculation that tries to provide an 18 indication. Does it, the sense I get is it tries 19 to provide an indication based on actual versus 20 a design life of the component.
21 It sounds like it's a ratio. Is it a 22 ratio?
23 MR. GRAY: So it's a ratio of the 24 number of cycles expected for the component 25 divided by the allowable based on the fatigue NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5366 1 curve. So it's the fraction of the allowable 2 life of the component from that stress cycle.
3 The cumulative usage factor is the sum 4 of all those incremental usage factors for all 5 the stress cycles in the design.
6 JUDGE KENNEDY: So all the stress 7 cycles that a particular component or series of 8 components would be exposed to?
9 MR. GRAY: Yes.
10 JUDGE KENNEDY: And so it's a design 11 type calculation. In other words, it's done when 12 the plant is being designed?
13 MR. GRAY: Yes.
14 JUDGE KENNEDY: And it's an indication 15 based on some projected amount of actual cycles 16 that would occur during the operation of the 17 plant of how close you are to ultimate failure of 18 the component, the fatigue life of the component, 19 the design life of the component.
20 MR. GRAY: The design life of the 21 component is represented by that allowable 22 fatigue usage, cumulative fatigue usage factor of 23 1. So basically, it's 100 percent of the stress 24 cycles allowed by the design curve.
25 And you calculate the fraction of that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5367 1 based on the loadings postulated for the 2 component of all the stress cycles that are 3 postulated for the component.
4 JUDGE KENNEDY: Does that imply that 5 the postulated cycles is less than the design 6 cycles? Is that, would it always be 1? We know 7 it's not, but --
8 MR. GRAY: No, let's clarify 9 terminology a little bit. Section 3 defines that 10 you need, requires a design specification for the 11 component. That design specification tells you 12 all the loads that have to be considered for the 13 component.
14 When it comes to the fatigue loads, 15 those loads are associated with a number of 16 cycles. Those loads translate then into stress 17 cycles on the component.
18 And then those stress cycles are used 19 to calculate the usage factor. So the design 20 cycles, when you say cycles, that's normally used 21 to refer to those number of cycles in the design 22 specification for the loads to be considered.
23 The allowable cycles are the allowable 24 cycles that you get from the design fatigue curve 25 for a given stress level.
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5368 1 JUDGE KENNEDY: So is the allowable 2 some sort of measure from the design perspective 3 of what that component is capable of 4 withstanding?
5 MR. GRAY: Yes, the design allowable 6 number of cycles is from the design fatigue 7 curve, which is based on test data plus margins.
8 JUDGE KENNEDY: And if this is a ratio 9 calculation, is that the denominator of the 10 calculation?
11 MR. GRAY: The denominator, yes.
12 JUDGE KENNEDY: So then the numerator 13 is an expected set of, expected level of --
14 MR. GRAY: Yes, expected number of 15 cycles for that stress cycle.
16 JUDGE KENNEDY: Okay.
17 MR. GRAY: And yes, you're right. The 18 stress cycles are a function of the number of 19 transients.
20 JUDGE KENNEDY: Okay.
21 MR. COX: Judge Kennedy, this is Alan 22 Cox with Entergy. One point of clarification.
23 We say expected cycles. I guess another way to 24 put that will be assumed cycles or cycles that 25 were specified in the design.
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5369 1 Again, these calculations were done 40 2 years ago as part of the design, so what was 3 assumed for some of those cycles, today we may 4 not expect to ever get there.
5 So it's some slight nuance there, but 6 it's something that could come into play because 7 of the operating history of the plant.
8 JUDGE KENNEDY: So the CUF value has 9 expected values in the numerator, and the 10 denominator is based on the design parameters.
11 And these are all done, the entire calculation is 12 done during the design process.
13 So these are, as Mr. Cox said, 14 historical values?
15 MR. GRAY: Well, this is Mark Gray 16 again. The original CUF was calculated during 17 the design process for the component when that 18 component was a Section 3 component.
19 JUDGE KENNEDY: Are you going to go on 20 to tell me that these have been recalculated 21 during the operation of the plant or due to 22 changes? Would you recalculate this design 23 parameter?
24 MR. GRAY: Yes. You can recalculate 25 that at any time. The reason I qualified what I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5370 1 said is not all of the Indian Point components 2 that have been evaluated for environmental 3 fatigue, had an original Section 3 design CUF 4 requirement.
5 JUDGE KENNEDY: So did those need to 6 be calculated to support the license renewal 7 application then?
8 MR. GRAY: Yes.
9 JUDGE KENNEDY: Okay. Would there be 10 any reason, during the life of the plant, to 11 recalculate other than say a need that you have 12 identified for the license renewal proceeding, to 13 recalculate the CUF?
14 MR. GRAY: Yes. In fact, there have 15 been instances of loadings that have been found 16 in operation at plants that weren't considered in 17 the original design.
18 And in those cases, a new analysis 19 would be performed to demonstrate that the 20 component was still good under the revised 21 loadings.
22 JUDGE KENNEDY: If the operating 23 history of the plant was different than the 24 allowable cycles, maybe I'm using the wrong word.
25 The actual cycles are allowable. I'm not sure.
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5371 1 Whatever's in the numerator, is that allowable?
2 There's head shaking going on over 3 here. Let's stay with Mr. Gray for a minute. Am 4 I getting crossed up again with this design 5 versus allowable?
6 MR. GRAY: Yes. Let me define. When 7 we, for a component that has a CUF calculation, 8 that CUF is based on the design fatigue curve.
9 And the denominator in those usage factor 10 calculations came from the design fatigue curve.
11 The numerator in those calculations 12 came from the design specification, the number of 13 expected loadings for the component. For 14 example, if there's an operational transient 15 that's discovered, that changes the numerator.
16 When the plant is counting their 17 cycles against what's been designed, now that 18 numerator now becomes the allowable for the plant 19 to track to because that's what was used in the 20 CUF calculation.
21 JUDGE KENNEDY: Okay. Yes, that helps 22 if I think in terms of fixed parameters versus 23 non-fixed parameters. From your testimony, I get 24 the sense that the denominator is a fixed 25 parameter and that the numerator could be fluid.
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5372 1 That may be a bad term in this context 2 but could change during the operation of the 3 facility as the operating history of the plant 4 changes. Is that fair?
5 MR. GRAY: That's a fair 6 interpretation, yes.
7 JUDGE KENNEDY: Okay.
8 MR. COX: This is Alan Cox again. I 9 think one clarification to that, or not 10 clarification, but another way to say it is the 11 allowable is the allowable for that analysis to 12 remain valid.
13 If the analysis said you had a low 14 CUF, you could allow additional cycles and revise 15 the analysis to accommodate those additional 16 cycles. But for that calculation, to calculate 17 that particular CUF to remain valid, you have to 18 stay below those number of cycles.
19 JUDGE KENNEDY: And I guess would the 20 limit then be on the allowable cycles up to a 21 value of, a ratio of 1.0? I mean if you 22 recalculate it, is that the limit to where you --
23 MR. COX: Yes. That's correct. You 24 could, that's the limit from the design spec.
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5373 1 valid. If you have a low CUF, you can revise the 2 calc to use a higher allowable.
3 And it would be up to the point of 4 where you exceeded 1.0 5 JUDGE KENNEDY: So starting at some 6 initial point, you had allowable and the design 7 values. Is that then the design basis for the 8 operation of the plant?
9 Is that monitored? Again, this is 10 probably not license renewal. Maybe it is 11 license renewal, but prior to the period of 12 extended operation, this was a design calculation 13 that was in place. I guess --
14 MR. AZEVEDO: This is Nelson Azevedo 15 from Entergy. Yes, Your Honor, just if I may try 16 to clarify, and maybe I won't. But the way I 17 think that they're the actual cycles the plant 18 sees.
19 Then next, they're the design cycles 20 that the plant was designed and then the 21 allowable cycles that the ASME code provides. So 22 that's the way I look at it, those three 23 different numbers.
24 So when the plant was originally 25 designed, or if it was modified, these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5374 1 calculations would get redone. It was designed 2 for X amount of cycles to make sure there 3 remained within the allowables from the ASME 4 code.
5 And now we track the actual cycles 6 versus the design cycles that were originally 7 used to design the component, if that clarifies 8 it.
9 JUDGE KENNEDY: The allowable, can 10 that, is that specified by the designer, or is it 11 specified by the code?
12 MR. AZEVEDO: The allowable cycles 13 comes from the ASME code. There's a stress range 14 versus number of allowable cycles. There's an SM 15 curve in the ASME code.
16 And for that specific stress, for that 17 specific cycle, you go to that curve, it'll tell 18 you what the allowable number of cycles is for 19 that specific condition.
20 JUDGE KENNEDY: And those constitute 21 the allowables?
22 MR. AZEVEDO: Those are the allowables 23 from the ASME code.
24 JUDGE KENNEDY: And that's in the 25 numerator or the denominator?
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5375 1 MR. AZEVEDO: That's in the 2 denominator.
3 JUDGE KENNEDY: Okay. So the actuals 4 are, whatever you, whatever's specified for the 5 design spec for the operation of a plant would go 6 in the numerator. And then that's tracked. Is 7 that tracked then through time?
8 MR. AZEVEDO: Yes. What we do is we 9 actually track the actual cycles versus the 10 design cycles that we used in the calculation.
11 The analyzed cycles, design cycles, those are 12 interchangeable terms.
13 JUDGE KENNEDY: Okay. Thanks. Mr.
14 Hiser, or Dr. Hiser, sorry. We're getting a 15 little, too. We've asked you too many questions.
16 They're getting a little too friendly here.
17 You seem to be expressing some, that's 18 the face. Are we tracking with how the NRC views 19 this CUF picture?
20 DR. HISER: This is Allen Hiser with 21 the staff. Yes, I think you're on the right 22 track now. It's very confusing between 23 allowable, design, projected and sorting that 24 out, I think, is a very important first step.
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5376 1 making the same face back at you because that's 2 where I was when we first started reading this 3 testimony.
4 DR. HISER: And I apologize. It's my 5 thinking of things and not --
6 (Simultaneous speaking.)
7 JUDGE KENNEDY: I believe we all do 8 it, and I apologize for bringing to anybody's 9 attention.
10 CHAIRMAN MCDADE: And we certainly 11 don't want to discourage you from thinking about 12 this.
13 DR. HISER: Thank you.
14 JUDGE KENNEDY: Maybe to the witnesses 15 for the State of New York, any concerns over the 16 discussion that Entergy's provided?
17 DR. LAHEY: This is Richard Lahey.
18 That's my understanding as well of the original 19 CUF.
20 JUDGE KENNEDY: Dr. Hopenfeld?
21 DR. HOPENFELD: This is Joram 22 Hopenfeld, Riverkeeper. There's one important 23 point that I would like to, can you hear me well?
24 Can you hear me okay?
25 JUDGE KENNEDY: Please take both, yes.
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5377 1 Maybe move the mic a little bit.
2 DR. HOPENFELD: It's not a detail, but 3 it's an important point because it relates to 4 your question as to what you do at the beginning 5 during the design stage.
6 After you take your maximum stress to 7 identify the minimal stress during that 8 transient. Take the difference. You have to 9 multiply that difference by a stress 10 concentration factor to allow for the fact that 11 LOCA stress may initiate or may propagate 12 differently than if you had just considered only 13 the average.
14 So the point is, that stress 15 concentration factor is a factor. It depends on 16 geometry. So if a situation in the plant, and 17 it's on the secondary side, due to geometry of 18 the changes or you have radiation effect.
19 JUDGE KENNEDY: Let me, I don't mean 20 to interrupt you, but we're going to get to that.
21 This, to me, is sort of setting the stage so that 22 we're all on the same page.
23 I think you've raised some of those 24 concerns in your testimony, and we'll get into 25 the specifics later of the calculations and I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5378 1 think try to deal with some of the points you 2 made.
3 I didn't mean to cut you off, but 4 we're going to get way beyond where I think we 5 need to be at this point. Appreciate it though.
6 Thank you.
7 MR. SIPOS: Excuse me, Your Honor, 8 John Sipos for the State of New York. Could I 9 move Dr. Hopenfeld's microphone closer to him?
10 CHAIRMAN MCDADE: Please.
11 MR. SIPOS: Thank you. Mr. Welkie can 12 do a better job of it than I can.
13 DR. HOPENFELD: Thank you.
14 CHAIRMAN MCDADE: All right. We're 15 going to get you a different microphone, Dr.
16 Hopenfeld. So we're going to continue. We've 17 got some questions over here to Entergy.
18 So by the time you're called on again, 19 Mr. Welkie will have a more effective microphone 20 for you.
21 DR. HOPENFELD: Hope it's not a 22 message for me.
23 JUDGE KENNEDY: Hopefully if you have 24 any questions before we get your microphone in 25 please jot them down so we don't lose them.
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5379 1 Let's go back to Entergy and maybe Mr. Gray, 2 we'll start with you.
3 Are there conservatisms built into 4 those calculations, and maybe, I guess I don't 5 want a simple yes or no because we're going to 6 get into conservatisms and margins later. But if 7 you could maybe outline if there are and sort of 8 in general terms, the types of conservatisms that 9 could be at play here.
10 MR. GRAY: Yes, and as you eluded to, 11 in our testimony we do make a distinction between 12 the ASME code margins and ASME code conservatisms 13 and analysis conservatisms.
14 Those are three categories of some 15 amount of conservatism. And the calculations 16 contain all three of those.
17 JUDGE KENNEDY: Right, and I 18 appreciate that, and I do remember that from the 19 testimony. And we'll have some specific 20 discussion about that and give New York State an 21 opportunity to weigh in.
22 But that's what I was looking for is 23 at that level, yes, there are conservatisms built 24 into it as you point out.
25 Does the WESTEMS code play a role in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5380 1 the CUF calculation, or is that a different 2 aspect of this, to this puzzle?
3 MR. GRAY: This is Mark Gray. The 4 WESTEMS code is the tool that Westinghouse used 5 for the ASME Section 3 evaluations, so yes, it 6 does the CUF calculation.
7 JUDGE KENNEDY: All right. Thank you.
8 Now let's move into, and I don't know how to say 9 these either. There's the CUFens. What's going 10 on there, and I'll start with Mr. Gray. And 11 there are probably others to answer.
12 So we started with just CUF, and now 13 we've added something to those calculations.
14 Maybe if you could address in sort of general 15 terms what that's all about and why it was done.
16 MR. GRAY: The CUF calculation was 17 done according to the ASME code, Section 3. The 18 penalty factor to account for the effects of 19 reactor water environment is termed Fen.
20 That methodology is prescribed by the 21 NUREGs, and there are a number of different ways 22 that that Fen can be applied. But essentially 23 the CUFen is the product of the ASME code CUF and 24 the Fen penalty factor to account for reactor 25 water environment.
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5381 1 And the reason that is done is because 2 the NRC has required that plants doing a license 3 renewal evaluation evaluate certain components 4 for the effects of the reactor water environment 5 on their design fatigue calculations.
6 JUDGE KENNEDY: And did you just 7 mention that those Fens, I'm not sure what, so 8 the environmental adjustment, that's prescribed 9 by the NRC and was used in these CUFen 10 calculations?
11 MR. GRAY: Yes. The Fen factors are 12 defined in different NUREG reports.
13 JUDGE KENNEDY: Okay. Let me go 14 backwards just a little bit because I was using 15 some terms relative to conservatisms. Later on 16 we're going to talk a little bit about safety 17 margin and reductions in safety margin and 18 conservatisms.
19 In your mind, is there a difference 20 between the term margins and conservatisms? Are 21 they different concepts? They trying to do 22 different things, or should the Board view those 23 as similar?
24 MR. GRAY: While they may have a 25 similar effect on the results of an analysis, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5382 1 do view those as having a different role. The 2 margin is something that, as an analyst, I can't 3 touch.
4 That's defined in the code methodology 5 and allowables, particularly the design fatigue 6 curve. The conservatism is a function of the way 7 the analysis is performed.
8 And that conservatism can be a 9 function of which section of the code I used to 10 do my analysis. The code allows different types 11 of analysis to be done that have different levels 12 of conservatism in them.
13 The other aspect of conservatism is 14 the assumptions that the analyst makes in the 15 inputs and the modeling. And that has to be 16 determined by the analyst and, of course, go 17 through a verification process.
18 JUDGE KENNEDY: So one distinction 19 that I heard you make is that margins are 20 dictated by the code and cannot be adjusted or 21 changed or reduced. Is that what I heard you 22 say?
23 MR. GRAY: Yes. I'll only qualify 24 that by the ASME code does have sort of a blanket 25 statement that if you can justify something other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5383 1 than what it says, you could do that.
2 But generally speaking, and what we've 3 done here, that hasn't been performed.
4 JUDGE KENNEDY: All right. Thank you.
5 Dr. Hopenfeld or Dr. Lahey, do you, we're going 6 to get into safety margins and reductions and 7 stuff. But do you have anything you'd like to 8 add to what Mr. Gray has said here about margins 9 and conservatisms?
10 DR. LAHEY: Your Honor, this is 11 Richard Lahey, not about the margins. When we 12 talked about Fen, then I have something to say.
13 JUDGE KENNEDY: Yes, and I think we're 14 going to get into, this is sort of the 15 preliminaries. We're going to get into the 16 details a little later, so just I'm sure we'll 17 get a chance to get into that.
18 Too many stickies here. At some point 19 in the testimony, and I guess New York State has 20 raised some objections or discussions about the 21 revision to the CUFen calculations that were 22 performed.
23 What motivated the, well, is that true 24 first of all? Were the CUFen calculations 25 revised during the license renewal process? And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5384 1 if so, why was that done? And I'll guess we'll 2 take it from there. Mr. Gray?
3 MR. GRAY: Yes. This is Mark Gray for 4 Entergy. There actually, in the whole process 5 there have been revisions to the calculations for 6 different reasons.
7 But I think the main thing that you're 8 referring to is that in the midst of performing 9 their fatigue management program, the cycles, the 10 actual cycles of different transients attract.
11 So as you know, this has been going on 12 over a number of years, so some of those original 13 CUFen calculations assumed a given number of 14 cycles for analysis based on projected cycles for 15 the plant.
16 As the cycle counts are updated, and 17 those projections are revised, then the 18 calculation may be revised to use a higher number 19 in the analysis so that there is more room for 20 the plant to operate within still an acceptable 21 number of analyzing cycles.
22 JUDGE KENNEDY: So these calculations 23 are revised to bring actual cycle information 24 into the calculation from the operation of the 25 plant. Is that what I heard?
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5385 1 MR. GRAY: Yes, and to allow more 2 because the plant's going to compare what they've 3 tracked against what we've analyzed.
4 So that's the plant's allowable versus 5 the analysts' allowable, which is the assigned 6 current allowable. I don't want to make, confuse 7 that again.
8 JUDGE KENNEDY: Does this include 9 being able to operate the plant beyond the 40 10 year life? I mean is that part of this puzzle 11 piece?
12 MR. GRAY: Yes. Let me qualify that 13 though by saying something, I think, that was 14 mentioned yesterday. The 40 year life is tied an 15 assumed number cycles in that 40 year life.
16 So the 60 year life, if it has been 17 justified that that 40 year design number of 18 cycles is really not even going to be reached in 19 a 60 year life, it's the 40 and the 60, it's 20 still defined by the same number of analyzed 21 cycles.
22 JUDGE KENNEDY: Okay. It seems like, 23 and this is, I don't really have anything here.
24 But it seems like from memory that a lot of these 25 revised CUF calculations were much lower than the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5386 1 original CUF calculations that were in the 2 application.
3 It would seem to me if you're, and I'm 4 not sure what caused that. Is it, as some would 5 say, a reduction in conservatisms or is it 6 bringing more actual plant data into the 7 calculation?
8 MR. GRAY: Okay. I think now you've 9 defined a context for me that I can better answer 10 your question.
11 JUDGE KENNEDY: Okay.
12 MR. GRAY: When you're referring to 13 the license renewal application, at that time, 14 the penalty factors and the CUF values that 15 Entergy used were simply, probably much more 16 conservative design fatigue usage factors.
17 Maybe at this point I should mention 18 that it's important to understand that when we do 19 a CUF calculation for design, we're not looking 20 to predict an exact or precise number.
21 We're looking to make sure that it's 22 within the allowable of one. When the analyst 23 gets the number under 1, he stops. And those 24 would be the types of numbers that Entergy 25 would've been taking from the design and applying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5387 1 a screening Fen factor, just to give an idea of 2 what components had to be analyzed further.
3 And when those components were 4 analyzed further within the details of how the 5 NUREGs say to apply the Fens and the current 6 industry practices, that analysis would have 7 removed a lot of conservatism from those original 8 design calculations. And that's why that big 9 difference.
10 JUDGE KENNEDY: Okay. And I think 11 we'll get into some of that discussion later on.
12 I know New York State has some questions that 13 we'll be addressing.
14 So there's now a set. At some point 15 there were CUFs. Now I guess as part of the 16 license renewal process, we have these CUFens.
17 So the values of CUFen that were developed, were 18 those developed as part of the license renewal 19 process? And are those the numbers that are 20 provided in the application?
21 MR. COX: This is Alan Cox with 22 Entergy. I think Mr. Gray eluded to the initial 23 calculations and using the initial CUF values 24 from the original design and then applying the, 25 what we consider bounding Fen factors, to give an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5388 1 estimate.
2 It was a projection that was put in 3 the LRA, and you saw some of the CUFen values 4 that were greater than one in that projection.
5 So that was, like I said, an initial screening 6 attempt.
7 The things that passed that screening 8 attempt didn't require further consideration.
9 The things that didn't pass that screening 10 attempt were slated for the revision of the 11 calculation, the more refined calculations that 12 Mr. Gray has since worked with Westinghouse to 13 accomplish.
14 JUDGE KENNEDY: All right. Thank you.
15 Yesterday we had some discussion about, maybe it 16 wasn't yesterday. It may have been Monday, the 17 discussion of time limited aging analyses.
18 Are these CUF, CUFen values considered 19 time limited aging analyses for the purpose of 20 license renewal?
21 MR. COX: This is Alan Cox for 22 Entergy. They are treated as time limited aging 23 analyses for the purpose of license renewal.
24 They are discussed in the same section.
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5389 1 licensing basis analysis. I believe, as Mr. Gray 2 indicated, the CUF, the environmental factor was 3 not a requirement of the initial design.
4 So that was not a, there was not a 5 CUFen calculation that was part of the current 6 licensing basis. So these environmental crushing 7 factors are applied as part of the aging 8 management program going forward for license 9 renewal.
10 JUDGE KENNEDY: Let me make sure I got 11 that clear. So the environmental adjustment is 12 performed on the current licensing basis, 13 cumulative usage factor calculations. Is that 14 what you just said?
15 MR. COX: That's correct. And in some 16 cases, that current licensing basis usage factor 17 calculation was revised along with applying the 18 Fen.
19 MR. STROSNIDER: This is Jack 20 Strosnider. Let me see if I, I'd like to see if 21 I can clarify one thing here that with regard to 22 the TLAA, the original fatigue calculation 23 originally calculated CUF without an 24 environmental factor is the TLAA because it was 25 in the licensing basis, the current licensing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5390 1 basis.
2 The environmental factor was not in 3 the current licensing basis, but the NRC 4 established guidance that it should be considered 5 as part of getting a renewed license.
6 So it will become part of the current 7 licensing basis when the license would be issued.
8 All right, so I don't know if that distinction 9 helps you.
10 But TLAA is actually the original 11 calculation because that's what was in the 12 licensing basis. And now there's some additional 13 work being done in support of license renewal to 14 adjust it for the environmental factor.
15 JUDGE KENNEDY: Just, Mr. Strosnider, 16 just to make sure I've got this clear. I think 17 Mr. Cox eluded to some revised CUF calculations 18 that were performed.
19 Those would be TLAAs that are part of 20 the current licensing basis once that revision 21 was done?
22 MR. STROSNIDER: Yes, recalculations 23 without the environmental factor would be one way 24 to manage the TLAA.
25 JUDGE KENNEDY: All right. Thank you.
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5391 1 That's what I thought I heard from Mr. Cox. I 2 appreciate it though. I don't know if anyone, 3 I'll go walk down the row here if the staff has 4 anything to offer in this sort of preliminary 5 discussion of CUFs and CUFens.
6 DR. HISER: This is Allen Hiser of the 7 staff. Now we agreed that CUF from the original 8 license, there's your CLB analyses, the RTLAAs, 9 revisions to those.
10 Clearly, it would just be updates to 11 the TLAA. The CUFen values are not TLAAs because 12 they are not in the CLB.
13 MR. STROSNIDER: Your Honor, this is 14 Jack Strosnider. If I could, you're asking, I'd 15 like to go back just for a second to the 16 discussion on margins because I think there's 17 something I should have pointed out that could 18 become important later.
19 That is that the fatigue analyses that 20 were being defined are captured in the 21 regulations in 10 CFR 5055(a). And the NRC has 22 said that you need to meet the fatigue analysis 23 and that the margins associated with ASME code 24 Section 3 analyses provide, essentially that's a 25 conclusion of adequate protection.
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5392 1 So what that translates to from a 2 practical point of view is that you need to meet 3 the cumulative usage factor of one and that 4 provides sufficient margin in accordance with the 5 regulations.
6 All right. So that could be different 7 than a margin less than one or something of that 8 nature. What the regulations require is 9 maintaining that cum and usage factor of 1 and 10 that that provides adequate margin.
11 So that could become part of the 12 discussion later.
13 JUDGE KENNEDY: All right. Thank you.
14 And just to be fair, do the New York State 15 witnesses have anything to offer in this 16 preliminary discussion?
17 DR. HOPENFELD: Joram Hopenfeld. I 18 can just make a comment, just an overall comment.
19 I don't want to get into details. It's important 20 to understand that the damage, the CUF really 21 represents damage to the material, fatigue 22 damage.
23 And that basically is a random 24 phenomenon, but what we are doing here, we are 25 using a deterministic method to calculate it.
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5393 1 And that's where the issue of conservatism would 2 come in.
3 JUDGE KENNEDY: All right. Thanks, 4 and we'll get into more of that as we move on.
5 I'll walk down the table of judges here. Is 6 there anything to ask in terms of the CUFs?
7 So we'll relieve you of this 8 preliminary discussion and move into some 9 specific questions. I have the questions 10 organized or grouped by topical area.
11 The first area I'd like to look at is, 12 as I mentioned in my opening remarks, the state, 13 I believe, has raised an overarching concern 14 issue with the adequacy of the Metal Fatigue 15 Aging Management Program.
16 I guess, for the record, I'd like to 17 ask Entergy to tell the Board what aging 18 management program is used for metal fatigue or 19 to manage?
20 MR. COX: It's the Fatigue Monitoring 21 Program.
22 JUDGE KENNEDY: Back to Entergy. In 23 your statement of position, you indicate that the 24 metal fatigue amp is consistent with GALL Rev 1 25 and the guidance in NUREG/CR-6250 and NUREG/CR-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5394 1 5999.
