ML082321093
| ML082321093 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee  |
| Issue date: | 07/22/2008 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | NRC/SECY/RAS |
| SECY RAS | |
| References | |
| 50-271-LR, ASLBP 06-849-03-LR, NRC-2296, RAS M-184 | |
| Download: ML082321093 (300) | |
Text
P/46- H- IgzL/
Official Transcript of Proceedings NUCLEAR REGULATORY COMMISSION
Title:
Entergy Nuclear Vermont Yankee Docket Number: 50-271-LR; ASLBP No. 1J6-849-03-LR Location: Newfane, Vermont DOCKETED USNRC August 15, 2008 (4:00pm)
Date: Tuesday, July 22, 2008 OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF Work Order No.: NRC-2296 Pages 880-1177 NEAL R. GROSS AND CO., INC.
Court Reporters and Transcribers 1323 Rhode Island Avenue, N.W.
Washington, D.C. 20005 (202) 234-4433 9-
880 iI UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMhISSION
+ + + + +
3 4 Ai04iZC SAFETY AND LICENSING BOARD 5 HEARING 6
7 In the Matter of:
8 ENTERGY NUCLEAR VERMONT 9 YANKEE, LLC Docket No. bu-271-LR 10 and ASLB No. 06-849-03-LR 11 ENTERGY NUCLEAR OPERATIONS, 12 INC. (Vermont Yankee Nuclear 13 Power Station) 14 15 Tuesday, July 22, 2008 16 17 Windham County Superior Court 18 7 Court Street 19 Newfane, Vermont 20 21 BEFORE:
22 ALEX S. KARLIN, Chair, Administrative Judge 23 RICHARD E. WARDWELL, Administrative Judge 24 WILLIAM REED, Administrative Judge 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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881 1 APPEARANCES:
2 On Behalf of Entergy Nuclear Vermont Yankee, LLC 3 and Entergy Nuclear Operations, Inc.:
4i DAVID R. LEWIS, ESQ.
5 MATIAS F. TRAVIESO-DIAZ, ESQ.
6 ELINA TEPLINSKY, ESQ.
7 of: Pillsbury Winthrop Shaw Pittman LLP 8 2300 N Street, N.W.
9 Washinqton, D.C. 20037-1128 10 11 On Behalf of the Nuclear Regulatory Commission:
12 LLOYD B. SUBIN, ESQ.
13 DAVID E. ROTH, ESQ.
14 MARY C. BATY, ESQ.
15 JESSICA A. BIELECKI, ESQ.
16 Office of the General Counsel 17 Mail Stop - 0-15 D21 18 U.S. Nuclear Regulatory Commission 19 Washington, D.C. 20555-0001 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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882 1 On Behalf of the New England Coalition:
2 KAREN L. TYLER, ESQ.
3 ANDREW LAUBVOGEL, ESQ.
4 of: Shems Dunkiel Kassel & Saunders PLLC 5 91 College Street 6 Burlington, Vermont 05401 7
8 On Behalf of the State of Vermont:
9 SARAH HOFMANN, ESQ.
10 Director for Public Advocacy 11 Department of Public Service 12 112 State Street - Drawer 20 13 Montpeliei, Vermont 05620-2601 14 15 ANTHONY Z. ROISMAN, ESQ.
16 National Legal Scholars Law Firm 17 84 East Thetford Road 18 Lyme, New Hampshire 03768 19 20 21 22 23 24 25 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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883 1 On Behalf of Lhe State of New Hampshire:
2 PETER C.L. ROTH, ESQ.
3 Senior Assistant Attorney General 4 State of New Hampshire 5 Office of the New Hampshire 6 Attorney General 7 33 Capitol Street 8 Concord, New Hampshire 03301 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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884 1P RO C E E D I NG S 2 8:30 A.M.
3 JUDGE KARLIN: Good morning and welcome to 4 the second day of hearings of the Atomic Safety and 5 Licensing Board proceeding in the Vermont Yankee 6 application for license renewal. I'm not going to go 7 through the long introduction of yesterday and 8 hopefully that will suffice, but I did want to mention 9 a couple of things before we get started.
10 First is a housekeeping matter. Just 11 please remember to turn off your cell phones and those 12 sort of things so they don't interrupt as we're going 13 along.
14 Second, I would hope that we all try to 15 speak clearly and loudly for the audience, for the 16 public to hear and that the witnesses will also speak 17 clearly and loudly and slowly. We're going to tryto 18 ask clear questions and hopefully elicit pretty direct 19 and short answers, except where we ask for a little 20 bit longer explanation and we'll ask for that when the 21 time comes.
22 We were looking -- Dr. Hopenfeld, I don't 23 know if you can move down a little bit further. The 24 reason we wanted you over there is for the line of 25 sight so the Judges could see you more clearly.
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885 1 That's helpful. Thank you.
2 One thing we might also mention is we 3 asked the press and some of the parties might not have 4 been aware of this and I'm not sure how much it will 5 be an issue today, to try to conduct or to conduct any 6 interviews they want to do outside of the hearing 7 room, outside of the courtroom here, the idea being if 8 we have a 10-minute break and come back in at 10 9 minutes and the media are doing an interview with 10 somebody in the back of the room it kind of messes ii 11 things up. So if you could encourage them and if 12 they're asking you some questions, maybe you could 13 step outside for that.. That will help. So we're not 14 going to have any interviews in the courtroom as it 15 were.
16 The one other thing to mention this 17 morning is I want to -- we're going to continue on 18 asking questions about the metal fatigue contention of 19 the witness panel. And we might get done today on.
20 that. I don't know. But when we do at the juncture 21 when the Board is finished asking questions, we're 22 going to take a break, 15 minutes or so and to think 23 about it ourselves, if we thought we've missed any 24 questions we thought we'd want to ask and also that's 25 the time as we reconvene after the 15-minute break for NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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886 1 the parties to suggest if theay have any other areas 2 where they think we should have asked questions or 3 it's important that something needs to be brought out.
4 And so while we're going on today, hopefully you'll be 5 taking your notes and think about those things, 6 because you're not going to have much time when we 7 take the break, a 10 or 15-minute break to start 8 scratching your head and think about additional 9 questions.
10 Once you give us suggestions, if you do, i1 you can either do it in writing which is going to be 12 pretty fast, handwritten or whatever. if you don't 13 want the other side to know about or you can just do 14 it in the open and say we think you ought to ask them 15 about whatever, but then we will either take another 16 quick adjournment or from the bench confer to decide 17 whether we want to ask, we think we need to ask those 18 additional questions or not.
19 So the main point is as we go along today, 20 be thinking about it if you think we may have missed 21 something important so that when that 15 minutes 22 comes, you can be pretty crisp about it and we can 23 proceed. So anyway we hope we'll get done today on 24 contention 2, but we may not either. We've got a lot 25 of questions today.
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887 1 With that, I just wanL to remind the 2 witnesses that you're still under oath and so you 3 acknowledge that you're -- you recognize that. And 4 with that we will proceed with questions.
5 I believe Dr. Reed was doing the 6 questioning mostly as we ended yesterday.
7 JUDGE REED: I would like to continue 8 along the lines of trying to understand better exactly 9 how these CUFen calculations were done. I think we 10 made a lot of progress yesterday and I thank you all 11 for helping us to understand that.
12 But what I would like to dc this morning 13 is to understand exactly the sequence of calculations i4 that were done, moving from the original calculations 15 in which the CUFens were calculated and reported to 16 be, some of the CUFens were reported to be over one.
17 And then you did a series of refined calculations in 18 which all the CUFens were less than one for the nine 19 components. And then you did a confirmatory 20 calculation of a single component and what I would 21 like *to do is to ask, I guess this question should go 22 to Mr. Stevens.
23 Could you help us understand first how you 24 did the original calculations and then what was the 25 change from that methodology to the refined analyses NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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888 1 and why did those numbers go down so substantially?
2 MR. STEVENS: I am structural integrity 3 and. dd nnt perform the first calculations so with 4 respect to that part I think Mr. Fitzpatrick would be 5 best to answer and then I can carry on for the refined 6 and confirmatory calculations.
7 JUDGE REED: I'd be happy to pose the 8 question to Mr. Fitzpatrick.
9 MR. FITZPATRICK: The license renewal 10 application existing design reports, the CUFs in the 11 design reports we used --
12 JUDGE REED: Please speak up. It' hard 13 to hear.
14 MR. FITZPATRICK: For the original license 15 application, the CUFs in the design reports we used --
16 JUDGE REED: What are the design reports?
17 MR. FITZPATRICK: When the plant was 18 designed, an ASME 3 stress analysis was done and --
19 JUDGE REED: So you're going back 35 years 20 for this?
21 MR. FITZPATRICK: Some of them. GE did an 22 update on the CUFs for power uprate and those were the 23 CUFs used in Table 431 of the application.
24 JUDGE WARDWELL: Who did that again?
25 MR. FITZPATRICK: The GE report assessing NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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889 1 the effects of power uprate on the CUFs.
_ JUDGE WARDWELL: What date was that 3 report?
4 MR. FITZPATRICK: 2003.
5 JUDGE KARLIN: General Electric. GE.
6 MR. FITZPATRICK: General Electric.
7 JUDGE KARLIN: That's people who built the 8 reactor.
9 MR. FITZPATRICK: Designed it.
10 JUDGE KARLIN: Designed it.
11 JUDGE REED: Were those calculations done 12 specific to Vermont Yankee orc were there some generic 13 calculations?
14 MR. FITZPATRICK: It was specific things 15 in the, table for Vermont Yankee and for the locations 16 that were identified in NUREG 6260 we used 6260 values 17 and there's a footnote on each one of those that we 18 didn't have plant specific, specifically the piping, 19 the original plant design, the B31 piping and piping 20 code. That didn't require explicit fatigue analysis.
21 Later plants are designed to ASME 3 and the Class 1 22 piping has its specific capabilities.
23 DR. REED: I'm still puzzled by some of 24 these statements. In the design reports the plant was 25 originally designed for 40 years and now we're looking NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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890 1 at CUFens for 60 years, so you must have made some 2 adjustments to account for the additional 20 years.
3 MR. FITZPATRICK: If you look at the 4 application, the number cycles in- the original 5 application did not change. Table 421, 431 and 432 6 has the same-number of cycles as the original design 7 and showed the projections that we wouldn't exceed the 8 original design cycles in 60 years.
9 JUDGE REED: So your original application 10 for the license renewal assumed the same number of i1 cycles as the original design and it was your 12 expectation you would not exceed that?
13 MR. FITZPATRICK: That's correct.
14 JUDGE REED: Weren't there many CUFs 15 greater than one in your analysis?
16 MR. FITZPATRICK: Not CUFs, CUFen with the 17 Fen factors applied.
18 JUDGE REED: Fine.
19 MR. FITZPATRICK: And below that table, 20 statements, we have the option to refine those 21 analysis and do an inspection program or repair or 22 replace over time. We knew we would have to do the 23 CUF analysis.
24 JUDGE WARDWELL: You've confused me more 25 than helped me. During the original design cumulative NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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891 1 use factors wqere calculated?
2 MR. FITZPATRICK: For some components, on 3 the reactor vessel, yes. Not for the piping.
4 JUDGE WARDWELL: So then you did the 5 additional analyses required for those that hadn't 6 been done during the original design?
7 MR. FITZPATRICK: We engaged spectral 8 integrity to do the CUF analysis.
9 JUDGE WARDWETL: So Mr. Stevens, you are 10 able to testify in regards to the Fen analysis 11 associated with the original, the initial calculations 12 in the license renewal application, yes or no?
13 MR. STEVENS: No.
14 JUDGE WARDWELL: Mr. Fitzpatrick, please 15 clarify for me.
16 MR. FITZPATRICK: The CUF used the 17 original design CUFs on NUREG 6260 CUFs in the license 18 renewal application.
19 JUDGE WARDWELL: Speak up. It's really 20 hard to hear you.
21 MR. FITZPATRICK: We used the original 22 design CUFs for NUREG 6260 CUfs in the original 23 license renewal application. The Fens were calculated 24 based on the NUREG by Entergy and the results did come 25 over one and it was presented in the application.
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892 I IJUDGE WARDWELL: Thank you.
2 JUDGE REED: Okay, so in the FSER which is 3 what exhibit is it, it's Staff Exhibit No. 1, if I'm 4 not mistaken on page 4.32, it's reflected that seven 5 of the nine components evaluated have an 6 environmentally adjusted CUF of greater than one. So 7 your initial -- as I would call it, the initial CUFen 8 analysis with the license application, the reanalysis 9 in 2007 and then the confirmatory analysis in 2008 on 10 one nozzle.
11 I The initial CUFen analysis you did for 12 this license renewal application showed seven of nine 13 locations exceeding the unity or exceeding one.
14 MR. FITZPATRICK: Yes.
15 JUDGE REED: Okay, I'm with you so far.
16 JUDGE WARDWELL: Is there any technical 17 reason you could not at that point have gone on and 18 performed what was later to be called the refine 19 calculations once you obtained your results that they 20 were over one for seven of the nine components?
21 MR. FITZPATRICK: No, we could have done 22 it at that time. Another group at Entergy was 23 preparing the application and we submitted it that 24 way.
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893 1 we spent in operation.
2 JUDGE REED: Okay, so I guess we rather 3 crudely understand how you came up with your original 4 set of numbers and maybe it would be. useful now to 5 turn to Mr. Stevens and ask if -- how the refined 6 numbers came into being.
7 I'm guessing that you're going to tell us 8 that basically we heard that yesterday, but the 9 refined calculations, tell us briefly how those were 10 calculated.
11 MR. STEVENS: So part of what Mr.
_2 Fitzpatrick said that I can't testify to is now we 13 have a set of results that were initially developed 14 that comes to me with the request to do some refined 15 analysis. I think a couple of things are important to 16 help clarify that initial set. We have, as Mr.
1-7 Fitzpatrick -just testified, we have several of the 18 locations that show unacceptable results that we're 19 now going to be doing refined analysis. on. And 20 another key part of that is for the piping locations, 21 they assumed generic values that are not specific to 22 VY. And as Mr. Fitzpatrick testified, that was 23 because of the piping code used which does not require 24 that CUFs be calculated.
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894 I do is to come up wi,-... some values for those pipin' 2 locations that are specific to VY. So we really have 3 two objectives. One is to come up with specific CUFs 4 for all locations, CUFens, as well as to do some 5 refined evaluations.
6 Another important point is the objective 7 of design analyses, those done originally and those 8 done by General Electric for EPU is to show 9 acceptability, not margin. Acceptability, as I 10 discussed yesterday, is a cumulative usage factor of 11 one. So once an analyst has shown the usage factor is 12 less than one, he has demonstrated acceptability and
- 13. he can stop his analysis.
14 So a lot of these analyses are done with 15 simplifications and conservatisms put in and if the 16 answer comes out acceptable, that's an acceptable 17 result and an acceptable method. It does not indicate 18 that the usage- factor could not be lowered.
19 JUDGE REED: Let me take a small amount of 20 time here to ask you some questions about the number 21 one.
22 You said just now that if you come up with 23 a number that's one or less that that's acceptable.
24 So in your opinion calculating a CUFen of .99 would be 25 acceptable. Is that correct?
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895
]_11 MR. STEVENS: That's correct.
2 JUDGE REED: So you feel that there's no 3 margin required to this failure point of one?
4 MR. STEVENS: I wouldn't characterize it 5 that way. I would say tha-t the 1.0 has margin in and 6 of itself because of-the methodology and the criteria 7 that are being applied. We talked about safety 8 factors 9 JUDGE REED: Let me contest that point.
10 Now the number 1.0 has no margin associated with it at 11 all, but that omission of CUFen, if you literally read 12 those definitions it's the number of cycles that you 13 expect to occur divided by the number of cycles it 14 would produce failure. Isn't that the definition of 15 CUFen?
16 MR. STEVENS: That's the definition, but
.17 I guess I would ask you to clarify --
18 JUDGE REED: Let me continue. If that's 19 the definition, doesn't it imply that if you made your 20 best calculation of CUFen that if you calculated a 21 CUFen equal to one you would expect failure to occur?
22 MR. STEVENS: No, sir.
23 JUDGE REED: If you do your best job of 24 calculating what happens -- statistically, I realize 25 there's some variation here, but wouldn't you expect NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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896 1 failure to occur when a CUFen equals one?
2 MR. STEVENS: No, sir.
3 JUDGE REED: Isn't that the definition of 4 CUFen?
5 MR. STEVENS: No, the definition is it's 6 a criteria. It's an allowable value. It does not 7 indicate failure. Failure of test data in the 8 laboratory with factor -- adjustment factors applied 9 to it is a criteria. It is not failure.
10 JUDGE REED: Well, I put it to you that we 11 just discussed the definition of accumulative use 12 factor and it's a ratio of number of cycles that you 13 expect to occur divided by the number of cycles that 14 are required to produce failure of the component. But 15 if that number is one by the definition you would 16 expect failure to occur.
17 MR. STEVENS: Let me see if I can state it 18 another way. If the failure curve we used was in fact 19 a failure curve without adjustment factors, then I 20 would agree with your statement.
21 JUDGE REED: But that's what I asked you 22 to postulate, that you were not taking into account 23 any conservatisms- in the calculation.
24 MR. STEVENS: I'm sorry, I misunderstood.
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897 1 don't have the option of changing that curve, 2 therefore it's not a part of my calculations. But if 3 that's what you allow me to do, then I agree with your 4 statement.
JUDGE REED: Okay, .so you're saying that 6 the failure curve and this is an ASME number or -- is 7 that right? This is coming from some report, has 8 conservatisms built into it?
9 MR. STEVENS: That's correct.
10 JUDGE WARDWELL: Aad these curves are in 11 the NUREG 6260 and 5783, is that correct?
12 MR. Si:EVENS: No, sir. The curves that 13 we're using are in ASME code.
14 JUDGE WARDWELL: Thank you.
15 JUDGE KARLIN: These are what we refer to 16 as the air curves. They're not environmentally 17 adjusted. They're just what ASME calculated as how 18 much stress this particular component would endure, 19 how many times, and there is a scattering of data 20 across the chart and you have to draw a curve that 21 tries to capture what that data reflects.
22 MR. STEVENS: Yes, sir. We call it the 23 design curve. It's an air curve through the data with 24 adjustment factors applied to account for certain 25 things and the resulting curve that's been adjusted is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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898 1 a design curve. That's the one in the ASME code that 2 we use.
3 JUDGE KARLIN: Okay.
4 JUDGE REED: Can you speak to how 5 conservative it is? Is it at the 95 percent limit?
6 Are there some data points on the other side of the 7 curve or is it -- does it completely bound all of the 8 data? Am I making sense in my question to you?
9 MR. STEVENS: it's a good question. I 10 think Mr. Fair is a better one to answer that.
11 MR. FAIR: Yes, if I can try to answer 12 that question. I agree with the statement that the 13 fatigue curve --
14 JUDGE REED: What curve?
15 MR. FAIR: The ASME design fatigue curve.
16 JUDGE REED: Fatigue.
17 MR. FAIR: Is based on test data on small 18 specimens that have been adjusted to account for the 19 difference between small specimens and actual 20 components and for the scatter of the data.
21 In the NUREG report in 6583, there is 22 assessment of the probability of fatigue crack 23 initiation giving a CUF of 1 and in that it estimates 24 that the probability of initiating a fatigue crack is 25 somewhere between 1 and 5 percent which is logical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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899 1 givren that you adjusted the data down to try to bound 2 the test data.
3 So the second aspect of it --
4 JUDGE REED: I'm sorry, you said adjusted 5 the data down --
6 MR. FAIR: I'm sorry, I misspoke.
7 Adjusted.the curve down to bound the test data.
8 JUDGE REED: Okay, so with the curve 9 bounds the test data. There is no data on the other 10 side of the curve. It's that conservative. Is that 11 what you're saying?
12 MR. FAIR: The original design curve 13 bounded the data as it existed at that time. And 14 based on the'data scatter from the test data, Argonne 15 developed a model with a standard deviation and used 16 that model to estimate the probability of initiating 17 fatigue crack at the ASME code limit of 1.0. And that 18 data is discussed, that evaluation is discussed in the 19 NUREG 6583. It's also discussed a little bit in the 20 6909, the latest NUREG which used the 95/5 basis for 21 developing a new air design fatigue curve. If you go 22 back and look at this new air design fatigue curve, 23 it's slightly above the original ASME fatigue curve 24 for carbon and low-alloy steels which shows that 25 original adjustment was somewhat conservative compared NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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900 1 to this criterion 6909.
2 The other aspect 3 JUDGE KARLIN: And with regard to 4 stainless steel?
5 MR. FAIR: With regard to stainless steel, 6 it's mixed.
7 JUDGE KARLIN: The NUREG 6909 curve as 8 compared to the ASME curve is mixed. Sometimes it's 9 above and sometimes it's below.
10 MR. FAIR: Sometimes it's below.
11 JUDGE KARLIN: Sometimes it's more 12 conservative. Sometimes it's less.
13 MR. FAIR: That's. correct-14 JUDGE KARLIN: And 6909 and Reg. Guide 15 1.207 combined to basically say the NRC should be 16 using, the staff should be using these new air curves 17 from 6909 for new reactors?
18 MR. FAIR: That's correct.
19 JUDGE KARLIN: Okay.
20 MR. FAIR: The other aspect I wanted to 21 point out in -- that's discussed in these NUREGs is 22 that when you do initiate a fatigue crack what you're 23 initiating is.a crack that's three millimeters deep.
24 It's not failure of the component, but it's a three 25 millimeter deep fatigue crack based on the size of the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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901 1 test data that was used in the fatigue testing.
2 JUDGE KARLIN: So if I understand what 3 you're saying on the ASME has a CUF --
4 MR. FAIR: That's correct.
5 JUDGE KARLIN: Cumulative use factor and 6 first they start with a bunch of tests and that's data 7 on a chart, right? Please speak, they don'ýt capture 8 a nod on the recording.
9 NR. FAIR: Yes.
10 JUDGE KARLIN: So there's data on a chart 11 and then they draw a curve through that chart to 12 and as I understand what you're saying that curve 13 showed that 95 percent of the dots are above the curve 14 and only 5 percent are below the curve. Is that 15 right?
16 MR. FAIR: For the new curve in 6909, 17 that's the estimate.
18 JUDGE KARLIN: Okay, for the ASME curve 19 are they all dots above the line or --
20 MR. FAIR: For the ASME curve, the 21 estimate was about a 1 to 5 percent probability of 22 crack initiation which would mean 1 to 5 percent could 23 fall below the line.
24 JUDGE KARLIN: One to 5 percent?
25 MR. FAIR: Right, depending on the stress NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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902 I -Ievel.
2 JUDGE KARLIN: So there's 95 percent 3 chance they're going to be above, and 5 percent 4 they're going to be below-5 MR. FAIR: That's correct.
6 JUDGE KARLIN: And when we say below the 7 line or the line -- what they're calibrating or what 8 they're testing is whether there will be a three 9 millimeter crack.
10 MR. FAIR: Initiated, that's correct.
!! JUDGE KARLIN: In the metal.
12 MR. FAIR: That's correct.
13 JUDGE KARLIN: Not necessarilyr the whole 14 thing breaks in half or something.
15 MR. FAIR: Correct.
16 JUDGE KARLIN: So that failure or whatever 17 the criterion is is a-three millimeter crack?
18 MR. FAIR: That's correct.
19 JUDGE KARLIN: And there's a 95 percent 20 chance that there will be no 3 millimeter cracks?
21 MR. FAIR: That's correct.
22 JUDGE KARLIN: And that's when you get a 23 1 to 1, 100 percent?
24 MR. FAIR: Right.
25 JUDGE KARLIN: Okay.
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903 JUDGE WARDWELL: So at a CUF of 1 for your 2 initial analysis that meant there is a I to 5 percent 3 chance that a small crack could have formed?
4 MR-. FAIR: That's correct.
5 JUDGE WARDWELL: What is the CFU value..was 6 -- what are some of your higher values.? Do you 7 remember, Mr. Fitzpatrick?
9 JUDGE WARDWELL: The environmentally 10 corrective ones, what were those --
11 MR. FITZPATRICK: On the initial --
12 JUDGE WARDWELL: Initial analysis, the 13 highest one.
14 MR. FITZPATRICK: Highest one. I think 15 around 10, 11.
16 JUDGE WARDWELL: If you had a CUFen -- how 17 are we going to call that?
.18 MR. FITZPATRICK: We usually call it C-U-19 F-E-N.
20 JUDGE WARDWELL: It can't be simpler than 21 that. CUFen of 10, is there any indication of what 22 the probability of that crack being formed is?
23 MR. FITZPATRICK: It would be pretty high.
24 There are some plots in NUREG 6583 that essentially 25 for a given stress and it's dependent upon the level NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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904 1 of stress, and that's an artifact of the statistical 2 evaluation that Argonne did. It will give you a 3 probability of initiation versus CUF. There are some 4 tables.
5 JUDGE WARDWELL: -If NUREG 6260 and 5783 6 are used which I believe they were used for all your
'7 analysis, both the initial refined and the 8 confirmatory, this same 1 to 5 percent chance 9 probability with a CUFen at 1.0 would exist for all 10 those analyses, is that correct or not?
11 MR. FAIR: That would not be correct 12 because the original evaluations in 6260 used some 13 interim fatigue curves developed by Argonne prior to 14 the development of'the NUREG 6583 and 5704. I don't 15 believe there was a statistical evaluation done to 16 estimate the probabilities using those preliminary 17 curves.
18 JUDGE WARDWELL: And the subsequent 19 analysis used which NUREGs now?
20 MR. FAIR: The subsequent analysis has 21 6583 and 5704.
22 JUDGE WARDWELL: Thank you.
23 JUDGE KARLIN: By subsequent analysis you 24 mean the 2007 re-analysis?
25 MR. FAIR: I was talking about the NEAL R. GROSS.
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905 1 subsequent evaluation of the data.
2 JUDGE KARLIN: Okay, I'm sorry.
3 JUDGE REED: Okay, so I think I understand 4 the points that you've made. So basically what I'm 5 understanding is that there's considerable 6 conservatism built into these fatigue curves. Now my 7 idea of a fatigue curve, correct me if I'm wrong, is 8 a series of data points where you're plotting 9 frequency on one axis and a strain -- stress or strain 10 on another axis and the point is the failure point.
11 Is that correct? Do I have that mentally wrong?
12 MR. FAIR: That would be the curve if ycu 13 used the actual data unadjusted, yes.
14 JUDGE REED: Yes. And so there's -- is 15 there a lot of statistical variation in these failure 16 points?
17 MR. FAIR: The estimated variation between 18 the mean and the lower bound is about 2 to 2.5, factor 19 of 2 to 2.5.
20 JUDGE REED: Okay.
21 MR. FAIR: I believe that's also reported 22 in the NUREGs.
23 JUDGE REED: So since you have this 24 conservatism built into the actual fatigue curves that 25 you're using to calculate the CUFens, you again feel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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906 1 that a limit of 1.0 is an appropriate limit, that you 2 don't need to set a limit of .5 or some lesser number?
3 MR. FAIR: That's correct..
4 JUDGE REED: Basically,. you're accounting 5 for all of the conservatisms in your - -in the 6 methodology by which you calculate the CUFens. You 7 don't need any conservatism on the limit of 1.0?
- 8 MR. FAIR: That's correct.-
9 JUDGE WARDWELL: Has anyone tried to.
10 quantify that in regards to how much error there is in 11 the resulting CUFen calculation? That being we 12 calculate a CUFen of 1.0, what is the error bar around 13 that calculation? It is calculated within .001 or is 14 it calculated within .5?
15 MR. FAIR: I'm not aware of any attempt to 16 estimate the uncertainty in the calculation.
17 Generally, the calculations are done with conservative 18 inputs and no attempt to quantify the exact level of 19 conservatism , but to try to use a conservative input 20 when you're doing the calculation itself.
21 JUDGE WARDWELL: But as you go ahead and-22 then refine the calculation, isn't part of that 23 sharpening the pencil in regards to applying it to 24 site-specific things and in essence you are also in 25 the process reducing some of that conservatism. Isn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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907 1 I that correct?
2 MR. FAIR: That is correct.
3 JUDGE WARDWELL: How do you know how far 4 you can go before you've gone too far without this 5 uncertainty analysis performed on the CUFen 6 calculation itself?
7 MR. FAIR: Well, it's up to the analyst to 8 maintain the input parameters as conservative values, 9 not to- use a nonconservative input.
10 JUDGE WARDWELL: Mr. Stevens, would you Ii like to comment on that question on how you, as a 12 company, do your analyses and comfort yourself that 13 you're not broaching on the conservatism.too much to 14 make it too close to being the actual creation perhaps 15 as opposed to having these inherent conservatisms 16 built in?
17 MR. STEVENS: Yes, sir. I agree with what 18 Mr. Fair just said and it's important that -- and we 19 pointed to four items in my testimony or our testimony 20 yesterday about four conservatisms inherent to the 21 analysis. There's other subtleties as far as heat 22 transfer coefficients that we calculate as a function 23 of flow rate that we bound the flow rates of these 24 transients and all that. But it's important that in 25 the transient definitions, the number or cycles, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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908 1 temperatures and pressures and flow ratcs used, and 2 all those definition~s that we are able to demonstrate 3 they are conservative.
4 In addition, we maintain the methodology 5 and guidance of the ASME code which from a consensus 6 body has been defined as a proper and conservative 7 methodology for us to use and much of our work we 8 attest to the fact that we have maintained that 9 methodology.
10 JUDGE KARLIN: Let me focus on that.
11 Isn't it -- I thought there was something in the 12 record that reflected that Lhe ASME was having a 13 problem with regard to recalculating its air curves 14 and that the NRC has asked them to do that and they 15 had not been able to reach a consensus-.
16 Mr. Fair, do you recall something like 17 that in the record?
18 MR. FAIR: Yes, there was. I don't recall 19 where it was in our record, but the fact is correct.
20 There was a discussion, a long discussion on the air 21 *curve for stainless steel and there was a concern by 22 some individuals that the adjustment on the stainless 23 steel in the high frequency range which was supposed 24 to be a factor of two was somewhat less than a factor 25 of two.
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909 1 So that was one of the changes we made in 2 the 6909 NUREG was we put the adjustment in with the 3 factor of two which results in the lowering of the 4 stainless steel repeat curve in tie high frequency 5 range.
6 JUDGE KARLIN: Right -- go ahead.
7 MR. FAIR: And there's a number of 8 individuals within the ASME that don't agree with what 9 we did on the stainless steel curves. They think 10 we're too conservative.
11ii JUDGE KARLIN: And I think -- tell me 12 about Reg. Guide 1.207? Was it -- that was at the 13 context where the staff decided to recommend. as 14 guidance to use the air curves from 6909, correct?
15 MR. FAIR: That is correct.
16 JUDGE KARLIN: In lieu of using the ASME 17 air curves?
18 MR. FAIR: That's correct. Well, we would 19 accept the use of the carbon and low-alloy steel air 20 curves which would be conservative, but we requested 21 them to use the new air curve in 6909.
22 JUDGE KARLIN: And are you familiar with 23 the draft guidance, was it 1144 that preceded Reg.
24 Guide 1.207?
25 MR. FAIR: Yes.
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910 1 JUDGE KARLIN: in that context, did they 2 not discuss the difficulties that ASME was having or 3 there was question and doubt about ASME's curves?
4 MR. PAIR: Yes. There was a discussion of 5 -- if you're talking about within the NUREG, yes.
6 JUDGE KARLIN: And so the staff decided, 7 had several options. One was to continue to use the 8 ASME air curve.
9 MR. FAIR: That's correct.
10 JUDGE KARLIN: And the other was-to come 11 up with its own air curve for new reactors-12 MR. FAIR: That's correct.
13 JUDGE KARLIN: And the staff decided 14 because of the debate within ASME about its air curves 15 that it would -- the staff decided to use the new air 16 curve of 6909 for new reactors?
17 MR. FAIR: That's correct.
18 JUDGE KARLIN: Right. And still it's the 19 staff's position that none of that applies to existing 20 reactors because essentially they're grandfathered or 21 you're not going to impose that and there are other 22 conservatisms that offset this problem?
23 MR. FAIR: That's correct. That's the 24 staff's position.
25 JUDGE KARLIN: Okay.
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911 1 JUDGE WARDWELL: After the analysis that 2 was performed for this license renewal application or 3 any of the applications like this, it seems to me it 4 would make better engineering sense and more 5 consistent with engineering practice for-an attempt to 6 be made to quantify the various conservatisms in some 7 fashion and then come up with an error bar that could 8 be useful to people performing these calculations so 9 that they are guided on how much conservatism there is 10 for any given calculations and the inputs that they do 11 put into it. Do either of you, Mr. Fair or Mr.
12 Stevens, kncw the reason why that hasn' c-been done for 13 analyses such as this performed for a license renewal 14 application?
15 (Pause.)
16 No is an answer.
17 MR. FAIR: No.
18 JUDGE WARDWELL: Fair enough.
19 MR. STEVENS: From our perspective, ours 20 being structural integrity, we think that such an 21 evaluation is at some level a little bit meaningless 22 if you can demonstrate that all your inputs are 23 bounding. Then you know that the result you get is a 24 conservative maximum. Any such errors would give you 25 a less number. When your criteria is acceptability, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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912 1 that kind of information is generally noL viewed as 2 meaningful to the folks in the industry.
3 JUDGE WARDWELL: But yet we know that they 4 aren't all.bounding. I mean just to start with the 5 curves have a 1 to 5 percent chance of not being 6 bounding.
7 MR. STEVENS: I was going to clarify Dr.
8 Reed's question too on margin earlier which is now 9 getting at your question. In addition to what's in 10 the curve there are margins in the way we calculate 11 stresses to use that curve.
12 And those margins can be very significant 13 and based on the writing in the Reg. Guide 1.207 and 14 my interpretation of that and Mr. Fair, I think, can 15 clarify further, but those conservatisms are a key 16 reason why those curves were not backfit to existing 17 plants.
18 Those conservatisms through many analyses 19 and many studies by many different organizations over 20 the course of the industry's history have demonstrated 21 that those analyses and results are very conservative.
22 JUDGE WARDWELL: Is another way of saying 23 what you've said, as I listen to you speak, that one 24 of the reasons you don't try to quantify the 25 conservatism is that the error in trying to estimate NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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913 I that conservatism may be as much or more than the 2 actual amount that's there so that the number that 3 you've generated somewhat meaningless as you say 4 because it's so difficult to quantify the 5 conservatisms for some of these behaviors that you 6 know you inherently have, but can't actually put a 7 number on how conservative it is?
8 MR. STEVENS: I think that's a fair way to 9 say it. I might clarify it or say it a little bit 10 differently.
11 JUDGE WARDWELL: I hope you can say it 12 simpler than I did as I was struggling through that.
13 MR. STEVENS: If I can demonstrate that my 14 number is very, very conservative and I have an error 15 of two orders of magnitude in the lower direction, 16 then I think just my answer being bounding and 17 conservative with respect to criteria is all that 18 generally satisfies folks.
19 JUDGE REED: Okay, let's come back to the 20 earlier point and that is we were trying to understand 21 this progression of CUFen numbers starting from the 22 original numbers in the application and we move to the 23 refined calculations.
24 Do you have anything further to add to us 25 about how those refined numbers were calculated? I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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914 1 thinik I understand that and I think I understand why 2 the refined numbers are so much less than the original 3 numbers.
4 JUDGE WARDWELL: Could you say that again 5 then, exactly why they are less, the components that 6 contributed to the fact that they are less?
7 MR. STEVENS: Yes. Again, there was --
8 remember, we have some locations that did not have 9 Vermont Yankee specific analyses performed so that was 10 a key to starting some of the refined analyses. We 11 wanted to replace those generic 6260 CUFens with 12 plant-specific values. So that was one key.
13 Another thing, if I may, take you back to 14 Judge Karlin's paper clip example yesterday which is 15 really an excellent example of how to help explain 16 some of this. And you recall I was talking about how 17 we might for one component have 20 transients to 18 evaluate. One simplification, conservatism an analyst 19 may do to make his analysis lie simpler is he may 20 choose the worst of those 20 transients, analyze that 21 one and pretend all the other transients look just 22 like it. It's a very bounding assumption.
23 So if the analyst did that and he analyzed 24 one transient that was the worst one in a quantity 25 that is the sum of all 20, and he showed acceptable NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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915 1 results, that's an acceptable analysis, a lot of 2 conservatism, and he's completed his evaluation.
3 In that sense, the result he achieved in 4 terms of CUFen, it might be .99 as you suggested, Dr.
5 Reed, which is acceptable. But obviously, if I were 6 to take the time to analyze all 20 of those 7 transients, I would get a much lower result. So my 8 point here is that the usage factor from an analyst 9 that analyzed all 20 transients as one very 10 conservatively and had he done that and achieved a 1i usage factor like 11 as Mr. Fitzpatrick said was in 12 the original license renewal application, there's 13 clearly other things I can do to show acceptability 14 which is what we call refined analysis.
15 Remember that his objective was to -- the 16 analyst's objective was to demonstrate acceptability, 17 not margin. So that gives me some leeway as an 18 analyst to go back and refine that calculation further 19 to show acceptability before I give up and say the 20 result is unacceptable.
21 And that, I think, what I'm trying to 22 characterize is the input given to structural 23 integrity with unacceptable CUFen results and now what 24 I can do as a first step to try and demonstrate 25 acceptability. I can go refine those calculations by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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916 1 removing some of the excess conservatisms that were 2 put into the analysis originally by another analyst.
3 And.that's, in fact, what we did.
4 JUDGE WARDWELL: Do you remember when you 5 were tasked to do this and when you finished this 6 analysis?
7 MR. STEVENS: Yes, sir.
8 JUDGE WARDWELL: Would you care to share 9 that with us?
10 MR. STEVENS: We -- my recollection is we i started discussions with Entergy in late, very late as 12 in November, December 2006 to understand a scope and 13 we began calculations in the spring of 2007, 14 approximately May time frame and that initial set was 15 completed in July of 2007, drafted for review.
16 JUDGE WARDWELL: I think yesterday you 17 testified that it took somewhere in the neighborhood 18 of three persons, a set amount of time that you quoted 19 yesterday, that related to this refined analysis, 20 those numbers that you gave yesterday. Is that 21 correct?
22 MR. STEVENS: That referred to the 23 confirmatory evaluation of the feedwater nozzle we did 24 in January of this year.
25 JUDGE WARDWELL: About how much labor NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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- I 917 I ef fort was reqjuired in your refined analysis, roughly--
2 Can you estimate?
3 MR. STEVENS: What T said yesterday was 4 three weeks, three people, about nine man weeks.
5 That's a reasonable estimate for doing these analyses 6 refined. Refined took a little bit longer because 7 some-of the inputs into the confirmatory analysis were 8 identical and we did not regenerate those.
9 Reasonable estimate for doing one of these 10 refined analyses which didn't have an initial starting 11 point to work from, 12, 13, 14 man weeks. The lapsed 12 time would depend on our workload on other activities 13 at the time.
14 JUDGE REED: Clarification, please. Is 15 that per component or was that for all nine 16 components?
17 MR. STEVENS: That would be per component.
18 JUDGE REED: Per component, 12 man weeks 19 per component.
20 MR. STEVENS: And that would be more for 21 the -- like the nozzle analyses that we did, piping, 22 some of the analyses we were able to do in a more 23 simplistic fashion. They took less time, but on the 24 average for the more involved analyses, yes, you're 25 correct.
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918 I JUDGE WARDWELL: And which more involved 2 analyses, confirmatory or the refined or both?
