IndianPointTranscript of Oct 15 2012

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202-234-4433
BEFORE: LAWRENCE G. McDADE MICHAEL F. KENNEDY RICHARD E. WARDWELL Chair Administrative Judge Administrative Judge DoubleTree by Hilton Hotel Tarrytown Westchester Ballroom 455 South Broadway Tarrytown, New York UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION + + + + + ATOMIC SAFETY AND LICENSING BOARD PANEL HEARING --------------------------------x Docket Nos. In the Matter of: : 50-247-LR and
ENTERGY NUCLEAR OPERATIONS, INC.: 50-286-LR (Indian Point Generating Units 2 and 3) : : ASLBP No.
--------------------------------x 07-858-03-LR-BD01 Monday, October 15, 2012
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and WILLIAM GLEW, ESQ. Assistant General Counsel Entergy Nuclear Operations, Inc. 440 Hamilton Avenue White Plains, New York (914) 272-3360 wglew@entergy.com of: APPEARANCES: On Behalf of Entergy Nuclear Operations, Inc.: KATHRYN M. SUTTON, ESQ. PAUL M. BESSETTE, ESQ. RAPHAEL KUYLER, ESQ. BRAD FAGG, ESQ. Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, N.W. Washington, D.C. 20004 (202) 739-5738 (Sutton) (202) 739-5796 (Bessette) (202) 739-5146 (Kuyler) (202) 739-5191 (Fagg) ksutton@morganlewis.com pbessette@morganlewis.com rkuyler@morganlewis.com bfagg@morganlewis.com
Neal R. Gross & Co., Inc. 202-234-4433
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On Behalf of the Nuclear Regulatory Commission: SHERWIN E. TURK, ESQ. BETH N. MIZUNO, ESQ. DAVID E. ROTH, ESQ. Office of the General Counsel Mail Stop - O-15 D21 U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 (301) 415-1533 (Turk) (301) 415-3122 (Mizuno) (301) 415-2749 (Roth) sherwin.turk@nrc.gov beth.mizuno@nrc.gov david.roth@nrc.gov On Behalf of the State of New York: JOHN J. SIPOS, ESQ. Assistant Attorneys General Office of the Attorney General of the State of New York The Capitol State Street Albany, New York 12224 (518) 402-2251 john.sipos@ag.ny.gov
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On Behalf of Riverkeeper, Inc.: PHILLIP MUSEGAAS, ESQ. DEBORAH BRANCATO, ESQ. Riverkeeper, Inc. 20 Secor Road Ossining, New York 10562 (800) 21-RIVER phillip@riverkeeper.org dbrancato@riverkeeper.org On Behalf of the State of New York: (cont.) JANICE A. DEAN, ESQ. KATHRYN LIBERATORE, ESQ. Assistant Attorneys General Office of the Attorney General of the State of New York 120 Broadway, 26th Floor New York, New York 10271 (212) 416-8459 (Dean) (212) 416-8482 (Liberatore) janice.dean@ag.ny.gov kathyrn.liberatore@ag.ny.gov

On Behalf of the State of Connecticut: ROBERT D. SNOOK, ESQ. Assistant Attorney General Office of the Attorney General State of Connecticut 55 Elm Street Post Office Box 120 Hartford, Connecticut 06141-0120 (860) 808-5020 robert.snook@po.state.ct.us On Behalf of Hudson River Sloop Clearwater, Inc.: MANNA JO GREENE, Environmental Director STEVEN C. FILLER KARLA RAIMUNDI Hudson River Sloop Clearwater, Inc. 724 Wolcott Avenue Beacon, New York 12508 (845) 265-8080 mannajo@clearwater.org

On Behalf of the Village of Buchanan: SEAN MURRAY, Mayor Municipal Building 236 Tate Avenue Buchanan, New York 10511-1298 (914) 737-1033 smurray@villageofbuchanan.com On Behalf of the City of New York: MICHAEL J. DELANEY, ESQ. Director of Energy Regulatory Affairs Office of Energy Policy NYC Office of the Mayor 253 Broadway, 10th Floor New York, New York 10007 (212) 676-0756 mdelaney@cityhall.nyc.gov