2 What's specific GALL AMP is consistent 3 with the fatigue monitoring program?
4 MR. COX: Your Honor, this is Alan Cox 5 for Entergy. That would be the GALL AMP that's 6 in Chapter 10. It's amp with a designation of 7 M1.
8 JUDGE KENNEDY: M1. What is the 9 relevance and --
10 (Simultaneous speaking.)
11 JUDGE WARDWELL: Excuse me. What's 12 the name on that one? Is there a name to that 13 amp?
14 MR. COX: I can get back to you on it.
15 I think it may be Fatigue Monitoring Program.
16 I'll have to check and get the exact --
17 JUDGE WARDWELL: Well, I can probably 18 look it up also myself. I just thought you might 19 know off the top of your head. Sorry.
20 MR. NG: This is Ching Ng from the 21 staff. The name of, the title of the amp is not, 22 M1 is metal fatigue of the pressure boundary.
23 JUDGE WARDWELL: Thank you.
24 JUDGE KENNEDY: Mr. Cox or whoever's 25 appropriate, the significance of the NUREG NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5395 1 citations, NUREG/CR-6250 and NUREG/CR-5999. Is 2 that 6260? I wrote 6250. Do I have it 3 incorrect?
4 MR. COX: I believe that 6260 is the 5 NUREG. And I believe, Mr. Gray can correct me if 6 I'm wrong, this is Alan Cox again. I believe 7 that NUREG 6260 is the NUREG that defines a set 8 of representative components that should be 9 assessed for environmental effects.
10 JUDGE KENNEDY: Any thoughts on CR-11 5999?
12 MR. GRAY: This is Mark Gray for 13 Entergy. CR-5999 was the initial NUREG to the 14 industry that identified a potential issue with 15 the effects of the reactor water environment.
16 And so NUREG/CR-6260 actually did 17 their evaluation to the curves of the CR-5999.
18 JUDGE KENNEDY: Dr. Lahey, and I guess 19 in fairness Dr. Hopenfeld, other than the issues 20 that New York State has raised with the CUFen 21 calculations and the synergistic effects, do you 22 have any specific concerns in your testimony that 23 you've identified with the Aging Management 24 Program for metal fatigue?
25 DR. LAHEY: Yes, Your Honor. And NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5396 1 later on I hope we can get into it. It has to do 2 with the predictions by WESTEMS and the 3 uncertainty or what they would call the 4 conservatisms that are in there, how to quantify 5 that.
6 JUDGE KENNEDY: Would that be the 7 CUFen, the CUF calculations then? Yes. Okay.
8 DR. LAHEY: In the CUFen calculation.
9 JUDGE KENNEDY: And we will get to 10 that. Dr. Hopenfeld?
11 DR. HOPENFELD: It's the same.
12 JUDGE KENNEDY: Okay. So we'll get to 13 that. I just wanted to make sure there was 14 nothing specific about the Aging Management 15 Program that you had issues with outside of those 16 calculations.
17 The CUF calculations, are they 18 relevant to anything other than metal fatigue or 19 the CUFen calculations? Is that strictly a, I 20 guess I'll start with Entergy. Is that strictly 21 a metal fatigue issue?
22 MR. AZEVEDO: Nelson Azevedo for 23 Entergy. Yes, that's correct, Your Honor.
24 JUDGE KENNEDY: And so how does the 25 fatigue monitoring program manage the metal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5397 1 fatigue aging effect?
2 MR. AZEVEDO: We have a site-specific 3 procedure for each unit, and we have a table.
4 And that table has the allowable number of cycles 5 that were analyzed by Westinghouse to ensure that 6 the CUF stays below 1.
7 So that is our allowable number of 8 cycles for each transient. And then 9 periodically, we go back. We actually review the 10 operating blocks from the plant and count all the 11 cycles.
12 JUDGE KENNEDY: So this is a 13 monitoring and data analysis to deal with the 14 numerator of the CUF calculation. Is that where 15 this goes?
16 MR. AZEVEDO: That's correct.
17 JUDGE WARDWELL: And by each unit, you 18 mean each plant and not some groupings of system, 19 structure or components. Is that correct?
20 MR. AZEVEDO: Yes. We have one for 21 Unit 2 and one for Unit 3 because they have 22 different cycles.
23 JUDGE KENNEDY: And are those cycles 24 monitored then for each? Are there different 25 cycles that are monitored for each particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5398 1 component that's identified as subject to metal 2 fatigue?
3 MR. AZEVEDO: Whatever the number of 4 types of cycles that were analyzed for each 5 component, we monitored those, all those.
6 JUDGE KENNEDY: Okay. Thank you. I'm 7 at the limit of my questions on the adequacy of 8 the amp. Again, I think the real issues, as we 9 pointed out earlier, lie in the CUFen 10 calculations and the CUF calculations and the 11 relative margins.
12 With that, I'm going to move away from 13 the amp discussion unless anyone on the Board 14 has, I'd like to start a little bit of discussion 15 on synergistic effects.
16 I recognize that we spent quite a bit 17 of time yesterday on synergism, but I thought it 18 would be appropriate to at least touch this issue 19 again with Dr. Hopenfeld sitting here today as a 20 witness for 26.
21 I guess I would ask if there's 22 anything that you could point to. Again, this is 23 either Dr. Lahey or Dr. Hopenfeld, if there's 24 anything in your testimony that would enlighten 25 us beyond, that we didn't touch on yesterday in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5399 1 25.
2 Any specific point in your testimony 3 that you'd like us to be aware of that wasn't 4 covered yesterday?
5 DR. HOPENFELD: Yes.
6 JUDGE KENNEDY: And what would that 7 be, Dr. Hopenfeld?
8 DR. HOPENFELD: That would be related 9 to the proposition that neutron irradiation is 10 not going to affect metal fatigue RVI components 11 because they do not contain flaws.
12 According to my analysis, that is not 13 true. A number of them does contain flaws. So 14 a crack will propagate from those flaws.
15 JUDGE KENNEDY: Can you point us to an 16 exhibit or a place in your testimony for support 17 for that assertion?
18 DR. HOPENFELD: Yes.
19 JUDGE KENNEDY: And if you need some 20 time, we can move on, and we could come back to 21 it. I'll give you a brief amount of time --
22 DR. HOPENFELD: Very brief. If you 23 look at my June 15th report on page 18.
24 CHAIRMAN MCDADE: Okay. Dr.
25 Hopenfeld, if you could, you tend a little bit to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5400 1 bob and weave when you're testifying --
2 DR. HOPENFELD: I'm sorry.
3 CHAIRMAN MCDADE: -- so you're coming 4 closer and further away from the microphone.
5 DR. HOPENFELD: As you can see, I'm 6 not a public speaker.
7 CHAIRMAN MCDADE: So maybe pull the 8 microphone a little to you so that you won't get 9 so far away from it.
10 DR. HOPENFELD: Yes. Page 18 on my 11 June 15th report.
12 MS. BRANCATO: That's Riverkeeper 13 Exhibit 144.
14 JUDGE KENNEDY: 144, and I guess that 15 reminds me. I've been referring to these as New 16 York State witnesses. I appreciate the fact that 17 Dr. Hopenfeld is here representing Riverkeeper.
18 My mistake. Thank you.
19 Page 18 of Riverkeeper 144. Is that 20 what you said, Dr. Hopenfeld?
21 DR. HOPENFELD: Yes. Do you see I 22 referring to numbers like CUFen of a factor of 3, 23 larger than the numbers that they have presented.
24 When you have factor of 3 on top of a number of, 25 this is not proprietary information.
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5401 1 JUDGE KENNEDY: I guess, Dr.
2 Hopenfeld, what support do you have for this 3 factor of 3? I wasn't able in your report to --
4 DR. HOPENFELD: Thank you. Thank you 5 very much. Can we go to Entergy 00683?
6 JUDGE KENNEDY: Are you asking us to 7 call up that --
8 DR. HOPENFELD: Riverkeeper, it's 9 NUREG 6909.
10 MS. BRANCATO: And that's actually --
11 DR. HOPENFELD: 857. Okay, NUREG 12 6909.
13 JUDGE KENNEDY: Dr. Hopenfeld?
14 CHAIRMAN MCDADE: Can you repeat the 15 exhibit number, Doctor? What was the exhibit 16 number for that, for NUREG 6909?
17 DR. HOPENFELD: It's New York 357.
18 CHAIRMAN MCDADE: 3-5-7?
19 DR. HOPENFELD: Yes.
20 CHAIRMAN MCDADE: Okay. You said New 21 York. I believe, is that Entergy 357?
22 MS. BRANCATO: No. He misspoke when 23 he referred to an Entergy exhibit. He's 24 referring to NUREG 6909, which is New York State 25 357.
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5402 1 CHAIRMAN MCDADE: Okay. Thank you.
2 DR. HOPENFELD: Can we go, can I 3 continue?
4 JUDGE KENNEDY: And this reference 5 that you've had us put up, this is to support 6 your assertion that there could be a factor of 3?
7 DR. HOPENFELD: That's correct, and 8 when you have a factor of 3, we use that on top 9 of their numbers. And again, I don't want to say 10 the number. And you put the number on their 11 numbers.
12 Then you come with the CUF or Fen 13 larger than 1, which indicates that there is an 14 engineering crack. There is a flaw.
15 Furthermore, even if the CUFen piece below 1, you 16 can also have a flaw.
17 JUDGE KENNEDY: I'm sort of a slow 18 reader here, but is there some specific section, 19 page that you're --
20 DR. HOPENFELD: Yes, page, I'm going 21 to go on. It's page 26 on that NUREG. And page 22 37, 28 and page 47.
23 JUDGE KENNEDY: You're going overload 24 us --
25 DR. HOPENFELD: Okay.
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5403 1 JUDGE KENNEDY: -- here, Dr.
2 Hopenfeld. Do you want to start with one 3 particular page?
4 DR. HOPENFELD: Let's start with page 5 26. Would you like me to make comment?
6 JUDGE KENNEDY: Point us to what 7 you're --
8 DR. HOPENFELD: Oh, yes. Would you 9 like me to comment on it?
10 JUDGE KENNEDY: In a perfect world I'm 11 hoping that you can point us to the support for 12 your assertion of the factor of 3.
13 DR. HOPENFELD: Yes, page 26.
14 JUDGE KENNEDY: Okay. Do we need to 15 come down a little bit? This appears to be 26.
16 DR. HOPENFELD: My page 26 is 17 different than this. Oh, here we go. Here we 18 go. It's just on top of 4.2.4, just a trigger, 19 just on top.
20 JUDGE KENNEDY: Are you, you want us 21 to be looking at Figure 15?
22 DR. HOPENFELD: Yes, the other figure.
23 This is for carbon scale. The other figure is of 24 --
25 (Simultaneous speaking.)
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5404 1 MR. HARRIS: I can't hear you, Doctor.
2 DR. HOPENFELD: This is for carbon 3 scale. The other figure is for stainless steel 4 or similar.
5 CHAIRMAN MCDADE: So I see a factor of 6 3 on there.
7 DR. HOPENFELD: Yes.
8 CHAIRMAN MCDADE: Is that the point 9 you're trying to make here?
10 DR. HOPENFELD: Yes.
11 CHAIRMAN MCDADE: And you're looking 12 at Figure 15, the left hand side, the middle of 13 it?
14 DR. HOPENFELD: That's correct.
15 JUDGE WARDWELL: And a factor of 3 16 basically covers the bounding limits, the upper 17 limits of all the scatter of the data rather than 18 the mean. Is that a fair assessment?
19 DR. HOPENFELD: That's correct. It 20 covers the scatter, the data. They took a series 21 of experiments, and obviously you have scatter.
22 So then they tried to correlate the light, which 23 is defined by a crack which is 3 millimeters 24 deep.
25 They tried to correlate it with an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5405 1 equation so they can deterministically calculate 2 it. And if you see here, to be conservative, 3 really you have to, you must calculate the 4 numbers by a factor of 3.
5 So when they say that the CUFen is, 6 and this is an inherent number in the 7 calculation. There is not new modeling or 8 anything up to this point.
9 The modeling would be the next step.
10 The assumptions and uncertainties in the models 11 have nothing to do with this. This is inherent 12 in the equation that they are using to calculate 13 the CUFen.
14 JUDGE KENNEDY: I guess, Dr.
15 Hopenfeld, I'm not sure I'm tracking how this 16 translates from this data to the need to apply a 17 factor of 3 on the cumulative usage factor.
18 DR. HOPENFELD: Okay. I think the 19 question is why do I apply a factor of 3.
20 JUDGE KENNEDY: Yes.
21 DR. HOPENFELD: If you take the Fen 22 factor, which is a correction factor for the 23 environment, and multiply it by the CLB CUF --
24 CHAIRMAN MCDADE: Okay. Excuse me, 25 Dr. Hopenfeld. Let me interrupt for a second.
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5406 1 There's a popular book out now referred to as 2 Lean In. Could you do that in a different 3 context?
4 You need to lean in to get closer to 5 the microphone. It's important for us to 6 understand what you're saying.
7 DR. HOPENFELD: Absolutely.
8 CHAIRMAN MCDADE: But in order to 9 understand it, we've got to hear it.
10 DR. HOPENFELD: Okay. The Fen, which 11 is a ratio of light and air to life in water, so 12 when you calculate the Fen, the Fen is based on 13 the ability to predict life in water. And that 14 represents, is represented by this data.
15 JUDGE KENNEDY: I guess, here's where 16 I'm struggling.
17 DR. HOPENFELD: Okay.
18 JUDGE KENNEDY: Entergy, admittedly, 19 was our overview discussion about CUFs and 20 CUFens, but what I heard him say is when they 21 apply the environmental adjustment factor, they 22 use a set of parameters or a methodology that has 23 been provided by the NRC and approved.
24 Is this suggesting that the NRC 25 methodology is incorrect? I don't know how to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5407 1 reconcile this with what Entergy has just 2 testified to how they adjust the CUF for 3 environmental factors.
4 I mean they clearly, well, I don't 5 think they apply a factor of three, yet they have 6 adjusted the CUF values for the plant for 7 environmental conditions.
8 We've got a lot of experts here. I 9 see it. I see a factor of 3 that covers the 10 spread in the data, but yet I recognize that the 11 Agency has provided a set of adjustment equations 12 that Entergy has said they faithfully have 13 applied.
14 We have four NRC staff witnesses. Any 15 thoughts on --
16 MR. STEVENS: Your Honor, Gary Stevens 17 of the staff. We're looking at this figure a 18 little bit out of context, so let me try and put 19 it in context for you.
20 This is an interim figure that 21 evaluating data scatter and material durability, 22 and it's not in any way indicating that the Fen 23 is off by a factor of 3.
24 And if you refer to page 25 at the 25 bottom, the text, and the discussion about Figure NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5408 1 15, it in fact tells you that, the argument is 2 being made is that this modified rate approach 3 works very well and that most of the scatter is 4 due to heat variation, which we call material 5 variability.
6 The important discussion, therefore, 7 is really in Chapter 7 of this document, which 8 begins on page 71, Chapter 7, which discusses all 9 the margins that need to be accounted for in 10 doing these kinds of evaluation.
11 And specifically, material variability 12 and data scatter is discussed in Section 7 that 13 begins on page 90, or sorry, 73. And what you 14 see from all of this discussion in this chapter 15 is there are factors that are applied to the 16 design fatigue curves to account for these kinds 17 of variations that are picked up by the Fen.
18 One of those factors is data scatter 19 and material variability, and that's really where 20 this factor of 3 comes in.
21 DR. HISER: And I think, Your Honor, 22 if you go to the figure or Table 12 --
23 MR. STEVENS: What page is it?
24 DR. HISER: It's on page 76 of New 25 York State 357.
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5409 1 MR. STEVENS: So what you see in this 2 table, and thank you Dr. Hiser for point that 3 out, the very top line is material variability 4 and data scatter.
5 And what you see is in the original 6 Section 3, ASME Fatigue Curves, they considered 7 a factor of 2 originally. And in this study, 8 we've increased that.
9 These are log normal distributions 10 that were considered, but the range is 2.1 to 11 2.8. And that's effectively that factor of 3 you 12 saw in that other figure.
13 Those are built into the design 14 fatigue curve for calculating the CUF itself.
15 So, in fact, the factor 3 is accounted for in the 16 CUF calculation.
17 JUDGE KENNEDY: So Mr. Stevens, it 18 would be your expectation in the calculations 19 that Entergy performed, they would have already 20 considered this factor of 3 in the scatter of the 21 data?
22 MR. STEVENS: Correct.
23 JUDGE WARDWELL: But this Table 12 24 says present report is 2.1 to 2.8. How do we get 25 from that number to showing where the actual NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5410 1 number that was used for the fatigue curves that 2 demonstrate where in that range it was using?
3 Or does it have that range plotted 4 that you use to then estimate somewhere in 5 between it? How does that work?
6 MR. STEVENS: This is Gary Stevens 7 with the staff. The factors that are shown in 8 Table 12 are log normal distributions of how 9 these factors play into, and there's a Monte 10 Carlo statistical analysis that's done to develop 11 a fatigue curve that it bounds 95 percent of the 12 data with 95 percent confidence.
13 The results of that Monte Carlo 14 statistical evaluation results in reduction 15 factors applied to the curve, which if you scroll 16 down to Table 13 on page 77, you'll see the end 17 result is that there's a reduction in life of 18 approximately 12 to 13 applied to the curves for 19 the different materials.
20 So what you may have read in the, I'm 21 sure you did read in the testimony, are factors 22 of 2 and 20 or 2 and 12. This is where they came 23 from. The life, the fatigue, the design curve is 24 reduced by a factor of 2 on stress or 12 on life, 25 whichever is more conservative.
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5411 1 And this is where they come from. So 2 based on the statistical evaluation of those log 3 normal distributions in Table 12, to get a 95 4 percent lower bound and 95 percent confidence 5 curve, you would come up with these factors on 6 life.
7 JUDGE WARDWELL: And again, just to 8 make sure I'm clear, this is all in relationship 9 to the Fen calculation.
10 MR. STEVENS: No. This is in relation 11 to actually the design fatigue curve that would 12 be used for the CUF calculation.
13 JUDGE WARDWELL: So I guess I'd go to 14 Dr. Hopenfeld then. I think you said that this, 15 that first graph that had the factor of 3 arrow 16 applied to the water condition.
17 And doesn't that seem to conflict with 18 where we've sugared this all down to in Table 13, 19 where if it's only involved with the CU 20 calculation, the CUF calculation?
21 DR. HOPENFELD: Yes. Can I answer 22 now? We confusing two things here, I believe.
23 JUDGE WARDWELL: If you can't hear 24 yourself over the speaker, we can't hear you for 25 sure.
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5412 1 DR. HOPENFELD: I think we're 2 confusing two things. Table 3 relates to the 3 ASME code, to the uncertainty in the ASME.
4 JUDGE WARDWELL: You say Table 3 or 5 13?
6 DR. HOPENFELD: Table 13. Excuse me.
7 Table 13 relates to the ASME code, to the margins 8 that we talked. That's what he is talking about 9 here.
10 What I was talking about, the factor 11 of 3, has nothing to do, the ASME code never 12 heard of Fen. They never heard of that. This 13 was done 30 or 40 years --
14 JUDGE WARDWELL: But can you show that 15 that previous figure you referenced, and what was 16 the figure again? Let's go back to that quickly.
17 DR. HOPENFELD: That was --
18 MR. SIPOS: I believe it was Figure 19 15, Your Honor.
20 DR. HOPENFELD: 15.
21 JUDGE WARDWELL: Sorry.
22 MR. SIPOS: Figure 15.
23 JUDGE WARDWELL: Okay. There we go.
24 There it is. It's in front of you now.
25 DR. HOPENFELD: Okay. This you can --
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5413 1 JUDGE WARDWELL: Where does that show 2 that that deals with the water effects, the Fen 3 part of this equation?
4 DR. HOPENFELD: Because this data was 5 obtained in water. There is also --
6 JUDGE WARDWELL: Where is that stated?
7 DR. HOPENFELD: Yes. If you take a 8 look at the equation that you have, you see, I 9 don't know which page it is. The equation that 10 comes from this figure, the mean equation, the 11 average equation for Fen --
12 JUDGE WARDWELL: Well, maybe I can 13 simplify it. Mr. Stevens for staff, do you agree 14 that this Figure 15 relates to in water types of 15 analyses?
16 MR. STEVENS: Yes.
17 JUDGE WARDWELL: Okay. Thank you.
18 Dr. Hopenfeld, is that, do you have anything 19 further to add? I mean it seems --
20 DR. HOPENFELD: Well, I just want to 21 make sure that we understand that the 22 uncertainties in the code have nothing to do with 23 this factor of 3. It's just two different 24 animals.
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5414 1 a large number of tests, and they had to put it 2 in a matter that one could calculate the 3 conversion factor.
4 So they correlate it. You see, and 5 they correlate it. You see that correlation is 6 good within a factor of 3. And it's the same 7 thing for, this is for carbon steel, but they are 8 the same thing for stainless steel that use the 9 other pages I gave you.
10 And there's more data than these, so 11 there's a lot of data that all show that they 12 fall within a factor of 3, the ability of Argonne 13 to correlate their data so the user can put it 14 somewhere in a deterministic way.
15 That's what I prefaced my presentation 16 before. So you can calculate it analytically.
17 But if you looked at this, it is because you are 18 using a deterministic method to calculate the 19 CUFen.
20 You have to use, you have to be 21 conservative. You can look at a minus 3. You 22 cannot look at the lower. You have to take the 23 ends of your distribution.
24 You have to be conservative. That's 25 why you have to multiply this by a factor of 3.
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5415 1 JUDGE KENNEDY: Said another way, Dr.
2 Hopenfeld, are you challenging the final 3 conclusions of this overall report, which seem to 4 lead to a way to deal with the scatter in the 5 data?
6 I mean it seems like these data 7 scatter issues are addressed as Mr. Stevens has 8 pointed out. And going back to the original 9 figure doesn't seem to convince me that it's not 10 included.
11 So I think we're at an impasse here.
12 I appreciate you bringing to our attention, and 13 I appreciate members of the staff taking us 14 through the report.
15 This seems to me to be an indication 16 that what you have identified is included in the 17 ultimate calculation. I'm not suggesting you 18 agree with that, but I haven't seen anything here 19 that would lead me to believe it's not being 20 accounted for.
21 And we're going to come back. I'm 22 sure this is going to come up again. I know 23 you've got issues all through here on the 24 conservatisms and the margins embedded in the 25 calculations.
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5416 1 But at least for now, I'd like to move 2 off of this figure and off of this topic.
3 MR. SIPOS: Excuse me, Judge Kennedy, 4 John Sipos over here for the State of New York.
5 I understand Your Honor's desire to move forward.
6 I'd just note for the record the Dr. Hopenfeld, 7 I believe, also referred to page, to charts on 8 page 37 and possibly 47.
9 And page 37 is PDF frame 57 of this 10 document should we wish to ever return to it.
11 JUDGE KENNEDY: Is there something, 12 let's at least put one of those pages up and see 13 if it enlightens us differently, 37.
14 MR. SIPOS: So page 37 is PDF frame 15 57.
16 JUDGE KENNEDY: Is this not just the 17 same data for different conditions and has a 18 displayed scatter? It may lack the factor of 3, 19 but it seems more of the same to me.
20 CHAIRMAN MCDADE: That's a question to 21 you, Dr. Hopenfeld.
22 JUDGE KENNEDY: Oh, I'm sorry. Does 23 this lead us to a different conclusion that we 24 would have with Figure 15?
25 DR. HOPENFELD: Can I answer that?
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5417 1 JUDGE KENNEDY: Oh, I'm sorry, Doctor.
2 Yes, I guess I'm not being clear.
3 DR. HOPENFELD: No. It's the same, 4 just gives you more data. But the point is, it's 5 more useful. And I should have probably started 6 with this page because you can see when you 7 derive the Fen, you see that Equation 21.
8 That equation that you see here is the 9 best fit line, you see. So that is the best fit.
10 It doesn't have a factor of 3 in here. It's for 11 you to, when you calculate the CUFen, you should 12 use the factor of 3.
13 JUDGE KENNEDY: I guess instead of me 14 testifying, Mr. Stevens, would you care to 15 address this yet again? It seems to me to be the 16 same issue.
17 MR. STEVENS: You're correct. It's 18 the same issue, just with more data. The 19 previous graph on page 26 I think it was, was 20 limited because it was doing an estimate using a 21 modified rate approach.
22 So it was just done on a subset of the 23 data, and here you're seeing all the data. So 24 it's essentially the same thing.
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5418 1 in Equation 21 is not the best fit curve 2 regarding the fatigue. Equation 21 has to do 3 with the Fen factor, so I just wanted to correct 4 that.
5 JUDGE KENNEDY: All right. Thank you.
6 Just I guess as a curiosity, and we keep using 7 the words margin and conservatism. Maybe I keep 8 using them.
9 These factors to try to deal with data 10 scatter, would you view those as, and I guess 11 I'll direct it to Mr. Stevens first. Is that a 12 margin, a conservatism, or are we talking about 13 the same thing?
14 MR. STEVENS: It's a difficult 15 question. Let me see if I can clarify. And I'm 16 going to, if you'll allow me to back up just a 17 little bit on the discussion on margins and 18 conservatisms, I'm going to give you my spin on 19 this.
20 So what I would call this is a part of 21 a design factor that's built into the design 22 curve. A design factor is, in fact, contributes 23 to a margin.
24 The way I look at margins is it's a 25 difference between where you are and where you're NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5419 1 allowed to go. And I break it into two pieces.
2 Some might think of margin as the difference 3 between where you are and what might constitute 4 a failure or a crack to initiate.
5 And another one is a margin between 6 where you are and where you're allowed to go. In 7 this case, we have an allowed CUFen of 1.0.
8 There are two different margins. And one we can 9 play with, and one we can't.
10 In the first case, the code itself 11 applies to the design factors to come in and the 12 methodology and the limit of 1.0 for CUF values.
13 And we're not allowed to play with the margins 14 that go into that value.
15 So these design factors we're talking 16 about that go into the design curve, they 17 contribute to that margin. And that's something 18 that we must meet. We can't change that.
19 And there's not even an argument to be 20 made where we can change those values and justify 21 them. It's a requirement of the code to maintain 22 those. That's one margin.
23 Another margin is if I calculate a 24 CUF, say of 0.5, I have margin between that and 25 the allowed value of 1. And that's something NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5420 1 that I can deal with and address.
2 That allows me to, for example, apply 3 more loading to the component and still maintain 4 its original design because I'm allowed, the 5 criteria that I'm allowed to go to is a CUF 6 allowed of 1.0.
7 So I look at margin as those two 8 parts. One is I can't touch, and the other I 9 can. And these design factors that we showed 10 here that went into the building of the design 11 curve that's in the ASME code, we're not allowed 12 to touch those.
13 Then we can talk about conservatisms 14 because as an analyst, if I'm doing a 15 calculation, the objective I have is to show 16 acceptability, not margin.
17 So once I achieve a CUF of less than 18 or equal to 1, my job is complete. I can stop 19 work. Any additional margins to drive that 20 calculated value lower, I'm not required to do.