3 MR. STEVENS: Both. The refined, the 12, 4 i3, 14q week estimate refers to the refined 5 calculation. The confirmatory would be a little bit
.6 less because some of the analyses I did for the 7 refined like building a finite element model, I could 8 make use of without dedicating time whereas in the 9 refined analysis I had to create that model.
10 JUDGE WARDWELL: And so just to be sure I 11 understand, those numbers you quoted now and quoted 12 yesterday refer to per component average?
- 13. MR. STEVENS': That's correct.
14 JUDGE WARDWELL: Mr. Fitzpatrick, *why did 15 you task them to do that if, in fact, your plan in 16 your license renewal application was to do that in the 17 future?
18 MR. FITZPATRICK: It's part of the -- it's 19 .part of the contention.
20 . JUDGE REED: I'm having trouble hearing 21.you.
22 MR. FITZPATRICK: I'm sorry, to resolve 23 the issue in the contention.
24 JUDGE REED: To resolve?
25 MR. FITZPATRICK: Try to resolve.
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919 1 JU-0GE REED: To resolve. Thank you..
2 JUDGE KARLIN: I want to ask, if I may,'
3 about as I understand what you're saying, Mr.
4 Stevens, that to calculate and we're talking about not 5 just CUF but the fen values also, the CUFens for the
- 6. reanalysis which occurred I guess from November of '06 7 to July of '07. You estimate 12 to 14 person weeks 8 per location. Is that right?
9 MR. STEVENS: That's correct.
10 JUDGE KARLIN: Why does it take so long?
11 Isn't it just sort of a straight-forward calculation?
12 MR. STEVENS: No, sir. It's -- there's 13 -quite a bit involved. It takes --- building a finite 14 element model is on the order of a week in and of 15 itself. Running 20 transients through that finite 16 element model are whatever means are used, takes time.
17 We have the quality assurance process that all of our 18 work must be documented and verified and checked by an 19 independent reviewer as well as the project manager 20 himself.
21 JUDGE KARLIN: Okay, so -
22 MR. STEVENS: All that together is 23 extensive time.
24 JUDGE KARLIN: But is it pretty much 25 mechanical or does it involve judgment, technical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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920 i analyst's judgment also.
2 MR. STEVENS: It does involve judgment.
3 JUDGE KARLIN: Okay, and with regard to 4 the single confirmatory CUFen analysis you did on the 5 feedwater nozzle, that was yesterday you said three 6 people, three weeks of work, nine person work week?
7 MR. STEVENS: Correct.
8 JUDGE KARLIN: For that. Did that also 9 involve judgment and time and effort?
10 MR. STEVENS: Yes, sir.
11 JUDGE KARLIN: So analyst's judgment was 12 involved in doing that?
13 MR. STEVENS: Yes, sir.
14 JUDGE KARLIN: Now I'm going to ask some 15 questions a little later, but maybe this gets into it.
16 On commitment number 27, it calls for Entergy to 17 conduct two additional what I'll call confirmatory 18 CUFen analyses on the core spray nozzle and the 19 reactor recirculation outlet.
20 Is that right?
21 MR. FITZPATRICK: I don't think it's in 22 commitment 27. That's in license condition in the 23 SER.
24 JUDGE KARLIN: Right, okay. Thank you.
25 I'll take that correction. Mr. Stevens, how long is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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921 1 it going to týake those two confirmatory analyses on 2 the core spray and the reactor recirculation outlets 3 I guess it is.
4 MR. STEVENS: It would be timing 5 consistent with that on the feedwater nozzles, so 6 approximately nine man weeks.
7 JUDGE KARLIN: And it would involve 8 judgment calls by various technical and scientific 9 people?
10 MR. STEVENS: That's correct.
11 JUDGE KARLIN: Okay.
12 JUDGE WARDWELL: Mr. Fitzpatrick, why 13 didn't you apply the same criteria you did in regards 14 to the refined analysis to the confirmatory analysis 15 and just perform those additional two at this point in 16 order to resolve this contention, help resolve this 17 contention?
18 MR. FITZPATRICK: Repeat the question, I 19 don't understand that.
20 JUDGE WARDWELL: When I asked you why did 21 you task Mr. Stevens to do the refined calculations 22 you stated you did that to help resole this 23 contention.
24 MR. FITZPATRICK: The initial assessment 25 we took the existing fatigue analysis, applied the FEN NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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922 1 factors of NUREG 6583 and 5704 and came up with higher 2 CUFens for a number of components.
3 We knew we would have to redo the analysis 4 for the VY components that weren't plant specific and 5 listed those in NUREG 6260 combined. Such integrity 6 has the expertise to do it. We engaged them to do it.
7 JUDGE WARDWELL: That's fine. That wasn't 8 my question, but that's a good answer for another 9 question, so I'm glad you stated that.
10 My question now is why haven't you gone 1i ahead and tasked them to compete the confirmatory 12 analysis for the other two nozzles that the staff is 13 requiring you to do at some point in the future, but 14 do it now to again help resolve this contention, using 15 the same approach or philosophy that you did when you 16 tasked them to do the refined calculation?
17 MR. FITZPATRICK: At this point, we 18 believe the refined analyses are conservative. The 19 confirmatory analysis demonstrates that. The results 20 show that there's no need to do that. We're going to 21 get similar results.
22 JUDGE WARDWELL: So with the refined 23 analysis because the CUFens were greater than one, you 24 felt the need at that point when -- at the time you're 25 deciding whether to task Mr. Stevens to perform a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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923 1 refined analysis, you had CUF values greatez than one 2 that inspired you to now task them to do at this point 3 to help resolve this contention. You don't have that 4 same situation is what you're saying with the 5 additional two nozzles that need confirmatory analysis 6 because you feel they're conservative enough and below 7 one at this pointand that that confirmatory analysis 8 can wait for the future consistent with what the staff 9 is requiring of you?
10 MR. FITZPATRICK: Yes, that's exactly 1i right.
12 JUDGE WARDWELL: Mr. Stevens, did you want 13 to add something to that?
14 MR. STEVENS: Just one other item I think 15 is important is we in the confirmatory evaluation that 16 everyone has acceptfed and reviewed it, we evaluated 17 the bounding nozzle, so technically going into this we 18 would say there's no reason to evaluate the other two 19 nozzles, given that we one, evaluated the bounding 20 nozzle; and two, we still believe these refined 21 analyses are conservative.
22 JUDGE WARDWELL: But didn't your value, 23 resulting value in your confirmative analysis for the 24 feedwater nozzle increase over what it was before?
25 MR. STEVENS: No, sir. CUFen went down in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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924 1 the confirmatory evaluation which was our objective in 2 those evaluations. It is lower.
3 JUDGE KARLIN: What went up? Something 4 went up 40 percent. What went up?
5 MR. STEVENS: The CUF went up.
6 JUDGE KARLIN: By?
7 MR. STEVENS: Approximately 40 percent.
8 JUDGE REED: I'd like to ask Mr. Fair to 9 state his opinion of what we just heard in light of 10 the fact that the staff is requiring that two 11 additional calculations be done. Is it the staff's 12 view that this calculation was bounding, this 13 feedwater?
14 MR. FAIR: Yes, it is. It was the highest 15 CUF going into the analysis. The reason that the 16 staff requested the other confirmatory analysis was 17 that the CUF analysis was not bounding, although the 18 CUFen analysis was bounding.
19 The staff couldn't make a judgment. The 20 reason that the CUFen analysis went down was there was 21 some refinements that were made in the confirmatory 22 calculation on the Fens for each transient which 23 instead of using a bounding Fen that covered all the 24 transients, they had a specific Fen for each 25 transient.
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925 1 The staff was unable Lo make a judgment 2 that the same level of reduction would apply to these 3 other two nozzles and that's why they requested that 4 they do the addiciunal confirmatory analyses.
5 JUDGE REED:' I thought I read in some of 6 your testimony or somewhere here that the staff made 7 a pretty clear statement that they did not believe 8 that this was bounding. I thought you used that word.
9 Am I mistaken?
10 MR. FAIR: I think the staff and the SE 11 did say they thought the feedwater nozzle was 12 bounding.
13 JUDGE REED: It's not so much that the 14 feedwater nozzle was bounding, but that the 15 confirmatory calculations were not bounding. I would 16 have to study here for a few minutes --
17 JUDGE WARDWELL: Let me help you here. In 18 a February 14 OA audit, the staff concluded that the 19 use of Green's function could under estimate the 20 cumulative use factor and therefore cannot be the 21 analysis of record. Isn't that correct?
22 MR. FAIR: That's correct.
23 JUDGE WARDWELL: And so that's the-24 motivation for why you're requiring the other nozzles 25 to also be analyzed. Is that correct?
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926 1 MR. FAIR: '.'nat's correct.
2 JUDGE WARDWELL: Why doesn't that also 3 apply to the other locations?
4 MR. FAIR: Because the other locations 5 weren't based on the Green's function evaluation.
6 JUDGE KARLIN: I thought we heard 7 yesterday that it was. Mr. Stevens maybe can answer 8 that.
9 MR. STEVENS: Just the three nozzles, core 10 spray nozzle recirculation nozzle, feedwater nozzle.
1i The other six locations, of the nine were not evaluated 12 with that methodology with the Green's function that 13 you referred to.
14 JUDGE WARDWELL: Why weren't they?
15 MR. STEVENS: They were done with other 16 more conservative methods.
17 JUDGE WARDWELL: Do those methods, those 18 conservative methods all relate to how the stresses 19 are analyzed and the number of stress component 20 tensers that are used in the field?
21 MR. STEVENS: Yes.
22 JUDGE WARDWELL: And are those other 23 locations such that they are more one dimensional if 24 you will that allow you -- or the flow is one 25 dimensional so that you ignore any of the small shear NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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927 1 stresses that might develop that would rcquire more 2 than one stress tenser to be analyzed?
3 MR. STEVENS: No, sir. For example, the 4 piping locations, feedwater piping recirc RHR piping 5 were evaluated with ASME code NV3600 formula 6 methodology for piping which accounts for all of that 7 in a conservative fashion.
8 JUDGE WARDWELL: When is the Green's 9 function used, let me ask you that?
10 MR. STEVENS: I'm sorry, did you say when?
11 JUDGE WARDWELL: Yes, when -- let me back 12 up quickly on that. 'There's the simplified Green's
.13 function and I assume theres a complex or a normal 14 Green's function. Is that correct?
15 MR. STEVENS: No, there's really -- I 16 would say there's just one Green's function.
17 JUDGE WARDWELL: It's been called the 18 simplified Green's function in much of the testimony.
19 MR. STEVENS: Right, and this has been the 20 source of a lot of confusion in the discussion on this 21 topic. It's not really the Green's function that 22 parties have - -are again disagreeing over. The 23 Green's function is a well-documented mathematical 24 technique that's understood and is very accurate.
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928 I and taking the results from using the Green's function 2 and what you do with that result.
3 JUDGE WARDWELL: And when you did that, 4 what did you do? How did you apply that?
5 - What did you do to the results of the 6 Green's function to simplify that or however you want 7 to word it?
8 MR. STEVENS: We took a single stress term 9 result from the Green's function, if you will, a 10 stress difference and utilized that to generate stress 11 different histori-es for all transients.
12 JUDGE WARDWELL: And that's what made the 13 analysis for all those other components besides the 14 three nozzles a quicker analysis or less complex 15 analysis or --
16 MR. STEVENS: Well, again, this Green's 17 function technique we're talking about was only used 18 for the three nozzles in the refined analysis. So it 19 was a simplification made for just those three nozzles 20 and what I call the second tier of the refined 21 analyses that were performed.
22 JUDGE WARDWELL: Say again then why were 23 the other locations able to be analyzed without the 24 Green's function?
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929 1 discussion of what an analyst may do once he shows 2 acceptability. He's finished. The other evaluations 3 for the other components lended themselves to not 4 having to make those simplifications or refinements to
.5 the analysis to show acceptability.
6 Some of the locations we use stresses that 7 were generated in the original stress report, for 8 example, that did not use Green's function, tha-t were 9 done consistent with using six stresses and we used 10 those and were able to show acceptability. There was 11 no need to go to a Green's function approach or a more 12 refined approach.
13 JUDGE KARLIN: If I may, while we're on 14 the Green's function, it references you to the FSER 15 page 4.38. Could you all pull that out? That's where 16 the discussion -- there's a four-page, I think, three 17 or four page discussion of the Green's function in the 18 staff's final safety evaluation report.
19 Page 4-38 of the FSER.
20 MS. BATY: Your Honor, I just wanted to 21 supply our witness a copy.
22 JUDGE KARLIN: Yes.
23 MS. TYLER: Judge Karlin, will you state 24 the exhibit number again, please?
25 JUDGE KARLIN: The exhibit number is Staff NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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930 i Exhibit No. 1, I believe. Staff Exhibit No . I 2 believe that's the-FSER. Let me double check.
3 (Pause.)
4 Is that right, Ms. Baty?
5 MS. BATY: Yes.
6 JUDGE KARLIN: Yes, Staff Exhibit No. 1, 7 final safety evaluation report, page 4-38. It's a 8 discussion of Green's function.
9 Perhaps this would yo to Mr. Stevens.
10 Help me here. As I understand it, are you all saying 11 there's nothing wrong with the Green's function per 12 se. The problem in how it occurred here was that 13 there was simplified input into doing the Green's 14 function calculation. Is that right?
15 MR. STEVENS: Simplified input as well as 16 simplified use of the output.
17 JUDGE KARLIN: Yes, Okay.
18 JUDGE WARDWELL: For only the three 19 nozzles.
20 MR. STEVENS: That's correct.
21 JUDGE KARLIN: So on the last paragraph on 22 page 4.38, there's a discussion of the staff's review 23 and the second sentence says "the applicant's 24 implementation of the Green's function input to the 25 software assumes that shear stress analyses are NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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931 I negligible."
2 And then it goes on, "this implementation 3 may not be valid for those locations with geometric 4 discontinuity or non-axis symmetric load case-. So 5 therefore the applicant's implementation for 6 calculating a stress intensity cannot be validated, 7 page 2.39, therefore the staff could not conclude the 8 refined fatigue analysis is valid."
Q As I understand what they're saying, 10 there's nothing wrong with the Green's function per 1i se, but you've got -- the input has got to be done 12 right and there was a simplified input. Only one 13 input as opposed to six inputs. Is that right?
14 MR. STEVENS: Yes, sir.
15 JUDGE KARLIN: And you all corrected for 16 that at the staff's request in doing the confirmatory 17 analysis for the feedwater nozzle?
18 MR. STEVENS: Yes, sir.
19 JUDGE KARLIN: Right. And as I understand 20 what you're saying when you ran through this analysis 21 the, confirmatory analysis showed a CUF that was 40 22 percent higher than what it had been before, but with 23 the addition of the Fen the CUFen was lower than what 24 it had been before.
25 MR. STEVENS: That's correct.
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932 1 JUDGE KARLIN: Okay. Now in your proposal 2 the license condition, Mr. Fair, that's being proposed 3 by the staff is that they do that same analysis for 4 these two other locations.
5 MR. FAIR: That's correct.
6 JUDGE KARLIN: And the proposed license 7 condition or commitment 27 would say that Entergy 8 would do this within two years prior to the start of 9 the period of extended operations, right?
10 MR. FAIR: I believe that's correct.
11 JUDGE KARLIN: Okay, and the period of 12 extended operations begins in 2012, right?
13 MR. FAIR: Again, I do not know the exact 14 dates.
15 JUDGE KARLIN: March. 2012, the current 16 license would expire, so the period of extended 17 operation would be March 2012, so the commitment or 18 the license condition as proposed, the recalculation 19 of those two CUFens would have to be done by and 20 completed and submitted to staff by March of 2010.
21 Are you with me, Mr. Fitzpatrick, is that right?
22 MR. FITZPATRICK: Yes, sir.
23 JUDGE KARLIN: Have you started doing it 24 now?
25 MR. FITZPATRICK: No, sir.
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933 i JUDGE KARLIN: You naven't asked Mr.
2 Stevens' firm to start working on it yet?
3 MR.. FITZPATRICK: No, sir.
4 JUDGE KARLIN: Okay. Let me ask another 5 angle on this. Under the recalculation under 690,9,
.6 Mr. Stevens, perhaps, you said you did that in four 7 hours over the weekend, right?
8 MR. STEVENS: Two of us, so I guess that 9 would be eight hours..
10 JUDGE KARLIN: Okay. And does that 11 involve judgment and -- why was :that so much quicker 12 and, the rest of it was you know, many, many weeks and 13 man hours?
14 MR. STEVENS: Again, we -- from my 15 description yesterday, the finite element analysis, 16 stress analysis of all these transients and 17 accounting, how they pair with each other and all that 18 doesn't factor into the calculation you're asking 19 about now. So we did not have to do all that. We did 20 the very, very tail end of the analysis which is given 21 the stresses and the number of occurrences, we can use 22 the 6909 fatigue curve to give allowable cycles, 23 recompute cumulative usage factor and Fens. That's a 24 relative short process.
25 JUDGE KARLIN: Okay. Maybe I'll ask Dr.
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934 1 Hopenfeld at this point.
2 With regard to the confirmatory analysis, 3 I understand part of the reason that was done to 4 correct for this Green's function simplified input 5- problem. Are you satisfied that the confirmatory 6 analysis at least deals with the and eliminates the 7 Green's function simplification problem that was 8 perceived?
9 MR. HOPENFELD: Well, the two nozzles 10 stated on the record are still subject to the Green's 11 function anal.ysis.
12 JUDGE KARLIN: Let. me ask this with regard 13 to the feedwater nozzle, the one that they did it for, 14 are you okay --
15 MR. HOPENFELD: With respect to that 16 aspect, yes, because they took the Green's function 17 out.
18 JUDGE KARLIN: Okay.
19 MR. HOPENFELD: But important, we 20 constantly hear these words conservatism. I mean to 21 say conservatism without quantifying it is not very 22 conservative.
23 My point is in the two items here, one --
24 go back to the different issue --
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935 understand. You have testified and we probably will 2 ask some questions about how you don't agree with some 3 of these conservatisms, particularly --
4 MR. HOPENFELD: It's not the question --
5 at this point, it's not the question of the mindset 6 that something is conservative.
7 I make a certain assumption that may have 8 no justification whatsoever. Now the results become 9 conservative. I convince myself it's conservative.
10 That's the problem. Because now we -- and the same 11 thing with the definition that you ask, is something 12 going to fail? And I can answer that question very 13 quickly. You see, it goes to the definition and how 14 people run tests prior to 30 or 40 years ago --
15 JUDGE KARLIN: Okay, well -- one of the 16 things I think we might want to get back to is there 17 was a discussion and Mr. Stevens, Mr. Fair was talking 18 particularly about well, why don't you calculate the 19 range of uncertainty associated with these 20 calculations? They're saying it doesn't need to be 21 done because it's conservative. And I understand that 22 your testimony is and you've submitted that you think 23 those uncertainties should be calculated and 24 determined. I know you disagree with what they've 25 said and we've got your testimony.
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936 1 MRI. HOPENFELD: I said the mindset and Mr.
2 Stevens kept saying conservatism and you'll be 3 convinced it's conservative.
4 JUDGE KARLIN: Right. Right, okay. But
.. 5 you are happy with the way they fixed the Green's 6 function for the feedwater nozzle --
7 MR. HOPENFELD: I have no problem with the 8 CUF with the exception of the bounding conditions to 9 how to calculate it. The bounding condition for the 10 Green's function and the bounding condition for the 11 Fen under NV 32, they're considered the same. The II 12 consequences are different. I think they are under 13 misconceptual of what the consequences are, but the 14 bounding conditions for the Fens as far as how they 15 use that is a contention, yes. But as far as getting 16 rid.of the simple aspects of the Green's function as 17 a simpliified method of reducing the amount of work, 18 yes, I'm satisfied with that.
19 JUDGE KARLIN: Okay. One thing at a time 20 and I just wanted to see if you were satisfied with 21 that.
22 MR. STEVENS: May I add one piece of 23 clarification?
24 JUDGE KARLIN: Okay.
25 MR. STEVENS: And I know we didn't say NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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937 this explicitly in this discussion, but the discussion 2 up to now about the 40 percent increase in CUF, we 3 focused on Green's function and the use of these 4 inputs, single stress term. Yet, we need to keep in 5 mind that our objective in the confirmatory analysis 6 was not to reproduce the refined analysis. It was to 7 address several items that had been brought up as 8 potential issues with the analyses and to redo that 9 Analysis independently, completely with satisfactory 10 compromises on all of those that would satisfy all I1 parties and we agreed to do that with the staff to 12 help them with their review process.
13 There are many factors that could have led 14 to the 40 percent increase and I think some of the 15 documented responses to the staff last fall from 16 Entergy indicated that the Green's function and the 17 single stress term was not the cause of that increase, 18 the bulk of that increase or a significant portion of 19 that increase. And that's why we still believe those 20 refined analyses are bounding for --
21 JUDGE KARLIN: What was the cause of the 22 40 percent increase or the major factors?
23 MR. STEVENS: There was approximately 20 24 -- what we characterized as 20 differences in the 25 analyses, processing of the inputs. An example would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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II 938 1 be there were a few transients, the way they were 2 estimated with the Green's function, the inputs were 3 changed in the confirmatory analysis because we did 4 not have to make those assumptions.
5 We changed material properties in the 6 sense -- we used the same material properties, but the 7 Green's function assumes the properties are constant 8 because that's a condition of a linear integration.
9 In the confirmatory evaluation, we -- material 10 properties varied with temperature. There were many 11 differences that were put into the confirmatory 12 analysis any one of which-could have contributed to 13 the 4.0 percent increase.
14 -JUDGE KARLIN: Well, okay. Let me refer 15 you to the Staff Exhibit 1, the SER, again on page 4-16 42. We're talking about this 40 percent increase and 17 I'm trying to find it referenced, if it is, in the 18 FSER and on page 4-42 at the bottom of the page, there 19 is a sentence that goes "with the maximum Fen value 20 used, the new EAF-CUFen is 0.893 which is greater than 21 the previous value of 0.639 reported by using the 22 Vermont Yankee Green's-function application. Is that 23 the 40 percent difference? What is that?
24 JUDGE REED: If I may make a correction, 25 the numbers I have is not zero point, but .089 and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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939' 1 .064.
2 JUDGE WARDWELL.: That's not what's in the 3 SER.
4 JUDGE KARLIN: What are Lhlose numbers?
5 I know what the numbers are in the FSER.. They are 6 0.839 which is the EAF-CUF and the previous value of 7 0.639. Is that a 40 percent increase?
8 JUDGE REED: And my numbers come from 9 parayraphs 20 and 21 of your initial statement 10 position..
11 JUDGE KARLIN: Well, let me stick with 12 this one first. What do these numbers in the FSER 13 mean? Maybe Mr. Fair can help us?
14 MR. FAIR: Yes. I wasn't the reviewer.
15 JUDGE KARLIN: I understand.
16 MR. FAIR: I believe that the .893 is the 17 application of the confirmatory analysis with the 18 constant FEN, that same FEN that was used in the 19 original analysis.
20 Then the Applicant further refined that 21 analysis, that confirmatory analysis, developing an 22 Fen for each transient which then lowered it below the 23 original --
24 JUDGE KARLIN: No, I don't think so. Look 25 at the sentence. It says with the maximum Fen value NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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940 1 ..use-, the new EAF-CUFen is 0. 893 which is greater than 2 the previous value of 0.639. So the previous value --
3 the first earlier one in time was the-.6 and the new 4 one is the .8, so something is going up.
5 Mr. Stevens?
6 MR. STEVENS: The numbers that Dr. Reed 7 was referring to are CUF values prior to FEN 8 evaluation and are the values that reflect the 40 9 percent.
10 JUDGE KARLIN: Okay, now where do they 11 derive from, where are they found if I wanted to find 12 them?
13 JUDGE WARDWELL: If you tried 40, page 21 14 they may be on that of his testimony.
15 JUDGE REED: That's 20 and 21 of Entergy's 16 initial statement of position.
17 JUDGE KARLIN: Okay, so are they in the 18 FSER? Mr. Fair, Mr. Stevens?
19 MR. STEVENS: I don't recall.
20 JUDGE KARLIN: I mean don't you think the 21 FSER should say that this the CUF went up 40 percent?
22 JUDGE WARDWELL: That's just the CUF, not 23 the CUFen, correct?
24 JUDGE KARLIN: Right, right.
25 JUDGE WARDWELL: The CUFs are .064 and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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941 1 0.89 as you ch-ange from the refined toý the 2 confirmatory. Is that correct?
3 MR. STEVENS: Yes, the values in the FSER ii 4 are taking the values that Dr. Reed identified, I 5 believe it was you stated in the NRC initia.l statement 6 of position which are the CUF values. And that these 7 are the CUFens applying the same Fen value that was 8 determined in a refined analysis to both of those 9 results.
10 JUDGE KARLIN: Okay, all right, stop right Ii there. So the Fen is a constant value in this 12 calculation and the CUF is a differential value. And 13 it's going up. It went up from .6 to .8 and Feni is a 14 constant, right? Isn't that a 40 percent increase?
15 I thought you said -- if you use a 16 constant Fen, the CUFen would have gone up 40 percent 17 by fixing the Green's function?
18 MR. STEVENS: Yes.
19 JUDGE KARLIN: But you didn't use a 20 constant Fen.
21 MR. STEVENS: No.
22 JUDGE KARLIN: You used a more specific or 23 particularized Fen.
24 JUDGE WARDWELL: And that came up to a .3 25 of CUFen, is that correct?
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942 I MR. STEVENS: That's correct.
2 JUDGE KARLIN: So the CUF went up and Fen 3 went down and the total result you conclude went lower 4 than the prior one.
5 MR. STEVENS: That's correct.
6 JUDGE WARDWELL: And your constant Fen is 7 either 10 or .1. I don't know which why it applies.
8, JUDGE KARLIN: So and in fact this would
- 9. be directly, I guess, well, Dr. Hopenteld?
10 MR. HOPENFELD: I would like to help them 11 to g!ve you -- I'll tell you where the reference where 12 we can find the CUF and it's -- the last one. I can 131 go back and find it.
1.4 If you look at NEC JH-21 and I think page 15 7 of 7. There's a table there where-you can see how 16 they've done that,.
17 JUDGE WARDWELL: Wait, bear with us while 18 we find those first.
19 JUDGE KARLIN: NEC JH-21. And that is 20 structural integrity?
21 MR. HOPENFELD: Correct, and I think it's 22 page 7 of 7. And you'll see a table there. I think 23 it's dated -- it's a revision. I think it was given 24 tous at the beginning of January. And you'll see 25 there they have the user factor for all the transients NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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943 i and then you see how thcy corrected it. I think this 2 was done for the exact analysis and they have similar 3 like that for other tables, but you asked about where 4 to see the user factors before the correction and 5 that's where it is.
6 JUDGE WARDWELL: This is page 7 of --
7 MR. HOPENFELD: Page 7 of 7.
8 JUDGE WARDWELL: And you can read that 9 thing?
10 MR. HOPENFELD: I need a magnifying glass.
11 JUDGE KARLIN: Do you agree with that, Mr.
12 Stevens?
13 MR. STEVENS: No, I'm not finding -- I'm 14 a little cross wired on the commonality of the 15 exhibits.
16 I had JH-21 as being the equivalent of 17 Entergy Exhibit E-227. Is that correct?
18 JUDGE KARLIN: I do not know. Maybe Ms.
19 Carpentier, do you have that?
20 (Off the record.)
21 JUDGE KARLIN: E-227.
22 MR. STEVENS: E-227 specifically is 23 Entergy calculation VY19Q303. That would be the 24 fatigue results for the confirmatory evaluation of the 25 feedwater nozzle. It reports one value. I'm not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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944 i seeing a comparison to any others.
2 JUDGE KARLIN: Dr. Hopenfeld?
3 MR. HOPENFELD: Yes, the table that I was 4 referring to gives you the usage factor without the 5 correction and with the correction. It's unfortunate 6
7 JUDGE KARLIN: It's just one of the 8 values.
9 MR. HOPENFELD: It's the latest one. It's 10 the latest one. It's the one that you get the final 11 answer to form .897, but you can see what the 12 differences are between. Betore correction and after 13 correction and all the usage factors.
14 JUDGE KARLIN: Mr. Fair, Mr. Stevens, I'll 15 go back to the FSER on page 4-42. The new EAF-CUFen 16 is 0.893. The previous value is 0.639. Unquote from 17 the FSER. You're saying that's the revised CUF and a 18 constant Fen value, is that right?
19 MR. FAIR: That's correct.
20 JUDGE KARLIN: Okay, perhaps you can then 21 show me -- let's go on in the FSER and tell me where 22 the ultimate CUFen value which with the Fen changed is 23 reflected in the SER, is it?
24 (Pause.)
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945 I_ by that. Is the final CUFen value that Ent..rgy has.
2 presented by the confirmatory analysis reflected in 3 the FSER, the number put. in the FSER?
4 MR. FAIR: Give me a moment. I thought it 5 was-in there. I'm looking for it.
6 JUDGE KARLIN: Okay.
7 (Pause.)
8 JUDGE KARLIN: Well, let's read the next 9 sentence. "This indicates the results of the Green's 10 function application using the specific software could 11 under estimate the CUF and therefore cannot be the 12 analysis of record."
13 Then the next sentence says "however, the
- 14. updated analysis, whether using the maximum Fen or 15 appropriate Fen yields CUFs lower than the code 16 allowable. The staff concludes that this updated 17 analysis is the analysis of record for the feedwater 18 nozzle. When it says "this updated analysis" what is 19 that? Is that the analysis with the revised Fen?
20 MR. FAIR: Yes, that's what is referred 21 to.
22 JUDGE KARLIN: But that value is not 23 MR. FAIR: Yes, appears not to be in --
24 JUDGE KARLIN: And what is that value, Mr.
25 Stevens?
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946 1 MR. STEVENS: It's _,331.
2 JUDGE KARLIN: Point 3531 and where does 3 that come from? I mean is there an exhibit that tells 4 us that? Is that this exhibit that Dr. Hopenfeid has 5 pointed us to?
6 MR. STEVENS: Yes, sir.
7 MS. BATY: Your Honor, it's Entergy 8 Exhibit E-228. also has a table with just these 9 critical numbers in it on page 6.
10 JUDGE KARLIN: E-228. All right. Let's 11 focus on the exhibit NEC JH-21, page 7. Itfs also 12 Entergy Exhibit E-227, as I understand it. Where is 13 this new value on this tiny little chart? Where --
14 where can I find it?
15 MR. STEVENS: If you go to Table 1 on page 16 7 of 7.
17 JUDGE KARLIN: Yes, sir.
18 MR. STEVENS: And upper half, far right.
19 JUDGE KARLIN: All right.
20 MR. STEVENS: With my glasses on, I can 21 see that it reads "total U60-ENV equals .35306."
22 JUDGE KARLIN: Okay.- There it is. There 23 it is. I see it. Which equates to .3531.
24 I wish the FSER had had that in there.
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947 1 did you ask-- it appears based on the statements in 2 the FSER that this was asked of them to calculate 3 later on because it has parentheses, "this value was 4 verbally provided during the audit."
5 Why did you ask for that calculation when 6 in fact what they considered to be the appropriate 7 calculation included the variation in the Fen value 8 for each of the different transients?
9 MR. FAIR: I would have preface this that 10 I'm not the reviewer, but my understanding of why it 11 was asked at that time was the intent was feedwater 12 analysis confirmatory analysis was going to be used to 13 show that all three nozzles were appropriately 14 conservative.
15 When Dr. Chang reviewed this confirmatory 16 analysis and noticed that there were different Fen 17 factors used in the confirmatory analysis, it couldn't 18 make a conclusion that this same level of conservatism 19 would exist in the. other two nozzles that would allow 20 you to drop that CUF down and that's why they were 21 asked to do the analysis of the other two nozzles.
22 so although the feedwater nozzle analysis 23 is acceptable, they couldn't make a judgment that the 24 other two nozzles had the same level of conservatism 25 in them that would come out and give a lower result.
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948 JUDGE KARLIN: You could or could not?
2 MR. FAIR: Could not.
3 JUDGE KARLIN: Could not, and therefore --
4 MR. FAIR: Requested the other two nozzles 5 be evaluated.
6 JUDGE KARLIN: Okay.
7 JUDGE WARDWELL: In the pause, I'll ask 8 again, Mr. Stevens, to refresh my memory on earlier 9 testimony this morning on why does not the same 10 approach need to be applied to the other components 11 besides the nozzles-,
12 MR. STEVENS: Because the other componen'ý-s 13 were demonstrated to be acceptable using other 14 analytical techniques that don't have these issues 15 included in them, Green's function issues. So we were 16 able to use existing conservative analysis that did 17 not rely on Green's functions that estimate stresses, 18 conservatively demonstrate the. CUFens were less than 19 one. We met criteria and our evaluation is complete.
20 (Pause.)
21 JUDGE WARDWELL: Saying it another way, 22 for. the refined analysis, when you analyzed the 23 nozzles, you had to or chose to use the Green's 24 functions to analyze the stress conditions on it that 25 ultimately resulted in demonstration of meeting the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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949 I criteria?
2 MR. STEVENS: Yes, sir.
3 JUDGE WARDWELL: Okay, I understand.
4 JUDGE KARLIN: It's been going about an 5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> a*rd a half now and you all have been very good in 6 trying to answer our questions. I think it's probably 7 good to try to take a break. I have 10 o'clock. Why 8 don't we reconvene at 10:15. So we'll stand adjourned 9- until 10:15.
10 (Off the record.)
11 JUDGE KARLIN: We'll go back on the 12 record, Mr. Reporter.
13 And let me remind the witnesses that 14 you're still under oath.
15 We are continuing with questioning related 16 to metal fatigue contention, andlI believe Dr. Reed 17 can start us off again.
18 JUDGE REED: Okay. Just a quick follow-up 19 on a statement Mr. Fair made. I'd like to ask you to 20 please open up your initial statement of position, the 21 staff's initial statement of position, and look on 22 page 17.
23 MR. FAIR: Now, what do you mean by the 24 initial statement of position?
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950 i number.
2 JUDGE KARLIN: It's not an exhibit. It 3 would be the pleading presumably.
4 JUDGE WARDWELL: Dated May 13th.
5 MR. FAIR: I think I have it.
6 JUDGE-REED: Okay. If you would look at 7 the bottom and read that paragraph on the bottom, 8 please, starting "although the confirmatory analysis."
9 MR. FAIR: Well, maybe I'm not on the 10 right -- did you say page 13?
i!.j JUDGE REED: No, 17. Sorry.
12 I41R. FAIR: Oh, I'm sorry. And again, 13 which?
14 JUDGE REED: The bottom paragraph. It 15 starts with the word "although."
16 MR. FAIR: All right. Somehow I don't 17 seem to have the -- oh, I'm sorry. I'm turning to the 18 wrong (pause) -- thank you so much.
19 I have it. Sorry about the delay.
20 JUDGE REED: No problem.
21 MR. FAIR: "Although the confirmatory 22 analysis was acceptable to the staff and the CUF with 23 feedwater nozzle was less than 1.0. The CUF produced 24 by the confirmatory analysis was greater than that 25 produced by the September 2007 analysis and thus not NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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951 1 bounding. SEP. (Staff Exhibit 1 at 442 to 443, Staff 2 Exhibit 2 at 820). Therefore, the staff requested 3 that Entergy make the confirmatory analysis, the 4 analysis of record for the feedwater nozzle. SER
..5 (Staff Exhibit) --
6 JUDGE REED: You can skip those 7 references. And then the final sentence is?
8 MR. FAIR: "Also, because the September 9 2007 analysis was not bounding for the feedwater 10 analysis, the staff proposed a license condition 11 requiring that Entergy preform ASME code analysis for 12 the core spray in the reactor recirculation outlet 13 nozzle at least two years prior to the period of 14 extended operation and make those analyses the 15 analyses of record for the core spray in the reactor 16 recirculation outlet nozzle.
17 JUDGE REED: Thank you.
18 So earlier I asked you if the staff's 19 position was that this confirmatory analysis was 20 bounding or not, and it was my understanding that you 21 said that you believed that it was bounding, and so in 22 light of this testimony that you just read or this 23 initial statement of position, were we simply confused 24 or --
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952 1 as to what the intent of your questions are. What I 2 meant when I said it was bounding, I meant it was 3 bounding for the other two nozzles. The reactor 4 feedwater nozzle had a bounding CUF.
5 JUDGE REED: Okay, but again, in the sense 6 of this, the staff's position is that that analysis-is 7 not bounding and that is hence why you are asking for 8 these two additional analyses to be performed; is that 9 not correct?
10 MR. FAIR: That's correct.
11 JUDGE REED: Okay. I just wanted to clear 12 that up.
13 Okay. I would like to change gears 14 slightly, and I'd like to talk now more particularly 15 about the Fen values. I observed earlier that there 16 seems to be quite a large variation in Fen values 17 ranging from one to I think I've seen numbers as high 18 as 70 or 90. So clearly fatigue cracking can be very 19 sensitive to environmental factors; is that correct, 20 Mr. Stevens?
21 MR. STEVENS: Yes.
22 JUDGE REED: So could you state for me 23 what environmental factors you believe fatigue 24 cracking is most sensitive to?
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953 1 factorsi but if we could pick out the five or six that 2 you think are important.
3 MR. STEVENS: The laboratory data that 4 Argonne evaluated would indicate that strain rate, 5 dissolved oxygen, temperature, and where appropriate 6 it --
7 JUDGE REED: Temperature of what?
8 MR. STEVENS: Fluid temperature.
9 JUDGE REED: Fluid, not steel temperature?
10 MR. STEVENS: Correct. They're assumed to.
11 be the same.
12 JUDGE REED: Okay.
13 MR. STEVENS: AnH where appropriate, 14 material sulfur content.
15 JUDGE REED: And is that sulfur content in 16 the water?
17 MR. STEVENS: That would be in the 18 material itself.
19 JUDGE REED: In the material. Anything 20 else?
21 MR. STEVENS: Those are the dominant ones 22 in the relations. There are other effects like strain 23 amplitude, how much you -- what level you stress a 24 component to that could indicate a threshold below 25 which you would not have to consider the other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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954 1 variables, but those are the dominant ones.
2 JUDGE REED: Well, let's talk for a minute 3 about one of these. Let's pick oxygen concentration 4 and talk about that for a moment. So utii you tell us 5 a little about how you've accounted for oxygen 6 concentration in your calculations?
7 MR. STEVENS: Yes, sir. Entergy provided 8 structural integrity with oxygen values that are 9 representative of plant operations, and we looked at 10 those values and took a bounding value that would have 11 been seen in plant operation and used those in the 12 formulas to estimate the Fen appropriately.
13 JUDGE REED: Now, this is a single 14 constant number you used for all transients for all 15 time?.
16 MR. STEVENS: No, sir. We took bounding 17 values, but with the implementation of hydrogen water 18 chemistry, I don't recall exactly the year that was 19 implemented, but it was well after plant start-up. It 20 has a significant impact in some areas of the reactor 21 on dissolved oxygen levels.
22 JUDGE REED: Exactly what is meant by 23 hydrogen water chemistry? I don't know that.
24 MR. STEVENS: Hydrogen water chemistry is 25 a method to bring under control water chemistry in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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!1 955 1 reactor and reduce dissolved oxygen and other things 2 that could be detrimental to materials in terms --
3 mainly stress corrosion cracks.
4 JUDGE -r~rLD: So this reduces the dissolved 5 oxygen.
6 MR. STEVENS: It reduces the dissolved 7 oxygen in some areas of the reactor, yes.
8 JUDGE REED: So a higher concentration of 9 dissolved oxygen is detrimental to fatigue cracking or 10 it tends to worsen fatigue cracking?
