ML15338A227
| ML15338A227 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 11/19/2015 |
| 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 28614 | |
| Download: ML15338A227 (220) | |
Text
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Station Docket Number: 50-247-LR and 50-286-LR ASLBP Number: 07-858-03-LR-BD01 Location: Tarrytown, New York Date: Thursday, November 19, 2015 Work Order No.: NRC-2016 Pages 5676-5894 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
5676 1 UNITED STATES OF AMERICA 2 U.S. NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5 + + + + +
6 ________________________________
7 In the Matter of: : Docket No.
8 ENTERGY NUCLEAR OPERATIONS, INC. : 50-247-LR 9 (Indian Point Nuclear Generating : 50-286-LR 10 Station, Units 2 and 3) : ASLBP No.
11 ________________________________ : 07-858-03-LR-BD01 12 13 Thursday, November 19, 2015 14 15 Doubletree Tarrytown 16 Westchester Ballroom 17 455 South Broadway 18 Tarrytown, New York 19 20 BEFORE:
21 LAWRENCE G. MCDADE, Chairman 22 MICHAEL F. KENNEDY, Administrative Judge 23 RICHARD E. WARDWELL, Administrative Judge 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5677 1 APPEARANCES:
2 3 On Behalf of the U.S. Nuclear Regulatory 4 Commission:
5 DAVID E. ROTH, ESQ.
6 SHERWIN E. TURK, ESQ.
7 BRIAN HARRIS, ESQ.
8 of: U.S. Nuclear Regulatory Commission 9 Office of General Counsel 10 Mail Stop 15 D21 11 Washington, D.C. 20555 12 david.roth@nrc.gov 13 sherwin.turk@nrc.gov 14 brian.harris@nrc.gov 15 301-415-2749 (Roth) 16 301-415-1533 (Turk) 17 301-415-1392 (Harris) 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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5678 1 On Behalf of Entergy Nuclear Operations, Inc.:
2 KATHRYN M. SUTTON, ESQ.
3 PAUL M. BESSETTE, ESQ.
4 RAPHAEL RAY KUYLER, ESQ.
5 of: Morgan, Lewis & Brockius, LLP 6 1111 Pennsylvania Avenue, NW 7 Washington, DC 20004 8 202-739-5738 (Sutton) 9 202-739-5796 (Bessette) 10 202-739-5146 (Kuyler) 11 ksutton@morganlewis.com 12 pbessette@morganlewis.com 13 rkuyler@morganlewis.com 14 15 On Behalf of the State of New York:
16 JOHN J. SIPOS, ESQ.
17 LISA S. KWONG, ESQ.
18 MIHIR A. DESAI, ESQ.
19 of: New York State 20 Office of the Attorney General 21 Environmental Protection Bureau 22 The Capitol 23 Albany, New York 12224 24 brian.lusignan@ag.ny.gov 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5679 1 On Behalf of Riverkeeper Inc.:
2 DEBORAH BRANCATO, ESQ.
3 of: Riverkeeper, Inc.
4 20 Secor Road 5 Ossining, New York 10562 6 800-21-RIVER 7 info@riverkeeper.org 8
9 On Behalf of Westchester County:
10 CHRISTOPHER INZERO, ESQ.
11 Assistant County Attorney 12 of: Westchester County Government 13 148 Martine Avenue 14 Room 600 15 White Plains, New York 10601 16 914-995-2000 17 18 On Behalf of Westinghouse Electric Company:
19 RICHARD J. COLDREN, ESQ.
20 of: Westinghouse Electric Company 21 1000 Westinghouse Drive 22 Cranberry Township, Pennsylvania 16066 23 412-374-6645 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5680 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:33 a.m.)
3 CHAIRMAN McDADE: Please be seated. The 4 hearing will come to order. Before we get started 5 with testimony, are there any administrative matters 6 to be taken up by the staff?
7 MR. HARRIS: No, Your Honor. This is 8 Brian Harris for the staff.
9 CHAIRMAN McDADE: Entergy?
10 MR. KUYLER: No, Your Honor.
11 CHAIRMAN McDADE: New York?
12 MR. SIPOS: Not at this time, Your Honor.
13 CHAIRMAN McDADE: Riverkeeper?
14 MS. BRANCATO: No, Your Honor. Thank you.
15 CHAIRMAN McDADE: Okay. Lets continue 16 with the taking of testimony with regard to Contention 17 26.
18 Judge Kennedy.
19 JUDGE KENNEDY: Yeah, this is Judge 20 Kennedy. I have just a couple follow-up questions on 21 Contention 26 first to Dr. Hopenfeld.
22 DR. HOPENFELD: Yes, sir.
23 JUDGE KENNEDY: Microphones at the ready?
24 DR. HOPENFELD: Can you hear me okay?
25 JUDGE KENNEDY: Thank you.
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5681 1 DR. HOPENFELD: Can you hear me, sir?
2 JUDGE KENNEDY: I can hear you. Thank 3 you.
4 DR. HOPENFELD: Okay.
5 JUDGE KENNEDY: In your pre-filed 6 testimony, you assert that Entergy relied improperly 7 on CUF values of record.
8 What do you mean by CUF values of 9 record?
10 DR. HOPENFELD: Okay. What I meant to 11 basically the term came from the LAR. Thats the term 12 they used in those tables, but what I mean -- what it 13 means -- what I think what it means is the CUF that 14 was calculated during the design stage. Thats the 15 CUF that the CLB is based on.
16 JUDGE KENNEDY: And why is that improperly 17 relied on?
18 DR. HOPENFELD: Because as we heard the 19 testimony yesterday, and I was trying to inject my ---
20 interject on here, is that -- the original plants were 21 designed, the --- when you calculated --- you assume 22 a certain number of changes. And in most of the 23 cases, not in all cases, some place the assumption 24 about the transients were not conservative, but I 25 believe in most case it was conservative.
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5682 1 But in addition to the number of changes 2 that you assume, you also calculate the stresses, but 3 you use the ASME code. And we have had a lot of 4 confusions --- confusing statements from Entergy about 5 the subject, but in -- the code has margins, has 6 allowances. It does not have an allowance for stress 7 concentration. It is you that you provide the stress 8 concentration.
9 Now, if you were designing the plant 40 or 10 50 years ago, and you go into one of the Pen books or 11 Peterson or something, got thousands and thousands of 12 different stress concentrations for different 13 geometries, because its a very common engineering 14 parameter that you have to use in any design.
15 Just to get you a feel for what Im 16 talking about, in my younger days, I remember, they 17 used to have razor blades that had three holes in 18 them. Now, these razor blades used to break all the 19 time. The reason was because theres a lot of stress 20 concentration in those holes. So, what they did, they 21 did away with the holes and they had a slot in there 22 and they put a stop to the breaking. Thats where the 23 stress concentration is a notch.
24 Every weld has one, because there is a 25 difference in the metal composition between the base NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5683 1 weld and what you --- and the welding material. So, 2 stress concentration, an extremely important 3 parameter. Now, when they designed, originally, the 4 stress concentration was used, did not take in effect 5 --- in account effects like corrosion, which affects 6 the surface roughness, but more importantly it causes 7 discontinuities between --- in the geometry.
8 You see the wall thinning. You sometimes 9 have a very abrupt change in wall thickness. So, that 10 wasnt taken in account and thats unsteady, but 11 another thing thats more important, and thats what 12 I test or discuss was the stress concentration depends 13 on ductility. And ductility, as we all agree, I hope, 14 is affected by embrittlement, by neutron flux. So, 15 that affected embrittlement, all the stress 16 concentration wasnt there. It wasnt taken in 17 account.
18 So, you look at that, see, -- and theres 19 an uncertainty there, but I am not applying for life 20 extension and Im going back. It is their 21 responsibility to come up with the upper limits, with 22 a conservative assumption. Every weld is an 23 uncertainty, that must be a conservative assumption.
24 Thats their job. Thats what Im talking about.
25 There is no accounting in that CUF for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5684 1 stress concentration that is being affected by 2 irradiation. Sure, irradiation does --- has improved 3 the uses, but Im talking about the stress 4 concentration. The stress concentration is the site 5 for stress -- for crack initiation. The cracks 6 initiate at corners. They dont -- really, crack 7 initiation at the stress concentration points. Thats 8 what you have to in account of. What Entergy just 9 said, well, they dont even mention it, but they keep 10 saying that they are conservative. We are 11 conservative whatever we do. They are not conserving 12 anywhere.
13 CHAIRMAN McDADE: Okay. Dr. Hopenfeld, I 14 just want to make sure I understand what youre 15 saying.
16 Although we cannot review the design basis 17 of the plant, what youre suggesting is that the 18 geometry of the plant is significantly different today 19 40 years into its operation than it was at the time of 20 the original design.
21 So, even if the CUF locations were 22 appropriate at the time of design, theyre not 23 necessarily appropriate today given the inherent 24 changes that would occur over time in the plant.
25 DR. HOPENFELD: You verbalized my thoughts NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5685 1 very well. I couldnt say it better. Thats exactly 2 -- but also in this specific occasion Im talking 3 about embrittlement.
4 Because if you are to -- usually the 5 stress concentration factors are experimental values, 6 but there are some -- there were some attention in the 7 literature that people try to come up with some kind 8 of correlation to see if you can calculate on an 9 empirical basis what it is, because at certain point 10 stress concentration goes to infinity. It depends on 11 the ratings and depends how --- at the corner it goes 12 to infinity.
13 So, the point is that the effect of 14 embrittlement, the effect of ductility on that stress 15 concentration or that CLB CUF, whatever, is not 16 reflected in those calculations. You dont have to do 17 anything, but do not say conservatively, because this 18 is untrue that I am conservative. They are not 19 conservative. This is one example.
20 I gave you yesterday about the Fen. The 21 Fen is based on a --- I dont want to get into that 22 now. Hopefully well get later.
23 CHAIRMAN McDADE: So, its your view that 24 with regard to, for example, Commitments 43 and 49, 25 that although they recalculated the CUF, that they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5686 1 didnt redetermine the appropriate limiting locations.
2 And that, therefore, the analysis is ineffectual in 3 determining whether or not the intended use will be 4 maintained for the next 20-year period.
5 DR. HOPENFELD: Yes, theyre recalculated 6 properly. They went through the raindrop procedure, 7 you know, the pagoda thing. Thats how to count the 8 maximum/minimum stresses and you take the difference 9 and you multiply by a stress concentration, but that 10 stress concentration they have multiplied -- they made 11 changes to it.
12 Theres one place and I remember in my 13 testimony, there was one weld where I couldnt tell 14 the difference, but there was a huge reduction in 15 their screening process or their reevaluation process 16 where they refuse the original CUF by I think an order 17 of magnitude and say, well, it came from some 18 California plant. I dont remember the detail of 19 that, but I did discuss it in my testimony.
20 They changed the CUF by an order of 21 magnitude. Adjusted it lower because of the stress 22 concentration. When I looked at the stress 23 concentration, I couldnt tell because the drawing was 24 so kind of murky.
25 CHAIRMAN McDADE: The drawing was what?
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5687 1 DR. HOPENFELD: You see, the stress 2 concentration depends on the geometry -- or in the 3 weld, in especially would depend on the radius at the 4 corner and they change that. They made changes 5 because they said it was too conservative. Originally 6 they said it was too conservative. I was trying to 7 find out how much --- I couldnt tell from the 8 drawings that they have provided.
9 But nevertheless, my concern wasnt that 10 much even with the geometry in this particular case, 11 it is where is the effect of embrittlement on the 12 ductility on the concentration factor.
13 JUDGE KENNEDY: Okay. Dr. Hopenfeld, I 14 think Im still a bit --- I guess I want to make sure 15 I understand the point you made. I heard two specific 16 points. One is that the applicant had used improper 17 non-conservative transients in calculating the CUF 18 values, and that the stress concentration factors 19 should have been applied to the CUF value 20 calculations, and that those values were improperly 21 applied. Is that what you just testified to?
22 DR. HOPENFELD: The second one is correct.
23 The first one I like to amplify a little bit, because 24 I dont --- all I was saying, and maybe I --- I was 25 saying that --- I was kind of too general, I think.
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5688 1 I think when those plants were originally 2 designed, you assume number of transients. And in 3 that -- along that thought I said originally most of 4 their chances were good, except there are some cases 5 that were underestimated, there were more transients, 6 but I dont know which plants they were, but I know 7 that was the case. But in most cases they were 8 conservative with respect to the number of transients.
9 So, in that respect when I talk about the 10 transient in the particular case -- in the case of 11 IPEC, transients -- number of transients or the --
12 its not really the number, its the intensity of the 13 transient. So, there has to be --- for 20 years they 14 didnt have any data for it on the pressurizer surge 15 line. So, I dont know how they got it. Weve been 16 trying to find out.
17 In that sense, to answer your question, in 18 that sense the number of transients is not --- maybe 19 they did the right thing, but I dont know what it is.
20 I do know that for 20 years theres no 21 data on the thermal loads on those certain components.
22 And I havent seen anywhere in there describing what 23 they have done.
24 And thats an uncertainty because when you 25 calculate a CUF, when you calculate the final CUF, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5689 1 past transients are reflected in there, but how do you 2 do something when you dont know what the number of 3 transients or what the transients were? You dont 4 have data for it.
5 JUDGE KENNEDY: Is that the particular 6 transient youre referring to when you -- or 7 particular component you are referring to when you 8 said improper non-conservative transients? Is that 9 the one we should focus on?
10 DR. HOPENFELD: That was -- I believe 11 there was connection of the stratification, because 12 originally -- Im going back to this issue of 13 stratification.
14 Originally when Westinghouse designed, 15 they wrongly so even though there was data, they 16 wrongly assumed that there will be no stratification.
17 And in the mid-80s, suddenly the 18 component started falling apart. Some components, not 19 all, because of stratification or there were the surge 20 line. I dont know this particular case. Mostly 21 welds.
22 And at that point they started getting 23 data, but for 20 years, they didnt have any. So, you 24 ask yourself, what did they do here? And I think they 25 discussed it, but I dont know what they did, but I am NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5690 1 not like the NRC staff. Id like to verify it and I 2 have no opportunity to verify it.
3 JUDGE KENNEDY: But that --
4 DR. HOPENFELD: So, I have to go trust 5 what they say, and I dont -- do not.
6 JUDGE KENNEDY: Dr. Hopenfeld, I didnt 7 mean to interrupt you, but yesterday we took the 8 testimony on this stratification issue and how it was 9 accounted for in the CUF calculation.
10 Do you remember that testimony from Mr.
11 Gray yesterday?
12 DR. HOPENFELD: No.
13 JUDGE KENNEDY: Okay.
14 DR. HOPENFELD: He was talking about 15 different part. He was talking about the moving 16 front. There is a problem, but that -- I didnt want 17 to -- that is not the one I really focusing. There 18 are two aspects.
19 You see, he was talking about -- he was 20 talking about the moving front when you -- during the 21 heat-up where the pressurizer forces the fluid towards 22 the primary pipe.
23 Thats what he was talking about, which is 24 -- is the moving front back and forth that cause 25 fatigue, but I was talking about the instability of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5691 1 the two layers.
2 When you have stratification, you have an 3 unstable situation, because two different fluids of 4 two different densities come in contact. There are 5 all kind of instabilities that you can define there.
6 One of the most common ones, I think, is 7 called the Helmholtz instability, which is affected --
8 - which describes --- that really takes into account 9 the different density and the sheer between the 10 plants.
11 Now, Entergy said that we are not going to 12 have thermal striping because there is -- because 13 theres a standing wave theory that says that we are 14 not going to have it.
15 Now, originally they say they are talking 16 about standing wave theory. Then they are talking 17 about the Reynolds number theory.
18 I, again, Ive been working on this -- we 19 were one of the first ones to identify this problem.
20 So, I worked on this problem 40 years ago, but -- and 21 I had some -- I admitted certain problems in this 22 area.
23 For the last few years I havent been 24 working, but I have been following the literature.
25 And believe me, I have never heard of a pressure wave NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5692 1 theory or Reynolds number theory.
2 Reynolds, you cant just say Reynolds 3 number, you have to be a Reynolds number, it has to be 4 based on something. Has to base -- at least based to 5 be on some kind of a geometry.
6 They just say a Reynolds number theory, 7 pressure wave -- this is voodoo engineering at best.
8 And thats what they say thats conservative. Thats 9 what --
10 MS. SUTTON: Your Honor, this is Kathryn 11 Sutton for the applicant. We object to these ad 12 hominem attacks on the experts references to voodoo 13 and whatnot.
14 We just ask that Your Honors direct the 15 witness to please curb those sort of ad hominem 16 attacks on our experts. Its -- the hearing is very 17 professional. We just ask that we maintain that sense 18 of decorum.
19 CHAIRMAN McDADE: Okay. I dont think 20 that when Mr. Bush commented on Ronald Reagans 21 economics as voodoo economics, he viewed it as an ad 22 hominem attack on President Reagan. At that point, 23 Governor Reagan.
24 I didnt view what Dr. Hopenfeld said as 25 an ad hominem attack. I took it merely as an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5693 1 indication that he thought that this was not based in 2 sound engineering judgment and its taken in that 3 regard.
4 Dr. Hopenfeld.
5 DR. HOPENFELD: True. I sincerely 6 apologize. I lost my cool. I shouldnt, and I 7 apologize to you, maam. I shouldnt have said that.
8 MR. SUTTON: Thank you. Thank you, 9 Doctor.
10 DR. HOPENFELD: I didnt meant to, but I 11 -- there are certain points you -- I dont know how to 12 describe, because we are trying to get the problem, we 13 are trying to understand something and we get 14 distracted by saying -- well, when I bring the issue 15 and Dr. Lahey bring an issue they say, well, its 16 already accounted somewhere.
17 You can deal with something, but I brought 18 the issue of the Fen saying, well, this is accounted 19 somewhere else. And the same thing with the oxygen.
20 So, we dont have --
21 JUDGE KENNEDY: Dr. Hopenfeld --
22 DR. HOPENFELD: -- time to get to the 23 details. Im sorry.
24 JUDGE KENNEDY: Can we get back to the, I 25 guess, what was the --
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5694 1 DR. HOPENFELD: Im sorry.
2 JUDGE KENNEDY: -- stratification problem 3 and which particular component are you concerned 4 about?
5 DR. HOPENFELD: Okay. The stratification 6 problem is whether you have types of fluctuation that 7 penetrates all the way to the surface.
8 What happens there, you have very large 9 fluctuations of the order between one to ten hertz 10 that could be very severe. And what they do is affect 11 the cracked surface.
12 Now, we dont understand the exact 13 phenomena. I believe that what it affects is really 14 affects the initiation time with respect to fatigue.
15 It doesnt really have an effect on the crack 16 propagation. We are not into Section 11 or anything.
17 We are into the initial initiation process.
18 JUDGE KENNEDY: I guess the question was, 19 Dr. Hopenfeld, which particular plant component would 20 this --
21 DR. HOPENFELD: The surge line.
22 JUDGE KENNEDY: The pressurizer surge 23 line? Is that what you said?
24 DR. HOPENFELD: Yes.
25 JUDGE KENNEDY: Okay. And so, is that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5695 1 improper non-conservative transient of concern is the 2 --
3 DR. HOPENFELD: Yes.
4 JUDGE KENNEDY: And is that also the 5 component that you felt there was 20 years of missing 6 data that should have been ---
7 DR. HOPENFELD: Yes.
8 JUDGE KENNEDY: -- accounted for?
9 DR. HOPENFELD: Yeah, thats what they 10 said -- stated, yes.
11 JUDGE KENNEDY: Thank you. And then the 12 stress corrosion or stress concentration factors, you 13 feel those should be applied differently than you 14 believe theyve been applied in calculating the CUF 15 value?
16 DR. HOPENFELD: Right. The stress 17 concentration factor is --- comes at a different 18 place. The one I really would be more concerned is 19 indication of the tube-to-tubesheet welds. There are 20 20,000. Not each concentration the same. Thats why 21 I asked yesterday how do you do it? And the answer 22 was theres a procedure in the ASME.
23 And Im not that familiar with the 24 procedure, but Im sure there is, but thats just not 25 an answer, really. I would have to see what theyve NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5696 1 done, but I have no access to their computer codes and 2 I dont really know what they have done.
3 JUDGE KENNEDY: Dr. Hopenfeld, let me try 4 it a different way. You brought up the stress 5 concentration factors.
6 Are they applicable to metal fatigue?
7 DR. HOPENFELD: Are they applicable to 8 fatigue? I dont understand the question.
9 JUDGE KENNEDY: Are these not metals?
10 DR. HOPENFELD: Could you please repeat 11 the --
12 JUDGE KENNEDY: I guess Im, you know, 13 this contention is about component metal fatigue.
14 DR. HOPENFELD: Right.
15 JUDGE KENNEDY: And weve been discussing 16 for almost a day now a Cumulative Usage Factor. And 17 I tried to start my question discussing any concerns 18 you had bout those calculations, the CUF of record, as 19 you termed them.
20 DR. HOPENFELD: Well, yes.
21 JUDGE KENNEDY: And so, you brought up the 22 transients, which I think we now understand.
23 DR. HOPENFELD: Yes. Yes.
24 JUDGE KENNEDY: And Im not sure I quite 25 grasp the stress concentration factor and how it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5697 1 applies to the CUF of record calculation.
2 DR. HOPENFELD: Can I explain to you?
3 What you do, you have a whole bunch of transients.
4 You look at the whole data of loads versus time. Then 5 you go to some technique, I said raindrop technique, 6 there are others, and you pick up the maximums and 7 they group them together.
8 When you take the maximum, the peak, 9 thats all the -- mostly thats what theyre talking 10 about. I dont really have a problem, but Im sure 11 that they know how to do it and Im sure theyre doing 12 an excellent job.
13 My problem is, is after you take the plus 14 -- the peak and subtracted the minimum, then you 15 multiply that by a concentration factor. That -- the 16 result that you get is related to the fatigue life of 17 the component, yes. It affects the fatigue.
18 JUDGE KENNEDY: So, youre suggesting that 19 theres a stress concentration factor term that needs 20 to be applied or has been applied to the cumulative 21 usage factor calculation.
22 Is that what you just said?
23 DR. HOPENFELD: Yes.
24 JUDGE KENNEDY: Okay. Thank you. Lets 25 turn to Entergy. I think theres two questions at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5698 1 least on the table. One is the lack of data, the 20-2 year data for the pressurizer surge line and how that 3 was handled in the CUF of record calculation.
4 Mr. Gray.
5 MR. GRAY: This is Mark Gray for Entergy.
6 The transient development for the surge line and 7 pressurizer nozzles is documented in our two WCAPs.
8 The WCAP for Unit 2 is WCAP 17199, which 9 is Entergy 681. And the Unit 3 WCAP is 17200, which 10 I dont readily have, but I can find that -- 682, 11 okay. So, Entergy 682.
12 Section 3 of each of those WCAPs describes 13 in detail the transient development for those nozzles.
14 Within that description there are, for Unit 3 in 15 particular, there is a discussion of how we handled 16 the data for the past operation. To summarize, the 17 way that is developed is in general youll have a 18 subset of the data for the plant operations.
19 For Unit 2 we had a good amount of data --
20 well, let me stop for a second. The reason there is 21 such a thing as past and future is because there was 22 a recommendation in the 90s due to the pressurizer 23 in-surge/out-surge issue that Westinghouse studied 24 within the Owners Group for the plants to change their 25 mode of operation to mitigate these transients.
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5699 1 So, the time that the plant incorporated 2 those changes is where we expected to see a difference 3 in the transients that resulted from the operations.
4 We had data for both that past and present for Unit 2.
5 For Unit 3, that data was -- we had the 6 data for the present, but for the past, you know, we 7 were lacking data. So, what was done and is described 8 in the calculation notes, as well as in the WCAP, is 9 a study of the plant operations.
10 Coupled with looking at data, we also 11 employed operator interviews asking the operators in 12 the history of the plant how theyve changed their 13 heat-up and cool-down operations.
14 I should say that the significant 15 transients happened during heat-up and cool-down of 16 the plant when the Delta-T between the pressurizer and 17 the hot leg is high and the stratification is 18 maximized.
19 So, a combination of operator interviews, 20 studying the heat-up and cool-down procedures, seeing 21 what effects there would be was one part of that 22 investigation.
23 The other part of the investigation was 24 using actually the results of the Owners Group program 25 where all of the Westinghouse plants at the time were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5700 1 studied for their susceptibility to in-surge and out-2 surge transients. And all the plants were 3 characterized according to a dimensionalist parameter, 4 which is -- and this is described in WCAP 13588, which 5 I know is in our exhibits, but, again, I dont have 6 the exhibit number.
7 That parameter was used to compare Indian 8 Point Unit 3's surge line and pressurizer layout to 9 those other plants and to look for similarity in 10 plants for which we did have data. And of course to 11 nobodys surprise, the most similar plant to Indian 12 Point, Unit 3, with respect to that, was Indian Point 13 Unit 2.
14 So, the data from Indian Point Unit 2 for 15 the past operation, as well as other plants, was all 16 considered and an evaluation was done to determine a 17 conservative estimation of the past transients for the 18 surge line and pressurizer.
19 JUDGE KENNEDY: Okay. Thank you, Mr.
20 Gray. You used the term heat-up and cool-down.
21 When do these -- when does that occur?
22 Is that something daily? Weekly?
23 Monthly? Annually?
24 MR. GRAY: No, its -- at the least, its 25 every refueling outage. Sometimes theyll cool down NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5701 1 and heat up for a different -- and Mr. Azevedo might 2 have a better estimate of --
3 MR. AZEVEDO: Yeah. This is Nelson 4 Azevedo for Entergy. Its once every two years.
5 Maybe once every few cycles well also cool down for 6 some other reason like, you know, equipment failure, 7 something like that, but normally just once every two 8 years.
9 JUDGE KENNEDY: And so, over 20 years of 10 operation heat-up and cool-down would occur on --
11 whats a number -- estimated number of heat-ups and 12 cool-downs over the 20 years of missing data?
13 MR. AZEVEDO: Well, we can look up the 14 data. I dont have it here in front of me, but, you 15 know, Im not implying that all over those 20-year 16 periods -- over that 20-year period when we cool down 17 10 times, you know.
18 Back then we were in a different cycle 19 length. So, the number was higher, but probably by a 20 factor of two or so.
21 JUDGE KENNEDY: All right. Thank you.
22 Dr. Hopenfeld, any particular concern over how the 23 analysis was handled? And did you review those WCAPs?
24 DR. HOPENFELD: I read those three years 25 ago when we started with this. I read them -- thats NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5702 1 when I got the information that they did not have the 2 transients and they developed some kind of models.
3 There wasnt sufficient detail in that --
4 those documents to see how conservative -- or if 5 conservatives they were, but that I couldnt tell and 6 that was my problem.
7 And I think if I read it today, I probably 8 couldnt tell either. So, I am very much -- maybe NRC 9 has, because they say that all these models are 10 conservative, but I couldnt tell. I dont know how 11 you can tell when you dont have data, that something 12 is conservative.
13 JUDGE KENNEDY: All right. Thank you, Dr.
14 Hopenfeld. Stress concentration factors and their 15 impacts on metal fatigue or CUF calculations?
16 MR. AZEVEDO: Yeah, Your Honor. This is 17 Nelson Azevedo for Entergy. First, let me comment 18 that I think its implied that the stress 19 concentrations change over time. They dont change 20 over time. Theyre a function of the geometry of the 21 plant. So, unless you modify the component, the 22 stress concentrations stay the same.
23 Also, the ASME code when you do fatigue 24 analysis, you use what the code calls peak stresses.
25 And peak stresses -- excuse me -- are already the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5703 1 intensified stresses.
2 Stress intensification factor is really 3 not the right term, because ASME Section 3 requires we 4 use -- excuse me -- stress intensity is not really 5 stresses, but the end result is the same, but the 6 stresses that we use are already peak stresses which 7 have already been identified. Theyre not 8 intensified. Theyre not intensified after we paired 9 the peaks and the valleys. Theyre intensified prior 10 to that and we use those peak stresses to pair them, 11 you know, to peaks and to valleys.
12 So, the stress concentration effects have 13 been incorporated and theyre clearly specified in the 14 ASME code how to calculate them.
15 JUDGE KENNEDY: And did I hear you say the 16 stress concentration factors arent influenced by 17 corrosion or embrittlement or radiation?
18 MR. AZEVEDO: Well, again, theyre 19 certainly not influenced by embrittlement or 20 corrosion, because theres no corrosion going on in 21 the primary side.
22 MR. STROSNIDER: Your Honor, this is Jack 23 Strosnider from Entergy. Id like to add to Mr.
24 Azevedos comments that the notion about changes in 25 geometry over time it should be recognized that under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5704 1 Section 11 of the ASME code, these systems are 2 inspected periodically. In particular, the welds are 3 looked at with -- using ultrasonic methods.
4 So, if there were any change which, you 5 know, as was pointed out is not expected, they would 6 be -- that would be identified through these 7 inspections. It would have to be put in the 8 corrective action program and evaluated.
9 One other thing which I think was in Dr.
10 Hopenfelds testimony and may have mentioned earlier 11 was the notion of flow-assisted corrosion. And I just 12 want to point out that that mechanism is not 13 applicable to the primary system components that were 14 talking about. So, that would not be something that 15 would change the geometry.
16 JUDGE KENNEDY: Thank you. Dr. Hopenfeld, 17 any final thoughts on stress concentration factors and 18 how --
19 DR. HOPENFELD: Yes.
20 JUDGE KENNEDY: -- Entergy is applying 21 them?
22 DR. HOPENFELD: I have several, but I 23 dont want to take too much time. But one that I 24 would like to choose is that the stress concentration 25 I was talking about is affected by ductility.
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5705 1 And if the ductility doesnt change, if 2 the irradiation doesnt affect ductility, then theres 3 no effect on it. But from what I heard yesterday, it 4 does affect ductility. And from what I read about it, 5 it does affect ductility.
6 The original stress concentration for 7 which these peaks are multiplied by do not have 8 embrittlement effect in it.
9 JUDGE KENNEDY: Are you suggesting that 10 the ASME code prescribed method is incorrect for this 11 calculation?
12 DR. HOPENFELD: No, the ASME code is 13 correct. What I am suggesting the number that you 14 have, decay or whatever the number, ASME code will 15 tell you go to the Pearson chart or something or 16 handbook and pick up what the concentration factor is 17 for this particular geometry. But it doesnt tell you 18 that if that geometry is subjected to embrittlement 19 over time, how to handle that, or at least Im not 20 familiar with.
21 So, I think its true the geometry on the 22 primary side doesnt change, except in one case I do 23 have a problem with the whole LAR, but I dont want to 24 take too much into it.
25 If you notice that in the original LAR --
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5706 1 I dont have time to address it. So, maybe if I have 2 time, Ill come back to it. Im sorry. It would take 3 me too long to explain.
4 It relates -- Ill focus my attention now 5 on the effect of radiation on the stress 6 concentration. I dont know how that was accounted 7 for.
8 JUDGE KENNEDY: Well, maybe just to clear 9 the air, Mr. Azevedo, if we focused just on 10 embrittlement and the stress concentration factors --
11 MR. AZEVEDO: This is Nelson Azevedo for 12 Entergy. Again, Your Honor, stress concentrations are 13 geometrical, impacted by the geometry of the 14 component, not the embrittlement of the component.
15 That impacts the material properties, not the stress 16 concentrations.
17 CHAIRMAN McDADE: Okay. Mr. Azevedo, I 18 just didnt hear what you said. Its affected by the 19 geometry, not by -- I just didnt --
20 MR. AZEVEDO: Its not affected by the 21 embrittlement.
22 JUDGE KENNEDY: So, this ductility 23 question that Dr. Hopenfeld is raising, you dont --
24 do you feel its significant in relation to stress 25 concentration factors?
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5707 1 MR. AZEVEDO: No, I dont feel it impacts 2 the stress concentration factor at all. As we 3 discussed over the last couple days, what it does 4 impact is the ability of the material to resist crack 5 propagation, but thats not what were talking about.
6 Were talking about CUFs and crack 7 initiation and irradiation has no impact on stress 8 concentration. So, its a geometry issue.
9 JUDGE KENNEDY: All right. Thank you.
10 Dr. Hopenfeld, I have one final question. At least it 11 will start as one final question.
12 On Page 6 of your report, Exhibit RIV or 13 Riverkeeper 144, you state that the Fen is an 14 experimental factor and the underlying premise is that 15 the user would not extrapolate the Fen to conditions 16 other than those in its derivation.
17 Are you suggesting that you believe that 18 Entergy did so? And where in your testimony do you 19 support that statement?
20 DR. HOPENFELD: Let me explain. Id like 21 to see the statement, but from what you read -- I 22 dont have it in front of me.
23 JUDGE KENNEDY: Would you like us to --
24 would it help if we put it up on the screen? Mr.
25 Welkie, could we try 144? Riverkeeper.
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5708 1 (Pause.)
2 JUDGE KENNEDY: Page 6, I hope.
3 DR. HOPENFELD: Where would you like me to 4 look?
5 JUDGE KENNEDY: Well, Im looking myself.
6 MR. SIPOS: I believe were on Page 8. I 7 believe were on Page 8 of the pdf, Your Honor.
8 JUDGE KENNEDY: Right. Thank you. Yes.
9 Document Page 6, which I think is pdf Page 8. Thank 10 you. Okay. Scroll down just a little bit.
11 Right. The last sentence under Section 12 1.1, since the Fen is an experimental factor, the 13 underlying principle of using the above equation is 14 that the user would not extrapolate the Fen to 15 conditions other than those that existed in its 16 derivation.
17 And I guess I -- that seems like a 18 hanging statement. I filled it in by suggesting are 19 you challenging the application of this by Entergy?
20 Has it been applied outside -- that you believe its 21 been applied outside the range of applicability?
22 DR. HOPENFELD: Yes.
23 JUDGE KENNEDY: And how do you support --
24 what do you point to to support that statement?
25 DR. HOPENFELD: One of several.
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5709 1 Obviously one we discussed was the oxygen. The oxygen 2 was -- I dont want to rehash that now, because there 3 are others. The other one is stress corrosion 4 cracking.
5 You see, when these tests -- and if I read 6 the rebuttal to my report, it doesnt seem like they 7 understand. It doesnt appear as to how these tests 8 were run, because they, in their testimony, said that 9 you can take the Fen as it was in this equation and 10 directly apply it.
11 Dr. Chopra, who had developed this 12 equation, discussed this issue for full two days 13 before the ACRS in 2006. And he made it very, very 14 clear that its up to the user to any -- make 15 adjustment for its environment, and I made that point 16 in my report.
17 In reply, Entergy said that its my 18 imagination, that Dr. Chopra never was there. I gave 19 you the reference. Its in the record, but -- and I 20 can give you the pages where he said that.
21 Now, to reply to your question, which I 22 didnt, the specific one was oxygen, but the one that 23 really concerned me especially for the tube-to-24 tubesheet welds is the stress corrosion aspect of it.
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5710 1 than metal fatigue and only in one respect for the 2 same material. Stress corrosion you have uniform, 3 steady-state --
4 JUDGE KENNEDY: Dr. Hopenfeld, lets back 5 up just a second. I -- again, I -- maybe its the way 6 Im asking the question.
7 What this statement seems to imply is this 8 test, these tests that generated the Fen factors had 9 a range of conditions under which the tests were run.
10 And I read that last sentence and I may be reading it 11 incorrectly, which is why I ask the question, as a 12 challenge to someone applying those factors outside 13 the applicable range of conditions under which they 14 were developed, I dont see that as having any bearing 15 on stress concentration factors.
16 Maybe oxygen content, Im not sure, but 17 this implies to me that there is an extrapolation of 18 the Fen to conditions that are inconsistent with its 19 derivation.
20 Could you please respond to that 21 particular question as what -- well, first of all, 22 what did you mean by this?
23 DR. HOPENFELD: Well, I started trying --
24 started explaining going into the stress 25 concentration -- stress corrosion cracking. There is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5711 1 no stress corrosion cracking in these tests. There 2 was no steady-state component during these tests. It 3 was only cycle components.
4 So, there is only fatigue, but there is a 5 synergy, as Dr. Lahey said, between fatigue and stress 6 corrosion cracking. Where is that synergy? In two 7 places.
8 One, in the initiation. And I would like 9 to -- because, again, when we talk about crack 10 initiation, crack propagation, were talking about two 11 different things. So, if you wish to see what Im 12 talking about, Im talking about the crack initiation 13 and propagation by the short cracks.
14 They are talking about Section 11 cracks.
15 Im talking about the short cracks the way are 16 described by Dr. -- or by Argonne in this report. And 17 we can go to the definition of what the crack means, 18 but there were no -- there was no stress corrosion 19 component during these tests.
20 So, you cannot apply these Fen directly to 21 a situation where the stress corrosion occurring 22 simultaneously, because their synergetic effect, their 23 mechanism of the synergy is as follows.
24 When you have steady-state tensile force 25 superimposed on the oscillating force, oscillating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5712 1 stress, what you do, youre affecting the distraction 2 of the outside layer at the tip of the crack.
3 So, the crack propagation usually would be 4 much faster, and thats what data shows that you have 5 a faster propagation of the crack, how it -- how the 6 CUFen would be affected, because the fatigue like, 7 thats what were talking about.
8 JUDGE KENNEDY: Doctor.
9 DR. HOPENFELD: Yes.
10 JUDGE KENNEDY: I hate to keep 11 interrupting you, Dr. Hopenfeld, but I think that --
12 if I look at this equation, it appears to be adjusting 13 laboratory data in air for laboratory data in water 14 conditions. Maybe water conditions that are 15 applicable for a pressurized water reactor.
16 What part of that do I not understand?
17 DR. HOPENFELD: What I think you dont 18 understand is its not only the water condition, its 19 the condition how the specimen was stressed. There 20 was no uniform stress at the time when the cycle 21 stresses were applied.
22 JUDGE KENNEDY: And how is that captured 23 in the conditions other than those that existed in its 24 derivation?
25 DR. HOPENFELD: Its not -- its not --
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5713 1 its up to the user to make adjustments for that.
2 Theres no stress corrosion --
3 JUDGE KENNEDY: Where in this document 4 does it say you need to do that?
5 DR. HOPENFELD: In the testimony -- in the 6 testimony of Dr. Chopra before ACRS, he discussed the 7 things that they did and the things they didnt do it.
8 And the members of the ACRS a whole bunch of questions 9 like you do right now. And the answer was, well, we 10 havent done this, its up to the user to adjust it.
11 Its up to the user to take care of it. We hadnt 12 looked at fluence. Its up to the user, and they keep 13 on going.
14 And we havent covered everything.
15 Theres a full two-day discussion of this, which is --
16 which to some degree if you read the report, some of 17 it is in here, but I --
18 JUDGE KENNEDY: Lets --
19 DR. HOPENFELD: What Im telling you is 20 that loads, there was no stress concentration --
22 Lets put it differently. Suppose you 23 took a sample. They use brand new samples, perfectly 24 clean -- due to stress -- a sample that already had --
25 that was already had some stress corrosion cracking.
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5714 1 The result is not going to be the same.
2 JUDGE KENNEDY: Let me --- I heard a lot 3 in your discussion there, and I heard you pointing us 4 to another document that you would suggest draws into 5 question the Fen calculation.
6 Is that what you just said? Im having 7 trouble following you, to be honest with you.
8 DR. HOPENFELD: It draws into the question 9 of the Fen. Its a new concept, really. It hasnt 10 been around for many years. So, its a perfect --
11 its an excellent concept. I have no problem with 12 that.
13 JUDGE KENNEDY: So, you ---
14 DR. HOPENFELD: Im just saying I have a 15 problem when you use --- put blindfolds and use it 16 everywhere. You have to see under what condition it 17 was obtained and ask yourself, is it applicable to 18 what Im doing? And I dont see that this is being 19 done.
20 I brought stress corrosion cracking as 21 one. Oxygen is two. Im sure there are others that 22 are constant.
23 JUDGE KENNEDY: Is there a particular 24 exhibit in your pre-filed testimony that youd like to 25 point us to, to address your concern? It doesnt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5715 1 appear to be this document, I guess, is my point.
2 DR. HOPENFELD: Well --
3 JUDGE KENNEDY: So, Ill give you an 4 opportunity to point us towards your most applicable 5 reference.
6 DR. HOPENFELD: Well, in my exhibit, I did 7 discuss the effect of stress corrosion cracking. And 8 I -- in a reference report by -- I guess by Argonne, 9 and it will take me time to look for it, I did discuss 10 the synergy between stress corrosion cracking, metal 11 fatigue. And I reference the work of Argonne where 12 they got a very, very detailed analysis showing 13 theres definitely synergy between stress corrosion 14 cracking and metal fatigue.
15 And they came up with equations and they 16 said, we can handle it. Theres information in the --
17 we can handle it. Its difficult to handle for welds, 18 but for the very base metal its okay, but the problem 19 is with the welds. We dont have enough data.
20 And welds usually are subjected to large 21 residual stresses. So, thats what the stress is.
22 JUDGE KENNEDY: Dr. Hopenfeld, are you 23 testifying that those subsequent references would lead 24 us to adjust the Fen parameters to account for other 25 mechanisms, aging mechanisms?
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5716 1 Im trying to put -- this started with an 2 Fen discussion, and were off into synergistic 3 effects.
4 DR. HOPENFELD: Here is what I suggested.
5 I think its an excellent question. Here is what I 6 suggest.
7 If youre asking me how to do it, I dont 8 know how to do it, because I dont have the data 9 although there is information -- there is some data in 10 the literature as to the synergy recreating how fast 11 the crack propagate with or without stress corrosion 12 cracking, and how fast it will initiate or not 13 initiate.
14 I dont know if I provided the reference.
15 Theres just too much material here, but there is an 16 effect. Now, how to take in account that effect?
17 I dont know, but I am sure a fraction 18 mechanic expert will come up with an answer and say, 19 well, look, if you want to be conservative, do this, 20 take this extreme. But if you dont want to be 21 conservative, thats what they doing.
22 Im talking about conservatism. Their 23 effect is finite. I dont know how to calculate it, 24 but if you -- you cannot say in the same breath that 25 you are conservative without taking into account.
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5717 1 Thats all Im saying.
2 JUDGE KENNEDY: I understand, Dr.
3 Hopenfeld. And as youre aware, we took quite a bit 4 of testimony over the last few days both on Contention 5 25 and 26 about synergistic effects.
6 I guess Ill just go back, circle one more 7 time to this Fen calculation. Do you have a 8 particular concern about how Entergy has applied the 9 adjustments for an environmental-assisted fatigue 10 calculation? And in particular, the application of 11 the Fen parameter.
12 DR. HOPENFELD: Yes, because they did not 13 account for the irradiation effect.
14 JUDGE KENNEDY: So, were back -- are we 15 back to synergistic effects?
16 DR. HOPENFELD: Its not -- were using 17 the word synergistically interchangeably. The way 18 I look synergistically, and maybe not exactly the 19 same as Dr. Lahey, I look synergistically as one thing 20 happening, another thing happen. They work 21 simultaneously.
22 And when they work simultaneously, the 23 result is different than separately. Thats what 24 synergistically mean.
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5718 1 as far as Im -- embrittlement, like the other thing, 2 just affects the material property. Its a different 3 property. Its not that it works together. Its just 4 the property is different. So, I -- in that case, the 5 synergy word doesnt mean much to me.
6 JUDGE WARDWELL: But let me take a crack 7 at what I -- I want to make sure you are or are not 8 saying.
9 Do you believe that the Fen should include 10 -- the selection of the Fen should include some aspect 11 associated with stress corrosion cracking and oxygen 12 content? Is that your position?
13 DR. HOPENFELD: All right. Let me answer 14 to -- yes. In the case of oxygen content, its 15 already included in there. They told you use a number 16 if you dont have the actual measurements of oxygen 17 near the surface. Its not at the surface, but near 18 the surface or near the component.
19 If you dont know what it is, then use a 20 conservative value. And Argonne gave you 0.4 -- maybe 21 its more. If you have justification, use something 22 else, but dont use 0.05.
23 Even Westinghouse in their analysis 24 acknowledge that oxygen gets in there during the heat-25 up period.
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5719 1 Now, how does it get out? Im not going 2 -- there are millions of -- oxygen is being reduced 3 during --- in the core all the time.
4 JUDGE WARDWELL: So, youre saying that 5 oxygen is already included in the Fen, but its not 6 included sufficiently, is your position.
7 DR. HOPENFELD: No, I -- the Fen includes 8 the oxygen. Theres an oxygen term. What do they 9 call it? Reduced oxygen with a star on it. So, you 10 have to put -- ask yourself what oxygen --
11 JUDGE WARDWELL: Okay. So, the Fen does 12 include the oxygen.
13 DR. HOPENFELD: Oh, sure.
14 JUDGE WARDWELL: And but you are -- are 15 you objecting to the value that the applicant has used 16 --
17 DR. HOPENFELD: Yes.
18 JUDGE WARDWELL: -- for oxygen in the Fen?
19 DR. HOPENFELD: Absolutely.
20 JUDGE WARDWELL: Okay. Thank you. Now, 21 what about stress corrosion cracking?
22 DR. HOPENFELD: Im sorry?
23 JUDGE WARDWELL: And what about stress 24 corrosion cracking?
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5720 1 there, and I think --
2 JUDGE WARDWELL: And you believe it should 3 be a component --
4 DR. HOPENFELD: Yes, but I dont --
5 JUDGE WARDWELL: -- in the calculation of 6 the Fen.
7 DR. HOPENFELD: -- know how to do it. I 8 wouldnt know how to do it. But if I was -- if 9 somebody said, hey, you are getting on this plane, 10 think of it this way. Stress corrosion is not only 11 unique to -- it occurs on planes, too.
12 If I get on a plane and the guy said we 13 got -- these wings are stress corroded, but theyre 14 also going to fatigue during the turbulence, then so 15 I add, did you take into account the stress corrosion 16 and said, no, I am not going to get on that plane.
17 So, the answer to your question, sir, yes, 18 I would include it. I dont know how, but, again, if 19 you take an expert person, and I can name you some 20 expert, Dr. James for one, he will come up with a 21 number how you can adjust or put a safety factor into 22 this.
23 JUDGE WARDWELL: And is that in your 24 testimony in regards to a suggested method to include 25 stress corrosion cracking into the selection of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5721 1 Fen value?
2 DR. HOPENFELD: I didnt feel it was my 3 position to -- in writing this report to make 4 suggestion as to what to do. I didnt put myself in 5 that. I just said its not adequate.
6 JUDGE WARDWELL: Do you have a cite to 7 anyone else -- is this your professional opinion, or 8 are there others in the industry to which you have 9 cited backing up your professional opinion in regards 10 to whether or not stress corrosion cracking should be 11 included as part of the selection of Fen?
12 DR. HOPENFELD: There are plenty of --
13 there is -- in the paper I cited -- indicated an 14 effect of synergy before. Now, they didnt say 15 specifically --
16 JUDGE WARDWELL: Excuse me, Dr. Hopenfeld.
17 Im not talking about synergism. Im now asking just 18 what you were trying to focus in on. The selection of 19 the Fen value, you believe, should include stress 20 corrosion cracking.
21 Im asking you, do you have a cite to 22 anyone else who also -- who shares that opinion of you 23 and your testimony? And if so, where do you cite 24 that?
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5722 1 addressing the Fen should be corrected by stress 2 corrosion crack. Its up to the user to do that. The 3 stress -- the code doesnt tell you, you know, how to 4 do this. Its up to the user to make the adjustments.
5 But I dont think that --- I havent seen 6 anywhere in dispute that -- I mean, the whole concept 7 of Fen is not that old. Its fairly new. So, I 8 havent seen any discussion in literature that say, 9 hey, these people should have adjusted the Fen.
10 I am telling you that that Fen was not the 11 effect of stress corrosion cracking. The effect of 12 pre-conditioning the specimen with crack was not 13 involved here.
14 JUDGE WARDWELL: Thank you. Let me turn 15 to Entergy, either Mr. Gray or Azevedo or whoever 16 else. Lets start more generically.
17 Is there any mechanism by which you would 18 -- is there any mechanism in the current guidance that 19 allows you to change or add or supplement different 20 parameters in the calculation of the Fen?
21 MR. AZEVEDO: You mean to account for 22 stress corrosion cracking?
23 JUDGE WARDWELL: Or any -- I was doing it 24 more generically to start with, but, yes, my next 25 question was going to be for stress corrosion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5723 1 cracking. So, fine. Use that as an example.
2 MR. AZEVEDO: Well, let me just start out 3 by saying that the stress corrosion cracking is 4 handled by a separate program. We have a separate 5 program to handle stress corrosion cracking specific 6 of LI-600. Those are the materials susceptible to 7 stress corrosion cracking. Thats a separate program.
8 JUDGE WARDWELL: Separate AMP?
9 MR. AZEVEDO: Its a separate -- yeah, 10 thats correct. We have inspections specifically for 11 that. So, thats addressed in a separate program.
12 To the extent --- well, stress corrosion 13 cracking is driven by a susceptible material, a 14 conducive environment, in the presence of stress.
15 To the extent that the environment impacts 16 the CUF, thats exactly what the Fen is for to account 17 for the impact of the environment on the crack 18 initiation. In this case, the CUF. So, we would 19 claim that thats already -- thats specifically what 20 the Fen is doing.
21 JUDGE WARDWELL: Okay. Thank you.
22 MR. AZEVEDO: But, again, stress corrosion 23 cracking is a separate program, a separate issue and 24 handled separately from the CUFen.
25 JUDGE WARDWELL: Yesterday we talked about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5724 1 the oxygen content and that youre using an order of 2 magnitude greater than what you are actually 3 experienced at the plant; is that correct?
4 MR. AZEVEDO: Thats correct.
5 JUDGE WARDWELL: And do you have anything 6 else to add to it just so those comments are here in 7 the transcript and saves us from flipping back to find 8 out where you said it before yesterday?
9 MR. AZEVEDO: Im not sure theres 10 anything else I can say other than that we feel that 11 the numbers that were using are extremely bounding 12 and thats already accounted for.
13 JUDGE WARDWELL: And when we were talking 14 about that number, that number does relate to the one 15 used for the ultimate calculation of the Fen; is that 16 correct?
17 MR. AZEVEDO: Thats correct.
18 JUDGE WARDWELL: Thank you.
19 MR. DOLANSKY: This is Bob Dolansky with 20 Entergy. I just would like to add I believe the 21 numbers that Mr. Azevedo gave yesterday were actually 22 in our testimony or in a cite.
23 Is that right, Nelson, the numbers you 24 read from yesterday?
25 MR. AZEVEDO: Yes, its one of the Entergy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5725 1 exhibits.
2 JUDGE WARDWELL: Thank you.
3 JUDGE KENNEDY: With that, I have no 4 further questions on Contention 26.
5 JUDGE WARDWELL: I think Id like to clear 6 up a couple, if I dare.
7 CHAIRMAN McDADE: Please.
8 JUDGE WARDWELL: This is for Mr. Azevedo 9 or whoever else in Entergy. Dr. Hopenfeld did mention 10 something about the importance of this fatigue for 11 welds.
12 Do you put any more emphasis on welds as 13 opposed to any other component in regards to the 14 fatigue analysis?
15 MR. AZEVEDO: All the locations, all the, 16 you know, nozzle corners, for example, welds, anywhere 17 where theres a change in geometry or change in the 18 materials, the ASME code specifically addresses that 19 and tells you how to calculate the stress indices and 20 the peak stresses which are used for fatigue analysis.
21 So, Id say welds are not handled any 22 different than any other component that requires to 23 be, you know, accounted for, for change in geometry.
24 JUDGE WARDWELL: And those environmental 25 conditions that you apply to other components are also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5726 1 applied to the welds like the oxygen content, et 2 cetera.
3 MR. AZEVEDO: Yes, all the CUFs are 4 amplified by the Fen. Thats correct.
5 JUDGE WARDWELL: Dr. Hopenfeld also 6 mentioned something about the fact that transient data 7 wasnt available from the early operations of the 8 plants.
9 Could you comment on that whether it is or 10 isnt, and then how have you adapted for that in 11 regards to the tracking of CUFs during operations and 12 that will be extended into the period of extended 13 operation?
14 MR. COX: This is Alan Cox. Let me start, 15 and Mr. Azevedo can continue, but I believe youre 16 referring to the lack of the details about pressurizer 17 heat-ups and cool-downs.
18 I just want to say that the number of 19 pressurizer plant heat-ups and cool-downs is known.
20 That is not lost.
21 What was not available was the specific 22 temperature information related to each of those heat-23 ups and cool-downs as far as how many cycles occurred.
24 JUDGE WARDWELL: Say again what was 25 missing. I missed a couple words right in there that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5727 1 are crucial.
2 MR. COX: The detailed temperatures 3 related to the -- the local temperatures that -- at 4 the pipe when the heat-ups and cool-downs occurred.
5 JUDGE WARDWELL: Arent those critical, 6 though, or are they not? And how did you handle that 7 lack of data?
8 MR. AZEVEDO: Well, yeah, this is exactly 9 what Mr. Gray was discussing a few minutes ago. Maybe 10 he can reiterate what he said before.
11 MR. GRAY: Hi. Yes. Mark Gray for 12 Entergy. We --
13 JUDGE WARDWELL: Are you suggesting I 14 wasnt paying attention, Mr. Azevedo?
15 MR. AZEVEDO: No, Your Honor. I did not 16 mean that.
17 (Laughter.)
18 JUDGE WARDWELL: I probably wasnt.
19 MR. GRAY: Yeah, let me explain a little 20 bit about the difference in the heat-up and cool-down 21 events versus the actual sub-events and maybe that 22 will clear that up a little bit.
23 During a given heat-up you can have sub-24 events, sub-cycles, transients that occur in the 25 pressurizer lower head due to in-surges and out-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5728 1 surges. So, the data for the number of heat-ups and 2 cool-downs for the plant was available. What we 3 didnt have was detailed temperature information for 4 those in-surges and out-surges.
5 And so, the study that we did both with 6 respect to the sensitivity of the Indian Point Unit 3 7 layout to in-surges and out-surges, the similar 8 operating procedures to other plants including Indian 9 Point 2, that study was all used to determine an 10 applicable set of transients for that path. And 11 thats what was documented in the WCAP and the 12 supporting calculations.
13 JUDGE WARDWELL: Thank you. I do recall 14 that testimony. I appreciate that.
15 Dr. Hopenfeld, two different times you 16 mentioned, I believe, the tube-to-tubesheet welds.
17 And I wasnt -- because you mentioned it twice, I was 18 wondering why that sticks in your mind as something of 19 importance.
20 And if so, to what degree is it important 21 in regards to the CUF and CUFen calculations?
22 DR. HOPENFELD: Its extremely important.
23 And I could spend half an hour, but I could spend a 24 week to talk about it, but I dont want to take the 25 week and I dont want to -- you wouldnt be interested NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5729 1 in a week of work.
2 The reason its important -
3 JUDGE WARDWELL: I think thats a safe 4 assumption.
5 DR. HOPENFELD: Okay. The reason its 6 important is because -- and the reason its important 7 to say -- to know what the CUF is, and if we can go 8 off to some material, maybe designated proprietary, 9 because I would like to mention a number for that --
10 JUDGE WARDWELL: Id like you to avoid 11 that at all possible. I dont think I need it in-12 depth enough to see that number.
13 DR. HOPENFELD: Okay. If you dont need 14 it, okay.
15 JUDGE WARDWELL: Make up a suggested 16 number. Dont --
17 DR. HOPENFELD: Okay. Suggested --
18 JUDGE WARDWELL: Or a range of numbers.
19 DR. HOPENFELD: More than one. Its 20 three.
21 JUDGE WARDWELL: More than one?
22 DR. HOPENFELD: Yes.
23 JUDGE WARDWELL: Fine.
24 DR. HOPENFELD: Three.
25 JUDGE WARDWELL: And whats this number NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5730 1 for? Number of what?
2 DR. HOPENFELD: Its the CUF. The CUFen 3 --
4 JUDGE WARDWELL: The CUF more than one --
5 DR. HOPENFELD: -- for the weld.
6 JUDGE WARDWELL: -- for what?
7 DR. HOPENFELD: For the welds, I mean, the 8 CUFen for the welds between the tube-to-tubesheet 9 welds. The tube-to-tubesheet welds. The CUFen for 10 the tube-to-tubesheet welds.
11 JUDGE WARDWELL: If it becomes greater 12 than one, then what?
13 DR. HOPENFELD: If its greater than one, 14 then what happens? First of all, I have to backup.
15 The analysis -- well, due to a steam line break, okay, 16 because its greater than one, theres a high 17 probability, I would say probably a hundred percent 18 probability, that those -- if its really more than 19 one, that those welds will fail.
20 Now, we dont know how theyre going to 21 fail. Theyll fail -- usually when these things fail, 22 it means there is a crack. Okay. So, I have 20,000 23 cracked welds and I dont know to what degree they 24 crack.
25 JUDGE WARDWELL: Are there actually NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5731 1 20,000, or was that just --
2 DR. HOPENFELD: Dont take the number 3 literally.
4 JUDGE WARDWELL: Okay. I want to make 5 sure what --
6 DR. HOPENFELD: Im going back in my 7 memory and Ive been away from these numbers for some 8 time. There are 10,000 tubes, roughly. Maybe I know 9 Entergy will say its 11,000. So, whatever. 10,000.