21 JUDGE KENNEDY: But in the analysis to 22 try to get to that acceptable value, did I 23 understand you to say that there's a piece of 24 margin there that you can't touch, and that's the 25 stuff that's embedded in the code?
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5421 1 MR. STEVENS: The stuff that's 2 embedded into the code with respect to the limit 3 on the usage factor of 1.0 and the design fatigue 4 curves and the margins they contain and the 5 stress allowables and the design factors that 6 might be applied to those, I'm not allowed to 7 touch those.
8 Now another we can talk about is 9 conservatism, and what I kind of view 10 conservatism as are simplifications I might do as 11 an analyst to get the job done quicker.
12 For example, if I have to evaluate 100 13 different loads, I may choose to pick the worst 14 one and just assume all the other 99 are of that 15 severity to make my job to complete it quicker.
16 And that's a conservatism that I as an 17 analyst choose to put into the analysis, and I'm 18 allowed to do so much as, so long as I continue 19 to meet those required margins.
20 In this case, my CUF I calculate must 21 be equal to or less than 1.0. If I don't achieve 22 that, then obviously that simplification was a 23 little too gross, and I might have to refine that 24 simplification to still meet those margins that 25 I cannot change.
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5422 1 So I look at, we have margins. Again, 2 I'll repeat. We have a margin that I'm not 3 allowed to touch. And these design factors we're 4 talking about that are built into fatigue curves 5 fall into that category.
6 Stress limits in the code and other 7 design factors fall into that category. There's 8 a margin I might obtain in my analysis with 9 respect to what I calculate versus what I'm 10 allowed.
11 And there's conservatisms that I might 12 apply, which I look at as simplifications that I 13 might use in my calculation process to get me to 14 the end. And those are what I would call 15 conservatisms.
16 Another form of conservatism, if there 17 is some embedded in the methodology, specified by 18 ASME code and by how they calculate, how they 19 combine stresses and what limits they use.
20 And again, those are, I put that into 21 the margin category as opposed to a conservatism.
22 It is a conservative thing to do, but it's a 23 margin that I'm not allowed to touch. I hope 24 that clarifies.
25 JUDGE KENNEDY: Thank you, Mr.
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5423 1 Stevens.
2 CHAIRMAN MCDADE: If you could, 3 regrettably, I need to ask you to clarify it a 4 little bit more. We're talking about certain 5 things that you can play with.
6 And to me, that's sort of engineering 7 speak for what you can legitimately adjust. Can 8 you give me a sort of summary of those kinds of 9 factors that you can legitimately adjust and 10 those that you can't, just sort of a quick 11 summary of that? Give some examples.
12 MR. STEVENS: Some examples, I gave 13 one, which would be in the number of different 14 loads I might evaluate. I can adjust. I still 15 must look at all the different loads, but how 16 exactly I consider those loads is within the 17 purview of what I can alter.
18 Things I can't change, I can't change 19 the stress limit I'm designing to. I cannot 20 change the usage factor limit that I have to 21 design to. I cannot change the fatigue curve I 22 use to calculate that usage factor in any way.
23 Other things I might change, heat 24 transfer coefficient, things of that nature that 25 go into the analysis. I can use different NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5424 1 assumptions, apply different conservatisms in 2 that.
3 So there's many aspects of the code 4 methodology that are not explicitly defined that 5 are left up to analyst judgment. And those 6 things that are explicitly defined in words in 7 the code are the things that I can't change.
8 CHAIRMAN MCDADE: Okay. Thank you, 9 Mr. Stevens.
10 JUDGE KENNEDY: Not to keep this 11 whole, Mr. Gray, earlier in the opening remarks 12 you talked about different types of conservatisms 13 and what was allowed to be changed by the analyst 14 and where there was flexibility.
15 Could you maybe put the Entergy 16 approach in the same context that Mr. Stevens 17 just did, if it's possible?
18 MR. GRAY: Yes. This is Mark Gray for 19 Entergy. I think what Mr. Stevens just said is 20 just a different semantical way of saying what I 21 said earlier.
22 The margins that are in the code 23 methodology and design curve, we did not touch.
24 We used the code design curve. We also used the 25 Fen expressions that were defined by the NUREGs.
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5425 1 The conservatisms that were, for 2 example, in that original, the original Section 3 3 design analyses were conservatism that we did 4 touch. And so we performed a more detailed 5 analysis of a component.
6 Find an element analysis versus an 7 interaction analysis, for example, and used more 8 specific loadings, using less enveloping or 9 grouping, as Mr. Stevens referred to, to remove 10 any gross conservatisms in the methodology, 11 particularly with the loadings.
12 JUDGE KENNEDY: So later on when we, 13 and I think we're going to get to a discussion 14 with Dr. Lahey and Dr. Hopenfeld about margins 15 and margin reductions.
16 I'm going to use that framework 17 hopefully when we pose questions coming up. So 18 Dr. Lahey, you have your hand up. I'll --
19 DR. LAHEY: Thank you. Can you hear 20 me all right?
21 JUDGE KENNEDY: I can. Just recognize 22 we're going to give you an opportunity to get 23 into safety margins and conservatism.
24 DR. LAHEY: Yes. And I'm only going 25 to talk about Fen right now because that's what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5426 1 you've been talking about, how to handle any 2 uncertainty by that factor.
3 JUDGE KENNEDY: To be honest, this 4 started as a discussion on synergism, and Figure 5 15 was used as an example of a synergistic issue 6 that needed to be dealt with in the CUF 7 calculation.
8 That's what I thought I had asked, and 9 maybe I've taken us down a long road. But that's 10 what I, my intent was to deal with synergism and 11 to offer up an opportunity to put anything in the 12 current testimony in front of us on Contention 26 13 that we didn't address yesterday.
14 And I know Dr. Hopenfeld didn't 15 participate yesterday even though he was here.
16 He wasn't a witness on 25. So I wanted to give 17 him that opportunity to bring that up. And 18 that's what he offered.
19 DR. LAHEY: So you don't want to talk 20 about any other uncertainty in Fen that's not 21 reflected here?
22 JUDGE KENNEDY: I believe we're going 23 to get to that.
24 DR. LAHEY: Okay.
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5427 1 to give you an opportunity. We'll have an 2 opportunity to go through that. I guess what I 3 was trying to do is close out some issues on 4 synergism.
5 And I've got a couple more questions 6 here and then possibly we can take a break.
7 CHAIRMAN MCDADE: Before you do, Judge 8 Kennedy, just to Dr. Hopenfeld, you had referred 9 not only to page 37 but also to page 47. And on 10 page 47, there's a Figure 36.
11 And that figure is basically the same 12 sort of data that was on page 37, except here is 13 relates to austenitic stainless steel and air as 14 opposed to carbon steels and low alloy steels in 15 the LWR environment. Is that correct?
16 DR. HOPENFELD: Probably, yes.
17 CHAIRMAN MCDADE: Okay.
18 JUDGE KENNEDY: Thinking back again to 19 the synergistic effects, and again here we're 20 dealing with the effect of potential irradiation 21 on metal fatigue.
22 Dr. Lahey, you provided a number of 23 references to support your synergism argument in 24 your pre-file testimony.
25 If I put aside for the time being, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5428 1 expanded materials degradation assessment report 2 or reference, what, I had a difficult time going 3 through.
4 I went through all your references.
5 I had a difficult time finding any examples that 6 would support your synergistic argument.
7 So I'm going to give you the 8 opportunity to point me to something in your 9 references, your exhibits and pre-file testimony 10 that would support your synergistic argument on 11 the potential that I missed them when I reviewed 12 your documents.
13 DR. LAHEY: All right, and thank you, 14 Your Honor. There was a report, the technical 15 paper by Korth, et. al. And I can get you a copy 16 of that if you don't have it.
17 JUDGE KENNEDY: If you could just give 18 me the exhibit number, that would be, and in a 19 perfect world if you could point me, unless it's 20 a short document. I'm pretty sure I've looked 21 through these, but --
22 DR. LAHEY: Well, we talked about it.
23 I would think you have. But anyway, in there is 24 a discussion of experiments. Now this was done 25 for fast breeder reactor conditions --
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5429 1 JUDGE KENNEDY: Right.
2 DR. LAHEY: -- higher temperature.
3 But in there they stated that when they ran low 4 cycle, I mean low amplitude, high frequency 5 fatigue experiments, because of the hardening due 6 to radiation-induced embrittlement, things were 7 better in terms of the fatigue.
8 The failure cycles were increased.
9 When they ran large amplitude, low frequency 10 fatigue experiments, it was the opposite. In 11 fact, in decreased by a factor of 2.
12 So there was a significant decrease.
13 When we talked about the experiments that Mr.
14 Lott was a coauthor of, that particular paper, 15 they also made similar statement.
16 Although they, their particular 17 experiments for light water reactor conditions, 18 which are our concern, were only done for low 19 amplitude, higher frequency fatigue.
20 But nevertheless, they cited the same 21 issue. So there's no perfect data set that I 22 know of exactly for our conditions, which would 23 allow us to quantify the degradation due to 24 embrittlement for fatigue for light water reactor 25 conditions.
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5430 1 But there's indication that there is 2 an effect, and this is being worked on for sure 3 by the light water reactor sustainability folks 4 in Chicago. So this is the basis of that 5 assertion that I made.
6 MR. SIPOS: And Judge Kennedy, just 7 for record identification, you were asking for 8 exhibit numbers.
9 JUDGE KENNEDY: Please.
10 MR. SIPOS: Korth, K-O-R-T-H, 11 Riverkeeper Exhibit 152, Arai, New York Exhibit 12 564 and Kanasaki, NRC Exhibit 177.
13 JUDGE KENNEDY: All right. Thank you, 14 Mr. Sipos. This question, I don't remember if it 15 came up yesterday, but this discussion about --
16 CHAIRMAN MCDADE: Excuse me. Just one 17 second if I could, and the Kanasaki exhibit, 18 that's the one that you were a coauthor on.
19 Correct, Dr. Lott?
20 DR. LOTT: That's correct.
21 CHAIRMAN MCDADE: And that's the one 22 you were referring to?
23 DR. LAHEY: Yes, Your Honor.
24 DR. LOTT: It's actually Kanasaki, 25 Hiroshi Kanasaki.
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5431 1 CHAIRMAN MCDADE: Okay. Thank you.
2 JUDGE WARDWELL: And what's the 3 exhibit number again?
5 JUDGE WARDWELL: Thank you.
6 JUDGE KENNEDY: I direct this question 7 to Entergy. This fast breeder reactor data with 8 the large amplitude, low frequency, is that data 9 at all relevant for metal fatigue in light water 10 reactors?
11 Is the type of fatigue that's being 12 dealt with in Indian Point 2 or 3 subject to 13 large, I guess, large amplitude, low frequency 14 fatigue.
15 DR. LOTT: No, I do not believe that 16 data is directly related to any PWR reactor 17 internals application. And we actually have done 18 some looking at the strain ranges that are in the 19 irradiated internals.
20 It's a small, very small number of 21 irradiated internals in the cumulative usage 22 factor calculations. And those tend to be on the 23 low side of the strain range within the limits 24 that were in the Kanasaki paper.
25 JUDGE KENNEDY: Dr. Lahey, any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5432 1 rebuttal to the assertion that large amplitude, 2 low frequency isn't a concern for metal fatigue 3 in Indian Point 2 or 3?
4 DR. LAHEY: No, I disagree with his 5 conclusion. I think that remains to be seen. We 6 do need a database sufficient to quantify, but 7 there's no doubt in my mind there will be an 8 effect, a detrimental effect.
9 JUDGE KENNEDY: All right. Make sure 10 I understood what you just said. Are you 11 disagreeing that large amplitude, low frequency 12 cycles are not, now we've got too many nots here.
13 Dr. Lott seemed to testify that, 14 appeared to testify that large amplitude, low 15 frequency cycling is not of a concern at Indian 16 Point 2 or 3. Is that what you're disagreeing 17 with, or are you disagreeing with something else?
18 DR. LAHEY: Yes, Your Honor. I would 19 disagree with that. The high frequency fatigue 20 is associated with things like flow induced 21 vibration, which have small amplitude but a lot 22 of cycles.
23 And I can clearly understand how the 24 hardening associated with irradiation can improve 25 the fatigue life. But when you go to the type of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5433 1 cycles that we look at here, which are associated 2 with thermal transients, with operation of the 3 pressurizer, scram, so in many different cycles 4 that they go through in a plant.
5 I think it's clearly a lower 6 frequency, larger amplitude type of application.
7 JUDGE KENNEDY: Are you saying that 8 you would characterize those types of transients 9 to be large amplitude, low frequency?
10 DR. LAHEY: Some of them definitely 11 will be.
12 JUDGE KENNEDY: Entergy?
13 MR. GRIESBACH: Your Honor, this is 14 Tim Griesbach from Entergy. I've looked at that 15 Korth and Harper paper also. That was done under 16 the liquid metal fast breeder reactor program at 17 very high temperatures, between 900 and 1100 18 degrees Fahrenheit and at very high strain 19 levels.
20 That would be considered more of a 21 creep fatigue rupture. And that describes 22 mechanisms that clearly we don't see in the PWR 23 operating environment under the stress levels and 24 strain levels that we would expect.
25 JUDGE KENNEDY: Thank you. Maybe does NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5434 1 the staff have any view towards this large 2 amplitude, low frequency? Should we be concerned 3 about it for light water reactors?
4 MR. STEVENS: This is Gary Stevens of 5 the staff. Those types of cycles are, which I 6 think we're really going to, the discussion in 7 the last few days has centered on accident loads, 8 are not something that would be considered in a 9 CUF calculation.
10 ASME code, it's not important to the 11 evaluation of those events, and ASME code doesn't 12 include the evaluation of those types of cycles 13 in the calculation of CUF.
14 JUDGE KENNEDY: Would those types of 15 events be more applicable to the shock loading 16 type discussion that Dr. Lahey has brought up?
17 MR. STEVENS: That's correct. This is 18 Gary Stevens of the staff. They're low 19 frequency, low probably events. And crack 20 initiation, fatigue crack initiation is not the 21 important thing that you evaluate for for those 22 events.
23 And that's not to say they're not 24 evaluated by ASME code. In fact, they are. It's 25 just that they're not included in a fatigue NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5435 1 calculation.
2 JUDGE KENNEDY: All right. Thank you 3 very much. Unless one of my board mates has a 4 follow up question, I would like to offer this up 5 as a time for a break --
6 CHAIRMAN MCDADE: Okay, it's just a --
7 JUDGE KENNEDY: -- if I may be so 8 bold.
9 CHAIRMAN MCDADE: -- few minutes 10 between 11:00 and 11:05. Should we come back at 11 11:15? Does anybody need any additional time?
12 MS. SUTTON: That works, Your Honor.
13 CHAIRMAN MCDADE: And we are in 14 recess.
15 (Whereupon, the above-entitled matter 16 went off the record at 11:01 a.m. and resumed at 17 11:15 a.m.)
18 CHAIRMAN MCDADE: Please be seated.
19 The hearing will come to order.
20 JUDGE KENNEDY: I have a few 21 additional questions on the general topic of 22 synergism and its relationship to metal fatigue.
23 Dr. Lahey, in my previous question I excluded the 24 expanded materials degradation assessment.
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5436 1 that come back in. It seemed to me that that was 2 a series of studies that focused on extension of 3 operating licenses beyond the 60 years.
4 And I think you used the term 5 sustainability a couple of times in the hearing.
6 I guess what I'm really wanting to discuss, and 7 conceding that there's work to be done to extend 8 the licenses from 60 to 80 years, how should the 9 Board view those particular references in this 10 particular licensing proceeding here today?
11 What's the relevance of that material?
12 Is there something in there that you can point to 13 that we need to pay attention to even though it's 14 for a 60 to 80 year license extension, if you 15 could address that?
16 DR. LAHEY: Thank you, Your Honor. As 17 I had indicated yesterday, this study is, in 18 fact, funded to go out to as far as 80 years.
19 However, no one believes, including those 20 researchers, that there's a sharp demarcation in 21 time.
22 So a lot of the issues that they're 23 concerned with extend down to 50 years, 60 years, 24 70 years, whatever. All right.
25 So they're working on what happens in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5437 1 terms of degradation, what we can count on as 2 going longer, what we have to fix or replace in 3 some way or what we can't do period.
4 And so that was the source of that.
5 Some of the things we're talking about here are 6 underway. The particular one we just got through 7 talking about, irradiation and the synergism or 8 possible synergism of embrittled material due to 9 radiation with fatigue is an experiment that 10 really there's only one place in the country it 11 can be done.
12 And that's in Idaho in their hot cells 13 and using their facility. And that's not an 14 experiment that's underway to my knowledge right 15 now because it's a big ticket, long duration item 16 if you think about how you have to do their 17 parametric experiments.
18 But it's definitely one that they have 19 in mind doing. It's just a question when it'll 20 be done. So my concern is not that we have data 21 that we can use right now to quantify the effect.
22 I know we do not. However, there's 23 indication that there is an effect. People say 24 there's uncertainty. We ought to take data.
25 Even the NRC said it's inclusive.
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5438 1 My concern is what do you do in the 2 meantime. Do you just say okay, we'll press on 3 and use our inspection program and that's good 4 enough? Or do you say there's a possibility and 5 try to put a factor in there so it's F 6 embrittlement.
7 So it's not only CUF times Fen. It's 8 times F embrittlement. And that's a number 9 greater than 1. How big it is depends on what 10 kind of margin you allow.
11 So that's really the crux of where we 12 stand. I would never say that we have the data 13 from the fast breeder program was sufficient to 14 work up the effect. I know it's not.
15 JUDGE KENNEDY: Okay.
16 DR. LAHEY: But it's not irrelevant 17 either. I do not believe it's irrelevant.
18 JUDGE KENNEDY: Let me turn it around 19 just slightly since you seem to indicate that 20 there's relevance in those documents.
21 Is there something that you could 22 point to in those references that would call into 23 question any particular decisions we would be 24 inclined to make here in this proceeding relative 25 to metal fatigue?
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5439 1 And maybe you've already done it, but 2 I'm not sure. I've got it fixed in my mind.
3 DR. LAHEY: Well, I think we've talked 4 about that issue. Yesterday, we talked about the 5 fact that you have researchers, like Dr. Chopra, 6 saying that we need, we don't have sufficient 7 data to understand any synergism that may occur.
8 We need to take data. All right. And 9 you have all these things that we've been talking 10 about today and yesterday were reviewed by the 11 NRC when they made a decision as to what to do.
12 And you had people make input as to 13 what they should consider, what they should do.
14 So it's not new. I'm not bringing up anything 15 that hasn't been discussed before.
16 What I'm suggesting is it just seems 17 to me to be questionable engineering to not take 18 into account some uncertainty when there is 19 uncertainty as to what's going to happen.
20 And it's going to happen. If it 21 happens, it's going to happen in a bad direction, 22 not a good direction.
23 JUDGE KENNEDY: Let me be more 24 specific, be even more specific. Is there 25 something in those reports that draws into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5440 1 question what has been going on over the last 20 2 years, which is extending licenses from 40 to 60 3 years?
4 Is there something specific that you 5 would point to in there that would lead us to 6 take note of what we're trying to do in this 7 proceeding, which is grant a license for another 8 20 years of operation for Indian Point?
9 I think we all recognize on the Board 10 that's there's a need to continue to grow the 11 data set and to look at issues that have, that 12 would resurrect themselves in the 60 to 80 time 13 frame.
14 But I think what we're trying to point 15 to is could we find something in those documents 16 that would draw into question what we're trying 17 to do here, which is extend a license from 20 to 18 60 years.
19 DR. LAHEY: In my view, not anything 20 different than the opinions, the suggestions and 21 the conclusions that we've already talked about 22 in the various documents, both Argonne Lab 23 documents, both informal discussions by people, 24 researchers and the technical papers, which you 25 had asked about earlier.
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5441 1 JUDGE KENNEDY: And in a nutshell, 2 what are those conclusions that those researchers 3 would offer to us?
4 DR. LAHEY: That there's the potential 5 for degradation in the fatigue life due to 6 embrittlement, and more work is needed to work up 7 a database so that we can find what that 8 degradation is, level of degradation.
9 JUDGE KENNEDY: And you view those 10 researchers as being concerned in extending the 11 life of a, extending a license from 40 to 60 12 years as well as looking forward beyond that?
13 DR. LAHEY: Absolutely, and you may 14 recall, my overarching concern is not only the 15 degradation of the fatigue life but at any time 16 during the extended operation, if you have an 17 impulsive load withstanding that in terms of core 18 coolability and damage to those components.
19 JUDGE KENNEDY: All right. Thank you.
20 Maybe I could turn to the NRC staff. Do you 21 share Dr. Lahey's concern that there may be some 22 issues that need to be addressed in this 40 to 60 23 year time period?
24 MR. STEVENS: This is Gary Stevens of 25 the NRC staff. No, we don't. Specifically, I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5442 1 guess I'll point to a few things. We earlier 2 were discussing NUREG 6909, which was New York 3 State Exhibit 357.
4 And that document itself really 5 doesn't have much in the way of discussion of 6 radiation effects. However, New York State 7 Exhibit 490A, which is the draft revision 1 of 8 that document, we have a section, 1.3.2, that 9 discusses this.
10 So staff is cognizant of the issue, 11 and we're not ignoring it. And, in fact, the 12 three citations that Dr. Lahey has offered in his 13 testimony are discussed in that section of 14 NUREG/CR-6909, one of the implicitly.
15 The Arai paper, which is New York 16 State 564 is actually referenced in the Kanasaki 17 paper, which is NRC 177.
18 You've already heard testimony from a 19 lot of the experts regarding the impact of the 20 radiation on strengthened materials and what all 21 the experts say about the impact on fatigue crack 22 life initiation, fatigue initiation crack life, 23 sorry.
24 That tends to improve that. You've 25 also heard testimony regarding the Korth and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5443 1 Harper paper, which is Riverkeeper 152, that in 2 fact that testing was done at very high 3 temperatures, 900 to 1100 degrees Fahrenheit.
4 And the concerns we have with that is, 5 as was mentioned by Mr. Griesbach, fatigue creep 6 and other effects that aren't applicable to light 7 water reactors.
8 From our perspective, if I could point 9 you to one thing that probably does the best job 10 to summarize where we are with this, it would be 11 Figure 12 of the Kanasaki paper, which is NRC 12 177.
13 JUDGE KENNEDY: Should we call that 14 up?
15 MR. STEVENS: That would be helpful.
16 Yes, thanks.
17 JUDGE KENNEDY: Mr. Welkie?
18 MR. STEVENS: Okay. Figure 12 here is 19 a comparison of the test data that was irradiated 20 with respect to the ASME design fatigue curve, 21 which is what is used to calculate CUF factors.
22 And as you can see, even though 23 there's a lack of data, the data we see tells us 24 that the ASME design sufficiently covers 25 irradiation effects.
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5444 1 We've had a lot of discussion on low 2 amplitude, high cycle, high amplitude, low cycle.
3 And generally speaking, the differentiation 4 between those two comes between 10 to the 4th, 10 5 to the 5th cycle.
6 So what you see here is the data 7 stands low and high cycle regimes. In fact, this 8 plot I would say covers the general level of 9 strain amplitudes that are seen in light water 10 reactor conditions under normal and upset 11 conditions.
12 And so we have no evidence, and we're 13 reasonably assured that radiation effects are 14 adequately covered by what we know right now.
15 We agree that more data would be 16 helpful and to quantify, but all the evidence we 17 have to date supports that what we're doing is 18 adequate.
19 JUDGE KENNEDY: All right. Thank you, 20 Mr. Stevens. Dr. Lahey, would you like to 21 respond to Figure 12?
22 DR. LAHEY: Yes. I'm certainly 23 familiar with that and this paper, and I have no 24 doubt that because of the hardening that occurs 25 with irradiation embrittlement that when you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5445 1 have smaller amplitudes, like was run here, that 2 things get better.
3 My concern is for larger amplitudes, 4 and I really want to get into that when we 5 discuss the WESTEMS code and what it calculates 6 right now and some problems with those 7 calculations. But I think it's not the right 8 time at this point.
9 JUDGE KENNEDY: When you say large 10 amplitude, small amplitude, how do I view that on 11 this Figure 12? What would constitute, I guess, 12 large amplitude? What would constitute low 13 amplitude?
14 DR. LAHEY: To understand that, you 15 really need to draw the stress-strain curve or a 16 hardened material. And it steepens, the stress 17 versus strain on the ordinate and abscissa.
18 And it steepens so you get a higher 19 yield strength, a higher ultimate strength, but 20 it drops off at a much lower strain. All right.
21 So to know exactly what the strain is, you'd have 22 to know exactly what the fluence is and the 23 damage is.
24 JUDGE KENNEDY: Maybe I could go back 25 to Mr. Stevens. This strain amplitude versus NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5446 1 fatigue life, what's being represented on the Y-2 axis? And does it bear any, provide any input or 3 insight to the large amplitude, low amplitude 4 discussion?
5 MR. STEVENS: You heard testimony, 6 this is Gary Stevens of the NRC staff. You heard 7 testimony earlier of an S-N curve, and this is an 8 example of one of those.
9 And what you see on the left, the 10 vertical axis, is a measure of the stress-strain 11 that would a complement where material would be 12 exposed to. What I would call high amplitude, 13 low cycle would be the left side of the figure.
14 JUDGE KENNEDY: Okay.
15 MR. STEVENS: Left, upper left.
16 JUDGE KENNEDY: Upper left. And Dr.
17 Lahey, that would not be your characterization of 18 large amplitude, low cycle?
19 DR. LAHEY: I mean you got to 20 understand the strain is elongation over the 21 initial length, right?
22 JUDGE KENNEDY: Yes, sir.
23 DR. LAHEY: I think it depends 24 entirely on the forcing function that you put on 25 a component, which strain it goes to. And I do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5447 1 not necessarily view this as large amplitude 2 strain.
3 CHAIRMAN MCDADE: Can you quantify for 4 me what you would consider high amplitude strain?
5 DR. LAHEY: Certainly strains that get 6 you up into the plastic region. What I mean, 7 beyond the yield strength, when you're up into 8 the plastic region and beyond. Those are high 9 strains.
10 So if you plot it, you have, you want 11 me to try to draw it?
12 CHAIRMAN MCDADE: Well, just describe 13 it for here.
14 DR. LAHEY: Okay. So it comes up.
15 Then you have yield and then ultimate, and then 16 you're gone. All right. And this is strain. So 17 when you're up into the plastic region, when 18 you're out of the elastic region, that's high 19 amplitude. And then beyond it's higher.
20 JUDGE KENNEDY: What sort of events 21 would we, would lead to those types of 22 conditions?
23 DR. LAHEY: Significant bloating of 24 structures, impulsive bloating of structures with 25 thermal events.
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5448 1 JUDGE KENNEDY: Caused by?
2 DR. LAHEY: Caused by your normal 3 operational transients. We'll talk about that in 4 detail, how it's being done now and what I view 5 as the deficiencies in the code.