11 MR. STEVENS: Generally speaking it's 12 dominant for carbon and low alloy steels, that the 13 higher the oxygen the more detrimental on fatigue. In 14 a case of stainless steels, at least the relationships 15 that.we use for austenitic from the NUREG CR-5704 that 16 indicates that lower oxygen is a bit more detrimental 17 than higher oxygen levels, forced austenitics.
18 JUDGE- REED: What type of steel are we 19 talking about for the feedwater nozzle?
20 MR. STEVENS: The feedwater nozzle 21 calculations are based on ferritic, carbon low alloy.
22 JUDGE REED: Carbon low alloy. There was 23 some mention of a -- you'll have to forgive me. Maybe 24 I should ask you to describe the feedwater nozzle very 25 briefly. Geometrically what does it look like?
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956 1 Ard i know there are cwo locations that 2 you're concerned about. So you might help us 3 understand a little bit about what it looks like and 4 wlhy you're analyzing two different locations on that 5 nozzle.
6 MR. STEVENS: The feedwater nozzle is 7 basically a component where the feedwater piping which 8 brings back condensed fluid to the reactor, joins the 9 reactor- pressure vessel. Very simplisticly, that's 10 two intersecting cylinders, an incoming pipe into a 11 larger cylindrical reactor pressure vessel.
12 The nozzle itself is a very large forging 13 that transitions in thickness from the thick feactor 14 pressure vessel to the thinner feedwater pipe. There 15 is a component called a safe end in between the nozzle 16 forging end of pipe that is another transition piece 17 to transition from the pipe to the nozzle.
18 JUDGE REED: Okay. There was some mention 19 of the installation of a thermal shield. I believe I 20 have the terminology correct.
21 MR. STEVENS: Thermal shield or thermal 22 sleeve is the more commonly referred term.
- 23. JUDGE REED: Thermal sleeve.
24 MR. STEVENS: Thermal sleeve is inside the 25 -- it connects or it touches to the safe end and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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957 1 channels the flow through the nozzle into the reactor 2 vessel and is connected to what's called a sparger.
3 The sparger distributes the feedwater flow evenly into 4 the inside of the reactor vessel. The thermal sleeve 5 acts as a shield to the. feedwater nozzle forging and 6 connection to the reactor pressure vessel to help 7 channel the flow and also minimize thermal cycling on 8 the nozzle itself.
9 JUDGE REED: So the thermal sleeve is 10 helpful with regard to fatigue in that it reduces the 11 stress on the feedwater nozzle due to temperature 12 changes; is that correct?
13 MR. STEVENS: Yes, it's very beneficial in 14 that it protects or greatly reduces the severity of 15 transience on the nozzle itself.
16 JUDGE REED: And did you account for the 17 presence of this sleeve in your analyses?
18 MR. STEVENS: Yes, sir.
19 JUDGE REED: But that sleeve was a recent 20 addition; is that correct?
21 MR. STEVENS: Can you clarify your 22 question?
23 JUDGE REED: It was my understanding that 24 the sleeve has the sleeve been in position sine the 25 plant was NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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958 1 MR. FITZ PATRICK.: The feedwa ter nozzle has 2 alway's had a thermal sleeve in it.
3 JUDGE REED: Yes.
4 MR. FITZPATRICK: The design was changed 5 in 1976 with a sleeve that had a tighter seal than the-6 original.
7 JUDGE REED: In '76?
8 MR. FITZPATRICK: '76.
9 JUDGE REED: So I had misread some 10 document actually. So these analyses have always 11 assumed the presence of a thermal sleeve.
12 MR. FITZPATRICK: Yes.
13 JUDGE REED: So let's go back to the 14 question of dissolved oxygen. So there is an 15 allegation by NEC that, in fact, fatigue is not really 16 sensitive to dissolved oxygen, but is sensitive to 17 something else called the electrochemical potential.
18 Could you respond to th at?
19 And maybe you're not the right witness to 20 do that, but 21 MR. STEVENS: I think Mr. Fair would have 22 a better answer to that than I would.
23 JUDGE REED: Mr. Fair.
24 MR. FAIR: Yes. There has been some 25 recent data that's indicated that electrochemical NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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959 1 potential is a significant contributor to the 2 environmental, fatigue. Argonne looked at that data 3 and determined that based on some of the testing that 4 they had done, it took a certain amount of time to get 5 a proper soak, heat soak in the material so that that 6 was not a concern. It would stabilize.
7 JUDGE REED: I didn't understand what you 8 said. A proper heat?
9 MR. FAIR: Yes. Well, I'm sorry. I'd 10 like -- I used bad terminology.
11 JUDGE REED: it's just I can't hear you 12 from across the room.
1 )JUDGE WARDWELL: Could you explain what 14 electrochemical potential is inthese situations that 15 is of concern?
16 MR. FAIR: Well, it's just the potential 17 electrical field that's set up that could have an 18 impact on the fatigue -- on the environmental effect, 19 and the data that we have for environmental is 20 basically measured oxygen content, and we do. not have 21 measurements on ECP.
22 When Argonne took a look at this issue, 23 they determined it took a while for the ECP to 24 stabilize at a given oxygen content so that there may 25 be some period of time, a short period of time where NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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960 1 the ECP could have an effect.
2 JUDGE REED: So let's cut to the bottom 3 here. Is it dissolved oxygen or electrochemical 4 potential that should be the controlling factor?
5 MR. FAIR: That issue has not been totally 6 settled in the industry. Again, the data that we have 7 for the environmental effect is all based. on dissolved 8 oxygen with very small amount of data that actually 9 has ECP measures.
10 JUDGE REED: Let me turn to Dr. Hopenfeld.
11 This is your issue. Could you please state what your 12 concerns is regarding dissolved oxygen?
13 DR. HOPENFELD: First of all, T would like 14 to comment that this is not a major concern.
15 JUDGE REED: This is not what?
16 DR. HOPENFELD: This is not a major 17 concern, but it is an item that is important to 18 understand.
19 JUDGE WARDWELL: Don't you testify that 20 it's a controlling parameter?
21 DR. HOPENFELD: Yeah, I'm saying, but a
-22 major -- a major factor compared to all the others, 23 why that is an important factor. I mean, you should 24 use ECP or you should use the electrochemical 25 potential instead of concentration. It comes through NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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961 1 the uncertainties of calculating the Fen and looking 2 elaborately on that.
3 But like I said, compared to others this 4 is not high on the priority, but let me explain.
5 JUDGE REED: Let me just observe that when 6 I asked Mr. Stevens for a list of controlling 7 parameters, the most significant parameters that 8 affect fatigue, environmental parameters that affect 9 fatigue, dissolved oxygen --
10 DR. HOPENFELD: Yes, that's correct.
11 JUDGE REED: -- was number two.
12 DR. HOPENFELD: Well, oxygen is important.
13 JUDGEREED: So are you saying that you've 14 been down around number ten?
15 DR. HOPENFELD: Let me explain what I come 16 from on this. The basic mechanism of a crack 17 propagator is not 100 percent understood, but oxygen 18 creates an important part of it, but the driving force 19 is ionic dissolution. In, the case of anodic 20 dissolution you have an anode and you have a cathode 21 and you have electrochemical potential to drive the 22 reaction.
23 The reason behind the electrochemistry, 24 and you write the equation for an electrochemical 25 potential, it's the activity that comes as a basic NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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962 1 coreometer, not the concentration. But dilute 2 concentrations you can sometimes say, yes, the 3 activity coefficient is not very important and you can 4 just go directly and right Lu potential in terms of 5 concentration.
6 Now, why is that important? It was one 7 item in the table that I provide you, and the reason 8 it comes in, because it is an electrochemical 9 parameter, and you're going to basic mass transfer 10 between electrodes. You'll find out the conductivity.
11 The ionic conductivity of the water also plays a part 12 in the anodic dissolution, and I think Argonne 13 discussions this and goes into the one parameter that 14 is important.
15 In that context I was saying it's more 16 important to use the -- I just want to make sure that 17 the science is correct. As you understand, the basic 18 parameter, if you look in every textbook you'll see 19 what defines electrochemical potential in your 20 battery, in your anywhere in certain terms of 21 activity. That's the basic thermodynamic parameter, 22 not concentration.
23 However, it's difficult to measure 24 absolutely. it should be measured by- the potential, 25 but that's why people are talking concentration, but NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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963 1 you have to understand that was the purpose of it.
2 When you have an uncertainty, and Argonne alludes to 3 the fact that different conductivity affects the 4 fatigue produced. And that's where I was trying to 5 explain.
6 JUDGE WARDWELL: Did you not state at your 7 Exhibit 64, page 427 and 28 that EPRI also believes 8 that this --
9 DR. HOPENFELD: Oh, yes, yes, they did.
10 They did.
11 JUDGE WARDWELL: -- chemical naturally is 12 a controlling parameter?
13 DR. HOPENFELD: Yes, yes, sir, and if you 14 wish, if you go to -- let me see if I can find the 15 exact page where it's stated.
16 JUDGE WARDWELL: Four, twenty-seven.
17 DR. HOPENFELD: -It should be -- to be 18 considered is the electrochemical potential. They 19 stated that very clearly.
20 Now, I did see some of the testing that 21 they've been talking about, but I haven't seen -- I 22 haven't analyzed the work. It's hard to get because 23 this is not the number one priority on the 24 uncertainties here.
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964 1- to focus on why -L isn't the number one priority. Are 2 you saying that representing this electrical-chemical 3 potential or at least the effects of it can be 4 approximated by just having the concentrations of 5 dissolved oxygen represented at the --
6 DR. HOPENFELD: That is --
7 JUDGE WARDWELL: Let me finish. Okay?
8 Because then I can hear you if you would let me finish 9 my question.
10 DR. HOPENFELD: Right.
11 JUDGE WARDWELL: Let me start it again.
12 Are you saying that this electrical-chemical potential 13 can be represented by a dissolved oxygen concentration 14 in regards to its effect On fatigue we're trying to 15 analyze?
16 DR. HOPENFELD: That is correct, except --
17 JUDGE WARDWELL: Now I'll let you explain.
18 Elaborate more if you wish.
19 DR. HOPENFELD: Yes, it is correct, but --
20 JUDGE WARDWELL: Okay, but it's your 21 position that a more accurate way to do it would be to 22 measure the electrical potential precisely.
23 DR. HOPENFELD: -- not from immediately --
24 any electrochemist will tell you that.
25 JUDGE WARDWELL: How could that be done?
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965 1 Ii DR. HOPENFELD: Well, you measure the 2 electrochemical potential.
3 JUDGE WARDWELL: How?
4 DR. HOPENFELD: I don't know practically, 5 but in the plant you probably don't do it, but in the 6 laboratory they do.
7 JUDGE WARDWELL: Well, practically how can 8 you do it in a plant?
9 DR. HOPENFELD: You can'L.
10 JUDGE WARDWELL: So why are you bringing 11
- this -- so isn't the only alternative available is to 12 use dissolved oxygen?
13 DR. HOPENFELD: In the plant, yes, but the 14 point is --
15 JUDGE WARDWELL: Thank you.
16 DR. HOPENFELD: -- sir, what I'm trying to 17 say when you hear that everything is conserved, what 18 I'm trying to tell you, that there are parameters in 19 here that come into play. I think Dr. -- persons at 20 Argonne -- I can mention about the factor of one to 21 two conductivity in the plant. That's where it comes 22 in.
23 JUDGE WARDWELL: And did Argonne show that 24 the measurement of dissolved oxygen always 25 underestimated the potential that might --
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966 1 DR. -1OPENFELD: No, I don't --
2 JUDGE WARDWELL: -- the potential impact 3 associated with the electrochemical potential?
4 DR. HOPENFELD: No, I don't think they got 5-. into that detail, except that, you know, the whole --
6 JUDGE WARDWELL: So, in fact, the 7 dissolved oxygen may over estimate the impact 8 associated with this parameter.
9 DR. HOPENFELD: It could be. I don't know 10 the exact kinetics. I mean, I don't think anybody ii knows what they are, but kinetics is going on in that 12 when the crack propagates. These are theories, which 13 i6 not exact science. The basic parameters and, 14 therefore, the people at EPRI said -- a lot of people 15 believe, and they're really talking from the 16 perspective of the scientist or the perspective of the 17 people who do tests in the laboratory, who can do 18 that. They're not talking in terms of scientists at-19 the plant. I never meant to.
20 JUDGE WARDWELL: In Entergy --
21 DR. HOPENFELD: All I was just trying to 22 tell you is there's an uncertainty, and I don't want 23 to tell you the uncertainty comes from nowhere. I'm 24 just trying to say where it comes from, and that 25 uncertainty very well might --
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967 1 JUDGE WARDWELL: And it could be on either 2 side of the estimation of its impact.
3 DR. HOPENFELD: Yes.
4 JUDGE WARDWELL: Entergy's statement of 5 position, Answer 33 on page 16 said it considered 6 oxygen values and water chemistry excursions in its 7 CUF analysis. Doesn't that resolve this issue?
8 DR. HOPENFELD: Absolutely not.
9 JUDGE WARDWELL: Why not? It's also using 10 not only oxygen but also water chemistry.
11 DR. HOPENFELD: Could I refer you, sir to 12 NUREG 6583 and NUREG 6909?
13 JUDGE WARDWELL: And what's the--
14 DR. HOPENFELD: Well, in Entergy's 15 documentation it's just called NUREG 69 -- 6583.
16 JUDGE WARDWELL: What's the exhibit? We 17 need the exhibit number to find it.
18 JUDGE KARLIN: The exhibit number for 19 NUREG 6909 is, among others, Entergy 2-30. That's 20 6909, and the other one you referred is NUREG 6583, is 21 Entergy Exhibit E-206, as I have it.
22 DR. HOPENFELD: This is extremely 23 important, and I would like to read it because this 24 is --
25 JUDGE WARDWELL: Where are you at?
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968 1 DR. HOPENFELD: I'm sorry?
2 JUDGE KARLIN: What page of which exhibit?
3 DR. HOPENFELD: NUREG 6583.
JUDGE WARDWELL: Wait, wait. Got to find 5 it You have to bear with us. Sixty-five, eighty-6 three?
7 DR. HOPENFELD: At 78.
8 JUDGE WARDWELL: At 78.
9 JUDGE REED: Page 78?
10 DR. HOPENFELD: Correct.
11 JUDGE WARDWELL: And did you say 6583?
12 DR. HOPENFELD: Sixty-five, eighty-three.
13 I have this Exhibit 204. I need 204.
14 JUDGE KARLIN: Here it is. Okay. Sixty-15 five, eighty-three. On what page, sir?
16 DR. HOPENFELD: On page 78.
17 JUDGE KARLIN: Seventy-eight.
18 DR. HOPENFELD: Can I read it?
19 JUDGE WARDWELL: Yeah. Is everyone .set?
20 DR. HOPENFELD: The value of the 21 temperature 22 JUDGE WARDWELL: Now, where are you 23 reading? I' m sorry.
24 DR. HOPENFELD: End is -- oh, can I read?
25 JUDGE KARLIN: What part of the page? The NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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969 1I first paragraph, second .
2 DR. HOPENFELD: I don't have paragraph..
3 JUDGE KARLIN: All right.
4 DR. HOPENFELD: I didn't -- I don't have 5 the thing.
6 JUDGE KARLIN: It's a long page.
7 DR. HOPENFELD: Yeah. Let me read it to 8 you. It's only one sentence.
9 JUDGE KARLIN: Please read it, yeah.
10 DR. HOPENFELD: The value of the 11 temperature and dissolved oxygen may be conservatively 12 taken as the maximum value for the -- the same wording 13 were given tn us this week by Entergy when they passed 14 out, and I don't know if you have it in evidence, when 15 they passed out in slides that they wanted to talk 16 about it.
17 This is the instruction. These are the 18 specifications in NUREG 6583 as to how to use that 19 equation. What you heard from Mr. Stevens before, he 20 was talking about steady state operation. These 21 equations when you look at the equation itself, in the.
22 exponent you have temperatures, oxygen, sulfur. You 23 have strain weight. These are to be determined during 24 the transient at the surface during that time.
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970 1 your sample somewhere in the plant once a week. This 2 is not the value, the intention you formulate in 3 dividing these equations. That's not the purpose of 4 Argonne to specify Ifldt you can use the steady state.
5 Now, let me go and take another 6 document--
7 JUDGE WARDWELL: Wait a minute.
8 DR. HOPENFELD: -- what's extremely 9 important.
10 JUDGE WARDWELL: I've got to slow you 11 down.
12 DR. HOPENFELD: Sure.
13 JUDGE WARDWELL: This seems to me a 14 different discussion than the electrical-chemical 15 discussion You are now saying if I am hearing you 16 correctly that you're arguing that they're using 17 dissolved oxygen values from a steady state 18 operational 1 condition and not for the transients, and 19 that's what t-you're objecting to; is that correct?
20 DR. HOPENFELD: That's correct, but I was 21 trying to answer your question. Why is oxygen 22 important? The oxygen concentration, that's what the 23 question i 3 about. That was my response.
24 JUDGE WARDWELL: I'm sorry. I did not 25 mean to asic that question.
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971 1 DR. HOPENFELD: Weli, that's what I was 2 responding, sir. I Wasn't responding in the context 3 of electrochemical potential. There is more than a 4 uutorial kind of thing. Look. This is the --
5 JUDGE WARDWELL: Just to make sure we're 6 not wasting time --
7 DR. HOPENFELD: Right.
8 JUDGE WARDWELL: -- I'm sorry if I 9 interrupt you, but if hear that I haven't made myself 10 clear, I don't want to waste everyone's time --
11 DR. HOPENFELD.: Absolutely.
12 JUDGE WARDWELL: -- nor your efforts 13 associated WAiith this.
14 I think the last question and what I 15 intended to try to resolve was whether or not 16 Entergy's fact that they or testimony I should say 17 that they consider oxygen values and water chemistry 18 excursions in a CUF analyses does not resolve this 19 issue of best representing anything associated with 20 these parameters and their impacts on this phenomenon 21 We're trying to address.
22 And what is your response to that?
23 DR. HOPENFELD: My response is that's 24 incorrect, and that's what I started reading this.
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972 1 i understand correctly, they probably talk about 2 excursion through the crane, okay, or after heat-up 3 some time because maybe the system was opened up.
4 But what the excursion --
5 JUDGE WARDWELL: I'll ask them what they 6 meant.
7 DR. HOPENFELD: Right. If you tell me 8 what they mean by "excursion ".
9 JUDGE WARDWELL: So Mr. Fitzpatrick and 10 Mr. Stevens --
11 DR. HOPENFELD: -- I've got to make sure 12 and I tell you what I understand.
13-11 JUDGE WARDWELL: Right. So what did you 14 mean by "excursions"? The oxygen values in law of 15 chemistry excursions in your analysis.
16 MR. FITZPATRICK: Could you point to where 17 you're speaking?
18 JUDGE WARDWELL: I was looking at your 19 statement of position, Answer 33 on page 16.
20 MR. FITZPATRICK: Thirty-three.
21 JUDGE WARDWELL: I haven't typed it.
22 MR. LEWIS: Point of clarification. Are 23 you referring to the testimony, the post -- statement 24 of position? Because if it's A-33, it's our 25 testimony.
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973 1 JUDGE WARDWELL: It could be the 2 testimony.
3 JUDGE KARLIN: Yeah, it's Answer 33 on 4 page 16. Is that where we are?
5 (Pause in proceedings.)
6 MR. FITZPATRICK: Is that Question 56 on 7 page 33?
8 JUDGE WARDWELL: I have Answer 57 on page 9 33, and I think it's also on 56, page 32. I was 10 trying to look at the other one also. And both of 11 those answers, 56 and 57.
12 JUDGE KARLIN: And now we're referring to 13 what was formerly Entergy Exhibit 2.82.01 on pages 32 14 and 33, which is now no longer an exhibit.
15 JUDGE WARDWELL: But as I interpret what 16 you were saying there, the oxygen values in the water 17 chemistry excursions were included in your CUF 18 analysis. Is that correct or is it not?
19 MR. FITZPATRICK: Yes. We get the single 20 value for oxygen, all the transients. That value 21 represented 13 years of measurement data including 22 start-ups and shutdowns, and that was an average plus 23 one standard deviation.
24 JUDGE WARDWELL: Okay. So you took the 25 average of a transient DO levels -- say that again.
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974 1 MR. FITZPATRICK: The oxygen measurements 2 I used to take at least twice a day. It's either 3 daily or twice a day. I always took it more during 4 this time when I tried to get this system down. That 5 data, we took a statistical average of it, and we 6 added the standard deviation. So the expressions in 7 the planning office are based on 50 ppp feedwater 8 oxygen, will typically run 36 to 40, in there.
9 JUDGE WARDWELL: How much does it vary 10 during the transience?
11 MR. FITZPATRICK: During the transient, I 12 don't think it varies that at all during a transient.
13 During a transient, that would be an injection.
14 Were the vessels hot? Once the 15 hydrochloric chemistry and the oxygen injection system 16 is stable, that doesn't change unless the system goes 17 off line. But there is no direct correlation between 18 the transient -- the oxygen injection, the hydrogen 19 injection system, and a transient.
20 JUDGE WARDWELL: Dr. Hopenfeld, do you 21 agree with that?
22 DR. HOPENFELD: No, absolutely not. If 23 you look, please, at JH-65.
24 JUDGE KARLIN: Give us a moment to find 25 it. That's okay.
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975 1 DR. HOPENFELD: I think the pages are 2 there. Do you see there --
3 JUDGE WARDWELL: What are you referring 4 to?
5 DR. HOPENFELD: JH-65.
6 JUDGE WARDWELL: I know, but where in 7 that?
8 DR. HOPENFELD: It's on the -- there are 9 two pages in there. One pages shows you the date on 10 -- the second page showing the oxygen.
11 JUDGE WARDWELL: So Fiqure 1?
12 DR. HOPENFELD: Yeah, it's only one.
13 JUDGE WARDWELL: Page 53.
14 DR. HOPENFELD: Right. Two, fifty-three, 15 is that what it is?
16 JUDGE WARDWELL: I'm looking at the 17 exhibit. You tell me what you're looking at.
18 DR. HOPENFELD: Yeah. Well, I thought I 19 did. It's 10ECJ865. There are only two pages in that 20 exhibit. I'm talking about the graph, the graph that 21 gives you oxygen concentration in ppm versus 22 temperature in degrees C. Only two pages, unless 23 you're looking at a different 24 JUDGE WARDWELL: I have three pages.
25 DR. HOPENFELD: Okay.
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976 1 JUDGE WARDWELL: But you're referring to 2 Figure 1 --
3 DR. HOPENFELD: Correct, correct, right.
4 Correct. It's only one figure.
5 You can see in that oxygen concentration 6 either hydrogen chemistry or normal state chemistry 7 goes up by an order of magnitude during that trend, up 8 and down. Another word I'd like to say is counting on 9 that gases have a negative solubility coefficient. So 10 as the temperature goes down, the oxygen concentration 11 goes up an order of magnitude.
12 Furthermore, if you will now permit me to 13 finish my line of thoulght, if you're going out to 14 NUREG 6909, and again, this is a very important --
15 it's important you understand it, and this kind of 16 misunderstanding about what we're talking about was 17 excursion because you can have excursion and do steady 18 state, too.
19 JUDGE KARLIN: What page? Sixty-nine, oh, 20 nine?
21 DR. HOPENFELD: A-5.
22 JUDGE KARLIN: A?
23 DR. HOPENFELD: A-5.
24 JUDGE KARLIN: A75.
25 DR. HOPENFELD: NUREG 6909.
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977 1 JUDGE KARLIN: A-5. This is the Appendix
- 2. 5.
3 DR. HOPENFELD: A-5, right. Sir, you 4 asked what is the difference becween these two NUREGs, 5 and you didn't get the answer.
6 JUDGE KARLIN: Okay. It's NUREG 6909, 7 page A-5.
8 DR. HOPENFELD: Can I read it?
9 JUDGE KARLIN: Yes, sir.
10 DR. HOPENFELD: The dissolved oxygen value 11 is obtained from each transient constituting the 12 stress cycle. For carbon and low alloy steel the 13 dissolved oxygen content, DO, associated with stress 14 cycle is the highest, highest oxygen content level in 15 the transient. And for us ferritic steel is the 16 lowest.
17 A value of .4 ppm. It's .. 4 ppm. It's 18 400 parts per billion is recommended. This is the 19 instruction with the package. What was passed to us 20 the other day was the same wording that said you 21 should value the oxygen at the highest concentration, 22 the highest concentration due to the transient, both 23 in NUREG 6583, but they didn't say that their 24 recommendation, that specification is 400 parts per 25 million.
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978
! Now, if you take this togecher with what 2 you see, the EPRI data, then your next step is to make 3 the calculation, and I would like to make the same 4 calculatioii to show you the result of mny calculation, 5 about the same time that Mr. Stevens did, and I'd like-.
6 to read you those numbers so we can compare what those 7 Fen values are for only that one uncertainty, which is 8 the oxygen content.
9 Can I do that?
10 JUDGE KARLIN: Well, didn't you put that 11 in your testimony?
12 DR. HOPENFELD: No, I did not. I just 13 calculated it about the same time he did.
14 JUDGE KARLIN: Well --
15 DR. HOPENFELD: I did put some of the 16 testimony -- I gave you the order of magnitude, yes.
17 In the table, I think it was Item 10, I 18 said use 19 JUDGE WARDWELL: Item 10 of what?
20 DR. HOPENFELD: The table, the table that 21 I provided.
22 JUDGE KARLIN: Ah, your table in your 23 rebuttal testimony?
24 DR. HOPENFELD: Yes. I'll give you the 25 number of the table.
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II 979 JUDGE KARLIN: Table 13 --
DR. HOPENFELD: Just a second and I'll 3 give you the table number.
4 JUDGE WARDWELL: Table 1.
5 DR. HOPENFELD: JH-63, there's a table 6 there.
7 JUDGE WARDWELL: Page 4?.
8 DR. HOPENFELD: Yes, I believe it is page 9 4, yes. On Item 10 there, I told you the oxygen 10 count, and if you put a factor of five in there it 11 increases the Fen by -- I don't know -- a factor of 50 12 or something, a factor of 55.
13 Do you see down there?
14 JUDGE WARDWELL: And that's with a 15 factor --
16 DR. HOPENFELD: Right.
17 JUDGE WARDWELL: That's with a factor of 18 four in the oxygen.
19 DR. HOPENFELD: Correct, correct. Because 20 you see, it's an exponential which is being amplified 21 by the -- you take the exponential and you see how 22 sensitive i t is to the oxygen-. You know, if you take 23 DF, DO to give you the sensitivity, the derivative 24 will give you sensitivity, the parameter.
25 You see how -- what it is, it makes a big NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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980 1 Ii difference because now you have it ba'ck here, and 2 that's why I gave you an order of magnitude. I told 3 you what the problem is, and all I'm trying to tell 4 you, I went through the same thing and I tried it by-5 pencil over th-e weekend, and I'd like to give you
_6 those numbers.
7 JUDGE KARLIN: Sure, all right.
8 DR. HOPENFELD: Okay.
9 JUDGE KARLIN: Tell us what they are.
10 DR. HOPENFELD: You'll have something to 11 compare one to one. It's number one; it's component 12 number one, between .6, .8. This is the CUFen, that 13 only due to the interest of the oxygen. There are 14 other parameters. I'm just talking about 01, which 15 hopefully we'll get to others.
16 JUDGE WARDWELL: We understand.
17 DR. HOPENFELD: But 01, the oxygen, okay?
18 One, I can repeat the number, .6 to .8.
19 Two, 4.5 to 6.
20 Three, 6.7 to 8.9.
21 Four, which is stainless steel, they're 22 doing the right thing. They used the lowest oxygen.
23 That's NUREG 6909, but you cannot use -- you see, the 24 accident is because the mechanism of crack 25 propagation. The theory is that the oxygen operates NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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981 1 differently through the 2 JUDGE KARLIN: Keep giving us the values.
3 What are the-values?
4 DR. HOPENFELD: Yeah. I was just going to 5.. tell you I didn't calculate it.
6 JUDGE KARLIN: Oh.
7 DR. HOPENFELD: I didn't calculate it 8 because their numbers I agree with it.
9 JUDGE KARLIN: Oh., okay.
10 DR. HOPENFELD: I agree with it with ii respect to that aspect alone, not others.
12if- JUDGE KARLIN: Okay, fine.
13 DR. HOPENFELD: But I keep qualifying 14 myself. Just remember I'm talking about the effect of 15 oxygen only. They did it correctly.
16 Five, I couldn't find some data. So I 17 just skipped that one. I couldn't find it over the 18 weekend, but it's more than one definitely, but I just 19 couldn't do it exactly.
20 Seven is one and 1.2.
21 Eight is 1.2 to 1.6.
22 Nine is 7.2 to 10.3.
23 And ten is 2.5 to 3.5.
24 JUDGE WARDWELL: To clarify --
25 DR. HOPENFELD: Yes.
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982 1 JUDGE WARDWELL: --- what was the value of 2 oxygen that they used or what was the value that you 3 used?
4 DR. HOPENFELD: Okay. That's what -- the 5 reason that you had two numbers here __
6 JUDGE WARDWELL: What was the value that 7 they used and what was the value that you used?
8 DR. HOPENFELD: They okay. Very good.
9 Let me just tell you what I got. I took their 10 equation, the numbers that they used. They used 11 between, depending on the component, between 50 to 100 12 on the average.
13 JUDGE WARDWELL: Parts per million.
14 DR. HOPENFELD: I couldn't go to that 15 exact because 16 JUDGE WARDWELL: Parts per million.
17 DR. HOPENFELD: -- they average. They had 18 96 on one side, your normal operation. The hydrogen 19 is 150. 1 just didn't want to do --
20 .JUDGE WARDWELL: Is that ppb or ppm?
21 DR. HOPENFELD: I did it over the weekend 22 -- I'm sorry?
23 JUDGE WARDWELL: Was that ppm- or ppb?
24 DR. HOPENFELD: Ppb.
25 JUDGE WARDWELL: Okay. B.
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983 1 DR. HOPENFELD: So I just took their 2 numbers, plugged the thing back into the equation, 3 pulled out the appropriate factor, and plugged my 4 number. Now, you have to realize the equation is 5 written in such a way that if you go about 500 parts 6 per billion, it doesn't make any difference because 7 that's constant. It's a number. It's a log of 12.5.
8 If you look at the -- you see it doesn't make any 9 difference. So once you get out of the 12.5,- it 10 doesn't matter.
i1 JUDGE WARDWELL: So for carbon steel and 12 low alloy steel --
13 DR. HOPENFELD: Correct.
14 JUDGE WARDWELL: -- the higher the 15 concentration of dissolved oxygen, the higher the Fen 16 value.
17 DR. HOPENFELD: Absolutely. Now, let me 18 tell you one more thing if I may. I gave you three 19 reasons why that's so. I'd like to give you another 20 one, and the only reason I'm doing it, well, I'm 21 probably getting excited here, but the problem is when 22 I do this conservative and everything is conservative, 23 and we get to this mind 24 JUDGE WARDWELL: We understand that. Curb 25 your enthusiasm and let's go --
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984 1 DR. HOPENFELD: But what -- but let--
2 JUDGE WARDWELL: Is that all you wanted to 3 say?
4 DR. HOPENFELD: No, no, no, 11o. What I 5 want to say, you- certainly can check on what I'm 6 saying, what I'm telling you here. And the incentive 7 check, you take a look at EPRI. Okay? Take a look at 8 what EPRI does about that. They realize; they realize 9 that this whole concept of Fen is work in progress.
10 They say these work. It's a work. in progress. I can 11 quote you the number where they say that.
12 Now, many uncertainty, many loose ends.
13 The bottom line is you define the people who are the 14 analysts. You make sure they understand what's behind 15 that. That's what it is. The whole thing is not 16 ready for the market yet. That doesn't mean you go 17 home and don't do anything. What you do is in the 18 back of your mind you say, "Well, I'm going to do 19 this. I'm going to use a conservative number. I'm 20 going to use the upper bound, but I want to make sure 21 I run it, I check it by somebody that these are real 22 numbers, not just because I decided it's a 23 conservative number."
24 JUDGE WARDWELL: We are --
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985 1 f jgu.. that I was going to provide you because chat 2 figure is NEC JH-84.
3 JUDGE KARLIN: It must be in the 4 rebuttal.
5 DR. HOPENFELD: Yeah, it is in the 6 rebuttal, right, and you see that --
7 JUDGE KARLIN: Oh, no, we don't see 8 anything yet.
9 DR. HOPENFELD: Oh, okay. I have to go 10 and get it myself. I could say the time table is the 11 result if you want to, but --
12 JUDGE KARLIN: Hold on a second.
1 MS. TYLER: Tell me the title. of the 14 document. He doesn't have an Exhibit 84. What's the 15 title of the document?
16 DR. HOPENFELD: Yeah, it's NEC JH-64.
17 MS. TYLER: Sixty-four.
18 JUDGE KARLIN: Yeah.
19 DR. HOPENFELD: Sixty-four, and it's page 20 418. Oh, did I say --
21 JUDGE KARLIN: You said 84.
22 DR. HOPENFELD: I'm sorry. I'm sorry.
23 It's 64. I apologize.
24 JUDGE WARDWELL: Well, I'm glad I have 25 never made a mistake either.
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986 1 (LaughLer.)
2 JUDGE WARDWELL: I'm with you. I know how 3 this is when you know where you are. Okay. What page 4 aLe you on?
5 DR. HOPENFELD: Page 418. See, at the 6 bottom carbon steel, Fen?
7 JUDGE WARDWELL: Yes. Is everyone with 8 you? Yeah.
9 DR. HOPENFELD: Are we on the same page 10 now?
Ii JUDGE WARDWELL: Yeah.
12 DR. HOPENFELD: Okay. You see that my 13 numbers, according to the numbers, I didn't give yuu 14 the Fens, but roughly they're on the order of 15 magnitade -- I can give them to you, but they are 16 between 80 to 100. That's the final CUFens.
17 If you look here you see what EPRI has is 18 they have F 550. I think that's about the temperature 19 we're talking about. Do you see the upper bound is 20 80? And this is not my calculation. It's sort of an 21 independent checking. So you see my number is 22 consistent with EPRI. EPRI numbers show that the 23 numbers in this area are something on the order of 80.
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987 1 revise rhis and call it minimum.
2 MR. STEVENS: May I clarify?
3 JUDGE WARDWELL: In a second. I just want 4 to ask a couple more fixing points and then I'll get 5 back to you. I'll get back to Entergy to respond.
6 So in conclusion, it's your position that, 7 in fact, they are not conservative in regards to the 8 value they selected for dissolved oxygen for carbon 9 steel and low alloy steel.
10 DR. HOPENFELD: (Unintelligible.)
ii JUDGE WARDWELL: It's your position that 12 their analysis for stainless steel in regard to 13 dissolved oxygen alone is adequdte.
14 DR. HOPENFELD: Yes.
15 JUDGE WARDWELL: Thank you.
16 What is your response to everything he has 17 just said, Mr. Stevens.
18 MR. STEVENS: Where do I start? Let's 19 start with the NEC JH-64 document, otherwise known as-20 MRP-47, Rev. 1. I think I can comment on that because 21 I was the primary author of that document.
22 JUDGE WARDWELL: So this is the EPRI 23 document.
24 MR. STEVENS: This is the EPRI document.
25 Let's start with the figure on page 418. What that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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988 1 figure is- showing is Fen is a function of temperature 2 under various oxygen and strain rate loads. The top 3 curve, the range of these are trying to show to 4 individuals, given the range of the parameters defined 5 by these equations, how Fen can vary.
6 There's several variables. So you have to
.7 take several graphs to show people the variance on any 8 of these variables. This one here is trying to show 9 as a function of temperature when you apply the 10 different oxygen levels how the Fen would apply. It 11 doesn't indicate in any way that those indications are 12 valid for Vermont Yankee or any other plant. It's 13 just merely demonstrating to you the variation in Fen 14 as a function of temperature under those variations.
15 The top curve, I think I even said this 16- yesterday in response to one of Dr. Reed's questions.
17 The Fen can be as high as 140 as indicated by that 18 figure, but that's under oxygen levels greater than 19 500 ppb and very low strain rate.
20 Those conditions don't exist at Vermont 21 Yankee, and whereas I would agree that that would be 22 a very conservative assessment, it's also very 23 unrealistic.
24 JUDGE WARDWELL: But have you not 25 characterized all of your analyses as being very NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1989 1 conservative and very bounding? Is it fair to say 2 then that, in fact, your dissolved oxygen -- your 3 selection of dissolved oxygen in your analysis is more 4 realistic than it is bounding?
5 MR. STEVENS: I would characterize it, 6 sir, as being bounding for the conditions we have as 7 info, which are for the Vermont Yankee plant. They 8 were labeled as maximum Fens as applied to Vermont 9 Yankee, riot as applied to the maximum you could 10 possibly achieve through these relationships.
11 JUDGE WARDW7ELL: How would -- and if I'm 12 wrong in remcmbering this -- if I understand it 13 correctly, you selected a value that is an average 14 plus one standard deviation, and that average included 15 all operational conditions with the transients 16 included in it, but wouldn't that value, in fact, be
- 17. very biased towards normal operational conditions?
18 MR. FITZPATRICK: Yes.
19 JUDGE WARDWELL: Is that an appropriate 20 conservative value or would the transients dominate 21 the potential failures that we're trying to evaluate 22 in-this contention?
23 MR. FITZPATRICK: In relation to the 24 oxygen levels in the transients, your higher oxygen 25 during start-up, which is a very slow, and sometimes NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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990 1 a cycle which is a gradual cool heat-up with a gradual 2 cool down. The contribution to the CUF from the 2 start-up is very small compared to the contribution 4 from an injection from HIPSI or the feedwater.
5 JUDGE KARLIN: Could you speak up, Mr.
6 Fitzpatrick?
7 MR. FITZPATRICK: The contribution to the 8 CUF from a start-up or a shutdown transient when the Q9 oxygen data shows that status for tht system, you're 10 going to higher oxygen when you're starting up the 11 plant as the systems come on line. That fatigue 12 contribution from that start-up is a vefy small 13 contribution to the total CUF.
14 The primarily contributors are when the 15 plant is running and something happens, when you get 16 the injection of the plants, when you're getting a 17 steady state. Also there's no direct correlation of 18 a higher oxygen content from any measurement we've 19 seen over there. The oxygen went up for this 20 transient. It just the transients occur very quickly.
21 There's nothing to change the oxygen.
22 JUDGE WARDWELL: But wouldn't it be more 23 appropriate to use just the oxygen levels that were 24 observed at the 20-some transients, or whatever it 25 was, that we were talking about yesterday -- I forgot NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVEý, N.W.
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991 1* -- that we're --
2 MR. FITZPATRICK: Those are design 3 transients.
4 JUDGE WARDWELL: analyzing as Ute 5 cumulative effects on this bending of the paper clip?
6 MR. FITZPATRICK: Those are the design 7 transients. There is no measured -- the measured data 8 that we've taken over time, we will shut the plant 9 down, show that there is no real change. Say that on, 10 plant trips I have to look it up. For an example, 11 if a plant trips, the 02 data is carried, still 12 measured the same frequency, and you don't see any 13 change until later on. You don't see any change to 14 the transient.
15 MR. STEVENS: May I clarify? The oxygen 16 measurements that Mr. Fitzpatrick is referring to are 17 indicative of what they would be during transients 18 that cause dominant fatigue.