10 They are welded on both sides of the plenum. So, it 11 might be 20,000.
12 So, you have 20,000 welds and they are --
13 they have exhausted their useful design usage factor.
14 They are damaged. They are not something brand new 15 that came in a box from Amazon. They have exhausted 16 their usefulness. So, now what happens? What 17 happens? Well, you have a steam line break.
18 Here the steam line break depends where 19 the break is, but usually for analysis purposes we 20 usually assume that the break occurs between the 21 containment and the relief valve and the safety valve, 22 not farther that you can isolate it. So, you cant 23 isolate that.
24 So, when you have a steam line break like 25 that, you impose 2,000 pounds on the primary side NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5732 1 because now you open to the atmosphere.
2 After you scram the reactor, the pressure 3 in the steam generator goes down. So, you impose that 4 pressure and now you have a leak, a direct path for 5 the primary fluid to go directly to the -- to bypass 6 the containment and go directly to outside.
7 If the operator doesnt operate, doesnt 8 do things properly, you deplete the water and you 9 uncover the core. So, what you have to do, you have 10 to keep the core cool. You have to keep adding water.
11 But at the time, you will not lower the level, too.
12 You will stop the leak. The only way to do it to stop 13 the leak when the leak is large, is to minimize the 14 levels on both sides.
15 JUDGE WARDWELL: Is it your position that 16 the sensitivity of the plants integrity is -- has a 17 higher degree of potential impact associated with any 18 potential failure of the tube-to-tubesheet welds than 19 other components that are also tracked for fatigue?
20 DR. HOPENFELD: This, in my mind, is very 21 critical --
22 JUDGE WARDWELL: You think thats the most 23 critical component.
24 DR. HOPENFELD: In my mind it is, because 25 of the numbers they came up with.
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5733 1 JUDGE WARDWELL: Okay. Thank you.
2 DR. HOPENFELD: If they came up with small 3 numbers, I wouldnt worry about it.
4 JUDGE WARDWELL: Im not worried about it.
5 Im just -- the welds are your most critical --
6 DR. HOPENFELD: That --- in this case, 7 yes.
8 JUDGE WARDWELL: Entergy, would you like 9 to comment on that position of Dr. Hopenfeld?
10 MR. AZEVEDO: This is Nelson Azevedo for 11 Entergy. First of all, the CUFens for the tube-to-12 tubesheet welds are all below one. So, theyre, I 13 believe, 0.3 and 0.8. We were just looking at them on 14 one of the exhibits.
15 JUDGE WARDWELL: We dont need the number, 16 but thats fine. Below one is fine.
17 MR. AZEVEDO: I apologize. So, theyre 18 less than one. So, the idea that they have -- we have 19 cracks, Im not sure how to respond to that, because 20 we feel that we dont have cracks. The CUFs are 21 within the allowables.
22 JUDGE WARDWELL: Do you believe that the 23 plant safety is any more sensitive to failures of 24 those than they are of any other particular components 25 or other components within the plant that are tracked NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5734 1 for fatigue?
2 MR. AZEVEDO: No, I dont feel that thats 3 the case. Theyre part of the reactor coolant 4 pressure boundary just like many other components.
5 JUDGE WARDWELL: Thank you. Dr. Hopenfeld 6 also mentioned something about pressure wave theory 7 and Reynolds number theory.
8 Do you know what he was talking about in 9 regards to that? And how have you handled or not 10 handled that particular application of those theories 11 to your fatigue analysis, if at all?
12 And if you dont know what he was talking 13 about, thats fine, too. And Ill try to have him 14 clarify.
15 MR. GRAY: This is Mark Gray for Entergy.
16 I believe that that was in reference to the loadings 17 that were used for the surge line analysis. The --
18 JUDGE WARDWELL: Excuse me. Is that what 19 you were referring to, Dr. Hopenfeld?
20 DR. HOPENFELD: Thats correct.
21 JUDGE WARDWELL: Thank you. Continue.
22 MR. GRAY: The surge line transients were 23 developed consistent with a Westinghouse Owners Group 24 program where stratification of the line is 25 considered.
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5735 1 The transients consider two effects of the 2 stratification. One effect is the overall bending 3 moment that occurs from the stratification in the 4 line, which is different than if you assume the line 5 to be at a uniform temperature. Those bending loads 6 are included in the analyses of the nozzles.
7 The other aspect of the stratification on 8 the nozzle at the hot leg, which is, you know, two --
9 in this evaluation, I should say, two locations that 10 are controlling or evaluated. The hot leg nozzle, 11 which is -- enters the hot leg on a horizontal from a 12 horizontal aspect on the surge line, and then the 13 nozzle on the bottom head of the pressurizer, which is 14 vertical. So, the stratification occurs in the nozzle 15 when, and only when, the reactor coolant pump is not 16 running.
17 When the reactor coolant pump is running, 18 stratification can occur in the line, but not in the 19 nozzle, because of the turbulence caused by the 20 reactor coolant pump in the loop.
21 So, when the -- when the nozzle is 22 stratified, that only occurs when the reactor coolant 23 pump is off. And this has all been discussed in WCAP 24 12639, which I Can find that exhibit number for you.
25 WCAP 12639 is the documentation of the Owners Group NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5736 1 studies of surge line stratification.
2 When the stratification occurs in the hot 3 leg nozzle, there is an out-surge that has to come 4 from the pressurizer to create that hot layer on the 5 top. And then the cold layer is fed by the hot leg 6 water.
7 Since the surge line is an open line, 8 theres no valves in it or anything. You get this 9 communication between the hot and the cold.
10 When the temperature difference is very 11 high, the stratification is more severe as far as its 12 effect on the stresses. So, when you evaluate the 13 nozzle, you evaluate the nozzle for the fact that this 14 stratification comes and goes.
15 It was analyzed conservatively for those 16 local effects by just assuming that it steps from 17 stratified condition to a non-stratified condition and 18 back.
19 So, those cycles are considered in the 20 fatigue evaluation of the nozzle, as well as the 21 bending moments coincident with that same thing 22 happening in the line, because you get a range of load 23 which gives you a range of stress from that.
24 A question that was raised was with 25 respect to when you have the stratification layer, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5737 1 there has also been observed historically not in surge 2 lines, but in feedwater lines back in the late 70s, 3 a term called thermal striping. Which what happens 4 is that layer, that interface between hot and cold 5 layers will begin to fluctuate at a very high 6 frequency. This caused, actually, cracking in 7 feedwater nozzles.
8 Number one, the presence of thermal 9 striping in feedwater nozzles caused them to fail in 10 a rather short period of time, because its a high-11 cycle fatigue phenomena.
12 Those -- because of those failures, there 13 were studies done of feedwater lines and nozzles in 14 particular really to investigate the cause of the 15 cracking which identified this striping phenomenon.
16 Thats also in WCAP 9693, which is also an 17 exhibit. Let me see if I can pull that up.
18 (Pause.)
19 MR. KUYLER: Your Honor, thats Entergy 20 Exhibit 217, WCAP 9693.
21 MR. GRAY: And actually the surge line 22 WCAP is 218. So, anyway, not to get into lots of 23 detail, but you can look in 9693, I think its in 24 section -- its a big volume. Section 1073. And I 25 can confirm that. I have notes on that where it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5738 1 pretty much gives the conclusions of a whole testing 2 program where they had to simulate what was happening 3 in the feedwater lines to determine what it took to 4 get this fluctuating interface at very low flow rates.
5 And feedwater lines are a little different 6 at this weld. The aux feed water is very cold coming 7 in. So, you get an even higher temperature 8 differential, which gives you a higher Richardson 9 number, which is the dimensionless quantity thats 10 used to determine whether you can have stratification 11 or not.
12 So, with those high Richardson numbers in 13 the feedwater line, you -- they had to get in 14 conjunction with the high Richardson number and the 15 stratification, a high enough flow in that cold layer 16 coming in so that -- and there were a number of 17 conditions that are summarized in WCAP 9693.
18 One is you have to have a persistent flow 19 of that cold layer. And it has to be a high enough 20 flow characterized by the Reynolds number that creates 21 this condition where that interface becomes unstable.
22 So, they describe two different 23 conditions. A stable interface with the low flows, 24 and a -- the wavy interface, is what they call it, for 25 the high flows. That occurs in feedwater lines NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5739 1 because of the conditions under which stratification 2 occurs in that continuous flow.
3 In surge lines, the characteristics of the 4 stratification transients is discussed in WCAP 12639.
5 We observed at least 15 plants worth of data. Youre 6 not going to observe striping in thermal couples on 7 the outside of the pipe. So, you dont see that.
8 The feedwater testing had to put sensors 9 on the inside in the test loop. So, the -- but the 10 characteristics of the transients when the 11 stratification comes and goes was observed in 12639.
12 It was used to develop the distributions of the cycles 13 of stratification that I described before.
14 What happens is the stratification is not 15 a sustained situation in the surge line because of 16 this communication back and forth between the hot leg 17 and the pressurizer. So, as a result of that, you 18 dont have that sustained condition.
19 Number two, a I mentioned before, the only 20 conditions under which the hot leg nozzle is 21 stratified is when the reactor coolant pump is off.
22 When the reactor coolant pump is off, you dont have 23 a source of spray flow, because any appreciable 24 velocity or flow, Reynolds number, again, for that 25 difference to cause a wavy interface.
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5740 1 And number three, WCAP 12639 though it 2 does consider striping because it was in the early 3 days of, you know, the development of surge line 4 stratification, it states very clearly and references 5 studies that thermal striping in the surge line is 6 inconsequential. Insignificant, I think the word is 7 what it uses.
8 JUDGE WARDWELL: Okay. Thank you. Im 9 all set.
10 CHAIRMAN McDADE: That concludes the 11 questions we have directly on Contention 26. I 12 propose to take a 10-minute break before we start 13 considering Contention 38.
14 Is there anything else that we need to 15 take up?
16 DR. LAHEY: Your Honor, Id like to try to 17 clarify for the record something that came up under 18 26.
19 CHAIRMAN McDADE: Okay. Hold that for 20 just a second, Dr. Lahey. Ms. Sutton or --
21 MR. KUYLER: Yes, Your Honor. There were 22 two items that I believe Your Honors had asked our 23 witnesses to look into yesterday, substantive matters 24 on this contention that I believe Mr. Gray has some 25 responses to.
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5741 1 CHAIRMAN McDADE: Okay. Specifically with 2 regard to the methodology used to address thermal 3 coupling?
4 MR. KUYLER: Yes.
5 CHAIRMAN McDADE: Is that the first one?
6 MR. KUYLER: Yes, Your Honor.
7 CHAIRMAN McDADE: Okay. Mr. Gray.
8 MR. GRAY: Yes, Your Honor. The question 9 was to where do we have an example in the record 10 showing how we treated the thermal couple data, the 11 sensors from the plant and how those were used for 12 incorporation into the transients and the transient 13 binning that I described.
14 Entergy 689, which is WCAP 12191, Section 15 2.6 describes the process used to characterize the 16 system transients based on the Delta-T. The 17 corresponding -- and thats for the charging system, 18 by the way.
19 The corresponding use of those -- of that 20 information is documented in Entergy 727, which is 21 calculation CN PAFN 0921. In Appendix A.3.1 of that 22 calculation, it describes how that information was 23 applied to the stress model to calculate fatigue.
24 CHAIRMAN McDADE: Okay. Thank you, Mr.
25 Gray.
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5742 1 MR. GRAY: I would like to also answer 2 another thing that was brought up, if I may.
3 CHAIRMAN McDADE: Can you give us general 4 life here of what it is before you jump into it?
5 MR. GRAY: Yes. Dr. Lahey stated that we 6 used elastic plastic analysis from MB 3228 of the 7 code. And we -- and I stated that we did not. I 8 would just like to clarify what may have occurred with 9 that.
10 CHAIRMAN McDADE: Please.
11 MR. GRAY: Okay. While MB 3228 of the 12 ASME code allows you to do a plastic analysis, the 13 section of MB 3228 that describes that is 3228.3.
14 This is commonly referred to as elastic plastic 15 analysis where you calculate strains. And from those 16 strains, you use those in your analysis. We did not 17 do that elastic plastic analysis.
18 What he may have been confused by in our 19 calculations and documentation is the fact that when 20 you do the linear elastic analysis of MB 3200, MB 21 3228.5, which I mentioned yesterday in my testimony, 22 describes a factor called K-E. Its a penalty that 23 you put on your elastic stress when you exceed certain 24 limits. And so, it allows you to exceed those limits 25 of stress equations when you penalize your usage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5743 1 factor calculation.
2 Thats called a simplified elastic plastic 3 correction factor in the code. So, you could see the 4 words elastic plastic with respect to the Ke penalty 5 factor, but its not the same as doing a 3228.3 6 plastic analysis.
7 CHAIRMAN McDADE: Okay. Thank you. Okay.
8 Dr. Lahey, before you proceed, what I was thinking it 9 might be appropriate to do, theres a couple of 10 references there to Entergy 689 and 727 relating to 11 methodology and I think were probably going to want 12 you to comment on those methodologies.
13 And it may be appropriate for us before 14 you begin to, you know, augment your testimony, to 15 take that break to give you the opportunity to take a 16 look at those two exhibits, see whether or not you 17 need additional time to review them before you 18 comment.
19 I mean, its -- when we move on from 26, 20 its not like this is a strong wall, you know, we can 21 come back to it later. A lot of these contentions 22 obviously are interrelated, but I would like to give 23 you the opportunity to at least take a look at those 24 two exhibits and that may be helpful in some questions 25 that we have when you come back.
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5744 1 DR. LAHEY: Ill do that over the break, 2 Your Honor.
3 CHAIRMAN McDADE: And it may well be, I 4 mean, were only going to take, you know, well break 5 until 10 minutes after 10:00. It may be that youll 6 need additional time. And if so, just, you know, let 7 us know.
8 Is there anything else we should take up 9 before the break, Ms. Sutton?
10 MS. SUTTON: No, nothing further, Your 11 Honor.
12 CHAIRMAN McDADE: Mr. Kuyler?
13 MR. KUYLER: Nothing further, Your Honor.
14 CHAIRMAN McDADE: Brian Harris.
15 MR. HARRIS: No, Your Honor.
16 CHAIRMAN McDADE: Okay. Well stand in 17 recess then to 10:10.
18 (Whereupon, the proceedings went off the 19 record at 9:55 a.m. and resumed at 10:10 a.m.)
20 CHAIRMAN McDADE: The hearing will come to 21 order.
22 MR. SIPOS: Judge McDade, this is John 23 Sipos for the State of New York. Dr. Lahey would like 24 some additional time to review those documents.
25 CHAIRMAN McDADE: Okay. Should we then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5745 1 take the additional testimony from Dr. Lahey up after 2 lunch? Would that be appropriate?
3 DR. LAHEY: That would be fine. I could 4 do them both at the same time after lunch.
5 CHAIRMAN McDADE: Okay. And we will 6 determine, I mean, there may or may not be significant 7 questions after that, but you indicated that you had 8 certain things that you wanted to clarify.
9 DR. LAHEY: Yes.
10 CHAIRMAN McDADE: And that may lead to 11 additional questioning by the Board. But at this 12 point, then, we might as well move on to 38. Before 13 we do, I believe Dr. Duquette is the only potential 14 witness who has not yet been sworn at least looking 15 out at the gallery of witnesses.
16 Dr. Duquette, would you please rise?
17 Would you raise your right hand? Do you swear that 18 the testimony you will give in this proceeding subject 19 to the penalties of perjury will be the truth, the 20 whole truth and nothing but the truth?
21 DR. DUQUETTE: I do.
22 CHAIRMAN McDADE: Okay. Please be seated.
23 and for the record, would you please state your full 24 name?
25 DR. DUQUETTE: My name is David Duquette.
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5746 1 CHAIRMAN McDADE: Okay. Dr. Duquette, a 2 couple of things that weve mentioned to other 3 witnesses before you were here. Its necessary for us 4 to maintain a transcript.
5 If a question is asked generally to the 6 intervenor witnesses and youre the one who is going 7 to respond, if you could state your name first to make 8 sure that the court reporter is able to attribute it 9 to you as opposed to Dr. Lahey or Dr. Hopenfeld.
10 If the question is directly to you, for 11 example, if I ask, Dr. Duquette, would you comment on 12 something, theres no need for you then again to 13 repeat your name, you know, because it will be clear 14 on the record who it is whos testifying.
15 Also, we just took a break. Well 16 probably go now until lunch. But if any witness needs 17 a break, you know, before the Board, you know, decides 18 we need a break, they should just simply, you know, 19 let us know and we can accommodate that.
20 I think those are the only bits of 21 information that I really needed to bring out to you 22 that you wouldnt already be aware of. So, with that, 23 I want to --
24 MR. BESSETTE: Your Honor, this is Paul 25 Bessette for Entergy. I just want to introduce Martin NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5747 1 ONeill has joined us as Entergy counsel for this 2 contention.
3 CHAIRMAN McDADE: Yes, we are very 4 familiar with Mr. ONeill from Track 1 and from all of 5 the pleadings.
6 Before we go further, I wanted to talk a 7 little bit about what we intend to do now. Were 8 moving on to Contention 38.
9 Theres a lot of overlap between the 10 various contentions and it is not our intent at this 11 point to revisit issues regarding the adequacy of the 12 AMP for RVIs that were covered, you know, by Judge 13 Wardwell the first two days of this hearing.
14 And, likewise, we dont intend to revisit 15 issues relating to metal fatigue and CUF values and 16 environmental adjustments and the various WESTEMS 17 issues that were covered by Judge Kennedy. Its not 18 our intent. Although some of those are applicable to 19 Contention 38 and Riverkeeper TC5, the combined 20 contention, we are not going to revisit them.
21 Likewise, with regard to the license 22 conditions that are a part of Contention 38, we --
23 there are sort of two aspects to that. One has to do 24 with enforceability, and the other has to do with 25 adequacy in order to provide reasonable assurance.
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5748 1 The first part of that, the 2 enforceability, is primarily a legal contention. So, 3 theres going to be minimal testimony that were going 4 to be eliciting on that just simply to ensure that we 5 understand how in practice this is going to be carried 6 out by the Agency. So, were going to be focusing 7 primarily on the adequacy of these individual 8 commitments in order to provide reasonable assurance.
9 That said with a preface, I want to know, 10 I mean, the parties have submitted detailed questions 11 that they propose the Board to ask. As you know form 12 the first few days of this, many of those questions 13 were not asked by members of the Board. And part of 14 that is a -- the concept of why were having this 15 hearing and what the Board is hoping to get out of it.
16 All of the parties to this have submitted 17 detailed presentations and detailed testimony. Many 18 issues are clear and it isnt necessary for the Board 19 to go through those again.
20 When the parties were preparing their 21 questions, obviously you had no way of knowing what, 22 if anything, the Board understood from the 23 submissions. But, so, in those instances where the 24 Board felt that it didnt need clarification, we 25 simply didnt go forward and ask those particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5749 1 questions. I say that as a preface to this.
2 In the Track 1, we had questions at the 3 end of the hearing from the parties and the question 4 arises as to how to handle that in this Track 2 5 proceeding. And what we would be looking for or, in 6 any event, even possibly amenable to are not to allow 7 parties to go through all of the questions that they 8 propose that werent answered, but only questions that 9 were specifically addressed where their own party, one 10 of their own witnesses, said something that you 11 believe is either incorrect or perhaps misleading the 12 way it came across, or that an opposing partys 13 witness testified to that you believe was misleading 14 or incorrect and had not already been addressed.
15 Because in many instances, weve gone back and forth 16 and the differences between the positions of the 17 witnesses were very clear.
18 So, what we would be looking for is a very 19 small universe. And what we would like counsel to do 20 is after lunch, to be prepared to discuss with us 21 before we begin testimony again, how you want to 22 proceed in that regard whether there are any 23 additional questions that you think need to be asked 24 in order to clarify or complete the record. And then 25 if so, whether it would be more efficient for you to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5750 1 advise us generally as to those issues you wish us to 2 consider, or alternatively to allow counsel to ask 3 questions.
4 We did allow counsel to ask questions at 5 the Track 1 hearing. Those questions were short.
6 They were focused. None of the parties took more than 7 30 minutes. And we certainly would envision if it 8 were sent to the parties, to ask some questions 9 relatively short, relatively focused on those areas 10 that I just addressed.
11 Are there any questions with regard to 12 what Ive just gone through from Entergy?
13 MR. BESSETTE: No, Your Honor. Thank you.
14 CHAIRMAN McDADE: From the staff?
15 MR. HARRIS: No, Your Honor. Thank you.
16 CHAIRMAN McDADE: New York?
17 MR. SIPOS: No, not now, Your Honor.
18 CHAIRMAN McDADE: Riverkeeper?
19 MS. BRANCATO: No, thank you.
20 CHAIRMAN McDADE: Okay. Thank you. Okay.
21 Dr. Hiser, some -- and basically, you know, one of our 22 purposes also in addition to clarify sometimes is to 23 summarize, you know, so we have in one place in the 24 record what perhaps in the exhibits and the testimony 25 is spread out over a relatively long period of time.
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5751 1 And nothing that I say is evidence. Its 2 only something that you say is evidence, but sometimes 3 Ill ask a question, Ill sort of summarize and ask 4 you whether or not it accurately reflects the position 5 of the NRC staff so that its on the record.
6 And then it is your testimony, youre the 7 one whos swearing to it under oath, because Im not 8 under oath, and you are in a much better position to 9 speak with confidence about what the NRCs position is 10 than am I.
11 Okay. That said, is it the position of 12 the NRC staff that license commitments made as part of 13 the license renewal are part of the CLB and are 14 enforceable under the ongoing oversight process 15 established by Part 50, specifically 10 CFR 54.33? Is 16 that something that you feel --
17 DR. HISER: I would just need to review 18 54.33, Your Honor.
19 CHAIRMAN McDADE: Okay. Lets strike the 20 particular citation. Is it the general view without 21 getting into the legal citation, that these license 22 commitments become part of the CLB?
23 DR. HISER: As incorporated -- in 24 particular as incorporated through a license condition 25 in the UFSAR, they are.
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5752 1 CHAIRMAN McDADE: Okay. Now, most license 2 commitments are captured in the FSAR, the Final Safety 3 Analysis Report. Some are made as license conditions 4 due to high regulatory or safety significance, 5 correct?
6 DR. HISER: Yes, thats correct.
7 CHAIRMAN McDADE: Okay. And there are 8 also others that I believe are referred to as 9 regulatory commitments; is that correct?
10 DR. HISER: Within the context of license 11 renewal, I dont --
12 CHAIRMAN McDADE: Yes.
13 DR. HISER: -- believe we use that 14 terminology. We have -- applicants make commitments 15 that are -- would be incorporated in the UFSAR. And 16 those are the only commitments that are -- pertain to 17 license renewal.
18 CHAIRMAN McDADE: Okay. In this 19 particular instance weve got -- we have commitments 20 30, 41, 42, 43, 44 and 49. Which category do these 21 commitments fall in?
22 DR. HISER: Those would be under the 23 license renewal commitment that would be incorporated 24 in the UFSAR that once the license is -- renewed 25 license is issued for the plant, then that would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5753 1 become a part of the CLB for the plant.
2 So, each of those commitments would be 3 included within the discussion that we had several 4 questions ago.
5 CHAIRMAN McDADE: Okay. Now, some of 6 these commitments are ongoing, for example, such as 7 Commitment 30. And others are commitments that are 8 completed and then they can be closed; is that 9 correct?
10 DR. HISER: Yes, thats correct.
11 CHAIRMAN McDADE: Okay. Commitment 43 and 12 49, the technical analysis for IP3, is that complete?
13 DR. HISER: If I can just review records 14 for a moment?
15 CHAIRMAN McDADE: Okay. As I understand 16 it, there were two, you know, with regard to IP3.
17 Theres a question of it being complete with regard to 18 IP3. theres an indication that Entergy will close 19 the commitment for IP3 prior to the PEO. And Im just 20 trying to get what the status is as far as the 21 completion of the commitment with regard to IP3.
22 DR. HISER: If you could repeat the 23 commitment numbers.
24 CHAIRMAN McDADE: These have to do with 25 Commitments 43 and 49. I believe theyre addressed in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5754 1 the Entergy answer -- testimony -- well --
2 DR. HISER: That is my understanding. For 3 IP2, those are closed. For IP3, they are still open.
4 CHAIRMAN McDADE: Okay. And what does 5 that mean in this particular context that Entergy will 6 close the commitments? What still needs to be done in 7 order to close the commitments?
8 DR. HISER: What is needed -- actually, 9 closure may not be the correct work, but really 10 completion of the action thats specified in the 11 commitment is what would be necessary for the 12 applicant to be able to state that they had fulfilled 13 the commitment. So, whatever action is specified 14 would need to be completed.
15 CHAIRMAN McDADE: Okay.
16 JUDGE WARDWELL: While youre looking, may 17 I ask Entergy under your testimony, I think it was 18 Answer 113, Page 69 through 70, you state that the 19 limiting location reviews required by Commitments 43 20 and 49 have been completed for both IP2 and 3; is that 21 correct?
22 MR. AZEVEDO: This is Nelson Azevedo for 23 Entergy. That is correct, Your Honor.
24 JUDGE WARDWELL: So, in your position as 25 far as your position is concerned, what is left to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5755 1 done in regards to closing out 43 and 49?
2 MR. AZEVEDO: So, after we closed it for 3 Unit 2, theres still some calculations that need to 4 be completed. And those have been completed and 5 theyve been reviewed. Theyve been -- it was part of 6 the NRC onsite audit back, I believe, in August. So, 7 but those are complete.
8 JUDGE WARDWELL: Is there any reason why 9 those particular limiting locations werent identified 10 as part of your initial application rather than have 11 to be put off as a commitment? Because if we had run 12 our hearings at any reasonable amount of schedule, 13 they would still be outstanding.
14 MR. AZEVEDO: Well, you know, the only 15 thing Id say is these calculations are extensive 16 calculations and they took time and we just didnt 17 feel that we needed to complete the Unit 3 portion 18 when we completed the Unit 2 portion.
19 So, the Unit 3 portion was extended beyond 20 the Unit 2 portion. Thats why they were still open, 21 but again they were completed early this year and the 22 commitments are closed.
23 JUDGE WARDWELL: Okay. Thank you.
24 MR. DOLANSKY: This is Bob Dolansky for 25 Entergy. Judge McDade, you had mentioned earlier NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5756 1 Commitment 30 you thought was open. I believe 2 Commitment 30 is complete.
3 CHAIRMAN McDADE: Well, Commitment 30 is 4 ongoing; is it not? It has continuing obligations.
5 Its been accepted by the NRC staff, and the NRC staff 6 has determined that it provides adequate assurance and 7 there are actions that need to be continually done 8 over the course of the period of extended operation in 9 the event the license is granted, correct?
10 MR. DOLANSKY: You are correct. We closed 11 it.
12 CHAIRMAN McDADE: Okay. And compliance 13 with Contention 30 then would be monitored, as you 14 indicated earlier, Dr. Hiser, under the FSAR and/or 15 the --
16 DR. HISER: Actually, I would say that 17 that item is completed. This is the original 18 commitment made in the original application regarding 19 the reactor vessel internals aging management.
20 With the submission of the AMP by the 21 applicant and the inspection plan, then that 22 effectively completed this commitment. So, we would 23 consider that to be complete.
24 CHAIRMAN McDADE: But the commitment also 25 includes then doing what is in the AMP that was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5757 1 submitted. You will monitor compliance. It envisions 2 various actions will be taken over the next 20 years.
3 DR. HISER: I guess the way that I would 4 interpret the commitment when it says evaluate and 5 implement the results, I think the development of the 6 AMP, the development of the inspection plan fulfilled 7 the commitment and implementation of the program 8 inspections, analyses, et cetera, is just a part of 9 implementation then of the AMP. So, I think from my 10 personal perspective, I would consider 30 to be 11 completed.
12 CHAIRMAN McDADE: Okay, but it is now part 13 of the FSAR, correct?
14 DR. HISER: It is a part of the FSAR that 15 would be identified as being completed. And this 16 happens many times. As we review applications and 17 applicants make commitments, sometimes theyre 18 completed before it becomes a part of the FSAR.
19 MR. COX: Judge McDade, Id like to 20 clarify that also. This is Alan Cox for Entergy. The 21 commitment was to submit the inspection plan and the 22 program. That was done.
23 That program has been incorporated into 24 the FSAR supplement. So, in that sense it will be an 25 ongoing commitment. Its now part of the FSAR thats NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5758 1 described there. Any changes to that will be done 2 under 5059. So, in essence, thats how that will be 3 controlled going forward.
4 MR. TURK: Your Honor, this is Sherwin 5 Turk.
6 CHAIRMAN McDADE:: Yes, Mr. Turk.
7 MR. TURK: Just as a point of information 8 if were looking at the SER supplement Number 2 where 9 there is a list of the commitments and the status as 10 of the time of the --
11 CHAIRMAN McDADE: Yes.
12 MR. TURK: -- SER 2 issuance, youll note 13 that theres a date of December 15 -- or December 12, 14 2015, for IP3. Thats the date that the Unit would --
15 the original license would expire and that would then 16 be going into the period of time to renewal until a 17 decision is made by the NRC as to whether license 18 renewal should be issued.
19 There were some recent correspondence from 20 Entergy that it might be worthwhile to note at this 21 point. Entergy, as you know, for Unit 2 sent in a 22 status report before Unit 2 entered the period of time 23 to renewal. And at that time they indicated that the 24 license commitments had been implemented for Unit 2.
25 There was also recent correspondence NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5759 1 regarding Unit 3. It may be that its important for 2 the witnesses to explain to you what has happened with 3 regard to Unit 3 so that you understand the status 4 currently.
5 CHAIRMAN McDADE: Okay. Thank you, Mr.
6 Turk.
7 Are you prepared to do that, Dr. Hiser, or 8 --
9 MR. TURK: Or perhaps the Entergy 10 witnesses could address that, Your Honor.
11 MR. STROSNIDER: this is Jack Strosnider 12 for Entergy and Im familiar with some of whats been 13 referred to. And I dont know that these are exhibits 14 on the docket, but in the case of Unit 2 as an example 15 what Entergy committed to do, two things.
16 One was to submit a letter to NRC 17 confirming complete implementation of Unit 2 license 18 renewal commitments required to be implemented prior 19 to entering the period of extended operation. And the 20 date for that to be completed was August 2013.
21 The second commitment was to modify the 22 Unit 2 updated Final Safety Analysis Report, 23 incorporate Unit 2 materials set forth in Appendix A 24 of the application, and develop a new appendix into 25 the Unit 2 FSAR, as well as updating correspondence NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5760 1 sections of the UFSAR with new or modified information 2 programs and transmit a letter to NRC confirming that 3 that had been completed. The completion date that was 4 established for that was September 28, 2013.
5 So, essentially this would confirm 6 completion of the commitments that were to be 7 completed before entering the period of extended 8 operation and to put into the updated FSAR those 9 commitments that will be ongoing throughout that 10 period of extended operation, which, as was noted, 11 would put them under the control of 5059.
12 Thats in an August 19, 2013 letter to --
13 actually, this is to Entergy from the NRC, but I think 14 what was being referred to is thats the general 15 philosophy of how this -- how these commitments are 16 managed in terms of being completed before entering 17 the period and what needs to be continued during the 18 period of operation -- extended operation.
19 MR. COX: This is Alan Cox again. Thats 20 correct and that was a description of what was agreed 21 upon for IP2. Similar actions are being done for IP3 22 prior to their PEO, which begins in December.
23 CHAIRMAN McDADE: Okay. Thank you, Mr.
24 Cox. Let me move on to Entergy. Can you explain what 25 peak editing under the WESTEMS system is, and explain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5761 1 why and how it is done, you know, perhaps specifically 2 addressing with regard to the pressure spray nozzle 3 evaluation for IP2?
4 MR. GRAY: This is Mark Gray for Entergy.
5 This is a technique that is employed in the analysis.
6 It basically when you do a fatigue analysis whether it 7 be with a computer program or manually, you have to 8 select the maximum and minimum stress states to form 9 your stress cycle pairs as dictated by the ASME code 10 in MB 3222.4(e)(5).
11 The way that you do that has developed 12 over the years. Different analysts use different 13 techniques. In the computer program that was used, 14 the program does an automated accounting for those 15 peaks and valleys, maxima and minima.
16 When it does that, there are two different 17 quantities of stress that are -- that have to be 18 employed because of their effect on the elastic 19 plastic penalty factor, as well as the total stresses 20 in the analysis.
21 So, the program since its an automated 22 approach, is developed as a tool for the engineer to 23 use. And in that regard, it will select more -- it 24 can potentially select more peaks and valleys than are 25 really needed for the evaluation.
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5762 1 In the practical application of the 2 program when those peaks and valleys are reviewed, the 3 analyst can then, if needed, identify those times that 4 are redundant with others.
5 Typical example. If the analyst defines 6 his transient for a heat-up, it goes from a stress-7 free condition to some stress state at the end of the 8 transient. For a cool-down, you do just the opposite.
9 So, the end of the heat-up, a stress 10 state, is the same as the beginning of the cool-down.
11 Well, the program doesnt know that those are really 12 the same state. It will select them both.
13 So, the analyst has the option of leaving 14 that conservatism in there and having more fatigue 15 pairs than really required and leaving that 16 conservatism and still have an acceptable answer, or 17 the analyst has the option to do a re-analysis with 18 those results eliminating the redundant stress states.
19 This is what we call peak editing. So, he removed 20 those states, re-analyzes and documents the final 21 result.
22 CHAIRMAN McDADE: Okay. In your pre-file 23 testimony, Dr. Lahey and Dr. Hopenfeld, you both 24 address the issue of peak editing and had criticisms 25 of it. In light of what Mr. Gray has just said, let NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5763 1 me ask Dr. Lahey first, then Dr. Hopenfeld, Can you 2 explain any continued concerns you have with the use 3 of peak editing?
4 DR. LAHEY: Your Honor, I dont recall 5 having expressed any concern about peak editing. I 6 understand the process. I think if its done by 7 experienced analysts, theres nothing wrong with it.
8 CHAIRMAN McDADE: Okay. Dr. Hopenfeld.
9 DR. HOPENFELD: I feel the same, except 10 one thing I do not understand, it was mentioned you 11 see the Fen if you look at the data, shows that 12 increases with the strain decreasing and its a 13 substantial change. So, what it says is really that 14 during transients, the length of the transients, the 15 strain may decrease.
16 Now, its not clear how that was accounted 17 or I couldnt tell without really going just from the 18 description was provided. Maybe it was okay, maybe 19 not, but I have no problem.
20 This is a standard procedure, and I 21 mentioned before the pagoda or the raindrop procedure 22 of how to put these things together and how to 23 identify and count the transients. That aspect of it 24 Im not worried.
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5764 1 there. And what I do worry about in some of the 2 expression I heard yesterday about that these things 3 are in the code, about the Fen and so forth, that 4 there -- if they rationalize that everything is in the 5 code, it doesnt -- they can come up with any number.
6 I have no way of -- to determine what 7 their uncertainties were, but the main thing is that 8 I was concerned is, oh, I didnt understand how do 9 they treat the effect of the Fen being increased with 10 strain decreased.
11 CHAIRMAN McDADE: Okay. Thank you, Dr.
12 Hopenfeld.
13 JUDGE WARDWELL: Just to make sure I 14 understand this also, Dr. Lahey, do you agree that the 15 term peak editing and user intervention are the 16 same in this particular -- certainly in regards to 17 Commitment -- I believe its 44.
18 DR. LAHEY: Its my understanding, Your 19 Honor, that the US NRC when they refer to user 20 intervention, theyre talking specifically about peak 21 editing. When I use that term, its more general.
22 It has to do with the injuring judgments 23 and other things the analysts can do to the code.
24 JUDGE WARDWELL: Okay. Thank you. And, 25 Entergy, is that your understanding also in regards to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5765 1 that for -- in regards to Commitment 44, the user 2 intervention, if that term is seen as the same as peak 3 editing?
4 MR. AZEVEDO: This is Nelson Azevedo, for 5 Entergy. Thats correct, Your Honor.
6 JUDGE WARDWELL: Thank you.
7 CHAIRMAN McDADE: With regard to 8 Commitment 41 for the steam generators, theres an 9 option either to redefine the pressure boundary, or to 10 inspect the tube-to-tubesheet welds.
11 There was a process for License Amendment 12 277 that has been completed. And with regard to the 13 other unit, it has not been.
14 Can you explain briefly the sort of 15 theoretical justification for taking the tube-to-16 tubesheet welds out of the definition of reactor 17 boundary, pressure boundary, Entergy?
18 MR. DOLANSKY: This is Bob Dolansky with 19 Entergy. First, just to clarify, that option is in 20 Commitment 42, not 41.
21 CHAIRMAN McDADE: Im sorry.
22 MR. DOLANSKY: So, thats called H star 23 analysis. So, when we talk about the H star analysis, 24 what that does is that takes the -- in very high level 25 -- Ill just give a high-level overview. You have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5766 1 tubesheet which is approximately 22 inches thick. And 2 the tubes are inserted into the tubesheet.
3 Theyre rolled into the tubesheet, which 4 means theyre pressed up against the hole in the 5 tubesheet. So, theres an interference fit. When 6 its manufactured, a little piece of the tube is left 7 at the bottom of the tubesheet. That piece of tube is 8 then welded to the tubesheet on the primary side.
9 That makes the tube-to-tubesheet weld.
10 So, what H star does is it takes -- it 11 does an analysis that shows that the -- under all 12 accident-required conditions under current licensing 13 basis loads and so forth, that no matter what happens 14 seismic, you know, LOCA loads, shock loads, whatever 15 you want to call it, that the tubes would not pull out 16 even if that weld were not there.
17 So, by doing that, they determine how much 18 of that tube you need inside the tubesheet to 19 withstand all the required forces. And thats called 20 your H star distance.
21 So, at IP2 we got the H star analysis 22 done. And that basically determined using round 23 numbers, approximately 19 inches from the top of the 24 secondary side of the tubesheet, you go down 19 25 inches, which leaves approximately three inches on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5767 1 bottom, but you dont need that to maintain your 2 pressure boundary.
3 So, we redefined the pressure boundary 4 from the weld at -- on the primary side to 5 approximately three inches up inside the tubesheet.
6 MR. AZEVEDO: Your Honor, this is Nelson 7 Azevedo. Let me just add a little bit to what Mr.
8 Dolansky just said.
9 In addition to the structural component to 10 make sure the tube stays in place, the interference 11 fit between the tube and the tubesheet hole also make 12 sure that the leakage, if there is any leakage, is 13 within acceptable limits. So, the interference fit 14 theres two things; leakage, and provide the 15 structural integrity for the tube.
16 MR. DOLANSKY: Right. And thank you, 17 Nelson. This is Bob Dolansky again with Entergy. So, 18 effectively what weve done is weve said that the 19 bottom three inches of the tube could go away, could 20 totally be gone and we would meet for both leakage and 21 structural, we would meet all requirements under all 22 accident conditions.
23 CHAIRMAN McDADE: Okay. Now, with regard 24 to Indian Point 2 in September of 2014, there was a 25 license amendment that was granted by the NRC.
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5768 1 What is the current status with regard to 2 Indian Point 3? You had the two options. One was to 3 redefine the boundary. The other was to inspect the 4 tube-to-tubesheet welds.
5 Whats the current status?
6 MR. DOLANSKY: This is Bob Dolansky with 7 Entergy. Commitment 42 is very, very specific. It 8 was written in a very specific and clear way. So, 9 under Option 1 analysis, IPEC will perform an 10 analytical evaluation of the tube-to-tubesheet welds 11 in order to establish a technical basis for either 12 determining that the tubesheet cladding and welds are 13 not susceptible to PWSCC, or redefining the pressure 14 boundary in which the tube-to-tubesheet weld is no 15 longer included and, therefore, is not required for 16 the reactor coolant pressure boundary function.
17 So, that second part is what we did for 18 Unit 2. And the last sentence, the redefinition of 19 the reactor coolant pressure boundary must be approved 20 by the NRC is a license amendment request, thats what 21 we did with H star. We basically submitted that as a 22 license amendment request. The staff reviewed it and 23 approved it.
24 For IP3, our plan -- the plan for IP3 is 25 to do the first part of Option 1, which is to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5769 1 establish a technical basis for determining that the 2 tubesheet cladding and welds are not susceptible to 3 PWSCC. So, that -- when we do that, that would not 4 require the -- we dont have -- that would not be a 5 license amendment request.
6 So, we would plan to do -- to determine 7 that the tubesheet cladding welds at IP3 are not 8 susceptible to PWSCC, and thats how we plan to 9 address it for Unit 3.
10 CHAIRMAN McDADE: Okay, but the license 11 amendment is not in effect for Unit 3 at this time.
12 And the question is, at this time, youre indicating 13 that you are required to and will pursue the technical 14 justification for Option 1.
15 Where do we have reasonable assurance in 16 the IP3 license renewal application at this time that 17 we will -- that the tubesheet welds will continue to 18 maintain their intended function?
19 We dont have the license amendment and we 20 dont have the technical analysis completed at this 21 time. So, if were looking just at the IP3 22 application for license renewal, where does the 23 reasonable assurance come from?
24 MR. DOLANSKY: This is Bob Dolansky with 25 Entergy. I believe our steam generator program NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5770 1 provides the reasonable assurance that the steam 2 generators are maintained in a manner that they can 3 perform their required safety function.
4 CHAIRMAN McDADE: Okay, but we had a 5 situation where as part of the license renewal the 6 staff addressed questions to Entergy. And in 7 response, Entergy suggested that they would do one of 8 two things in order to answer the staffs concern in 9 this regard. That they could either, as you did, 10 apply for a license amendment establishing that this 11 is not part of the pressure boundary and, therefore, 12 does not present a safety issue, or provide the 13 technical, you know, justification with regard to the 14 tube-to-tubesheet welds.
15 Let me move -- Dr. Hiser, can you be of 16 assistance on this?
17 DR. HISER: Yeah, I think -- this is Allen 18 Hiser of the staff. I think if we looked at 54.29 19 where it requires renewed license -- and Ill try to 20 cut out a lot of the words -- renewed license may be 21 issued if the Commission finds that actions have been 22 identified and have been or will be taken with respect 23 to managing the effects of aging with the 24 implementation of this commitment and the 25 implementation of that commitment within the UFSAR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5771 1 that then is controlled by 50.59 and through NRC 2 inspections -- well, let me backup.
3 The imposition of the commitment and it 4 being incorporated in the UFSAR is sufficient to 5 provide the staff with reasonable assurance consistent 6 with 54.29.
7 CHAIRMAN McDADE: And I guess where Im 8 hung up on, Dr. Hiser, is this: The concept provide 9 technical justification, it sort of assumes that once 10 you do the analysis, you may or may not be able to 11 technically justify it.
12 If you havent done the analysis yet, you 13 can assume based on general knowledge that you will be 14 able to do it. But it seems that the Agency was 15 asking for Entergy to provide this technical 16 justification and you havent yet received that 17 technical justification.
18 I mean, isnt it conceivable that the 19 technical justification simply cant be provided?
20 DR. HISER: Well, the commitment has two 21 pieces to it; Option 1, Option 2.
22 CHAIRMAN McDADE: Yes.
23 DR. HISER: If the applicant is unable to 24 complete Option 1, whatever NRC approval is necessary, 25 then Option 2 would become operative and they would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5772 1 required to do the inspection consistent with the 2 completion date for that commitment.
3 So, if the analysis is not necessary right 4 now, it would be necessary that they demonstrate that 5 they meet Option 1, or perform the inspections that 6 are covered by Option 2.
7 CHAIRMAN McDADE: Okay. So, that brings 8 us to the next question. We have the technical, I 9 mean, the -- there are actually multiple options. One 10 was changing, you know, the license amendment which 11 they did for IP3, the technical justification or the 12 inspections. So, lets get down to the inspections 13 themselves and whether or not the inspections are 14 capable of providing the reasonable insurance.
15 Dr. Duquette, you had issues with regard 16 to the adequacy and the nature of the inspections and 17 can you elaborate on that?
18 DR. DUQUETTE: Duquette, New York State.
19 Yes, I am very positive about wanting to see a 20 physical inspection of whats going on in the system.
21 Everything Ive seen indicates that there arent any 22 analyses that are available at least at the present 23 time, or anything in the system that would make me 24 feel comfortable with any kind of a paper analysis 25 that would make me feel comfortable that you couldnt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5773 1 get stress corrosion cracking in the tube-to-tubesheet 2 welds.
3 And so, I think the Option 2, which is the 4 inspection, is the only one that makes any sense.
5 CHAIRMAN McDADE: Well, at this point, you 6 know, one of the things that you raises is saying that 7 there was not an adequate inspection technique.
8 Entergy proposed to use and identify EVT1 as the 9 inspection technique that they would use.
10 What criticisms do you have? Why would 11 you think that EVT1 would not be adequate to 12 accomplish that function?
13 DR. DUQUETTE: I thought I -- in my 14 testimony, Id have to go back and review it, but that 15 there was no industry-accepted technique at the 16 present time. I dont think I meant there was no 17 adequate technique to do that inspection.
18 I think that there are physical methods to 19 do the inspection. Today its being done in other --
20 in foreign steam generators, to my understanding. And 21 so, I think there are techniques that could -- that 22 can be used.
23 I didnt see in anything that was 24 presented to me where Entergy or the NRC had indicated 25 any specific technique, except for a statement that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5774 1 there are techniques that are available. I agree with 2 that, but I would like to see what technique that they 3 are going to use.
4 CHAIRMAN McDADE: Okay. Well, I believe 5 in the testimony Entergy indicated that it would be 6 EVT1. Am I correct there?
7 MR. DOLANSKY: Yes, you are correct. Our 8 plan is to do an EVT1.
9 CHAIRMAN McDADE: Okay. And are you 10 familiar with that inspection technique, Dr. Duquette?
11 DR. DUQUETTE: I dont think I am.
12 CHAIRMAN McDADE: Okay. Mr. Dolansky, Can 13 you briefly explain? I know we had it the other day.
14 We had some detailed discussion of EVT1, but could you 15 just sort of briefly explain the method?
16 MR. DOLANSKY: Yes. EVT -- this is Bob 17 Dolansky with Entergy. Again, just to start at the 18 same point, in Contention 25 we went in some detail 19 about performing an EVT1 to inspect for stress 20 corrosion cracking.
21 So, I think its -- I would say that its 22 understood through the industry that thats an 23 acceptable method, but an EVT1 is a very detailed, 24 close-up, visual examination. It uses a character 25 card.
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5775 1 When you calibrate the EVT1, you have to 2 do a character card. I believe its 0.044-inch height 3 with open case letters such as an O or a C or an E, 4 not something with like a P or a Q that has a tail 5 that would make it a little easier to see.
6 You have to be within a certain distance.
7 Off the top of my head, I dont remember all the 8 details. You have to be within a certain distance and 9 theres a certain scan speed that you have to 10 maintain. And its -- basically an EVT1 is an 11 accepted approach to look for cracking.
12 Does that answer the -- I think thats 13 relatively high level. If anybody else remembers or 14 wants to add anything --
15 CHAIRMAN McDADE: No, I think that should 16 be sufficient. Based on what Mr. Dolansky just said, 17 Dr. Duquette, its my understanding that the purpose 18 of the inspection is to detect cracking.
19 Is there any reason to believe that that 20 method would not be sufficient to detect cracking?
21 DR. DUQUETTE: No, I think it would be --
22 it would detect cracking. And as I indicated, I 23 think, a few minutes ago, I would feel far more 24 comfortable with a physical inspection, which is what 25 that technique implies and probably would work just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5776 1 fine.
2 CHAIRMAN McDADE: Okay. Now, with regard 3 to once -- and I shouldnt say once, rather if 4 cracking is detected, there is specific actions to be 5 taken, correct?
6 MR. DOLANSKY: Any cracking that were 7 detected would be put into our corrective action 8 program, absolutely, yes.
9 DR. DUQUETTE: Im sorry, I didnt hear 10 the answer.
11 MR. DOLANSKY: This is Bob Dolansky with 12 Entergy.
13 DR. DUQUETTE: Duquette, I didnt hear the 14 answer to that.
15 MR. DOLANSKY: If any cracking were 16 detected, it would be put into the Entergy corrective 17 action program just like we do in Section 11 or vessel 18 internals, you know, New York State 25.
19 We go out and perform inspections on an 20 EVT1. If we found anything, it would be put into our 21 corrective action program.
22 CHAIRMAN McDADE: Okay. And that -- and 23 I believe theres reference to SPR-LR Revision 2, 24 which is New York State 161, that the corrective 25 actions would need to be consistent with that; am I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5777 1 correct?
2 MR. DOLANSKY: I dont know the SPR.
3 Could we bring that up and I could look at it? Im 4 not sure what --
5 CHAIRMAN McDADE: New York 161.
6 (Pause.)
7 MR. COX: Your Honor, this is Alan Cox for 8 Entergy.
9 CHAIRMAN McDADE: Yes.
10 MR. COX: The Standard Review Plan for 11 license renewal is what youve called up here. And, 12 again, thats the NRCs guide for reviewing license 13 renewal applications.
14 There are discussions in there about the 15 corrective action program. Im not sure if thats 16 what youre referring to, but it is the same 17 corrective action program that Mr. Dolansky referred 18 to in saying that the inspection results would be 19 entered into that program and evaluated under that 20 program.
21 CHAIRMAN McDADE: And I guess my question 22 was that that corrective action program of necessity 23 needs to be consistent with the provisions of SPR-LR 24 Revision 2. And specifically 8.1-6 to 8.1-7.
25 Dr. Hiser, is that correct?
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5778 1 DR. HISER: Yes, thats correct.
2 CHAIRMAN McDADE: Okay. Let me go on to 3 something else. Talking about the -- weve got the 4 tube-to-tubesheet welds. Were also talking about the 5 divider plate.
6 Can you explain very briefly what the 7 divider plate is?
8 MR. DOLANSKY: This is Bob Dolansky with 9 Entergy. Can we go to the Entergy pre-file testimony?
10 Ill give you the page.
11 CHAIRMAN McDADE: I believe maybe Answer 12 130 you discuss it briefly.
13 MR. DOLANSKY: Yes, sir.
14 MR. COX: Thats Entergy 698 would be the 15 exhibit number.
16 MR. DOLANSKY: Well start on Page 81 and 17 then go to Page 84. So, if we can pull up Page 81 --
18 CHAIRMAN McDADE: Yeah, Im not looking to 19 have you go through the entire several pages. Just 20 very briefly what is the divider plate?
21 MR. DOLANSKY: Okay. Basically -- this is 22 Bob Dolansky with Entergy. When reactor coolant comes 23 in from the reactor, its -- the hottest comes from 24 the reactor, goes through the steam generator at the 25 large U-tube -- through the tubes, which are large U-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5779 1 tubes.
2 Comes in whats called the hot leg, the 3 channel head, goes up through the tube. As its going 4 through the tube, it transfers the heat to the 5 secondary feedwater and then it goes out the cold leg 6 side of the steam generator.
7 So, hot water comes in the channel head, 8 goes through the tube and comes out on the cold side.
9 Theres a divider plate in the middle that just keeps 10 those two sides separate in the channel head.
11 CHAIRMAN McDADE: Okay. And its not part 12 of the coolant system pressure boundary, is it?
13 MR. DOLANSKY: That is correct. And, in 14 fact, at IP3 theres a little thing called a mouse 15 hole. Theres actually a hole in the bottom of the 16 divider plate to allow some -- when we shut down and 17 drain, it allows water to communicate between both 18 sides.
19 CHAIRMAN McDADE: And why -- what is it 20 made out of?
21 MR. DOLANSKY: Its made out of --
22 CHAIRMAN McDADE: Is it Alloy 600 or Alloy 23 690 or --
24 MR. DOLANSKY: We have it in our 25 testimony. I just have to find it. Give me one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5780 1 moment, please, Your Honor.
2 CHAIRMAN McDADE: Well, let me follow. Is 3 it a material thats particularly susceptible to 4 cracking?
5 MR. DOLANSKY: Yes, its a material that 6 is susceptible to PWSCC. Yes, Your Honor. Bob 7 Dolansky with Entergy.
8 CHAIRMAN McDADE: Okay. And what are the 9 implications of cracking in the divider plate?
10 MR. DOLANSKY: Um --
11 CHAIRMAN McDADE: You indicated that its 12 not part of the pressure boundary and there actually 13 is in it, you know, designed a hole.
14 If there is a crack in the divider plate, 15 what consequence is that to the operation of the 16 reactor -- in the steam generator, rather?
17 MR. AZEVEDO: Your Honor, this is Nelson 18 Azevedo. Maybe I can start and some of my colleagues 19 can jump in.
20 It depends if the crack is big enough, it 21 could allow coolant to bypass the tubes themselves.
22 So, the water will come in through the hot leg side 23 and go out the cold leg side without going through the 24 tubes.
25 So, if you imagine after a design basis NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5781 1 accident, you wouldnt be able to remove heat from the 2 primary side. If the divider plate was gone, then the 3 water just bypassed the tubes. So, you lose that 4 ability.
5 CHAIRMAN McDADE: Okay. So, although it 6 does not -- it is not part of the pressure boundary, 7 it, nevertheless, plays a significant safety function.
8 MR. AZEVEDO: It plays a function. Im 9 not sure if its a significant safety function.
10 Again, maybe somebody can jump in.
11 MR. STROSNIDER: This is Jack Strosnider 12 for Entergy. So, I dont have the reference right at 13 hand, but the Electric Power Research Institute 14 actually has evaluated that condition.
15 They postulated a large thru-wall crack in 16 the divider plate, which would allow this 17 communication between the hot leg -- between the hot 18 side of the channel head and the cold side.
19 And they looked at that from an accident 20 perspective and concluded that it would not -- that 21 you could still meet all the design basis accident 22 conditions that you could -- that you could manage 23 those appropriately even with a large crack in that 24 component.
25 CHAIRMAN McDADE: Thank you. Dr.
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5782 1 Hopenfeld.
2 DR. HOPENFELD: Yes. With regard to the 3 plant, the plate may not play a very -- as EPRI said, 4 it may not play a very important role. It doesnt 5 have an important role in the design basis accident.
6 However, there is a certain sequence of events, 7 especially a station -- after a station -- for a 8 station blackout.
9 You get into a situation thats called 10 high and dry. And you get into the severe accident, 11 but I dont want to get in too far. What happens 12 there, we depend on cooling the core by natural 13 circulation.
14 If that plate is not there, which is not 15 going to be there especially if the hole is very big 16 or the whole thing is gone, so you would have all the 17 coolant bypassing the tubes up and you are not going 18 to be removing the heat from the core. So, there is 19 a concern, but its during severe accidents.
20 However, we have spent -- or Westinghouse 21 spent huge amount of money. This is not a trivial 22 case even though its a severe accident, and we have 23 spent huge amount of studying on this. And all those 24 studies are -- rely on 1/7th scale tests that were 25 done at Westinghouse somewhere in the 70s.
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5783 1 There have been I dont know how many 2 studies and reviews over that. So, all the 3 information we have is based on those studies where 4 the plate was there.
5 Now, they remove the plate. So, what you 6 have done something to the plate. Basically what I 7 mean, its being removed because its not functioning 8 anymore. Now, youve done something that you affect 9 the consequence of whats going to happen during 10 severe accidents.
11 Now, I dont know what the legalities are.
12 But if I remember correctly, there are some things --
13 if you do something to the plant that affects the 14 severe accident, you have to explain it. Now, what 15 EPRI has done, it just didnt carry it far enough.
16 What they have done is okay for normal 17 operation, just small break LOCAs, but its not 18 correct, due to a -- or a situation where you get into 19 the natural circulation.
20 Mr. Strosnider knows exactly what Im 21 talking about, because we discussed EPRI over the 22 years.
23 MR. STROSNIDER: Your Honor.
24 CHAIRMAN McDADE: Just before you --
25 MR. STROSNIDER: Im sorry.
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5784 1 CHAIRMAN McDADE: Dr. Lahey.
2 DR. LAHEY: Richard Lahey, New York. I 3 also reviewed the EPRI report and --
4 JUDGE WARDWELL: Excuse me. Is this the 5 2014 report I saw references to in this commitment 6 testimony -- or really it was a statement of position 7 by Entergy.
8 DR. LAHEY: I have to look back at --
9 MR. ONEILL: Your Honor, this is Mr.
10 ONeill for Entergy. Before we delve any further into 11 the details of the EPRI report, I think the witnesses 12 are referring to the October 2014 EPRI report thats 13 New York State exhibit NYSR0544A through D. I just 14 want to remind the Board and the parties that that is 15 a proprietary document.
16 JUDGE WARDWELL: And, Mr. Strosnider, is 17 that your belief, the report you were referring to?
18 MR. STROSNIDER: Jack Strosnider for 19 Entergy. Yes, I do believe that is the report.
20 DR. LAHEY: So, since its proprietary, 21 does that mean I cant discuss it or --
22 CHAIRMAN McDADE: Right now, I mean, as 23 far as the details go. Discuss what your concerns 24 are.
25 DR. LAHEY: All right. My concerns are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5785 1 always focused on the safety significance. They did 2 an analysis of a thru crack and came up with a flow 3 area, which was relatively small in terms of flow 4 bypass from one side to the other through the plate.