6 My guess is we'll need to clear the 7 courtroom when we do that.
8 JUDGE KENNEDY: I guess. I mean 9 Entergy testified earlier that in terms of metal 10 fatigue, they don't view these large amplitude, 11 low cycle events to be of concern for metal 12 fatigue.
13 Are you, again, suggesting otherwise?
14 Are we back to that disagreement?
15 DR. LAHEY: Yes, sir. I think they 16 get results, which depend entirely on the models 17 they use and the transients that are assumed.
18 And if you did things in a different way, you get 19 a significantly higher amplitude.
20 JUDGE KENNEDY: So you're suggesting 21 for the same forcing function or same event, you 22 could get different results, depending on the 23 methodology?
24 DR. LAHEY: Yes. And I'll show you 25 some reasons why they get the results they get.
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5449 1 JUDGE KENNEDY: All right.
2 CHAIRMAN MCDADE: And the clarify in 3 my own mind that it's the position of Entergy 4 that these high amplitude events are not of 5 concern is because they're not going to happen in 6 the Indian Point environment. Is that correct?
7 DR. LOTT: This is Randy Lott for 8 Entergy. That is essentially correct. Yes.
9 We're not, we believe that the particular cases 10 we have with irradiated internals will fit into 11 the scheme that's described by this Figure 12.
12 CHAIRMAN MCDADE: Okay. And your 13 disagreement is that you believe in the 14 environment present at Indian Point, these will 15 occur or may occur.
16 DR. LAHEY: Your Honor, I believe 17 they're under-predicting it right now, and I'll 18 show you why when we get into that.
19 CHAIRMAN MCDADE: Okay. And are you, 20 to differentiate, are you saying they will occur, 21 or are you saying they may occur?
22 DR. LAHEY: They may occur.
23 CHAIRMAN MCDADE: Okay.
24 JUDGE KENNEDY: All right. Thank you.
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5450 1 make a clarification. This is Gary Stevens, NRC 2 staff.
3 JUDGE KENNEDY: Okay.
4 MR. STEVENS: You have to recognize 5 that if there's a load in the design basis, even 6 one cycle of a load, it could not fall above the 7 dotted line with respect to strain amplitude, or 8 you would calculate a CUF greater than 1 and you 9 would not have an acceptable design.
10 So I just wanted to make sure that 11 we're not discussing strain amplitude loads that 12 are off the chart here because you would not be 13 able to qualify such a load for an adequate 14 design.
15 JUDGE KENNEDY: Maybe I'm mishearing 16 Dr. Lahey, but I believe he's suggesting for the 17 same events that Entergy's analyzing, he's 18 contending that he would get a different result 19 or someone else would get a different result for 20 the same event.
21 I don't know if that, where that falls 22 in this fatigue curve discussion. But I think 23 it, seems to have a general disagreement of what 24 the amplitude would be for the same event.
25 CHAIRMAN MCDADE: Is that correct, Dr.
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5451 1 Lahey?
2 DR. LAHEY: Yes, sir.
3 JUDGE KENNEDY: I needed a couple 4 minutes. There's a whole bunch of questions here 5 that were already asked yesterday on 26, so I 6 need to make sure I don't miss one nor ask you 7 that you guys have already answered.
8 At this point, I'd like to start some 9 discussion related to Dr. Lahey's supplemental 10 reply testimony. In particular, so this is New 11 York State 567.
12 And in there, there's a Figure 1, 13 which I believe Dr. Lahey has offered to try to 14 explain his position. And I think the Board has, 15 at least a number of questions to try to 16 understand what's being presented in Figure 1.
17 So Mr. Welkie, could you, if I've got 18 the right citation, it's New York State 567. And 19 there's a Figure 1 back about five or six pages.
20 DR. LAHEY: All right, Your Honor. As 21 I discuss this, you'll need to tell me what is 22 proprietary and what is not.
23 JUDGE KENNEDY: Are you suggesting 24 there's real data in there?
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5452 1 discuss the way WESTEMS works and the way, what's 2 missing and things like that. So I don't know 3 how nervous that makes Westinghouse.
4 JUDGE KENNEDY: This is a great 5 example where I thought I had a bunch of 6 conceptual questions on a depiction that had no, 7 I mean it has the concepts displayed but no basis 8 in Indian Point data or WESTEMS methodology.
9 But is it, can we start first with 10 just the figure itself? I know you don't know 11 what questions we're going to ask. But is there 12 any problem with that figure? I'm sorry?
13 MR. KUYLER: Yes, Your Honor. There's 14 no problem discussing this figure.
15 JUDGE KENNEDY: So we'll ask our 16 questions slowly, give you a chance to react.
17 MS. SUTTON: Yes, Your Honor. If we 18 start getting into the WESTEMS methodology, in 19 particular, we'll slow you down.
20 JUDGE KENNEDY: And I guess from my 21 perspective, I would, I'm a little shocked to 22 find out we're going to get into WESTEMS 23 methodology.
24 But maybe I, maybe it's a good 25 indication I don't understand this figure. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5453 1 start to walk us through it, at least with an 2 overview of what is being displayed here.
3 And we'll stop before you go into 4 WESTEMS methodology unless you can't describe 5 this figure without going into the WESTEMS 6 methodology, and we'll go a different way.
7 Could you at least, from an overview 8 perspective, describe what's being displayed 9 here?
10 DR. LAHEY: Certainly. I will do my 11 best to keep away from any sensitive information.
12 On the vertical access, the ordinate, is CUFen.
13 And you've now defined that carefully.
14 And on the abscissa, the horizontal 15 axis, is a time scale. So there's actually two 16 scales there. One is fluence, which is the 17 integrated, high energy neutron flux times time, 18 the time you're at that level and the other 19 scale, which is time itself.
20 So both of them are proportional to 21 time. So you can think about it, the horizontal 22 axis is a time axis. The only reason it's not 23 perfect is because you don't operate all the 24 time.
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5454 1 wouldn't be operating. But it's convenient to 2 just think about it as a time axis.
3 JUDGE WARDWELL: I've got to ask this 4 question right off the bat, I guess, Dr. Lahey.
5 This is Judge Wardwell. There's only one value 6 shown on each of the two axes.
7 That gives us no relation, no idea of 8 how long any of the axes are. There's no way to, 9 there's no scale, if you will, in regards to the 10 two axes such that this is only a schematic. Is 11 that a fair assessment? There's no --
12 DR. LAHEY: You should think about it 13 as a cartoon, a schematic, yes.
14 JUDGE WARDWELL: Thank you.
15 DR. LAHEY: The 10 to the 17th there, 16 when you think about fluence because it's 17 normally quoted in decades, 10 to the 21, 10 to 18 the 22, that sort of thing, you should think 19 about it as a log scale.
20 And so, 10 to the 17th was put there 21 just as a benchmark for the onset of irradiation 22 damage to carbon steel.
23 JUDGE WARDWELL: Right, but it doesn't 24 get us into any indication of where is 10 to the 25 22nd.
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5455 1 DR. LAHEY: No, but --
2 JUDGE WARDWELL: And same with the 3 CUFen on the vertical axis, we've got one.
4 That's fine, but I have no idea where 0.5 is.
5 DR. LAHEY: Well zero is on the 6 bottom.
7 JUDGE WARDWELL: Well, there's not a 8 zero there.
9 DR. LAHEY: No, but I'm telling you.
10 JUDGE WARDWELL: So that is a zero.
11 DR. LAHEY: It should be there, and so 12 halfway in between would be the 0.5.
13 JUDGE WARDWELL: Is zero on the 14 horizontal axis, or is that horizontal axis log 15 rhythmic for both values?
16 DR. LAHEY: it's a log scale.
17 JUDGE WARDWELL: Thank you.
18 DR. LAHEY: But down to the left on 19 that axis is a low fluence. So it's not of any 20 concern in terms of radiation damage. So what 21 I'm trying to show on this figure is at least 22 three things.
23 I'm sorry if I put so much data on one 24 figure, but hopefully I can talk you through it.
25 So the first thing is just let's look at what I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5456 1 call the limit line, the LL.
2 The limit line is the predictions that 3 are being done by WESTEMS now. And why do I call 4 it a limit line? Because that's what you 5 normally call a prediction or a correlation that 6 is conservative.
7 And the way WESTEMS is used and the 8 way it's been formulated is you try to make 9 assumptions such that the results have 10 conservatism in that.
11 And so it's always below. It's always 12 better, or excuse me, not below. It's always 13 closer to CUFen of 1 than what you really think 14 it should be. Is that clear to everybody?
15 All right. So as time goes on, this 16 dotted line goes up until you get to the end of 17 light for the period of extended operations. And 18 in this case, at that point, there's a margin, a 19 small margin.
20 So it would be some number slightly 21 less than 1. I don't want to quote a number, but 22 less than 1. All right.
23 Now the question is, the fundamental 24 question is because the way WESTEMS is used, 25 you're allowed to systematically, if you're above NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5457 1 1, if you make assumptions which are too 2 conservative and it gives you a result that's 3 above 1, you're allowed to go back and 4 recalculate, make different assumptions as long 5 as you can justify them, until you get below 1.
6 So in the end, as that goes on and on 7 and you get closer and closer to unity, which is 8 your failure criteria, and you start really 9 pushing it, then the question of how conservative 10 is WESTEMS? What's the margin? What really is 11 the margin that's there?
12 And everyone says it's conservative.
13 Don't worry about it because we got a lot of 14 conservatism in there. But then the question is 15 we're willing to trust, but you need to verify.
16 So how do you verify the margin? So 17 a good way to do that, the normal way to do that, 18 is you make the run. It doesn't have to be for 19 every component. You just pick one that's 20 sensitive, and you make a best estimate 21 prediction.
22 So instead of saying I'm using what I 23 think is a large heat transfer coefficient, you 24 use your best estimate for the heat transfer 25 coefficient.
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5458 1 Instead of doing all kinds of 2 assumptions that are built into the model, with 3 some conservatism, use your best estimate. And 4 then do what's known is a propagation of error 5 analysis.
6 I know the NRC likes to think about it 7 as a propagation of uncertainty. But I didn't 8 make up the words. That's what people call it.
9 And work out the intervals in plus or minus 10 uncertainty.
11 And these are, if you read any 12 technical paper, a journal paper and you see 13 experimental data with an error band on it, plus 14 or minus, that's what we're talking about.
15 It's the best fit to the data plus or 16 minus the uncertainty due to measurement errors 17 and whatever. Okay. So this is the uncertainty 18 due to prediction errors, modeling errors, et 19 cetera.
20 And that's what I've called delta. So 21 I drew three cases here. Case 1, which is all 22 the way to the right, is my best estimate line 23 assuming no degradation in the prediction due to 24 irradiation.
25 So this is no embrittlement. So BE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5459 1 means best estimate. Sub NE means no 2 embrittlement. All right. So that's what right 3 now the licensing process would propose.
4 And so if we go out here at this 5 point, then you look at plus or minus 6 uncertainty. And how do I do that? I'm 7 suggesting, and I've put in my testimony, you can 8 use a number of ways to do it.
9 One way is the Kline & McClintock 10 propagation of error analysis. And so I won't 11 write it down, but I'll tell you how it goes.
12 You just take the partial, so if you, partial 13 derivative.
14 So if you're an engineer, you just 15 love this method because you say the uncertainty 16 squared is equal to partial of a function of 17 different variables that contribute to error.
18 Partial of F, respect to X1 squared 19 and then the error in X1 squared plus the partial 20 of F at function, respect to X2 squared times the 21 error of that variable squared. So --
22 JUDGE KENNEDY: So --
23 DR. LAHEY: -- let me just give you a 24 specific example --
25 JUDGE KENNEDY: Okay.
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5460 1 DR. LAHEY: -- so it'll make it 2 concrete.
3 JUDGE KENNEDY: That's what I was 4 going to ask you for.
5 DR. LAHEY: Okay. So power is equal 6 to I square R. Right? Everybody okay with that?
7 Power is equal to I square R, electric power. R 8 is --
9 JUDGE KENNEDY: I don't know what it 10 does to fatigue, but I'll let you keep going.
11 JUDGE WARDWELL: You're just 12 illustrating the propagation of error.
13 DR. LAHEY: I'm illustrating the 14 method with something that's easy to do. So now 15 the error in power is the partial of I square R 16 with respect to I. So it'd be 2I times R times 17 the error in our current measurement.
18 So if you run an experiment, you have 19 plus or minus 2 percent error in reading the 20 amps. Okay. Plus, and so you square that. Plus 21 the partial of power respect to R.
22 So that's just I square times the 23 error in R. So you go to the manufacturer of 24 your resister, and it says this has so many ohms 25 plus or minus 2 percent. Put that in.
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5461 1 You then take the square root of both 2 sides. You have the error in your power 3 measurement. So that's just a simple way. You 4 can do it with any function.
5 And so it's not, I had the question or 6 not the question, the criticism come back, you're 7 talking about random sort of stuff. And this is 8 deterministic. This is highly deterministic.
9 You're just talking about the 10 uncertainty in these particular models. All 11 right, or these particular evaluations. So 12 that's how you get plus or minus delta.
13 Is that clear because I mean it's 14 nothing magic? It's pretty straightforward.
15 Engineers love it because it's easy to do. It 16 gets them to use their calculus, and they crank 17 their way to victory.
18 Okay. So now I've assumed, just for 19 argument's sake, that my plus error band or my 20 error bar plus delta is as shown there so that 21 the upper part of it is above CUF of 1. Okay.
22 So what does that mean? That means 23 that even my best estimate prediction has some 24 chance of exceeding 1. The best estimate is 25 significantly below, but there is an error or an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5462 1 uncertainty, which allows it to be above 1.
2 So even though, when I, now I compared 3 the limit line with the best estimate, and I 4 would say in that case, the limit line is not 5 really conservative. It's not. They think it 6 is. It's not. On the other hand --
7 JUDGE WARDWELL: But as I look at 8 this, just to make sure I understand what you're 9 saying, the error you have in that, your 10 propagation of error results ended up to be about 11 0.25 worth of CUF.
12 DR. LAHEY: Yes. They're large.
13 JUDGE WARDWELL: Order of the CUF.
14 DR. LAHEY: It would be the error --
15 JUDGE WARDWELL: That's just your 16 schematic assumption. It has, that was no 17 calculation that you derived based on CUF 18 analyses, right? That's just schematically 19 showing if you did have --
20 DR. LAHEY: If I did have this 0.25 21 arranging CUF --
22 JUDGE WARDWELL: Right.
23 DR. LAHEY: -- that's what it would 24 be. And it could be the other way. It could be 25 the top of those error bars is below, in which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5463 1 case the conclusion is the limit line is 2 adequately conservative.
3 JUDGE WARDWELL: Or another way to say 4 it, if in fact the propagation of error was only 5 0.1 in the CUF, it would be well below it.
6 DR. LAHEY: Yes.
7 JUDGE WARDWELL: Okay.
8 DR. LAHEY: If, in fact, the best 9 estimate is that far below, as shown here, 10 exactly that.
11 JUDGE WARDWELL: Or on top of it. If 12 the propagation of error resulted in 0.01 instead 13 of 0.25 as you have schematically represented --
14 DR. LAHEY: Right.
15 JUDGE WARDWELL: -- then schematically 16 representing this, it would show a very tiny, a 17 bit above the best estimate line and be well 18 below the limit line. Correct?
19 DR. LAHEY: Exactly.
20 JUDGE WARDWELL: Okay.
21 DR. LAHEY: Then I would be very 22 happy. I'd say I'm happy.
23 JUDGE WARDWELL: And you don't have 24 any data to show what that bar should be.
25 DR. LAHEY: I don't have anything, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5464 1 when they get really, really tight, and they 2 start working out in the plasticity region, 3 you're really pushing the envelope.
4 And I need to know what the margins, 5 I think it's very imprudent not to know what the 6 margin is. I mean if we're really working our 7 way out in the bathtub curve towards the upper 8 part.
9 JUDGE WARDWELL: This schematic, 10 again, is just illustrating what it might look 11 like, if in fact, you hit it up with --
12 DR. LAHEY: -- a large bar --
13 JUDGE WARDWELL: -- error bar like a 14 quarter of a total distance.
15 DR. LAHEY: Where would that bar come 16 from? For example, can I deviate, Your Honor, 17 from this plot for a little bit?
18 JUDGE KENNEDY: Let's stay right here 19 for a second.
20 DR. LAHEY: Because I can tell you why 21 that error bar may be large. And we'll come back 22 to it. All right. So the next part of this is, 23 now let's say that the concerns not only that I 24 have but others have about the possible 25 degradation of the fatigue life due to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5465 1 embrittlement, due to radiation-induced 2 embrittlement or thermally-induced embrittlement, 3 but here, radiation because of fluence.
4 So now I have a curve, which goes up.
5 And until it gets to about, I don't know, 10 to 6 the 21 or six point, they have a criterion, 6.7 7 times 10 to the something or other, it'll stay 8 essentially the same.
9 And then it starts getting worse 10 because the denominator gets worse. Remember, 11 it's the number of cycles over the number of 12 cycles to failure times Fen.
13 So the number of cycles to failure.
14 If embrittlement reduces that, the denominator 15 gets smaller. Therefore, the CUFen prediction 16 gets bigger. So now --
17 JUDGE KENNEDY: Just for argument's 18 sake, we've been at this for a couple of days.
19 I'm still not sure we've seen the support for the 20 premise that that synergistic effect occurs.
21 I mean it's an interesting hypothesis, 22 and this certainly demonstrates the hypothesis 23 that's been in front of us through all this 24 testimony. But I'm still looking for that 25 citation that points us to where this hypothesis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5466 1 has been supported.
2 DR. LAHEY: I would love to bring you 3 the data, Your Honor, but it won't be here for a 4 few years. That's the problem.
5 JUDGE KENNEDY: So you're --
6 DR. LAHEY: But people aren't spending 7 millions and millions of dollars of taxpayer 8 money just for the fun of it. I mean they're 9 worried about it as well.
10 CHAIRMAN MCDADE: Excuse me. Dr.
11 Lahey, let me make sure I understand. What 12 you're saying is because of an absence of data, 13 that in your view, this error bar should be 14 large?
15 DR. LAHEY: No. And Your Honor, I'm 16 not trying to tie that to our uncertainty as to 17 whether this embrittlement impacts it or not.
18 I'm going to assume here it does for this 19 particular curve.
20 JUDGE WARDWELL: The comment I would 21 like to make would be to get this on even footing 22 would be that you've got the lines labeled wrong.
23 It's not BE with no embrittlement.
24 It's really BE assuming embrittlement 25 doesn't affect the strength, and then your BE NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5467 1 with the E isn't BE with embrittlement.
2 DR. LAHEY: Exactly.
3 JUDGE WARDWELL: It's BE with the 4 assumption that embrittlement does affect fatigue 5 life.
6 DR. LAHEY: I agree. That's a very 7 good way to think about it. Or it could be 8 something without embrittlement. I mean just no 9 irradiation, but that's a very good way to think 10 about it.
11 JUDGE WARDWELL: Right.
12 DR. LAHEY: So anyway, if you'll buy 13 this just to see what happens, what happens as 14 time goes on, this fluence goes on. It's gets 15 worse and worse.
16 And at some point, it hits 1.0 well 17 before the end of a period of extended operation.
18 In fact, so that's 0.2. But in fact, at 0.3, if 19 you tie on the uncertainty --
20 JUDGE WARDWELL: There's no facts in 21 this figure. Is that correct?
22 DR. LAHEY: Well, in fact, that's the 23 only fact. Yes. I mean this is my cartoon, man.
24 I'm the cartoonist, so I can do as I wish. So 25 anyway, when you get to 0.3, you now have that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5468 1 uncertainty bar.
2 And you see that well before the end 3 of the period of extended operation, if it 4 happens that there is synergism with irradiation 5 and fatigue, you will have a good chance of 6 fatigue failure.
7 So that's how this all fits together.
8 Now, the reason I put this in my testimony was 9 because we kept saying for years you're giving us 10 this limit line prediction.
11 You're giving us these CUFen results, 12 and you keep cranking it up, cranking it up.
13 You're going to make sure what they call 14 conservatism, you keep eliminating them.
15 And I'm worried about at some point, 16 it's not longer conservatisms. It's necessary 17 margins that you're cutting into, design margins.
18 And so I need, to feel comfortable, I need to 19 know what's the margin.
20 Is it really that conservative, to 21 don't worry about anything? You can just keep 22 iterating. Or at some point, are you non-23 conservative?
24 And the only way I know to get that, 25 and we've been suggesting it for years is do an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5469 1 error analysis. And this is how you do an error 2 analysis. I sent references to a textbook all 3 sophomores at RPI used to learn how to do this.
4 And it bounced.
5 It didn't work. They thought, it 6 doesn't matter what they thought. But anyway, 7 now I figure if I draw a cartoon and write down 8 the equation for a propagation of errors, you 9 can't miss it.
10 That's what I'm talking about. So 11 this is a plea to do this because I don't know 12 any other way to know what the margin is.
13 It's not good enough to say there's 14 conservatism, and I've done this and that because 15 later on I'm going to show you other pictures, 16 which show you things that they believe are 17 conservative assumptions, which are not.
18 They're doing them in the wrong way.
19 I mean they're not conservative. They're missing 20 the boat on some of these things.
21 JUDGE KENNEDY: I've got millions of 22 questions. One thought that comes to mind, we 23 had a lot of discussion earlier about margins, 24 the margins that are in the ASME code calculation 25 plus the margin to CUF of 1, and then on top of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5470 1 that, the concept of conservatisms.
2 I'm assuming you tracked that 3 conversation before.
4 DR. LAHEY: Yes.
5 JUDGE KENNEDY: How does that bear 6 into this cartoon here? Does the best estimate 7 have margins in it?
8 DR. LAHEY: I would suggest to compare 9 apples and apples, that all the ASME code 10 conservatism, which is similar to what we talked 11 about earlier, all right, should remain in the 12 best estimate. I have no trouble with that.
13 JUDGE KENNEDY: Right. And I believe 14 I heard Entergy testify that they don't and will 15 not reduce those margins, that those are off the 16 table.
17 DR. LAHEY: I think they're off the 18 table.
19 MR. GRAY: Yes, that's correct.
20 DR. LAHEY: They're off the table.
21 JUDGE KENNEDY: So we've got margins 22 --
23 DR. LAHEY: Yes.
24 JUDGE KENNEDY: -- that nobody's 25 disputing.
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5471 1 DR. LAHEY: So you might quarrel with 2 it being called best estimate, but anyway, those 3 margins are in there because fatigue, the onset 4 of a crack is a random process.
5 I used to do this at GE, and you run 6 these samples. And they all look the same, but 7 they all don't have the same number of cycles to 8 failure. But if you then plot it up, they're 9 within a band.
10 And then the uncertainty that the ASME 11 puts on bounds that plus a little more surface 12 finish and et cetera, et cetera. So I think 13 that, you don't touch.
14 That's not part of the best estimate.
15 Otherwise, it's really not apples and apples 16 comparison with your limit line.
17 JUDGE KENNEDY: I mean I think the 18 other question you've already, you already 19 testified that the limit line, again, potential 20 WESTEMS calculation has conservatisms built in 21 it.
22 And it's difficult to me. I can sort 23 of, I sort of understand your best estimate and 24 then doing an error analysis and getting an 25 uncertainty and laying that on top of there.
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5472 1 I don't know how to translate that to 2 the load limit line and put an uncertainty on 3 that in the same manner because it already has 4 conservatisms built into it.
5 DR. LAHEY: I'm sorry I'm mislead you.
6 I'm not recommending you put a plus or minus 7 uncertainty on the limit line.
8 JUDGE KENNEDY: Well, I --
9 DR. LAHEY: The limit line, by 10 definition, is supposed to be conservative.
11 JUDGE KENNEDY: But I thought I heard 12 you say that because of the uncertainty, even 13 though the limit line shows a CUF less than 1 at 14 end of life, it could actually be greater than 1 15 because of the uncertainty.
16 And I guess all I'm suggesting, do you 17 really intend to apply the same uncertainty to 18 the best estimate line and the limit line?
19 DR. LAHEY: So let's go back to Case 20 1 again. And so we can say here's the best 21 estimate, which I would agree with Judge 22 Wardwell, we could think about as a best estimate 23 calculation where no effective embrittlement is 24 taken into account.
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5473 1 and we can talk about what goes into that, why I 2 think it might be large. It exceeds unity at the 3 top. The plus delta exceeds unity.
4 So that says if you really do the best 5 you can do and do the error analysis or the 6 uncertainty analysis, there's a pretty good 7 chance you're going to have a failure at that 8 point or actually a little before that point.
9 So your prediction in your limit line, 10 which says it's below 1 is wrong. It really --
11 JUDGE KENNEDY: I'm sorry.
12 DR. LAHEY: -- is not taking into 13 account what the true situation is. It can fail 14 earlier. It's not conservative.
15 JUDGE KENNEDY: I guess I don't know 16 how you, well, again, recognizing this is a 17 cartoon, but we're trying to bring it into the 18 real world here because it is demonstrative of 19 the issues we're trying to deal with.
20 DR. LAHEY: Exactly.
21 JUDGE KENNEDY: And we're going to get 22 to margins and conservatisms probably as we move 23 through the day.
24 I have a difficult time trying to 25 think in the same terms of a best estimate line NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5474 1 with uncertainties and a limit line that has 2 uncertainties or conservatisms already embedded 3 in it with the same uncertainty band around it.
4 So, I mean I could argue on the other 5 side, and maybe Entergy would and maybe we should 6 give them a chance, that that limit line is so 7 conservative there's no uncertainties to be 8 placed on that limit line. And it's good to go.
9 DR. LAHEY: That's exactly what they 10 do, Your Honor. And now the question is, is it 11 that conservative? And here's how you determine.
12 Let me tell you where, I'll give you another 13 example.
14 I don't know exactly your background, 15 so I don't know if this is helpful. But in the 16 world that I have lived in, we worry about the 17 thermal limits on the fuel, so-called critical 18 heat flux.
19 So if you plot the flux versus 20 quality, you take the experimental data. And one 21 way to run your plant is draw a line underneath 22 all that data. That's the limit line.
23 And as long as you don't go in heat 24 flux greater than that, you're okay. The other 25 way is to make a best fit of that data plus or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5475 1 minus uncertainty and then evaluate it.
2 Both ways have been used in the past.
3 I've used both ways.
4 JUDGE KENNEDY: Are those the two ways 5 that are evidenced on this chart?
6 DR. LAHEY: That's our two ways. But 7 the question is, because we don't have any way to 8 know has this been drawn under all the data. I 9 mean is it, are they living in a fool's paradise, 10 I mean is one way to think about it.
11 Do they think they're all that 12 conservative, and they're not really?
13 JUDGE KENNEDY: I guess said another 14 way, if that limit line isn't right, we should be 15 seeing failures in real plant data with CUFs less 16 than 1. So we have a CUF prediction based on the 17 limit line that's 0.9. That component fails due 18 to metal fatigue.
19 DR. LAHEY: Well, there have been some 20 failures, which have been attributed to 21 manufacturing flaws and things like that when 22 they're below 1.