19 The other response I was going to make 20 with Exhibit NEC JH-65, which was this paper from --
21 JUDGE WARDWELL: Before you go to that --
22 I'm sorry to interrupt, but I just want to make sure 23 I understood what you just said. Would you repeat 24 that? I don't know what you're referring to -- the 25 comment.
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992 1 MR. STEVENS: Mr. Fitzpatrick said that 2 the oxygen levels are monitored once or twice daily on 3 a continuous basis.
4 JUDGE WARDWELL: Riyht.
5 MR. STEVENS: And those oxygen levels --
6 because of the water chemistry control and all of that 7 during plant operation are indicative of what they 8 would be if a transient occurred during that period, 9 in between reads if you will --
10 JUDGE WARDWELL: Can I stop you right 11 there with a promise I'll get back to you?
12 MR. STEVENS: Yes.
13 JUDGE WARDWELL: Dr. Hopenfeld, what 14 indication do you have, or evidence do you have, that 15 the oxygen levels could be as high as what you use in 16 your analysis at Vermont Yankee?
17 DR. HOPENFELD: Well, for one thing, it's 18 plain physics. If I didn't know anything else, I 19 would tell you that the temperature goes -- as the 20 temperature goes down, the oxygen concentration goes 21 up, you saw the--
22 JUDGE WARDWELL: Sorry. Say that again.
23 It's hard to --
24 DR. HOPENFELD: As the temperature -- the 25 solubility of gases is inversely proportional to the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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993 I temperature, which is by Henfy's Law, whatever. When 2 the temperature goes down, the oxygen concentration 3 goes up. The equation that you have to resolve here, 4 or solve, are -- those require you to find out what 5 the oxygen concentration is during the transient at 6 the surface, -not somewhere else.
7 And EPRI makes the point very, very clear 8 in their writeug. I can't -- I don't know if I can 9 find the page. Maybe someone can find. it for me.
10 They say that oxygen is unknown in the transient.
11 it's c*ompletely opposite, so Mr. Stevens said. He 12 says he knows it.
13 I'd say I don't understand the issue. I 14 think maybe they weren't that careful or maybe they 15 didn't understand it to that degree, or for whatever 16 reason, when they wrote 6583 they told you to 17 calculate the oxygen at its maximum boundary to the 18 transient. In 6909 they specified 400, not only the 19 shutdown -- not only during the startup/shutdown, but 20 let me answer about the shutdown, and let me --
21 JUDGE KARLIN: Dr. Hopenfeld, may I just 22 interrupt? This is strange, if we go -- you're citing 23 at the EPRI document, NEC Exhibit JH-64, right?
24 DR. HOPENFELD: Yes.
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994 i reliability gui<delines for addressing fatigue 2 environmental effects in a license renewal 3 application, MRP-47. This is the -- EPRI's guidance 4 on this issue. And if we go to page iii of the 5 matter, it says that the author of. that document is 6 Gary Stevens, who is sitting right there next to you.
7 And so I'm very -- I have a difficult time with Dr. --
8 -when Mr. Stevens tells me that -- what they say, and 9 you're saying that it's directly opposite. I mean, he 10 wrote the report.
11 DR. uOPENFELD: What I'm saying is the 12 numbers that I have calculated, according to their 13 equation, their values --
14 JUDGE KARLIN: Yes.
15 DR. HOPENFELD: -- substituting their 16 oxygen content, which was 50 to 100 -- whatever it was 17 -- with my numbers, which are -- which were prescribed 18 by NUREG-6909, which says all transients use 400 parts 19 per billion. That's what they recommend to use with 20 those equations during transient.
21 JUDGE KARLIN: And let me ask, in this 22 case as I understand it, the dissolved oxygen value 23 that was used was 50 parts per billion, is that right?
24 DR. HOPENFELD: 50 to 100, depending on 25 the component.
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995 i JUDGE KARLIN: Okay. Let me ask Mr.
2 Fitzpatrick on that. What dissolved oxygen value was 3 used in calculating these Fens?
4 MR. FITZPATRICK: So let me ask --
5 JUDGE KARLIN: I read somewhere that it 6 was 50 parts per billion based on this 13 years and 7 all that other stuff.
8 MR. FITZPATRICK: That's the feedwater 9 line on the feedwater safe end, dissolved oxygen 10 concentration.
11 JUDGE KARLIN: Okay.
12 MR. FITZPATRICK: Inside the reactor, the 13 oxygen concentration varies due to radioelectrolysis 14 with chemistry going on inside the core. Most of the 15 -- when the water goes through the core, it creates 16 steam. A lot of the oxygen goes out.
17 Throughout the circuit, EPRI has a program 18 that determines oxygen levels around the circuit. So 19 each section of the lesson there are values for 20 dissolved action.
21 JUDGE KARLIN: So do you agree with what 22 Dr. Hopenfeld just said, that you -- that Entergy used 23 values from 50 to 100 parts per billion 24 MR. FITZPATRICK: Even higher than that.
25 JUDGE KARLIN: -- oxygen.
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996 1 MR. FITZPATRICK: Even higher than that.
2 DR. HOPENFELD: On the average.
3 JUDGE KARLIN: Okay. On the average.
4 DR. HOPENFELD: We really --
5 JUDGE KARLIN: Well, what size did you 6 use? I mean 7 MR. FITZPATRICK: Exactly?
8 JUDGE KARLIN: Well, if you can --
9 JUDGE WARDWELL: If you've got them handy, 10 yes.
11 JUDGE KARLIN: Yes.
MR. FITZPATRICK: It's E-212.
13 JUDGE KARLIN: E?
14 MR. FITZPATRICK: E-212. Table 1.
15 JUDGE KARLIN: E-212.. What was. the page?
16 MR. FITZPATRICK: Page 14.
17 JUDGE KARLIN: E-212 is? Could you 18 identify tha*t?
19 MR. FITZPATRICK: It's the EPRI 20 calculation for VY 16Q-303.
21 JUDGE KARLIN: Okay. Dated?
22 MR. FITZPATRICK: It's dated 7/5/07.
23 JUDGE KARLIN: Okay. We're with you. And 24 what page?
25 MR. FITZPATRICK: Page 14.
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997 1 JUDGE KARLIN: Page 14. All right. And 2 what is that we're looking at?
3 MR. FITZPATRICK: All right. Those are 4 inputs --
5 JUDGE KARLIN: Are those your dissolved 6 oxygen levels that you used?
7 MR. FITZPATRICK: Dissolved oxygen levels 8 from each of the components evaluated in the analysis.
9 JUDGE WARDWELL: How do you reconcili that 10 with the recommendation in 6909 that we should be 11 using 400 parts per billion?
12 MR. FITZPATRICK: He misquoted the last 13 sentence in the appendix on 6909, on page A-5.
14 JUDGE KARLIN: All right. Hold on.
15 MR. FITZPATRICK: It's the bottom 16 sentence.
17 JUDGE KARLIN: We're at Exhibit --
18 MR. FITZPATRICK: 6909, Exhibit --
19 JUDGE KARLIN: A-230 at page A-5, is that 20 right?
21 MR. FITZPATRICK: That's correct.
22 JUDGE KARLIN: Okay. The last sentence on 23 that page?
24 MR. FITZPATRICK: The sentence says, "A 25 value of .4 ppm for carbon and low-alloy steels and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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998 1 0.05 ppm for austenitic steels can be used to perform 2 a conservative evaluation."
3 JUDGE KARLIN: Okay.
4 MR. FITZPATRICK: It's not prescriptive.
5 JUDGE KARLIN: Not prescriptive, all 6 right.
7 MR. FITZPATRICK: It says "can."
8 JUDGE KARLIN: And-since you wrote it, Mr.
9 Stevens, what did you mean by "can"? No, I'm sorry, 10 you didn't write this one. This is 6909. I'll 11 withdraw the question.
12 Is there any place -- well, that seems to 13 be -- is there any other indication in 6909 that some 14 other value can be used? I mean, are-they just sort 15 of throwing that out there?
16 MR. FAIR: If I could help?
17 JUDGE KARLIN: Yes, Mr. Fair.
18 MR. FAIR: This was put in there in case 19 somebody that's using this procedure does not have 20 dissolved oxygen to input.
21 JUDGE KARLIN: Doesn't have the actual 22 values.
23 MR. FAIR: That's right.
24 JUDGE WARDWELL: That it would be 25 permissible to use this --
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999 I MR. FAIR: -' a --
2 JUDGE WARDWELL: -- and still meet the reg 3 guide, if that's what --. I mean 4 MR. FAIR: That's correct.
5 JUDGE WARDWELL: -- the NUREG, if that was 6 of interest --
7 MR. FAIR: I --
8 JUDGE KARLIN: Dr. Hopenfeld, would you 9 agree wiLh that?
10 DR. HOPENFELD: I would. I would agree 11 with that, to the extent they had a -- they had a 12 instrument sitting at the surface of each of those 13 components measuring the oxygen. During their 14 training they don't have anything like that.
15 JUDGE KARLIN: All right. So let me stop 16 you there. So --
17 DR. HOPENFELD: And that is what is 18 recognized. I think this -- what Mr. Fair said, he 19 reads what Argonne could have thought about it, and 20 then the definition is, you know, what chem is? I 21 don't know what --
22 JUDGE REED: Do you believe that the 23 oxygen concentration at the surface of these 24 components is larger than the bulk oxygen?
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1000 1 physics. There is about --
2 JUDGE REED: Aoplied physics.
3 DR. HOPENFELD: It increases by an order 4 of magnitude going from 50 to 100.
5 JUDGE REED: But is that -- first of all, 6 i don't understand the physics,, and I'm -not sure we 7 should take the time to delve into it. But is that 8 the assumption in which these curves were generated?
9 MR. FAIR: Yes, it was the 10 JUDGE REED: Was it the local right next 11 to the --
12 DR. HOPENFELD: Yes.
13 JUDGE REED: How did you measure that, 14 then? I don't believe that.
15 DR. HOPENFELD: The assumption, that those 16 things were generated in a laboratory, temperature 17 uniform, oxygen uniform, measured -- everything was 18 measured accurately. Then, I am taking this and 19 trying to apply it to --
20 JUDGE REED:- If the curves are correlated 21 against the bulk oxygen content, that's what you have 22 to use, not the content adjacent to the surface of the 23 metal, because that's not how the curve is run.
24 DR. HOPENFELD: They're the same. The 25 two --
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1001 I JUDGE REED: Pardon me?
2 DR HOPENFELD: In a case of -- where the 3 curves were used, they are the same.
4 JUDGE REED: They're the same in the 5 lower -- they're the same in the lab, but not in the 6 reactor.
7 DR. HOPENFELD: They were not writing the 8 train. They were writing the steady-state.
9 JUDGE WARDWELL: Let me see if I can help 10 clarify,, at least for me. It may not for you, Mr.
11 Reed, but -- Mr. Fitzpatrick, do you dispute the fact 12 that solubility changes dramatically with temperature?
13 MR. FITZPATRICK: No. That's physics.
14 JUDGE WARDWELL: During transients, how 15 does the temperature vary in these components?
16 MR. FITZPATRICK: Measure each transient, 17 which will go from operating down to 100 degrees 18 Fahrenheit for a certain transient.
19 JUDGE WARDWELL: That's a pretty drastic 20 temperature change, isn't it, for that component.
21 MR. FITZPATRICK: Yes.
22 JUDGE WARDWELL: Would you not expect the 23 dissolved oxygen to increase by several factors, if 24 not orders of magnitude?
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I1 1002 i Liming. If the transient is very rapid, I don't think 2 it could -- in order for the chemistry to happen, to 3 occur, I --
4 JUDGE WARDWELL: What was --
5 MR. FITZPATRICK: I didn't get to that 6 level of chemistry, but the phenomenon is there.
7 JUDGE WARDWELL: Mr. Stevens, what was the 8 basis for your selection of those values we were 9 looking at in the previous exhibit? E-212 VY, page 10 14. We look at DO values, as you said, between 50 and ii 100.
12 MR. STEVENS: Those values were provided ii 13 to us by Entergy, consistent with what Mr. Fitzpatrick 14 had testified earlier.
15 JUDGE WARDWELL: And, Mr. Fitzpatrick, 16 which of those -- what is the basis for those in 17 regards to how you incorporated the change in 1,8 dissolved oxygen associated *with a change in 19 temperature for each of those components and the 20 resulting change in solubility of dissolved oxygen?
21 MR. FITZPATRICK: It wasn't evaluated to 22 that specific level. The oxygen levels given were 23 based on an EPRI model reactor with different 24 operating conditions -- normal water chemistry and for 25 hydrogen water chemistry at different power levels.
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1003 1 And there is representative steady-state at those 2 power levels.
3 JUDGE WARDWELL: It's only during the 4 transients that these cumulative use factors are 5 evaluated, correct?
6 MR. FITZPATRICK: If you don't have a 7 transient, you don't have any usage, yes.
8 JUDGE WARDWELL: And as I'm hearing now, 9 that change in temperature of that component is very 10 influential in determining the dissolved oxygen that's 11 available at that transient.
12 MR. FITZPATRICK: Yes. And 4t -- that's 13 one part of the Fen expression. if the transient 14 occurs very fast, you have a strain rate component,
- 15. which cancels out that content.
16 MR. STEVENS: May I add some clarification 17 for you?
18 JUDGE KARLIN: Sure, go ahead, sir.
19 MR. STEVENS: I'm going to try and clarify 20 where -- your oxygen questions. We have talked about 21 a variety of inputs here. We have talked about an old 22 EPRI paper from 1983. We have talked about 23 temperature. I'm going to go back to NEC JH-64, which 24 is the --
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1004 1 time I promised I'd get back to you and I haven't 2 gotten back to you?
3 MR. STEVENS: That's kind of where we are, 4 yes.
5 JUDGE WARDWELL: I'm off the hook for 6 that.
7 MR. STEVENS: This is the MRP guidance for 8 license renewal that I authored. And we in the 9 last 45 minutes or so; we have talked about ECP, we 10 have talked about oxygen, we have talked about 11 temperature. And this document identified that these 12 are some issues. And as Mr. Fair testified, there i3 have been some other observations and data taken on 14 these.
15 But what this document basically says is 16 what we have is the best -- the best method based on 17 what we know today. And this identifies things like 18 ECP and how some of the experts have said maybe that's 19 a better parameter. It talks about time history, 20 variation of things during transients, and then it 21 makes a recommendation that's based on all of these 22 best practices and knowledge of the industry on what 23 to do.
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1005 1 document. And at the bottom it makes a recommendation 2- on what to do, and it points at a section in this 3 document -- 425 -- and says, "This is what you should 4 do." And what it says you should do for oxygen is 5 exactly what we did for the Entergy evaluation.
6 And what this document says is, given all 7 of these inputs and issues that have been identified, 8 that- is the best way to evaluate this particular issue. And what it would say is to take the 10 measurements in the plants, the bulk levels, and it 11 would say to take those and time-averace them, and use 12 those inputs into your analysis. And that's what we 13 did.
14 And, in addition, we -- to the average-we 15 took a one sigma deviation on those to make sure we 16 bounded some of these variations that occurred over 17 the time in the plant. So we are following the 18 guidance and the methodology that has been defined to 19 us based on all of the information we have at this 20 point.
21 On the 1983 EPRI paper that shows very 22 high oxygen content, the Figure 1 of NEC JH-65, we 23 don't know where these measurements were taken. We 24 don't know what plant they were taken. We have no 25 reason to know whether they're applicable at all to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1006 1 Vermont Yankee.
2 What we might be able to infer from some 3 of the wording in here is that these are .related to 4 BWR startup events. It does say that in the texz, 5 although it does not say specifically that that's 6 where this data was taken.
7 So there's a couple of observations we can 8 make on that. First off, at least half of the data or 9 more is below 150 degrees Centigrade, which is a 10 threshold temperature below which environmental 11 effects don't apply or Fen is one.
12 And, secondly, we know from our analysis, 13 as well as 40 years of experience with doing these 14 analyses, startup events contribute insignificantly to 15 fatigue. So, and then, the fact that this paper is 25 16 years old aimed at stress corrosion cracking issues, 17 you know, we have to be careful on how we apply that 18 to environmental fatigue analyses today.
19 So my point would be how we evaluated 20 oxygen and put it into the- relationship is exactly 21 consistent with all of the guidance out there by EPRI 22 and the industry.
23 JUDGE WARDWELL: Well, I think we've got 24 the picture on DO and ECP as best we can. Would you 25 like to add anything else?
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1007 1 DR. HOPENFELD: I'd like to add a couple 2 of things. For one, with regard to the word "can,"
3 I'm not --
4 JUDGE KARLIN: I'm sorry, I didn't hear 5 that.
6 DR. HOPENFELD: That the mention of the 7 word "can," I mean, Mr. Fitzpatrick said that you 8 don't really have to do it because it says "you can 9 use it." I don't think the intent behind that --
10 because they still don't measure the oxygen 11 concentration during the transient at the surface.
12 And the data was looked at under steadS-state 13 conditions.
14 Dr. Chang, when he went to the ACRS, he 15 told them, because the question about oxygen came up, 16 obviously. And he told them, "Yes, well, I'm not sure 17 they're using bounding values for oxygen." But then 18 he said -- well, Mr. Stevens said that the usage is 19 very small.
20 Well, I went and looked for the transients 21 going up and down for the startup and the 300 --
22 startup transients and the 300 shutdown transients.
23 And I went to the table that I mentioned to you before 24 -- I think it's NEC JH-21 -- and I looked at those 25 transients, and I edited out under 300 -- for the --
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1008 I i can give them to you -- and each transient was very 2 -- the usage factor is very, very small. But there 3 are 300 of them, so -- 600 of them, and they add up to 4 50 percent or the total.
5 Now, if this is so small, why -- why do 6 you even include shutdown? Why do you -- it's going.
7 to cost more money to run more transients if it's 8 nothing.
9 I was trying -- I was surprised Dr. Chang 10 comes in, and ACRS probably made some decisions based 11 on what -- his testimony. He comes. in and he says 12 they used -- there is no usage here at all. And they 13 -- because he 14 JUDGE KARLIN: Can I stop you there? Dr.
15 Chang's testimony before the ACRS on what date? Was 16 this February --
17 DR. HOPENFELD: I have to check. I don't 18 have it in front of me. I can give you his testimony 19 also in this proceeding. I can give you the page 20 where that --
21 JUDGE KARLIN: Well, let me just ask 22 counsel for NEC if they could find that, and at some 23 later point give us that citation to that testimony 24 you're referring to.
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1009 1 particulai ACRS paper i goc from Entergy. It was 2 attached to -- it was one of their exhibits.
3 JUDGE KARLIN: Which exhibit and what's 4 the page?
5 DR. HOPENFELD: Yes!
6 JUDGE KARLIN: Ms. Tyler, if you could 7 help us with that, either now or later.
8 DR. HOPENFELD: But in the same context, 9 I would like to give you that -- the -- Dr. Chang's 10 testimony on page 10 -- for page 12, NRC testimony.
11 JUDGE.KARLIN: Page 12 of --
12 DR. HOPENFELD: It's page 12 of his 13 testimony.
14 JUDGE KARLIN: Oh, okay. Hold on a second 15 while we 16 JUDGE KARLIN: And then, it was repeated 17 in a different form to the ACRS.
18 MS. BATY: Let me point out for the record 19 that this exhibit -- that this testimony has not been 20 -- the Board has yet to rule on the admissibility of 21 this testimony, and there is a pending motion to 22 withdraw the testimony before the Board.
23 JUDGE KARLIN: All right. So noted. What 24 page?
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1010 1 the page. This.was my notes. I don't have -- it's 2 NRC. I don't remember which number -- which exhibit.
3 JUDGE WARDWELL: It's Dr. Chang's 4 testimony?
5 DR. HOPENFELD: Yes.
6 JUDGE WARDWELL: Okay. That's Staff 2.
7 DR. HOPENFELD: I don't have --
8 JUDGE WARDWELL: NEC --
9 DR. HOPENFELD: He said they did not use 10 bounding numbers, with the exception of the -- of the 11 heatup. He used the word "heatup."
12 JUDGE WARDWELL: You said you're referring 13 to page 12?
14 DR. HOPENFELD: Yes, on the bottom there 15 somewhere. That's what my note said, on page 12 on 16 the bottom. Dr. Chang agreed this occurred through 17 heatup of -- usage factor is negligible. He didn't 18 quantify either one of them.
19 JUDGE WARDWELL: I'm looking at one 20 sentence here that says the DO values used in the Fen 21 calculations are the average DO values plus one 22 standard deviation, which bounds almost all of the 23 data points in normal plant operation.
24 DR. HOPENFELD: That's what he said, yes.
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1011 1 the word-- he said that the oxygen occurred during 2 heatup.
3 JUDGE WARDWELL: Yes. The staff noted 4 that --
5 DR. HOPENFELD: The usage factor is 6 negligible.
7 JUDGE WARDWELL: And this is one -- the 8 staff noted that excursions where oxygen content 9 increases do occur during heatup. However, no 10 significant thermal transients occur during this 11 period, so that practically no fatigue usage factor is 12 1 accrued during this period.
13 DR. HOPENFELD: He didn't quantify it.
14 And I tried to quantify it. My usage factor doing 15 those things comes to about 50 percent of the --- both 16 heatup and cooldown. And he also didn't say -- he 17 just made the statement -- I would like for him to 18 testify, so we can find out.
19 JUDGE KARLIN: Can I ask a question here?
20 we've spent an hour or something talking about 21 dissolved oxygen and the electrochemical potential.
22 And you have a chart, Dr. Hopenfeld, on page -- the 13 23 factors 24 DR. HOPENFELD: Yes.
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1012 1 testimony.
2 DR. HOPENFELD: Yes.
3 JUDGE KARLIN: Is dissolved oxygen one of 4 your major concerns and problems here?
5 DR. HOPENFELD: It was one of them. It 6 was not -- it was one of them. I basically --
7 JUDGE KARLIN: Okay. It was one of them.
8 DR. HOPENFELD: One of them. It is a 9 Major input, yes.
10 JUDGE KARLIN: It's one of the 13.
11 DR. HOPENFELD: Very important.
12 JUDGE KARLIN: But of the 13, what are 13 your top three problems with regard -- top three.
14 DR. HOPENFELD: Top three?
15 JUDGE KARLIN: The biggest three problems.
16 DR. HOPENFELD: The one that bothers me 17 the most has to do with -- again, you talk in terms --
18 you have to put yourself in the mind-set as you have 19 these --
20 JUDGE KARLIN: Just what they are, just 21 what -- you've got 13.
22 JUDGE WARDWELL: Just give us three of 23 them.
24 DR. HOPENFELD: Oh, you mean an example?
25 Okay.
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1013 1 JUDGE KARLIN: You've got 13 factors..
2 DR. HOPENFELD: I'm sorry. The factor 3 about the cracks in the cladding.
4 JUDGE KARLIN: Cracks in the cladding.
5 JUDGE WARDWELL: That's number one?
6 DR. HOPENFELD: Yes, I would say this is 7 number one. Surface roughness.
8- JUDGE KARLIN: Okay.
9 DR. HOPENFELD: And I already said the --
10 what was that one that I said?
11 JUDGE KARLIN: Oxygen.
12 DR. HOPENFELD: Yes, and --
13 JUDGE KARLIN: You think oxygen is in the 14 top three?
15 DR. HOPENFELD: Yes. Oh, absolutely.
16 JUDGE KARLIN: Okay.
17 JUDGE WARDWELL: It's number 2, surface 18 finish?
19 DR. HOPENFELD: I would say number --
20 JUDGE WARDWELL: No, no. I mean, I'm just 21 -- you said surface roughness. I'm saying that your 22 number 2 --
23 DR. HOPENFELD: Yes.
24 JUDGE WARDWELL: -- of your table, surface 25 finish is one of them.
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1014 1 DR. HOPENFELD: Y.s.
2 JUDGE WARDWELL: Number 10, oxygen, is the 3 other one Of your top three.
4 DR. HOPENFELD: Right.
51 JUDGE WARDWELL: And then, number 13, 6 existing surface cracks?
7 DR. HOPENFELD: Correct.
8 JUDGE WARDWELL: Is the other --
9 DR. HOPENFELD: Correct.
10 JUDGE WARDWELL: -- another one.
11 DR. HOPENFELD: Now, in terms of 12 importance, I can't say this is higher than that. I'm 13 just saying-14 JUDGE-WARDWELL: No, that's why --
15 DR. HOPENFELD: -- those are -- those 16 three are very important. Not that -- there are nine 17 more, and you have to evaluate each one of them. I 18 don't have data -- a lot of them. Nobody does. But 19 what you have to know, which I believe they do not, 20 they believe because the -- it states conservative, 21 conservative, conservative, he believes it. When you 22 look to those -- all of these 13 factors.
23 JUDGE KARLIN: But, Dr. Hopenfeld, let me 24 ask -- isn't it true that they calculate these CUFens 25 for every nuclear powerplant that -- that's being used NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1015 1 in the U+/-+/-ited States? It's a common thing -- the 2 calculation of CUFens.
3 DR. HOPENFELD: Well, I don't know. The 4 whole concept of this me'thodology, and I -- I was 5 going to read to you, when Mr. Stevens said that he 6 was involved in this -- writing this report. I'm sure 7 that many people wrote this report, and I don't know 8 wha-t part he had --
9 JUDGE KARLIN: Well, but let me ask -- I 10 just want to get back --
11 DR. HOPENFELD: No, no.
12 JUDGE KARLIN: -- is calculation of CUFens 13 a normal thing that's done for all nuclear powerplants 14 in the United States?
15 DR. HOPENFELD: I don't know.
16 JUDGE KARLIN: You don't know.
17 DR. HOPENFELD: I really cannot testify to 18 that, because I don't know. And I was trying to 19 get --
20 JUDGE KARLIN: Is it unique here? Have 21 you ever seen it done before? Are they doing it at 22 Indian Point?
23 DR. HOPENFELD: I'm sure they do, because 24 as soon as they see the data, the NRC tells them to do 25 that, they would do that. However --
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1016 1 JUDGE WARDWELL: Mr.. Fair, is this -- as 2 far as staff experience is concerned, is this a common 3 calculation that is done at various -- at numerous 4 plants?
5 DR. HOPENFELD: For reactors that have --
6 JUDGE WARDWELL: I'm asking Mr. Fair.
7 DR. HOPENFELD: It's only for those that 8 -- if it's fair?
9 JUDGE WARDWELL: I'm asking -Mr. Fair 10 because --
11 DR. HOPENFELD: .Oh, oh.
12 JUDGE WARDWELL: -- you didn't kniow. I 13 was asking Mr. Fair whether or not it is a common --
14 -MR. FAIR: It's common for all plants 15 undergoing license renewal.
16 JUDGE WARDWELL: And it's -- how is it for 17 the other plants that aren't going through license 18 renewal?
19 MR. FAIR: The staff I know -- I'm afraid 20 to use the terminology, but the staff did a study back 21 in about 1995 to determine whether we should have 22 existing operating plants evaluate their components 23- for environmental effects.
24 But part of the evaluation involved a risk 25 assessment. As a result of the risk assessment, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1017 sLaff determined that they could just justify 2 backfitting this to existing operating plants because 3 of the low risk.
4 JUDGE KARLIN: Well, let me ask you about 5 that, then. -
6 MR. FAIR: Okay.
7 JUDGE KARLIN: The requirement to do a 8 CUFen analysis is applied to. all plants that are 9 looking for a license renewal. Is that what you're 10 saying?
11 MR. FAIR: That's correct.
12 JUDGE KARLIN: Okay. And in -- but it's 13 not aoplied to existing plants that are not looking 14 for a renewal.
15 MR. FAIR: That's correct.
16 JUDGE KARLIN: And the CUFen analysis 17 that's imposed upon license renewal applicants is 18 NUREG 5704 and 6583.
19 MR. FAIR: Correct.
20 JUDGE KARLIN: And the -- but a totally 21 different CUFen analysis is imposed upon new reactors, 22 which is 6909.
23 MR. FAIR: That's correct.
24 JUDGE KARLIN: So neither one of them is 25 a backfit.. Nothing is applied to existing plants at NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I 1018 1 all, is that right,?
2 MR. FAIR: Yes.
3 JUDGE KARLIN: Unless they are looking for 4 renewal or a -- yes, unless they're looking for 5 renewal.
6 .. MR. FAIR: That's correct.
7 JUDGE WARDWELL: And is it fair to say 8 that the low risk came .about under the assumption they 9 were going to be closing down also within a short 10 period of time, and knowing that- the amount of 11 cumulative use factors are not likely to be exceeded 12 in the future. Is that where the low risk- came in?
13 MR. FAIR: No. The low r'isk came in from 14 an evaluation of the probability of initiating a 15 fatigue crack if you have a CUP greater than one, 16 coupled with the probability of then running that 17 fatigue crack through the component to get leakage, 18 and the probability of once you ran the crack through 19 the component you would get a failure of the 20 component.
21 That total risk was determined to be low.
22 So the -- you know, there are several factors that 23 went into the risk assessment. The probability 'of 24 initiating a crack, the probability that the crack 25 goes through the component, the probability that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1019 1 causes a comrponent to fail, and the consequences if 2 the component failed of what would happen to the 3 plant.
4 JUDGE WARDWELL: How many metal fatigue 5 failures have occurred nationwide at plants?
6 MR. FAIR: I don't believe that there is 7 any failures that occurred. I think there has been 8 several cases of leakage due to unanticipated thermal 9 loading.
10 JUDGE WARDWELL: And are those -- were 11 those leakages detected in readily accessible areas, 12 or were some in areas that could have gone unnoticed i3 for even longer periods of time, such that more 14 drastic failures could have occurred, do you know?
15 MR. FAIR: That I can't answer.
16 JUDGE REED: So, Mr. Stevens, I believe I 17 heard you some time ago state that the Fen values for 18 situations with temperatures below 150 degrees C, the 19 Fen values are one in that case. Did I hear that 20 correctly?
21 MR. STEVENS: Yes, sir.
22 JUDGE REED: Okay. I also believe that 23 it's NEC's position, or that NEC asserts, that they 24 believe the decrease in light of up to a factor of two 25 is possible in this temperature range. Do I have that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1020 correct, Dr. Hopenfeld?
1 2 DR. HOPENFELD: That is correct. And 3 -that's a direct quotation of Dr. -- the author of that 4 Argonne report, the guy who developed these equations.
5 That's the part between the ACRS -- to the ACRS, and 6 he said -- I mean, the question came up, "What about 7 the temperature?" And he said, "Well, you know, on 8 the average about 150. Most of the data falls apart 9 above that." But if you go below the 150, you could 10 have -- it's not necessarily zero. But when you put 11 the Fen in statistical correlation, it exponentially 12 drops out at zero. That's one.
13 And they also said, if you look at the 14 data, if you go back to the original raw data, all you 15 see -- what you will see, you will see there is only 16 one point -- one data point at-the very low -- at the 17 50 to 40 -- 50 to 40 parts per billion. In other 18 words, there's a lot of weighing to be put in there on 19 that -- on that very -- one data point.
20 He said, "Wel1, even there it's not 100 21 percent sure when you -go to the lower accident that 22 you don't have some" -- so this is a statistical 23 correlation. It's the best correlationyou can come 24 up with. I'm not questioning that. But you have to 25 realize that this -- they say that this is -- the data NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS.
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1021 1 that -- the answer comes to 2.*9,99S, and that's 2 correct.
3 JUDGE REED: I'm sorry. I'm not following 4 you. Is it your point that statistically the 5 statement that Dr. Stevens made is correct, that the
- 6. Fen is one below 150, but there is some statistical 7 fluctuation around that, and there is some 8 possibility? I didn't really follow what you said.
9 DR. HOPENFELD: No. I'm saying that Dr.
10 -- the person who developed these equations -- not me 11 -- he said if you look at his equation it may be when 12 we go to the indication -- below 150, whatever the 13 requirement is -- I think it was 150 -- it's zero.
14 But it really isn't. It's -- it could be as much as 15 a factor of two.
16 JUDGE REED: I'm sorry. You said it is 17 zero, and I didn't --
18 DR. HOPENFELD: Well, the exponential term 19 drops out.
20 JUDGE KARLIN: Well, let me just stop you, 21 Dr. Hopenfeld. Let's pull out the relevant NUREG, and 22 you can point us to where --
23 DR. HOPENFELD: Okay.
24 JUDGE KARLIN: -- Mr. or Dr. Chopra, who 25 wrote these NUREGs -- from Argonne wrote --
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1022 I DR. HOPENFELD: Okay.
2 JUDGE KARLIN: Cite us to the page that he 3 talks about this matter. I remember seeing something 4 about that,, and so 5 DR. HOPENFELD: Yes, I think --
6- JUDGE KARLIN: I just can't find it.
7 DR. HOPENFELD: It's NUREG --
8 JUDGE KARLIN: Is it 6909? Is that what 9 we're talking about?
10 MS. TYLER: If you go to page 26.
11 JUDGE KARLIN: 26?
12 MS. TYLER: Yes.
13 JUDGE KARLIN: Yes, okay: That'- it.
14 Yes. And is that also E-230? We're talking about 15 NUREG-6909.
16 MS. TYLER: Yes, E-230.
17 DR. HOPENFELD: You can go to any one of 18 those equations and see 19 JUDGE KARLIN: On what page?
20 DR. HOPENFELD: Okay. Okay. That's --
21 I'm looking at the equations. Let me find the 22 equations where the temperatures were in there.
23 Actually, we -probably -- we talked about -- that 24 equation was brought into evidence this morning, the 25 Fen equals T. I'm looking for it, but -- oh. Just a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1023 minute.
c I'll. get it in a minute.
2 JUDGE KARLTN: Take your time. 6909 is a 3 long document.
4 iDR. HOPENFELD: Let me -- while I'm 5 looking at it, let me talk about the equation was
- 6. brought up -- oh, here I think it is. Yes.
7 JUDGE WARDWELL: How do you spell his 8 name?
9 DR. HOPENFELD: The person who wrote this?
10 JUDGE KARLIN: Chopra, that's C-H-O-P-R-A.
11 DR. HOPENFELD: Just a minute. I have to 12 spell it out.
13 JUDGE KARLIN: Okay. Chopra.
14 DR. HOPENFELD: I think it's Dr. Chopra.
15 Yes, here it is. Chopra and W.J. Shack. I think that 16 Mr. Shack -- Dr. Shack is a member of ACRS.
17 If you go to -- let me see what -- find 18 the Fen equations here. Okay. If you go to -- on 19 page 38, okay, you'll see there's an equation there, 20 Fen is a fraction of -- is a function of .6 -- the 21 first term says the constant drops out.
22 The next one -- you see there's a T star 23 there, and that T star is really -- is a normalized T.
24 It's T minus some reference value, which I think is 25 150 -- I don't remember that calculation. I believe NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1024 1 it's 150. And so the whole term at the lower 2 temperature drops out. It becomes -- what you have is 3 constant, because you. see the term on the right hand 4 is zero. And what you wind up with is a constant.
5 JUDGE KARLIN: Well 6 DR. HOPENFELD: If T star is zero, the 7 rest is --
8 JUDGE KARLIN: But, Dr. Reed, could you 9 restate your question? It was about 150 degrees and 10 it --
11 JUDGE REED: Well, there seems to be a 12 difference of opinion between the two parties as to 13 whether temperatures below 150 degrees -- what the 14 environmental factor is. There's an assertation by 15 Entergy that at below 150 degrees the Fen value is 16 one. Dr. Hopenfeld believes that it may be as large 17 as two.
18 JUDGE KARLIN: And there's something on 19 this page 38 that supports what you just said?
20 DR. HOPENFELD: On page 38, I'm explaining 21 where it comes from. When you see the equation there, 22 it says a constant, and then you have an exponential 23 to -- times the --
24 JUDGE KARLIN: Which equation? 26, 27, or 25 28?
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1025 1 DR. HOPENFELD: Take any uiie. Take 28.
2 JUDGE KARLIN: All right.
3 DR. HOPENFELD: And you will see it's 4 sulfur times temperature. Notice it is not the real 5 temperature. It is a reduced temperature. It's a T 6 minus T8 -- 28.
7 JUDGE KARLIN: Where does it say that 150 8 degrees is not one?
9 DR. HOPENFELD: Okay.
10 JUDGE KARLIN: This calculation says it?
11 DR. HOPENFELD: No, no. The -- where it 12 says it isn't one was in the testimony of Dr. Chopra 13 at the ACRS.
14 JUDGE KARLIN: Oh, okay.
15 DR. HOPENFELD: We do have that as an 16 exhibit.
17 JUDGE KARLIN: All right.
18 DR. HOPENFELD: I just didn't know the 19 number of that exhibit. It's an ACRS --
20 JUDGE WARDWELL: It also says it right 21 there in the following paragraph below 28 -- one, two, 22 three, four, five, six, seven -- seven lines down, 23 that within the threshold of -this is -- Fen is equal 24 to one.
25 DR. HOPENFELD: Yes, correct.
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1026 1 JUDGE WARDWELL: Is that not correct?
2- Where does it say the Fen should be -two under other 3 circumstances?
4 DR. HOPENFELD: No, it's not just for 5 -- it was a factor of two higher than the equation would 6 predict.
7 MR. STEVENS: MayI clarify?
8 JUDGE KARLIN: Well, just -- in a moment, 9 but I agree with what Dr. Wardwell just -- the 10 threshold strain amplitude is also defined, below 11 which lightwater reactor coolant environments have no 12 effect on fatigue life, i.e. a Fen of one. And is 13 that what you're saying, Mr. Stevens, is 150 degrees?
14 MR. STEVENS: Yes, but I -- I need to 15 clarify,, because in all the confusion I might have 16 confused you further. I was -- I thought the 17 discussion was referring to carbon and low-alloy 18 steels. There is a similar effect, although not one, 19 for austenitics. And I --
20 JUDGE KARLIN: Okay.
21 JUDGE WARDWELL: Austenitics?
22 MR. STEVENS: May I clarify now?
23 JUDGE KARLIN: Yes.
24 MR. STEVENS: I hesitate to do this, but 25 I'll refer you to NEC JH-64 again. This is the EPRI NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1027 1 HRP report, page 4-18.
2 JUDGE KARLIN: You're citing yourself 3 again, is this what we're doing?
4 (Laughter.)
5 MR. STEVENS: Yes, sir. There's two 6 figures on this page that show Fen as a -function of 7 temperature.
8 JUDGE WARDWELL: I'm sorry. And the page 9 again.
10 MR. STEVENS: 4-18. Two figures on this 11 page: top one being for stainless steel, bottom one 12 being for carbon steel. My earlier statement of Fen 13 is one below 150 was referring to the carbon steel, 14 and you can see by that graph that the Fen goes down 15 to one at lower temperatures.
16 The upper graph for austenitics shows that 17 the Fen for stainless steel at lower temperatures is 18 approximately two. So I recognize the adjustment can 19 be a factor of two at lower temperatures for 20 austenitic material. Yes, that's true by these 21 equations.
22 JUDGE KARLIN: So is that -- do you agree 23 with that, Dr. Hopenfeld?
24 DR. HOPENFELD: Well, I thought -- if I am 25 wrong, correct me. I was really -- I did check that, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1028.
1 but I went by the testimony of Dr. Chopra before. the
- 2 ACRS, and I don't remember him saying -- making a 3 distinction between stainless steel and carbon.
4 JUDGE KARLIN: So do you agree, disagree, 5 or don't know?
6 DR. HOPENFELD: I don't know.
7 JUDGE KARLIN: You don't know. Okay.
8 That's fair enough.
9 DR. HOPENFELD: If Mr. Chopra was here, I 10 would find out, but I -- I would say given --
i physically speaking, it doesn't cut off right .there, 12 because it's 150 degrees.