T A B L E Witness Dr. Jeffrey Horowitz Dr. Joram Hopenfeld Exhibits: NRC Staff 3 Clearwater 4 Riverkeeper 9 New York 17 Entergy 7 Board 1-2 O F C O N T E N T S Direct Cross Redirect Recross 1293 1317 Mark Recd 1270 1270 1270 1270 1270 1270 1270 1270 1270 1270 1315
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JUDGE McDADE: Good morning. P R O C E E D I N G S 10:56 a.m. We are here It is It
in the matter of Entergy Nuclear Operations. our docket number 50-247 LR and 50-286 LR.
involves an application by Entergy for the license renewal of Indian Point Units 2 and 3. Let me just very briefly get started. are close to the end of a relatively long process, that this started with an application that was filed by Entergy, that included both safety aspects and also an environmental report. After that was submitted, the Nuclear Regulatory Commission issued a Notice of an Opportunity for Hearing. In response to that notice, We
various entities petitioned to intervene and to participate in this proceeding. Of those, several
were not found to have standing or to present contentions that were viable, and others were. We have the State of New York, Riverkeeper and Clearwater as entities that have standing and were admitted as participants. In addition to those
parties, we also have as parties Entergy, the applicant, and the Nuclear Regulatory Commission staff.
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In addition, there are interested government entities that have asked to participate. We have the state of Connecticut, we have the City of New York, we have the Village of Buchanan, we have the Town of Cortlandt, and we have Westchester County. I'll give a very brief background. After
the petitions to intervene were granted, there was a period where there were mandatory disclosures, where the parties had to turn over documents to each other and information to each other. During that same period of time, the Nuclear Regulatory Commission staff continued to review the application, the license application, and also the environmental report, and based on their review prepared documents referred to as a safety evaluation report and an environmental impact statement. During the course of this hearing, you are going to hear about two different kinds of contentions: environmental contentions and safety or Really, there's nothing that
technical contentions.
involves safety that doesn't also involve the environment and vice-versa. But there are some basic
differences for our proceedings. With the safety contentions, Entergy has
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the burden of demonstrating that they will be able to operate the facility in a safe manner through the period of extended operations. With regard to the
environmental contentions, the NRC staff has an obligation to prepare an Environmental Impact Statement, and the challenges on the environmental side are to the adequacy of the NRC's Environmental Impact Statement, which of course is based in part on the environmental report that was submitted by Entergy. Now our purpose here is part of an evidentiary hearing. Most of what is going to go on
over the next several days is these three judges, myself, Judge McDade, Judge Wardwell and Judge Kennedy, who have been designated to be the Atomic Safety Licensing Board in this particular case, will be asking questions of the witnesses that have been presented by the parties. We have already received from those parties several thousand pages of direct testimony, and I believe about 1,400 exhibits, that the parties, the interveners, New York, Riverkeeper, Clearwater, presented their direct testimony of their witnesses. Then Entergy and the NRC staff had an opportunity to respond, and then the interveners had
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an opportunity to submit rebuttal testimony. not starting at square one. much in the middle. So we're
We're starting pretty
For individuals who have not been
involved with this hearing before, it may seem difficult to follow. It would be sort of like coming
into "Lost" at Season 3. But please try to bear with us. To the
degree that you can, if you are interested, all of the testimony and all of the exhibits are available through the NRC website. We will also ask the
parties, in many instances, and by the parties here I mean the witnesses, to explain acronyms, at least the first time through. You're going to be hearing about AMPs and SAMAs, and we will ask them to describe what an AMP is, an Aging Management Plan. A SAMA is -- you know,
well, I'll let them explain what a SAMA is, because that's part of what we're trying to figure out during the course of this hearing. This isn't the typical courtroom. typical courtroom is really only set up for two parties, to have a plaintiff and a defendant. we have ten parties. Here, A
Also we anticipated having
public interest, and most courtrooms do not have enough room for a significant number of members of the
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public. Also, there was press interest and interest from various elected and governmental officials. So that's why we're located here instead But the
of a more traditional courtroom facility.
same decorum that happens in any, what you would see in any federal court is going to apply here. Most of what goes on is the judges ask questions of the witnesses. We will direct our
questions to the witnesses; they will direct their answers to us. They're not going to be arguing back
and forth between each other. Likewise, if counsel have an issue, they will raise it and address it to the Judge. not going to be addressing it to each other. They're So it's
basically going to be a flow of information coming from the bench, to the witnesses, to the counsel, and back to the bench. Likewise, this is not a public meeting. This is an adjudicative, evidentiary hearing. So
other than the parties, nobody else is going to have a speaking role, that individuals had an opportunity to submit their limited appearance statements with regard to the policy involved. But for this particular hearing, we have
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a lot of material to get through over the next couple of weeks, and it really is going to be necessary for us to stay on task and to move forward. We have
allowed the accredited press to have cameras, but just to avoid any disruption, we are going to have to insist that only the accredited press use photography and ask that -- and insist that everybody turn their cell phones off, so that they're not ringing during the course of this particular proceeding. We have studied the sworn testimony. We
have read the exhibits, and as I said, we're going to be somewhat starting in the middle. We are going to
try to identify issues and make sure that we understand what those issues are, and make sure that we understand the testimony that has been submitted by the parties. Before we get into that, I want to go through some just sort of nuts and bolts preliminary matters. After that, we are going to have brief
presentations from an expert from Entergy and an expert from Riverkeeper, on the first contention, which is a technical contention. You will hear it referred to as "Riverkeeper TC-2," which is just it was presented by Riverkeeper. It is a technical as opposed to an
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environmental contention, and it was the second one that they submitted. Some of the contentions that we're going to hear, there are going to be a lot of questions with regard to. Others, there aren't going to be that
many, and it doesn't mean that one contention is more important than another; it just means that on some of the contentions, we have more questions to ask, to ensure that we understand fully what the issues are and fully understand what the positions are and the basis for those positions of the expert witnesses who are going to testify. By way of preliminary matters, let me just mention very quickly. We have had seven motions in
limine that we have not yet ruled on, and let me say up front with regard to those seven, the first seven, we are denying the motions in limine. There was a motion by Entergy and a motion by the NRC staff asking to strike certain filings of Clearwater on their Clearwater Environmental Contention 3, which was an environmental justice contention. There was also a motion by Entergy and the NRC staff seeking to strike certain information submitted by New York in their rebuttal contention on
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New York 12, which is a SAMA contention having to do with clean-up costs. There were two motions -- there
was a motion by the NRC staff with regard to the rebuttal submitted by New York on New York 5, having to do with buried pipes and aging management plans. Entergy filed a motion seeking to strike certain rebuttal testimony of New York on New York 16, which has to do with population projections, and Entergy also has one regarding New York 26, and that's a Joint Contention Riverkeeper TC-1, having to do with metal fatigue. Those motions in limine are denied. is another motion in limine that was filed by Riverkeeper, having to do with Contention TC-2, flowaccelerated corrosion. There were issues having to do There
with the adequacy of discovery. In an initial order, we indicated that we were going to wait until we had a fully robust record to make that decision, and accordingly, we are going to continue to hold in abeyance Riverkeeper TC-2. We
are not going to rule on it until after we have heard the testimony on that contention. There was a motion that we have not yet ruled on filed by Entergy to submit additional questions regarding New York Contention 37, having to
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do with the no action alternative, and that motion is granted. Riverkeeper filed a motion to file
additional exhibits with regard to Riverkeeper TC-2, the flow-accelerated corrosion contention. granted that motion. effect earlier today. But it is although granted, it is somewhat limited, and we have expressed what we intend with regard to those exhibits. Next, some basic things I wanted to run through with the parties. With regard to New York That We have
We have issued an order to that
Contention 5, there was a motion in limine. motion in limine was settled, and we received documentation to that effect.
We received a redlined version of the testimony, which indicated what was to be stricken, based on the agreement of the parties. In the
redlined version, on Exhibit 399, page 18, lines 16 to 18, it starts with "In my opinion." On the redline that we received, the following was indicated that it was going to be excluded. But on the document we received, the Was it the intention of
revised document, it wasn't.
the parties that that be deleted? MS. DEAN: Your Honor, Janice Dean for the
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version. State. Could you read the sentence, if you don't
mind, that follows "In my opinion." JUDGE McDADE: it's on page 18. Okay. This is, as I said,
It starts "No, I don't understand
Mr. Hollison's opinion, except that it appears to believe leaks are acceptable." Then it starts a new
sentence "It is my opinion that the leak of a radioactive fluid presents a danger to the population in the vicinity of the radioactive leak." As I said, that was on the redlined But on the version that we received as the
final exhibit, it was still there. MS. DEAN: stricken, Your Honor. That clause should have been That's my error. I'll correct
that and make an additional filing this evening. JUDGE McDADE: Okay. I don't think it's Just,
necessary to make an additional finding (sic).
you know, from the standpoint of the Board, that is stricken and it's clear on the record that that is not going to be considered. What we are going to do is basically admit exhibits that have been submitted. Each of the
parties have submitted exhibits lists, and we are going to be admitting at this time all of the exhibits listed on those exhibit lists, which a few minor
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those. exceptions. Now the exhibit lists have come in over time, and given the amount of time that this case has gone on, there have been certain modifications. So
I just want to make sure we're all playing off the same sheet of music, that from our standpoint, Entergy, their most recent exhibit list is their Revision 7. It was filed on October 12th? MS. SUTTON: JUDGE McDADE: was Revision 3? MR. TURK: One moment, Your Honor. Okay. Just while you're New York, we have That's correct, Your Honor. And from the NRC staff, it
JUDGE McDADE:
looking, let me go to the others. New York 17? MS. DEAN:
That's correct, Your Honor. Riverkeeper 9. Yes, that's correct. And Clearwater 4? Yes, Your Honor. Okay. We are admitting
JUDGE McDADE: MS. BRANCATO: JUDGE McDADE: MS. GREENE: JUDGE McDADE:
Am I correct, Mr. Shepp (sic), that it's NRC
is Revision 3? MR. TURK: NRC 3 dated October 9th. Okay, thank you.
JUDGE McDADE:
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once. (Whereupon, the documents referred to as NRC Staff 3, Clearwater 4, Riverkeeper 9, New York 17 and Entergy 7 were marked for identification and received in evidence.) JUDGE McDADE: Okay. There are a few We issued an
exceptions to what is listed on there.
order back on March 6th that Riverkeeper Exhibit 60 was modified and Riverkeeper Exhibits 79 and 89 were struck. Also, Clearwater Exhibit 13, which as identified is a letter dated February 4th, 1981. The
exhibit list is being augmented to add and additional correspondence, because in the exhibit, there's more than just that original letter. Clearwater Exhibits 43 and 44 are accurately described on the exhibit list, but the exhibits themselves are not stamped. The Board will
have those stamped as Clearwater 43 and 44 and admit them. Clearwater lists New York Exhibit 133-E on its
exhibit list. We're only going to be admitting exhibits So it was originally a New York exhibit. It
will be admitted through New York, not through
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Clearwater. On Entergy Exhibit 267, it is identified on the exhibit list as a Census Bureau Summary File 4. The exhibit itself actually is Summary File 3, and we will modify the exhibit list accordingly and admit File 3, which is the exhibit that was presented. Staff Exhibits 2 through 14 are basically from the exhibit list, placeholders for New York and Entergy exhibits that their experts make reference to. We're not admitting them as NRC exhibits; we're admitting them as Entergy and New York State exhibits, and they will stay as placeholders on the NRC exhibit list. Also, and hopefully this is the last one. Well, it's not quite the last one, NRC on the exhibit list, you have the exhibit listed 114-A. itself is stamped 114. as Exhibit 114-A. There are certain documents that were filed both public and non-public. We are going to The exhibit
We'll restamp it and accept it
accept both of those into evidence, and we will take care of stamping those as public or non-public. are also Riverkeeper 53. list as Riverkeeper 53. There
It is listed on the exhibit There are actually several
parts to it, Part A through O, and we will admit
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Riverkeeper 53 A through O. New York 13 and New York 14 originally were on the exhibit list as excerpts. They included, So it's New
when you open the files, different files.
York 13 A through K and New York 14 A through J, and we are admitting all of those. I think those are all of the corrections that we needed to make with regard to the exhibits. There is also a motion pending before us having to do with a proposed settlement, having to do with Riverkeeper Environmental Contention 3, and it's a joint contention with Clearwater, Clearwater Environmental Contention 1, having to do with spent fuel pools. One of the questions that we had, the first question, and I'll go to each of those three parties, is from the settlement agreement itself, the enforcement mechanism for the agreement. envision? What do you
Do you envision that becoming part of the
current operating basis, becoming a license condition? How does Entergy envision that the agreement would be enforceable? MR. BESSETTE: Your Honor, we don't Similar to the
envision this as a license condition.
settlement of the concrete containment issue with New
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York, we would believe it would be enforced like any settlement agreement between the parties, as a legal agreement between the parties. We will, if this is settled, include certain additional commitments in our radiological and environmental program, which will be implemented, in accordance with an Entergy procedure. JUDGE McDADE: Okay, and the court We kind So
reporter is sort of facing in one direction.
of know everybody, this has all gone on so long.
if you would, at least when you first speak, mention your name, Mr. Bessette, so that the court reporter will not attribute your remarks to anybody else, and hopefully you'll be proud of the remarks you make and will want that, you know. But in any event, in the event that you don't, at least nobody else will be blamed for them. That goes -- I realize, you know, it's sort of a difficult thing, and particularly to the witnesses as well. We're not asking you to repeat your name every time you talk, but if a question is directed to you, it would be helpful if you would say "Dr. Alan Hiser, so that the court reporter would have an opportunity to identify you as the speaker, and that
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Your Honor. well? MS. BRANCATO: Yes, Your Honor. It's our the appropriate person would be either credited or blamed for the testimony. Okay. Riverkeeper, is that your view as
understanding that Entergy's commitments to monitor an additional sampling location would become part of Entergy's REMP, which sounds like that's consistent with Mr. Bessette's representations. JUDGE McDADE: So yes.
Well, if it -- if it was
part of the REMP, wouldn't that become part of the current licensing basis? MR. BESSETTE: It's a plant procedure,
I'm not sure it's part of the current
licensing basis, no. JUDGE McDADE: From the NRC staff's
standpoint, if this is made part of it, how would the NRC staff monitor this and enforce it? MR. TURK: Your Honor, Sherwin Turk. It
is not our intention to enforce the agreements between Entergy and the other parties in the proceeding. Just
as in the case of the containment contention, which was settled and then dismissed by Your Honors, the staff do not intend to enforce that agreement, and we will not.
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This is a matter between the parties who have reached the settlement agreement. If the
additional provisions become part of the radiological and environmental monitoring program, I do not know, as I sit here, whether or not we enforce that provision. I can check and get back to you on that. But our intention is not to take on enforcement responsibility unless it is part of an enforceable document, and I would simply have to check to see if that document is one that we enforce. JUDGE McDADE: appreciate that, Mr. Turk. Okay. If you would, I
Clearwater, what is your And let
view on this, of how this would be enforced? me just sort of go back here a second. our opinion, this Board ceases to exist.
Once we write We have been
assigned to serve as the Atomic Safety Licensing Board for this contested litigation. We, the Judges, hopefully will continue to exist, but we will not have continuing jurisdiction over this particular matter. We have every reason to
believe, and certainly all the parties have every reason to believe, that if the commitment is made, the commitment will be followed. But you know, what we're trying to do is just make sure that we understand what the
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understanding of the parties is down the road, in the event that one of the parties believe that the commitment was not fully being honored. Clearwater, what is your view on what you would do in the event that that occurred? MS. GREENE: JUDGE McDADE: MS. GREENE: It was our understanding -Ms. Greene. Yes. Manna Jo Greene, We had long
Environmental Director for Clearwater.
negotiations, and at the very end, this was actually one of the issues that Clearwater Board of Directors asked for clarification. We felt that with the
impending hearing, we were kind of running out of time. But it was our understanding that this would be enforced by NRC as part of the REMP. JUDGE McDADE: Okay. One other thing. As
is required under the regulations, the motion itself indicated the review by all of the parties, and what their view was of this particular proposed settlement. The Town of Cortlandt, however, has expressed a significant interest in EC-3 and Clearwater EC-1. Have the parties consulted with the
Town of Cortlandt, and have they offered a view on this?
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MR. BESSETTE: No, Your Honor. We have But also I
not consulted with the Town of Cortlandt.
do want to add, with regard to your original question, again, this is Paul Bessette from Entergy. Entergy
will internally control all of these agreements with commitments in its procedures. Any additional sampling will be reported in periodic reports to the NRC. So it will certainly
be documented, and Entergy's other commitment with regard to disclosure of groundwater reports will be made publicly. So we believe it will all be clear to
the parties, and that Entergy intends to and will meet its commitments in the settlement agreement. JUDGE McDADE: And part of our role here
is just to make sure it's very clear on the record that the understanding of Entergy and the understanding of Riverkeeper and the understanding of Clearwater on this is consistent. Riverkeeper or Clearwater, have you consulted with the Town of Cortlandt, and have they expressed an opinion as to the -- whether this settlement is in the public interest? MS. BRANCATO: from Riverkeeper. Riverkeeper?
This is Deborah Brancato
With specific respect to the
settlement, we have not consulted with the Town of
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Cortlandt. JUDGE McDADE: MS. GREENE: JUDGE McDADE: Clearwater? No, we have not, Your Honor. Okay. We are not going to What we
rule on this proposed settlement right here.
would ask is if the three parties could at least nominate one of you to contact the representatives of Cortlandt, and to get them either to come here first thing tomorrow morning to express their views, or to articulate it through a representative, either Riverkeeper, Clearwater or Entergy. And also, Mr. Turk, if you could advise us in the morning with regard to the NRC's position with regard to, you know, specifically how and this would be treated by the NRC, that the REMP would be handled by you. MR. TURK: We'll do that. JUDGE McDADE: Okay. What we are Yes, thank you, Your Honor.
proposing to do at this particular point in time, and by proposing to do, we had specifically requested from the parties that there be a presentation. The first
contention we are going to hear and ask questions about is a technical contention having to do with a phenomenon called flow-accelerated corrosion.
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One of the ways in which flow-accelerated corrosion is handled, according to the Aging Management Program by Entergy, is through a program called CHECWORKS, and we have asked first Entergy to have their expert, Dr. Horowitz, explain an overview of the CHECWORKS program. This has nothing to do with Indian Point itself or how it operates at Indian Point. What we
want to do is to understand and make sure that we properly understand what the program is, how it's supposed to work and then we will get into specific questions about how it works or doesn't work at Indian Point. After Dr. Horowitz for Entergy has had an opportunity to express his overview of the CHECWORKS program, we're then going to ask an expert from Riverkeeper, Dr. Hopenfeld, to do the same. Again,
this initial presentation is not going to be getting into specifics about how the program operates at Indian Point. It's only going to be an overview of the design of the program and how theoretically the program works or doesn't work. To Drs. Horowitz and
Hopenfeld, we are going to ask a lot of questions of you about the program and its application at Indian
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Point, and I'm sure you're probably going to be very tired of answering our questions by the time we're done. But at least through the original presentation, if you could just again focus on the overview of the program. question? MR. TURK: Thank you, Your Honor. I don't Mr. Turk, you had a
want to interrupt, but we do have three housekeeping matters that I'd like to raise at the appropriate time. If you were willing, I'd raise them now, just
so we can get them out of the way. JUDGE McDADE: Well, let me just a couple
more housekeeping matters here, and then we'll go to your housekeeping matters. What I would propose to do
is after the presentations by Dr. Hopenfeld and Dr. Horowitz, which should be about 15 minutes each, is to take a very brief break at that point in time, no more than ten minutes. We will come back. We will then take
another break in the mid-afternoon, and continue through until approximately six o'clock. any particular magic with that time. There's not
If we reach an
appropriate breaking point a little before six or if we go a little after six, that may be the case.
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Honor. For the rest of the proceeding, we are going to be starting at nine o'clock. We are going to If
go through until again approximately six o'clock.
we, you know, have a few more minutes to go in order to finish up a contention and allow a group of witnesses to go on their way, we will run a little bit later. Likewise, if we finish up a particular contention just a few minutes before six, we're not going to impanel a new group of witnesses only to have them then go on their way a few minutes later. We
envision we will take a break in the morning and a break in the afternoon, and that we will also take a lunch break of approximately an hour. So you please make accordingly your plans. I'm not familiar with the areas around here, as far as how long it's going to take you to go and get out and get something to eat, and whether you bring something with you or go out. But in order to make sure we get
through as much as we can, we're going to try to keep the luncheon breaks to about an hour. MR. TURK: Mr. Turk?
Thank you very much, Your The first
We have three housekeeping matters.
one relates to the testimony on flow-accelerated corrosion. Your Honor has issued an order, I believe
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either late yesterday or this morning, allowing the admission of four additional exhibits from Riverkeeper. The staff has not yet had an opportunity to read those exhibits. us to question on them. I know the Board is allowing But until we read them, we
won't be able to develop questions. So I would like to ask that during one of the breaks today at least, we be afforded enough time to read them, to determine if we have questions and to formulate questions. Or alternatively -Well, you don't need to go I am relatively confident,
JUDGE McDADE: through the alternative.
given the number of questions that we have about flowaccelerated corrosion, that we are not going to be turning to you before the end of today, to have the opportunity to do any questioning with regard to it. So you will have all night to look at the exhibits. MR. TURK: That's terrific. I would still
ask my alternative, though. of the admission.
I'm not sure the purpose
The four exhibits, I believe, were
intended to be admitted to help the Board in understanding Dr. Hopenfeld's presentation, not for all purposes. So I'm not sure the intent, but I would
Page 1283 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
ask that given the Board's decision to admit them, that they be admitted only for the purpose of elucidating his presentation to the Board. JUDGE McDADE: Well actually, it's 180
degrees opposite, that based on the representations of Riverkeeper, those are documents that Dr. Hopenfeld may well refer to in offering his opinion. But at least in the opinion of the Board and based on the order that we issued today, they are four more directed to flow-accelerated corrosion and flow-accelerated corrosion at Indian Point, than they are to the CHECWORKS program. So we do not envision that Dr. Hopenfeld will be referring to those documents during his initial presentation. But if he believes that it is
helpful to him, as we understood the representations of Riverkeeper that they would be in answering our questions broader, not just on the design, the theoretical design of CHECWORKS, but broader on flowaccelerated corrosion and how flow-accelerated corrosion is monitored and the use of the CHECWORKS program at Indian Point to monitor and control flowaccelerated corrosion, that we will allow Dr. Hopenfeld to use and refer to those exhibits for that purpose.
Page 1284 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
But not for the original presentation, which again, as I indicated and we specified specifically in our order, is directed towards a theoretical overview of the CHECWORKS program alone, how it is designed, what it's designed to do and theoretically how it would operate in any facility, not just in the Indian Point facility. further, Mr. Turk? MR. TURK: Yes. Our second item, Your Anything
Honor, relates to another fast-breaking news development. Approximately one week to ten days ago, One of those
Entergy filed some new exhibits.
exhibits refers to underground piping at Indian Point. I don't know if the Board recalls as you sit here, but our testimony indicates that there is no underground piping within the scope of license renewal. So the staff is considering that new
exhibit, and may need to revise our testimony to address it. So we have not yet developed the additional words or the change in words in our testimony, but we'll be doing that as the week progresses, and we will then propose some revisions to our testimony. JUDGE McDADE: Okay, and I believe that's
Page 1285 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
you. MS. MIZUNO: And one other thing related That exhibit is the New York 5? MR. TURK: Yes. And as far as New York 5
JUDGE McDADE:
goes, it is either going to be late in this week or early next week before we get to New York 5. So you
should have plenty of time to further review that and to make any changes you believe are necessary. MR. TURK: Thank you, Your Honor. And
then the third item, I will turn to Ms. Beth Mizuno. She has one additional late development that she needs to address. MS. MIZUNO: The late development in this
instance is New York's submittal of its exhibit New York State 444. That came in on Tuesday, and the NRC
staff has proposed questions for the Board to consider asking, based on that exhibit. It came in on Tuesday,
so we have some proposed questions for you. I have four copies, one for each of the Judges and one for your clerk, that I can provide at the break, if that's acceptable to you. JUDGE McDADE: That would be fine. Thank
to New York State Exhibit 444.
New York State DEC Statement of Environmental Quality
Page 1286 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Review for the Cricket Valley Natural Gas Plant, and it's certified, it provides a certification based in large part on the Cricket Valley FEIS and DEIS, i.e., the final environmental impact statement for Cricket Valley and the draft environmental impact statement for Cricket Valley. We believe that for a full, for development of a full, sound, robust fair and complete record, it would be useful for the judges to have the FEIS and the EIS, the DEIS -- sorry, the final and draft EISs for Cricket Valley. However, they are quite voluminous, and the staff has pulled excerpts that we think are particularly useful in this regard, and would like to submit those as additional exhibits at this time. have ten copies of those. JUDGE McDADE: MS. MIZUNO: versions as well. JUDGE McDADE: they been marked as? MS. MIZUNO: Those would be NRC 165, which Okay, and what numbers have Okay. And oh yes, electronic I
is the FEIS, the final, and NRC 166, which consists of excerpts from the draft Environmental Impact Statement for Cricket Valley.
Page 1287 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
That's all. JUDGE WARDWELL: this Judge Wardwell. Will we be getting -JUDGE McDADE: Okay. We will receive
those, and if you can, at the break; we're not going to admit them at this time, since the other parties haven't had an opportunity to review them. Before we
rule and admit them, we will give the other parties an opportunity to review them, and if they have any objection, to so state it. MS. MIZUNO: Thank you, Your Honor.
Will we be getting electronic
versions in camera of the proposed questions also? MS. MIZUNO: Yes. This afternoon. I
think we can manage it later on this afternoon, Your Honor. JUDGE McDADE: MR. SIPOS: MR. TURK: Thank you.
Your Honor -For clarification, the proposed
exhibits that Ms. Mizuno is referring to are actually a part of the same document that New York has just had admitted. Am I right? Or they're supporting
documents for those documents that New York had admitted on their own motion. JUDGE WARDWELL: Another reason -- this is
Judge Wardwell again, to identify ourselves is that we
Page 1288 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
a try then? have many parties. Someone starts speaking, and we
really don't even know who's speaking ourselves, because if it's where we get back and forth like we do, it sometimes gets very confusing. know where you're at. You don't even
So remind me to make sure I
introduce myself when I speak. JUDGE McDADE: And actually one of the
really neat things about the set up here as you may notice, when you start to speak, the microphone, the little red light goes on on the microphone. So if you
can't figure out who's talking, look for the red light. JUDGE WARDWELL: (Laughter.) MR. SIPOS: Your Honor, could I give that It may be you.
This is John Sipos, Assistant Attorney Do I understand
General for the State of New York.
that NRC will also be submitting electronic copies of these proposed exhibits to all the parties today? MS. MIZUNO: something that we can do. technologically savvy. This is Beth Mizuno. I'm just not very It's That's
I will do my best.
certainly within our ability. within mine. JUDGE McDADE:
I'm just not sure it's
Okay.
Page 1289 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE WARDWELL: that under EIE? Well, are we able to do
This is Judge Wardwell again. That's a difficult question.
MR. TURK:
Because we are remote from headquarters, I'm not sure what our EIE filing capabilities are. We can try.
If nothing else, we do have a PDF version of the proposed exhibits. We can email them, so that
all parties can obtain and the Board members can obtain a copy by email. I don't know if we can EIE
file remotely, but we can try. JUDGE McDADE: MR. TURK: Well, let me ask -I'm
I'm told by -- I'm sorry.
told by Mr. Roth, who's much more technologically advanced than I am and much younger as well, that we can. So we'll try. JUDGE McDADE: Okay. Before we admit the
exhibits, they're going to be received through the EIE, the electronic system that we have, and all of the other parties, you're going to have an opportunity to review them. Again, you know, we're not going to be getting to that contention for the next couple of days, and you know, we will see, you know, the relevance, I assume from New York 444. That's the part of the exhibit that the
Page 1290 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
documents that New York considered to be relevant, that if there are areas that the staff witnesses believe need to be drawn to our attention, in order to put that in context, that's what these are going to be received for. But we do want to make sure that New York has a full opportunity to see the whole document. assume that they do; otherwise, they wouldn't have been able to excerpt it. But we just need to make I
sure that you and they are singing off the same sheet of music, and the document that they think you're using is the document that you're using. That's why it will come in through the electronic, the EIE, before we admit. MR. SIPOS: Mr. Sipos.
Judge McDade, John Sipos. I believe New York
Just a point of clarification.
State Exhibit 444 is the entire SEQR finding statement for the Cricket Valley facility. I believe what Ms.
Mizuno is talking about is other documents that were prepared or presented as part of that proceeding. So New York 444, it's my understanding, is the entire finding statement. There are other
documents from that proceeding, and that's what I think she's referring to. So ours was not an exhibit.
Ours was not intended to be an except.
Page 1291 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Honor. MS. MIZUNO: JUDGE McDADE: Similarly, Your Honor -Okay, and as I sit here
right now, excuse me, as I sit here right now, as I said, we've got 1,400 exhibits and somebody mentions Exhibit 444. The full extent of it does not We'll have to go take a
immediately spring to mind.
look at it, and you will then have an opportunity to see the proposed staff Exhibits 165 and 166, to see. Again, we haven't seen them yet. haven't seen them yet. They may be extremely But we'll take that up You
relevant; they may not be. later in the week. MR. SIPOS: MR. TURK:
Thank you, Your Honor. And just one last point, Your
The document that New York had admitted is a
state environmental review document prepared by the New York State Department of Environmental Conservation. What Ms. Mizuno is proposing to offer is the EIS prepared by the same state agency for that same facility. It's the FEIS and the DEIS for that
same facility, prepared by the New York agency. JUDGE McDADE: No, I understand. Judge
Wardwell, anything before we begin the presentations by Dr. Horowitz?
Page 1292 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE WARDWELL: JUDGE McDADE: JUDGE WARDWELL: MS. SUTTON: No, I'm okay. Anything? No, I'm ready.
Your Honor if I may, Kathryn
Sutton on behalf of the applicant. By way of reminder, during a recent prehearing conference, we noted that Dr. Horowitz has some health issues, and may require some assistance from his companion on the Board over there, Rob Aleksick. So we're asking the Court's indulgence to
please allow Mr. Aleksick to help Dr. Horowitz, to the extent necessary during his presentation. JUDGE McDADE: Of course, and we also
indicated Dr. Horowitz, if during the course of the questioning, as you're going to be a witness and we're going to have a lot of questions on specifically with regard to the use of CHECWORKS at Indian Point, if you need a break or you need to take a few minutes, please don't be shy about letting us know. MS. SUTTON: JUDGE McDADE: Thank you. Okay. Now Dr. Horowitz,
we're advised that you had prepared a PowerPoint presentation to assist you in giving your overview of CHECWORKS; is that correct? DR. HOROWITZ: Jeff Horowitz for
Page 1293 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
applicant. That's correct, Your Honor. JUDGE McDADE: Okay. What we are going to
do before we begin the presentation, because the presentations themselves will be evidence, we are going to swear the entire panel of witnesses at once. If you would, you don't need to stand, but please just raise your right hand. [WITNESSES SWORN.] JUDGE McDADE: Okay, thank you. Dr.
Horowitz, our IP person will pull it up.
If you just,
when you want to move to the next slide, just simply say "next," and Mr. Wilkie will move to the next slide for you. DIRECT EXAMINATION DR. HOROWITZ: Thank you, Your Honor.
This afternoon I'll present a brief overview of CHECWORKS, talk a little about its history, its development, inputs and outputs and how it's used. Next slide. We begin back in 1986 with the accident at Surry Unit 2, which was a failure of a condensate line. It demonstrated the need to affect singleThere were very limited U.S. programs In
phased piping.
in place that were doing the single-phase FAC. 1987, EPRI and NUMARC --
Page 1294 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
MR. ALEKSICK: This is Robert Aleksick for
the applicant, and with Your Honor's position, I'll pick up the presentation where Dr. Horowitz left off. Following the accident at Surry, EPRI, the R&D organization, and NUMARC, the Nuclear Utilities Management and Resources Council, committed to developing a computer program to assist identification of inspection locations. In addition, NUMARC at that time, or in that general time, issued programmatic guidance, including guidance on how to use CHEC or equivalent methods. Since that time, in 1986 and 1987, CHEC has
gone through a number of evolutions into following a code called CHECMATE and ultimate today to a code called CHECWORKS. genesis. But they all stem from the same
Next slide, please. JUDGE McDADE: And Dr. Horowitz, in the
CHECWORKS, you're the "H" in there, right? DR. HOROWITZ: JUDGE McDADE: That's correct. Okay. I just mentioned
that, that he was one of the original authors of it, and the initials were based on the original authors. He was the "H" in CHECWORKS. MR. ALEKSICK: Please continue.
In terms of the development
of the CHEC code, it was released seven months after
Page 1295 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the Surry accident, based on data largely but not entirely from Europe, laboratory data from England and France, plant and lab data from Germany, and that included all the known laboratory data at the time. There was some limited use of data from U.S. plants as well, and the empirical data was used in conjunction with existing scientific knowledge at the time, to put together the algorithms internal to the code, to predict rates of FAC. And by FAC, that's Next
an acronym from flow-accelerated corrosion. slide, please. CHEC and all the way up to today
CHECWORKS, is based on extending work done by Keller and Kastner and Berge, European researchers, and the algorithm internal to CHECWORKS today considers seven distinct factors including temperature and the other factors listed on the slide show here. I would point out that the factors, the seven factors are interrelated and some of them are functions of one another. So the actual algorithm
internal to CHECWORKS is not quite as simple as it would appear. You just simply multiply those seven But there are just the seven basic
factors together. inputs.
Next slide.
CHEC represented a
Page 1296 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
significant improvement over previous approaches, partially due to the use of a larger data set. Also,
largely due to the ability of the CHEC family of codes to consider local conditions. Although FAC is really
a line level phenomenon, the local situation, the local geometry, for example, does play a role in the FAC rate at that point, and CHEC and CHECWORKS account for that. In addition, the geometry factors within CHECWORKS were developed using some insight from copper modeling tests, and that correlation internal to the code has been continually validated and refined and improved over the years since it was originally developed, using both plant and lab data. Next slide. The data input to CHECWORKS One is
is segregated into five primary categories.
the heat balance diagram, which is essentially a definition of the major plant equipment, the turbines, the heaters and so forth, and how those are connected. That's used to calculate -- that, in conjunction with the global plant conditions, is used to calculate the distribution of oxygen and pH around the steam cycle. The plant component information, which comprises the bulk of the data, these are things like materials, component geometries, wall thicknesses,
Page 1297 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
operating design conditions, etcetera, are input to a section of the program under plant components. And finally, if applicable, as it usually is, component replacement information and inspection data from the field is considered, and there's a place to input that into the software as well. Next slide. In terms of the actual
analysis, the plant for the purposes of analysis is divided into a number of lines that have similar chemistry and operating conditions. So for example,
the pipe in between two sets of feed water heaters would comprise one of what we call an analysis line. Typically, there are 20 to 50 analysis lines per unit. unit. At Indian Point, we have about 40 per
So it's in line with the rest, with the Using the
standard -- with what we would expect.
information that's input, including the global information, where is calculated for each operating period? When I say "operating period," I mean the 18 to 24 month period of operation between plant outages. What that means is that CHECWORKS calculates
the wear at each operating period and cumulates it, so that at the time you were analyzing it, say today, the predicted total wear represents that cumulation of
Page 1298 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
wear at each operating cycle, and at whatever operating and chemistry conditions prevail at that time. So for example, if we had a power uprate and the wear rate were different before and different after, CHECWORKS cumulates those to give an integrated a total value of wear, based on the individual conditions in the past. I might also like to point out that not every line in the plant is suitable for CHECWORKS modeling. There are a variety of reasons that that
might not be the case, and those sorts of lines are addressed separately. Next slide. CHECWORKS was designed to
handle changes in operating and chemistry conditions, in particular -- well, I should say in particular operating conditions and chemistry conditions, and those sets of operating conditions are associated to those operating periods, a period of time in the past. The basic design consideration in developing CHEC and CHECWORKS was to enable the analyst to model changes in conditions, and to forecast the effect of such changes. In addition, the
primary design consideration was to be able to handle both inspected and non-inspected components.
Page 1299 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
This is important, because once we inspect a component, the CHECWORKS prediction becomes much less important. Once we've inspected it, we know how
thick it is, we know what its thickness profile is and what its wear rate will be. But for those uninspected
components, it's extremely important to have the CHECWORKS predictions. And then CHECWORKS is one of the tools that the plants use to help select inspection locations, to increase that population of inspected components. Next slide, please. There are two basic
analyses that can be performed in CHECWORKS, Pass 1 and Pass 2. They're very similar. Pass 1 is the
analysis that one might conduct at the very beginning of plant life, when no inspection data was available. The Pass 1 output from CHECWORKS consists of predicted wear rates and so on that are calculated based on operating and chemistry conditions, without regard to field data or measurements of pipe wall thicknesses. Pass 2 analysis is the same thing, with
the addition of inspection data from fact components, that is imported to the model to calibrate its predictions. I'd like to note that those Pass 2 results
Page 1300 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
are a good way to assess the validity of the model's predictions, and that the software uses a best estimate approach in comparing the field observations, the measured pipe wall thicknesses, to the predicted pipe wall thicknesses. It draws a correlation line
through the center of that data. JUDGE WARDWELL: This is Judge Wardwell.
In your Pass 1 analysis, is that done building upon all the previous Pass 1's and any corrections that were made as part of Pass 2 in the past, and only adding on the next 18 month changes in conditions for the estimate? MR. ALEKSICK: do it that way. No, Your Honor. We don't
In practice, the Pass 1 analysis We're introducing it here
isn't used very much.
because it's one of the principles of the program. But day-to-day operation of the program, now that we're decades into the life of the FAC program, Pass 2 analysis are the -- 99 percent of what we'll discuss in this hearing will be Pass 2. JUDGE WARDWELL: JUDGE KENNEDY: Thank you. This is Judge Kennedy.
Just following up on that, is the wear calculation of Pass 1-Pass 2, is that the same calculation? is it using the same analytical model? I mean
Page 1301 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
again. MR. ALEKSICK: between Pass 1 and Pass 2. Yes, it is identical The only difference is
that the Pass 2 result has a calibration factor applied to it, a single number that multiplies it. It
may increase the Pass 1 wear rates by ten percent, or decrease it by 23 percent sort of across the board, to make the Pass 1 predictions match as closely as possible the field observations. JUDGE KENNEDY: This is Judge Kennedy
So there is an adjustment of the wear rate in
the Pass 1 calculation, or it may be after the Pass 2 calculation, to adjust the wear calculation to incorporate the measurement data? MR. ALEKSICK: Yes, Your Honor. The Pass
2 calculation, part of the analysis that the software does when it's doing this Pass 2 analysis is reports to the user the -- it's a value called LCF or line correction factor, and that is that single number. It's just a -- it's a calibration factor. But it
increases or decreases the Pass 1 results too. JUDGE KENNEDY: let's go back to Pass 1. One last follow-up, and There's been an evolution
from CHEC to CHECWORKS, and there's probably been versions of CHECWORKS I would assume. What I'm after is the data that's been
Page 1302 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Your Honor. collected at various operating plants, either in the United States or worldwide, is that data used to inform the wear model or the wear calculational model, or is there a unique model developed for each plant application and the wear calculation is unique to that plant? I guess I'm trying to look to see if, you know, we started off with just laboratory data. we, it appears that the model used some operating plant data, and now a lot of time has passed. I'm Then
just trying to find out if the model is informed by the operating data at not just the, let's say for this case Indian Point, but other operating plants in the United States? I mean is there -Both of those are true,
MR. ALEKSICK:
The CHECWORKS code itself and the
algorithms internal to it, based on these seven factors I mentioned before, is continuously enhanced and revised as we go forward in time, and as more data become available and so forth. So and EPRI, the Electric Power Research Institute, is the institution that has responsibility for that. They maintain an active user's group and In
issue updates to the software and so forth.
addition to the software improvements, each user
Page 1303 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
question. parameters. incorporates inspection data from their particular site, to make a plant-specific calibration of the model. JUDGE KENNEDY: And this may be the same
You introduced a concept of global Again, this is Judge Kennedy. What are
global parameters? MR. ALEKSICK: Plant global data is a term
used in CHECWORKS modeling to refer to input data that is used across the model. So for example, the pH, the
oxygen concentration, the heat balance diagram, you know, what's the flow rate through the final feed water and so forth. These are sort of fundamental inputs that affect the entire model. In addition to that global
data, there is component data, what's the geometry, what's the material, what's the size and the thickness and so forth. JUDGE KENNEDY: Is the global data for a
whole line, or is it applied to many lines in the CHECWORKS calculation? MR. ALEKSICK: The global data applies Part of what
essentially to the entire plant.
CHECWORKS does is represent the heat balance diagram internally, for purposes of calculating pH around the
Page 1304 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
whole thermodynamic cycle. So it applies to all
components in the CHECWORKS model. JUDGE KENNEDY: MR. ALEKSICK: Next slide, please. Thank you. Thank you, Your Honors.
I think we've anticipated some of An important
this material through these questions.
part of the program, the CHECWORKS program, is the ability to adjust the Pass 1 predictions, based on inspection data, to create a model that reflects reality in the field as closely as possible. That's our alternate goal. The means by
which we accomplish this is we divide the model up into, remember I said analysis lines. 40 per unit. There are about
An analysis line represents a collection
of piping that experiences similar operating and chemistry conditions. So for each analysis line, there's a calibration factor calculated by CHECWORKS. called the LCF, the line correction factor. It's So
because we have 40 analysis lines roughly, we have 40 line correction factors roughly. CHECWORKS also creates charts, scatter plots showing predicted values versus measured values, so that the analyst can assess, for each analysis line, the degree to which the program accurately
Page 1305 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
again. reflects field conditions. Some of those lines do not agree very well with the observations in the field, for various reasons. Some of those lines do agree very well with So part of the modeling
the field observations.
process is to go through each analysis line, apply, you know, apply predetermined criteria, to determine whether each line can be considered well-calibrated or not. A well-calibrated line is an analysis line in CHECWORKS that we believe represents actual conditions in the field fairly well, and they can therefore be relied on with some degree of confidence. A non-calibrated line, conversely, is a set of output from the model that we don't think represents reality as closely as we would like, and therefore we treat those sorts of lines quite differently, primarily by increasing the level of inspection coverage for such a line. JUDGE KENNEDY: This is Judge Kennedy
The adjustment that you're making with the
line correction factors, is that an adjustment to the wear calculation or a reset of the min wall thickness, or both? MR. ALEKSICK: It is solely an adjustment
Page 1306 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
to the wear prediction. JUDGE KENNEDY: So when you talk about an
outlier, and you do the assessment of well-calibrated line or not so well-calibrated line -To say it differently, is there a balancing between what the model predicted for wear rate, versus what's being measured in the field, and if the field measurements conflict with the wear rate, is that termed a non-calibrated line, or do you go through the adjustment process? I'm trying to
understand how you get to this outlier decision. MR. ALEKSICK: A typical analysis line
might contain 20, 30 or 40 inspections, components that are inspected, and it might contain 50 or 100 or 150 total components. Each one of those inspected
components, the inspection data set is imported to CHECWORKS. CHECWORKS compares its prediction of wear rate to the wear rate shown through the inspections, and plots each one of those inspections as a distinct point on the scatter plot. points on that scatter plot. The outliers are the points that are extremely high or diverse significantly from the ideal 45 degree angle line. I'm not sure. Have I answered So you might have 40 or 50
Page 1307 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
your question, sir? JUDGE KENNEDY: MR. ALEKSICK: You're getting there. Can you remind me of our
end goal on this question please? JUDGE KENNEDY: really understand. I think end goal is to
The outliers, are they just
segregated from the population and then treated through say additional inspections? I'm trying to make, I'm trying to understand if the outliers are used to adjust the wear rate for, and consequently also the min wall thickness, or are they really just segregated from the data population, so that you wouldn't do an adjustment of the wear rate model. You would just call -- in other words, these data points conflict with what the model would predict. So there's something else going on there,
either a measurement error or some phenomenon that isn't being treated by the wear rate model. So instead of adjusting the wear rate model, you just treat it as an outlier. understand where that point is. MR. ALEKSICK: Okay. Well, I think it I'm trying to
would helpful to distinguish here between the line and the component, and when we're doing a CHECWORKS model,
Page 1308 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
we think about both. But the discussion we're having Do we have an
so far really is about the line.
adequate characterization of what's really going on in that line? general? There are always edge cases and outliers. But overall, do we have a good correlation between our predictions and our measurements? question one. I guess that's Does our model really agree with it in
With respect to how do we address
individual outliers, by definition any outlier has been inspected. If it's on the scatter plot and it's
got a measurement to be compared to the prediction, it has been measured. Once a component has been measured, it moves into a different stage, and although we still care what CHECWORKS predicts about it, we're not going to hang our hat on that. If we have a set of
inspection data and we know how thick it is, we're going to use that information to make our decisions going forward. So we don't really need to, for the purposes of fitness for service and component integrity, we don't need to worry too much about the CHECWORKS prediction once we've collected the data. That said, we do care a lot about the integrity of the
Page 1309 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
model, and any time we have an outlier, we go through and disposition those, and ensure that we understand why that outlier exists. JUDGE KENNEDY: JUDGE McDADE: this is Judge McDade. Okay. Thank you.
Before you continue on,
Could you for me just explain
very briefly how you determine the line correcting factor, and then also then how it is used in the CHECWORKS program? MR. ALEKSICK: Certainly, Your Honor. The
first point is CHECWORKS calculates the line correction factor; the analyst does not. The way that
CHECWORKS calculates that line correction factor is it takes the wear. So if we've inspected ten components, we have ten predicted values and ten measured values. CHECWORKS takes the ratio, those ten ratios, they can be represented as ten points on a graph, and selects the median value of those. factor. So your median value, if you're predicting 50 mils per year and you're measuring 51 mils per year, and that happens to be the median value, then your line correction factor is that ratio. That works That is the correction set of ratios of measured to predicted
Page 1310 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
quite well, especially in the cases where all the ratios are close to one. In a case, however, where the ratios, where there was a great deal of scatter and a large number of outliers, then we might end up calling that situation non-calibrated and inspecting it more, rather than relying on a model. JUDGE McDADE: But it would still
calculate, the program would still calculate out a line correction factor; is that correct? MR. ALEKSICK: Yes, Your Honor. In every
case, for every analysis line, there is a line correction factor calculated at each time of analysis. JUDGE McDADE: by predicted? MR. ALEKSICK: predicted-measured? DR. HOROWITZ: MR. ALEKSICK: Measured over predicted. Right, that makes sense. It is measured-predicted or And that's measured divided
It's measured over predicted, because you're multiplying that ratio against the prediction. JUDGE McDADE: So if the measured as a --
and we're doing this based on wear rates or thickness? MR. ALEKSICK: DR. HOROWITZ: Wear rates. Judge, you're doing it
Page 1311 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
my question. based on the total wear calculated. The program
integrates up the amount of wear, and says I have this much wear and I have this much measured wear, and I compare the two. JUDGE McDADE: So if our measured wear is
higher than the predicted wear -DR. HOROWITZ: JUDGE McDADE: LCF is greater than one. Then the LCF would be
greater than one, and that's not desirable, right, because if you didn't -- if you wanted to somehow be aware of a problem, you would rather have the line correction factor below one, because at least your predicted wear is higher than your measured wear. I'm saying this only in a theoretical basis, so I see if I understand the line correction factor. DR. HOROWITZ: that's correct. As a theoretical basis,
Practically, there are a lot of
complexities involved with that. JUDGE McDADE: And then the second half of
Once you've identified what the line
correction factor is, how does the CHECWORKS program use that? Say the line correction factor is 1.5.
What happens then? MR. ALEKSICK: The line correction factor
Page 1312 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
please. continue. MR. ALEKSICK: Thank you. Next slide, The most That's is a multiplier, and the Pass 1 wear rate times the multiplier equals the Pass 2 wear rate. JUDGE McDADE: All right. Please
CHECWORKS gives us a lot of output.
important outputs are the predicted wear rate.
provided in mils per year; the predicted thickness; and the predicted time to reach critical thickness. In this context, critical thickness is a user-entered variable that represents some sort of minimum allowable wall thickness. Often we use the hoop stress minimum, and the predicted time to critical thickness or time to Tcrit, that's a capital T, lower case C-R-I-T, is a value in hours that CHECWORKS presents, that is an estimate of the remaining life of the component. In addition, for Pass 2 analyses, which again are pretty much all of the analyses that we do on a day-to-day basis, the LCF is provided, as well as the measured thicknesses in the output deck. Next slide, please. In addition to all
that, there is -- CHECWORKS is used, I believe in every single power plant, nuclear power plant in North America, as well as across the globe, and it's
Page 1313 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
correct. supported by EPRI, the Electric Power Research Institute. EPRI offers training, hotline support. There's a twice annual gathering of nuclear professionals under the auspices of CHUG, which is the CHECWORKS Users Group, and finally CHECWORKS, as we mentioned before, is periodically updated. The software itself and the algorithm within
the software is periodically updated, based on new information and user feedback. remarks. That concludes my
I thank you for your attention. JUDGE KENNEDY: This is Judge Kennedy. Once you've performed a Pass
Just one quick question.
2 analysis, is all subsequent analysis on that line a Pass 2 analysis, or is -- I mean Pass 1 means it's never been informed by an inspection base? MR. ALEKSICK: Yes. Essentially that's You can
There is a facility and a program.
flip a switch, telling CHECWORKS to ignore all of the inspection data. So if for some reason you wanted to But in general, you know, in
do a Pass 1 analysis.
the real world, all the analyses are Pass 2 analyses. JUDGE KENNEDY: MR. ALEKSICK: JUDGE McDADE: Thank you. Thank you, Your Honors. Okay. Dr. Horowitz, do you
have anything to add to that?
Page 1314 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
light. DR. HOROWITZ: Jeff Horowitz. No, I think
Rob did a very good job in presenting the presentation. I think the thing to keep in mind is
that practically, there are complexities to everything we talked about. I'm sure it will come out during the
rest of the hearing. JUDGE McDADE: But there's nothing that
you would disagree with, with how he characterized your presentation? DR. HOROWITZ: JUDGE McDADE: JUDGE KENNEDY: JUDGE McDADE: ready to proceed? DR. HOPENFELD: MR. KUYLER: Absolutely. No, absolutely not. Thank you. Judge Kennedy?
I have nothing, thank you. Dr. Hopenfeld, are you
Your Honor, if I may, this is
Ray Kuyler for the applicant. JUDGE McDADE: Okay. MR. KUYLER: Thank you, Your Honor. We I didn't notice the red
had an opportunity to review Dr. Hopenfeld's presentation that was filed on Friday, and we would like to say that given the Board's guidance that this should be a theoretical presentation about how CHECWORKS works at any unit, in our opinion,
Page 1315 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
essentially from Slide 5, unnumbered Slide 5 in the PDF onward, it does appear that most of the material is Indian Point specific, attempts to raise issues that are either briefed in the testimony or raise new and related issues to the testimony and are not really a theoretical consideration of CHECWORKS. So I would object to, unless there are questions from the Board, to Slides 5 and forward, at least given the Board's guidance. JUDGE McDADE: Okay, thank you, and I hope
that we've been clear from our order, the PowerPoint presentations themselves are not evidence in this proceeding. They are accepted, one from Dr. Horowitz
as Board Exhibit 1; the one from Dr. Hopenfeld as Board Exhibit 2, both for identification. (Whereupon, the documents referred to were marked for identification as Board Exhibits 1 and 2.) JUDGE McDADE: They're not admitted into
evidence, that we are allowing them to use that to help them articulate their position. is the testimony that they give. there's sworn testimony. But the evidence
They're under oath,
That's what we're
considering, as opposed to the PowerPoint presentation
Page 1316 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
itself, which is just there for identification. I think, as we indicated in our order, that the PowerPoint presentation of Dr. Hopenfeld, that was furnished to the parties last week, addresses both CHECWORKS theoretically and also CHECWORKS as it is applied, and Dr. Hopenfeld may well be referring to it later during his testimony, because we do have a lot of questions of him as it is applied. But we're not going to strike the PowerPoints and, you know, we will go ahead with Dr. Hopenfeld, again with a focus on the theory behind CHECWORKS, how it works generally, and then get into, after the break, a lot of questions on the specifics with regard to Indian Point. MR. FAGG: Fagg for the applicant. could, for clarification. Dr. Hopenfeld -I'm sorry Brad
Your Honor.
Just one question, if I We don't want to be
unnecessarily disruptive here, but we also do want to sort of protect the record. As my colleague, Mr. Kuyler indicated, we expect when Dr. Hopenfeld starts talking, he may well get into Indian Point-specific testimony. Is it the
Board's preference that we note our objections at that point on the record, or how -- we'd like some guidance, I guess, as to how to proceed.
Page 1317 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
for allowing presentation. Honor. JUDGE McDADE: DIRECT EXAMINATION DR. HOPENFELD: I would like to thank you Okay. Dr. Hopenfeld? JUDGE McDADE: Okay. I think you've
already pretty well noted your objections and, you know, I think you've noted your objections. the order clarifying what we had requested. We issued That was
furnished to Riverkeeper, and I'm sure Riverkeeper has spoken with Dr. Hopenfeld. And, you know, if we believe Dr. Hopenfeld is becoming premature in getting into the specifics of its application and Indian Point, we will ask him to hold that off until after the break, when we get into questions. But your objection has been noted, and there will be no need to be unnecessarily disruptive. MR. FAGG: Thank you very much, Your
me to make those comments to Entergy's Could I have the next slide please?
Entergy failed to mention ani important fact, and that is that CHECWORKS was designed to produce non-conservative predictions, that are as much as 100 percent, and they're off as much as a factor of a ten, 900 percent. That is not consistent, it is not
Page 1318 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
compliant with existing regulations. I would like to make another note about the comment that was made with regard to the fact that the experience that was gained at Surry was indicated that we need more inspection. all. That wasn't the case at There was
It wasn't an issue of inspection.
inspection before.
There was inspection since 1980.
What really was learned that's being missed here is the message that we got out of Surry, that engineering judgment alone is not enough. It's
not enough just to say well, based on my 45 years of experience, that's okay. Now there is a unique difference between operating these plants, nuclear plants, and operating conventional plants, operating up to nine facilities. They operate differently. procedures. They have different
One thing they have and you don't have in
nuclear plants, and I've asked this for the last 40 years, and that is they usually supplement their information, their judgment with coupons. You put coupons in the line and you get a feel for the chemistry. going on. You get a feel for what's
In a nuclear facility, it's a difficult Let me go further.
thing to do, because of radiation. JUDGE McDADE:
Well before you go further
Page 1319 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
focus. a little bit, if we can focus again on CHECWORKS. We're going to be getting into, and your testimony went into a great deal of detail, saying that in your expert opinion, one, they rely too much on CHECWORKS, that the other factors they utilize are not adequate standing alone to assess flow-accelerated corrosion, and that in your opinion, the CHECWORKS program does not add value because it does not produce conservative results. That said, we're going to get into that, and we've got hours' worth of questions, I'm afraid, on that. DR. HOPENFELD: JUDGE McDADE: Yes. But what I'd like you to do
right now is to focus on the design of CHECWORKS, not the fact that it doesn't produce conservative results, but why you think it is defective as a program. DR. HOPENFELD: Thank you. I will try to
Could you go ahead with the next one, please.
First, I'll tell you a little bit about my background, because it has been misrepresented. I have a firsthand knowledge about the background that led to the development of CHECWORKS, because at that time, I was the NRC project manager on a big, large thermohydraulic cooperative program with
Page 1320 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
I'm sorry. CEGB and EPRI. I visited their facilities. a lot of people on this area. laboratories. I talked to
I visited the MIT
I visited the Penn State laboratories. I'm not
I visited a lot; I talked to a lot of people. coming in from the moon to tell you about what happened there.
So could I have the next slide please? Could you come back to the previous one.
The development of the computer code to predict corrosion or wall thinning in a plant is a monumental job. The problem, nobody's ever tried that before
EPRI came with it. They came up with it within seven months. So you ask yourself, how did they do that? How can
you do something like that in seven months, and people hadn't been doing it for a hundred years before? now, I think there's only one code, and it took 20 years to develop. So this is not a trivial thing, but they came up in seven months. Now how did they do that? Even
First of all, they changed the definition and the name of what used to be called erosion-corrosion, and they called it FAC. I have no problem with that. You can
call it anything you want.
Page 1321 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Secondly, and this is the problem, what they said FAC is only controlled by one mechanism. Take a look at the equation that I put on the board here. You'll see FAC or corrosion is known to be one corrosion, which is
controlled by two mechanisms: usually just dissolution. it will dissolve. Second is erosion.
If you put metal in acid,
That's more than a
mechanical effect, where you erode the oxide that usually protects the material. If you fly on the
plane, if there was no oxide layer, the aluminum would evaporate. thing. Now the erosion aspect of that, if you lose that oxide layer, then you have a synergy between the two. Now the corrosion part of it, the mass So the oxide layer is the protective
transfer control, the one that they have the F1 theorem in that equation, it's fairly easy to calculate. right input. If you don't have the input, you can't calculate either. It so happened that Entergy doesn't That's not very difficult, if you have the
have the right input, even for that particular case. JUDGE McDADE: Okay, Doctor. Is what
you're saying is you think it is a defect in
Page 1322 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
CHECWORKS, that it focuses on corrosion -DR. HOPENFELD: Absolutely, yes it does.
(Simultaneous speaking.) JUDGE McDADE: And it's your view that
corrosion and erosion have to be considered together, and that in your view CHECWORKS is defective? DR. HOPENFELD: JUDGE McDADE: experts, but certainly one. DR. HOPENFELD: slide please. JUDGE McDADE: to make sure I understand. DR. HOPENFELD: JUDGE McDADE: Yes. You're saying, it's your Okay, Doctor. I just want Well, can I have the next All the experts, yes. Well apparently not all the
expert opinion and we've already accepted you as an expert, your Ph.D. in Mechanical Engineering from MIT, 40 years in the industry -DR. HOPENFELD: JUDGE McDADE: accepted you as an expert. No, UCLA. Okay, I'm sorry. We've
We're just focusing on
CHECWORKS, and you're saying one of the defects in it, one of the reasons why it is not a reliable predictor, is because you have to consider corrosion and erosion
in tandem, and it focuses on corrosion and dismisses
Page 1323 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Yeah. erosion as outside the scope of -DR. HOPENFELD: Absolutely, you got it. That's the
It's not one, it's the major one.
one I'm going to focus on, and please, you know, take me to task. I'm not telling you what I'm -- could I
have the next one, please. Okay. Let me -- let's go back. Okay.
How did they do that?
First of all, what they did,
they neglected, they completely ignored what was in the literature. For example, there is a paper, which
I bought here into evidence; there's a paper by Dr. McDonald, who was at that time, the head of the Department of Electrochemistry at Penn State, one of the top experts in the field in this country. He has a theory about erosion/corrosion that makes it very clear that this is not a mass transfer control project. They just picked it up I have no
because it was an easy way to handle. problem with that.
I would have done the same thing
if somebody told me I want an answer in seven months. But then I would work further, and I believe the French have done that. But they haven't. Well, let's go
Then they made some other assumptions. to the next one.
Number two assumption that you see, which