23 But in fact, we haven't run this out 24 far enough to take into account the effect of 25 embrittlement, for example, and what that might NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5476 1 do to it.
2 JUDGE KENNEDY: And again, that's the 3 inconclusive data that you constantly point to.
4 DR. LAHEY: That's one way to do it.
5 JUDGE KENNEDY: Maybe just in case I 6 didn't hear it right, you don't, you're not aware 7 of any metal fatigue failures where a predictive 8 technique would have predicted that the metal 9 shouldn't have fatigued and failed.
10 Is there any evidence of that that 11 you've seen?
12 DR. LAHEY: Yes. There has been that 13 data. I don't know I can give you the reference 14 off the --
15 JUDGE KENNEDY: Is that different than 16 the manufacturing defects that you just --
17 DR. LAHEY: That's what they attribute 18 it to.
19 JUDGE KENNEDY: Maybe --
20 DR. LAHEY: I think it was a 0.7, 21 Havana 0.7.
22 JUDGE KENNEDY: What would that be 23 indicative of in this whole discussion here about 24 trying to manage aging for metal fatigue? Is 25 that an issue that's not included, not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5477 1 considered?
2 DR. LAHEY: The reason I'm doing this 3 and I'm concerned with it is because we have been 4 asked to trust the results are conservative.
5 Trust us. They're conservative.
6 And then we can go back and keep 7 reducing what we view as conservatisms that are 8 unnecessary because we have so much margin we 9 don't need them.
10 And it just gets tighter and tighter 11 and tighter. And at some point, you worry about 12 how do you know what the conservatism is. How 13 much conservatism do you really have? And this 14 is the only way I know how to actually get at 15 that.
16 JUDGE KENNEDY: If Entergy reduced the 17 conservatisms, took all the conservatisms out and 18 left only the margin, design margins or whatever 19 the right word is in the ASME code, is that still 20 a conservative calculation?
21 DR. LAHEY: I think they could use, 22 the WESTEMS code is really an encoding of a 23 procedure that we used to do by hand. In 1961, 24 when I did my first job, I was doing exactly 25 this, thermal stress analysis, but we did it all NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5478 1 by hand.
2 Now it's much more encoded, and I 3 think that's great. It helps out as long as you 4 get it right. I can show you later on what they 5 would need to do to that code to do a best 6 estimate calculation.
7 They do it with that code. And then 8 do the error analysis and sit the problem, answer 9 the concern. Is it conservative or not?
10 JUDGE KENNEDY: And again, I guess 11 what we'd be most interested in is can you 12 identify a problem with using the margins that 13 are in the ASME code plus some conservatisms or 14 no conservatisms to generate a load limit line.
15 What is fundamentally wrong with that?
16 DR. LAHEY: At the end of the day, 17 that may cover all the concerns. But it's not 18 for sure. And when you're playing with the 19 health and safety of people in this area of the 20 country, I think it's not the right thing to do.
21 JUDGE KENNEDY: Are you suggesting 22 that there's insufficient margin in the ASME 23 calculation to cover the uncertainties in, I 24 guess, the overall calculation?
25 DR. LAHEY: Yes. For example, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5479 1 ASME code, the 20 cycles and the factor, or 2 excuse me, the two cycles and the factor of 20, 3 20 cycles and a factor of 2 on stress, that is 4 for the air data.
5 If you look at the Fen prediction, and 6 you think about how did they take that data. So 7 how did they take that data? They did it in 8 autoclave. So they put the little machine that 9 runs the fatigue experiments, and you could 10 control the chemistry, the temperature.
11 You could do a precise job. And then 12 that's what they fit and got the Fen correlation.
13 The problem is, when you go to the plant, then 14 you look at a flow situation where you have 15 turbulence and you start thinking about what the 16 chemical engineers called surface renewal theory, 17 sub-shielding of the oxygen.
18 You get a lot of sub-shielding in an 19 autoclave that you would not get in the real 20 application. So is the Fen really accurate, and 21 how do you put that uncertainty into the thing?
22 Well, this is one way to do that.
23 It's part of the delta.
24 JUDGE KENNEDY: So your concern isn't 25 with the original CUF calculation and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5480 1 uncertainties in that. Your concern is with the 2 environmental adjustment factor and covering the 3 uncertainties in that.
4 DR. LAHEY: It's only one part.
5 There's also part of the modelings that we can 6 get into, which are not, which are really not 7 conservative at all. They're non-conservative.
8 JUDGE KENNEDY: I think, let's stay on 9 the cartoon for a while.
10 JUDGE WARDWELL: I got a question 11 before we leave this cartoon.
12 (Simultaneous speaking.)
13 JUDGE WARDWELL: -- one clarifying 14 thing that may --
15 JUDGE KENNEDY: Thank you, Dr. Lahey.
16 JUDGE WARDWELL: Give you some time, 17 give you time to think of something else. But I 18 do want to clarify one statement you made early 19 on. You stated that that limit line is 20 associated with the WESTEMS calculation.
21 Correct? That's what you said.
22 DR. LAHEY: I'm calling the results of 23 the WESTEMS calculation a limit line, yes.
24 JUDGE WARDWELL: Okay. But isn't the 25 WESTEMS just a computer code that is one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5481 1 mechanism to calculate out the CUFs. The limit 2 line is just a calculation of the CUFs. Could it 3 not have been done by hand?
4 DR. LAHEY: Absolutely.
5 JUDGE WARDWELL: Okay. So that limit 6 line is not necessarily indicate of WESTEMS or 7 not. It's the calculation of the CUF line.
8 DR. LAHEY: Right. If you made the 9 same assumptions that they make in the code --
10 JUDGE WARDWELL: Right.
11 DR. LAHEY: -- and did it by hand, 12 well they may, you may have a WESTEMS limit line.
13 JUDGE WARDWELL: Right. You may have 14 whatever, but a limit line is not unique, I'm 15 saying, in regard, your cartoon is not unique to 16 WESTEMS.
17 It could be a cartoon for any limit 18 line that happened to be calculated to, happened 19 to be done, calculating out the CUF relationship 20 with either the time for a period event at 21 operation or the fluence.
22 DR. LAHEY: Yes, sir. When I say 23 limit line, what I mean is instead of a best 24 estimate, it's a supposedly conservative 25 calculation.
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5482 1 JUDGE WARDWELL: Right.
2 (Simultaneous speaking.)
3 DR. LAHEY: Right now the question is 4 --
5 JUDGE WARDWELL: However it was done.
6 DR. LAHEY: -- is it really, and 7 what's the margin.
8 JUDGE WARDWELL: Fine. I just wanted 9 to clarify that point --
10 DR. LAHEY: Right.
11 JUDGE WARDWELL: -- that it's not just 12 a WESTEMS calc.
13 JUDGE KENNEDY: All right. Dr. Lahey, 14 is there anything additional that you'd like to 15 discuss? This is Judge Kennedy, on this figure.
16 DR. LAHEY: Unless there's any 17 questions, I've tried to explain it. If I didn't 18 do it, please have somebody ask me.
19 JUDGE KENNEDY: I think we'll have 20 additional questions when we get to the 21 conservatisms discussion later.
22 DR. LAHEY: All right.
23 JUDGE KENNEDY: I guess I'll turn to 24 Entergy. Do you have any rebuttal to this 25 figure, this cartoon, other than what's been --
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5483 1 MR. GRAY: This is Mark Gray for 2 Entergy. The concept is pretty straightforward, 3 and if we were trying to do a precise 4 calculation, we probably could use such a 5 technique.
6 But what we would propose, in fact, is 7 you can do this on the front end or on the back 8 end. If you do it on the front end, you select 9 your inputs in such a way that the only error 10 that you're going to get is going to go below the 11 limit line.
12 And so when we are maximizing stresses 13 so that we can get a conservative usage factor, 14 we select the inputs to the stress calculation, 15 and we model the calculation that we do for the 16 stresses, such that we're already calculating a 17 larger than expected load and stress range that 18 we use for the fatigue calculation.
19 So I would say that the calculation 20 that we've done is sufficient because any 21 uncertainty on our assumptions would go in the, 22 would make the answer less.
23 JUDGE KENNEDY: So you don't, do you 24 not feel the need to add any uncertainty upon 25 your calculation, as Dr. Lahey has indicated, a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5484 1 delta above your calculation to account for 2 uncertainties?
3 MR. GRAY: No, we do not.
4 JUDGE KENNEDY: Do you believe they're 5 included in the original calculation, analysis 6 method?
7 MR. GRAY: Yes.
8 JUDGE KENNEDY: This discussion of the 9 ASME margins that I may have miscommunicated, 10 going back to some conservatisms can be removed, 11 margins cannot be removed.
12 So one thought I had in trying to 13 address Dr. Lahey's concern about the reduction 14 in conservatism is to suggest that there's still 15 margins in the code evaluations.
16 Is that a true statement? Is their 17 margin still, are those untouchable margins in 18 the code something that can be relied on to give 19 confidence in the final result?
20 MR. GRAY: Yes. As we said 21 previously, we're not touching those margins in 22 our selection of inputs and conservatisms in the 23 analysis.
24 JUDGE KENNEDY: Are those margins 25 sufficient to cover potential uncertainties in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5485 1 the analysis, or is that the wrong way to be 2 thinking about this?
3 MR. GRAY: The ASME code doesn't 4 dictate the method that you use to get your 5 stresses, for example.
6 It has some very high level guidelines 7 of the ways that you treat the stresses that you 8 calculate and how you conform them to the 9 equations that are stipulated that you meet in 10 the code on your way to calculation of the usage 11 factor.
12 After that, the analyst must justify 13 that his stress calculation is a conservative.
14 JUDGE KENNEDY: Go ahead.
15 DR. LAHEY: Your Honor, could I say 16 one thing on that his?
17 JUDGE KENNEDY: On the ASME margins?
18 DR. LAHEY: On the statement and your 19 suggestion. By definition, a limit line 20 shouldn't have any plus or minus delta on it. I 21 mean it's very consistent to use ASME code 22 assumptions of conservatism in a limit line.
23 It's very consistent to make 24 assumptions to make it conservative. But by 25 definition, it doesn't need any uncertainty NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5486 1 because it's a bounding calculation.
2 It has enough conservatism built in.
3 The only thing of concern is what is it. I mean 4 --
5 (Simultaneous speaking.)
6 JUDGE WARDWELL: Yes. I think that 7 will get into my questions I have for Mr. Gray.
8 So as I heard you said that you know what those, 9 as you're assuming conservative parameters for 10 your input that you're allowed to do, you're 11 aware of those that you are doing.
12 And you're usually motivated, as I 13 heard Mr. Stevens say, usually probably because 14 it's a less expensive analysis because you can 15 simplify some of the runs or whatever else.
16 But you are aware of what those are.
17 Correct?
18 MR. GRAY: That's correct.
19 JUDGE WARDWELL: Right. And so you 20 are developing a limit line. And what you're 21 saying is that with that limit line, as long as 22 we're below 1, we know we're conservative.
23 MR. GRAY: That's correct.
24 JUDGE WARDWELL: But likewise, you 25 could also take out all those conservatisms out NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5487 1 of that for every one of the parameters. Could 2 you not right off the bat?
3 MR. GRAY: Theoretically you could.
4 JUDGE WARDWELL: And so you could 5 create a best estimate line because that's where 6 you would be at that point. Would it not be the 7 closest to your guess of what truth would be in 8 that particular sets of materials and the 9 resulting CUFs that you're calculating with the 10 cycles that are applied to it?
11 MR. GRAY: While your suggestion might 12 be a responsibility --
13 JUDGE WARDWELL: I'm not suggesting 14 anything. I'm just saying you could come up with 15 that best estimate line, if in fact, you 16 eliminated all the, you took your best estimate 17 of all the parameters that you're putting in, not 18 incorporating any of the conservatisms, the 19 margins.
20 MR. GRAY: If you had a way to do 21 that, that might be possible, but I don't believe 22 that that's possible. So we do always make some 23 conservative assumptions, yes.
24 JUDGE WARDWELL: Well, I thought you 25 knew how much conservatism, conservative nature NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5488 1 of your inputs that developed your limit line.
2 MR. GRAY: You know what maximum loads 3 are. You know what maximum inputs are, for 4 example. That doesn't mean you know precisely 5 what the actual value might be.
6 JUDGE WARDWELL: Or another way to say 7 it, you really don't know what you would want to 8 say is your minimum loads necessarily.
9 MR. GRAY: Or best estimate.
10 JUDGE WARDWELL: Best estimate load.
11 Okay. Thank you. Let me just finish up. But if 12 you could, if you were able, I understand what 13 you just said.
14 But if you were able to, that would 15 just create a best estimate line. Correct, in 16 regards to just trying to correlate what you're 17 saying with this cartoon?
18 MR. GRAY: That could be possible.
19 JUDGE WARDWELL: Okay.
20 MR. STEVENS: Your Honor, Gary Stevens 21 as NRC staff. Would you mind if I said a few 22 words here?
23 JUDGE WARDWELL: Not at all.
24 MR. STEVENS: I guess I would 25 interpret it that he would not be allowed to do NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5489 1 a best estimate line because, let's go back to 2 the margin discussion that I had earlier.
3 Part of the margin is things he can't 4 touch. In order to do an appropriate uncertainty 5 analysis, if you could, which by the way you 6 can't because the code would not allow that.
7 And the reason it would not allow that 8 is because part of your best estimate analysis 9 would be to use a best estimate fatigue curve, 10 which you're not allowed to do.
11 JUDGE WARDWELL: Of the what curve?
12 MR. STEVENS: Fatigue curve or the S-N 13 curve, to calculate your CUF. You're not allowed 14 to do that with the code. You have to use the 15 design curve --
16 JUDGE WARDWELL: But haven't we taken 17 out, we all agree that we're not going to touch 18 those code things. And those are as if there are 19 no margin. We were taking those at those values, 20 and we're not touching them.
21 MR. STEVENS: Well to me, that's not 22 a best estimate analysis.
23 JUDGE WARDWELL: I'm only using that 24 phrase in regards to this cartoon. I'm not 25 giving it any other credence in regards to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5490 1 bestness of it or the estimate of it. It's just 2 nomenclature to relate to this cartoon. That's 3 all.
4 You would create a line below your 5 limit line that would have the conservative 6 assumptions that you've made and are allowed to 7 make out of it is all I'm saying.
8 You could derive a line for that is 9 what I was asking. Okay.
10 MR. STEVENS: Okay.
11 JUDGE WARDWELL: Any other comments on 12 that? So I understand that there are those 13 margins from the code and actions required by the 14 code that limit the degree that you can touch.
15 And I think we all agree those are 16 untouchable and will always be in there.
17 MR. COX: Yes. Your Honor, one 18 comment on that. I think if I understand Mr.
19 Stevens correctly, you could do that, but you 20 wouldn't have a best estimate line. You would 21 have a lower limit line.
22 JUDGE WARDWELL: Well, call it 23 anything you want to. I'm only using, again, I 24 only use that nomenclature in reference to 25 picturing this on this cartoon.
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5491 1 Call it an Ernie line if you want. I 2 don't care what you call the line. I'm not 3 giving it any credence that it is the best 4 estimate. I'm just giving it a, being consistent 5 with what's on the cartoon. That's all. Thank 6 you.
7 DR. LAHEY: Your Honor, I certainly 8 agree. And I think I said earlier, to do this 9 "best estimate" --
10 JUDGE WARDWELL: You don't like my 11 suggestion of Ernie?
12 DR. LAHEY: But I would recommend you 13 retain the ASME code. And so it's not exactly a 14 best estimate, but then it's apples and apples 15 comparison.
16 So some things that, just so you 17 understand, one of the things that we're talking 18 about here is right now you make an assumption of 19 so many scrams during the light.
20 Let's say your best estimate of number 21 of scrams is 100, and so, but you really don't 22 use the same thing. I mean you can use 200 in 23 your limit line.
24 And you say I got conservatism here, 25 which you do if you really believe you only have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5492 1 100. So you'd use 200 in the limit line and 100 2 in the best estimate and go through each one like 3 that.
4 And in the end, you have some way to 5 define what sort of margin. We have some ability 6 to understand what's the cushion, if any. Right 7 now we don't know, particularly as you get closer 8 and closer and closer.
9 I come from a background where if I'm 10 sitting there in my office, and I ask somebody to 11 design a piece of equipment to last for 60 years 12 and fatigue is one of the issues, and they come 13 in with a design where they're rapidly 14 approaching 1 and they got all kinds of, it's 15 really at the bitter edge, I'd throw them out of 16 the office.
17 I'd say, listen guy. You're not going 18 to design a piece of equipment like that. But 19 now because we can't redesign the reactor, we're 20 asking to get out there, the stuff that any 21 rational engineer would never accept.
22 So what you need is enough confidence 23 you got enough margin in there to take into 24 account anything that may happen. That's where 25 we're at.
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5493 1 JUDGE KENNEDY: I can't let the 2 rapidly approaching 1 go by the wayside without 3 asking a question. Do you perceive the CUF 4 values that are calculated for Indian Point 1 and 5 2, 2 and 3?
6 I don't know what the values of 1 7 would be, for 2 and 3 are rapidly approaching 1 8 over the next 20 years?
9 DR. LAHEY: Well, they're --
10 JUDGE KENNEDY: And I'm not sure what 11 --
12 DR. LAHEY: Yes, they're --
13 JUDGE KENNEDY: -- graphically 14 approaching means in this context.
15 DR. LAHEY: I can give you a numerical 16 value, but I was asked not to do it.
17 JUDGE KENNEDY: Well, let's --
18 DR. LAHEY: There are several 19 components are --
20 JUDGE KENNEDY: Let's say for 21 argument's sake they're all going to get to 1, 20 22 years from now. Is that your concept of rapidly 23 approaching?
24 DR. LAHEY: Yes.
25 JUDGE KENNEDY: And why is that a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5494 1 concern?
2 DR. LAHEY: If you get to 1 or beyond, 3 you got a problem. Well, even in the licensing 4 basis, they would have to take action at that 5 point, yes.
6 JUDGE KENNEDY: Right.
7 DR. LAHEY: If I'm, if you calculate 8 at the end of 60 years, end of period of extended 9 operation, you have a CUFen of 0.2, I'm not 10 really concerned about that.
11 But if it's decimal point, you know 12 what I'm saying?
13 JUDGE KENNEDY: So your concern, as it 14 gets to 1, what do you perceive happens when the 15 CUF value gets to 1? Do we lose the intended 16 function? Do we crack? Do we fail?
17 DR. LAHEY: The assumption, of course, 18 is you get a crack of 3 millimeters. My, as you 19 may remember from the last couple days, my 20 problem is as this, and this is a new discussion 21 I'm going to create.
22 JUDGE KENNEDY: It is.
23 DR. LAHEY: As this thing fatigues --
24 JUDGE KENNEDY: I started it.
25 DR. LAHEY: We hear and we hear, and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5495 1 you get a number of microcracks. And all of a 2 sudden you have an impulsive load. Then you've 3 got a big problem. So I don't want a design 4 where things get very degraded.
5 JUDGE KENNEDY: I guess I'm getting 6 confused again because I thought we put to bed 7 this question of did they analyze these shock 8 loads. And I'm assuming that this covers all the 9 way up to the maximum CUF values that they have 10 in their analysis to date.
11 Are you suggesting they did not do 12 that? I thought we just settled that question.
13 DR. LAHEY: What we talked about this 14 morning was for the baffle bolt, baffle former 15 bolts. An analytical method has been set up, 16 which I believe will create the right kind of 17 shock loads.
18 And they could be applied to other 19 components as well. I haven't seen that, but 20 this type of sub-cool decompression model could 21 be applied throughout the system.
22 But as you may recall, right now I 23 haven't seen them do the type of design basis 24 LOCA breaks with a type of opening times that 25 would create the larger ones.
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5496 1 In principle, they can get the loads.
2 They can get the loads right, but it makes a huge 3 difference if it's a snap load or a gradual load.
4 JUDGE KENNEDY: But didn't they do 5 that for the original design, and why is it 6 different?
7 DR. LAHEY: Using a different code, 8 they have done that. And to assure if you have 9 ductile structures, you will maintain an intact 10 geometry.
11 And as I said yesterday, we spent a 12 lot of taxpayer money verifying that in the LOCA 13 program to show that indeed you could maintain 14 the coolable geometry and cool the core.
15 Now that we're winding up with a 16 highly degraded geometry, both due to fatigue and 17 irradiation, that hasn't been done.
18 JUDGE KENNEDY: We have no CUF values 19 at the end of life greater than 1 according to 20 the testimony of Entergy. Why are we in a highly 21 degraded condition?
22 DR. LAHEY: Okay. The CUF value is a 23 moving target. I mean there was a really nice 24 Westinghouse paper, and I think the author of it 25 is in the room, which described the process for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5497 1 a RHR accumulator nozzle.
2 It's an iterative process. You make 3 certain assumptions, and they're supposedly very 4 conservative. And if you get a CUF of less than 5 1, CUFen less than 1, you stop. It's good 6 enough.
7 Maybe that's fine, but if it becomes 8 19, which happened, then you go back and start 9 looking at what did you do that you might want to 10 relax. And some of them are obviously 11 conservative.
12 If you assume too many cycles of a 13 certain transient, so back it up. You did this 14 or that. Back it up. But as you keep doing this 15 and you keep going over and over, there's no 16 limit to what you can cut in order to get below 17 1.
18 And that's where we become very 19 concerned. At some point, you're cutting into 20 design margins. It's not just conservatism.
21 JUDGE KENNEDY: This is where I keep 22 getting confused. I thought there was a point 23 beyond which these reductions are off the table.
24 And I guess maybe I keep getting 25 myself confused between conservatisms and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5498 1 margins, which we tried to earlier have a lot of 2 discussion about.
3 But I keep hearing from Entergy that 4 there's a limit to this refinement of 5 calculation, that there's areas that they do not 6 go. Are you suggesting that's not true?
7 DR. LAHEY: Well, I think maybe the 8 NRC should comment on it, but what I've read says 9 that if they have that situation, they can either 10 fix it or they can recalculate it.
11 They're allowed to recalculate it, and 12 then if they can justify that that's a 13 conservative calculation, fine. The problem is 14 they just say it's conservative.
15 I mean there's no, there's nothing 16 that has been defined as what conservatism really 17 is in the code. That's the concern.
18 JUDGE KENNEDY: Are you saying in the 19 code or in the analysis method, in the input, I 20 mean are you opening it up to the whole --
21 DR. LAHEY: Into the results of 22 WESTEMS, which includes all of those things.
23 JUDGE KENNEDY: I think we'll get back 24 to this in the afternoon. But I appreciate your 25 input.
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5499 1 DR. LAHEY: I mean, I want to say that 2 I understand the approach. And even though if 3 you don't really understand what they're doing, 4 it looks pretty startling when you see numbers go 5 from 20 down to 0.8.
6 And you say oh my God. What's going 7 on? And then you realize it's a process that 8 they do. And I don't even mind the process. I 9 understand it.
10 It's just at some point as you keep 11 doing it, you're cutting into the bone. All 12 right. And we need to know --
13 JUDGE KENNEDY: How would you know 14 when we're at that point? Do you have a sense of 15 where that point is?
16 DR. LAHEY: The only way I know is to 17 determine what sort of margin you have and to 18 compare it, something like this.
19 JUDGE KENNEDY: To do a best estimates 20 calculation.
21 DR. LAHEY: Best estimate with 22 uncertainty. And then you say okay, compared to 23 that, my error bar is below the limit line and --
24 (Simultaneous speaking.)
25 JUDGE KENNEDY: So you're not buying NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5500 1 Entergy's argument that in doing the calculations 2 or in essence doing a load limit type 3 calculation.
4 DR. LAHEY: I believe President Reagan 5 was right. You trust but verify.
6 CHAIRMAN MCDADE: Okay. And I don't 7 want to get into a big discussion here right 8 before lunch.
9 But just to satisfy me, from your 10 standpoint, if you were looking at it during the 11 period of extended operation and the 12 environmental adjusted CUF was 0.1, you wouldn't 13 have very many concerns because you would believe 14 that there would be sufficient margin there so 15 that there would not be a potential for problem.
16 At the other end of the spectrum, if 17 within the period of extended operation, the 18 environmentally adjusted CUF was 0.99, you would 19 be very concerned because of the possibility of 20 insufficient margin.
21 (Simultaneous speaking.)
22 CHAIRMAN MCDADE: So that, in fact, it 23 might be above 1, although their calculation is 24 below 1. Is that correct?
25 DR. LAHEY: Yes, Your Honor. That's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5501 1 exactly right.
2 CHAIRMAN MCDADE: Okay. And that in 3 factoring, in preparing their environmental 4 adjustment for the CUF, in your view, there are 5 factors that are not adequately considered, such 6 as the effect of neutron embrittlement and such 7 as the fact that in your view, there are the 8 potential for high amplitude events within the 9 design basis that have not factored in.
10 DR. LAHEY: And we'll get into that 11 after lunch, I guess, on some of the modeling 12 assumptions that are made, some of the models 13 that are used and how if you do those correctly, 14 you dramatically increase the amplitude.
15 CHAIRMAN MCDADE: Okay. But at least 16 the way I described it is consistent with the 17 testimony you were hoping that we would 18 understand this morning. Nothing that I said was 19 --
20 (Simultaneous speaking.)
21 DR. LAHEY: I agree with what you 22 said, except there's also modeling things that 23 are influencing the result --
24 CHAIRMAN MCDADE: Right, in addition 25 to --
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5502 1 DR. LAHEY: -- that were non-2 conservative in my view.
3 CHAIRMAN MCDADE: In addition to that 4 we're going to get into later.
5 DR. LAHEY: Yes.
6 CHAIRMAN MCDADE: Okay. Thank you.
7 Judge Kennedy, your suggestion?
8 JUDGE KENNEDY: I suggest we take a 9 break at this time.
10 CHAIRMAN MCDADE: Okay. One quick 11 thing before we do break for lunch, and let me 12 just note for administrative. There was an 13 Entergy document, Entergy R-00186. It was filed 14 in connection with Track 1.
15 It was an R document. There was a new 16 one that was filed in connection with the Track 17 2, and we are going to sua sponte make that 18 Entergy R-20186. So when you do your revised 19 exhibit list, if you could have that correspond.
20 It is now 12:40. Would it be 21 appropriate to break until 1:40? Okay. And the 22 next question is, and I'm thinking this may well 23 be that when we come back at 1:40, it might be 24 appropriate for us to go into a closed session 25 initially so that Dr. Lahey might comment on some NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5503 1 proprietary information.
2 So for the individuals who are 3 spectators and all of the participants here have 4 signed the non-disclosure agreements. But we 5 will at least at 1:40 have a closed session.
6 And for anybody who is present 7 probably we're hopeful that by 2 o'clock then we 8 would be able to open up the session again to the 9 public session.
10 So we will stand at recess until 1:40, 11 have a closed session with anticipation we'll 12 open it approximately 2 o'clock.