13 JUDGE KARLIN: Okay.
14 JUDGE REED: Mr. Stevens, in the cases 15 where the components you're analyzing were stainless 16 steel, did you use the correct value? If the 17 temperatures fell down to 150 degrees, would you have 18 used --
19 MR. STEVENS:-- Yes, sir.
20 JUDGE REED: But in the cases where it's 21 -- like the feedwater nozzle where it's not stainless, 22 you would have used an appropriate value.
23 MR. STEVENS: That's correct.
24 JUDGE REED: Which might be one.
25 MR. STEVENS: That's correct.
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1029 1 JUDGE REED: Okay. Dr. Mr. Fair --
2 MR. FAIR: Could I try to help clarify a 3 little bit? I think there might be a little confusion 4 on the calculation.
5 JUDGE KARLIN: All right. If you can make 6 it relatively quick.
7 MR. FAIR: I will.
8 JUDGE KARLIN: We think we're --
9 MR. FAIR: If you have the NUREG/CR-6909, 10 and go to the procedure A-1, page A-1 near the back of ii it --
12 JUDGE KARLIN: That's the Appendix 1.
13 Okay. I'm with you.
14 MR. FAIR: And if you go to the equation 15 A-2, which is one of the Fen inspections.
16 JUDGE KARLIN: Yes.
17 MR. FAIR: If you go down to the variables 18 in A-5 with a T less than 150 degrees C, this T star 19 is equal to zero. So while I think it -- that they're 20 referring to the expression in A-2 that includes T 21 star goes to zero at below 150 degrees, and you are 22 left with an Fen as the exponential of that constant.
23 So there is a value above one, but it's something 24 close to two.
25 DR. HOPENFELD: That's correct.
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1030 1 JUDGE KARLIN: Okay.
2 DR. HOPENFELD: That's what I was talking 3 about.
4 JUDGE KARLiI: That seemed to be helpful.
5 MS. TYLER: Judge Karlin, i have located 6 the discussion in the transcript, if that would be 7 helpful.
8 JUDGE KARLIN: Yes. Is that an exhibit?
9 MS. TYLER: It's Exhibit NEC JH-27, and 10 the relevant discussion is on page 25.
11 JUDGE KARLIN: Great. Thank you. We'll 12 take a look at that.
13 .A couple more questions?
14 JUDGE WARDWELL: I just had a couple of 15 followups to get back to --
16 JUDGE REED: I just need to understand 17 what Mr. Fair is saying. Are you saying that we were 18 wrong about the Fen being one below 150 degrees, that 19 it's a constant below 150 degrees, but that constant 20 is not necessarily one?
21 MR. FAIR: That's correct.
22 JUDGE REED: Okay.
23 JUDGE WARDWELL: Just a couple of 24 followups that we've got. We blew by it, and I just 25 -- they are just quick fixes again, and that deals NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE.,N.W.
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1031 1 with the hydrogenated water. "Where in the plant -- I 2 think, Mr. Fitzpatrick, you said that not all of the 3 plant contains the hydrogenated water. Or it's only 4 contained in certain parts of the plant.
5 MR. FITZPATRICK: The hydrogen is irjected 6 at the suction of the feed pumps. The feedwater 7 stream in the reactors -- it"s fed into the reactors.
8 JUDGE WARDWELL: And in that hydrogenated 9 water, the oxygen levels are lower, is that correct?
10 MR. FITZPATRICK: It depends on where --
!i are you comparing the two values in the chart? The 12 oxygen is measured in the same area. That's right.
13 The oxygen values are measured in the same area, and 14 the hydrogen is injected in a similar system -- same 15 system in a different location, and in the reactor.
16 So the data is taken on the piping, we get 17 the EWR BIA program, determine the oxygen level at 18 different locations in the reactor, and we have that 19 for hydrogen injection and prior to hydrogen 20 injection.
21 JUDGE WARDWELL: One other point that you 22 brought up that I'd like to just touch upon, and if it 23 -- it will probably get lengthy, so we'll continue 24 after lunch. I just want to know whether we -- if 25 it's going to be lengthy or not. But we were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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II 10-32 1 discussing the relationship between solubility and 2 oxygen and temperature. You implied that the effects 3 of low temperature and the resulting increase in 4 dissolved oxygen would be compensated for in a 5 transient based on strain.rate. At least that's how 6 I interpreted what you were about to say.
7 MR. FITZPATRICK: In reality, yes.
8 JUDGE WARDWELL: That probably is going to 9 be a longer discussion, is it not?
10 MR. FITZPATRICK: Yes. And --
11 JUDGE WARDWELL: Well, good. Let's just 12 wait until after lunch, because it's on my list that 13 I -- we'll do that, because Dr. Hopenfeld has that on 14 his list and it will be one of those parameters we'll 15 talk about after lunch.
16 DR. HOPENFELD: Just one comment before we 17 go. I think Mr. --
18 JUDGE WARDWELL: Is this in response to 19 one of my questions?
20 DR. HOPENFELD: Well, it's really related, 21 because it -- no, it's not in response to --
22 JUDGE KARLIN: All right. We'll just have 23 it after lunch.
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1033 1 questions. It is now noon. Let us reconvene at 1:15.
2 We're now adjourned. Thank you.
3 (Whereupon, at 12:03 p.m., the 4 proceedings in the foregoing matter 5 recessed for lunch until 1:19 p.m.)
6 JUDGE KARLIN: We'll go back on the record 7 at this point. I apologize that we're a couple 8 minutes late and appreciate your patience on that.
- 9. We'll try not to do it again.
10 We'll remind the witnesses that you're 11 under oath and so please advise by that. And before 12 we starL, I would like to say I'm remiss in not 13 mentioning this this morning. We have another judge 14 with us from the Atomic Safety and Licensing Board, 15 Michael Gibson, over here, most recently a partner 16 with Jones Day down in Houston and has joined us as of 17 two weeks ago and sitting in on this session because 18 it's so fascinating on technical issues. And he's 19 getting all of this, I hope. Welcome.
20 Okay. Now we're focusing on Contention 21 No. 2, the metal fatigue and who wants to go first.
22 Dr. Wardwell, I think, is --
23 MS. TYLER: There was on other reference 24 that you had asked me to find.
25 JUDGE KARLIN: Great. Okay.
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1034 1 MS. TYLER: This is when Dr. Hopenfeld was 2 referring to Dr. Chang's profession of the occupant 3 issue and that transcript was an Entergy exhibit.
4 It's E2-36 and the relevant discussion is on page 135.
5 JUDGE KARLIN: Thank you. That's great.
6 JUDGE WARDWELL: I think we broke right at 7 lunch talking about, starting to talk about, the 8 strain rate with Mr. Fitzpatrick in regards to how 9 that affects the Fen value and to refresh everyone's 10 memory, I think earlier on it was alluded to when we 11 were talking about temperature effects on dissolved 12 oxygen and how those reduced temperatures would 13 increase the dissolved oxygen and possibly increase 14 the Fen and I believe, Mr. Fitzpatrick, that you said 15 that would compensated for or at least alluded to that 16 by the strain rate. Could you elaborate more on why 17 you feel that's correct?
18 MR. FITZPATRICK: It depends on the -- the 19 rate temperature change and temperature change of --
20 the change in the stress and the strain. That's 21 hypothetical for each transient. When we were talking 22 about -- We were getting into the solubility. I was 23 talking to other consultants and engineers.. I think 24 I'm corrected. The solubility may increase if the 25 temperature goes down and if the temperature goes down NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1j035 1 -- I think I was in error when I said it was one way 2 or the other before. However, for the transients 3 we're talking about, if the temperature goes down and 4 the vessel is still pressurized and the oxygen won't 5 come out of solution because it was not in saturated 6 condition -- and the vessel is still in the power --
7' side. It won't get oxygen coming out of solution. If 8 your oxygen does come out of solution, it's in the 9 steam or low temperatures.
10 JUDGE WARDWELL: What is -- I hate to go i1 back to oxygen. How have you incorporated strain rate 12 into your Fon analysis?
13 MR. FITZPATRICK: We view a value of 14 integrity that can be used for all the Fen factors.
15 They've used the value of strain rate that would 16 maximize the Fen value. When you has a very rapid 17 transient and you have a very fast strain rate, there 18 is no effect. The Fen is one or low. If you have a 19 very slow transient, that maximizes the Fen. They 20 used the minimum strain rate which maximizes the Fen 21 value in the instructions --
22 MR. STEVENS: May I?
23 JUDGE WARDWELL: Would you like to 24 elaborate?
25 MR. STEVENS: Yes.
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1036 1 JUDGE WARDWELL: Mr. Stevei.s.
2 MR. STEVENS: The strain rate, in the Fen 3 expressions, the strain rate, there's a value that 4 maximizes that term. In other words, the n is for a 5 low strain rate. The Fen goes up with decreasing 6 st'rain rate.
7 There's a value of strain rate below which 8 the Fen does not increase in those equations. We've 9 referred to that as a saturated value. That is it's 10- the worst strain rate you can put into the expression ii to yield the maximum Fen. All of our calculations for 12 all components whether we find it confirmatory use 13 that saturated value of strain rate.
14 In effect, it makes the worst case assumption and 15 takes strain rate determination out of the equation if i6 you will.
17 JUDGE REED: Could you please explain from 18 a physical point of view why an environmental factor 19 would be affected by the strain rate? I don't see the 20 connection.
21 MR. STEVENS: I think Mr. Fair might 22 answer that clearer than I could.
23 MR. FAIR: Yes, I believe what happens 24 when we strain the component is there's an oxide layer 25 that protects the base material and you crack that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1037 1 oxide layer. So when you do it very fast you dont 2 have much time to do much damage to the underlying 3 material. But with a slow strain rate, you keep it 4 exposed for a longer period of time and that maximizes 5 especially the environment.
6 JUDGE WARDWELL: Wouldn't that also depend 7 upon the magnitude of strain or is there an inherent 8 assumption that the magnitude of strain is the same 9 for all the transients?
10 MR. FAIR: No, once you -- The magnitude 11 of the strain, there's a cutoff point where you don't 12 crack the oxide layer and that's that strain level of 13 which the Fen goes to one. Above that, once you crack 14 the oxide layer you are getting the damage and that 15 damage is a function of how long the base material is 16 exposed before you reform the oxide layer.
17 And it's not dependent on the magnitude of 18 the strain, but just how long you keep the base 19 material exposed. The fatigue life now is a function 20 of the actual strain level because the higher the 21 strain the more damage you do on the fatigue cycle.
22 JUDGE WARDWELL: Dr. Hopenfeld, do you 23 have any objections to what has just been said in 24 regard to how strains handle before we get into 25 whether or not you think it's adequate or not? Is NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1038 1 there anything that they've said that wasn't your 2 understanding of how they handled it?
3 DR -HOPENFELD: No, I understood how they 4 handled it. I used their numbers when I came up with 5 my numbers. I used exactly what they did. I just 6 took their numbers and put flushed out their oxygen 7 and put mine there.
8 JUDGE WARDWELL: We're talking about 9 strain rate now.
10 DR. HOPENFELD: Yes, I know. I used the 11 same strain because you see --
12 JUDGE WARDWELL: So you have no dispute 13 with how they handled strain.
14 DR. HOPENFELD: Well, I used the same.
15 No, I have no dispute of how they handled strain.
16 JUDGE WARDWELL: Okay. Thank you.
17 DR. HOPENFELD: I do have a -- I would 18 like to comment if I may or maybe I'll comment some 19 other time regarding on the mechanism --
20 JUDGE WARDWELL: If it doesn't deal with 21 strain rate, I don't want you to comment right now.
22 DR. HOPENFELD: Yes and no because the 23 implication here is that you -- that we really 24 understand the exact mechanism of the oxide layer, how 25 it cracks and when it cracks. There are some other NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1039
! theories, you know, other theories that compute things 2 physically that I'm absolutely sure I -have a good 3 feeling with it, but it's something that our gang came 4 up with, I don't know, within the next ten years that 5 other people say yes and there was something about 6 hydrogen -- It's a-complex issue.
7 JUDGE WARDWELL: This is in regards to --
8 DR. HOPENFELD: It's so over simplified 9 that my mind has been in shock.
10 JUDGE WARDWELL: So this is in regards to 11 how the oxide layerb.ehaves which --
12 DR. HOPENFELD: Right. What I'm saying is 13 this is not given what the gentleman said. He may be 14 right. This is a work in progress. So the best 15 reason to conclude that he's conservative, that's 16 where the problem comes in.
17 JUDGE WARDWELL: But you have no evidence 18 to dispute that either. It's still as you say 19 possibly a work in progress is all empirical things --
20 DR. HOPENFELD: I have no dispute in 21 theory. You know, there are a lot of theories, but 22 that's not the only theory and I'm not familiar with 23 all of them, but I'm familiar with that one and it 24 makes sense. But that doesn't mean that -- because 25 you say the strain does this and doesn't do that and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1040 i that's what's conservative just because of this 2 theory. I mean, it's naive.
3 JUDGE WARDWELL: Dr. Hopenfeld, what --
4 Any other questions on strain rate? Dr. Reed, any 5 questions on it?
6 JUDGE REED: No.
7 JUDGE WARDWELL: Dr. Hopenfeld, what leads 8 you to believe that the base metal of the feedwater 9 nozzle is cracked?
10 DR. HOPENFELD: Okay. In the -- I don't 11 know exactly the history, but I believe somewhere in 12 the '70s, late '70s or maybe mid '70s, a whole bunch 13 of BWRs, I remember, where the feedwater nozzle 14 cracked and a lot of BWRs are replaced. They remove 15 the cladding, remove the welding. From what my 16 understanding is, they haven't done so. In other 17 words, the weld metal is still there. They haven't 18 done anything with that as opposed to other plants.
19 JUDGE REED: Could we investigate that 20 point for just a moment? I'm a little confused about
- 21. the geometry of this nozzle. Isn't it clad with 22 stainless steel?
23 MR. FITZPATRICK: It's clad with stainless
-24 steel in a blended use.
25 JUDGE REED: Pardon.
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1041 1 MR. FITZPATRICK: In a blend rate. It is 2 clad with stainless steel and in '70s when they 3 replaced -- In '76 they replaced the sparger. They 4 pulled the sparger out to pull the original thermal 5 sleeve out of the vessel. They were doing inspection.
6 They actually did --
7 JUDGE REED: When you refer to "they" you 8 mean you as Entergy.
9 MR. FITZPATRICK: Entergy and GE. GE was 10 doing this for a lot of plants back then. They 11 replaced the spargers at the same time they inspected 12 the whole -- radius. They grouted out any indications 13 they could find with -- I think they were doing PT 14 inspections back then. People were sitting in the 15 vessel core heads.
16 JUDGE WARDWELL: Are you talking about at 17 Vermont Yankee?
18 MR. FITZPATRICK: At Vermont Yankee, yes.
19 JUDGE WARDWELL: The owner of Vermont 20 Yankee at that time was doing what -- Your testimony 21 is that they did this.
22 MR. FITZPATRICK: Yes.
23 JUDGE WARDWELL: Okay.
24 MR. FITZPATRICK: They inspected it and 25 there was a period of inspection doing in the vessel NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1042 1 during the: PT inspections.
2 JUDGE WARDWELL: PT?
3 MR. FITZPATRICK:- Penetrant testing.
4 JUDGE WARDWELL: What is it?
5 MR. FITZPATRICK: Penetrant testing.
6 JUDGE WARDWELL: Penetrant testing, okay.
7 MR. FITZPATRICK: You put a dye into the 8 point of the crack.
9 JUDGE WARDWELL: Okay.
10 MR. FITZPATRICK: And through the years 11 they've developed further UT techniques.
12 JUDGE WAPRWELL: UT?
13 MR. FITZPATRICK: Ultrasonic testing.
14 JUDGE WARDWELL: All right.
15 MR. FITZPATRICK: Most inspection is done 16 with ultrasonic testing. They can put the probes on 17 the outside of the nozzle and investigate that the 18 geometry is including the probe to -- Our exhibit, we 19 have a diagram. It's a small one. E-233, we give you 20 a diagram of the head of the nozzle.
21 JUDGE REED: E-233.
22 MR. FITZPATRICK: Yes.
23 JUDGE REED: And the page?
24 MR. FITZPATRICK: There are five pages in 25 it. They are all marked 106.
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1043 1 JUDGE REED: The very last page.
2 MR. FITZPATRICK: Yes. The last page.
3 This is a section called the nozzle looking in a 4 vertical plane and the blend rate is, if you look down 5 on the page, at section one where the radial surface
- 6. is.
7 JUDGE REED: Yes.
8 MR. FITZPATRICK: That's called the blend 9 radius.
-10 JUDGE KARLIN: Okay.
1i MIR. FITZPATRICK: That's where the CUFen 12 is calculated.
13 JUDGE KARLIN: That's where the CUFen was 14 calculated.
15 MR. FITZPATRICK: Yes. One of the 16 locations.
17 JUDGE KARLIN: One of the locations, okay.
18 JUDGE REED: Is that called the nozzle 19 core (phonetic)?
20 MR. FITZPATRICK: Yes, that's the 21 terminology of the NRC is nozzle core.
22 JUDGE REED: Thank you.
23 MR. FITZPATRICK: And they've done 24 inspections to demonstrate the method works in 25 mockups. It's pretty much standard instrumental.
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1044
- 1. They'll do a UT exam on the exterior of this, on the 2 whole nozzle, to investigate these areas. The UT 3 technique is sized to capture a maximum or minimum 4 size flaw and we have another analysis at- Section 11 5 that the postulated flaw in that. We have postulated 6 a flaw in that nozzle core already and we have done a 7 Section 11 analysis. for that. That's outside the 8- fatigue.
9 JUDGE WARDWELL: Section 11-?
10 MR. FITZPATRICK: ASME Section 11. That's II a service inspection and that was in response. This 12 inspection -- There's a special inspection called 13 augmented inspection and it's in response to the NUREG 14 that was done in the '70s. What is it? Six-nine --
15 i haven't got the number.
16 JUDGE WARDWELL: Are we looking at -- Does 17 the feedwater go in between the lines of this nozzle
- 18. or is this the cladding of the nozzle?
19 MR. FITZPATRICK: That represents the full 20 thickness of the nozzle. The feedwater pipe will be 21 here and the center line would be here. So it would 22 be the top section of the pipe. This is the vessel 23 wall. The pipe's, coming in horizontally. This is the 24 safe vent well down here and this is the port nozzle 25 of these.
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1045 1 JUDGE WARDWELL: Where is the feedwater 2 going?
3 MR. FITZPATRICK: (Indicating) This way.
4 There is the thermal sleeve that fits in there and 5 it's pressed right into the safe vent. You don't see 6 it in this diagram and the feedwater flow is in 7 through the thermal sleeve. It's a pipe within a 8 pipe. You can think of it that way. So the full 9 feedwater flow never really gets to this part.
10 JUDGE KARLIN: Try to describe what you're 11 pointing to so we can have something on the record 12 that will transcribe.
13 MR. FITZPATRICK: Try to describe it.
14 MR. STEVENS: May I?
15 JUDGE KARLIN: Sure.
16 JUDGE WARDWELL: Mr. Stevens please.
17 MR. STEVENS: On this picture where it 18 says "Vessel"..
19 JUDGE KARLIN: Now we're referring to?
20 MR. STEVENS: We're referring to page 21 five.
22 JUDGE KARLIN: E-233 Vermont Yankee and 23 page five, the diagram. Right?
24 MR. STEVENS: That is correct.
25 JUDGE KARLIN: Okay.
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1046 1 JUDGE WARDWELL: The diagram shows several 2 lines. it looks like a closed in component.
3 MR. STEVENS: Correct. So remember the --
4 Recall the earlier description I gave the nozzle being 5 the intersection of two cylinders, the large vessel 6 cylinder and the incoming pipe and that's what you're 7 -- What you're seeing here is a cross section of that 8 intersection, one-half of that cross section. The 9 lower, half of that cross section is not shown here, 10 but it would be an inverted image of this.
11 JUDGE WARDWELL: And it's a cross section 12 of a doughnut. We're seeing one-half of a cross 13 section of a doughnut type of --
14 MR. STEVENS: Correct.
15 JUDGE WARDWELL: Coating, yes.
16 MR. STEVENS: Another way I've described 17 this to folks is if you took this and revolved it 18 about a center line you would have -- There would be 19 one difference in doing that to the real 20 configuration. The vessel portion of this would be 21 flat if you rotated that about a center line axis 22 when, in fact, the vessel is itself a cylinder. But 23 it's close. So if you do this solid revolution, call 24 it, it gives you close representation of what the real 25 component is.
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- I *1047 1 JUDGE REED: Now the clad, would you 2 specify exactly what portion of this nozzle is clad in 3 this picture?
4 MR. STEVENS: Yes, the cladding is put on 5 to the vessel wall interior.- surface and the nozzle 6 forging.
7 JUDGE REED: And which part is called the 8 nozzle forging.
9 MR. STEVENS: The thicker part. The part 10 that's identified as nozzle in this diagram is the 1i forging. -
12 JUDGE REED: And the forging ends there on 13 where the wall becomes thin or?
14 MR. STEVENS: Yes. On the one side, it's 15 the forging itself, the nozzle, is attached to the 16 vessel itself with a weld, a full penetration weld, 17 which is shown bythe dark region between vessel and 18 nozzle.
19 JUDGE REED: Okay.
20 MR. STEVENS: And then it's adjoined to 21 the safe end at the other:end where the dark region 22 between the nozzle and safe end.
23 JUDGE REED: I didn't understand, but 24 those are wells.
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1048 1 wells. Yes, sir.
2 JUDGE REED: Thank you.
3 JUDGE KARLIN: And when you say the 4 interior is clad also, does that mean the lower 5 horizontal line in the diagram that's over the 6 interior on this?
7 MR. STEVENS: Yes. The nozzle forging 8 itself is clad contiguously with inside the vessel and 9 then if you look at these regions hat are marked 1, 10 2a, 2b and 3.
11 JUDGE KARLIN: Yes.
12 MR. STEVENS: The nozzle itself is clad 13 into those regions.
14 JUDGE KARLIN: All right.
15 JUDGE REED: Is it clad all the way down 16 to the weld position or?
17 MR. FITZPATRICK: Some of the nozzles end 18 up just before the weld.
19 JUDGE REED: When you're ultrasonic 20 testing, is it able to detect cracks of the cladding 21 even though you're testing from the outside?
22 MR. FITZPATRICK: It's designed to detect 23 minimum sized flaw that is postulated in the base 24 metal weld. It's either 3/16ths or 1/4 inch. I think 25 it's 3/16ths. It can detect up to a 3/16ths crack in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE-, N.W.
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1049 1 the base metdl weld.
2 JUDGE REED: Now' when you say a 3/16ths 3 crack --
4 MR. FITZPATRICK: Yes.
5 JUDGE REED: Is that along -- Is that 6 depth?
7 MR. FITZPATRICK: Yes.
8 JUDGE REED: So it's not opened up. I 9 mean, it's just a microscopic opening.
10 MR. FITZPATRICK: Microscopic crack, yes.
11 And there was another analysis that is done to support 12 this issue back in the '70s that has been refined a 13 few times and that crack analysis supports the 14 inspection program for that nozzle. We postulate 15 crack -- It's an analysis that shows crack erosion at 16 the time and the inspection program is designed such 17 that we've inspected prior to getting appreciable 18 crack.
19 JUDGE REED: So it's my understanding that 20 in some plants this cladding has been removed.
21 MR. FITZPATRICK: Yes.
22 JUDGE REED: Is that correct?
23 MR. FITZPATRICK: Yes.
24 JUDGE REED: And for what reason?
25 MR. FITZPATRICK: That eliminates the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1050 1 possibility of getting clackks in base metal. The 2 cladding actually, drove The cladding drove the 3 cracks because the original designed thermal sleeve 4 allowed leakage by 5 -. JUDGE REED: What? Leakage by?
6 MR. FITZPATRICK: Leakage.
7 JUDGE REED: Leakage.
8 .MR. FITZPATRICK: The original thermal 9 sleeve, there was a gap between the inside of the pipe 10 and the outside of the thermal sleeve and they had 11 leakage by the thermal sleeve and that mixed with the 12 hot reactor water and so that was the mechanism that 13 cracked the cladding.
14 JUDGE WARDWELL: Do you want to clarify?
15 MR. STEVENS: By leakage, we're not 16 referring to leakage outside of the pressure boundary.
17 It's a relative term to indicate leakage past this 18 thermal sleeve.
19 JUDGE REED: I understand that. Yes.
20 MR. FITZPATRICK: When they replaced the 21 thermal sleeve, they did what's called an interference 22 fit. It's the design -- it's an -- material. They 23 froze it and rammed it into the pipe and let it heat 24 up and it gave a very rigid fit and we actually have 25 thermal couples on the outside of the pipe indicating NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1051 1 if there: s leakage on that or not and that's monitored 2 periodically.
3 JUDGE REED: So now there is not a lot of 4 leakage past the thermal couple.
5 MR. FITZPATRICK.: We tried in the analysis 6 to determine if there was an possible leakage and if 7 something changes with that, we will have to build a 8 corrective action plan.
9 JUDGE REED: You do not believe you had 10 cracks in the cladding prior to installation of this.
11 Now the thermal sleeve was changed a long time ago, 12 wasn't it?
13 MR. FITZPATRICK: Yes, and the eight 14 cracks that were found were grounded down at that 15 time. And they would do periodic inspections of the 16 cladding from the inside of the vessel using PT.
17 Given the exposure that these little inspectors would 18 take over time doing that, the technology advanced 19 over the years to do UT, ultrasonic testing, and it's 20 almost done on every -- I think it gets done on every 21 BWR feedwater nozzle on an -- basis. There's a second 22 program to do investigation. Every plant has their 23 own real specific program that they have.
24 JUDGE REED: With this background, what 25 can you tell us about existing cracking in either the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1052 1 cladding or the base metal?
2 MR. FITZPATRICK: The-inspection program 3 is not showing any cracks. They haven't detected any 4 cracks in the past 20 years that are bigger than 5 3/16ths and we know that. Our Section 11 analysis 6 which goes into the protected corrective actions to be 7 found for these cracks covers that site, covers that 8 phenomenon.
9 The fatigue analysis --
10 JUDGE REED: What analysis?
1i MR. FITZPATRICK: The fatigue analysis in 12 ASME Section 3, you don't postulate cracks in the base 13 metal in trying to determine acceptance. A fatigue 14 usage, again some acceptance of the -- Level 1 that 15 has an assumption there are not cracks in that. ASME 3 16 analysis. Once you get into cracking, you would-be 17 into the ASME Section 11 analysis.
18 JUDGE REED: So you assume no cracks in 19 your analysis.
20 MR. FITZPATRICK: It's inherently ASME 21 Section 3 analysis.
22 JUDGE REED: And that's the analysis you 23 did, that you follow. Is that --
24 MR. FITZPATRICK: All Section 3 analysis.
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1053 1 is the analysis that we've been talking about is 2 Section 3 analysis.
3 MR. FITZPATRICK: Yes.
4 JUDGE REED: Thank you.
5 JUDGE KARLIN: Well, I don't know. Maybe 6 I'm cutting to the chase a little bit too prematurely.
7 But, Dr. Hopenfeld, when we look -- I've looked at 8 your chart of uncertainties, Table 1 in your rebuttal, 9 and you have these 13 factors listed of uncertainties i0 in the ANLE Argonne National Lab.
11 DR. HOPENFELD: Right.
12 JUDGE KARLIN: 1998 and 2007. Then' 13 equations and I guess we turn to No. 13, is it, which 14 is Factor 13 or Uncertainty 13 you have as "existing 15 surface cracks." Right?
16 DR. HOPENFELD: Is it 13?
17 JUDGE KARLIN: Is that the one you're-18 talking about?
19 DR. HOPENFELD: Yes, 13. Right.
20 JUDGE KARLIN: This is what we're talking 21 about here with the crack --
22 DR. HOPENFELD: Correct. Yes.
23 JUDGE KARLIN: -- cracked cladding, 24 cracking and all that.
25 DR. HOPENFELD: Yes.
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1054 1 JUDGE KARLIN: And you say, "Existing 2 fatigue cracks," -- Does NUREG 6909 deal with this 3 issue at all?
4 DR. HOPENFELD: No.
5 JUDGE KARLIN: No. And you say it was not 6 addressed in the Entergy analysis. Is that correct?
7 DR. HOPENFELD: Yes.
8 JUDGE KARLIN: And your comment is 9 "Existing fatigue cracks in the cladding or base metal 10 can provide sites for accelerated corrosion, thereby, 11 azccelerate fatigue failure under cycling loads." Now 12 as a theoretical statement, I suppose -- Does anybody 13 challenge that as a theoretical statement? Mr.
14 Stevens, theoretically, that could be true.
15 MR. STEVENS: Theoretically, I suppose it 16 could be. Yes.
17 DR. HOPENFELD: I don't know if it's 18 theoretical. I think it's observation. My experience 19 if there was an ground surface you could get a crack.
20 JUDGE KARLIN: When I say "theoretical" I 21 mean- existing fatigue cracks in the cladding can 22 provide sites.
23 DR. HOPENFELD: Right.
24 JUDGE KARLIN: Now the question is are 25 there any existing fatigue cracks in the cladding and NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1055 1 I guess what we're hearing is, no, there aren't any.
2 DR. HOPENFETT: Can I answer that 3 question?
4 JUDGE KARLIN: Yes.
5 DR. HOPENFELD: First of all, I take an 6 issue here with the statement that it was -- what 7 3/16th of an inch. You said it was a microscopic 8 crack. Is that what the statement was? I don't 9 think it's a microscopic crack. In the testing that 10 you do -- I'm not digressing here, but we were talking 11 this morning about clads, about life. one definition 12 of. life is crack it completely onto the reflection 13 itself --
14 JUDGE KARLIN: Definition of what? Light?
15 DR-. HOPENFELD: Reflection. One 16 definition of the life of a component, remember the 17 big N on the bottom of the page.
18 JUDGE KARLIN: Okay. Got you.
19 DR. HOPENFELD: Remember we were doing all 20 these -- Is fracture into the Nth. Another definition 21 is --
22 JUDGE KARLIN: Fracture to the Nth?
23 DR. HOPENFELD: Yes. To the --
24 JUDGE KARLIN: To the end.
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1056 1 it's being one. 1'hat's all it is is one requirement.
2 But some other people when you test they have a 3 definition and maybe it's convenient to some degree is 4 to run to a point which you have, what's called, an 5 engineering crack of about three millimeters and then 6 you, see them when you're testing the loading drops.
7 So that's a different definition.
8 What we're talking about here in the tests 9 that Argonne ran, by the time you get three millimeter 10 you're over the initiation process. You're 11 analygating (sic) to the proposition. So when he says 12 it's very, vefy small, it's not Three-sixteenths is 13 not -- I can't remember what it is.
14 JUDGE KARLIN: Well, we don't need to 15 debate whether 3/16ths is --
16 DR. HOPENFELD: It's not microscopic.
17 Let's look at the microscope. I can feel. I know --
18 JUDGE KARLIN: Dr. Hopenfeld, we can posit 19 that 3/16th is 3/16ths.
20 DR. HOPENFELD: Right.
21 JUDGE KARLIN: The adjective "microscopic' 22 can be discarded.
23 DR. HOPENFELD: It's important because --
24 JUDGE KARLIN: Mr. Fitzpatrick.
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1057 1 "microscopic" in the same sentence as 3/16ths.
2 JUDGE KARLIN: All right. Let's just 3 dispense with the word "microscopic" and say it's 4 3/16ths. Right?
5 DR. HOPENFELD: Okay. Now the reason for 6 that, for one thing, when you do ultrasonic, it's 7 difficult to do ultrasonic when you have a base metal 8 and at the same time you have a clad of stainless 9 steel and carbon. So it's difficult to distingyuish 10 between the two. Especially when you do the UT, you 11 really get -- because you don't really know whether 12 you've penetrated one millimeter in there or a 13 fraction of a micron.
14 When GE examined a whole slew of damaged 15 nozzles, there were some of them that cracked through 16 the base metal. It's my understanding and I don't 17 know what kind of machines they are using today for UT 18 examination, but my understanding is that we're 19 talking about minimum detection, something like one 20 quarter of an inch and the clad if I understand 21 correct is a little bit less. So there is a 22 possibility of -- at the base metal.
23 But be it as it may, take a look what the 24 people at Argonne ran. They're in 6909 or the other, 25 6583. These specimens were not cladding. These were NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1058 1 not cladding.. This was iuCL the same type of a test.
2 Now they've taken this and in one of their -- they 3 said, "Well, we admit. We're going to make the 4 assumption that the cladding is cracked." For 5 whatever reason, NRC asked them and they said they're 6 going to assume.
7 Well, if you assume something, first of 8 all, you really cannot tell -- You have to admit you 9 can't tell whether it's cracked beyond the base metal 10 or not.
11 JUDGE KARLIN: So let me stop you there if 12 I man.
13 DR. HOPENFELD: Okay.
14 JUDGE KARLIN: You're acknowledging that 15 Entergy has assumed that they are cracked.
16 DR. HOPENFELD: Yes. In one of the labs, 17 they said they assumed that they are cracked.
18 JUDGE KARLIN: They are making the 19 assumption.
20 DR. HOPENFELD: And they also -- possible 21 that they could, in fact, propagate it through the 22 next 20 years. Once you've made that assumption, it 23 seems to me you should be consistent in the 24 calculation of the Fen.
25 JUDGE KARLIN: Well, let's ask Mr.
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1059 1 FitzpaLrLck or. Mr. Stevens.
2 MR. STEVENS: May I clarify?
3 JUDGE KARLIN: Go ahead.
4 MR. STEVENS: My comment on this issue, 5 Item 13, is it's not relevant to our CUFen analysis.
6 Our CUFen analyses inherent in them, there's a Section 7 3 analysis which does not allow cracks and we're also 8 doing a calculation that demonstrates --
9 JUDGE KARLIN: Wait a second. What do you 10 mean it doesn't allow cracks? It prohibits there will 11 be never be a crack.
12 MR. STEVENS: Section 3 as part of 13 fabrication of vessels if there were any indications 14 it requires repair. The analysis --
15 JUDGE KARLIN: So it assumes there will be 16 none. There are no cracks.
17 MR. STEVENS: That's correct.
18 JUDGE KARLIN: And if there are cracks 19 it's invalidate.
20 MR. STEVENS: It would have to be repaired 21 so that there were no flaws under the Section 3 22 fabrication.
23 JUDGE KARLIN: Yes. You have to have no 24 cracks in order for this to work.
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1060 I is a calculation of crack. Our criteria against crack 2 initiation we're showing to be acceptable. So the 3 presence of a crack is meaningless to an analysis that 4 has to assume no crack to begin with and our criteria 5
6 JUDGE KARLIN: Doesn't it invalidate the 7- analysis if there is a crack?
8 MR. STEVENS: If a crack was detected, 9 then you would be into a Section 11 program like Mr.
10 Fitzpatrick explained and what we have here 11 historically is, yes, they would indicate cracks in 12 the VY feedwater nozzle. They were repaired and a 13 complete repair was implemented that included grind 14 out of the cracks as well as thermal sleeve and 15 sparger replacement that restored that component to a 16 new condition and since that time, Section 11 programs 17 have verified within their capability the absence of 18 cracking as well as analysis that's been done, updated 19 analysis, to meet the CUF requirements of Section 3 20 which would say you would have and analyzed against 21 the presence of cracks.
22 In addition to all that, we have a belt 23 and suspenders program, a Section 11 program, that 24 continues to inspect those nozzles and, as a part of 25 that, there is the crack growth analysis tied into NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1061 1 that program that Mr. Fitzpatrick alluded to. It says 2 even if all of that might be mistaken, we're going to 3 postulate a flaw and demonstrate the growth of that 4 flaw as acceptable over the life of the plant. So 5 it's a combination belt and suspenders program of 6 acceptability and manage the fatigue in this 7 component.
8 But with respect to the CUFen, cracks are 9 not relevant. They don't factor into the analysis.
10 JUDGE WARDWELL: And is that a better way 11 to say it that, in fact, you have, that Entergy has, 12 a monitoring and maintenance program that repairs all 13 cracks such that they havc no influence on the CUFens?
14 MR. STEVENS: Yes, sir. That would be a 15 correct way to say it.
16 JUDGE WARDWELL: Rather than to say it's 17 not relevant. It is relevant but you don't allow them 18 to occur from the monitoring and maintenance program.
19 MR. STEVENS: Yes. If you detected a 20 crack, you would be outside of Section -3 and into 21 Section 11 and would have to correct that situation.
22 JUDGE WARDWELL: Recognize that we don't 23 understand the significance of a Section 3, a Section 24 11. That doesn't mean much to us. It sounds like 25 it's a very important thing to you people at Entergy NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1062 1 that when you go into a Section 11 means you nave to 2 do some stuff and that, of course, is a corrective 3 action thing.
4 How often do you inspect this particular 5 component to assure that those cracks are detected and 6 repaired expeditiously so that provocation would not 7 occur?
8 MR. FITZPATRICK: Right now, it's very 9 four cycles there's a 100 percent UT done on all four 10 nozzles.
11 JUDGE WARDWELL: Every four --
12 MR. FITZPATRICK: Every four cycles.
13 JUDGE WARDWELL: -- refueling cycles?
14 MR. FITZPATRICK: Yes. Approximately six 15 years. We just finished the last one in 2007.
16 JUDGE WARDWELL: Describe if you could for 17 me a little more detail of this suspenders part of the 18 belt, and suspenders and that being where you assume 19 that it's cracked. What have you done with that 20 assumption or what have you applied that assumption 21 to?
22 MR. STEVENS: If we have a CUF analysis 23 that indicates CUF is less than one, the indication 24 would be that there are no cracks first off. Second 25 though, because of the history of these components as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1063 1 wull as Section 11 programs, they do get periodically 2 inspected for any kind of deterioration due to fatigue 3 and other mechanisms that might be present. Those as 4 Mr. Fitzpatrick alluded to use typically ultrasonic 5 techniques which have improved drastically in the last 6 25 years and are heavily qualified by organizations
.7 such as EPRI.
8 But nevertheless those inspections do have 9 limitations. There is a threshold below which they 10 cannot detect cracking. In order to compensate for 11 that, an analysis is done postulating a flaw --
12 JUDGE WARDWELL: And is that the 3/16ths 13 that we were talking about before?
14 MR. STEVENS: Yes, sir.
15 JUDGE KARLIN: Okay. So that can't see a 16 crack that's smaller than that.
17 MR. STEVENS: Yes, sir.
18 JUDGE KARLIN: And therefore possibly 19 there is a crack o.f that size in there.
20 MR. STEVENS: You postulate a flaw size 21 that may have been missed.
22 JUDGE KARLIN: Right.
23 MR. STEVENS: And do an analysis that 24 shows acceptability of that flaw and growth over 25 future operation.
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1064 1 JUDGE WARDWELL: And what type of analysis
.2 is that?
3 MR. STEVENS: That is a fracture mechanics 4 analysis.
5 JUDGE WARDWELL: And that allows you to 6 estimate the propagation of that crack?
7 MR. STEVENS: Yes.
8 JUDGE WARDWELL: Dr. Hopenfeld, what 9 evidence do you haITP that the feedwater nozzle 10 cladding is now cracked?
11 DR. HOPENFELD: It now cracked. No, I 12 don't have direct evidence it's cracked. I looked at 13 their inspection reports and they state not detected 14 which means within the detection capability of UT. It 15 was not -- As I said, 3/16th, it was my understanding 16 one quarter of an inch, but that's not that different.