Page 1324 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
is really critical, and I think it was mentioned, but Entergy did not get into the details of that. When
you buy a piece of equipment, the manufacturer tells you well, you've got chromium, maybe as much .5 or whatever, it gives you an upper limit. It doesn't tell you what the range is, and then they you give you the lower limit. It doesn't
tell you what the sensitivity that you need, the accuracy that you need in order to predict what the corrosion is. It so happened that the corrosion is
sensitive, very sensitive to the chrome content. So what can you do? The only, you can't
put input in there, without -- which will give an answer within a factor of ten, if you don't know what the input is. What you can do or what you should do
is, which EPRI is apparently not doing, is to measure. How do you do it? There is an excess for
fluorescence, a peak that you can measure, but they're not doing that. So this is another one -But how is that a
JUDGE WARDWELL: criticism of CHECWORKS?
I'm not clear on that. I'm sorry? How is your last
DR. HOPENFELD: JUDGE WARDWELL:
statement, that energy is not measuring chrome content --
Page 1325 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
DR. HOPENFELD: JUDGE WARDWELL: question, okay? Because that's -Let me finish my
How is your last statement, accusing
or alleging that Entergy hasn't measured chrome content a criticism of the CHECWORKS model? DR. HOPENFELD: Okay. The corrosion rate The
-- if you remember there was a term there, F1.
corrosion rate, the mass transfer control rate has been proven time and time, and they wouldn't dispute that, because they've stated the same thing, that it's very sensitive to the chromium content. JUDGE WARDWELL: I understand that. But
why is the criticism of that a criticism of the CHECWORKS model? Let me rephrase this. Can't the
CHECWORKS model incorporate
wear rates associated
with various percentages of chrome, if it was known? DR. HOPENFELD: the type of chromium. there. JUDGE WARDWELL: But if you did know, if No, because you don't know
You don't know what is in
you did know the chrome content, would CHECWORKS be able to handle that? DR. HOPENFELD: JUDGE WARDWELL: Much better, yes sir. So it's not a criticism
of CHECWORKS; is that correct?
Page 1326 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
correct. DR. HOPENFELD: JUDGE WARDWELL: I'm sorry? So your statement is not
a criticism of CHECWORKS; it's a criticism of what's being inputted into CHECWORKS? DR. HOPENFELD: it is the same. In that aspect, yes. But
I don't see the distinction. I think we're supposed to
JUDGE WARDWELL: focus on what is
criticism of CHECWORKS or what was
stated previously, rather than all these other items, which we're going to get into. questioning those indepth. DR. HOPENFELD: Well, I don't know about We have a time for
that, because I don't know how to distinguish between the two. JUDGE WARDWELL: Can we just wait? Can we
just get into the testimony, then, and forego this, or do you want to still go through this? DR. HOPENFELD: No, no. I'll continue.
If you call them separately, that's fine. JUDGE McDADE: Okay, Doctor. I am
I had thought that the chemical composition
of the steel, it was the metallurgical factor, was one of the factors that was inputted into CHECWORKS. therefore the chromium content of the steel was something that CHECWORKS took into consideration. Am So
Page 1327 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
I incorrect there? DR. HOPENFELD: uncertainty -JUDGE McDADE: DR. HOPENFELD: I am incorrect or I'm -No, you're correct. But Yes, yes. But there's an
there's an uncertainty, and my point is that that number is not known within a factor of six at least. That six results in a factor of ten in the predictions. That's my point. JUDGE McDADE: Okay, and again, I think
getting to what Judge Wardwell was asking about, is that a criticism of the CHECWORKS program itself, as opposed to the input that is being put into the CHECWORKS program at Indian Point? In other words,
it's there because the, as you said in your testimony; I'm not -- we haven't found any facts, but your testimony "can be off by a factor of six." If it was accurate, then it wouldn't adversely impact the reliability of the CHECWORKS program? DR. HOPENFELD: That is correct. It was
reduce it, but that's only one. it. JUDGE McDADE: DR. HOPENFELD: Okay.
Yes, it would reduce
But I don't want to get
Page 1328 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
into that. I don't make a distinction, but that may Well, so let me go on. One thing that
be moot, okay.
they have done, in presenting the -- would you please run the next slide now? Okay. As a result of this, CHECWORKS
predictions are non-conservative, because of all these assumptions that were made. Now that presents
conservative and that as much as a factor of ten. However, the way the data was presented by EPRI originally, it misrepresented what really CHECWORKS was doing. Let me go to the next -JUDGE McDADE: Okay. Again Doctor, I'm
sorry to interrupt here, because it's important to me that I understand what you're saying, and issues with regard to input and the program itself. We have
talked about, you know, what the quality of the steel was. It was my understanding that CHECWORKS did take into consideration things like the geometry of the pipe flow, the flow velocity, the pipe roughness, the void factor, the temperature, the oxygen content, the pH content, the impurities in the water, that that was all taken into consideration the CHECWORKS program. Now if the inputs are incorrect, if you're
Page 1329 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
not putting in the correct data, then it's not going to be a reliable predictor. But the question right
now is just are those factors considered in the CHECWORKS program, and if the input were correct, would it result in a reliable predictor of flowaccelerator corrosion? DR. HOPENFELD: Yeah. This is only one. There was F3, for They're
There were others, F1, F2 or F3.
example, which you're using right now. talking about an average. a local value.
They're not talking about
What they call a local value is not really a local value; it's an average value, and I'm going to be very specific and show you in a few slides what I'm -- what you call specific and what you call local, you have to have an understanding of what I'm talking about. So let me show you how the data was misrepresented. slide? JUDGE McDADE: If we could, Doctor, as far Could you please give me the next
as the data being misrepresented, we're going to be asking you about the data, and you've presented us with a lot of exhibits and a lot of testimony, specific to Indian Point and the data. Again, what
Page 1330 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
to the next. we'd like to do is just get the overview of the CHECWORKS program. Then we're going to take a short break, and then we're going to go into, you know, perhaps for everybody else except you and me, excruciating detail about the specifics. But again, just sort of focusing
on the structure of the program and things not that you feel are inadequate of what Entergy plugged into the system, but what you think are the defects in the system. DR. HOPENFELD: I understand your point
100 percent, and I don't want to harp on stuff like that. Honestly, I don't. The reason I brought that One
up is they brought up the issue of history.
reason of history, and I was there; I knew what happened, and when it happened. One reason that this CHECWORKS, if you go to NUREG-1801, you will see what NRC was talking about. They're talking about this bounds the data.
That's why this was accepted, because they believed that it bounds the data. industry. percent. It's not. So but I'll skip it. Let's go Oh, it's great. I've talked to people in the It's plus or minus 50
Could you have the third, skip the next
Page 1331 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
two please? Hopefully, we can back to it. Well, this
has nothing to do with the input data. with the mechanism.
This has to do
Remember I told you that Corrosion,
corrosion is two, three components.
dissolution by erosion and by synergy. Now one way of comparing whether it really is that way, what you do, you compare the number lost of the wall thickness in this fairly well clean geometry. What's a clean geometry? A pipe. If the
Entergy plant, the IP was a straight pipe, I wouldn't be here, because everybody can calculate that. not the problem. If it was running -- but we know that this is not one straight pipe. It's got elbows, it's got That's
arcs, it's got valves, it's got all kind of things. That's what the issue is. I mean the accident at It occurred in
Surry didn't occur in a straight pipe. an elbow.
We know how to handle straight pipes.
That's not an issue. What they talk, but the whole theory is for straight pipes. Here's an elbow. that I looked at. I have no problem with that.
This is one out of maybe hundreds You see the straight section? You It's
can calculate what the corrosion rate is there. very accurate.
Page 1332 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Now by comparing the corrosion rate of the straight section to what happens in the elbow, especially at the curve, comparing the two, you can say whether -- you can demonstrate that this not the mass transfer control. If it was a mass transfer
control, that ratio would be about 1.6, and this is based on the latest CFD type of calculations, that it would be 1.6. Take a look what you've got here. have at minimum 6 to 52. There is no way that What they have You
CHECWORKS would calculate anything.
over there, which is the F3, that's for averages. That's what an engineer does when he makes heat balances. But to get individual, local characterization of that wall, you have to use a very sophisticated numerical code. JUDGE McDADE: So what you're saying, what
you're saying, Doctor, is in your expert opinion, you do not believe that the CHECWORKS program can adequately take into consideration the geometry of pipe corrosion? DR. HOPENFELD: Absolutely. You can get
an average, but that's not -- the input is not average. The code is entered with the minimum. You
Page 1333 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
don't care that -- I mean you take a look. The whole
elbow here is one and a half inch thick, okay. But you've got one point there, that for some reason there were some bugs in there, and it became (indiscernible), and when that start leaks, that's what the concern is. wall thickness is. stress for. The hoop stress is based on the internal pressure, on the radius, which is the size of that pipe, and which is the size of and the thickness, and that's how you calculate it. the critical. And you're interested in That's That's what the critical
That's what you calculate the hoop
That's what the ASME code does.
where the safety comes in. Now let me go to the next one, and show you where I'm getting with that. If you look, this is
the grid, and I look for maybe 50 or 40 of those. That just shows you that corrosion is a local phenomena. grid. Take a look. This grid is a six-inch
What it is is a grid you make, it's just like You draw boxes. Then you take a transducer and you go one
on a map.
after another and you measure the thickness. have they report the thickness.
What you
Take a look at one of
them, and that's not the worse; there are worse than
Page 1334 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
that. If you look at it, you can see here's .513, and
they report that this is the minimum. Then you have next one, 1.492. six inches, that much, okay. Now think about that. JUDGE McDADE: Okay. Well Doctor, we are So over
You have one inch loss.
going to think about it, and we're going to talk about it for quite a bit. Again, this is getting into the
specifics of Indian Point, which we are going to get to in detail after the break. Again, what we're looking for right now is just the structure of the system, and again, as I understand, your point here is that in your opinion, the geometry of pipe flow is not adequately taken into consideration in the design and implementation of the program. DR. HOPENFELD: Which goes back to the
assumption that this only metal dissolution control. That's what this next one, please. I get carried away. (Laughter.) DR. HOPENFELD: This is another one, just is. This goes back to control, and
I appreciate you cutting me off.
a smaller, thinner line, but basically sends the same message. I gave you a reference here for
Page 1335 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
that's true. convenience, to see where they said that FAC is not a local phenomenon. The question was asked in that is it a local phenomenon? The
particular reference,
answer was no, and then the gentleman went and redefined something completely different what I said. Well, the next one please. One component
at IP that is not being monitored by CHECWORKS is the steam generator. components. Steam generators are very important
It's a safety-significant component. It's not being
That reactor vessel is a number two. monitored. JUDGE McDADE:
Again, at this point,
Entergy concedes they don't use CHECWORKS with regard to steam generators. DR. HOPENFELD: No, but I'll tell you, but
But here's the other point that I want
to bring, and if this is not the point, I'll keep quiet. What they're saying, and that's what bothers
me, because it goes to the heart of the whole problem of operating the plant in a non-safety way. They say we're going to wait until the thickness is something, and then we decide whether it can take the local loads or not. JUDGE McDADE: We'll get into -- I mean
this afternoon, we'll be talking about whether or not
Page 1336 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
said -JUDGE McDADE: Doctor, to me. If you talk So just as follows. to Entergy. Entergy? JUDGE McDADE: DR. HOPENFELD: No. Of all the bad things I the Aging Management Program for flow-accelerated corrosion is adequate or not. CHECWORKS. DR. HOPENFELD: JUDGE McDADE: program itself? DR. HOPENFELD: No. Next please. This is Absolutely. Anything further on the Right now, just
a summary, so I don't want to harp on the thing again. Basically, it's hard to draw the line. where you're coming from, Your Honor. to draw a line. I understand But it's hard
The two are intermarried. My conclusion is basically
Next please.
First of all, I'd like to say something If I may, can I tell something to
to me, I'll betcha they'll hear you, okay. direct it to me. forth. DR. HOPENFELD: best people I have ever met.
We don't want arguments back and
Obviously, they are the But I want to tell you
that I don't -- all the bad things I'm telling you
Page 1337 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
about this code, and that includes them. it. They bought it. They bought So
NRC has it on the books. They had no choice.
they had to buy it.
The NRC does
have it in NUREG-1801. it.
They were crazy enough to buy
But the point I'm trying to say, it's not them that I'm talking about. What my problem with
this is that it was developed fast, and that was good. It was response to what industry wanted. stopped. They didn't go further. But they
That's the problem.
It stopped 20 years ago. Okay. My main point here, I believe that
Entergy shares some of the thoughts about CHECWORKS with me, because otherwise, they would have used this for most, for the rest of the components. use CHECWORKS in the plant. They hardly
So if it was such a great
code, they would have been using it. But they testified that they're only using it 15 percent of the time. Now we've asked them what
are the other programs being used to control aging, or control wall thicknesses, and we never got an answer. Thank you very much for listening to me. got carried away. JUDGE McDADE: Not a problem. Let me ask I'm sorry I
one question for Dr. Horowitz or -- one of the things
Page 1338 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
of three. applicant. that was mentioned, I think back on Slide 7 of your presentation, was that there are some systems for which CHECWORKS isn't an appropriate predictor. Can
you define what those are, what the criteria area for the kinds of components, kinds of systems where CHECWORKS is appropriate and where it isn't? DR. HOROWITZ: Jeff Horowitz for the Most of them are small
Yes, Your Honor.
bore systems, which are known as socket-welded piping, and also lines which operate intermittently or occasionally, and there are log lines, vents and drains in this category. JUDGE McDADE: Okay, thank you. We've got
a lot of questions about, as I said, flow-accelerated corrosion and the Aging Management Program in place Before we get into that with our
at Indian Point.
questions, it might be appropriate to take a brief recess. I have right now that it's about quarter If we could take a ten minute recess and be We are in recess.
back at five minutes of three.
(Whereupon, the proceedings in the foregoing matter went off the record at 2:44 p.m. and went back on the record at 3:02 p.m.) JUDGE McDADE: We are going to get
Page 1339 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
started. We have at least somebody here from all of We are going to come to order. And I would ask, you know, during the course of this hearing, we do have a lot to cover, and we want to make sure we get through it. We only have
the parties.
this facility for a very limited amount of time. So if we are going to take a 10-minute break, let's try to keep it to a 10-minute break. If
we are going to take an hour for lunch, let's try to keep it to an hour. We started off with a 10-minute
break, and we are now at about 18. So we have come to order. Judge Kennedy,
you had some questions on this contention? JUDGE KENNEDY: This is Judge Kennedy.
Let me start by taking us back and refocusing us on the entire contention. So I am going to take a minute
and just at least describe, in my words, what this contention is all about. And we are talking about Riverkeeper-TC-2, and this is a contention challenging the adequacy of the Aging Management Program, which Entergy is proposing to use to manage the aging effect of flowaccelerated corrosion for select components within the scope of license renewal. This has been termed a safety contention
Page 1340 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
because of the components for which the program is being applied. In Riverkeeper's initial petition, and as this contention was admitted, they have focused on a couple of issues, the first of which is that the Aging Management Program is deficient because it does not provide sufficient details. Specifically, they listed
inspection method and frequency of inspection and criteria for component repair and replacement. They then went on to challenge the Aging Management Program for relying on the results of CHECWORKS without benchmarking or tracking worker performance at Indian Point at the uprated power levels. So that is the contention as we see it. The issues focus, in my mind, in two major areas. One, for want of a better term, is the level of detail that is provided in the application or on the record for what constitutes this Aging Management Program. The second, and will be much more into the technical details of CHECWORKS and how it is benchmarked, very similar, getting much deeper into the testimony of Dr. Horowitz and Dr. Hopenfeld as we go forward. But I would like to take us away from all of the pure technical data and talk and interrogate
Page 1341 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Appendix B? some of the witnesses about the level of detail that is -- that should be in the Aging Management Program, since there is a direct challenge to the information that is or isn't provided within Entergy's Aging Management Program. I guess I would like to start, and I have some sight line issues to the witness table with some monitors and stuff. I will try to first start by
directing a question either to Entergy, to staff, or Riverkeeper. And then, once we get someone responding
from one of those parties, maybe I can do a better job of directing the question to a specific person. I do have -- I do have some sight line issues. Let me direct this question to Entergy. If I was to go look for a description of the Aging Management Program for flow-accelerated corrosion, what would I be looking for? contained? Where would it be But
And what information is provided for that
Aging Management Program? Do I look in Appendix A? Do I look in
Do I -- where do I -- where would one go
to understand what is within the flow-accelerated corrosion Aging Management Program? Again, to Entergy first. MR. COX: Judge Kennedy, this is Alan Cox
Page 1342 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
for Entergy. The Aging Management Programs are
primarily described in Appendix B of the license renewal application. Appendix A also has a summary
description of those programs. JUDGE KENNEDY: So we would look in either
place, Appendix B or Appendix A. MR. COX: That's correct. Both places
refer to the industry guidance document, the NSAC202L, which is the basis for the program. JUDGE KENNEDY: If my memory serves me,
there is maybe a paragraph or two paragraphs contained within Appendix B of the license renewal application related to flow-accelerated corrosion? MR. COX: That's probably correct. The
format that we use for describing programs in the LRA is based on the guidance in NEI-9510, Appendix D I believe it is, and four programs that are considered consistent with the GALL program. There is not a lot of discussion there, because those programs are described in the GALL Report. We do include a reference to the GALL Report.
We include a statement of whether those programs are consistent. We talk about any exceptions that are
taken to what the GALL Report specifies for that program. And in this case, we said there were no
Page 1343 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
exceptions to what is in the GALL Report for the FAC Program. JUDGE KENNEDY: And I'm not trying to be
too clever here, but I think that is what I am trying to get at. As you continue to expound on your answer,
we have moved from I'll say Appendix B to other documents that may -- or appear to be referred to from Appendix B. You reference -- you mention GALL. That's
what I'm trying to get to is, what would be a concise view of what is contained within flow-accelerated Aging Management Program for Indian Point? MR. COX: Well, I think Appendix A and the
first paragraph, the program description section of Appendix B, have a concise description, and it talks about the methods that are used, the predictive capability of the model. The details are incorporated through the reference to the GALL Report, NUREG-1801, so it's -I mean, you can't separate the FAC -- you can't divorce yourself from the NUREG description of the program to give a description of the details that are included within that. JUDGE KENNEDY: So GALL is certainly a
major player, if, as has been done in this case, the
Page 1344 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
your mouth. meant to say? MR. COX: What I meant to say is that the consistency with GALL appears to subsume a reference to the contents of GALL for this flow-accelerated Aging Management Program. And, again, I don't want to put words in That's what I heard. Is that what you
GALL program description is essentially incorporated by reference into Appendix B of the license renewal application. JUDGE KENNEDY: And is that done through
this consistency evaluation done first by Entergy I would assume? In other words, you did some -- some
assessment was performed of GALL. MR. COX: That is correct. We evaluated
the implementing procedures at the site against the program description in the GALL Report and determined that the procedures that we used required the same steps, took the same actions that are specified in the GALL Report. JUDGE KENNEDY: Maybe while we're talking
about GALL, this term "consistent with GALL" is used time and again, both in staff testimony and in Entergy's testimony. Could you describe for us what
it means to be consistent with GALL?
Page 1345 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
MR. COX: We treat that to mean it is You can kind of look at
essentially the same program.
that statement along with the statement that we say there are no exceptions taken to what is in GALL. We take that to mean if GALL says your program includes a predictive model, then we have to have a procedure that shows that we are using a predictive model. If it says we are going to use UT
inspection techniques, our procedures have to say we are going to use UT inspection techniques to be able to say that we are consistent with the GALL Program. JUDGE KENNEDY: So does the flow-
accelerated Aging Management Program cascade down into plant procedures? Is that a part of what is -- I
guess would be included as the description of GALL, of the Aging Management Program? Or how do I connect
those two entities, the plant procedures, either implementing the Flow-Accelerated Corrosion Program -I'm trying to see the linkage, because it seems like we have got a summary level document that would provide a linkage to GALL, and then it sounds deeper into plant implementing procedures. And I'm trying to figure out where we, as the Board, would look to assess whether there is an adequate level of detail in the Aging Management
Page 1346 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
look? Program. Again, when we started this, and when
Riverkeeper first filed the contention, there was just -- I mean, just the summary paragraph was provided. And I didn't know if we -- if the process has evolved beyond there to include and incorporate more documents. I'm really looking for, where do I go Do I only go look at Appendix B, or possibly
Appendix B plus GALL? MR. COX: Well, I think Appendix B plus
GALL does provide an adequate description of the program. You know, again, when you go to the GALL
Report, you have the reference to NSAC-202L, which is a fairly detailed description of an effective FAC management program. So -I'm sorry. Could you
JUDGE WARDWELL: repeat that again?
You tend to talk pretty fast, and
I missed that reference that you just said. MR. COX: I said the GALL Report
references NSAC-202L, which is the EPRI guidance document for a FAC program. JUDGE WARDWELL: So -So now we have another
document we are interested in, this -MR. COX: Right. I mean, that's -- you You go to the
know, like I said, the link is there.
Page 1347 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
don't -JUDGE McDADE: Can you pull up This is the document you GALL Report and it says this is a program -- you have to have a program that is based on the guidance in NSAC-202L. So, yeah, there is another document
involved here. JUDGE McDADE: Excuse me. So that is
Riverkeeper Exhibit 000012, correct? MR. COX: It is one of the exhibits. I
Exhibit 000012, Riverkeeper? are referring to?
Do you see it on the screen? Yes. That is correct. Okay. And just sort of
MR. COX:
JUDGE McDADE:
going back a second, you are starting -- Appendix B is in your license application. The GALL Report is an
NRC guidance document labeled NUREG-1801. MR. COX: That's correct. Okay. So you are saying
JUDGE McDADE:
you make reference, and Appendix B incorporates by reference, the GALL Report. The GALL Report
incorporates 202L, which is Riverkeeper 000012 -MR. COX: That's correct. -- exhibit, yes,
JUDGE McDADE: Riverkeeper 000012. JUDGE WARDWELL:
Do we have a good exhibit
Page 1348 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
number for GALL and/or the license renewal application? Because I think at some point we will
want to pull those up, and I don't have that. MR. KUYLER: Kuyler for the Applicant. Your Honor, this is Ray I believe GALL Rev 1 is New
York State 000146, and the GALL -- the FAC sections are in C, 000146C, if I'm not mistaken. JUDGE McDADE: JUDGE WARDWELL: GALL 1, did you say? MR. KUYLER: Yes, Your Honor. That brings up a question. Thank you. And actually that's
JUDGE KENNEDY:
In terms of the Flow-Accelerated Corrosion Program for Indian Point, is it consistent with GALL Rev 1 or GALL Rev 2 or -MR. COX: This is Alan Cox for Entergy. There was -- you know,
It is consistent with both.
the changes between GALL Rev 2 and Rev 3 were largely administrative, didn't affect any great deal the technical content of that program description. JUDGE KENNEDY: So for all intents and
purposes, it is consistent, then, with GALL Rev 2? MR. COX: Right. GALL Rev 2 added the GALL
reference to Rev 3 of the NSAC-202L document. Rev 1 had referred to Rev 2.
And, again, the changes
Page 1349 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
between Rev 2 and Rev 3 of the EPRI document were fairly minor. JUDGE KENNEDY: So now we have proceeded And maybe just
from Appendix B through GALL to NSAC.
to use a specific example, if Riverkeeper is interested in understanding what the inspection method or inspection frequency is, where in that lineage would we be pointed to? MR. COX: I think the evaluation for how
you determine the inspection frequency would be in the NSAC-202L document. JUDGE KENNEDY: So I guess I'm trying --
if we're at the plant level implementing procedure, somewhere in the procedure there is going to be a specified frequency that is based on the guidance of the NSAC document. MR. COX: Is that what I should understand? That's correct. So now if Entergy wants to
JUDGE KENNEDY:
change that inspection frequency, what sort of process would be used to do that? It's a plant procedure. Is the NRC Is
it just a plant procedure change? involved? MR. COX:
It's a plant procedure change.
It would be -- you know, because the program description in Appendix A of the LRA references NSAC-
Page 1350 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
that? MR. AZEVEDO: Azevedo for Entergy. Your Honor, this is Nelson 202L, the change would have to be consistent with 202L. It would be -- it would require a 50.50 change
to evaluate it against the SAR, which is the licensing basis document that states that it is consistent with the NSAC-202L program. JUDGE KENNEDY: So Entergy would then have
to justify the basis for that change if it went outside the guidance of the NSAC document, is that what you are thinking? MR. COX: That's correct. And does the NSAC document
JUDGE KENNEDY:
provide a sufficient degree of accuracy or preciseness on numbers of inspections, or is it truly a guidance that provides criteria for inspection frequency? MR. COX: Do you guys want to speak to
The actual inspection frequency
is actually based on the measurements that we take. So once we go out in the field and inspect a component, the inspection frequency is derived from that -- from those results. JUDGE KENNEDY: MR. AZEVEDO: How? What we do is we calculate
the wear, because we know what the thickness was in
Page 1351 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
again. the beginning when the system was put in service. We
compared that to the measured thickness remaining, and then we also calculate the critical thickness for the component. And that is the thickness required to
carry all of the design loads and still be within the required stress allowables. And so we take the measured thickness. account for future wear, and then we calculate the point in time in the future where we are going to be reaching the critical thickness, and we schedule an inspection before we reach that point. JUDGE McDADE: Okay. Now, is there some We
place that I could go in your documentation that would lead me through that? what we do? If the result is X, this is
Or does that rely primarily on In other words, you look at the
engineering judgment?
result, and then you make an engineering judgment as to what to do as a follow up. mechanism written out? MR. AZEVEDO: This is Nelson Azevedo The actual Or is the precise
It is pretty precise, Your Honor.
guidelines are provided in EN-DC-315.
That is the
Entergy fleet procedure governing FAC programs, and there are a few other documents that reference -- in that procedure that tells you exactly what to do.
Page 1352 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE WARDWELL: So did I just hear a
fourth document crop up here now? MR. AZEVEDO: referenced in EN-DC-315. There are documents That's correct. And what is -- could you
JUDGE WARDWELL:
just say more about what that is? MR. AZEVEDO: document covers -JUDGE WARDWELL: MR. AZEVEDO: What is EN -EN-DC-315 is the Do you mean precisely which
I'm sorry.
Entergy fleet-wide procedure that covers FAC programs for the entire Entergy fleet. MR. KUYLER: Kuyler for the Applicant. Your Honor, this is Ray If I can just point to
Entergy Exhibit 000038, that is EN-DC-315. JUDGE KENNEDY: Kennedy again. Thank you. This is Judge
Mr. Cox, I think I cut you off when we
started our discussion of the consistency with GALL assessment, and how Entergy in this case views, what does it mean to be consistent with GALL, so that you can make that linkage to NUREG-1801. MR. COX: Okay. Should I repeat it?
JUDGE KENNEDY: MR. COX:
Yes, please. I'd like to take -- about
JUDGE KENNEDY:
Page 1353 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
halfway through this long discussion through the trail of documentation, we started at the reference -incorporation by reference of the GALL Aging Management Program, and in this case for flowaccelerated corrosion. And that reference is
supported by an assessment that the program that Entergy is promoting or offering for this aging effect is consistent with GALL. And I think I cut you off when you were giving an answer to the question of, how does Entergy perform the assessment of consistent with GALL? does that entail? MR. COX: That would entail looking at the Mr. Azevedo mentioned EN-DCWhat
implementing procedures. 315.
That's one of the implementing procedures for And we looked at that procedure to
the FAC program.
make sure that it included the elements that are described in the GALL program description, including a reference that says the program is consistent with -- or implements the guidance of NSAC-202L, the EPRI guidance document. We would find that in the procedures. Ultimately, before we entered the period of extended operation, we would annotate those procedures to indicate that those specific steps that implement the
Page 1354 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
elements of the GALL program are flagged to indicate that they can't be changed without going and looking at that procedure. We treat those as commitments, licensing commitments, that would require an individual to specifically look at that commitment, that step, to make sure that the changes to that step don't undo any of the things that we have taken credit for for license renewal. JUDGE KENNEDY: Is this -- should I read
this to be a verbatim compliance to the attributes of GALL? Or is it -- are there -- is there some room in
there for interpretation of what meets a GALL attribute, if you will? MR. COX: verbatim compliance. We treat it as essentially Now, there are statements in
GALL that -- you know, and they may be called statements of facts, that don't really tell you any action that the program needs to take. And we may not
address each of those statements there that are provided kind of for information. But if it is an action that the program says you need to do to take as part of your program, we would evaluate that as saying we have to do that. We treat it as verbatim compliance with that
Page 1355 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
statement. JUDGE KENNEDY: I mean, for argument's
sake -- GALL doesn't say this, but if for argument's sake GALL specified the inspection frequency, do I understand it that -- and, again, this hypothetical case, Entergy would look at the plant procedures to see if that is consistent with their inspection frequency? And, if it is, would they declare that
consistent with GALL then? MR. COX: That's correct. If GALL said
you inspect it once every refueling outage, we would have to have a procedure that implemented an inspection once every refueling outage, before we would say we were consistent with GALL, for that element. JUDGE KENNEDY: And in this case, what we
have is that GALL is calling out this NSAC-202 document for these level of detail issues, is that -MR. COX: That's correct. And just to make sure I'm
JUDGE McDADE:
understanding it correctly, I mean, as I read GALL it is sort of a statement of objectives rather than specifics. incorporate. This is what a program should/must It has 10 separate areas. You start
with your application, Appendix B.
It makes reference
Page 1356 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
procedure. procedure. big word. EN-DC -JUDGE McDADE: Well, "essentially" is a -- it says, "We comply with the requirements of GALL." After you look at that, and that's New York Exhibit 000146C, you then go to NSAC-202L, which is Riverkeeper 000012. That now contains more detail
on how to actually accomplish what GALL says you must do. And then the last exhibit referred to
Entergy 000038, which is the EN-DC-315, in your view is the specifics of how the NSAC-202L will be applied by Entergy in your plant. That's where the specific
details are for the people on the ground to get guidance. MR. COX: That's essentially correct. The
Where is it not correct? MR. COX: The EN-DC is an implementing That is the implementing
That is correct.
The NSAC-202L document does provide the
details, we believe, to adequately describe an effective program. And we use the EN-DC-315 procedure
to ensure that we are taking those actions described in the NSAC document. JUDGE McDADE: But if we are looking to
see what Entergy actually is going to do in making a decision as to whether or not it will adequately