13 MR. SIPOS: Excuse me, Your Honor?
14 John Sipos for the State of New York. I just 15 wanted to clarify one question for the Board, and 16 it follows up on a question from Judge Kennedy.
17 There was some discussion of the 18 phrase "rapidly approaching 1 or 1.0 or unity,"
19 and that was a phrase that we picked up during 20 the November 5 pre-hearing conference.
21 And it was our understand that that 22 was a safe harbor phrase that would be 23 acceptable.
24 MS. SUTTON: Your Honor, this is 25 Kathryn Sutton. This is the third time counsel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5504 1 from New York has testified on behalf of his 2 witnesses. And we object.
3 MR. SIPOS: I'm not.
4 CHAIRMAN MCDADE: Okay. I don't 5 believe that Mr. Sipos was testifying. I believe 6 that he was clarifying.
7 And I think that he correctly 8 commented on what was said during the status 9 conference, that we did not want the witnesses 10 and asked parties to instruct the witnesses not 11 to use specifics but that, again, the term that 12 as I understood it, what Dr. Lahey was saying by 13 rapidly approaching meaning in his view, the 14 environmental adjusted CUF was close to.
15 It had nothing to do with speed. It 16 had to do with its nearness to the 0.1 or 1.0, 17 which then raised concerns in his mind. Is that 18 how you were using the term, Dr. Lahey?
19 DR. LAHEY: Yes, sir. Yes, Your 20 Honor.
21 CHAIRMAN MCDADE: And that is what you 22 were referring to, Mr. Sipos?
23 MR. SIPOS: Yes, Your Honor. And I 24 was not trying to testify. I was trying to 25 provide --
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5505 1 CHAIRMAN MCDADE: I didn't anticipate 2 that you were testifying. I thought you were 3 trying to clarify something for the Board so that 4 we would properly understand Mr. Lahey, Dr.
5 Lahey's testimony.
6 MR. SIPOS: And it was a phrase that 7 originated from the Board.
8 CHAIRMAN MCDADE: I believe, actually 9 from me.
10 MR. SIPOS: I believe so, Your Honor.
11 That's all I was trying to clarify.
12 MS. SUTTON: It's good to know, Your 13 Honor, that we can make similar clarifications as 14 necessary. So thank you very much.
15 CHAIRMAN MCDADE: If you believe that 16 it is necessary to clarify something, I am 17 confident that you will not be shot.
18 MS. SUTTON: Thank you, Your Honor.
19 CHAIRMAN MCDADE: We are in recess.
20 (Whereupon, the above-entitled matter 21 went off the record at 12:41 p.m. and resumed at 22 1:44 p.m. in Closed Session.)
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13 CHAIRMAN MCDADE: Okay. Are we ready 14 to go? We're on the record and we're in an open 15 session. And the public has been seated. I've 16 got two final questions back on the old synergism 17 topic that we had this morning. Entergy, on Page 18 152 of your pre-filed testimony which I believe 19 is Entergy 679, you state that fatigue in a 20 radiation embrittlement contribute to potential 21 aging effects in very different ways.
22 And then you go on to say, no basis to 23 apply additional fatigue correction factor to 24 address, there is no basis to apply an additional 25 fatigue correction factor to address potential NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5596 1 embrittlement. And it cites to ENT631 at D3. I 2 can't find that statement at D3. Either my 3 reading is failing or the cite may be inaccurate.
4 So it starts on Page 152 of the pre-5 filed testimony and it's discussing fatigue in a 6 radiation embrittlement and how they contribute 7 in very different ways. I mean, I think this is 8 an attempt to address Dr. Lahey's thoughts of 9 adding another additional factor to deal with 10 embrittlement and its combined effect on fatigue.
11 MR. KUYLER: Your Honor, would it be 12 possible to have Entergy Exhibit 631, Page D3 put 13 up on the screen?
14 CHAIRMAN MCDADE: That would be fine.
15 Mr. Welkie? It's not proprietary, it's just 16 copyrighted, correct?
17 MR. KUYLER: Your Honor, I believe 18 that exhibit is full text copyrighted but not 19 proprietary.
20 CHAIRMAN MCDADE: Okay. Thank you.
21 JUDGE KENNEDY: It's quite a ways into 22 the document. And if it leaps off the page at 23 us, I'll stand corrected. So that's D3. I 24 believe the discussion is related to fatigue and 25 radiation embrittlement contributions, aging NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5597 1 effects.
2 DR. LOTT: Can we go back up?
3 JUDGE KENNEDY: If it's going to be 4 anywhere, it's probably going to be in that.
5 DR. LOTT: Yes. I think we were 6 referring to the statement at the end of, I guess 7 it's the top paragraph on this view at least.
8 That the work of several researches suggest that 9 neutron radiation does not result in further 10 reduction of fatigue properties. And some cases 11 suggest an improvement which is effectively a 12 description of the discussion we've had in 6909.
13 However, minimal data on the combined 14 effects of water chemistry and neutron influence 15 currently exist in literature.
16 JUDGE KENNEDY: Okay. I mean I guess 17 --
18 MR. LOTT: Did we present that as a 19 direct cite? Or was it --
20 JUDGE KENNEDY: Well I was thinking it 21 was a direct quote from your, in your pre-filed 22 testimony from D3. So if that's the statement, 23 the indication is that there's no data to 24 support.
25 DR. LOTT: Well I think it suggests NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5598 1 that work of several researchers that neutron 2 embrittlement does not result in further 3 reduction. So I think that's a positive 4 statement rather than a fairly negative statement 5 as you suggested.
6 JUDGE KENNEDY: Oh I see. I got you.
7 All right. I think I see the logic better -- I 8 had a question about walk us through the logic 9 but given the way the statement's worded here 10 which is different than I had written down -- and 11 I'll have to go back and check this out.
12 If your testimony is that this is the 13 support for the statement of why no additional 14 fatigue correction factor is warranted to address 15 potential embrittlement --
16 DR. LOTT: Yes.
17 JUDGE KENNEDY: And I'll think about 18 that in relation to the way it's, fold it back 19 into the original testimony.
20 DR. LOTT: Okay.
21 JUDGE KENNEDY: So D3, the last 22 sentence in the paragraph. I guess the first 23 paragraph. All right, I'm going to have to think 24 about it. I really just wanted to find the 25 support and where I looked, I wasn't finding the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5599 1 words that were in the original testimony. That 2 helps.
3 DR. LOTT: Okay.
4 JUDGE KENNEDY: Well it may help but 5 I'll take it for now. It's the best we can do.
6 I have a number of questions related to a safety 7 margins discussion that Dr. Lahey has started.
8 I'll start first with Dr. Lahey.
9 You've introduced a set of concerns 10 related to the reduction in conservatisms in the 11 CUFen calculations. And your concern appears to 12 be that they could be reducing the safety 13 margins. And I first want to start by having you 14 clarify what you mean by safety margins.
15 I mean, we recognize we're reducing 16 conservatisms. But I think your concern goes to 17 a reduction in safety margins.
18 DR. LAHEY: That's correct. In the, 19 what I call the limit line approach or the 20 WESTEMS approach, what's assumed is that there's 21 a lot of conservatism and from various sources, 22 modeling or number of cycles or various ways that 23 they proceed with this calculation.
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5600 1 it's above CUFen of one then they're free to go 2 back and redo that if they can identify something 3 that's a conservatism that's pretty obvious. And 4 they can relax it and justify it. So they do.
5 And there's nothing wrong with that 6 approach except at some point, you start cutting 7 into -- you go from conservatisms to margins, 8 engineering margins that allow for uncertainties.
9 And if you keep cutting too much, you're really 10 cutting into things that are important.
11 Normally, there's a demarcation for 12 that but we see no demarcation at all. There 13 seems to be no rules, no guidance as to what you 14 can do or what you can't. To the point you have 15 some components that -- I'm going to use, you 16 know, my normal language. They're playing every 17 trick in the book. All right?
18 They're doing all the things you're 19 allowed. And they're all the way up to working 20 in the plasticity range. And once you get there, 21 you're pushing that thing pretty hard. You're 22 way up there towards fatigue failure.
23 So to us, we believe it's very 24 important to know what margins there are. I 25 mean, I'm sure that the people who do that feel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5601 1 comfortable that there's enough residual 2 conservatism so that that's not such a scary 3 thing. But unless you know what that is, it's 4 potentially pretty scary.
5 So that was the whole thing that I 6 discussed earlier about how to quantify the 7 margin.
8 JUDGE KENNEDY: So if I understand you 9 correctly, you don't have necessarily a concern 10 about reduction in conservatisms. It's 11 constantly reducing the conservatisms and not 12 knowing that you haven't eroded the safety 13 margins.
14 DR. LAHEY: That's correct Your Honor.
15 ` JUDGE KENNEDY: And this concern arose 16 as you reviewed the revised calculations that 17 were presented in the testimony. And the 18 potential to redo those calculations, I guess at 19 any time.
20 DR. LAHEY: That's correct. I mean, 21 I've been looking at all this for eight years 22 now. And you get a result that's high and then 23 next time you see it, it's really low and then 24 the next time you see it, it's halfway between.
25 I mean it just floats all over the place.
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5602 1 And once it gets up, essentially to 2 unity, then I'm very concerned. Because I don't 3 know what's left. Is it enough?
4 JUDGE KENNEDY: Fair enough. Let's 5 turn to Entergy. I think we talked a little bit 6 about this this morning but I'm not sure we got 7 all the way through the problem. So I thought 8 I'd bring the safety margins discussion back up.
9 We talked about margins and we talked about 10 conservatisms this morning.
11 I guess I would like to see if you 12 could address how the analyst knows that he can't 13 continue to reduce conservatisms and erode safety 14 margins. Where is the guidance for the analyst 15 to know that they're not taking away margins that 16 are needed to cover for uncertainties or other 17 issues? And I'll look to Mr. Gray first.
18 MR. GRAY: Mark Gray for Entergy. I 19 think the primary guidance that every analyst has 20 in this industry is the ASME code. We must 21 follow the code and the conservative methods that 22 are explicitly given within the code.
23 As we said earlier, the code designed 24 fatigue curve includes margin. The code methods 25 for stress allowables -- for example, the design NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5603 1 stress intensity allowable in Section 3 is an 2 allowable stress with built in margin that 3 affects factors in your evaluation.
4 And so, these are given margins that 5 we must live with. We can't change. After that, 6 as far as conservatism goes, I also have 7 different methods that I can use within the 8 boundaries of the code. And let me use the 9 example.
10 These analyses that have been 11 performed are still elastic analyses. They are 12 linear elastic analyses. Now NB-3228 of the code 13 allows you to do a plastic analysis. We have not 14 done that yet. So at this point, we have not 15 even gone to that. And that would be, within 16 Section 3, that would be your next major step in 17 reducing conservatism in your analysis.
18 So we haven't used that approach.
19 We've used the linear elastic approach given in 20 NB-3200 along with the other conservatisms that 21 are there. There is such a thing called, in NB-22 3228.5 --
23 CHAIRMAN MCDADE: Sorry, could you 24 repeat that?
25 MR. GRAY: NB-3228.5. There's a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5604 1 penalty factor called K sub E which is known 2 throughout the industry to give a very 3 conservative correction when your primary plus 4 secondary stress intensity exceeds an allowable 5 value. You're allowed to that then check another 6 equation and penalize your usage factor 7 calculation with KE.
8 All of these are still in the analysis 9 that we've been done. So at this point, even 10 these calculations haven't used the least 11 conservative method that the code allows.
12 CHAIRMAN MCDADE: And perhaps, is 13 there any way that you can, you know, sort of 14 briefly summarize that when the environmentally 15 adjusted CUF is recalculated, how the analyst 16 determines and quantifies the impact on the 17 safety margin.
18 MR. GRAY: Once again, the safety 19 margin is defined by the code. And so, the 20 inherent margins that we're not allowed to touch, 21 the analyst meets by meeting the 1.0 allowable in 22 the code. And making sure that the corresponding 23 stresses are within the design stress intensity 24 allowables. And so, that's a place that we don't 25 touch. And that's the margin in the analysis.
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5605 1 CHAIRMAN MCDADE: But what Dr. Lahey 2 was talking about is that you look at the 3 analysis, it is at a particular level, just it's 4 X. That it's then recalculated and it's X minus 5 .2. And then you look at it again and it's X 6 minus .3.
7 When it's recalculated, how does the 8 analyst determine whether that recalculation has 9 an impact on the conservatism? And if so, what 10 that impact is. Is there any way of quantifying 11 that?
12 MR. GRAY: Your first question was how 13 does the analyst deal with margin? Now you've 14 asked me how the analyst deals with conservatism.
15 CHAIRMAN MCDADE: Well you seem to be 16 saying that the margin is in the code itself. So 17 that's I changed it from margin to conservatism.
18 MR. GRAY: Okay. So for conservatism, 19 there are different levels of conservatism that 20 are generally used in these analyses. For 21 example, you group your transients. When you 22 know that that's too conservative, when the 23 answer is too high, you can ungroup those 24 transients.
25 CHAIRMAN MCDADE: But why are those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5606 1 two terms synonymous? That it's too high and 2 therefore, it's --
3 MR. GRAY: Okay. I'll fix my words.
4 When it does not meet the allowable. That's the 5 only thing that makes it too high, when it 6 doesn't meet the allowable. This is binary.
7 JUDGE KENNEDY: And by bundling them, 8 that's an assumption the analyst has made to 9 simplify the calculation?
10 MR. GRAY: Correct.
11 JUDGE KENNEDY: And so, they don't 12 meet the allowable so now they're going to 13 unbundle -- as if I know what these terms mean.
14 Unbundle the transients and do individual 15 calculations. And that's perceived as a 16 reduction in conservatism?
17 MR. GRAY: Yes because all the 18 transients are not of the same severity. So if 19 I'm going to be conservative, if I have 500 20 cycles of different transients, I take the worst 21 transient with the worst severity will give me 22 the worst stress range. And I assume all 500 23 cycles are of that severity, that's conservative.
24 I can then -- if those 500 cycles are 25 really distributed over ten different transients NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5607 1 of different severities, I can unbundle, to use 2 your word, those transients into ten different 3 cases with their respective cycles.
4 JUDGE KENNEDY: In some ways, a more 5 accurate calculation, maybe more reflective of 6 the actual conditions. I don't know about 7 accuracy but more reflective of the actual 8 conditions. As opposed to bundling them and 9 using a maximum --
10 MR. GRAY: Yes.
11 JUDGE KENNEDY: -- a parameter that 12 would maximally impact the cumulative usage 13 factor.
14 MR. GRAY: Yes.
15 CHAIRMAN MCDADE: That's your view Mr.
16 Gray and the view of Entergy?
17 MR. GRAY: Yes.
18 CHAIRMAN MCDADE: Okay.
19 MR. STROSNIDER: This is Jack 20 Strosnider for Entergy. I'd like to give a 21 little perspective on this concept of margin in 22 terms of what it takes to meet the regulations.
23 I want to start off with the fact that the 24 tendency of 55A endorses the ASME code which 25 establishes a very clear demarcation in terms of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5608 1 what margin needs to be maintained.
2 You need to meet a usage factor, 3 cumulative usage factor of one with those margins 4 that are in the ASME code. And that's why you've 5 heard numerous witnesses already testify that 6 they don't touch that. That's what you have to 7 maintain, the margin you have to maintain in 8 order to meet the regulations and in order to 9 satisfy Part 54 in terms of maintaining your 10 current licensing basis.
11 The people also talk about a margin 12 between what they're calculated cumulative usage 13 factor is and that demarcation point of one. The 14 example was given earlier today of what if it's 15 .5? Then I've got a margin of .5 to one. That's 16 not the margin that's required by the 17 regulations. And you can go and you can 18 recalculate and you can use up some of that 19 margin if you want to characterize it that way.
20 But as long as you're meeting the 21 usage factor of one as calculated with the 22 margins that are in the ASME code, you're 23 satisfying the regulations. And that is adjusted 24 now for the environmental effects as consistent 25 with the guidance to meet Part 54.
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5609 1 So I just wanted to make sure that 2 it's very clear, the margin we're talking about 3 that's necessary to satisfy the license renewal 4 rule, if you will.
5 JUDGE KENNEDY: That's the, I guess to 6 put it back to the original question, would that 7 be perceived to be the safety margin at the 8 untouchable part of the calculation?
9 MR. STROSNIDER: Yes, that's correct.
10 And that is, you know, by endorsing that in the 11 regulations, the NRC has concluded that that's 12 what's necessary for reasonable assurance. All 13 right, it's a regulation and that margin is 14 there. And that's why people don't touch it and 15 that's what you need to meet.
16 The rest of the margin and the 17 conservatisms are things that people can work 18 with. But they need to meet what's in the code 19 as endorsed in the regulations.
20 JUDGE KENNEDY: Thank you. Dr. Lahey?
21 CHAIRMAN MCDADE: I was just going to 22 say, our concern in understanding this is that 23 when you take the first glance at this, you say 24 that the environmental adjusted CUF can't exceed 25 one. But when it approaches one, it's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5610 1 recalculated. And you know that it needs to be 2 recalculated because it's approaching one.
3 And then if it approaches one again, 4 you recalculate it again. So almost by 5 definition then, it can never exceed one because 6 before it reaches one, it's going to be 7 recalculated. So what we need to have clear in 8 our minds and on the record is the justification 9 for the recalculation. And the assurance that 10 the recalculation provides the accurate 11 description of reality of what's actually there.
12 And that's, I think, what Dr.
13 Kennedy's questions are and I think that was Dr.
14 Lahey's concern. And we're just trying to see --
15 I want to make sure I understand how Entergy and 16 the NRC staff is addressing the concern of that 17 perception. Am I correct in what your concern 18 was Dr. Leahy?
19 DR. LAHEY: Yes, sir. My concern is 20 in this process of iterating, getting below one, 21 that you don't throw out necessary design margin.
22 CHAIRMAN MCDADE: And necessary 23 conservatisms.
24 DR. LAHEY: That's correct.
25 MR. STROSNIDER: This is Jack NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5611 1 Strosnider for Entergy. I'd like to address that 2 again if I can. I think the problem is that 3 people are dismissing those margins that are 4 required by the ASME code. The margins are 5 there. All right? That's what's required.
6 And when you recalculate because 7 you're using a less conservative analysis method, 8 you can do that. You haven't touched the margins 9 that are required by the ASME code. And those 10 margins, I mean those design rules provide 11 margin.
12 The other thing I want to comment on 13 is this notion that people keep saying that you 14 can just redo this cumulative usage factor 15 forever and never reach one. And that's not the 16 case. There are examples and I know some of the 17 people from Entergy can speak to examples where 18 they've actually had to go in and do other 19 actions because they couldn't.
20 You know, they have to change the 21 loading or they have to change components. So 22 it's not a given that you can always recalculate 23 and get it less than one. All right? So I hope 24 that's helpful.
25 MR. AZEVEDO: Your Honor, this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5612 1 Nelson Azevedo. If I may add some --
2 CHAIRMAN MCDADE: Yes, sir. Go ahead.
3 MR. AZEVEDO: Yes. In fact, Mr. Gray 4 a few moments ago mentioned plastic analysis. We 5 haven't gotten to that point yet. Some of the 6 analysis, especially once again to the elastic 7 plastic analysis become very expensive.
8 And there have been cases that I've 9 been involved with, in fact some at Indian Point, 10 where it's cheaper for us to either modify the 11 way we run the plant or just replace the end 12 component.
13 One case I was involved with was to 14 pressurize a spray piping at another plant. We 15 just chose to replace the piping. It was just 16 more cost effective than getting to these elastic 17 plastic analyses were very expensive.
18 Specific at Indian Point, back in the 19 '90s on the charging nozzle, we use what we call 20 the normal charging nozzle. And we were coming 21 up to a CUF of one. And we just decided to use 22 a different nozzle. So we changed the way we run 23 the plant just to address, you know, these 24 issues.
25 So the idea that we can just keep NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5613 1 going forever and ever and keep redoing these 2 analyses, it's not practical and it's not even 3 cost effective. If I may just say another 4 comment, I heard statements like we play every 5 trick in the book and manipulate these analyses.
6 I am the owner of these issues at 7 Indian Point. And we absolutely make sure that 8 we meet all our safety margins. And we do not 9 manipulate any of these calculations.
10 JUDGE KENNEDY: Thank you Mr. Azevedo.
11 CHAIRMAN MCDADE: Dr. Leahy, do you 12 now understand where the safety margins are?
13 DR. LAHEY: I like a couple of the 14 comments and I agree with them. I like in 15 particular, the last one. We wholeheartedly 16 endorse that approach. My understanding is that 17 for one of the Indian Point reactors, and I can 18 identify if you wish, the CUF end is for the 19 pressurizer spray nozzle rapidly approaching 20 unity. And they have done what I call every 21 trick in the book but they're allowed. I mean, 22 they've done the averaging of the stresses, peak 23 averaging, et cetera, including elastic plastic 24 analysis. We had two -- that's the documentation 25 that we were sent. So we've had two people say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5614 1 they don't do any elastic plastic analysis.
2 But that's very different from what we 3 read. But the approach of, once you get to that 4 point which is sort of pushing the envelope, then 5 it should be a decision based on cost. And we 6 wholeheartedly embrace the thought of replacement 7 and make the problem go away versus keep 8 iterating the calculation.
9 CHAIRMAN MCDADE: Okay. And if I 10 could interject here, Dr. Lahey a couple of 11 things. One, you know, when you use the term 12 every trick in the book, we did not interpret 13 that as a pejorative term in any way. I 14 interpreted as, that there were certain 15 mechanisms that are available to them and that 16 they were utilizing the mechanisms that are 17 identified.
18 The second is, you again used the 19 term, you know, rapidly approaching unity. And 20 as we had a discussion with Mr. Sipos before 21 lunch, that that phrase originated with me. And 22 perhaps it's, since it's not necessarily 23 temporally related, getting darn close might be 24 a better, more descriptive way of doing that.
25 So rather than just simply adopting NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5615 1 the inarticulate phrase that I used, you know, 2 would getting darn close be a, perhaps, more 3 accurate substitute?
4 DR. LAHEY: Extremely close, yes. I 5 agree, darn close.
6 JUDGE KENNEDY: And again, that is 7 darn close at end of life or today?
8 DR. LAHEY: Yes, calculated for the 9 end of life or the extended operation.
10 JUDGE KENNEDY: Thank you. In the 11 discussion that you heard from Entergy, did you 12 understand there to be any reduction in safety 13 margins or margins that you're concerned about in 14 the approach that they've taken?
15 DR. LAHEY: I mean I understand the 16 position that there's inherent margin in the ASME 17 code. All right? We do appreciate that. That's 18 from the error data. But now, they have other 19 things going on. I've described some of them.
20 The Fen factor has uncertainty. And I talked 21 about, you know, what the real situation is in 22 the plant versus the autoclave data.
23 There's a lot of things that, in the 24 end, we would like to have some understanding of 25 what the real margin is. If the only thing it is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5616 1 is this 20 cycles, factor 20 on cycles or two on 2 stress, okay, that's where it's known. If 3 there's other things, better yet. But we don't 4 know what it is.
5 CHAIRMAN MCDADE: Dr. Hopenfeld, did 6 you have something to add to that?
7 DR. HOPENFELD: Yes. Just as a note, 8 I took a course from the father of all the ASME 9 code, Dr. Cooper many, many years. One thing I 10 do remember, what he said was that these things 11 are not for modeling the margins that you have in 12 the code off a scanner for materials variability.
13 Some statistical as to how the stresses were 14 counted.
15 They are not for stress concentration 16 factors. They are not for the effect of the 17 environment. They are not to affect for modeling 18 or assumptions or input. This is up to the user.
19 Now according to Entergy, and I can 20 quote it, according to them, because there is a 21 margin there, a factor of two and a factor of 20 22 -- and I think they change it now. But because 23 of those factors, they can go back and the 24 analyst can come up with any model he feels or is 25 in his judgment to use and he will satisfy the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5617 1 code. And that is just not true.
2 There's one example because I was 3 concerned about the effect of it, was the effect 4 of oxygen on the Fen. The Argonne recommended to 5 use a certain value for a reason to which we will 6 later go into tomorrow. They said well, we use 7 this number, the result is too high. So it's too 8 conservative.
9 In other words, the word too 10 conservative is immediate tells you that what are 11 they are doing, they're really shaving the 12 margin. They are trying to get a number that 13 they want to get.
14 So what you want to do to do it in an 15 honest way, you put in your best estimate of what 16 the input is. And in this case, you're supposed 17 to use the conservative value of the input 18 because it's a deterministic method. So you use 19 a conservative value but if the result isn't, you 20 use the result whatever it is.
21 But when they see the result is too 22 high, they just say well, we changed the model.
23 That's what they do. And that's what's wrong 24 about it.
25 CHAIRMAN MCDADE: They're not just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5618 1 changing it. They have to --
2 DR. HOPENFELD: So you can keep on 3 going with it as long as you go back and devise 4 another model. Now stress concentration, for 5 example, there is a definite technical reason why 6 there is a synergy. And what I mean a synergy, 7 that one and one together more than one 8 separately.
9 There is a symmetry between stress 10 energy, stress corrosion cracking and metal 11 fatigue. Both for the initiation part of it and 12 for the propagation part of it. That additional 13 static stress that you have due to stress 14 corrosion cracking reduces the time of destroying 15 the oxide layer. So it needs fixing. But they 16 don't account for that.
17 This is just one example. That can go 18 to the heat transfer too. We started discussing 19 it. We'll get more into it tomorrow about 20 thermal static. Most of the previous that 21 occurred due to thermal fatigue were due to 22 stratification. And they made a lot, all of it 23 is based on models. They had lost but they don't 24 have data for 20 years which is half of a 25 lifetime of the plant.
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5619 1 For the thermal stratification on the 2 pressurized, surge line on the pressurizer.
3 There must be uncertainties. When you have data, 4 you must have some kind of a model to come up 5 with data. You don't have thermal data so you 6 generate something. It's impossible to conceive 7 that there are no uncertainties in this.
8 CHAIRMAN MCDADE: Okay. Thank you Dr.
9 Hopenfeld.
10 JUDGE KENNEDY: One last question 11 maybe for Mr. Gray and I'm trying to this from 12 memory from the discussion this morning. I think 13 we get the point about the code driven margins.
14 And you know, I've been using the term safety 15 margins because those seem to be areas that just 16 aren't touched.
17 There are some modeling assumptions 18 and user inputs that are adjustable. Are there 19 likewise some user inputs, techniques that are 20 applied to calculate the thermal stresses that 21 are also off the table for the user?
22 In other words, the example I'm 23 thinking of that comes to mind when I hear this 24 discussion is the delta T that was applied for 25 the stratification and the way that was done.
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5620 1 Could a user go in and change that? Could they 2 do it differently?
3 I mean, I'm sure they can. But is 4 that sort of thing that's not allowed within the 5 process that you have built at Entergy for Indian 6 Point?
7 CHAIRMAN MCDADE: And if I could add, 8 and if so, what would be necessary to justify it?
9 MR. GRAY: The delta T is an input to 10 the problem. In fact, my earlier example I think 11 might be what you're talking about. Where I 12 could look at the worst temperature difference 13 that could ever occur across the component and 14 use that for all the cycles that could ever 15 occur.