5 However, when they looked at the accident, 6 the largest load that you could put on it, it appeared 7 that what they did is took the high pressure on one 8 side and atmospheric pressure on the other, which is 9 what you would get instantaneously with a loss of 10 coolant accident, and then concluded it could 11 withstand that.
12 It was not at all clear that they did it 13 as an impulsive load. In fact, it appears they did it 14 as a static load. And from my previous testimony, you 15 know, theres a huge difference between hitting 16 something with a sledgehammer and pushing your hand 17 against it with the same force.
18 So, its not at all clear to me that they 19 cant break out the welds and blow out the plate 20 completely. Its a fairly thick plate. Its a couple 21 inches thick. And so, the analysis needs to be done.
22 I asked about it at my testimony. The 23 response I got back was not much. I mean, it did not 24 clarify that issue, in my mind, but I -- the safety 25 significance of it if you lose that plate or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5786 1 significantly create a bypass between one side of the 2 lower plenum of the steam generator and the other, you 3 no longer can use that generator to steam off to 4 remove energy.
5 So, if at the same time -- if the event 6 which causes all this would be a seismic event, for 7 example, and you lose offsite power and then you lose 8 your steaming capability of a steam generator, you 9 have a big problem. You really need the steam 10 generators to allow for the ability of the operators 11 to bring in water separately to cool the core.
12 CHAIRMAN McDADE: Okay. Is it this sort 13 of synthesis of your opinion that it is ill-advised 14 for Entergy to rely on the EPRI report?
15 DR. LAHEY: If my understanding of the 16 EPRI report is incorrect and they have actually done 17 a shock analysis and they have concluded based on 18 those impulsive loads that it can withstand it, then 19 Im okay, but I dont see that.
20 I mean, we talked about the analysis 21 yesterday, I think it was, which had to do with the 22 shock loads on the bolts. The baffle former bolts.
23 And those were not the biggest shock loads you can get 24 by far, because of the way they did it.
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5787 1 do? And even though we have raised that in our 2 previous testimony, there has really been no response.
3 So, as far as Im concerned, you cant really rely on 4 it until you know in detail what was done, what code 5 was used, what break time was used, how strong it was.
6 Is it the maximum strength, or not?
7 MR. STROSNIDER: Your Honor, Jack 8 Strosnider for Entergy.
9 CHAIRMAN McDADE: Yes.
10 MR. STROSNIDER: Two comments that Im 11 comfortable I can make without getting into 12 proprietary aspects of this. The first is with regard 13 to Dr. Hopenfelds discussion about severe accidents, 14 Ill point out severe accidents are also known as 15 beyond-design basis accidents, meaning that they are 16 not part of the current licensing basis. They are 17 used in probabilistic risk assessments that go beyond 18 the current licensing basis and beyond the design 19 basis accidents that need to be analyzed under Part 54 20 under license renewal. So, theyre really not within 21 the scope of this discussion.
22 With regard to the EPRI analysis, the one 23 thing I would point out is that that analysis was done 24 using the design basis loads. And I think I can say 25 that with, you know, thats pretty well known.
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5788 1 And, you know, that document is available 2 for review. And if Dr. Lahey has specific comments on 3 the analysis, which is available for him to look at, 4 then we would want to hear those specific comments, 5 but, you know, big picture they analyzed the design 6 basis accidents in that evaluation. And thats what 7 is, you know, required under Part 54 for license 8 renewals is to maintain that design basis. So, thats 9 what they did all of this, Your Honor, in the interest 10 of safety.
11 CHAIRMAN McDADE: Okay. Thank you. Dr.
12 Lahey.
13 DR. LAHEY: Yeah, I -- certainly I did 14 review this document. I have expressed this concern.
15 I have gotten no feedback on what was actually done.
16 And as you know, it -- when you say you did a design 17 basis accident, it matters a lot what sort of 18 technique you used for it.
19 If you used a code which is a large-volume 20 standard loss of coolant accident code, you certainly 21 do not get the kind of impulsive loads that will 22 really occur.
23 If you use a separate code like the 24 Westinghouse code we talked about yesterday and you 25 apply the right break size and the right break opening NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5789 1 time, you can get that resolved.
2 No details were given. In fact, it looked 3 from reading the report, like it was sort of a static 4 load or a quasi-static load.
5 MR. LOTT: Your Honor, this is Randy Lott 6 for Entergy. I believe that the study that Dr. Lahey 7 is referring to is whats called the EPRI Phase 2 8 repot, which, again, I believe is Entergy 523.
9 Im trying -- Im struggling to say, I 10 mean, Im familiar with the report in some -- to some 11 extent and clearly it was taken, first of all, to 12 evaluate the purely hypothetical case of a complete 13 severing of the weld at the top of the -- between the 14 tubesheet and the divider plate.
15 Theres other testimony that we filed that 16 indicates that, A, this is a highly improbable 17 circumstance and that we do not predict that a 18 complete cracking of this would grow along that 19 interface.
20 Then as was suggested, it was looked at 21 what the effect of opening that gap would be on the 22 leakage through the divider plate, and found that that 23 was acceptable in all cases.
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5790 1 plate with the failed weld. And what they determined 2 was that the failure itself actually made the stresses 3 on the -- that would be afforded from the LOCA 4 analysis when it was done, would reduce them due to a 5 smaller Delta-P across the plate and also due to 6 increased flexibility in the system.
7 So, when they looked at the analysis, they 8 said we do not need to redo the current licensing 9 basis analysis, because what weve already done in the 10 current license base remains the controlling 11 condition, the limiting condition.
12 So, therefore, as Dr. Lahey -- as weve 13 just demonstrated in our previous testimony on the 14 baffle bolts of other, we certainly understand the way 15 that these LOCA forces are applied in these 16 conditions. And the study simply concluded that there 17 was no need to go through that entire process.
18 Again, it was just a purely hypothetical 19 study in the first place, because we think that the 20 failure of this weld is highly unlikely. And Ill 21 also suggest that this is a massive structure and its 22 not going to simply disappear. And theres no 23 evidence that it will simply disappear. So, theres 24 no -- hardly any place for it to go.
25 MR. DOLANSKY: This is Bob --
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5791 1 CHAIRMAN McDADE: Okay. Thank you, Dr.
2 Lott.
3 MR. STROSNIDER: Jack Strosnider from 4 Entergy. Just to add one more --
5 CHAIRMAN McDADE: Before you --
6 MR. STROSNIDER: Sorry.
7 CHAIRMAN McDADE: Mr. Dolansky first.
8 MR. DOLANSKY: Yes. Thank you, Judge.
9 this is Bob Dolansky with Entergy. I just want to 10 kind of take a step back. Were starting to talk 11 about the loads and all that stuff.
12 EPRI report has many, you know, contains 13 a lot of information. To me, the really important 14 part of the EPRI report is that theyve looked at the 15 possibility of this cracking occurring and said it 16 cant.
17 This issue was originally driven from 18 foreign operating experience. French plants had 19 cracking. They saw the cracking. They did 20 significant amount of work, research and destructive 21 testing on these components after they were removed.
22 Additionally, EPRI did a lot of work to --
23 and the result of that work is that this is not a 24 concern. The cracking is not a concern. We can, you 25 know, go further down and discuss the, you know, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5792 1 evaluations on whether it will fail or not and all 2 that stuff, but to me the real crux of the matter is, 3 and what New York State 544A really talks about is 4 that this is not a concern, because this isnt going 5 to happen.
6 And what we thought was happening in 7 France when the issue was first raised, the more 8 research we did and the more destructive testing they 9 actually did on some of the steam generators that had 10 this that they took out of service and actually 11 destructively removed the metal and did the testing, 12 it turned out that there was no cracking going through 13 the wall. It was just in a very shallow, cold work 14 surface. So, to me, thats the whole issue.
15 And as a slight aside, I just -- Dr. Lahey 16 says that hes concerned about safety and I understand 17 that. And I just want to put it on the record that 18 Im very concerned about safety, too. I work at that 19 plant every day.
20 CHAIRMAN McDADE: Okay. I think thats --
21 MR. DOLANSKY: I care about safety a great 22 deal. And to imply that hes worried about it because 23 of safety, and Im not worried about safety, thats 24 not the case. I care about safety as much as anybody 25 else and I want to make sure that we do the safe thing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5793 1 at the plant.
2 CHAIRMAN McDADE: Okay. I certainly nave 3 not interpreted the testimony of Dr. Lahey in any way 4 as questioning the commitment to safety on the part of 5 Entergy as a company or on the witnesses who have 6 presented testimony on behalf of Entergy. The 7 question just simply is interpreting the data, whether 8 or not the data supports the thesis that you have.
9 And in this regard, and I think it was 10 clear from the record and I didnt ask a lot of 11 questions about it, of what Entergy views as the 12 significance of that report.
13 And what I wanted to just make sure I 14 understood is why Dr. Lahey believed that reliance on 15 that report is, in his view, not warranted, as I 16 understand it, based on a lack of data in the report 17 with regard to the shock loads that were present and 18 the -- some of the methods that were used; is that 19 correct, Dr. Lahey?
20 DR. LAHEY: Yeah. I, you know, all these 21 comments are things you can see in the report. That 22 doesnt really answer my primary concern. What Im 23 interested in is when they say it can survive LOCA 24 loads.
25 How did they get those LOCA loads? If you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5794 1 dont do it right, you can say you ran a LOCA, but the 2 pressure difference versus time is not impulsive, you 3 know. Its a different sort of loading of the plate.
4 And a two-inch plate with secure welds should handle 5 that very nice.
6 If you do a shock load, however, thats 7 what remains to be done. And if -- then if the welds 8 are weakened by stress corrosion cracking and things 9 of this nature, thats an additional thing that needs 10 to be studied.
11 I havent seen that data. So, until I see 12 that data, I cant be really comfortable that thats 13 been done.
14 CHAIRMAN McDADE: Okay. Do you have any 15 follow-up on this?
16 JUDGE WARDWELL: Not really.
17 MR. STROSNIDER: This is Jack Strosnider 18 for Entergy. The one other comment I wanted to make 19 earlier very briefly is when you talk about the 20 hypothetical problem that Dr. Lott described in terms 21 of the size of crack that was evaluated, that crack 22 would be easily visible for anybody doing any kind of 23 work in the channel head. It wouldnt require any of 24 these advanced methods. Its a very, very large 25 crack.
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5795 1 So, just to reemphasize, very unlikely 2 its going to happen in the first place. If a crack 3 did form, it would be seen during inspections well 4 before it got to the size thats been evaluated. So, 5 I just wanted to give that practical perspective on 6 this.
7 CHAIRMAN McDADE: Okay. Thank you. Id 8 like to move on to some issues with regard to the 9 timing of the inspections with regard to Indian Point 10 2 within ten years of the PEO, with Indian Point 3 at 11 the first refueling outage. These generators were put 12 into service, Indian Point 2 in 2000, Indian Point 3 13 in 1989.
14 So, these steam generators will be in 15 place for a significant period of time prior to the 16 beginning of the period of extended operation for 17 Indian Point 3 and already the period of extended 18 operation for Indian Point 2.
19 How is it determined that these would be 20 appropriate times for the inspection? I believe Dr.
21 Duquette suggests that, you know, it would be good 22 engineering practice or necessary engineering practice 23 to have a baseline inspection prior to the start of 24 the period of extended operation, you know.
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5796 1 and significantly into the life of the steam 2 generators. How are these periods for inspection 3 arrived at and whats the basis behind them?
4 MR. AZEVEDO: Your Honor, this is Nelson 5 Azevedo for Entergy. Let me just start by saying that 6 these locations, excuse me, are inspected every time 7 we go into the primary side. Thats every other 8 refueling outage there is a visual inspection.
9 Its not the EVT1, its not the detailed 10 visual inspection that were talking about, but they 11 are visually inspected. So, if there were gross 12 issues going on, those would be picked up.
13 As far as the EVT1 and the schedule of 14 that inspection, that was really based on the work 15 that the French have done and the EPRI have done that 16 basically concluded this is not an issue, you know.
17 These are flaws that are very shallow, have no --
18 essentially no structural impact, and they pose no 19 safety significance. So, thats why that time frame 20 was chosen.
21 CHAIRMAN McDADE: Mr. Cox.
22 MR. COX: Yeah, one other factor. This is 23 Alan Cox for Entergy. The operating experience in the 24 industry for this type of material under these 25 temperatures and operating condition shows that it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5797 1 takes a number of years for this to develop.
2 If you inspected a steam generator after 3 20 years of operation, just based on the industry 4 experience with this you would not expect to see any 5 kind of -- you would not expect that time frame to 6 have been long enough to develop stress corrosion, 7 cracking.
8 CHAIRMAN McDADE: Okay. What are the 9 lifespans of these generators, the anticipated 10 lifespan of the generators?
11 For example, Indian Point 2 went into 12 service in 2000.
13 MR. AZEVEDO: This is Nelson Azevedo for 14 Entergy. Is the, you know, for 60 years, if I 15 understand your question correctly. These generators 16 are anticipated to be good for the remainder of the 17 life of the plant.
18 CHAIRMAN McDADE: Okay. And for Indian 19 Point 2 -- Three, rather, that went into service in 20 1989, likewise you would anticipate that that 21 generator would be used for the full period of 22 extended operation.
23 MR. AZEVEDO: That is correct, Your Honor.
24 MR. DOLANSKY: Id just like to add that 25 Im the program owner for the steam generators. We go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5798 1 into those steam generators, as Mr. -- this is Bob 2 Dolansky for Entergy -- every other outage, 3 effectively, every four years. And both generators --
4 all four generators at both units, both the tubing and 5 the tube-to-tubesheet, you know, the channel head, and 6 the secondary side, we do inspections on all those 7 areas and they are all in very, very good shape. We 8 see no problem with them reaching the end of the 9 period of extended operation.
10 CHAIRMAN McDADE: Okay. The IP2 steam 11 generator was replaced in 2000. What, if any, 12 relevance do the reasons of why that was replaced have 13 to what were considering now?
14 MR. DOLANSKY: I think the relevance is 15 that both the IP3 and IP2 steam generators were 16 replaced because of the tube material that they had.
17 The tube material was degrading. And that was mill-18 annealed Alloy 600. Both steam generators were 19 significantly upgraded.
20 Unit 2, IP2, has thermally-treated Alloy 21 600, which is a very good material. And Unit 3, even 22 though its older, it has thermally-treated Alloy 690.
23 And thats really -- I would say thats the best 24 material for steam generator tubes. So, the 25 significant upgrade in tube material after they were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5799 1 replaced is the reason.
2 CHAIRMAN McDADE: Okay. And can you 3 exp0lain just very briefly what is the difference 4 between mill-annealed tubing and the thermal-treated?
5 MR. GORDON: Your Honor, this is Barry 6 Gordon for Entergy. Mill-annealed was the original 7 type of heat treatment to -- for Alloy 600. It was a 8 wide range of temperatures and each mill essentially 9 did it different ways and it didnt have an optimized 10 microstructure as the thermally-treated tubes are.
11 Thermally-treated ones also have a 12 subsequent heat treatment at a lower temperature that 13 diffuses it. What you want to do in Alloy 600 is have 14 chromium carbides on the grain boundaries. And with 15 thermally-treated Alloy 600 has is a subsequent heat 16 treatment at various temperatures and times that will 17 produce a more uniform, homogenous, distribution of 18 chromium around the grain boundary. So, its not 19 quite as depleted.
20 And the results, the testing results of 21 the actual operating experience with this material has 22 been outstanding, actually.
23 CHAIRMAN McDADE: With both the 600 TT and 24 the 690 --
25 MR. GORDON: Well, 690 is --- has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5800 1 absolutely a perfect record. There is no --- well, 2 since first introduced in the field, there has been 3 absolutely no operating experience degradation of 4 Alloy 690 with higher chromium.
5 CHAIRMAN McDADE: Okay. Weve had 6 significant testimony about the experience with the 7 French reactors and their steam generators.
8 Do we know what the material was that 9 these -- that experienced the observable cracking 10 there? Was it mill-annealed, or was it the 600 or 690 11 TT?
12 MR. GORDON: It was mill-annealed Alloy 13 600 by and large.
14 DR. DUQUETTE: Duquette, New York. Just 15 to clarify the record a little bit, Im not sure if 16 theres some confusion here, perhaps not, but the 17 divider plate, which is where the cracking has been 18 observed, is, as far as I know, always mill-annealed 19 600 in both the French reactors and the reactors at 20 Indian Point.
21 690 versus 600 is the tube material. And 22 I dont think at the present time the tube material 23 except when we talked about the tube-to-tubesheet 24 welds, I dont think the tube material is an issue 25 right at the moment.
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5801 1 And so, if we back off to what the divider 2 plate cracking is and what the French experience is, 3 that was an Alloy 600, not 690. To my knowledge, the 4 French havent seen any cracking in their 690 either.
5 And so, those are two different issues.
6 I dont know if its appropriate now or 7 not if the Board wants to entertain it, but there were 8 several comments by Entergy about the French 9 experience that perhaps this is the time to share and 10 --
11 CHAIRMAN McDADE: Well, let me just ask 12 one thing before we get to that, Dr. Duquette.
13 DR. DUQUETTE: Of course.
14 CHAIRMAN McDADE: And in the testimony 15 that was provided by Entergy when you discuss the 16 divider plates, you indicated that they were made of 17 Alloy 600 both at -- and I believe both at the IP2 and 18 IP3; is that correct?
19 MR. DOLANSKY: Yes.
20 CHAIRMAN McDADE: And was this the 600 TT, 21 or the mill-annealed 600; do you know? I dont 22 believe its specified in the testimony.
23 MR. GORDON: This is Barry Gordon from 24 Entergy. I would assume its -- I think they assume 25 its the mill-annealed Alloy 600. The more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5802 1 susceptible material.
2 CHAIRMAN McDADE: Okay.
3 MR. DOLANSKY: To go to what Dr. Duquette 4 said really when were talking about mill-annealed and 5 thermally-treated, were talking about the tubes, not 6 so much the divider plates. And the tube -- what --
7 the tube material really comes into the discussion 8 when were talking about the tube-to-tubesheet weld.
9 CHAIRMAN McDADE: Okay. Thank you. Dr.
10 Duquette.
11 DR. DUQUETTE: I think I agree with that.
12 I think thats what I said. Until we --
13 CHAIRMAN McDADE: Okay. Dr. Duquette --
14 DR. DUQUETTE: -- talk about the tube-to-15 tubesheet weld --
16 CHAIRMAN McDADE: Excuse me. Dr. Duquette 17 --
18 DR. DUQUETTE: -- the tubes are not --
19 CHAIRMAN McDADE: Okay. When youre 20 talking, youre talking to us. Were not having the 21 witnesses talk back and forth to each other. Its 22 sort of, you know, in follow-up well talk to the 23 other potential witnesses.
24 DR. DUQUETTE: I apologize.
25 CHAIRMAN McDADE: Anyway, Dr. Duquette, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5803 1 you thought that you wanted to raise with regard to 2 the French experience that you felt is relevant that 3 we should --
4 DR. DUQUETTE: Well, the French experience 5 --
6 CHAIRMAN McDADE: -- take into 7 consideration?
8 DR. DUQUETTE: -- is brought up as a 9 trivial problem. Number one, I have done a lot of 10 other consulting in other kinds of plants. If I saw 11 cracks of that nature in almost any component in any 12 plant that I inspected, I would certainly be 13 concerned.
14 But in the French experience, they noted, 15 and I think they were correct, that the cracking took 16 place in the cold work -- in the thin cold work skin 17 that was on their divider plates.
18 CHAIRMAN McDADE: And actually I wanted to 19 get into that. Before we go further, can you explain 20 what cold warping is --
21 DR. DUQUETTE: Oh, surely.
22 CHAIRMAN McDADE: -- and why its 23 significant?
24 DR. DUQUETTE: If you roll a plate, for 25 example, at room temperature or near room temperature, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5804 1 its called cold rolling. And so, there are two --
2 there are several ways to process materials.
3 Theres hot rolling, which would mean that 4 you would roll it at relatively hot -- high 5 temperatures. And cold rolling usually means at near 6 room temperature you process the material. It could 7 be wire drawing, it could be cold rolling to make 8 plate.
9 There are lots of ways to cold roll 10 materials. And so, cold rolling usually strengthens 11 the material. And when you do that, you usually loose 12 some ductility in the material.
13 CHAIRMAN McDADE: Okay. And am I correct 14 that the -- in the French experience, the only 15 observed cracking was in cold rolled material?
16 DR. DUQUETTE: The French plates seemed to 17 have been preferentially cold rolled. That is they 18 had more cold rolling in the surfaces than they did in 19 the body of the material. And that can happen if you 20 do a light amount of cold rolling or grinding on the 21 surface, something that deforms the surface 22 preferentially.
23 Many plates are cold rolled heavily. The 24 automobile youre driving, for example, will have been 25 cold rolled right through the entire steel thats in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5805 1 it so that the entire steel has the same properties.
2 And so, cold rolling -- surface cold 3 rolling, which is what the French reported, could have 4 come from grinding, it could have come from machining 5 the plate, it could have come from doing a light cold 6 roll at the end of the process for making the plate, 7 but the experience is that cold rolling decreases the 8 immune -- I wont say immunity. It increases 9 susceptibility to primary water stress corrosion 10 cracking. Thats well established.
11 And the problem with Indian Point is we 12 have no idea what the condition of those plates are 13 whether theyre heavily cold rolled, or lightly cold 14 rolled, or completely annealed or cold rolled at all.
15 We just dont know anything about them, as far as I 16 know, or at least we havent seen any evidence from 17 the original manufacturer having supplied them as to 18 what their condition is.
19 Under the worst of cases, the last pass 20 that they were -- when they were made into plate, they 21 were heavily cold rolled, and its quite possible that 22 theyre cold rolled from the surface right through the 23 body of the plate. Thats not unusual for lots of 24 cold rolling operations. In fact, its quite commonly 25 done to get uniform properties across plate.
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5806 1 I would like to be able to say that the 2 Indian Point situation has no cold rolling at all or 3 that its only a skin effect as the French saw, but we 4 dont have any evidence of that yet. And until we 5 look, we dont really know whether its cracking or 6 not and whether or not its cold rolled or not.
7 And so, my argument would be that in the 8 absence of knowledge we have to assume -- we dont 9 have to assume, but Im going to assume that theres 10 a possibility that the plate that was provided by the 11 manufacturer of the plate and put in place was 12 heavily cold rolled. I have no way of knowing that it 13 is not.
14 CHAIRMAN McDADE: Okay. Now, the SG tubes 15 themselves, the 3,000 whatever tubes in each 16 generator, are thermally treated, either 600 or 690 17 thermally treated. That would suggest that theres no 18 cold rolling with regard to the tubes and is it your 19 issue that this is only -- your view that this is only 20 an issue with regard to the divider plate?
21 DR. DUQUETTE: Not quite. Again, Im not 22 sure what we can say about the 2014 report or the 2012 23 interim report that EPRI provided, but they laid out 24 some scenarios for what Ill call destroying the 25 pressure boundary by the cracks that form in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5807 1 divider plate progressing into the tube-to-tubesheet 2 welds by cracking the cladding thats on the tubesheet 3 itself.
4 And so, theres a path that could be 5 followed for a stress corrosion crack that would begin 6 in the divider plate and then progress into other 7 parts of the steam generator eventually perhaps 8 compromising the pressure boundary.
9 CHAIRMAN McDADE: Okay. And in here, the 10 part of the pressure boundary were talking about are 11 the SG tubes themselves.
12 DR. DUQUETTE: Would be the -- pressure 13 boundary would be compromised by a crack that would 14 occur in the tube-to-tubesheet welds. Because once 15 you do that, you expose the inside of the --
16 independent of the cold expansion of the tubes into 17 the tubesheet once youve cracked the tube-to-18 tubesheet weld, you have a path for compromising the 19 pressure boundary.
20 And I would argue that some discussion 21 made earlier about allowable leaks if you broke enough 22 of the welds in the pressure boundaries, I think you 23 would probably exceed the ability for one tube to 24 provide the leaking, which I think was the analysis 25 that was done.
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5808 1 That is if one tube-to-tubesheet weld were 2 compromised, then the leak would be acceptable. If 3 20,000 of them were compromised, Im not so sure that 4 would be correct, not that Im suggesting that there 5 would be 20,000 compromised all at the same time.
6 CHAIRMAN McDADE: Okay. If you could 7 continue talking about the French experience and part 8 of that I would also like you to address, I believe, 9 Entergy has suggested that the lessons to be learned 10 from the French experience are somewhat limited 11 because you have differences with regard to the water 12 chemistry programs, the thermal impact, the cyclical 13 loading so that the concerns that you observed from 14 the French experience would not be necessarily 15 applicable to the Indian Point experience.
16 Have I misstated Entergys position at 17 all?
18 MR. DOLANSKY: No, Your Honor.
19 CHAIRMAN McDADE: Okay. Dr. Duquette.
20 DR. DUQUETTE: I cant disagree with that.
21 There is certainly differences from the French 22 experience, and I know something about that, and the 23 US experience.
24 Its also a fact, and it has to be 25 accepted, that only about 20 percent -- I believe the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5809 1 number is about 20 percent of the French reactors 2 showed cracking in the divider plates. They saw it at 3 Chinon. They saw it at Gravelines. They saw it in a 4 number of places, but they certainly didnt see it in 5 all of their steam generators.
6 And I believe that my understanding is 7 that they now inspected all of their steam generators.
8 So, its not a problem that goes through the entire 9 French fleet. I suspect it will not be a problem 10 throughout the entire United States fleet or anyone 11 elses fleet, as far as that goes, but the fact of the 12 matter is that they did see cracking, they did 13 identify with cold work, and I know Ive said this, 14 but we have no way of knowing what the cold work 15 situation is at Indian Point 2 or 3. And so, I think 16 theres some concern in that area.
17 I would like to see regular inspections.
18 And that doesnt mean every other month, but regular 19 inspections to be sure that if any cracks form there 20 arent growing. And if theyre growing, theyre not 21 growing to eventually compromise the pressure 22 boundary.
23 And so, Im not suggesting we decommission 24 the --
25 CHAIRMAN McDADE: I dont know if this is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5810 1 a good time for you to address it. I dont want to 2 lose your train of thought, but --
3 DR. DUQUETTE: Okay.
4 CHAIRMAN McDADE: -- you just raised the 5 issue of the timing of inspections. We had had the 6 discussion earlier from Entergy, their explanation as 7 to why the timing that they proposed, which is, you 8 know, not until after the beginning of the period of 9 extended operation and I believe about 22 years into 10 the operation of IP2, and 28 years into the operation 11 of IP3, you know.
12 Do you disagree with their explanation 13 that inspecting earlier would be unnecessary because 14 there is no basis to believe that cracking would occur 15 that early in the operation given the nature of the 16 materials?
17 DR. DUQUETTE: Well, the Indian Point 3 18 reactor that was put in place in 1989 has been in 19 service for quite some time.
20 And so, if there are cracks -- and I dont 21 think anyone has looked at this point, at least have 22 not seen any evidence in that. If there are cracks in 23 those divider plates, I think wed like to know that.
24 And if we do see them, I think wed like to know; A, 25 are they growing, or are they so large that we have to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5811 1 do something about them?
2 And if theyre growing --
3 CHAIRMAN McDADE: But do you disagree with 4 the underlying premise that you would not expect --
5 there would be no reason to believe that cracks would 6 be -- would either originate or propagate early in the 7 period of operation by the steam generator?
8 DR. DUQUETTE: I dont have an answer to 9 that. The problem weve had with the inspections that 10 have been so far by the French primarily, is that its 11 like a snapshot in time.
12 They saw cracks in the reactors. They 13 did, in some cases, come back in and look a few years 14 later. I think the first cracks were identified in 15 about 2007. And I think some five years later they 16 looked again and the cracks that they had seen in 2007 17 had not grown in their case.
18 And Im not surprised at that if its only 19 growing in a thin, cold warp layer, then it sort of 20 ran out of steam in that cold warp layer.
21 I would certainly like to get into the 22 1989 unit and see if theres anything there. Its 23 been a long period of time that its been in place.
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5812 1 in 2000.
2 I dont see any -- I think Entergy has 3 said that they have the capability of doing the 4 inspections. Perhaps I dont know the economics of 5 the situation, but I dont know why they wouldnt do 6 them. I dont know why they would rely on an 7 analytical process to eliminate the possibility when 8 they could, in fact, look at them and indicate that 9 they have the capability to do that. Im not sure why 10 the pushback on it.
11 CHAIRMAN McDADE: Okay. Well, let me go 12 back. I believe Mr. Dolansky indicated that there is 13 inspection that is done, a visual inspection at each 14 outage that would demonstrate any gross abnormality, 15 but what the inspections theyre talking about 16 pursuant to the license commitment has to do with the 17 EVT1, the more detailed inspection.
18 And so, is the concern that you just 19 raised not alleviated by the testimony of Mr. Dolansky 20 as to the, you know, the sort of gross inspection on 21 a periodic basis during refueling outages as opposed 22 to the specific inspections, you know, identified, you 23 know, in the license commitment, which would be, you 24 know, not until the first outage after the start of 25 extended operations for Indian Point 2, meaning NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5813 1 basically 28 years into the life of a steam generator?
2 DR. DUQUETTE: Surely. I certainly would 3 feel a lot more comfortable if someone from Entergy 4 were to stand up and say that in their visual 5 inspections that they do on a regular basis that they 6 look specifically for cracks in the divider plate.
7 If they tell me that theyve done that, 8 have looked and have been very judicious about it 9 knowing that they might be there, I might feel better 10 about having to do a more detailed inspection.
11 I havent heard that and I certainly 12 havent seen it in their written testimony or anything 13 that was provided to me before this. So, to my 14 knowledge, the visual inspection that they do in that 15 area isnt looking specifically at the -- at least as 16 far as I know, isnt looking specifically for the 17 possibility of small, initiated cracks in the divider 18 plate near the weld area.
19 I dont know if you would like Entergy to 20 comment on that or not, but Im not sure the visual 21 inspection would see it unless you had someone who was 22 qualified to look for the kind of cracking that were 23 talking about.
24 CHAIRMAN McDADE: Mr. Dolansky, do you 25 wish to comment on that?
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5814 1 MR. DOLANSKY: This is Bob Dolansky with 2 Entergy. We have not done an EVT1 on the divider 3 plate looking specifically for cracking. Our position 4 is that if there were -- the size of the flaw to 5 become structurally significant would be very large.
6 The examinations -- the visual inspections 7 that we do are general visual inspections of the 8 entire bowl area, including the divider plate. And 9 when we perform those inspections if there were gross, 10 you know, large flaws, gross abnormalities, they would 11 be seen.
12 Additionally, if there were cracking that 13 got through to a low alloy steel, that got through the 14 cladding, we would expect to see evidence of that in 15 the form of rust color or something like that. And 16 that would definitely be seen in the general 17 inspections that are performed every time we go into 18 the steam generator bowls.
19 CHAIRMAN McDADE: Okay. Thank you. Dr.
20 Duquette.
21 DR. DUQUETTE: Dr. Duquette, New York 22 State. I think I understood that answer to mean 23 unless its a gross defect, it either wouldnt be 24 picked up or wouldnt be recorded or no one would be 25 very concerned about it.
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5815 1 Stress corrosion cracks start small and 2 they can grow fairly rapidly in Alloy 600 if they 3 havent breached the cladding on the tubesheet yet.
4 And I think the comment was if they had breached the 5 cladding on the tubesheet, they would have seen some 6 corrosion from the tubesheet through the crack in the 7 cladding.
8 That certainly makes me feel better about 9 where we are, but it doesnt tell me anything about 10 whether there are cracks in the divider plate now, how 11 big they are, where theyre going or whether they 12 would have started into the cladding on the tubesheet 13 without actually having reached the carbon steel 14 underneath.
15 My concern about stress corrosion cracks 16 is theyre not a single -- they dont just occur and 17 theyre there and they break something or dont break 18 something. They grow as a function of time, and small 19 ones will grow into big ones if theyre growing at 20 all.
21 And so, my concern would be that if 22 theres a small crack now that can be seen, I 23 certainly would like to know that. And I certainly 24 would like to know what its direction is going to be.
25 And Im sure well talk about this later, but Id like NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5816 1 to know whats going to be done about it if one is 2 identified.
3 I think I heard this morning that if one 4 is identified, it will go through some standard 5 remediation process without defining what that 6 remediation process is. So, thats another area of 7 concern if you do find cracking.
8 I dont understand why as an engineer, I 9 dont understand why having seen cracking in similar 10 structures, a significant number of them, that they --
11 there wouldnt be some concern about at least 12 identifying them and finding out if theyre going to 13 be a problem.
14 I certainly think an examination of both 15 steam generators at this point to allay the problem, 16 put it aside and say we dont see any cracking at all, 17 I certainly would then feel better about delaying a 18 second inspection. But to have the first inspection 19 well into the relicensing period seems, to me, to be 20 -- I just dont think its good engineering practice 21 if you know that the component, it has shown cracking.
22 And, again, its not a single steam 23 generator in France. It was -- I think it was 18 or 24 20 percent of the steam generators showed cracking in 25 them. They explained the cracking, they indicated why NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5817 1 they didnt see any expansion of it, but, again, we 2 dont know what the condition of the divider plate is 3 at Indian Point in either one of the steam generators.
4 I just would feel better if we had a 5 baseline or a thorough examination of that area had 6 been taken. If no one had ever seen a crack in a 7 divider plate anywhere in the world, Id say probably 8 theyre proceeding as they should be. But there are 9 just too many of them in steam generators where the --
10 we dont know what the condition is in our case.
11 And Im not suggesting we cut samples out 12 of a divider plate. I just think there should be a 13 thorough inspection of the divider plate and should be 14 a thorough and visual -- not just a visual inspection, 15 but one at some magnification to see if the cracking 16 is there. Its a comfort level, perhaps, more than 17 anything else.
18 I dont think were near disaster in any 19 of them, or we probably would have seen it somewhere 20 else in the US fleet, but I think its just good 21 engineering practice.
22 CHAIRMAN McDADE: Okay. I believe you 23 testified that the rate of propagation of such cracks 24 could be rather rapid. And I try to just sort of 25 focus on what rather rapid means.
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5818 1 Youve heard the testimony from Mr.
2 Dolansky with regard to what the inspections are at 3 each outage. What is the period between outages?
4 MR. DOLANSKY: 24 months.
5 CHAIRMAN McDADE: Thank you, Mr. Dolansky.
6 24 months. So, these --
7 MR. DOLANSKY: This is Bob Dolansky. Let 8 me just clarify. We go into the steam generators 9 typically every two cycles. So, we would go into the 10 steam generator bowl area roughly every 48 months, 11 every four years.
12 CHAIRMAN McDADE: Okay. Thank you.
13 DR. DUQUETTE: Everyone in the stress 14 corrosion cracking field talks about rapid crack 15 growth. For us, that can be a fairly slow crack 16 growth compared to what most people might look at.
17 We do know, for example, that the history 18 of problems in the PWRs due to stress corrosion 19 cracking hadnt been identified in -- I believe the 20 first numbers that were reported were probably 10 or 21 12 years after the steam generators were put in place 22 with the mill-annealed tubes.
23 And Mr. Gordon has a very nice table which 24 I can show if you wish to, but I think its included 25 in the testimony I provided, indicating the number of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5819 1 problems that have occurred with stress corrosion 2 cracking in various components in the steam 3 generators. Some werent identified until the 1990s 4 and the steam generators had been in place for a very 5 long time.
6 The whole steam generator issue for those 7 of us who have done stress corrosion cracking for --
8 Ive done work for EPRI, for example, on stress 9 corrosion cracking in some of their alloys. They take 10 a long time in terms of numbers of years.
11 We do know, however, that once they 12 initiate, they grow exponentially. Not a very high 13 exponent, but they -- the rate of acceleration 14 increases with time. So, they can take a very long 15 time to initiate. They will also be slow to propagate 16 initially. And as they get larger, will propagate 17 faster.
18 So, I think if we saw no cracking 19 whatsoever in a reasonably recent inspection of the 20 steam generator divider plates and we saw no cracking 21 at all, again, I would feel more comfortable with what 22 were seeing, but we dont know. We dont know whats 23 there at all.
24 Im not going to suggest that the cracks 25 will grow over days or over months. Its certainly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5820 1 going to be over years. But if we do see some, I 2 think the first thing one would want to do is come 3 back in a few years and see what the growth rate has 4 been hoping that they havent grown catastrophically.
5 If we came back for a second inspection 6 and saw no growth whatsoever or no new cracks, you 7 probably want to stop right there. You probably 8 wouldnt have to go beyond that point.
9 But I think -- theres an old German 10 saying that one data point is worse than no data 11 points. And I think thats probably true in this 12 case. I think Id like to see whats happening as a 13 function of time.
14 Maybe get a baseline in the next year or 15 two. Five years from now come back in and look at it 16 again and see where we are.
17 CHAIRMAN McDADE: Okay. What were trying 18 to determine is whether or not the proposed inspection 19 schedule provides reasonable assurance. And what we 20 have from Mr. Dolansky is that this is looked at in a 21 -- perhaps not the right word, but gross fashion on at 22 least a 48-month. And that they then have this 23 detailed inspection scheduled for Indian Point 3, the 24 1989 reactor, I believe it will be in 2017. That they 25 suggest that given the rate of propagation of these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5821 1 cracks in order for a crack to pose any issue, it 2 would be identifiable in these periodic inspections 3 and that you would be able to identify even a much 4 smaller crack in the inspection that they propose for 5 IP3 in 2017. And that given the rate of propagation, 6 you would not expect a crack to cause any problem in 7 the interim period.
8 Do you disagree with that? And if so, 9 why?
10 DR. DUQUETTE: Im very comfortable with 11 the -- if they do a detailed crack analysis in 2017, 12 Im very comfortable with that. And I would like to 13 see a second inspection at some time in the future.
14 Again, the testimony I think Ive heard is 15 there is a visual inspection of the bowl area. I 16 think when I asked specifically if anything was done 17 to look specifically at the divider plate, Im not 18 sure that I understood the answer, but I dont think 19 anyone has looked specifically at the place where the 20 French had observed cracking.
21 And if you look at the reports that are 22 both public and in the EPRI reports, the cracks that 23 were observed in the French reactors initially had to 24 be looked at in something more than a visual manner.
25 Theyre pretty small.
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5822 1 Now, when they looked at the crack itself, 2 there were fairly large cracks from a microscopic 3 point of view. And theres some beautiful pictures 4 that they produced, but visually they would have been 5 very difficult to see without some other indication.
6 And so, the 2017 period, I think its a 7 great period. Id like to see them both done in 2017.
8 I think the earlier we identify no problem would make 9 everyone -- would certainly make me more comfortable 10 about the possibility of the cracks growing up into 11 the cladding and possibly to the tube-to-tubesheet 12 welds where they would possibly compromise the 13 pressure boundary.
14 CHAIRMAN McDADE: Okay. Are there any 15 provisions for follow-up inspections under the 16 licensing commitment? In other words, if we have the 17 inspection in 2017 as far as EVT1, is that going to be 18 repeated?
19 MR. AZEVEDO: Your Honor, this is Nelson 20 Azevedo for Entergy. That depends on what we find.
21 If we find --
22 CHAIRMAN McDADE: Assuming you find no 23 cracks in 2017 given the license commitment, theres 24 no provision for follow-up inspection.
25 MR. AZEVEDO: There are currently no plans NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5823 1 to go back if we find nothing. Thats correct.
2 CHAIRMAN McDADE: Okay. And can you 3 explain the justification for that?
4 MR. DOLANSKY: This is Bob Dolansky with 5 Entergy. Again, to me the justification would be the 6 French experience. I mean, the fact that the French 7 saw cracking, they didnt actually do anything about 8 it. They left it in service.
9 Then they removed steam generators from 10 service for other reasons, did destructive testing.
11 Turned out that the cracking was non-consequential.
12 So, if we go out and inspect and see nothing, I would 13 see no reason why we would need to go out again.
14 Theres nothing that would drive me to 15 feel that thats required or necessary, to be honest.
16 CHAIRMAN McDADE: Okay. But the 17 inspection you would be doing -- and lets focus just 18 on Indian Point 3 right now -- would be approximately 19 28 years into the life of that steam generator, 20 correct?
21 MR. DOLANSKY: Correct. 1989 to 2017, 22 yes.
23 CHAIRMAN McDADE: Okay. And is it your 24 position that if there was given the EVT1 inspection 25 in 2017, 27 or so years into the life of that, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5824 1 would have no reason to expect that there would then 2 be cracking in -- during the continued -- cracking of 3 any significance during the continued operation of 4 that steam generator during the period of extended 5 operation?
6 MR. DOLANSKY: That is correct, Your 7 Honor.
8 CHAIRMAN McDADE: Okay. Dr. Duquette, do 9 you --
10 MR. COX: This is Alan Cox. Let me add 11 one thing to that. Mr. Dolansky indicated that we 12 share Dr. Laheys concern for safety. And one aspect 13 of that is the safety of the people at the plant that 14 are doing the work.
15 So, weve got an EPRI report that says 16 that the investigation concluded that a crack running 17 the full length and depth of the weld is not a safety 18 concern, you know. So, I think the decision that wed 19 have to make at the plant is, do we want to spend the 20 dose, I mean, if you do this inspection, youre 21 putting people at some risk by the radiation exposure 22 theyre going to incur during the inspection. And if 23 youve got a situation where there is no safety 24 concern, its hard to justify from a management safety 25 perspective why you would subject people to that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5825 1 additional dose to go do that inspection. Thats 2 another consideration that would come into play in 3 making the decision.
4 In the 2017, that is the -- thats the 5 next available opportunity for doing an inspection.
6 The unit -- thats the next outage, next refueling 7 outage that will come up on IP3.
8 MR. STROSNIDER: And this is Jack 9 Strosnider for Entergy and I just want to expand 10 briefly on what Mr. Cox just said with regard to the 11 -- we had some discussion earlier about this very 12 large flaw that was demonstrated in the EPRI analysis 13 did not impact the safety analysis.
14 You dont need to do an enhanced visual 15 examination to see a flaw that size. Examinations 16 that theyre doing every 48 months when they go in and 17 they look, you would see that kind of a flaw long 18 before it got that big. So, you dont have to rely on 19 the enhanced visual to maintain safety.
20 MR. AZEVEDO: Your Honor, this is Nelson 21 Azevedo. May I add one additional point? The reason 22 why this issue even came up was because of operating 23 experience. In this case, overseas.
24 We will continue to monitor operating 25 experience so if things were to change in the future, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5826 1 it would -- we evaluate that and determine whether it 2 would be appropriate to go back and do inspections.
3 So, I just wanted to point that out.
4 CHAIRMAN McDADE: Okay. Thank you. Dr.
5 Duquette, do you see a need for continued inspections 6 after, for example, IP3 after the 2017? And at what 7 period and why?
8 DR. DUQUETTE: I have to back off on the 9 safety issue as far as the personnel are concerned and 10 what they can do. I think if youre going to do an 11 inspection in 2017, that team will have had experience 12 on how to do it and what theyre doing.
13 And if Im only suggesting one more 14 inspection, say, five or eight years later, I dont 15 think that the total dose that that team is going to 16 see is going to be very much more. And so, I think 17 Im having a problem wrapping my arms around the fact 18 that this is a safety issue for the people who are 19 doing the inspection, because youre going to be doing 20 one in 2017 anyway.
21 Looking at some more steam generators, I 22 dont think its going to expose people to that, but 23 thats not my area of expertise. And so, Ill have to 24 back away from there.
25 But the fact of the matter is the French NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5827 1 experience is brought up both by me and by Entergy and 2 Entergy is absolutely correct. The French explained 3 why their cracking stopped where it did. I know Ive 4 said this, and I dont want to be too repetitious, but 5 we dont know what the condition of the divider plates 6 are or the welds or anything else in the machines that 7 we have now.
8 In addition to that when they talk about 9 not being able to see a small flaw, Im not sure how 10 much experience the people who are testifying have on 11 identifying cracks in Alloy 600, but one comment that 12 came up is correct.
13 If you penetrate through the cladding on 14 the tubesheet and you begin to corrode the carbon 15 steel underneath, youll see that, but fine cracks in 16 welds are really, really difficult to see visually.
17 So, if you get a crack on a weld or in a 18 heat-affected zone, youre not going to see it 19 visually unless you do something more than that in 20 most situations especially in the welds. Theyre just 21 very difficult to identify unless youve got really 22 experienced people and somewhat of a more advanced 23 technique.
24 So, I dont think that 48-month visual 25 inspections are going to detect very much unless NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5828 1 theyve got -- and theyre right -- a massive crack.
2 But the -- when they -- when it was said just a few 3 minutes ago that the EPRI report indicated there was 4 no problem, that isnt quite true.
5 The EPRI report laid out several 6 scenarios. They did indicate that they probably were 7 not likely, but they -- it was a thorough enough 8 report, I was very impressed with it, to point out 9 that there is a scenario for a crack, for example, to 10 progress up into the Alloy 600 cladding on the 11 tubesheet, progress across that cladding and then 12 intersect at least one or more of the tube-to-13 tubesheet welds. And if that happens, you have the 14 risk of compromising the pressure boundary. Its as 15 simple as that.
16 And I would argue that theres no way that 17 a team thats looking at it visually is going to see 18 the fine cracks that I have seen in stress corrosion 19 cracking situations without doing something more than 20 that.
21 Ive analyzed thousands of cracks in my 22 career and typically I have to use some technique 23 other than just looking at it unless its such a 24 massive crack that I can drive a truck through it.
25 CHAIRMAN McDADE: Well, perhaps not to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5829 1 drive a truck through it, but as I understand the 2 position of Entergy is that well before the time that 3 these cracks would become an issue, they would be 4 observable through their periodic inspections. And 5 that these inspections, I guess, for Indian Point 3 in 6 2017, for Indian Point 2 probably in 2023, 7 approximately ten years after the period of extended 8 operation begins, that these more detailed EVT1 would 9 be sufficient to ensure that these cracks would not, 10 could not propagate undetected to the point where they 11 would raise an issue as to the continued function.
12 Do you have a problem with that position 13 and --
14 DR. DUQUETTE: As I indicated just a few 15 seconds ago, yes, I do. My own personal experience is 16 you can have very long cracks that are virtually 17 invisible to the naked eye. Ive seen them in paper 18 mills, Ive seen them in power plants and a number of 19 other places where we had to do something more than 20 just look at them to see that there were cracks 21 present.
22 And so, I disagree that a visual 23 examination in the kinds of structures youre looking 24 at here will necessarily show you whether you have a 25 crack that has to be dealt with. And at some point we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5830 1 should talk about dealt with as well, but I disagree 2 that you necessarily would not -- that you would 3 necessarily see a crack that was close to compromising 4 the situation.
5 The cracks were talking about are growing 6 in welds, theyre growing in welded material on the 7 tubesheets, and theyre progressing if theyre going 8 to compromise the pressure boundary by breaking the 9 pressure boundary at the tube-to-tubesheet welds, 10 youre again looking at welded materials where cracks 11 are very difficult to see because of the structure of 12 the weld itself.
13 CHAIRMAN McDADE: Well, let me go back and 14 showing my ignorance, perhaps, of the process, but 15 were talking about the divider plate and the capacity 16 for cold working on the divider plate. Were talking 17 about the tubes where I concede theres no cold 18 working given the nature of the particular product.
19 Is cold working an issue with regard to 20 the welds? And if not, would welds be susceptible to 21 cracking in the same way the divider plate would be or 22 a cold-worked piece of metal would be?
23 DR. DUQUETTE: Cold-worked and mill-24 annealed Alloy 600 will accelerate the cracking 25 problem. But Mr. Gordon testified just a little while NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5831 1 ago, and hes correct, Alloy 600 that is mill-annealed 2 is susceptible all by itself. And the weld material 3 that you use to weld Alloy 600, which is about the 4 same composition, is also susceptible.
5 Cold working will accelerate the process.
6 Youll get earlier initiation and more rapid 7 propagation, but that doesnt mean that you wont get 8 propagation through welded Alloy 600 -- its actually 9 called Alloy 182, but you certainly will get cracking 10 in that alloy. It just is not as rapid as it would be 11 in a cold work material.
12 Cold work material, the numbers Ive seen 13 in a number of places, I think, including in the EPRI 14 report, and theyre out in the public. So, its not 15 anything thats secret. Cold working increases the 16 crack propagation rate by about a factor of four, but 17 there is a finite crack propagation rate. Its just 18 that it goes four times -- about four times faster 19 into material thats cold worked.
20 CHAIRMAN McDADE: Okay. Its after noon 21 and Im wondering if it may be a good time for us to 22 break for lunch. I propose to break and come back at 23 one oclock.
24 Does that pose problems for anybody? Is 25 that sufficient time? Does the staff need any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5832 1 additional time?
2 MR. HARRIS: No, Your Honor.
3 CHAIRMAN McDADE: Entergy.
4 MS. SUTTON: Thats fine, Your Honor.
5 MR. SIPOS: Your Honor, the State would 6 request 75 minutes. An hour and 15 minutes.
7 CHAIRMAN McDADE: Okay. Now, Ive got to 8 -- lets see. 75, 60, okay. So, were talking about 9 1:15?
10 MR. SIPOS: Yes.
11 CHAIRMAN McDADE: Okay. Thats -- well 12 stand in recess then until 1:15.
13 (Whereupon, the proceedings went off the 14 record at 12:05 p.m.)
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5833 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 (1:15 p.m.)
3 CHAIRMAN McDADE: Okay. Please be seated.
4 Were ready to proceed. Mr. Sipos, it looks like you 5 might have something before we get started.
6 MR. SIPOS: Yes. I just actually for 7 clarity of the record, I think there was a couple of 8 homework assignments for Dr. Lahey. And I just -- I 9 thought it would be helpful for the record if I just 10 read the exhibits and their titles so that they are 11 all in one place for the parties and the Board as they 12 look back at it subsequent to the hearing. Would that 13 be --
14 CHAIRMAN McDADE: Yes, please.
15 MR. SIPOS: Okay. So, the first exhibit, 16 I believe, is Entergy Exhibit Entergy R681. And that 17 is WCAP-17199-P, Rev 2 November 2015.
18 The next one is Entergy R689. Thats 19 WCAP-12191, Rev 5. And the cover page has an October 20 2015 date.
21 Then the third one is Entergy Exhibit 727.
22 And that is CN-PAFN-09-21, Rev 4 also with a November 23 2015 date. I believe those are the three documents 24 that you have discussed with Dr. Lahey.
25 CHAIRMAN McDADE: Okay. Thank you, Mr.
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5834 1 Sipos.
2 Okay. The question is whether we continue 3 on 38, or go back to Dr. Lahey. We had talked about, 4 you know, some matters that you wanted to bring up, 5 Dr. Lahey. Why dont we get that out of the way now 6 before we proceed on?
7 DR. LAHEY: Thank you, Your Honor. The --
8 theres two basic things. One homework assignment or 9 break assignment that you gave me on to look at 10 thermal couple processing, signal processing. And the 11 other one has to do with the discussion that we had 12 yesterday, which was my self-imposed homework for last 13 night because I was told that the answer to my 14 question was in Entergy 681.
15 So, I -- all these documents, 16 incidentally, I have seen before. I just dont carry 17 numbers in my head, but they were not new documents to 18 me. So, anyway, if you dont mind, I would just like 19 to resolve the thing we talked about, clarify the 20 record with the thing we talked about yesterday, 21 which, just to remind you, we had discussed some 22 problems with the heat transfer coefficient modeling 23 in the WESTEMS code.
24 And I showed you a couple of areas in 25 terms of thermal boundary layer effects and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5835 1 nodalization where if you get non-conservative 2 results, these are two independent things that can 3 lead to non-conservative results.
4 So, I was -- as I understood the testimony 5 of Mr. Gray, I believe it was, which maybe I didnt, 6 but it sounded like he said that you dont really need 7 to worry about that, because we specify the transients 8 and we adjust the duration of them so that we get the 9 maximum stresses.
10 So, and he -- and when I ask -- or when 11 you ask on my behalf where was all this documented, I 12 was told 681. So, when I went back last night and 13 went through 681, there was a lot of work shown in 14 determining the transients. Some of them are more 15 complicated than others such as the in-surges and out-16 surges of the pressurizer.
17 And then there were other components as 18 well, but basically it was determining what is the 19 temperature and the flow transients and the number of 20 the various transients, but my question had to do with 21 the thermal hydraulic analysis of these transients 22 which lead to the stresses.
23 And in the document it was very clear, and 24 in all other documents that Ive read on this subject, 25 its very clear that once you have the transients, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5836 1 then put them into this thermal hydraulics model that 2 we talked about yesterday and you then determine what 3 the stresses may be. So, it really doesnt resolve my 4 concerns at all.
5 And so, my shock yesterday that I 6 expressed, I mean, if we dont have to worry about 7 heat transfer coefficients, whats the code for? It 8 looks like they are indeed using the code. They break 9 up various components into zones and pick constant 10 heat transfer coefficients in the various zones. They 11 dont have to be the same. And they try to pick ones 12 that they believe are conservative.
13 But what I showed yesterday, these fully 14 developed heat transfer coefficients cannot be 15 conservative because of these two effects that I 16 discussed. So, thats one thing I wanted to resolve 17 and it might be I just misunderstood Mr. Gray, but it 18 sounded pretty clear thats what they were saying.
19 So, thats all I have to say about that 20 issue. And if you would like Mr. Gray to respond, we 21 can do it, or do you want me to go on to the other --
22 CHAIRMAN McDADE: Why dont you go on, Dr.
23 Lahey?
24 DR. LAHEY: Okay. The other issue is sort 25 of a longstanding concern Ive had and Ive put it in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5837 1 previous testimony that Ive submitted and it never 2 was resolved to me is, how do you handle the thermal 3 coupled measurements? Because you heard this morning 4 even they make some measurements and infer the fluid 5 temperatures from this in terms of stratification or 6 the possibility of thermal striping and various 7 others.
8 And the problem is the documents that I 9 was given to review, which I have and I had previously 10 seen these, is Entergy 689 and 727, they use the 11 transients, but theres no indication at all in how 12 they are processed. And I want to just remind you as 13 to the concern and this is something that Ive got a 14 lot of experience with.
15 If you have an instrument in the fluid, a 16 thermal couple resistance temperature detector or any 17 other thing, theres a certain amount of heat capacity 18 in this. Theres inertia in it.
19 So, it will measure the temperature of the 20 fluid and at steady-state you get a very -- if its 21 calibrated, you get a very nice result. But during a 22 transient when its changing with time, theres a lag.
23 It takes a while for the device to come up to the 24 temperature of the fluid. Either go down, or go up 25 depending what the fluid is doing.
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5838 1 And so, what you have to do, theres 2 really two fundamental ways to treat it. One, you 3 just write down the differential equation, which is 4 the energy balance on the center itself, and it 5 amounts to numerically differentiating the data. And 6 you may know thats a noisy affair and you have to do 7 it very carefully in order to get a reasonable answer.
8 The other way is to solve for the step 9 solution or the impulse solution, which is the 10 derivative of that, get what the stress people like to 11 call the Greens function and then you convolute it 12 by integrating -- its called the Duhamel theorem, you 13 integrate all these step solutions by whats going on 14 in your signal and you get what the real temperature 15 is, but you cant just take the temperature from the 16 reading and use that as the temperature and nowhere do 17 they talk about that at all.
18 And when I ask the question and I got a 19 response in testimony from Entergy, I believe, it was 20 we take care of it. We know about thermal couple lag.
21 I dont see anything like that and its 22 important.
23 JUDGE KENNEDY: Dr. Lahey, this is Judge 24 Kennedy. As I understood it yesterday, they were 25 taking peak and minimum values from the transient NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5839 1 data.
2 Does that eliminate some of the concerns 3 about the thermal lag effect in the thermal couples?
4 DR. LAHEY: If youre measuring what the 5 peak and the minimum is, you need to make the 6 correction to know what the real peak is and what the 7 real minimum is.
8 JUDGE KENNEDY: What is the effect of 9 calibrating the thermal couple? Is that an attempt to 10 --
11 DR. LAHEY: You need to --
12 JUDGE KENNEDY: Would that not consider 13 that effect?
14 DR. LAHEY: Sir, you need to calibrate 15 your temperature sensor for sure, but during 16 transients it has a certain inertia. So, its like if 17 you take a piece of metal and drop it in boiling 18 water, it doesnt instantly come to the temperature of 19 the boiling water. It takes a while because of its 20 heat capacity, mass times the specific heat to heat 21 up.
22 And depending on what the temperature 23 sensor is and how massive it is, the more the inertia 24 is. But in any event, you just dont get the right 25 answer unless you make corrections.
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5840 1 JUDGE KENNEDY: I mean, would you not get 2 to the correct temperature? I mean, eventually its 3 going to reach the right temperature at some point.
4 DR. LAHEY: For steady-state. Yeah, if 5 you go up and reach a steady state, you wait a while 6 until its all settled out, you can get a result, but 7 theres all kinds of different transients that theyre 8 looking at. Its not just that particular one that 9 was discussed in terms of the surge line.
10 JUDGE KENNEDY: Well, since my memory is 11 failing me, maybe someone from Entergy could help us 12 understand how the thermal couple data is used and 13 whether its adjusted for some of the effects that Dr.