Page 1357 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
315. control the effects of aging, we should focus on the Exhibit 000038, EN-DC-315, because that's what the people in the plant are actually going to be looking at when they are carrying through the program? we need to move back from that to the earlier documents? MR. COX: Well, you know, we typically Or do
don't provide implementing procedures as part of the LRA. So I guess my position would be that the GALL
Report, with this reference to NSAC-202L, does define the program. Now, the implementing procedure is EN-DCSo, I mean, you can look at that, and you should
find that it is consistent with what is in the GALL Report and NSAC-202L. But I don't think you are going
to find a lot of additional level of detail beyond that that is necessary to be able to say that you have an effective program. In other words, I believe that the GALL Report, in conjunction with the reference to NSAC202L, is a pretty robust description of an Aging Management Program for FAC that it will be effective. MR. AZEVEDO: what Mr. Cox has said? JUDGE McDADE: Please. Your Honor, may I address
Page 1358 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Azevedo. MR. AZEVEDO: Again, this is Nelson
Some interface -- for example, EN-DC-315 But it So
requires that we do ultrasonic inspections.
doesn't tell you how to do ultrasonic inspections. if you look into that level of detail, there is another procedure that actually tells the inspectors how to perform the inspection. If you are going to do a calculation to calculate the critical wall thickness, that level of detail is not provided in EN-DC-315. different procedure. It is a
It is a reference in the EN-DC-
315 that gives the details that you need to perform those calculations. Those are just two examples. Okay. Thank you.
JUDGE McDADE: JUDGE WARDWELL:
In GALL, and maybe we can
pull that up, New York State 000146 I believe is -someone said was -- and we want to get to -- where I'm referencing is XI.M62. long way. You've got to scroll down, a
You'll eventually pick up some page Let me watch you do it. Go until you get to
numbers, I believe.
There you go.
whatever I just said, which I can say again -- well, I can look here. applies. XI.M1.6.2 or 6.1. That's where it
XI.M17 is the flow-accelerated corrosion Is that correct, Mr. Cox?
portion of that.
Page 1359 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
MR. COX: That's correct. And that's where we are Now we're
JUDGE WARDWELL:
trying to get to on this exhibit here. getting close. far. is.
Go down to -- you may have gone too Let me see what that Keep going.
Just go back up a page.
Yeah, you've got to go down to M17.
No, no, sorry, it was the top header. Go to the previous page. Keep going. That's
Where it says XI.M3, we want to get to XI.M17. 61. If you want to go by page numbers, it's 61. There we are.
We're getting close.
This is GALL, correct, Mr. Cox? MR. COX: That's correct. And could you scroll down
JUDGE WARDWELL:
one -- can you make that one page, Andy, I think would be best. page. Okay. There you go. Now let's jump down a
Yeah. So it's two pages of dialogue. Is that a
correct assessment? MR. COX: That's correct. On the second page of it,
JUDGE WARDWELL:
for that first paragraph, the second -- the second line right at the end, a new sentence starts, "The inspection schedule developed by the licensee on the basis of the results of such predictive code provides
Page 1360 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Honor. decades. JUDGE WARDWELL: Mr. Azevedo -- did I reasonable assurances." And then it goes on to talk
about inspections results are evaluated. How long have you been using predictive codes at the plant? years? Twenty years? MR. COX: '80s/early '90s. JUDGE WARDWELL: Okay. So we've got a Has it been two years? Ten
I don't need the exact number. It has probably been since late
decade or so of you utilizing and monitoring for flowaccelerated corrosion, is that correct? MR. COX: That's correct. At least two
pronounce that correct, or close enough, or whatever? With all of that history, aren't you pretty well set on where your inspection points are, or the numbers of them? Or can at least say where you are going to go
in the near future on inspection points with that much history? MR. AZEVEDO: Yes, that's correct, Your
For the locations that we have inspected, that
is correct. JUDGE WARDWELL: pretty well set, isn't it? MR. AZEVEDO: Yeah. It is -- basically, And the frequency must be
Page 1361 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
it's -JUDGE WARDWELL: MR. AZEVEDO: Have you ever doubled it? it double? MR. AZEVEDO: It is hard to say. Really, what we do, like I said before, we calculate the critical thickness and we implement an inspection before we reach that point. JUDGE WARDWELL: Why don't I need to see
that information in order to convince myself that, yes, your inspection program meets what is written here in GALL? Why don't I need to see that as part of Program, excuse me.
your aging management plan? MR. AZEVEDO: inspection, the actual -JUDGE WARDWELL:
Do you mean the actual
No.
Just, this is how
often we are going to do it, and we are going to do it at blankety-blank number of locations. MR. AZEVEDO: Well, because that number is
going to change every time we do an inspection. JUDGE WARDWELL: MR. AZEVEDO: Sure. But by how much?
It could change quite a bit. A hundred percent? Would
JUDGE WARDWELL:
We have had instances where
we go out and do inspections, and I think that the component could be reaching its useful life. And it
Page 1362 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
cycles. has a number of cycles left. JUDGE WARDWELL: It is not unusual. I am not talking about
I am interested in how many -- frequency of What I'm driving at here is you have some Where is that
inspection.
plant experience at Indian Point.
experience reflected in your Aging Management Program that allows me to make a decision that, yes, you have demonstrated consistency with GALL, rather than merely stating, "It is," or, "Trust me, it is," is the way someone might read what you currently have before us. MR. ALEKSICK: If I may, Your Honor. This
is Rob Aleksick for the Applicant. JUDGE WARDWELL: MR. ALEKSICK: Sure. I guess I would start by When we talk about
saying that -- a clarification.
inspection frequency in the world of FAC, it is different than in, say, ISI or other programs. is no set schedule or set percentage coverage or things like that. Because the rate of FAC varies widely from different -- from component to component, there is an individual inspection frequency for each component, and that inspection frequency is determined primarily by the measured wall thicknesses, and the information that you are asking about, so that you could look at There
Page 1363 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
document? MR. COX: No, that's not. That's part of the history and say, "Have we complied with GALL in the past?" It is in several places, but I would point Your Honors -- probably the best place is in Entergy Exhibits 000050 and 000051, which are the documentation of the CHECWORKS model, which includes essentially every inspection of all modeled components dating back to the program inception, back as early as 1992. So there are 3- or 4,000 inspections that have been conducted in that period of time that are in the CHECWORKS database, and that are available, and they are printed out in numerous places in those exhibits. JUDGE WARDWELL: But why isn't the heart
of that program not summarized, as it applies to Indian Point, in your Aging Management Program? MR. COX: Well, I think -- I'm looking at
NSAC-202L, and it has a section that addresses remaining service life. JUDGE WARDWELL: Is that a site-specific
the program where we describe -JUDGE WARDWELL: And GALL isn't site-
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specific, correct? MR. COX: That's correct. Plant-specific, and nor
JUDGE WARDWELL: is NSAC, is that correct? MR. COX:
That's correct. So we have no Indian
JUDGE WARDWELL:
Point plant-specific document before us, that correct? MR. COX: Well, I mean, there are -Besides the results. I
JUDGE WARDWELL:
mean, we have a document, but we haven't referenced those yet in our hierarchy of how we get to an inspection program. We have just been notified of
some CHECWORKS reports, or whatever, 000050 and 000051, that we could go look at. But what I am
looking for is some type of plant-specific -MR. COX: I guess what I was looking --- characterization of
JUDGE WARDWELL:
the Aging Management Program or a reason why that is not feasible to be done. MR. COX: Cox for Entergy. Well, I think -- this is Alan
Again, I thought your question was,
how can you look at what has been submitted as part of the LRA to get an appreciation for how the program would be effective for that demonstration? JUDGE WARDWELL: I'm looking for your
Page 1365 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Aging Management Program, and I have been directed to four different documents now of your Aging Management Program. And I don't see any specificity as it
applies to Indian Point, and I don't find it particularly easy to see what is a program. And I'm curious as to, why isn't that? mean, I have been involved with numerous programs development and -- for various projects, and usually that is what is done. And I'm curious as to, why I
hasn't that been done, and is it -- and the reasons for why it hasn't been done. So that someone can look
at it and judge the program to then compare to GALL and say whether or not it is consistent at Indian Point. MR. COX: Well, I guess I'm trying to
separate program description from implementing procedures, and I think sometimes it is hard to draw the line between those. You know, I think the fact
that we have a commitment that says we are going to follow the GALL Report and, by reference, NSAC-202L, is a demonstration that we are going to have an effective program. NSAC-202L is a program that has been developed through the industry, has been demonstrated as an effective program, so that's -- it is kind of a
Page 1366 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
situation where if you're consistent with the program, it has been looked at and evaluated and assessed by the NRC as being an effective program, and you have a commitment to do that, that is a demonstration that you are going to have an effective program. Now, the implementing procedures provide -- you know, if you are onsite doing audits or inspections and you wanted to look at implementing procedure details, operating experience -- and all of that information is available, and a lot of it is in our exhibits that we have submitted here -- that those are not exhibits that are included as part of the license renewal application. JUDGE WARDWELL: Do you consider a
statement something to the effect that, "Over the past 20 years, we have conducted an average of X number of inspections at X number of locations on a frequency of, oh, every 18 months at Indian Point," do you consider that an implementing procedure? statement like that? MR. COX: That would be kind of a general A general
statement of operating experience or I guess of program inspections. But, again, as Mr. Azevedo
explained, you know, each outage we look at all of the components that are in the program and do this
Page 1367 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
projection of remaining service life. So that is how -- you know, it is not a set frequency. It is not always going to be the same It is going to be based on
number of components.
looking at all of the components in the program before each outage to see what the remaining service life is and make sure that we have inspections scheduled prior to meeting that expected service life. JUDGE WARDWELL: I can appreciate possibly
some of the challenges with drawing a line on where or how you describe your program at Indian Point, and certainly would not expect to see -- this is the details of our calculations as you suggested, Mr. Azevedo, and I appreciate that. expecting that. But, likewise, a general discussion of what you think will take place in the future, so a person can then look at it and say, "Yeah, they've got an inspection program," or, you know, that is just one example. There is other things that are called for in And I am not
GALL that to me have no corollary to what has been presented for how we are doing these at Indian Point. Let me ask you this one question, and then I'll get -- I'll let Judge Kennedy, which is his area doing this anyhow -- but do you consider -- and any of
Page 1368 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
you can answer this, but I'll direct it to Mr. Cox to start with -- do you consider GALL to be a program? Or do you consider GALL to be a description of the attributes of a program? MR. COX: I'm not sure the distinction The -Well, the distinction
that you are drawing there. JUDGE WARDWELL:
would be, could I, as an applicant, say, "Oh, we'll do everything consistent with GALL, because GALL is an Aging Management Program for Indian Point"? Or would
I be required to present my AMP and point out how my AMP, by having some descriptions of those types of things that will be conducted at Indian Point, I am able to demonstrate that in fact it is consistent with GALL? Is GALL by itself a standalone program, or do
I have to demonstrate a consistency with GALL? MR. COX: I think all GALL programs are I think in the case of the
not necessarily the same.
Flow-Accelerated Corrosion Program, the GALL Report defines the program. The standard review plan talks
about the 10 elements of a program, and the way we consider that is those 10 elements define your program and defines the preventive actions. inspection methods. criteria. It defines the
It defines the acceptance
Page 1369 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
And so, you know, I think particularly in the case of the FAC Program, the GALL Program is a program. JUDGE WARDWELL: MR. COX: and objectives. Okay.
It is not just a list of goals
It is an effective program. Well, let me -Before you is accepted
JUDGE McDADE: JUDGE WARDWELL: criteria on your screen.
It just happened to be up We haven't moved off of And this is
here, and this is from GALL. this.
So we can take a look at that.
what you state is the acceptance criteria for Indian Point. And I will just quickly read it. "Acceptance criteria. Inspection results are input
for a predictive computer code such as CHECWORKS to calculate the number of refueling operations -operating -- refueling or operating cycles remaining before the component reaches the minimum allowable wall thickness. "If calculations indicate that an area will reach the minimum allowable wall thickness before the next scheduled outage, the component is to be repaired or replaced." That, in your opinion, is the
sufficiency of the acceptance criteria that is needed
Page 1370 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
at this point in time for your license renewal application? MR. COX: Yes, sir. I believe it is. Thank you. Let me focus, again, And I don't
JUDGE WARDWELL: JUDGE McDADE:
Okay. Okay.
on what we have here on the GALL Report.
mean this in a pejorative way, but would you disagree that the GALL Report could be viewed as sort of a list of 10 platitudes? I mean, basically, this is saying, like, what should happen. You know, sort of like, you know,
promote the general welfare, ensure the blessings of liberty for ourselves and our prosperity. a goal. Now, it's
It's something that we want to have happen,
but the devil is in the details. So if I look at the GALL Report, and the NUREG, it specifies in those 10 criteria what I need to do, but it doesn't tell me very much about how I'm going to do it. And as I understand from what you
have said, that we start off with this list of 10 things that the aging management plan should include, what it is supposed to accomplish. It is -- you know, inspection results are evaluated to determine if additional inspections are needed to assure that the extent of wall thinning is
Page 1371 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
adequately determined, and assure that intended function will not be lost and identify corrective actions. Clearly, that is something that we need to
have accomplished, but that doesn't tell me very much about how to accomplish it. And when we are told that the Applicant has said, "We will be consistent with GALL," it is, again, sort of a general statement that you want the plant to work properly. You want flow-accelerated
corrosion to be adequately managed during the period of extended operation. But then, we get down to the specifics of how you are going to do that, and, as I understand it, you are saying that you take these goals, you then look to NAC-202L, Riverkeeper Exhibit 000012, and then you look to Entergy Exhibit 000038, which is your ENDC-315. Now, is there anything more specific than EN-DC-315, that you can go and follow and say, "If this happens, then this is what I am going to do"? And you know ahead of time what the criteria are. there anything more specific than EN-DC-315, or is that what we have to make our determination on as to whether or not the program is adequate? MR. COX: Well, I think you could make Is
Page 1372 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
your determination on EN-DC-315. I mean, there are When you
some things that are not included there.
start talking about determining minimal, acceptable wall thickness, that is kind of an engineering function that structural engineers at the plant -they have -- you know, they have procedures for doing that. Nelson mentioned the actual procedure for doing the UT inspections. There is going to be
procedures for how a technician in the field actually uses the ultrasonic testing probe to do that UT thickness measurement. So, I mean, there are certain
things that are kind of within the skill of the personnel that are implementing the program that may be covered by other procedures, as far as the details of how to do the inspection and use the equipment. But, you know, I think in general the program is -- even up to NSAC-202L, I think that defines enough of the essence of the program that a competent mechanical engineer can take that and go put in place a program, and another engineer can come behind him and review it and say, "Yeah. Your program
is consistent with NSAC-202L and with the GALL Report." JUDGE McDADE: Is there any place -- for
Page 1373 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
example, if there were a particular elbow in a piping that was tested, and it indicated that the wall thickness was X, that tells your engineer that that thickness is adequate there as opposed to inadequate there, or do they just have to use their general judgment with regard to what the speed of the flow is, what the pressure is, and what the thickness of the wall is? MR. COX: You know, that is all built into
the CHECWORKS program as part of the NSAC-202L program and the site procedures. JUDGE McDADE: tells you where to test. tested. MR. COX: Okay. Once you have tested it, The -You know, CHECWORKS just I'm asking once you have
then you also have steps -- in fact, some of what we just read here for acceptance criteria -- that says we need to look at the time to critical thickness. So we need to look and see what is the expected service life of that component, and we are going to do that based on looking at how long it is going to take to get to the minimum critical wall thickness, which, again, that is a number that is derived from a structural engineer based on looking at the design loads that are defined in the current
Page 1374 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
licensing basis for the plant, you know, plantspecific parameters on the piping wall thickness and that sort of thing. So I guess to answer your question, I think the details are there in the method that we would use to evaluate that actual measurement. We are
doing trending based on what is the thickness now based on what it -- compared to what it was the last time it was inspected or based on what the nominal thickness was when the pipe was installed. So that is -- I mean, that is what the engineer would have to use. He would have to do that
projection, maybe draw a straight line through two measured points and say, "When is it going to reach the minimum thickness? And I've either got to repair
it or replace it before I get there, or I've got to do another inspection to confirm my results." JUDGE McDADE: Okay. Generally, in these
pipes, is it a linear progression as far as the flowaccelerated corrosion? In other words, if it is X
today, and then X minus one next outage, and X minus two next outage, that you could predict it is going to be X minus three the outage after that? you know, again, is it linear? MR. ALEKSICK: This is Rob Aleksick for Or is it --
Page 1375 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the Applicant. Yes, Your Honor, it is a linear
process, and your example is exactly correct. JUDGE McDADE: Would it ever not be? In
other words, where that rate of erosion would be inconsistent, where it would -- and, again, assuming certain things like the temperature, the water chemistry, those kinds of inputs remain basically the same. Would one expect that the rate of corrosion at
any particular point in the system would remain consistent? MR. ALEKSICK: Yes, Your Honor. Given
steady-state operating and chemistry conditions, one can reasonably expect the flow-accelerated corrosion wear rate to be linear with time. JUDGE WARDWELL: JUDGE McDADE: JUDGE WARDWELL: Just one quick question. Go ahead. So are you saying, Mr.
Cox, that you really -- if you did not have EN-DC-315, would you feel as comfortable in stating that you are consistent with GALL? MR. COX: Well, I think, you know, we have
to look at the implementing procedures to see -- if an NRC inspector was coming onsite to look at whether we are consistent with GALL, that is what he would have to look at is the implementing procedure.
Page 1376 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
I mean, you can look at -- we have a commitment that says, yes, we are going to be consistent with GALL, we are going to do what GALL requires, what GALL recommends, but to actually see if we are doing that in the field, you've either got to go look at the data, you've got to look at the implementing procedures. I mean, you've got to look at the plantspecific information to see if we are actually doing what it is that we said we would do. could -JUDGE WARDWELL: myself clear. I guess I didn't make I mean, we
If you did not have EN-DC-315, would
you be as comfortable in saying you are consistent with GALL? Let me ask it another way. Is EN-DC-315
really your aging management plan for flow-accelerated corrosion? MR. COX: EN-DC-315 is the implementing
procedure for the Aging Management Program for flowaccelerated corrosion. I guess to answer your
question, no, I would not be as comfortable without EN-DC-315. JUDGE WARDWELL: And just to fix another When you are
point, because it may come up later.
saying "implementing procedures," it's implementing
Page 1377 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
procedures, it's not the implementation of those procedures. There is just a description of how you
are going to implement it, not an actual implementation of it yet. MR. COX: Right. When we are dealing with
JUDGE WARDWELL: license renewal, because -MR. COX:
It is not necessarily the
results and the actual applications procedure, but it's the procedure itself that tells you how to implement the program as described in the GALL Report. JUDGE WARDWELL: JUDGE KENNEDY: Thank you. Just following on Judge
Wardwell's question, I envision that to mean that below -- if EN-DC-315 is a fleet-wide procedure, would there then be specific implementing procedures at Indian Point for the -- to implement the fleet-wide procedure? far? JUDGE WARDWELL: I'm a civil engineer. MR. AZEVEDO: Azevedo for Entergy again. Your Honor, this is Nelson No, EN-DC-315 is the You can't push a rope. Or am I trying to push this long rope too
implementing procedure as far as the program is concerned. As I mentioned before, for each specific
Page 1378 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
000048? Applicant. test there are other procedures -- I mentioned the ultrasonic inspection, how to implement the actual steps there are other procedures. But from a
programmatic standpoint, EN-DC-315 is applicable at Indian Point. JUDGE KENNEDY: Where would the scope of
the Flow-Accelerated Corrosion Program be contained? Would that be in EN-DC-315? Or is there -- I mean,
what constitutes the components that are within the scope for license renewal? MR. ALEKSICK: Rob Aleksick again for the
Your Honor, EN-DC-315 provides guidance on
how to identify that scope, and the actual implementation of that is provided in -- I don't have the exhibit number, but it's what we call the system susceptibility evaluation, and it is an extremely detailed listing of every single line that is susceptible to FAC and the reasons for that. JUDGE KENNEDY: for Indian Point -MR. ALEKSICK: JUDGE KENNEDY: MR. ALEKSICK: JUDGE McDADE: Yes. -- Units 2 and 3? Yes, Your Honor, it would. Can we put up Exhibit Do you see it on And that would be specific
Is that it, Entergy 000048?
Page 1379 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the -MR. ALEKSICK: Yes, Your Honor. This is
the exhibit for Indian Point Unit 2. equivalent document for Unit 3. JUDGE McDADE: Okay.
There is an
Which is the next --
we don't need to pull it out, but it's Exhibit 000049 for Indian Point 3? MR. ALEKSICK: Yes. Yes, Your Honor. It
is -- Exhibit 000049 is the equivalent document for Unit 3. JUDGE KENNEDY: I think we have now -- we
have started at what is in the application and, for argument's sake, the Appendix B description for flowaccelerated corrosion. And we have now weaved our way
through NSAC-202 to EN-DC-315 down to some I'll say plant-specific implementing procedures at Indian Point. The original focus of this question was really trying to understand, is there a bright line, when an applicant writes an application and subsequently interacts with the staff, to document what constitutes the program for Indian Point for flow-accelerated corrosion? How is that determination made? Because
what it appears from this is once you pass NSAC-202,
Page 1380 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
we are now down into a large number of either fleetwide or station-side implementing procedures. am trying to understand, from -- let's say from Riverkeeper's perspective, how they would have gotten there. I think you have given the Board a path to understanding where all of this information is, but this -- recognizing that this started early on at a level at which the application is written, and where commitments were made -- and commitments have been changed over time to where we sit today -- to implement a specific flow-accelerated corrosion program for Indian Point. And I am really looking for how that bright line of what is in Appendix B that goes forward into the UFSAR or -- how that determination is made, what -- where are the details committed to that constitutes the program? MR. COX: I think I just have to keep And I
going back to the Appendix B and Appendix A, which both refer to NSAC-202L, and that is where the details are. The NSAC-202L document tells us that we have to
generate this type of report to assess the system's susceptibility. JUDGE KENNEDY: So --
Page 1381 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
example. MR. COX: It gives us details on
projecting service life and scheduling inspections prior to reaching that expected service life, so -JUDGE KENNEDY: And maybe this is a good
NSAC-202 is called out in GALL, and so
Entergy chose to carry forward that descriptive information because that was a specific attribute of GALL that pointed to a specific referenceable document where inspection frequency, a specific number, isn't called out in GALL. That is what I'm trying -- I'm trying to get to how we -- how Entergy decided what goes into Appendix B of the license renewal application, and then subsequently carried forward. Is it at that
level where attributes that are specific -- or help me. This is -- I mean, I -- trust me, the discussion
of taking us all the way down to the plant procedures was very instructive for the Board. But this is going
to come up on a number of Aging Management Program contentions as we go through the next couple of weeks. And I think we are all, as a Board here, trying to struggle with what level of information constitutes a documentable program inside the application. that help. And if you could help us, we will take
Page 1382 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
MR. COX: back to Appendix B. program. Well, I think you have to go That is where we describe the
And in this case, you've got to bring in the
reference documents that are described in Appendix B. There are other programs where there is a lot more detail in the actual words in the GALL Program to give you things like inspection frequency, how many inspections you have to do, what the frequency is. Those details are typically in the GALL Program. JUDGE KENNEDY: Would it be fair to say,
if the specifics are in GALL, the specifics will be in Appendix B? MR. COX: Well, the reference in
Appendix B, it may just say that we are consistent with GALL, and that we will talk about the things that are an exception. So if there is no exceptions to
GALL, you may not find -- again, this is based on the standard format that was established in NEI-9510 back several years ago. If you are consistent with GALL,
you are only going to talk about the things that you are going to do that are exceptions to what GALL specifies that you would do. So if you are going to do a different frequency, you would have to describe that. If you
don't describe an exception, then the frequency that
Page 1383 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
with that. JUDGE WARDWELL: Do you agree that the is in the GALL Report would be the frequency for your program inspections. JUDGE WARDWELL: Do you agree that
Appendix B for flow-accelerated corrosion consists of a page and a half of narrative? MR. COX: That's correct. I would agree
program description occupies two paragraphs -- that's maybe a quarter of a page long -- and pretty much just parrots what GALL says as a program description? MR. COX: Yeah, that's true. But that --
again, you have to keep in mind that includes the reference to the NSAC-202L document. So essentially
we are incorporating that description into our program description. JUDGE WARDWELL: Do you have any
understanding of what we are struggling with here? MR. COX: I believe I do. Okay. I just wonder if
JUDGE WARDWELL:
you thought we were just somewhere in outer space, what are these people even asking for? MR. COX: I understand. I do. I
understand exactly why you are asking this question, but --
Page 1384 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Sutton. Let me ask, while we have this document up, we haven't heard from you, Mr. Mew. listed here, and you didn't approve it. Your name is Did you MS. SUTTON: behalf of the Applicant. Your Honor, Kathryn Sutton on I think you are also
struggling with a legal issue with respect to the use of the GALL. And, again, we would point you to
Entergy's Statement of Position that fully describes the Commission's position, particularly in Oyster Creek, on the use of the GALL and the incorporation of the GALL-described program into an LRA. And for that purpose, I will point you to pages 9 and 10 of the Statement of Position for ease of reference. JUDGE McDADE: Okay. Thank you, Ms.
disapprove it, or you just didn't get around to it? MR. MEW: I didn't hear the question. I
didn't hear the question. JUDGE McDADE: Okay. We have up Exhibit Do you see the first
000048, Entergy Exhibit 000048. page right on the screen? approval chain? MR. MEW:
You were part of the
No, Your Honor. Pardon?
JUDGE McDADE:
Page 1385 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
staff. that. MR. MEW: No. I do not approve CSI's Approval of this document is
document in this matter.
done through the Entergy process, which is EN-DC-149, which gives you steps in order to approve a document from a vendor. MR. COX: This is Alan Cox. I can clarify
If you go to the form from the EN-DC-149 that
Ian mentioned, you will find there is a cover sheet there with his name on it approving these. This is a
vendor supply document, so the vendor prepares it, reviews it, approves it, and then Entergy has another form that goes on top of this that gives the Entergy approval of that document. JUDGE McDADE: JUDGE KENNEDY: could hear from the staff. Okay. Maybe at this time we And I think we are going
to walk down the same path of, from the staff's perspective, what constitutes the Flow-Accelerated Corrosion Program? contained? Where is that description
And then we will go on from there. And I would like to hit on the consistency
with GALL and get the staff's perspective, what does it mean to be consistent with GALL? MR. HISER: This is Allen Hiser of the
The GALL Program on flow-accelerated corrosion
Page 1386 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
GALL AMP. is the program XI.M17. That we believe has the If
necessary detail for an Aging Management Program. there is a need for specific information -- for example, specific description of inspection frequencies -- then they would be provided there.
If,
for example, inspections needed to be performed every outage, then that would be provided in the GALL AMP. JUDGE WARDWELL: MR. HISER: Sorry. Where?
It would be provided in the For example, some
It would be specified.
of the AMPs specify that inspections should be performed every 10 years. This AMP does not have the
need for that specificity in this case. JUDGE KENNEDY: So would you agree with
Entergy as to where we would find the flow-accelerated corrosion description? the application? MR. HISER: In the application, it would Where would you look for it in
principally be in Appendix B. JUDGE KENNEDY: for that bright line. that Appendix B? And I think we are looking
How much material should be in
Can you shed some light on what you
feel would be the right level of detail that should be in Appendix B and carried forward? MR. HISER: Consistent with the process
Page 1387 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
that is used for information provided in the application, and the staff's review, one element has not been discussed is the Aging Management Program audits that we perform. And it is during those
audits, which are summarized in the SER and are described in our testimony, where we do a deeper review of the elements of the program. So that, for
example, is where we reviewed EN-DC-315 -- was a part of that AMP audit. JUDGE WARDWELL: Can you think of any
reason why some of those same things that you have discussed and bring up in the SER could not or should not be summarized in an applicant's Aging Management Program for flow-accelerated corrosion? MR. HISER: I guess what I would say is
the Commission has helped us to frame what is necessary within the application. And for an existing
program and a program consistent with GALL such as the FAC Program, the Commission has helped to indicate what level of detail is necessary. JUDGE WARDWELL: MR. HISER: And what did they say?
That describing consistency
with GALL was with a limited description of the program, which -JUDGE WARDWELL: Did they say that you
Page 1388 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
would take the applicant's word for it when they said, "We are consistent with GALL"? MR. HISER: No. And, again, that's why we
do the AMP audit is that we go to verify the -JUDGE WARDWELL: back to the beginning again? And then, aren't we right How -- it's not a matter Doesn't
of just saying you are consistent with GALL.
the Commission say you have to demonstrate -- they have to demonstrate that they are consistent with GALL. GALL. not? MR. HISER: Yes, it is. And you have done that It is not just a statement of consistency with It is a demonstration of consistency, is it
JUDGE WARDWELL: through your SER.
I mean, you have documented your
approach to that in your SER. MR. HISER: That's correct. So why doesn't an
JUDGE WARDWELL:
applicant just submit those types of things, or at least a general description, oh, not probably to the detail that you do certainly in your audits, but is it that challenging and that onerous in a very expensive application anyhow to go that extra step to provide some specificity as it relates to Indian Point? MR. HISER: Well, in the specific case for
Page 1389 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the FAC Program, I think we do not want a high level of specificity, because the program is an Aging Management Program that relies on inspection results, modeling, and predictions, to help to define the inspection scope and the inspection frequency. that was specified in the application, then the applicant -- well, then, rightly that's what they should be doing, whatever they specified. In this case, we think it is inadvisable to provide that level of specificity. We want the If
program to be a living program that responds to findings within the plant, within the industry, and makes accommodations based on those. JUDGE McDADE: But, Dr. Hiser, once you
have blessed their program, how do you ensure over time, over the next 20 years, that it will continue to operate as you understood it at the time of the audit, if it is somewhat ephemeral? And, again, what I'm getting at is you need to have adequate number of inspections. "adequate" is in the eye of the beholder. Well,