16 But when we know better and we have 17 information that tells us that it's not always 18 that high, then what would be required of the 19 analyst is to justify lower delta Ts for some 20 number of cycles.
21 And for example, that's what I 22 referred to earlier in WCAP 17199. You'll see 23 that, for example, for the charging nozzle.
24 That's what was done. The nature of the design 25 transient, its shape was not changed but those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5621 1 values were. And those were based on a 2 calculation and just a whole development of a 3 methodology that had to be justified and verified 4 by an independent verifier.
5 JUDGE KENNEDY: So the only rock solid 6 margins that we can point to, the untouchables, 7 would be the code based margins? I mean, other 8 than the justification of changing techniques 9 that would have to meet someone's review and 10 approval. I mean, those are all on a case by 11 case basis.
12 MR. GRAY: They are case by case.
13 MR. COX: This is Alan Cox for 14 Entergy. Let me add just a little bit to that.
15 I mean, we're talking about removing 16 conservatisms. We're not removing all of the 17 conservatisms. The analyst that's working for 18 Mark doing these calculations, when he makes 19 these changes to remove excess conservatism, he 20 still has to justify that the result that he has 21 or the input that he ends up with is still 22 conservative.
23 The one exception I can think of to 24 that might be the number of transients. Now you 25 could say we're going to use a best estimate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5622 1 number for transients instead of using the design 2 value. And you might say, well that's a problem.
3 Well it would be a problem except we 4 have a program that's set up to monitor the 5 number of actual transients to make sure that we 6 don't ever go over that number without taking 7 actions to address the situation.
8 So I think, you know, you never get to 9 a point where you've taken all the conservatism 10 out of these estimates. You always end up with 11 a conservative input even though it may not be as 12 conservative as where you started in the initial 13 revision of the calculation.
14 JUDGE KENNEDY: So a check and balance 15 on the reduction in conservatisms is the review 16 of the calculation? And the need for the analyst 17 to prove that the calculation is conservative 18 with the new set of inputs?
19 MR. COX: That's correct. It's 20 incumbent upon the analyst and his reviewer to 21 make sure that those assumptions are justifiable.
22 JUDGE KENNEDY: Are these calculations 23 all done under the Appendix B program for the 24 station?
25 MR. AZEVEDO: Yes, Your Honor. This NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5623 1 is Nelson Azevedo. They're done under -- I can't 2 speak for, I'm sure the Westinghouse methodology 3 is similar to what we have at the site. So all 4 calculations are done under our 10 CFR 50 5 Appendix B program.
6 Mr. Cox stated, they're independently 7 reviewed and they're approved by a supervisor.
8 In addition to that, we have an independent 9 oversight organization. From time to time, they 10 pull these documents and they go through and they 11 verify that everything was done appropriately.
12 And on top of that, the NRC comes on 13 site and audits as well. So it's not just the 14 independent reviewer. It's the approver and the 15 on-site organization and the NRC as well.
16 JUDGE KENNEDY: Thank you. And that 17 brings up an interesting question. Maybe Mr.
18 Stevens, you've heard the back and forth on the 19 reduction of conservatisms and the redoing of 20 calculations or refinement of calculations or 21 whatever word that you want to use. From the 22 staff's perspective, is there any level of 23 discomfort in what you've heard here?
24 MR. STEVENS: No, sir.
25 JUDGE KENNEDY: So maybe to get you to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5624 1 expand a little bit, what raises your comfort 2 level in this discussion?
3 MR. STEVENS: This is Gary Stevens 4 with the staff. So I guess I'll reflect first 5 back to my discussion when I talked about two 6 margins and conservatism. And I said, I'll call 7 it margin one is something that's implicit or 8 explicit in the code and we can't touch it.
9 And margin two is a result of our 10 calculation and that we might be less than the 11 allowable and there's some margin left. And then 12 conservatism is simplifications we may have put 13 into the analysis.
14 And I think the testimony has been 15 pretty clear that nobody can touch margin one.
16 I guess one observation I wanted to make, you 17 know, because I think a lot of the discussion 18 I've heard is we're trying to quantify margins.
19 And in some cases we can do that.
20 I showed you factors of two and twelve 21 on fatigue curves and two and 20. So we can 22 quantify that. Section 3 tends to use a factor 23 of three against ultimate failure. We can 24 quantify that.
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5625 1 to the margin one term that can't be touched.
2 And one example that I'll give is, when you have 3 several transients you're analyzing, how you 4 combine those into paired loads for use in a 5 fatigue calculation.
6 The code is explicit on how you do 7 that and there's conservatism in that process.
8 Because from a designer point of view, you don't 9 know the order of occurrence that these loads may 10 occur in. And the code, the way, the process 11 they use is to take the worst case scenario of 12 how those loads might occur to make a 13 conservative evaluation.
14 So there's other things that go into 15 that margin one term that really can't be 16 quantified but they're explicit in the code 17 methodology. And I tried to allude to that 18 earlier when I talked about margin one and that 19 there are certain design factors as well as 20 explicit instructions in the code that lead to 21 that margin.
22 So I bring that up because what the 23 analysts can change or alter is those things that 24 contribute to margin two and the conservatism.
25 And where I can appreciate the observation that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5626 1 it seems like the analyst has an unlimited 2 opportunity to go back and revisit those, the 3 reality is there's not an infinite opportunity.
4 There were a finite amount of 5 assumptions that the analyst would have built in.
6 An experienced person like myself or some of the 7 other expert witnesses, it would be a function of 8 each analysis.
9 You know, they would look at an 10 analysis and, from their own experience and 11 industry experience and what they know about code 12 analysis, they would come up with a list of those 13 things that contributed to margin two and 14 conservatism such that if they were going to 15 revisit that analysis, they would pick off from 16 that list those things they could do to come up 17 with an acceptable result.
18 The staff doesn't have any discomfort 19 with that process because in the final analysis, 20 we have reasonable assurance, with our knowledge 21 of the code, the processes used, the industry 22 practices that have been adopted, that in the 23 final analysis a CUF or a CUFen of less than one 24 provides reasonable assurance that there's low 25 likelihood of crack initiation.
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5627 1 JUDGE KENNEDY: All right, thank you.
2 I hazard to look to Dr. Lahey. One final closure 3 statement you care to make on safety margins and 4 reduction in conservatisms?
5 DR. LAHEY: Well I think that it's 6 been a good discussion. I find there's great 7 inconsistency in the discussions we had 8 associated with some of the issues I brought up 9 with nodalization, heat transfer coefficient 10 locally, that sort of thing and some other input 11 that we had.
12 They can't both be true. So that's 13 why I want to look at the record a little bit and 14 try to understand what's happening. I mean, if 15 in fact it doesn't matter what the heat transfer 16 coefficient is, there's a lot of people talking 17 about stuff that they don't have to. And a lot 18 of write up on things they don't have to.
19 And why worry about the code going 20 unstable at 8,00 BTU per hour foot square if it 21 doesn't matter? So you know, there's things like 22 that. But by and large, I think it was a 23 reasonable discussion.
24 I want to say again -- I know for the 25 people who have been here all the time, it seems NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5628 1 like a long time now, three days. My overarching 2 concern is not that you just cycle this baby 3 until you get a crack. I mean, that's something 4 we have to worry about.
5 But I'm really concerned about the 6 weakening of the material as you cycle it. And 7 at some point in time, you get a significant 8 shock load which causes failure. And if that 9 leads to a uncoolable geometry, we're in big 10 trouble.
11 So I've merged all my silos with 12 embrittlement, fatigue, and safety analysis. And 13 hopefully, future meetings like this will involve 14 it all. I noticed from day one, our discussion 15 sort of covered everything. And that's a big 16 change from when we started. Where we were told, 17 look that has nothing to do with fatigue. You 18 know, you're talking about embrittlement.
19 So I think we've made some progress.
20 And I think in the right direction. And I 21 appreciate the opportunity to participate.
22 JUDGE KENNEDY: All right, thank you.
23 Dr. Hopenfeld, last words?
24 DR. HOPENFELD: I'd like to make a 25 couple of words regarding conservatism. We can't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5629 1 just talk about conservatism. There must be some 2 kind of a test to see what that really means. I 3 can tell you what it doesn't mean.
4 It definitely doesn't mean that 5 counting the number of that you repeat in your 6 report, that you are conservative almost every 7 second setting, that that is the proof that you 8 are conservative. That is not proof that you are 9 conservative.
10 So I would like to know when they keep 11 on saying that they are conservative, that all 12 their models, all their assumptions, even the 13 over simplified model are all conservative, the 14 inputs they used are conservative and Entergy, I 15 mean NRC agrees with that. I'd like to know 16 where is the test? Where is the verification of 17 that? What's the philosophy behind it that you 18 can show me yes, this is conservative.
19 And the reason it's important, because 20 going back to what I said at the beginning, the 21 CUFen are calculated, that's a deterministic 22 calculation. The ASME requires you, that the 23 burden of proof is on them, not on us. They have 24 to defend it, not just say well, I'm 25 conservative, the analyst thinks that this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5630 1 fine. That is not enough.
2 And as regulations say, you have to 3 verify it. And I don't believe that NRC, from 4 what they have testified here, that they verify.
5 They do not verify it.
6 JUDGE KENNEDY: All right. Thank you 7 Dr. Hopenfeld. Maybe a question for, certainly 8 related to the revision of the CUFen calculation.
9 On Page 66, Dr. Lahey, of your pre-filed 10 testimony which is New York State 530, you raised 11 some concerns with these revised calculations.
12 Two things caught my eye. One is you 13 had concerns related to the use of modified 14 design transients and 60 year projected cycles.
15 I guess first of all, what do you mean by 16 modified design transients? And what's the 17 problem with their usage?
18 DR. LAHEY: I don't actually recall 19 the quote. But I think we did talk about the 20 number of transients and that we have a track 21 record. It seems right to me, if you know what 22 the various transients are, to take advantage of 23 it.
24 But you have to also remember that you 25 have to extrapolate that out for 20 more years.
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5631 1 And so, you can't always tell when you're going 2 to get a scram or some other event like that. So 3 there has to be some margin built in.
4 And I take it from what I've seen, 5 they've tried to preserve that. They've tried to 6 do it.
7 JUDGE KENNEDY: Does it provide you 8 any comfort that they're also monitoring these 9 transients continuously?
10 DR. LAHEY: Yes, that's what I said.
11 I think it's good to take advantage of what's 12 happened historically, monitor it, you know, do 13 a guesstimation of what it's going to be in the 14 future, monitor it and then take whatever action 15 you have.
16 And let me say why. Because we have 17 a couple of components that I'm seriously 18 concerned about. One we talked about that has 19 already gone into the elastic plastic analysis so 20 you're beyond the yield curve.
21 And the other one is your RHR 22 accumulator, low pressure injection, intermediate 23 pressure injection nozzle. So this particular 24 nozzle is, I won't say rapidly approaching one, 25 but darn high in CUF. And if it fails, you not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5632 1 only create a loss of coolant accident, but you 2 knock our your accumulator, you knock our several 3 of your engineering ECC system, emergency core 4 coolant system.
5 If you want to fail something, that's 6 probably the worst thing to fail. And so I think 7 it's very incumbent upon us to make sure we don't 8 push that margin too hard because there's some 9 consequences for those kind of failures.
10 JUDGE KENNEDY: I understand your 11 concern but is not, at least as I understand it, 12 all the current cumulative usage fatigue values 13 at Indian point less than one, project to the end 14 of life today?
15 DR. LAHEY: They are. Some of them 16 are hard to get to. All right? I don't want to 17 say pulling all the tricks out but you've had to 18 do a lot of things to get there.
19 JUDGE KENNEDY: All right, thank you.
20 Another question for you, Dr. Lahey and I think 21 it, well it comes out of your testimony. And I 22 guess we may have to go to Entergy to get the 23 answer. But you raised a question about the FEN 24 values used for two similar reactor coolant 25 system pressure boundary components. That for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5633 1 IP2, they have one value and for IP3, another 2 value.
3 And I think you raised the concern of 4 why that would be. And I guess I don't have an 5 explanation but I'm hoping that Entergy does.
6 DR. LAHEY: Let me tell you my guess 7 and they can tell you what really happened. I 8 think it's part of the game. They found in one, 9 they didn't have to be any lower so they left it 10 what it was and it wound up less than one. On 11 the other one, that wouldn't do it so they did 12 some averaging of strain rate or some other way 13 to reduce it and they reduced it. Maybe I'm 14 wrong, but I think that's just a reflection of 15 this iterative game.
16 JUDGE KENNEDY: I guess --
17 CHAIRMAN MCDADE: Can we substitute 18 part of the analysis for part of the game?
19 DR. LAHEY: What's that?
20 CHAIRMAN MCDADE: Can we substitute 21 part of their analysis?
22 DR. LAHEY: Yes, sir.
23 CHAIRMAN MCDADE: To part of their 24 game?
25 DR. LAHEY: Right. It's so much fun NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5634 1 to do stress analysis, I can tell you.
2 JUDGE KENNEDY: I may not have been 3 clear on my question. I think you pointed to the 4 FEN values for these components. That you 5 indicate they differ substantially and you don't 6 understand why they would between IP2 and IP3.
7 And unfortunately, I didn't write down what this 8 component was. It's on Page 28 of New York State 9 568. Maybe we could look it up. I don't know.
10 Andy, is it something you could put up? 28 of 11 568, New York State.
12 DR. LAHEY: I have to get the -- oh 13 you're going to put it up? Okay. Is that not it 14 Andy, or was it? It's 568 which -- is it Dr.
15 Lahey's supplemental pre-filed testimony on the 16 cover?
17 567 has -- specifically 567, Page 28 18 it makes, for example, for the RHR accumulator 19 nozzle fatigue analysis for IP2, it has a FEN of 20 13.8 and for IP2, 7.79 for IP3.
21 DR. LAHEY: So I gave you my guess as 22 to why but I'd love to hear what the real reason 23 is.
24 MR. GRAY: May I offer an answer to 25 that?
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5635 1 JUDGE KENNEDY: Answers are good.
2 CHAIRMAN MCDADE: We hope so.
3 JUDGE KENNEDY: Go ahead.
4 MR. GRAY: Yes. I think it's a 5 misunderstanding of the value that's in the table 6 in the report. The process that's used to 7 calculate the CUFen is using what the new regs 8 call the modified rate approach. The modified 9 rate approach actually calculates an integrated 10 Fen based on the details of the stress cycle 11 history for every fatigue pair.
12 And so, there's an integration done --
13 and this is described in our WCAP, of how that's 14 performed. There's an integration done for the 15 stress cycle applying the Fen equations for each 16 one of the fatigue pairs that are then summed to 17 give you a cumulative answer.
18 The details of all of that aren't, 19 they're in the calculations but they're not in 20 the final report. So that Fen is an effective 21 Fen that you get from dividing the integrated 22 CUFen that you did with that complicated process, 23 divide that by the CUF before you did that. So 24 that's an overall effective Fen.
25 So when you do that process for the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5636 1 two different units, the inputs for the two units 2 are different. They're a different number of 3 cycles of different transients. Different 4 transients will pair causing different strain 5 rates to be used in those integrated processes.
6 So because they're a different number 7 of cycles of different transients and all of 8 those different fatigue pairs, it's very 9 conceivable that you're going to get a final 10 answer that's different. And then when you 11 couple that with the fact that because the cycles 12 are different, the CUF without the environmental 13 factor, those were also different, that overall 14 effective ratio is going to be different.
15 JUDGE KENNEDY: So it comes down to 16 different transients for the two different 17 plants? Different operating history?
18 MR. GRAY: Yes.
19 JUDGE KENNEDY: Dr. Lahey, does that 20 help?
21 DR. LAHEY: Yes, I understood that.
22 I mean, sort of, I view Fen as an environmental 23 correction factor and it depends on various 24 variables like oxygen content. So I'm not sure 25 how all that is consistent but I understand what NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5637 1 they've done.
2 JUDGE KENNEDY: Thank you.
3 CHAIRMAN MCDADE: Okay. Just a follow 4 up. I mean, on the face of it, it would seem 5 like these two would be relatively close given 6 the relatively similar history of the plants.
7 They would both have the same, basically the same 8 water chemistry program. Although IP2 went 9 online earlier, would have more transients. But 10 wouldn't it, why is the number so different? Mr.
11 Gray?
12 MR. GRAY: Mark Gray for Entergy.
13 This is mostly going to be a function of the way, 14 not only how long the plant ran but the way the 15 plant was operated. And especially on these 16 nozzles, you could have more safety injections, 17 for example, at the beginning in life from 18 testing or whatever other phenomena could happen 19 in the operation of the plant. So yes, these 20 things can be variable from unit to unit.
21 CHAIRMAN MCDADE: Okay. And there 22 would be a sufficient difference in the way the 23 plants were operated to, you know, explain the 24 significant difference or at least the size of 25 the difference between the two?
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5638 1 MR. GRAY: Yes, there could.
2 CHAIRMAN MCDADE: Okay.
3 JUDGE KENNEDY: Entergy, in responding 4 to Dr. Lahey's interest in having an error 5 analysis performed, you responded that the EAF 6 calculation is deterministic and therefore, an 7 uncertainty analysis is not required. What do 8 you mean that the EAF analysis is deterministic?
9 And I'll take anybody.
10 MR. GRAY: Mark Gray for Entergy. The 11 term deterministic is in opposition to a 12 probabilistic method where in probabilistic 13 methods, error analyses are more appropriate and 14 often done. And deterministic approach, as we 15 have already discussed, chooses inputs that are 16 chosen to be conservative inputs to give you 17 conservative outputs.
18 JUDGE KENNEDY: So the uncertainty in 19 various parameters is dealt with by selecting 20 conservative inputs? Is that what you're saying?
21 MR. GRAY: The worst case or bounding 22 value, yes.
23 JUDGE KENNEDY: So by properly 24 selecting conservative inputs, you're suggesting 25 that an error analysis is unnecessary?
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5639 1 MR. GRAY: Yes.
2 JUDGE KENNEDY: Dr. Lahey?
3 DR. LAHEY: Well I think we discussed 4 that in great detail this morning. And 5 hopefully, I allayed their fear that I was not 6 looking for a probabilistic analysis. What's 7 called an error analysis is this propagation of 8 error type of uncertainty analysis that you apply 9 to best estimate or such things.
10 And I gave the example of power equals 11 I square R. So everything's deterministic but it 12 gives you a measure of the uncertainty in the 13 prediction.
14 JUDGE KENNEDY: Do you feel that the 15 approach that Entergy has taken in performing 16 these calculations by using conservative 17 assumptions sufficiently covers the uncertainty 18 in the inputs?
19 DR. LAHEY: No, Your Honor. I still 20 have no clue as to what the margin really is. As 21 they get up very close to unity, I don't know 22 what the margin is compared to a best estimate 23 plus uncertainty. Is it more or less? I mean, 24 are they really where they think they are? Or 25 are they on the other side of the line?
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5640 1 JUDGE KENNEDY: Thank you.
2 JUDGE WARDWELL: Can I interject some 3 additional for Mr. Gray if I might? I believe 4 your quote was, an uncertainty analysis is not 5 required for a deterministic evaluation. That 6 isn't necessarily an error propagation analysis, 7 is it? As was highlighted in our earlier 8 discussions looking at the cartoon that Dr. Lahey 9 had put up.
10 MR. GRAY: Mark Gray from Entergy. My 11 interpretation is that those would be synonymous 12 terms.
13 JUDGE WARDWELL: The error 14 propagation, as was discussed earlier, isn't that 15 almost limited to deterministic analyses? You 16 wouldn't need to do that with a probabilistic 17 uncertainty analysis, would you? It's just the 18 opposite of what you're stating it seems to me.
19 MR. GRAY: I don't see the connection 20 you're making, no.
21 JUDGE WARDWELL: Dr. Lahey?
22 DR. LAHEY: You're correct Your Honor.
23 JUDGE WARDWELL: Thank you. I'm not 24 thanking you saying I'm correct. I just wanted 25 to make sure what your opinion was.
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5641 1 MR. COX: Alan Cox for Entergy. I'd 2 like to add one point. I mean, when we talk 3 about an error analysis, I mean what we're doing 4 with the approach that we're using for these 5 analyses, I want to say we're intentionally 6 introducing errors in the conservative direction.
7 So it's not clear to me how you could 8 get any benefit from an error analysis when 9 you've intentionally not chosen the best estimate 10 values. You have erred on the conservative side 11 in all of your inputs. So what, you know, I see 12 limited value in doing an error analysis when 13 you've intentionally skewed your results in that 14 direction.
15 JUDGE WARDWELL: Well okay. Let's 16 talk about that a bit then. Why couldn't you 17 come up with a best estimate, a best guess of 18 what you think the actual CUF calculation should 19 be? Is there any reason why you couldn't do 20 that?
21 MR. COX: Well I think Mr. Gray talked 22 about that a little bit this morning. It would 23 be a difficult task because of all the --
24 JUDGE WARDWELL: Regardless of the 25 difficulty. I understand why you may not want to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5642 1 do it. I'm interested in, could it not be done?
2 That is taking your best guess at all your input 3 parameters of what truth is.
4 MR. AZEVEDO: This is Nelson Azevedo 5 for Entergy. Yes, Your Honor, you could do a 6 best estimate analysis.
7 JUDGE WARDWELL: So by definition, 8 that best guess is your best guess with what 9 would be taking place there. And those input 10 parameters, even though you still have that, will 11 have some plus or minus associated with that.
12 Would that not be correct in some of the cases?
13 They're not absolutes.
14 MR. AZEVEDO: Well Your Honor, the 15 difficulty comes in how you quantify that. I 16 mean, if you have --
17 JUDGE WARDWELL: I fully understand 18 the difficulty. Don't get me wrong. I'm not 19 saying you should necessarily do this. But I'm 20 countering your testimony that says uncertainty 21 analysis isn't good for deterministic. And that 22 I understand. But I don't think that's the same 23 as an error propagation where it's only limited 24 to basically, deterministic analyses where you're 25 taking the error bars around a parameter input NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5643 1 that you have and then seeing how that 2 propagates. So that you can have an estimate of 3 what is the total plus or minus once you're done 4 through your calculations. And I'm just saying, 5 could not that be done?
6 MR. AZEVEDO: This is Nelson Azevedo 7 for Entergy. Yes, Your Honor, it could be done.
8 Personally, I don't see how that would be 9 different from what we already do which we take 10 the penalty up front by assuming conservative 11 values and then just do it that way. Also, if I 12 may add --
13 JUDGE WARDWELL: Can I? Save your 14 thought because I want to address hat comment 15 first and then give me your next comment.
16 Because you'll lose me and I'm going to put the 17 burden on you to remember what you were going to 18 say rather than me trying to remember when I'm 19 going to ask you a question on your first 20 statement. So I cheat because I've got the 21 gavel. Or he's got the gavel and will let me use 22 it.
23 Isn't the difference that with doing 24 it up front, when you get to the very end and you 25 have a number, you don't know what the plus and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5644 1 minus is around that number. Where if you did it 2 the other way, you would at least have some 3 estimate of what that might be. Would not that 4 be the case?
5 MR. AZEVEDO: That is true. We don't 6 know what the delta. However, what we do know is 7 that whatever that number is, its below what we 8 calculated.
9 JUDGE WARDWELL: Yes. And you know 10 that in both too. But I just, I wanted -- so you 11 do agree that at least there is some difference 12 because you at least have some estimate of that 13 number?
14 MR. AZEVEDO: Yes, I do agree.
15 JUDGE WARDWELL: Now what was your 16 second comment? And I hope you forgot it because 17 then I don't have to worry about it.
18 MR. AZEVEDO: What I was going to say 19 is both the paper that's referenced by New York 20 State on this issue and other papers that I've 21 looked at and on the internet, this idea of 22 propagation of error in similar evaluations are 23 really applicable to random data.
24 Like if you're doing a test, you're 25 collecting a lot of data and you want to analyze NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5645 1 the data. This is definitely appropriate. In 2 this case, I really don't see how that's 3 appropriate.
4 JUDGE WARDWELL: Thank you. That's 5 helpful.
6 DR. LAHEY: Your Honor, that is really 7 incorrect statement. This is not for random 8 data.
9 JUDGE WARDWELL: Do you have a comment 10 on that Dr. Leahy?
11 DR. LAHEY: It's craziness, what you 12 just heard.
13 CHAIRMAN MCDADE: Do you want to 14 elaborate on that Dr. Leahy? You said this is 15 not random data.
16 DR. LAHEY: No. I think the real 17 confusion was -- I mean, I've been asking for 18 what's the uncertainty, what's in their analysis 19 for a long time. And I thought sort of everybody 20 knew what that meant. But apparently not because 21 when I send a reference, a book that we use at 22 university in sophomore level so people know how 23 to treat random data, how to treat deterministic 24 predictions with plus or minus uncertainty.
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5646 1 deal with random data, we do deterministic 2 calculations. So I thought okay, let's try it 3 again. And so finally, you know, I sent them the 4 formula. And so I don't see why they're still 5 thinking it's random data.
6 What I'm talking about is a 7 deterministic calculation. And then you have a 8 process which is called propagation of error.
9 Kline and McClintock goes way back in time, been 10 used for decades. And it will allow you to work 11 out what the plus or minus uncertainty is.
12 It's wide used by experimentalists.
13 That's how you get the error bars on your 14 experimental data. So it has mothing to do with 15 randomness.
16 CHAIRMAN MCDADE: Can you explain in, 17 say a minute or less, what a propagation of error 18 analysis would consist of?
19 DR. LAHEY: I didn't write it. Do you 20 want me to write it?
21 CHAIRMAN MCDADE: No. Just explain 22 it.
23 DR. LAHEY: It's the partial 24 derivatives. You have a function of a bunch, the 25 result is a function of a bunch of variables. So NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5647 1 CUF N depends on a number of things. So you take 2 the partial of CUF N with respect to the first 3 variable times the uncertainty in that. All 4 right? You square it. Plus the partial of CUF 5 N with respect to the next variable.
6 CHAIRMAN MCDADE: And how do you 7 determine the uncertainty in each of these?
8 DR. LAHEY: It depends on what the 9 variable is. You know, depending on the 10 variable, you have information as to the 11 uncertainty.
12 For example, if you did a best fit 13 calculation, one of the parameters you'd have in 14 there would be the Dittus-Boelter correlation.
15 The Dittus-Boelter correlation has a plus or 16 minus uncertainty of 25 percent. So that would 17 be what you'd use there.
18 You go to the next variable that 19 they're using. What's your uncertainty in flow 20 rate, et cetera, et cetera. And you add them all 21 up and then you wind up with this final estimate 22 of the uncertainty. That's wide used.
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5648 1 there's another formula which has second 2 derivatives we could talk about. But this, I 3 think, would be a very useful exercise because 4 for the first time, we can see how they, where 5 they are when they're up against the limit.