14 Lahey is concerned with.
15 MR. GRAY: This is Mark Gray for Entergy.
16 Yes, there are -- one important aspect of 17 understanding this is its understood that there is a 18 lag in the thermal couple. And its also understood 19 that the thermal couples were calibrated and the 20 readings in the plant computer are used for operating 21 the plant. So, theyre pretty reliable temperature 22 measurements, number one.
23 Number two, these transients dont happen 24 in milliseconds. These transients happen in the 25 actual plant data over minutes, in reality. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5841 1 design transients are very conservatively estimated to 2 occur over seconds. So, the bottom line is this --
3 youre correct in saying that if theres any 4 difference between where I started and where I ended, 5 we are capturing the whole history of the transient.
6 Were capturing that whole temperature history. So, 7 thats not an instantaneous thing that happens.
8 And so we can, number one, be confident 9 for the rate of these transients that were getting a 10 good reading as far as, again, what matters to stress.
11 And what matters to stress is not the absolute 12 temperature. What matters to stress is the change in 13 the temperature.
14 And as long as weve looked at the whole 15 excursion of the temperature range we have the Delta-T 16 that we need. And that was -- thats Step 1, but the 17 only thing that we discussed yesterday is the fact 18 that that is not the temperature history thats being 19 used in the stress analysis.
20 These results -- and thats what is 21 discussed in the calc note reference that I gave you.
22 These results are then binned according to severity so 23 that every transient thats tracked as far as its 24 overall Delta-T goes is not analyzed for its actual 25 Delta-T. Its binned in a higher Delta-T.
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5842 1 For example, everything thats counted 2 between a Delta-T of 320 degrees and, say, 300 -- Im 3 making this up, because Im not looking at the 4 calculation, would all be assigned a Delta-T of 320 5 degrees in the stress analysis. And, again, the key 6 here is, is that the stress range is a function of the 7 temperature change. So, these conservatisms are 8 sufficient to account for a small lag in a thermal 9 couple reading.
10 JUDGE KENNEDY: All right. Dr. Lahey, 11 response.
12 DR. LAHEY: Go ahead.
13 JUDGE KENNEDY: No, I --
14 DR. LAHEY: Well, my understanding of 15 that, I, you know, Im filtering it down to we dont 16 do anything. And, you know, Im used to whole 17 international meetings dealing with the inverse 18 problem. Theres textbooks on, you know, and the 19 entire purpose of the textbook is how to treat the 20 inverse problem. And Im hearing we didnt do that, 21 I mean, even though were well aware of the lag.
22 So, if you just forget about data to 23 benchmark your prediction and you just use some sort 24 of prediction and then put all that through your 25 WESTEMS code, which theyre apparently doing, its NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5843 1 really getting pretty far from reality. I mean, why 2 not -- why not at some point benchmark your result?
3 Im -- what I was trying to show yesterday 4 with the nodalization is its very unlikely that 5 theyre tracking sharp temperature change fronts. And 6 if youre not, youre not predicting the right kind of 7 thermal stress.
8 JUDGE KENNEDY: I need to do a memory 9 check again. Dr. Lahey, I thought yesterday in this 10 discussion of the analysis of the transients, the 11 thermal hydraulic analysis of the transients --
12 DR. LAHEY: Right.
13 JUDGE KENNEDY: -- that you agreed that 14 the methodology they were using to capture the 15 transient, again, from an analysis standpoint, that 16 that methodology was okay and that that data was then 17 transferred into the WESTEMS code and the stress 18 analysis performed, but I didnt hear yesterday that 19 you had any concern with the thermal hydraulic 20 analysis that developed the transient data.
21 Did I mishear you yesterday?
22 DR. LAHEY: All these documents are 23 associated with specifying the transients. All right.
24 And what Im talking about is making measurements of 25 the transients to verify or disprove what youre NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5844 1 predicting. And you need to do the inverse problem in 2 order to do that.
3 JUDGE KENNEDY: I think Im losing focus 4 here. We started with the thermal couple data --
5 DR. LAHEY: Yes.
6 JUDGE KENNEDY: -- which, as I understood 7 it, was your concern over their use of plant data to 8 characterize the transient that was of interest. In 9 that case, it was the pressurizer surge line nozzle, 10 I guess. So, we -- it appeared we tried to address 11 that.
12 This seems to be branching back to where 13 we were under Contention 26 about thermal hydraulic 14 methods.
15 DR. LAHEY: Im trying to clarify the 16 record on Contention 26, yes.
17 JUDGE KENNEDY: In regard to what, sir?
18 DR. LAHEY: In regard to my concern over 19 how they measure -- on this particular question, how 20 they measure the fluid temperature as a function in 21 time because you heard just now, yeah, were aware of 22 the lag, we take care of it.
23 JUDGE KENNEDY: Do you have a problem with 24 them using the peak steady-state values, both the peak 25 and the minimum? Is that what youre saying?
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5845 1 DR. LAHEY: If they know for sure what the 2 peak and the minimum is, if its taken during a 3 transient with no correction, I have a serious 4 problem. If its for a long period of time and they 5 know for sure what it is, that seems okay.
6 JUDGE KENNEDY: Im going to ask Mr. Gray 7 to verify this, but I understood him to say they take 8 all of the transient data under consideration during 9 the event.
10 Mr. Gray, can we go back to the transient 11 data again?
12 MR. GRAY: Um --
13 JUDGE KENNEDY: The plant data.
14 MR. GRAY: Okay. The plant data that we 15 get from the plant computer, number one, just to 16 reiterate, we can have high confidence in that data.
17 Its calibrated for the plant to use to run the plant, 18 number one. So, this thermal couple data isnt 19 something that is that much in question.
20 Number two, if we had an infinite decimal 21 transient that occurred in the fluid, this lag could 22 be a concern. Transients dont happen that way in 23 plants. And this lag will occur in thermal couple, 24 thats true.
25 But as you have said, if I have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5846 1 temperature at the beginning and I have the 2 temperature at the end and this is a transient that 3 occurs over minutes, I will get that -- the maximum 4 temperature change in the fluid.
5 Thats reflected in the thermal couple 6 data. Theres nothing wrong with that. Thats 7 standard practice in interpreting the plant data. If 8 I was trying to solve a fluids problem and I wanted 9 very precise numbers, then I might do something more 10 sophisticated.
11 Were trying to solve a stress problem and 12 were trying to use inputs that are comparable to the 13 inputs that we use in our current licensing basis 14 calculations to get stress. So, these are the 15 temperature changes, for example, that you see at the 16 regenerative heat exchanger outlet temperature.
17 These are used to run the plant. Theyre 18 also sufficient for us to look at the temperature 19 change, because its the temperature change that 20 influences the stress analysis.
21 When you do stress analysis, thats what 22 youre concerned about. That stress range, thats a 23 function of the change in the temperature. So, we 24 havent done anything abnormal or anything thats not 25 typically done in the industry to calculate a linear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5847 1 elastic stress range according to the ASME code, 2 number one.
3 Number two, I think theres still a 4 misunderstanding of how the different pieces of the 5 program were used. And the only thing that the 6 thermal hydraulic model was used for was to process 7 this temperature sensor data and to characterize it 8 into bins of maximum Delta-Ts. Thats all.
9 After that, those cycles that were counted 10 with those maximum Delta-Ts were applied 11 conservatively to the stress model, which includes 12 various zones in the model that see different 13 temperatures. Thats done with a transfer function 14 approach to get the stress in the component.
15 That stress is also then a function not 16 only of the actual temperature differences for every 17 cycle that was noted in the history that we got from 18 the plant data, but all of those cycles that occur 19 over a certain Delta-T range are all assigned a Delta-20 T of the highest range in that bin.
21 This is a very conservative way to do 22 analysis. And this gives you maximum stress ranges 23 that, in turn, are used in the fatigue usage 24 calculation.
25 JUDGE KENNEDY: All right. Thank you.
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5848 1 Dr. Lahey, Ill allow you to respond if youll limit 2 your response to --
3 DR. LAHEY: How long?
4 JUDGE KENNEDY: -- the use of thermal 5 couple data --
6 DR. LAHEY: Yes, Your Honor.
7 JUDGE KENNEDY: -- in the manner that Mr.
8 Gray just described.
9 DR. LAHEY: Sure. And the essence of the 10 disagreement with one of his statements is were 11 trying to solve a stress problem, not a fluids 12 problem, all right.
13 The problem is you cant decouple them.
14 If you get your thermal hydraulics forcing function 15 wrong, you get your stress result wrong. You just 16 cant simply be sloppy in one and precise in the 17 other. You have to be precise in both. So, thats 18 the essence of the disagreement.
19 JUDGE KENNEDY: Does this take us back to 20 the disagreement we had yesterday about the bulk 21 temperature to surface temperature Delta-T, or is it 22 more complicated than that?
23 DR. LAHEY: Well, one of the non-24 conservatisms is, in fact, how they treat their heat 25 transfer coefficient and not including the developing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5849 1 part of the thermal boundary layer and the 2 nodalization that they use.
3 I mean, the data that hes talking about, 4 the process data has lags right in it. I mean, its 5 not really what the transient is. If its a very slow 6 transient, its not bad. If its a very rapid 7 transient, its terrible.
8 JUDGE KENNEDY: Would you like to put a 9 time frame on very slow and very rapid, please? What 10 would very rapid be to you?
11 DR. LAHEY: In seconds.
12 JUDGE KENNEDY: What would very slow be 13 then?
14 DR. LAHEY: Very slow. Hours, I mean, you 15 know, things that go on for a long time. Everything 16 reaches equilibrium. If you go through a lot of the 17 kind of transients that give you the biggest loading, 18 you know, from the thermal hydraulics point of view, 19 theyre fairly fast transients.
20 JUDGE KENNEDY: What would be an event 21 that would operate on the seconds time frame? What 22 sort of accident will we be talking about?
23 DR. LAHEY: What sort of accident, youre 24 asking?
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5850 1 accident? is it a reactor coolant pump trip? Is it 2 a steam line break? Is it a --
3 DR. LAHEY: Well, you -- a number of 4 things can happen fairly rapidly. Scrams happen 5 rapidly. So do breaks, if youre interested in that, 6 but Im more interested here in the kind of -- they 7 have a whole bunch of different transients that they 8 analyze to come up with the net fatigue of a 9 particular component.
10 So, if youre looking at, for example, the 11 coarse spray line nozzle, then these events, they go 12 on and off. Every time youre changing the pressure, 13 you want to reduce the pressure, the spray will go on.
14 And then if thats under control, it goes off and you 15 go back and forth. And those are fairly rapid events.
16 JUDGE KENNEDY: All right. Thank you.
17 Just one for clarification, the discussion that we 18 just had about the thermal hydraulics calculation in, 19 I assume, the WESTEMS code, is that the discussion 20 that we had yesterday about the boundary layer in the 21 front?
22 DR. LAHEY: Yes, sir.
23 JUDGE KENNEDY: So, weve taken a lot of 24 testimony yesterday on this topic.
25 DR. LAHEY: But I wanted to clarify the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5851 1 record, because it sounded like at the end that we 2 were told that dont worry about all this heat 3 transfer stuff, you know, that isnt really the way we 4 do it. But when I look back at all the documents that 5 they quoted, thats the way they do it. On top of it, 6 they get in there and specify what the transients are.
7 JUDGE KENNEDY: Im sorry, is there 8 something wrong with them specifying the transients?
9 DR. LAHEY: No.
10 JUDGE KENNEDY: Oh, okay.
11 DR. LAHEY: You have to determine the 12 transients. I dont have any problem with that. I 13 have a problem with saying that takes care of the 14 issues that I had raised. It does not.
15 JUDGE KENNEDY: Okay. I just want to make 16 sure I understood what you meant. Thanks.
17 MR. AZEVEDO: Your Honor, this is Nelson 18 Azevedo. May I add just one additional point?
19 JUDGE KENNEDY: Ill take one more, sure.
20 MR. AZEVEDO: The primary load for the 21 pressurizer surge line for the pipe is the Delta-T 22 between the top of the pipe and the bottom of the 23 pipe.
24 So, even if you were to assume that these 25 RDDs lag by, say, a few seconds, you wouldnt expect NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5852 1 that to have any measurable impact on the Delta-T from 2 the top of the pipe to the bottom of the pipe.
3 Because whatever the lag is for one, should be the 4 same -- roughly the same for the others.
5 So, again, the primary load is the Delta-T 6 between the top of the pipe and the bottom of the 7 pipe, which introduce a bending moment, and I just 8 dont see how this will have any measurable impact on 9 that parameter.
10 JUDGE KENNEDY: All right. Thank you, Mr.
11 Azevedo.
12 MR. GRAY: Your Honor, may I add one 13 thing, too? This is Mark Gray for Entergy.
14 JUDGE KENNEDY: One last remark.
15 MR. GRAY: Okay. I think its still very 16 important to understand and I dont think its fully 17 understood how these things are being used, but the 18 temperature load thats used in the stress analysis is 19 not the identical temperature thats read from the 20 plant computer data. Its more severe, its more like 21 a design transient, it still uses conservative heat 22 transfer coefficients barring the other discussion, 23 which I wont go back to.
24 And so, the bottom line is we are not 25 using the actual temperature measurements in time that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5853 1 are gathered from that to feed that thermal hydraulic 2 model to load the stress analysis. Thats just not 3 true. We are using something more conservative in 4 these Delta-T bins.
5 JUDGE KENNEDY: And where does that Delta-6 T come from?
7 MR. GRAY: The Delta-T is what we get by 8 binning the read temperatures. So, its the 9 temperature change thats important here.
10 JUDGE KENNEDY: The plant data.
11 MR. GRAY: And it doesnt occur -- these 12 are not scrams. These are not, you know, high-rate 13 transients, for example, in the charging line. This 14 is a heat exchanger.
15 I turn off the letdown, the charging 16 temperature responds -- its a heat exchanger curve.
17 We all have seen those and its not fast. Its 18 relatively slow. Its not seconds even though it is 19 then analyzed in seconds.
20 JUDGE KENNEDY: All right. Thank you.
21 CHAIRMAN McDADE: Okay. Thank you. I 22 think that takes care of our discussion there.
23 Getting back to 38, Ive got a question, Dr. Duquette.
24 I dont want to get into a discussion of 25 the steam generator AMP. Thats been handled by a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5854 1 joint stipulation which I should note was Entergy 2 Exhibit 700, but there are some questions that I had.
3 You indicated that at Indian Point steam 4 generators with a number of plugged tubes may be more 5 susceptible to PWSCC than French reactors. But in the 6 15 years of operation, the steam generator at Indian 7 Point had only 48 out of approximately 13,000 tubes 8 blocked.
9 Why would this be of a consequence? How 10 would this affect the susceptibility to PWSCC?
11 DR. DUQUETTE: Its certainly not going to 12 affect the susceptibility of PWSCC in the divider 13 plate. It has to do with whether or not the crack 14 will progress to the interface between the -- well, 15 the diluted weld, the tube-to-tubesheet weld is the 16 area that would be affected most.
17 And I was not aware of those statistics.
18 And having heard them, I probably would back away from 19 my testimony on that issue.
20 CHAIRMAN McDADE: Okay. Thank you. Just 21 to clarify in that discussion, the discussion of AVB 22 wear and TSP wear, Entergy, could you explain to me 23 just very briefly what AVB wear and TSP wear is?
24 MR. DOLANSKY: This is Bob Dolansky with 25 Entergy. Just to make sure its very clear, thats NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5855 1 Alpha Victor Bravo, AVB. And Tango Sierra Papa, TSP.
2 CHAIRMAN McDADE: Yes.
3 MR. DOLANSKY: AVB stands for anti-4 vibration bar. At the top of the tubes they bend over 5 their U-tubes. So, at the top in the U-bend area they 6 go through a final support plate. And then in the U-7 bend area theyre not supported by a support plate.
8 Instead they are supported by anti-vibration bars, 9 which are inserted between the tubes to make sure that 10 they dont vibrate too much.
11 TSP is tube support plate. So, as you go 12 up from the tubesheet up the straight length of the 13 tubes on both the hot and cold side of the steam 14 generator, it goes through tube support plates. Those 15 plates are placed every so often to provide support to 16 the tubes. So, thats how the straight portion of the 17 tube is kept from vibrating, and the AVB is how the U-18 tube portion of the tube is kept from vibrating.
19 CHAIRMAN McDADE: Okay. Thank you.
20 Dr. Hopenfeld.
21 DR. HOPENFELD: Can I make a comment with 22 respect to just the last sentence before I forget?
23 CHAIRMAN McDADE: Im sorry, Dr.
24 Hopenfeld. Youve got to move to the microphone. I 25 couldnt hear you.
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5856 1 DR. HOPENFELD: Yeah. Can I make a 2 comment with respect to the vibration that hes 3 talking about, I believe, is under normal operating 4 conditions. I dont believe that the AVBs there can 5 really -- were really designed to withheld the steam 6 line break kind of vibration that you can get.
7 CHAIRMAN McDADE: Okay. Thank you.
8 Dr. Hiser, at one point, specifically 9 Question 141 of your testimony, NRC 161, you used the 10 term verification inspection. I just want to make 11 sure I understand what you mean by the term 12 verification inspection.
13 (Pause.)
14 CHAIRMAN McDADE: This is on Page 81 of 15 your pre-file testimony, Question 141 -- or Answer 16 141, fourth line down. You use the term verification 17 inspection.
18 And, again, its just I want to make sure 19 I understand is that a term of art or how exactly is 20 that used?
21 DR. HISER: Actually, I believe its Page 22 61.
23 CHAIRMAN McDADE: Page 61, yes.
24 DR. HISER: Okay. The verification 25 inspection is just an inspection to verify the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5857 1 effectiveness of the water chemistry program. So, 2 its not really a term of art. Its just the way that 3 we laid the words out in that response.
4 CHAIRMAN McDADE: Okay. Thank you. Okay.
5 Dr. Lahey, you submitted testimony that was critical 6 of the inspection methodology acceptance criteria and 7 corrective action criteria for divider plates.
8 In light of the testimony youve heard so 9 far, is there anything you wish to say to elaborate on 10 that testimony?
11 DR. LAHEY: Your Honor, Im more concerned 12 with the tube-to-tubesheet welds. The issue that I 13 was concerned with is the safety issue, which we 14 talked about before. And it has to do with the -- how 15 the impact loads are calculated. We never get any 16 information on that and its very important how they 17 do that.
18 CHAIRMAN McDADE: Okay. Dr. Kennedy, do 19 you have some questions of Dr. Hopenfeld?
20 JUDGE KENNEDY: Yes, I have a couple 21 questions, just loose ends that are dangling around on 22 38. Im going to address the first question to 23 Entergy, but its really a Dr. Hopenfeld question.
24 In the supporting testimony for Contention 25 38, Dr. Hopenfeld asserts that the scope of metal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5858 1 fatigue analysis should be extended into the steam 2 generator. And I guess first Id like to ask Entergy, 3 is metal fatigue a concern in the steam generator 4 components internal? Im assuming you mean its 5 internals. And if not, why not?
6 MR. AZEVEDO: This is Nelson Azevedo for 7 Entergy. Yes, Your Honor, the steam generators were 8 analyzed for fatigue. In fact, there are fatigue 9 locations in our reports.
10 JUDGE KENNEDY: So, they were analyzed.
11 MR. AZEVEDO: Yes.
12 JUDGE KENNEDY: So, they are -- does that 13 mean theyre within the scope of the fatigue 14 monitoring program?
15 MR. AZEVEDO: They are within the scope of 16 the fatigue monitoring program. Let me just remind 17 you, though, that the secondary side does not see 18 primary coolant. So, the Fen issue that weve been 19 discussing does not apply to the secondary side.
20 JUDGE KENNEDY: So, you wouldnt apply the 21 Fen factor to the secondary side components.
22 MR. AZEVEDO: Thats correct, because 23 thats a primary water side issue.
24 JUDGE KENNEDY: All right. Dr. Hopenfeld, 25 this is the extension into the steam generator, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5859 1 metal fatigue calculations.
2 DR. HOPENFELD: Sir, I would like to have 3 an opportunity, also make a comment regarding the H 4 factor because its extremely important maybe later 5 on, just the H factor that was just discussed a few 6 minutes ago.
7 JUDGE KENNEDY: Can we close out this item 8 and --
9 DR. HOPENFELD: Yeah, okay.
10 JUDGE KENNEDY: Do you have any additional 11 concerns about metal fatigue in the steam generator 12 and whether --
13 DR. HOPENFELD: Well --
14 JUDGE KENNEDY: -- its being managed for 15 aging?
16 DR. HOPENFELD: Yes, because metal fatigue 17 has been experienced in a feed line break. It has 18 been experienced in tubes on the top, the U-bands.
19 And obviously those tubes sit in water. They dont 20 sit in air. So, the same correction factor has to be 21 applied.
22 The fact that the water is not radioactive 23 is completely immaterial. What affects the ASME code 24 does not take in effect of the environment, doesnt 25 take effect in water.
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5860 1 So, thats what the NRC in 1996 or 2 whatever came up with the recommendation or with the 3 requirement that they include correction for the 4 environment. Why not do it to the secondary side 5 where this is the most important part of the plant 6 safety wise?
7 Most of the accidents we have, they were 8 initiated in the secondary side. Most of the damages 9 that we -- or leaks that we have on the secondary 10 side.
11 JUDGE KENNEDY: So, your concern -- is 12 your concern with the need to apply Fen factors to --
13 DR. HOPENFELD: Absolutely.
14 JUDGE KENNEDY: -- the secondary side?
15 DR. HOPENFELD: Thats my whole thing.
16 They have to apply that. Otherwise this is not a 17 fatigue program. This is something else, but its not 18 a fatigue program.
19 JUDGE KENNEDY: I guess --
20 DR. HOPENFELD: I would just want you to 21 understand theres absolutely no reason to -- just the 22 fact that the water is radioactive in one side and the 23 other one isnt, thats just has nothing to do with 24 crack propagation or leakage or anything.
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5861 1 can find out here. I see the NRC in front of us.
2 Your recommendation was to apply the Fen factors to 3 the metal fatigue calculations.
4 Why are they not applied -- or should they 5 be applied to the secondary side components?
6 MR. STEVENS: This is Gary Stevens of the 7 NRC staff. Our guidance is clear that the Fen 8 evaluations are limited to reactor coolant pressure 9 boundary components.
10 JUDGE KENNEDY: So, is it the fact that 11 the function is pressure boundary components, or the 12 fact that they are subjected to a water environment 13 thats on the primary side of the reactor coolant 14 system?
15 MR. STEVENS: Its reactor coolant 16 pressure boundary.
17 JUDGE KENNEDY: That is a pressure 18 boundary.
19 MR. STEVENS: Correct.
20 JUDGE KENNEDY: So, in the case that Dr.
21 Hopenfeld mentioned about the U-tube region of the 22 steam generator tubes, would that constitute a reactor 23 coolant system pressure boundary?
24 MR. STEVENS: This is Gary Stevens of the 25 staff. Im going to defer to one of my colleagues, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5862 1 because Im not a steam generator expert.
2 MR. AZEVEDO: Your Honor, may I correct 3 something I said before? Ive been corrected. The 4 Fens have been applied to all CUFs. I misspoke 5 before.
6 JUDGE KENNEDY: Both primary and 7 secondary?
8 MR. AZEVEDO: That is correct.
9 CHAIRMAN McDADE: Thank you, Mr. Azevedo.
10 JUDGE KENNEDY: Lets go to Mr. Hopenfeld 11 then. Dr. Hopenfeld.
12 DR. HOPENFELD: I would like to understand 13 that. I havent seen any Fen correction into the 14 secondary side. Would you please provide us with some 15 reference to it?
16 There are references on the primary side, 17 but there was nothing on the secondary side. They 18 kept repeating in the testimony, this is brand now.
19 they kept repeating in the testimony that theyre not 20 doing the secondary side.
21 JUDGE KENNEDY: Lets give Mr. Azevedo a 22 chance to respond to that.
23 MR. GRAY: This is Mark Gray on --
24 JUDGE KENNEDY: Or Mark Gray.
25 MR. GRAY: -- behalf of Entergy. In the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5863 1 process of addressing the RAIs on the environmental 2 fatigue, Entergy did do a screening process to 3 determine limiting locations. And that was applied to 4 all of the CLB locations that had a fatigue usage 5 calculation.
6 So, even though I agree with Mr. Stevens 7 that the regulation does not apply to secondary side 8 components, because these had a CLB, Entergy also 9 included those steam generator locations that had a 10 CUF calculation in the screening process to determine 11 the limiting locations for environmental fatigue.
12 JUDGE KENNEDY: Is there an exhibit within 13 the testimony that --
14 MR. GRAY: Yes.
15 JUDGE KENNEDY: -- you would point to for 16 that?
17 MR. GRAY: As soon as I put my glasses on.
18 Wait a second. Thats Entergy 683.
19 JUDGE KENNEDY: All right. Thank you.
20 Dr. Hopenfeld --
21 DR. HOPENFELD: Yes.
22 JUDGE KENNEDY: -- did you hear the 23 citation?
24 DR. HOPENFELD: Im sorry?
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5864 1 that Mr. Gray gave?
2 DR. HOPENFELD: No, I didnt. I heard 3 what he said that they did the CUFs for the secondary 4 side.
5 JUDGE KENNEDY: Entergy 683 is what hes 6 referring to.
7 DR. HOPENFELD: I dont -- Ill have to 8 check. I dont --
9 JUDGE KENNEDY: I understand.
10 DR. HOPENFELD: I dont have it in my 11 mind. But what I would like to say that I brought up 12 this issue of effect of geometry change and the stress 13 concentration. This is more important on the 14 secondary side, because its all over, because it is 15 subjected to FAC.
16 And those of you that were at the FAC 17 hearing, you saw what kind of surfaces we have there, 18 what kind of geometry changes we have there. So, I 19 havent seen any calculation to indicate that that was 20 taken in account.
21 Now, when the plant was designed, they 22 didnt have any geometry changes on the secondary 23 side.
24 JUDGE KENNEDY: I guess Ill turn to 25 Entergy. I thought I heard either earlier today or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5865 1 yesterday in regard to stress concentration factors 2 that geometry changes were the major consideration in 3 the application of this concentration package.
4 Is that still true?
5 MR. AZEVEDO: Well, yeah. I think were 6 talking about different geometry changes, though. The 7 geometry changes that I was talking about was going 8 from a thin section to a thick section, for example.
9 Thats a geometry change.
10 I believe the geometry change thats being 11 discussed now is changes from the way the plant was to 12 what it is currently. So, the thicknesses changed 13 over time perhaps as a result of phenomena like flow 14 accelerator corrosion or some other phenomena. I 15 believe thats whats being discussed right now.
16 JUDGE KENNEDY: Would that be a situation 17 where the stress concentration factors would be 18 applicable?
19 MR. AZEVEDO: Well, let me just say that 20 the -- if we are talking about flow accelerator 21 corrosion, which I dont know that we are, but if we 22 are, first of all, this was discussed during the flow 23 accelerator corrosion issue, but that is only 24 applicable to balance-of-plant piping. And that 25 piping was not designed to the same requirements as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5866 1 the piping that weve been discussing, the components 2 weve been discussing.
3 So far the fatigue calculation that weve 4 been discussing are mandated by ASME Section 3. The 5 balance-of-plant piping that would be susceptible to 6 flow accelerator corrosion, thats designed to a P31.1 7 code, which is totally different, does not require an 8 explicit fatigue analysis. Fatigue cycles are handled 9 differently by stress reduction factors and that is a 10 totally different type of analysis.
11 JUDGE KENNEDY: I appreciate that, Mr.
12 Azevedo. I was presuming we were talking about metal 13 fatigue.
14 Dr. Hopenfeld, were you addressing that in 15 regard to metal fatigue?
16 DR. HOPENFELD: Yeah, I was addressing 17 metal fatigue. Ill give you an example so maybe you 18 can see where Im coming from. Lets say just off the 19 top of my head, lets say that the J-tube, that would 20 be a good example, because the flow comes in there 21 high velocity and turns around and it starts eroding 22 around the band.
23 So, you have high erosion and you have 24 very abrupt changes in the --- around the band in the 25 surface in the thickness. These are concentration NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5867 1 factors that has to be taken in account.
2 Another affect, which I didnt know until 3 we had the meetings last -- two years ago, that some 4 of the components they have, have extremely huge 5 imperfection on the surface. I think it was called 6 dilation, but they were huge, which we were told that 7 they accept -- they escaped the initial screening and 8 they were in the plant.
9 Because when I brought up the question of 10 that this was a result of corrosion, say, no, thats 11 the way that we got it from the factory. We just 12 didnt catch it in time. NRC didnt catch it either, 13 but there wasnt one component. There were several.
14 Now, these are concentration factors. You 15 have to take into account when they designed the 16 plant, they didnt know that they had all these 17 components with dilation to them.
18 JUDGE KENNEDY: Are these components 19 within the scope of license renewal, Dr. Hopenfeld?
20 DR. HOPENFELD: Well, theyre on the 21 secondary side.
22 JUDGE KENNEDY: Are they within the scope 23 of license renewal?
24 DR. HOPENFELD: I think anything that is 25 metal fatigue, wouldnt that be a scope or a license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5868 1 -- anything metal fatigue, in my mind, is a scope --
2 within the license renewal.
3 JUDGE KENNEDY: Im not sure, but I think 4 Entergy knows. Mr. Azevedo, lets just take the J-5 tubes. Would they be within the scope of license 6 renewal for Indian Point? Do you have J-tubes?
7 MR. AZEVEDO: Your Honor, this is Nelson 8 Azevedo. Yeah, we do have J-tubes. They are part of 9 the steam generator. So, I would consider part of 10 license renewal.
11 JUDGE KENNEDY: So, theyre within the 12 scope.
13 MR. AZEVEDO: Yes.
14 JUDGE KENNEDY: Do you have a response to 15 Dr. Hopenfelds concern about these factors?
16 MR. AZEVEDO: The only thing I can say is, 17 you know, the J-tubes are part of the secondary side 18 of the steam generators. Theyre managed by the steam 19 generator program. We do, do periodic inspections.
20 We have no indication there was any significant 21 degradation going on. And Im not sure what else I 22 can say.
23 JUDGE KENNEDY: What sort of aging 24 mechanisms are accounted for in the steam generator 25 program? What sort of effects are looked for?
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5869 1 MR. COX: This is Alan Cox. The typical 2 aging effect for the secondary side where you dont 3 have to deal with the effects of radiation would be 4 loss of material and cracking due to various 5 mechanisms.
6 JUDGE KENNEDY: All right. Thank you.
7 DR. HOPENFELD: Can I make one comment 8 here?
9 CHAIRMAN McDADE: Dr. Hopenfeld.
10 DR. HOPENFELD: I hear that the answer is 11 that this is managed by a different program. Stress 12 corrosion cracking is managed by a different program.
13 Metal fatigue is a different program. These programs 14 are related. They are not completely unrelated. A 15 crack doesnt know whether its stress corrosion was 16 designated in one program or fatigue in another 17 program.
18 The same thing, the J-tube doesnt know 19 that they have been divided. Its a system. Its a 20 management kind of thing that you have to look at the 21 whole entire plant, not just in pieces here and there.
22 Thats why things falling in between the cracks.
23 MR. DOLANSKY: Judge Kennedy, this is Bob 24 Dolansky.
25 JUDGE KENNEDY: Mr. Dolansky.
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5870 1 MR. DOLANSKY: Can I just state something, 2 please?
3 JUDGE KENNEDY: Go ahead.
4 MR. DOLANSKY: Bob Dolansky for Entergy.
5 Im not sure about the metal fatigue part, but I can 6 tell you like if we talk about J-tubes in the steam 7 generators, this last outage at each steam generator 8 we went into the secondary side of the steam 9 generator, we performed video inspections of the 10 inside of the J-tubes on a representative sample of 11 the J-tubes, and we did not see any evidence of any 12 kind of corrosion or erosion or any evidence of any 13 cracking in the J-tubes.
14 JUDGE KENNEDY: Okay. Thank you.
15 CHAIRMAN McDADE: Dr. Lahey, you had an 16 issue?
17 DR. LAHEY: Yes. While were talking 18 about steam generators and fatigue, New York State 19 000559 is a -- and Table 4.3-10, thats a part of the 20 Indian Point license renewal application. And in this 21 table, the -- for IP3 the CUF, its not designated as 22 CUFen, but its the CUF, is 1.0 for the main feedwater 23 nozzle.
24 Now, its our understanding that when the 25 -- when something reaches 1.0, then action has to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5871 1 taken, but we have heard nothing more about this. And 2 so, its not clear to us where that stands. And its 3 an important thing, because it can induce all kinds of 4 other problems if it breaks.
5 MR. COX: This is Alan Cox for Entergy.
6 I just want to point out that the CUF, the C-U-F, has 7 not reach 1.0. If every transient thats counted and 8 considered in that analysis reached its assumed value, 9 then you would reach 1.0. You still would not have 10 exceeded 1.0, but that -- if that was to happen at 11 all, it would be very near the end of the PEO and 12 were monitoring the number of those transients to 13 ensure that they dont exceed those numbers.
14 CHAIRMAN McDADE: Okay. Dr. Hopenfeld, go 15 ahead.
16 DR. HOPENFELD: You have one. Its 17 physically impossible that its not going to be at 18 least 10001 if we put -- if you put the correction 19 factor.
20 If you look at the equation I have 21 somewhere, the CUFen, the corrected CUF, it is 22 multiplied by Fen, which is always more than one. So, 23 if you look at that one, its, you know, its all 24 probably two or three.
25 MR. AZEVEDO: Judge Kennedy, may I step in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5872 1 for a second?
2 JUDGE KENNEDY: Please.
3 MR. AZEVEDO: I dont have the exhibit 4 here in front of me, but I can tell you for the 5 feedwater nozzles, what we did was we calculated --
6 the feedwater nozzles are different from the other 7 components. What controls is the number of hours in 8 standby where youre at aux feedwater, you have the 9 cold feedwater going in and the hot feedwater coming 10 out. And so, that number that you talked about gave 11 us the allowable number of hours, which we now track.
12 So, that gives us the allowable number of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> that we can operate in Mode 2. So, obviously if 14 we approach that, we will have to redo the 15 calculation, but thats the reason why youll see a 16 high CUF to give us the highest number of allowable 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.
18 JUDGE KENNEDY: Just going back to the 19 testimony yesterday, and I guess this -- I don want 20 to get into a discussion about whether its 1.001 or 21 -- but yesterday the testimony was that all CUFs in 22 the plant are less than one.
23 I mean, I dont know if your -- I guess 24 what Im curious is what does that mean in the context 25 of now in covering a component with a CUF of one, are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5873 1 there others that are higher?
2 And I do recognize that were not at the 3 end of life yet, but --
4 MR. AZEVEDO: I, you know, the allowable 5 is 1.0 or less. So, 1.0 would still be accepted.
6 Again, I dont have the actual list in front of me, 7 but I believe the feedwater nozzle is the special 8 case.
9 JUDGE KENNEDY: Yeah, I guess Im just 10 being a little sensitive to yesterday we heard a 11 couple of individuals quote numbers that all CUFs for 12 Indian Point 2 and 3 are less than one. And Im just 13 wondering how we reconcile that with this.
14 MR. ONEILL: Your Honor, this is Mr.
15 ONeill. Is there any way we could pull this exhibit 16 up just so the witnesses could see it?
17 JUDGE KENNEDY: Thats a good point. Im 18 sure we can.
19 MR. ONEILL: I believe this, and Dr.
20 Lahey can correct me if Im wrong, did you say it was 21 New York State 00559?
22 DR. LAHEY: Until now, what we have heard 23 is we fight hard to -- as they get darn close to 1.0, 24 to keep below 1.0, because 1.0 is the action point.
25 So, this seems like 1.00.
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5874 1 JUDGE WARDWELL: If I understand you 2 correctly, Mr. Azevedo, are you saying that from this 3 table, 4.3-10, that the way you handle main feedwater 4 nozzle is you set the cumulative use factor to one, 5 calculate out the number of hours that it can be 6 operated, because it is on standby a lot, and then 7 youre tracking those hours to make sure it stays 8 below that number of hours that is designated by the 9 1.0?
10 MR. AZEVEDO: Well, yes. The only thing 11 I need, I need to verify is whether we in fact set it 12 to 1.0 or some other number. I will need to verify 13 that, but thats -- in essence, thats correct.
14 MR. TURK: This is Sherwin Turk. I hope 15 I dont mess this up, but my notes indicate --
16 CHAIRMAN McDADE: Me too.
17 MR. TURK: Pardon me?
18 CHAIRMAN McDADE: Me too.
19 MR. TURK: Early in the discussion 20 yesterday, I dont know if this is the testimony 21 youre thinking of, but I believe it was Mr. Gray --
22 or, Im sorry, Mr. Cox who said the limit is 1.0 and 23 the recalculated number can be up to that number.
24 MR. SIPOS: Excuse me, Your Honor. This 25 is John Sipos from the State of New York. I have --
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5875 1 Im going to object to what Mr. Turk is doing right 2 now.
3 MR. TURK: Im reading my notes, Mr.
4 Sipos. You can read yours.
5 CHAIRMAN McDADE: The objection is noted.
6 The objection is overruled. I will allow Mr. Turk to 7 continue.
8 MR. TURK: I cant speak for the 9 witnesses, Your Honor. There may be some other 10 testimony as well.
11 CHAIRMAN McDADE: Whats your point, Mr.
12 Turk, succinctly?
13 MR. TURK: I was trying to -- because we 14 dont have daily transcripts here, I was trying to 15 determine what was said actually yesterday.
16 CHAIRMAN McDADE: Okay. And the witnesses 17 can correct me as --
18 MR. COX: This is Alan Cox with --
19 CHAIRMAN McDADE: Judge Kennedy indicated 20 that his recollection is that the testimony was that 21 all of the CUFs were below one. I dont recall what 22 I had heard, but I had recalled seeing this particular 23 table, 4.3-10, and the 1.0.
24 And whatever was said, what I had heard 25 was that it was one or below. And thats the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5876 1 testimony of Mr. Nelson Azevedo that you viewed it as 2 1.0 was within spec.
3 MR. AZEVEDO: Thats correct, Your Honor.
4 CHAIRMAN McDADE: And I just -- and just 5 to clarify in response to Judge Wardwells question 6 that this is something that would be monitored, you 7 know, since this is not in use constantly that you 8 would monitor the number of hours that it would be 9 used to make sure that, in fact, those number of hours 10 were not exceeded and, therefore, the CUF did not go 11 above 1.00.
12 MR. AZEVEDO: Thats correct.
13 CHAIRMAN McDADE: Okay.
14 MR. ONEILL: Your Honor, this is Mr.
15 ONeill. I just think we also need to be mindful of 16 the context in which those discussions may have 17 occurred. This appears to be the original LRA, right?
18 And that number --
19 CHAIRMAN McDADE: Excuse me.
20 MR. ONEILL: Okay.
21 CHAIRMAN McDADE: You talk to us, and then 22 well talk to them.
23 MR. ONEILL: Okay. Thanks, Your Honor, 24 but I just want to emphasize that this appears to be 25 the original LRA. And the discussion yesterday may NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5877 1 have been taking place in the context of, you know, 2 re-analyses, CUFen analyses that were done 3 subsequently with respect to a primary side, you know, 4 pressure boundary components and perhaps not secondary 5 side components as addressed in the original LRA.
6 CHAIRMAN McDADE: I believe it was 7 broader, but I think that the testimony of Mr. Azevedo 8 today clarifies what the position is of Entergy.
9 So, at this point the Board has basically 10 run out of questions. We have answered those 11 questions that we had, clarified what we thought 12 needed to be clarified, which then brings us back to 13 the question that I posed at the beginning of todays 14 session. And, again, focusing on the limitations that 15 I put there of additional questions to correct or 16 clarify testimony by your own witness that would 17 otherwise be both material and misleading, or to point 18 out testimony of opposing parties witnesses that was 19 incorrect or misleading and that has not already been 20 inquired into or otherwise addressed by the Board.
21 With that limited universe, does Entergy 22 have additional questioning that they feel is 23 appropriate at this time?
24 MR. BESSETTE: Your Honor, we do 25 appreciate the opportunity. We believe the board has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5878 1 done some thorough interrogation of the witnesses. We 2 would have just a couple of wrap-up questions, but we 3 would suggest if we could just have even just 20 4 minutes to caucus. We were doing our homework at 5 lunch.
6 If that would be appropriate, again, I 7 think it would be a matter of minutes.
8 CHAIRMAN McDADE: Okay. And from New 9 York, whats your view?
10 MR. SIPOS: All right. This is going to 11 take a little while. John Sipos, State of New York.
12 Id like to review what has happened in this 13 proceeding with Track 1 and Track 2.
14 In Track 1 on August 8, 2012, the State of 15 New York filed a motion for cross examination. It was 16 over the objection of the other -- the applicant and 17 the federal regulator. And that was pursuant to 18 Atomic Energy Act Section 274(l).
19 Your Honors and the Commission allowed 20 limited attorney questioning at Track 1. There was an 21 opportunity for the parties to file a request either 22 under Part 2, or under the Atomic Energy Act, again, 23 Section 274. And 274 is a specific reg for a 24 sovereign state such as New York.
25 New York did not file such a motion. No NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5879 1 other party filed such a motion. There was even a 2 gentle reminder from the Board in one of the 3 scheduling notes in September, I believe.
4 So, the State is surprised that at this 5 late time in this Track 2 hearing on the fourth day of 6 the hearing, there is now a suggestion that the 7 parties could conduct cross examination or examination 8 of their own witnesses or follow-up examination of 9 other parties witnesses. So, the State has a very 10 serious concern and objection as to that.
11 CHAIRMAN McDADE: Okay. Mr. Sipos, during 12 the Track 1 contentions, the Board allowed basically 13 what I was just suggesting today at the request of New 14 York. And New York not only had no objection, it, in 15 fact, went ahead and did do the questioning as 16 suggested, which the Board found to be helpful to it 17 in reaching its initial decision.
18 There has been no further discussion from 19 any of the parties with regard to whether the parties 20 wished to ask any questions, present any questions 21 other than in the written presentation of questions 22 that was done by all of the parties.
23 And my question to you, I guess, at this 24 point is if in the Track 1 contentions this was a 25 procedure that New York requested and utilized, where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5880 1 is the prejudice to New York in the Track 2 2 contentions to allow a similar limited questioning 3 that would be available to New York and Riverkeeper to 4 the same degree that it would be available to any 5 other party?
6 MR. SIPOS: Your Honor, John Sipos for the 7 State of New York. Id like to respond with a few 8 points.
9 The motion that was filed on August 8, 10 2012, was for Track 1 and Track 1 only. It did not 11 extend to other aspects of the proceeding and we were 12 already --we had already split or bifurcated the 13 proceeding. That is my recollection.
14 Secondly, there was in the scheduling 15 order, or the modified scheduling order, an 16 opportunity for the parties, like there was in Track 17 1, to so request the opportunity for attorney-18 initiated questioning of the witnesses. And that 19 deadline came and went, I believe, in the middle of 20 October.
21 To my knowledge -- well, I can speak for 22 the State of New York. The State of New York in that 23 time did not so avail itself of that opportunity and 24 I am not aware that any other party filed a motion 25 that day seeking that pathway forward.
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5881 1 So, in talking about --
2 CHAIRMAN McDADE: I understand, Mr. Sipos.
3 MR. SIPOS: -- the prejudice ---
4 CHAIRMAN McDADE: I understand. My 5 question -- you had said that before. My question to 6 you is not to repeat what you had said before, but it 7 was specifically to address how if this was a 8 procedure that was requested and utilized by New York 9 in Track 1 for the Board to sua sponte allow this 10 based on the Boards determination that it could 11 potentially be helpful to us, where the prejudice to 12 New York arises.
13 MR. SIPOS: Yes, I was going to get to 14 that. The prejudice to New York arises from hearing 15 about this for the first time on the fourth day of the 16 hearing. There was no prejudice the last time, 17 because the State moved in a timely, early manner and 18 there were -- there was authorization from the Board 19 and the commissioner.
20 This -- today is the first time I, as a 21 State of New York representative, heard that there 22 will be this possibility. If I had known in October, 23 if I had known in mid-October/late October, the State 24 would have prepared itself and operated differently in 25 this Track 2 proceeding. So, heres --
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5882 1 CHAIRMAN McDADE: And, Mr. Sipos, again 2 going back to my preface to this, you at least from 3 the standpoint of the board could not have prepared 4 yourself differently because this is not open-ended 5 questioning.
6 This is questioning that as Ive indicated 7 a couple of times now, is very limited. It is based 8 only on the verbal/oral testimony that has come in at 9 this particular proceeding where if you believe that 10 one of your witnesses, and you may well not, but 11 believe that one of your witnesses offered testimony 12 that you believed might be either incorrect or somehow 13 misleading, that you would have the opportunity while 14 the witnesses are here, while we are here, to help 15 correct the record.
16 Likewise, while your witnesses are here if 17 you believe that there was testimony, verbal 18 testimony, not the written testimony that came in, not 19 the pre-filed testimony, not the exhibits, but the 20 testimony of the witnesses that you believed was 21 either incorrect or somehow misleading that could send 22 the Board in the wrong direction, that you would be 23 given a brief opportunity to make inquiry into that.
24 And, again, based only on what has gone on here in the 25 hearing over the last four days.
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5883 1 So, it doesnt reflect anything with 2 regard to the written testimony where youve had the 3 opportunity to read and to submit written rebuttal and 4 rebuttal testimony, as well as rebuttal statement of 5 position, but its solely limited to what has gone on 6 here in the hearing.
7 And the question again in that limited 8 circumstance and, you know, Ive got an open mind on 9 this, but I just -- as I sit here right now, I dont 10 see what the prejudice would be to New York to afford 11 you that opportunity that you may or may not take 12 advantage of, but, likewise, to allow Entergy the 13 opportunity, as was explained, for a very few limited 14 number of questions that would serve the purpose, you 15 know, for which I proffer this.
16 Again, you can choose to take advantage of 17 it, or not, and thats fine. The question then would 18 arise if Entergy chooses to take advantage of it, how 19 is New York prejudiced given the limitations that I 20 have put on their ability to ask questions? How would 21 New York be prejudiced by that?
22 MS. SUTTON: Your Honor, this is Kathryn 23 Sutton for the applicant.
24 CHAIRMAN McDADE: Excuse me, Ms. Sutton.
25 Let me just get this from Mr. Sipos first.
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5884 1 MR. SIPOS: Judge, you are probably 2 hearing some frustration on my part. My understanding 3 coming into this proceeding having never been in an 4 NRC proceeding, was that the rules were changed in 5 2004 and there is the Citizen Action Network decision 6 from the First Circuit. And that before that time 7 there was allowance for attorney questioning along 8 with discovery. And that the 2004 rulemaking in Part 9 2 changed it.
10 So, this is -- and New York understands 11 rules change. And as we said eight years ago, as 12 Deputy Attorney General Mylan Denerstein said, well 13 play on the court that the NRC provides for us, on the 14 playing field that NRC provides for us.
15 CHAIRMAN McDADE: Okay. Am I correct, Mr.
16 Sipos, and, again, my recollection is that with Track 17 1 New York made the request.
18 MR. SIPOS: Yes.
19 CHAIRMAN McDADE: We granted the request.
20 The opposing party appealed it and the Commission 21 upheld the ruling of the Board to allow it.
22 MR. SIPOS: That is correct.
23 CHAIRMAN McDADE: Now, let me also go 24 back. Ms. Sutton, Im not quite certain what you 25 wanted to say. I have a strange feeling it might have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5885 1 been that its not worth the aggravation.
2 MS. SUTTON: Sort of along those lines, 3 Your Honor. We were responding to the sua sponte 4 request that you posed today.
5 CHAIRMAN McDADE: Sua sponte offer, not 6 necessarily a request.
7 MS. SUTTON: Yes, a request for an answer, 8 an offer. Were willing to withdraw that response and 9 just rest the case.
10 MR. TURK: Your Honor, may I speak for a 11 moment for the staff?
12 CHAIRMAN McDADE: Yeah, very briefly.
13 Then were going to take a quick recess and come back.
14 MR. TURK: I think the only issue is 15 whether the Board would find it helpful for the 16 parties to do any further questioning perhaps only of 17 their own witnesses if for no other reason than simply 18 to clarify statements that may have been made.
19 And Mr. Sipos is correct that the rules 20 were changed in 2004. But as he pointed out when he 21 was arguing for the right to cross examination, the 22 rules do permit the board to allow questioning when 23 they find it will help them in reaching their 24 decision.
25 MR. SIPOS: Is that --
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5886 1 CHAIRMAN McDADE: We are going to take a 2 very brief recess. Were going to recess for about 10 3 minutes and then we will come back and either have 4 further discussion on this or, you know, recess and 5 close the hearing. So, were going to stand in recess 6 for 10 minutes.
7 (Whereupon, the proceedings went off the 8 record for a brief recess at 2:29 p.m. and resumed at 9 2:38 p.m.)
10 CHAIRMAN McDADE: Please be seated. Okay.
11 The hearing will come to order. I didnt give Ms.
12 Brancato a chance to be heard on this. Do you wish to 13 be?
14 MS. BRANCATO: Yes, thank you. First, 15 briefly, prior to the discussion about counsel 16 pursuing clarifying questions, I just wanted to point 17 out I believe Dr. Hopenfeld had indicated he wanted to 18 make a statement and it was put on hold and shelved.
19 So, if youre inclined to give him the opportunity to 20 make one last comment that he had indicated --
21 CHAIRMAN McDADE: To make a statement 22 regarding what?
23 MS. BRANCATO: It was about a particular 24 issue that had been discussed. If Your Honors wanted 25 to --
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5887 1 CHAIRMAN McDADE: Dr. Hopenfeld, what is 2 the topic?
3 DR. HOPENFELD: First, Id like to comment 4 its extremely important. I started and I thought I 5 would get another opportunity to talk about it. And 6 it has to do with the -- has to do with the factor of 7 three uncertainty in the Fen calculations.
8 What the statement was made yesterday, all 9 this was taken in the code. Its absolutely wrong.
10 That Fen isnt uncertainty data. It has nothing to do 11 with the code. As a matter of fact, its not a factor 12 of three, its a factor of six, but I just didnt want 13 to get into more detail.
14 The reason its a factor of six because 15 the Fen -- and I can go through the numbers with you.
16 The Fen -- but I dont want to get into -- the main 17 thing for the record I want to put in what the 18 gentleman said is absolutely misleading, is incorrect 19 that Fen has nothing to do -- the uncertainty of Fen 20 have nothing to do with the ASME code.
21 ASME code doesnt know anything about Fen.
22 Fen is something that was devised by the NRC by 23 Argonne. It has nothing to do with the code. Those 24 uncertainties are not -- the table that he was talking 25 about, he was talking about the margins which were due NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5888 1 to the variations in the surface roughness specimen 2 counting loads, but has nothing to do with this, what 3 I was talking about.
4 You can go through the basic -- the best 5 thing to do, to call the people at Argonne. They 6 developed this. Ask them. Thats all.
7 CHAIRMAN McDADE: And what was the other 8 point, Dr. Hopenfeld?
9 DR. HOPENFELD: Okay. My other point is 10 maybe -- it will take a little bit more time.
11 CHAIRMAN McDADE: Excuse me. The other 12 point you said will take some time?
13 DR. HOPENFELD: Yeah, little bit more 14 time.
15 CHAIRMAN McDADE: Before you get into the 16 point, just tell me what it is.
17 DR. HOPENFELD: It has to do with H star.
18 CHAIRMAN McDADE: With what?
19 DR. HOPENFELD: The H star, the 19 inches 20 of height which allows -- which assumes that this area 21 is not a safety area and we dont have to get -- we 22 dont have to inspect it or we dont have to inspect 23 it as often.
24 CHAIRMAN McDADE: Okay. I think, Dr.
25 Hopenfeld, Im going to cut you off here. That is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5889 1 focus of a license amendment. Whether or not that 2 license amendment was appropriately granted or not is 3 outside the scope of this proceeding. So, I think 4 that we have a good understanding of what it is from 5 the testimony, and also from the documents that were 6 presented.
7 And to a very large degree, that 8 particular issue is outside the scope of this 9 proceeding because it was the subject of a license 10 amendment. But thank you, Dr. Hopenfeld.
11 MS. SUTTON: Your Honor, Kathryn Sutton 12 for the applicant. Also, with respect to New York 38 13 prior to the break, Mr. Azevedo made a statement that 14 he would like to correct on the record.
15 CHAIRMAN McDADE: Okay. Thank you, Ms.
16 Sutton. Mr. Azevedo.
17 MR. AZEVEDO: Yes, Your Honor. This is 18 Nelson Azevedo. This relates to the answer to Judge 19 Kennedy, I believe it was, whether we applied Fens to 20 the secondary side. And at first I said we did not, 21 and then I corrected myself. Turns out I was right 22 the first time.
23 The Fen correction factors were 24 specifically specified for the primary side. Its for 25 primary waters, not for the secondary waters. So, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5890 1 did not apply those primary water Fens to the 2 secondary side CUFs.
3 CHAIRMAN McDADE: Okay. Thank you, sir.
4 So, you thought you made your first mistake of your 5 life, and you found out you didnt.
6 MR. AZEVEDO: I wish it was the first one.
7 CHAIRMAN McDADE: Okay. Ms. Brancato, do 8 you have any comments on Mr. Sipos objection?
9 MS. BRANCATO: Yes. Riverkeeper is 10 generally in support of this position of the State of 11 New York. In the absence of motions in accordance 12 with the Boards scheduling order, we dont 13 particularly think questions from the parties is 14 necessarily appropriate.
15 CHAIRMAN McDADE: Okay. Thank you.
16 MS. BRANCATO: And just that Riverkeeper 17 would prefer the alternative that you proposed if we 18 are to ask clarifying questions, that we would compile 19 them, submit them to you, and then you could determine 20 whether such clarifications are needed.
21 CHAIRMAN McDADE: Okay. I think the 22 situation given your position, given the position 23 stated by Entergy, we are going to sustain Mr. Sipos 24 objection. And at this point in time, were going to 25 terminate the evidentiary hearing on the Track 2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5891 1 contentions.
2 What we would direct of the parties and if 3 this schedule is not appropriate, let us know, and you 4 can let us know by email, we would ask the parties to 5 get together sometime within the next two weeks and by 6 the close of business, not Thanksgiving week, but the 7 week after that if you could, if possible, come up 8 with a proposed schedule for post-trial briefing, the 9 submitting of proposed findings of fact and 10 conclusions of law, et cetera, that were not looking 11 to get anything other than just a proposed schedule, 12 which, if possible, you know, if it can be done by 13 agreement between the parties. So, if you can get 14 together and discuss it and, if possible, present a 15 joint suggestion to us.
16 Mr. Sipos.
17 MR. SIPOS: And, Your Honor, would that 18 schedule include the possibility for the parties to 19 review the transcript from the court reporter? We did 20 that in Track 1 after the hearings.
21 CHAIRMAN McDADE: Okay. Im not really 22 sure what you mean.
23 MR. SIPOS: Like an errata sheet. The 24 last time -- sometimes theres perhaps typos in the 25 transcript. And I think last time --
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5892 1 CHAIRMAN McDADE: The answer is yes. And 2 Im sorry I just misunderstood you, but were not 3 looking for the errata sheet by a week from Friday.
4 All were looking for is from you to come up with a 5 proposed schedule, you know, realistically by when, 6 you know, can this be done.
7 MR. SIPOS: Thank you.
8 CHAIRMAN McDADE: Yes, and any other 9 proposed issues that come up post-trial. Again, what 10 were looking for is just a proposed schedule.
11 MS. SUTTON: Yes, understood, Your Honor.
12 MR. HARRIS: Understood, Your Honor.
13 CHAIRMAN McDADE: Okay. Is there anything 14 else that the staff believes should be taken up at --
15 before we close this evidentiary hearing?
16 MR. HARRIS: No, Your Honor.
17 CHAIRMAN McDADE: Entergy?
18 MS. SUTTON: No, Your Honor, other than to 19 -- on behalf of Entergy and Westinghouse to thank the 20 Board and all of the support here at the hearing.
21 MR. SIPOS: Similarly from the State of 22 New York wed like to thank Your Honors and your staff 23 for checking up here and spending a week in the Empire 24 State.
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5893 1 as well, of course.
2 CHAIRMAN McDADE: And before we do break, 3 I would like to, you know, first of all very much 4 compliment all of the witnesses. I am extremely 5 impressed with your ability to answer the questions 6 that we have posed.
7 Weve had the opportunity to go through 8 the documents and read them and focus on a particular 9 question. Youre sitting there not knowing what 10 questions were going to ask. So, these questions 11 although youre very familiar with the record, come 12 out of the blue. And your ability to locate the 13 documents that are of reference and to answer the 14 questions is truly impressive and I want to thank you 15 very much.
16 And I also want to comment with regard to 17 counsel, you know, we have had significant filings 18 both in the preparation of the pre-trial testimony, 19 and also in the preparation of the statements of 20 position that were very helpful. And a lot of work 21 went into that and they were all done in an extremely 22 professional way that made this proceeding much easier 23 for the Board. So, again, I want to thank you very 24 much. We really appreciate -- recognize and 25 appreciate your work in that regard.
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5894 1 This evidentiary hearing on the Track 2 2 contentions is now closed. Thank you.