17 The point that's being missed here and 18 that's a practical engineering problem that I've seen 19 through all my life almost with different endeavors, 20 nothing in the nuclear business, is when you have 21 cracks you just grind them out. You get rid of them.
22 You shim them out. You don't want them. That's a 23 standard procedure.
24 He's talking about walking it to one 25 section to another section and that's a ASME Code.
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1065 1 That's a different world. In the real world, you have 2 these things and what happens is that -these are site 3 corrosion product, what those corrosion products would 4 do if the -- time is unknown. But, more importantly, 5 when you want to test-and you want to test some smooth 6 surfaces and then you say, "I'm going to -use these at 7 the end and I'm going to say these are conservative, 8 well, he is absolutely sure that this is conservative.
9 T don.'t see how that is conservative when he already 10 starts with cracks because he doesn't know where they 11 are. So he does the analysis and that's because the 12 ASME asked him to an analysis. But that's a different 13 world.
14 In the real world, you have these FUM 15 (phonetic) numbers. They came in from laboratories 16 for very; very smooth surfaces. I don't know.
17 JUDGE WARDWELL: What was the wording in 18 the inspection program that indicated that there was 19 no cracking in this nozzle?
20 MR. FITZPATRICK: No relevant indications.
21 JUDGE WARDWELL: There's no --
22 DR. HOPENFELD: No relevant indications.
23 Usually you classify something like that in terms of 24 POD which is probability of detection. They don't 25 talk about that.
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1066 I MR. FITZPATRICK: The SER states a quarter 2 inch crack. The analysis maybe used in a quarter 3 crack, too.
4 JUDGE KARLIN: Where is that?
5 - MR. FITZPATRICK: If you. look at SER --
6 The -FSER study, the whole discussion starts at the 7 bottom of page 4-25. Do you have the section?
8 JUDGE KARLIN: Are you talking about the 9 final safety evaluation?
10 MR. FITZPATRICK: Yes, as it were.
11 JUDGE KARLIN: Okay.
12 MR. FITZPATRICK: It's Code 3 -- Analysis.
13 JUDGE KARLIN: Page four --
14 MR. FITZPATRICK: That's at the bottom of 15 page 4-25.
16 JUDGE KARLIN: Four-25.
17 MR. FITZPATRICK: Yes, and continues on to 18 4-27.
19 JUDGE KARLIN: This is a discussion of 20 feedwater nozzle fatigue analysis.
21 MR. FITZPATRICK: Yes, this is -- This was 22 the section of the inspection prior to looking at EAF 23 Section --
24 JUDGE KARLIN: Okay.
25 MR. STEVENS: May I clarify one thing on NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1067 1 that?
2 JUDGE WARDWELL: Yes, go ahead.
3 MR. STEVENS: On page 4-26, next to the 4 last paragraph where it's talked about a 0.25 inch 5 flaw, that doesn't necessarily mean that's the 6 capability of the *UT system. The technical basis 7 behind this work which I'm very familiar with says 8 that there are certain effects that would drive a 9 crack to one quarter of an inch that are difficult to 10 include in the analysis. The analysis is supposed to 11 assume *a quarter inch or the capability of the UT 12 system whichever is greater. So this value here in 13 initial crack size may, in fact, reflect that 14 technical basis more than it reflects the capability 15 of the UT system.
16 So, in fact, Mr. Fitzpatrick's comment 17 about 3/16ths of an inch capability may be true. But 18 the technical basis for this work requires us to 19 assume one quarter inch minimum because of other 20 stress effects that would be present. My point is I 21 don't want you to look- at the quarter inch and be 22 confused that might be a UT capability. It might be 23 far better than that.
24 DR. HOPENFELD: Can I --
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1068 1 you like to respond?
2 DR. HOPENFELD: Well, not a comment on 3 that. You~see, we don't -- When you weld something, 4 you put a bead in there and that'.s a machine, weld, 5 usually there's an uncertainty with the thickness that 6 you get there and it's I went to the original 7 drawings and I read it and couldn't figure out exactly 8 what those differences are and we asked them to tell 9 us what is "as Is dimension." It was wrong if you're 10 interested.
11 Now the cladding is -- I believe it was 12 like 5/16. So we're not talking -- I don't remember 13 exactly what the cladding is. But that could be 14 within the tolerances. If you're through the 15 tolerances, you might be already within the base metal 16 and whether you are in the base metal or not it 17 doesn't really matter because you see the interfaces 18 is the point of stress. It's the initiation point and 19 when you put all that corrosion products, it's 20 something that Argonne hasn't run and I can't see in 21 the world how that could be conservative.
22 JUDGE WARDWELL: Thank you.
23 Moving onto your third of three most 24 important issues relating to Table 1 Uncertainties in 25 the Fen equation dealing with surface finish, would NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1069 1 you like to elaborate a little bit more, Dr. Hopenfeld 2
3 DR. HOPENFELD: Sure.
4 JUDGE WARDWELL: -- on what you mean by 5 that or why it's so important?
6 DR. HOPENFELD: Yes. Let me get you in 7 the right direction on this.
8 JUDGE WARDWELL: We always like that.
9 MS. BIELECKI: May we show him our copy?
10 JUDGE WARDWELL: Yes. Sure.
11 DR. HOPENFELD: Okay. Could you please -7 12 You're talking about the number that would be the 13 first one or the second one? The oxygen or. the 14 surface?
15 .JUDGE WARDWELL: The surface.
16 DR. HOPENFELD: The surface, right. Okay.
17 I have it. NEC JH-28.
18 JUDGE WARDWELL: Twenty-eight. I'm sorry.
19 What is thatagain? NEC what JH?
20 DR. HOPENFELD: NEC at 28 page three.
21 JUDGE KARLIN: Twenty-eight what?
22 DR. HOPENFELD: Page three. NEC JH-28.
23 JUDGE WARDWELL: And this is the ACRS 24 meeting?
25 DR. HOPENFELD: No. That's the -- It's my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1070 1 presentation: Do you see a table there?
2 JUDGE KARLIN: No. NEC JH-28 is an 3 excerpt from the February 7; 2008 Advisory Committee 4 Meeting on Reactor Safeguards.
5 DR. HOPENFELD: No.
6 MS. TYLER: Dr. Hopenfeld, what's the 7 title of the document that you want to refer them to?
8 JUDGE KARLIN: Yes. What's the title?
9 MS. TYLER: What's the title of the 10 document?
11 DR. HOPENFELD: Oh, yes. I see. I'm 12 sorry. I got screwed up. Okay. NEC -- Well, it says 13 JH-23 at 76. I think it's the NUREG 6909 report.
14 MS. TYLER: If it's 6909, it's JH-26.
15 DR. HOPENFELD: Yes, the 6909. Twenty-16 six.
17 JUDGE KARLIN: So you're referring to 18 6909.
19 DR. HOPENFELD: Right. Correct.
20 JUDGE KARLIN: NUREG 6909.
21 DR. HOPENFELD: Right and I believe it's 22 page 76 that there's a table there and --
23 JUDGE KARLIN: Page? What page, sir?
24 DR. HOPENFELD: Seventy-six.
25 JUDGE KARLIN: Seventy-six.
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1071 i DR. HOPENFELD: Right.
2 JUDGE KATRVI1\N: There's a Table 12 on that 3 page?
.4 DR. HOPENFELD: Yes.
5 JUDGE KARLIN: Is that what you're 6 referring to?
7 DR. HOPENFELD: Yes, sir. I'm sorry.
8 JUDGE KARLIN: All right. Let's wait for 9 everyone else to get there.
10 DR. HOPENFELD: Yes.
11 JUDGE KARLIN: Okay? What's the question?
12 JUDGE WARDWELL: Yes. Would you like to 13 elaborate more on how important that is?
14 DR. HOPENFELD: Sure.
15 JUDGE WARDWELL: And what impact does it 16 have on the Fens? How sensitive are they to this --
17 DR. HOPENFELD: Sure. You see on that 18 page what you have on the left-hand side is you have 19 number 2, 2.5, 4 and proposed plan. These are 20 parameters and not as Mr. Fitzpatrick said, this is 21 not a safety factor. This is an adjustment parameter 22 in-the computer code, excuse me, ASME Code. And you 23 notice that the surface roughness is a factor of four.
24 So it's pretty heavy. It's considered to be very 25 important. These things were done, I don't know, 30 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS -
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1072 1 or 40 or 50 years ago indicating there was clearance -
2 3 . JUDGE WARDWELL: What does a Section 3 4 criterion mean?
5 DR. HOPENFELD: I'm sorry.
6 JUDGE WARDWELL: What does a Section 3 7 criterion document mean?
8 DR. HOPENFELD: Well, it's what the ASME 9 Codes are based on for calculating the fatigue curve 10 as the stress versus the best -- cycles.
11 JUDGE WARDWELL: Yes.
12 DR. HOPENFELD: That's where it comes 13 from. That's what the -- calculating the stress, the 14 fatigue, level of -- air by the ASME Code and I think 15 there are a similar curve that was presented by the 16 NRC somewhere in one of your exhibits.
17 JUDGE WARDWELL: Right.
18 DR. HOPENFELD: Yes, it's the ASME Code 19 that the crack doesn't work by itself. The ASME Code, 20 the data in here is based on a large number of 21 experiments. Ninety-nine percent of them were 22 conducted in air, okay, in an environment, not in an 23 industrial environment. So -- And I've. been -- for 24 many years. So the person who agrees in charge at 25 that time, Dr Cooper, and being a lot of people under NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1073 I us and they came up with numbers as Lu the various 2 effects that you should really involve the 3 experimental data that you got in the lab report and 4 when you put it in the ASME Code, somebody could use 5 it. It's still in air. Conceptually, it's probably 6 not the same environment the same as air that you had 7 in the laboratory. But it's air.
8 But realizing that factors like size and 9 the most important one in the surface -- they put 10 factors in it for best estimates, best guesses, they ii could. But those estimates were based on, the 12 roughness of tne surface was based on machine 13 surfaces, what you leave on the machine, whatever the 14 machine surface is. I mean, different components have 15 different machine surfaces. You know, you grind it.
16 You use a -- or whatever it is you use to forge it or 17 whatever it. So you have different surfaces and they 18 did a number before.
19 Okay. So now when you come to the issue 20 of surface roughness being in water, definitely it 21 would be like water reactive, the first question is 22 the surface roughness here the same as the surface 23 roughness there (Indicating). And, of course, you 24 look at it and I believe that they did and I even 25 believe that Argonne didn't look too far beyond that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1074 1 is they said, "Well, they're still talking about 2 machine surfaces."
3 But what you have, a lot of. these 4 components are carbon steel, low-alloy steel, that 5 have been cooking there for many, many years. Their 6 surface is corroded and we'll talk about that later.
7 The surface what you heard is not on a machine surface 8 and the corrosion corroded some of the corrosion 9 surfaces and you might have pits, ridges. These all 10 could be high stress points for crack initiation.
11 Some of the pits could be points for accumulating 12 corrcsion products. iL is not the same thing.
13 Now Dr. -- I don't think they went beyond 14 the point of assuming that these surfaces are really 15 machine surfaces. They haven't considered it because 16 there's no ordinary problem they've considered -- on 17 the -- surface.
18 JUDGE KARLIN: Well, let me stop you 19 there.
20 DR. HOPENFELD: Sure.
21 JUDGE KARLIN: Let me stop you there, Dr.
22 Hopenfeld. We're looking at this chart. It's on page 23 76 of the NUREG 6909. Right?
24 DR. HOPENFELD: The chart?
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1075 I referred to.
2 DR. HOPENFELD: Oh, this thing. Right.
3 JUDGE KARLIN: That you referred us to.
4 DR. HOPENFELD: The table, yes.
5 JUDGE KARLIN: The table. I'm sorry. And 6 it's 6909 table and it has a parameter and the 7 parameter is surface finish. Right?
8 DR. HOPENFELD: Correct.
9 JUDGE KARLIN: On the left-hand column and 10 it says, "Section 3 Criterion Document" and by that we 11 mean the ASME document?
12 DR. HOPENFELD: I don't know. I would 13 think so, yes.
14 JUDGE KARLIN: In air. Well, they say you 15 should-have a factor of 4.0.
16 DR. HOPENFELD: Right.
17 JUDGE KARLIN: And then the present 18 report, I suppose that means the 6909 NUREG, that 19 report says the factor should be less.
20 DR. HOPENFELD: Yes.
21 JUDGE KARLIN: 2.0 to 3.5.
22 DR. HOPENFELD: And I'm saying that's 23 right. That's exactly the point.
24 JUDGE KARLIN: And these are the 25 environmental factors, are they not?
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107.6 1 DR. HOPENFELD: No.
2 JUDGE KARLIN: But you're starting with 3 the curve in the air and you're saying, "Why don't we 4 adjust it by four or why don't we adjust it by 3.5?"
5 DR. HOPENFELD: No. Let me explain'.
6 That's the reason I'm being here so that you can 7 understand so we're talking about the same thing.
8 JUDGE KARLIN: That's what I thought.
9 DR. HOPENFELD: But you're right. But 10 here is the point. They say this is not -- This has 11 nothing to do with the Code. Remember on the right-12 hand side it's a present report. It's when they 13 calculated their air volume. Okay. They believe that 14 these are the numbers that should be in there.
15 One reason their number is -- reason they 16 believe is the Code is very conservative is because 17 they said, "Well, this is one parameter that we 18 believe is between 2.0 to 3.5. That's what he 19 believes and that's not necessarily correct. I don't 20 know how to work with the way this has been tested to 21 see whether he really talks about the real surface 22 that you have in a reactor. And then you look atthe 23 corroded surface that you have or surfaces that 24 especially the surfaces which are carbon steel and 25 low-alloy steel and you see that they were exposed to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1077 1 high accelerated corrosion, i mean, there's a 2 landscape of entirely different surfaces and I'll show 3 you those pictures in the --
4 JUDGE WARDWELL: What are these numbers 5 used for if they're not Fens?
6 DR. HOPENFELD: I'm sorry.
7 JUDGE WARDWELL: What are these numbers --
8 DR. HOPENFELD: These were. used more or 9 less asa recommendation. If he had his choice, he 10 would have recommended a new air and detect the ASME 11 Code and replace it with his.
12 JUDGE WARDWELL: I'm sorry. I don't think 13 you understand me. I don't The question is now 14 what is the 2.0 to 3.5 versus the 4.0 you used or any 15 of these numbers you used.
16 DR. HOPENFELD: Well, the number of these 17 things, what he is trying to say here with regard to 18 the Fen, he's trying to say here that the ASME Code 19 which has their air curve in there is very 20 conservative to compare what he has. But then he says 21 that it's his judgment. He says it's between 6.0 to 22 -27.4 which is a range that he gives and he said he 23 used that and that's the reason when they say, they're 24 talking about, there's a lot of conservatism. There 25 is a judgment that there is conservatism in the ASME NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1078 1 Code.. i've had people think that it's not 2 conservative.
3 JUDGE KARLIN: Can we stop you there?
4 DR. HOPENFELD: Yes.
5 JUDGE KARLIN: Mr. Fair, maybe you could 6 help us. Do you agree with his, with Dr. Hopenfeld's, 7 discussion of this chart and what it's showing us?
8 MR. FAIR: I'm not sure that I understand 9 his discussion of the chart.
10 JUDGE KARLIN: Okay. What's your I1 understanding of these factors and the loading 12 history, I'm sorry, the surface finish? There's 4.01 13 for Section 3 and then there's a 2.0 -- What are those 14 things?
15 MR. FAIR: Yes, the numbers in the left-16 hand column under the Section 3 Criterion Document 17 come from an original ASME criterion document that 18 they published in 1960s explaining the bases for the 19 fatigue evaluation procedure and these were the 20 assumed values they used to adjust the mean test data 21 that they used to establish the fatigue air curve 22 adjusted downwards to get the design curve.
23 JUDGE WARDWELL: So they divided that 24 curve for 4.0.
25 MR. FAIR: No. By 20 for the total.
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1079 I JUDGE WARDWELL: No. We're only talking 2 surface now.
3 DR. HOPENFELD: No, they did it altogether 4 because 5 JUDGE WARDWELL: We're talking to Mr. Fair, 6 now.
7 DR. HOPENFELD: I'm sorry.
8 JUDGE WARDWELL: Thank you.
9 MR. FAIR: The right-band column is the 10 latest assessment that was done by Argonne of the 11 available literature to relook at those parameters to 12 see what they thought those parameters would be ifl 13 light of the current data and these were the estimates 14 of the range of estimates they got from the literature 15 on these parameters.
16 JUDGE KARLIN: If I may stop you. These 17 are the air curves, right, and adjustments?
18 MR. FAIR: That's right.
19 JUDGE KARLIN: And this is an example 20 where you might say -- When you said the 6909 is less 21 conservative than the old method, this is an exact 22 example of that, is it not?
23 MR. FAIR: That's right because --
24 JUDGE KARLIN: Because the old method was 25 at an adjustment factor of 4.0 and the new method of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1080 1 6909 has an adjustment of 2-.0 or 3.5.
2 MR. FAIR: Well, that wasn't the specific 3 area I was referring to because the old adjustment 4 just put an fixed adjustment of 20. The current 6909 5 assumed a probability distribution with all of these 6 parameters and then did a simulation to determine what 7 the *adjustment factor should be and the current --
8 JUDGE KARLIN: Is this the Monte Carlo 9 9595?
10 MR. FAIR: That's exactly right. And the 11 current testament based on that Monte Carlo simulation 12 was thiat adjustment factor could be 12 so that the 13 previous air curve was conservative in comparison to 14 the current Argonne assessment.
15 JUDGE KARLIN: Right.
16 JUDGE WARDWELL: What did you use, 17 Entergy, in your analysis? Either Mr. Stevens or Mr.
18 Fitzpatrick.
19 MR. STEVENS: We used the ASME Section 3 20 fatigue curve which is represented by the numbers 21 under the Section.3 criteria document.
22 JUDGE WARDWELL: So it's represented by 23 the 4.0 number if we are only talking about surface 24 roughness.
25 MR. STEVENS: Yes, sir.
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1081 1 JUDGE WARDWELL: Dr-. Hupenfeld, do you 2 have any indications besides just your common sense 3 that says there must be adverse surface finish beyond 4 what was assumed in the Section 3 Criterion Document.
5 DR-. HOPENFELD: Yes, I think 6909 gives an 6 equation of the effect of surface roughness and if you 7 look at the surface roughness that these people are 8 talking about it's not the same surface roughness that 9 you would see in an actual plant, in an actual 10 component -- So this is an uncertainty.
11 b I don't know exactly what the exact effect 12 is in effect because there is an equation in 6909 13 relating to surface roughness. But that surface 14 roughness is again a machine.
15 JUDGE WARDWELL: Let me clarify something 16 with yourself if I might.
17 DR. HOPENFELD: Yes.
18 JUDGE WARDWELL: Or let you clarify for 19 me. Entergy just testified they use a Section 3 20 criterion for this discussion that you're just 21 bringing up in regards to 6909 sugars down to a 22 recommendation herein of a value of somewhere between 23 2.0 and 3.5 of which 2.0 if you look at the asterisks 24 can be used for carbon and low-alloy.
25 DR. HOPENFELD: Yes.
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1082 1 JUDGE 'WARDWELL: That seems to be if 2 you're using the present report half as much influence 3 as what was used. So they're more conservative by a 4 factor of two.
5 DR. HOPENFELD: This is the -- Yes. That 6 two was the number. But I'm saying this 2.0 to 3.5 7 was not based on actual surface. That was --
8 JUDGE WARDWELL: But where -- What 9 evidence do you have and what are the numbers for that 10 evidence of actual surfaces?
11 DR. HOPENFELD: No evidence but based on 12 the surface roughness of a corroded surface on the 13 pipe and you see it on carbon steel or low-alloy steel 14 is much higher than a machine surface that you get it 15 out of --
16 JUDGE WARDWELL: So you disagree with 17 Argonne in regards to the development of 6909.
18 DR. HOPENFELD: I doubt that it was 19 raised. That's the reason I brought it up because --
20 JUDGE WARDWELL: Who else disagrees with 21 Argonne?
22 DR. HOPENFELD: I'm sorry.
23 JUDGE WARDWELL: Who else -- Can you quote 24 then reference a cite that disagrees the way you do 25 with what Argonnne has done and supplied on that?
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1083 1 DR. HOPENFELD: Okay. I don't know the 2 invested issue, the specific issue, of the surface 3 roughness either.
4 JUDGE WARDWELL: Thank you.
5 DR. HOPENFELD: But with regard to the 6 ASME Code 7 JUDGE WARDWELL: No. We're talking 8 surface finish now.
9 DR. HOPENFELD: Yes, but the two come 10 together. They talk about a 20 factor. They add all 11 these factors together. They added here 20 and they 12 added here to whatever the number of times. But if 13 you're talking about just the surface itself, okay, 14 and that's what -- Let's say that a factor of -- that 15 this reference here, the 4.0, the average number.
16 Let's say just for -- I'm not saying that that's 17 right. Let's say 1.0. Okay. Then you say, "I didn't 18 run these, didn't generate equations for a number of 19 10. We generated".. They're using actually a number 20 of four because when they multiplied their Fen which 21 is their Fen divided by -- in water divided by air, 22 they're basically using the number 4.0. But if they 23 take a number -- if their thing was really 10, then 24 you would have a different number. That's how you do 25 the surface.
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1084 1 JUDGE WARDWELL: I understand.
2 -DR. HOPENFELD: You have to extend it --
3 JUDGE WARDWELL: If you had a number of 4 100, what happens?
5 DR. HOPENFELD: I'm not going -- Look. If 6 you want me to give you a number on this, I -cannot 7 because 8 JUDGE WARDWELL: I'm asking you for a cite 9 of someone else's support of the position you're 10 taking because it seems to me you can't support any 11 other number besides what's here.
12 DR. HOPENFELD: No, I don't support this -
13 - Look. This number reflects surface which was a 14 machine, not surface that was exposed to corrosion.
15 JUDGE WARDWELL: Can you point us to where 16 it says that this is an assumption that is a machine 17 surface that's not corrosional (sic)?
18 DR. HOPENFELD: Yes. I would have to go 19 back there. It's in the discussion. There's nothing 20 talked about the actual surface. You have to talk 21 about the actual surface.
22 JUDGE WARDWELL: Mr. Stevens or Mr.
23 Fitzpatrick from Entergy, do you have any indications 24 that these numbers refer to machine surfaces as 25 opposed to operational surfaces that may not be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1085 1 perceived?
2 MR. STEVENS: No, sir. The testimony we 3 heard yesterday was the purpose of these factors was 4 to translate the ASME air data to components in 5 reactors and one of the items included in that is 6 surface finish. So that indicates that the surface 7 finishes that were considered are consistent with 8 components in nuclear reactors.
9 JUDGE WARDWELL: So to say it another way 10 if; in fact, it was a machine surface, the recommendation may have been under here of a factor of 12 1.0 possibly.
13 MR. STEVENS: Possibly.
14 JUDGE WARDWELL: So the 4.0 accounts for 15 those types of operational surfaces that you would 16 expect.
17 MR. STEVENS: Yes, sir.
18 JUDGE KARLIN: Let me ask. On this chart 19 on page 76 of NUREG 6909 -- Let me ask this of Mr.
20 Stevens. These two columns, the present report and 21 Section 3, are those CUFs or are they Fen numbers?
22 MR. STEVENS: Neither.
23 JUDGE KARLIN: Okay. Neither.
24 MR. STEVENS: Do you recall we talked 25 about --
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1086 1 JUDGE KARLIN: They are the air -- Are 2 they the air curve on smooth pieces of metal?
3 MR. STEVENS- They are adjustments to the 4 air curve to come up with a design curve.
5 JUDGE KARLIN: Right. Okay. So they 6 don't have - They're not Fens. They are the air 7 curve, smooth metal, adjusted to reflect some 8 conservatism.
9 MR. STEVENS: Yes.
10 JUDGE KARLIN: Okay. So where is the Fen?
11 Is there Fen? Where is the Fen -- These are not Fen 12 factors.
13 MR. STEVENS: No.
14 JUDGE KARLIN: These are not 15 environmentally adjusted in any way, shape or form.
16 They don't say, well, you know -- Is a rough surface 17 a different environment than a smooth surface. or is 18 there just not a Fen at all?
19 MR. STEVENS: These describe adjustments 20 made to the curve prior to application of Fen factors.
21 JUDGE KARLIN: Right.
22 JUDGE REED: Mr. Stevens, to help my 23 colleague, if you adjust the curve down by a factor of 24 4.0 it implies that the Fen also is -- Well, I guess 25 the Fen goes up by a factor of 4.0, doesn't it? Isn't NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1087 i that --
2 JUDGE WARDWELL: Only the same. They are 3 two different things. The factor of 4.0 is in 4 recognition that you don't have a machine surface even 5 in air so that you're reducing that to a recognit-ion 6 that you're not having a machine surface.
7 DR. HOPENFELD: No.
8 JUDGE WARDWELL: Is that a fair 9 assessment, Mr. Stevens?
10 MR. STEVENS: Yes, that is.
11 JUDGE WARDWELL: .Why is it not, Dr.
12 Hopenfeld?
13 DR. HOPENFELD: Because -- Let's stick to 14 the point in time. Because go back to where the 15 original ASME Code comes from. It comes from 16 laboratory tests. Then we have -- I said it already.
17 Then they got altogether. So we know we don't have a 18 perfect surface in a laboratory. We're using smooth 19 surfaces and -- reproducibility. Let's make 20 allowances. Okay. Then we made allowances and they 21 say, "We made an allowance before." Okay.
22 JUDGE WARDWELL: Because it's not a 23 machine surface.
24 DR. HOPENFELD: No. Because it is a 25 machine. Because those tests we're doing -- with a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1088 1 machine surface.
2 JUDGE WARDWELL: Right.
3 DR. HOPENFELD: In real life, you're going 4 to have a machine surface.
5 JUDGE WARDWELL: That's why you have 4.0.
6 DR. HOPENFELD: That's why they put 4.0.
7 JUDGE WARDWELL: Thank you.
8 DR. HOPENFELD: But now comes the concept 9 that they haBv( here and comes along and he says, "We 10 want to get rid of all the curve. Okay. We want to 11 get it out there and ".
12 JUDGE WARDWELL: Who is they? Who says 13 this?
14 DR. HOPENFELD: The people who came -- The 15 Argonne people with the hefty end concept. We want a 16 curve that uses the -- In air, I want to take it out 17 and put in, substitute, with a value, a light value, 18 okay, a stress value versus fatigue cycles in air --
19 in water. The simple way of doing it is dividing the 20 value and multiplying it by the same factor.
21 Do you see what I'm saying? That's -- Fen 22 is a factor of any air divided by 10 or -- in -- what 23 do you call it, in the reactor and Fen in air and 24 divided it by the reactor and multiply by the ASMU 25 which is the AMA argued that you got in the reactor.
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1089 1 MR. STEVENS: May i clarify?
2 JUDGE WARDWELL: Mr: Stevens.
3 MR. STEVENS: This factor, surface finish, 4 on NUREG 6909. page 76, the factor of 4.0 for. the 5 Criterion Document and 2.5 to 3.5 in the present 6 NUREG, the specimens that were tested mirror polished 7 specimens. What's in a vessel are machine components,
.8 forged components. That factor is intended to account q for that difference.
10 JUDGE REED: And can you say what.- the 1I ultimate effect is on a Fen value that would be 12 calculated for machine if you had the exact same 13 transient on the exact same specimen except one is 14 mirror polished and one has a surface roughness? How 15 do these factors translate to the ultimate answer that 16 we're looking for, the Fens?
17 MR. STEVENS: The surface finish is 18 included in these factors that develop the curve.
19 Therefore, you don't double-dip and do it again when 20 you compute an Fen.
21 JUDGE KARLIN: It's not in the Fen.
22 MR. STEVENS: That's correct..
23 JUDGE KARLIN: Okay.
24 JUDGE WARDWELL: The surface finishes are 25 already accounted for in the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1090 1 MR. STEVENS: It's already accounted for.
2 So there's no need to put it in the Fen.
3 JUDGE WARDWELL: Translation apply this 4 factor of 4.0.
5- DR. HOPENFELD: I think that's a good --
6 JUDGE REED: I guess I need a better 7 answer than that. I'm sorry. If I do a calculation 8 of a CUFen for a mirror polished specimen and I do the 9 same calculation for -- What I'm trying to understand 10 is what these factors mean in terms of the ultimate 11 limits that we're placing on these. So you have to 12 help me understand whether a factor of 4.0 or a factor 13 of 20 here, how does that translate into an effect on 14 the calculated CUFen numbers?
15 MR. STEVENS: The calculations we did were 16 components in a reactor. So we used a curve that had 17 been adjusted for surface finish.
18 JUDGE REED: And if you had not used a 19 curve that was adjusted for surface finish, what would 20 -- how much smaller would the CUFens have been?
21 Can you say?
22 MR. STEVENS: From Section 3, 23 approximately a factor of 4.0.
24 JUDGE REED: That was my question. So 25 it's directly proportional to these numbers.
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1091
_ MR. STEVENS: Yes.
2 JUDGE REED: Okay. Thank you:
3 (Off the record discussions.)
4 DR. HOPENFELD: Are we allowed to explain 5 this a little, just a little bit about that?
6 JUDGE KARLIN: I think we are going to 7 take a break for a moment. It's .2:30 p.m. We will 8 reconvene in ten minutes. We'll take a break and 9 adjourn for-ten minutes. Off the record.
10 (Whereupon, at 2:29 p.m., the above-11 entitled matter recessed and reconvened at 2:41. p.m.)
12 JUDGE KARLIN: We're back on the record.
13 Ms. Tyler, did we lose Dr. Hopenfeld?
14 MS. TYLER: I just asked one of the ladies 15 in the back.
16 JUDGE KARLIN: Great. I'll wait until he 17 comes in before I remind everyone you're still under 18 oath. But I appreciate that you all have been sitting 19 there for most of two days in the warm and heat and 20 we're sitting here with glasses of water and enjoying 21 ourselves and I don't think you have any sustenance 22 over there. So a secret weapon. Okay. That's fair 23 enough because it's been pretty warm.
24 I think our questions at this point are 25 not for Dr. Hopenfeld.
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1092 1 JUDGE WARDWELL: I just want to make sure 2 that he hears them though.
3 JUDGE KARLIN: Yes.
4 (Off the record discussions.)
5 JUDGE KARLIN: Ms. Tyler, could you go and 6 get Dr. Hopenfeld?
7 MS. TYLER: Yes. Apparently he has 8 injured himself downstairs and I think we need to go 9 down and see what happened.
10 JUDGE KARLIN: Oh my gosh.
11 MS. TYLER: Yes. Hopefully 12 JUDGE KARLIN: Okay.
13 MS. TYLER: Hopefully, it's not serious.
14 I'll be right back.
15 JUDGE KARLIN: Please do. Yes. Maybe we 16 should take a short break.
17 JUDGE WARDWELL: Might as well.
18 JUDGE KARLIN: Why don't we take a five 19 minute break and see if we can find out what Dr.
20 Hopenfeld -- So we'll be adjourned for five minutes.
21 Off the record.
22 (Whereupon, at 2:43 p.m., the above-23 entitled matter recessed and reconvened at 2:50 p.m.)
24 JUDGE KARLIN: We'll go back on the record 25 now.
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1093 1 The Atomic SafeLy and Licensing Board is 2 now back in session. I would remind the witnesses 3 that you are still under oath.
4 Dr. Hopenfeld, are you ali right? I 5 understand you had an accident?
6 DR. HOPENFELD: I'm sorry for 7 interrupting.
8 JUDGE KARLIN: No,. that's all right.
9 DR. HOPENFELD: Actually, I wanted you to 10 feel sorry for me.
11 JUDGE KARLIN: All right. Well, we'll 12 work on that. You've been very patient, and there's 13 been a lot of warm days and afternoons.
14 So I think we have some more questions.
15 JUDGE WARDWELL: I think we have pretty 16 much finished up with surface finish, drain rate, 17 oxygen and existing surface cracks or surface 18 cladding, which seem to be the most important.
19 I surveyed my colleagues, and we are 20 pretty clear on your position, Dr. Hopenfeld, on the 21 other issues.
22 DR. HOPENFELD: May I just make one 23 comment?
24 JUDGE WARDWELL: In what regard?
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1094 1 impression that I felt.. that I had done something.
2 wrong. I didn't mean to do that., What. I wanted to 3 say is they just haven't gotten that far.
4 JUDGE WARDWELL: Thank you.
5 For Entergy, these -- with the notice that 6 in fact this table was presented as part of the 7 rebuttal, I wanted to query you in regards to whether 8ý or not you had any comments on the other ones that Dr.
9, Hopenfeld has brought up in his rebuttal with regards 10 to how you may have addressed these in your analyses.
11 JUDGE KARLIN: Let's clarify what the 12 table is.
13 JUDGE WARDWELL: Yes, it's table one, page 14 four of NEC JH 63.
15 And so the remaining other ones that Dr.
16 Hopenfeld agrees are less important than the three 17 most important ones are, deal with data scatter, size, 18 flow rate, heat to heat variation, loading history, 19 cyclic strain hardening, temperature below 150 which 20 we really have covered, trace impurities in the water, 21 and sulfite morphology.
22 If you have no additional comments, that's 23 fine. Also, that is fine, see if you wanted to 24 address how -- or refresh our memories of how these 25 are addressed in your cumulative use factors, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1095 1 environmentally faccored into that analysis.
2 MR. STEVENS: I guess the only thing I
- 3. would sav is that this table indicates that none of 4 these factors were addressed in Entergy's analysis.
5 I don't agree with that.
6 All but two of them were either directly 7 or inherently included in the analysis.
8 JUDGE WARDWELL: And which two weren't
-9 either directly or indirectly included?
10 MR. STEVENS: On page six, we have already 11 talked about item #13, existing cracks, and I had 12 identified that was not relevant.
13 In item #11, it talks about trace 14 impurities, and NUREG 6909 in fact points out that 15 those kinds of things were not considered because it's 16 not -- it's very improbable that any kind of an 17 impurity would be present during a transient event.
18 So therefore they did not feel it appropriate to 19 evaluate.
20 JUDGE WARDWELL: Were all the others 21 considered under 6909?
22 MR.. STEVENS: Yes.
23 JUDGE KARLIN: Were they considered -- you 24 mentioned considered under 6909. As I understand it, 25 you didn't apply 6909. But they were considered by NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1096 1 Entergy, or were they considered by 6909.?
2 MR. STEVENS: I would say both.
3 JUDGE KARLIN: Okay.
4 MR. STEVENS: With that comparison I 5 testified on yesterday using a 6909 bounding the 6 previous results.
7 JUDGE KARLIN: Okay.
8 MR. STEVENS: They are covered.
9 JUDGE WARDWELL: Thank you.
10 JUDGE REED: Dr. Hopenfeld, you claimed 11 that Entei.-gy used incorrect heat transfer questions in 12 their analysis; is that correct?
13 DR. HOPENFELD: Yes, absolutely.
14 JUDGE REED: You agree? Do you believe 15 that the heat transfer coefficient should have been 16 larger or smaller than it actually is?
17 DR. HOPENFELD: I don't know, in some 18 places it should be larger, in some places it should 19 be lower. I wasn't concerned that much with the 20 absolute volume but more with the distribution. And 21 I would like to give you the background for that if I 22 may.
23 JUDGE REED: Yes, please.
24 DR. HOPENFELD: When I was into getting 25 into the area of calculating the CUF--
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1097 1 JUDGE REED: We've left the FDN, and we're 2 now back on CUF.
3 DR. HOPENFELD: We're on CUF now, you're 4 not on the FDN. There were two items here that I'll 5 have to go through. And I left off about the Green 6 function that we've talked a lot about this morning, 7 and I'd like to give you my perspective, that is 8 different from you-hear from the grievants.
9 JUDGE WARDWELL: A little louder, please.
10 DR. HOPENFELD: My perspective is 11 different than Mr. Stevens with respect to the 12 refunction, and also, and then I'll talk about the 13 heat transfers, which apply both to the Green 14 function, Green's function, and the final element of 15 the other analysis that they have done.
16 First, with respect to the Green function, 17 what one has to understand that what the basic 18 equation is that heat transfer, not linear heat 19 transfer equation. When you go and make 20 approximations by using the Green's function, what you 21 are doing, you are linearizing that equation.
22 JUDGE REED: I'm a little puzzled. The 23 Green's function has to do with how the stress is 24 calculated.
25 DR. HOPENFELD: Correct. I said we are in NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1098 1 the area of Lhe CUF, not the CFEN. And the CU`F does 2 a phase in calculating the -- using the Green function 3 and the finite element. Except it is not --
4 JUDGE REED: We're going to relate this to 5 heat transfer?
6 DR. HOPENFELD: Yes.
7 JUDGE REED: You used the term, heat 8 transfer equations.
9 DR. HOPENFELD: Right.
10 JUDGE REED: I think it's the heat 11 transfer coefficients, the expression.
12 DR. HOPENFELD: No, no, I'll get there.
13 But I will give you -- I am trying to elaborate what 14 you were told this morning about the Green function.
15 And I think it will be different, starting with the 16 heat transfer. I mean I could go immediately to the 17 heat transfer coefficients if you wish. But I thought 18 I would give you the whole background.
19 JUDGE REED: Please help me understand 20 what your contention is.
21 DR. HOPENFELD: Well, there are two items.
22 One has to do with the Green function, which was 23 discussed, and the heat transfer coefficient is 24 equally important there.
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1099 i influence the heat equations, or are the heat 2 equations evaluated with the heat functions?
3 DR. HOPENFELD: Well, we are about to 4 suggest -- and that's why I was going -- because to 5 answer your question I would like to talk about two 6 things, and if I start with the Green's function, I 7 think that will come out.
8 JUDGE REED: We'll listen to your comments 9 about the Green's function.
10 DR. HOPENFELD: I'm sorry?
II JUDGE KARLIN: Proceed with Green's 12 function.
13 DR. HOPENFELD: And you will see whcre it 14 goes. It does go to the heat transfer. I'll give you 15 the exact words when we get there. So what you are 16 going, because it is a nonlinear equation.
17 JUDGE KARLIN: Now what's a nonlinear 18 equation?
19 DR. HOPENFELD: Well, the terms under the 20 second differential equation depends on location and 21 time.
22 JUDGE KARLIN: But what equation?
23 DR. HOPENFELD: The basic energy equation 24 that- describes the temperature distribution in a 25 component from which they take the stresses.
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1100 1 JUDGE KARLIN: Is this the heat conduction 2 equation?
3 DR. HOPENFELD: This is the heat 4 conduction equation.
5 JUDGE KARLIN: Now I understand.
6 DR. HOPENFELD: I call it the heat 7 transfer equation. This is the basic heat transfer 8 equation.
9 JUDGE REED: This is diffusion theory?
10 DR. HOPENFELD: Correct. The terms is, 11 the heat capacity, the conductivity, the so forth.
12 And the reason I'm bringing it up is because they made 13 several assumptions which are not justified, and it 14 just went through there. And I want to make sure that 15 you understand what is behind them.
16 They have linearized that equation. In 17 other words, I assume that the properties could be 18 used as an average volume.
19 Another place --
20 JUDGE REED: Pardon me, that equation is 21 basically linear. It is only the properties.
22 DR. HOPENFELD: That is correct.
23 JUDGE REED: The thermal conductivity --
24 DR. HOPENFELD: Yes, conductivity, heat 25 capacity, and density.
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I -11i01 JUDGE REED: Are functions of the 2 temperature of the metal, hence nonlinear 3 DR. HOPENFELD: That's correct, the 4 patterning of the temperature.