And you're
going to inspect at a certain number of locations, but you have to decide which one of those locations are going to be the most susceptible to flow-accelerated corrosion.
Page 1390 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
And the question is, in looking for guidance to see whether or not in practice the program is working as intended, where do you look? And, you
know, where do you then have your inspectors follow up to ensure that? Is there anything that they can look
to, or are they required just simply to look to something like the EN-DC-315? And if Entergy or any applicant chooses to change those procedures over time, how would the NRC address that? MR. HISER: Partly, that would be reviewed
through our reactor oversight process where the regional inspectors look at the programs that are being implemented at the plant. In general, for
license renewal -- let's get more specific to the FAC Program. The FAC Program is a longstanding, existing program at the Applicant's facility. So we
have a high level of familiarity with what they have implemented, and a high level of confidence that they have appropriately implemented the program. In general, for license renewal AMPs, we have regional inspections that look at how the plants have implemented the programs. One of those, the
IP-71003 inspection, is implemented just prior to
Page 1391 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
experience. entering the period of extended operation to assure that the plant has implemented programs consistent with their application. ways. The third, really, is based on operating If the plant suddenly finds that it is So those would be some of the
doing inspections and finding that it needs to do replacements, because they are no longer meeting their acceptance criteria on wall thickness, that would be an indication that maybe the program performance is not what it should be. So that would be one way that
we would be able to detect if there is a problem occurring. JUDGE McDADE: And then, what does the NRC
do with that information, given, from our standpoint, the somewhat vagueness of what is in the application? And, again, I'm starting with the premise -- and correct me if you disagree with this -- is that the guidance in GALL is somewhat general in nature. That
not only does the NRC, but clearly the Applicant, has a vested interest in following the principles set forth in GALL. They have a big investment in the plant. They don't want failures within the plant. problem that is down the road, if there is a The
Page 1392 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
difference of opinion between the engineers at the Applicant and the engineers at the NRC as to whether or not the -- and I don't want to use the word "application" the wrong way -- the application of these principles is no longer adequate, how is that resolved when you have these sort of general guidance criteria? MR. HISER: Well, I guess to just touch on
the first part, I don't believe that we would say that GALL is an implementable program. Management Program description. It is an Aging The licensee, or the
Applicant in this case, does have procedures that they use to implement the AMP -- EN-DC-315, for example. In terms of disagreement between the staff and the -- at that point the licensee on implementation of the program, I think those are things that the staff identified -- would identify during inspections, and that would be resolved as many differences of opinion are, regarding the appropriateness and necessity of what the licensee is doing. JUDGE McDADE: Okay. But am I correct,
then, that as you look at it, as we are going down this road from the Appendix B to NUREG-1801 to NSAC202L to EN-DC-315 to the system susceptibility
Page 1393 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
correct. evaluation, that each one of those progressively provides more detail, and that is all part of the Aging Management Program that they are committed to. MR. HISER: Yeah. I think that is
And, again, we do -- through our AMP audit,
we go down to that level of detail in terms of our review to assure that the -- not only are the merits of the program consistent with the GALL AMP, but also the details of the program provide what we believe is adequate aging management for FAC in this case. JUDGE McDADE: And would it be accurate to
say, if down the road there were changes in EN-DC-315, that in your view -- and "your view" not necessarily meaning Dr. Hiser's view, but in the view of the NRC, no longer were consistent with GALL, that that would mean that it was no longer consistent with the current operating basis. MR. HISER: I think we would evaluate how
the changes were made to the programs, and we would look at what impact those changes would have had. JUDGE McDADE: Right. And I anticipate,
of course, that there is going to be changes over time. As you indicated, you view this as a dynamic But if there were a difference of opinion
program.
between the engineering judgment of the Applicant and
Page 1394 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
of the NRC, if you concluded -- if the NRC concluded that it no longer met GALL, that that would mean it no longer met the current operating basis as well, and that would be something that would require action by the NRC. MR. HISER: I think that's correct. Okay. May I -- just in following Yes.
JUDGE McDADE: JUDGE KENNEDY:
up from that, if we talk about the regional inspection prior to the period of extended operation, I'm trying to visualize what sets the scope of that inspection. I have in mind Appendix B, and we have got a number of descriptions of Aging Management Programs contained in the application. Maybe help us
understand how the scope of that inspection is determined. Is it driven from Appendix B? You also
got quickly down into EN-DC-315, and I'm wondering -you know, I keep getting there. MR. HISER: IP-71003 inspection. Yeah. I have not performed an
But from some of the feedback
from the regions, they get to that level of detail also. So, but they are looking at it from somewhat of a different perspective. We are looking
at it from the perspective of adequacy of the
Page 1395 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
procedure in meeting needed objectives. They are
looking at it from the perspective of, how has it been implemented? So that they are looking at the results
and things like that, some of the documentation of the inspection findings and things like that. JUDGE KENNEDY: So what helped them get
from, for argument's sake, Appendix B down to that level? How do they get there, since what we start
with, what we have in front of us -- again, we have lots of testimony, but this all starts with the program description in Appendix B and -MR. HISER: Yeah. Well, partly it would
feed from the things that we have in the SER, the things that we have reviewed as the pieces of the program, if you will, that we think help to assure consistency with the GALL program and would just pretty much fall from that, using that as a starting point in their inspection. JUDGE KENNEDY: I mean, is it possible
that when the staff did its audit and inspection during the technical review of the license application they looked at a set of procedures that were X, Y, and Z, and then the regional inspectors come in a year or two, five years later, could there be a whole new set of implementing procedures? And I'm just trying to
Page 1396 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
understand how this -- either whether it's the chain of custody or the chain of data. I mean, I think we have been walked through this path a couple of times, and we all get to the same point. And I'm more comfortable when I
understand it at the Appendix B level -- again, Appendix B of the application. When we start moving
from there -- I am okay up to NSAC-202, but it is when we start moving beyond that that I -- I don't know how to think about that. Maybe you could help us understand from the agency's perspective how they look at it, following, let's say, the technical review of the application, how they start getting into the regional inspections and the scope of the regional inspections. MR. HISER: Well, I think the AMP
description in Appendix B provides sort of overarching elements of the program. And if the Applicant were
to, say, eliminate EN-DC-315 and come up with some new procedure, then it would have to meet the same objectives as EN-DC-315. I mean, it may have
different methods for doing things, may use a different code beyond CHECWORKS, for example. But it would still have to meet the essential elements of what is described in their AMP,
Page 1397 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
I'm not -MR. HISER: Yeah. I -what is described in the GALL AMP, and what is in Appendix B. JUDGE KENNEDY: struggling with. using CHECWORKS. And maybe that is what I'm
I think that -- let's say they stop I think that is a red flag, because
it is going to be described in the Appendix B, if they no longer commit to using NSAC-202. line. That's a bright
I think that is -- it is when we start moving
beyond that. And I really -- I think what I'm looking for is, is it okay to move beyond that if it is not called out in GALL? It is -- I'm getting the
impression that what is a clear attribute or a clear criteria, a clear technical issue that is stated in GALL, appears to make it to Appendix B. Are we really only talking about the stuff that, at least in this case, Dr. Hopenfeld is concerned about, the inspection frequency, which isn't in -- a clearly defined attribute in GALL, or the acceptance criteria? There probably was a question in there.
JUDGE KENNEDY:
Again, I think this -- it
-- is what we are trying to get to is, as Judge
Page 1398 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Wardwell has explained, where do you cut off putting the level of detail in the application? And now every
time we go down this path we move into an array of plant -- either fleet-wide procedures, implementing procedures, to get to where the detail is. But
eventually we end back up at Appendix B and start all over again. Now we are -- you brought up the construct of the regional inspection, and I envision them going back to the Appendix B and starting there. MR. HISER: Judge Kennedy, could I give We are talking
you one example that might help here?
about inspection frequency and number of inspections. I'm sorry. MR. COX: This is Alan Cox. I'm sorry.
JUDGE KENNEDY: to go on somewhere. MR. COX:
I'm looking for the light
Alan Cox for Entergy.
And I'm
-- you know, I'm going back to the Appendix B, the reference to NSAC-202L. NSAC-202L -- this is speaking
specifically about inspection frequency and number of inspections. Section 4.7.3 of NSAC-202L is titled "Remaining Service Life." JUDGE KENNEDY: I'm sorry. Where are you
Page 1399 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
page, Andy? MR. COX: That was it right at the bottom you. 000012. JUDGE McDADE: Mr. Cox, would it be up. JUDGE McDADE: Do you want us to pull up reading in Appendix B? MR. COX: This is in the NSAC-202L. Okay. Sorry. Hang on
JUDGE KENNEDY: just a second. Can I -Okay.
MR. COX:
JUDGE KENNEDY:
-- just so I can call that
Riverkeeper 000012 for that? JUDGE WARDWELL: Yes. That's Riverkeeper
helpful for us to be viewing that while you're talking about it? MR. COX: It wouldn't hurt. And what page are you on in
JUDGE McDADE: that document? MR. COX:
On page 4-25. Okay. I'm there. If you I beat
JUDGE WARDWELL: Just scroll.
You'll see the page.
select the whole page, it helps. MR. COX: Right there. Can you select the whole
JUDGE WARDWELL:
Page 1400 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
of that page. Basically, this is telling us -- it is This is what is
talking about remaining service life.
going to define the -- not necessarily the frequency but the timing of the inspections and the number of inspections. And the recommendation here is that we
determine the FAC, the remaining FAC service life, for each component. And once we do that -- if you flip over to the next page, it has got -- the last part of this section has got three bullets there. Depending on
what you find there, if the predicted service life is shorter than the amount of time until the next inspection, then you've got three options for how to deal with that component. You've got to shorten the inspection interval, due the inspection sooner, you've got to do a more detailed analysis to obtain more accurate value of acceptable thickness, or you've got to repair or replace the component. So using this approach, you
are going to look at that remaining service life. This is going to define which components have to be inspected during your next inspection. It
is going to define how long you have until you have to do inspections for those that may still have a remaining service life that is greater than the
Page 1401 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
minimum. So I guess I would contend that, based on this description right here, what is in NSAC-202L, this tells you how you are going to define the frequency and the timing of your inspections. I mean,
you could go to the EN-DC-315 procedure, which is going to implement this. You are going to find very
little differences in that procedure in terms of level of detail that go beyond this method that is described here. So, you know, when the -- when we look at, are we consistent with the program, we are going to do this again before we enter the PEO, we are going to come in and look at our procedures and say, "Do we meet what we said in the LRA? Appendix B?" Do we meet what is in
You know, we are going to look at this
and say, "Do we have a procedure that follows the NSAC method?" In Appendix A that is going to go into our SAR, part of our current licensing basis, we are going to have a statement that says we've got a program that is based on NSAC-202L. This is a recommendation out
of 202L to do this, to define your inspection schedule and frequency, scope -- scope and frequency. You know, so if we do something that is
Page 1402 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
different from this, then we are no longer consistent with what is now part of our current licensing basis in the SAR. I think -- I mean, to me, this describes
the -- it gives you the controls that you are looking for as far as how you would come in and say that we are consistent with what we need to have for a program that is described in Appendix B of the LRA. This is example is on -- again, on determining what components to inspect. And we talked
about the number of inspections and when to inspect them. There is also a section in here that talks --
we talked a minute ago about the system susceptibility evaluation. There is a section in here that addresses that, how you determine what systems are susceptible, so that would all go into the system susceptibility evaluation report as far as how you make that determination about what is included in the program. So I think you are going to find that there is very few details that are missing from what you have in Appendix B through the references to NSAC202L that are found there. JUDGE WARDWELL: And I think you have
selected probably a pretty good example, and it is one that is of reasonable interest to parties that are
Page 1403 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
wondering whether or not there is any consistency with GALL, whether you have an adequate Aging Management Program. Is it not feasible to paraphrase that, or even just incorporate that entire thing into your description of the Aging Management Program? And even
go a step further and say, you know, at Indian Point we have -- there has been -- you know, this is the -you know, the average results, or put some bounding -I don't want to use that phrase, because we're going to use "bounding" for something else -- but, you know, get our arms around how often and to what degree you have -- your experience at Indian Point has been to date, so that someone has an idea of what may take place in the future, because, as we say, it is -- at least your position is that it is linear with time. So things probably aren't going to change drastically is what I referred -- inferred from that. So what is -- is it not feasible to put that in your Aging Management Program? MR. COX: It would be feasible, and we do
put some things in -- we do put some operating experience into the LRA that talks about the fact that the program is finding wall thinning. It is being
able to tell us when we need to go make repairs before
Page 1404 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the LRA. we get to -JUDGE WARDWELL: MR. COX: But this isn't --
-- loss of a function. What you just described This is how you are going
JUDGE WARDWELL: isn't operating experience.
to move forward with your Aging Management Program. MR. COX: You know, we could put more in
You know, the yardstick that we are being
judged against is the GALL Report and the references in the GALL Report. You know, if we put steps in
there that were identical to what is in the GALL Report, you could look at that and say, "Yeah, you've demonstrated you are consistent." You know, by copying what is in the GALL Report you could say that you are -- that's a demonstration of being consistent with GALL. I mean,
you could copy it and say, "This is the ending point program," but have you really -- I mean, I think the thing that we struggle with is, have you really included -- have you really added any additional information to the process if you are repeating what is in the GALL Report? I mean, that's what -- you know, you could put something in there that is not verbatim out of the GALL Report. Maybe it's in our own words, maybe it's
Page 1405 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
paraphrased. And, you know, then depending on how
close it is to what the GALL Report is, we start getting questions about, "Well, you're not using the same words as in the GALL Report, so is this really demonstrating that you are consistent with GALL, if you don't -- if you describe it in some other way?" JUDGE WARDWELL: People my age are
starting to look towards retirement, and some people my age in retirement may be very interested in what is going on at Indian Point. wonder about this. mechanical stuff. corrosion." Do you think it's very easy for them to pick up or even find what is your Aging Management Program, and then determine whether or not it is consistent with GALL? MR. COX: Well, I think, you know, is that And they say, "Gee, I
I know a little bit about I'm interested in flow-accelerated
something you can do without coming onsite and auditing implementing procedures? That is I guess the
quandary that we're in here is, how far do you -- how far do you go in terms of putting procedures -- actual procedures for how you are going to do this. know -JUDGE WARDWELL: Could you get any less You
Page 1406 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
words in your Aging Management Program than currently exists? MR. COX: We could try. Thanks. You know, that -- again, we
JUDGE WARDWELL: MR. COX: No.
have kind of agreed with the -- through the industry. We worked with NRC to come up with this format of describing programs. And, again, I think there is a
lot more there than what appears to be, if you look at that one paragraph. I mean, you've got to pull the
threads, and you've got to look at the other references that are there. JUDGE KENNEDY: I think this is a good
example because GALL doesn't point NSAC-202 specifically under this attribute. But you were able
to get us to inspection information without taking us the EN-DC-315. And I guess if we keep working this
puzzle, is there more of this? MR. COX: Well, I think you could find The scope of the
other examples similar to this.
program I believe does point you to NSAC-202L, although it's not in this specific element. correct on that. You're
But I believe we are -- We do
consider that we're tied to implementing the recommendation NSAC-202L for that element because of
Page 1407 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
what's stated in the scope of the program and the program description before that. JUDGE WARDWELL: How many aging management Have you
plans have you written for other plants?
only written Indian Point's or been involved with other applications from Entergy? MR. COX: I've been involved with all of
the applications for Entergy and several others in addition to that. JUDGE WARDWELL: How does the aging
management plan differ at your other plants compared to what we're reading for Indian Point? I would
assume they'd be pretty much exactly the same. MR. COX: When you say aging management
plan, are you referring to the -JUDGE WARDWELL: What's in Appendix B of
your license renewal application. MR. COX: Again, the program, for the FAC
program, it's going to be very similar to this for the other plants. JUDGE WARDWELL: virtually identical? MR. COX: Virtually, yes. Thank you. And again, Mr. Cox, your Would you say it's
JUDGE WARDWELL: JUDGE McDADE:
Page 1408 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
position, you're the team manager for license renewal for Entergy. MR. COX: That's correct. So you'd be involved in any
JUDGE McDADE:
license renewal for any of the nuclear plants that Entergy owns. MR. COX: That's correct. I think I would like to go
JUDGE KENNEDY:
back to Dr. Hiser and talk a bit about this consistent with GALL concept and what the staff does to ensure that it's consistent. A two-part question. How do
you communicate what consistent with GALL means and then how does the staff assess that a particular Aging Management Program is consistent with GALL? MR. HISER: Could you clarify what you
mean communicate what consistent with GALL means? Communicate within the GALL report? JUDGE KENNEDY: Within?
I guess when you know
someone refers to a particular program for, say, Indian Point as being consistent with GALL what does that mean? Is it verbatim compliance? Is it -- I'm
looking -- Let's just stay on that one first and then we'll go to the other part. MR. HISER: Yes. I'm looking for -Verbatim compliance is
what we look for when we review when we perform, for
Page 1409 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
example, our AMP audit review. We look at the central For
items that are called out in the GALL AMP.
example NSAC-202L was one thing that is called out in GALL. When we did the AMP audit at Indian Point we were at Revision 2 of GALL or Revision 1 of the GALL Report. It called out Revision 2 of NSAC and it So through our RAIs
appointed implemented Revision 3.
they identified that as an exception to the GALL Report because they used a different revision. And we
had not accepted it within GALL at that point in time. So the verbatim compliance is one of the essential parts of our review. JUDGE KENNEDY: In this particular case
for flow-accelerated corrosion where the inspection frequency is not explicitly specified nor is a reference to NSAC-202 at least at that GALL element specified, what would the staff do in that case? MR. HISER: Well, I think in this case the
way the NSAC-202L is called out under the program description, I think that permeates all of the elements. So we would expect that each element would For example,
be addressed by the NSAC in general.
inspection frequency would be clearly something that's --
Page 1410 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE KENNEDY: So because the NSAC
document is in the program description, that should trickle or at least flow through the other attributes I guess unless there's a conflicting guidance. would that not be the case? 25 inspections. MR. HISER: Yeah. Then we would expect Or
Let's say it's specified
that to be in the applicant's description of their program. JUDGE KENNEDY: Is that true in other
Aging Management Programs if some overarching reference is called out in the program description? Does that generally flow through the other attributes? MR. HISER: In some cases, but every AMP
is a little bit different because the aging concerns are different. The materials, the component, So it's really hard to say.
everything is different.
In this case, the EPRI NSAC Report provides sort of a self-contained program if you will because the way it was developed and the purpose that it was developed for. And I guess the one thing that I would just to go back I think I used the word or the phrase "verbatim compliance with the GALL AMP." actually be "verbatim consistency." And it would
Since the GALL
Page 1411 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
wiggle room. JUDGE KENNEDY: And if there was such a AMP is guidance, it does not have any requirement or really compliance aspect to it. So it would be a
consistency with the -- It's verbatim consistency with what is in the GALL AMP that we would seek to evaluate. JUDGE KENNEDY: of a verbatim nature though. So the consistency is one It's not -- It needs to
be within -- It's close and there are some engineering judgment applied by the staff. Do we need to take
away from here that it is intended to be, if it's consistent with GALL, a verbatim consistency? the best way to -I'm looking to see if there is any wiggle room in this consistency. struggling a little bit. MR. HISER: I think there's very little And I think we're Is that
wiggle room, where would I go to find out what the delta is? How much wiggle is in there? MR. HISER: Well, the wiggle room would be
identified through exceptions to GALL, things like that. And that would be the thing that would help to
identify the things that were not verbatim consistent with the GALL AMP.
Page 1412 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE KENNEDY: So if there wasn't
verbatim consistency, then the staff would pursue a path where we would see an exception to GALL here or an enhancement to GALL or something. you're trying to tell me? MR. HISER: We would ask RAIs for example Is that what
with the Indian Point application, the Revision 3 of NSAC-202L versus Revision 2 with something that we identified that was not verbatim consistency. JUDGE KENNEDY: So if we have verbatim
consistency, then it's consistent with GALL. MR. HISER: Yes. If we don't have verbatim
JUDGE KENNEDY:
consistency, then we see an enhancement or an exception to the GALL AMP in the program description. MR. HISER: Then the -Or in the application.
JUDGE KENNEDY: MR. HISER:
Yeah, the application should Absent
then identify enhancements or exceptions.
that, then we would expect there to be verbatim consistency. JUDGE KENNEDY: Do the exceptions and
enhancements carry forward in the program description or how do they move forward with -- You know, as we move away from the application phase into the period
Page 1413 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
of extended operation, what captures enhancements? MR. HISER: They would be captured within So, for example, we
the safety evaluation report.
would review an AMP that was purported to be consistent with GALL. We would evaluate exceptions or So that would sort of set
enhancements at that point.
the criteria for what the AMP should meet. Then as the applicant implements the program, that would then -- Those would be embedded within the program. So I'm not sure that it would be
possible to pull the thread and say, "Well, this aspect of the program was enhancement. This part was
exception" other than going back to the SER. JUDGE KENNEDY: I don't want to put words
in your mouth, but I'm almost hearing that if the Aging Management Program is not verbatim consistent with GALL there would be some verbiage in the program description that would clue us in to this either enhancement or exception. MR. HISER: There should be, yes. There
would be multiple places within the application, within RAI responses, within the SER. JUDGE KENNEDY: Maybe that brings -- Maybe I'm perceiving
that's where I'm getting confused.
that the Appendix B to the application is what carries
Page 1414 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Appendix A. MR. HISER: the application. That would be in Appendix A of forward. Is there more that carries forward the
commitments that Entergy's made that I'm missing here than Appendix B? MR. HISER: Yes, there are commitments
within Appendix A of the application. JUDGE KENNEDY: Appendix B plus Appendix A. MR. HISER: Yes. And that, for example, So I may need to use
if an applicant needed to implement enhancements to their existing program so that it met the description of the GALL program -- so they wanted to implement a program consistent with GALL, their current program had gaps. So they had enhancements. That would be
called out through a commitment as the fact that the applicant would implement those enhancements prior to PEO through some other time frame. JUDGE KENNEDY: And that would go in
And that would be specifically
subject to review of inspection during the IP-71003 inspection. JUDGE KENNEDY: Can you clarify for me
exactly what the difference is between Appendix A and Appendix B and why do we have both of these and what's
Page 1415 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the AMPs. the difference? MR. HISER: Appendix B is a description of
Appendix A provides I believe the UFSAR So
supplement and our list of commitments normally.
a list of commitments is that there are actions that the applicant is committed to perform as a part of its application. JUDGE WARDWELL: Is Appendix A more what's
taking place right now at the plant? MR. HISER: The UFSAR supplement is
implemented within a certain time frame after issuance of the renewed license. Commitments would I believe
in almost all cases would be implemented prior to the PEO, the period of extended operation. JUDGE WARDWELL: And I'm looking at It is four
Appendix A for flow-accelerated corrosion. sentences long. MR. HISER: supplement description.
That's probably the UFSAR I guess I'm not certain for
Indian Point that commitments for implementation for example, enhancements or exceptions may be in different places. I know in many cases they're in
Appendix A application. JUDGE WARDWELL: But the program it's
referring to here is what's in place at the time of
Page 1416 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the application or current licensing basis or I don't know what the right word is. MR. HISER: In general that would
represent the program that they will have implemented prior to entering PEO. In the case of the FAC program
because it is an existing program, then it also would be consistent with what they're doing today. JUDGE WARDWELL: That's where I got
confused because the very first sentence says, "The Flow-Accelerated Corrosion Program is an existing
program that applies to safety related and non-safety related..." and it goes on. A one sentence paragraph. And then the second paragraph starts off, "The program..." which I assume you were referring to the existing program there. MR. HISER: Yes. So that's unique in this And that's one sentence.
JUDGE WARDWELL:
situation for flow-accelerated corrosion because they do have an existing program. Accelerated It's not -- This Flow-
Corrosion Program that's the existing
program, is that a single document or is that something like our AMP that's kind of a hierarchy of detail as we meander our way down as we pull the thread to get down into further and further details.
Page 1417 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
MR. HISER: Maybe I would be represented
EN-DC-315 and the other procedures that implement. JUDGE WARDWELL: So there's no document
that sits on anyone's table with the title sheet saying "Flow-accelerated corrosion program" that exists more than four sentences long. MR. HISER: Well, the EN-DC-315 if you
look at the title of it is "Flow-accelerated corrosion program." So in essence that probably is the highest
ranked procedure if you will that then implements the other procedures. But I would expect that the FAC
engineer probably has a notebook that's probably about that thick that would have all of the procedures that exist to implement the program. JUDGE WARDWELL: somewhat what you just said. Sure. So that is
Isn't that consistent I don't I guess
with a statement that or a question I asked. know whether it was a statement or question. I hope it was a question.
The transcript always
amazes me on how blabbering I am when I look it over. But the EN-DC is in essence their AMP. with that statement? MR. HISER: That is the implementable Do you agree
program is probably the way that I would look at it. Yes.
Page 1418 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
steps. JUDGE WARDWELL: answer I got from Mr. Cox. JUDGE KENNEDY: So going back to Part 2 of Close enough to the same
the question, could you describe the process the staff uses to determine or assess consistency with GALL as in this case the Flow-Accelerated Corrosion Program? What's the process that it's gone through? MR. HISER: The process has a couple of
Probably the most significant is the AMP audit
that we perform where we go to the plant facility, review all of their background documentation, normally their implementing procedures for the program to make our evaluation of whether their program is consistent with the GALL AMP. So through that and then through
any RAIs or requests for additional information that would be necessary as a result of that AMP or from our review of what is in Appendix B of the application is how we would evaluate that specific AMP. MR. YODER: Matthew Yoder from the staff.
I'd like to add that even for an AMP that is verbatim consistent with the GALL there is a potential for the staff to ask for additional information. For
instance, if we had operating experience from that plant or from another plant about a specific system, we would ask questions to the licensee and probe that
Page 1419 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
issue. So just because there's this verbatim
consistency, there are additional things in addition to the audit that the technical staff that are reviewing that application probe those type of issues as well. MR. HISER: I think the one thing that's
in Appendix B that we haven't talked about is the description of operating experience. And I think in
the case of the FAC program that actually has more line space, if you will, than the program description. JUDGE KENNEDY: As we were talking about
before this concept of verifying the consistency with GALL, is this the process that I should take away as how the staff does that, this audit and inspection of the Aging Management Program possibly followed up by RAIs and so on and so forth? MR. HISER: Yes, that is the way that the
staff evaluates consistency with GALL pretty much for all AMPs. JUDGE KENNEDY: MR. HISER: Did you mean pretty much? I So
No, I do mean all AMPs.
guess the thing -- This is an existing program. this one has a very long track record. well-worn path with this program. programs are not as longstanding.
So it's a very
Some of the other
Page 1420 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE KENNEDY: Is that to say the staff
has a lot of experience at interacting in this case with Indian Point on a Flow-Accelerated Corrosion Program related issues? MR. HISER: Is that what? Well, we have a track record
in terms of Generic Letter responses and things like that. JUDGE KENNEDY: MR. HISER: Okay.
Also we're a part of the
review that we did of the Indian Point application. JUDGE KENNEDY: Okay. Thank you. I've
got a couple of thoughts and unfortunately I can't see Dr. Hopenfeld. site line. DR. HOPENFELD: JUDGE KENNEDY: Sorry. It's not your fault. It's You're behind the -- I've lost visual
the big guy needs a monitor here. DR. HOPENFELD: there has been annoying. JUDGE KENNEDY: skylight up here. DR. HOPENFELD: JUDGE KENNEDY: Okay. I think we're hearing It's raining. There's a The background noise over
through the microphones is all the rain coming down. DR. HOPENFELD: My hearing is not that
Page 1421 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
your mouth. great. That's why. JUDGE KENNEDY: I just wanted to ask you
a couple of questions before we leave this whole topic. DR. HOPENFELD: JUDGE KENNEDY: Sure. Maybe I'm putting words in
The focus on inspection frequency,
inspection methods and repair and replacement criteria. DR. HOPENFELD: JUDGE KENNEDY: discussion here. Okay. You've heard all the
Is there something you'd like to Why
point out to us why you think that's significant?
you think they haven't possibly answered that question here today? DR. HOPENFELD: just go slow. Yes, absolutely. Let me
One thing there was a statement made by
this gentleman that the corrosion that they have observed is linear with time. critical statement. And I've looked. I haven't seen any data. That's a very bold
They haven't provided us any data based on my experience, knowing the literature and talking to a lot of people and just the theory of it because the geometry changes with time. Maybe it's uniform in a
Page 1422 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
straight section. I have no problem with that. But
the geometry changes. The question is what happens in an orifice, what happens in a bend, the one I showed you, and there are many, many of those in the plant. haven't shown us on iota. They
They haven't shown us one
piece of data to back it up. I have looked at some data from Japan over 4,000 or 5,000 or 6,000 hours and these are average values. values. value. Again, please just remember these are average Of interest to the ASME code is the local You don't know what it is. The only way you
can do it is by very close inspection and using a smaller grid that they are using. The probe sight that they are using for these kind of variations that you have is too large. They don't have the sensitivity. answered your question. JUDGE KENNEDY: reaction from Entergy. Maybe we can get a I don't know if I