6 Is there significant margin? If that 7 error bar is below the limit line, I for one am 8 pretty comfortable.
9 CHAIRMAN MCDADE: Okay. To Entergy, 10 in light of the way Dr. Lahey just explained the 11 propagation of error analysis as he understands 12 it and believes that it's documented. What does 13 that, what is random data? How does that fit in 14 or affect that?
15 MR. AZEVEDO: Well Your Honor, this is 16 Nelson Azevedo for Entergy. The basis for my 17 statement is New York State 347, Page 311. And 18 in the middle of the page, it says propagation of 19 error formulas. For 5.58, 5.59 and the box 20 starts, if X, Y, and Z are independent, random 21 variables and G is well behaved. So that's where 22 it comes from, from New York State Exhibit 347.
23 DR. LAHEY: So maybe I shouldn't have 24 used the word random. They're independent 25 variables. They're uncorrelated variables is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5649 1 what I meant.
2 CHAIRMAN MCDADE: Okay. But the 3 question is, in a deterministic analysis, why is 4 Entergy not doing a propagation of error 5 analysis?
6 MR. AZEVEDO: This is Nelson Azevedo 7 again. Again Your Honor, because we feel that 8 the conservative assumptions that we're making by 9 assuming conservative values bounds the problem 10 that we're solving. So doing a -- personally I, 11 maybe somebody else in the Entergy panel can 12 speak to.
13 But personally, I don't know how to 14 calculate these kinds of errors in a 15 deterministic manner. I know in a probabilistic 16 manner.
17 MR. STROSNIDER: This is Jack 18 Strosnider for Entergy. I have some experience 19 in performing probabilistic assessments of 20 structural integrity issues. So my perspective 21 on this -- and I think there may be some 22 semantics here.
23 But I think in the first case, when 24 you talk about a propagation of error analysis, 25 as Dr. Leahy said, that's typically the way NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5650 1 experimentalists, that's what they talk about 2 doing. And it has to do with measuring. All 3 right? Measurement errors and the various, the 4 variables in an experiment that you're measuring 5 and how you propagate those errors through the 6 measurements.
7 If you want to look at a structural 8 analysis from an uncertainty point of view, what 9 you would do is a probabilistic assessment which 10 means that each variable in the analysis, you 11 treat as a random variable and then you put 12 together a distribution.
13 And that's one of the challenges here, 14 is if you really want to do an uncertainty 15 analysis on a structural evaluation, you need a 16 distribution. You need to know the shape of the 17 distribution, you need to know the parameters of 18 the distribution. And then you can go -- and you 19 need to know their dependencies, if there are 20 any.
21 Then you can go through and you can do 22 an analysis. And when you want to understand the 23 uncertainty in that, you do that by performing 24 sensitivity studies and by doing calculations, 25 for example, to look at confidence intervals NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5651 1 based on the amount of data that you have and 2 those sort of things.
3 It's a very sophisticated analysis, 4 not easy to do, to collect all that information 5 and do it properly. Now when you look at the 6 deterministic analysis, you're taking each one of 7 those random variables, you're making an 8 assumption about what that variable is.
9 Typically and as explained in this 10 case, a conservative assumption. And you run 11 your analysis with that. One insight I want to 12 share is that what you typically find, any time 13 you compare deterministic analysis with a true 14 probabilistic assessment where you assess the 15 uncertainties.
16 If you look at, for example, a 9595 17 confidence level on an outcome from a 18 probabilistic assessment of a structure, it is 19 almost always lower than the numbers that you get 20 when you do the deterministic analysis and assume 21 all those bounding values.
22 When you assume all the founding 23 values as they're doing in these analyses, you 24 come out with things that are very, very high 25 confidence levels, 9999 kind of stuff which, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5652 1 know, typically what's used in these in these 2 structural evaluations is 9595. That's what the 3 NRC has found as acceptable.
4 So I don't know if that helps. But I 5 think that's the range of the type of analyses 6 that you can do. There's no -- to come back to 7 doing this sort of uncertainty analysis which 8 would probably be the more appropriate. You 9 know, if you were going to do something, that 10 would probably be what you want to do.
11 First of all, there's no requirement 12 for it. The experience shows that when you do a 13 deterministic analysis with bounding values, that 14 you're going to come out with higher confidence 15 levels than you would by doing the random, you 16 know, the random probabilistic assessment.
17 And I just want to come back one more 18 time to re-emphasize that the margins that are 19 established in the regulations and the margins 20 that are established in the ASME code, those 21 things are not put in there lightly. All right?
22 There's a lot work. The ASME code is 23 a consensus code. You've got some of the best 24 people in the country. You've got the NRC 25 participating. And they're looking to put the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5653 1 right levels of conservatism in those 2 evaluations. And the NRC doesn't put it into 3 regulations until they have it there.
4 So I don't know if that's helpful.
5 But like I said, I've done probabilistic risk 6 assessments on pressure vessels and piping and 7 steam generator tubes. You know, when you do the 8 deterministic analysis, it comes out with a 9 higher confidence level than these other types of 10 evaluations. That's what you typically find.
11 CHAIRMAN MCDADE: Okay. And Dr.
12 Lahey, as I understand what your concern here is, 13 is that in the absence of a propagation of error 14 analysis, it's not possible to quantify with any 15 degree of certainty, the margin of error. And 16 that therefore, you are not sanguine that the 17 conservatives built in are adequate to ensure, 18 provide reasonable assurance with regard to the 19 continued viability of the component. Is that 20 correct?
21 DR. LAHEY: Yes. What I'm looking for 22 -- yes sir, it's correct. I'm looking for some 23 indication that the margin that they think is 24 there is really there. This is one idea to do 25 it. I don't disagree you can do a more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5654 1 sophisticated analysis. But that isn't what I 2 think we need to do here.
3 Rather, I think we should assume, in 4 the best estimate, the ASME code is there. All 5 right? So you take care of that there. Same in 6 your limit line. And then all the other 7 parameters that affect the CUF end, those are 8 things that you can get either analytically with 9 the derivatives or numerically by running it with 10 different ones and dividing it by the same and 11 you get the numerical derivative. All right?
12 It's a very doable thing and it would 13 give a lot of confidence in terms of where we're 14 at.
15 CHAIRMAN MCDADE: And Mr. Azevedo, as 16 I understand the position of Entergy is that 17 given the margins that are built into the code 18 and given the conservatives that are also present 19 in your analysis, that you are satisfied that 20 even with these adjustments, there are sufficient 21 margins and conservatives left that were not 22 close to falling out of, you know, that they 23 still provide reasonable assurance. And they do 24 it by, with a significant degree of reliability.
25 MR. AZEVEDO: Yes Your Honor, I agree NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5655 1 with that.
2 CHAIRMAN MCDADE: That's your 3 position?
4 MR. AZEVEDO: Yes it is.
5 CHAIRMAN MCDADE: Okay. And Dr.
6 Hiser, Mr. Stevens, what's the view of the NRC 7 with regard to this?
8 MR. STEVENS: This is Gary Stevens of 9 the staff. I think I can point you to a couple 10 things in our testimony and in the exhibits 11 that'll help out with this. First I'll say that, 12 you know, the code approach that's being used to 13 calculate CUF is not unique to that.
14 There are many other integrity 15 evaluations that are done using code throughout 16 the regulation that are consistent. And the 17 intent is to use bounding values of inputs that 18 lead to very conservative results. That's the 19 definition of a deterministic evaluation.
20 I support the testimony regarding 21 probabilistic. But if I go with the flow here, 22 and I think what I'm hearing is what happens if 23 I tweak some of the inputs in the analysis? How 24 much does it affect the analysis?
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5656 1 earlier in response to Dr. Wardwell's question, 2 yes it's possible to do that. It's very 3 difficult but it's possible. And in fact, over 4 the course of the history of the industry, there 5 have been some attempts to do that.
6 I'm going to refer you to our 7 testimony, Answer 163 on Page 177 of NRC 168. As 8 you can imagine, some of these analyses get quite 9 complicated. And the number of inputs you could 10 potentially adjust for best estimate is large.
11 Our testimony here talks about 12 adjusting one of the those which is the input 13 loading. There's been many studies and we point 14 out one, or actually two here, that looked at 15 instead of using bounding design basis 16 transients, what's the effect on CUF if we use 17 best estimate transients like those actually 18 experienced in a plant?
19 And so, if you will, the analysis 20 that's cited here which is in NRC Exhibit 175.
21 It's a 1973 pressure vessel and piping technical 22 paper. That was an example of analysis that 23 looked at, if all I did in the evaluation was to 24 change the transient definitions to best 25 estimate, what happens?
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5657 1 And what's been shown for more than 30 2 years now throughout the industry, that has a 3 very overwhelming effect on CUF. It drops by as 4 much as two orders of magnitude. What you get 5 from these studies -- and there was also some in 6 new Reg CR6260. I don't have the exhibit number 7 for that off hand. It is one of the exhibits.
8 Similar things were done where they 9 looked at not only transient severity, but some 10 other inputs. And I'll put it in, they looked at 11 best estimate type adjustments to those. And 12 what you conclude from this wealth of experience 13 is that when you look at best estimate 14 evaluations of CUF, it drops substantially, if 15 you will, the delta bar down from what we're 16 calculating is orders of magnitude.
17 And what you conclude from those is 18 that the calculations we're doing are very, very 19 conservative. And if we were to go down the path 20 of doing an error propagation analysis, we in 21 fact would show that we have is very 22 conservative.
23 So I would direct you to our testimony 24 there. And that is just one example of how the 25 industry has looked at best estimate types of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5658 1 estimates of CUF and the impact of that and what 2 those errors might be.
3 CHAIRMAN MCDADE: Okay. Thank you Mr.
4 Stevens.
5 JUDGE KENNEDY: All right, thank you.
6 Moving on a bit, moving away from uncertainties 7 and margins. I have a couple questions for Dr.
8 Hopenfeld. On Page 4 of your pre-filed testimony 9 which I believe is Riverkeeper 142, you raised 10 concerns about failing to consider the impact of 11 dissolved oxygen in the refined fatigue 12 evaluations.
13 First of all, is this in regard to the 14 environmental assisted portion of the 15 calculation?
16 MR. HOPENFELD: Yes, in regard to the 17 calculation of the Fen.
18 JUDGE KENNEDY: Relative to the Fen?
19 Is that what you said?
20 MR. HOPENFELD: The Fen, yes.
21 JUDGE KENNEDY: It appears to me that 22 the equations that Entergy's used for adjusting 23 for environmental factors accounts for dissolved 24 oxygen. Do you agree with that?
25 MR. HOPENFELD: No.
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5659 1 JUDGE KENNEDY: And why don't you 2 agree?
3 MR. HOPENFELD: The equation they're 4 using I agree. But how they use the equation, I 5 don't.
6 JUDGE KENNEDY: Okay. So the equation 7 is capable of accounting for dissolved oxygen?
8 MR. HOPENFELD: Oh sure.
9 JUDGE KENNEDY: Is that what you're 10 saying?
11 MR. HOPENFELD: Yes.
12 JUDGE KENNEDY: But Entergy, in their 13 calculations are not properly accounting for the 14 dissolved oxygen?
15 MR. HOPENFELD: That's correct.
16 JUDGE KENNEDY: And why is that?
17 MR. HOPENFELD: Okay. This is an 18 important subject and I feel that, from the 19 testimony that Entergy provided and NRC, they 20 don't understand how that Fen was obtained. So 21 give me a minute or second just to go through it.
22 These tests were conducted in the 23 little autoclave, like 20 gallon, little system 24 where the water was circulating. The 25 measurements temperature, the measurement of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5660 1 oxygen were extremely accurate. They were taken 2 all the time. They knew exactly what happens at 3 the surface with the oxygen.
4 So when the measurements of oxygen was 5 taken, that reflected what happened with oxygen.
6 Because this was a very small, small tiny little 7 system. The water was pure, everything was 8 clean, everything was known. And imagine if 9 there were billions. They're not using 10 continuous online but almost continuous online 11 measurements.
12 Now what they said, what Entergy says 13 or it's their perception that the Fens, as they 14 were generated in these little tests, are 15 directly applicable to the reactor system.
16 Because everything in the Fen that was measured 17 is really is directly applicable to the coolant 18 chemistry of the reactor. And this is absolutely 19 not true.
20 Again, what you are measuring, what 21 you're supposed to do in calculating the Fen, 22 you're supposed to put as specified by Argonne --
23 and they know what's involved in them, they ran 24 the test. They know what you have to do.
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5661 1 calculate, you have to put it into the equation 2 the -- for carbon steel you have to put the 3 maximum oxygen during the transient. For 4 stainless steel, you have to put the minimum 5 oxygen you extract.
6 Now, they realized that we don't know 7 that. There's no mention of it. Nobody sits 8 there. In the plant, you measure the oxygen in 9 the bulk, sometimes for the sampling, which also, 10 you have to have a lot of correction. You do it 11 maybe once a week. I don't know how often they 12 do it but they don't do it during the transients.
13 So what Argonne has done and EPRI too, 14 they specified look, if you don't know what it 15 is, here's a guideline, use Form 4. And Entergy 16 looks at it and said, .4, I get numbers larger 17 than one if I use that. That is too 18 conservative.
19 In other words, what I'm saying, when 20 they talk about conservatism, they're not talking 21 about conservatism. They're talking a number 22 that they can adjust. And they're going to quote 23 something conservative that's not conservative.
24 The number they get to find an answer they want.
25 Now Argonne was very specific as to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5662 1 what number should be used during the transient.
2 EPRI was very specific. And they said no, we 3 don't have to worry about that because all we 4 have to do is use the steady state concentration 5 during the transient.
6 But this has nothing to do with what 7 happens at the surface. It's completely two 8 different animals. Furthermore, now somebody at 9 Westinghouse probably understood the problem.
10 And what he did and he realized it -- and from my 11 testimonies, I think other people in the country 12 realize the problem.
13 It's not a simple thing to do, the way 14 they are rationalizing it. What the person from 15 Westinghouse -- I spent three or four pages on 16 that. They said, look we know oxygen gets into 17 the system during the heat up period. And when 18 it gets in there, however, look at the equation.
19 The equation, it doesn't matter. In 20 other words, he's saying and then he calls down 21 and say, well the equation says that if the 22 oxygen -- when it gets in there, that a 23 temperature of 150 then the term in the 24 exponential cancels out and it doesn't matter.
25 And this is true.
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5663 1 But then he says it doesn't matter.
2 He says well but, we have proven an assumption.
3 Because originally, they made an assumption that 4 oxygen is .05. What they said that we have 5 proven with this equation that oxygen in the 6 plant is .05.
7 That's equivalent to saying that you 8 can have some equation that was the Fen equation 9 that was done in laboratory as predicting its own 10 input. That's exactly what it says. And then 11 they extended that to the case that where they 12 applied zero oxygen throughout the transients.
13 Now I have asked, we've asked for the 14 last four or five years, please give us data on 15 the transients during the heat up and cool down.
16 We never got the answer. And I know there is 17 such a thing because EPRI produced such data for 18 BWRs.
19 And you can see that during the 20 transient, the oxygen changes by orders of 21 magnitude as the temperature changes. Now the 22 first criticism that we got was, well this is not 23 up to us because this is high oxygen, this is 24 BWR.
25 It was the principle that I was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5664 1 showing. During the transients, things change.
2 Argonne, EPRI, all specified you have to account 3 for oxygen during the transient and you have to 4 use the maximum value. Well they say now the 5 maximum value is .005 which is the steady state 6 value. But that has nothing to do with the 7 transient.
8 Now I don't know the physics of it, of 9 oxygen mechanism during the transient for a 10 particular component. This is not, I hope so, 11 this is not a tiny little system about that size.
12 In comparison, it's smaller than that. But you 13 can get and you can see everything.
14 You're measuring and you say, well 15 that's what's going to happen somewhere in the 16 reactor vessel. These are two different animals.
17 And they keep coming back to it and using .005 in 18 the calculations. So when I put the number of .4 19 ppm which Argonne recommended, it's not my 20 number. I cannot put a factor of five on the Fen 21 which translates the factor and the CUF.
22 So you see, when I was telling you 23 this morning that uncertain in the Fen which is 24 a factor of three. That's just inherent 25 uncertainty of expressing the experimental data.
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5665 1 That's all it is. That's in there, you can't get 2 away from that.
3 In addition to have, you have these 4 input calculations. Now if you go back -- if 5 they want to do a deterministic analysis, do you 6 say, look I don't know what the oxygen is but 7 it's my responsibility to look at the end point.
8 No matter what, even if I don't know, if you 9 would happen to describe it, I have to use .4.
10 That's what they're telling me that's an end 11 point.
12 But the person from Entergy looked at 13 it and said oh we're not going to use that, 14 that's too conservative. So you see, they choose 15 what conservatism that goes back to the modeling.
16 JUDGE KENNEDY: So Dr. Hopenfeld, your 17 concern is they're not using a proper transient 18 based dissolved oxygen content?
19 MR. HOPENFELD: I am concerned that 20 during the transient, they should be using, 21 during the transient they should not be using the 22 steady state value of .005. They should be using 23 the number that was specified by Argonne, the 24 people who designed and ran these experiments.
25 That's what they should be using instead of just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5666 1 I will use something that, theoretically, it was 2 calculated that we are running, that the reactor 3 runs at .005 during the transient. That's just 4 not true.
5 JUDGE KENNEDY: So the recommendation 6 of EPRI and the Argonne people is to use .4?
7 MR. HOPENFELD: Correct.
8 JUDGE KENNEDY: For this parameter if 9 you don't know the transient values?
10 MR. HOPENFELD: Yes. Take a look at 11 NUREG-6905. Hopefully I remember this, at 85.
12 Okay. 6909, I'm sorry, at A5.
13 JUDGE KENNEDY: Page 85?
14 MR. HOPENFELD: A5. A, it's Appendix 15 5 on the bottom.
16 JUDGE KENNEDY: All right, thank you.
17 Entergy, do you have a response to the transient 18 issue here, the issue with the transient 19 dissolved oxygen?
20 MR. COX: This is Alan Cox. Let me 21 start out and some of my colleagues may want to 22 jump in here. But the first point I'd like to 23 make is we're not using the steady state value.
24 We're using a value that is an order of magnitude 25 higher than the steady state value.
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5667 1 The normal operating concentration is 2 .005 ppm, five ppb. And the threshold in the 3 equation that we're using is .05. So it's an 4 order of magnitude higher than our normal 5 operating concentration. And we've not seen 6 anything to indicate that, during a transient, 7 that oxygen spontaneously appears in the system 8 in such a way that it increases by an order of 9 magnitude to where it would exceed that 10 particular threshold.
11 JUDGE KENNEDY: Is it possible to 12 measure the dissolved oxygen during a transient?
13 I mean, is this being monitored continuously?
14 Would the system be able to pick up that 15 difference?
16 MR. COX: It's monitored at a point.
17 I don't know that we see any changes during 18 transients. It's monitored at one point in the 19 system. The other I'd like to point out, there's 20 a difference in BWRs and PWRs here.
21 In a PWR, you run with a hydrogen over 22 pressure so that scavenges the available oxygen.
23 That's what allows us to keep the numbers as low 24 as they are. In a BWE, your primary system goes 25 into, turns into steam, goes through the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5668 1 condenser. You can't fill your condenser with a 2 bunch of non-condensable hydrogen gas. So you 3 don't have that ability to control oxygen with 4 hydrogen.
5 So it's a completely different 6 scenario. In the BWR world, there is an EPRI 7 program that's used to calculate the oxygen at 8 different points in the system. Because it does 9 change much more drastically than it does in a 10 PWR.
11 JUDGE KENNEDY: Anything from anyone 12 else on the Entergy side?
13 MR. AZEVEDO: This is Nelson Azevedo.
14 Just to add to your question, Your Honor. We 15 monitor the oxygen about ten times a day.
16 They'll have a data sheet here in front of me.
17 I guess we could monitor more often but that's 18 how often we monitor now. So it's monitored 19 pretty often and we have actual values.
20 JUDGE KENNEDY: Do the values display 21 much variation through the day? This is an 22 example.
23 MR. AZEVEDO: No. They're obviously 24 different when we are shut down. But once we 25 start up, we add the hydrogen and the hydrazine NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5669 1 to the primary side which essentially scavenges 2 all the oxygen. And then from there on, until we 3 open up the system again as Mr. Cox said, it's 4 about five ppd.
5 JUDGE KENNEDY: How would --
6 CHAIRMAN MCDADE: Is this all part of 7 that water chemistry AMP we discussed the other 8 day?
9 MR. AZEVEDO: That's correct.
10 JUDGE KENNEDY: If I understand what 11 Dr. Hopenfeld's saying, there's a recommendation 12 on the table from EPRI or Argonne or both that 13 indicates if you don't know the dissolved oxygen 14 during a transient, a value of .4 would be 15 applicable. Is this a case that's, should you be 16 using .4 for Indian Point?
17 MR. AZEVEDO: This is Nelson Azevedo 18 again. Mr. Gray or somebody can jump in. That 19 is when you don't have actual numbers. We have 20 actual numbers, measured numbers. And again, as 21 Mr. Cox said, during a transient, oxygen does not 22 spontaneously generate in the reactor coolant 23 system.
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5670 1 than what we're measuring.
2 JUDGE KENNEDY: Mr. Gray?
3 MR. GRAY: This is Mark Gray for 4 Entergy. The reference in new reg CR6909 on Page 5 A5 says that the dissolved oxygen values obtained 6 from each transient constituting the stress cycle 7 for carbon and low alloy steels, the dissolved 8 oxygen content, DO, associated with the stress 9 cycle is the highest oxygen level in the 10 transient, et cetera.
11 That last sentence says a value of .4 12 ppm for carbon and low alloy steels and .05 ppm 13 for Austenitic steels can be used for the DO 14 content to perform a conservative evaluation. So 15 that implied that when you don't know the value, 16 when you have nothing to go by, that's the 17 conservative input to the equation.
18 They operate the plant according to a 19 spec that gives a maximum value for dissolved 20 oxygen. And I won't reiterate what these 21 gentlemen have already said.
22 The other important thing to recognize 23 though that may have been mischaracterized is the 24 new regs from Argonne have repeatedly said, not 25 just 6909, that in order to have this NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5671 1 environmental effect, that you have to have a 2 combination of the parameters to be above their 3 threshold limits to have this environmental 4 effect.
5 We refer to that in our answer --
6 sorry, I have to put my glasses on. On our 7 answer 184 in our testimony. In new reg CR6815, 8 for example, that's Entergy 225 where the new reg 9 says that it's the product of the transformed 10 strain rate oxygen and temperature values is 11 based on experimental data.
12 And we quote that new reg that says 13 it's significant. The environmental factor is 14 significant only when four conditions are 15 satisfied simultaneously. When the strain 16 amplitude temperature and dissolved oxygen and 17 water are above certain threshold values, and the 18 strain rate is below a threshold value.
19 So going back to the point that was 20 made before, when the temperature is below it's 21 threshold value, even if I use this maximum DO 22 value, the Fen is still at its threshold value.
23 The equation that they've given us to use in the 24 new reg reinforces this statement that is made in 25 the new reg.
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5672 1 That unless the product of those 2 parameters is non zero, I don't get a higher Fen.
3 JUDGE KENNEDY: Thank you. Maybe Mr.
4 Stevens or someone from the NRC, any concerns 5 with the application of the dissolved oxygen 6 factor for Indian Point?
7 MR. STEVENS: This is Gary Stevens for 8 the staff. No, Your Honor. In general, I agree 9 with what Entergy has testified and how they 10 characterized the statement in new reg CR6909.
11 JUDGE KENNEDY: All right, thank you.
12 Dr. Hopenfeld, the final word?
13 MR. HOPENFELD: My final word is that 14 they disregard the guidelines that both -- the 15 NPR47 I believe.
16 JUDGE KENNEDY: Could you say that 17 again? I missed that last --
18 MR. HOPENFELD: NPR 47, it's EPRI 19 guidelines also indicated that you have to input 20 into your equation the maximum oxygen, the oxygen 21 during the maximum -- the maximum amount of 22 oxygen during the transient.
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5673 1 about. The oxygen during the transient is not 2 what they are talking about.
3 Again, I was going back to this little 4 test. That little test is a measure value of 5 oxygen that really happens at the surface. He's 6 talking about adding hydrazine as a catalyst.
7 You have tons and tons of material. You've got 8 all kind of reactions going on in there. You 9 don't know what it is.
10 You cannot use this analytical 11 equation to tell me that it predicts what the 12 oxygen is in the plant. That's what they say.
13 MR. STEVENS: Your Honor, may I?
14 JUDGE KENNEDY: Go ahead Mr. Stevens.
15 MR. STEVENS: Gary Stevens, NRC staff.
16 I'll comment on NRP47 because I was a co-author 17 of that document. And I'll just say that in 18 there, there are some guidelines for treating 19 dissolved oxygen on a time averaged approach.
20 And I'll just say that from the testimony I've 21 heard and read, that Entergy's approach is 22 consistent with that.
23 Second thing, I think we need to 24 correct a few things for the record that were 25 stated here. I had some difficulty understanding NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5674 1 Dr. Hopenfeld but there was a lot of discussion 2 regarding the experimental set ups that Argonne 3 National Laboratory used to collect this 4 information.
5 And I heard some mention that 6 dissolved oxygen was measured at the surface of 7 specimens and its relevance or lack thereof to 8 components. And that's not true. One of the --
9 in New York State 356, there's a good discussion 10 of the experimental setup and tests in Section 2 11 of new reg CR6583 which is New York State Exhibit 12 356.
13 And what you'll see in there very 14 clearly is that, that would be a very difficult 15 achievement to measure dissolved oxygen at the 16 surface of a component. It's measured, the bulk 17 dissolved oxygen content of the fluid in the 18 circuit is measured in those tests. There's a 19 figure that shows that in that section and a nice 20 write up on how those tests are conducted.
21 And that's entirely consistent with 22 how dissolved oxygen measurements are taken in 23 the plant. So there shouldn't be any concerns 24 about inconsistencies with dissolved oxygen 25 measurements between test setups and plant NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5675 1 measurements.
2 JUDGE KENNEDY: All right. Thank you 3 Mr. Stevens.
4 CHAIRMAN MCDADE: It might be 5 appropriate, we're approaching 6:00, we've been 6 going for a while. It might be appropriate to 7 break until tomorrow morning. I would propose 8 that we start at 8:30. Does that pose any 9 problems?
10 MR. HARRIS: No, Your Honor.
11 MR. SIPOS: No, Your Honor.
12 MR. ROTH: No, Your Honor.
13 CHAIRMAN MCDADE: Okay. I believe we 14 had one homework assignment. I guess Mr. Gray 15 identifying documents about the way Entergy's 16 WESTEMS handles the coupling, thermal couple 17 data.
18 DR. LAHEY: I understand that to mean 19 how we treated the thermal couple data in the 20 development of the transients.
21 CHAIRMAN MCDADE: Okay. That said, we 22 are in recess until 8:30 tomorrow morning. Thank 23 you.
24 (Whereupon, the above-entitled matter 25 went off the record at 5:45 p.m.)
NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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