3 (Whereupon, the hearing in the above-4 entitled matter concluded at 2:48 p.m.)
5 6
7 8
9 10 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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Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Entergy Nuclear Operations, Inc.
Indian Point Nuclear Generating Station Docket Number: 50-247-LR and 50-286-LR ASLBP Number: 07-858-03-LR-BD01 Location: Tarrytown, New York Date: Thursday, November 19, 2015 Work Order No.: NRC-2016 Pages 5676-5894 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433
5676 1 UNITED STATES OF AMERICA 2 U.S. NUCLEAR REGULATORY COMMISSION 3 + + + + +
4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 5 + + + + +
6 ________________________________
7 In the Matter of: : Docket No.
8 ENTERGY NUCLEAR OPERATIONS, INC. : 50-247-LR 9 (Indian Point Nuclear Generating : 50-286-LR 10 Station, Units 2 and 3) : ASLBP No.
11 ________________________________ : 07-858-03-LR-BD01 12 13 Thursday, November 19, 2015 14 15 Doubletree Tarrytown 16 Westchester Ballroom 17 455 South Broadway 18 Tarrytown, New York 19 20 BEFORE:
21 LAWRENCE G. MCDADE, Chairman 22 MICHAEL F. KENNEDY, Administrative Judge 23 RICHARD E. WARDWELL, Administrative Judge 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5677 1 APPEARANCES:
2 3 On Behalf of the U.S. Nuclear Regulatory 4 Commission:
5 DAVID E. ROTH, ESQ.
6 SHERWIN E. TURK, ESQ.
7 BRIAN HARRIS, ESQ.
8 of: U.S. Nuclear Regulatory Commission 9 Office of General Counsel 10 Mail Stop 15 D21 11 Washington, D.C. 20555 12 david.roth@nrc.gov 13 sherwin.turk@nrc.gov 14 brian.harris@nrc.gov 15 301-415-2749 (Roth) 16 301-415-1533 (Turk) 17 301-415-1392 (Harris) 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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5678 1 On Behalf of Entergy Nuclear Operations, Inc.:
2 KATHRYN M. SUTTON, ESQ.
3 PAUL M. BESSETTE, ESQ.
4 RAPHAEL RAY KUYLER, ESQ.
5 of: Morgan, Lewis & Brockius, LLP 6 1111 Pennsylvania Avenue, NW 7 Washington, DC 20004 8 202-739-5738 (Sutton) 9 202-739-5796 (Bessette) 10 202-739-5146 (Kuyler) 11 ksutton@morganlewis.com 12 pbessette@morganlewis.com 13 rkuyler@morganlewis.com 14 15 On Behalf of the State of New York:
16 JOHN J. SIPOS, ESQ.
17 LISA S. KWONG, ESQ.
18 MIHIR A. DESAI, ESQ.
19 of: New York State 20 Office of the Attorney General 21 Environmental Protection Bureau 22 The Capitol 23 Albany, New York 12224 24 brian.lusignan@ag.ny.gov 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5679 1 On Behalf of Riverkeeper Inc.:
2 DEBORAH BRANCATO, ESQ.
3 of: Riverkeeper, Inc.
4 20 Secor Road 5 Ossining, New York 10562 6 800-21-RIVER 7 info@riverkeeper.org 8
9 On Behalf of Westchester County:
10 CHRISTOPHER INZERO, ESQ.
11 Assistant County Attorney 12 of: Westchester County Government 13 148 Martine Avenue 14 Room 600 15 White Plains, New York 10601 16 914-995-2000 17 18 On Behalf of Westinghouse Electric Company:
19 RICHARD J. COLDREN, ESQ.
20 of: Westinghouse Electric Company 21 1000 Westinghouse Drive 22 Cranberry Township, Pennsylvania 16066 23 412-374-6645 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5680 1 P-R-O-C-E-E-D-I-N-G-S 2 (8:33 a.m.)
3 CHAIRMAN McDADE: Please be seated. The 4 hearing will come to order. Before we get started 5 with testimony, are there any administrative matters 6 to be taken up by the staff?
7 MR. HARRIS: No, Your Honor. This is 8 Brian Harris for the staff.
9 CHAIRMAN McDADE: Entergy?
10 MR. KUYLER: No, Your Honor.
11 CHAIRMAN McDADE: New York?
12 MR. SIPOS: Not at this time, Your Honor.
13 CHAIRMAN McDADE: Riverkeeper?
14 MS. BRANCATO: No, Your Honor. Thank you.
15 CHAIRMAN McDADE: Okay. Lets continue 16 with the taking of testimony with regard to Contention 17 26.
18 Judge Kennedy.
19 JUDGE KENNEDY: Yeah, this is Judge 20 Kennedy. I have just a couple follow-up questions on 21 Contention 26 first to Dr. Hopenfeld.
22 DR. HOPENFELD: Yes, sir.
23 JUDGE KENNEDY: Microphones at the ready?
24 DR. HOPENFELD: Can you hear me okay?
25 JUDGE KENNEDY: Thank you.
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5681 1 DR. HOPENFELD: Can you hear me, sir?
2 JUDGE KENNEDY: I can hear you. Thank 3 you.
4 DR. HOPENFELD: Okay.
5 JUDGE KENNEDY: In your pre-filed 6 testimony, you assert that Entergy relied improperly 7 on CUF values of record.
8 What do you mean by CUF values of 9 record?
10 DR. HOPENFELD: Okay. What I meant to 11 basically the term came from the LAR. Thats the term 12 they used in those tables, but what I mean -- what it 13 means -- what I think what it means is the CUF that 14 was calculated during the design stage. Thats the 15 CUF that the CLB is based on.
16 JUDGE KENNEDY: And why is that improperly 17 relied on?
18 DR. HOPENFELD: Because as we heard the 19 testimony yesterday, and I was trying to inject my ---
20 interject on here, is that -- the original plants were 21 designed, the --- when you calculated --- you assume 22 a certain number of changes. And in most of the 23 cases, not in all cases, some place the assumption 24 about the transients were not conservative, but I 25 believe in most case it was conservative.
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5682 1 But in addition to the number of changes 2 that you assume, you also calculate the stresses, but 3 you use the ASME code. And we have had a lot of 4 confusions --- confusing statements from Entergy about 5 the subject, but in -- the code has margins, has 6 allowances. It does not have an allowance for stress 7 concentration. It is you that you provide the stress 8 concentration.
9 Now, if you were designing the plant 40 or 10 50 years ago, and you go into one of the Pen books or 11 Peterson or something, got thousands and thousands of 12 different stress concentrations for different 13 geometries, because its a very common engineering 14 parameter that you have to use in any design.
15 Just to get you a feel for what Im 16 talking about, in my younger days, I remember, they 17 used to have razor blades that had three holes in 18 them. Now, these razor blades used to break all the 19 time. The reason was because theres a lot of stress 20 concentration in those holes. So, what they did, they 21 did away with the holes and they had a slot in there 22 and they put a stop to the breaking. Thats where the 23 stress concentration is a notch.
24 Every weld has one, because there is a 25 difference in the metal composition between the base NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5683 1 weld and what you --- and the welding material. So, 2 stress concentration, an extremely important 3 parameter. Now, when they designed, originally, the 4 stress concentration was used, did not take in effect 5 --- in account effects like corrosion, which affects 6 the surface roughness, but more importantly it causes 7 discontinuities between --- in the geometry.
8 You see the wall thinning. You sometimes 9 have a very abrupt change in wall thickness. So, that 10 wasnt taken in account and thats unsteady, but 11 another thing thats more important, and thats what 12 I test or discuss was the stress concentration depends 13 on ductility. And ductility, as we all agree, I hope, 14 is affected by embrittlement, by neutron flux. So, 15 that affected embrittlement, all the stress 16 concentration wasnt there. It wasnt taken in 17 account.
18 So, you look at that, see, -- and theres 19 an uncertainty there, but I am not applying for life 20 extension and Im going back. It is their 21 responsibility to come up with the upper limits, with 22 a conservative assumption. Every weld is an 23 uncertainty, that must be a conservative assumption.
24 Thats their job. Thats what Im talking about.
25 There is no accounting in that CUF for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5684 1 stress concentration that is being affected by 2 irradiation. Sure, irradiation does --- has improved 3 the uses, but Im talking about the stress 4 concentration. The stress concentration is the site 5 for stress -- for crack initiation. The cracks 6 initiate at corners. They dont -- really, crack 7 initiation at the stress concentration points. Thats 8 what you have to in account of. What Entergy just 9 said, well, they dont even mention it, but they keep 10 saying that they are conservative. We are 11 conservative whatever we do. They are not conserving 12 anywhere.
13 CHAIRMAN McDADE: Okay. Dr. Hopenfeld, I 14 just want to make sure I understand what youre 15 saying.
16 Although we cannot review the design basis 17 of the plant, what youre suggesting is that the 18 geometry of the plant is significantly different today 19 40 years into its operation than it was at the time of 20 the original design.
21 So, even if the CUF locations were 22 appropriate at the time of design, theyre not 23 necessarily appropriate today given the inherent 24 changes that would occur over time in the plant.
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5685 1 very well. I couldnt say it better. Thats exactly 2 -- but also in this specific occasion Im talking 3 about embrittlement.
4 Because if you are to -- usually the 5 stress concentration factors are experimental values, 6 but there are some -- there were some attention in the 7 literature that people try to come up with some kind 8 of correlation to see if you can calculate on an 9 empirical basis what it is, because at certain point 10 stress concentration goes to infinity. It depends on 11 the ratings and depends how --- at the corner it goes 12 to infinity.
13 So, the point is that the effect of 14 embrittlement, the effect of ductility on that stress 15 concentration or that CLB CUF, whatever, is not 16 reflected in those calculations. You dont have to do 17 anything, but do not say conservatively, because this 18 is untrue that I am conservative. They are not 19 conservative. This is one example.
20 I gave you yesterday about the Fen. The 21 Fen is based on a --- I dont want to get into that 22 now. Hopefully well get later.
23 CHAIRMAN McDADE: So, its your view that 24 with regard to, for example, Commitments 43 and 49, 25 that although they recalculated the CUF, that they NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5686 1 didnt redetermine the appropriate limiting locations.
2 And that, therefore, the analysis is ineffectual in 3 determining whether or not the intended use will be 4 maintained for the next 20-year period.
5 DR. HOPENFELD: Yes, theyre recalculated 6 properly. They went through the raindrop procedure, 7 you know, the pagoda thing. Thats how to count the 8 maximum/minimum stresses and you take the difference 9 and you multiply by a stress concentration, but that 10 stress concentration they have multiplied -- they made 11 changes to it.
12 Theres one place and I remember in my 13 testimony, there was one weld where I couldnt tell 14 the difference, but there was a huge reduction in 15 their screening process or their reevaluation process 16 where they refuse the original CUF by I think an order 17 of magnitude and say, well, it came from some 18 California plant. I dont remember the detail of 19 that, but I did discuss it in my testimony.
20 They changed the CUF by an order of 21 magnitude. Adjusted it lower because of the stress 22 concentration. When I looked at the stress 23 concentration, I couldnt tell because the drawing was 24 so kind of murky.
25 CHAIRMAN McDADE: The drawing was what?
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5687 1 DR. HOPENFELD: You see, the stress 2 concentration depends on the geometry -- or in the 3 weld, in especially would depend on the radius at the 4 corner and they change that. They made changes 5 because they said it was too conservative. Originally 6 they said it was too conservative. I was trying to 7 find out how much --- I couldnt tell from the 8 drawings that they have provided.
9 But nevertheless, my concern wasnt that 10 much even with the geometry in this particular case, 11 it is where is the effect of embrittlement on the 12 ductility on the concentration factor.
13 JUDGE KENNEDY: Okay. Dr. Hopenfeld, I 14 think Im still a bit --- I guess I want to make sure 15 I understand the point you made. I heard two specific 16 points. One is that the applicant had used improper 17 non-conservative transients in calculating the CUF 18 values, and that the stress concentration factors 19 should have been applied to the CUF value 20 calculations, and that those values were improperly 21 applied. Is that what you just testified to?
22 DR. HOPENFELD: The second one is correct.
23 The first one I like to amplify a little bit, because 24 I dont --- all I was saying, and maybe I --- I was 25 saying that --- I was kind of too general, I think.
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5688 1 I think when those plants were originally 2 designed, you assume number of transients. And in 3 that -- along that thought I said originally most of 4 their chances were good, except there are some cases 5 that were underestimated, there were more transients, 6 but I dont know which plants they were, but I know 7 that was the case. But in most cases they were 8 conservative with respect to the number of transients.
9 So, in that respect when I talk about the 10 transient in the particular case -- in the case of 11 IPEC, transients -- number of transients or the --
12 its not really the number, its the intensity of the 13 transient. So, there has to be --- for 20 years they 14 didnt have any data for it on the pressurizer surge 15 line. So, I dont know how they got it. Weve been 16 trying to find out.
17 In that sense, to answer your question, in 18 that sense the number of transients is not --- maybe 19 they did the right thing, but I dont know what it is.
20 I do know that for 20 years theres no 21 data on the thermal loads on those certain components.
22 And I havent seen anywhere in there describing what 23 they have done.
24 And thats an uncertainty because when you 25 calculate a CUF, when you calculate the final CUF, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5689 1 past transients are reflected in there, but how do you 2 do something when you dont know what the number of 3 transients or what the transients were? You dont 4 have data for it.
5 JUDGE KENNEDY: Is that the particular 6 transient youre referring to when you -- or 7 particular component you are referring to when you 8 said improper non-conservative transients? Is that 9 the one we should focus on?
10 DR. HOPENFELD: That was -- I believe 11 there was connection of the stratification, because 12 originally -- Im going back to this issue of 13 stratification.
14 Originally when Westinghouse designed, 15 they wrongly so even though there was data, they 16 wrongly assumed that there will be no stratification.
17 And in the mid-80s, suddenly the 18 component started falling apart. Some components, not 19 all, because of stratification or there were the surge 20 line. I dont know this particular case. Mostly 21 welds.
22 And at that point they started getting 23 data, but for 20 years, they didnt have any. So, you 24 ask yourself, what did they do here? And I think they 25 discussed it, but I dont know what they did, but I am NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5690 1 not like the NRC staff. Id like to verify it and I 2 have no opportunity to verify it.
3 JUDGE KENNEDY: But that --
4 DR. HOPENFELD: So, I have to go trust 5 what they say, and I dont -- do not.
6 JUDGE KENNEDY: Dr. Hopenfeld, I didnt 7 mean to interrupt you, but yesterday we took the 8 testimony on this stratification issue and how it was 9 accounted for in the CUF calculation.
10 Do you remember that testimony from Mr.
11 Gray yesterday?
12 DR. HOPENFELD: No.
13 JUDGE KENNEDY: Okay.
14 DR. HOPENFELD: He was talking about 15 different part. He was talking about the moving 16 front. There is a problem, but that -- I didnt want 17 to -- that is not the one I really focusing. There 18 are two aspects.
19 You see, he was talking about -- he was 20 talking about the moving front when you -- during the 21 heat-up where the pressurizer forces the fluid towards 22 the primary pipe.
23 Thats what he was talking about, which is 24 -- is the moving front back and forth that cause 25 fatigue, but I was talking about the instability of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5691 1 the two layers.
2 When you have stratification, you have an 3 unstable situation, because two different fluids of 4 two different densities come in contact. There are 5 all kind of instabilities that you can define there.
6 One of the most common ones, I think, is 7 called the Helmholtz instability, which is affected --
8 - which describes --- that really takes into account 9 the different density and the sheer between the 10 plants.
11 Now, Entergy said that we are not going to 12 have thermal striping because there is -- because 13 theres a standing wave theory that says that we are 14 not going to have it.
15 Now, originally they say they are talking 16 about standing wave theory. Then they are talking 17 about the Reynolds number theory.
18 I, again, Ive been working on this -- we 19 were one of the first ones to identify this problem.
20 So, I worked on this problem 40 years ago, but -- and 21 I had some -- I admitted certain problems in this 22 area.
23 For the last few years I havent been 24 working, but I have been following the literature.
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5692 1 theory or Reynolds number theory.
2 Reynolds, you cant just say Reynolds 3 number, you have to be a Reynolds number, it has to be 4 based on something. Has to base -- at least based to 5 be on some kind of a geometry.
6 They just say a Reynolds number theory, 7 pressure wave -- this is voodoo engineering at best.
8 And thats what they say thats conservative. Thats 9 what --
10 MS. SUTTON: Your Honor, this is Kathryn 11 Sutton for the applicant. We object to these ad 12 hominem attacks on the experts references to voodoo 13 and whatnot.
14 We just ask that Your Honors direct the 15 witness to please curb those sort of ad hominem 16 attacks on our experts. Its -- the hearing is very 17 professional. We just ask that we maintain that sense 18 of decorum.
19 CHAIRMAN McDADE: Okay. I dont think 20 that when Mr. Bush commented on Ronald Reagans 21 economics as voodoo economics, he viewed it as an ad 22 hominem attack on President Reagan. At that point, 23 Governor Reagan.
24 I didnt view what Dr. Hopenfeld said as 25 an ad hominem attack. I took it merely as an NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5693 1 indication that he thought that this was not based in 2 sound engineering judgment and its taken in that 3 regard.
4 Dr. Hopenfeld.
5 DR. HOPENFELD: True. I sincerely 6 apologize. I lost my cool. I shouldnt, and I 7 apologize to you, maam. I shouldnt have said that.
8 MR. SUTTON: Thank you. Thank you, 9 Doctor.
10 DR. HOPENFELD: I didnt meant to, but I 11 -- there are certain points you -- I dont know how to 12 describe, because we are trying to get the problem, we 13 are trying to understand something and we get 14 distracted by saying -- well, when I bring the issue 15 and Dr. Lahey bring an issue they say, well, its 16 already accounted somewhere.
17 You can deal with something, but I brought 18 the issue of the Fen saying, well, this is accounted 19 somewhere else. And the same thing with the oxygen.
20 So, we dont have --
21 JUDGE KENNEDY: Dr. Hopenfeld --
22 DR. HOPENFELD: -- time to get to the 23 details. Im sorry.
24 JUDGE KENNEDY: Can we get back to the, I 25 guess, what was the --
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5694 1 DR. HOPENFELD: Im sorry.
2 JUDGE KENNEDY: -- stratification problem 3 and which particular component are you concerned 4 about?
5 DR. HOPENFELD: Okay. The stratification 6 problem is whether you have types of fluctuation that 7 penetrates all the way to the surface.
8 What happens there, you have very large 9 fluctuations of the order between one to ten hertz 10 that could be very severe. And what they do is affect 11 the cracked surface.
12 Now, we dont understand the exact 13 phenomena. I believe that what it affects is really 14 affects the initiation time with respect to fatigue.
15 It doesnt really have an effect on the crack 16 propagation. We are not into Section 11 or anything.
17 We are into the initial initiation process.
18 JUDGE KENNEDY: I guess the question was, 19 Dr. Hopenfeld, which particular plant component would 20 this --
21 DR. HOPENFELD: The surge line.
22 JUDGE KENNEDY: The pressurizer surge 23 line? Is that what you said?
24 DR. HOPENFELD: Yes.
25 JUDGE KENNEDY: Okay. And so, is that the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5695 1 improper non-conservative transient of concern is the 2 --
3 DR. HOPENFELD: Yes.
4 JUDGE KENNEDY: And is that also the 5 component that you felt there was 20 years of missing 6 data that should have been ---
7 DR. HOPENFELD: Yes.
8 JUDGE KENNEDY: -- accounted for?
9 DR. HOPENFELD: Yeah, thats what they 10 said -- stated, yes.
11 JUDGE KENNEDY: Thank you. And then the 12 stress corrosion or stress concentration factors, you 13 feel those should be applied differently than you 14 believe theyve been applied in calculating the CUF 15 value?
16 DR. HOPENFELD: Right. The stress 17 concentration factor is --- comes at a different 18 place. The one I really would be more concerned is 19 indication of the tube-to-tubesheet welds. There are 20 20,000. Not each concentration the same. Thats why 21 I asked yesterday how do you do it? And the answer 22 was theres a procedure in the ASME.
23 And Im not that familiar with the 24 procedure, but Im sure there is, but thats just not 25 an answer, really. I would have to see what theyve NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5696 1 done, but I have no access to their computer codes and 2 I dont really know what they have done.
3 JUDGE KENNEDY: Dr. Hopenfeld, let me try 4 it a different way. You brought up the stress 5 concentration factors.
6 Are they applicable to metal fatigue?
7 DR. HOPENFELD: Are they applicable to 8 fatigue? I dont understand the question.
9 JUDGE KENNEDY: Are these not metals?
10 DR. HOPENFELD: Could you please repeat 11 the --
12 JUDGE KENNEDY: I guess Im, you know, 13 this contention is about component metal fatigue.
14 DR. HOPENFELD: Right.
15 JUDGE KENNEDY: And weve been discussing 16 for almost a day now a Cumulative Usage Factor. And 17 I tried to start my question discussing any concerns 18 you had bout those calculations, the CUF of record, as 19 you termed them.
20 DR. HOPENFELD: Well, yes.
21 JUDGE KENNEDY: And so, you brought up the 22 transients, which I think we now understand.
23 DR. HOPENFELD: Yes. Yes.
24 JUDGE KENNEDY: And Im not sure I quite 25 grasp the stress concentration factor and how it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5697 1 applies to the CUF of record calculation.
2 DR. HOPENFELD: Can I explain to you?
3 What you do, you have a whole bunch of transients.
4 You look at the whole data of loads versus time. Then 5 you go to some technique, I said raindrop technique, 6 there are others, and you pick up the maximums and 7 they group them together.
8 When you take the maximum, the peak, 9 thats all the -- mostly thats what theyre talking 10 about. I dont really have a problem, but Im sure 11 that they know how to do it and Im sure theyre doing 12 an excellent job.
13 My problem is, is after you take the plus 14 -- the peak and subtracted the minimum, then you 15 multiply that by a concentration factor. That -- the 16 result that you get is related to the fatigue life of 17 the component, yes. It affects the fatigue.
18 JUDGE KENNEDY: So, youre suggesting that 19 theres a stress concentration factor term that needs 20 to be applied or has been applied to the cumulative 21 usage factor calculation.
22 Is that what you just said?
23 DR. HOPENFELD: Yes.
24 JUDGE KENNEDY: Okay. Thank you. Lets 25 turn to Entergy. I think theres two questions at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5698 1 least on the table. One is the lack of data, the 20-2 year data for the pressurizer surge line and how that 3 was handled in the CUF of record calculation.
4 Mr. Gray.
5 MR. GRAY: This is Mark Gray for Entergy.
6 The transient development for the surge line and 7 pressurizer nozzles is documented in our two WCAPs.
8 The WCAP for Unit 2 is WCAP 17199, which 9 is Entergy 681. And the Unit 3 WCAP is 17200, which 10 I dont readily have, but I can find that -- 682, 11 okay. So, Entergy 682.
12 Section 3 of each of those WCAPs describes 13 in detail the transient development for those nozzles.
14 Within that description there are, for Unit 3 in 15 particular, there is a discussion of how we handled 16 the data for the past operation. To summarize, the 17 way that is developed is in general youll have a 18 subset of the data for the plant operations.
19 For Unit 2 we had a good amount of data --
20 well, let me stop for a second. The reason there is 21 such a thing as past and future is because there was 22 a recommendation in the 90s due to the pressurizer 23 in-surge/out-surge issue that Westinghouse studied 24 within the Owners Group for the plants to change their 25 mode of operation to mitigate these transients.
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5699 1 So, the time that the plant incorporated 2 those changes is where we expected to see a difference 3 in the transients that resulted from the operations.
4 We had data for both that past and present for Unit 2.
5 For Unit 3, that data was -- we had the 6 data for the present, but for the past, you know, we 7 were lacking data. So, what was done and is described 8 in the calculation notes, as well as in the WCAP, is 9 a study of the plant operations.
10 Coupled with looking at data, we also 11 employed operator interviews asking the operators in 12 the history of the plant how theyve changed their 13 heat-up and cool-down operations.
14 I should say that the significant 15 transients happened during heat-up and cool-down of 16 the plant when the Delta-T between the pressurizer and 17 the hot leg is high and the stratification is 18 maximized.
19 So, a combination of operator interviews, 20 studying the heat-up and cool-down procedures, seeing 21 what effects there would be was one part of that 22 investigation.
23 The other part of the investigation was 24 using actually the results of the Owners Group program 25 where all of the Westinghouse plants at the time were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5700 1 studied for their susceptibility to in-surge and out-2 surge transients. And all the plants were 3 characterized according to a dimensionalist parameter, 4 which is -- and this is described in WCAP 13588, which 5 I know is in our exhibits, but, again, I dont have 6 the exhibit number.
7 That parameter was used to compare Indian 8 Point Unit 3's surge line and pressurizer layout to 9 those other plants and to look for similarity in 10 plants for which we did have data. And of course to 11 nobodys surprise, the most similar plant to Indian 12 Point, Unit 3, with respect to that, was Indian Point 13 Unit 2.
14 So, the data from Indian Point Unit 2 for 15 the past operation, as well as other plants, was all 16 considered and an evaluation was done to determine a 17 conservative estimation of the past transients for the 18 surge line and pressurizer.
19 JUDGE KENNEDY: Okay. Thank you, Mr.
20 Gray. You used the term heat-up and cool-down.
21 When do these -- when does that occur?
22 Is that something daily? Weekly?
23 Monthly? Annually?
24 MR. GRAY: No, its -- at the least, its 25 every refueling outage. Sometimes theyll cool down NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5701 1 and heat up for a different -- and Mr. Azevedo might 2 have a better estimate of --
3 MR. AZEVEDO: Yeah. This is Nelson 4 Azevedo for Entergy. Its once every two years.
5 Maybe once every few cycles well also cool down for 6 some other reason like, you know, equipment failure, 7 something like that, but normally just once every two 8 years.
9 JUDGE KENNEDY: And so, over 20 years of 10 operation heat-up and cool-down would occur on --
11 whats a number -- estimated number of heat-ups and 12 cool-downs over the 20 years of missing data?
13 MR. AZEVEDO: Well, we can look up the 14 data. I dont have it here in front of me, but, you 15 know, Im not implying that all over those 20-year 16 periods -- over that 20-year period when we cool down 17 10 times, you know.
18 Back then we were in a different cycle 19 length. So, the number was higher, but probably by a 20 factor of two or so.
21 JUDGE KENNEDY: All right. Thank you.
22 Dr. Hopenfeld, any particular concern over how the 23 analysis was handled? And did you review those WCAPs?
24 DR. HOPENFELD: I read those three years 25 ago when we started with this. I read them -- thats NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5702 1 when I got the information that they did not have the 2 transients and they developed some kind of models.
3 There wasnt sufficient detail in that --
4 those documents to see how conservative -- or if 5 conservatives they were, but that I couldnt tell and 6 that was my problem.
7 And I think if I read it today, I probably 8 couldnt tell either. So, I am very much -- maybe NRC 9 has, because they say that all these models are 10 conservative, but I couldnt tell. I dont know how 11 you can tell when you dont have data, that something 12 is conservative.
13 JUDGE KENNEDY: All right. Thank you, Dr.
14 Hopenfeld. Stress concentration factors and their 15 impacts on metal fatigue or CUF calculations?
16 MR. AZEVEDO: Yeah, Your Honor. This is 17 Nelson Azevedo for Entergy. First, let me comment 18 that I think its implied that the stress 19 concentrations change over time. They dont change 20 over time. Theyre a function of the geometry of the 21 plant. So, unless you modify the component, the 22 stress concentrations stay the same.
23 Also, the ASME code when you do fatigue 24 analysis, you use what the code calls peak stresses.
25 And peak stresses -- excuse me -- are already the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5703 1 intensified stresses.
2 Stress intensification factor is really 3 not the right term, because ASME Section 3 requires we 4 use -- excuse me -- stress intensity is not really 5 stresses, but the end result is the same, but the 6 stresses that we use are already peak stresses which 7 have already been identified. Theyre not 8 intensified. Theyre not intensified after we paired 9 the peaks and the valleys. Theyre intensified prior 10 to that and we use those peak stresses to pair them, 11 you know, to peaks and to valleys.
12 So, the stress concentration effects have 13 been incorporated and theyre clearly specified in the 14 ASME code how to calculate them.
15 JUDGE KENNEDY: And did I hear you say the 16 stress concentration factors arent influenced by 17 corrosion or embrittlement or radiation?
18 MR. AZEVEDO: Well, again, theyre 19 certainly not influenced by embrittlement or 20 corrosion, because theres no corrosion going on in 21 the primary side.
22 MR. STROSNIDER: Your Honor, this is Jack 23 Strosnider from Entergy. Id like to add to Mr.
24 Azevedos comments that the notion about changes in 25 geometry over time it should be recognized that under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5704 1 Section 11 of the ASME code, these systems are 2 inspected periodically. In particular, the welds are 3 looked at with -- using ultrasonic methods.
4 So, if there were any change which, you 5 know, as was pointed out is not expected, they would 6 be -- that would be identified through these 7 inspections. It would have to be put in the 8 corrective action program and evaluated.
9 One other thing which I think was in Dr.
10 Hopenfelds testimony and may have mentioned earlier 11 was the notion of flow-assisted corrosion. And I just 12 want to point out that that mechanism is not 13 applicable to the primary system components that were 14 talking about. So, that would not be something that 15 would change the geometry.
16 JUDGE KENNEDY: Thank you. Dr. Hopenfeld, 17 any final thoughts on stress concentration factors and 18 how --
19 DR. HOPENFELD: Yes.
20 JUDGE KENNEDY: -- Entergy is applying 21 them?
22 DR. HOPENFELD: I have several, but I 23 dont want to take too much time. But one that I 24 would like to choose is that the stress concentration 25 I was talking about is affected by ductility.
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5705 1 And if the ductility doesnt change, if 2 the irradiation doesnt affect ductility, then theres 3 no effect on it. But from what I heard yesterday, it 4 does affect ductility. And from what I read about it, 5 it does affect ductility.
6 The original stress concentration for 7 which these peaks are multiplied by do not have 8 embrittlement effect in it.
9 JUDGE KENNEDY: Are you suggesting that 10 the ASME code prescribed method is incorrect for this 11 calculation?
12 DR. HOPENFELD: No, the ASME code is 13 correct. What I am suggesting the number that you 14 have, decay or whatever the number, ASME code will 15 tell you go to the Pearson chart or something or 16 handbook and pick up what the concentration factor is 17 for this particular geometry. But it doesnt tell you 18 that if that geometry is subjected to embrittlement 19 over time, how to handle that, or at least Im not 20 familiar with.
21 So, I think its true the geometry on the 22 primary side doesnt change, except in one case I do 23 have a problem with the whole LAR, but I dont want to 24 take too much into it.
25 If you notice that in the original LAR --
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5706 1 I dont have time to address it. So, maybe if I have 2 time, Ill come back to it. Im sorry. It would take 3 me too long to explain.
4 It relates -- Ill focus my attention now 5 on the effect of radiation on the stress 6 concentration. I dont know how that was accounted 7 for.
8 JUDGE KENNEDY: Well, maybe just to clear 9 the air, Mr. Azevedo, if we focused just on 10 embrittlement and the stress concentration factors --
11 MR. AZEVEDO: This is Nelson Azevedo for 12 Entergy. Again, Your Honor, stress concentrations are 13 geometrical, impacted by the geometry of the 14 component, not the embrittlement of the component.
15 That impacts the material properties, not the stress 16 concentrations.
17 CHAIRMAN McDADE: Okay. Mr. Azevedo, I 18 just didnt hear what you said. Its affected by the 19 geometry, not by -- I just didnt --
20 MR. AZEVEDO: Its not affected by the 21 embrittlement.
22 JUDGE KENNEDY: So, this ductility 23 question that Dr. Hopenfeld is raising, you dont --
24 do you feel its significant in relation to stress 25 concentration factors?
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5707 1 MR. AZEVEDO: No, I dont feel it impacts 2 the stress concentration factor at all. As we 3 discussed over the last couple days, what it does 4 impact is the ability of the material to resist crack 5 propagation, but thats not what were talking about.
6 Were talking about CUFs and crack 7 initiation and irradiation has no impact on stress 8 concentration. So, its a geometry issue.
9 JUDGE KENNEDY: All right. Thank you.
10 Dr. Hopenfeld, I have one final question. At least it 11 will start as one final question.
12 On Page 6 of your report, Exhibit RIV or 13 Riverkeeper 144, you state that the Fen is an 14 experimental factor and the underlying premise is that 15 the user would not extrapolate the Fen to conditions 16 other than those in its derivation.
17 Are you suggesting that you believe that 18 Entergy did so? And where in your testimony do you 19 support that statement?
20 DR. HOPENFELD: Let me explain. Id like 21 to see the statement, but from what you read -- I 22 dont have it in front of me.
23 JUDGE KENNEDY: Would you like us to --
24 would it help if we put it up on the screen? Mr.
25 Welkie, could we try 144? Riverkeeper.
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5708 1 (Pause.)
2 JUDGE KENNEDY: Page 6, I hope.
3 DR. HOPENFELD: Where would you like me to 4 look?
5 JUDGE KENNEDY: Well, Im looking myself.
6 MR. SIPOS: I believe were on Page 8. I 7 believe were on Page 8 of the pdf, Your Honor.
8 JUDGE KENNEDY: Right. Thank you. Yes.
9 Document Page 6, which I think is pdf Page 8. Thank 10 you. Okay. Scroll down just a little bit.
11 Right. The last sentence under Section 12 1.1, since the Fen is an experimental factor, the 13 underlying principle of using the above equation is 14 that the user would not extrapolate the Fen to 15 conditions other than those that existed in its 16 derivation.
17 And I guess I -- that seems like a 18 hanging statement. I filled it in by suggesting are 19 you challenging the application of this by Entergy?
20 Has it been applied outside -- that you believe its 21 been applied outside the range of applicability?
22 DR. HOPENFELD: Yes.
23 JUDGE KENNEDY: And how do you support --
24 what do you point to to support that statement?
25 DR. HOPENFELD: One of several.
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5709 1 Obviously one we discussed was the oxygen. The oxygen 2 was -- I dont want to rehash that now, because there 3 are others. The other one is stress corrosion 4 cracking.
5 You see, when these tests -- and if I read 6 the rebuttal to my report, it doesnt seem like they 7 understand. It doesnt appear as to how these tests 8 were run, because they, in their testimony, said that 9 you can take the Fen as it was in this equation and 10 directly apply it.
11 Dr. Chopra, who had developed this 12 equation, discussed this issue for full two days 13 before the ACRS in 2006. And he made it very, very 14 clear that its up to the user to any -- make 15 adjustment for its environment, and I made that point 16 in my report.
17 In reply, Entergy said that its my 18 imagination, that Dr. Chopra never was there. I gave 19 you the reference. Its in the record, but -- and I 20 can give you the pages where he said that.
21 Now, to reply to your question, which I 22 didnt, the specific one was oxygen, but the one that 23 really concerned me especially for the tube-to-24 tubesheet welds is the stress corrosion aspect of it.
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5710 1 than metal fatigue and only in one respect for the 2 same material. Stress corrosion you have uniform, 3 steady-state --
4 JUDGE KENNEDY: Dr. Hopenfeld, lets back 5 up just a second. I -- again, I -- maybe its the way 6 Im asking the question.
7 What this statement seems to imply is this 8 test, these tests that generated the Fen factors had 9 a range of conditions under which the tests were run.
10 And I read that last sentence and I may be reading it 11 incorrectly, which is why I ask the question, as a 12 challenge to someone applying those factors outside 13 the applicable range of conditions under which they 14 were developed, I dont see that as having any bearing 15 on stress concentration factors.
16 Maybe oxygen content, Im not sure, but 17 this implies to me that there is an extrapolation of 18 the Fen to conditions that are inconsistent with its 19 derivation.
20 Could you please respond to that 21 particular question as what -- well, first of all, 22 what did you mean by this?
23 DR. HOPENFELD: Well, I started trying --
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5711 1 no stress corrosion cracking in these tests. There 2 was no steady-state component during these tests. It 3 was only cycle components.
4 So, there is only fatigue, but there is a 5 synergy, as Dr. Lahey said, between fatigue and stress 6 corrosion cracking. Where is that synergy? In two 7 places.
8 One, in the initiation. And I would like 9 to -- because, again, when we talk about crack 10 initiation, crack propagation, were talking about two 11 different things. So, if you wish to see what Im 12 talking about, Im talking about the crack initiation 13 and propagation by the short cracks.
14 They are talking about Section 11 cracks.
15 Im talking about the short cracks the way are 16 described by Dr. -- or by Argonne in this report. And 17 we can go to the definition of what the crack means, 18 but there were no -- there was no stress corrosion 19 component during these tests.
20 So, you cannot apply these Fen directly to 21 a situation where the stress corrosion occurring 22 simultaneously, because their synergetic effect, their 23 mechanism of the synergy is as follows.
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5712 1 stress, what you do, youre affecting the distraction 2 of the outside layer at the tip of the crack.
3 So, the crack propagation usually would be 4 much faster, and thats what data shows that you have 5 a faster propagation of the crack, how it -- how the 6 CUFen would be affected, because the fatigue like, 7 thats what were talking about.
8 JUDGE KENNEDY: Doctor.
9 DR. HOPENFELD: Yes.
10 JUDGE KENNEDY: I hate to keep 11 interrupting you, Dr. Hopenfeld, but I think that --
12 if I look at this equation, it appears to be adjusting 13 laboratory data in air for laboratory data in water 14 conditions. Maybe water conditions that are 15 applicable for a pressurized water reactor.
16 What part of that do I not understand?
17 DR. HOPENFELD: What I think you dont 18 understand is its not only the water condition, its 19 the condition how the specimen was stressed. There 20 was no uniform stress at the time when the cycle 21 stresses were applied.
22 JUDGE KENNEDY: And how is that captured 23 in the conditions other than those that existed in its 24 derivation?
25 DR. HOPENFELD: Its not -- its not --
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5713 1 its up to the user to make adjustments for that.
2 Theres no stress corrosion --
3 JUDGE KENNEDY: Where in this document 4 does it say you need to do that?
5 DR. HOPENFELD: In the testimony -- in the 6 testimony of Dr. Chopra before ACRS, he discussed the 7 things that they did and the things they didnt do it.
8 And the members of the ACRS a whole bunch of questions 9 like you do right now. And the answer was, well, we 10 havent done this, its up to the user to adjust it.
11 Its up to the user to take care of it. We hadnt 12 looked at fluence. Its up to the user, and they keep 13 on going.
14 And we havent covered everything.
15 Theres a full two-day discussion of this, which is --
16 which to some degree if you read the report, some of 17 it is in here, but I --
18 JUDGE KENNEDY: Lets --
19 DR. HOPENFELD: What Im telling you is 20 that loads, there was no stress concentration --
22 Lets put it differently. Suppose you 23 took a sample. They use brand new samples, perfectly 24 clean -- due to stress -- a sample that already had --
25 that was already had some stress corrosion cracking.
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5714 1 The result is not going to be the same.
2 JUDGE KENNEDY: Let me --- I heard a lot 3 in your discussion there, and I heard you pointing us 4 to another document that you would suggest draws into 5 question the Fen calculation.
6 Is that what you just said? Im having 7 trouble following you, to be honest with you.
8 DR. HOPENFELD: It draws into the question 9 of the Fen. Its a new concept, really. It hasnt 10 been around for many years. So, its a perfect --
11 its an excellent concept. I have no problem with 12 that.
13 JUDGE KENNEDY: So, you ---
14 DR. HOPENFELD: Im just saying I have a 15 problem when you use --- put blindfolds and use it 16 everywhere. You have to see under what condition it 17 was obtained and ask yourself, is it applicable to 18 what Im doing? And I dont see that this is being 19 done.
20 I brought stress corrosion cracking as 21 one. Oxygen is two. Im sure there are others that 22 are constant.
23 JUDGE KENNEDY: Is there a particular 24 exhibit in your pre-filed testimony that youd like to 25 point us to, to address your concern? It doesnt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5715 1 appear to be this document, I guess, is my point.
2 DR. HOPENFELD: Well --
3 JUDGE KENNEDY: So, Ill give you an 4 opportunity to point us towards your most applicable 5 reference.
6 DR. HOPENFELD: Well, in my exhibit, I did 7 discuss the effect of stress corrosion cracking. And 8 I -- in a reference report by -- I guess by Argonne, 9 and it will take me time to look for it, I did discuss 10 the synergy between stress corrosion cracking, metal 11 fatigue. And I reference the work of Argonne where 12 they got a very, very detailed analysis showing 13 theres definitely synergy between stress corrosion 14 cracking and metal fatigue.
15 And they came up with equations and they 16 said, we can handle it. Theres information in the --
17 we can handle it. Its difficult to handle for welds, 18 but for the very base metal its okay, but the problem 19 is with the welds. We dont have enough data.
20 And welds usually are subjected to large 21 residual stresses. So, thats what the stress is.
22 JUDGE KENNEDY: Dr. Hopenfeld, are you 23 testifying that those subsequent references would lead 24 us to adjust the Fen parameters to account for other 25 mechanisms, aging mechanisms?
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5716 1 Im trying to put -- this started with an 2 Fen discussion, and were off into synergistic 3 effects.
4 DR. HOPENFELD: Here is what I suggested.
5 I think its an excellent question. Here is what I 6 suggest.
7 If youre asking me how to do it, I dont 8 know how to do it, because I dont have the data 9 although there is information -- there is some data in 10 the literature as to the synergy recreating how fast 11 the crack propagate with or without stress corrosion 12 cracking, and how fast it will initiate or not 13 initiate.
14 I dont know if I provided the reference.
15 Theres just too much material here, but there is an 16 effect. Now, how to take in account that effect?
17 I dont know, but I am sure a fraction 18 mechanic expert will come up with an answer and say, 19 well, look, if you want to be conservative, do this, 20 take this extreme. But if you dont want to be 21 conservative, thats what they doing.
22 Im talking about conservatism. Their 23 effect is finite. I dont know how to calculate it, 24 but if you -- you cannot say in the same breath that 25 you are conservative without taking into account.
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5717 1 Thats all Im saying.
2 JUDGE KENNEDY: I understand, Dr.
3 Hopenfeld. And as youre aware, we took quite a bit 4 of testimony over the last few days both on Contention 5 25 and 26 about synergistic effects.
6 I guess Ill just go back, circle one more 7 time to this Fen calculation. Do you have a 8 particular concern about how Entergy has applied the 9 adjustments for an environmental-assisted fatigue 10 calculation? And in particular, the application of 11 the Fen parameter.
12 DR. HOPENFELD: Yes, because they did not 13 account for the irradiation effect.
14 JUDGE KENNEDY: So, were back -- are we 15 back to synergistic effects?
16 DR. HOPENFELD: Its not -- were using 17 the word synergistically interchangeably. The way 18 I look synergistically, and maybe not exactly the 19 same as Dr. Lahey, I look synergistically as one thing 20 happening, another thing happen. They work 21 simultaneously.
22 And when they work simultaneously, the 23 result is different than separately. Thats what 24 synergistically mean.
25 In the case of embrittlement and fatigue, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5718 1 as far as Im -- embrittlement, like the other thing, 2 just affects the material property. Its a different 3 property. Its not that it works together. Its just 4 the property is different. So, I -- in that case, the 5 synergy word doesnt mean much to me.
6 JUDGE WARDWELL: But let me take a crack 7 at what I -- I want to make sure you are or are not 8 saying.
9 Do you believe that the Fen should include 10 -- the selection of the Fen should include some aspect 11 associated with stress corrosion cracking and oxygen 12 content? Is that your position?
13 DR. HOPENFELD: All right. Let me answer 14 to -- yes. In the case of oxygen content, its 15 already included in there. They told you use a number 16 if you dont have the actual measurements of oxygen 17 near the surface. Its not at the surface, but near 18 the surface or near the component.
19 If you dont know what it is, then use a 20 conservative value. And Argonne gave you 0.4 -- maybe 21 its more. If you have justification, use something 22 else, but dont use 0.05.
23 Even Westinghouse in their analysis 24 acknowledge that oxygen gets in there during the heat-25 up period.
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5719 1 Now, how does it get out? Im not going 2 -- there are millions of -- oxygen is being reduced 3 during --- in the core all the time.
4 JUDGE WARDWELL: So, youre saying that 5 oxygen is already included in the Fen, but its not 6 included sufficiently, is your position.
7 DR. HOPENFELD: No, I -- the Fen includes 8 the oxygen. Theres an oxygen term. What do they 9 call it? Reduced oxygen with a star on it. So, you 10 have to put -- ask yourself what oxygen --
11 JUDGE WARDWELL: Okay. So, the Fen does 12 include the oxygen.
13 DR. HOPENFELD: Oh, sure.
14 JUDGE WARDWELL: And but you are -- are 15 you objecting to the value that the applicant has used 16 --
17 DR. HOPENFELD: Yes.
18 JUDGE WARDWELL: -- for oxygen in the Fen?
19 DR. HOPENFELD: Absolutely.
20 JUDGE WARDWELL: Okay. Thank you. Now, 21 what about stress corrosion cracking?
22 DR. HOPENFELD: Im sorry?
23 JUDGE WARDWELL: And what about stress 24 corrosion cracking?
25 DR. HOPENFELD: Stress corrosion is not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5720 1 there, and I think --
2 JUDGE WARDWELL: And you believe it should 3 be a component --
4 DR. HOPENFELD: Yes, but I dont --
5 JUDGE WARDWELL: -- in the calculation of 6 the Fen.
7 DR. HOPENFELD: -- know how to do it. I 8 wouldnt know how to do it. But if I was -- if 9 somebody said, hey, you are getting on this plane, 10 think of it this way. Stress corrosion is not only 11 unique to -- it occurs on planes, too.
12 If I get on a plane and the guy said we 13 got -- these wings are stress corroded, but theyre 14 also going to fatigue during the turbulence, then so 15 I add, did you take into account the stress corrosion 16 and said, no, I am not going to get on that plane.
17 So, the answer to your question, sir, yes, 18 I would include it. I dont know how, but, again, if 19 you take an expert person, and I can name you some 20 expert, Dr. James for one, he will come up with a 21 number how you can adjust or put a safety factor into 22 this.
23 JUDGE WARDWELL: And is that in your 24 testimony in regards to a suggested method to include 25 stress corrosion cracking into the selection of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5721 1 Fen value?
2 DR. HOPENFELD: I didnt feel it was my 3 position to -- in writing this report to make 4 suggestion as to what to do. I didnt put myself in 5 that. I just said its not adequate.
6 JUDGE WARDWELL: Do you have a cite to 7 anyone else -- is this your professional opinion, or 8 are there others in the industry to which you have 9 cited backing up your professional opinion in regards 10 to whether or not stress corrosion cracking should be 11 included as part of the selection of Fen?
12 DR. HOPENFELD: There are plenty of --
13 there is -- in the paper I cited -- indicated an 14 effect of synergy before. Now, they didnt say 15 specifically --
16 JUDGE WARDWELL: Excuse me, Dr. Hopenfeld.
17 Im not talking about synergism. Im now asking just 18 what you were trying to focus in on. The selection of 19 the Fen value, you believe, should include stress 20 corrosion cracking.
21 Im asking you, do you have a cite to 22 anyone else who also -- who shares that opinion of you 23 and your testimony? And if so, where do you cite 24 that?
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5722 1 addressing the Fen should be corrected by stress 2 corrosion crack. Its up to the user to do that. The 3 stress -- the code doesnt tell you, you know, how to 4 do this. Its up to the user to make the adjustments.
5 But I dont think that --- I havent seen 6 anywhere in dispute that -- I mean, the whole concept 7 of Fen is not that old. Its fairly new. So, I 8 havent seen any discussion in literature that say, 9 hey, these people should have adjusted the Fen.
10 I am telling you that that Fen was not the 11 effect of stress corrosion cracking. The effect of 12 pre-conditioning the specimen with crack was not 13 involved here.
14 JUDGE WARDWELL: Thank you. Let me turn 15 to Entergy, either Mr. Gray or Azevedo or whoever 16 else. Lets start more generically.
17 Is there any mechanism by which you would 18 -- is there any mechanism in the current guidance that 19 allows you to change or add or supplement different 20 parameters in the calculation of the Fen?
21 MR. AZEVEDO: You mean to account for 22 stress corrosion cracking?
23 JUDGE WARDWELL: Or any -- I was doing it 24 more generically to start with, but, yes, my next 25 question was going to be for stress corrosion NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5723 1 cracking. So, fine. Use that as an example.
2 MR. AZEVEDO: Well, let me just start out 3 by saying that the stress corrosion cracking is 4 handled by a separate program. We have a separate 5 program to handle stress corrosion cracking specific 6 of LI-600. Those are the materials susceptible to 7 stress corrosion cracking. Thats a separate program.
8 JUDGE WARDWELL: Separate AMP?
9 MR. AZEVEDO: Its a separate -- yeah, 10 thats correct. We have inspections specifically for 11 that. So, thats addressed in a separate program.
12 To the extent --- well, stress corrosion 13 cracking is driven by a susceptible material, a 14 conducive environment, in the presence of stress.
15 To the extent that the environment impacts 16 the CUF, thats exactly what the Fen is for to account 17 for the impact of the environment on the crack 18 initiation. In this case, the CUF. So, we would 19 claim that thats already -- thats specifically what 20 the Fen is doing.
21 JUDGE WARDWELL: Okay. Thank you.
22 MR. AZEVEDO: But, again, stress corrosion 23 cracking is a separate program, a separate issue and 24 handled separately from the CUFen.
25 JUDGE WARDWELL: Yesterday we talked about NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5724 1 the oxygen content and that youre using an order of 2 magnitude greater than what you are actually 3 experienced at the plant; is that correct?
4 MR. AZEVEDO: Thats correct.
5 JUDGE WARDWELL: And do you have anything 6 else to add to it just so those comments are here in 7 the transcript and saves us from flipping back to find 8 out where you said it before yesterday?
9 MR. AZEVEDO: Im not sure theres 10 anything else I can say other than that we feel that 11 the numbers that were using are extremely bounding 12 and thats already accounted for.
13 JUDGE WARDWELL: And when we were talking 14 about that number, that number does relate to the one 15 used for the ultimate calculation of the Fen; is that 16 correct?
17 MR. AZEVEDO: Thats correct.
18 JUDGE WARDWELL: Thank you.
19 MR. DOLANSKY: This is Bob Dolansky with 20 Entergy. I just would like to add I believe the 21 numbers that Mr. Azevedo gave yesterday were actually 22 in our testimony or in a cite.
23 Is that right, Nelson, the numbers you 24 read from yesterday?
25 MR. AZEVEDO: Yes, its one of the Entergy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5725 1 exhibits.
2 JUDGE WARDWELL: Thank you.
3 JUDGE KENNEDY: With that, I have no 4 further questions on Contention 26.
5 JUDGE WARDWELL: I think Id like to clear 6 up a couple, if I dare.
7 CHAIRMAN McDADE: Please.
8 JUDGE WARDWELL: This is for Mr. Azevedo 9 or whoever else in Entergy. Dr. Hopenfeld did mention 10 something about the importance of this fatigue for 11 welds.
12 Do you put any more emphasis on welds as 13 opposed to any other component in regards to the 14 fatigue analysis?
15 MR. AZEVEDO: All the locations, all the, 16 you know, nozzle corners, for example, welds, anywhere 17 where theres a change in geometry or change in the 18 materials, the ASME code specifically addresses that 19 and tells you how to calculate the stress indices and 20 the peak stresses which are used for fatigue analysis.
21 So, Id say welds are not handled any 22 different than any other component that requires to 23 be, you know, accounted for, for change in geometry.
24 JUDGE WARDWELL: And those environmental 25 conditions that you apply to other components are also NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5726 1 applied to the welds like the oxygen content, et 2 cetera.
3 MR. AZEVEDO: Yes, all the CUFs are 4 amplified by the Fen. Thats correct.
5 JUDGE WARDWELL: Dr. Hopenfeld also 6 mentioned something about the fact that transient data 7 wasnt available from the early operations of the 8 plants.
9 Could you comment on that whether it is or 10 isnt, and then how have you adapted for that in 11 regards to the tracking of CUFs during operations and 12 that will be extended into the period of extended 13 operation?
14 MR. COX: This is Alan Cox. Let me start, 15 and Mr. Azevedo can continue, but I believe youre 16 referring to the lack of the details about pressurizer 17 heat-ups and cool-downs.
18 I just want to say that the number of 19 pressurizer plant heat-ups and cool-downs is known.
20 That is not lost.
21 What was not available was the specific 22 temperature information related to each of those heat-23 ups and cool-downs as far as how many cycles occurred.
24 JUDGE WARDWELL: Say again what was 25 missing. I missed a couple words right in there that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5727 1 are crucial.
2 MR. COX: The detailed temperatures 3 related to the -- the local temperatures that -- at 4 the pipe when the heat-ups and cool-downs occurred.
5 JUDGE WARDWELL: Arent those critical, 6 though, or are they not? And how did you handle that 7 lack of data?
8 MR. AZEVEDO: Well, yeah, this is exactly 9 what Mr. Gray was discussing a few minutes ago. Maybe 10 he can reiterate what he said before.
11 MR. GRAY: Hi. Yes. Mark Gray for 12 Entergy. We --
13 JUDGE WARDWELL: Are you suggesting I 14 wasnt paying attention, Mr. Azevedo?
15 MR. AZEVEDO: No, Your Honor. I did not 16 mean that.
17 (Laughter.)
18 JUDGE WARDWELL: I probably wasnt.
19 MR. GRAY: Yeah, let me explain a little 20 bit about the difference in the heat-up and cool-down 21 events versus the actual sub-events and maybe that 22 will clear that up a little bit.
23 During a given heat-up you can have sub-24 events, sub-cycles, transients that occur in the 25 pressurizer lower head due to in-surges and out-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5728 1 surges. So, the data for the number of heat-ups and 2 cool-downs for the plant was available. What we 3 didnt have was detailed temperature information for 4 those in-surges and out-surges.
5 And so, the study that we did both with 6 respect to the sensitivity of the Indian Point Unit 3 7 layout to in-surges and out-surges, the similar 8 operating procedures to other plants including Indian 9 Point 2, that study was all used to determine an 10 applicable set of transients for that path. And 11 thats what was documented in the WCAP and the 12 supporting calculations.
13 JUDGE WARDWELL: Thank you. I do recall 14 that testimony. I appreciate that.
15 Dr. Hopenfeld, two different times you 16 mentioned, I believe, the tube-to-tubesheet welds.
17 And I wasnt -- because you mentioned it twice, I was 18 wondering why that sticks in your mind as something of 19 importance.
20 And if so, to what degree is it important 21 in regards to the CUF and CUFen calculations?
22 DR. HOPENFELD: Its extremely important.
23 And I could spend half an hour, but I could spend a 24 week to talk about it, but I dont want to take the 25 week and I dont want to -- you wouldnt be interested NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5729 1 in a week of work.
2 The reason its important -
3 JUDGE WARDWELL: I think thats a safe 4 assumption.
5 DR. HOPENFELD: Okay. The reason its 6 important is because -- and the reason its important 7 to say -- to know what the CUF is, and if we can go 8 off to some material, maybe designated proprietary, 9 because I would like to mention a number for that --
10 JUDGE WARDWELL: Id like you to avoid 11 that at all possible. I dont think I need it in-12 depth enough to see that number.
13 DR. HOPENFELD: Okay. If you dont need 14 it, okay.
15 JUDGE WARDWELL: Make up a suggested 16 number. Dont --
17 DR. HOPENFELD: Okay. Suggested --
18 JUDGE WARDWELL: Or a range of numbers.
19 DR. HOPENFELD: More than one. Its 20 three.
21 JUDGE WARDWELL: More than one?
22 DR. HOPENFELD: Yes.
23 JUDGE WARDWELL: Fine.
24 DR. HOPENFELD: Three.
25 JUDGE WARDWELL: And whats this number NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5730 1 for? Number of what?
2 DR. HOPENFELD: Its the CUF. The CUFen 3 --
4 JUDGE WARDWELL: The CUF more than one --
5 DR. HOPENFELD: -- for the weld.
6 JUDGE WARDWELL: -- for what?
7 DR. HOPENFELD: For the welds, I mean, the 8 CUFen for the welds between the tube-to-tubesheet 9 welds. The tube-to-tubesheet welds. The CUFen for 10 the tube-to-tubesheet welds.
11 JUDGE WARDWELL: If it becomes greater 12 than one, then what?
13 DR. HOPENFELD: If its greater than one, 14 then what happens? First of all, I have to backup.
15 The analysis -- well, due to a steam line break, okay, 16 because its greater than one, theres a high 17 probability, I would say probably a hundred percent 18 probability, that those -- if its really more than 19 one, that those welds will fail.
20 Now, we dont know how theyre going to 21 fail. Theyll fail -- usually when these things fail, 22 it means there is a crack. Okay. So, I have 20,000 23 cracked welds and I dont know to what degree they 24 crack.
25 JUDGE WARDWELL: Are there actually NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5731 1 20,000, or was that just --
2 DR. HOPENFELD: Dont take the number 3 literally.
4 JUDGE WARDWELL: Okay. I want to make 5 sure what --
6 DR. HOPENFELD: Im going back in my 7 memory and Ive been away from these numbers for some 8 time. There are 10,000 tubes, roughly. Maybe I know 9 Entergy will say its 11,000. So, whatever. 10,000.