The linearity issue first
maybe and then I guess it speaks to inspection method. I think that's what Dr. Hopenfeld is trying to raise. MR. ALEKSICK: Thank you, Your Honor. I can
This is Rob Aleksick again for the Applicant. comment on the linearity part.
I'm not the right one
Page 1423 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
to talk about the inspection technique. I'm trying to find -- There are many places where it's documented that as I said under constant operating and chemistry conditions FAC rates are linear. I read that say downstream of an orifice
if that orifice wears away over the course of many years and the inside diameter thereby increase, then FAC might not be linear there because the operating conditions have changed. circumstance. And in general if you give me a moment I'll find a reference if you'd like to point out the fact that FAC is linear. JUDGE KENNEDY: It would be most useful if That's a somewhat unusual
you could give us an exhibit that's within the record here today. MR. ALEKSICK: JUDGE WARDWELL: Certainly, Your Honor. And what about an elbow? Are they the problem
We've heard a bit about elbows.
that -- How would you respond to that potential problem of the change in direction of the fluids? MR. ALEKSICK: Well, I would point out
that FAC wear rates are not consistent within an elbow. One portion of the elbow may wear more rapidly But at each location under consistent
than another.
Page 1424 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
higher? MR. ALEKSICK: Six inches. I think six conditions the wear rate will be linear at that point. In recognition of that fact, we inspect the entire elbow as well as upstream and downstream of it in a fairly extensive grid pattern so that we can see wear patterns as they develop over time. That's
the reason for the inspection technique that we use. JUDGE WARDWELL: Do you have a rough
dimensions of elbows and what is this grid pattern? Give us a feeling for the coverage. MR. ALEKSICK: Sure. That information is
spelled out in painful detail in various procedures. But roughly speaking up to about a ten inch nominal pipe size, we would be looking at a one or two inch grid spacing. Between 10 and 20 inches we would be
looking at maybe two, three, four inch grid spacing. And above 20 inches it would be a little bit higher than that. JUDGE WARDWELL: What's a little bit
inches is the maximum acceptable grid spacing. MR. MEW: Ian Mew for the Applicant.
NSAC-202L gives you a recommendation for grid sizes for different pipe sizes. it's a one inch grid. Between one to six inches,
Six to eight or eight to ten
Page 1425 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
what? it's like three inches. Twenty inch is five inches. Those are the
And above that is a six inch grid.
recommendations from NSAC-202L which is incorporated in EN-DC-315. JUDGE WARDWELL: And that grid spacing
wraps around the entire elbow. MR. MEW: That is correct. And that grid spacing is
JUDGE WARDWELL:
Where you take measurements or where you
perform the CHECWORKS analysis or both? MR. ALEKSICK: If I might, it might be If we
helpful since we have NSAC-202L up already.
could move to page 4-11, there's a figure there. JUDGE McDADE: Also let me just interrupt
for a second particularly when we're bouncing back and forth between witnesses. state your name. Again, it's important to
For example, Mr. Mew, you didn't But I just want to make
state your name beforehand.
sure that the court reporter has down who said what. So after the fact, when we're going back and forth between witnesses, start it off by saying your name and then that way the appropriate person will be attributed. MR. MEW: Sorry, Your Honor. Thank you for the reminder,
MR. ALEKSICK:
Page 1426 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
mean? MR. ALEKSICK: That is an indication of if Your Honor. JUDGE McDADE: to cut you off. Thank you. I didn't mean
Go right ahead. Page 4-13. You went a
MR. ALEKSICK: little too far. There we go.
There we go.
Just slide down a bit.
That's a nice illustration of what a It's roughly to scale. And you can
grid looks like.
see that the data points are collected at the intersections. So when we unwrap that grid we end up
with a rectangular matrix of wall thickness measurements. JUDGE WARDWELL: What's the squiggly scan
wall thinning is observed at a point on the grid the procedures call for what's called a refined grid or a scan. In other words, if we observe where at the
intersecting grid points we inspect in more detail either through a scan and/or a smaller grid around that area. And I might point out that on the very next page 4-15 is the table that Mr. Mew was referring to earlier that provides guidance on the specific grid sizes. JUDGE KENNEDY: So how does CHECWORKS do
Page 1427 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
limiting? MR. ALEKSICK: I mean limiting in the with elbows, predicted versus measured? MR. ALEKSICK: JUDGE KENNEDY: I'm sorry. I didn't hear.
I guess I'm thinking back
to the opening presentation and the focus on elbows and the challenge about erosion. Does CHECWORKS --
How does it predictive measure compare for these elbow type? MR. ALEKSICK: CHECWORKS provides a single
prediction of wear rates and wear for the entire elbow. It does not predict on a grid basis like that.
So it gives us essentially the limiting case of wear. And when we go and inspect it although we consider every single measurement, there are typically 100 or 200, perhaps more, measurements for each elbow. But
we reduce that data to a single value of wear, the maximum that is representative and limiting for the entire component. JUDGE WARDWELL: And how do you know it's
sense that it is the maximum value of wear for the component. JUDGE WARDWELL: CHECWORKS predicts? MR. ALEKSICK: Yes. Yes, Your Honor. And you say that's what
Page 1428 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
it this way. JUDGE WARDWELL: predicting the maximum? MR. ALEKSICK: Well, the intent and the And how do you know it's
design criteria for CHECWORKS were set up to do that. CHECWORKS gives us a single wear rate per component that is the maximum expected on the component. JUDGE WARDWELL: For those conditions to
go into that, the various F factors that go into the calculation, is that correct? MR. ALEKSICK: JUDGE WARDWELL: Yes. But that doesn't mean
that -- Does CHECWORKS know it's an elbow? MR. ALEKSICK: Yes. Each component has a
specific geometry code to indicate it's an elbow or reducer or etc. JUDGE WARDWELL: I guess I still don't What do
understand on how you know it's a maximum. you input that dictates it's a maximum? MR. ALEKSICK: want to answer that one. DR. HOROWITZ: Jeff Horowitz.
I think Dr. Horowitz might
Let me try
We have defined geometry factors which
relate the corrosion rate in the straight pipe to a given fitting. And we use that as a maximum value.
So whatever the number is -- Dr. Hopenfeld used 1.6 --
Page 1429 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
say that's correct, it would be 1.6 X the straight pipe. And that will be the maximum we expect to see
on the elbow. JUDGE McDADE: Perhaps if I could before
we wander too far, this discussion got started when Dr. Hopenfeld opined that the corrosion is not linear. The question then passed back to Entergy to demonstrate that it is. And in the preface to that,
you indicated I believe that you believed that it would be linear except when there were operating parameters that changed. And my question from that is do you have a way of predicting or identifying when those operating parameters have changed so that you would be alive to the possibility of a nonlinear progression of the flow-accelerated corrosion. MR. ALEKSICK: One of the duties of the
FAC program engineer is to maintain awareness of the plant, the state of the plant. So design changes,
operational changes and other items that might affect the rate of FAC, it's his responsibility to be aware of those. In some cases, it's a very obvious event like the power uprates that occur. Then we knew the But in
pre- and post-operating conditions there.
Page 1430 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Honor. addition to that if, for example, a train of heaters is valved out for a period of a few months for maintenance or other reasons, those are the sorts of things that the FAC program owner maintains awareness of and makes the appropriate determinations on how that might affect the wear rates. JUDGE McDADE: And showing more than a
minimal degree of ignorance in metallurgy, particularly if you had a situation where you had an elbow that you described, would it not be possible there for a sum of the oxidized metal to break loose creating a cavity and then having that cavity increase the rate of corrosion or erosion where that cavity is? And if that's not correct, tell me. But if it is correct, how would you predict it or identify it? MR. ALEKSICK: That is not correct, Your
Although the surface roughness can change over
time -- it does change over time -- it's not the case that metal breaks off from the interior of the pipe and leaves a cavity. The metal essentially dissolves
slowly over a period of time and a 10 or 20 year old piece of pipe will have a greater internal roughness than a newly manufactured one. That is true.
But through observation and through -- I'm still looking up to find the right pithy reference for
Page 1431 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
you. Entergy. you. But I can just tell you through experience of 23 years in this field the wear rates are linear and you can plot a measurement that at 1992 and then inspect the same component in 2002 and in 2012 and you will see a linear progression of wear. MR. KUYLER: Your Honor, Ray Kuyler for
If I can reference the witness's
recollection, I believe the issue of linearity with time is discussed in Answer 53 of Entergy's testimony and there's a reference to Dr. Horowitz's book on Flow-Accelerated Corrosion which is Exhibit 000036B. JUDGE McDADE: JUDGE WARDWELL: refreshment of your memory? MR. ALEKSICK: Yes, Your Honor. Thank So Thank you. Was that a correct
We are just opening that over here as well.
in that answer we point to the flow-accelerated corrosion in power plants book. JUDGE KENNEDY: I guess, Dr. Hopenfeld,
let's come back to you and talk about the repair and replacement criteria. testimony they == JUDGE WARDWELL: interrupt quickly? JUDGE KENNEDY: Yes. Wait. Can I just It seemed like in Entergy's
Page 1432 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE WARDWELL: what they just said? What's your response to
Why aren't you satisfied with
what's there in regards to -DR. HOPENFELD: I'm not a very good Some of these are
communicator on stuff right there. complex problems.
I was trying to explain that the
heart of the problem is in the definition of what corrosion is. If you say it's a dissolution problem, these F1, F2, F3, what they had are okay. And the
conclusion that it's fairly linear, especially linear for straight section, is also okay. It's also okay to
say that it's not that much different whether it's an elbow or it's an orifice. 1.6, 1.2, whatever. But when we're talking about the fact on the high turbulence and that's what it is -- the key is the turbulence -- it's not just only the velocity. It's the local turbulence. local. It can be very, very Let me tell me It's maybe by a factor of
It can be just around a weld.
how my experience of it. JUDGE WARDWELL: Before you do that
though, I just want to -- I'd like you to answer the question I'm specifically interested in. DR. HOPENFELD: Yes.
Page 1433 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
NSAC-202L. JUDGE WARDWELL: Okay. NSAC-202 shows a Applicant. okay. JUDGE WARDWELL: EN-DC whatever. Yeah. JUDGE WARDWELL: rest of that. And let's move on to the
And that is as far as what they're
doing for elbows you do not have any criticism of that approach. And is that not a pretty good approach for
measuring the elbow to reflect the changes in the wear rates around the elbow? DR. HOPENFELD: trying to answer. on averages. maximum. Okay. No. That's what I was
They are basing their measurement What they report is not the
The equation cannot report maximum. JUDGE WARDWELL: No, I mean in regards to
measurements.
The grid measurements in ED, isn't it? The grid measurement is
DR. HOPENFELD:
EN-DC-315 is what we were looking at. that?
Is that correct
That had the grid sizes and all that stuff for
the elbow. DR. HOPENFELD: MR. ALEKSICK: No, Your Honor. JUDGE WARDWELL: MR. ALEKSICK: Okay. NSAC. Oh. Rob Aleksick for the
Yes, we are looking at
Page 1434 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
diameter. DR. HOPENFELD: It's up to the user to grid pattern for what and requirements for grid patterns around an elbow where they take actual measurements. Are you satisfied with that approach?
Do you have any criticisms of that approach? DR. HOPENFELD: I have a criticism with This is
this table in the sense that this is general. for any situation. JUDGE WARDWELL:
As it relates to pipe
look at this data and say, "Hey, I'd better look, get a better grid." And I don't see that here. I have no
problem with these general. I'm familiar with it. That's what you do.
I looked at it before.
Then you get it everywhere.
You're trying to minimize the amount of money that you're going to spend on inspection. If
you make that grid too small, pretty soon you're going to run out of money. So I think this is good. question about it. There is no
But when you look at your own
plant and you have this idea that the whole thing is not really local and you don't really understand it because the equation tells you it's not that bad, the only way you can do it is to run -- I said it before
Page 1435 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
and I'll say it again -- CFD codes. And that those do, they go to the fundamental equation to describe the turbulence anywhere around. And they have models from this.
Twenty years ago, we didn't have those computer codes that could predict that kind of stuff. But now we are at a point that we can predict very accurately using turbulence models. run the computer codes takes a long time. But you To
come up with a fairly good prediction as to where you're going to have the maximum corrosion rate. This
is still based on the assumption that it's based on metal dissolution. When you come to the situation when the process is controlled by both corrosion and the synergy, all bets are off. that. We don't have a theory for You have to really
You have to do something.
start from scratch from a clean piece of paper. JUDGE McDADE: Okay. Dr. Hopenfeld, if
you could just for me to clarify something. DR. HOPENFELD: JUDGE McDADE: Yes. Could you explain your
understand of impingement corrosion and cavitation erosion? DR. HOPENFELD: Yes.
Page 1436 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE McDADE: applicable here? DR. HOPENFELD: Sure. They're all FAC And how those are
corrosion because -- Let's take cavitation erosion. On ships you probably know that the propeller usually gets a lot of cavitation corrosion. What it is, you have bubbles that next to the surface explode. As a result of their exploration, there is a tremendous pressure and stress imposed on the surface. When you have it many, many times, you've
achieved the surface and you basically corrode the surface. Now the reason I would call it also FAC because usually these things happen when the pressure changes suddenly. changes. That's when the vapor pressure
That's one cavitation. Droplet corrosion occurs in wet steam and
usually an extraction line.
And you can see it very
clearly because there are hundreds of components which erode and they have many leaks of those, too. Luckily, it's not in the major safety part of the plant, but some of them are. But what you have there is you have where the droplet condenses it just impacts the surface. you do that thing many, many times, you erode the If
Page 1437 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Entergy. surface. That's a mechanical aspect. Now the other aspect of it which is more common in other lines is where you have sand in the line. Now in the case of nuclear power plants, we
don't really understand because most of the stuff that you -- Once the corrosion -- are soluble, but there may be some which are not. And if you sit there 20
years and bounce and bounce on that, what do you think is going to happen if some of those are not soluble? JUDGE McDADE: But as I understand your
testimony, part of your testimony is because CHECWORKS does not take into consideration impingement corrosion and captivation erosion. of wear. DR. HOPENFELD: JUDGE McDADE: Correct. Okay. Let me ask to It is not a valid predictor
You've indicated that neither of those are Is there
really part of flow-accelerated corrosion.
any way that CHECWORKS identifies either of those impingement corrosion or captivation erosion? CHECWORKS identify them? MR. ALEKSICK: the Applicant. This is Rob Aleksick for Does
No, Your Honor, CHECWORKS is not
designed and does not predict degradation due to cavitation erosion or liquid drop impingement.
Page 1438 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
parts. JUDGE McDADE: Now why do you consider
that those aren't part of flow-accelerated corrosion? MR. ALEKSICK: Well, let me answer in two
First, from a definitional perspective,
Entergy uses the term "flow-accelerated corrosion" in the same manner in sort of a standard academic definition that's used by EPRI and in many of the documents that we have had as exhibits. Flow-accelerated corrosion is a pure corrosion process. That is not to say that other degradation mechanisms are not active. JUDGE McDADE: And by corrosion here
you're talking about a chemical as opposed to a mechanical process. MR. ALEKSICK: Yes. Precisely. Other
degradation mechanisms may occasionally or rarely be active in the same piping systems that flowaccelerated corrosion is active. And in fact the
Flow-Accelerated Corrosion Program at Entergy does address those degradation mechanisms, but not through the use of CHECWORKS which is not designed to predict those forms of well loss. JUDGE McDADE: Okay. But your testimony
is although CHECWORKS doesn't address this there are other aspects of the aging management program that
Page 1439 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
again. McDADE: will identify those portions of the system that would be susceptible to erosion as opposed to corrosion. MR. ALEKSICK: Yes, Your Honor.JUDGE
And what would those be? MR. ALEKSICK: Well, I would point you to In general FAC is the
Question 51 in our testimony.
predominant damage mechanism active in the systems that we're discussing here. However, if there is
impingement or cavitation or indeed any other degradation mechanism the FAC Program is in a sense a wall-thinning program. And so through the use
particularly of operating experience as well as engineering judgment, those other degradation mechanisms are addressed. JUDGE McDADE: Right. And that's what I'm
trying to get you to elaborate for us here; whereas how do you identify where those other mechanisms are going to occur so that you can appropriately judge the frequency of inspection? MR. AZEVEDO: Yes. It's Nelson Azevedo
We identified those primarily through
operating experience both internal and external. JUDGE McDADE: Okay. Now by operating
experience meaning you've tested in certain places and you've identified either where there is or is not wall
Page 1440 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
experience. thinning. MR. AZEVEDO: Either that or through leaks
that have developed either at Indian Point or other facilities. JUDGE McDADE: Okay. When you say leaks
that have developed at other facilities, you've identified sort of generically those kinds of places that would be most susceptible to erosion so that you could then focus on them. MR. AZEVEDO: JUDGE McDADE: MR. AZEVEDO: JUDGE McDADE: Yes, that is correct. At the individual facility. That's correct. Okay. Is there anything
other than -- And I don't mean to put words in your mouth here. But it sounds like what you're saying is
engineering judgment is the basis for determining these other locations or locations subject to erosion as opposed to corrosion. Is there anything other than
engineering judgment based on past experience that informs your decision? MR. AZEVEDO: Well, I would say operating
I would classify that as a little bit But, yes, you're
different than engineering judgment. correct.
We don't have a predictive code like
CHECWORKS if that's what you're asking.
Page 1441 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
JUDGE McDADE: Okay. But what I'm
suggesting is the engineering judgment is based on the inspections that you have done in the past and also looking at inspections that have been done at similar facilities to identify those areas that are susceptible to corrosion or erosion here. MR. AZEVEDO: JUDGE McDADE: Yes, that's correct. Okay. Now I believe also
you indicated that it in your view is unlikely and we'll hear back from Dr. Hopenfeld in a second because I don't think he shares his view is that it's unlikely that you're going to see corrosion and erosion in the same pipe at the same time. why you believe that? DR. HOROWITZ: Jeff Horowitz. The reason And Can you explain briefly
is for the corrosion you need an outside layer. the erosion tends to destroy the outside with everything else. JUDGE McDADE: DR. HOPENFELD: Okay. Dr. Hopenfeld.
The reason I brought you
that large elbow before and -JUDGE McDADE: little bit if you could. DR. HOPENFELD: The reason I showed you Lean into the microphone a
that large elbow and many others but this one really
Page 1442 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
article. wrong. hypothesis? DR. HOPENFELD: But let me go now. There's a lot of things I have to go back. You illustrated the point. like 52 times. Remember I had a number there
You notice the erosion on the top and
the erosion at the maximum point was 52 times larger. If that's not a local thing on the same component, I don't know what local means. JUDGE McDADE: Dr. Hopenfeld and Dr. As I understood
Horowitz, correct me if I'm wrong.
the Entergy's position it's that if you have enough flow that you're not going to have the corrosion there. You're not going to have the oxidation. So
therefore if you have the corrosion, it is only going to be in a situation where you're not going to have significant erosion and visa versa. I correct? DR. HOROWITZ: JUDGE McDADE: Yes, you are. What's wrong with that Dr. Horowitz, am
make a good point.
And if you really want to get into
that, you may want to read the scientific article by Dr. Dick MacDonald. I think that's his name. Dick
MacDonald from Penn State. JUDGE McDADE: I've got you. I don't need to read the
Page 1443 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
what it is. DR. HOPENFELD: I know. Okay. Here's And And
You have a surface, a metal surface.
then you have a protective layer, outside layer. then you have fluid.
And when the flow is fairly low, The whole process is
the level of turbulence is low.
controlled basically by metal dissolution. When you go beyond that and it's not necessarily velocity and it's not very clearly defined yet, but you go through very, very high turbulence and at that point you have a situation that part of that outside layer is weakened. And the reason it's
weakened, the adhesion is weakened because the number of vacancies, the atoms are not that cohesive anymore. The outside layer is not coherent with the metal surface. It's easier for the flow shear to remove
part of the outside layer. At this point, you get in the situation that you have both, erosion and corrosion. a very difficult thing to describe. you have. And that's
But that's what You have
So you have a very low velocity.
a fairly smooth, slow situation where the corrosion rate is roughly proportionate to the velocity. Then you get over a certain critical velocity where the turbulence becomes very high and then the thing zooms. And if you go and look into the
Page 1444 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Horowitz. area. data and the literature, you see sometimes people say "Well, it's only a proportion only to the first power of velocity." Others they say it's as high as five.
What I'm getting to is a very complicated But we still don't know. But the point is it's
just not as simple as you heard it this morning. JUDGE WARDWELL: When one takes a
measurement of the pipe thickness, what does it measure? Corrosion or erosion or both? DR. HOPENFELD: probe doesn't know. It doesn't know. The
It just measures whatever it is.
It could have been who knows. JUDGE WARDWELL: from Entergy. Whoever wants to answer
Probably Mr. Aleksick. I'd like to try. Jeff
DR. HOROWITZ:
The presentation in Professor MacDonald's But it's assuming that the path is All the data and all the Looking
paper is fine.
critical velocity.
experiments assume that you don't get there.
at metal graphically at the surface, you see corrosion period. JUDGE WARDWELL: With the incorporation of
line correction factors into CHECWORKS, does not that line correction factor use a measured rate? DR. HOROWITZ: Yes, it does.
Page 1445 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
that. that. JUDGE WARDWELL: Doesn't that measured
rate as Dr. Hopenfeld said include whatever is taking place there if in fact you're wrong and erosion is taking place there? DR. HOROWITZ: But it's still corrosion. MR. ALEKSICK: And if I might expand on Yes, it does, Your Honor.
This is again Rob Aleksick for the Applicant.
Part of the process of modeling is to exclude degraded pipe that was degraded by mechanisms other than flowaccelerated corrosion. So if we have a pipe
measurement of thinned wall that was due to liquid droplet impingement, say, then the modeling analyst will not use that data to calibrate the CHECWORKS model. JUDGE WARDWELL: But even if there was a
small amount of erosion occurring at a given location the model somewhat handles it through a line correction factor which by necessity looks at whatever is thinning the pipe, not just corrosion if something else was taking place. Is that correct? First, it's our position
MR. ALEKSICK:
that erosion and corrosion don't occur simultaneously. JUDGE WARDWELL: I clearly understand
Page 1446 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
averages. later. DR. HOPENFELD: But I'm sorry. I go back look at it. CHECWORKS. MR. ALEKSICK: you said is correct. Yes. But I think in general what And that's part of the
reason for a calibration process. JUDGE WARDWELL: Dr. Hopenfeld, what is FAC CHECWORKS does to
wrong with that position then?
some degree incorporate whatever takes place there through this line correction factor. DR. HOPENFELD: No. But first of all you
Then you have to go back to the There is no prediction there because it There is no correlation of
varies by a factor of 10. anything. JUDGE WARDWELL:
Yes.
We'll get into that
to what the German said again. JUDGE WARDWELL: The lack of correlation
at least incorporates whatever is wearing it at that point due to line correction factor. DR. HOPENFELD: Yes, it's still based on
The only way you can do it, the only
possible way, is what has been occurring in the literature or in the last ten years. using CFD codes. It's people
You go back to the stock equation. And then you see exactly
You solve what's going on.
Page 1447 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
region. complicated. what the maximum is. Now there's a next step for somebody, maybe somebody that's going to be younger than I am, to look into how you can get over that critical velocity that Dr. Horowitz said. critical velocity only. But it's not the
See, it's not only velocity.
It's the turbulence that affects it. Velocity is an indication through the Reynolds number of geometry and turbulence. much more than that. You have to go to the You have to do the That's the level But it's
fundamental how these are created. fundamental instability of the flow.
you have to go and look at it before you draw conclusions. It's just not -- I hate to sound very It's not a straightforward answer. So
what it is you have a combined effect of erosion and corrosion over a certain period of time for a certain region. For low turbulence, it's okay. Everything
they do is perfect. But most of the components are not in that I wouldn't have any problem if they had a
plant running from here to China in a straight line. That would be perfect. I wouldn't be here. I almost hate to leave
JUDGE KENNEDY:
Page 1448 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Yes. JUDGE WARDWELL: We've jumped ahead of this erosion/corrosion issue. DR. HOPENFELD: JUDGE KENNEDY: I'm sorry. I said I hate to leave the
erosion/corrosion issue because I'm not sure we've really gotten closure. members of the Board. tomorrow? JUDGE WARDWELL: JUDGE KENNEDY: Yes, I have more. You've got more questions. And I may want to ask other Are we going to chase this
things and I still need to go back and tie some knots on. JUDGE KENNEDY: I think we'll move on. for Dr. Hopenfeld. We're pursuing your issues about the inspection frequency/inspection methods. And the one If that's the case, then
I've got one final question
last one I wanted to talk is the repair/replacement criteria. It seemed when we went through the
testimony with Entergy that they pointed to GALL that GALL had a criterion in there for minimal critical wall thickness. And then a decision would be made for
repair and replacement. I guess I'm really trying to understand
Page 1449 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
what your concern is over that issue. addressed it? Not addressed it? Have they
Is there more that
needs to be focused on? DR. HOPENFELD: If you know when that
critical thickness would occur, I have no problem with that. The problem is you don't know. There are two You
and three uncertainties. have another uncertainty.
You have the frequency.
We haven't even gotten to
it and that has to do -- You have to realize what they are doing. They are sampling. This is an inspection by sampling. taking a fairly small number of components. a lot of other components which are not being inspected. Now this whole idea of using a line is -I'll give you an example. I'll try to go very fast. You're
There are
I went to Sequoyah after that accident or about the time of the accident. They have a distribution ring That's how
in the steam generator which has J-tubes. you get the water into the steam generator.
I saw one tube, one J-tube, which is something like two inches in diameter gone. next to it is in perfect shape. you? The one
What does it tell
The small difference in the metal or the weld
itself could make a big difference.
Page 1450 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
Thank you. JUDGE McDADE: I think we're going to answered. question? JUDGE KENNEDY: I think it's yet to be So when you hear about line that's an academic thing. components. the same. JUDGE KENNEDY: It seems to me that we're It's an ideal thing. You can take two
They look the same, but they don't smell
going to get into this when we get into the application of CHECWORKS at Indian Point and get into the predictive mode of that. DR. HOPENFELD: Did I answer your
I understand what your concern is and I'm
not sure we can -- I think we've got to go much deeper into how CHECWORKS is applied at Indian Point, what its accuracy is, what the scope of components is that they apply the code to to really get to the bottom of it. We're going to come back to your repair/replacement criteria I believe. DR. HOPENFELD: JUDGE KENNEDY: Thank you. Now that I understand it.
start to get into some additional areas here and the question is whether we take a break for a few minutes
Page 1451 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
morning. and then come back or break for the day. I think given the fact that it's past 5:30 p.m. at this point that we probably would be best served by coming back tomorrow at 9:00 a.m. going to have the same panel of witnesses. We're I would
anticipate that we will probably go with this panel of witnesses through the morning tomorrow. MR. ALEKSICK: JUDGE McDADE: Yes. And perhaps beyond the
So I think at this point we're just about Are there any housekeeping
ready to take a break.
matters that any of the parties have that they want to address now before we break for the evening? MS. SUTTON: This is Kathryn Sutton. Entergy?
Nothing on behalf of Entergy. We have no issues, Your
Honor, housekeeping matters. JUDGE McDADE: MR. SIPOS: Okay.
And, Your Honor, this is John The State likewise
Sipos for the State of New York. has no issues at this time. MR. MUSEGAAS:
Sorry, Your Honor.
We have
one housekeeping matter or perhaps it's a clarification question going back to this morning's discussion of the motion that's before you regarding Riverkeeper/Clearwater EC-3 and the motion for
Page 1452 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
settlement. And we understand we've made some efforts
to do outreach to Cortland and do consultation during the day today. I'm not sure if we've heard back yet.
But I'm just trying to understand how you would like us to consider while the Board is considering the motion. Are we to assume that we
should be prepared to go ahead and with that contention over the next couple of weeks? - this is a little bit speculative. Or do you -
Do you presume
that you might be able to rule on the motion in the short term so that we will know in the very short time frame whether that is necessary? JUDGE McDADE: It would be our goal to
rule on it in the short term. MR. MUSEGAAS: JUDGE McDADE: Okay. And fortunately it is one
of the contentions that was sort of at the backend of our schedule for this particular session. we will be able to rule on it very quickly. Hopefully But
before we do rule on it, what we did want to do is to give the town of Cortland an opportunity either directly or derivatively through the parties to express their view as to whether or not it's in the public interest and also to hear back from the NRC staff, Mr. Turk, as to the NRC's position with regard
Page 1453 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
to enforceability of it. At that point, there
wouldn't be anything else that we would need by way of input and hopefully we would be able to reach a consensus on it very quickly after that. Now at this point the Board has already had the joy of reading through all of the testimony of the parties and that contention and the exhibits. we hopefully will be able to decide what to do with that very quickly. MR. BESSETTE: Bessette from Entergy. Your Honor. This is Paul But
I have tried to make initial
contact with the Town of Cortland on behalf of all the parties. And as soon as we hear something we'll
inform the Board. JUDGE McDADE: Okay. There's one other
housekeeping matter that I want to make and address specifically to Clearwater. The Board represented
when you raised the issue a while back that one of your witnesses was going to need a Spanish interpreter. And based on my experience, long
experience, with the Department of Justice, that was never a problem. We have been reaching out to court certified Spanish interpreters and have been having a difficult time particularly given the fact that we are
Page 1454 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
not able to state with precision exactly when we will be hearing that contention and the hearing from that particular witness. So the one question that I had for you to consider is whether or not Riverkeeper would be able to provide an interpreter for your witness and then to any of the other parties whether or not they would have any objection to the interpreter not being court certified English/Spanish interpreter. I think the questioning is not going to be particularly either lengthy or complex and that we would be able to -- If we were going to have one witness on the stand for many hours, if we were going to have the kind of testimony that we'd receive from Dr. Hopenfeld or Dr. Horowitz, it would be necessary to have someone who is very skilled and experienced not just bilingual but as an interpreter. In this instance, we may not. But the
question is, first of all, and we don't need an answer right this minute, to Clearwater whether or not that would be something that you would be able to provide and to the other parties whether or not you have any objection. And again we are still attempting to
secure the services of an interpreter English/Spanish who has been certified by the Administrative Office of
Page 1455 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25
the Courts. MR. BESSETTE: Your Honor, Paul Bessette.
We would have no problems with an alternate interpreter, although we would propose it not be one of the lawyers assigned to this proceeding. JUDGE McDADE: No, I agree. I think that
would probably be best because it would be difficult for them to handle both roles simultaneously. Anyway, Judge Wardwell, do you have anything further for this evening? JUDGE WARDWELL: JUDGE McDADE: JUDGE KENNEDY: JUDGE McDADE: break for the evening? MS. GREENE: Your Honor, I think you asked No. Judge Kennedy? I do not. Thank you.
Anybody else before we
me a question but didn't wait for my response. JUDGE McDADE: I'm sorry. Ms. Greene.
Because I said that I didn't need a response tonight. I didn't know if you would have it immediately. MS. GREENE: Well, just in terms of And if you don't need
whether we would consider it.
a response tonight, my response to the question about consideration is yes, we will consider it. And I do
know of somebody that might be appropriate if

