ML082530277

Vermont Yankee July 2008 Evidentiary Hearing - Applicant Exhibit E4-09-VY, Declaration of Neil Wilmshurst

ML082530277
Person / Time
Site:	Vermont Yankee
Issue date:	04/18/2008
From:	Wilmshurst N Electric Power Research Institute
To:	Atomic Safety and Licensing Board Panel
SECY RAS
References
50-271-LR, ASLBP-06-849-03-LR, Entergy-Applicant-E4-09-VY, RAS M-324
Download: ML082530277 (6)

Text

DOCKETED USNRC August 12, 2008 (11:00am)

OFFICE OF SECRETARY RULEMAKINGS AND ADJUDICATIONS STAFF April 18, 2008 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

)

ENTERGY NUCLEAR VERMONT )

YANKEE, LLC and ENTERGY NUCLEAR)

OPERATIONS, INC. ) Docket No. 50-271-LR

. )

)

(Vermont Yankee Nuclear Power Station) ) ASLBP No. 06-849-03-LR DECLARATION OF NEIL WILMSHURST IN SUPPORT OF EPRI's OPPOSITION TO MOTION TO COMPEL

1. I, Neil Wilmshurst, am the Director of Nuclear Plant Technology at the Electric Power Research Institute, Inc ("EPRI").

2. I hold a B.Sc. in Naval Engineering from the Royal Naval Engineering College, a Post Graduate Diploma in Nuclear Reactor Technology from the Royal Naval College -

Greenwich, and a Masters Degree in Defense Administration from the Cranfield Institute of Technology. I have worked in the nuclear industry for in excess of 25 years in both the defense and public utility sectors. I have been employed by EPRI for 4 1/2 years, and for the last 1/2 years I have had supervisory responsibility for the CHECWORKS software research program and flow-accelerated corrosion ("FAC") studies.

3. EPRI is a nonprofit scientific research organization, which conducts public interest research and development on technologies needed for the safe, reliable and environmentally sound generation, transmission and utilization of electricity.

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4. EPRI is funded by member utilities, public power suppliers, rural cooperatives, Federal, state and local governmental agencies and international utilities.

5. Every nuclear utility in the United States supports EPRI's research programs in materials science, fuels research and maintenance and operations. There are 104 operating commercial nuclear reactor units in the United States, and each is a CHECWORKS licensee and CHECWORKS User Group ("CHUG") member.

6. EPRI licenses the results of its research, including software products, in two ways.

Companies or organizations that fund EPRI's nuclear sector research receive paid-up, internal use licenses. Licenses are also available to other organizations on a non-discriminatory basis. Licensees may participate in user groups related to the research, such as CHUG. CHUG membership is also available without the purchase of a CHECWORKS license.

-7. CHECWORKS is a software package used to predict wear rates and remaining service life in the pipe components of steam and feed water cooling systems. It was first released in 1993.

8. CHECWORKS utilizes a set of proprietary mathematical algorithms to assess individual components of pipe wear due to FAC, such as thermodynamic, chemical, and pipe material conditions.

9. CHECWORKS takes into account plant specific conditions as well as experiential data generated over the last 15 years at approximately 255 nuclear power plants worldwide.

10. EPRI derives approximately $1 million per year from CHECWORKS related activities.

EPRI offers CHECWORKS licenses to non-EPRI nuclear sector members for $300,000 per 2

seat. Membership in CHUG without licensing CHECWORKS requires payment of an annual fee between $11,000 and $30,000 based upon number of units.

11. Nuclear Power plants properly using CHECWORKS have never reported a failure in a steam and feed water system pipe or component of 2" in diameter or greater. There have been a few reported leaks in pipe components at smaller than 2" in diameter, however, failures in such pipes do not have the same consequences for personnel safety or plant operation.

CHECWORKS is not recommended for use in the prediction of FAC in pipes smaller than 2" in diameter.

12. CHECWORKS is provided to licensees as an executable software application consisting of assembled object code.

13. In 1997, a 5-diameter "sweep" (i.e. bent pipe) in an extraction steam line failed at the Fort Calhoun Nuclear Power Station. Post accident investigation by the U.S. Nuclear Regulatory Commission revealed that although the utility had used CHECWORKS, it made several errors the most significant of which was not including replaced components in the model causing the failure location to be missed.

14. Attached hereto as Exhibit 1 is a true and correct copy of EPRI's Master Agreement with Entergy.

15. There are three members of the CHECWORKS software and design team, EPRI employees David Ha and Ronald King, and outside contractor Jeff Horrowitz. No other person within or without EPRI has access to CHECWORKS source code or mathematical algorithms.

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16. Updates to CHEC WORKS using plant specific data do not change the algorithms or source code. All calculations work from the same equations regardless of power rate, flow conditions, chemical composition, or temperature.

17. The following is a partial list of vendors that offer engineering and/or technical services to aid in the mitigation of flow-accelerated corrosion: Structural Integrity Associates; Enercon Services Inc.; John Reas; Areva; Tetra Engineering; Harris Group; McDermott Technology, Inc.; Westinghouse; Altran Solutions; CSI Technologies; Atomic Energy Canada Ltd.; and Nuclear Safety Solutions. If the CHECWORKS source code and algorithms were released into the public, any one of these parties could incorporate CHECWORKS design ideas into their products and services.

18. The following is a list of software that competes with CHECWORKS in assessment of flow-accelerated corrosion: Comsys, Seimens (Germany); BRT Cicero, EdF (France); and RAMEK, (Russia).

19. Domestic utilities have reported approximately 116 uprates to commercial nuclear reactor units since 1977. The following is a list of uprates at nuclear power units comparable to that projected at Vermont Yankee (data available at http://www.nrc.gov/reactors/operating/licensing/power-uprates.html#past):

Nuclear Station Uprate Year Duane Arnold 15.3% 2001 Dresden 2 17% 2001 Dresden 3 17% 2001 Quad Cities 1 17.8% 2001 4

Quad Cities 2 17.8% 2001 Clinton 20% 2002

20. Each of these power stations uses CHECWORKS. There have been no reported failures in any major steam and feed water system piping component at any of these plants.

21. All of the above are Boiling Water Reactors (BWR), of the similar design to Vermont Yankee.

22. There are 104 total operating'commercial nuclear reactor units in the United States. Of these, 69 are Pressurized Water Reactors (PWR) and 35 are Boiling Water Reactors (BWR).

Vermont Yankee is a BWR.

23. The original embedded algorithms have had negligible changes from CHEC (released 1988),

CHECMATE, (released 2 years later) and the current version, CHECWORKS, (released 1993). Some information has been updated, such as the wear factor from the chemical Hydrazine, based on extended laboratory reports. None of these algorithms are modified by plant specific data.

24. CHECWORKS requires considerable training and expertise to operate, as well as substantial engineering judgment to interpret its predictions.

25. I have reviewed the abstracts of patent disclosures attributed to Dr. Joram Hopenfield. Two of these patents, Nos. 4,922,748 and 4,779,453, are in the field of assessment of FAC.

26. Comparison of actual data gathered at Vermont Yankee with CHECWORKS' predictions would be adequate to assess the accuracy and precision of the software's wear predictions.

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I declare under penalty of perjury that the foregoing is true and correct. Executed on April 18, 2008.

NEIL WILMSHURST ELECTRIC POWER RESEARCH INSTITUTE 1300 West WT Harris Blvd Charlotte, N.C. 28262-2867