5 JUDGE REED: Okay, then I understand.
6 DR. HOPENFELD: But that's part of it. So 7 what you are doing in the concept, we're in the 8 concept here so you will see where I am going with 9 this, what you are doing is basically, the beginning 10 of the Green's function is taking the surface 11 integral, it's a double integral; you convert them 12 into a lining, right, you look beneath the surface, 13 just like you know if you are in the farm, instead of 14 looking at the tows, you look at what's going on with 15 the fence.
16 What is important here for doing this, 17 when you apply this when you have Green's function, 18 one of the inputs is the heat flux coefficient. First 19 off that's how you calculate the temperature.
20 So the heat transfer coefficient has to be 21 constant, you see. That is one of the basic 22 assumptions there that they had made.
23 My contention is that the heat transfer 24 coefficient is not constant. And the reason for that 25 it's not constant during the transient which you have NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1102 1 a force convection flow, and it is not constant during 2 the transients where you have a free convection flow, 3 and you have condensation.
4 JUDGE REED: Let me see if I understand 5 precisely what you say is not constant. I thought I 6 heard you say heat transfer coefficient?
7 DR. HOPENFELD: Correct.
8 JUDGE REED: Now this is the coefficient 9 expressing the heat transfer from the fluid to the 10 surface of the metal; is that correct?
11 DR. HOPENFELD: Correct. It's written as 12 K -- the heat flux H into the heat transfer 13 - coefficient times the bulk fluid, that's the wall 14 temperature, or vice versa, that's being closed by 15 either way. And that heat transfer coefficient, as I 16 said, it's not constant, it's not constant along the 17 symmetry -- along the nozzle, either in the X 18 direction or circumferential.
19 You see the basic *assumption of this 20 asymmetric model that they have that all these 21 properties are constant. Now why is that important?
22 If you go --
23 JUDGE WARDWELL: And all your discussion 24 relates only to the three nozzles, is that correct?
25 It doesn't --
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1103 DR. HOPENFELD: I am focusing on these 2 three just for discussion. But anything else, because they are using different computer code in some type of 4 pipe, what they call pipe, or proprietary code. I'm 5 not too familiar what's in there. But I basically 6 know when they have to.
7 But if you would please look at NEC JH-15.
8 JUDGE KARLIN: JH-15?
9 DR. HOPENFELD: Yes.
10 JUDGE KARLIN: Page?
11 JUDGE WARDWELL: *That's another 12 calculation su1ILmary from Structural integrity 13 Associates?
14 DR. HOPENFELD: No, there is a curve 15 there, let's see if I don't have the page number.
16 (Pause) 17 DR. HOPENFELD: There is a curve in the 18 document. I will talk about it if it doesn't come.
19 MS. TYLER: Dr. Hopenfeld, is that the 20 stress/time.
21 DR. HOPENFELD: It provides the flat 22 stress versus time with two different heat transfer 23 coefficients.
24 MS. TYLER: That's on page one dash seven.
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1104 1 of the exhibit? JH-15?
2 MS. TYLER: Yes.
3 DR. HOPENFELD: I thought I had the page 4 marked, and then I didn't. So it's -- okay. But you 5 see the point here is that this was provided by 6 Entergy, and what it does is, it shows you the result, 7 the thermal stresses, are very sensitive to the heat 8 transfer coefficient.
9 This is average heat transfer coefficient; 10 it doesn't recognize the local heat transfer 11 coefficient, because they made assumptions that it 12 doesn't vary.
ii 13 In the meeting that we had on January 8 "h, 14 we had --
15 JUDGE KARLIN: Meeting? What meeting?
16 DR. HOPENFELD: The meeting we had that --
17 the public meeting between NRC, public and Entergy, 18 they had discussed the results of their calculations 19 with regard to the CUF for the prenozzle, because they 20 wanted to continue with that Green function, to use 21 the Green's function.
22 And in doing so, one of the items that 23 wasn't very clear was they indicated that any 24 discrepancies were very important to the heat transfer 25 coefficient. The results were very very sensitive to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1105 1 the heat transfer coefficient.
2 JUDGE REED: Now I have to question you 3 about this particular figure, because this figure is 4 making the point that the stress depends on the heat 5 transfer it says for a different set of heat transfer 6 coefficients representing different flow rate 7 conditions.
8 MR. STEVENS: Correct. Correct.
9 JUDGE REED: Since this calculation was 10 done by Structural Integrity, let me turn very quickly 11 to Mr. Stevens, and ask him to explain to me what 12 these two curves really represent?
13 MR. STEVENS: This is a, first off it's a 14 typical representation for the purposes of describing 15 the methodology in the report, so -- but it's showing 16 the stress response to two different flow rates, same 17 transient. It doesn't specify what flow rates. It's 18 just showing as a typical example.
19 JUDGE REED: What was changed between the 20 two curves? Was it just the heat transfer coefficient 21 itself, or was it the entire assumption of what the 22 heat transfer equation is struck, as Hopenfeld would 23 call it, it looks like.
24 MR. STEVENS: This curve would have only 25 varied the heat transfer coefficient.
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1106 1 JUDGE REED: Because different flow rates 2 have different Reynolds numbers. So you have a 3 Reynolds number dependence built into your heat 4 transfer expression.
5 So what I'm trying to understand is, the 6 coefficient in front is also dependent on the flow 7 rate? Or is it just the Reynolds number to the point 8 eight power?
9 MR. STEVENS: Just the Reynolds number.
10 JUDGE REED: Okay, so you really are not -
11 - you are -just changing -- this is just basically two 12 curves at differenit flow rates.
13 MR. STEVENS: That's correct.
14 JUDGE REED: I don't get the point then.
15 JUDGE WARDWELL: Before we get to that, 16 can I just fix one other thing?
17 -In your confirmatory analysis this doesn't 18 apply at all; is that correct?
19 MR. STEVENS: That's correct.
20 JUDGE WARDWELL: And it won't for the 21 future, two other nozzles that will be evaluated using 22 the same confirmatory analysis. This only applies to 23 the refined analysis for those two?
24 MR. STEVENS: That's correct.
25 JUDGE WARDWELL: Thank you.
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1107 JUDGE REED: However, you would expect a.
2 similar curve, a similar dependence on heat transfer 3 even with the confirmatory calculations, would you 4 not?
5 MR. STEVENS: Yes, sir.
6 JUDGE REED: So the only thing that 7 doesn't apply here is that you use this Green's 8 function methodology, but a different, an improved 9 methodology would produce similar curves, different 10 but similar.
II JUDGE WARDWELL: Well, it wouldn't 12 linearize it as much, would it, as Green's function 13 does?
14 MR. STEVENS: The effect of heat transfer 15 on stress results depicted in this figure would be 16 important to the confirmatory analysis. The Green's 17 function shown in this figure would not.
18 JUDGE REED: So Dr. Hopenfeld, you were in 19 the process of discussing.
20 DR. HOPENFELD: I want to make sure I'm 21 not running ahead of myself. I'm going really step by 22 step.
23 JUDGE REED: Well, you called our 24 attention to this particular curve, and now I 25 understand it, so we can move along.
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1108 1 DR. HOPENFELD: Yes.
2 JUDGE KARLIN: We don't want to go too 3 step-by-step. Let's move it along if we can.
4 DR. HOPENFELD: The next step is the 5 important one.
6 JUDGE KARLIN: Great.
7 DR:. HOPENFELD: And what it is, it says, 8 that because the two different velocities, you see, if 9 I had doubled -- that's the first thing -- if I double 10 the velocity, okay, I double the stress, I affect the 11 changes in the stress, and that's the message of this 12 graph, okay.
13 In turn the velocity affects the heat 14 transfer almost linearly if you say the stresses are 15 directly affected; it's very sensible.
16 MR. STEVENS: May I clarify from the 17 standpoint of a fatigue analysis, would you care about 18 peak stress? There is no difference between these two 19 curves. The peak stress of the two curves near the 20 coordinate is the same. So whereas the stress out at 21 steady state is different, what is important to the 22 fatigue analysis is the peak stress, and in this 23 particular case those two curves are not 24 distinguishable.
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1109 1 it may or may not have an impact on the stresses of 2 interest for fatigue analysis.
3 DR. HOPENFELD: Can I say --
4 JUDGE KARLIN: Please respond.
5 DR. HOPENFELD: Because that is not where 6 I'm-going. I will just tell you that you don't want 7 to come from nowhere and tell you there's a 8 relationship between different velocity and different 9 stress modes. That's all I'm trying to say here, in 10 setting out the basis. You see the affected velocity 11 on the stress level.
12 Now they made the assumption that the 13 velocity is similar throughout the flow, and I'll 14 define similar in a minute; and they also made the 15 assumption that there is now circumferential 16 difference in the velocity, and because of that there 17 is no difference in the heat transfer coefficient, and 18 the temperature is uniform throughout the whole thing.
19 How does that affect, how that assumption 20 affects the -- where he picks up -- decides where the 21 maximum stresses are is something that I cannot say.
22 But I can show you from this that the effect is 23 significant on the local stresses.
24 Now so the next thing is, we look as to 25 why -- what is the justification for them to neglect NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1110 iI the velocity distribution throughout the nozzle, both 2 circumferentially and axia!!v.
3 JUDGE REED: Now, can we pause there for 4 a moment, and let me repeat back-to you what I think 5 you said, and see if I understood correctly.
6 If I'm understanding,: your point is that 7 if we go take a point in the nozzle and go 8 circumferentially around the nozzle, that the flow 9 field may be larger at the top of the nozzle than it 10 is around the bottom. Hence the heat transfer 11 coefficients would be different as we go around the 12 nozzle.
13 And your contention is --
14 DR. HOPENFELD: And axially.
15 JUDGE REED: And by axially, you mean as 16 you move along the length of the pipe.
17 DR. HOPENFELD: Yes.
18 JUDGE REED: So whereas the bulk flow 19 through the nozzle is constant. So if they used this 20 bulk flow to determine a single velocity, then they 21 would not -- your conjecture or your assertion is that 22 Mr. Stevens used a constant heat transfer across the 23 entire surface, the inner surface of this nozzle.
24 DR. HOPENFELD: Right.
25 JUDGE REED: And that if he had varied the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1 heat transfer coefficient, it would have caused' 2 sirniF icantly hiQher stresses --
3 -DR. HOPENFELD: Correct.
4 JUDGE REED: -- to be calculated in the 5 nozzle?
6 That seems to me on the face of it to be 7 a plausible argument. Could I ask you to respond, Mr.
8 Stevens?
9 MR. STEVENS: Yes, would you like me to 10 respond with respect to the refined analyses or the 1i confirmatory analyses?
12 JUDGE REED: Well, I think both.
13 MR. STEVENS: Well, the refined analyses 14 used,-- well, let me back up.
15 Heat transfer, I agree, is a function of 16 velocity and temperature. So we need to account for 17 those in our calculations.
18 One way I can do that, because it is 19 commonly recognized by analyses of this type that the 20 higher the heat transfer coefficient you apply, the 21 more conservative your stress results are, because you 22 increase the heat transfer and introduce larger 23 temperature differentials in the component which would 24 lead to higher thermal stresses.
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1112 1 integration technique like the Green's function, it is 2 important that I pick a bounding heat transfer 3 coefficient if I'm only going to use one single value.
4 When I do the Green's function, I do have 5 to use one set of heat-transfer coefficients.
6 JUDGE REED: One set meaning uniform on 7 the entire surface, inner surface of this nozzle?
8 MR. STEVENS: One set as in we would 9 transfer different values of heat transfer coefficient 10 along the component where appropriate. But in each I1 regio-n there would only be one value of heat transfer 12 coefficient.
13 JUDGE REED: What would a region be?
14 MR. STEVENS: A region would be an area 15 where it is constant, say diameter. So therefore the 16 velocity in that region would be the same.
17 JUDGE REED: I see.
18 MR. STEVENS: I change diameter, that's 19 another region, I need to use another diameter because 20 the velocity changes.
21 JUDGE WARDWELL: And you designed your 22 finite element mesh to be able to do that in the 23 regions of your interest, to change that heat?
24 MR. STEVENS: Well, an input to our finite 25 -- not exactly. Yes, our model is built with those NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1113 1 transitions in it. But an input to that model is heat 2 transfer coefficients. So when we calculate those 3 heat transfer coefficients, we have to take account of 4 those different diameters in the model.
5 - JUDGE WARDWELL: But your mesh is still 6 also designed so that you can put them into the model
- 7. --
8 MR. STEVENS: That's correct.
9 JUDGE WARDWELL: -- and not only 10 calculating from those regions, but it gives you an 11 opportunity as an application point for those 12 coefficients.
13 MR. STEVENS: That's correct.
14 So I would calculate for each one of those 15 regions a value of heat transfer coefficient. And I 16 would pick it to bound flow rates, and temperatures 17 that the component will seek.
18 So for these 20 transients that we talked 19 about yesterday, where the flow rate might range from 20 very low to very high, I would pick the highest flow 21 rate to compute my heat transfer coefficients.
22 JUDGE WARDWELL: And is that what you did 23 during the refined analysis?
24 MR. STEVENS: Yes.
25 JUDGE WARDWELL: Thank you.
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11114 1 JUDGE REED: So again you believe you are 2 picking conservatively large heat transfer 3 coefficients-that would yield maximum stresses?
4 MR. STEVENS: Yes.
5 JUDGE REED: Or conservatively large 6 stresses.
7 MR. STEVENS: We calculated heat transfer 8 coefficients to cover these effects I just mentioned, 9 velocity and temperature, to bound those effects.
10 JUDGE REED: Now in these models, your 11 model, your finite element model of this nozzle is 12 two-dimensioiial or three-dimensional?
13 MR. STEVENS: It's an axi-symmetric model 14 which you have seen in cross section and it's two 15 dimensional.
16 JUDGE REED: So that's two dimensional.
17 MR. STEVENS: But it is treated as a solid 18 revolution. The computer program can actually give us 19 stresses at different azimuths circumferentially.
20 JUDGE REED: How would it do that if in 21 fact you have no mesh grid in that azimuthal 22 direction?
23 MR. STEVENS: It's a technique of the 24 finite element program that if all conditions are the 25 same, you tell it that, it will compute the same NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1115 1 answer around circumferentially. But it also gives 2 the ability, a good example is moment loading on these 3 nozzles. It does allow you to supply non-symmetric 4 loading to that component, and then it will properly 5 compute the stresses around the circumference of that 6 component for that non-symmetric loading.
7 So the conditions have to be right in 8 order to use that model for those. They have the 1 ability to analyze certain non-symmetric loads, like 10 applied mechanical loads, but not things like
!i temperature transients. So the temperature transients 12 are assumed to be uniform around the circumference.
13 If you wanted to take into account those 14 kind of effects, where appropriate, you would have to 15 build a three-dimensional model that also included the 16 circumferential portion of the structure.
17 JUDGE REED: Would it be excessively 18 difficult to build that model?
19 MR. STEVENS: It does take a significantly 20 longer amount of time to perform these analyses using 21 such a model.
22 JUDGE WARDWELL: Certainly more than 30 23 percent more time that the extra direction might 24 indicate?
25 MR. STEVENS: That's correct.
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1116 I JUDGE WARDWELL: vVIa about your 2 confirmatory analysis? Are we ready to move on?
3 JUDGE REED: I'm not sure we're done with 4 heat transfer.
5 JUDGE WARDWELL: No, I mean what he did, 6 he said this is what he did for the confined. Now 7 what you do for the confirmatory.
8 MR. STEVENS: On the confirmatory 9 evaluation, since we modeled the transients in the 10 finite element model, apply them as the temperature 11 variation, now we have the ability to change the heat 12 transfer coefficient through that transient, since we 13 are modeling it, as opposed to the Green's function, 14 where we want to make sure we bound it because we are 15 going to use that result to integrate the stress 16 response of this transient, and that process requires 17 us to have a constant value for that integration 18 process.
19 So we kind of have one shot at heat 20 transfer in a Green's function input. And the 21 confirmatory evaluation, much more sophisticated, we 22 can specify it throughout the transient.
23 So we can vary heat transfer as a function 24 of temperature and flow rate during that transient as 25 it would occur during the confirmatory analysis.
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1117 1 JUDGE REED: Wouldn't you expect 2 significantly larger shear stresses at the nozzle 3 corner if in fact there was considerable variation in 4 the heat transfer coefficient azimuthally around that 5 opening? And isn't that not accounted for in your 6 model?
7 MR. STEVENS: We our axi-symmetric 8 model does not account for circumferential variations 9 in temperature. There is no indication -- I mean that 10 would be an inappropriate assumption under the 11 transients and the high flow rates we are using.
12 JUDGE REED: Well, it was Dr. Hopenfeld's
.13 conjecture that in fact the heat transfer coefficients 14 would vary significantly as we go azimuthally around 15 the nozzle. That would lead to a significant 16 fluctuation in the temperature field azimuthally 17 around the nozzle. That would lead to larger shear 18 stresses, would it not?
19 MR. STEVENS: Under the conditions we are 20 evaluating, I don't known of any circumstances where 21 that would come into play.
22 JUDGE REED: So you don't --
23 MR. STEVENS: I don't agree with that 24 assessment.
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1118 i assumption that the heat transfer coefficient varies 2 around the -- is that --
3 MR. STEVENS: That is correct, for the 4 condition, these transients that we are evaluating, 5 yes, I agree.
6 JUDGE KARLIN: Are you saying it didn't 7 happen, or it's not scientifically correct?
8 MR. STEVENS: Not sciehtifically correct.
9 JUDGE REED: I'm sorry, now what does that 10 mean, not scientifically correct?
11 JUDGE KARLIN: I withdraw the question.
12 JUDGE REED: Decause I believe it's 13 scientifically correct to say you have got a 14 significantly distorted temperature field as you went 15 azimuthally around the nozzle, that you would develop 16 fairly large shear stresses.
17 JUDGE KARLIN: Right, now let's ask that 18 question, is that scientifically true? Do you agree 19 with what he just said?
20 MR. STEVENS: I agree with that.
21 JUDGE KARLIN: Okay. i thought you said 22 the opposite a moment ago.
23 MR. STEVENS: Well, what I was saying is, 24 for the conditions we are evaluating --
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1119 1 didn't happen here.
2 MR. STEVENS: That's correct.
3 JUDGE KARLIN: So scientifically the ii 4 proposition Dr. Reed just said, yes, you agree with 5 the proposition that Dr. Hopenfeld stated you agree 6 with, but you are just saying it didn't happen here?
7 MR. STEVENS: Yes, I agree.
8 JUDGE WARDWELL: And why doesn' t it happen 9 here? You mean by happening here is for the modeling 10 associated with Vermont Yankee?
11 MR. STEVENS: Yes.
12 JUDGE WARDWELL: And why -- I guess I 13 don't understand what you mean by, didn't happen here.
14 You didn't incorporate it, or it physically doesn't 15 happen at Vermont Yankee for whatever reasons?
16 MR. STEVENS: Given the conditions we are 17 evaluating, that does not happen. We have very high 18 flow rates causing these significant transients on 19 these nozzles, fully developed flow that would not 20 allow for those kinds of temperature variations.
21 JUDGE WARDWELL: So now it seems like we 22 are getting down to whether or not you have fully 23 developed flow.
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1120 1 please go to NEC JH-14, 10.
2 . JUDGE REED: Fourteen, page 10?
3 DR. HOPENFELD: Right., this is feedwater 4 piping, it's a sketch, it's a cartoon of the feedwater 5 piping in -- at VY that we were given.
6 JUDGE REED: Where is the vessel in this?
7 Where is the nozzle?
8 DR. HOPENFELD: I believe it's on the top 9 there. By the two hangers there. Hard to see. But 10 my point here is, Mr. Stevens makes the assumption Il that it doesn't happen, then he said it doesn't 12 happen.
13 He said the flow is fully developed 14 because it's 48 inches.
15 JUDGE REED: Because what?
16 DR. HOPENFELD: Because it's 48 inches 17 away from the entries.
18 JUDGE KARLIN: You're saying there is a 19 linear flow of 48 inches and therefore he says it's 20 fully developed, and you are saying 48 inches is 21 enough for it to be fully developed.
22 DR. HOPENFELD: That's the next dialogue.
23 JUDGE KARLIN: Oh, yes.
24 DR. HOPENFELD: But let me first say what 25 is a fully developed flow. Fully developed flow is a NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1121 I flow where the velocity is similar everywhere along 2 the pipe. If you take a cut section somewhere,
.3 anywhere, the velocity distribution for turbulent flow 4 is going to be like power,- one-seventh power, and it 5 is well established.
6 If you go somewhere else, it's all the 7 same. It's similar. When you come for undeveloped.
8 flows, for an undeveloped flow, and I am-talking about 9 force convection now -- there are two items here I 10 want to talk one is force convection, another is 11 pre-convection, because some of those transients are 12 both.
13 I am going to go now to the force 14 convection first. If he says that all you need is 48 15 inches, and this 48 inches, you look at this figure, 16 that's exactly what it is. If you look at the data,-
17 before you look at the data, you usually in 18 engineering terms, you need 48 inches for the 19 feedwater. The feedwater diameter is about 10 inches, 20 so you are talking about four diameters, five 21 diameters.
22 Usually in engineering --
23 JUDGE REED: Well, can I stop you? We are 24 looking at this exhibit, NEC JH-14, page 10, and there 25 is a Figure 1, and where does it say 48 inches?
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1122 1 DR. HOPENFELD: That is the --
2 JUDGE REED: You said it's right here.
3 DR. HOPENFELD: Yes, it's right here. If 4 you look on the top you see a scale there. But you 5 can't read the scale. If I try to strain my eyes, and 6 I really don't want to cause you to do that. But you 7 can see it's around four to five. But he claims it's 8 four.
9 JUDGE KARLIN: What's 45?
10 DR. HOPENFELD: Four to five inches.
11 JUDGE KARLIN: What is?
12 DR. HOPENFELD: I mean four to five feet; 13 it's about 48 inches.
14 JUDGE KARLIN: What is?
15 DR. HOPENFELD: The length of the pipe 16 from the elbow to where it enters the nozzle.
17 JUDGE REED: We don't see -- we don't even 18 know where the nozzle is.
19 DR. HOPENFELD: Well, I think there's a 20 nozzle in the end there, you see the very end. But if 21 you can't see very well, I can't either. Mr. Stevens 22 testimony is that the length is 48 inches, from the 23 straight line is 48 inches.
24 JUDGE WARDWELL: So why did you have to 25 refer us to this figure? All we have to say is, his NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1123 1 testimony is that it's 48 inches.
2 DR. HOPENFELD: Right. Because you can 3 see it with your eyes --
4 JUDGE WARDWELL: No, you can't, that's 5 what I'm saying. And you can't say it either, you 6 can't point to where it is.
7 DR. 'HOPENFELD: Okay, but there is a point 8 I want to show the figures too, because it's not only 9 that straight actor. There's a whole -- I have a 10 reason to get there.
11 JUDGE WARDWELL: You are arguing about the 12 48 inches in regards to developing flow? You think ir 13 should be longer?
14 DR. HOPENFELD: Oh, yes. Let me just say 15 why. First of all I provided you data here showing --
16 JUDGE KARLIN: Well, why don't we -- let's 17 all take a time out here. Do we have any questions?
18 Where are we in'terms of questions?
19 JUDGE REED: Well, the subject was heat 20 transfer coefficients. And I think I am essentially 21 done.
22 JUDGE KARLIN: You don't have anymore?
23 You are done? Rich?
24 JUDGE WARDWELL: Yes, I do. I'd like to 25 go back to Mr. Stevens, and ask him to defend the 48 NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1124 1 inches for uniform flow, fully developed flow, because 2 I think that hinges on how you do your justification 3 for the selection of your heat coefficients.
4 MR. STEVENS: Okay, I'm going to actually 5 point to one ofiDr. Hopenfeld's exhibits, NEC JH-29.
6 JUDGE KARLIN: Okay, we're there.
7 MR. STEVENS: That's a two-page extract of 8 a textbook, Heat.and Mass Transfer by Eckhard. I'm 9 looking at the second page which is page 212 of the 10 textbook, Figure 8-9. What this figure is, it'-s not 11 really applicable to the conditions and geometry we 12 have, but it's useful for me trying to answer your 13 question.
14 This says, this is flow near entrance of 15 a tube. And the chart is showing what is called the 16 Nusselt number on the ordinates, NU, and that is 17 proportional to the heat transfer coefficient.
18 As a function of X over D, which is the 19 distance downstream of the tube entrance, as 20 nondimensionalized to the diameter of the tube, so if 21 you will what this graph gives us is a variation of 22 heat transfer downstream from that discontinuity.
23 Now we don't have a sharp entrance to a 24 tube; what we have is an elbow, and therefore the 25 discontinuities associated with this, this would be NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1125 1 overstating iL. Bu-t nevertheless, let's take a look 2 at it.
3 The other thing you will see on this 4 picture is several -lines that is a function of 5 Reynold's number. And given that we are- looking at a 6 constant diameter tube, these lines would indicate 7 increasing velocity in that tube as you move 8 vertically up the chart. Higher Reynold's number, 9 higher velocity.
10 What you see here is -- and actually as 11 you look to the far extreme right of the curve, of 12 these curves, that would be indicative of fully 13 developed flow, what the heat transfer coefficient 14 does for fully developed flow.
15 What you see with increasing velocities is 16 that these lines flatten out. The effect of that 17 entrance becomes more and more insignificant.
18 Now the part of this graph that is not 19 really applicable to some of our nozzles is the 20 Reynold's number. This goes up to -- the largest 21 Reynold's number. is 101,600; it's one E to the five.
22 Our Reynold's number in the upper E to the 23 five to. the mid-E to the sixth range, well off the 24 chart here.
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1126 1 this chart is, you can see that the effects of the 2 entrance are diminished. Amd now when you add to the 3 fact that w.e don't have an entrance; what we have is 4 an elbow. These effects- of using fully developed flow 5 are appropriate. And in fact that's what has been 6 done in our industry in piping for more than 40 years, 7 as Dr. Hopenfeld testified yesterday, the way we do 8 these analyses has been very robust, and hasn't 9 changed in 40 years, with respect to this element. In 10 fact these textbooks we are looking at, the 11 methodology has been well developed -for many years 12 longer than I've actually been around. It has not 13 changed; it's still consistent.
14 And all the commercial piping codes still 15 use this methodology. I'm not aware of any instances 16 of any components in our industry where it's been 17 shown that the relationships we are using are 18 inappropriate or nonconservative.
19 JUDGE REED: Dr. Hopenfeld, what would you 20 use in regards to the number of diameters --
21 DR. HOPENFELD: Could I answer the --
22 JUDGE REED: -- flow.
23 DR. HOPENFELD: Can I make a comment about 24 25 JUDGE REED: I would like you to answer my NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1127 1 question.
2 DR. HOPENFELD: What would I use?
3 JUDGE REED: What do you -- what do you 4 recommend being used as a number of diameters to 5 develop fully developed flow?
6 DR. HOPENFELD: Oh, okay, I would say that 7 for this -- that for their application it would be, at 8 the minimum, at the very very minimum, 12. I would 9 say that you probably would go up to 40.
10 JUDGE REED: Forty?
11 DR. HOPENFELD: Forty. Let me tell you 12 why, where the 12 comes.
13 JUDGE REED: I'm not interested -- yes, I 14 want to know the basis of that.
15 DR. HOPENFELD: You try to put a flow 16 meter in a line. You just want to measure your flow.
17 You are going to talk to the vendor, and he will tell 18 you you need at least 100 feet in order to get 19 accurate readings on your flow meter so the flow would 20 be similar; it would be fully developed.
21 And he will tell you, well, I don't really 22 believe -- they don't need that kind of accuracy.
23 What you need is a flow meter, because especially if 24 you are running and gauging fuel.
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1128 i put a flow straightener ahead of that component so the 2 flow is not going to be -- you -have all these 3 tornadoes around, it's going to be fully developed.
4 But you still have to have even with a 5 flow straightener-- some section ahead which is 6 straight, and then you ask, you know, what -- how 7 straight should it be? And so what it depends what's 8 up there, if you have an elbow or you have a valve, or 9 whatever you have, an elbow is one of them. An elbow 10 by my memory, the minimum number is -- like one of the 11 twelve and a half diameters with a straightener. If 12 you don't have a straightener, the cusLomary 13 II engineering number is hedging for years. It's not 14 today. This is a new invention here, what we got.
15 It's been for -- since I can remember going to school.
16 And this I gave you, this is just an 17 example and it -- the -- because this is easy to 18 understand what's needed. But it -- the flow is going 19 to be different whether you are downstream from the 20 valve or you are downstream from the elbow.
21 JUDGE WARDWELL: " Thank you, I think you 22 answered my question, thank you.
23 Dr. Reed?
24 JUDGE REED: Dr. Hopenfeld, in your 25 testimony, JH-03 on page 20, you give a table in which NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1129 1 you recalculate your own CUFen numbers.
2 DR. HOPENFELD: Yes.
3 JUDGE REED: Page 20, there is a table, 4 Table 3, recalculated cumulative usage factors for 5 sample locations.
6 Do you have that table?
7 DR. HOPENFELD: Yes, it's on page 20.
8 JUDGE REED: So you -- you would propose 9 that for Vermont Yankee that these are more 10 appropriated CUFens than the ones they calculate, is 11 that correct?
12 DR. HOPENFELD: Correct.
13 JUDGE REED: Now the largest CUFen that 14 you calculate is 13.77 on a particular outlet and all 15 16 DR. HOPENFELD: Yes.
17 JUDGE REED: Is that correct?
18 DR. HOPENFELD: Yes.
19 JUDGE REED: So if I use the definition of 20 a CUFen, and apply it to that particular component, 21 then I would maintain that one would expect failure of 22 that component, since this was calculated for 60 23 years; correct?
24 DR. HOPENFELD: That's correct.
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1130 2 DR. HOPENFELD: That's correct. I used 3 their numbers.
4 JUDGE REED: Then would you not expect 5 failure of that component in 4.63 years?
6 DR. HOPENFELD: I don't know, I do not 7 know how to relate these numbers --
8 JUDGE REED: By the very definition of C-9 U-F-e-n.
10 DR. HOPENFELD: Well, yes, for the --
11 regarding the definition of term, which I really 12 wanted to elaborate on that, because it depends how 13 people define, how they got the number of cycles under 14 what conditions, whether it was engineering crack, or 15 whether it was complete failure. I would say this is 16 all statistical. The higher the number --
17 JUDGE REED: Of course it's statistical, 18 but there is a definition fo what this factor is 19 supposed to mean.
20 DR. HOPENFELD: Right, it means potential 21 failure, but it doesn't mean --
22 JUDGE REED: It means that. you are way 23 past failure. You expect failure in much shorter than 24 60 years.
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1131 1 understand the way they defined their FEM and the way 2 their FEM has been used here, it's an engineering 3 crack.
4 JUDGE REED: No, I'm talking about a 5 definition. There is a very simple definition of both 6 a CUF and an FEN. So it's the number of cycles to 7 failure, divided by - I'm sorry, the expected number 8 of cycles, divided by the number to failure.
9 DR. HOPENFELD: Correct, but the number to 10 failure doesn't mean that it really has to fail.
11 JUDGE REED: No, no, that's the 12 definition. It has to fail.
13 DR. HOPENFELD: By definition, it has to 14 fail.
15 JUDGE REED: That is the definition of 16 this factor. You are talking about conservatisms 17 built into how we calculate it. I'm talking about the 18 definition.
19 DR. HOPENFELD: But sir --
20 JUDGE REED: I can put it to you, sir, 21 that if you calculate a number, 15.77, for a 60-year 22 analysis, that you are predicting failure in four 23 years, or a little over four years.
24 How can that be possible?
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1132 i don't believe that that's what it is.
2 JUDGE REED: That's your number.
3 DR. HOPENFELD: Yes, my number is 13-7, 4 but I don't agree with your supposition that this 5 -relates to -- that there is a correlation between this 6 number and when it fails.
7 JUDGE REED: Given that the plant has not 8 failed, that none of these nozzles has failed, how can 9 you justify proposing that the CUFen numbers could 10 possibly be as large as what you propose?
11 DR. HOPENFELD: How can I justify? All 12 this says, all these numbers say, and I think that's 13 what the ASME code, to the best of my understanding, 14 and what the guidance are, to say if you have.-- and 15 I believe that Mr. Stevens talked about that too -- it 16 doesn't mean everything falls apart once that number 17 is. about one. All it says, when you reach about one 18 you have got to do something.. I cannot buy your 19 supposition --
20 JUDGE REED: Even if I accept your point, 21 that it doesn't fall apart, just major cracking 22 occurs, We have not seen major cracking in any of 23 these components in 30-something years of operation.
24 And yet your CUFens predict that they fail in periods 25 of time that would be substantially shorter than that.
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1133 1 Hence I have to infer that your 2 calculations are extremely excessivelv conservative.
3 DR. HOPENFELD: They are conservative, but 4 I'd like to explain why.
5 JUDGE REED: Well, I'm concerned that 6 these CUFens that were 100 or 200, but that doesn't 7 mean that they are appropriate for use in licensing.
8 DR. HOPENFELD: Well, for the reason that 9 this tells you, this is the guideline, it tells you; 10 because of this I have got to do something. They A! calculate it in such a way that less than one they say 12 you don't have to do anything.
13 All this says, you've got to take an 14 action.
15 JUDGE WARDWELL: Let me ask it in this way 16 if I-might. It seems to me that the CUFens that you 17 calculate are highly dependent on the FEN that you 18 selected.
19 DR. HOPENFELD: Correct.
20 JUDGE WARDWELL: What is your technical 21 justification for a selection of 17 and 12 for 22 stainless and carbon steel, specific technical basis.
23 DR. HOPENFELD: Specific techhical base, 24 the specific technical base that in the abstract of 25 your 6909, the people have -- that came up with'these NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1134 i equations to calculate the FEN have done research and have looked -- and I've counted about 41 different 3 papers -- different research and concluded that you 4 could have bounding numbers, conservative numbers, 5 which are -- would vary. .One major difference between--
6 6909 and 6583 is that this gives you a guideline.
7 But I'd like to say one more thing --
8 JUDGE WARDWELL.. Are you saying Argonne 9 recommends these things?
10 DR. HOPENFELD: Yes, I'll give you the 11 reference. Let me just read this thing to you please.
12 That's the most important thing in the whole 13 presentation.
14 This is in the abstract of the -- of NUREG 15 6909. That's what this thing does.
16 JUDGE KARLIN: You are saying -they 17 recommend this-for all plants and --
18 DR. HOPENFELD: There --
19 JUDGE KARLIN: -- in lieu of that there 20 are no other values.
21 DR. HOPENFELD: The implication as far as 22 I'm concerned, there is an uncertainty in this 23 technology, and we gave into bottom numbers.
24 JUDGE KARLIN: But that's not an 25 application of that in a practical sense then; is that NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1135 1 correct?
2 DR. HOPENFELD: I think it is. Because it 3 doesn't say -- I don't buy into the proposition that 4 in fact it's 12 even if it was 20. The fact that this 5 falls apart.
6 JUDGE KARLIN: Well, point us to where 7 that is anyhow.
8 DR. HOPENFELD: All I'm saying, it doesn't 9 take -- You can run up, I have done it --
10 JUDGE KARLIN: Point it out, could you, 1i where 17 and 12 is used here?
12 DR. HOPENFELD: I'm sorry?
13 JUDGE KARLIN: In 6909 you say, 17 and 12 14 15 DR. HOPENFELD: Yes, I'm just trying to 16 get --
17 JUDGE KARLIN: Could you point that out so 18 we have it onthe record?
19 DR. HOPENFELD: Yes, I am just trying to 20 find where the exact word is.
21 JUDGE KARLIN: Well, why don't we give you 22 time, and you can come back to us later with where 23 that is.
24 DR. HOPENFELD: Oh, I know where that is.
25 JUDGE KARLIN: That's all the questions I NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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I1136 1 -have.
2 DR. HOPENFELD: It's in the abstract.
3 It's on the top of that page.
4 JUDGE KARLIN: That's okay. Just take 5 your time and find it. We'll get back -- you can just 6 give it to us later, give it to your counsel.
7 DR. HOPENFELD: Can I make just one 8 comment if I could say, I would like to --
9 JUDGE KARLIN: Well, let's just stop here.
10 Let's look at NUREG 6909, I have the abstract in front 11 of me, Dr. Hopenfeld. I think we should all refer to 12 that. Because it does appear to me thaL there are a I number 12 and a number 17 show up on that page. I'm 14 not sure what they all mean, but hopefully somebody 15 Will explain that to me.
16 And in the abstract, on page triple I, is 17 this what you are referring to, quote: Under certain 18 environmental loading conditions fatigue lives and 19 water relative to those in air can be a factor of 12 20 lower for austenitic stainless steels, three lowers 21 for nickle-chromium-iron alloys, and 17 lowers for 22 carbon and lower alloy steels.
23 Is that where you are getting the 12 and 24 17?
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1137 1 referring to, saving time looking it up here.
2 JUDGE KARLIN: I'm not sure what that 3 means, but I found the numbers for you. You tell us -
4 - do my colleagues have any questions? Does that mean 5 -- anything?
6 So that's where your numbers came from on 7 this chart?
8 DR. HOPENFELD: Yes, yes. For the FEN.
9 JUDGE KARLIN: The FEN.
10 DR. HOPENFELD: The original came from the 11 application.
12 11 JUDGE KARLIN: All right.
13 JUDGE REED: Mr. Fair, what gives you 14 confidence in the analysis performed by Entergy?
15 MR. FAIR: Well, I have to say I was not 16 the reviewer on these analyses. I think based on the 17 safety evaluation report, though, we did have a review 18 of these calculations that determined that the 19 parameters input were adequate, and the analysis 20 methodologies were adequate.
21 That's the basis for my conclusion that 22 they have an acceptable calculation.
23 JUDGE REED: So you believe that -- let's 24 talk in terms of their refined analysis -- you believe 25 their refined analyses are conservative. I think NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1138 1 there is a statement in the testimony by the staff 2 that the staff believes the refined analysis were 3 conservative.
4 MR. FAIR: The confirmatory analysis of 5 the feedwater nozzle came up with a lower ultimate CUF 6 than the defined analysis, so that it did demonstrate 7 that the original refined analysis for the feedwater 8 nozzle was conservative.
9 JUDGE REED: So it's still the position of 10 the staff that all of the refined analyses for all 11 nine locations are conservative?
12 MR. FAIR: No, that is not the position of 13 the staff. The fact that the feedwater nozzle 14 confirmatory analysis came out to demonstrate that the 15 refined analysis was conservative in that particular 16 nozzle, we couldn't draw a conclusion that the same 17 level of conservatism would exist *in the other two 18 nozzles, which is why we requested that they do 19 further confirmatory analysis.
20 JUDGE REED: Were you completely 21 comfortable with all the changes that were made to do 22 the confirmatory analysis?
23 MR. FAIR: Again, .I was not the one who 24 went in an audited and reviewed that analysis. But I 25 believe based on what I've read in the essay, the NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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-1139 1 review of that analysis, that it -- that that analysis 2 was adequate.
3 JUDGE REED: Even though that analysis 4 assumed that -- used a different FEN technology, a 5 different assumption, instead of using a single 6 environmental factor applied at the tail end of the 7 calculation, they used different FENS for each 8 transient I believe, and the net effect was that the 9 correction factor, the FEN applied, was substantially 10 lower in the confirmatory analysis of the feedwater 11 analysis than it was for the refined analysis.
12 You are still comfortable with the way 13 that was done?
14 MR. FAIR: Yes, I am comfortable with 15 using the FEN that applies to the transients being 16 analyzed for each fatigue usage calculation.