Greene. MS. GREENE: JUDGE McDADE: Thank you. Okay. 9:00 a.m. tomorrow. available. So I do need some time to check into that. JUDGE McDADE: MS. GREENE: Okay. Thank you.
And I think everyone would be
very pleased with the services that this gentleman could provide. JUDGE McDADE: Okay. Thank you, Ms.
And again anticipate we'll take a short break in the morning, an hour at lunch, a break in the afternoon and go until sometime between 5:00 p.m. and 6:00 p.m. tomorrow evening. Thank you. Off the record.
(Whereupon, at 5:37 p.m., the above entitled matter was recessed to resume the next day at 9:00 a.m.)

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Page 1252 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Neal R. Gross & Co., Inc.

--------------------------------x 07-858-03-LR-BD01 Monday, October 15, 2012

Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

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Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

We're starting pretty

For individuals who have not been

Also we anticipated having

Neal R. Gross & Co., Inc. 202-234-4433

of a more traditional courtroom facility.

Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

We have issued an order to that

revised document, it wasn't.

Neal R. Gross & Co., Inc. 202-234-4433

It starts "No, I don't understand

necessary to make an additional finding (sic).

Neal R. Gross & Co., Inc. 202-234-4433

looking, let me go to the others. New York 17? MS. DEAN:

Am I correct, Mr. Shepp (sic), that it's NRC

Neal R. Gross & Co., Inc. 202-234-4433

exceptions to what is listed on there.

will be admitted through New York, not through

Neal R. Gross & Co., Inc. 202-234-4433

We'll restamp it and accept it

It is listed on the exhibit There are actually several

parts to it, Part A through O, and we will admit

Neal R. Gross & Co., Inc. 202-234-4433

when you open the files, different files.

Do you envision that becoming part of the

envision this as a license condition.

settlement of the concrete containment issue with New

Neal R. Gross & Co., Inc. 202-234-4433

reporter is sort of facing in one direction.

of know everybody, this has all gone on so long.

Neal R. Gross & Co., Inc. 202-234-4433

I'm not sure it's part of the current

licensing basis, no. JUDGE McDADE: From the NRC staff's

Neal R. Gross & Co., Inc. 202-234-4433

Clearwater, what is your And let

Once we write We have been

Neal R. Gross & Co., Inc. 202-234-4433

Environmental Director for Clearwater.

Town of Cortlandt, and have they offered a view on this?

Neal R. Gross & Co., Inc. 202-234-4433

not consulted with the Town of Cortlandt.

This is Deborah Brancato

With specific respect to the

settlement, we have not consulted with the Town of

Neal R. Gross & Co., Inc. 202-234-4433

rule on this proposed settlement right here.

Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

Neal R. Gross & Co., Inc. 202-234-4433

go through until again approximately six o'clock.

Thank you very much, Your The first