10 They are welded on both sides of the plenum. So, it 11 might be 20,000.
12 So, you have 20,000 welds and they are --
13 they have exhausted their useful design usage factor.
14 They are damaged. They are not something brand new 15 that came in a box from Amazon. They have exhausted 16 their usefulness. So, now what happens? What 17 happens? Well, you have a steam line break.
18 Here the steam line break depends where 19 the break is, but usually for analysis purposes we 20 usually assume that the break occurs between the 21 containment and the relief valve and the safety valve, 22 not farther that you can isolate it. So, you cant 23 isolate that.
24 So, when you have a steam line break like 25 that, you impose 2,000 pounds on the primary side NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5732 1 because now you open to the atmosphere.
2 After you scram the reactor, the pressure 3 in the steam generator goes down. So, you impose that 4 pressure and now you have a leak, a direct path for 5 the primary fluid to go directly to the -- to bypass 6 the containment and go directly to outside.
7 If the operator doesnt operate, doesnt 8 do things properly, you deplete the water and you 9 uncover the core. So, what you have to do, you have 10 to keep the core cool. You have to keep adding water.
11 But at the time, you will not lower the level, too.
12 You will stop the leak. The only way to do it to stop 13 the leak when the leak is large, is to minimize the 14 levels on both sides.
15 JUDGE WARDWELL: Is it your position that 16 the sensitivity of the plants integrity is -- has a 17 higher degree of potential impact associated with any 18 potential failure of the tube-to-tubesheet welds than 19 other components that are also tracked for fatigue?
20 DR. HOPENFELD: This, in my mind, is very 21 critical --
22 JUDGE WARDWELL: You think thats the most 23 critical component.
24 DR. HOPENFELD: In my mind it is, because 25 of the numbers they came up with.
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5733 1 JUDGE WARDWELL: Okay. Thank you.
2 DR. HOPENFELD: If they came up with small 3 numbers, I wouldnt worry about it.
4 JUDGE WARDWELL: Im not worried about it.
5 Im just -- the welds are your most critical --
6 DR. HOPENFELD: That --- in this case, 7 yes.
8 JUDGE WARDWELL: Entergy, would you like 9 to comment on that position of Dr. Hopenfeld?
10 MR. AZEVEDO: This is Nelson Azevedo for 11 Entergy. First of all, the CUFens for the tube-to-12 tubesheet welds are all below one. So, theyre, I 13 believe, 0.3 and 0.8. We were just looking at them on 14 one of the exhibits.
15 JUDGE WARDWELL: We dont need the number, 16 but thats fine. Below one is fine.
17 MR. AZEVEDO: I apologize. So, theyre 18 less than one. So, the idea that they have -- we have 19 cracks, Im not sure how to respond to that, because 20 we feel that we dont have cracks. The CUFs are 21 within the allowables.
22 JUDGE WARDWELL: Do you believe that the 23 plant safety is any more sensitive to failures of 24 those than they are of any other particular components 25 or other components within the plant that are tracked NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5734 1 for fatigue?
2 MR. AZEVEDO: No, I dont feel that thats 3 the case. Theyre part of the reactor coolant 4 pressure boundary just like many other components.
5 JUDGE WARDWELL: Thank you. Dr. Hopenfeld 6 also mentioned something about pressure wave theory 7 and Reynolds number theory.
8 Do you know what he was talking about in 9 regards to that? And how have you handled or not 10 handled that particular application of those theories 11 to your fatigue analysis, if at all?
12 And if you dont know what he was talking 13 about, thats fine, too. And Ill try to have him 14 clarify.
15 MR. GRAY: This is Mark Gray for Entergy.
16 I believe that that was in reference to the loadings 17 that were used for the surge line analysis. The --
18 JUDGE WARDWELL: Excuse me. Is that what 19 you were referring to, Dr. Hopenfeld?
20 DR. HOPENFELD: Thats correct.
21 JUDGE WARDWELL: Thank you. Continue.
22 MR. GRAY: The surge line transients were 23 developed consistent with a Westinghouse Owners Group 24 program where stratification of the line is 25 considered.
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5735 1 The transients consider two effects of the 2 stratification. One effect is the overall bending 3 moment that occurs from the stratification in the 4 line, which is different than if you assume the line 5 to be at a uniform temperature. Those bending loads 6 are included in the analyses of the nozzles.
7 The other aspect of the stratification on 8 the nozzle at the hot leg, which is, you know, two --
9 in this evaluation, I should say, two locations that 10 are controlling or evaluated. The hot leg nozzle, 11 which is -- enters the hot leg on a horizontal from a 12 horizontal aspect on the surge line, and then the 13 nozzle on the bottom head of the pressurizer, which is 14 vertical. So, the stratification occurs in the nozzle 15 when, and only when, the reactor coolant pump is not 16 running.
17 When the reactor coolant pump is running, 18 stratification can occur in the line, but not in the 19 nozzle, because of the turbulence caused by the 20 reactor coolant pump in the loop.
21 So, when the -- when the nozzle is 22 stratified, that only occurs when the reactor coolant 23 pump is off. And this has all been discussed in WCAP 24 12639, which I Can find that exhibit number for you.
25 WCAP 12639 is the documentation of the Owners Group NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5736 1 studies of surge line stratification.
2 When the stratification occurs in the hot 3 leg nozzle, there is an out-surge that has to come 4 from the pressurizer to create that hot layer on the 5 top. And then the cold layer is fed by the hot leg 6 water.
7 Since the surge line is an open line, 8 theres no valves in it or anything. You get this 9 communication between the hot and the cold.
10 When the temperature difference is very 11 high, the stratification is more severe as far as its 12 effect on the stresses. So, when you evaluate the 13 nozzle, you evaluate the nozzle for the fact that this 14 stratification comes and goes.
15 It was analyzed conservatively for those 16 local effects by just assuming that it steps from 17 stratified condition to a non-stratified condition and 18 back.
19 So, those cycles are considered in the 20 fatigue evaluation of the nozzle, as well as the 21 bending moments coincident with that same thing 22 happening in the line, because you get a range of load 23 which gives you a range of stress from that.
24 A question that was raised was with 25 respect to when you have the stratification layer, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5737 1 there has also been observed historically not in surge 2 lines, but in feedwater lines back in the late 70s, 3 a term called thermal striping. Which what happens 4 is that layer, that interface between hot and cold 5 layers will begin to fluctuate at a very high 6 frequency. This caused, actually, cracking in 7 feedwater nozzles.
8 Number one, the presence of thermal 9 striping in feedwater nozzles caused them to fail in 10 a rather short period of time, because its a high-11 cycle fatigue phenomena.
12 Those -- because of those failures, there 13 were studies done of feedwater lines and nozzles in 14 particular really to investigate the cause of the 15 cracking which identified this striping phenomenon.
16 Thats also in WCAP 9693, which is also an 17 exhibit. Let me see if I can pull that up.
18 (Pause.)
19 MR. KUYLER: Your Honor, thats Entergy 20 Exhibit 217, WCAP 9693.
21 MR. GRAY: And actually the surge line 22 WCAP is 218. So, anyway, not to get into lots of 23 detail, but you can look in 9693, I think its in 24 section -- its a big volume. Section 1073. And I 25 can confirm that. I have notes on that where it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5738 1 pretty much gives the conclusions of a whole testing 2 program where they had to simulate what was happening 3 in the feedwater lines to determine what it took to 4 get this fluctuating interface at very low flow rates.
5 And feedwater lines are a little different 6 at this weld. The aux feed water is very cold coming 7 in. So, you get an even higher temperature 8 differential, which gives you a higher Richardson 9 number, which is the dimensionless quantity thats 10 used to determine whether you can have stratification 11 or not.
12 So, with those high Richardson numbers in 13 the feedwater line, you -- they had to get in 14 conjunction with the high Richardson number and the 15 stratification, a high enough flow in that cold layer 16 coming in so that -- and there were a number of 17 conditions that are summarized in WCAP 9693.
18 One is you have to have a persistent flow 19 of that cold layer. And it has to be a high enough 20 flow characterized by the Reynolds number that creates 21 this condition where that interface becomes unstable.
22 So, they describe two different 23 conditions. A stable interface with the low flows, 24 and a -- the wavy interface, is what they call it, for 25 the high flows. That occurs in feedwater lines NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5739 1 because of the conditions under which stratification 2 occurs in that continuous flow.
3 In surge lines, the characteristics of the 4 stratification transients is discussed in WCAP 12639.
5 We observed at least 15 plants worth of data. Youre 6 not going to observe striping in thermal couples on 7 the outside of the pipe. So, you dont see that.
8 The feedwater testing had to put sensors 9 on the inside in the test loop. So, the -- but the 10 characteristics of the transients when the 11 stratification comes and goes was observed in 12639.
12 It was used to develop the distributions of the cycles 13 of stratification that I described before.
14 What happens is the stratification is not 15 a sustained situation in the surge line because of 16 this communication back and forth between the hot leg 17 and the pressurizer. So, as a result of that, you 18 dont have that sustained condition.
19 Number two, a I mentioned before, the only 20 conditions under which the hot leg nozzle is 21 stratified is when the reactor coolant pump is off.
22 When the reactor coolant pump is off, you dont have 23 a source of spray flow, because any appreciable 24 velocity or flow, Reynolds number, again, for that 25 difference to cause a wavy interface.
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5740 1 And number three, WCAP 12639 though it 2 does consider striping because it was in the early 3 days of, you know, the development of surge line 4 stratification, it states very clearly and references 5 studies that thermal striping in the surge line is 6 inconsequential. Insignificant, I think the word is 7 what it uses.
8 JUDGE WARDWELL: Okay. Thank you. Im 9 all set.
10 CHAIRMAN McDADE: That concludes the 11 questions we have directly on Contention 26. I 12 propose to take a 10-minute break before we start 13 considering Contention 38.
14 Is there anything else that we need to 15 take up?
16 DR. LAHEY: Your Honor, Id like to try to 17 clarify for the record something that came up under 18 26.
19 CHAIRMAN McDADE: Okay. Hold that for 20 just a second, Dr. Lahey. Ms. Sutton or --
21 MR. KUYLER: Yes, Your Honor. There were 22 two items that I believe Your Honors had asked our 23 witnesses to look into yesterday, substantive matters 24 on this contention that I believe Mr. Gray has some 25 responses to.
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5741 1 CHAIRMAN McDADE: Okay. Specifically with 2 regard to the methodology used to address thermal 3 coupling?
4 MR. KUYLER: Yes.
5 CHAIRMAN McDADE: Is that the first one?
6 MR. KUYLER: Yes, Your Honor.
7 CHAIRMAN McDADE: Okay. Mr. Gray.
8 MR. GRAY: Yes, Your Honor. The question 9 was to where do we have an example in the record 10 showing how we treated the thermal couple data, the 11 sensors from the plant and how those were used for 12 incorporation into the transients and the transient 13 binning that I described.
14 Entergy 689, which is WCAP 12191, Section 15 2.6 describes the process used to characterize the 16 system transients based on the Delta-T. The 17 corresponding -- and thats for the charging system, 18 by the way.
19 The corresponding use of those -- of that 20 information is documented in Entergy 727, which is 21 calculation CN PAFN 0921. In Appendix A.3.1 of that 22 calculation, it describes how that information was 23 applied to the stress model to calculate fatigue.
24 CHAIRMAN McDADE: Okay. Thank you, Mr.
25 Gray.
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5742 1 MR. GRAY: I would like to also answer 2 another thing that was brought up, if I may.
3 CHAIRMAN McDADE: Can you give us general 4 life here of what it is before you jump into it?
5 MR. GRAY: Yes. Dr. Lahey stated that we 6 used elastic plastic analysis from MB 3228 of the 7 code. And we -- and I stated that we did not. I 8 would just like to clarify what may have occurred with 9 that.
10 CHAIRMAN McDADE: Please.
11 MR. GRAY: Okay. While MB 3228 of the 12 ASME code allows you to do a plastic analysis, the 13 section of MB 3228 that describes that is 3228.3.
14 This is commonly referred to as elastic plastic 15 analysis where you calculate strains. And from those 16 strains, you use those in your analysis. We did not 17 do that elastic plastic analysis.
18 What he may have been confused by in our 19 calculations and documentation is the fact that when 20 you do the linear elastic analysis of MB 3200, MB 21 3228.5, which I mentioned yesterday in my testimony, 22 describes a factor called K-E. Its a penalty that 23 you put on your elastic stress when you exceed certain 24 limits. And so, it allows you to exceed those limits 25 of stress equations when you penalize your usage NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5743 1 factor calculation.
2 Thats called a simplified elastic plastic 3 correction factor in the code. So, you could see the 4 words elastic plastic with respect to the Ke penalty 5 factor, but its not the same as doing a 3228.3 6 plastic analysis.
7 CHAIRMAN McDADE: Okay. Thank you. Okay.
8 Dr. Lahey, before you proceed, what I was thinking it 9 might be appropriate to do, theres a couple of 10 references there to Entergy 689 and 727 relating to 11 methodology and I think were probably going to want 12 you to comment on those methodologies.
13 And it may be appropriate for us before 14 you begin to, you know, augment your testimony, to 15 take that break to give you the opportunity to take a 16 look at those two exhibits, see whether or not you 17 need additional time to review them before you 18 comment.
19 I mean, its -- when we move on from 26, 20 its not like this is a strong wall, you know, we can 21 come back to it later. A lot of these contentions 22 obviously are interrelated, but I would like to give 23 you the opportunity to at least take a look at those 24 two exhibits and that may be helpful in some questions 25 that we have when you come back.
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5744 1 DR. LAHEY: Ill do that over the break, 2 Your Honor.
3 CHAIRMAN McDADE: And it may well be, I 4 mean, were only going to take, you know, well break 5 until 10 minutes after 10:00. It may be that youll 6 need additional time. And if so, just, you know, let 7 us know.
8 Is there anything else we should take up 9 before the break, Ms. Sutton?
10 MS. SUTTON: No, nothing further, Your 11 Honor.
12 CHAIRMAN McDADE: Mr. Kuyler?
13 MR. KUYLER: Nothing further, Your Honor.
14 CHAIRMAN McDADE: Brian Harris.
15 MR. HARRIS: No, Your Honor.
16 CHAIRMAN McDADE: Okay. Well stand in 17 recess then to 10:10.
18 (Whereupon, the proceedings went off the 19 record at 9:55 a.m. and resumed at 10:10 a.m.)
20 CHAIRMAN McDADE: The hearing will come to 21 order.
22 MR. SIPOS: Judge McDade, this is John 23 Sipos for the State of New York. Dr. Lahey would like 24 some additional time to review those documents.
25 CHAIRMAN McDADE: Okay. Should we then NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5745 1 take the additional testimony from Dr. Lahey up after 2 lunch? Would that be appropriate?
3 DR. LAHEY: That would be fine. I could 4 do them both at the same time after lunch.
5 CHAIRMAN McDADE: Okay. And we will 6 determine, I mean, there may or may not be significant 7 questions after that, but you indicated that you had 8 certain things that you wanted to clarify.
9 DR. LAHEY: Yes.
10 CHAIRMAN McDADE: And that may lead to 11 additional questioning by the Board. But at this 12 point, then, we might as well move on to 38. Before 13 we do, I believe Dr. Duquette is the only potential 14 witness who has not yet been sworn at least looking 15 out at the gallery of witnesses.
16 Dr. Duquette, would you please rise?
17 Would you raise your right hand? Do you swear that 18 the testimony you will give in this proceeding subject 19 to the penalties of perjury will be the truth, the 20 whole truth and nothing but the truth?
21 DR. DUQUETTE: I do.
22 CHAIRMAN McDADE: Okay. Please be seated.
23 and for the record, would you please state your full 24 name?
25 DR. DUQUETTE: My name is David Duquette.
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5746 1 CHAIRMAN McDADE: Okay. Dr. Duquette, a 2 couple of things that weve mentioned to other 3 witnesses before you were here. Its necessary for us 4 to maintain a transcript.
5 If a question is asked generally to the 6 intervenor witnesses and youre the one who is going 7 to respond, if you could state your name first to make 8 sure that the court reporter is able to attribute it 9 to you as opposed to Dr. Lahey or Dr. Hopenfeld.
10 If the question is directly to you, for 11 example, if I ask, Dr. Duquette, would you comment on 12 something, theres no need for you then again to 13 repeat your name, you know, because it will be clear 14 on the record who it is whos testifying.
15 Also, we just took a break. Well 16 probably go now until lunch. But if any witness needs 17 a break, you know, before the Board, you know, decides 18 we need a break, they should just simply, you know, 19 let us know and we can accommodate that.
20 I think those are the only bits of 21 information that I really needed to bring out to you 22 that you wouldnt already be aware of. So, with that, 23 I want to --
24 MR. BESSETTE: Your Honor, this is Paul 25 Bessette for Entergy. I just want to introduce Martin NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5747 1 ONeill has joined us as Entergy counsel for this 2 contention.
3 CHAIRMAN McDADE: Yes, we are very 4 familiar with Mr. ONeill from Track 1 and from all of 5 the pleadings.
6 Before we go further, I wanted to talk a 7 little bit about what we intend to do now. Were 8 moving on to Contention 38.
9 Theres a lot of overlap between the 10 various contentions and it is not our intent at this 11 point to revisit issues regarding the adequacy of the 12 AMP for RVIs that were covered, you know, by Judge 13 Wardwell the first two days of this hearing.
14 And, likewise, we dont intend to revisit 15 issues relating to metal fatigue and CUF values and 16 environmental adjustments and the various WESTEMS 17 issues that were covered by Judge Kennedy. Its not 18 our intent. Although some of those are applicable to 19 Contention 38 and Riverkeeper TC5, the combined 20 contention, we are not going to revisit them.
21 Likewise, with regard to the license 22 conditions that are a part of Contention 38, we --
23 there are sort of two aspects to that. One has to do 24 with enforceability, and the other has to do with 25 adequacy in order to provide reasonable assurance.
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5748 1 The first part of that, the 2 enforceability, is primarily a legal contention. So, 3 theres going to be minimal testimony that were going 4 to be eliciting on that just simply to ensure that we 5 understand how in practice this is going to be carried 6 out by the Agency. So, were going to be focusing 7 primarily on the adequacy of these individual 8 commitments in order to provide reasonable assurance.
9 That said with a preface, I want to know, 10 I mean, the parties have submitted detailed questions 11 that they propose the Board to ask. As you know form 12 the first few days of this, many of those questions 13 were not asked by members of the Board. And part of 14 that is a -- the concept of why were having this 15 hearing and what the Board is hoping to get out of it.
16 All of the parties to this have submitted 17 detailed presentations and detailed testimony. Many 18 issues are clear and it isnt necessary for the Board 19 to go through those again.
20 When the parties were preparing their 21 questions, obviously you had no way of knowing what, 22 if anything, the Board understood from the 23 submissions. But, so, in those instances where the 24 Board felt that it didnt need clarification, we 25 simply didnt go forward and ask those particular NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5749 1 questions. I say that as a preface to this.
2 In the Track 1, we had questions at the 3 end of the hearing from the parties and the question 4 arises as to how to handle that in this Track 2 5 proceeding. And what we would be looking for or, in 6 any event, even possibly amenable to are not to allow 7 parties to go through all of the questions that they 8 propose that werent answered, but only questions that 9 were specifically addressed where their own party, one 10 of their own witnesses, said something that you 11 believe is either incorrect or perhaps misleading the 12 way it came across, or that an opposing partys 13 witness testified to that you believe was misleading 14 or incorrect and had not already been addressed.
15 Because in many instances, weve gone back and forth 16 and the differences between the positions of the 17 witnesses were very clear.
18 So, what we would be looking for is a very 19 small universe. And what we would like counsel to do 20 is after lunch, to be prepared to discuss with us 21 before we begin testimony again, how you want to 22 proceed in that regard whether there are any 23 additional questions that you think need to be asked 24 in order to clarify or complete the record. And then 25 if so, whether it would be more efficient for you to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5750 1 advise us generally as to those issues you wish us to 2 consider, or alternatively to allow counsel to ask 3 questions.
4 We did allow counsel to ask questions at 5 the Track 1 hearing. Those questions were short.
6 They were focused. None of the parties took more than 7 30 minutes. And we certainly would envision if it 8 were sent to the parties, to ask some questions 9 relatively short, relatively focused on those areas 10 that I just addressed.
11 Are there any questions with regard to 12 what Ive just gone through from Entergy?
13 MR. BESSETTE: No, Your Honor. Thank you.
14 CHAIRMAN McDADE: From the staff?
15 MR. HARRIS: No, Your Honor. Thank you.
16 CHAIRMAN McDADE: New York?
17 MR. SIPOS: No, not now, Your Honor.
18 CHAIRMAN McDADE: Riverkeeper?
19 MS. BRANCATO: No, thank you.
20 CHAIRMAN McDADE: Okay. Thank you. Okay.
21 Dr. Hiser, some -- and basically, you know, one of our 22 purposes also in addition to clarify sometimes is to 23 summarize, you know, so we have in one place in the 24 record what perhaps in the exhibits and the testimony 25 is spread out over a relatively long period of time.
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5751 1 And nothing that I say is evidence. Its 2 only something that you say is evidence, but sometimes 3 Ill ask a question, Ill sort of summarize and ask 4 you whether or not it accurately reflects the position 5 of the NRC staff so that its on the record.
6 And then it is your testimony, youre the 7 one whos swearing to it under oath, because Im not 8 under oath, and you are in a much better position to 9 speak with confidence about what the NRCs position is 10 than am I.
11 Okay. That said, is it the position of 12 the NRC staff that license commitments made as part of 13 the license renewal are part of the CLB and are 14 enforceable under the ongoing oversight process 15 established by Part 50, specifically 10 CFR 54.33? Is 16 that something that you feel --
17 DR. HISER: I would just need to review 18 54.33, Your Honor.
19 CHAIRMAN McDADE: Okay. Lets strike the 20 particular citation. Is it the general view without 21 getting into the legal citation, that these license 22 commitments become part of the CLB?
23 DR. HISER: As incorporated -- in 24 particular as incorporated through a license condition 25 in the UFSAR, they are.
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5752 1 CHAIRMAN McDADE: Okay. Now, most license 2 commitments are captured in the FSAR, the Final Safety 3 Analysis Report. Some are made as license conditions 4 due to high regulatory or safety significance, 5 correct?
6 DR. HISER: Yes, thats correct.
7 CHAIRMAN McDADE: Okay. And there are 8 also others that I believe are referred to as 9 regulatory commitments; is that correct?
10 DR. HISER: Within the context of license 11 renewal, I dont --
12 CHAIRMAN McDADE: Yes.
13 DR. HISER: -- believe we use that 14 terminology. We have -- applicants make commitments 15 that are -- would be incorporated in the UFSAR. And 16 those are the only commitments that are -- pertain to 17 license renewal.
18 CHAIRMAN McDADE: Okay. In this 19 particular instance weve got -- we have commitments 20 30, 41, 42, 43, 44 and 49. Which category do these 21 commitments fall in?
22 DR. HISER: Those would be under the 23 license renewal commitment that would be incorporated 24 in the UFSAR that once the license is -- renewed 25 license is issued for the plant, then that would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5753 1 become a part of the CLB for the plant.
2 So, each of those commitments would be 3 included within the discussion that we had several 4 questions ago.
5 CHAIRMAN McDADE: Okay. Now, some of 6 these commitments are ongoing, for example, such as 7 Commitment 30. And others are commitments that are 8 completed and then they can be closed; is that 9 correct?
10 DR. HISER: Yes, thats correct.
11 CHAIRMAN McDADE: Okay. Commitment 43 and 12 49, the technical analysis for IP3, is that complete?
13 DR. HISER: If I can just review records 14 for a moment?
15 CHAIRMAN McDADE: Okay. As I understand 16 it, there were two, you know, with regard to IP3.
17 Theres a question of it being complete with regard to 18 IP3. theres an indication that Entergy will close 19 the commitment for IP3 prior to the PEO. And Im just 20 trying to get what the status is as far as the 21 completion of the commitment with regard to IP3.
22 DR. HISER: If you could repeat the 23 commitment numbers.
24 CHAIRMAN McDADE: These have to do with 25 Commitments 43 and 49. I believe theyre addressed in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5754 1 the Entergy answer -- testimony -- well --
2 DR. HISER: That is my understanding. For 3 IP2, those are closed. For IP3, they are still open.
4 CHAIRMAN McDADE: Okay. And what does 5 that mean in this particular context that Entergy will 6 close the commitments? What still needs to be done in 7 order to close the commitments?
8 DR. HISER: What is needed -- actually, 9 closure may not be the correct work, but really 10 completion of the action thats specified in the 11 commitment is what would be necessary for the 12 applicant to be able to state that they had fulfilled 13 the commitment. So, whatever action is specified 14 would need to be completed.
15 CHAIRMAN McDADE: Okay.
16 JUDGE WARDWELL: While youre looking, may 17 I ask Entergy under your testimony, I think it was 18 Answer 113, Page 69 through 70, you state that the 19 limiting location reviews required by Commitments 43 20 and 49 have been completed for both IP2 and 3; is that 21 correct?
22 MR. AZEVEDO: This is Nelson Azevedo for 23 Entergy. That is correct, Your Honor.
24 JUDGE WARDWELL: So, in your position as 25 far as your position is concerned, what is left to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5755 1 done in regards to closing out 43 and 49?
2 MR. AZEVEDO: So, after we closed it for 3 Unit 2, theres still some calculations that need to 4 be completed. And those have been completed and 5 theyve been reviewed. Theyve been -- it was part of 6 the NRC onsite audit back, I believe, in August. So, 7 but those are complete.
8 JUDGE WARDWELL: Is there any reason why 9 those particular limiting locations werent identified 10 as part of your initial application rather than have 11 to be put off as a commitment? Because if we had run 12 our hearings at any reasonable amount of schedule, 13 they would still be outstanding.
14 MR. AZEVEDO: Well, you know, the only 15 thing Id say is these calculations are extensive 16 calculations and they took time and we just didnt 17 feel that we needed to complete the Unit 3 portion 18 when we completed the Unit 2 portion.
19 So, the Unit 3 portion was extended beyond 20 the Unit 2 portion. Thats why they were still open, 21 but again they were completed early this year and the 22 commitments are closed.
23 JUDGE WARDWELL: Okay. Thank you.
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5756 1 Commitment 30 you thought was open. I believe 2 Commitment 30 is complete.
3 CHAIRMAN McDADE: Well, Commitment 30 is 4 ongoing; is it not? It has continuing obligations.
5 Its been accepted by the NRC staff, and the NRC staff 6 has determined that it provides adequate assurance and 7 there are actions that need to be continually done 8 over the course of the period of extended operation in 9 the event the license is granted, correct?
10 MR. DOLANSKY: You are correct. We closed 11 it.
12 CHAIRMAN McDADE: Okay. And compliance 13 with Contention 30 then would be monitored, as you 14 indicated earlier, Dr. Hiser, under the FSAR and/or 15 the --
16 DR. HISER: Actually, I would say that 17 that item is completed. This is the original 18 commitment made in the original application regarding 19 the reactor vessel internals aging management.
20 With the submission of the AMP by the 21 applicant and the inspection plan, then that 22 effectively completed this commitment. So, we would 23 consider that to be complete.
24 CHAIRMAN McDADE: But the commitment also 25 includes then doing what is in the AMP that was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5757 1 submitted. You will monitor compliance. It envisions 2 various actions will be taken over the next 20 years.
3 DR. HISER: I guess the way that I would 4 interpret the commitment when it says evaluate and 5 implement the results, I think the development of the 6 AMP, the development of the inspection plan fulfilled 7 the commitment and implementation of the program 8 inspections, analyses, et cetera, is just a part of 9 implementation then of the AMP. So, I think from my 10 personal perspective, I would consider 30 to be 11 completed.
12 CHAIRMAN McDADE: Okay, but it is now part 13 of the FSAR, correct?
14 DR. HISER: It is a part of the FSAR that 15 would be identified as being completed. And this 16 happens many times. As we review applications and 17 applicants make commitments, sometimes theyre 18 completed before it becomes a part of the FSAR.
19 MR. COX: Judge McDade, Id like to 20 clarify that also. This is Alan Cox for Entergy. The 21 commitment was to submit the inspection plan and the 22 program. That was done.
23 That program has been incorporated into 24 the FSAR supplement. So, in that sense it will be an 25 ongoing commitment. Its now part of the FSAR thats NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5758 1 described there. Any changes to that will be done 2 under 5059. So, in essence, thats how that will be 3 controlled going forward.
4 MR. TURK: Your Honor, this is Sherwin 5 Turk.
6 CHAIRMAN McDADE:: Yes, Mr. Turk.
7 MR. TURK: Just as a point of information 8 if were looking at the SER supplement Number 2 where 9 there is a list of the commitments and the status as 10 of the time of the --
11 CHAIRMAN McDADE: Yes.
12 MR. TURK: -- SER 2 issuance, youll note 13 that theres a date of December 15 -- or December 12, 14 2015, for IP3. Thats the date that the Unit would --
15 the original license would expire and that would then 16 be going into the period of time to renewal until a 17 decision is made by the NRC as to whether license 18 renewal should be issued.
19 There were some recent correspondence from 20 Entergy that it might be worthwhile to note at this 21 point. Entergy, as you know, for Unit 2 sent in a 22 status report before Unit 2 entered the period of time 23 to renewal. And at that time they indicated that the 24 license commitments had been implemented for Unit 2.
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5759 1 regarding Unit 3. It may be that its important for 2 the witnesses to explain to you what has happened with 3 regard to Unit 3 so that you understand the status 4 currently.
5 CHAIRMAN McDADE: Okay. Thank you, Mr.
6 Turk.
7 Are you prepared to do that, Dr. Hiser, or 8 --
9 MR. TURK: Or perhaps the Entergy 10 witnesses could address that, Your Honor.
11 MR. STROSNIDER: this is Jack Strosnider 12 for Entergy and Im familiar with some of whats been 13 referred to. And I dont know that these are exhibits 14 on the docket, but in the case of Unit 2 as an example 15 what Entergy committed to do, two things.
16 One was to submit a letter to NRC 17 confirming complete implementation of Unit 2 license 18 renewal commitments required to be implemented prior 19 to entering the period of extended operation. And the 20 date for that to be completed was August 2013.
21 The second commitment was to modify the 22 Unit 2 updated Final Safety Analysis Report, 23 incorporate Unit 2 materials set forth in Appendix A 24 of the application, and develop a new appendix into 25 the Unit 2 FSAR, as well as updating correspondence NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5760 1 sections of the UFSAR with new or modified information 2 programs and transmit a letter to NRC confirming that 3 that had been completed. The completion date that was 4 established for that was September 28, 2013.
5 So, essentially this would confirm 6 completion of the commitments that were to be 7 completed before entering the period of extended 8 operation and to put into the updated FSAR those 9 commitments that will be ongoing throughout that 10 period of extended operation, which, as was noted, 11 would put them under the control of 5059.
12 Thats in an August 19, 2013 letter to --
13 actually, this is to Entergy from the NRC, but I think 14 what was being referred to is thats the general 15 philosophy of how this -- how these commitments are 16 managed in terms of being completed before entering 17 the period and what needs to be continued during the 18 period of operation -- extended operation.
19 MR. COX: This is Alan Cox again. Thats 20 correct and that was a description of what was agreed 21 upon for IP2. Similar actions are being done for IP3 22 prior to their PEO, which begins in December.
23 CHAIRMAN McDADE: Okay. Thank you, Mr.
24 Cox. Let me move on to Entergy. Can you explain what 25 peak editing under the WESTEMS system is, and explain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5761 1 why and how it is done, you know, perhaps specifically 2 addressing with regard to the pressure spray nozzle 3 evaluation for IP2?
4 MR. GRAY: This is Mark Gray for Entergy.
5 This is a technique that is employed in the analysis.
6 It basically when you do a fatigue analysis whether it 7 be with a computer program or manually, you have to 8 select the maximum and minimum stress states to form 9 your stress cycle pairs as dictated by the ASME code 10 in MB 3222.4(e)(5).
11 The way that you do that has developed 12 over the years. Different analysts use different 13 techniques. In the computer program that was used, 14 the program does an automated accounting for those 15 peaks and valleys, maxima and minima.
16 When it does that, there are two different 17 quantities of stress that are -- that have to be 18 employed because of their effect on the elastic 19 plastic penalty factor, as well as the total stresses 20 in the analysis.
21 So, the program since its an automated 22 approach, is developed as a tool for the engineer to 23 use. And in that regard, it will select more -- it 24 can potentially select more peaks and valleys than are 25 really needed for the evaluation.
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5762 1 In the practical application of the 2 program when those peaks and valleys are reviewed, the 3 analyst can then, if needed, identify those times that 4 are redundant with others.
5 Typical example. If the analyst defines 6 his transient for a heat-up, it goes from a stress-7 free condition to some stress state at the end of the 8 transient. For a cool-down, you do just the opposite.
9 So, the end of the heat-up, a stress 10 state, is the same as the beginning of the cool-down.
11 Well, the program doesnt know that those are really 12 the same state. It will select them both.
13 So, the analyst has the option of leaving 14 that conservatism in there and having more fatigue 15 pairs than really required and leaving that 16 conservatism and still have an acceptable answer, or 17 the analyst has the option to do a re-analysis with 18 those results eliminating the redundant stress states.
19 This is what we call peak editing. So, he removed 20 those states, re-analyzes and documents the final 21 result.
22 CHAIRMAN McDADE: Okay. In your pre-file 23 testimony, Dr. Lahey and Dr. Hopenfeld, you both 24 address the issue of peak editing and had criticisms 25 of it. In light of what Mr. Gray has just said, let NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5763 1 me ask Dr. Lahey first, then Dr. Hopenfeld, Can you 2 explain any continued concerns you have with the use 3 of peak editing?
4 DR. LAHEY: Your Honor, I dont recall 5 having expressed any concern about peak editing. I 6 understand the process. I think if its done by 7 experienced analysts, theres nothing wrong with it.
8 CHAIRMAN McDADE: Okay. Dr. Hopenfeld.
9 DR. HOPENFELD: I feel the same, except 10 one thing I do not understand, it was mentioned you 11 see the Fen if you look at the data, shows that 12 increases with the strain decreasing and its a 13 substantial change. So, what it says is really that 14 during transients, the length of the transients, the 15 strain may decrease.
16 Now, its not clear how that was accounted 17 or I couldnt tell without really going just from the 18 description was provided. Maybe it was okay, maybe 19 not, but I have no problem.
20 This is a standard procedure, and I 21 mentioned before the pagoda or the raindrop procedure 22 of how to put these things together and how to 23 identify and count the transients. That aspect of it 24 Im not worried.
25 I do -- there is a lot of judgement in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5764 1 there. And what I do worry about in some of the 2 expression I heard yesterday about that these things 3 are in the code, about the Fen and so forth, that 4 there -- if they rationalize that everything is in the 5 code, it doesnt -- they can come up with any number.
6 I have no way of -- to determine what 7 their uncertainties were, but the main thing is that 8 I was concerned is, oh, I didnt understand how do 9 they treat the effect of the Fen being increased with 10 strain decreased.
11 CHAIRMAN McDADE: Okay. Thank you, Dr.
12 Hopenfeld.
13 JUDGE WARDWELL: Just to make sure I 14 understand this also, Dr. Lahey, do you agree that the 15 term peak editing and user intervention are the 16 same in this particular -- certainly in regards to 17 Commitment -- I believe its 44.
18 DR. LAHEY: Its my understanding, Your 19 Honor, that the US NRC when they refer to user 20 intervention, theyre talking specifically about peak 21 editing. When I use that term, its more general.
22 It has to do with the injuring judgments 23 and other things the analysts can do to the code.
24 JUDGE WARDWELL: Okay. Thank you. And, 25 Entergy, is that your understanding also in regards to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5765 1 that for -- in regards to Commitment 44, the user 2 intervention, if that term is seen as the same as peak 3 editing?
4 MR. AZEVEDO: This is Nelson Azevedo, for 5 Entergy. Thats correct, Your Honor.
6 JUDGE WARDWELL: Thank you.
7 CHAIRMAN McDADE: With regard to 8 Commitment 41 for the steam generators, theres an 9 option either to redefine the pressure boundary, or to 10 inspect the tube-to-tubesheet welds.
11 There was a process for License Amendment 12 277 that has been completed. And with regard to the 13 other unit, it has not been.
14 Can you explain briefly the sort of 15 theoretical justification for taking the tube-to-16 tubesheet welds out of the definition of reactor 17 boundary, pressure boundary, Entergy?
18 MR. DOLANSKY: This is Bob Dolansky with 19 Entergy. First, just to clarify, that option is in 20 Commitment 42, not 41.
21 CHAIRMAN McDADE: Im sorry.
22 MR. DOLANSKY: So, thats called H star 23 analysis. So, when we talk about the H star analysis, 24 what that does is that takes the -- in very high level 25 -- Ill just give a high-level overview. You have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5766 1 tubesheet which is approximately 22 inches thick. And 2 the tubes are inserted into the tubesheet.
3 Theyre rolled into the tubesheet, which 4 means theyre pressed up against the hole in the 5 tubesheet. So, theres an interference fit. When 6 its manufactured, a little piece of the tube is left 7 at the bottom of the tubesheet. That piece of tube is 8 then welded to the tubesheet on the primary side.
9 That makes the tube-to-tubesheet weld.
10 So, what H star does is it takes -- it 11 does an analysis that shows that the -- under all 12 accident-required conditions under current licensing 13 basis loads and so forth, that no matter what happens 14 seismic, you know, LOCA loads, shock loads, whatever 15 you want to call it, that the tubes would not pull out 16 even if that weld were not there.
17 So, by doing that, they determine how much 18 of that tube you need inside the tubesheet to 19 withstand all the required forces. And thats called 20 your H star distance.
21 So, at IP2 we got the H star analysis 22 done. And that basically determined using round 23 numbers, approximately 19 inches from the top of the 24 secondary side of the tubesheet, you go down 19 25 inches, which leaves approximately three inches on the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5767 1 bottom, but you dont need that to maintain your 2 pressure boundary.
3 So, we redefined the pressure boundary 4 from the weld at -- on the primary side to 5 approximately three inches up inside the tubesheet.
6 MR. AZEVEDO: Your Honor, this is Nelson 7 Azevedo. Let me just add a little bit to what Mr.
8 Dolansky just said.
9 In addition to the structural component to 10 make sure the tube stays in place, the interference 11 fit between the tube and the tubesheet hole also make 12 sure that the leakage, if there is any leakage, is 13 within acceptable limits. So, the interference fit 14 theres two things; leakage, and provide the 15 structural integrity for the tube.
16 MR. DOLANSKY: Right. And thank you, 17 Nelson. This is Bob Dolansky again with Entergy. So, 18 effectively what weve done is weve said that the 19 bottom three inches of the tube could go away, could 20 totally be gone and we would meet for both leakage and 21 structural, we would meet all requirements under all 22 accident conditions.
23 CHAIRMAN McDADE: Okay. Now, with regard 24 to Indian Point 2 in September of 2014, there was a 25 license amendment that was granted by the NRC.
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5768 1 What is the current status with regard to 2 Indian Point 3? You had the two options. One was to 3 redefine the boundary. The other was to inspect the 4 tube-to-tubesheet welds.
5 Whats the current status?
6 MR. DOLANSKY: This is Bob Dolansky with 7 Entergy. Commitment 42 is very, very specific. It 8 was written in a very specific and clear way. So, 9 under Option 1 analysis, IPEC will perform an 10 analytical evaluation of the tube-to-tubesheet welds 11 in order to establish a technical basis for either 12 determining that the tubesheet cladding and welds are 13 not susceptible to PWSCC, or redefining the pressure 14 boundary in which the tube-to-tubesheet weld is no 15 longer included and, therefore, is not required for 16 the reactor coolant pressure boundary function.
17 So, that second part is what we did for 18 Unit 2. And the last sentence, the redefinition of 19 the reactor coolant pressure boundary must be approved 20 by the NRC is a license amendment request, thats what 21 we did with H star. We basically submitted that as a 22 license amendment request. The staff reviewed it and 23 approved it.
24 For IP3, our plan -- the plan for IP3 is 25 to do the first part of Option 1, which is to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5769 1 establish a technical basis for determining that the 2 tubesheet cladding and welds are not susceptible to 3 PWSCC. So, that -- when we do that, that would not 4 require the -- we dont have -- that would not be a 5 license amendment request.
6 So, we would plan to do -- to determine 7 that the tubesheet cladding welds at IP3 are not 8 susceptible to PWSCC, and thats how we plan to 9 address it for Unit 3.
10 CHAIRMAN McDADE: Okay, but the license 11 amendment is not in effect for Unit 3 at this time.
12 And the question is, at this time, youre indicating 13 that you are required to and will pursue the technical 14 justification for Option 1.
15 Where do we have reasonable assurance in 16 the IP3 license renewal application at this time that 17 we will -- that the tubesheet welds will continue to 18 maintain their intended function?
19 We dont have the license amendment and we 20 dont have the technical analysis completed at this 21 time. So, if were looking just at the IP3 22 application for license renewal, where does the 23 reasonable assurance come from?
24 MR. DOLANSKY: This is Bob Dolansky with 25 Entergy. I believe our steam generator program NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5770 1 provides the reasonable assurance that the steam 2 generators are maintained in a manner that they can 3 perform their required safety function.
4 CHAIRMAN McDADE: Okay, but we had a 5 situation where as part of the license renewal the 6 staff addressed questions to Entergy. And in 7 response, Entergy suggested that they would do one of 8 two things in order to answer the staffs concern in 9 this regard. That they could either, as you did, 10 apply for a license amendment establishing that this 11 is not part of the pressure boundary and, therefore, 12 does not present a safety issue, or provide the 13 technical, you know, justification with regard to the 14 tube-to-tubesheet welds.
15 Let me move -- Dr. Hiser, can you be of 16 assistance on this?
17 DR. HISER: Yeah, I think -- this is Allen 18 Hiser of the staff. I think if we looked at 54.29 19 where it requires renewed license -- and Ill try to 20 cut out a lot of the words -- renewed license may be 21 issued if the Commission finds that actions have been 22 identified and have been or will be taken with respect 23 to managing the effects of aging with the 24 implementation of this commitment and the 25 implementation of that commitment within the UFSAR NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5771 1 that then is controlled by 50.59 and through NRC 2 inspections -- well, let me backup.
3 The imposition of the commitment and it 4 being incorporated in the UFSAR is sufficient to 5 provide the staff with reasonable assurance consistent 6 with 54.29.
7 CHAIRMAN McDADE: And I guess where Im 8 hung up on, Dr. Hiser, is this: The concept provide 9 technical justification, it sort of assumes that once 10 you do the analysis, you may or may not be able to 11 technically justify it.
12 If you havent done the analysis yet, you 13 can assume based on general knowledge that you will be 14 able to do it. But it seems that the Agency was 15 asking for Entergy to provide this technical 16 justification and you havent yet received that 17 technical justification.
18 I mean, isnt it conceivable that the 19 technical justification simply cant be provided?
20 DR. HISER: Well, the commitment has two 21 pieces to it; Option 1, Option 2.
22 CHAIRMAN McDADE: Yes.
23 DR. HISER: If the applicant is unable to 24 complete Option 1, whatever NRC approval is necessary, 25 then Option 2 would become operative and they would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5772 1 required to do the inspection consistent with the 2 completion date for that commitment.
3 So, if the analysis is not necessary right 4 now, it would be necessary that they demonstrate that 5 they meet Option 1, or perform the inspections that 6 are covered by Option 2.
7 CHAIRMAN McDADE: Okay. So, that brings 8 us to the next question. We have the technical, I 9 mean, the -- there are actually multiple options. One 10 was changing, you know, the license amendment which 11 they did for IP3, the technical justification or the 12 inspections. So, lets get down to the inspections 13 themselves and whether or not the inspections are 14 capable of providing the reasonable insurance.
15 Dr. Duquette, you had issues with regard 16 to the adequacy and the nature of the inspections and 17 can you elaborate on that?
18 DR. DUQUETTE: Duquette, New York State.
19 Yes, I am very positive about wanting to see a 20 physical inspection of whats going on in the system.
21 Everything Ive seen indicates that there arent any 22 analyses that are available at least at the present 23 time, or anything in the system that would make me 24 feel comfortable with any kind of a paper analysis 25 that would make me feel comfortable that you couldnt NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5773 1 get stress corrosion cracking in the tube-to-tubesheet 2 welds.
3 And so, I think the Option 2, which is the 4 inspection, is the only one that makes any sense.
5 CHAIRMAN McDADE: Well, at this point, you 6 know, one of the things that you raises is saying that 7 there was not an adequate inspection technique.
8 Entergy proposed to use and identify EVT1 as the 9 inspection technique that they would use.
10 What criticisms do you have? Why would 11 you think that EVT1 would not be adequate to 12 accomplish that function?
13 DR. DUQUETTE: I thought I -- in my 14 testimony, Id have to go back and review it, but that 15 there was no industry-accepted technique at the 16 present time. I dont think I meant there was no 17 adequate technique to do that inspection.
18 I think that there are physical methods to 19 do the inspection. Today its being done in other --
20 in foreign steam generators, to my understanding. And 21 so, I think there are techniques that could -- that 22 can be used.
23 I didnt see in anything that was 24 presented to me where Entergy or the NRC had indicated 25 any specific technique, except for a statement that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5774 1 there are techniques that are available. I agree with 2 that, but I would like to see what technique that they 3 are going to use.
4 CHAIRMAN McDADE: Okay. Well, I believe 5 in the testimony Entergy indicated that it would be 6 EVT1. Am I correct there?
7 MR. DOLANSKY: Yes, you are correct. Our 8 plan is to do an EVT1.
9 CHAIRMAN McDADE: Okay. And are you 10 familiar with that inspection technique, Dr. Duquette?
11 DR. DUQUETTE: I dont think I am.
12 CHAIRMAN McDADE: Okay. Mr. Dolansky, Can 13 you briefly explain? I know we had it the other day.
14 We had some detailed discussion of EVT1, but could you 15 just sort of briefly explain the method?
16 MR. DOLANSKY: Yes. EVT -- this is Bob 17 Dolansky with Entergy. Again, just to start at the 18 same point, in Contention 25 we went in some detail 19 about performing an EVT1 to inspect for stress 20 corrosion cracking.
21 So, I think its -- I would say that its 22 understood through the industry that thats an 23 acceptable method, but an EVT1 is a very detailed, 24 close-up, visual examination. It uses a character 25 card.
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5775 1 When you calibrate the EVT1, you have to 2 do a character card. I believe its 0.044-inch height 3 with open case letters such as an O or a C or an E, 4 not something with like a P or a Q that has a tail 5 that would make it a little easier to see.
6 You have to be within a certain distance.
7 Off the top of my head, I dont remember all the 8 details. You have to be within a certain distance and 9 theres a certain scan speed that you have to 10 maintain. And its -- basically an EVT1 is an 11 accepted approach to look for cracking.
12 Does that answer the -- I think thats 13 relatively high level. If anybody else remembers or 14 wants to add anything --
15 CHAIRMAN McDADE: No, I think that should 16 be sufficient. Based on what Mr. Dolansky just said, 17 Dr. Duquette, its my understanding that the purpose 18 of the inspection is to detect cracking.
19 Is there any reason to believe that that 20 method would not be sufficient to detect cracking?
21 DR. DUQUETTE: No, I think it would be --
22 it would detect cracking. And as I indicated, I 23 think, a few minutes ago, I would feel far more 24 comfortable with a physical inspection, which is what 25 that technique implies and probably would work just NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5776 1 fine.
2 CHAIRMAN McDADE: Okay. Now, with regard 3 to once -- and I shouldnt say once, rather if 4 cracking is detected, there is specific actions to be 5 taken, correct?
6 MR. DOLANSKY: Any cracking that were 7 detected would be put into our corrective action 8 program, absolutely, yes.
9 DR. DUQUETTE: Im sorry, I didnt hear 10 the answer.
11 MR. DOLANSKY: This is Bob Dolansky with 12 Entergy.
13 DR. DUQUETTE: Duquette, I didnt hear the 14 answer to that.
15 MR. DOLANSKY: If any cracking were 16 detected, it would be put into the Entergy corrective 17 action program just like we do in Section 11 or vessel 18 internals, you know, New York State 25.
19 We go out and perform inspections on an 20 EVT1. If we found anything, it would be put into our 21 corrective action program.
22 CHAIRMAN McDADE: Okay. And that -- and 23 I believe theres reference to SPR-LR Revision 2, 24 which is New York State 161, that the corrective 25 actions would need to be consistent with that; am I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5777 1 correct?
2 MR. DOLANSKY: I dont know the SPR.
3 Could we bring that up and I could look at it? Im 4 not sure what --
5 CHAIRMAN McDADE: New York 161.
6 (Pause.)
7 MR. COX: Your Honor, this is Alan Cox for 8 Entergy.
9 CHAIRMAN McDADE: Yes.
10 MR. COX: The Standard Review Plan for 11 license renewal is what youve called up here. And, 12 again, thats the NRCs guide for reviewing license 13 renewal applications.
14 There are discussions in there about the 15 corrective action program. Im not sure if thats 16 what youre referring to, but it is the same 17 corrective action program that Mr. Dolansky referred 18 to in saying that the inspection results would be 19 entered into that program and evaluated under that 20 program.
21 CHAIRMAN McDADE: And I guess my question 22 was that that corrective action program of necessity 23 needs to be consistent with the provisions of SPR-LR 24 Revision 2. And specifically 8.1-6 to 8.1-7.
25 Dr. Hiser, is that correct?
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5778 1 DR. HISER: Yes, thats correct.
2 CHAIRMAN McDADE: Okay. Let me go on to 3 something else. Talking about the -- weve got the 4 tube-to-tubesheet welds. Were also talking about the 5 divider plate.
6 Can you explain very briefly what the 7 divider plate is?
8 MR. DOLANSKY: This is Bob Dolansky with 9 Entergy. Can we go to the Entergy pre-file testimony?
10 Ill give you the page.
11 CHAIRMAN McDADE: I believe maybe Answer 12 130 you discuss it briefly.
13 MR. DOLANSKY: Yes, sir.
14 MR. COX: Thats Entergy 698 would be the 15 exhibit number.
16 MR. DOLANSKY: Well start on Page 81 and 17 then go to Page 84. So, if we can pull up Page 81 --
18 CHAIRMAN McDADE: Yeah, Im not looking to 19 have you go through the entire several pages. Just 20 very briefly what is the divider plate?
21 MR. DOLANSKY: Okay. Basically -- this is 22 Bob Dolansky with Entergy. When reactor coolant comes 23 in from the reactor, its -- the hottest comes from 24 the reactor, goes through the steam generator at the 25 large U-tube -- through the tubes, which are large U-NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5779 1 tubes.
2 Comes in whats called the hot leg, the 3 channel head, goes up through the tube. As its going 4 through the tube, it transfers the heat to the 5 secondary feedwater and then it goes out the cold leg 6 side of the steam generator.
7 So, hot water comes in the channel head, 8 goes through the tube and comes out on the cold side.
9 Theres a divider plate in the middle that just keeps 10 those two sides separate in the channel head.
11 CHAIRMAN McDADE: Okay. And its not part 12 of the coolant system pressure boundary, is it?
13 MR. DOLANSKY: That is correct. And, in 14 fact, at IP3 theres a little thing called a mouse 15 hole. Theres actually a hole in the bottom of the 16 divider plate to allow some -- when we shut down and 17 drain, it allows water to communicate between both 18 sides.
19 CHAIRMAN McDADE: And why -- what is it 20 made out of?
21 MR. DOLANSKY: Its made out of --
22 CHAIRMAN McDADE: Is it Alloy 600 or Alloy 23 690 or --
24 MR. DOLANSKY: We have it in our 25 testimony. I just have to find it. Give me one NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5780 1 moment, please, Your Honor.
2 CHAIRMAN McDADE: Well, let me follow. Is 3 it a material thats particularly susceptible to 4 cracking?
5 MR. DOLANSKY: Yes, its a material that 6 is susceptible to PWSCC. Yes, Your Honor. Bob 7 Dolansky with Entergy.
8 CHAIRMAN McDADE: Okay. And what are the 9 implications of cracking in the divider plate?
10 MR. DOLANSKY: Um --
11 CHAIRMAN McDADE: You indicated that its 12 not part of the pressure boundary and there actually 13 is in it, you know, designed a hole.
14 If there is a crack in the divider plate, 15 what consequence is that to the operation of the 16 reactor -- in the steam generator, rather?
17 MR. AZEVEDO: Your Honor, this is Nelson 18 Azevedo. Maybe I can start and some of my colleagues 19 can jump in.
20 It depends if the crack is big enough, it 21 could allow coolant to bypass the tubes themselves.
22 So, the water will come in through the hot leg side 23 and go out the cold leg side without going through the 24 tubes.
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5781 1 accident, you wouldnt be able to remove heat from the 2 primary side. If the divider plate was gone, then the 3 water just bypassed the tubes. So, you lose that 4 ability.
5 CHAIRMAN McDADE: Okay. So, although it 6 does not -- it is not part of the pressure boundary, 7 it, nevertheless, plays a significant safety function.
8 MR. AZEVEDO: It plays a function. Im 9 not sure if its a significant safety function.
10 Again, maybe somebody can jump in.
11 MR. STROSNIDER: This is Jack Strosnider 12 for Entergy. So, I dont have the reference right at 13 hand, but the Electric Power Research Institute 14 actually has evaluated that condition.
15 They postulated a large thru-wall crack in 16 the divider plate, which would allow this 17 communication between the hot leg -- between the hot 18 side of the channel head and the cold side.
19 And they looked at that from an accident 20 perspective and concluded that it would not -- that 21 you could still meet all the design basis accident 22 conditions that you could -- that you could manage 23 those appropriately even with a large crack in that 24 component.
25 CHAIRMAN McDADE: Thank you. Dr.
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5782 1 Hopenfeld.
2 DR. HOPENFELD: Yes. With regard to the 3 plant, the plate may not play a very -- as EPRI said, 4 it may not play a very important role. It doesnt 5 have an important role in the design basis accident.
6 However, there is a certain sequence of events, 7 especially a station -- after a station -- for a 8 station blackout.
9 You get into a situation thats called 10 high and dry. And you get into the severe accident, 11 but I dont want to get in too far. What happens 12 there, we depend on cooling the core by natural 13 circulation.
14 If that plate is not there, which is not 15 going to be there especially if the hole is very big 16 or the whole thing is gone, so you would have all the 17 coolant bypassing the tubes up and you are not going 18 to be removing the heat from the core. So, there is 19 a concern, but its during severe accidents.
20 However, we have spent -- or Westinghouse 21 spent huge amount of money. This is not a trivial 22 case even though its a severe accident, and we have 23 spent huge amount of studying on this. And all those 24 studies are -- rely on 1/7th scale tests that were 25 done at Westinghouse somewhere in the 70s.
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5783 1 There have been I dont know how many 2 studies and reviews over that. So, all the 3 information we have is based on those studies where 4 the plate was there.
5 Now, they remove the plate. So, what you 6 have done something to the plate. Basically what I 7 mean, its being removed because its not functioning 8 anymore. Now, youve done something that you affect 9 the consequence of whats going to happen during 10 severe accidents.
11 Now, I dont know what the legalities are.
12 But if I remember correctly, there are some things --
13 if you do something to the plant that affects the 14 severe accident, you have to explain it. Now, what 15 EPRI has done, it just didnt carry it far enough.
16 What they have done is okay for normal 17 operation, just small break LOCAs, but its not 18 correct, due to a -- or a situation where you get into 19 the natural circulation.
20 Mr. Strosnider knows exactly what Im 21 talking about, because we discussed EPRI over the 22 years.
23 MR. STROSNIDER: Your Honor.
24 CHAIRMAN McDADE: Just before you --
25 MR. STROSNIDER: Im sorry.
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5784 1 CHAIRMAN McDADE: Dr. Lahey.
2 DR. LAHEY: Richard Lahey, New York. I 3 also reviewed the EPRI report and --
4 JUDGE WARDWELL: Excuse me. Is this the 5 2014 report I saw references to in this commitment 6 testimony -- or really it was a statement of position 7 by Entergy.
8 DR. LAHEY: I have to look back at --
9 MR. ONEILL: Your Honor, this is Mr.
10 ONeill for Entergy. Before we delve any further into 11 the details of the EPRI report, I think the witnesses 12 are referring to the October 2014 EPRI report thats 13 New York State exhibit NYSR0544A through D. I just 14 want to remind the Board and the parties that that is 15 a proprietary document.
16 JUDGE WARDWELL: And, Mr. Strosnider, is 17 that your belief, the report you were referring to?
18 MR. STROSNIDER: Jack Strosnider for 19 Entergy. Yes, I do believe that is the report.
20 DR. LAHEY: So, since its proprietary, 21 does that mean I cant discuss it or --
22 CHAIRMAN McDADE: Right now, I mean, as 23 far as the details go. Discuss what your concerns 24 are.
25 DR. LAHEY: All right. My concerns are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5785 1 always focused on the safety significance. They did 2 an analysis of a thru crack and came up with a flow 3 area, which was relatively small in terms of flow 4 bypass from one side to the other through the plate.