17 JUDGE REED: So why then did the staff ask 18 after the fact, ask that Entergy go back and apply the 19 original FEN to the new CUF that was calculated in the 20 confirmatory --
21 MR. FAIR: Well, the reason that the staff 22 did that was to try. and determine whether we could use 23 the feedwater analysis as a confirmation for all three 24 nozzles, so we wanted to get as close to a one-to-one 25 comparison of the, two analysis methodologies as NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1140 1 possible, with only the Green's function being a 2 difference.
- 3. And when that analysis came up higher than 4 the original analysis, then we decided we couldn't 5 assume that they were going to get the same level of 6 additional conservatism by breaking the transients up 7 and looking at an FEN for each transient, without 8 further confirmatory analysis.
9 JUDGE REED: And that's what led you to 10 require that Entergy do additional calculations of two 11 more nozzles?
12 MR. FAIR: That's correct.
13 JUDGE WARDWELL: That calculation will 14 include individual events for each transient?
15 MR. FAIR: Well, we didn't specify how 16 they are going to do it. They could -- the CUFens are 17 fairly low on those two nozzles. They may make a 18 conservative assumption --
19 JUDGE WARDWELL: Just to save time?
20 MR. FAIR: -- just to save time.
21 JUDGE REED: Okay.
22 JUDGE WARDWELL: Quick question while we 23 are on JH 03, we had that out for Dr. Hopenfeld on 24 page 16 of that. I'll quote you, so I think you will 25 remember it anyhow.
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1141 1 7c said: In my opinion -- this is you 2 saying this -- the number of transients proposed by 3 Entergy should be a minimum multiplied by 1.2 to 4 account for the probability of an increase in 5 unanticipated failures due to the 20 percent uprate, 6 power uprate.
7 How did you arrive at the 1.2. number?
8 DR. HOPENFELD: Okay, as we briefly talked 9 the other day, with the -- from the information given 10 to us, from the information given to us, the first
!! time, I thought I understood how they calculated the 12 numbers. They took the number of transients today 13 after 40 years, multiplied that number by 1.5. and 14 that was the number of transients.
15 Then there was a change evidently. And 16 then when I went to read -- when I read and I quoted 17 to you what Entergy stated, it was difficult for me to 18 understand how they arrived at that number. They had 19 they talked about it, but they haven't really 20 indicated how they got it, and what kind of changes 21 were involved with in the past. Because I don't know 22 what they were counting. They didn't really give us 23 data from day one. I don't know whether some of these 24 changes were more severe or less severe.
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1142 i 1.2?
2 DR. HOPENFELD: I arrived at 1.2 through 3 judgment because they increased the power by a factor 4 of 20, and I wanted to account for the fact that under 5 EPU conditions, even recent experience shows that the 6 proprietary a few years ago, as the EPU and the power 7 is increased, I want them to take into account that 8 factor.
9 JUDGE WARDWELL: You., selected it using 10 engineering judgment?
11 DR. HOPENFELD: Oh, completely engineering 12 judgment. I needed a hangar to hang my hat on.
13 JUDGE REED: Well, just a quick follow up 14 to that, what is the experimental observation, what, 15 two years of operation now at increased power, have 16 you seen an increased number of transients in that 17 period? I'm assuming you are tracking these 18 transients, so you should now?
19 MR. FAIR: The only transient we had since 20 power uprate and the normal shutdown for the 2007 fuel 21 outage was in August running at 25 percent power. We 22 went down in the spring to the refueling outage, or 23 the plant. We went down in the spring for the 24 refueling outages. There were no transients during 25 the power extension phase. Not even the test NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1143 1 transient. We actually did a test transient. It did 2 not -- the feedwater pump trip test phase. But that 3 was part of the EPU power extension plan.
4 JUDGE REED: Was the change in power level 5 held as transient?
6 MR. FAIR: Yes.
7 JUDGE REED: Didn't you recently change 8 power level?
9 MR. FAIR: Power level went up. The power 10 level at EPU, they had this big test to show that if 11 they lost one -of their Carter tank pumps, the feed 12 pump6 will -- research all that before you got your 13 reduced oower.
14 JUDGE KARLIN: So you had a transient in 15 August of 2007. This was unplanned reduction in power 16 as a result of the problem with the cooling structure?
17 Okay, so there was a transient-there.
18 Did you have a transient two weeks -- a 19 week ago when you had another problem with the cooling 20 switch?
21 MR. FAIR: Yes, when they were at 25 22 percent power, they tripped.
23 JUDGE KARLIN: Okay, let me ask. What I'm 24 trying to get to is, I guess, from the first, from the 25 point of startup to the uprate there was a certain NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., NW.
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1144 1 number of transients that occurred over a certain 2 period of time, from the point of uprate to today 3 there are a certain number of transients that occurred 4 over a certain period of time.
5 Has the rate increased, decreased, or 6 remained the same?
.7 MR. FAIR: We've got three data points.
8 I'd say -- I wouldn't characterize it as an increase.
9 It may have decreased. But it's a small --
10 JUDGE KARLIN: You are saying it's a small
- 11. data point, small timeframe. I understand the small 12 timeframe. But if you extrapolated that out for, you 13 know, the 36 years or whatever minus the time since 14 the uprate would you have the same number, more or 15 less?
16 MR. FAIR: Same, probably.
17 JUDGE KARLIN: You haven't done that?
18 MR. FAIR: I don't have those numbers, no.
19 JUDGE KARLIN: So you don't know whether 20 it's increasing after the uprate, or decreasing or the 21 same?
22 MR. FAIR: No.
23 JUDGE KARLIN: Okay. Did you have 24 something on that, Mr. Stevens?
25 MR. STEVENS: No, sir.
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114.5 1 JUDGE WARDWELL: Mr. Fair, in your 2 experience, reviewing -- well, let me ask you, how 3 many license renewal applications have you reviewed?
4 MR. FAIR: It's more than a doz~en'. I
-5 don't have a count.
6 JUDGE WARDWELL: That's fine.
7 Cumulative use factors are calculated as 8 a predictive mode in the license applications; is that 9 correct?
10 MR. FAIR: That's correct, yes.
11 JUDGE WARDWELL: Is it fair to say that 12 j these are continually calculated and recalculated 13 during actual operations once we get into -- once the 14 plants get into the renewal period as a tracking tool?
15 MR. FAIR: Well, there are two ways they 16 do it. one is to monitor the actual fatigue usage and 17 track that.
18 Another method is to count the number of 19 cycles that were used in the calculation, and assure 20 yourself that you don't exceed that number of cycles, 21 and therefore that verifies the CUF 22 JUDGE WARDWELL: So it's essentially doing 23 the same thing in regards to that?
24 MR. FAIR: Correct.
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1146 1 as a tracking tool; is that correct?
2 MR; FAIR:. Correct.
3 JUDGE WARDWELL: And those are really two 4 different types of applications of the CUFs, isn't it?
5 One is a predictive mode, and one is a tracking, 6 monitoring, and however else you want to call it, type 7 of mode during operations?
8 MR. FAIR: That's correct.
9 JUDGE WARDWELL: Thank you.
10 JUDGE KARLIN: I have, Mr. Fair, probably 11 these questions are for you, relating to what I'll 12 call commitment #27. If you could refer to the FSER, 13 which I guess is staff Exhibit No. 1, and we will go 14 to page 4-34 again.
15 I'm interested in what y'all refer to 16 there as commitment #27, and there are four pages in 17 the FSER, 4-34 to 4-37 inclusive I think, that spent 18 almost the bulk of the time talking about the 19 evolution of this commitment, #27.
20 Now I understand you didn't do the review.
21 Mr. Chang, Dr. Chang, did the specific review here.
22 But perhaps you can help me.
23 MR. FAIR: I'll try.
24 JUDGE KARLIN: Okay. Now on page 4-34 in 25 the I guess the second full paragraph on that page, NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1147 1 you start talking about, the staff reviewed the 2 applicant's commitment 427 which was provided in a 3' letter dated July 2 6 th ,2006.
4 So that was way back there in 2006 they 5 camre in with a commitment #27, I guess, that's what it 6 reflects. Then lat~er in that paragraph it talks about 7 January 4 th 2007, *the applicant provided a revised 8 commitment #27, all,-right.
9 You see that?
10 MR. FAIR: Yes.
11 JUDGE KARLIN: Agree that's there?
12 Then over on page 4-35 in the one, two, 13 three, four, five, the fifth paragraph down, we have 14 yet another revised commitment #27 of July 3 rd , 2007; 15 right? You see that?
16 MR. FAIR: Yes.
17 JUDGE KARLIN: You agree with that?
18 And then the next page talks about a 19 letter dated July 3 0 1h , 2007, from the applicant. *You 20 follow that? And there is a long quote that goes into 21 4-37, page 37, right?
.22 - MR. FAIR: Right.
23 JUDGE KARLIN: You have to speak so he can 24 record it, yes?
25 MR. FAIR: Yes.
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1148 1 JUDGE KARLIN: Okay, because what I'm 2 trying to get at is, you know, let's see if I can find 3 that other exhibit, this conversation that took place 4 on August 2 0 'h, around. 2007, right in tne middle of 5 all this it seems like. And I don't see a word about 6 that in here.
7 JUDGE-WARDWELL: It's a 10/25/07 memo that 8 summarizes that if that helps you locate that.
9 JUDGE KARLIN:. Yes, a 10/25 memo. I'm 10 trying to find the --
11 JUDGE WARDWELL: While he's looking for 12 that, is there any indication of why a submittal 13 summarizing a phone call took from August 2 5 th to 14 10/25 to be written?
15 MR. FAIR: Well, usually, the staff 16 documents their correspondences with licensees. I 17 don't know the specifics of the memo.
18 JUDGE KARLIN: Okay, well, let's to the 19 memo. It's NEC JH 62, but if you could look at that 20 exhibit.
21 NEC JH 62, are you with me?
22 MR. FAIR: I'm with you.
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1149 1 right?
2 MR. FAIR: Yes, I'm following.
3 JUDGE KARLIN:. Okay, and it says, 4 enclosure two contains a summary of the issues 5 discussed with the applicant, and this concerns 6 commitment #27, right?
7 MR. FAIR: Yes.
8 JUDGE KARLIN: So we go to enclosure two, 9 and it's in that memo it says, the enclosure two. that 10 the NRC staff's position is that in order to meet the i requirements of 10 CFR 54.21©) (1) an applicant for a 12 license renewal must demonstrate in the LRA, the 13 license renewal application, that the evaluation of 14 the time limited aging analysis has been completed.
15 The NRC does not accept the commitment to complete the 16 evaluation of the PLAA prior to entering the period of 17 extended operation.
18 Now were you involved in that 19 conversation?
20 MR. FAIR: No, I was not.
21 JUDGE KARLIN: No, you weren't in the 22 meeting, but are you familiar with this memo or this 23 concept?
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1150 1 seen it.
2 JUDGE KARLIN: Well, one question is, why 3 isn't that reflected in the FSER? You have a four-4 page discussion of commitment #27, and this seems like 5 a significant event?
6 MR. FAIR: Again, I can't answer the 7 question, because I didn't develop that section of the 8 SER.
9 JUDGE KARLIN: Okay. And it's true to 10 note, if you would look at that, that the regulation 11 being cited is 10 CFR 54.2l(c. (1),right?
12 MR. FAIR: That's correct.
13 JUDGE KARLIN: It doesn't say 14 (c) (l).(3),does it?
15 MR. FAIR: No, it doesn't.
16 JUDGE KARLIN: Or one or two or three.
17 MS. BATY: Your Honor, if you look at 18 those documents, it lists the individuals who were 19 present for this phone call. And there were three 20 individuals, NRC staff representatives, and one of 21 those individuals is in the room right now, and that 22 is the project manager, Jonathan Rowley. The other 23 individual -- the other staff individual has passed 24 away, and then the other one was Dr. Chang.
25 JUDGE KARLIN: All right.
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I1151 1 MS. BATYý If it would be helpful to Lile 2 board, Mr. Rowley is in the room and will be 3 testifying later on, and he wrote this document, to 4 explain it. But otherwise I don't think'Mr. Fair 5 knows any of the other details-.
6 JUDGE KARLIN: I posited that Mr. Fair was 7 not part of that conversation. I did want to make 8 that clear, and I asked him that question. So I think 9 that is clear on the record; the thing speaks for 10 itself.
11 Enclosure one has a list of participants, 12 and Mr. Fair's name isn't on it, and he said he did 13 not participate in this, and Dr. Uhang did. And 14 that's one of the problems with Dr. Chang not being 15 here.
16 And I don't think we are in a position to 17 add new witnesses on behalf of the staff at this point 18 on contention number two.
19 But I'm just troubled by the fact that 20 that is never mentioned in the FSER. And it just 21 seems like a significant event.
22 But let's go to the FSER, and the last of 23 the appendix, what, A -- I think it's appendix A to 24 the FSER, if you could refer to that, because now we 25 are going to get to the actual commitment #27 as it NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1152 1 survived the evolution that the FSER mostly reflects 2 with the absence of the August 2007 problem.
3 And what is that, Appendix A, FSEN, 4 Vermont Yankee NPS license renewal commitments. Mr.
5 Fair, what are these commitments?
6 MR. FAIR: Well, they are commitments by 7 the applicant to the NRC staff to complete certain 8 actions.
9 JUDGE KARLIN: Okay. Are they legally 10 binding?
1I MR. FAIR: I believe the commitments in 12 the FSER are not legally binding, but the -- I believe 13 there is a -- that they have to be made conditions of 14 the license.
15 JUDGE KARLIN: Okay, all right. How are 16 they made conditions of the license? What happens -7 17 these are not legally binding in the FSER. But are 18 all of these converted into some license condition?
19 MR. FAIR: I can't speak to that.
20 JUDGE KARLIN: Okay. Or sometimes they 21 are and sometimes they're not?
22 MR. FAIR: I believe they are. I believe 23 they normally are taken as license conditions when 24 they have commitments.
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1153 1 something?
2 JUDGE WARDWELL: Yes, just a quick 3 question.
4 To the best of your knowledge are all the
-5 promises made by the applicant in response to RAIs 6 converted into these commitments as presented here as 7 best you know?
8 MR. FAIR: As best I know.
9 JUDGE KARLIN: So everything they say in 10 the whole licensing process for two years or three 11 , years, I don't think you really want to say that 12 everything they promise is put i=to writing as a 13 commitment?
14 MR. FAIR: Well, every commitment -- okay.
15 JUDGE KARLIN: Every commitment - it's a 16 more formal thing. There may be other informal thin gs 17 that are not incorporated as commitments, and thus 18 perhaps not incorporated as license conditions?
19 MR. FAIR: That's possible. I can't say.
20 JUDGE KARLIN: Yes, we are speculating.
21 But we can go -- if we could go to Appendix A of the 22 FSER on page A8, and here we have the wonderful
-23 commitment #27, all right. Two years prior, at least 24 two years prior to entering the period of extended 25 operation for the location specified in -- and there's NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1154 i locations -- NUREG 6260 for BWRs of the VY vintage, VY 2 will refine our current fatigue analyses to include 3 the effects of reactor water environment, and verify 4 that the cumulative use factors are less than -- that 5 one, I think it's a typo, less than one.
6 Does that say -- is that the condition we 7 are talking about where they are going to do two 8 additional CUFen analyses on the core spraying of 9 reactor recirculation?
10 MR. FAIR: I believe that is.
11 JUDGE KARLIN: Okay, I mean that's what I 12 1 thought. But why didn't they just say that?
13 MS. BATY: Your Honor, the license 14 conditions expresses that out in part one of the SER.
15 JUDGE KARLIN: Okay.
16 MS. BATY: One point seven of the SER.
17 JUDGE KARLIN: Okay, 1.7. We'll go to 18 that in a minute perhaps. But let me go to the next 19 one.
20 This includes applying the appropriate FEN 21 factors to valid CUFs. Who- decides what's 22 appropriate?
23 MR. FAIR: In implementing the commitment, 24 it would be the applicant.
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1155 1 what he thinks is appropriate?
2 MR. FAIR: Yes.
3 JUDGE KARLIN: Down on subparagraph two of 4 this, more -- I'm reading -- more limiting VY-specific 5 locations with a valid CUF may be added in addition to 6 -- who decides whether they are added?
7 MR. FAIR: Again, this would be the 8 applicant.
9 JUDGE KARLIN: Okay, and number three, 10 represented CUF values from other plants adjusted to 11 or enveloping the VY plant-specific external loads may 12 be used. Who makes the decision on that, the NRC or 13 the applicant?
- 14. MR. FAIR: Again, it's the applicant.
15 JUDGE KARLIN: Why doesn't the NRC make 16 these things? I mean isn't it a judgment call?
17 MR. FAIR: Yes, it is.
18 JUDGE KARLIN: What if the applicant makes 19 a choice that's wrong? Anyway to catch them?
20 MR. FAIR: Well, yes, they could be all 21 expired but have a period of extended operation to 22 verify the commitments are implemented.
23 JUDGE KARLIN: So the licensee will make 24 a choice on all these "mays" in here, because there 25 are quite a few more of them.
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1156 1 MR. FAIR: Yes.
2 JUDGE KARLIN: Item #4. says, an analysis 3 using NRC-approved version of ASME code, or.an NRC-4 approved alternative may be performed in the next 5 paragraph. During the period of assembly operations, 6 VY may also use one of the following options..
7 So there are a lot of options, a lot of 8 discretion in there, right?
9 MR. FAIR: Yes.
10 JUDGE KARLIN: And those discretionary 11 choices are the applicant's discretionary choices?
12 MR. FAIR: As this commitment states.
13 JUDGE KARLIN: If the applicant chooses 14 something the staff doesn't agree with, can the staff 15 say something and get them to change it?
16 MR. FAIR: If they audit the 17 implementations of these commitments and have concerns 18 with it, yes they can add some kind of an issue.
19 JUDGE KARLIN: All right, now what if Dr.
20 Hopenfeld didn't agree with one of these choices that 21 was made, would he have an opportunity to come weigh 22 in?
- Would NEC have an opportunity to file an 23 contention and have a -- is there a notice of 24 opportunity for a request a hearing every time one of 25 these things happens?
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1157 1 MR. FAIR: I don't believe so.
2 JUDGE KARLIN: Okay, so it's just the --
3 it's pretty much the applicant's choice to do Yankee's 4 judgments, and unless the staff objects that is going 5 to be it. No public scrutiny allowed on whether that 6 cuts the mustard or not.
7 MR. FAIR: Yes, I agree that's true.
8 JUDGE KARLIN: Thank you.
9 Okay, I think we are getting there with 10 regard to convention #2. We have asked pretty much 11 the questions we thought were of concern to us..
12 We are going to go back into the room and 13 take a recess now, 15 minutes, and go over our notes 14 and see if there is something we think we might have 15 missed or want.to ask any further clarification on.
16 During that timeframe hopefully you all 17 will think about whether you think there is something 18 that has come up in this process that we should probe 19 or ask or something we missed.
20 And this is the time when you will give us 21 suggestions. So we will take a -- well, why don't we 22 reconvene at 4:30. That will be a 20-minute break.
23 So we are now adjourned for 20 minutes.
24 (Whereupon, at 4:12 p.m. the proceeding in 25 the above-entitled matter went off the record to NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1158 1 return on the record at 4:52 p.m.)
2 JUDGE KARLIN: All right. As we 3 discussed; the Board went back and reviewed its 4 questions to try to think through if there was 5 something we thought we hadn't covered or we still 6 wanted to get some information on or needed 7 elicitation in the record. And so we've done that.
8 We have also received -- thank you -- from 9 a number of the parties some proposed questions. I'm 10 not going to read the questions that we have received, 11 but I would acknowledge that. we received questions 12 from the State of New Hampshire, several questions in 13 written form, and we received some questions from 14 Entergy. And we received a- set of questions in 15 writing from New England Coaliition, I believe in 16 coordination with the State of Vermont. So thank you.
17 We have taken a look at those and tried to 18 study whether we think the matter is -- needs 19 clarification on the record. I also understand --
20 does the Staff have something you want to give us 21 orally?
22 MS. BATY: Your Honor, we have changed our 23 mind. We don't have anything further.
24 JUDGE KARLIN: Okay. All right, fine.
25 That's great. I appreciate that.
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II 1159 1 And having done that, we have seveali qu-,estions we are going to ask. And if your question 3 does not get asked, it's because we believe -- we 4 don't have any -- we feel we are clear enough on the 5 record and we're clear enough-- for our understanding 6 that we don't need to ask those questions. The record 7 and the evidence is sufficient for us to understand 8 the issue.
9 So with that, we have several questions 10 that are going to be asked, and I believe Dr. Wardwell 11 will start.-
12 So let me say this -- the witnesses all 13 rememberwe are -- you are still under oath. So thank 14 you.
15 JUDGE WARDWELL: I think the first will be 16 addressed to Mr. Fitzpatrick in regards to discussions 17 we had in. relationship to the transients that have 18 occurred so far under the -- our uprate existing 19 there. And the first question is: what is your 20 definition of the transients for the purpose of the 21 cycle count? Is it only the zero to full power, or 22 full power to zero, or all transients included in 23 anything considered to be a major transient?
24 MR. FITZPATRICK: Major transients --
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1160 power level would be a major transient. A power 2 reduction and a gradual heat -- for example, when they 3 -- the cooling tower was offline last year, they 4 reduced power 50 percent, they reduced power 5 gradually. There's a tech spec they have to follow to 6 reduce power and increase power.
7 JUDGE KARLIN: You previously testified 8 that you have approximately 90 transients over the 9 history of a facility, right?
10 MR. FITZPATRICK: The question was since 1.1 we did power uprate.
12 JUDGE KARLIN: Well, let's just go from 13 the beginning. What is your -- when you say you had 14 90 transients since the beginning -- 96 -- is that 15 just full power transients, or all transients of 16 whatever magnitude?
17 MR. FITZPATRICK: That's startup/shutdown 18 transients. That was that one particular category.
19 JUDGE KARLIN: So that only includes 20 startup and shutdown transients?
21 MR. FITZPATRICK: Yes.
22 JUDGE KARLIN: Are there other transients 23 you've had since -- the last 36 years?
24 MR. FITZPATRICK: Yes.
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1161 I the --
2 MR. FITZPATRICK: That was one number from 3 one transient that gave us that example.
4 JUDGE KARLIN: Well, I misunderstood.
-5 JUDGE WARDWELL: So what are the total 6 number from -- do you know?
.7 JUDGE KARLIN: Yes. What's the total 8 number of transients?
9 JUDGE WARDWELL: From '72 to 2008.
10 MR. FITZPATRICK: The total number of
!! every transient? I'd have to go back and recalculate 12 it -- or look it up and calculate it. It's 13 caiculations out there that were put in discovery that 14 evaluate the plant, how many transients you've had at 15 certain times. They are documented in that. The last 16 time we did an assessment was in -- in response to an 17 RAI -- peak usage, CUF -- at the end of 2005. And 18 that was one of the license renewal amendments.
19 JUDGE WARDWELL: Do you have any 20 estimation of how many of those would be in the life 21 of a plant? And how it compares to --
22 MR. FITZPATRICK: Well, major -- turbine 23 trips, I think it was -- say HPSI injections in the 24 feedwater. Turbine trip is one of those shutdown --
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1162 i from zero power, breakdown, and tripped offline. That 2 was included in the CUF that's -- we've tracked.
3 JUDGE KARLIN: Well, but we're not asking 4 about 2005. I'm trying to understand -- I was under 5 the impression that you -- we asked you, for CUFens, 7
6 how many -- and a transient is an event which causes 7 stress, I thought, which is a part of the calculation 8 of the metal fatigue, stress, and that sort of thing, 9 and so how many transients have you had since the 10 plant started operation. And you said something in 11 the range of 90 to 96. Now I understand that that's 12 only a special kind of transient, and you have a lot 13 of other kinds that you didn't tell. me about.
14 MR. FITZPATRICK: I said, for example, 15 startup transients, shutdown transients, and --
16 JUDGE KARLIN: What about '78 or '83? I 17 don't care about a year. I just want the total number 18 of transients.
19 MR. FITZPATRICK: That's the total number 20 of startup/shutdown transients.
21 JUDGE KARLIN: Well, I want all 22 transients. Since the beginning of time to today, how 23 many have you had, of any magnitude, of any kind, of 24 any color or description?
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1163 1 offhand.
2 JUDGE KARLIN: -okay.
3 JUDGE WARDWELL: Can you get that to us?
4 MR. FITZPATRICK: Yes, sir.
5 JUDGE KARLIN: All right. Then, we'll -
6 JUDGE WARDWELL: Within this week?
7 MR. FITZPATRICK: I'd have to consult with 8 the people who -
9 JUDGE KARLIN: Mr. Lewis, do you think you 10 all could arrange to have that for us?
11 MR. LEWIS: I'll do my best.
12 JUDGE KARLIN: Thank you. I think that 13 number actually came out in the uprate proceeding, so 14 you might go back and check. It might need -to be 15 updated.
16 JUDGE REED: Would Mr. Stevens have those 17 numbers, since he did -- you had to have those figures 18 for those transients in order to do your analyses, is 19 that correct?
20 MR. STEVENS: Well, no, we had the input 21 provided by Entergy. Recall, those were design 22 numbers that were shown to be conservative compared to 23 the actual counts. The only indication I have of what 24 you're asking for was in the license renewal 25 application.
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1164
! I be+/-lieve it -was Table 4.3.2 maybe that 2 had a tabulation for several different trans.tents and 3 the number that had been accumulated as of a certain 4 date in the projection forward. I ceon't recall 5 specifically what those numbers are, but they were in 6 the application.
7 JUDGE REED: So in the CUFen transient 8 count, did you include all transients or only some 9 subset of transients?
10 MR. STEVENS: We included all transients 11 that had any impact on fatigue.
12 JUDGE KARLIN: So that's a subset of 13 transients.
14 MR. STEVENS: A subset of design 15 transients, that's correct.
16 JUDGE KARLIN: And how many were they?
17 MR. STEVENS: I can only speak 18 approximately.
19 JUDGE KARLIN: Okay.
20 MR. STEVENS: Depending on the component, 21 so for a feedwater nozzle approximately 20.
22 JUDGE WARDWELL: Different types of 23 transients.
24 MR. STEVENS: Different types of 25 transients.
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1165 1 JUDGE REED: Types, not numbers.
2 MR. STEVENS: No, not numbers.
3 JUDGE REED: Not. quantities. How many 4 total numbers?
5 MR. STEVENS: Each one of those transients 6 would have had a different quantity associated with
.7 them.-
8 MR. FITZPATRICK: May I speak?
9 JUDGE KARLIN: Yes, Mr. Fitzpatrick.
10 MR. FITZPATRICK: The calculations for the 11 feedwater nozzle show the transients that. were 12 actually evaluated. And each one of those is a 13 certain number. There are --
14 JUDGE KARLIN: Was that in one of the 15 exhibits?
16 MR. FITZPATRICK: Yes.
17 JUDGE KARLIN: Okay, great. Which exhibit 18 would that be?
19 JUDGE WARDWELL: That number is based on 20 what?
21 MR. FITZPATRICK: That's the design 22 number, plus any additions we did for 60 years using 23 the EF analysis.
24 JUDGE WARDWELL: But it's a selective 25 design number, not the actual number that has NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1166 1 occurred.
2 MR. FITZPATRICK: Right. The actual 3 numbers are lower than that,. and there is a
.4 calcuatEion that actually tracks it. The results --
5 JUDGE -WARDWELL: Well, what would be 6 useful for us is to see the actual numbers, just to 7 confirm --
8 MR. FITZPATRICK: Yes.
9 JUDGE WARDWELL: -- what you intended to 10 do for your analysis.
1I1 MR. FITZPATRICK:. Yes. Yes.
12 JUDGE REED: I think a comparison between 13 the actual numbers that occurred and the numbers 14 assumed in the analysis would make us more 15 comfortable.
16 MR. FITZPATRICK: Entergy has that.
17 JUDGE KARLIN: But we haven't seen it yet.
18 We haven't been provided it.
19 MS. HOFMANN: We don't have that as an 20 exhibit?
21 JUDGE KARLIN: No. They are still looking 22 for the exhibit.
23 MR. FITZPATRICK: We have -- this shows 24 the numbers that we used.
25 JUDGE KARLIN: Do you have it, Mr.
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1167 1, Stevens?
2 MR. STEVENS: Yes, I can answer half the 3 question, which is, what did we analyze?
4 JUDGE KARLIN: All right.
5 MR. STEVENS: Exhibit E-2-11. E-2-11 is 6 Structural Integrity,Associates' calculation, VY 16Q-7 302, dated July 18, 2007.
8 JUDGE KARLIN: Yes, okay.
9 MR. STEVENS: There's a couple of places 10 we could refer to in here. The best one, in terms of 11 number -- different types of transients and the 12 quantity, one place we coul-d look is starting on 13 page 18, Table 5.
14 JUDGE KARLIN: Table 5, yes. It's a nice, 15 long table.
16 MR. STEVENS: Two pages.
17 JUDGE KARLIN: Two pages, okay. Long 18 enough.
19 MR. STEVENS: In column number 1, it's 20 transient number. These would be the different types 21 of transients, 25 transients.
22 JUDGE KARLIN: Twenty-five di f ferent types 23 of transients.
24 MR. STEVENS: Different type. In the far 25 right column, 13 is the number of cycles of each of NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W.
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1168 1 those transients. Each trariient is defined by 2 multiple points in. time. That's why you'll see 3 multiple lines within each transient number.
4 So just as an example, on page 19 --
5 JUDGE KARLIN: No, but wait a second.
6 Let's just stay with this -- or I guess we're still on 7 the chart. Go ahead, 19 is --
8 MR. STEVENS: This would be the second 9 page of that table.
10 JUDGE KARLIN: Yes, okay.
.111 MR. STEVENS: Event number 20, far right, 12 300 cycles were assumed for 60 years.
13 JUDGE KARLIN: We're still -- but that 14 doesn't tell us the actuals.
15 MR. STEVENS: That's correct.
16 JUDGE KARLIN: And when you say transients 17 are assumed, are these -- these are 25 different types 18 of transients. Okay. Within each type, is there any 19 -- is it only a -- is it any amount of amplitude of a 20 transient, or is it only a major? Is there any other 21 qualifier which excludes or includes -- you know what 22 I mean?
23 MR. STEVENS: Within each transient, the 24 temperature and pressure would vary.
25 JUDGE KARLIN: Yes.
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116.9 1 i'iR. STEVENS: And those --
2 JUDGE KARLIN: I mean, is there something 3 that says, "Well, they are too small, we're not going 4 to count those," within each category or --
5 MR. STEVENS: Not within those listed 6 here, I don't believe. We had --
7 JUDGE KARLIN: Oh. But -- okay. But this 8 does not give us actual transients.
9 MR. STEVENS: No.
10 JUDGE KARLIN: And --
11 MR. FITZPATRICK: Entergy has those 12 numbers.
13 JUDGE KARLIN: Great. And I think we 14 would probably request that be submitted by Entergy, 15 if you could, Mr. Lewis. Thank you.
16 JUDGE REED: I'm a little curious about 17 one thing. One particular transient occurred 10,000 18 times?
19 JUDGE KARLIN: It didn't occur, actually.
20 JUDGE REED: I'm sorry. Well, they 21 assumed it occurred. It must have occurred a large 22 number of times in -- what's that, a small power 23 fluctuation?
24 MR. STEVENS: That's a daily power 25 reduction.
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1170 1 JUDGE REED: Okay.
2 JUDGE WARDWELL: Mr. Fitzpatrick, have you 3 had any actual thermal transients throughout the life 4 of the plant, that are outside the design basis as 5 provided by the designer?
6 MR. FITZPATRICK: Not that I know of.
7 JUDGE WARDWELL: You testified, did you 8 not, that there is -- well, maybe there's some 9 confusion on how many transients have occurred.since 10 the uprate. And I think you stated that there has 11 only been one full transient; there are other less 12 than. Have you included the July '08 power reduction 13 down to 25 percent for the cooling towers as a 14 transient, the August 7th cooling tower collapse, and 15 a 50 percent power-down, an August '07 turbine stop 16 valve incident resulting in a 100 percent power-down, 17 and the 2004 condenser leak resulting in a 50 percent 18 power-down?
19 MR. FITZPATRICK: 2004 was prior to power 20 uprate.
21 JUDGE KARLIN: Right, prior to the power 22 uprate.
23 JUDGE WARDWELL: Would the other three be 24 included in the transients that have occurred since 25 power uprate, in your testimony?
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11.71 1 MR. FITZPATRICK: Power reductions and the 2 trip at 25 percent in August.
3 JUDGE REED: Sorry: You've got to speak 4 louder.
5 MR. FITZPATRICK: The power reductions and 6 the trip from 25 percent power in August 2008. The 7 power reductions have a small -- a power reduction has 8 a small effect on cumulative usage. It's mostly seen 9 in the feedwater. That's why there's -- it's a large 10 number of transients where feedwater is evaluated, and i1 this is small usage -- very small usage factor --
12 factor from those deductions.
13 PARTICIPANT: Could you speak up?
14 JUDGE KARLIN: Yes.
15 MR. FITZPATRICK: I think I am.
16 JUDGE KARLIN: Yes. Try to speak up some 17 more if you could. It has been a long day.
18 Appreciate it, Mr. Fitzpatrick.
19 JUDGE WARDWELL: Let me rephrase. Hasn't 20 the total number of less than full transients that 21 have occurred in the uprate include the July 8th 22 power-down of July of '08, power reduction down 25 23 percent because of the cooling tower leaks? Would 24 that be considered a transient?
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1372 1 a transient. I did leave Entergy in March, so I 2 haven't followed every case since then.
3 JUDGE WARDWELL: How about the August '07 4 cooling tower collapse, resulting in a 50 percent 5 power-down?
6' MR. FITZPATRICK: That would be a 7 transient, yes.
8 JUDGE WARDWELL: How about the August '07 9 turbine stop valve incident resulting in a 100 percent 10 power-down?
11 MR. FITZPATRICK: Pardon me?
12 JUDG(E WARDWELL: The August '07 turbine 13 stop valve incident resulting in a 100 percent power-14 down.
15 MR. FITZPATRICK: Stop valve incident 16 occurredat 25 percent --
17 JUDGE WARDWELL: Okay. And it occurred 18 August '07.
19 MR. FITZPATRICK: Yes.
20 JUDGE WARDWELL: Was that an incident? Is 21 that a transient?
22 MR. FITZPATRICK: That was a transient, 23 yes.
24 JUDGE WARDWELL: Thank you.
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1173 1 about this issue of trace elements and impurities.
2 And, first, I want to clarifw, that we are talking 3 about trace elements in the fluid itself, not in the 4 mud. Is that correct? In your. earlier testimony 5 about trace elements --
6 MR. STEVENS: Yes.
7 JUDGE REED: we were speaking about 8 impurities within the cooling.
9 MR. STEVENS: Correct.
10 JUDGE REED: Okay. And so I believe your 11 testimony was that they were not considered because 12 you felt it was unlikely that they would be present 13 during a transient.
14 MR. STEVENS: Correct.
15 JUDGE REED: Now, it has been brought to 16 our attention that there was an incident in which 17 there was a leakage of service water through the 18 condenser. Was it -- is it possible that impurities 19 were injected into the system as a result of that 20 incident?
21 MR. STEVENS: I can't speak to that.
22 MR. FITZPATRICK: What date is the 23 incident?
24 JUDGE REED: I'm assuming it was probably 25 this incident in 2004, but I'm not certain.
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1174 1 MR. FITZPATRICK: Some- sort of --
2 JUDGE REED: Pardon me?
3 MR. FITZPATRICK: Some sort of impact to 4 the condenser that -- under norimal operations.
5 JUDGE REED: All right. So that answers 6 our question. Thank you.
7 JUDGE KARLIN: Now, this is a question for 8 Mr. Stevens. We had talked -- I had asked you some 9 questions, I think probably yesterday, about 6909 and 10 the calculations that you did over a weekend I guess, 11 applying 6909 to the nine I .guess locations, and you 12 took four hours to do it, remember that?
13 MR. STEVENS: I do, sir.
14 JUDGE KARLIN: Good. That was fast, that 15 was good. I'm trying to make sure I understand what 16 you did and what was meant by that. When you did that 17 analysis, did you -- you substituted the 6909 curves, 18 by just substituting the 6909 curves? What would have 19 been the result if you had done' everything according 20 to 6909?
21 What did -- when you did the four-hour 22 analysis applying 6909 -- let me back up -- what did 23 you do? You used 6909 in full, the air curves, the 24 95/95, you know, confidence levels, the Fens, and 25 everything else, or just some component of it?
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- ii1175 1 j MR. STEVENS: Everything.
JUDGE KARLIN: So you did the soup to nuts 3 as if the -- from scratch it was calculated under 4 6909.
5 MR. STEVENS: Yes, sir.
6 JUDGE KARLIN: Okay. And so you applied 7 all of 6909 to the CUFen analysis for Vermont Yankee, 8 and came up with the numbers that were less than one, 9 in all respects.
10 MR. STEVENS: Yes, sir.
11 JUDGE KARLIN: Okay.
12 JUDGE REED: Buc let's see, those numbers 13 -- and maybe I'm recalling the testimony wrong, but I 14 thought your point was that they were not only less 15 than one, but less than the refined analyses. Was 16 that --
17 MR. STEVENS: That was my testimony, yes.
18 JUDGE KARLIN: Yes, yes, that's right.
19 Well, do we have anything else at this 20 point? I think we are done with the witness panel 21 today. Thank you very much for all of your time and 22 effort. You have obviously spent a lot of time on 23 this, and have been patient in trying to answer our 24 questions.
25 We are about to adjourn until tomorrow.
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1176 1 We'il obviously start with &otntention number 3 2 tomorrow morning. I think it's safe to say contention 3 number 4 will not they don't need to show up until 4 after lunch at least.
5 -. (Laughter.)
6 But we may go a little faster with 7 contention 3 and 4-than what we had with 2.
8 We have also thought about the Chang 9 testimony problem. And it's our ruling that we are 10 going to leave the Chang. testimony. in for what it's iI worth. And we think that we've had some reference to 12 Dr. Chang's testimony here today. I think that was 13 all right.
14 And I think we found it to some extent 15 helpful, and so we are going to leave that in as 16 testimony that we might, for what it's worth, use in 17 this proceeding. And so that's our ruling on the 18 Chang testimony -- and the exhibits that went along 19 with it.
20 With that, we are adjourned for today, and 21 I look forward to seeing everyone here tomorrow 22 morning at 8:30.
23 MS. BATY: Your Honor, I want to ask a 24 question. I was wondering, are witnesses on 25 contention 2 panel, are they excused or --
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1177 1 JUDGE KARLIN: They are excused.
2 MS. BATY: Okay. They don't need to 3 remain in Vermont.
4 JUDGE KARLIN: They are excused. Good
-"5 question.
6 MS. BATY: Thank you.
7 JUDGE KARLIN: Thank you. We are 8 adjourned. See you all tomorrow at 8:30, please.
9 Thank you.
10 (Whereupon, at 5:14 p.m., the proceedings 11 in the foregoing matter were adjourned, 12 to reconvene at 8:30 a.m., the following 13 day.)
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CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: Entergy Nuclear Vermont Yankee, LLC & Entergy Nuclear Operations, Inc.
Name of Proceeding: Hearing.
Docket Number: 50-271-LR, ASLBP No. 06-849-03-LR Location: Newfane, Vermont were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken by me and, thereafter reduced to typewriting by me or under the direction of the court reporting.company, and that the transcript is a true and accurate record of the foregoing proceedings.
Of ftcial Reporter Neal R. Gross & Co., Inc.
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