5 However, when they looked at the accident, 6 the largest load that you could put on it, it appeared 7 that what they did is took the high pressure on one 8 side and atmospheric pressure on the other, which is 9 what you would get instantaneously with a loss of 10 coolant accident, and then concluded it could 11 withstand that.
12 It was not at all clear that they did it 13 as an impulsive load. In fact, it appears they did it 14 as a static load. And from my previous testimony, you 15 know, theres a huge difference between hitting 16 something with a sledgehammer and pushing your hand 17 against it with the same force.
18 So, its not at all clear to me that they 19 cant break out the welds and blow out the plate 20 completely. Its a fairly thick plate. Its a couple 21 inches thick. And so, the analysis needs to be done.
22 I asked about it at my testimony. The 23 response I got back was not much. I mean, it did not 24 clarify that issue, in my mind, but I -- the safety 25 significance of it if you lose that plate or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5786 1 significantly create a bypass between one side of the 2 lower plenum of the steam generator and the other, you 3 no longer can use that generator to steam off to 4 remove energy.
5 So, if at the same time -- if the event 6 which causes all this would be a seismic event, for 7 example, and you lose offsite power and then you lose 8 your steaming capability of a steam generator, you 9 have a big problem. You really need the steam 10 generators to allow for the ability of the operators 11 to bring in water separately to cool the core.
12 CHAIRMAN McDADE: Okay. Is it this sort 13 of synthesis of your opinion that it is ill-advised 14 for Entergy to rely on the EPRI report?
15 DR. LAHEY: If my understanding of the 16 EPRI report is incorrect and they have actually done 17 a shock analysis and they have concluded based on 18 those impulsive loads that it can withstand it, then 19 Im okay, but I dont see that.
20 I mean, we talked about the analysis 21 yesterday, I think it was, which had to do with the 22 shock loads on the bolts. The baffle former bolts.
23 And those were not the biggest shock loads you can get 24 by far, because of the way they did it.
25 So, its a question what did they really NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5787 1 do? And even though we have raised that in our 2 previous testimony, there has really been no response.
3 So, as far as Im concerned, you cant really rely on 4 it until you know in detail what was done, what code 5 was used, what break time was used, how strong it was.
6 Is it the maximum strength, or not?
7 MR. STROSNIDER: Your Honor, Jack 8 Strosnider for Entergy.
9 CHAIRMAN McDADE: Yes.
10 MR. STROSNIDER: Two comments that Im 11 comfortable I can make without getting into 12 proprietary aspects of this. The first is with regard 13 to Dr. Hopenfelds discussion about severe accidents, 14 Ill point out severe accidents are also known as 15 beyond-design basis accidents, meaning that they are 16 not part of the current licensing basis. They are 17 used in probabilistic risk assessments that go beyond 18 the current licensing basis and beyond the design 19 basis accidents that need to be analyzed under Part 54 20 under license renewal. So, theyre really not within 21 the scope of this discussion.
22 With regard to the EPRI analysis, the one 23 thing I would point out is that that analysis was done 24 using the design basis loads. And I think I can say 25 that with, you know, thats pretty well known.
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5788 1 And, you know, that document is available 2 for review. And if Dr. Lahey has specific comments on 3 the analysis, which is available for him to look at, 4 then we would want to hear those specific comments, 5 but, you know, big picture they analyzed the design 6 basis accidents in that evaluation. And thats what 7 is, you know, required under Part 54 for license 8 renewals is to maintain that design basis. So, thats 9 what they did all of this, Your Honor, in the interest 10 of safety.
11 CHAIRMAN McDADE: Okay. Thank you. Dr.
12 Lahey.
13 DR. LAHEY: Yeah, I -- certainly I did 14 review this document. I have expressed this concern.
15 I have gotten no feedback on what was actually done.
16 And as you know, it -- when you say you did a design 17 basis accident, it matters a lot what sort of 18 technique you used for it.
19 If you used a code which is a large-volume 20 standard loss of coolant accident code, you certainly 21 do not get the kind of impulsive loads that will 22 really occur.
23 If you use a separate code like the 24 Westinghouse code we talked about yesterday and you 25 apply the right break size and the right break opening NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5789 1 time, you can get that resolved.
2 No details were given. In fact, it looked 3 from reading the report, like it was sort of a static 4 load or a quasi-static load.
5 MR. LOTT: Your Honor, this is Randy Lott 6 for Entergy. I believe that the study that Dr. Lahey 7 is referring to is whats called the EPRI Phase 2 8 repot, which, again, I believe is Entergy 523.
9 Im trying -- Im struggling to say, I 10 mean, Im familiar with the report in some -- to some 11 extent and clearly it was taken, first of all, to 12 evaluate the purely hypothetical case of a complete 13 severing of the weld at the top of the -- between the 14 tubesheet and the divider plate.
15 Theres other testimony that we filed that 16 indicates that, A, this is a highly improbable 17 circumstance and that we do not predict that a 18 complete cracking of this would grow along that 19 interface.
20 Then as was suggested, it was looked at 21 what the effect of opening that gap would be on the 22 leakage through the divider plate, and found that that 23 was acceptable in all cases.
24 The people that do that study also did 25 consider LOCA forces on the failed -- the divider NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5790 1 plate with the failed weld. And what they determined 2 was that the failure itself actually made the stresses 3 on the -- that would be afforded from the LOCA 4 analysis when it was done, would reduce them due to a 5 smaller Delta-P across the plate and also due to 6 increased flexibility in the system.
7 So, when they looked at the analysis, they 8 said we do not need to redo the current licensing 9 basis analysis, because what weve already done in the 10 current license base remains the controlling 11 condition, the limiting condition.
12 So, therefore, as Dr. Lahey -- as weve 13 just demonstrated in our previous testimony on the 14 baffle bolts of other, we certainly understand the way 15 that these LOCA forces are applied in these 16 conditions. And the study simply concluded that there 17 was no need to go through that entire process.
18 Again, it was just a purely hypothetical 19 study in the first place, because we think that the 20 failure of this weld is highly unlikely. And Ill 21 also suggest that this is a massive structure and its 22 not going to simply disappear. And theres no 23 evidence that it will simply disappear. So, theres 24 no -- hardly any place for it to go.
25 MR. DOLANSKY: This is Bob --
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5791 1 CHAIRMAN McDADE: Okay. Thank you, Dr.
2 Lott.
3 MR. STROSNIDER: Jack Strosnider from 4 Entergy. Just to add one more --
5 CHAIRMAN McDADE: Before you --
6 MR. STROSNIDER: Sorry.
7 CHAIRMAN McDADE: Mr. Dolansky first.
8 MR. DOLANSKY: Yes. Thank you, Judge.
9 this is Bob Dolansky with Entergy. I just want to 10 kind of take a step back. Were starting to talk 11 about the loads and all that stuff.
12 EPRI report has many, you know, contains 13 a lot of information. To me, the really important 14 part of the EPRI report is that theyve looked at the 15 possibility of this cracking occurring and said it 16 cant.
17 This issue was originally driven from 18 foreign operating experience. French plants had 19 cracking. They saw the cracking. They did 20 significant amount of work, research and destructive 21 testing on these components after they were removed.
22 Additionally, EPRI did a lot of work to --
23 and the result of that work is that this is not a 24 concern. The cracking is not a concern. We can, you 25 know, go further down and discuss the, you know, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5792 1 evaluations on whether it will fail or not and all 2 that stuff, but to me the real crux of the matter is, 3 and what New York State 544A really talks about is 4 that this is not a concern, because this isnt going 5 to happen.
6 And what we thought was happening in 7 France when the issue was first raised, the more 8 research we did and the more destructive testing they 9 actually did on some of the steam generators that had 10 this that they took out of service and actually 11 destructively removed the metal and did the testing, 12 it turned out that there was no cracking going through 13 the wall. It was just in a very shallow, cold work 14 surface. So, to me, thats the whole issue.
15 And as a slight aside, I just -- Dr. Lahey 16 says that hes concerned about safety and I understand 17 that. And I just want to put it on the record that 18 Im very concerned about safety, too. I work at that 19 plant every day.
20 CHAIRMAN McDADE: Okay. I think thats --
21 MR. DOLANSKY: I care about safety a great 22 deal. And to imply that hes worried about it because 23 of safety, and Im not worried about safety, thats 24 not the case. I care about safety as much as anybody 25 else and I want to make sure that we do the safe thing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5793 1 at the plant.
2 CHAIRMAN McDADE: Okay. I certainly nave 3 not interpreted the testimony of Dr. Lahey in any way 4 as questioning the commitment to safety on the part of 5 Entergy as a company or on the witnesses who have 6 presented testimony on behalf of Entergy. The 7 question just simply is interpreting the data, whether 8 or not the data supports the thesis that you have.
9 And in this regard, and I think it was 10 clear from the record and I didnt ask a lot of 11 questions about it, of what Entergy views as the 12 significance of that report.
13 And what I wanted to just make sure I 14 understood is why Dr. Lahey believed that reliance on 15 that report is, in his view, not warranted, as I 16 understand it, based on a lack of data in the report 17 with regard to the shock loads that were present and 18 the -- some of the methods that were used; is that 19 correct, Dr. Lahey?
20 DR. LAHEY: Yeah. I, you know, all these 21 comments are things you can see in the report. That 22 doesnt really answer my primary concern. What Im 23 interested in is when they say it can survive LOCA 24 loads.
25 How did they get those LOCA loads? If you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5794 1 dont do it right, you can say you ran a LOCA, but the 2 pressure difference versus time is not impulsive, you 3 know. Its a different sort of loading of the plate.
4 And a two-inch plate with secure welds should handle 5 that very nice.
6 If you do a shock load, however, thats 7 what remains to be done. And if -- then if the welds 8 are weakened by stress corrosion cracking and things 9 of this nature, thats an additional thing that needs 10 to be studied.
11 I havent seen that data. So, until I see 12 that data, I cant be really comfortable that thats 13 been done.
14 CHAIRMAN McDADE: Okay. Do you have any 15 follow-up on this?
16 JUDGE WARDWELL: Not really.
17 MR. STROSNIDER: This is Jack Strosnider 18 for Entergy. The one other comment I wanted to make 19 earlier very briefly is when you talk about the 20 hypothetical problem that Dr. Lott described in terms 21 of the size of crack that was evaluated, that crack 22 would be easily visible for anybody doing any kind of 23 work in the channel head. It wouldnt require any of 24 these advanced methods. Its a very, very large 25 crack.
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5795 1 So, just to reemphasize, very unlikely 2 its going to happen in the first place. If a crack 3 did form, it would be seen during inspections well 4 before it got to the size thats been evaluated. So, 5 I just wanted to give that practical perspective on 6 this.
7 CHAIRMAN McDADE: Okay. Thank you. Id 8 like to move on to some issues with regard to the 9 timing of the inspections with regard to Indian Point 10 2 within ten years of the PEO, with Indian Point 3 at 11 the first refueling outage. These generators were put 12 into service, Indian Point 2 in 2000, Indian Point 3 13 in 1989.
14 So, these steam generators will be in 15 place for a significant period of time prior to the 16 beginning of the period of extended operation for 17 Indian Point 3 and already the period of extended 18 operation for Indian Point 2.
19 How is it determined that these would be 20 appropriate times for the inspection? I believe Dr.
21 Duquette suggests that, you know, it would be good 22 engineering practice or necessary engineering practice 23 to have a baseline inspection prior to the start of 24 the period of extended operation, you know.
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5796 1 and significantly into the life of the steam 2 generators. How are these periods for inspection 3 arrived at and whats the basis behind them?
4 MR. AZEVEDO: Your Honor, this is Nelson 5 Azevedo for Entergy. Let me just start by saying that 6 these locations, excuse me, are inspected every time 7 we go into the primary side. Thats every other 8 refueling outage there is a visual inspection.
9 Its not the EVT1, its not the detailed 10 visual inspection that were talking about, but they 11 are visually inspected. So, if there were gross 12 issues going on, those would be picked up.
13 As far as the EVT1 and the schedule of 14 that inspection, that was really based on the work 15 that the French have done and the EPRI have done that 16 basically concluded this is not an issue, you know.
17 These are flaws that are very shallow, have no --
18 essentially no structural impact, and they pose no 19 safety significance. So, thats why that time frame 20 was chosen.
21 CHAIRMAN McDADE: Mr. Cox.
22 MR. COX: Yeah, one other factor. This is 23 Alan Cox for Entergy. The operating experience in the 24 industry for this type of material under these 25 temperatures and operating condition shows that it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5797 1 takes a number of years for this to develop.
2 If you inspected a steam generator after 3 20 years of operation, just based on the industry 4 experience with this you would not expect to see any 5 kind of -- you would not expect that time frame to 6 have been long enough to develop stress corrosion, 7 cracking.
8 CHAIRMAN McDADE: Okay. What are the 9 lifespans of these generators, the anticipated 10 lifespan of the generators?
11 For example, Indian Point 2 went into 12 service in 2000.
13 MR. AZEVEDO: This is Nelson Azevedo for 14 Entergy. Is the, you know, for 60 years, if I 15 understand your question correctly. These generators 16 are anticipated to be good for the remainder of the 17 life of the plant.
18 CHAIRMAN McDADE: Okay. And for Indian 19 Point 2 -- Three, rather, that went into service in 20 1989, likewise you would anticipate that that 21 generator would be used for the full period of 22 extended operation.
23 MR. AZEVEDO: That is correct, Your Honor.
24 MR. DOLANSKY: Id just like to add that 25 Im the program owner for the steam generators. We go NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5798 1 into those steam generators, as Mr. -- this is Bob 2 Dolansky for Entergy -- every other outage, 3 effectively, every four years. And both generators --
4 all four generators at both units, both the tubing and 5 the tube-to-tubesheet, you know, the channel head, and 6 the secondary side, we do inspections on all those 7 areas and they are all in very, very good shape. We 8 see no problem with them reaching the end of the 9 period of extended operation.
10 CHAIRMAN McDADE: Okay. The IP2 steam 11 generator was replaced in 2000. What, if any, 12 relevance do the reasons of why that was replaced have 13 to what were considering now?
14 MR. DOLANSKY: I think the relevance is 15 that both the IP3 and IP2 steam generators were 16 replaced because of the tube material that they had.
17 The tube material was degrading. And that was mill-18 annealed Alloy 600. Both steam generators were 19 significantly upgraded.
20 Unit 2, IP2, has thermally-treated Alloy 21 600, which is a very good material. And Unit 3, even 22 though its older, it has thermally-treated Alloy 690.
23 And thats really -- I would say thats the best 24 material for steam generator tubes. So, the 25 significant upgrade in tube material after they were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5799 1 replaced is the reason.
2 CHAIRMAN McDADE: Okay. And can you 3 exp0lain just very briefly what is the difference 4 between mill-annealed tubing and the thermal-treated?
5 MR. GORDON: Your Honor, this is Barry 6 Gordon for Entergy. Mill-annealed was the original 7 type of heat treatment to -- for Alloy 600. It was a 8 wide range of temperatures and each mill essentially 9 did it different ways and it didnt have an optimized 10 microstructure as the thermally-treated tubes are.
11 Thermally-treated ones also have a 12 subsequent heat treatment at a lower temperature that 13 diffuses it. What you want to do in Alloy 600 is have 14 chromium carbides on the grain boundaries. And with 15 thermally-treated Alloy 600 has is a subsequent heat 16 treatment at various temperatures and times that will 17 produce a more uniform, homogenous, distribution of 18 chromium around the grain boundary. So, its not 19 quite as depleted.
20 And the results, the testing results of 21 the actual operating experience with this material has 22 been outstanding, actually.
23 CHAIRMAN McDADE: With both the 600 TT and 24 the 690 --
25 MR. GORDON: Well, 690 is --- has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5800 1 absolutely a perfect record. There is no --- well, 2 since first introduced in the field, there has been 3 absolutely no operating experience degradation of 4 Alloy 690 with higher chromium.
5 CHAIRMAN McDADE: Okay. Weve had 6 significant testimony about the experience with the 7 French reactors and their steam generators.
8 Do we know what the material was that 9 these -- that experienced the observable cracking 10 there? Was it mill-annealed, or was it the 600 or 690 11 TT?
12 MR. GORDON: It was mill-annealed Alloy 13 600 by and large.
14 DR. DUQUETTE: Duquette, New York. Just 15 to clarify the record a little bit, Im not sure if 16 theres some confusion here, perhaps not, but the 17 divider plate, which is where the cracking has been 18 observed, is, as far as I know, always mill-annealed 19 600 in both the French reactors and the reactors at 20 Indian Point.
21 690 versus 600 is the tube material. And 22 I dont think at the present time the tube material 23 except when we talked about the tube-to-tubesheet 24 welds, I dont think the tube material is an issue 25 right at the moment.
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5801 1 And so, if we back off to what the divider 2 plate cracking is and what the French experience is, 3 that was an Alloy 600, not 690. To my knowledge, the 4 French havent seen any cracking in their 690 either.
5 And so, those are two different issues.
6 I dont know if its appropriate now or 7 not if the Board wants to entertain it, but there were 8 several comments by Entergy about the French 9 experience that perhaps this is the time to share and 10 --
11 CHAIRMAN McDADE: Well, let me just ask 12 one thing before we get to that, Dr. Duquette.
13 DR. DUQUETTE: Of course.
14 CHAIRMAN McDADE: And in the testimony 15 that was provided by Entergy when you discuss the 16 divider plates, you indicated that they were made of 17 Alloy 600 both at -- and I believe both at the IP2 and 18 IP3; is that correct?
19 MR. DOLANSKY: Yes.
20 CHAIRMAN McDADE: And was this the 600 TT, 21 or the mill-annealed 600; do you know? I dont 22 believe its specified in the testimony.
23 MR. GORDON: This is Barry Gordon from 24 Entergy. I would assume its -- I think they assume 25 its the mill-annealed Alloy 600. The more NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5802 1 susceptible material.
2 CHAIRMAN McDADE: Okay.
3 MR. DOLANSKY: To go to what Dr. Duquette 4 said really when were talking about mill-annealed and 5 thermally-treated, were talking about the tubes, not 6 so much the divider plates. And the tube -- what --
7 the tube material really comes into the discussion 8 when were talking about the tube-to-tubesheet weld.
9 CHAIRMAN McDADE: Okay. Thank you. Dr.
10 Duquette.
11 DR. DUQUETTE: I think I agree with that.
12 I think thats what I said. Until we --
13 CHAIRMAN McDADE: Okay. Dr. Duquette --
14 DR. DUQUETTE: -- talk about the tube-to-15 tubesheet weld --
16 CHAIRMAN McDADE: Excuse me. Dr. Duquette 17 --
18 DR. DUQUETTE: -- the tubes are not --
19 CHAIRMAN McDADE: Okay. When youre 20 talking, youre talking to us. Were not having the 21 witnesses talk back and forth to each other. Its 22 sort of, you know, in follow-up well talk to the 23 other potential witnesses.
24 DR. DUQUETTE: I apologize.
25 CHAIRMAN McDADE: Anyway, Dr. Duquette, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5803 1 you thought that you wanted to raise with regard to 2 the French experience that you felt is relevant that 3 we should --
4 DR. DUQUETTE: Well, the French experience 5 --
6 CHAIRMAN McDADE: -- take into 7 consideration?
8 DR. DUQUETTE: -- is brought up as a 9 trivial problem. Number one, I have done a lot of 10 other consulting in other kinds of plants. If I saw 11 cracks of that nature in almost any component in any 12 plant that I inspected, I would certainly be 13 concerned.
14 But in the French experience, they noted, 15 and I think they were correct, that the cracking took 16 place in the cold work -- in the thin cold work skin 17 that was on their divider plates.
18 CHAIRMAN McDADE: And actually I wanted to 19 get into that. Before we go further, can you explain 20 what cold warping is --
21 DR. DUQUETTE: Oh, surely.
22 CHAIRMAN McDADE: -- and why its 23 significant?
24 DR. DUQUETTE: If you roll a plate, for 25 example, at room temperature or near room temperature, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5804 1 its called cold rolling. And so, there are two --
2 there are several ways to process materials.
3 Theres hot rolling, which would mean that 4 you would roll it at relatively hot -- high 5 temperatures. And cold rolling usually means at near 6 room temperature you process the material. It could 7 be wire drawing, it could be cold rolling to make 8 plate.
9 There are lots of ways to cold roll 10 materials. And so, cold rolling usually strengthens 11 the material. And when you do that, you usually loose 12 some ductility in the material.
13 CHAIRMAN McDADE: Okay. And am I correct 14 that the -- in the French experience, the only 15 observed cracking was in cold rolled material?
16 DR. DUQUETTE: The French plates seemed to 17 have been preferentially cold rolled. That is they 18 had more cold rolling in the surfaces than they did in 19 the body of the material. And that can happen if you 20 do a light amount of cold rolling or grinding on the 21 surface, something that deforms the surface 22 preferentially.
23 Many plates are cold rolled heavily. The 24 automobile youre driving, for example, will have been 25 cold rolled right through the entire steel thats in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5805 1 it so that the entire steel has the same properties.
2 And so, cold rolling -- surface cold 3 rolling, which is what the French reported, could have 4 come from grinding, it could have come from machining 5 the plate, it could have come from doing a light cold 6 roll at the end of the process for making the plate, 7 but the experience is that cold rolling decreases the 8 immune -- I wont say immunity. It increases 9 susceptibility to primary water stress corrosion 10 cracking. Thats well established.
11 And the problem with Indian Point is we 12 have no idea what the condition of those plates are 13 whether theyre heavily cold rolled, or lightly cold 14 rolled, or completely annealed or cold rolled at all.
15 We just dont know anything about them, as far as I 16 know, or at least we havent seen any evidence from 17 the original manufacturer having supplied them as to 18 what their condition is.
19 Under the worst of cases, the last pass 20 that they were -- when they were made into plate, they 21 were heavily cold rolled, and its quite possible that 22 theyre cold rolled from the surface right through the 23 body of the plate. Thats not unusual for lots of 24 cold rolling operations. In fact, its quite commonly 25 done to get uniform properties across plate.
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5806 1 I would like to be able to say that the 2 Indian Point situation has no cold rolling at all or 3 that its only a skin effect as the French saw, but we 4 dont have any evidence of that yet. And until we 5 look, we dont really know whether its cracking or 6 not and whether or not its cold rolled or not.
7 And so, my argument would be that in the 8 absence of knowledge we have to assume -- we dont 9 have to assume, but Im going to assume that theres 10 a possibility that the plate that was provided by the 11 manufacturer of the plate and put in place was 12 heavily cold rolled. I have no way of knowing that it 13 is not.
14 CHAIRMAN McDADE: Okay. Now, the SG tubes 15 themselves, the 3,000 whatever tubes in each 16 generator, are thermally treated, either 600 or 690 17 thermally treated. That would suggest that theres no 18 cold rolling with regard to the tubes and is it your 19 issue that this is only -- your view that this is only 20 an issue with regard to the divider plate?
21 DR. DUQUETTE: Not quite. Again, Im not 22 sure what we can say about the 2014 report or the 2012 23 interim report that EPRI provided, but they laid out 24 some scenarios for what Ill call destroying the 25 pressure boundary by the cracks that form in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5807 1 divider plate progressing into the tube-to-tubesheet 2 welds by cracking the cladding thats on the tubesheet 3 itself.
4 And so, theres a path that could be 5 followed for a stress corrosion crack that would begin 6 in the divider plate and then progress into other 7 parts of the steam generator eventually perhaps 8 compromising the pressure boundary.
9 CHAIRMAN McDADE: Okay. And in here, the 10 part of the pressure boundary were talking about are 11 the SG tubes themselves.
12 DR. DUQUETTE: Would be the -- pressure 13 boundary would be compromised by a crack that would 14 occur in the tube-to-tubesheet welds. Because once 15 you do that, you expose the inside of the --
16 independent of the cold expansion of the tubes into 17 the tubesheet once youve cracked the tube-to-18 tubesheet weld, you have a path for compromising the 19 pressure boundary.
20 And I would argue that some discussion 21 made earlier about allowable leaks if you broke enough 22 of the welds in the pressure boundaries, I think you 23 would probably exceed the ability for one tube to 24 provide the leaking, which I think was the analysis 25 that was done.
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5808 1 That is if one tube-to-tubesheet weld were 2 compromised, then the leak would be acceptable. If 3 20,000 of them were compromised, Im not so sure that 4 would be correct, not that Im suggesting that there 5 would be 20,000 compromised all at the same time.
6 CHAIRMAN McDADE: Okay. If you could 7 continue talking about the French experience and part 8 of that I would also like you to address, I believe, 9 Entergy has suggested that the lessons to be learned 10 from the French experience are somewhat limited 11 because you have differences with regard to the water 12 chemistry programs, the thermal impact, the cyclical 13 loading so that the concerns that you observed from 14 the French experience would not be necessarily 15 applicable to the Indian Point experience.
16 Have I misstated Entergys position at 17 all?
18 MR. DOLANSKY: No, Your Honor.
19 CHAIRMAN McDADE: Okay. Dr. Duquette.
20 DR. DUQUETTE: I cant disagree with that.
21 There is certainly differences from the French 22 experience, and I know something about that, and the 23 US experience.
24 Its also a fact, and it has to be 25 accepted, that only about 20 percent -- I believe the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5809 1 number is about 20 percent of the French reactors 2 showed cracking in the divider plates. They saw it at 3 Chinon. They saw it at Gravelines. They saw it in a 4 number of places, but they certainly didnt see it in 5 all of their steam generators.
6 And I believe that my understanding is 7 that they now inspected all of their steam generators.
8 So, its not a problem that goes through the entire 9 French fleet. I suspect it will not be a problem 10 throughout the entire United States fleet or anyone 11 elses fleet, as far as that goes, but the fact of the 12 matter is that they did see cracking, they did 13 identify with cold work, and I know Ive said this, 14 but we have no way of knowing what the cold work 15 situation is at Indian Point 2 or 3. And so, I think 16 theres some concern in that area.
17 I would like to see regular inspections.
18 And that doesnt mean every other month, but regular 19 inspections to be sure that if any cracks form there 20 arent growing. And if theyre growing, theyre not 21 growing to eventually compromise the pressure 22 boundary.
23 And so, Im not suggesting we decommission 24 the --
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5810 1 a good time for you to address it. I dont want to 2 lose your train of thought, but --
3 DR. DUQUETTE: Okay.
4 CHAIRMAN McDADE: -- you just raised the 5 issue of the timing of inspections. We had had the 6 discussion earlier from Entergy, their explanation as 7 to why the timing that they proposed, which is, you 8 know, not until after the beginning of the period of 9 extended operation and I believe about 22 years into 10 the operation of IP2, and 28 years into the operation 11 of IP3, you know.
12 Do you disagree with their explanation 13 that inspecting earlier would be unnecessary because 14 there is no basis to believe that cracking would occur 15 that early in the operation given the nature of the 16 materials?
17 DR. DUQUETTE: Well, the Indian Point 3 18 reactor that was put in place in 1989 has been in 19 service for quite some time.
20 And so, if there are cracks -- and I dont 21 think anyone has looked at this point, at least have 22 not seen any evidence in that. If there are cracks in 23 those divider plates, I think wed like to know that.
24 And if we do see them, I think wed like to know; A, 25 are they growing, or are they so large that we have to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5811 1 do something about them?
2 And if theyre growing --
3 CHAIRMAN McDADE: But do you disagree with 4 the underlying premise that you would not expect --
5 there would be no reason to believe that cracks would 6 be -- would either originate or propagate early in the 7 period of operation by the steam generator?
8 DR. DUQUETTE: I dont have an answer to 9 that. The problem weve had with the inspections that 10 have been so far by the French primarily, is that its 11 like a snapshot in time.
12 They saw cracks in the reactors. They 13 did, in some cases, come back in and look a few years 14 later. I think the first cracks were identified in 15 about 2007. And I think some five years later they 16 looked again and the cracks that they had seen in 2007 17 had not grown in their case.
18 And Im not surprised at that if its only 19 growing in a thin, cold warp layer, then it sort of 20 ran out of steam in that cold warp layer.
21 I would certainly like to get into the 22 1989 unit and see if theres anything there. Its 23 been a long period of time that its been in place.
24 And if theres nothing there, I certainly would feel 25 more comfortable about the unit that was put in place NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5812 1 in 2000.
2 I dont see any -- I think Entergy has 3 said that they have the capability of doing the 4 inspections. Perhaps I dont know the economics of 5 the situation, but I dont know why they wouldnt do 6 them. I dont know why they would rely on an 7 analytical process to eliminate the possibility when 8 they could, in fact, look at them and indicate that 9 they have the capability to do that. Im not sure why 10 the pushback on it.
11 CHAIRMAN McDADE: Okay. Well, let me go 12 back. I believe Mr. Dolansky indicated that there is 13 inspection that is done, a visual inspection at each 14 outage that would demonstrate any gross abnormality, 15 but what the inspections theyre talking about 16 pursuant to the license commitment has to do with the 17 EVT1, the more detailed inspection.
18 And so, is the concern that you just 19 raised not alleviated by the testimony of Mr. Dolansky 20 as to the, you know, the sort of gross inspection on 21 a periodic basis during refueling outages as opposed 22 to the specific inspections, you know, identified, you 23 know, in the license commitment, which would be, you 24 know, not until the first outage after the start of 25 extended operations for Indian Point 2, meaning NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5813 1 basically 28 years into the life of a steam generator?
2 DR. DUQUETTE: Surely. I certainly would 3 feel a lot more comfortable if someone from Entergy 4 were to stand up and say that in their visual 5 inspections that they do on a regular basis that they 6 look specifically for cracks in the divider plate.
7 If they tell me that theyve done that, 8 have looked and have been very judicious about it 9 knowing that they might be there, I might feel better 10 about having to do a more detailed inspection.
11 I havent heard that and I certainly 12 havent seen it in their written testimony or anything 13 that was provided to me before this. So, to my 14 knowledge, the visual inspection that they do in that 15 area isnt looking specifically at the -- at least as 16 far as I know, isnt looking specifically for the 17 possibility of small, initiated cracks in the divider 18 plate near the weld area.
19 I dont know if you would like Entergy to 20 comment on that or not, but Im not sure the visual 21 inspection would see it unless you had someone who was 22 qualified to look for the kind of cracking that were 23 talking about.
24 CHAIRMAN McDADE: Mr. Dolansky, do you 25 wish to comment on that?
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5814 1 MR. DOLANSKY: This is Bob Dolansky with 2 Entergy. We have not done an EVT1 on the divider 3 plate looking specifically for cracking. Our position 4 is that if there were -- the size of the flaw to 5 become structurally significant would be very large.
6 The examinations -- the visual inspections 7 that we do are general visual inspections of the 8 entire bowl area, including the divider plate. And 9 when we perform those inspections if there were gross, 10 you know, large flaws, gross abnormalities, they would 11 be seen.
12 Additionally, if there were cracking that 13 got through to a low alloy steel, that got through the 14 cladding, we would expect to see evidence of that in 15 the form of rust color or something like that. And 16 that would definitely be seen in the general 17 inspections that are performed every time we go into 18 the steam generator bowls.
19 CHAIRMAN McDADE: Okay. Thank you. Dr.
20 Duquette.
21 DR. DUQUETTE: Dr. Duquette, New York 22 State. I think I understood that answer to mean 23 unless its a gross defect, it either wouldnt be 24 picked up or wouldnt be recorded or no one would be 25 very concerned about it.
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5815 1 Stress corrosion cracks start small and 2 they can grow fairly rapidly in Alloy 600 if they 3 havent breached the cladding on the tubesheet yet.
4 And I think the comment was if they had breached the 5 cladding on the tubesheet, they would have seen some 6 corrosion from the tubesheet through the crack in the 7 cladding.
8 That certainly makes me feel better about 9 where we are, but it doesnt tell me anything about 10 whether there are cracks in the divider plate now, how 11 big they are, where theyre going or whether they 12 would have started into the cladding on the tubesheet 13 without actually having reached the carbon steel 14 underneath.
15 My concern about stress corrosion cracks 16 is theyre not a single -- they dont just occur and 17 theyre there and they break something or dont break 18 something. They grow as a function of time, and small 19 ones will grow into big ones if theyre growing at 20 all.
21 And so, my concern would be that if 22 theres a small crack now that can be seen, I 23 certainly would like to know that. And I certainly 24 would like to know what its direction is going to be.
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5816 1 to know whats going to be done about it if one is 2 identified.
3 I think I heard this morning that if one 4 is identified, it will go through some standard 5 remediation process without defining what that 6 remediation process is. So, thats another area of 7 concern if you do find cracking.
8 I dont understand why as an engineer, I 9 dont understand why having seen cracking in similar 10 structures, a significant number of them, that they --
11 there wouldnt be some concern about at least 12 identifying them and finding out if theyre going to 13 be a problem.
14 I certainly think an examination of both 15 steam generators at this point to allay the problem, 16 put it aside and say we dont see any cracking at all, 17 I certainly would then feel better about delaying a 18 second inspection. But to have the first inspection 19 well into the relicensing period seems, to me, to be 20 -- I just dont think its good engineering practice 21 if you know that the component, it has shown cracking.
22 And, again, its not a single steam 23 generator in France. It was -- I think it was 18 or 24 20 percent of the steam generators showed cracking in 25 them. They explained the cracking, they indicated why NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5817 1 they didnt see any expansion of it, but, again, we 2 dont know what the condition of the divider plate is 3 at Indian Point in either one of the steam generators.
4 I just would feel better if we had a 5 baseline or a thorough examination of that area had 6 been taken. If no one had ever seen a crack in a 7 divider plate anywhere in the world, Id say probably 8 theyre proceeding as they should be. But there are 9 just too many of them in steam generators where the --
10 we dont know what the condition is in our case.
11 And Im not suggesting we cut samples out 12 of a divider plate. I just think there should be a 13 thorough inspection of the divider plate and should be 14 a thorough and visual -- not just a visual inspection, 15 but one at some magnification to see if the cracking 16 is there. Its a comfort level, perhaps, more than 17 anything else.
18 I dont think were near disaster in any 19 of them, or we probably would have seen it somewhere 20 else in the US fleet, but I think its just good 21 engineering practice.
22 CHAIRMAN McDADE: Okay. I believe you 23 testified that the rate of propagation of such cracks 24 could be rather rapid. And I try to just sort of 25 focus on what rather rapid means.
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5818 1 Youve heard the testimony from Mr.
2 Dolansky with regard to what the inspections are at 3 each outage. What is the period between outages?
4 MR. DOLANSKY: 24 months.
5 CHAIRMAN McDADE: Thank you, Mr. Dolansky.
6 24 months. So, these --
7 MR. DOLANSKY: This is Bob Dolansky. Let 8 me just clarify. We go into the steam generators 9 typically every two cycles. So, we would go into the 10 steam generator bowl area roughly every 48 months, 11 every four years.
12 CHAIRMAN McDADE: Okay. Thank you.
13 DR. DUQUETTE: Everyone in the stress 14 corrosion cracking field talks about rapid crack 15 growth. For us, that can be a fairly slow crack 16 growth compared to what most people might look at.
17 We do know, for example, that the history 18 of problems in the PWRs due to stress corrosion 19 cracking hadnt been identified in -- I believe the 20 first numbers that were reported were probably 10 or 21 12 years after the steam generators were put in place 22 with the mill-annealed tubes.
23 And Mr. Gordon has a very nice table which 24 I can show if you wish to, but I think its included 25 in the testimony I provided, indicating the number of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5819 1 problems that have occurred with stress corrosion 2 cracking in various components in the steam 3 generators. Some werent identified until the 1990s 4 and the steam generators had been in place for a very 5 long time.
6 The whole steam generator issue for those 7 of us who have done stress corrosion cracking for --
8 Ive done work for EPRI, for example, on stress 9 corrosion cracking in some of their alloys. They take 10 a long time in terms of numbers of years.
11 We do know, however, that once they 12 initiate, they grow exponentially. Not a very high 13 exponent, but they -- the rate of acceleration 14 increases with time. So, they can take a very long 15 time to initiate. They will also be slow to propagate 16 initially. And as they get larger, will propagate 17 faster.
18 So, I think if we saw no cracking 19 whatsoever in a reasonably recent inspection of the 20 steam generator divider plates and we saw no cracking 21 at all, again, I would feel more comfortable with what 22 were seeing, but we dont know. We dont know whats 23 there at all.
24 Im not going to suggest that the cracks 25 will grow over days or over months. Its certainly NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5820 1 going to be over years. But if we do see some, I 2 think the first thing one would want to do is come 3 back in a few years and see what the growth rate has 4 been hoping that they havent grown catastrophically.
5 If we came back for a second inspection 6 and saw no growth whatsoever or no new cracks, you 7 probably want to stop right there. You probably 8 wouldnt have to go beyond that point.
9 But I think -- theres an old German 10 saying that one data point is worse than no data 11 points. And I think thats probably true in this 12 case. I think Id like to see whats happening as a 13 function of time.
14 Maybe get a baseline in the next year or 15 two. Five years from now come back in and look at it 16 again and see where we are.
17 CHAIRMAN McDADE: Okay. What were trying 18 to determine is whether or not the proposed inspection 19 schedule provides reasonable assurance. And what we 20 have from Mr. Dolansky is that this is looked at in a 21 -- perhaps not the right word, but gross fashion on at 22 least a 48-month. And that they then have this 23 detailed inspection scheduled for Indian Point 3, the 24 1989 reactor, I believe it will be in 2017. That they 25 suggest that given the rate of propagation of these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5821 1 cracks in order for a crack to pose any issue, it 2 would be identifiable in these periodic inspections 3 and that you would be able to identify even a much 4 smaller crack in the inspection that they propose for 5 IP3 in 2017. And that given the rate of propagation, 6 you would not expect a crack to cause any problem in 7 the interim period.
8 Do you disagree with that? And if so, 9 why?
10 DR. DUQUETTE: Im very comfortable with 11 the -- if they do a detailed crack analysis in 2017, 12 Im very comfortable with that. And I would like to 13 see a second inspection at some time in the future.
14 Again, the testimony I think Ive heard is 15 there is a visual inspection of the bowl area. I 16 think when I asked specifically if anything was done 17 to look specifically at the divider plate, Im not 18 sure that I understood the answer, but I dont think 19 anyone has looked specifically at the place where the 20 French had observed cracking.
21 And if you look at the reports that are 22 both public and in the EPRI reports, the cracks that 23 were observed in the French reactors initially had to 24 be looked at in something more than a visual manner.
25 Theyre pretty small.
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5822 1 Now, when they looked at the crack itself, 2 there were fairly large cracks from a microscopic 3 point of view. And theres some beautiful pictures 4 that they produced, but visually they would have been 5 very difficult to see without some other indication.
6 And so, the 2017 period, I think its a 7 great period. Id like to see them both done in 2017.
8 I think the earlier we identify no problem would make 9 everyone -- would certainly make me more comfortable 10 about the possibility of the cracks growing up into 11 the cladding and possibly to the tube-to-tubesheet 12 welds where they would possibly compromise the 13 pressure boundary.
14 CHAIRMAN McDADE: Okay. Are there any 15 provisions for follow-up inspections under the 16 licensing commitment? In other words, if we have the 17 inspection in 2017 as far as EVT1, is that going to be 18 repeated?
19 MR. AZEVEDO: Your Honor, this is Nelson 20 Azevedo for Entergy. That depends on what we find.
21 If we find --
22 CHAIRMAN McDADE: Assuming you find no 23 cracks in 2017 given the license commitment, theres 24 no provision for follow-up inspection.
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5823 1 to go back if we find nothing. Thats correct.
2 CHAIRMAN McDADE: Okay. And can you 3 explain the justification for that?
4 MR. DOLANSKY: This is Bob Dolansky with 5 Entergy. Again, to me the justification would be the 6 French experience. I mean, the fact that the French 7 saw cracking, they didnt actually do anything about 8 it. They left it in service.
9 Then they removed steam generators from 10 service for other reasons, did destructive testing.
11 Turned out that the cracking was non-consequential.
12 So, if we go out and inspect and see nothing, I would 13 see no reason why we would need to go out again.
14 Theres nothing that would drive me to 15 feel that thats required or necessary, to be honest.
16 CHAIRMAN McDADE: Okay. But the 17 inspection you would be doing -- and lets focus just 18 on Indian Point 3 right now -- would be approximately 19 28 years into the life of that steam generator, 20 correct?
21 MR. DOLANSKY: Correct. 1989 to 2017, 22 yes.
23 CHAIRMAN McDADE: Okay. And is it your 24 position that if there was given the EVT1 inspection 25 in 2017, 27 or so years into the life of that, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5824 1 would have no reason to expect that there would then 2 be cracking in -- during the continued -- cracking of 3 any significance during the continued operation of 4 that steam generator during the period of extended 5 operation?
6 MR. DOLANSKY: That is correct, Your 7 Honor.
8 CHAIRMAN McDADE: Okay. Dr. Duquette, do 9 you --
10 MR. COX: This is Alan Cox. Let me add 11 one thing to that. Mr. Dolansky indicated that we 12 share Dr. Laheys concern for safety. And one aspect 13 of that is the safety of the people at the plant that 14 are doing the work.
15 So, weve got an EPRI report that says 16 that the investigation concluded that a crack running 17 the full length and depth of the weld is not a safety 18 concern, you know. So, I think the decision that wed 19 have to make at the plant is, do we want to spend the 20 dose, I mean, if you do this inspection, youre 21 putting people at some risk by the radiation exposure 22 theyre going to incur during the inspection. And if 23 youve got a situation where there is no safety 24 concern, its hard to justify from a management safety 25 perspective why you would subject people to that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5825 1 additional dose to go do that inspection. Thats 2 another consideration that would come into play in 3 making the decision.
4 In the 2017, that is the -- thats the 5 next available opportunity for doing an inspection.
6 The unit -- thats the next outage, next refueling 7 outage that will come up on IP3.
8 MR. STROSNIDER: And this is Jack 9 Strosnider for Entergy and I just want to expand 10 briefly on what Mr. Cox just said with regard to the 11 -- we had some discussion earlier about this very 12 large flaw that was demonstrated in the EPRI analysis 13 did not impact the safety analysis.
14 You dont need to do an enhanced visual 15 examination to see a flaw that size. Examinations 16 that theyre doing every 48 months when they go in and 17 they look, you would see that kind of a flaw long 18 before it got that big. So, you dont have to rely on 19 the enhanced visual to maintain safety.
20 MR. AZEVEDO: Your Honor, this is Nelson 21 Azevedo. May I add one additional point? The reason 22 why this issue even came up was because of operating 23 experience. In this case, overseas.
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5826 1 it would -- we evaluate that and determine whether it 2 would be appropriate to go back and do inspections.
3 So, I just wanted to point that out.
4 CHAIRMAN McDADE: Okay. Thank you. Dr.
5 Duquette, do you see a need for continued inspections 6 after, for example, IP3 after the 2017? And at what 7 period and why?
8 DR. DUQUETTE: I have to back off on the 9 safety issue as far as the personnel are concerned and 10 what they can do. I think if youre going to do an 11 inspection in 2017, that team will have had experience 12 on how to do it and what theyre doing.
13 And if Im only suggesting one more 14 inspection, say, five or eight years later, I dont 15 think that the total dose that that team is going to 16 see is going to be very much more. And so, I think 17 Im having a problem wrapping my arms around the fact 18 that this is a safety issue for the people who are 19 doing the inspection, because youre going to be doing 20 one in 2017 anyway.
21 Looking at some more steam generators, I 22 dont think its going to expose people to that, but 23 thats not my area of expertise. And so, Ill have to 24 back away from there.
25 But the fact of the matter is the French NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5827 1 experience is brought up both by me and by Entergy and 2 Entergy is absolutely correct. The French explained 3 why their cracking stopped where it did. I know Ive 4 said this, and I dont want to be too repetitious, but 5 we dont know what the condition of the divider plates 6 are or the welds or anything else in the machines that 7 we have now.
8 In addition to that when they talk about 9 not being able to see a small flaw, Im not sure how 10 much experience the people who are testifying have on 11 identifying cracks in Alloy 600, but one comment that 12 came up is correct.
13 If you penetrate through the cladding on 14 the tubesheet and you begin to corrode the carbon 15 steel underneath, youll see that, but fine cracks in 16 welds are really, really difficult to see visually.
17 So, if you get a crack on a weld or in a 18 heat-affected zone, youre not going to see it 19 visually unless you do something more than that in 20 most situations especially in the welds. Theyre just 21 very difficult to identify unless youve got really 22 experienced people and somewhat of a more advanced 23 technique.
24 So, I dont think that 48-month visual 25 inspections are going to detect very much unless NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5828 1 theyve got -- and theyre right -- a massive crack.
2 But the -- when they -- when it was said just a few 3 minutes ago that the EPRI report indicated there was 4 no problem, that isnt quite true.
5 The EPRI report laid out several 6 scenarios. They did indicate that they probably were 7 not likely, but they -- it was a thorough enough 8 report, I was very impressed with it, to point out 9 that there is a scenario for a crack, for example, to 10 progress up into the Alloy 600 cladding on the 11 tubesheet, progress across that cladding and then 12 intersect at least one or more of the tube-to-13 tubesheet welds. And if that happens, you have the 14 risk of compromising the pressure boundary. Its as 15 simple as that.
16 And I would argue that theres no way that 17 a team thats looking at it visually is going to see 18 the fine cracks that I have seen in stress corrosion 19 cracking situations without doing something more than 20 that.
21 Ive analyzed thousands of cracks in my 22 career and typically I have to use some technique 23 other than just looking at it unless its such a 24 massive crack that I can drive a truck through it.
25 CHAIRMAN McDADE: Well, perhaps not to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5829 1 drive a truck through it, but as I understand the 2 position of Entergy is that well before the time that 3 these cracks would become an issue, they would be 4 observable through their periodic inspections. And 5 that these inspections, I guess, for Indian Point 3 in 6 2017, for Indian Point 2 probably in 2023, 7 approximately ten years after the period of extended 8 operation begins, that these more detailed EVT1 would 9 be sufficient to ensure that these cracks would not, 10 could not propagate undetected to the point where they 11 would raise an issue as to the continued function.
12 Do you have a problem with that position 13 and --
14 DR. DUQUETTE: As I indicated just a few 15 seconds ago, yes, I do. My own personal experience is 16 you can have very long cracks that are virtually 17 invisible to the naked eye. Ive seen them in paper 18 mills, Ive seen them in power plants and a number of 19 other places where we had to do something more than 20 just look at them to see that there were cracks 21 present.
22 And so, I disagree that a visual 23 examination in the kinds of structures youre looking 24 at here will necessarily show you whether you have a 25 crack that has to be dealt with. And at some point we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5830 1 should talk about dealt with as well, but I disagree 2 that you necessarily would not -- that you would 3 necessarily see a crack that was close to compromising 4 the situation.
5 The cracks were talking about are growing 6 in welds, theyre growing in welded material on the 7 tubesheets, and theyre progressing if theyre going 8 to compromise the pressure boundary by breaking the 9 pressure boundary at the tube-to-tubesheet welds, 10 youre again looking at welded materials where cracks 11 are very difficult to see because of the structure of 12 the weld itself.
13 CHAIRMAN McDADE: Well, let me go back and 14 showing my ignorance, perhaps, of the process, but 15 were talking about the divider plate and the capacity 16 for cold working on the divider plate. Were talking 17 about the tubes where I concede theres no cold 18 working given the nature of the particular product.
19 Is cold working an issue with regard to 20 the welds? And if not, would welds be susceptible to 21 cracking in the same way the divider plate would be or 22 a cold-worked piece of metal would be?
23 DR. DUQUETTE: Cold-worked and mill-24 annealed Alloy 600 will accelerate the cracking 25 problem. But Mr. Gordon testified just a little while NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5831 1 ago, and hes correct, Alloy 600 that is mill-annealed 2 is susceptible all by itself. And the weld material 3 that you use to weld Alloy 600, which is about the 4 same composition, is also susceptible.
5 Cold working will accelerate the process.
6 Youll get earlier initiation and more rapid 7 propagation, but that doesnt mean that you wont get 8 propagation through welded Alloy 600 -- its actually 9 called Alloy 182, but you certainly will get cracking 10 in that alloy. It just is not as rapid as it would be 11 in a cold work material.
12 Cold work material, the numbers Ive seen 13 in a number of places, I think, including in the EPRI 14 report, and theyre out in the public. So, its not 15 anything thats secret. Cold working increases the 16 crack propagation rate by about a factor of four, but 17 there is a finite crack propagation rate. Its just 18 that it goes four times -- about four times faster 19 into material thats cold worked.
20 CHAIRMAN McDADE: Okay. Its after noon 21 and Im wondering if it may be a good time for us to 22 break for lunch. I propose to break and come back at 23 one oclock.
24 Does that pose problems for anybody? Is 25 that sufficient time? Does the staff need any NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5832 1 additional time?
2 MR. HARRIS: No, Your Honor.
3 CHAIRMAN McDADE: Entergy.
4 MS. SUTTON: Thats fine, Your Honor.
5 MR. SIPOS: Your Honor, the State would 6 request 75 minutes. An hour and 15 minutes.
7 CHAIRMAN McDADE: Okay. Now, Ive got to 8 -- lets see. 75, 60, okay. So, were talking about 9 1:15?
10 MR. SIPOS: Yes.
11 CHAIRMAN McDADE: Okay. Thats -- well 12 stand in recess then until 1:15.
13 (Whereupon, the proceedings went off the 14 record at 12:05 p.m.)
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5833 1 A-F-T-E-R-N-O-O-N S-E-S-S-I-O-N 2 (1:15 p.m.)
3 CHAIRMAN McDADE: Okay. Please be seated.
4 Were ready to proceed. Mr. Sipos, it looks like you 5 might have something before we get started.
6 MR. SIPOS: Yes. I just actually for 7 clarity of the record, I think there was a couple of 8 homework assignments for Dr. Lahey. And I just -- I 9 thought it would be helpful for the record if I just 10 read the exhibits and their titles so that they are 11 all in one place for the parties and the Board as they 12 look back at it subsequent to the hearing. Would that 13 be --
14 CHAIRMAN McDADE: Yes, please.
15 MR. SIPOS: Okay. So, the first exhibit, 16 I believe, is Entergy Exhibit Entergy R681. And that 17 is WCAP-17199-P, Rev 2 November 2015.
18 The next one is Entergy R689. Thats 19 WCAP-12191, Rev 5. And the cover page has an October 20 2015 date.
21 Then the third one is Entergy Exhibit 727.
22 And that is CN-PAFN-09-21, Rev 4 also with a November 23 2015 date. I believe those are the three documents 24 that you have discussed with Dr. Lahey.
25 CHAIRMAN McDADE: Okay. Thank you, Mr.
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5834 1 Sipos.
2 Okay. The question is whether we continue 3 on 38, or go back to Dr. Lahey. We had talked about, 4 you know, some matters that you wanted to bring up, 5 Dr. Lahey. Why dont we get that out of the way now 6 before we proceed on?
7 DR. LAHEY: Thank you, Your Honor. The --
8 theres two basic things. One homework assignment or 9 break assignment that you gave me on to look at 10 thermal couple processing, signal processing. And the 11 other one has to do with the discussion that we had 12 yesterday, which was my self-imposed homework for last 13 night because I was told that the answer to my 14 question was in Entergy 681.
15 So, I -- all these documents, 16 incidentally, I have seen before. I just dont carry 17 numbers in my head, but they were not new documents to 18 me. So, anyway, if you dont mind, I would just like 19 to resolve the thing we talked about, clarify the 20 record with the thing we talked about yesterday, 21 which, just to remind you, we had discussed some 22 problems with the heat transfer coefficient modeling 23 in the WESTEMS code.
24 And I showed you a couple of areas in 25 terms of thermal boundary layer effects and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5835 1 nodalization where if you get non-conservative 2 results, these are two independent things that can 3 lead to non-conservative results.
4 So, I was -- as I understood the testimony 5 of Mr. Gray, I believe it was, which maybe I didnt, 6 but it sounded like he said that you dont really need 7 to worry about that, because we specify the transients 8 and we adjust the duration of them so that we get the 9 maximum stresses.
10 So, and he -- and when I ask -- or when 11 you ask on my behalf where was all this documented, I 12 was told 681. So, when I went back last night and 13 went through 681, there was a lot of work shown in 14 determining the transients. Some of them are more 15 complicated than others such as the in-surges and out-16 surges of the pressurizer.
17 And then there were other components as 18 well, but basically it was determining what is the 19 temperature and the flow transients and the number of 20 the various transients, but my question had to do with 21 the thermal hydraulic analysis of these transients 22 which lead to the stresses.
23 And in the document it was very clear, and 24 in all other documents that Ive read on this subject, 25 its very clear that once you have the transients, you NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5836 1 then put them into this thermal hydraulics model that 2 we talked about yesterday and you then determine what 3 the stresses may be. So, it really doesnt resolve my 4 concerns at all.
5 And so, my shock yesterday that I 6 expressed, I mean, if we dont have to worry about 7 heat transfer coefficients, whats the code for? It 8 looks like they are indeed using the code. They break 9 up various components into zones and pick constant 10 heat transfer coefficients in the various zones. They 11 dont have to be the same. And they try to pick ones 12 that they believe are conservative.
13 But what I showed yesterday, these fully 14 developed heat transfer coefficients cannot be 15 conservative because of these two effects that I 16 discussed. So, thats one thing I wanted to resolve 17 and it might be I just misunderstood Mr. Gray, but it 18 sounded pretty clear thats what they were saying.
19 So, thats all I have to say about that 20 issue. And if you would like Mr. Gray to respond, we 21 can do it, or do you want me to go on to the other --
22 CHAIRMAN McDADE: Why dont you go on, Dr.
23 Lahey?
24 DR. LAHEY: Okay. The other issue is sort 25 of a longstanding concern Ive had and Ive put it in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5837 1 previous testimony that Ive submitted and it never 2 was resolved to me is, how do you handle the thermal 3 coupled measurements? Because you heard this morning 4 even they make some measurements and infer the fluid 5 temperatures from this in terms of stratification or 6 the possibility of thermal striping and various 7 others.
8 And the problem is the documents that I 9 was given to review, which I have and I had previously 10 seen these, is Entergy 689 and 727, they use the 11 transients, but theres no indication at all in how 12 they are processed. And I want to just remind you as 13 to the concern and this is something that Ive got a 14 lot of experience with.
15 If you have an instrument in the fluid, a 16 thermal couple resistance temperature detector or any 17 other thing, theres a certain amount of heat capacity 18 in this. Theres inertia in it.
19 So, it will measure the temperature of the 20 fluid and at steady-state you get a very -- if its 21 calibrated, you get a very nice result. But during a 22 transient when its changing with time, theres a lag.
23 It takes a while for the device to come up to the 24 temperature of the fluid. Either go down, or go up 25 depending what the fluid is doing.
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5838 1 And so, what you have to do, theres 2 really two fundamental ways to treat it. One, you 3 just write down the differential equation, which is 4 the energy balance on the center itself, and it 5 amounts to numerically differentiating the data. And 6 you may know thats a noisy affair and you have to do 7 it very carefully in order to get a reasonable answer.
8 The other way is to solve for the step 9 solution or the impulse solution, which is the 10 derivative of that, get what the stress people like to 11 call the Greens function and then you convolute it 12 by integrating -- its called the Duhamel theorem, you 13 integrate all these step solutions by whats going on 14 in your signal and you get what the real temperature 15 is, but you cant just take the temperature from the 16 reading and use that as the temperature and nowhere do 17 they talk about that at all.
18 And when I ask the question and I got a 19 response in testimony from Entergy, I believe, it was 20 we take care of it. We know about thermal couple lag.
21 I dont see anything like that and its 22 important.
23 JUDGE KENNEDY: Dr. Lahey, this is Judge 24 Kennedy. As I understood it yesterday, they were 25 taking peak and minimum values from the transient NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5839 1 data.
2 Does that eliminate some of the concerns 3 about the thermal lag effect in the thermal couples?
4 DR. LAHEY: If youre measuring what the 5 peak and the minimum is, you need to make the 6 correction to know what the real peak is and what the 7 real minimum is.
8 JUDGE KENNEDY: What is the effect of 9 calibrating the thermal couple? Is that an attempt to 10 --
11 DR. LAHEY: You need to --
12 JUDGE KENNEDY: Would that not consider 13 that effect?
14 DR. LAHEY: Sir, you need to calibrate 15 your temperature sensor for sure, but during 16 transients it has a certain inertia. So, its like if 17 you take a piece of metal and drop it in boiling 18 water, it doesnt instantly come to the temperature of 19 the boiling water. It takes a while because of its 20 heat capacity, mass times the specific heat to heat 21 up.
22 And depending on what the temperature 23 sensor is and how massive it is, the more the inertia 24 is. But in any event, you just dont get the right 25 answer unless you make corrections.
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5840 1 JUDGE KENNEDY: I mean, would you not get 2 to the correct temperature? I mean, eventually its 3 going to reach the right temperature at some point.
4 DR. LAHEY: For steady-state. Yeah, if 5 you go up and reach a steady state, you wait a while 6 until its all settled out, you can get a result, but 7 theres all kinds of different transients that theyre 8 looking at. Its not just that particular one that 9 was discussed in terms of the surge line.
10 JUDGE KENNEDY: Well, since my memory is 11 failing me, maybe someone from Entergy could help us 12 understand how the thermal couple data is used and 13 whether its adjusted for some of the effects that Dr.
14 Lahey is concerned with.
15 MR. GRAY: This is Mark Gray for Entergy.
16 Yes, there are -- one important aspect of 17 understanding this is its understood that there is a 18 lag in the thermal couple. And its also understood 19 that the thermal couples were calibrated and the 20 readings in the plant computer are used for operating 21 the plant. So, theyre pretty reliable temperature 22 measurements, number one.
23 Number two, these transients dont happen 24 in milliseconds. These transients happen in the 25 actual plant data over minutes, in reality. The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5841 1 design transients are very conservatively estimated to 2 occur over seconds. So, the bottom line is this --
3 youre correct in saying that if theres any 4 difference between where I started and where I ended, 5 we are capturing the whole history of the transient.
6 Were capturing that whole temperature history. So, 7 thats not an instantaneous thing that happens.
8 And so we can, number one, be confident 9 for the rate of these transients that were getting a 10 good reading as far as, again, what matters to stress.
11 And what matters to stress is not the absolute 12 temperature. What matters to stress is the change in 13 the temperature.
14 And as long as weve looked at the whole 15 excursion of the temperature range we have the Delta-T 16 that we need. And that was -- thats Step 1, but the 17 only thing that we discussed yesterday is the fact 18 that that is not the temperature history thats being 19 used in the stress analysis.
20 These results -- and thats what is 21 discussed in the calc note reference that I gave you.
22 These results are then binned according to severity so 23 that every transient thats tracked as far as its 24 overall Delta-T goes is not analyzed for its actual 25 Delta-T. Its binned in a higher Delta-T.
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5842 1 For example, everything thats counted 2 between a Delta-T of 320 degrees and, say, 300 -- Im 3 making this up, because Im not looking at the 4 calculation, would all be assigned a Delta-T of 320 5 degrees in the stress analysis. And, again, the key 6 here is, is that the stress range is a function of the 7 temperature change. So, these conservatisms are 8 sufficient to account for a small lag in a thermal 9 couple reading.
10 JUDGE KENNEDY: All right. Dr. Lahey, 11 response.
12 DR. LAHEY: Go ahead.
13 JUDGE KENNEDY: No, I --
14 DR. LAHEY: Well, my understanding of 15 that, I, you know, Im filtering it down to we dont 16 do anything. And, you know, Im used to whole 17 international meetings dealing with the inverse 18 problem. Theres textbooks on, you know, and the 19 entire purpose of the textbook is how to treat the 20 inverse problem. And Im hearing we didnt do that, 21 I mean, even though were well aware of the lag.
22 So, if you just forget about data to 23 benchmark your prediction and you just use some sort 24 of prediction and then put all that through your 25 WESTEMS code, which theyre apparently doing, its NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5843 1 really getting pretty far from reality. I mean, why 2 not -- why not at some point benchmark your result?
3 Im -- what I was trying to show yesterday 4 with the nodalization is its very unlikely that 5 theyre tracking sharp temperature change fronts. And 6 if youre not, youre not predicting the right kind of 7 thermal stress.
8 JUDGE KENNEDY: I need to do a memory 9 check again. Dr. Lahey, I thought yesterday in this 10 discussion of the analysis of the transients, the 11 thermal hydraulic analysis of the transients --
12 DR. LAHEY: Right.
13 JUDGE KENNEDY: -- that you agreed that 14 the methodology they were using to capture the 15 transient, again, from an analysis standpoint, that 16 that methodology was okay and that that data was then 17 transferred into the WESTEMS code and the stress 18 analysis performed, but I didnt hear yesterday that 19 you had any concern with the thermal hydraulic 20 analysis that developed the transient data.
21 Did I mishear you yesterday?
22 DR. LAHEY: All these documents are 23 associated with specifying the transients. All right.
24 And what Im talking about is making measurements of 25 the transients to verify or disprove what youre NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5844 1 predicting. And you need to do the inverse problem in 2 order to do that.
3 JUDGE KENNEDY: I think Im losing focus 4 here. We started with the thermal couple data --
5 DR. LAHEY: Yes.
6 JUDGE KENNEDY: -- which, as I understood 7 it, was your concern over their use of plant data to 8 characterize the transient that was of interest. In 9 that case, it was the pressurizer surge line nozzle, 10 I guess. So, we -- it appeared we tried to address 11 that.
12 This seems to be branching back to where 13 we were under Contention 26 about thermal hydraulic 14 methods.
15 DR. LAHEY: Im trying to clarify the 16 record on Contention 26, yes.
17 JUDGE KENNEDY: In regard to what, sir?
18 DR. LAHEY: In regard to my concern over 19 how they measure -- on this particular question, how 20 they measure the fluid temperature as a function in 21 time because you heard just now, yeah, were aware of 22 the lag, we take care of it.
23 JUDGE KENNEDY: Do you have a problem with 24 them using the peak steady-state values, both the peak 25 and the minimum? Is that what youre saying?
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5845 1 DR. LAHEY: If they know for sure what the 2 peak and the minimum is, if its taken during a 3 transient with no correction, I have a serious 4 problem. If its for a long period of time and they 5 know for sure what it is, that seems okay.
6 JUDGE KENNEDY: Im going to ask Mr. Gray 7 to verify this, but I understood him to say they take 8 all of the transient data under consideration during 9 the event.
10 Mr. Gray, can we go back to the transient 11 data again?
12 MR. GRAY: Um --
13 JUDGE KENNEDY: The plant data.
14 MR. GRAY: Okay. The plant data that we 15 get from the plant computer, number one, just to 16 reiterate, we can have high confidence in that data.
17 Its calibrated for the plant to use to run the plant, 18 number one. So, this thermal couple data isnt 19 something that is that much in question.
20 Number two, if we had an infinite decimal 21 transient that occurred in the fluid, this lag could 22 be a concern. Transients dont happen that way in 23 plants. And this lag will occur in thermal couple, 24 thats true.
25 But as you have said, if I have the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5846 1 temperature at the beginning and I have the 2 temperature at the end and this is a transient that 3 occurs over minutes, I will get that -- the maximum 4 temperature change in the fluid.
5 Thats reflected in the thermal couple 6 data. Theres nothing wrong with that. Thats 7 standard practice in interpreting the plant data. If 8 I was trying to solve a fluids problem and I wanted 9 very precise numbers, then I might do something more 10 sophisticated.
11 Were trying to solve a stress problem and 12 were trying to use inputs that are comparable to the 13 inputs that we use in our current licensing basis 14 calculations to get stress. So, these are the 15 temperature changes, for example, that you see at the 16 regenerative heat exchanger outlet temperature.
17 These are used to run the plant. Theyre 18 also sufficient for us to look at the temperature 19 change, because its the temperature change that 20 influences the stress analysis.
21 When you do stress analysis, thats what 22 youre concerned about. That stress range, thats a 23 function of the change in the temperature. So, we 24 havent done anything abnormal or anything thats not 25 typically done in the industry to calculate a linear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5847 1 elastic stress range according to the ASME code, 2 number one.
3 Number two, I think theres still a 4 misunderstanding of how the different pieces of the 5 program were used. And the only thing that the 6 thermal hydraulic model was used for was to process 7 this temperature sensor data and to characterize it 8 into bins of maximum Delta-Ts. Thats all.
9 After that, those cycles that were counted 10 with those maximum Delta-Ts were applied 11 conservatively to the stress model, which includes 12 various zones in the model that see different 13 temperatures. Thats done with a transfer function 14 approach to get the stress in the component.
15 That stress is also then a function not 16 only of the actual temperature differences for every 17 cycle that was noted in the history that we got from 18 the plant data, but all of those cycles that occur 19 over a certain Delta-T range are all assigned a Delta-20 T of the highest range in that bin.
21 This is a very conservative way to do 22 analysis. And this gives you maximum stress ranges 23 that, in turn, are used in the fatigue usage 24 calculation.
25 JUDGE KENNEDY: All right. Thank you.
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5848 1 Dr. Lahey, Ill allow you to respond if youll limit 2 your response to --
3 DR. LAHEY: How long?
4 JUDGE KENNEDY: -- the use of thermal 5 couple data --
6 DR. LAHEY: Yes, Your Honor.
7 JUDGE KENNEDY: -- in the manner that Mr.
8 Gray just described.
9 DR. LAHEY: Sure. And the essence of the 10 disagreement with one of his statements is were 11 trying to solve a stress problem, not a fluids 12 problem, all right.
13 The problem is you cant decouple them.
14 If you get your thermal hydraulics forcing function 15 wrong, you get your stress result wrong. You just 16 cant simply be sloppy in one and precise in the 17 other. You have to be precise in both. So, thats 18 the essence of the disagreement.
19 JUDGE KENNEDY: Does this take us back to 20 the disagreement we had yesterday about the bulk 21 temperature to surface temperature Delta-T, or is it 22 more complicated than that?
23 DR. LAHEY: Well, one of the non-24 conservatisms is, in fact, how they treat their heat 25 transfer coefficient and not including the developing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5849 1 part of the thermal boundary layer and the 2 nodalization that they use.
3 I mean, the data that hes talking about, 4 the process data has lags right in it. I mean, its 5 not really what the transient is. If its a very slow 6 transient, its not bad. If its a very rapid 7 transient, its terrible.
8 JUDGE KENNEDY: Would you like to put a 9 time frame on very slow and very rapid, please? What 10 would very rapid be to you?
11 DR. LAHEY: In seconds.
12 JUDGE KENNEDY: What would very slow be 13 then?
14 DR. LAHEY: Very slow. Hours, I mean, you 15 know, things that go on for a long time. Everything 16 reaches equilibrium. If you go through a lot of the 17 kind of transients that give you the biggest loading, 18 you know, from the thermal hydraulics point of view, 19 theyre fairly fast transients.
20 JUDGE KENNEDY: What would be an event 21 that would operate on the seconds time frame? What 22 sort of accident will we be talking about?
23 DR. LAHEY: What sort of accident, youre 24 asking?
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5850 1 accident? is it a reactor coolant pump trip? Is it 2 a steam line break? Is it a --
3 DR. LAHEY: Well, you -- a number of 4 things can happen fairly rapidly. Scrams happen 5 rapidly. So do breaks, if youre interested in that, 6 but Im more interested here in the kind of -- they 7 have a whole bunch of different transients that they 8 analyze to come up with the net fatigue of a 9 particular component.
10 So, if youre looking at, for example, the 11 coarse spray line nozzle, then these events, they go 12 on and off. Every time youre changing the pressure, 13 you want to reduce the pressure, the spray will go on.
14 And then if thats under control, it goes off and you 15 go back and forth. And those are fairly rapid events.
16 JUDGE KENNEDY: All right. Thank you.
17 Just one for clarification, the discussion that we 18 just had about the thermal hydraulics calculation in, 19 I assume, the WESTEMS code, is that the discussion 20 that we had yesterday about the boundary layer in the 21 front?
22 DR. LAHEY: Yes, sir.
23 JUDGE KENNEDY: So, weve taken a lot of 24 testimony yesterday on this topic.
25 DR. LAHEY: But I wanted to clarify the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5851 1 record, because it sounded like at the end that we 2 were told that dont worry about all this heat 3 transfer stuff, you know, that isnt really the way we 4 do it. But when I look back at all the documents that 5 they quoted, thats the way they do it. On top of it, 6 they get in there and specify what the transients are.
7 JUDGE KENNEDY: Im sorry, is there 8 something wrong with them specifying the transients?
9 DR. LAHEY: No.
10 JUDGE KENNEDY: Oh, okay.
11 DR. LAHEY: You have to determine the 12 transients. I dont have any problem with that. I 13 have a problem with saying that takes care of the 14 issues that I had raised. It does not.
15 JUDGE KENNEDY: Okay. I just want to make 16 sure I understood what you meant. Thanks.
17 MR. AZEVEDO: Your Honor, this is Nelson 18 Azevedo. May I add just one additional point?
19 JUDGE KENNEDY: Ill take one more, sure.
20 MR. AZEVEDO: The primary load for the 21 pressurizer surge line for the pipe is the Delta-T 22 between the top of the pipe and the bottom of the 23 pipe.
24 So, even if you were to assume that these 25 RDDs lag by, say, a few seconds, you wouldnt expect NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5852 1 that to have any measurable impact on the Delta-T from 2 the top of the pipe to the bottom of the pipe.
3 Because whatever the lag is for one, should be the 4 same -- roughly the same for the others.
5 So, again, the primary load is the Delta-T 6 between the top of the pipe and the bottom of the 7 pipe, which introduce a bending moment, and I just 8 dont see how this will have any measurable impact on 9 that parameter.
10 JUDGE KENNEDY: All right. Thank you, Mr.
11 Azevedo.
12 MR. GRAY: Your Honor, may I add one 13 thing, too? This is Mark Gray for Entergy.
14 JUDGE KENNEDY: One last remark.
15 MR. GRAY: Okay. I think its still very 16 important to understand and I dont think its fully 17 understood how these things are being used, but the 18 temperature load thats used in the stress analysis is 19 not the identical temperature thats read from the 20 plant computer data. Its more severe, its more like 21 a design transient, it still uses conservative heat 22 transfer coefficients barring the other discussion, 23 which I wont go back to.
24 And so, the bottom line is we are not 25 using the actual temperature measurements in time that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5853 1 are gathered from that to feed that thermal hydraulic 2 model to load the stress analysis. Thats just not 3 true. We are using something more conservative in 4 these Delta-T bins.
5 JUDGE KENNEDY: And where does that Delta-6 T come from?
7 MR. GRAY: The Delta-T is what we get by 8 binning the read temperatures. So, its the 9 temperature change thats important here.
10 JUDGE KENNEDY: The plant data.
11 MR. GRAY: And it doesnt occur -- these 12 are not scrams. These are not, you know, high-rate 13 transients, for example, in the charging line. This 14 is a heat exchanger.
15 I turn off the letdown, the charging 16 temperature responds -- its a heat exchanger curve.
17 We all have seen those and its not fast. Its 18 relatively slow. Its not seconds even though it is 19 then analyzed in seconds.
20 JUDGE KENNEDY: All right. Thank you.
21 CHAIRMAN McDADE: Okay. Thank you. I 22 think that takes care of our discussion there.
23 Getting back to 38, Ive got a question, Dr. Duquette.
24 I dont want to get into a discussion of 25 the steam generator AMP. Thats been handled by a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5854 1 joint stipulation which I should note was Entergy 2 Exhibit 700, but there are some questions that I had.
3 You indicated that at Indian Point steam 4 generators with a number of plugged tubes may be more 5 susceptible to PWSCC than French reactors. But in the 6 15 years of operation, the steam generator at Indian 7 Point had only 48 out of approximately 13,000 tubes 8 blocked.
9 Why would this be of a consequence? How 10 would this affect the susceptibility to PWSCC?
11 DR. DUQUETTE: Its certainly not going to 12 affect the susceptibility of PWSCC in the divider 13 plate. It has to do with whether or not the crack 14 will progress to the interface between the -- well, 15 the diluted weld, the tube-to-tubesheet weld is the 16 area that would be affected most.
17 And I was not aware of those statistics.
18 And having heard them, I probably would back away from 19 my testimony on that issue.
20 CHAIRMAN McDADE: Okay. Thank you. Just 21 to clarify in that discussion, the discussion of AVB 22 wear and TSP wear, Entergy, could you explain to me 23 just very briefly what AVB wear and TSP wear is?
24 MR. DOLANSKY: This is Bob Dolansky with 25 Entergy. Just to make sure its very clear, thats NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5855 1 Alpha Victor Bravo, AVB. And Tango Sierra Papa, TSP.
2 CHAIRMAN McDADE: Yes.
3 MR. DOLANSKY: AVB stands for anti-4 vibration bar. At the top of the tubes they bend over 5 their U-tubes. So, at the top in the U-bend area they 6 go through a final support plate. And then in the U-7 bend area theyre not supported by a support plate.
8 Instead they are supported by anti-vibration bars, 9 which are inserted between the tubes to make sure that 10 they dont vibrate too much.
11 TSP is tube support plate. So, as you go 12 up from the tubesheet up the straight length of the 13 tubes on both the hot and cold side of the steam 14 generator, it goes through tube support plates. Those 15 plates are placed every so often to provide support to 16 the tubes. So, thats how the straight portion of the 17 tube is kept from vibrating, and the AVB is how the U-18 tube portion of the tube is kept from vibrating.
19 CHAIRMAN McDADE: Okay. Thank you.
20 Dr. Hopenfeld.
21 DR. HOPENFELD: Can I make a comment with 22 respect to just the last sentence before I forget?
23 CHAIRMAN McDADE: Im sorry, Dr.
24 Hopenfeld. Youve got to move to the microphone. I 25 couldnt hear you.
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5856 1 DR. HOPENFELD: Yeah. Can I make a 2 comment with respect to the vibration that hes 3 talking about, I believe, is under normal operating 4 conditions. I dont believe that the AVBs there can 5 really -- were really designed to withheld the steam 6 line break kind of vibration that you can get.
7 CHAIRMAN McDADE: Okay. Thank you.
8 Dr. Hiser, at one point, specifically 9 Question 141 of your testimony, NRC 161, you used the 10 term verification inspection. I just want to make 11 sure I understand what you mean by the term 12 verification inspection.
13 (Pause.)
14 CHAIRMAN McDADE: This is on Page 81 of 15 your pre-file testimony, Question 141 -- or Answer 16 141, fourth line down. You use the term verification 17 inspection.
18 And, again, its just I want to make sure 19 I understand is that a term of art or how exactly is 20 that used?
21 DR. HISER: Actually, I believe its Page 22 61.
23 CHAIRMAN McDADE: Page 61, yes.
24 DR. HISER: Okay. The verification 25 inspection is just an inspection to verify the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5857 1 effectiveness of the water chemistry program. So, 2 its not really a term of art. Its just the way that 3 we laid the words out in that response.
4 CHAIRMAN McDADE: Okay. Thank you. Okay.
5 Dr. Lahey, you submitted testimony that was critical 6 of the inspection methodology acceptance criteria and 7 corrective action criteria for divider plates.
8 In light of the testimony youve heard so 9 far, is there anything you wish to say to elaborate on 10 that testimony?
11 DR. LAHEY: Your Honor, Im more concerned 12 with the tube-to-tubesheet welds. The issue that I 13 was concerned with is the safety issue, which we 14 talked about before. And it has to do with the -- how 15 the impact loads are calculated. We never get any 16 information on that and its very important how they 17 do that.
18 CHAIRMAN McDADE: Okay. Dr. Kennedy, do 19 you have some questions of Dr. Hopenfeld?
20 JUDGE KENNEDY: Yes, I have a couple 21 questions, just loose ends that are dangling around on 22 38. Im going to address the first question to 23 Entergy, but its really a Dr. Hopenfeld question.
24 In the supporting testimony for Contention 25 38, Dr. Hopenfeld asserts that the scope of metal NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5858 1 fatigue analysis should be extended into the steam 2 generator. And I guess first Id like to ask Entergy, 3 is metal fatigue a concern in the steam generator 4 components internal? Im assuming you mean its 5 internals. And if not, why not?
6 MR. AZEVEDO: This is Nelson Azevedo for 7 Entergy. Yes, Your Honor, the steam generators were 8 analyzed for fatigue. In fact, there are fatigue 9 locations in our reports.
10 JUDGE KENNEDY: So, they were analyzed.
11 MR. AZEVEDO: Yes.
12 JUDGE KENNEDY: So, they are -- does that 13 mean theyre within the scope of the fatigue 14 monitoring program?
15 MR. AZEVEDO: They are within the scope of 16 the fatigue monitoring program. Let me just remind 17 you, though, that the secondary side does not see 18 primary coolant. So, the Fen issue that weve been 19 discussing does not apply to the secondary side.
20 JUDGE KENNEDY: So, you wouldnt apply the 21 Fen factor to the secondary side components.
22 MR. AZEVEDO: Thats correct, because 23 thats a primary water side issue.
24 JUDGE KENNEDY: All right. Dr. Hopenfeld, 25 this is the extension into the steam generator, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5859 1 metal fatigue calculations.
2 DR. HOPENFELD: Sir, I would like to have 3 an opportunity, also make a comment regarding the H 4 factor because its extremely important maybe later 5 on, just the H factor that was just discussed a few 6 minutes ago.
7 JUDGE KENNEDY: Can we close out this item 8 and --
9 DR. HOPENFELD: Yeah, okay.
10 JUDGE KENNEDY: Do you have any additional 11 concerns about metal fatigue in the steam generator 12 and whether --
13 DR. HOPENFELD: Well --
14 JUDGE KENNEDY: -- its being managed for 15 aging?
16 DR. HOPENFELD: Yes, because metal fatigue 17 has been experienced in a feed line break. It has 18 been experienced in tubes on the top, the U-bands.
19 And obviously those tubes sit in water. They dont 20 sit in air. So, the same correction factor has to be 21 applied.
22 The fact that the water is not radioactive 23 is completely immaterial. What affects the ASME code 24 does not take in effect of the environment, doesnt 25 take effect in water.
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5860 1 So, thats what the NRC in 1996 or 2 whatever came up with the recommendation or with the 3 requirement that they include correction for the 4 environment. Why not do it to the secondary side 5 where this is the most important part of the plant 6 safety wise?
7 Most of the accidents we have, they were 8 initiated in the secondary side. Most of the damages 9 that we -- or leaks that we have on the secondary 10 side.
11 JUDGE KENNEDY: So, your concern -- is 12 your concern with the need to apply Fen factors to --
13 DR. HOPENFELD: Absolutely.
14 JUDGE KENNEDY: -- the secondary side?
15 DR. HOPENFELD: Thats my whole thing.
16 They have to apply that. Otherwise this is not a 17 fatigue program. This is something else, but its not 18 a fatigue program.
19 JUDGE KENNEDY: I guess --
20 DR. HOPENFELD: I would just want you to 21 understand theres absolutely no reason to -- just the 22 fact that the water is radioactive in one side and the 23 other one isnt, thats just has nothing to do with 24 crack propagation or leakage or anything.
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5861 1 can find out here. I see the NRC in front of us.
2 Your recommendation was to apply the Fen factors to 3 the metal fatigue calculations.
4 Why are they not applied -- or should they 5 be applied to the secondary side components?
6 MR. STEVENS: This is Gary Stevens of the 7 NRC staff. Our guidance is clear that the Fen 8 evaluations are limited to reactor coolant pressure 9 boundary components.
10 JUDGE KENNEDY: So, is it the fact that 11 the function is pressure boundary components, or the 12 fact that they are subjected to a water environment 13 thats on the primary side of the reactor coolant 14 system?
15 MR. STEVENS: Its reactor coolant 16 pressure boundary.
17 JUDGE KENNEDY: That is a pressure 18 boundary.
19 MR. STEVENS: Correct.
20 JUDGE KENNEDY: So, in the case that Dr.
21 Hopenfeld mentioned about the U-tube region of the 22 steam generator tubes, would that constitute a reactor 23 coolant system pressure boundary?
24 MR. STEVENS: This is Gary Stevens of the 25 staff. Im going to defer to one of my colleagues, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5862 1 because Im not a steam generator expert.
2 MR. AZEVEDO: Your Honor, may I correct 3 something I said before? Ive been corrected. The 4 Fens have been applied to all CUFs. I misspoke 5 before.
6 JUDGE KENNEDY: Both primary and 7 secondary?
8 MR. AZEVEDO: That is correct.
9 CHAIRMAN McDADE: Thank you, Mr. Azevedo.
10 JUDGE KENNEDY: Lets go to Mr. Hopenfeld 11 then. Dr. Hopenfeld.
12 DR. HOPENFELD: I would like to understand 13 that. I havent seen any Fen correction into the 14 secondary side. Would you please provide us with some 15 reference to it?
16 There are references on the primary side, 17 but there was nothing on the secondary side. They 18 kept repeating in the testimony, this is brand now.
19 they kept repeating in the testimony that theyre not 20 doing the secondary side.
21 JUDGE KENNEDY: Lets give Mr. Azevedo a 22 chance to respond to that.
23 MR. GRAY: This is Mark Gray on --
24 JUDGE KENNEDY: Or Mark Gray.
25 MR. GRAY: -- behalf of Entergy. In the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5863 1 process of addressing the RAIs on the environmental 2 fatigue, Entergy did do a screening process to 3 determine limiting locations. And that was applied to 4 all of the CLB locations that had a fatigue usage 5 calculation.
6 So, even though I agree with Mr. Stevens 7 that the regulation does not apply to secondary side 8 components, because these had a CLB, Entergy also 9 included those steam generator locations that had a 10 CUF calculation in the screening process to determine 11 the limiting locations for environmental fatigue.
12 JUDGE KENNEDY: Is there an exhibit within 13 the testimony that --
14 MR. GRAY: Yes.
15 JUDGE KENNEDY: -- you would point to for 16 that?
17 MR. GRAY: As soon as I put my glasses on.
18 Wait a second. Thats Entergy 683.
19 JUDGE KENNEDY: All right. Thank you.
20 Dr. Hopenfeld --
21 DR. HOPENFELD: Yes.
22 JUDGE KENNEDY: -- did you hear the 23 citation?
24 DR. HOPENFELD: Im sorry?
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5864 1 that Mr. Gray gave?
2 DR. HOPENFELD: No, I didnt. I heard 3 what he said that they did the CUFs for the secondary 4 side.
5 JUDGE KENNEDY: Entergy 683 is what hes 6 referring to.
7 DR. HOPENFELD: I dont -- Ill have to 8 check. I dont --
9 JUDGE KENNEDY: I understand.
10 DR. HOPENFELD: I dont have it in my 11 mind. But what I would like to say that I brought up 12 this issue of effect of geometry change and the stress 13 concentration. This is more important on the 14 secondary side, because its all over, because it is 15 subjected to FAC.
16 And those of you that were at the FAC 17 hearing, you saw what kind of surfaces we have there, 18 what kind of geometry changes we have there. So, I 19 havent seen any calculation to indicate that that was 20 taken in account.
21 Now, when the plant was designed, they 22 didnt have any geometry changes on the secondary 23 side.
24 JUDGE KENNEDY: I guess Ill turn to 25 Entergy. I thought I heard either earlier today or NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5865 1 yesterday in regard to stress concentration factors 2 that geometry changes were the major consideration in 3 the application of this concentration package.
4 Is that still true?
5 MR. AZEVEDO: Well, yeah. I think were 6 talking about different geometry changes, though. The 7 geometry changes that I was talking about was going 8 from a thin section to a thick section, for example.
9 Thats a geometry change.
10 I believe the geometry change thats being 11 discussed now is changes from the way the plant was to 12 what it is currently. So, the thicknesses changed 13 over time perhaps as a result of phenomena like flow 14 accelerator corrosion or some other phenomena. I 15 believe thats whats being discussed right now.
16 JUDGE KENNEDY: Would that be a situation 17 where the stress concentration factors would be 18 applicable?
19 MR. AZEVEDO: Well, let me just say that 20 the -- if we are talking about flow accelerator 21 corrosion, which I dont know that we are, but if we 22 are, first of all, this was discussed during the flow 23 accelerator corrosion issue, but that is only 24 applicable to balance-of-plant piping. And that 25 piping was not designed to the same requirements as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5866 1 the piping that weve been discussing, the components 2 weve been discussing.
3 So far the fatigue calculation that weve 4 been discussing are mandated by ASME Section 3. The 5 balance-of-plant piping that would be susceptible to 6 flow accelerator corrosion, thats designed to a P31.1 7 code, which is totally different, does not require an 8 explicit fatigue analysis. Fatigue cycles are handled 9 differently by stress reduction factors and that is a 10 totally different type of analysis.
11 JUDGE KENNEDY: I appreciate that, Mr.
12 Azevedo. I was presuming we were talking about metal 13 fatigue.
14 Dr. Hopenfeld, were you addressing that in 15 regard to metal fatigue?
16 DR. HOPENFELD: Yeah, I was addressing 17 metal fatigue. Ill give you an example so maybe you 18 can see where Im coming from. Lets say just off the 19 top of my head, lets say that the J-tube, that would 20 be a good example, because the flow comes in there 21 high velocity and turns around and it starts eroding 22 around the band.
23 So, you have high erosion and you have 24 very abrupt changes in the --- around the band in the 25 surface in the thickness. These are concentration NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5867 1 factors that has to be taken in account.
2 Another affect, which I didnt know until 3 we had the meetings last -- two years ago, that some 4 of the components they have, have extremely huge 5 imperfection on the surface. I think it was called 6 dilation, but they were huge, which we were told that 7 they accept -- they escaped the initial screening and 8 they were in the plant.
9 Because when I brought up the question of 10 that this was a result of corrosion, say, no, thats 11 the way that we got it from the factory. We just 12 didnt catch it in time. NRC didnt catch it either, 13 but there wasnt one component. There were several.
14 Now, these are concentration factors. You 15 have to take into account when they designed the 16 plant, they didnt know that they had all these 17 components with dilation to them.
18 JUDGE KENNEDY: Are these components 19 within the scope of license renewal, Dr. Hopenfeld?
20 DR. HOPENFELD: Well, theyre on the 21 secondary side.
22 JUDGE KENNEDY: Are they within the scope 23 of license renewal?
24 DR. HOPENFELD: I think anything that is 25 metal fatigue, wouldnt that be a scope or a license NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5868 1 -- anything metal fatigue, in my mind, is a scope --
2 within the license renewal.
3 JUDGE KENNEDY: Im not sure, but I think 4 Entergy knows. Mr. Azevedo, lets just take the J-5 tubes. Would they be within the scope of license 6 renewal for Indian Point? Do you have J-tubes?
7 MR. AZEVEDO: Your Honor, this is Nelson 8 Azevedo. Yeah, we do have J-tubes. They are part of 9 the steam generator. So, I would consider part of 10 license renewal.
11 JUDGE KENNEDY: So, theyre within the 12 scope.
13 MR. AZEVEDO: Yes.
14 JUDGE KENNEDY: Do you have a response to 15 Dr. Hopenfelds concern about these factors?
16 MR. AZEVEDO: The only thing I can say is, 17 you know, the J-tubes are part of the secondary side 18 of the steam generators. Theyre managed by the steam 19 generator program. We do, do periodic inspections.
20 We have no indication there was any significant 21 degradation going on. And Im not sure what else I 22 can say.
23 JUDGE KENNEDY: What sort of aging 24 mechanisms are accounted for in the steam generator 25 program? What sort of effects are looked for?
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5869 1 MR. COX: This is Alan Cox. The typical 2 aging effect for the secondary side where you dont 3 have to deal with the effects of radiation would be 4 loss of material and cracking due to various 5 mechanisms.
6 JUDGE KENNEDY: All right. Thank you.
7 DR. HOPENFELD: Can I make one comment 8 here?
9 CHAIRMAN McDADE: Dr. Hopenfeld.
10 DR. HOPENFELD: I hear that the answer is 11 that this is managed by a different program. Stress 12 corrosion cracking is managed by a different program.
13 Metal fatigue is a different program. These programs 14 are related. They are not completely unrelated. A 15 crack doesnt know whether its stress corrosion was 16 designated in one program or fatigue in another 17 program.
18 The same thing, the J-tube doesnt know 19 that they have been divided. Its a system. Its a 20 management kind of thing that you have to look at the 21 whole entire plant, not just in pieces here and there.
22 Thats why things falling in between the cracks.
23 MR. DOLANSKY: Judge Kennedy, this is Bob 24 Dolansky.
25 JUDGE KENNEDY: Mr. Dolansky.
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5870 1 MR. DOLANSKY: Can I just state something, 2 please?
3 JUDGE KENNEDY: Go ahead.
4 MR. DOLANSKY: Bob Dolansky for Entergy.
5 Im not sure about the metal fatigue part, but I can 6 tell you like if we talk about J-tubes in the steam 7 generators, this last outage at each steam generator 8 we went into the secondary side of the steam 9 generator, we performed video inspections of the 10 inside of the J-tubes on a representative sample of 11 the J-tubes, and we did not see any evidence of any 12 kind of corrosion or erosion or any evidence of any 13 cracking in the J-tubes.
14 JUDGE KENNEDY: Okay. Thank you.
15 CHAIRMAN McDADE: Dr. Lahey, you had an 16 issue?
17 DR. LAHEY: Yes. While were talking 18 about steam generators and fatigue, New York State 19 000559 is a -- and Table 4.3-10, thats a part of the 20 Indian Point license renewal application. And in this 21 table, the -- for IP3 the CUF, its not designated as 22 CUFen, but its the CUF, is 1.0 for the main feedwater 23 nozzle.
24 Now, its our understanding that when the 25 -- when something reaches 1.0, then action has to be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5871 1 taken, but we have heard nothing more about this. And 2 so, its not clear to us where that stands. And its 3 an important thing, because it can induce all kinds of 4 other problems if it breaks.
5 MR. COX: This is Alan Cox for Entergy.
6 I just want to point out that the CUF, the C-U-F, has 7 not reach 1.0. If every transient thats counted and 8 considered in that analysis reached its assumed value, 9 then you would reach 1.0. You still would not have 10 exceeded 1.0, but that -- if that was to happen at 11 all, it would be very near the end of the PEO and 12 were monitoring the number of those transients to 13 ensure that they dont exceed those numbers.
14 CHAIRMAN McDADE: Okay. Dr. Hopenfeld, go 15 ahead.
16 DR. HOPENFELD: You have one. Its 17 physically impossible that its not going to be at 18 least 10001 if we put -- if you put the correction 19 factor.
20 If you look at the equation I have 21 somewhere, the CUFen, the corrected CUF, it is 22 multiplied by Fen, which is always more than one. So, 23 if you look at that one, its, you know, its all 24 probably two or three.
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5872 1 for a second?
2 JUDGE KENNEDY: Please.
3 MR. AZEVEDO: I dont have the exhibit 4 here in front of me, but I can tell you for the 5 feedwater nozzles, what we did was we calculated --
6 the feedwater nozzles are different from the other 7 components. What controls is the number of hours in 8 standby where youre at aux feedwater, you have the 9 cold feedwater going in and the hot feedwater coming 10 out. And so, that number that you talked about gave 11 us the allowable number of hours, which we now track.
12 So, that gives us the allowable number of 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> that we can operate in Mode 2. So, obviously if 14 we approach that, we will have to redo the 15 calculation, but thats the reason why youll see a 16 high CUF to give us the highest number of allowable 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />.
18 JUDGE KENNEDY: Just going back to the 19 testimony yesterday, and I guess this -- I don want 20 to get into a discussion about whether its 1.001 or 21 -- but yesterday the testimony was that all CUFs in 22 the plant are less than one.
23 I mean, I dont know if your -- I guess 24 what Im curious is what does that mean in the context 25 of now in covering a component with a CUF of one, are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5873 1 there others that are higher?
2 And I do recognize that were not at the 3 end of life yet, but --
4 MR. AZEVEDO: I, you know, the allowable 5 is 1.0 or less. So, 1.0 would still be accepted.
6 Again, I dont have the actual list in front of me, 7 but I believe the feedwater nozzle is the special 8 case.
9 JUDGE KENNEDY: Yeah, I guess Im just 10 being a little sensitive to yesterday we heard a 11 couple of individuals quote numbers that all CUFs for 12 Indian Point 2 and 3 are less than one. And Im just 13 wondering how we reconcile that with this.
14 MR. ONEILL: Your Honor, this is Mr.
15 ONeill. Is there any way we could pull this exhibit 16 up just so the witnesses could see it?
17 JUDGE KENNEDY: Thats a good point. Im 18 sure we can.
19 MR. ONEILL: I believe this, and Dr.
20 Lahey can correct me if Im wrong, did you say it was 21 New York State 00559?
22 DR. LAHEY: Until now, what we have heard 23 is we fight hard to -- as they get darn close to 1.0, 24 to keep below 1.0, because 1.0 is the action point.
25 So, this seems like 1.00.
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5874 1 JUDGE WARDWELL: If I understand you 2 correctly, Mr. Azevedo, are you saying that from this 3 table, 4.3-10, that the way you handle main feedwater 4 nozzle is you set the cumulative use factor to one, 5 calculate out the number of hours that it can be 6 operated, because it is on standby a lot, and then 7 youre tracking those hours to make sure it stays 8 below that number of hours that is designated by the 9 1.0?
10 MR. AZEVEDO: Well, yes. The only thing 11 I need, I need to verify is whether we in fact set it 12 to 1.0 or some other number. I will need to verify 13 that, but thats -- in essence, thats correct.
14 MR. TURK: This is Sherwin Turk. I hope 15 I dont mess this up, but my notes indicate --
16 CHAIRMAN McDADE: Me too.
17 MR. TURK: Pardon me?
18 CHAIRMAN McDADE: Me too.
19 MR. TURK: Early in the discussion 20 yesterday, I dont know if this is the testimony 21 youre thinking of, but I believe it was Mr. Gray --
22 or, Im sorry, Mr. Cox who said the limit is 1.0 and 23 the recalculated number can be up to that number.
24 MR. SIPOS: Excuse me, Your Honor. This 25 is John Sipos from the State of New York. I have --
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5875 1 Im going to object to what Mr. Turk is doing right 2 now.
3 MR. TURK: Im reading my notes, Mr.
4 Sipos. You can read yours.
5 CHAIRMAN McDADE: The objection is noted.
6 The objection is overruled. I will allow Mr. Turk to 7 continue.
8 MR. TURK: I cant speak for the 9 witnesses, Your Honor. There may be some other 10 testimony as well.
11 CHAIRMAN McDADE: Whats your point, Mr.
12 Turk, succinctly?
13 MR. TURK: I was trying to -- because we 14 dont have daily transcripts here, I was trying to 15 determine what was said actually yesterday.
16 CHAIRMAN McDADE: Okay. And the witnesses 17 can correct me as --
18 MR. COX: This is Alan Cox with --
19 CHAIRMAN McDADE: Judge Kennedy indicated 20 that his recollection is that the testimony was that 21 all of the CUFs were below one. I dont recall what 22 I had heard, but I had recalled seeing this particular 23 table, 4.3-10, and the 1.0.
24 And whatever was said, what I had heard 25 was that it was one or below. And thats the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5876 1 testimony of Mr. Nelson Azevedo that you viewed it as 2 1.0 was within spec.
3 MR. AZEVEDO: Thats correct, Your Honor.
4 CHAIRMAN McDADE: And I just -- and just 5 to clarify in response to Judge Wardwells question 6 that this is something that would be monitored, you 7 know, since this is not in use constantly that you 8 would monitor the number of hours that it would be 9 used to make sure that, in fact, those number of hours 10 were not exceeded and, therefore, the CUF did not go 11 above 1.00.
12 MR. AZEVEDO: Thats correct.
13 CHAIRMAN McDADE: Okay.
14 MR. ONEILL: Your Honor, this is Mr.
15 ONeill. I just think we also need to be mindful of 16 the context in which those discussions may have 17 occurred. This appears to be the original LRA, right?
18 And that number --
19 CHAIRMAN McDADE: Excuse me.
20 MR. ONEILL: Okay.
21 CHAIRMAN McDADE: You talk to us, and then 22 well talk to them.
23 MR. ONEILL: Okay. Thanks, Your Honor, 24 but I just want to emphasize that this appears to be 25 the original LRA. And the discussion yesterday may NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5877 1 have been taking place in the context of, you know, 2 re-analyses, CUFen analyses that were done 3 subsequently with respect to a primary side, you know, 4 pressure boundary components and perhaps not secondary 5 side components as addressed in the original LRA.
6 CHAIRMAN McDADE: I believe it was 7 broader, but I think that the testimony of Mr. Azevedo 8 today clarifies what the position is of Entergy.
9 So, at this point the Board has basically 10 run out of questions. We have answered those 11 questions that we had, clarified what we thought 12 needed to be clarified, which then brings us back to 13 the question that I posed at the beginning of todays 14 session. And, again, focusing on the limitations that 15 I put there of additional questions to correct or 16 clarify testimony by your own witness that would 17 otherwise be both material and misleading, or to point 18 out testimony of opposing parties witnesses that was 19 incorrect or misleading and that has not already been 20 inquired into or otherwise addressed by the Board.
21 With that limited universe, does Entergy 22 have additional questioning that they feel is 23 appropriate at this time?
24 MR. BESSETTE: Your Honor, we do 25 appreciate the opportunity. We believe the board has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5878 1 done some thorough interrogation of the witnesses. We 2 would have just a couple of wrap-up questions, but we 3 would suggest if we could just have even just 20 4 minutes to caucus. We were doing our homework at 5 lunch.
6 If that would be appropriate, again, I 7 think it would be a matter of minutes.
8 CHAIRMAN McDADE: Okay. And from New 9 York, whats your view?
10 MR. SIPOS: All right. This is going to 11 take a little while. John Sipos, State of New York.
12 Id like to review what has happened in this 13 proceeding with Track 1 and Track 2.
14 In Track 1 on August 8, 2012, the State of 15 New York filed a motion for cross examination. It was 16 over the objection of the other -- the applicant and 17 the federal regulator. And that was pursuant to 18 Atomic Energy Act Section 274(l).
19 Your Honors and the Commission allowed 20 limited attorney questioning at Track 1. There was an 21 opportunity for the parties to file a request either 22 under Part 2, or under the Atomic Energy Act, again, 23 Section 274. And 274 is a specific reg for a 24 sovereign state such as New York.
25 New York did not file such a motion. No NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5879 1 other party filed such a motion. There was even a 2 gentle reminder from the Board in one of the 3 scheduling notes in September, I believe.
4 So, the State is surprised that at this 5 late time in this Track 2 hearing on the fourth day of 6 the hearing, there is now a suggestion that the 7 parties could conduct cross examination or examination 8 of their own witnesses or follow-up examination of 9 other parties witnesses. So, the State has a very 10 serious concern and objection as to that.
11 CHAIRMAN McDADE: Okay. Mr. Sipos, during 12 the Track 1 contentions, the Board allowed basically 13 what I was just suggesting today at the request of New 14 York. And New York not only had no objection, it, in 15 fact, went ahead and did do the questioning as 16 suggested, which the Board found to be helpful to it 17 in reaching its initial decision.
18 There has been no further discussion from 19 any of the parties with regard to whether the parties 20 wished to ask any questions, present any questions 21 other than in the written presentation of questions 22 that was done by all of the parties.
23 And my question to you, I guess, at this 24 point is if in the Track 1 contentions this was a 25 procedure that New York requested and utilized, where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5880 1 is the prejudice to New York in the Track 2 2 contentions to allow a similar limited questioning 3 that would be available to New York and Riverkeeper to 4 the same degree that it would be available to any 5 other party?
6 MR. SIPOS: Your Honor, John Sipos for the 7 State of New York. Id like to respond with a few 8 points.
9 The motion that was filed on August 8, 10 2012, was for Track 1 and Track 1 only. It did not 11 extend to other aspects of the proceeding and we were 12 already --we had already split or bifurcated the 13 proceeding. That is my recollection.
14 Secondly, there was in the scheduling 15 order, or the modified scheduling order, an 16 opportunity for the parties, like there was in Track 17 1, to so request the opportunity for attorney-18 initiated questioning of the witnesses. And that 19 deadline came and went, I believe, in the middle of 20 October.
21 To my knowledge -- well, I can speak for 22 the State of New York. The State of New York in that 23 time did not so avail itself of that opportunity and 24 I am not aware that any other party filed a motion 25 that day seeking that pathway forward.
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5881 1 So, in talking about --
2 CHAIRMAN McDADE: I understand, Mr. Sipos.
3 MR. SIPOS: -- the prejudice ---
4 CHAIRMAN McDADE: I understand. My 5 question -- you had said that before. My question to 6 you is not to repeat what you had said before, but it 7 was specifically to address how if this was a 8 procedure that was requested and utilized by New York 9 in Track 1 for the Board to sua sponte allow this 10 based on the Boards determination that it could 11 potentially be helpful to us, where the prejudice to 12 New York arises.
13 MR. SIPOS: Yes, I was going to get to 14 that. The prejudice to New York arises from hearing 15 about this for the first time on the fourth day of the 16 hearing. There was no prejudice the last time, 17 because the State moved in a timely, early manner and 18 there were -- there was authorization from the Board 19 and the commissioner.
20 This -- today is the first time I, as a 21 State of New York representative, heard that there 22 will be this possibility. If I had known in October, 23 if I had known in mid-October/late October, the State 24 would have prepared itself and operated differently in 25 this Track 2 proceeding. So, heres --
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5882 1 CHAIRMAN McDADE: And, Mr. Sipos, again 2 going back to my preface to this, you at least from 3 the standpoint of the board could not have prepared 4 yourself differently because this is not open-ended 5 questioning.
6 This is questioning that as Ive indicated 7 a couple of times now, is very limited. It is based 8 only on the verbal/oral testimony that has come in at 9 this particular proceeding where if you believe that 10 one of your witnesses, and you may well not, but 11 believe that one of your witnesses offered testimony 12 that you believed might be either incorrect or somehow 13 misleading, that you would have the opportunity while 14 the witnesses are here, while we are here, to help 15 correct the record.
16 Likewise, while your witnesses are here if 17 you believe that there was testimony, verbal 18 testimony, not the written testimony that came in, not 19 the pre-filed testimony, not the exhibits, but the 20 testimony of the witnesses that you believed was 21 either incorrect or somehow misleading that could send 22 the Board in the wrong direction, that you would be 23 given a brief opportunity to make inquiry into that.
24 And, again, based only on what has gone on here in the 25 hearing over the last four days.
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5883 1 So, it doesnt reflect anything with 2 regard to the written testimony where youve had the 3 opportunity to read and to submit written rebuttal and 4 rebuttal testimony, as well as rebuttal statement of 5 position, but its solely limited to what has gone on 6 here in the hearing.
7 And the question again in that limited 8 circumstance and, you know, Ive got an open mind on 9 this, but I just -- as I sit here right now, I dont 10 see what the prejudice would be to New York to afford 11 you that opportunity that you may or may not take 12 advantage of, but, likewise, to allow Entergy the 13 opportunity, as was explained, for a very few limited 14 number of questions that would serve the purpose, you 15 know, for which I proffer this.
16 Again, you can choose to take advantage of 17 it, or not, and thats fine. The question then would 18 arise if Entergy chooses to take advantage of it, how 19 is New York prejudiced given the limitations that I 20 have put on their ability to ask questions? How would 21 New York be prejudiced by that?
22 MS. SUTTON: Your Honor, this is Kathryn 23 Sutton for the applicant.
24 CHAIRMAN McDADE: Excuse me, Ms. Sutton.
25 Let me just get this from Mr. Sipos first.
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5884 1 MR. SIPOS: Judge, you are probably 2 hearing some frustration on my part. My understanding 3 coming into this proceeding having never been in an 4 NRC proceeding, was that the rules were changed in 5 2004 and there is the Citizen Action Network decision 6 from the First Circuit. And that before that time 7 there was allowance for attorney questioning along 8 with discovery. And that the 2004 rulemaking in Part 9 2 changed it.
10 So, this is -- and New York understands 11 rules change. And as we said eight years ago, as 12 Deputy Attorney General Mylan Denerstein said, well 13 play on the court that the NRC provides for us, on the 14 playing field that NRC provides for us.
15 CHAIRMAN McDADE: Okay. Am I correct, Mr.
16 Sipos, and, again, my recollection is that with Track 17 1 New York made the request.
18 MR. SIPOS: Yes.
19 CHAIRMAN McDADE: We granted the request.
20 The opposing party appealed it and the Commission 21 upheld the ruling of the Board to allow it.
22 MR. SIPOS: That is correct.
23 CHAIRMAN McDADE: Now, let me also go 24 back. Ms. Sutton, Im not quite certain what you 25 wanted to say. I have a strange feeling it might have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5885 1 been that its not worth the aggravation.
2 MS. SUTTON: Sort of along those lines, 3 Your Honor. We were responding to the sua sponte 4 request that you posed today.
5 CHAIRMAN McDADE: Sua sponte offer, not 6 necessarily a request.
7 MS. SUTTON: Yes, a request for an answer, 8 an offer. Were willing to withdraw that response and 9 just rest the case.
10 MR. TURK: Your Honor, may I speak for a 11 moment for the staff?
12 CHAIRMAN McDADE: Yeah, very briefly.
13 Then were going to take a quick recess and come back.
14 MR. TURK: I think the only issue is 15 whether the Board would find it helpful for the 16 parties to do any further questioning perhaps only of 17 their own witnesses if for no other reason than simply 18 to clarify statements that may have been made.
19 And Mr. Sipos is correct that the rules 20 were changed in 2004. But as he pointed out when he 21 was arguing for the right to cross examination, the 22 rules do permit the board to allow questioning when 23 they find it will help them in reaching their 24 decision.
25 MR. SIPOS: Is that --
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5886 1 CHAIRMAN McDADE: We are going to take a 2 very brief recess. Were going to recess for about 10 3 minutes and then we will come back and either have 4 further discussion on this or, you know, recess and 5 close the hearing. So, were going to stand in recess 6 for 10 minutes.
7 (Whereupon, the proceedings went off the 8 record for a brief recess at 2:29 p.m. and resumed at 9 2:38 p.m.)
10 CHAIRMAN McDADE: Please be seated. Okay.
11 The hearing will come to order. I didnt give Ms.
12 Brancato a chance to be heard on this. Do you wish to 13 be?
14 MS. BRANCATO: Yes, thank you. First, 15 briefly, prior to the discussion about counsel 16 pursuing clarifying questions, I just wanted to point 17 out I believe Dr. Hopenfeld had indicated he wanted to 18 make a statement and it was put on hold and shelved.
19 So, if youre inclined to give him the opportunity to 20 make one last comment that he had indicated --
21 CHAIRMAN McDADE: To make a statement 22 regarding what?
23 MS. BRANCATO: It was about a particular 24 issue that had been discussed. If Your Honors wanted 25 to --
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5887 1 CHAIRMAN McDADE: Dr. Hopenfeld, what is 2 the topic?
3 DR. HOPENFELD: First, Id like to comment 4 its extremely important. I started and I thought I 5 would get another opportunity to talk about it. And 6 it has to do with the -- has to do with the factor of 7 three uncertainty in the Fen calculations.
8 What the statement was made yesterday, all 9 this was taken in the code. Its absolutely wrong.
10 That Fen isnt uncertainty data. It has nothing to do 11 with the code. As a matter of fact, its not a factor 12 of three, its a factor of six, but I just didnt want 13 to get into more detail.
14 The reason its a factor of six because 15 the Fen -- and I can go through the numbers with you.
16 The Fen -- but I dont want to get into -- the main 17 thing for the record I want to put in what the 18 gentleman said is absolutely misleading, is incorrect 19 that Fen has nothing to do -- the uncertainty of Fen 20 have nothing to do with the ASME code.
21 ASME code doesnt know anything about Fen.
22 Fen is something that was devised by the NRC by 23 Argonne. It has nothing to do with the code. Those 24 uncertainties are not -- the table that he was talking 25 about, he was talking about the margins which were due NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5888 1 to the variations in the surface roughness specimen 2 counting loads, but has nothing to do with this, what 3 I was talking about.
4 You can go through the basic -- the best 5 thing to do, to call the people at Argonne. They 6 developed this. Ask them. Thats all.
7 CHAIRMAN McDADE: And what was the other 8 point, Dr. Hopenfeld?
9 DR. HOPENFELD: Okay. My other point is 10 maybe -- it will take a little bit more time.
11 CHAIRMAN McDADE: Excuse me. The other 12 point you said will take some time?
13 DR. HOPENFELD: Yeah, little bit more 14 time.
15 CHAIRMAN McDADE: Before you get into the 16 point, just tell me what it is.
17 DR. HOPENFELD: It has to do with H star.
18 CHAIRMAN McDADE: With what?
19 DR. HOPENFELD: The H star, the 19 inches 20 of height which allows -- which assumes that this area 21 is not a safety area and we dont have to get -- we 22 dont have to inspect it or we dont have to inspect 23 it as often.
24 CHAIRMAN McDADE: Okay. I think, Dr.
25 Hopenfeld, Im going to cut you off here. That is the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5889 1 focus of a license amendment. Whether or not that 2 license amendment was appropriately granted or not is 3 outside the scope of this proceeding. So, I think 4 that we have a good understanding of what it is from 5 the testimony, and also from the documents that were 6 presented.
7 And to a very large degree, that 8 particular issue is outside the scope of this 9 proceeding because it was the subject of a license 10 amendment. But thank you, Dr. Hopenfeld.
11 MS. SUTTON: Your Honor, Kathryn Sutton 12 for the applicant. Also, with respect to New York 38 13 prior to the break, Mr. Azevedo made a statement that 14 he would like to correct on the record.
15 CHAIRMAN McDADE: Okay. Thank you, Ms.
16 Sutton. Mr. Azevedo.
17 MR. AZEVEDO: Yes, Your Honor. This is 18 Nelson Azevedo. This relates to the answer to Judge 19 Kennedy, I believe it was, whether we applied Fens to 20 the secondary side. And at first I said we did not, 21 and then I corrected myself. Turns out I was right 22 the first time.
23 The Fen correction factors were 24 specifically specified for the primary side. Its for 25 primary waters, not for the secondary waters. So, we NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5890 1 did not apply those primary water Fens to the 2 secondary side CUFs.
3 CHAIRMAN McDADE: Okay. Thank you, sir.
4 So, you thought you made your first mistake of your 5 life, and you found out you didnt.
6 MR. AZEVEDO: I wish it was the first one.
7 CHAIRMAN McDADE: Okay. Ms. Brancato, do 8 you have any comments on Mr. Sipos objection?
9 MS. BRANCATO: Yes. Riverkeeper is 10 generally in support of this position of the State of 11 New York. In the absence of motions in accordance 12 with the Boards scheduling order, we dont 13 particularly think questions from the parties is 14 necessarily appropriate.
15 CHAIRMAN McDADE: Okay. Thank you.
16 MS. BRANCATO: And just that Riverkeeper 17 would prefer the alternative that you proposed if we 18 are to ask clarifying questions, that we would compile 19 them, submit them to you, and then you could determine 20 whether such clarifications are needed.
21 CHAIRMAN McDADE: Okay. I think the 22 situation given your position, given the position 23 stated by Entergy, we are going to sustain Mr. Sipos 24 objection. And at this point in time, were going to 25 terminate the evidentiary hearing on the Track 2 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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5891 1 contentions.
2 What we would direct of the parties and if 3 this schedule is not appropriate, let us know, and you 4 can let us know by email, we would ask the parties to 5 get together sometime within the next two weeks and by 6 the close of business, not Thanksgiving week, but the 7 week after that if you could, if possible, come up 8 with a proposed schedule for post-trial briefing, the 9 submitting of proposed findings of fact and 10 conclusions of law, et cetera, that were not looking 11 to get anything other than just a proposed schedule, 12 which, if possible, you know, if it can be done by 13 agreement between the parties. So, if you can get 14 together and discuss it and, if possible, present a 15 joint suggestion to us.
16 Mr. Sipos.
17 MR. SIPOS: And, Your Honor, would that 18 schedule include the possibility for the parties to 19 review the transcript from the court reporter? We did 20 that in Track 1 after the hearings.
21 CHAIRMAN McDADE: Okay. Im not really 22 sure what you mean.
23 MR. SIPOS: Like an errata sheet. The 24 last time -- sometimes theres perhaps typos in the 25 transcript. And I think last time --
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5892 1 CHAIRMAN McDADE: The answer is yes. And 2 Im sorry I just misunderstood you, but were not 3 looking for the errata sheet by a week from Friday.
4 All were looking for is from you to come up with a 5 proposed schedule, you know, realistically by when, 6 you know, can this be done.
7 MR. SIPOS: Thank you.
8 CHAIRMAN McDADE: Yes, and any other 9 proposed issues that come up post-trial. Again, what 10 were looking for is just a proposed schedule.
11 MS. SUTTON: Yes, understood, Your Honor.
12 MR. HARRIS: Understood, Your Honor.
13 CHAIRMAN McDADE: Okay. Is there anything 14 else that the staff believes should be taken up at --
15 before we close this evidentiary hearing?
16 MR. HARRIS: No, Your Honor.
17 CHAIRMAN McDADE: Entergy?
18 MS. SUTTON: No, Your Honor, other than to 19 -- on behalf of Entergy and Westinghouse to thank the 20 Board and all of the support here at the hearing.
21 MR. SIPOS: Similarly from the State of 22 New York wed like to thank Your Honors and your staff 23 for checking up here and spending a week in the Empire 24 State.
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5893 1 as well, of course.
2 CHAIRMAN McDADE: And before we do break, 3 I would like to, you know, first of all very much 4 compliment all of the witnesses. I am extremely 5 impressed with your ability to answer the questions 6 that we have posed.
7 Weve had the opportunity to go through 8 the documents and read them and focus on a particular 9 question. Youre sitting there not knowing what 10 questions were going to ask. So, these questions 11 although youre very familiar with the record, come 12 out of the blue. And your ability to locate the 13 documents that are of reference and to answer the 14 questions is truly impressive and I want to thank you 15 very much.
16 And I also want to comment with regard to 17 counsel, you know, we have had significant filings 18 both in the preparation of the pre-trial testimony, 19 and also in the preparation of the statements of 20 position that were very helpful. And a lot of work 21 went into that and they were all done in an extremely 22 professional way that made this proceeding much easier 23 for the Board. So, again, I want to thank you very 24 much. We really appreciate -- recognize and 25 appreciate your work in that regard.
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5894 1 This evidentiary hearing on the Track 2 2 contentions is now closed. Thank you.
3 (Whereupon, the hearing in the above-4 entitled matter concluded at 2:48 p.m.)
5 6
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